L-2024-158, Supplemental Information to License Amendment Request to Adopt Common Emergency Plan with Site-Specific Annexes
| ML24269A203 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Point Beach, Seabrook, Turkey Point  |
| Issue date: | 09/25/2024 |
| From: | Mack K Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-2024-158 | |
| Download: ML24269A203 (1) | |
Text
l=PL..
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Re:
Florida Power & Light Company St. Lucie Units 1 and 2, Docket Nos. 50-335, 50-389 Turkey Point Units 3 and 4, Docket Nos. 50-250, 50-251 NextEra Energy Seabrook, LLC Seabrook Station, Docket No. 50-443 NextEra Energy Point Beach, LLC Point Beach Units 1 and 2, Docket Nos. 50-266, 50-301 September 25, 2024 L-2024-158 Supplemental Information to License Amendment Request to Adopt Common Emergency Plan with Site-Specific Annexes
References:
- 1. Florida Power & Light Company letter L-2022-160, "License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2," October 4, 2022 (M L22278A031)
- 2. NRC Letter, "Point Beach Nuclear Plant, Units 1 and 2; Seabrook Station, Unit 1; St.
Lucie Plant, Unit Nos. 1 and 2; and Turkey Point Nuclear Generating Unit Nos. 3 and 4 -
Supplemental Information Needed for Acceptance of Requested Licensing Action RE:
Amendment Request for Common Emergency Plan (EPID L-2022-LLA-0146),"
November 22, 2022 (ML22311A558)
- 3. Florida Power & Light Company letter L-2022-185, "Supplement to License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2,"
December 9, 2022 (ML22343A254)
- 4. NRC Letter, "Point Beach Nuclear Plant, Units 1 and 2; Seabrook Station, Unit 1; St.
Lucie Plant, Unit Nos. 1 and 2; and Turkey Point Nuclear Generating Unit Nos. 3 and 4 -
Acceptance of Requested Licensing Action RE: Amendment Request for Common Emergency Plan (EPID L-2022-LLA-0146)" (ML22339A001)
- 5. NRC Message from Justin Poole, Project Manager for NextEra Fleet, "Request for Additional Information RE: Fleet Emergency Plan Amendment Request," June 22, 2023 (ML23173A152)
- 6. Florida Power & Light Company letter L-2023-098, "Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2," August 7, 2023 (ML23219A102)
Florida Power & Light Company 15430 Endeavor Drive, Jupiter, FL 33478
L-2024-158 Page 2 of 3
- 7. Florida Power & Light Company letter L-2023-155, "Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2," November 28, 2023 (ML23332A005)
- 8. NRC Updated Slides for the Public Meeting on March 19, 2024, Regarding the NextEra Emergency Plan License Amendment (ML24078A023)
- 9. Florida Power & Light Company letter L-2024-068, "Supplemental Information to License Amendment Request to Adopt Common Emergency Plan with Site-Specific Annexes,"
May 6, 2024 (ML24127A063)
- 10. NRC Letter, "Point Beach Nuclear Plant, Units 1 and 2; Seabrook Station; St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 1 and 2 - Interim Audit Summary Report in Support of Review of License Amendment Requests Regarding Fleet Emergency Plan Amendment (EPID L-2022-LLA-0146)," (ML24193A243)
- 11. Florida Power & Light Company letter L-2024-125, "Notice of Intent to Provide Supplemental Information to License Amendment Request to Adopt Common Emergency Plan with Site-Specific Annexes," July 24, 2024 (ML24206A140)
- 12. Florida Power & Light Company letter L-2024-136, "Supplement to License Amendment Request to Adopt Common Emergency Plan with Site-Specific Annexes," September 16, 2024 (ML24260A246)
In Reference 1, Florida Power & Light Company (FPL), acting on behalf of itself and as agent for NextEra Energy Seabrook, LLC and NextEra Energy Point Beach, LLC submitted a license amendment request (LAR) to change the emergency plan for each site. Specifically, the proposed amendment would adopt a new fleet common emergency plan with site-specific annexes.
In Reference 2, the NRC staff requested supplemental information to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment request.
Reference 3 provided supplemental information that enabled the NRC staff in Reference 4 to conclude the application provided technical information in sufficient detail to perform a detailed technical review and make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment.
Reference 5 transmitted a request for additional information that the NRC staff has determined is necessary to complete its review.
Reference 6 provided information responsive to Reference 5 and requested an audit process to resolve some items more efficiently.
Reference 7 provided revised responses to requests for additional information, a revised Common Emergency Plan, and revised site-specific annexes due to information gained as a result of the audit process conducted on September 27, 2023, and September 28, 2023.
Reference 9 provided supplemental information regarding those requests for additional information identified in Reference 8 where responses failed to provide sufficient justification to allow the NRC to continue its review of the LAR.
L-2024-158 Page 3 of 3 Reference 1 O provided the observations of the NRC staff from the June 11, 2024, demonstration drill and provided an updated status of the requests for additional information (RAls).
Reference 11 provided notice of its intent to supplement the LAR with additional information including a revised Common Emergency Plan and revised site-specific annexes to bring to closure the outstanding RAls identified in Enclosure 2 to Reference 10.
Reference 12 provided supplemental information to bring to closure the outstanding RAls identified in Enclosure 2 to Reference 10.
The enclosure to this letter provides a revised Common Emergency Plan that clarifies the Note to Position F, Shift Dose Assessor, in Section B, Emergency Response Organization, to permit this position to be filled as a collateral duty to any on-shift position other than the Radiation Protection Technician (RPT).
This letter does not alter the conclusions in Reference 1 that the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change.
This letter contains no new or revised regulatory commitments.
If you should have any questions regarding this letter, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at (561) 904-5164.
Sincerely, Kenneth A. Mack Director, Regulatory Affairs cc: NRC Project Manager - Point Beach NRC Project Manager - St. Lucie NRC Project Manager - Turkey Point NRC Project Manager - Seabrook Regional Administrator - NRC Region 1 Regional Administrator - NRC Region 2 Regional Administrator - NRC Region 3 NRC Resident Inspector - Point Beach NRC Resident Inspector - St. Lucie NRC Resident Inspector - Turkey Point NRC Resident Inspector - Seabrook Wisconsin Emergency Management Chief, Bureau of Radiation Control, Florida Department of Health Director Homeland Security and Emergency Management (New Hampshire)
ENCLOSURE 1 EP-AA-100, NextEra Common Emergency Plan
NEXTera*
ENERGY&.
Title:
NUCLEAR FLEET PROGRAM DESCRIPTION NON-SAFETY RELATED INFORMATION USE NextEra Common Emergency Plan Responsible Department: REGULATORY AFFAIRS Special Considerations:
Revision Approved By 0
Approval Date TYPE DATE DOCT DOCN 1----~~--~~~~~~~~~--~~~~--iSYS STATUS REV
- OF PAGES Program No.
EP-AA-100 Revision No.
0 PROGRAM EP-AA-100 DRAFT 0
99
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EP-AA-100 PROGRAM TITLE:
NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Table of Contents PAGE:
2 of 100 INTRODUCTION........................................................................................................................ 3 A:
Assignment of Responsibility.............................................................................................. 5 B:
Emergency Response Organization................................................................................... 8 C:
Emergency Response Support and Resources................................................................ 23 D:
Emergency Classification System.................................................................................... 26 E:
Notification Methods and Procedures................................................................................ 30 F:
Emergency Communications............................................................................................ 33 G:
Public Education and Information..................................................................................... 35 H:
Emergency Facilities and Equipment............................................................................... 37 I:
Accident Assessment....................................................................................................... 45 J:
Protective Response........................................................................................................ 50 K:
Radiological Exposure Control......................................................................................... 57 L:
Medical and Public Health Support.................................................................................... 61 M:
Recovery, Reentry, and Post-Accident Operations........................................................... 63 N:
Exercises and Drills.......................................................................................................... 66 0:
Radiological Emergency Response Training..................................................................... 75 P:
Responsibility for the Planning Effort................................................................................ 77 Appendix 1, Definitions............................................................................................................. 80 Appendix 2, Abbreviations and Acronyms................................................................................. 83 Appendix 3, 1 O CFR 50 Appendix E. IV Cross Reference.......................................................... 85
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EP-AA-100 INTRODUCTION PROGRAM TITLE:
NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET PAGE:
3 of 100 The NextEra Common Emergency Plan provides the means to protect the health and safety of the general public, persons temporarily visiting or assigned to nuclear power plants operated by NextEra Energy Point Beach, LLC, NextEra Energy Seabrook, LLC, and Florida Power & Light Company (collectively "NextEra"), and plant employees. NextEra operates the Point Beach, Seabrook Station, Saint Lucie, and Turkey Point nuclear plants.
The NextEra emergency preparedness program is based upon the requirements of 10 CFR 50.47 and 1 O CFR 50 Appendix E, and the guidelines of the U.S. Nuclear Regulatory Commission (NRC) as established in NUREG-0654/FEMA-REP-1, Revision 2.
The NextEra emergency plan and site annexes are formatted using the outline numbering style of NUREG-0654 R2 to explicitly align with the 10 CFR 50.47(b) planning standards, the requirements of 10 CFR 50 Appendix E, and the elements of NUREG-0654 R2. That formatting provides a direct cross-reference to the elements of NUREG-0654 R2.
The formal NextEra emergency plan for each NextEra site consists of the following program and bases documents:
NextEra Common Emergency Plan - The NextEra common emergency plan identifies and describes the methods for responding to emergencies and maintaining emergency preparedness. Planning efforts common to all NextEra power reactor sites are encompassed within the NextEra common emergency plan.
Site Emergency Plan Annex - The site emergency plan annexes contain information and guidance that is unique to the site. The site annexes are subject to the same review and audit requirements as the common emergency plan.
Site Emergency Action Level (EAL) Technical Basis Document (TBD) - The EAL TBD establishes the classification scheme used to declare emergencies. The EAL TBD documents references and inputs used to determine values or events that would result in declaration of an emergency. The EAL TBD fulfills requirements of 1 O CFR 50 Appendix E.IV.B.1.
Site On-Shift Staffing Analysis - The on-shift staffing analysis documents that the minimum shift crew can perform the actions required by Emergency Operating Procedures (EOP) and the emergency plan, without task overlap or overburden, prior to Emergency Response Organization (ERO) augmentation. The on-shift staffing analysis fulfills requirements of 10 CFR 50 Appendix E.IV.A.9.
Site Evacuation Time Estimate (ETE) Study - The ETE study defines the plume exposure
(-10 mile) Emergency Planning Zone (EPZ). It documents the population within defined areas of the EPZ and establishes evacuation routes and ETEs for different scenarios for those populations. The ETE study fulfills requirements of 10 CFR 50 Appendix E. IV paragraphs 2-7.
Site Protective Action Recommendation (PAR) Technical Basis Manual (TBM) - The PAR TBM document the bases used to develop site-specific protective action recommendation procedures. The PAR TBM fulfills requirements of 10 CFR 50 Appendix E.IV paragraph 3.
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4 of 100 Site Alert and Notification System (ANS) Design Report - The ANS design report is the FEMA-approved document that contains the specific design, testing, and maintenance of the system. The ANS design report fulfills requirements of 10 CFR 50 Appendix E.IV.D.3.
Except for the NextEra Common Emergency Plan, the above documents are maintained and revised separately but as part of the site emergency plan.
Any changes made that may affect or alter the emergency plan program or bases documents described above will be evaluated and made using the change process in 10 CFR 50.54(q) and Regulatory Guide 1.219.
There are supporting and complementing emergency plans, including those of federal agencies; the states of Florida, New Hampshire, Wisconsin, and Massachusetts; and local government agencies that support the NextEra sites. These plans contain coordinated emergency response and preparedness instructions for declared emergencies. Each plan has been prepared and is maintained by its respective organization and is coordinated as appropriate with the other plans.
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Assignment of Responsibility PAGE:
5 of 100 Primary responsibilities for emergency response by the nuclear facility licensee, and by state and local organizations within the EPZs have been assigned, the emergency responsibilities of the various supporting organization have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
Regulatory
References:
10 CFR 50.47(b)(1); 44 CFR 350.5(a)(1);
10 CFR Part 50 Appendix E.IV.A I
A.1 I
The federal, state, local, tribal, licensee, and other private sector organizations that I comprise the overall response for the EPZs are identified.
Element A.1.a.1 below provides a summary of NextEra response organization responsibilities as they relate to the overall concept of operations for event response. A detailed description of the NextEra Emergency Response Organization (ERO) is contained in Section B.
The elements below identify the federal, Offsite Response Organizations (OROs), and other organizations that encompass the overall response organization for an event at a NextEra site.
I A.1.a !
The organizations having an operational role specify their concept of operations and relationship to the total effort.
- 1. NextEra Emergencies are initially declared and responded to by the on-shift staff under the direction of the Shift Manager. Augmentation of the shift ERO is required at the Alert emergency classification level or higher, and discretionary at the Unusual Event emergency classification level. The ERO has the capability to expand or contract to meet the needs of the emergency.
When the emergency response facilities are staffed the augmenting ERO relieves the on-shift personnel of emergency response functions not directly associated with unit operations.
NextEra overall responsibilities for event response are as follows:
Recognize, classify and declare an emergency.
Notify appropriate NextEra personnel, federal, and OROs.
Request additional support from federal, ORO, and private organizations.
Establish and maintain effective communications with onsite and offsite entities.
Continuously assess the consequences of the accident, and periodically communicate response status and assessment information to the appropriate groups and authorities.
Take protective actions onsite and recommend protective actions to offsite authorities.
Monitor and control radiation exposure of personnel responding during an emergency.
In conjunction with OROs, provide emergency information to the media and public through periodic media briefings and media statements.
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- 2. Federal Organizations NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 6 of 100 Control, responsibility and interface of federal organizations is governed by the National Response Framework (NRF) and the Nuclear/Radiological Incident Annex to the NRF when they are called to respond to an event at a nuclear power plant. The NRC acts as the lead federal agency with regard to technical matters during a nuclear incident, including providing radiological assistance.
- 3. Offsite Response Organizations The NextEra ERO coordinates response actions with OROs. Interface between the site and the OROs is governed by their respective emergency plans, which are developed and maintained in coordination with the NextEra emergency plan. OROs are described in the site annexes.
A.1.b Each organization's emergency plan illustrates these interrelationships diagram.
Refer to Section 8.4 for the interrelationships between the NextEra ERO, federal response organizations, and the OROs.
I Each organization identifies the individual, by title/position, who will be in charge o~J A._1._c~!_h~~~~~~-~~~~~~~~~~~~~--~~~--
e emergency response.
The title of the individual who will be in charge of the emergency response is provided in Elements 8.2 and 8.2.a.
A.2 References to the applicable acts, codes, or statutes that provide the legal basis for emergency response-related authorities, including those that delegate responsibility and authority to state, local, and tribal governments are included.
Each emergency plan indicates who may declare a "State of Emergency" and the powers that ensue.
'--------'-'------------------------------------~
This element is not applicable to the licensee emergency plan.
A.3 Each organization specifies the key individual(s), by title/position, responsible for the following functions, applicable to their organizations: command and control, alerting and notification, communications, public information, accident assessment, public health and sanitation, social services, fire and rescue, traffic control, emergency medical services, law enforcement, transportation, protective response (including authority to request federal assistance and to initiate other protective actions), and radiological exposure control.
Refer to Element 8.1.a and Table 8-1 for a list of key individuals responsible for command and control, alerting and notification, communications, public information, accident assessment, protective response (including authority to request federal assistance and to initiate other protective actions), and radiological exposure control.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 7 of 100 EP-AA-100 A.4 Written agreements with the support organizations having an emergency response role within the EPZs are included. The agreements describe the concept of operations, emergency measures to be provided, mutually acceptable criteria for their implementation, and arrangements for exchange of information.
Assistance will be provided, as necessary, by federal response organizations and OROs that are mandated by charter, regulation or law to protect public health and safety. Federal response organizations and OROs cooperate with NextEra and have developed radiological emergency plans and procedures in an integrated manner. Additional support agreements (Letter of Agreement - LONMemorandum of Understanding - MOUs) are not required with these agencies.
Support agreements are necessary when an organization or individual is expected to provide assistance to NextEra and is not required otherwise to do so. To that extent, LOAs have been developed between NextEra and several entities to provide emergency response support and services consistent with this plan.
Specifically, the agreement minimum content includes the following:
A description of the concept of operations, meaning the mutually accepted criteria for implementation.
When the support will be provided (as a minimum, the agreement states that the support provider will offer its services during an emergency at the affected site(s), including during a Hostile Action).
Identification of the support to be provided.
Arrangements for exchange of information during event support.
A contract/purchase order with a private contractor is considered acceptable in lieu of a LOA for the specified duration of the contract. The current signature copies of applicable LOAs and contracts are listed in the site annexes and are maintained locally on file.
A.5 Each principal response organization is capable of continuous operations for a protracted period. The principal response organization specifies the individual, by title/position, who is responsible for ensuring continuity of resources (technical, administrative, and material).
NextEra maintains a depth to the ERO that is capable of providing continuous (24 hour/day) operation throughout a declared emergency by providing relief of the on-shift and augmenting ERO positions by qualified individuals. The shift rotation and ERO staffing for protracted ERO operations is designated by the Emergency Director.
The Emergency Director is the individual responsible for assuring continuity of resources (technical, administrative, and material) within the ERO.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 8:
Emergency Response Organization PAGE:
8 of 100 On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the interfaces among various onsite response activities and offsite support and response activities are specified.
Regulatory
References:
10 CFR 50.47(b)(2); 44 CFR 350.5(a)(2);
10 CFR Part 50, Appendix E. IV.A l 8.1 The emergency plan specifies how the requirements of 10 CFR 50.47(b)(2) and the applicable sections of Appendix E to 10 CFR Part 50 are met.
- 1. 10 CFR 50.47(b)(2) Compliance In December of 2019, the NRC issued NUREG-0654 R2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. The scope of NUREG-0654 R2 states "NPP applicants and licensees may voluntarily use the guidance in this document to demonstrate compliance with the underlying NRC regulations." The NextEra emergency plan and site annexes are based on the criteria provided in NUREG-0654 R2 as approved by the NRC.
- 2. 10 CFR 50 Appendix E Compliance Refer to the 1 O CFR 50 Appendix E. IV.A cross-reference in Appendix 3 of this emergency plan.
The site-specific emergency response organization (ERO) is developed. Note that while other site programs, such as operations, fire response, rescue and first aid, and security, may be controlled via other licensing documents, it is only when these personnel are assigned EP functions that they become part of this regulatory 8.1.a standard. Consideration is given to ensure that EP functions are not assigned to individuals who may have difficulties performing their EP function(s) simultaneously with their other assigned (non-EP) duties. Appendix E to 10 CFR Part 50 requires licensees to perform an on-shift staffing analysis to ensure on-shift staff can support the EP functions assigned, as well as other assigned duties.
A description of the normal site operating organization is contained in each sites' UFSAR.
The requirements for on-shift operations staff, security force staff, and fire brigade/first aid staff are controlled by Technical Specifications and other licensing and administrative documents.
Positions from these departments are described in the emergency plan only when assigned an emergency preparedness function that is performed during an emergency.
Site specific on-shift staffing analysis reports are developed in accordance with 10 CFR 50 Appendix E. IV.A.9 and NEI 10-05. The site specific on-shift staffing analysis reports are maintained as part of the site emergency plans and are referenced in the site annexes.
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NEXTERA COMMON EMERGENCY PLAN 9 of 100 EP-AA-100 NUCLEAR FLEET The on-shift ERO and minimum augmenting ERO is composed of the following positions, which are assigned responsibilities within the following functions (organized by facility):
- 1. Control Room (CR)
A. Shift Manager Organizational Interface and Coordination Command and Control Facility/Group Management and Supervision Contact and Use of External Support Services Use of Medical, Fire and Law Enforcement Support NRC Notification and Communications Event Classification ERO Notification State and Local Event Notification ERF Communications Accident Detection and Assessment Effluent Release and Dose Assessment OSC Team Priorities, Dispatch and Control Site Assembly and Accountability Site Evacuation ERO Radiological Protection Offsite Protective Action Recommendations Emergency Exposure First Aid Event Termination B. Radiation Protection Technician Radiological Monitoring Activities ERO Radiological Protection Emergency Exposure Contamination Control Measures On-site radiological monitoring C. Security Shift Supervisor Organizational Interface and Coordination Use of Medical, Fire and Law Enforcement Support NRC Notification and Communications Site Assembly and Accountability
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NEXTERA COMMON EMERGENCY PLAN 10 of 100 EP-AA-100 NUCLEAR FLEET Site Evacuation D. Shift Technical Advisor (STA)
Note - Assigned as a collateral duty in accordance with Technical Specification.
- Accident Detection and Assessment Core Damage Assessment E. Shift Communicator Note - Assigned as a collateral duty to an on-shift position other than the RPT.
NRC Notification and Communications State and Local Event Notification and Communications OSC Team Priorities, Dispatch and Control F. Shift Dose Assessor Note - Assigned as a collateral duty to any on-shift position other than the RPT.
Effluent Release and Dose Assessment
A. Site Emergency Director Organizational Interface and Coordination Federal Assistance Continuous Emergency Response Operations Command and Control Facility/Group Management and Supervision Contact and Use of External Support Services Integration of Offsite Agency Personnel in the ERF NRC Notification and Communications Event Classification State and Local Event Notification ERF Communications Facility Activation Backup and Alternative Facilities
- Accident Detection and Assessment OSC Team Priorities, Dispatch and Control Site Assembly and Accountability Site Evacuation ERO Radiological Protection Offsite Protective Action Recommendations
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NEXTERA COMMON EMERGENCY PLAN 11 of 100 EP-AA-100 NUCLEAR FLEET Emergency Exposure Event Termination Recovery B. TSC Classification Advisor Facility/Group Management and Supervision Event Classification State and Local Event Notification ERF Communications Facility Activation Facility Operation
- Accident Detection and Assessment ERO Radiological Protection Offsite Protective Action Recommendations C. Reactor Engineer - Remote 12osition Facility Operation
- Accident Detection and Assessment Core Damage Assessment D. Electrical/l&C Engineer - Remote 12osition Facility Operation
- Accident Detection and Assessment E. Mechanical Engineer - Remote 12osition Facility Operation Accident Detection and Assessment F. ORO Communicator State and Local Event Notification ERF Communications G. ENS Communicator NRC Notification and Communications ERF Communications H. TSC Radiation Protection Coordinator Facility/Group Management and Supervision Contact and Use of External Support Services Event Classification
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NEXTERA COMMON EMERGENCY PLAN 12 of 100 EP-AA-100 NUCLEAR FLEET State and Local Event Notification ERF Communications Facility Activation Facility Operation Backup and Alternative Facilities
- Accident Detection and Assessment Effluent Release and Dose Assessment OSC Team Priorities, Dispatch and Control Site Evacuation ERO Radiological Protection Offsite Protective Action Recommendations Emergency Exposure Contamination Control Measures Decontamination Recovery
- 3. Operations Support Center (OSC)
A. Lead OSC Supervisor Facility/Group Management and Supervision ERF Communications Facility Activation Facility Operation Backup and Alternative Facilities OSC Team Priorities, Dispatch and Control Site Evacuation First Aid Recovery B. Fix-It-Now (FIN) Supervisor Facility/Group Management and Supervision Contact and Use of External Support Services Facility Activation Backup and Alternative Facilities
- Accident Detection and Assessment OSC Team Priorities, Dispatch and Control Site Assembly and Accountability
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NEXTERA COMMON EMERGENCY PLAN 13 of 100 EP-AA-100 NUCLEAR FLEET C. Radiation Protection Su[2ervisor ([2osition not reguired if TSC and OSC are co-located)
Facility/Group Management and Supervision Contact and Use of External Support Services Facility Activation Backup and Alternative Facilities Accident Detection and Assessment OSC Team Priorities, Dispatch and Control Site Assembly and Accountability Site Evacuation ERO Radiological Protection Radiation Protection Briefings D. Maintenance (Mechanical, Electrical and l&C)
OSC Team Priorities, Dispatch and Control E. Radiation Protection Technician Radiological Monitoring Activities OSC Team Priorities, Dispatch and Control ERO Radiological Protection Emergency Exposure Contamination Control Measures Decontamination Radiation Protection Briefings
- 4. Emergency 0[2erations Facility (EOF)
A EOF Manager Organizational Interface and Coordination Continuous Emergency Response Operations Facility/Group Management and Supervision Contact and Use of External Support Services Integration of Offsite Agency Personnel in the ERF Dispatch and Control of Offsite EOC Liaisons ERF Communications Facility Activation Facility Operation Site Evacuation Recovery
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NEXTERA COMMON EMERGENCY PLAN 14 of 100 EP-AA-100 NUCLEAR FLEET B. EOF Radiation Protection Coordinator Facility/Group Management and Supervision Integration and Use of the Radiological Laboratory Facility Operation
- Accident Detection and Assessment Effluent Release and Dose Assessment Radiological Monitoring Activities Offsite Protective Action Recommendations Radiation Protection Briefings Post-Accident Environmental Sampling C. Field Monitoring Team Technician Facility Activation Radiological Monitoring Activities D. Field Monitoring Team Driver Facility Activation Radiological Monitoring Activities E. EOF Dose Assessor NRC Notification and Communications ERF Communication Facility Activation Facility Operation Effluent Release and Dose Assessment Offsite Protective Action Recommendations F. Remote Dose Assessor - Remote 12osition su12ervised by EOF RP Coordinator Effluent Release and Dose Assessment Offsite Protective Action Recommendations
- 5. Joint Information System (JIS) / Joint Information Center (JIC)
NextEra Corporate Communications and key business units maintain a staff to operate a Joint Information System.
Refer to Sections H.5 and G for JIC/JIS details.
A. Site JIS Manager Facility/Group Management and Supervision Integration of Offsite Agency Personnel in the ERF
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EP-M-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET ERF Communications Media Briefings Facility Activation B. Site JIS Coordinator Media Briefings Accommodation of News Media Personnel Facility Activation Facility Operation C. Remote JIS Manager-Remote interface position to the corporate JIS Facility/Group Management and Supervision ERF Communications Media Statements Media Briefings Accommodation of News Media Personnel Media Monitoring Rumor Control PAGE:
15 of 100 The remote emergency response organization (ERO) positions are defined.
B.1.b Resources necessary to perform the functions and tasks assigned to the remote response positions, as well as a backup capability, are described.
The NextEra ERO includes remote response positions. Remote response positions are not required to physically manipulate plant equipment or take other physical actions at the site.
Remote response positions are provided the resources to collaborate with ERO personnel in their assigned emergency facility. These resources provide; the ability to communication audio/visually between emergency facility and the remote responder.
the ability to access procedures, information and data.
the ability to share screens/documents.
ERO members responding remotely to an emergency are capable of performing all functions and tasks assigned to their position, including support provided to other ERO members, as described in the emergency plan and implementing procedures.
Remote ERO Responders can perform the assigned functions anywhere power and internet connectivity is available.
These positions support the on-shift staff prior to activation of the TSC and EOF.
- 1. Remote Responders Assigned to the TSC (refer to Section B.1.a.2)
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16 of 100 The Reactor Engineer, Electrical/l&C Engineer, and Mechanical Engineer ERO minimum staff positions are remote responders assigned to the TSC.
- 2. Remote Responders Assigned to the EOF (refer to Section B.1.a.4)
The Remote Dose Assessor ERO minimum staff position is assigned to the EOF.
B.2 An individual is designated as the on-shift emergency coordinator (individual title may vary) who has the authority and responsibility to immediately and unilaterally initiate any emergency response measures, including approving protective action recommendations (PARs) to be disseminated to authorities responsible for implementing offsite emergency response measures.
The Emergency Director ERO position has overall command and control of a declared emergency at a NextEra site.
The Shift Manager is the individual who is on-shift at all times and assumes the role of Emergency Director upon emergency declaration. As Emergency Director, the Shift Manager has the authority and responsibility to immediately and unilaterally initiate any emergency actions, including providing protective action recommendations (PARs) to authorities responsible for implementing offsite emergency measures, The Shift Manager maintains overall command and control until relieved.
The remote positions (refer to Section B.1.b) report to the Shift Manager until their associated response facility is activated.
B.2.a The functional responsibilities assigned to the ERO are established and the responsibilities that may not be delegated to other members of the ERO are clearly specified in the emergency plan.
~
The Site Emergency Director will relieve the Shift Manager of overall Command and Control and the other key functions listed in Table B-1 at an Alert or higher emergency classification level.
Non-delegable responsibilities include the following:
Event declaration ORO and NRC Notification PARs for the general public Emergency Exposure (Dose limits and Kl)
Approving departures from license conditions per 10 CFR 50.54(x) transition from the Shift Manager to the Site Emergency Director upon transfer of command and control.
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IA table is developed depicting the site-specific on-shift staffing plan, as well as the I 8 *3
!ERO staffing augmentation plan.
The ERO is composed of on-shift personnel located at the site at all times, and augmenting personnel (responding to their assigned emergency facility or remotely).
Refer to Table 8-1 for the on-shift and augmenting ERO staffing plan.
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 18 of 100 Table B-1: On-Shift and Augmenting ERO Staffing Plan F
f O Sh"ft TSC/OSC/JIS/Remote i EOF/JIC(el/JIS/
unc 10n n-1 1
Remote
- --~
i Alert - 60 min.
Alert - 90 min.
t Alert - 90 min.
Command and Control
- Provide overall ERO command and control
- Authorize personnel dose extensions Facility Management
- Facility/Group Management and Su ervision Emergency Classifications
- Evaluate plant conditions and recommend ECLs Communications
- Communicate ECLs and PARs to OROs, including the NRC Supervision of RP Staff and Site Radiation Protection (1) Shift Manager Not applicable Shift Manager(a>
Shift Communicator<a>u>
- Evaluate and assess plant and offsite rad data in the development of onsite protective actions and offsite PARs Shift Manager(a)
- Recommend onsite protective actions and offsite PARs
- Direct all RP activities including FMTs
Projections
- Perform dose assessments and projections and provide input to PAR decision-maker (1) Shift Dose Assessor<a>
( 1) Site Emergency Director - TSC (gl Not applicable Site Emergency Director - TSC (g>
Not applicable (1) TSC Classification Advisor-TSC (1) ORO Not applicable (1) EOF Manager-EOF Not applicable Shift Communicator<aJ(hl Communicator-TSC N t
- 1.
bl (1) ENS o app 1ca e Communicator-TSC (1) RP Supervisor-TSC RP TSC/OSC<9l Coordinator-Tse (1) Remote Dose Assessor-Remote Not applicable (1) EOF RP Coordinator-EOF (1) EOF Dose Assessor-EOF
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 19 of 100 l
Alert - 60 min.
Alert - 90 min. I Alert - 90 min.
Radiation Note: If a site has committed to a different staffing requirement in their individual Protection annex for this function, this function is not applicable to that site. Note (k) is
- Provide RP coverage a licable for all sites.
for accessing unknown radiological environments
- Provide in-plant surve s Field Monitoring Teams
- Provide environmental Not applicable surveys (inside and outside the Protected Area Engineering
- Provide engineering coverage related to the specific discipline of ST A(a) the assigned engineer Supervision of Repair Team Activities
- Direct in-plant event response and repair activities Repair Team Activities
- Provide support for event mitigation and e ui ment re air Security
- Coordinate security related activities Media Information
- Manage and coordinate media information related to the event Information Technology (IT)
- Ensure IT equipment is o erable.
Not applicable Not applicable (1) Security Shift Supervisor Securit staff(c)
Not applicable (f)
(a) Assigned as a collateral function.
(3) RP Technician -
(3) RP Technician -
OSC<k>
OSC Not applicable RP Technician -
OSC<k>
(1) Reactor Engineer-Remote (1) Electrical/l&C Engineer-Remote (1) Mechanical En ineer-Remote (1) FIN Supervisor-OSC RP Supervisor -
TSC/OSC (I)
Not applicable Not applicable Not applicable (1) Lead OSC Supervisor-OSC RP Supervisor -
OSC(i>
(1) Mechanic-OSC (2) FMT Technician (2) FMT Driver Not applicable Not applicable
( 1) Electrician-OSC N t r bl (1) l&C Technician-0 app ica e osc Not applicable Not applicable (1)SiteJIS Manager-JIG JIS staff(d) -Remote Not applicable (1) Site JIS Coordinator-JIG (1) Remote JIS Mana er-Remote (f)
(f)
(f)
(b) FMTs operate as directed by the RP Supervisor (TSC/OSC) prior to EOF activation and as directed by the EOF RP Coordinator after EOF activation.
(c) Per the site-specific security plan.
(d) JIS per NextEra Communications Emergency Response Plan. Does not need to be performed in the JIC, but the JIS function needs to be established at this point.
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20 of 100 (e) ERO staffing of the JIC is concurrent with other ERFs (although facility activation is coordinated with the ORO public information personnel and has no time requirement).
(f) IT personnel monitor critical digital assets remotely and respond any time an issue is identified.
(g) Site Emergency Director (TSC), RP Supervisor, and FIN Supervisor (OSC) are interim 60-minute response positions. RP Supervisor could be TSC RP Coordinator or OSC RP Supervisor. Interim response positions assist the on-shift staff and remote responders (Engineers and Dose Assessor),
but do not accept functions/responsibilities until the positions' facility (TSC or OSC) is activated.
(h) Shift Dose Assessor assumes Shift Communications after being relieved by the Remote Dose Assessor.
(i)
If TSC and OSC are co-located, RP Supervisor (OSC) is not a minimum staffing position.
U)
Shift Manager performs the initial ORO, ERO and NRC notifications.
(k) Protected area FMT function is performed by RP technician responding under "Radiation Protection" function as a collateral duty.
(I)
Repair Activities include minor maintenance performed by on-shift operations staff (collateral duty) and development of troubleshooting/repair plans created by on-shift operations staff (collateral duty),
Engineers (remote) and FIN Supervisor (OSC). FIN Supervisor performs or assists Operators on urgent/high priority repair activities.
activity, local services support, and state, local, and tribal government
[
The interfaces between and among the licensee functional areas of emergency 8
4
_ ___,_o_r_g_c_a_n_iz_a_ti_o_n_s_a_re-id_e_n_t-ifi_e_d_. T_he-in_f_o_rm~at-io_n_in_c_1u_d_e_s_a_1_1 _li_c_e_n_s_e_e_e_m_e_rg_e_n_c_y __ ~
response facilities. A block diagram is preferred for ease of use, but not required.
Figure B.4 identifies the interfaces between NextEra ERFs, NRC, OROs, and local support organizations.
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21 of 100 Figure 8.4: Interrelationship of Emergency Response Organizations Security osc Industry Support Fuel Provider NSSS Provider Consultants INPO ANI Control Local EOC(s)
Media Public NRC Federal Support DOE FEMA Military All Other State Warning Pt Local Warning Pt Local Support Law Fire Medical Initial Interface
- Full Interface ---
Note: Communication from the TSC, Control Room and EOF to the Local EOC(s) is not applicable for Seabrook Station.
Dependent upon the emergency, a near or on-site Incident Command Post (ICP) may be established in coordination with local support organizations. The ICP will interface with the site security, and NextEra response facilities. Based on the event, NextEra provides the appropriate liaison (Security, Operations or Radiation Protection) to the ICP.
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22 of 100 The external organizations, including contractors, that may be requested to provide I 8*5 technical assistance to and augmentation of the ERO, as applicable, are specified.
- 1. Institute of Nuclear Power Operations (INPO)
INPO has an emergency response plan that enables it to provide the assistance in locating sources of emergency personnel, equipment, and operational analysis.
- 2. Other External (non-NextEra) Support Organizations Other external (non-NextEra) support organizations are not used to provide additional personnel for positions on the NextEra ERO or to perform an operational role. Other external (non-NextEra) support organizations that may be requested to provide technical assistance are described in the site annexes.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET C:
Emergency Response Support and Resources PAGE:
23 of 100 Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate state and local staff at the licensee's EOF have been made, and other organizations capable of augmenting the planned response have been identified.
Regulatory
References:
1 O CFR 50.47(b)(3); 44 CFR 350.5(a)(3);
10 CFR Part 50, Appendix E, Sec. IV.E 1
Emergency response support and resources provided to the licensee's EOF, as are described.
The EOF contains dedicated work areas and logistics resources for federal and, depending on the site, state response personnel. Federal and state personnel respond to the EOF in accordance with their emergency response plans and procedures.
C.2 Provisions made for additional emergency response support and resources are described and include the r~ - The individual(s), by title/position, authorized to ~equest emergency response-I
~=:_ support and resources from responding organizations.
__J The individual authorized to request assistance and resources from responding organizations is the Emergency Director.
Refer to Element 8.2.a for greater detail regarding command & control.
(1) Each organization from which emergency response support and/or resources may be requested, (2) the circumstance(s) in which the emergency response support and/or resources would be required, (3) the process for requesting needed C.2.b emergency response support and/or resources, (4) categories of capabilities and/or resources expected to be provided, (5) when the expected emergency response support and/or resources would be available once requested, and (6) how integration would occur.
~----~--
Refer to Elements A.1.a and A.4 for the description and details of the provisions made for additional assistance and resources.
Coordination of NPP site access and support for external organizations that have agreed to provide requested emergency response support and resources.
Site access is controlled at all times by the Security organization in accordance with the site security plan and procedures. The Security organization is responsible for coordination with external organizations when site access is needed for non-badged response personnel at an Alert or higher emergency classification level.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 24 of 100 EP-M-100 d
1~gr,eements between licensees and local agencies for law enforcement, medical
_J and ambulance services, fire, hospital support, and other support.
Local support organizations may be called to assist onsite for events requiring firefighting, medical, or law enforcement. Immediate assistance with firefighting, medical, and law enforcement at the sites is initiated using pre-established site-specific communications systems.
Agreements have been formally developed and documented through memorandums of understanding (MOUs), contracts, and/or letters of agreement (LOAs).
Refer to Element A.4 for details on agreements.
C.3 The capability of each principal organization to coordinate with other principal organizations leading the incident response is described.
~
Coordination of response actions and exchange of information among Emergency Directors from appropriate response organizations is provided via pre-designated communication links between NextEra, the NRC, and ORO EOCs.
C.4 Radiological laboratories, their general capabilities, and expected availability to provide radiological monitoring analysis services that can be used in an emergency are described. Plans to augment the identified radiological laboratories are described.
NextEra has radiological laboratories located at each site. The site laboratories are the central point for receipt and analysis of onsite samples and includes equipment for chemical and radiological analyses. The laboratories provide analyses of samples from plant systems.
Environmental monitoring sample analysis is also performed on-site or arrangements are made with off-site facilities.
Site specific details for the radiological laboratories are described in the site annexes.
C.5 Arrangements are described for integrating the licensee's response with the NRC Headquarters and regional incident response centers and, when dispatched, the NRC's site response team.
The Site Emergency Director in the TSC and the EOF Manager are the initial primary contact positions for the NRC site response team personnel sent to those facilities.
Consistent with 10 CFR 50 Appendix E, areas within the EOF and TSC are established for NRC site response teams that include:
Space for members of an NRC site team.
Space for conducting briefings with emergency response personnel.
Communication with other NextEra and offsite emergency response facilities.
Access to plant data and radiological information.
Access to office equipment and supplies.
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25 of 100
~
The activation process for the NRC's emergency response data system (EROS) I
- .a during an emergency is described.
When an emergency occurs, ERO personnel will ensure EROS operation as soon as possible but not later than one hour after an alert or higher emergency classification level is declared, in accordance with 10 CFR 50.72(a)(4).
C.5.b Provisions to continuously maintain open communications lines with the NRC, when requested, are described.
The ERO is capable of maintaining continuous communications with the NRC. When requested, open communication lines will be staffed by knowledgeable personnel to ensure efficient and effective information flow.
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Emergency Classification System PAGE:
26 of 100 A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and state and county response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Regulatory
References:
10 CFR 50.47(b)(4); 44 CFR 350.5(a)(4);
10 CFR Part 50 Appendix E.IV.B and C D.1 A standard emergency classification and action level scheme is established and maintained. The scheme provides detailed EALs for each of the four EC Ls in Section IV. C.1 of Appendix E to 10 CFR Part 50.
~-----~-----------------------------------------~
NextEra has established and maintains a standard emergency classification and emergency action level scheme. The EAL Technical Basis Document is referenced in the site annexes. The spectrum of postulated emergency events is categorized into the following four (4) emergency classification levels (ECLs):
Unusual Event Alert Site Area Emergency General Emergency The four ECLs are described as follows:
- 1. Unusual Event (UE)
Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.
- 2. Alert Events are in progress, or have occurred, which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life-threatening risk to site personnel or damage to site equipment because of hostile action.
Any releases are expected to be small fractions of the EPA Protective Action Guideline exposure levels.
- 3. Site Area Emergency (SAE)
Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or hostile action that results in intentional damage or malicious acts; 1) toward site personnel or equipment that could lead to the likely failure of or; 2) that prevent effective access to, equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA PAG exposure levels beyond the site boundary.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 27 of 100 EP-AA-100
- 4. General Emergency (GE)
Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or hostile actions that result in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.
D.1.a The EALs are developed using guidance provided or endorsed by the NRC that is applicable to the reactor design.
Emergency Action Levels (EALs) at NextEra sites have been developed in accordance with NRC endorsed guidance. This guidance and the NextEra site EAL schemes have been approved by the NRC.
If the entire EAL scheme is to be changed, then the new EAL scheme will be submitted to the NRC for approval prior to implementation.
The initial eme~gency classification and action level scheme is discussed a~d D.1.b agreed to by the licensee and OROs, and approved by the NRC. Thereafter, the scheme is reviewed with OROs on an annual basis.
The NRC approved NextEra EAL schemes have been agreed to by the OROs associated with the site.
The current EAL scheme is reviewed with the sites' respective OROs on an annual basis.
D.2 The capability to assess, classify, and declare the emergency condition within 15 minutes after the availability of indications to NPP operators that an EAL has been met or exceeded is described.
~--~----------------------------------~
NextEra has and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an EAL threshold has been met or exceeded. Details for classification timeliness criteria are documented in the site specific EAL Technical Bases Document.
D.3 A summary of emergency response measures to be taken for each ECL is provided. The detailed emergency response measures are described in implementing procedures.
NextEra maintains procedures that include immediate actions to be taken that are consistent with any declared ECL.
Emergency Operating Procedures provide instructions to Control Room personnel to assist in mitigating the consequences of a broad range of accidents and multiple equipment failures.
These procedures are based on guidelines developed by the owners' groups.
Emergency plan implementing procedures provide instructions to ERO personnel for response activities primarily associated with assessment, classification, notification and protective actions.
Other functions such as communications, termination and recovery are also addressed.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET A summary of response actions taken at each ECL is as follows:
- 1. Unusual Event (UE)
Initial and follow-up event notification to the OROs and NRC.
PAGE:
28 of 100 Notification of ERO personnel. This is an information only notification and does not require activation of emergency facilities or response organizations. Any Emergency Response Facility (ERF) may be activated at the discretion of the Emergency Director.
- 2. Alert Initial and follow-up event notification to the OROs and NRC.
Augmentation of the shift ERO (refer to Element A.1.a) by activating the Technical Support Center, Operations Support Center and Emergency Operations Facility.
The Joint Information System shall be established at this ECL, with Joint Information Center activation determined in coordination with the offsite agencies.
If a release is occurring, monitoring teams are available for dispatch and offsite dose projections are developed.
- 3. Site Area Emergency Initial and follow-up event notification to the OROs and NRC.
Augmentation of the shift ERO by activating the TSC, OSC and EOF if not previously performed.
The Joint Information System is in operation or Joint Information Center is staffed by NextEra ERO (JIC activation determined in coordination with the offsite agencies).
Implementation of onsite protective actions (refer to Section J).
If a release is occurring, monitoring teams are available for dispatch and offsite dose projections are developed.
Offsite precautionary actions may be recommended under certain conditions (as required by site specific OROs).
- 4. General Emergency Initial and follow-up event notification to the OROs and NRC.
Augmentation of the shift ERO by activating the TSC, OSC and EOF if not previously performed.
The Joint Information System is in operation or Joint Information Center is staffed by NextEra ERO (JIC activation determined in coordination with the offsite agencies).
Implementation of onsite protective actions (refer to Section J) if not previously performed.
If a release is occurring, monitoring teams are available for dispatch and offsite dose projections are developed.
Offsite protective action recommendations are communicated to the OROs and NRC.
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D.4 I
Emergency response measures based on the ECL declared by the licensee and'.J applicable offsite conditions are described. -------------------
This element is not applicable to the licensee emergency plan.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET E:
Notification Methods and Procedures PAGE:
30 of 100 Procedures have been established for notification, by the licensee, of state and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway EPZ have been established.
Regulatory
References:
10 CFR 50.47(b)(5); 44 CFR 350.5(a)(5);
10 CFR Part 50 Appendix E.IV.A, C, D and E The mutually agreeable process for direct and prompt notification of response organizations, aligned with the emergency classification and action level scheme, is described.
- 1. ERO Notification The Emergency Director will direct or perform notification of the ERO for all emergency classification levels. ERO personnel report to their assigned emergency response facilities as directed. In the event of a security threat, personnel may be instructed to respond to alternative facilities, or seek cover if on-site.
The means for alerting and notifying ERO members are described in Element F.1.c.
- 2. ORO Event Notification NextEra, in cooperation with the OROs, has established mutually agreeable content, methods and procedures for notification of OROs. When an ECL is initially declared, or upgraded, or changes are made to PARs, a notification to the OROs is made within 15 minutes.
Receipt location of notification messages is site specific. ORO notification locations are described in the site annexes.
- 3. NRC Event Notification NextEra will notify the NRC using ENS as soon as possible after notification of the OROs, and not later than 60 minutes after event declaration.
An accelerated call to the NRC will be made immediately after notification of local law enforcement agencies (LLEAs), or within about 15 minutes of the recognition of the security-based threat (discovery of an imminent threat or attack against the site), to ensure the NRC is notified of safeguards events. The information provided in the accelerated NRC notification will be limited to the following:
Site name.
ECL if determined prior to the accelerated notification.
Nature of the threat and the attack status.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 31 of 100 EP-AA-100 1 ~~rovisions for notification of response organizations are established, including the
- .a means for verification of messages.
The provisions for notification of response organizations are described above in Element E.1.
Notifications to OR Os include a means of verification or authentication within the automated system or by providing call back verification phone numbers.
The capability to notify responsible OROs within 15 minutes and the NRC within 601 minutes is described.
The capability to notify offsite response organizations and the NRC within the required time periods is described above in Element E.1.
E.2 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.
NextEra ANS used to alert and notify the general public within the plume exposure pathway EPZ is described as follows. Detailed information is maintained in the ANS design report for each site as listed in the site-specific annexes to the Common Emergency Plan.
General
Description:
The ANS is designed to provide an alerting signal to essentially 100% of the population on an area wide basis throughout the 10-mile EPZ. The OR Os provide an informational or instructional message to the population via various methods as approved by FEMA.
If the primary alerting signal fails, back-up systems are described in the site-specific annexes and ANS design report.
Activation of the ANS requires procedures and relationships between both NextEra and the OROs. Prompt alerting and notification of the public within the plume exposure pathway EPZ is the obligation of state and county government or other responsible authority.
ANS is tested on a periodic basis (Element F.3) as described in the station's ANS design report.
E.3 The licensee, in conjunction with state, local, and tribal organizations, establishes the contents of the initial and follow-up emergency notifications to be sent from the NPP.
~----.~---------------------------------------~
NextEra sites and OR Os have established the content of the initial notification message to be used during an emergency. Minimum content of the initial notification will include the following:
The site's name Time of event
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EP-AA-100 The ECL PROGRAM TITLE:
NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Protective Action Recommendation (PAR)
Whether a release is taking place PAGE:
32 of 100 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.
I E.4 I
Each organization establishes the contents of the initial and follow-up messages to /
the public including, as applicable, instructions for protective actions.
This element is not applicable to the licensee emergency plan.
~- I Provisions are made to provide timely supplemental information periodically
~~oughout the radiological incident to inform the public.
J ORO procedures provide for initial and follow-up messages to the public including instructions for protective actions, if required. NextEra will assist with establishment appropriate instructions and message content when requested by the ORO.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET F:
Emergency Communications PAGE:
33 of 100 Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.
Regulatory
References:
10 CFR 50.47(b)(6); 44 CFR 350.5(a)(6);
10 CFR Part 50, Appendix E.IV.E L F.1 I
Each principal response organization establishes redundant means of I
communication and addresses the following provisions:
~
1-:--:-= I Continuous capability for notification to, and activation of, the emergency response I
~
network, including a minimum of two independent communication links.
_J Each site maintains communications systems that are designed to facilitate normal and emergency communication. Refer to the UFSARs for descriptions of the primary site communications systems.
Provisions exist for continuous capability of communications with OROs and the NRC. Systems available for internal and external communications include:
- Telephone Systems Public Address System Radio Communications Cellular Telephones Satellite Telephones Local and Wide Area Networks Data Systems Cellular and satellite telephones provide communications capability should the main telephone systems lose power.
Site specific communications system beyond the above are described in the site annexes.
F.1.b Communication with applicable organizations to include a description of the methods that may be used when contacting each organization.
The methods for notification of response organizations are described in Elements E.1 and F.1.a.
F.1.c Systems for alerting or activating emergency personnel in each response organization.
Personnel within the Protected Area are notified of the emergency classification via the public address system. The sounding of alarms and announcement of the emergency classification and other pertinent data,relating to the emergency classification are made over the public address system.
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 34 of 100 Notification of personnel located onsite, but outside the Protected Area, is accomplished through PA system announcements, administrative controls, and by Security personnel.
NextEra sites use an automated ERO notification system to notify ERO members of a declared emergency. Multiple redundancies are incorporated such that activation of the system can be performed by computer or from any phone system, and operation can take place from more than one location.
F.2 Systems for coordinated communication methods for applicable fixed and mobile l medical support facilities are described.
~
Communications methods have been coordinated with medical facilities (ambulance and hospital). Site specific communications systems used for hospital and ambulance coordination are described in the site annexes.
F.3 The testing method and periodicity for each communication system used for the functions identified in evaluation criteria E.2, F.1, and F.2 are described.
Communication systems testing is accomplished in accordance with Table F-1.
Table F-1: Communication System Testing Requirements C
"f St Tf R
t ommumca 10n ;ys em es ma equiremen ORO Notification System Monthly (a)
NRC FTS (ENS) Network Monthly (b)
EROS Verify Transmission Quarterly ERO Notification System Per Elements N.4.h and N.4.i Field MonitorinQ Teams Communication Annually (a)
Telephone System Frequent Use (c)
Station Radio System Frequent Use (c)
Station PA System Frequent Use (c)
ANS per site specific ANS Design Report (a) Test credit may be given by successful use in a drill.
(b) NRC ENS in the Control Room is Frequent Use. TSC and EOF require monthly testing.
(c) Communication systems that are listed with a testing frequency of "Frequent Use" indicate that the associated equipment is normally used at a sufficient high regularity, such that separate additional testing is not needed.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET G:
Public Education and Information PAGE:
35 of 100 Emergency planning information is made available to the public on a periodic basis and includes information on how they will be notified and what actions they may be asked to take (e.g.,
listening to a local broadcast station, remaining indoors, etc.). Information will also be provided to the news media to include principal points of contact to receive information (including the physical location(s)) and information about the coordinated dissemination of information from all agencies engaged in the response.
Regulatory
References:
10 CFR 50.47(b)(7); 44 CFR 350.5(a)(7);
10 CFR Part 50, Appendix E.IV.D and F G.1 Provisions are made for a coordinated annual dissemination of information to the public within the plume exposure pathway EPZ, including transient populations and those with access and functional needs, regarding how they will be notified and what actions should be taken. The information is disseminated using multiple methods, to include non-English translations per current Federal guidance.
NextEra, in coordination with OROs, updates and distributes site related emergency planning information annually to residents living within the plume-exposure pathway emergency planning zone (EPZ). Information disseminated to the public is in the form of printed or electronic materials. Public information for the transient population is also provided.
Annual distribution of safety information which contains educational information on emergency preparedness, sheltering, ANS, radiation, and telephone numbers of agencies to contact for more information.
Information for residents with special needs and non-English translations is incorporated per current federal guidance.
1 G.2 disseminating information to the public and media. Plans include the physical I
lMethods, consistent with JIS-concepts, are established for coordinating and --
L_ location(s) for interacting with the media.
NextEra Corporate Communications and business unit personnel maintain programs and processes for the coordination and dissemination of information to the public and media using JIS concepts. Specifically, the process provides a structure and system for developing and delivering coordinated interagency messages; developing, recommending, and executing public information plans and strategies; advising decision makers concerning public affairs issues that could affect a response effort; and controlling rumors and inaccurate information that could undermine public confidence in the emergency response effort.
Physical locations for interacting with the media are maintained at the corporate headquarters and locally near each site. Specific site locations are described in the site annexes Element H.5.
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- 8 _3 j Organizations design~te new~ media points of contact an~ spokesperson(s) with access to necessary information.
A spokesperson is designated as the primary point of contact for NextEra and is responsible for the consistency of the information released by the utility. The spokesperson may select individuals to address the public on behalf of NextEra as their respective expertise is needed.
This position is not designated as an ERO position.
~ Arrangements are made for the timely exchange of information among the I
~::_ desiQnated spokespersons repres~nting the entities invol\fed in incid_ent resp~~-~~
Arrangements are made for the exchange of information among the designated spokespersons that use various means and technologies as agreed upon by the particular agencies. NextEra will provide information and updates to the ORO and federal public information officers (PIOs) to address the emergency, including plant conditions and associated response actions.
OROs address public response and actions in accordance with their respective plans.
G.4 Organizations establish coordinated arrangements for identifying and addressing public inquiries and inaccurate information.
NextEra personnel coordinate with ORO and federal PIOs via the JIS, or in a JIC when activated, to identify and address public inquiries and inaccurate information.
Public information personnel monitor media and public sources for misleading or erroneous information and to address inquiries. Rumors and misinformation are collected and provided to the appropriate individual or agency PIO. The PIOs assess and discuss the rumors and misinformation to coordinate responses.
ORO and federal PIOs address misinformation relating to offsite conditions, including protective action directives. NextEra spokespersons address misinformation regarding station/utility rumors. Rumors and incorrect information are addressed in media statements and at news conferences as appropriate.
G.5 Organizations conduct programs to acquaint news media with the emergency plans at least The news media will be provided materials to acquaint them with emergency planning effort at the NextEra specific site(s) annually.
Typical content includes site information, information concerning radiation, emergency planning, and points of contact for release of information to the media during an emergency.
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Emergency Facilities and Equipment PAGE:
37 of 100 Adequate emergency facilities and equipment to support the emergency response are provided and maintained.
Regulatory
References:
10 CFR 50.47(b)(8); 44 CFR 350.5(a)(8);
10 CFR Part 50, Appendix E.IV.E
~.1 I A TSC is established, using current Federal guidance, from which NPP conditions \
are evaluated and mitigative actions are developed.
The Technical Support Center (TSC) provides a dedicated location for management and technical support to operations personnel and to relieve the operations staff of emergency response actions and communications not related to plant system manipulations.
The TSC is activated when minimum staffing requirements are met, key systems and equipment are verified operational, and the ERO personnel are prepared to perform their functions. When activated, the TSC's primary functions include:
Provide ERO command & control Continued evaluation of event conditions Develop and issue offsite protective actions recommendations Provide ORO event notifications Provide ENS communications with the NRC Display and trend plant data Develop response priorities and mitigative actions Coordination of site emergency response actions Provide engineering support The TSC is a permanent facility in a well-engineered structure in accordance with standard building codes.
The TSC is sized to accommodate ERO responders and NRC representatives.
Personnel in the TSCs are protected from radiological hazards, including direct radiation and airborne contaminants under accident conditions, with radiological habitability standards similar to the Control Room. To ensure adequate radiological protection, radiation monitoring equipment is located in the TSCs, or periodic radiation surveys are conducted. These systems indicate radiation dose rates while in use. In addition, potassium iodide (Kl) is available to TSC personnel for use.
The facility has the capability to supply and display technical information for use by technical and designated management personnel in support of reactor operations and Control Room functions during emergency and recovery operations.
The TSCs normal power is from onsite power and backup power is supplied from emergency power source.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 38 of 100 EP-AA-100 Each TSC provides communications to the Control Room, OSC, EOF, Corporate Headquarters, NRC, and OROs.
The TSCs have access to drawings and other records, including general arrangement diagrams, piping and instrumentation diagrams (P&IDs), electrical schematics and plant procedures as either electronic or paper documents.
Site specific details of the TSC are described in the site annexes.
H.2 An OSC is established, using current Federal guidance, from which repair team activities are planned and teams are dispatched to implement actions.
The Operations Support Center (OSC) provides a dedicated location for coordinating and planning event response activities and for staging personnel and equipment. The OSC is sized to accommodate ERO responders.
The OSC is activated when minimum staffing requirements are met, key systems and equipment are verified operational, and the ERO personnel are prepared to perform their functions. When activated, the OSC's primary functions include:
Provide staging area for maintenance, operations, RP, and other support personnel.
Provide for briefing, dispatch, and coordination of emergency response teams.
Dosimetry (dose of legal record and self-reading capable of monitoring emergency radiation exposure), respiratory protection, radiation survey equipment, and RWPs are available to OSC personnel. In the event of a personnel contamination, decontamination will be performed in the area normally designated for this purpose.
Radiation and contamination levels in and around the OSC are assessed during emergencies.
Each OSC provides communications to the Control Room, TSC, and emergency response teams.
The OSCs have access to drawings and other records, including general arrangement diagrams, piping and instrumentation diagrams (P&IDs), electrical schematics and plant procedures as either electronic or paper documents.
Site specific details of the primary and backup OSC are described in the site annexes.
H.3 An EOF is established, using current Federal guidance, as the primary base of emergency operations for the licensee during a radiological incident. The EOF facilitates the management and coordination of the overall emergency response, including the sharing of information with Federal, state, local, and tribal government authorities.
The Emergency Operations Facility (EOF) provides a dedicated location for support of the site event response activities.
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 39 of 100 The EOF is activated when minimum staffing requirements are met, key systems and equipment are verified operational, and the ERO personnel are prepared to perform their functions. When activated, the EOF's primary functions include:
Coordinate emergency response activities with federal, state, and local authorities.
Coordinate support activities performed by personnel brought in to assist NextEra personnel.
Perform offsite dose assessment and field monitoring activities.
Development of dose based offsite protective actions recommendations.
Coordination of radiological and environmental assessment activities with offsite agencies.
Communicate with the NRC HPN line.
Coordinate corporate support.
Support site acquisition of external assistance (technical, craft, admin, etc.).
Support site acquisition of equipment, supply, and logistic resources.
The EOF is a permanent facility in a well-engineered structure in accordance with standard building codes.
The EOFs are sized to accommodate ERO responders and NRC, FEMA, and state representatives.
Because the EOF is located outside the plume exposure EPZ for all NextEra sites, specialized ventilation systems and radiological monitoring are not required. The EOF ventilation system is consistent in design with standard building codes.
The EOFs have the capability for the acquisition, display, and evaluation of unit, radiological and meteorological conditions necessary to perform accident assessment and determine protective measures.
Each EOF provides communications to the Control Room, TSC, field monitoring teams, NRC, and OROs.
The EOFs have access to drawings and other records, including general arrangement diagrams, piping and instrumentation diagrams (P&IDs), electrical schematics and plant procedures as either electronic or paper documents.
The EOFs provides working areas for Federal, State and local response personnel. Including conference areas with white boards, separate briefing/debriefing areas, telephones, ERO telephone contact lists, access to the internet, necessary office supplies and photocopier access, and access to plant radiological information.
Normal power to the EOFs is from a reliable offsite source.
Alternate temporary locations for the Emergency Operations Facility may be designated by the EOF Manager if a natural disaster or other (non-radiological) external event significantly affects the operational capability of the facility.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Site specific details of the EOF are described in the site annexes.
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40 of 100 lu 3 tFor an EOF that is located more than 25 miles away from the NPP site, provisions L_:.a are made for locating NRC and offsite responders closer to the NPP site.
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This element does not apply as the NextEra EOFs are not located more than 25 miles from the sites.
H.4 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.
An alternative facility provides a location for the staging of ERO personnel in the event of a Security or Hostile Action threat for each NextEra site. The alternative facility may also serve as an evacuation location for TSC and OSC personnel should those facilities become uninhabitable.
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.
Remote Engineering ERO is available to perform engineering assessments for both primary and alternate facilities.
Site specific details of the alternative facilities are described in the site annexes.
H.5 A JIC is established, and its location is identified, to coordinate communication from Federal, state, local, and tribal government authorities and licensee personnel with the p and media.
A near-site JIC (outside the 1 O mile EPZ) is established for each site. ERO staffing of the JIC is concurrent with other ERFs, although facility activation is coordinated with the joint offsite agencies and has no time requirement.
When activated the JIC functions as a physical location for interacting with the media and for coordination between NextEra, federal and ORO PIOs regarding communications information to the public and the media.
NextEra provides space and equipment at their corporate facility to provide coordination of public information response activities with site and corporate JIS/JIC personnel.
Site specific details of the JICs are described in the site annexes.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 41 of 100 EP-AA-100 H.6 Each organization establishes an emergency operations center (EOC) for use in directing and controlling response functions. For an EOC located within the plume exposure pathway EPZ, an alternate EOC or location outside the plume exposure pathway EPZ is identified to continue response functions in the event of an evacuation.
This element is not applicable to the licensee emergency plan.
H.7 Onsite monitoring systems used to initiate emergency response measures in accordance with the emergency classification scheme, as well as those to be used for conducting assessment, are identified. Monitoring systems consist of geophysical phenomena monitors, including meteorological, hydrologic, and seismic instrumentation; radiation monitors and sampling equipment; plant process monitors; and fire, toxic gas, and combustion products detectors.
NextEra sites have installed instrumentation for seismic monitoring, radiation monitoring, hydrologic monitoring, meteorological monitoring, and fire/ toxic gas/combustion products detectors in accordance with site Current Licensing Basis (CLB) documents.
- 1. Meteorological Monitoring Each NextEra site has a permanent on site meteorological monitoring station for the acquisition and recording of wind speed, wind direction, and stability class for use in offsite dose projection. Meteorological information is displayed in the Control Room, TSC, and EOF. Refer to the UFSARs for descriptions of the meteorological monitoring systems.
- 2. Hydrologic Monitoring Each NextEra site has hydrological monitors that support the acquisition of data used for event recognition and declaration. Refer to the UFSARs for descriptions of the hydrologic monitoring systems.
- 3. Seismic Monitoring Each NextEra site has a seismic monitoring system that supports the acquisition of data used for event recognition and declaration. Refer to the UFSARs for descriptions of the seismic monitoring system.
- 4. Process and Area Radiation Monitors Process Radiation Monitors (PRMs) measure radioactive noble gas, iodine, and particulate concentrations in gaseous effluent pathways and gross radioactivity in other gaseous and fluid streams, and are used for event recognition and declaration.
Area Radiation Monitors (ARMs) measure in-plant dose rates and allow in-plant dose rate determinations to be made remotely. This information may be used to aid in the determination of plant area accessibility for the protective action function.
Refer to the UFSARs for descriptions of the PRM and ARM systems.
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- 5. Portable Radiation Monitors PAGE:
42 of 100 Portable radiation monitoring equipment is available for uses such as area monitoring, sampling, personnel surveys, and continued accident assessment.
- 6. Sampling Systems Liquid and gaseous sampling systems, consisting of normal sampling systems and panels located throughout the unit(s) at each site, are used for event recognition and declaration.
Refer to the UFSARs for descriptions the sites sampling systems.
- 7. Fire Detection Systems The fire detection system, consisting primarily of fire/smoke detectors, control panel units, and annunciator panels, are used for event recognition and declaration. The fire detection equipment, alarms, and suppression equipment are described in detail in the UFSAR and in the sites' Fire Hazard Analysis Report.
H.8 Provisions are made to acquire data from offsite monitoring and analysis equipment, including data on geophysical phenomena (e.g., meteorological, hydrologic, and seismic monitors) and radiological data (e.g., from FMTs, environmental dosimeters, and laboratory analyses).
- 1. Meteorological Monitoring Weather forecasts and certain meteorological data is available from the National Weather Service.
- 2. Seismic Monitoring Seismic information from offsite sources can be obtained from the National Earthquake Information Center. The USGS is the contact agency to obtain information about a seismic event.
- 3. Hydrologic Monitoring Hydrologic information is available from the National Weather Service.
- 4. Radiological Environmental Monitoring Offsite programs and processes are developed within the Radiological Environmental Monitoring Program (REMP) as described in the Offsite Dose Calculation Manual (ODCM) at each site. The Radiological Environmental Monitoring Program includes:
Fixed continuous air samplers Routine sampling of water, vegetation, consumable products A dose monitoring network
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 43 of 100 EP-AA-100 The locations of the normal onsite and offsite environmental monitoring stations are described in the ODCM. Additional predetermined emergency offsite monitoring locations are contained in procedures.
Site specific details of the radiological environmental assessment program are provided in the site specific ODCMs.
- 5. Laboratory facilities, fixed or mobile Refer to Element C.4 for details on facilities for counting and analyzing samples.
H.9 Organizations directly responsible for offsite radiological monitoring provide radiological monitoring equipment. This includes equipment that is located or stored near the NPP site, as well as additional equipment that may be the site.
Each NextEra site maintains a supply of equipment, either at the site or the near-site EOF, for two Field Monitoring Teams assigned to perform onsite and offsite radiological monitoring and sampling functions.
Federal, industry and private entities can be contacted to coordinate additional materiel and personnel resources for offsite radiological monitoring.
H.10 Instrumentation is provided to obtain current meteorological information. Additional provisions are made to obtain representative meteorological information from other sources as needed by the NPP's radiological assessment models for site-specific characterization of plume dispersion and transport. Meteorological information is provided to the control room, TSC, EOF (or backup EOF), and NRC (via EROS).
Refer to Element H.7.1 for a description of the onsite meteorological monitoring capabilities.
Refer to Element H.8.1 for a description of the offsite meteorological monitoring capabilities.
Site meteorological information is available on workstations in the Control Room(s), TSC, EOF, and to remote dose assessors.
EROS provides the NRC with selected meteorological data points on a near real-time basis.
Meteorological inputs for the sites' dose assessment model are provided by ERF plant parameter display systems that obtain data from the site meteorological towers. Input parameters include wind speed, wind direction and stability class.
H.11 Provisions are made to ensure that emergency equipment and supplies are tested, I maintained, and available in sufficient quantities, to include reserves and replacements, when needed. This includes:
NextEra emergency equipment and kits are inventoried to verify adequate supplies and materials, and to inspect condition semi-annually and following each use.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 44 of 100 EP-AA-100 Emergency use equipment and instruments are operationally checked semi-annually during the inventory, and prior to use if needed as specified in procedures.
Sufficient reserves of instruments and equipment are maintained to replace those removed from service for calibration or repair.
Identification of the organization(s) responsible for the testing and maintenance of]
emergency equipment.
NextEra personnel are responsible for oversight of maintenance and testing of emergency equipment.
[ H.11.b Calibration and operational checks of emergency equipment per national standards or the manufacturer's instructions, whichever is more frequent.
Requirements to calibrate emergency equipment and instruments are specified in site procedures.
iEmergency kits are identified by g~-neral category. Content; a~d quantity of each H.12 emergency kit are specified in the emergency plan or other document(s) referenced in the emergency plan.
Emergency kits are assembled for radiation protection, field monitoring, first aid or other emergency use needs based on location and availability at each site.
Details of emergency kit contents and locations are contained in site procedures used to maintain facilities and equipment.
H.13 Each organization identifies the location(s) for the receipt and analysis of field
__ j' monitoring data and coordination of sample media and identifies the organization(s) responsible for assessing radiological data.
The site radiological laboratory is the primary location for receipt of field monitoring team samples. The EOF RP Coordinator is responsible for direction and coordination of field monitoring sample analyses, and for assessing the radiological data obtained from the Field Monitoring Teams.
Sampling and analysis equipment are available (see Element C.4) for quantitative activity determination of liquid and air samples, and qualitative activity determination of terrestrial samples.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 45 of 100 EP-AA-100 I:
Accident Assessment Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
Regulatory
References:
1 O CFR 50.47(b)(9); 44 CFR 350.5(a)(9);
10 CFR Part 50, Appendix E.IV.A, Band E Capabilities for performing radiological assessment for all reactor core and spent uel pool sources, individually and collectively, including response to events occurring simultaneously at all units on the NPP site, are described. These apabilities include:
I JEethods for determining the magnitude and isotopic composition of an ongoing J I
1.1.a release of radioactive material through waterborne or airborne release pathways, L__
or estimating these parameters for a potential release.
The magnitude of a release of radioactive material to the environment is primarily identified directly by effluent monitors. Survey and sample analysis may also be used to determine the magnitude of a release. Indirect means such as core damage estimates and release pathway assumptions may be used to estimate the magnitude of a release of radioactive material.
The isotopic composition of a release of radioactive material to the environment may be determined by; (1) effluent gaseous monitors, (2) survey and sample analysis, or (3) source term estimates based on core damage and release pathway assumptions.
Dose assessment model methods are capable of estimating source term and magnitude of gaseous releases from effluent monitors or plant parameter data and release rate projections.
1.1.b A radiological assessment model for airborne releases that provides estimates of offsite radiation exposures and contamination levels using a dispersion model that is representative of the plant release points, topographical features, and meteorological regimes at the NPP site.
NextEra uses site specific versions of the Unified RASCAL Interface (URI) off-site dose projection computer model. The underlying dose assessment model in URI is the NRC RASCAL 4 model, based on the methods and equations documented in NUREG-1940.
The URI model provides off-site radiological dose and dose rate estimates based on near real time or hypothetical inputs. Projected dose is based on EPA-400-R92-001 dose conversion factors and provided as; (1) the total effective dose equivalent, or TEDE (the sum of the effective dose equivalent from immersion, 4 days of ground deposition, and the committed effective dose equivalent from inhalation), and (2) the committed dose equivalent to the thyroid (CDE thyroid).
URI dose projection results are given for various locations from the site boundary to 10 miles.
URI is capable of providing dose assessment results for multiple release points from the site.
URI dose projection results and field monitoring readings are used in assessing radiological EALs and PARs.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 46 of 100 EP-AA-100
[
I A capability to coordinate and implement in-field radiological assessments by FMTs and/or sampling teams and to assess the data obtained.
Environmental surveys inside and outside the protected area are performed by Field Monitoring Team members under the direction of the EOF RP Coordinator.
Field monitoring teams are directed to track and evaluate a radioactive plume by monitoring radiation levels and by obtaining and analyzing air samples. Field monitoring surveys and sampling may be performed at pre-identified locations or other geographic locations within the EPZ determined during the event. Samples taken by the offsite monitoring teams will be evaluated further by one of the available laboratory facilities described in Element C.4.
I Methods for assessing contamination of drinking water through liquid release I
1.2 Jpathways or deposition of airborne materials for NPP sites located on or near
~--- ___ bodies of water from which public drinking water is drawn.
_ __ _/
This element is not applicable to the licensee emergency plan.
1.3 The capability and responsibility for monitoring the following parameters, which 1
J provide input to radiological assessments during an emergency, are described:
- 1. Status of reactor fuel (e.g., no fuel damage, technical specification activity, clad failure, core melt.).
- 2. Status of containment integrity.
- 3.
Leakage of radioactive material from plant systems, structures and components.
L_J::
Status of engineered safety features used to mitigate the release of radioactive material to the environment (e.g., filters, containment spray, etc.).
Onset and duration of an actual release of radioactive material to the J
environment, or estimating these parameter for a potential release. ____ _
The ERO monitors plant parameters using information provided by plant data transmittal systems to assess the status of reactor fuel using core damage assessment procedures.
The ERO monitors plant data systems to evaluate the status of containment integrity, systems used to mitigate the release of radioactive material to the environment and to identify leakage of radioactive material from plant systems, structures, and components.
Effluent and process monitors are used to determine the onset and duration of an actual or potential release of radioactive material to the environment.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 47 of 100 EP-AA-100 1.4 The methods and responsibility for determining the source term present in reactor coolant, containment atmosphere, and spent fuel pool area atmosphere are described.
Source term present in reactor coolant, containment atmosphere, and spent fuel pool area atmosphere are estimated using effluent, process and area radiation monitor readings, comparison of plant conditions against design basis event scenarios, sample analysis and environmental survey results, and plant parameter indications as inputs into the dose assessment and core damage assessment processes.
1.4.a The contingency arrangements to obtain and analyze highly radioactive samples from the reactor coolant system, containment atmosphere and sump, and spent fuel pool storage area are described.
Each NextEra site has arrangements to obtain and analyze highly radioactive samples from the reactor coolant system, containment atmosphere and sump, and spent fuel pool.
Site specific arrangements to obtain and analyze highly radioactive samples are described in the site annexes.
1.5 The organizations responsible for FMT activities, and necessary resources, are identified.
~-----~--------------------------*---------------~
NextEra is responsible for NextEra field monitoring team activities.
NextEra field monitoring team activities are coordinated with environmental monitoring efforts performed by ORO field monitoring teams.
1.6 Each organization, where appropriate, provides methods, equipment, and expertise to make timely assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways, including development of post-plume PARs for comparison to current Federal guidance.
NextEra sites use an industry recognized dose assessment model to make timely assessments of the actual or potential magnitude and locations of any radiological hazards through gaseous release pathways. Dose assessment results and field monitoring readings assist in evaluating appropriate ECLs based on radiological EALs, and for developing any related PARs.
The actual or potential magnitude of liquid radiological releases with regard to the ECLs are determined by liquid effluent monitors, direct area surveys, or sample analyses.
With regard to the ingestion pathway, field monitoring teams are used to obtain liquid effluent samples from radioactive liquid releases. Sample results are used in conjunction with Offsite Dose Calculation Manual (ODCM) methods to estimate potential ingestion exposure in support of EAL determination. Also, liquid release monitoring activities are coordinated and sample results shared with ORO agency personnel to assist their determination in intermediate phase protective actions.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 48 of 100 EP-AA-100 1.7 The capability to detect and measure radioiodine concentrations in air in the plume exposure pathway EPZ as low as 1 E-7 µCi/cc (microcuries per cubic centimeter) under field conditions is described. The sample collection process takes into account the sample flow rate, collection efficiency of the sample media used to collect the sample, duration of the sample, counter efficiency, and background radiation, including interference from the presence of noble gases.
~
NextEra field monitoring equipment has the capability to detect and measure airborne radioiodine concentrations as low as 1 E-7 µCi/cc in the presence of noble gases. Air samples will be taken with portable air sampling equipped with a Silver Zeolite or equivalent cartridge and particulate filter. Interference from the presence of noble gas and background radiation is minimized by ensuring that monitoring teams move to areas of low background prior to analyzing the sample cartridge.
Air sample results can be estimated in the field through the use of portable monitors. The samples can be subsequently analyzed for greater precision by the laboratory facilities described in Element C.4.
1.8
~----
A means is established for relating the various measured parameters (e.g.,
exposure rates, contamination levels, and air activity levels) to dose or dose rates.
Provisions are made for estimating integrated dose from the projected and actual l
dose rates and for comparing these estimates with current federal guidance. In addition, provisions are established to validate dose projections with field data and compare projections with other organizations also calculating dose projections.
The detailed provisions are described in implementing procedures.
NextEra field monitoring teams will track the plume from any radiological release by monitoring radiation levels and by obtaining and analyzing air samples. Field monitoring team environmental survey and air sample results are compared with dose assessment results to validate or adjust projections. Additionally, field monitoring results can be input into the dose assessment model to develop projections at different locations.
1.9 Arrangements to locate and track the airborne radioactive plume are made using available resources, which includes federal, state, and tribal governments, and/or licensee resources. Provisions are made to characterize the plume including taking peak plume measurements. Identification of the plume, includes determining a measurement that is high enough to be reasonably above background radiation readings and sufficient enough to indicate submersion within the plume.
NextEra maintains equipment for the utility field monitoring teams. Methods to monitor a radioactive plume include establishing peak centerline values and immersion areas. Monitoring strategies may include the traversing of plumes when road networks and exposure rate permit.
Additionally, local field sampling and monitoring points are specified to support pre-positioning of teams or use in comparison with dose projection results.
Data from the NextEra field monitoring teams is compared to data provided by state field monitoring teams that may be dispatched into the area. Data collected before state field monitoring teams are in the field is made available to state dose assessment personnel.
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49 of 100 1.10 Organizations directly responsible for radiological monitoring, analysis, and dos:J projections describe the capability for coordinating monitoring efforts, tracking a trending data, and sharing analytical results with other organizations performing radiological assessment functions.
NextEra EOF dose assessment personnel coordinate field monitoring team radiological monitoring activities and compare dose projection results with ORO and NRC representatives.
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Protective Response PAGE:
50 of 100 A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (Kl), as appropriate. ETEs have been developed by applicants and licensees.
Licensees shall update the ETEs on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
Regulatory
References:
10 CFR 50.47(b)(10); 44 CFR 350.5(a)(10);
10 CFR Part 50, Appendix E.IV.2-6, E and I J.1 The means and time required to alert, notify, and provide a range of protective I
actions for onsite individuals and individuals who may be in areas controlled by the licensee (including members of the public) during a radiological incident are described.
NextEra maintains procedures to provide for a range of protective actions for all areas controlled by the site. Protective actions have been developed for radiological incidents and to protect personnel during hostile actions directed at the site.
Sitewide notifications and announcements are routinely made using the Public Address (PA) system. Personnel on site are notified of a declared emergency through the PA system.
Visitors within the Protected Area are escorted by badged individuals. The escort is responsible for controlling and directing their assigned visitors regarding actions required by any announcements and alarms.
Security personnel are used, as available, to augment PA announcements and to check OCA areas for remaining individuals.
L J ~Provisions are made for evacuation of onsite non-essential personnel at an
- .a SAE/General Emergency (GE).
"--'---------------------------~
Site evacuation is required following a Site Area Emergency or General Emergency unless delayed due to safety issues. The sounding of an alarm over the public address system occurs for the initiation of site evacuation.
When a site evacuation occurs, ERO and other essential personnel respond to their designated response facilities/areas. Non-essential personnel inside the Protected Area typically exit to the OCA by following normal RP and Security processes and proceed to a designated assembly area. Further evacuation of non-essential personnel inside the OCA occurs as warranted for the particular site.
A process is in place to perform a rapid evacuation of the Protected Area without onsite monitoring and OCA assembly if conditions warrant. Monitoring in this instance is performed at an offsite location.
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51 of 100 Provisions are made and coordinated with appropriate offsite entities for evacuation routes and transportation for onsite individuals to a suitable offsite location. Selection of location considers the potential for inclement weather, high traffic density, and potential radiological conditions. Alternate location(s) and route(s) are identified.
Designated offsite locations for site evacuees, and the process to use them, have been identified through coordination with local emergency management personnel.
The site evacuation process takes into consideration meteorological and radiological data, weather and other travel hazards.
On-site personnel will evacuate the site when directed. Site evacuation routes and evacuation locations are contained in the site annexes.
~
Provisions for radiological monitoring and decontamination, if necessary, of
~- personnel evacuated from the NPP site are described.
Personnel evacuating are monitored for contamination, and, if possible and necessary, decontaminated before leaving the site. If conditions do not allow for decontamination of personnel on-site, they will be directed to designated offsite reception center(s) for radiological monitoring and decontamination, if required.
The capability to account for all individuals inside the NPP Protected Area following declaration of an SAE or GE is described. The names of missing individuals are J
ascertained within 30 minutes following the emergency declaration and J.4 accountability is maintained for the duration of the incident. This capability includes provisions for prompt accountability following events that may preclude completion
~ _________ within 30 minutes (e.g., hostile action).
The emergency alarm, together with the public address system, is used to alert and notify on-site personnel of the need for assembly at a Site Area or General Emergency classification level (or earlier at the discretion of the Emergency Director).
ERO personnel report to their assigned emergency response facility.
Typically, accountability of personnel inside the Protected Area is completed within 30 minutes of event declaration. Following a hostile action event, the personnel accountability process is initiated following containment or cessation of the threat. Missing individual(s) will be identified by Security. Appropriate actions will be taken to locate missing individual(s). When necessary, search and rescue team(s) will be dispatched to locate and, if necessary, rescue missing individual(s).
After initially completed, accountability will be maintained continuously throughout the emergency for personnel inside the Protected Area.
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52 of 100 J.5 Provisions are made for personal radiological protection for individuals arriving or_J remaining onsite during the incident.
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Protective equipment and supplies are available to personnel remaining on site or arriving on site during the emergency to minimize the effects of radiological exposures or contamination in accordance with radiation protection procedures. Protective measures include the following:
- 1. Individual Respiratory Protection Respiratory protection equipment is used by qualified personnel when called for by exposure control procedures. The radiological use respiratory protection program is maintained by RP.
Self-contained breathing apparatus is used in areas that are deficient in oxygen or when fighting fires. Self-contained breathing apparatus are available with other firefighting equipment for use by the site fire brigade.
- 2. Individual Thyroid Protection Efforts are made to utilize respiratory protective equipment to minimize ingestion and/or inhalation of radionuclides and to maintain internal exposure below the limits specified in 10 CFR 20, Appendix B. However, if an emergency involves the accidental or potential ingestion or inhalation of radioactive iodine, Potassium Iodide tablets (Kl) are maintained and available for distribution.
The administration of potassium iodide (Kl) to NextEra and vendor personnel may be used to mitigate the consequences of inhalation of radioiodine during an emergency. The process for administration of radioprotective drugs is described in implementing procedures.
- 3. Protective Clothing Protective clothing will be issued when needed to limit personal contamination and minimize the spread of contamination.
J 6 responsible OROs, including evacuation, sheltering, and, if appropriate, J
The basis and methodology are established for the development of PARs for the radioprotective drug use, for the plume exposure pathway EPZ. Current Federal guidance is used.
NextEra sites have developed PARs, in accordance with agreements made with the state agencies, for the plume exposure pathway EPZ that include evacuation, sheltering, and recommendations for radioprotective Potassium Iodide use based on the following:
NUREG-0654/FEMA-REP-1, Supplement 3, Guidance for Protective Action Strategies, November 2011 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, May 1992 Guidance for Industry, Kl in Radiation Emergencies, Questions and Answers, FDA, December 2002
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53 of 100 Potassium Iodide as a Thyroidal Blocking Agent in Radiation Emergencies, FDA Guidance, November 2011 PARs for the general public will be based on plant conditions and/or offsite dose assessment results.
PARs beyond the 10-mile EPZ will be developed on an "ad hoc basis" from projected or measured dose in excess of EPA PAGs. Because dose projection accuracy is limited by distance, actual field measurements are used to corroborate projections before issuing PARs in areas outside the 10-mile EPZ.
The PAR strategy basis document is referenced in the site annexes.
J.7 A site-specific protective action strategy or decision-making process, informed by the ETE study, is coordinated between the licensee and OROs. Current Federal guidance is used.
~---~-
NextEra offsite protective action recommendation strategies, informed by the ETE report, have been developed using guidance provided in NUREG-0654/FEMA-REP-1, Supplement 3, Guidance for Protective Action Strategies, in coordination with the state and local agencies.
J.8 are:
[
J.8.a I Incorporated either by reference or in their entirety into the emergency plan.
I The most recent ETEs are incorporated by reference into this emergency plan. Refer to the site annexes for specific reference to the ETE study.
Updated ETE studies will be submitted to the NRC under 1 O CFR 50.4 no later than 365 days after NextEra determines that the criteria for updating the ETE have been met and at least 180 days before using it to form protective action recommendations and providing it to state and county governmental authorities for use in developing offsite protective action strategies.
During the years between decennial censuses NextEra will estimate EPZ permanent resident population changes once a year, but no later than 365 days from the date of the previous estimate, using the most recent U.S. Census Bureau annual resident population estimate and state/county government population data, if available. NextEra will maintain these estimates so that they are available for NRC inspection during the period between decennial censuses and will submit these estimates to the NRC with any updated ETE report.
The criteria that require a full update to the site ETE study is as follows:
- 1. The availability of the most recent decennial census data from the U.S. Census Bureau; OR
- 2. If at any time during the decennial period, the EPZ permanent resident population increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone, including all affected emergency response planning areas, or for the entire 10-mile EPZ to increase by 25 percent or 30 minutes, whichever is less, from the currently NRC approved or updated ETE.
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NEXTERA COMMON EMERGENCY PLAN 54 of 100 EP-AA-100 NUCLEAR FLEET J.8.b Incorporated either by reference or as a summary of the latest ETE analysis into l the emergency plan.
This element is not applicable to the licensee emergency plan.
PARs are provided, in a timely manner, directly to the designated ORO(s)
J.9 responsible for making protective action decisions (PADs) within the plume exposure pathway EPZ.
Applicable plume exposure pathway EPZ PARs of evacuate and shelter are developed at the General Emergency classification level and provided to the ORO personnel responsible for making protective action decisions.
PARs are communicated using the initial notification form and process. See Section E for a discussion of emergency notification.
~J Plans include maps, charts, or other information that demonstrate the following fo~
the plume exposure pathway EPZ:
J.10.a Evacuation routes, evacuation areas, reception centers in host areas, and shelter l areas.
Details on evacuation routes, evacuation areas, reception centers in host areas, and shelter areas are provided in the site ETE report.
[
J.10.b J Population distribution around the NPP site by evacu~_tion areas.
I Details on population distribution around the NextEra sites, by evacuation areas, are provided in the site ETE report.
A capability for implementing protective actions based on current Federal guidance J.11 is established. The process ensures coordinated implementation of PADs with all appropriate jurisdictions. The process for implementing protective actions for the plume exposure pathway EPZ is described and includes the following:
I~~~
Means for identifying and protecting residents who would have difficulty in implementing protective actions without assistance. This includes those with C access and functional needs, transportation-dependent residents, those in special facilities, and those in correctional facilities. These means include notification, I support, and assistance in implementing protective actions where appropriate.
This element is not applicable to the licensee emergency plan.
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NEXTERA COMMON EMERGENCY PLAN 55 of 100 EP-AA-100 NUCLEAR FLEET The decision-making methodologies for use of radioprotective drugs and the provisions for administration to the general public, emergency workers, and J.11.b institutionalized persons within the plume exposure pathway EPZ. This includes the means of determining quantities, maintaining and managing supplies, communicating recommendations, and distributing.
This element is not applicable to the licensee emergency plan.
Means of evacuation informed by the updated ETEs. The evacuation routes and J.11.c transportation resources to be utilized are described and include projected traffic capacities of evacuation routes and implementation of traffic control schemes during evacuation.
This element is not applicable to the licensee emergency plan.
The locations of pre-identified reception centers beyond the boundaries of the J.11.d plume exposure pathway EPZ, organizations responsible for managing reception centers, arrangements for handling service animals and pets, and provisions for radiological monitoring/decontamination.
This element is not applicable to the licensee emergency plan.
Means for the initial and ongoing control of access to evacuated areas and J.11.e organizational responsibilities for such control, including identifying pre-selected control points.
This element is not applicable to the licensee emergency plan.
Identification of and means for dealing with potential impediments to the use of I
I J.11.f evacuation routes (e.g., seasonal impassability of roads) and contingency measures. The resources available to clear impediments and responsibility for re-routing traffic, as necessary, are described.
I This element is not applicable to the licensee emergency plan.
J.11.g Identification of and means to implement precautionary protective actions (e.g.,
taken at an E)
This element is not applicable to the licensee emergency plan.
Protective actions to be used for the ingestion exposure pathway EPZ are J.12 specified, including the methods for protecting the public from consumption of contaminated foodstuffs, and are based on current Federal guidance.
This element is not applicable to the licensee emergency plan.
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56 of 100 he means for registering, monitoring, and decontaminating evacuees, service nimals, pets, vehicles, and possessions at reception centers in host areas are escribed. The personnel and equipment available are capable of monitoring 20 percent of the plume exposure pathway EPZ population, including transients,
~--* _J assigned to each facility within a 12-ho_u_r_p_e_r_io_d_. ____________ _
This element is not applicable to the licensee emergency plan.
14 General plans for the removal or continued exclusion of individuals from restricted-1
~------~a_re_a_s~re ~eveloped. Relocation plans include:
__________ J
~_J_.1_4_.a_~I _P_ro_cess for implementing current federal guidance for reloc_a_t_io_n_. -------~
This element is not applicable to the licensee emergency plan.
~ Means to identify and determine the boundaries of relocation areas, L~_.b_~bu
___ f __ fe
___ r __ z_o_n_e. ___________________________ *-*---------~
This element is not applicable to the licensee emergency plan.
~
Prioritization of relocation based on projected dose to an individual and the L~':__ timeframe for relocation.
This element is not applicable to the licensee emergency plan.
Control of access to and egress from relocation areas and security provisions for J.14.d I t d L----~e_v_acua e areas.
This element is not applicable to the licensee emergency plan.
[
J.14.e _J Contamination control_ during relocation. ______________________________________ _]
This element is not applicable to the licensee emergency plan.
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J.14.f I Means for coordinating and ~roviding assistance during relocation.
This element is not applicable to the licensee emergency plan.
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NEXTERA COMMON EMERGENCY PLAN 57 of 100 EP-AA-100 NUCLEAR FLEET K:
Radiological Exposure Control Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.
Regulatory
References:
10 CFR 50.47(b)(11); 44 CFR 350.5(a)(11);
10 CFR Part 50, Appendix E.IV.E
[~
The radiation protection controls for emergency workers to be implemented during emergencies are described. These controls address the following aspects:
-~
Approval is required if emergency workers are expected to receive dose in excess of 10 CFR 20 occupational dose limits. ALARA practices are utilized during emergencies as much as practical.
Onsite emergency exposure guidelines for emergency workers consistent with K.1.a their assigned duties and current Federal guidance and the conditions under which the guidelines apply.
Onsite exposure guidelines for emergency workers, consistent with EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, U.S. Environmental Protection Agency, May 1992, Table 2-2, "Guidance on Dose Limits for Workers Performing Emergency Services," have been established as follows:
All activities during the emergency.
10 Protecting valuable property when lower dose is not practicable.
25 Lifesaving or protection of large populations when lower dose is not practical per EPA-400-R-92-001.
Greater Than 25 Lifesaving or protection of large populations, only if individuals receiving exposure is a volunteer, and fully aware of risks involved.
NOTES Emergency exposure limits are exclusive of current occupational exposure.
Only one emergency exposure is allowed per lifetime.
Dose to lens of the eye is limited to three times listed value.
Dose to other organs, including skin and body extremities, is limited to ten times listed value.
The capability to evaluate emergency worker dose (i.e., the sum of the effective K.1.b dose equivalent and the committed effective dose equivalent) at the time of exposure when direct measurement is not feasible.
Emergency worker exposure is monitored at the time of exposure by the use of electronic dosimeters. If direct measurement of airborne concentrations is not available at time of exposure, workers will be provided respiratory protection, when feasible, and total exposures will be calculated after the fact using follow up survey data and whole body counting equipment.
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58 of 100 I~
The capability to monitor and assess the radiation doses received by emergency I
~
workers for the duration of the incident.
Personnel dosimeters are issued to and worn by NextEra radiation worker qualified personnel who may be required to work in Radiological Controlled Areas in accordance with radiation protection procedures.
Radiation protection personnel in the OSC and TSC have the responsibility to monitor and assess the radiation doses received by ERO personnel on a 24-hour per day basis throughout a declared event.
Personnel dose records are documented and managed using a computerized system. Should this system not be readily accessible or available, personnel dose is manually recorded.
Dosimeters are available and will be provided to offsite agency responders if they are required to enter a Radiological Controlled Area or are expected to receive a dose in excess of 100 mRem for the event.
[
K.1.d I The capability to implement onsite contamination control measures.
Radiation safety controls are established 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day to contain the spread of loose surface radioactive contamination. Contamination control limits are defined in radiation protection procedures. Personnel leaving the contaminated areas are monitored to ensure that they are not radioactively contaminated.
[
K.1.e I The capability to decontaminate emergency workers, equipment, and vehicles.
Personnel decontamination is performed using normal radiation protection procedures in on-site facilities. Personnel decontamination facility locations are described in the site annexes.
Contamination on personnel will be removed in accordance with established radiation protection procedures.
Equipment will be released for use outside of the contaminated areas only when radioactive contamination is within acceptable limits. All equipment must be checked for contamination before being taken from a known contaminated area. Equipment and material decontamination is performed using normal radiation protection procedures.
~----------------------------------------
K.1.f Appropriate radiation protection briefings for repair teams that are being dispatched into the plant, and FMTs being sent onsite and offsite, the scope of which is consistent with the expected risk to the team.
Emergency teams, including Field Monitoring Teams, that must enter areas where they might be expected to receive higher than normal doses will be briefed on the task assigned and appropriate protective measures.
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NEXTERA COMMON EMERGENCY PLAN 59 of 100 EP-AA-100 NUCLEAR FLEET
[-~.1.g The process for NPP site access and dosimetry issuance to personnel from OROs I arriving to assist with the onsite response.
The site access process into the protected area for local support organizations responding on site during an emergency is controlled by site security personnel. Non-NextEra emergency workers supporting on-site activities will be issued dosimetry and/or be monitored by radiation protection personnel when responding to areas where a radiation dose may be received.
[~~
lndividual(s) who can authorize personnel to receive radiation doses in excess of the occupational dose limits in accordance with the minimum standards set forth in 10 CFR Part 20 or 29 CFR 1910.1096, as applicable to the organization, are identified by title/position. Such authorizations are documented.
Section B.2.a describes the responsibility for authorization of exposures to radiation in excess of 1 O CFR 20 limits. Such authorizations are documented as part of the emergency exposure controls process provided in Element K.1.c.
K.2.a The process for allowing onsite volunteers to receive radiation exposures in the course of carrying out lifesaving and other emergency activities is described.
All personnel dispatched into radiation areas or areas of unknown radiation levels are briefed on the task and environmental conditions and are provided appropriate monitoring and personnel protective equipment.
Refer to Element K.1.a for the description of activities and their exposure thresholds and considerations.
K.2.b The process for authorizing emergency workers to incur exposures that may result in doses in excess of the current Federal g 1nce is described.
This element is not applicable to the licensee emergency plan.
The capability to determine the doses received by emergency workers involved in K.3 any commercial NPP radiological incident is described. Each organization makes provisions for distribution of direct-reading dosimeters (DRDs) and permanent record dosimeters (PRDs).
This element is not applicable to the licensee emergency plan.
K.3.a Provisions to ensure that DRDs are read at designated intervals and dose records J are maintained for emergency workers are described.
This element is not applicable to the licensee emergency plan.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 60 of 100 EP-AA-100 K.4 Action levels for determining the need for decontamination are specified and the means for radiological decontamination are established for emergency workers and the general public, as well as equipment, vehicles, and personal possessions.
The means for disposal of contaminated waste created by decontamination efforts are also established.
This element is not applicable to the licensee emergency plan.
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET L:
Medical and Public Health Support Arrangements are made for medical services for contaminated injured individuals.
Regulatory
Reference:
10 CFR 50.47(b)(12); 44 CFR 350.5(a)(12);
10 CFR Part 50, Appendix E.IV.E 61 of 100 Arrangements are established with primary and backup hospitals ( one hospital is located outside the plume exposure pathway EPZ) and medical services. These L.1 facilities have the capability for evaluation of radiation exposure and uptake. The persons providing these services are adequately trained and prepared to handle contaminated, injured emergency workers and members of the general public.
~*--------
This element is not applicable to the licensee emergency plan.
l ]
rrangements for the medical treatment of contaminated injured onsite personnel L 2 and those onsite personnel who have received significant radiation exposures and/or significant uptakes of radioactive material are described. These arrangements include the following components:
~-
[__!:_~~-.a
/ An onsite first aid capability with adequate medical equipment and supplies.
On-shift first aid personnel will provide first aid to individuals who are injured. Radiation protection personnel will provide contamination control support to potentially contaminated injured personnel.
NextEra maintains first aid supplies, and equipment for the treatment of injured or contaminated/injured persons. Descriptions of equipment and supplies, and radiological monitoring and decontamination equipment and supplies are in site procedures.
Q.2.b j Primary and backup offsite medical facilities. ------
Arrangements have been made with local hospitals for the medical treatment of contaminated injured or over exposed personnel. These facilities and their services are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
Offsite medical facilities used to treat contaminated injured personnel are described in the site annexes.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 62 of 100 EP-M-100 L.2.c Radiological controls capability, including the isolation of contamination, assessment of contamination levels, radiation exposure monitoring for facility staff, collection of contaminated waste, and decontamination of areas.
NextEra personnel are available to assist medical personnel with decontamination, radiation exposure monitoring, and contamination control.
Radiological controls capability, including the isolation of contamination, assessment of contamination levels, radiation exposure monitoring for medical facility staff, collection of contaminated waste, and decontamination of treatment areas are described in hospital procedures.
L.2.d Provisions to evaluate for radiological contamination either prior to transport to a medical or after arrival.
Injured personnel are evaluated for radiological contamination prior to transport to a medical facility per site procedures. If contamination monitoring is not possible due to the medical condition of the individual, contamination monitoring is performed as soon as possible following treatment at the medical facility.
L.2.e Contact information for facilities capable of treating overexposure to radioactive material.
The Radiation Emergency Assistance Center Training Site (REAC/TS) located at Oak Ridge, Tennessee, will respond to and/or provide advice and assistance to offsite medical facilities in the event of a severe radiation accident.
L.3 Supplemental lists are developed that indicate the location of the closest public, private, and military hospitals and other emergency medical facilities within the state or contiguous states considered capable of providing medical support for any contaminated, individual.
This element is not applicable to the licensee emergency plan.
L.4 Each organization arranges for the transportation of contaminated, injured individuals and the means to control contamination while transporting victims of radiological incidents to medical support facilities and the decontamination of transport vehicle following use.
~---~---
Injured personnel are evaluated for radiological contamination and packaged to control contamination prior to transport to a medical facility per radiation protection department procedures. NextEra personnel will assist with decontamination of transport vehicles if necessary.
Transportation agreements for contaminated injured personnel are described in site annexes.
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NEXTERA COMMON EMERGENCY PLAN 63 of 100 EP-AA-100 NUCLEAR FLEET M:
Recovery, Reentry, and Post-Accident Operations General plans for recovery and reentry are developed.
Regulatory
Reference:
10 CFR 50.47(b)(13); 44 CFR 350.5(a)(13);
10 CFR Part 50, Appendix E.IV.H General recovery, reentry, and return plans for radiological incidents are M.1 developed, as appropriate. These plans address reoccupancy, as appropriate. The plans should include:
Provisions for allowing reentry into areas controlled by the licensee. Reentry M.1.a planning includes evaluation of the controls necessary for reentry under post-incident conditions.
-~,-----~---------------~--
Reentry can occur during the plume or post-plume phase and refers to the temporary movement of people into an area of actual or potential hazard. Personnel who have been evacuated or relocated from a restricted area may be allowed to reenter under controlled conditions to perform additional emergency response activities.
Reentry into the OCA will be based on site conditions. During or following a HAB incident, reentry criteria take into consideration site security and threat conditions.
Provisions for reentry into restricted areas, including exposure and contamination M.1 control, as appropriate. A method for coordinating and implementing decisions regarding temporary reentry into restricted areas is addressed.
This element is not applicable to the licensee emergency plan.
~~
Individuals who will comprise the licensee's recovery organization are identified by]
title/ position. The recovery organization includes technical personnel with responsibilities to develop, evaluate, and direct recovery and reentry operations.
The recovery activities would be managed much like a normal outage, except that certain activities unique to the post-accident situation may be controlled by the recovery organization.
The recovery organization would function as a matrix management organization to coordinate activities with the normal company organization. This organization may be located at the EOF or the site, as appropriate.
The primary positions in the recovery organization are described as follows:
Recovery Manager - Overall management of recovery activities. High level coordination with offsite agencies.
Onsite Recovery Coordinator - Directs the onsite recovery activities.
Offsite Recovery Coordinator - Directs interface with offsite agencies during the recovery.
Radiological Assessment Coordinator {if needed} - Coordinates radiological and environmental assessment with offsite agencies. Coordinates offsite radwaste management and decontamination activities.
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64 of 100 Spokesperson - Directs the public information program during the recovery phase.
M.3 The process for initiating recovery actions is described and includes the criteria for terminating the emergency.
~---~---
Steps will be taken to terminate from the event, either directly or following a transition period (prior to entering a state of recovery operations). Usually, the Unusual Event and Alert classification levels will be directly terminated (no entry into recovery).
Items that must be considered before terminating the emergency condition to either a normal or a recovery organization are as follows:
Emergency Action Level criteria Releases of radioactive materials to the environment In-plant radiation levels Plant stable and long term core cooling available Containment integrity Functionality and integrity of plant systems, facilities, power supplies, equipment, and instrumentation Fire, flood, earthquake or similar hazardous emergency conditions Security issues Site access not limited for personnel and support services Decisions to relax protective actions for the public will be made by the appropriate state authorities.
When transition from an emergency to a recovery phase is necessary, the Emergency Director will designate a Recovery Manager and develop a recovery organization.
The Emergency Director will inform the ERO, OROs, and NRC upon exiting the state of emergency and either returning to normal organizational control or entering recovery.
M.4 The process for initiating recovery actions is described and includes provisions to ensure continuity during transfer of responsibility between phases. The chain of command is established.
This element is not applicable to the licensee emergency plan.
_l
- The framework for relaxing protective actions and allowing for return are described.
Prioritization is given to restoring access to vital services and facilities.
M.5 This element is not applicable to the licensee emergency plan.
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65 of 100
[
M 6
~
organization(s) responsible for developing and implementing cleanup operations offsite is identified.
This element is not applicable to the licensee emergency plan.
M.7 Provisions for developing and modifying sampling plans are established.
Provisions for laboratory analysis of samples are included in the plan.
~
The recovery organization will coordinate NextEra environmental sampling activities with the state agencies. Refer to Element C.4 for a description of laboratory capabilities.
M.8 A method for periodically conducting radiological assessments of public exposure I is established.
This element is not applicable to the licensee emergency plan.
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Exercises and Drills PAGE:
66 of 100 Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
Regulatory
References:
10 CFR 50.47(b)(14); 44 CFR 350.5(a)(14);
10 CFR Part 50, Appendix E.IV.F I
l Exercises and drills are conducted, observed, and critiqued/evaluated as set forth L N.1 in NRC and FEMA regulations and guidance.
~---~
- 1. Exercise: An exercise is an event that tests the integrated capability and a major portion of the elements of the emergency plans and organizations.
Over the period of the exercise cycle, exercises will test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communications networks, test the public alert and notification system, and ensure that emergency organization personnel are familiar with their duties.
Exercises must provide the opportunity for the ERO to demonstrate proficiency in the key skills necessary to implement the principal functional areas (see N.4) of emergency response.
State and local agencies within the plume exposure pathway EPZ are provided the opportunity to participate by invitation as described in Element N.2.a.
- 2. Drill: A drill is aimed at testing, developing and maintaining skills in one or more emergency plan functions.
Drill types may be operational or discussion-based events (e.g., single ERF or tabletop drills). Drills may be a component of an exercise.
During drills; activation of all of the ERFs is not required, supervised instruction is permitted, participants may be given the opportunity to resolve problems (success paths), and focus may be primarily on onsite training objectives. Drills may include evaluation of specific performance objectives or be conducted for non-evaluated training only.
The ERO (not necessarily each ERO member) shall be provided the opportunity to develop and maintain key emergency response skills within the scope of their duties in drills and exercises during each exercise cycle.
Over the course of an eight-year cycle all unique initiating conditions in the EAL scheme (with the exception of judgment ICs) are made available for the demonstration of event classification within drills or exercises.
[-- N.~-1 The proc~ss to critigue/evaluate exercis~s and drills is described.
Critiques of each drill and exercise will be held following each event to evaluate areas and identify issues. The critique is performed following the conclusion of a drill or exercise using preselected drill and exercise performance objectives.
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67 of 100 Provisions are made for federal and ORO representatives to observe and participate in drill and exercise critiques when present.
A written report is prepared following a critique to document whether the objectives were successfully demonstrated.
A remedial exercise is only required if the emergency plan is not satisfactorily tested during the biennial exercise such that NRC, in consultation with FEMA, cannot (1) find reasonable assurance that adequate protective measures would be taken during a radiological emergency, or (2) determine that the ERO has maintained key skills specific to emergency response.
The process used to track findings and associated corrective actions identified by N.1.b drill and exercise critiques/evaluations, including their assignment and completion, is described.
Failed performance objectives and other programmatic weaknesses are entered into the corrective action program (CAP).
N.1.c I A drill or e~ercise starts between 6:00 p.m. and 4:00 a.m. at least once every eight-
~
exercise cycle.
Each NextEra site will conduct at least one off-hours drill or exercise within an eight-year exercise cycle.
An off-hours drill or exercise is established as any time of day on a weekday holiday, or any time of day on a weekend day, or between the hours of 6:00 p.m. and 4:00 a.m. on a normal workday.
The off-hours drill requirement may be satisfied by an actual event provided it meets the above off-hours criteria and the objectives are evaluated and documented in a critique report for the augmentation of the ERO, the transfer of responsibilities, and facility activation.
I N.1.d =rA drill or exercise is unannounced at least once every eight-year exercise cycle.
j Each NextEra site will conduct at least one unannounced drill or exercise within an eight-year cycle.
The unannounced drill requirement may be satisfied by an actual event provided objectives are evaluated and documented in a critique report for the augmentation of the ERO, the transfer of responsibilities, and facility activation.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET PAGE:
68 of 100 Exercises are designed to enable the response organizations' demonstration of the N.2 key skills and capabilities necessary to implement the emergency plan. The following two types of exercises are conducted at the frequency noted:
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Plume Exposure Pathway Exercises Plume exposure pathway exercises are conducted biennially. These exercises include mobilization of licensee and state, N.2.a local, and tribal government personnel and resources and implementation of emergency plans to demonstrate response capabilities within the plume exposure pathway EPZ.
Each NextEra site will conduct a plume exposure pathway exercise biennially. Specifically, the plume exposure pathway exercise is developed to provide the ERO with the opportunity to demonstrate proficiency in the principal functional areas of emergency response:
Management and coordination of emergency response Accident assessment Event classification Notification of the OROs Assessment of the onsite and offsite impact of radiological release PAR development (required only in exercises that include a GE)
Protective action decision-making (onsite protective actions)
Plant system repair and mitigative action implementation OROs will be invited to participate in plume exposure pathway exercises. If an ORO chooses not to participate, their participation is not required and it should be documented that they were given the opportunity to participate.
Biennial plume exposure pathway exercise scenarios are submitted to the NRC under 10 CFR 50.4 at least 60 days before they are held.
1
---~-,-n--g-e-stion Exposure Pathway Exercises Ingestion exposure pathway exercises*
are conducted at least once every eight years. These exercises include mobilization of state, local, and tribal government personnel and resources and N.2.b implementation of emergency plans to demonstrate response capabilities to a within the ingestion exposure pathway EPZ.
NextEra will assist in development and participate as requested in an ingestion exposure pathway exercise to support FEMA evaluation of ORO emergency plan response activities in this area.
The scope, objectives and schedule will be coordinated with appropriate federal emergency organizations and OROs for exercises in which they participate.
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NEXTERA COMMON EMERGENCY PLAN 69 of 100 EP-AA-100 NUCLEAR FLEET Exercise Scenario Elements During each eight-year exercise cycle, biennial, N.3 evaluated exercise scenario content is varied to provide the opportunity to demonstrate the key skills and capabilities necessary to respond to the following scenario elements:
Hostile Action-Based (HAB) Hostile action directed at the NPP site. This scenario N.3.a element may be combined with either a radiological release scenario or a no/minimal radiological release scenario, but a no/minimal radiological release scenario should not be included in consecutive HAB exercises at an NPP site.
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Each NextEra site will conduct at least one HAB scenario in an exercise within an eight-year cycle.
The HAB scenario will include either a radiological release scenario or no/minimal radiological release scenario, but HAB scenarios combined with a no/minimal radiological release scenario will not be used in consecutive HAB exercises.
I N.3.b J Rapid Escalation An initial classification of, or rapid escalation to, an SAE or GE. I Each NextEra site will conduct at least one rapid escalation scenario in an exercise within an eight-year cycle.
The rapid escalation scenario will begin with an initial declaration of, or rapid escalation to, the Site Area Emergency classification level while event response is performed from the Control Room.
No/Minimal Release of Radioactive Materials No release or an unplanned N.3.c minimal release of radioactive material which does not require public protective actions. This scenario element is used only once during each eight-year exercise cycle.
Each NextEra site will conduct at least one no/minimal radiological release scenario that does not require PARs in an exercise within an eight-year cycle.
The licensee is required to demonstrate the ability to respond to a no/minimal radiological release scenario. State, local, and tribal government response N.3.c.1 organizations have the option, and are encouraged, to participate jointly in this demonstration. If the offsite organizations elect not to participate in the licensee's required minimal or no release exercise, the OROs will still be obligated to meet the exercise requirements as specified in 44 CFR 350.9.
OROs located within the plume exposure pathway EPZ are invited to participate in exercises with no/minimal radiological release scenarios.
NextEra will support offsite agencies in meeting FEMA demonstration requirements when they elect to not participate in a required no/minimal release scenario that is included in an exercise.
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70 of 100 When planning for a joint no/minimal radiological release exercise, affected state, local, and tribal jurisdictions, the licensee, and FEMA will identify offsite capabilities that may still need to be evaluated and agree upon appropriate alternative N.3.c.2 evaluation methods to satisfy FEMA's biennial criteria requirements. Alternative evaluation methods that could be considered during the extent of play negotiations include expansion of the exercise scenario, out of sequence activities, plan reviews, staff assistance visits or other means as described in FEMA guidance.
FEMA will determine whether a no/minimal radiological release scenario is acceptable for use in a full or partial participation biennial exercise.
I N.3.d I Resource Integration Integration of offsite resources with onsite response.
Each NextEra site will conduct at least one scenario that integrates offsite resources provided by local support organizations with onsite response in an exercise within an eight-year cycle.
Demonstration of resource integration includes briefings, offsite response to the site, and coordination of worker protection, as appropriate to the scenario.
N.3.e 1
10 CFR 50.155(b)(2) Strategies Demonstration of the use of equipment, J
procedures, and strategies developed in compliance with 10 CFR 50.155(b )(2).
Each NextEra site will conduct at least one scenario requiring demonstration of the ability to transition between procedures and select the strategy(ies) for preventing or mitigating fuel damage and limiting radiological releases, within an eight-year cycle.
The MBDBE exercise scenario will be based in one of the site specific strategies used to mitigate spent fuel pool damage scenarios or one of the 7 strategies for PWRs used to mitigate reactor accidents and maintain containment.
The MBDBE exercise may be conducted separately from the main exercise timeline and sequence of events. This includes the (simulated) deployment and use of equipment associated with these strategies. At a minimum, TSC and OSC ERO staff will participate in this portion of the exercise. Participation of Control Room, EOF, JIC ERO, and offsite officials may be simulated.
Methods to accomplish this demonstration are dependent upon the nature of the postulated initiating event, the plant response/accident sequence, and the ability of responders to select and implement mitigation/management strategies. These methods involve conducting any of the following:
A demonstration of the transition from a controlling AOP or EOP into the Extensive Damage Mitigation Guidelines (EDMGs), FLEX support guidelines (FSGs), or Severe Accident Management Guidelines (SAMGs).
A demonstration of the use of EDMGs.
A demonstration of the use of FSGs.
A demonstration of the use of SAMGs.
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NEXTERA COMMON EMERGENCY PLAN 71 of 100 EP-AA-100 NUCLEAR FLEET
[~.4 Drills are designed to enable an organization's demonstration and maintenance of key skills and capabilities necessary to fulfill functional roles. Drills include, but are not limited to, the following at their noted frequencies:
Emergency Medical Drills Emergency medical drills are conducted annually.
N.4.a These drills involve a simulated, contaminated individual and contain provisions for participation by support services agencies (i.e., ambulance and offsite medical treatment ility)
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.
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Medical Services Drills Medical services drills are conducted annually at each medical facility designated in the emergency plan. These drills involve a simulated, N.4.b contaminated emergency worker and/or member of the general public and contain L
___1;ovisions for participation by support services agencies (i.e., ambulance and offsite medical treatment facility).
This element is not applicable to the licensee emergency plan.
Laboratory Drills Laboratory drills are conducted biennially at each laboratory designated in the emergency plan. These drills involve demonstration of handling, N.4.c documenting, provisions for record keeping, and analyzing air, soil, and food samples, as well as quality control and quality assurance processes. These drills also involve an assessment of the laboratory's capacity to handle daily and weekly J samples and the volume of samples that can be processed daily or weekly.
I This element is not applicable to the licensee emergency plan.
Environmental Monitoring Drills Environmental monitoring drills are conducted N.4.d annually. These drills include direct radiation measurements in the environment, collection and analysis of all sample media (e.g., water, vegetation, soil, and air),
and provisions for record keeping.
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Each NextEra site will conduct an environmental monitoring drill once per calendar year.
The scope of the environmental monitoring drill will include performance objectives for direct radiation measurements in the environment, collection and analysis of sample media (e.g.,
water, vegetation, soil, and air), communications, and record keeping.
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NEXTERA COMMON EMERGENCY PLAN 72 of 100 EP-AA-100 NUCLEAR FLEET Ingestion Pathwa~ and Post-Plume Phase Drills Ingestion pathway and post-plume phase drills are conducted biennially. These drills involve sample plan N.4.e development, analysis of lab results from samples, assessment of the impact on food and agricultural products, protective decisions for relocation, and food/crop embargos.
This element is not applicable to the licensee emergency plan.
Communications Drills Communications amongst and between emergency response organizations, including those at the state, local, and Federal level, the FMTs, and nuclear facility within both the plume and ingestion exposure pathway N.4.f EPZs, are tested at the frequencies determined in evaluation criterion F.3.
Communications drills include the aspect of understanding the content of messages and can be done in conjunction with the testing described in evaluation criterion F.3.
Each NextEra site will conduct communications drills once per calendar year.
Communications tests described in Element F.3 can be performed as drills provided they include the aspect of understanding the content of messages.
Post-Accident Sampling Drills Post-accident sampling drills are conducted annually. These drills address capabilities including analysis of liquid and N.4.g containment atmosphere samples with simulated elevated radiation levels. This criterion is not applicable if the NPP unit(s) does (do) not have licensing basis requirements for post-accident sampling.
Refer to site annexes for the Post-Accident Sampling Drill requirements.
N.4.h Off-Hours Report-In Drills Off-hours report-in drills are conducted biennially and are unannounced.
Each NextEra site will conduct an off-hours unannounced ERO report-in drill at least once within an eight-year cycle.
The scope of the off-hours unannounced ERO report-in drill will require actual response to the assigned facility.
The Off-Hours Report-In Drill requirement may be satisfied by an actual event provided objectives are evaluated and documented in a critique report.
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73 of 100 Off-Hours Call-In Drills Off-hours call-in drills are conducted quarterly, such that N.4.i each ERO member's normally expected response time is assessed at least biennially based on call-in drill responses or an alternate means for determining response time. Some drills are unannounced.
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The NextEra ERO notification is an all-call process. Each NextEra site will conduct an off-hours unannounced ERO call-in drill biennially to verify each minimum staffing ERO position meets the required Table B-1 response time.
The scope of the off-hours unannounced ERO call-in drill will require collection of the ERO notification system report which documents response within the required time.
Completion of an Element N.4.h off-hours unannounced ERO report-in drill satisfies the requirements of the off-hours unannounced ERO call-in drill in this element.
The Off-Hours Call-In Drill requirement may be satisfied by an actual event provided the objectives are evaluated and documented in a critique report.
N.4.j Onsite Personnel Protective Action Drills Onsite personnel protective action drills are conducted during every eight-year exercise cycle. These drills demonstrate the NPP site's ability to implement and coordinate protective actions for onsite personnel iring hostile action.
Each NextEra site will conduct a protective action drill within an eight-year cycle.
The scope of the protective action drill will demonstrate the ability to implement and coordinate protective actions for onsite personnel during a hostile action using one or more of the following:
Warning personnel in the OCA outside the protected area Evacuation of personnel from target buildings, including security personnel Site evacuation by opening (while continuing to defend) security gates (demonstrated through discussion/table-top)
Dispersal of licensed operators Sheltering of personnel in structures away from potential site targets Arrangements for accounting for personnel after the attack Aircraft Threat/Attack Response Drills Aircraft threat/attack response drills are conducted during every eight-year exercise cycle. These drills demonstrate the use of procedures and protective measures developed for responding to hostile action involving an aircraft threat or attack.
Each NextEra site will conduct an aircraft threat/attack response drill at least once within an eight-year cycle.
This drill may be combined with the beyond design basis demonstration in Element N.3.e.
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inimum Staffing Drills An ERO minimum staffing (no participation of non-inimum augmenting ERO personnel) drill is conducted at least once during every ght-year exercise cycle Each NextEra site will conduct a minimum staffing drill at least once within an eight-year cycle.
A minimum staffing response drill requires facility activation, full transfer of responsibilities from the Control Room, and demonstration of event assessment and response activities.
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Radiological Emergency Response Training PAGE:
75 of 100 Radiological emergency response training is provided to those who may be called on to assist in an emergency.
Regulatory
References:
10 CFR 50.47(b)(15); 44 CFR 350.5(a)(15);
10 CFR Part 50, Appendix E.IV.F 0.1 Each organization ensures the training of emergency responders and other appropriate individuals with an operational role is described in the emergency plan.
Initial training and at least annual retraining are provided.
Initial and continuing training is conducted to ensure ERO personnel are properly qualified to their specific position. Categories of ERO personnel requiring training include:
- 1. Emergency Directors (includes the aspect of classification, notification and PARs)
- 2. Accident Assessment
- 3. ERO Field Monitoring Team Technicians receive initial training for the tasks they will be expected to perform during an emergency. The following general topics will be included in the training:
Equipment and equipment checks Communications Plume tracking techniques Personnel monitoring Emergency exposure criteria Locations and use of radiological emergency equipment
- 4. Repair and Damage Control Teams
- a. Operations, maintenance (including OSC FIN Supervisor), chemistry and radiation protection personnel who would be assigned to repair and damage control teams are trained as part of their normal job-specific duties to respond to both normal and abnormal plant conditions and work under direction of an ERO supervisor in the OSC.
- 5. Security
- a. Security personnel receive emergency plan training as part of their normal job specific training.
- b. Security personnel assigned a specific ERO position receive training on emergency plan related tasks.
- 6. Fire Brigade - Refer to the site fire protection program.
- 7. First Aid - Personnel assigned as first aid responders maintain qualifications equivalent to Red Cross Standard First Aid techniques.
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76 of 100 l
0.1.a Site-specific emergency response training is developed and conducted for those offsite organizations that may be called upon to provide onsite assistance in the event of an emergency.
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NextEra offers emergency response training annually to local support organizations. Training includes basic radiation protection, the notification process for their organization, and their organization's expected role.
The offered training for local support organizations who will enter the site also includes the general site layout, site access procedures, and the identity (by position and title) of the onsite individual who will control their support activities.
e ERO training program consists of learning objectives that are used to develop d maintain key skills. This includes a systematic analysis of jobs and tasks to be rformed from which learning objectives are derived.
The ERO training program is developed and evaluated based on position-specific responsibilities/tasks using Systems Approach to Training (SAT) principles, when applicable.
Q.2.a I The ERO training program is reviewed at least annually and revised as necessary. /
Changes to the training program are identified from trainee feedback and by critique items captured during drills and incorporated per the principles of the SAT process.
Training sessions that provide performance opportunities to develop, maintain, or 0.2.b demonstrate key skills are critiqued in order to identify weak or deficient areas that need correction.
All individuals participating in the ERO training program are given the opportunity to provide feedback of training sessions. Any weak or deficient areas identified and corrected.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 77 of 100 EP-AA-100 P:
Responsibility for the Planning Effort Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.
Regulatory
References:
10 CFR 50.47(b)(16); 44 CFR 350.5(a)(16);
10 CFR Part 50, Appendix E.IV.B and G The training program, including initial training and periodic retraining, of individua~
responsible for the planning effort is described.
Initial EP program training for new EP staff members is performed and documented.
Continuing training for EP staff members is performed periodically through job related opportunities (such as courses, workshops, information exchange meetings with other licensees, conferences held by industry and government agencies, etc.) to maintain current knowledge of the overall planning effort or to enhance working knowledge of plant operations.
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;;--r;he individual with the overall authority and responsibility for radiological emergency response planning is identified by title/position.
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The Chief Nuclear Officer has the overall authority and responsibility for the NextEra Common Emergency Plan.
P.3 The individual(s) with the responsibility for the development, maintenance, review, updating, and distribution of emergency plans, as well as the coordination of these plans with other response organizatjons, is ide~tified by title/position.
The site Regulatory Affairs Managers are responsible for the development, maintenance, review, and updating of the emergency plan, as well as the coordination of the plan with other response organizations.
~-T-h_e_p-ro_c_e--ss_fo_r_r_e_v_i-ew-in--g*--a--n--n-u_a_ll_y_, a-n-d-up_d_a_t-in_g_a_s_n_e_c_e_s_s-ar_y_, -th_e_e--m-e-rg-en_c_y ___ _
plan, implementing procedures, maps, charts, and agreements is described. The P.4----'--_p_ro_c_e_s--'-s--'-in_c--'-lu_d_e_s_a_m_e_th_o_d_f_o_r_re_c_o.c_rd_i_n_g_c_h_a_n_ge_s_m_a_d_e __ to __ t_h_e_d_o_c __ u_m_e_n_t_s_a_n_d_, -~
when appropriate, how those changes are retained.
The formal emergency plan (as defined in the introduction section) and the emergency plan implementing procedures (as defined in Section P.7) will be reviewed on an annual basis and updated if necessary. Any changes to regulations, issues identified by drills and exercises, assessments and audits, or other updates will be evaluated and incorporated into the emergency plan if warranted.
Letters of Agreement will be reviewed and verified on an annual basis, and updated if warranted.
Changes will be processed in accordance with 10 CFR 50.54(q) requirements and NextEra document control/records management procedures.
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NEXTERA COMMON EMERGENCY PLAN 78 of 100 EP-AA-100 NUCLEAR FLEET Provisions for distributing the emergency plan and implementing procedures to all P.5 organizations and appropriate individuals with responsibility for implementation of the plan/procedures is described.
Revised copies of the emergency plan are posted and distributed in accordance with NextEra records management system procedures.
Changes to the emergency plan are submitted to the NRC in accordance with 10 CFR 50.4.
P.6 A listing of annexes, appendices, and supporting plans and their originating agenc~
is included in the emergency plan.
Refer to Introduction Section for a listing of emergency plan extension documents (documents that are considered part of the emergency plan but are maintained separately).
Emergency plans developed by other agencies that support the NextEra Common Emergency Plan include the following:
Department of Homeland Security National Response Framework U.S. Nuclear Regulatory Commission Incident Response Plan Plans for organizations that support individual sites are listed in the site annexes.
An appendix containing a listing by title of the procedures required to maintain and P.7 implement the emergency plan is included. The listing includes the section(s) of the emergency plan to be implemented by each procedure.
__J Table P.7-1 provides a listing, by title, of the common response and maintenance procedures required to implement the emergency plan, and the section(s) of the emergency plan to be implemented by each procedure.
A listing, by title, of the site-specific response and maintenance procedures required to implement the emergency plan is provided in the site annexes.
A table of contents and a cross-reference index to each of the NU REG-P.8 0654/FEMA-REP-1, Rev. 2 evaluation criteria are included. The evaluation criteria that do not apply are identified.
The NextEra emergency plan contains a specific table of contents. The emergency plan paragraphs are numbered corresponding to the NUREG-0654/FEMA-REP-1 R2 evaluation criteria. Evaluation criteria which do not apply to utilities are listed and identified.
I P.9 I Provisions for addressing the requirements of 10 CFR 50.54(t) are described.
I Emergency preparedness program elements are reviewed by persons that have no direct responsibility for the implementation of the emergency preparedness program, in accordance with 10 CFR 50.54(t).
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 79 of 100 EP-AA-100 P.10 The administrative process for the periodic review and updating of contact information identified in the emergency plan and implementing procedures is described.
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The NextEra emergency communications directory contains select contact numbers for ORO and support organizations identified in the emergency plan and implementing procedures. The ERO call-out system contains comprehensive ERO contact information.
NextEra ERO contact information is verified semi-annually and updated as needed.
Facility and support contact information in the emergency communications directory is verified annually and updated as needed.
P.11 The process for entering EP program-related issues that could reduce the effectiveness of the emergency plan into the site-wide corrective action program is described.
The NextEra corrective action program is used to capture all events that do not meet program regulations, requirements, standards, or are otherwise conditions adverse to quality.
Changes in plant configuration are evaluated for their impact on the effectiveness of the emergency plan through the plant modification or license compliance review processes specified in change procedures and, if required, the 10 CFR 50.54(q) change evaluation process.
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NEXTERA COMMON EMERGENCY PLAN 80 of 100 EP-AA-100 NUCLEAR FLEET Table P.7-1: Emergenc)l Plan lm~lementing Procedures Plan Sections Document ID Document title Implemented
[To be developed following E-Plan approval]
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EP-AA-100 Appendix 1 Definitions NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET 81 of 100 Accident: any unforeseen, or unintentional occurrence or mishap resulting in, or potentially resulting in, physical injury or injury due to radiation exposure or excessive exposure to radioactive materials.
Activated: an emergency response facility is declared activated when minimum staffing requirements are met, key systems and equipment are verified operational, and the ERO personnel are prepared to perform their functions.
Annual: For drills and exercise periodicity, annual is once per calendar year. For training and qualification periodicity and work products, annual is every 12 months not to exceed 15 months.
Concept of Operations: delineation of an organization's roles and responsibilities and how the organization will function to accomplish those responsibilities.
Dosimeter: an instrument used to measure and record radiation doses or dose rates.
Emergency Operations Center (EOC): a facility that is the primary base of emergency operations for an ORO in a radiological incident.
Emergency Planning Zone (EPZ): a geographic area surrounding a commercial NPP for which emergency planning is needed to ensure that prompt and effective actions can be taken by OROs to protect public health and safety in the event of a radiological incident. The plume exposure pathway EPZ is approximately 10 miles in radius, while the ingestion exposure pathway EPZ has a radius of approximately 50 miles.
Emergency Response Data System (EROS): a direct near real-time electronic data link between the licensee's onsite computer system and the NRC Operations Center that provides for the automated transmission of a limited data set of selected plant parameters.
Emergency Response Organization (ERO): the personnel assigned to perform tasks and activities associated with implementation of a licensee's emergency plan for coping with radiological incidents.
Evacuation Time Estimate (ETE): a calculation of the time it would take to evacuate the public within the plume exposure pathway EPZ under emergency conditions.
Evaluation: the process of observing drill or exercise performance to identify strengths and opportunities for improvement in an entity's emergency preparedness and response capabilities.
Field Monitoring Team (FMT): a group used to detect and monitor radiation in the environment.
Ingestion Exposure Pathway: the principal exposure from this pathway would be from ingestion of contaminated water or foods, such as milk or fresh vegetables.
Ingestion Exposure Pathway Emergency Planning Zone: a geographic area, approximately 50 miles in radius surrounding a commercial NPP.
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NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Appendix 1 Definitions PAGE:
82 of 100 Letter of Agreement (LOA): a document executed between two or more parties outlining specific arrangements relating to the accomplishment of an action. Letters of agreement may cover personnel, equipment, or other types of emergency support, and may take the form of letters, contracts, purchase orders, or other procurement mechanisms.
Memorandum of Understanding (MOU): a document which details the respective authorities and responsibilities of the signatory organizations for specified radiological emergency response planning, preparedness, or response.
Offsite Response Organization (ORO): state, tribal, or local governmental organization that is responsible for carrying out emergency response functions during a radiological emergency.
Offsite: the area outside the Protected Area.
Onsite: the area inside the Protected Area.
Owner Controlled Area (OCA): That portion of company property surrounding and including the station which is subject to limited access and control as deemed appropriate.
Planning Standard (PS): one of the 16 emergency preparedness planning standards established in 1 O CFR 50.47(b) that the emergency plan must meet and which are supported by the corresponding sections of 10 CFR 50 Appendix E.
Plume Exposure Pathway: a term describing the means by which whole body radiation exposure occurs as a result of immersion in a gaseous release of radioactive material. The principal exposure sources from this pathway are: (a) whole body external exposure to gamma radiation from the plume and from deposited materials, and (b) inhalation exposure from the passing radioactive plume. The duration of principal potential exposures could range in length from 30 minutes to days.
Plume Exposure Pathway Emergency Planning Zone: a geographic area approximately 1 O miles in radius surrounding a commercial NPP.
Post-Plume Phase: includes response activities that occur after a release has been terminated.
Also known as the "Environmental Phase".
Potassium Iodide (Kl): a prophylactic compound containing a stable (i.e., non-radioactive) form of iodine that can be used effectively to block the uptake of radioactive iodine by the thyroid gland in a human being.
Protected Area: the area (within the Owner Controlled Area) occupied by the nuclear unit(s) and associated equipment and facilities enclosed within the security perimeter fence. The area within which accountability of personnel is maintained in an emergency when required.
Protective Action Guide (PAG): The projected dose to an individual, resulting from a radiological incident at which a specific protective action to reduce or avoid that dose is warranted.
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83 of 100 Protective Action Recommendation (PAR): a formal advisement from a NPP licensee to state and/or county government officials, or from state officials to other offsite officials, concerning emergency measures that should be taken to protect the public from exposure to radiation.
Radioprotective Drug: a chemical compound or substance serving to protect or aid in protecting against the injurious effects of radiation.
Reasonable Assurance: a determination that ORO and utility plans and preparedness are adequate to protect public health and safety in the emergency planning areas of commercial NPPs.
Reception Center: a pre-designated facility located outside the plume exposure pathway EPZ at which the evacuated public can register; receive radiation monitoring and decontamination; receive assistance in contacting others; receive directions to congregate care centers; reunite with others; and receive general information. It generally refers to a facility where monitoring, decontamination, and registration of evacuees are conducted. A reception center is also referred to as a registration center or public registration and decontamination center.
Site Boundary: the line beyond which the land or property is not owned or controlled by the licensee.
Thyroid Committed Dose Equivalent (CDE): the dose to the thyroid that will be received from an intake of radioactive material by an individual during the 50-year period following the intake (10 CFR 20.1003).
Total Effective Dose Equivalent (TEDE): the sum of the deep dose equivalent (for external exposures) and committed effective dose equivalent (for internal exposures).
Transient Population: persons who do not permanently reside in the plume exposure pathway EPZ, but may be present during an emergency.
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NEXTERA COMMON EMERGENCY PLAN 84 of 100 EP-AA-100 NUCLEAR FLEET Appendix 2 Abbreviations and Acronyms AOP Abnormal Operating Procedures ANSI American Nuclear Standards Institute CFR Code of Federal Regulations CR Control Room DLR Dosimeter of Legal Record (synonymous with TLD)
DRD Direct-reading Dosimeter EAL Emergency Action Level EAS Emergency Alert System ECL Emergency Classification Level ENS Emergency Notification System EOC Emergency Operations Center EOF Emergency Operations Facility EP Emergency Preparedness EPA Environmental Protection Agency EPZ Emergency Planning Zone ERDS Emergency Response Data System ERF Emergency Response Facility ERO Emergency Response Organization ETE Evacuation Time Estimate FEMA Federal Emergency Management Agency FLEX Diverse and Flexible Coping Strategies FMT Field Monitoring Team GE General Emergency HAB Hostile Action-Based HPN Health Physics Network l&C Instrumentation and Control ICP Incident Command Post IT Information Technology JIC Joint Information Center JIS Joint Information System Kl Potassium Iodide LLEA Local Law Enforcement Agency LOA Letter of Agreement MOU Memorandum of Understanding NEI Nuclear Energy Institute NPP Nuclear Power Plant NRC Nuclear Regulatory Commission OCA Owner Controlled Area ORO Offsite Response Organization
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NEXTERA COMMON EMERGENCY PLAN 85 of 100 EP-AA-100 NUCLEAR FLEET Appendix 2 Abbreviations and Acronyms osc Operations Support Center PAD Protective Action Decision PAG Protective Action Guide PAR Protective Action Recommendation HAB Hostile Action-Based REP Radiological Emergency Preparedness RWP Radiation Work Permit SAE Site Area Emergency TEDE Total Effective Dose Equivalent TLD Thermoluminescent Dosimeter (synonymous with DLR)
TSC Technical Support Center UE Unusual Event
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Appendix 3 1 O CFR 50 Appendix E.IV Cross-Reference 86 of 100
- 1. The applicant's emergency plans shall contain, but not necessarily be limited to, information needed to demonstrate compliance with the elements set forth below, i.e., organization for coping with radiological emergencies, assessment actions, activation of emergency organization, notification procedures, emergency facilities and equipment, training, maintaining emergency preparedness, recovery, and onsite protective actions during hostile action.
Regulatory Criteria E-Plan
- 2. This nuclear power reactor license applicant shall also provide an analysis of J.8 the time required to evacuate various sectors and distances within the plume exposure pathway EPZ for transient and permanent populations, using the most recent U.S. Census Bureau data as of the date the applicant submits its application to the NRC.
- 3. Nuclear power reactor licensees shall use NRC approved evacuation time J.8 estimates (ETEs) and updates to the ETEs in the formulation of protective action recommendations and shall provide the ETEs and ETE updates to State and local governmental authorities for use in developing offsite protective action strategies.
and shall provide the ETEs and ETE updates to State and local governmental J.7 authorities for use in developing offsite protective action strategies.
- 4. Within 365 days of the later of the date of the availability of the most recent J.8.a decennial census data from the U.S. Census Bureau or December 23, 2011, nuclear power reactor licensees shall develop an ETE analysis using this decennial data and submit it under§ 50.4 to the NRC. These licensees shall submit this ETE analysis to the NRC at least 180 days before using it to form protective action recommendations and providing it to state and local governmental authorities for use in developing offsite protective action strategies.
- 5. During the years between decennial censuses, nuclear power reactor licensees J.8.a shall estimate EPZ permanent resident population changes once a year, but no later than 365 days from the date of the previous estimate, using the most recent U.S. Census Bureau annual resident population estimate and state/local government population data, if available. These licensees shall maintain these estimates so that they are available for NRC inspection during the period between decennial censuses and shall submit these estimates to the NRC with any updated ETE analysis.
- 6. If at any time during the decennial period, the EPZ permanent resident J.8.a population increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone, including all affected Emergency Response Planning Areas, or for the entire 10-mile EPZ to increase by 25 percent or 30 minutes, whichever is less, from the nuclear power reactor licensee's currently NRC approved or updated ETE, the licensee shall update the ETE analysis to reflect the impact of that population increase.
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Appendix 3 10 CFR 50 Appendix E.IV Cross-Reference Regulatory Criteria The licensee shall submit the updated ETE analysis to the NRC under § 50.4 no later than 365 days after the licensee's determination that the criteria for updating the ETE have been met and at least 180 days before using it to form protective action recommendations and providing it to state and local governmental authorities for use in developing offsite protective action strategies.
- 7. After an applicant for a combined license under part 52 of this chapter receives its license, the licensee shall conduct at least one review of any changes in the population of its EPZ at least 365 days prior to its scheduled fuel load. The licensee shall estimate EPZ permanent resident population changes using the most recent U.S. Census Bureau annual resident population estimate and state/local government population data, if available. If the EPZ permanent resident population increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone, including all affected Emergency Response Planning Areas, or for the entire 10-mile EPZ, to increase by 25 percent or 30 minutes, whichever is less, from the licensee's currently approved ETE, the licensee shall update the ETE analysis to reflect the impact of that population increase. The licensee shall submit the updated ETE analysis to the NRC for review under§ 50.4 of this chapter no later than 365 days before the licensee's scheduled fuel load.
10 CFR 50 Appendix E.IV.A-Organization 87 of 100 E-Plan J.8.a N/A The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:
Regulatory Criteria E-Plan
- 1. A description of the normal plant operating organization.
B.1.a
- 2. A description of the onsite ERO with a detailed discussion of:
- a. Authorities, responsibilities, and duties of the individual(s) who will take B.1.a charge during an emergency; B.2 B.2.a
- b. Plant staff emergency assignments; B.1.a
- c. Authorities, responsibilities, and duties of an onsite emergency coordinator B.1.a who shall be in charge of the exchange of information with offsite B.2 authorities responsible for coordinating and implementing offsite B.2.a emergency measures.
- 3. A description, by position and function to be performed, of the licensee's N/A headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.
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- 4. Identification, by position and function to be performed, of persons within the 8.1.a licensee organization who will be responsible for making offsite dose projections, and a description of how these projections will be made 1.6 and the results transmitted to state and local authorities, NRC, and other E.3 appropriate governmental entities.
1.10
- 5. Identification, by position and function to be performed, of other employees of 8.1.a the licensee with special qualifications for coping with emergency conditions that may arise.
Other persons with special qualifications, such as consultants, who are not 8.5 employees of the licensee and who may be called upon for assistance for emergencies shall also be identified. The special qualifications of these persons shall be described.
- 6. A description of the local offsite services to be provided in support of the A.1.a (5) licensee's emergency organization.
- 7. By June 23, 2014, identification of, and a description of the assistance A.4 expected from, appropriate state, local, and federal agencies with responsibilities for coping with emergencies, including hostile action at the site.
For purposes of this appendix, "hostile action" is defined as an act directed toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force.
- 8. Identification of the state and/or local officials responsible for planning for, A.1.a.3 ordering, and controlling appropriate protective actions, including evacuations when necessary.
- 9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis B.1.a demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Appendix 3 10 CFR 50 Appendix E.IV Cross-Reference 10 CFR 50 Appendix E.IV.8 -Assessment Actions 89 of 100 Regulatory Criteria E-Plan
- 1. The means to be used for determining the magnitude of, and for continually 1.4 assessing the impact of, the release of radioactive materials shall be described, 1.4.a including emergency action levels that are to be used as criteria for determining 1.6 the need for notification and participation of local and state agencies, the Commission, and other federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety.
The emergency action levels shall be based on in-plant conditions and D.1.a instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant.
The initial emergency action levels shall be discussed and agreed on by the D.1.b applicant or licensee and state and local governmental authorities, and approved by the NRC.
Thereafter, emergency action levels shall be reviewed with the state and local D.1.b governmental authorities on an annual basis.
- 2. A licensee desiring to change its entire emergency action level scheme shall D.1.a submit an application for an amendment to its license and receive NRC approval before implementing the change.
Licensees shall follow the change process in § 50.54(q) for all other emergency P.4 action level changes.
10 CFR 50, Appendix E.IV.C - Activation of Emergency Organization Regulatory Criteria E-Plan
- 1. The entire spectrum of emergency conditions that involve the alerting or D.1 activating of progressively larger segments of the total emergency organization D.3 shall be described.
The communication steps to be taken to alert or activate emergency personnel E.1.1 under each class of emergency shall be described.
Emergency action levels (based not only on onsite and offsite radiation D.1 monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described.
The existence, but not the details, of a message authentication scheme shall E.1.a be noted for such agencies.
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Appendix 3 10 CFR 50 Appendix E.IV Cross-Reference Regulatory Criteria The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG-0654/FEMA-REP-1.
- 2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded.
90 of 100 E-Plan D. 1 D.2 Site EAL TBD Licensees shall not construe these criteria as preventing implementation of Site EAL response actions deemed by the licensee to be necessary to protect public TBD health and safety provided that any delay in declaration does not deny the state and local authorities the opportunity to implement measures necessary to protect the public health and safety.
10 CFR 50, Appendix E.IV.D - Notification Procedures Regulatory Criteria E-Plan
- 1. Administrative and physical means for notifying local, state, and federal officials E.2 and agencies and agreements reached with these officials and agencies for the prompt notification of the public and for public evacuation or other protective measures, should they become necessary, shall be described. This description shall include identification of the appropriate officials, by title and agency, of the state and local government agencies within the EPZs.
- 2. Provisions shall be described for yearly dissemination to the public within the G.1 plume exposure pathway EPZ of basic emergency planning information, such as the methods and times required for public notification and the protective actions planned if an accident occurs, general information as to the nature and effects of radiation, and a listing of local broadcast stations that will be used for dissemination of information during an emergency.
Signs or other measures shall also be used to disseminate to any transient G.1 population within the plume exposure pathway EPZ appropriate information that would be helpful if an accident occurs.
- 3. A licensee shall have the capability to notify responsible state and local E.1.b governmental agencies within 15 minutes after declaring an emergency.
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Appendix 3 10 CFR 50 Appendix E.IV Cross-Reference 91 of 100 Regulatory Criteria E-Plan The licensee shall demonstrate that the appropriate governmental authorities E.2 have the capability to make a public alerting and notification decision promptly on being informed by the licensee of an emergency condition.
Prior to initial operation greater than 5 percent of rated thermal power of the N/A first reactor at a site, each nuclear power reactor licensee shall demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ.
The design objective of the prompt public alert and notification system shall be E.2 to have the capability to essentially complete the initial alerting and initiate notification of the public within the plume exposure pathway EPZ within about 15 minutes. The use of this alerting and notification capability will range from immediate alerting and notification of the public (within 15 minutes of the time that state and local officials are notified that a situation exists requiring urgent action) to the more likely events where there is substantial time available for the appropriate governmental authorities to make a judgment whether or not to activate the public alert and notification system.
The alerting and notification capability shall additionally include administrative E.2 and physical means for a backup method of public alerting and notification capable of being used in the event the primary method of alerting and notification is unavailable during an emergency to alert or notify all or portions of the plume exposure pathway EPZ population. The backup method shall have the capability to alert and notify the public within the plume exposure pathway EPZ, but does not need to meet the 15-minute design objective for the primary prompt public alert and notification system.
When there is a decision to activate the alert and notification system, the N/A appropriate governmental authorities will determine whether to activate the entire alert and notification system simultaneously or in a graduated or staged manner. The responsibility for activating such a public alert and notification system shall remain with the appropriate governmental authorities.
1 O CFR 50, Appendix E.IV.E - Emergency Facilities and Equipment Adequate provisions shall be made and described for emergency facilities and equipment, including:
Regulatory Criteria E-Plan
- 1. Equipment at the site for personnel monitoring; K.1.b K.1.c
- 2. Equipment for determining the magnitude of and for continuously assessing the 1.6 impact of the release of radioactive materials to the environment; I. 7 1.8 H.7
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- 3. Facilities and supplies at the site for decontamination of onsite individuals;
- 4. Facilities and medical supplies at the site for appropriate emergency first aid treatment;
- 5. Arrangements for medical service providers qualified to handle radiological emergencies onsite;
- 6. Arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary;
- 7. Arrangements for treatment of individuals injured in support of licensed activities on the site at treatment facilities outside the site boundary; 92 of 100 E-Plan J.3 K.1.e L.2.a L.2.b L.4 L.2.b 8.a (i) A licensee onsite technical support center and an emergency operations H.1 facility from which effective direction can be given and effective control can H.3 be exercised during an emergency; 8.a (ii) For nuclear power reactor licensees, a licensee onsite operational support H.2 center; 8.b For a nuclear power reactor licensee's EOF required by paragraph 8.a of this H.3 section, either a facility located between 10 miles and 25 miles of the nuclear power reactor site(s), or a primary facility located less than 10 miles from the nuclear power reactor site(s) and a backup facility located between 10 miles and 25 miles of the nuclear power reactor site(s). An EOF may serve more than one nuclear power reactor site. A licensee desiring to locate an EOF more than 25 miles from a nuclear power reactor site shall request prior Commission approval by submitting an application for an amendment to its license.
For an EOF located more than 25 miles from a nuclear power reactor site, H.3.a provisions must be made for locating NRC and offsite responders closer to the nuclear power reactor site so that NRC and offsite responders can interact face-to-face with emergency response personnel entering and leaving the nuclear power reactor site. Provisions for locating NRC and offsite responders closer to a nuclear power reactor site that is more than 25 miles from the EOF must include the following:
(1) Space for members of an NRC site team and federal, state, and local C.5 responders; (2) Additional space for conducting briefings with emergency response C.5 personnel; (3) Communication with other licensee and offsite emergency response C.5 facilities;
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Appendix 3 10 CFR 50 Appendix E.IV Cross-Reference Regulatory Criteria (4) Access to plant data and radiological information; and (5) Access to copying equipment and office supplies; 8.c By June 20, 2012, for a nuclear power reactor licensee's EOF required by paragraph 8.a of this section, a facility having the following capabilities:
93 of 100 E-Plan C.5 C.5 (1) The capability for obtaining and displaying plant data and radiological H.3 information for each reactor at a nuclear power reactor site and for each nuclear power reactor site that the facility serves; (2) The capability to analyze plant technical information and provide technical H.3 briefings on event conditions and prognosis to licensee and offsite response organizations for each reactor at a nuclear power reactor site and for each nuclear power reactor site that the facility serves; and (3) The capability to support response to events occurring simultaneously at H.3 more than one nuclear power reactor site if the emergency operations facility serves more than one site; and 8.d For nuclear power reactor licensees, an alternative facility (or facilities) that H.4 would be accessible even if the site is under threat of or experiencing hostile action, to function as a staging area for augmentation of emergency response staff and collectively having the following characteristics:
the capability for communication with the EOF, Control Room, and plant H.4 security; the capability to perform offsite notifications; H.4 and the capability for engineering assessment activities, including damage H.3.b control team planning and preparation, for use when onsite emergency H.4 facilities cannot be safely accessed during hostile action.
The requirements in this paragraph 8.d must be implemented no later than N/A December 23, 2014, with the exception of the capability for staging emergency response organization personnel at the alternative facility ( or facilities) and the capability for communications with the emergency operations facility, Control Room, and plant security, which must be implemented no later than June 20, 2012.
8.e A licensee shall not be subject to the requirements of paragraph 8.b of this N/A section for an existing EOF approved as of December 23, 2011.
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- 9. At least one onsite and one offsite communications system; each system shall have a backup power source.
All communication plans shall have arrangements for emergencies, including titles and alternates for those in charge at both ends of the communication links and the primary and backup means of communication. Where consistent with the function of the governmental agency, these arrangements will include:
- a. Provision for communications with contiguous state/local governments within the plume exposure pathway EPZ.
Such communications shall be tested monthly.
- b. Provision for communications with federal emergency response organizations.
Such communications systems shall be tested annually.
- c.
Provision for communications among the nuclear power reactor control room, the onsite TSC, and the EOF; and among the nuclear facility, the principal state and local emergency operations centers, and the field assessment teams.
Such communications systems shall be tested annually.
94 of 100 E-Plan F.1.a E.1 E.1 F.1.a F.3 E.1 F.1.a F.3 F.1 F.3
- d. Provisions for communications by the licensee with NRC Headquarters and E.1 the appropriate NRC Regional Office Operations Center from the nuclear F.1 power reactor control room, the onsite TSC, and the EOF.
Such communications shall be tested monthly.
10 CFR 50, Appendix E.IV.F -Training Regulatory Criteria
- 1. The program to provide for:
F.3 E-Plan (a) The training of employees and exercising, by periodic drills, of emergency N.4 plans to ensure that employees of the licensee are familiar with their 0.1 specific emergency response duties, and (b) The participation in the training and drills by other persons whose N.4.a assistance may be needed in the event of a radiological emergency shall 0.1.a be described.
This shall include a description of specialized initial training and periodic 0.1 retraining programs to be provided to each of the following categories of emergency personnel:
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- i.
Directors and/or coordinators of the plant emergency organization; ii.
Personnel responsible for accident assessment, including control room shift personnel; iii. Radiological monitoring teams; iv. Fire control teams (fire brigades);
- v. Repair and damage control teams; vi. First aid and rescue teams; vii. Medical support personnel; viii. Licensee's headquarters support personnel; ix. Security personnel.
In addition, a radiological orientation training program shall be made available to local services personnel; e.g., local emergency services/Civil Defense, local law enforcement personnel, local news media persons.
- 2. The plan shall describe provisions for the conduct of emergency preparedness exercises as follows: Exercises shall test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communications networks, test the public alert and notification system, and ensure that emergency organization personnel are familiar with their duties.
2.a A full participation exercise which tests as much of the licensee, state, and local emergency plans as is reasonably achievable without mandatory public participation shall be conducted for each site at which a power reactor is located.
Nuclear power reactor licensees shall submit exercise scenarios under § 50.4 at least 60 days before use in a full participation exercise required by this paragraph 2.a.
95 of 100 E-Plan 0.1 (1) 0.1 (2) 0.1 (3) 0.1 (6) 0.1 (4) 0.1 (7) 0.1 (6) 0.1.a N/A 0.1 (5) 0.1.a G.5 N.1 N.2.a N.2.a
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Appendix 3 10 CFR 50 Appendix E.IV Cross-Reference 96 of 100 Regulatory Criteria E-Plan (i) For an operating license issued under this part, this exercise must be N/A conducted within 2 years before the issuance of the first operating license for full power (one authorizing operation above 5 percent of rated thermal power) of the first reactor and shall include participation by each state and local government within the plume exposure pathway EPZ and each state within the ingestion exposure pathway EPZ. If the full participation exercise is conducted more than 1 year prior to issuance of an operating licensee for full power, an exercise which tests the licensee's onsite emergency plans must be conducted within one year before issuance of an operating license for full power. This exercise need not have state or local government participation.
(ii) For a combined license issued under part 52 of this chapter, this exercise N/A must be conducted within two years of the scheduled date for initial loading of fuel. If the first full participation exercise is conducted more than one year before the scheduled date for initial loading of fuel, an exercise which tests the licensee's onsite emergency plans must be conducted within one year before the scheduled date for initial loading of fuel. This exercise need not have state or local government participation. If FEMA identifies one or more deficiencies in the state of offsite emergency preparedness as the result of the first full participation exercise, or if the Commission finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, the provisions of§ 50.54(gg) apply.
(iii) For a combined license issued under part 52 of this chapter, if the applicant N/A currently has an operating reactor at the site, an exercise, either full or partial participation, shall be conducted for each subsequent reactor constructed on the site. This exercise may be incorporated in the exercise requirements of Sections IV.F.2.b. and c. in this appendix. If FEMA identifies one or more deficiencies in the state of offsite emergency preparedness as the result of this exercise for the new reactor, or if the Commission finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, the provisions of§ 50.54(gg) apply.
2.b Each licensee at each site shall conduct a subsequent exercise of its onsite N.2.a emergency plan every 2 years.
Nuclear power reactor licensees shall submit exercise scenarios under§ 50.4 N.2.a at least 60 days before use in an exercise required by this paragraph 2.b.
The exercise may be included in the full participation biennial exercise required N.2.a by paragraph 2.c. of this section.
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Appendix 3 10 CFR 50 Appendix E.IV Cross-Reference 97 of 100 Regulatory Criteria E-Plan In addition, the licensee shall take actions necessary to ensure that adequate N.4 emergency response capabilities are maintained during the interval between biennial exercises by conducting drills, including at least one drill involving a combination of some of the principal functional areas of the licensee's onsite emergency response capabilities. The principal functional areas of emergency response include activities such as management and coordination of emergency response, accident assessment, event classification, notification of offsite authorities, assessment of the onsite and offsite impact of radiological releases, protective action recommendation development, protective action decision making, plant system repair and mitigative action implementation.
During these drills, activation of all of the licensee's emergency response facilities (TSC, OSC, and the EOF) would not be necessary, licensees would have the opportunity to consider accident management strategies, supervised instruction would be permitted, operating staff in all participating facilities would have the opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills may focus on the onsite exercise training objectives.
2.c Offsite plans for each site shall be exercised biennially with full participation by N.2.a each offsite authority having a role under the radiological response plan. Where the offsite authority has a role under a radiological response plan for more than one site, it shall fully participate in one exercise every two years and shall, at least, partially participate in other offsite plan exercises in this period.
If two different licensees each have licensed facilities located either on the N/A same site or on adjacent, contiguous sites, and share most of the elements defining co-located licensees, then each licensee shall:
(1) Conduct an exercise biennially of its onsite emergency plan; N/A (2) Participate quadrennially in an offsite biennial full or partial participation N/A exercise; (3) Conduct emergency preparedness activities and interactions in the years N/A between its participation in the offsite full or partial participation exercise with offsite authorities, to test and maintain interface among the affected state and local authorities and the licensee. Co-located licensees shall also participate in emergency preparedness activities and interaction with offsite authorities for the period between exercises; (4) Conduct a hostile action exercise of its onsite emergency plan in each N/A exercise cycle; and (5) Participate in an offsite biennial full or partial participation hostile action N/A exercise in alternating exercise cycles.
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Appendix 3 10 CFR 50 Appendix E.IV Cross-Reference 98 of 100 Regulatory Criteria E-Plan 2.d Each state with responsibility for nuclear power reactor emergency N/A preparedness should fully participate in the ingestion pathway portion of exercises at least once every exercise cycle. In states with more than one nuclear power reactor plume exposure pathway EPZ, the state should rotate this participation from site to site.
Each state with responsibility for nuclear power reactor emergency N/A preparedness should fully participate in a hostile action exercise at least once every cycle and should fully participate in one hostile action exercise by December 31, 2015. States with more than one nuclear power reactor plume exposure pathway EPZ should rotate this participation from site to site.
2.e Licensees shall enable any state or local government located within the plume N.1 exposure pathway EPZ to participate in the licensee's drills when requested by such State or local government.
2.f Remedial exercises will be required if the emergency plan is not satisfactorily N.1.a tested during the biennial exercise, such that NRC, in consultation with FEMA, cannot (1) find reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency or (2) determine that the Emergency Response Organization (ERO) has maintained key skills specific to emergency response. The extent of state and local participation in remedial exercises must be sufficient to show that appropriate corrective measures have been taken regarding the elements of the plan not properly tested in the previous exercises.
2.g All exercises, drills, and training that provide performance opportunities to N.1 develop, maintain, or demonstrate key skills must provide for formal critiques in order to identify weak or deficient areas that need correction.
Any weaknesses or deficiencies that are identified in a critique of exercises, N.1.b drills, or training must be corrected.
2.h The participation of state and local governments in an emergency exercise is N.2.a not required to the extent that the applicant has identified those governments as refusing to participate further in emergency planning activities, pursuant to § 50.47(c)(1). In such cases, an exercise shall be held with the applicant or licensee and such governmental entities as elect to participate in the emergency planning process.
2.i Licensees shall use drill and exercise scenarios that provide reasonable N.3 assurance that anticipatory responses will not result from preconditioning of N.4 participants. Such scenarios for nuclear power reactor licensees must include a wide spectrum of radiological releases and events, including hostile action.
Exercise and drill scenarios as appropriate must emphasize coordination among onsite and offsite response organizations.
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EP-AA-100 NEXTERA COMMON EMERGENCY PLAN NUCLEAR FLEET Appendix 3 10 CFR 50 Appendix E.IV Cross-Reference Regulatory Criteria 2.j(i) The exercises conducted under paragraph 2 of this section by nuclear power reactor licensees must provide the opportunity for the ERO to demonstrate proficiency in the key skills necessary to implement the principal functional areas of emergency response identified in paragraph 2.b of this section.
j(ii) Each exercise must provide the opportunity for the ERO to demonstrate key skills specific to emergency response duties in the control room, TSC, OSC, EOF, and JIC.
99 of 100 E-Plan N.1 N.2.a N.1 j(iii) In each 8-calendar-year exercise cycle, nuclear power reactor licensees shall N.3 vary the content of scenarios during exercises conducted under paragraph 2 of this section to provide the opportunity for the ERO to demonstrate proficiency in the key skills necessary to respond to the following scenario elements:
(1) hostile action directed at the plant site, N.3.a (2) No radiological release or an unplanned minimal radiological release that N.3.c does not require public protective actions; (3) An initial classification of or rapid escalation to a Site Area Emergency or N.3.b General Emergency; (4) Implementation of strategies, procedures, and guidance developed under N.3.e
§50.155(b)(2); and (5) Integration of offsite resources with onsite response.
N.3.d j(iv) The licensee shall maintain a record of exercises conducted during each 8-N.3 year exercise cycle that documents the content of scenarios used to comply with the requirements of section IV.F.2.j of this appendix.
j(v) Each licensee shall conduct a hostile action exercise for each of its sites no N/A later than December 31, 2015.
j(vi) The first 8-year exercise cycle for a site will begin in the calendar year in N/A which the first hostile action exercise is conducted. For a site licensed under 10 CFR part 52, the first 8-year exercise cycle begins in the calendar year of the initial exercise required by section IV.F.2.a of this appendix.
10 CFR 501 Appendix E.IV.G-Maintaining Emergency Preparedness Regulatory Criteria Provisions to be employed to ensure that the emergency plan, its implementing procedures, and emergency equipment and supplies are maintained up to date shall be described.
E-Plan P.4 P.9 P.10 P.11 P.12
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100 of 100 Regulatory Criteria E-Plan Criteria to be used to determine when, following an accident, reentry of the facility M.1 would be appropriate or when operation could be resumed shall be described.
10 CFR 50, Appendix E.IV.I - Onsite Protective Actions During Hostile Action Regulatory Criteria E-Plan By June 20, 2012, for nuclear power reactor licensees, a range of protective J.1 actions to protect onsite personnel during hostile action must be developed to ensure the continued ability of the licensee to safely shut down the reactor and perform the functions of the licensee's emergency plan.