ML24361A123
| ML24361A123 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/22/2025 |
| From: | Michael Waters Policy and Oversight Branch |
| To: | Federal Emergency Management Agency |
| References | |
| Download: ML24361A123 (1) | |
Text
Stephanie Dobitsch Assistant Administrator National Preparedness Directorate Federal Emergency Management Agency 400 C Street, SW Washington, DC 20024
SUBJECT:
Donald C. Cook Nuclear Plant Alert and Notification System (ANS) Evaluation Report
Dear Ms. Dobitsch:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated September 30, 2024, which provided the Federal Emergency Management Agency (FEMA) approval of Revision 3 of the Donald C. Cook Nuclear Plant (CNP) Alert and Notification System (ANS) Design Report which was received on October 1, 2024.1 As described in Revision 3 of the CNP ANS Design Report, the station selected a mass notification system (MNS) as the backup alerting and notification method for the 10-mile emergency planning zone (EPZ). The CNP also proposes its intention to continue its use of the Integrated Public Alert and Warning System (IPAWS) - Wireless Emergency Alert and (WEA)/IPAWS - Emergency Alert System concurrently as the primary ANS for the CNP 10-mile EPZ. The revised CNP ANS Plan and design report further stipulates that the MNS will be the back-up alerting and notification method to IPAWS in lieu of route alerting which will no longer be used as the back-up ANS. Furthermore, the back-up alerting system will utilize the MNS vendors National Life Safety Database, which contains over 265 million landlines, Voice over Internet Protocol (VoIP), and mobile phones in the United States.
Per Section V, Parts A and B of the Memorandum of Understanding (MOU) between the Department of Homeland Security (DHS/FEMA) and the NRC regarding radiological emergencies, planning, and preparedness, dated July 1, 20242:
FEMA coordinates all Federal planning for offsite impact of radiological emergencies and takes the lead for assessing offsite radiological emergency response plans and preparedness, makes findings and determinations as to the adequacy and capability of implementing offsite plans, and communicates those findings and determinations to the NRC. As outlined within Section V, Part A, FEMA Approves Alert and Notification System (ANS) design reports. When the ANS design report undergoes significant changes, including any changes to primary and back-up alert methods, FEMA will allow 1 NRCs Agencywide Documents Access and Management System (ADAMS) Accession No. ML22263A280 2 ADAMS (ML24184A043)
January 22, 2025
S. Dobitsch the NRC to review the ANS design report to ensure that the NRC-regulated aspects of ANS are maintained.
As outlined within Section V, Part B, The NRC reviews FEMA's findings and determinations in conjunction with the NRC onsite findings for the purpose of making determinations on the overall state of emergency preparedness. These overall findings and determinations are used by the NRC to make radiological health and safety decisions in the issuance of licenses and the continued operation of licensed utilization facility to include taking enforcement actions such as notices of violations, civil penalties, orders, or shutdown of operating reactors. This delineation of responsibilities avoids duplicative efforts by the NRC in preparedness matters. Additionally, as outlined within Part B, the NRC Reviews FEMA's findings and determinations of offsite plans to determine that the plans, including ANS design reports, are adequate and can be effectively implemented.
The NRC evaluated the updated CNP ANS Design Report received on October 1, 2024, and found that it contained sufficient information to be considered an adequate submittal for NRC to conduct its review. At this time, the NRC did not identify any licensing basis issues associated with the CNP ANS Design Report.
Consistent with the roles of each respective agency as set forth in the aforementioned MOU, the NRC conducted a review of the FEMA findings. To aid its review, the NRC utilized the FEMA evaluation criteria and sample template for ANS changes and use of IPAWS3. The NRC review focused on the applicable requirements in Title 10 of the Code of Federal Regulations (10 CFR)
Section 50, Appendix E,Section IV.D.3.
The CNP ANS Design Report utilizes internet or cellular based systems for both the primary and back-up ANS. The staff conducted a risk-informed assessment and thorough review to determine if there is reasonable assurance that backup capability for alert and notification would be available in the event the primary method is unavailable during an emergency. Therefore, the NRC considered the reliability of the CNP systems and potential common failure modes. In addition, the NRC also considered as defense-in-depth, the Realism rule in 10 CFR 50.47(c)(1),
which notes that under extreme circumstances and radiological emergencies (inclusive of both primary and back-up ANS failures), the Offsite Response Organizations (ORO) will deploy all available resources, technology, and personnel to support public messaging and safety.
In conclusion, the NRC accepts the findings of FEMA that Revision 3 of the CNP Alert and Notification System Evaluation Report meets the applicable requirements in 10 CFR 50, Appendix E,Section IV.D.3, and enables the NRC to make a finding of reasonable assurance for public health and safety.
3 ADAMS Accession No. ML19339G862, ADAMS Accession No. ML2107A238
S. Dobitsch Please feel free to contact my staff, Cindy Rosales-Cooper, Acting Chief, Policy and Oversight Branch at (301) 287-9500 or at Cindy.Rosales-Cooper@nrc.gov, if you have questions.
Sincerely, Michael Waters, Acting Director Division of Preparedness and Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission Signed by Waters, Michael on 01/22/25