NG-22-0055, Revision to Duane Arnold Energy Center (DAEC) ISFSI-Only Emergency Plan

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Revision to Duane Arnold Energy Center (DAEC) ISFSI-Only Emergency Plan
ML22140A125
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 05/20/2022
From: Both J
NextEra Energy Duane Arnold
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
NG-22-0055
Download: ML22140A125 (12)
v • d • e


Text

NEXT era..

ENERG Y ~

ARNOLD DUANE

May 20, 2022 NG-22-0055 10 CFR 50.54(q) 10 CRF 72.44(f)

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49

Revision to Duane Arnold Energy Center (DAEC) ISFSl-Only Emergency Plan

NextEra Energy Duane Arnold, LLC issued revisions to the DAEC 's ISFSl-Only Emergency Plan on 4/26/22 and 5/16/22. These revisions incorporated changes that do not reduce the effectiveness of the DAEC Emergency Plan. Pursuant to 10 CFR 50.54(q)(5) and 10 CFR 72.44(f), enclosed are the 50.54(q) Screening forms which provide a summary of the changes and analysis.

This letter contains no new commitments and no revisions to existing commitments.

If you have any questions or require additional information, please contact Tracy Weaver at (319) 851-7250.

J Decommissioning Director, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC

Enclosure

cc: Director, Division of Spent Fuel Management Administrator, Region Ill, USNRC Inspector, DAEC, USNRC

NextEra Energy Duane Arnold, LLC, 3277 DAEC Ro ad, Palo, IA 52324 Enclosure to NG-22-0055

Duane Arnold Energy Center 50.54(q) Screening Forms

10 Pages Follow 10CFR50.54(q) SCREENING FORM Page 1 of 4 PCR/AR/NAMS No.: 02425298

SECTION>1: STATION APi:>Lic.A.l31Llri

SECTION 2: f>URPOSE Identify the reason for the screening:

[8'.11 OCFR50.54(q) screening of a Change to the Emergency Plan or procedures implementing the Plan D Emergency Preparedness Function Assessment

SECTION 3: PROVIDE A BRIEF DESCRIPTION OF *PROPOSED CHANGE AND LIST THE PROCESS/DOCUMENTTHAT IS DRIVING THE CHANGE.

Procedure Number and Current Revision:

DAEC PDEP, "PERMANENTLY DEFUELED EMERGENCY PLAN", Rev. 1 - RETIRE EBO, "EMERGENCY ACTION LEVELS TECHNICAL BASES DOCUMENT", Rev. 6 - RETIRE DAEC IOEP, "DAEC ISFSl-ONL Y EMERGENCY PLAN", Rev. NI DAEC EBO, "EAL TECHNICAL BASES DOCUMENT', Rev. NI EPIP 1.1, "Determination of Emergency Action Levels", Rev. 34 EPIP 1.2, "Notifications", Rev. 56 EPIP 1.3, "Facility Assembly and Site Evacuation", Rev. 24 EPIP 2.3, "Operation of the FTS-2001 Phone Network", Rev. 14 EPIP 2.5, "Emergency Response Operation", Rev. 29 EPIP 3.1, "ISFSI Radiological Monitoring", Rev. 35 EPIP 3.3, Rev. 39 - RETIRE EPIP 4.3, "Rescue and Emergency Repair Work, Rev. 25 EPIP 5.2, "Termination and Recovery, Rev. 15 EPIP 6.1, "Drill and Exercise Program", Rev. 8 EPIP 6.2 Maintenance of Emergency Response Facilities and Equipment", Rev. 7 Process/Document Driving Change:

DAEC submitted to the NRC License Amendment Request (TSCR-192) to revise the DAEC Emergency Plan and Emergency Action Level (EAL) scheme for ISFSI-Only condition. The NRC has issued Amendment 318 to the Facility License that approves an ISFSl-Only Emergency Plan and EAL scheme for the DAEC.

EP-AA-100-1007-F01, Revision 8 10CFR50.54(q) SCREENING FORM Page 2 of 4 PCR/AR/NAMS No.: 02425298

Brief Description (include why the change is being made):

All spent fuel has been removed from the spent fuel pool and is now stored at the ISFSI. As a result, a complete NRG-approved revision of the DAEC Emergency Plan and EAL scheme becomes effective. The current PDEP will be superseded by the DAEC ISFSl-Only Emergency Plan (IOEP). The current EBD will be superseded by the DAEC EBD. Changes to EPIPs will be made to align them with the IOEP and EBD. EPIP 3.3 is no longer needed and is being retired.

D Check if EAL Validation & Verification is Attached (required for EAL change not in the NRC SER)

SECTION 4:0ETAILED DESCRIPTION OF,6.CTIVITY BEINGiREVIEWED.: The ~ctivify is an* evenfor action, orsefiesof actibnsthatmay*result ln a change to the

.* emergency.plan* or affectthe implementation* of the emergency plan.

Change Description of Change Reason for Change Screening Planning Number Standard I Program Element*

1. Implement the DAEC ISFSl-Only Emergency Plan (IOEP) and DAEC IZJ Editorial Change:

Emergency Action Level and Bases Document (EBD) that were Analysis is NOT required approved by the NRC in License Amendment 318. Revise EPIPs to IZJ Proposed change does NOT conform to the IOEP and EBD. affect the Planning Standards

In addition, editorial and conforming changes were made to the IOEP /Program Elements: NOT required and EBD, as described in the attached matrix. Analysis is D Proposed change DOES affect the Planning Standards I Program Elements:

Analvsis IS reauired

  • Planning Standard I Program Element from Section 7

EP-AA-100-1007-F01, Revision 8 10CFR50.54(q) SCREENING FORM Page 3of4 PCR/AR/NAMS No.: 02425298

SECTION 5: RESULTS OF SCREENING 1'8:1 If NO Section 7 criteria are affected, a 10CFR50.54(q) Evaluation is NOT required.

D If ANY Section 7 criteria are affected, a 10CFR50.54(q) is required. Use Form 2 for Emergency Plan changes, to evaluate the change.

For all other changes, use Form 5

SECTIONS: SIGNATURE Prepa red by (Print Name) Signature Date

Tracy Weaver 4-z& -z:c_

Reviewed by (Print Name) :Si~+-?. Date

Steve Inghram ~ /i~ /1-1--

SFAM Approval (Print Name) Date M* Oav;s. q/~ (:./,2Q.

CFAM I PTL Approval (Print Name) Signature Date

EP-AA-100-1007-F01, Revision 8 10CFR50.54(q) SCREENING FORM Page 4 of 4 PCR/AR/NAMS No.: 02425298

Section 7: Are any of the following affected by this Change? (Document in Section 4 for each change;)

No. Planning Standards I Functions Requirement YES NO

1. Responsibility for emergency response is assigned.. 50.47(b)(1) D 0
2. The response organization has the staff to respond and to augment staff on a 50.47(b)(1) D 0 continuing basis (i.e., 2417 suooort) in accordance with the emeroency plan.
3. The process ensures that onshift emergency response responsibilities are staffed 50.47(b)(2) D 0 and assigned (includino on-shift staffing study and assumptions)
4. The process for timely augmentation of onshift staff is established and maintained. 50.47(b)(2) D 0
5. Arrangements for requesting and using offsite assistance have been made. 50.47(b)(3) D 0
6. State and local staff can be accommodated at the EOF in accordance with the 0 emeroency plan. 50.47(b)(3) D
7. A standard scheme of emergency classification and action levels is in use. 50.47(b)(4) D 0 Procedures for notification of State and local governmental agencies are capable 50.47(b)(5) D
8. of alerting them of the declared emergency within 15 minutes after declaration of 0 an ememency and providini:i follow-up notifications.
9. Administrative and physical means have been established for alerting and 50.47(b)(5) D 0 providino prompt instructions to the public within the plume exposure pathway.

The public ANS meets the design requirements of FEMA-REP-10, "Guide for

10. Evaluation of Alert and Notification Systems for Nuclear Power Plants", or is 0 compliant with the licensee's FEMA-approved ANS design report and supporting 50.47(b)(5) D FEMA aooroval letter. -
11. Systems are established for prompt communication among principal emergency 0 response ori:ianizations. 50.47(b)(6) D
12. Systems are established for prompt communication to emergency response 50.47(b)(6) D 0 personnel.
13. Emergency preparedness information is made available to the public on a periodic 0 basis within the plume exposure pathway EPZ. 50.47(b)(7) D
14. Coordinated dissemination of public information during emergencies is established. 50.47(b)(7) D 0
15. Adequate equipment & facilities are maintained to support emergency response. 50.47(b)(8) D 0
16. Methods, systems, and equipment for assessment of radioactive releases are in 50.47(b)(9) D use 0
17. A range of public PARs is available for implementation during emergencies. 50.47(b)(10) D 0 Evacuation time estimates for the population located in the plume exposure 50.47(b)(10) D
18. pathway EPZ are available to support the formulation of PARs and have been 0 provided to State and local oovernmental authorities.
19. A range of protective actions is available for plant emergency workers during 50.47(b)(10) D 0 emeri:iencies, including those for hostile action events
20. The resources for controlling radiological exposures for emergency workers are established. 50.47(b)(11) D 0
21. Arrangements are made for medical services for contaminated, injured individuals 50.47(b)(12) D 0
22. Plans for recovery and reentry are developed. 50.47(b)(13) D 0
23. A drill and exercise program (including radiological, medical, health physics, and 0 other prooram areas) is established. 50.47(b)(14) D Drills, exercises, and training evolutions that provide performance opportunities to 50.47(b)(14) D 0
24. develop, maintain, and demonstrate key skills, are assessed via a formal critique process in order to identify weaknesses.
25. Identified weaknesses are corrected. 50.47(b)(14) D 0
26. Training is provided to emergency responders. 50.47(b)(15) D 0
27. Responsibility for emergency plan development and review is established. 50.47(b)(16) D 0
28. Planners responsible for emergency plan development and maintenance are 50.47(b)(16) D properly trained. 0

EP-AA-100-1007-F01, Revision 8 DAEC IOEP and DAEC EBO editorial and conforming changes

Doc Page* Section Change Justification Changed font to Arial, spacing to "normal", and scale to 100%, for Editorial changes for DAECIOEP all all consistency. consistency.

various various consistent with Replaced generic references to "nuclear power plant" or "plant" to "facility". Nomenclature change Amd #311.

Editorial change consistent "DAEC Control Room" should be "DAEC Emergency Response Facility" with implementation of Amds 12 of 28 F 1.1.2 #315 & 318.

13 of 28 H Made "Radiological condition... " plural, "Radiological conditions..... " Editorial corrections.

Remove sentence stating: "This authorization is coordinated with the Site This position was eliminated 150 of 28 K Radiation Protection Coordinator when available. " by Amd #318.

Minor editorial changes to ensure verbiage from EPA PAG Table 3-1 is Editorial corrections.

16of28 Table K.l verbtim.

11 19 of 28 N Change "estimate" to "estimated

  • Editorial corrections.

21of28 p Changed semicolon to a comma in the section title. Editorial corrections.

24 of 28 App 2 Added bullets to list of LOAs. Editorial change for clarity.

Remove EPIP 2.8, Security Threat, from the list. Previously deleted by 25 of28 App3 PCR02403688

28 of 28 App4 Remove NCO, NWS and SFP from the list of acronyms, they are not used. Editorial change

11 Changed font to Arial, spacing to "normal, and scale to 100%, for Editori"al changes for DAEC EBD all all consistency. consistency.

11 or 11 plant11 to 11 facility11

  • Nomenclature change

~ various various consistent with Replaced generic references to "nuclear power plant Amd #311.

Removed "plus Notes". Per Amd #318, there are no

--- 4 of 20 4.1 applicable Notes.

Removed AOP, CDE, cpm, DODAM, FAA, FBI, MSL, NORAD, ORO and TEDE. Editorial - they are no longer 8/9of20 6.1 referenced in the text.

Removed NORMAL LEVELS, UNPLANNED and VISIBLE DAMAGE. Editorial - they are no longer 10 of 20 6.2 referenced in the text.

Att. 1, Table Rearrange Table so Alerts are in the first column. Editorial change 12 of 20 PD-1

Att. 2, Table Rearrange Table E-1 to a vertical format. Editorial change 20 of 20 E-1 Correct 11 HM-20" to "HSM-2011; Remove "Outside HSM Door - Centerline of Att. 2, Table DSC11 from first block under HSM-01 through HSM-20; Correct 30 11 rem/hr" to Editorial corrections.

11 in the 20 of 20 E-1 11 mrem/hrlast block.

Att. 2, Table Incorporate additions for HSM-31 through HSM-60. Previously incorporated by 20of20 E-1 PCR02411975.

  • Reflects page number of original submittal for easier reference.

10CFR50.54(q) SCREENING FORM Page 1of4 PCR/AR/NAMS No.: 02426388. 02426562

SECTION 1: STATION APPLICABILITY Applicable activity for review (process, document, modification, etc):

[APP!fcable Site: ~ Duane Arnold Energy Center D Point Beach Oseabrook D St. Lucie 0Turkey Point==1

SECTION2: PURPOSE Identify the reason for the screening:

~ 1 OCFR50.54(q) screening of a Change to the Emergency Plan or procedures implementing the Plan D Emergency Preparedness Function Assessment

SECTION 3: PROVIDE ABRIEF DESCRIPTION OF PROPOSED CHANGE AND LIST THEPROCESS!DOCUMENTTHATIS DRIVING THE CHANGE.

Procedure Number and Current Revision:

OP-028, "ERO Offsite Agencies Notification Monthly Test", Rev. 34 DAEC IOEP, "DAEC ISFSl-Only Emergency Plan," Rev. 0 EPI P 1.2, "Notifications", Rev. 57 EPIP 2.3, "Operation of the FTS-2001 Phone Network" - RETIRE EPI P Index, "EPIP Index", Rev. 198

Process/Document Driving Change:

RIS 2000-11, "NRC Emergency Telecommunications System," dated June 30, 2000, provides NRG-approved alternatives to using the FTS 2001.

Brief Description (include why the change is being made):

The NRC has issued Amendment 318 to the Facility License that approved an ISFSl-Only Emergency Plan and EAL scheme for the DAEC. Subsequently, the Control Room is no longer attended. The Emergency Notification System (ENS) phone line requires transition to the Security Building due to continuous staffing requirements. Rerouting of the current FTS 2001 line is an option, however, the site is transitioning to a Voice over Internet Protocol (VoIP) system as part of the decommissioning plan. A VoIP system meets the requirements for the ENS as outlined in RIS 2000-11, which states, .Any other telecommunications system or network that can provide long distance access independent of the local telephone switch." Emergency Plan documents are being updated accordingly.

D Check if EAL Validation & Verification is Attached (required for EAL change not in the NRC SER)

EP-AA-100-1007-F01, Revision 8 10CFR50.54(q) SCREENING FORM Page 2of4 PCR/AR/NAMS No.: 02426388, 02426562

SECTION 4: DETAILED DESCRIPTION OF ACTIVITY BEING REVIEWED; The "activity" is an event or action, or series.of actions that may result in a change to the emergency plan or affect the irnplementation of the emergency plan.

Change Description of Change Reason for Change Screening Planning Number Standard I Program Element*

1. Revise the Emergency Planning program documents to remove The Control Room ENS line D Editorial Change:

references to FTS 2001. FTS 2001 is being replaced with a VoIP is no longer continuously Analysis is NOT required system that provides long distance access outside of the local attended. Testing of the l:S:I Proposed change does NOT telephone switch. communication method will the Planning Standards remain unchanged. affect /Program Elements:

Analysis is NOT required D Proposed change DOES affect the Planning Standards I Program Elements:

Analysis IS reQuired -

  • Planning Standard I Program Element from Section 7

SECTION 5: RESULTS OF SCREENING l:S:I If NO Section 7 criteria are affected, a 1 OCFR50.54(q) Evaluation is NOT required.

D If ANY Section 7 criteria are affected, a 10CFR50.54(q) is required. Use Form 2 for Emergency Plan changes, to evaluate the change.

For all other changes, use Form 5

EP-AA-100-1007-F01, Revision 8 10CFR50.54(q) SCREENING FORM Page 3 of 4 PCR/AR/NAMS No. : 02426388. 02426562

SECTION 6: SIGNATURE Prepared by (Print Name) Signature Date

Tracy Weaver 5-Z-z-z__

Reviewed by (Print Name) Signature Date

Steve Inghram s{vf 1 SFAM ~TA (Print Name) Signature Date

CFAM I PTL Approval (Print Name) Signature Date

N /ft

EP-AA-100-1007-F01, Revision 8 10CFR50.54(q) SCREENING FORM Page 4 of 4 PCR/AR/NAMS No.: 02426388, 02426562

Section 7: Are any of the following affected by this change? (Document in Section 4 for each change.)

No. Planning Standards I Functions Requirement YES NO

1. Responsibility for emergency response is assigned.. 50.47(b)(1) D [ZJ
2. The response organization has the staff to respond and to augment staff on a [ZJ continuing basis (i.e., 2417 suooort) in accordance with the emerqency plan. 50.47(b)(1) D
3. The process ensures that onshift emergency response responsibilities are staffed [ZJ and assigned (including on-shift staffing study and assumptions) 50.47(b)(2) D
4. The process for timely augmentation of onshift staff is established and maintained. 50.47(b)(2) D [ZJ
5. Arrangements for requesting and using offsite assistance have been made. 50.47(b)(3) D [ZJ
6. State and local staff can be accommodated at the EOF in accordance with the [ZJ emergencv olan. 50.47(b)(3) D
7. A standard scheme of emergency classification and action levels is in use. 50.47(b)(4) D [ZJ

Procedures for notification of State and local governmental agencies are capable 50.47(b)(5) D [ZJ

8. of alerting them of the declared emergency within 15 minutes after declaration of an emergency and providinq follow-up notifications.
9. Administrative and physical means have been established for alerting and 50.47(b)(5) D [ZJ providing oromot instructions to the public within the olume exoosure oathwav.

The public ANS meets the design requirements of FEMA-REP-10, "Guide for

10. Evaluation of Alert and Notification Systems for Nuclear Power Plants", or is 50.47(b)(5) D [ZJ compliant with the licensee's FEMA-approved ANS design report and supporting FEMA aooroval letter.
11. Systems are established for prompt communication among principal emergency 50.47(b)(6) D [ZJ response ornanizations.
12. Systems are established for prompt communication to emergency response 50.47(b)(6) D [ZJ personnel.
13. Emergency preparedness information is made available to the public on a periodic [ZJ basis within the olume exoosure pathway EPZ. 50.47(b)(7) D
14. Coordinated dissemination of public information during emergencies is established. 50.47(b)(7) D [ZJ
15. Adequate equipment & facilities are maintained to support emergency response. 50.47(b)(8) D [ZJ
16. Methods, systems, and equipment for assessment of radioactive releases are in 50.47(b)(9) D [ZJ use
17. A range of public PARs is available for implementation during emergencies. 50.47(b)(10) D [ZJ

Evacuation time estimates for the population located in the plume exposure 50.47(b)(10) D [ZJ

18. pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities.
19. A range of protective actions is available for plant emergency workers during [ZJ emergencies, including those for hostile action events 50.47(b)(10) D
20. The resources for controlling radiological exposures for emergency workers are [ZJ established. 50.47(b)(11) D
21. Arrangements are made for medical services for contaminated, injured individuals 50.47(b)(12) D [ZJ
22. Plans for recovery and reentry are developed. 50.47(b)(13) D [ZJ
23. A drill and exercise program (including radiological, medical, health physics, and [ZJ other proQram areas) is established. 50.47(b)(14) D Drills, exercises, and training evolutions that provide performance opportunities to 50.47(b)(14) D [ZJ
24. develop, maintain, and demonstrate key skills, are assessed via a formal critique process in order to identify weaknesses.
25. Identified weaknesses are corrected. 50.47(b)(14) D [ZJ
26. Training is provided to emergency responders. 50.47(b)(15) D [ZJ
27. Responsibility for emergency plan development and review is established. 50.47(b)(16) D [ZJ
28. Planners responsible for emergency plan development and maintenance are properly trained. 50.47(b)(16) D [ZJ

EP-AA-100-1007-F01, Revision 8

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