SBK-L-17074, Radiological Emergency Plan (Ssrep), Revisions 70 and 71

Radiological Emergency Plan (Ssrep), Revisions 70 and 71

ML17121A391
Person / Time
Site:	Seabrook
Issue date:	05/02/2017
From:	Browne K NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML17121A389	List: ML17121A392 SBK-L-17074, Radiological Emergency Plan (Ssrep), Revisions 70 and 71
References
SBK-L-17074
Download: ML17121A391 (5)

Text

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SEABROOK May 2, 2017 Docket No. 50-443 Docket No. 72-63 SBK-L-17074 United States Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001 Seabrook Station Radiological Emergency Plan (SSREP), Revisions 70 and 71 In accordance with the requirements of 10 CFR 50, Appendix E; 10 CFR 50.4, and 10 CFR 72.44(£), enclosed are Revisions 70 and 71 to the Seabrook Station Radiological Emergency Plan (SSREP).

The revisions do not reduce the effectiveness of the SSREP, and the SSREP continues to meet the standards of 10 CFR 50.47(b) and 10 CFR 50, Appendix E. The Resident Inspector copy is provided directly through the NextEra Energy Seabrook, LLC records management system. provides a summary of changes to the SSREP. Enclosure 2 provides a summary of the change analysis required by 10 CFR 50.54(q)(5) and Enclosure 3 provides a copy of the revised manual.

Should you have any questions regarding the enclosed revisions, please contact me at (603) 773-7932.

Sincerely, FU+aU- r w Licensing Manager NextEra Energy Seabrook, LLC PO Box 300, Seabrook, NH 03874

United States Nuclear Regulatory Commission SBK-L-17074/ Page 2 cc (with enclosures):

J.P. DeBoer, Region I, Division of Reactor Safety cc (without Enclosure 3):

AT1N: Document Control Desk Director, Spent Fuel Storage and Transportation, Office of Nuclear Material Safety and Safeguards Nuclear Regulatory Commission Washington, DC 20555-0001 J. Poole, NRC Project Manager, Project Directorate I-2 cc (without enclosures):

D. H. Dorman, NRC Region I Administrator P. Cataldo, NRC Senior Resident Inspector

Encfosure 1 to SBK-L-17074 Summary of Changes Radiological Emergency Plan (SSREP), Revision 70

• Section 6 - Updated description of new seismic monitor alarms (EC 282184).

• Section 8.3 - Removed reference to cancelled STMM and replaced with corporate communications policies.

• Figure 8.1 - Reformatted Figure. Added EMT position to more clearly indicate that an EMT is required on shift. Revised note to state that the qualified EMT may be staffed by a member of the Fire Brigade.

• Section 10.1.2 - Improved description of field monitoring instrumentation sensitivity.

Changed terms for TLD to Dosimeter of Legal Record (DLR) and electronic dosimetry to self-reading dosimetry to support NEI Efficiency Bulletin 16-26c (AR 02168330).

• Sections 12.l - Replaced reference to the site EP Drill and Exercise Manual with applicable fleet and site procedures.

• Section 12.1.2.2 - Corrected referenced step number.

• Appendix A, Rev. 64 - Returned the Security Personnel position to Table 1. This position was inadvertently deleted due to an editing error during a previous revision (AR 2092861).

• Appendix D, Rev. 61 - Replaced outdated INPO Letter of Agreement with current letter from INPO Website. Updated Remote Monitoring Area LOA with new lease information. Updated Seabrook Fire Department Letter of Agreement.

Radiological Emergency Plan (SSREP), Revision 71

• Appendix G, Rev 55 - Cancelled ER 5.7 as there is now only one standard procedure for all Raddose V users (ER 5.3).

Enclosure 2 to SBK-L-17074 Change Analysis Summary Radiological Emergency Plan (SSREP), Revision 70 Revision 70 updated the description of new seismic monitor alarms in Section 6. In Section 8.3 a reference to cancelled site manual was replaced with corporate communications policies.

Changing the monitor description and referencing replacement policy are not associated with a planning standard.

Figure 8.1 was reformatted and the EMT position added to more clearly indicate that an EMT is required on shift. Additionally, a note was revised to state that the qualified EMT position may be staffed by an existing Fire Brigade member. The 10 CFR 50.54(q) evaluation determined the 10CFR50.47(b)(2) function will continue to be maintained because this revision does not change the requirement to staff the onshift emergency organization with a qualified EMT. The timing of this function remains unaffected because the EMT position will continue to be staffed continuously. The 10CFR50.47(b)(l2) function will continue to be maintained because a qualified EMT remains available on site with immediate PA and RCA access regardless of whether the EMT is a Fire Brigade member or not.

In Section 10.2.1, the description of field monitoring instrumentation sensitivity was improved and terms changed from TLD to Dosimeter of Legal Record (DLR) and electronic dosimetry to self-reading dosimetry to support NEI Efficiency Bulletin 16-26c. A 10 CFR 50.54(q) evaluation was performed for this changed. The evaluation concluded that per SSREP implementing procedure ER 5 .2, Site Perimeter and Offsite Monitoring and Environmental Sampling, Seabrook Station field monitoring and environmental sampling personnel continue to use the same instrumentation considered by SS25564. In fact, SS25564 is referenced in ER 5.2.

Therefore the SSREP continues to maintain the capability to detect and measure radioiodine concentrations in the air as low as 10- 7 µCi/cc under field conditions per the guidance of NUREG-0654/FEMA-REP-1. Rev.1, Evaluation Criterion I-9. There is no timing associated with this function.

The revision to Section 12.1 replaced reference to the site EP Drill and Exercise Manual with applicable fleet and site procedures and corrected a reference step number. The 10 CFR 50.54(q) evaluation for this changed determined the emergency responder training function is maintained because there is no change to the overall objective intent as only the administrative location of objectives is being revised. The timing remains unaffected because there is no change to the frequency of objective demonstration.

Appendix A was changed to add a previously deleted Security Personnel position to Table 1.

This position was inadvertently deleted due to an editing error in a previous revision.

The revision to Appendix D replaced the outdated INPO Letter of Agreement with current letter from INPO Website, updated Remote Monitoring Area LOA with new lease information and updated the Seabrook Fire Letter of Agreement. This is associated with planning standard 10CFR50.47(b)(3), Emergency Response Support and Resources (Arrangements for requesting and using offsite assistance have been made). The 10 CFR 50.54(q) evaluation concluded that as

recognized in the SSREP Appendix D, the INPO emergency assistance agreement is initiated by INPO with its member utilities and is not maintained current within the SSREP as the current letter of certification is on the INPO webpage. This revision to Appendix D replaces the 1994 letter with the most recent letter. The remote monitoring area lease was renewed and thus replaced in Appendix D with the current lease. The ability to maintain the function in the future is maintained because other than the change in financial compensation for the remote monitoring area, no changes were made to the use of the facility. The Seabrook Fire Department Letter of Agreement was also updated. This revision complies with the function associated with the planning standard because it updates the plan with the current letters of agreement. There is no timing associated with this function.

The above changes to the SSREP do not reduce the effectiveness of the emergency plan and the emergency plan as changed continues to meet the planning standards of 10 CFR 50.47 (b) and the requirements of 10 CFR 50, Appendix E.

Radiological Emergency Plan (SSREP), Revision 71 Revision 71 deleted procedure ER 5.7 from SSREP Appendix G and notes that the information is now contained in ER 5.3. ER 5.7 is being deleted so that there is only one standard procedure for all Raddose-V users. This is not an intent change to the plan as it's simply a change to the list of procedures referenced in the plan. There is no change to dose assessment responsibility, modeling, or ability to conduct dose assessment. Any pertinent information that was contained in ER 5.7 was moved to ER 5.3.

The above change to the SSREP does not reduce the effectiveness of the emergency plan and the emergency plan as changed continues to meet the planning standards of 10 CFR 50.4 7 (b) and the requirements of 10 CFR 50, Appendix E.