ML24285A103

– Issuance of Amendments Regarding Fleet Emergency Plan Amendment

ML24285A103
Person / Time
Site:	Saint Lucie, Point Beach, Seabrook, Turkey Point
Issue date:	12/13/2024
From:	Justin Poole NRC/NRR/DORL/LPL3
To:	Coffey B Florida Power & Light Co, Point Beach, NextEra Energy Seabrook
References
EPID L-2022-LLA-0146
Download: ML24285A103 (1)

Text

December 13, 2024 Bob Coffey Executive Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company NextEra Energy Point Beach, LLC NextEra Energy Seabrook, LLC Mail Stop: EX/JB 700 Universe Blvd.

Juno Beach, FL 33408

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2; SEABROOK STATION, UNIT NO. 1; ST. LUCIE PLANT, UNIT NOS. 1 AND 2; AND TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 - ISSUANCE OF AMENDMENTS REGARDING FLEET EMERGENCY PLAN AMENDMENT (EPID L-2022-LLA-0146)

Dear Bob Coffey:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the following enclosed amendments:

Amendment Nos. 276 and 278 to Renewed Facility Operating License Nos. DPR-24 and DPR-27 for the Point Beach Nuclear Plant, Units 1 and 2 (Point Beach),

respectively; Amendment No. 176 to Renewed Facility Operating License No. NPF-86 for the Seabrook Station, Unit No. 1 (Seabrook);

Amendment Nos. 255 and 210 to Renewed Facility Operating License Nos. DPR-67 and NPF-16 for the St. Lucie Plant, Unit Nos. 1 and 2 (St. Lucie), respectively; and Amendment Nos. 300 and 293 to Subsequent Renewed Facility Operating License Nos. DPR-31 and DPR-41 for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point), respectively.

In response to the application dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024 (Agencywide Documents Access and Management System Accession Nos. ML22278A031, ML22343A254, ML23219A102, ML23332A005, ML24127A063, ML24206A140, ML24260A246, ML24269A203, and ML24289A016, respectively), from Florida Power & Light Company, NextEra Energy Seabrook, LLC and NextEra Energy Point Beach, LLC (collectively referred to as the licensee),

the amendments revise each sites emergency plan by creating a new fleet-common emergency plan with site-specific annexes.

A copy of the Safety Evaluation is enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Justin C. Poole, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250, 50-251, 50-266, 50-301, 50-335, 50-389, and 50-443

Enclosures:

1. Amendment No. 276 to DPR-24

2. Amendment No. 278 to DPR-27

3. Amendment No. 176 to NPF-86

4. Amendment No. 255 to DPR-67

5. Amendment No. 210 to NPF-16

6. Amendment No. 300 to DPR-31

7. Amendment No. 293 to DPR-41

8. Safety Evaluation cc: Distribution via Listserv

NEXTERA ENERGY POINT BEACH, LLC DOCKET NO. 50-266 POINT BEACH NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 276 Renewed License No. DPR-24

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment filed by NextEra Energy Point Beach, LLC, (the licensee), dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, by Amendment No. 276, Renewed Facility Operating License No. DPR-24 is hereby amended to authorize revision to the Emergency Plan as set forth in NextEra Energy Point Beach, LLCs application dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 12 months of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael X. Franovich, Deputy Director Office of Nuclear Reactor Regulation Date of Issuance: December 13, 2024 Michael X.

Franovich Digitally signed by Michael X. Franovich Date: 2024.12.13 10:11:12 -05'00'

NEXTERA ENERGY POINT BEACH, LLC DOCKET NO. 50-301 POINT BEACH NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 278 Renewed License No. DPR-27

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment filed by NextEra Energy Point Beach, LLC, (the licensee), dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, by Amendment No. 278, Renewed Facility Operating License No. DPR-27 is hereby amended to authorize revision to the Emergency Plan as set forth in NextEra Energy Point Beach, LLCs application dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3.

This license amendment is effective as of the date of issuance and shall be implemented within 12 months of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael X. Franovich, Deputy Director Office of Nuclear Reactor Regulation Date of Issuance: December 13, 2024 Michael X.

Franovich Digitally signed by Michael X. Franovich Date: 2024.12.13 10:12:06 -05'00'

NEXTERA ENERGY SEABROOK, LLC, ET AL.*

DOCKET NO. 50-443 SEABROOK STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 176 Renewed License No. NPF-86

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment filed by NextEra Energy Seabrook, LLC, et al.

(the licensee), dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

• NextEra Energy Seabrook, LLC, is authorized to act as agent for the: Hudson Light & Power Department, Massachusetts Municipal Wholesale Electric Company, and Taunton Municipal Lighting Plant and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

2.

Accordingly, by Amendment No. 176, Renewed Facility Operating License No. NPF-86 is hereby amended to authorize revision to the Emergency Plan as set forth in NextEra Energy Seabrook, LLCs application dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 12 months of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael X. Franovich, Deputy Director Office of Nuclear Reactor Regulation Date of Issuance: December 13, 2024 Michael X.

Franovich Digitally signed by Michael X. Franovich Date: 2024.12.13 10:12:42 -05'00'

FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-335 ST. LUCIE PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 255 Renewed License No. DPR-67

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Florida Power & Light Company (FPL, the licensee), dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, by Amendment No. 255, Renewed Facility Operating License No. DPR-67 is hereby amended to authorize revision to the Emergency Plan as set forth in Florida Power & Light Companys application dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 12 months of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael X. Franovich, Deputy Director Office of Nuclear Reactor Regulation Date of Issuance: December 13, 2024 Michael X.

Franovich Digitally signed by Michael X. Franovich Date: 2024.12.13 10:13:18 -05'00'

FLORIDA POWER & LIGHT COMPANY ORLANDO UTILITIES COMMISSION OF THE CITY OF ORLANDO, FLORIDA AND FLORIDA MUNICIPAL POWER AGENCY DOCKET NO. 50-389 ST. LUCIE PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 210 Renewed License No. NPF-16

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Florida Power & Light Company, et al.

(FPL, the licensee), dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, by Amendment No. 210, Renewed Facility Operating License No. NPF-16 is hereby amended to authorize revision to the Emergency Plan as set forth in Florida Power & Light Companys application dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 12 months of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael X. Franovich, Deputy Director Office of Nuclear Reactor Regulation Date of Issuance: December 13, 2024 Michael X.

Franovich Digitally signed by Michael X. Franovich Date: 2024.12.13 10:13:52 -05'00'

FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-250 TURKEY POINT NUCLEAR GENERATING UNIT NO. 3 AMENDMENT TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE Amendment No. 300 Subsequent Renewed License No. DPR-31

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Florida Power & Light Company (the licensee) dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, by Amendment No. 300, Subsequent Renewed Facility Operating License No. DPR-31 is hereby amended to authorize revision to the Emergency Plan as set forth in Florida Power & Light Companys application dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 12 months of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael X. Franovich, Deputy Director Office of Nuclear Reactor Regulation Date of Issuance: December 13, 2024 Michael X.

Franovich Digitally signed by Michael X. Franovich Date: 2024.12.13 10:14:33 -05'00'

FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-251 TURKEY POINT NUCLEAR GENERATING UNIT NO. 4 AMENDMENT TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE Amendment No. 293 Subsequent Renewed License No. DPR-41

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Florida Power & Light Company (the licensee) dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, by Amendment No. 293, Subsequent Renewed Facility Operating License No. DPR-41 is hereby amended to authorize revision to the Emergency Plan as set forth in Florida Power & Light Companys application dated October 4, 2022, as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, and evaluated in the NRC staffs safety evaluation enclosed with this amendment.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 12 months of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael X. Franovich, Deputy Director Office of Nuclear Reactor Regulation Date of Issuance: December 13, 2024 Michael X.

Franovich Digitally signed by Michael X. Franovich Date: 2024.12.13 10:15:04 -05'00'

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION AMENDMENT NO. 276 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-24 AMENDMENT NO. 278 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-27 AMENDMENT NO. 176 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-86 AMENDMENT NO. 255 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-67 AMENDMENT NO. 210 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-16 AMENDMENT NO. 300 TO SUBSEQENT RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AMENDMENT NO. 293 TO SUBSEQENT RENEWED FACILITY OPERATING LICENSE NO. DPR-41 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 SEABROOK STATION, UNIT NO. 1 ST. LUCIE PLANT, UNIT NOS. 1 AND 2 TURKEY POINT NUCLEAR GENERATING, UNIT NOS. 3 AND 4 NEXTERA ENERGY POINT BEACH, LLC/NEXTERA ENERGY SEABROOK, LLC FLORIDA POWER & LIGHT COMPANY, ET AL.

DOCKET NOS. 50-266, 50-301, 50-443, 50-335, 50-389, 50-250, and 50-251

1.0 INTRODUCTION

By application dated October 4, 2022, and as supplemented by letters dated December 9, 2022, August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024 (Agencywide Documents Access and Management System Accession Nos. ML22278A031, ML22343A254, ML23219A102, ML23332A005, ML24127A063, ML24206A140, ML24260A246, ML24269A203, and ML24289A016, respectively), Florida Power & Light Company, NextEra Energy Seabrook, LLC, and NextEra Energy Point Beach, LLC (collectively referred to as NextEra or the licensee), submitted changes to the emergency plans for Point Beach Nuclear Plant, Units 1 and 2, Saint Lucie Plant, Units 1 and 2, Seabrook Station, Unit 1 and Turkey Point Nuclear Generating Plant, Units Nos. 3 and 4 to the U.S. Nuclear Regulatory Commission (NRC) for review and prior approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR).

Specifically, the amendment proposes to modify the existing site emergency plans with a new fleet-common emergency plan with site-specific annexes. The proposed fleet-common emergency plan is referred to as the NextEra CEP. NextEra stated that the proposed NextEra CEP with site-specific annexes was developed using the guidance in NUREG-0654/FEMA REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 2, (hereafter referred to as NUREG-0654) dated December 2019 (ML19347D139) and establishes an updated licensing basis for NextEra nuclear sites.

The supplemental letters dated August 7, 2023, November 28, 2023, May 6, 2024, July 24, 2024, September 16, 2024, September 25, 2024, and October 15, 2024, provided additional information that clarified the application but did not expand the scope of the application as originally noticed and, therefore, did not change the NRC staffs proposed no significant hazards consideration determination as published in the Federal Register (FR) on February 21, 2023 (88 FR 10557).

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance, on which the NRC staff based this review, are provided below.

2.1 Regulatory Requirements The planning standards, as set forth in 10 CFR 50.47(b), establish the requirements that the onsite and offsite emergency response plans must meet in order for the NRC staff to find there is reasonable assurance that the licensee will take adequate protective measures in the event of a radiological emergency.

In addition, Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV.1, states, in part, that the emergency response plans submitted by an applicant for a nuclear power reactor operating license under this part, or for an early site permit (as applicable) or combined license under 10 CFR part 52, shall contain information needed to demonstrate compliance with the standards described in

§ 50.47(b), and they will be evaluated against those standards.

The requirements for making changes to emergency plans, as set forth in 10 CFR 50.54(q)(4),

state, [t]he changes to a licensees emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC.

2.2 Guidance The NRC staff used the following applicable guidance documents to conduct its review:

NUREG-0654/FEMA-REP-1, Revision 2, provides specific evaluation criteria that the NRC has determined as an acceptable means of complying with the standards in 10 CFR 50.47. These criteria provide a basis for NRC licensees (and applicants),

and State and local offsite response organizations (OROs) to develop acceptable radiological emergency preparedness plans.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the licensees regulatory and technical analyses in support of its proposed NextEra CEP with site-specific annexes, as described in its application. The proposed NextEra CEP with site-specific annexes is structured to follow the general format of NUREG-0654. The following NRC staff technical evaluation of the license amendment request (LAR) is structured to reflect the 16 planning standards in Section II, Planning Standards and Evaluation Criteria, of NUREG-0654, and addresses the requirements in 10 CFR 50.47(b),

including any applicable requirements in Appendix E to 10 CFR Part 50.

3.1 Background

As stated in its application and supplemental letters, the proposed NextEra CEP with site-specific annexes was developed based upon the updated NRC guidance contained in NUREG-0654. In the application and supplemental letters, NextEra provided information that was needed to support the NRC staffs evaluation of the proposed changes to the NextEra CEP.

The LAR includes enclosures which describe the licensees evaluation of changes that could be considered as reductions in effectiveness. NextEra provided a justification matrix for each plant that identifies the wording in the current NextEra emergency plans and a justification for changes in emergency plan wording. Tables are provided that compare the current ERO assigned to each emergency response facility with the proposed ERO assignments with a justification for each change.

Finally, as summarized in the application dated October 4, 2022, enclosure 10, Offsite Response Organization Concurrence, of the LAR, NextEra has provided copies of its NextEra CEP with site-specific annexes to State and local OROs with emergency planning and preparedness responsibilities for the affected sites; each of the State and local OROs confirmed that they do not object to the licensees adoption of the NextEra CEP with site-specific annexes.

3.2 Evaluation Section II, Planning Standards and Evaluation Criteria, of NUREG-0654, contains evaluation criteria for each planning standard of 10 CFR 50.47(b). The following discussion provides the results of NRC staffs review of the proposed NextEra CEP with site-specific annexes and the staffs finding that all 16 Planning Standards and Evaluation Criteria of NUREG-0654 are met:

A. Assignment of Responsibility, B. Emergency Response Organization, C. Emergency Response Support and Resources, D. Emergency Classification System, E. Notification Methods and Procedures, F. Emergency Communications, G. Public Education and Information, H. Emergency Facilities and Equipment, I.

Accident Assessment, J. Protective Response, K. Radiological Exposure Control, L. Medical and Public Health Support, M. Recovery, Reentry, and Post Accident Operations, N. Exercises and Drills, O. Radiological Emergency Response Training, and P. Responsibility for the Planning Effort: Development, Periodic Review, and Distribution of Emergency Plans.

3.2.1 Criterion II.A, Assignment of Responsibility NUREG-0654, Evaluation Criterion II.A, addresses planning standard 10 CFR 50.47(b)(1),

which states:

Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Section IV.A of Appendix E to 10 CFR Part 50, requires, in part, that [t]he organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization and the means for notification of such individuals in the event of an emergency.

The requirements of 10 CFR 50.47(b)(1) and the applicable requirements of Section IV.A of Appendix E to 10 CFR Part 50 are addressed in Section A, Assignment of Responsibility, of the proposed NextEra CEP with site-specific annexes.

3.2.1.1 NextEra CEP The proposed NextEra CEP describes the assignment of responsibility to NextEra, and State and local OROs within the Emergency Planning Zones (EPZs) for the NextEra sites. NUREG-0654 Evaluation Criteria A.1 through A.5 provide the primary responsibilities for emergency response by NextEra, and by Federal, State and local OROs within the EPZs. The interrelationships between NextEra, Federal, State and local OROs, and local services support (e.g., fire, medical and local law enforcement) are illustrated in a block diagram in element B.4 of the proposed NextEra CEP.

The proposed NextEra CEP identifies the individuals who will oversee the emergency response.

It further identifies the responsibilities of key individuals responsible for command-and-control, alerting and notification, communications, public information, accident assessment, protective response (including the authority to request Federal assistance and to initiate other protective actions), and radiological exposure control.

The proposed NextEra CEP relies on Federal, State, and local organizations to provide emergency response assistance. NextEra states that assistance will be provided by Federal, State and local OROs that are mandated by charter, regulation, or law to protect public health and safety. NextEra concludes that the additional support agreements (Letters of Agreement (LOAs) and Memoranda of Understanding (MOUs)) are not required with these agencies.

NextEra states that the additional entities that are expected to provide emergency response support have developed LOAs or contracts/purchase orders with NextEra. LOAs and contracts are referenced by organization and title in the site-specific annexes to the NextEra CEP, with the actual LOAs and contracts maintained on file at the applicable location. NextEra concludes that a contract/purchase order with a private contractor is considered acceptable in lieu of an LOA for the specified duration of the contract.

The proposed NextEra CEP states that NextEra maintains an ERO that can provide continuous operation for an extended period. The Emergency Director is the individual responsible for assuring continuity of resources (technical, administrative and material).

3.2.1.2 Emergency Plan Annexes The proposed NextEra CEP site-specific annexes have a listing of the local OROs with an emergency response role, as well as figures identifying the respective sites 10-mile EPZ and 50-mile Ingestion Pathway Zone. Each site-specific annex has a list of LOAs/MOUs that are maintained by each site with the listed organizations.

3.2.1.3 Proposed Changes to Site-Specific Emergency Plans NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.1.4 Criterion II.A, Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has identified the primary responsibilities for emergency response by NextEra, and State and local OROs within the EPZs, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(1) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.2 Criterion II.B, Emergency Response Organization NUREG-0654, Evaluation Criterion II.B, addresses planning standard 10 CFR 50.47(b)(2),

which states:

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.

As noted above,Section IV.A of Appendix E to 10 CFR Part 50 requires, in part, that [t]he organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization and the means for notification of such individuals in the event of an emergency.

The requirements of 10 CFR 50.47(b)(2) and applicable requirements of Section IV.A of Appendix E to 10 CFR Part 50 are addressed in portions of Section B, Emergency Response Organization, of the proposed NextEra CEP with site-specific annexes.

3.2.2.1 Proposed Changes to the NextEra CEP with site-specific annexes related to ERO staffing and augmentation The proposed changes to the NextEra CEP are discussed in the following sections that include a section common to all NextEra sites with site-specific exceptions as noted. The following evaluation first addresses alignment of the proposed NextEra CEP staffing with the Emergency Preparedness (EP) functions as provided by NUREG-0654 and then evaluates any remaining changes to the site-specific emergency plans.

In conjunction with this LAR, NextEra has performed and documented an On-Shift Staffing Analysis (OSA) per 10 CFR Part 50, Appendix E, Section IV.A.9 following the guidance of the Nuclear Energy Institute (NEI) document NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Revision 0, June 2011 (ML111751698).

Command-and-control The purpose of the ERO command-and-control function is to: (1) provide overall ERO command-and-control, until relieved; (2) approve emergency action level (EAL) and/or protective action recommendation (PAR) classifications, until relieved; and (3) authorize personnel dose extensions, until relieved. The Shift Manager is the on-shift individual who will initially assume the ERO command-and-control function. Once relieved of the ERO command-and-control function, the Shift Manager will direct the operation of the plant to mitigate consequences of the event and assist the emergency director with reclassifications and protective action recommendations.

The guidance in NUREG-0654, Table B-1, Emergency Response Organization (ERO) Staffing and Augmentation Plan, provides that the Operations Shift Manager will provide on-shift command-and-control capability. NUREG-0654 further provides that the on-shift Shift Manager will be relieved of the command-and-control function by the Emergency Coordinator in Technical Support Center (TSC) within 60 minutes of an Alert or greater emergency classification level with further augmentation by the Emergency Director in the Emergency Operations Facility (EOF) within 60 minutes of a Site Area Emergency or greater emergency classification level.

NextEra current command-and-control ERO staffing is as follows:

Point Beach currently has one Shift Manager on shift who would be augmented by one Site Emergency Director in the TSC within 60 minutes of an Alert or greater emergency classification level and an EOF Manager within 90 minutes of an Alert or greater emergency classification level.

Saint Lucie currently has one Shift Manager on shift who would be augmented by one Site Emergency Director in the TSC who would respond within 60 minutes of an Alert or greater emergency classification level and an EOF Manager who would respond within 60 minutes of a Site Area Emergency or greater emergency classification level.

Turkey Point currently has one Shift Manager on shift who would be augmented by one Site Emergency Director in the TSC who would respond within 60 minutes of an Alert or greater emergency classification level and an EOF Manager who would respond within 60 minutes of a Site Area Emergency or greater emergency classification level.

Seabrook currently has one Shift Manager on shift who would be augmented by one Site Emergency Director in the TSC, one EOF Manager, and one Response Manager in the EOF who would respond within 60 minutes of an Alert or greater emergency classification level.

The proposed NextEra CEP with site-specific annexes will augment with a qualified Site Emergency Director in the TSC within 60 minutes of the Alert or greater emergency classification level and an EOF Manager within 90 minutes of the Alert or greater emergency classification level. The EOF Manager responds within 90 minutes of an Alert or greater emergency classification level; however, the command-and-control function remains with the qualified Site Emergency Director in the TSC.

As described in the proposed NextEra CEP, the proposed augmentation of a qualified Site Emergency Director in the TSC within 60 minutes of an Alert or greater emergency classification provides support to the Shift Manager for the command-and-control and Emergency Classifications functions. In addition, NextEra proposes to augment with a Radiation Protection (RP) Supervisor (TSC RP Coordinator or Operations Support Center (OSC) RP Supervisor) and an OSC Fix-it-Now (FIN) Supervisor within 60 minutes of an Alert or greater emergency classification level. The RP Supervisor provides support for the supervision of augmenting RP staff. If an urgent/high priority repair activity is required prior to OSC activation at 90 minutes, the Site Emergency Director will direct the OSC FIN Supervisor to perform the required repair activity or help operations to perform the repair activity. The augmenting 60-minute responders described above provide the Shift Manager adequate staffing to delegate task, prioritize, and provide command-and-control/oversight of the event.

The NRC staff finds that the proposed augmentation of a Site Emergency Director, OSC FIN Supervisor and RP Supervisor within 60 minutes of an Alert or greater emergency classification provides additional support to the Shift Manager and reduces the command-and-control burden, therefore allowing the extension in timing for the augmentation of the command-and-control function by the Site Emergency Director in the TSC within 90 minutes from an Alert or greater emergency classification level.

Based on the above evaluation, the NRC staff has determined that the proposed NextEra CEP with site-specific annexes will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the command-and-control function.

Communications The purpose of the Communications function is to communicate EAL and PARs to the Offsite Response Organizations (OROs) and the NRC, until relieved.

NUREG-0654, Table B-1 recommends one on-shift communicator that may be assigned other duties. Following an Alert or greater emergency classification level, the TSC will be staffed with two communicators within 60 minutes, and an additional communicator, as needed, within 90 minutes. In addition, NUREG-0654, Table B-1 recommends the staffing of one communicator in the EOF within 60 minutes of a Site Area Emergency or greater emergency classification level.

NextEra current communications ERO staffing is as follows:

Point Beach currently has one on-shift communicator who is augmented by one ORO Communicator and one Emergency Notification System (ENS)

Communicator in the TSC within 60 minutes of an Alert or greater emergency classification level.

Saint Lucie currently has one on-shift communicator who is assigned communicator responsibilities as a collateral duty who will be augmented by one ORO Communicator in the TSC within 60 minutes of an Alert or greater emergency classification level and an additional ORO Communicator in the TSC within 60 minutes of a Site Area Emergency or greater emergency classification level.

Turkey Point currently has one on-shift communicator who is assigned communicator responsibilities as a collateral duty who will be augmented by one ORO Communicator in the TSC within 30 minutes of an Alert or greater emergency classification level, one ENS Communicator in the TSC within 60 minutes of an Alert or greater emergency classification level and one ORO Communicator in the EOF within 60 minutes of a Site Area Emergency or greater emergency classification level.

Seabrook currently has two on-shift communicators and does not currently provide augmenting ERO communicators.

NextEra states that it employs a system (Emergency Response Notifications for Incidents and Events (ERNIE)) that performs initial ORO and NRC notifications using electronic means.

Specifically, the technology advancements have enhanced the initial notification to the ORO by using an electronic system that contacts the ORO warning points and emergency management staff via email, text and verbal computer-generated voice communications, thus eliminating the need for a communicator to perform the verbal portion of the initial notification.

NextEra proposes the ENS and ORO communications to be performed by the following:

An on-shift Communicator is assigned as a collateral duty to the designated ERNIE operator and is available to make the ENS notification and further continuous communications with the OROs and the NRC until relieved by the ORO Communicator and ENS Communicator positions in the TSC within 90 minutes of an Alert or greater emergency classification level.

After the on-shift Dose Assessor is relieved by the Remote Dose Assessor (within 60 minutes), the on-shift Dose Assessor is available to assume on-shift ORO Communicator position until relieved by the ORO Communicator and ENS Communicators in the TSC at within 90 minutes of an Alert or greater emergency classification level.

Because the proposed NextEra CEP will provide one on-shift communicator as a collateral duty, with augmentation by one communicator within 60 minutes, with further augmentation by one ORO Communicator in the TSC and one ENS Communicator in the TSC within 90 minutes of an Alert or greater emergency classification level, the NRC staff finds the proposed changes are acceptable.

Based on the above evaluation, the NRC staff has determined that the proposed NextEra CEP with site-specific annexes will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Communications function.

Radiation Protection The purpose of the RP Function is to: (1) provide qualified RP coverage for responders accessing potentially unknown radiological environments during emergency conditions; (2) provide in-plant surveys, and (3) control dosimetry and Radiologically Controlled Area access.

NUREG-0654, Table B-1 recommends two RP technicians for a single unit site and one RP Technician per unit for a multi-unit site, with augmentation by three RP technicians within 60 minutes of an Alert or greater emergency classification level and an additional three RP technicians within 90 minutes of an Alert or greater emergency classification level.

NextEra current RP ERO staffing is as follows:

Point Beach currently has two on-shift RP technicians who are augmented by three RP technicians within 60 minutes of an Alert or greater emergency classification level and an additional three RP technicians within 90 minutes of an Alert or greater emergency classification level.

Saint Lucie currently has two on-shift RP technicians who are augmented by six RP technicians within 30 minutes of an Alert or greater emergency classification level and an additional six RP technicians within 60 minutes of an Alert or greater emergency classification level.

Turkey Point currently has one on-shift RP technician who is augmented by seven RP technicians within 30 minutes of an Alert or greater emergency classification level and an additional six RP technicians within 60 minutes of an Alert or greater emergency classification level.

Seabrook has one on-shift RP technician who is augmented by six RP technicians within 60 minutes of an Alert or greater emergency classification level.

In the supplement dated September 16, 2024, NextEra withdrew its proposed changes to ERO staffing for the RP function from the amendment request. The proposed NextEra CEP has been changed to maintain the existing site-specific ERO staffing for the RP function, except for Saint Lucie which is being updated to NUREG-0654, Table B-1 ERO staffing for the RP function.

The proposed NextEra CEP includes a Table B-1, On-shift and Augmenting ERO Staffing Plan, that provides two on-shift RP technicians who are augmented by three RP technicians within 60 minutes of an Alert or greater emergency classification level and an additional three RP technicians within 90 minutes of an Alert or greater emergency classification level. The table includes a note that states, If a site has committed to a different staffing requirement in their individual annex for this function, this staffing requirement is not applicable to that site.

The Point Beach and Saint Lucie site-specific annexes do not contain different site-specific RP staffing requirements than what is specified in the NextEra CEP Table B-1 for the RP function.

Turkey Point only NextEra states that the previous revision of the Turkey Point Emergency Plan combined all qualified individuals for similar functions from Table B-1 for ERO augmentation staff covering RP functions. The augmentation staff covering the function was generically titled RP Technicians.

NextEra states that the proposed NextEra CEP does not combine the similar functions and augmentation staff. Under the proposed NextEra CEP, offsite dose assessment, offsite surveys, onsite (out-of-plant) surveys augmenting staff are listed under the Dose Assessments/

Projections and Field Monitoring Teams functions in the proposed NextEra CEP, and the Chemical/Radio-chemistry task has been eliminated. These functions/tasks account for eight of the augmentation staff not marked with a (*).

NextEra further states that the Protective Actions/Radiation Protection and Radiation Accident Assessment and Support of Operational Accident Assessment/In-plant surveys (above) are functions/tasks requiring qualified RP Technicians augmentation staff. Under the proposed NextEra CEP, the function requiring qualified RP Technicians augmentation staff is an RP function (i.e., providing RP coverage for accessing unknown radiological environments; controlling dosimetry and Radiologically Controlled Area access; and providing in-plant surveys). The proposed Turkey Point site-specific annex requires a total of six (6) qualified RP Technicians augmented staff for the RP function.

Therefore, the proposed Turkey Point site-specific annex will maintain the existing on-shift RP Technician and augmentation by three RP Technicians in the OSC within 30 minutes of an Alert or greater emergency classification level and three RP Technicians in the OSC within 60 minutes of an Alert or greater emergency classification level.

Seabrook only The proposed Seabrook site-specific annex maintains the RP Technician staffing levels in the current Seabrook Emergency Plan which consist of one on-shift RP Technician augmented by six RP Technicians within 60 minutes of an Alert or greater emergency classification level.

A note in the table states that one of the six RP Technicians may be the on-shift RP technician and two may be Junior RP Technicians.

Saint Lucie only The NextEra CEP proposes to staff two on-shift RP Technicians who are augmented by three RP Technicians within 60 minutes and an additional three RP Technicians within 90 minutes of an Alert or greater emergency classification level, respectfully.

NextEra further states that the augmenting three RP Technicians within 60 minutes of an Alert or greater emergency classification level report to the interim RP Supervisor provide RP support for the following:

Early, immediate reentry support of the OSC FIN Supervisor if directed by the Site Emergency Director (RP Technician 1);

Protected Area/Owner Controlled Area Field Monitoring Team (FMT) tasks supporting PAR development by providing early identification of releases and provide data inputs to dose assessment (RP Technician 2); and Other tasks as assigned, including support for the above tasks (RP Technician 3).

Additionally, NextEra states that with the NextEra CEP having a single OSC FIN Supervisor performing as the Repair Team Activities function as a single person, this frees up a second RP technician to provide the Protected Area/Owner Controlled Area FMT activities in lieu of supporting the second repair team reentry leaving the third RP technician responder to still be assigned other tasks, including supporting the second RP technician with FMT duties or the two on-shift RP Technicians with any tasks needed.

Because Point Beach and Saint Lucie will provide two RP Technicians on-shift with augmentation by three RP Technicians within 60 minutes and three RP Technicians within 90 minutes of an Alert or greater emergency classification level, the proposed changes are consistent with the guidance of NUREG-0654, Table B-1 and are therefore acceptable.

Because the proposed site-specific annexes for Seabrook and Turkey Point will maintain the existing ERO staffing for the RP function, the NRC staff finds the proposed changes to the proposed NextEra CEP with site-specific annexes acceptable.

Based on the above evaluation, the NRC staff has determined that the proposed NextEra CEP with site-specific annexes will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Radiation Protection function.

Supervision of RP Staff and Site RP The purpose of the supervision of RP staff and site RP functions is to: (1) evaluate and assess plant and offsite radiological data in the development of onsite protective actions and offsite PARs; (2) recommend onsite and offsite PARs to the applicable decision-maker; (3) direct all RP activities, including radiological FMT activities; and (4) provide relevant information to applicable communicators who are communicating offsite PARs to OROs.

NUREG-0654, Table B-1 recommends that the supervision of RP function be augmented by a Site RP Coordinator in the TSC within 60 minutes of an Alert or higher classification, and by a RP Manager in the EOF within 60 minutes of a Site Area Emergency or greater emergency classification level.

NextEra current RP Supervision ERO staffing is as follows:

Point Beach currently utilizes the Shift Manager to provide on-shift RP supervision with augmentation by a Site Radiation Protection Coordinator in the TSC within 60 minutes of an Alert or greater emergency classification level and an EOF Radiation Protection Manager within 90 minutes of an Alert or greater emergency classification level.

Saint Lucie currently utilizes the Shift Manager to provide on-shift RP supervision with augmentation by an RP Supervisor in the TSC within 60 minutes of an Alert or greater emergency classification level.

Turkey Point currently utilizes the Shift Manager to provide on-shift RP supervision with augmentation by an RP Coordinator in the TSC within 60 minutes of an Alert or greater emergency classification level.

Seabrook currently utilizes the Shift Manager to provide on-shift RP supervision with augmentation by an RP Coordinator in the TSC, an RP Coordinator in the EOF, and an Offsite Monitoring Coordinator in the EOF within 60 minutes of an Alert or greater emergency classification level.

The proposed NextEra CEP requires an RP Supervisor (TSC RP Coordinator or OSC RP Supervisor) to physically arrive on site within 60 minutes of an Alert or greater emergency classification level to address the Supervision of RP ERO staffing function.

Because the RP Supervisor (either a TSC RP Coordinator or OSC RP Supervisor) will provide support to the Shift Manager for the supervision of RP Technicians and site RP functions within 60 minutes of an Alert or greater emergency classification level until augmentation by the TSC RP Coordinator and OSC RP Supervisor (OSC RP Supervisor position is not required if TSC and OSC are co-located) within 90 minutes from the Alert or greater emergency classification level, the NRC staff finds the Supervision of RP staff and Site RP is acceptable.

Based on the above evaluation, the NRC staff has determined that the proposed NextEra CEP will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Supervision of RP Staff and Site RP function.

Dose Assessments/Projections The purpose of this function is to perform dose assessments and projections, and provide input to the Emergency Director, until relieved. NUREG-0654, Table B-1 identifies the dose assessment/projection function as an on-shift position and clarifies that: [o]ther personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time.

NextEra current dose assessment ERO staffing is as follows:

Point Beach currently has one individual who performs the shift dose assessor function as a collateral duty who is augmented by one TSC dose assessor within 60 minutes of an Alert or greater emergency classification level and one EOF dose assessor within 90 minutes of an Alert or greater emergency classification level.

Saint Lucie current emergency plan does not assign a Dose Assessor on-shift ERO collateral duty for the Dose Assessments/Projections function, although the on-shift Chemistry Technician is assigned the responsibility by procedure who is augmented by a TSC dose assessor within 30 minutes of an Alert or greater emergency classification level and an EOF dose assessor within 60 minutes of a Site Area Emergency or greater emergency classification level.

Turkey Point current emergency plan does not assign a Dose Assessor on-shift ERO collateral duty for the Dose Assessments/Projections function, although the on-shift Chemistry Technician is assigned the responsibility by procedure who is augmented by one TSC dose assessor within 30 minutes and an EOF dose assessor within 60 minutes of a Site Area Emergency or greater emergency classification level.

Seabrook currently has one individual who performs the shift dose assessment function as a collateral duty with augmentation by an EOF dose assessor who also performs the dose assessment function as a collateral duty within 60 minutes of an Alert or greater emergency classification level.

NextEra proposes one on-shift Dose Assessor augmented by one remote Dose Assessor within 60 minutes of an Alert or greater emergency classification level and one EOF Dose Assessor within 90 minutes of an Alert or greater emergency classification level.

NextEra states that the staffing for the on-shift Dose Assessor relies on procedure guidance (position checklist) to ensure dose assessment function is not impeded but allows for the person to perform alternate tasks if no release is occurring. The on-shift Dose Assessor function will be driven by a position checklist titled EP Operator. The EP Operator will be a field operator who is not assigned to the fire brigade, plant operations during off-normal conditions, or the concurrent performance of ERO functions such as command-and-control. The EP Operator will have the following priorities established in their position checklist:

1. If there is a release in progress due to the declared emergency:

a. The EP Operator will perform the dose assessment function until relieved by the Remote Dose Assessor.

b. When relieved by the Remote Dose Assessor, the EP Operator will perform the following:

i.

Maintain an open line with the NRC after initial communication from the Emergency Classification Advisor - OR -

ii. Take messages from offsite response organizations to pass to the Shift Manager if the EP operator cannot immediately answer the question.

2. If there is no release in progress, the EP Operator will perform the following:

a. Maintain an open line with the NRC after initial communication from the Emergency Classification Advisor - OR -

b. Take messages from offsite response organizations to pass to the Shift Manager if the EP operator cannot immediately answer the question.

3. If a release occurs prior to relief by the Remote Dose Assessor, and if the EP Operator is performing any other task other than dose assessment, then the EP Operator will be instructed by procedure to turn over the tasks to the Emergency Classification Advisor and perform the dose assessment function.

4. The Emergency Classification Advisor and the EP Operator have the ability to call in other field operators depending on the emergency to assist with the performance of the tasks if need be.

NextEra provides further clarification that the above tasks referenced as being performed by the Emergency Classification Advisor are performed or delegated by the Shift Manager/Emergency Director.

Because the proposed NextEra CEP will continue to provide the capability to perform dose assessment on shift with augmentation by one remote dose assessor within 60 minutes from an Alert or greater emergency classification level, and the proposed changes support extending the EOF dose assessor from within 60 minutes of a Site Area Emergency or greater emergency classification level to within 90 minutes of an Alert or greater emergency classification level, the NRC staff finds the Dose Assessments/Projections function is acceptable.

Based on the above evaluation, the NRC staff has determined that the proposed NextEra CEP with site-specific annexes would continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Dose Assessments/Projections function.

Emergency Classifications The purpose of the emergency classification function is to evaluate plant conditions and recommend emergency classification, until relieved. NUREG-0654, Table B-1 recommends that an emergency classification advisor perform this function on shift and clarifies that: [o]ther personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time. Additionally, NUREG-0654, Table B-1 recommends that the on-shift Emergency Classification Advisor be augmented by one Emergency Classification Advisor in the TSC within 60 minutes of an Alert or greater emergency classification level.

NextEra current emergency classification ERO staffing is as follows:

Point Beach currently has the Shift Technical Advisor or an Operating Supervisor performing the function as a collateral duty who is augmented by the TSC Emergency Classification Advisor within 60 minutes of an Alert or greater emergency classification level.

Saint Lucie currently has the Shift Technical Advisor or Unit Supervisor performing the function as a collateral duty who is augmented by one Classification Advisor in the TSC within 60 minutes of an Alert or greater emergency classification level and one Recovery Manager (RM) Operations Advisor in the EOF responding within 60 minutes of a Site Area emergency or greater emergency classification level.

Turkey Point currently does not assign an on-shift ERO collateral duty for the Emergency Classifications function, although the Shift Technical Advisor is assigned the responsibility by procedure who is augmented by one Classification Advisor in the TSC within 60 minutes of an Alert or greater emergency classification level and one RM Operations Advisor in the EOF responding within 60 minutes of a Site Area emergency or greater emergency classification level.

Seabrook currently has one Unit Supervisor as an on-shift position with collateral responsibility for the Emergency Classification function who is augmented by one TSC Operations Technician within 60 minutes of an Alert or greater emergency classification level.

NextEras proposed shift staffing is based on procedure guidance, via position checklists, and the use of established technology for offsite communications. The procedure guidance and technology were developed to address a wide range of emergency conditions. Regarding emergency planning functions associated with the Shift Manager/Emergency Director and the Emergency Classification Advisor (Command-and-control, Emergency Classifications, Communications, Supervision of Radiation Protection and Engineering), the position checklist must be developed to address a wide range of emergency conditions from plant equipment issues, fire, natural hazards, and hostile actions (for example).

NextEra stated that the simplistic task of the Emergency Classification Advisor to Evaluate plant conditions and recommend emergency classifications, until relieved was simply a description of the Senior Reactor Operator (SRO) in the affected control room as it is their responsibility to keep the Shift Manager abreast of the conditions of the event. NextEra concluded that due to their training and experience, and since they are experiencing the event in real time, the affected unit SRO would be the best person to provide advice and recommendations on emergency classification.

NextEra proposes that the Site Emergency Director (located in the TSC) will be responding within 60 minutes and a TSC Classification Advisor within 90 minutes from an Alert or greater emergency classification level to provide assistance to the Shift Manager/Emergency Director for the Emergency Classification function.

Because the proposed NextEra CEP would use the affected unit SRO to provide advice and recommendations on emergency classification to the Shift Manager with support provided by the Site Emergency Director in the TSC within 60 minutes and a TSC Classification Advisor within 90 minutes of an Alert or greater emergency classification level, the NRC staff finds that the Emergency Classification function is acceptable.

Based on the above evaluation, the NRC staff has determined that the proposed NextEra CEP would continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Emergency Classification function.

Engineering The purpose of the engineering function is to provide engineering coverage related to core/thermal hydraulics, electrical/instrumentation and control (I&C) systems and equipment, and mechanical systems and equipment, until relieved.

NUREG-0654, Table B-1 recommends a Core/Thermal Hydraulics Engineer to evaluate reactor conditions for the on-shift engineering function and clarifies that: [o]ther personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time. Additionally, it recommends augmentation by one Electrical/I&C engineer, one Mechanical Engineer and one Core/Thermal Hydraulics engineer within 60 minutes of an Alert or greater emergency classification level.

NextEra current engineering ERO staffing is as follows:

Point Beach currently has a Shift Technical Advisor on shift (as a collateral duty) and one Core/Thermal Engineer, one Mechanical Engineer, and one Electrical Engineer respond within 60 minutes of an Alert or greater emergency classification level.

Saint Lucie currently has a Shift Technical Advisor on shift (as a collateral duty) and one Core/Thermal Engineer responding within 30 minutes of an Alert or greater emergency classification level, and one Mechanical Engineer and one Electrical Engineer responding within 60 minutes of an Alert or greater emergency classification level.

Turkey Point currently has a Shift Technical Advisor on shift (as a collateral duty),

one Core/Thermal Engineer responding within 30 minutes of an Alert or greater emergency classification level, and one Mechanical Engineer and one Electrical Engineer responding within 60 minutes of an Alert or greater emergency classification level.

Seabrook currently has a Shift Technical Advisor on shift (as a collateral duty) and is augmented by one Electrical Engineer, one I&C Engineer, one Mechanical Engineer and one Reactor Engineer within 60 minutes of an Alert or greater emergency classification level.

NextEra proposes to have the Shift Technical Advisor on shift perform the Engineering function as a collateral duty, augmented by one Reactor Engineer, one Mechanical Engineer, and one Electrical Engineer responding remotely within 60 minutes of an Alert or greater emergency classification level.

Because the proposed NextEra staffing would provide engineering coverage within 60 minutes of an Alert or greater emergency classification, the NRC staff finds that the Engineering function is acceptable.

Based on the above evaluation, the NRC staff has determined that the proposed NextEra CEP with site-specific annexes would continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Engineering function.

Security NUREG-0654, Table B-1 recommends the on-shift security function to be provided by security staffing per the Site-Specific Security Plan. Table B-1 does not include on-shift staffing for security. Additionally, Table B-1 recommends augmentation by a Security Liaison within 60 minutes of an Alert or greater emergency classification level.

NextEra current security ERO staffing is as follows:

Point Beach currently has one on-shift Security Supervisor with augmentation by one Security Liaison in the TSC who would respond within 60 minutes of an Alert or greater emergency classification level.

Saint Lucie currently provides one on-shift Security Shift Supervisor with augmentation by an Emergency Security Manager in the EOF within 60 minutes of a Site Area Emergency or greater emergency classification level.

Turkey Point currently provides one on-shift Security Shift Supervisor with augmentation by one Security Supervisor in the TSC within 60 minutes of an Alert or greater emergency classification level and one Emergency Security Manager in the EOF within 60 minutes of a Site Area Emergency or greater emergency classification level.

Seabrook currently has one on-shift security shift supervisor with no augmentation.

NextEra proposes to have one on-shift Security Shift Supervisor per the site security plan augmented by one Security Liaison in the TSC within 90 minutes of an Alert or greater emergency classification level. The site-specific Physical Security Plan (PSP) defines on-shift security staffing. This PSP staffing supports initial event response, either security or emergency plan related. The Security Shift Supervisor communicates directly with the Shift Manager informing them of security-related actions and conditions. This communication does not change with the augmentation of the ERO.

NextEra further states that following the transfer of command-and-control, the Security Liaison position coordinates security and emergency related communications and response actions between the Site Emergency Director and the security force. NextEra concludes that the Security Liaison position provides communication and coordination resources that are not needed until the TSC and OSC are augmented at the 90-minute point in time.

Because the Security Shift Supervisor communicates directly with the Shift Manager informing them of security-related actions and conditions and this communication does not change with the augmentation of the ERO, and there is augmentation of an individual to act as the liaison between the site security force and the TSC when it is activated withing 90 minutes of an Alert or greater emergency classification level, the NRC staff finds that the Security function is acceptable.

Based on the above evaluation, the NRC staff has determined that the proposed NextEra CEP with site-specific annexes would continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Security function.

Repair Team Activities NUREG-0654, Table B-1 recommends that the following maintenance personnel should respond to the OSC to support repair team activities:

One electrician and one mechanic within 60 minutes of an Alert or greater emergency classification level to provide support for emergency core cooling system equipment, event mitigation, and equipment repair.

One I&C technician within 90 minutes of an Alert or greater emergency classification level to aid with logic manipulation, support for event mitigation and equipment repair, and support of digital I&C, if applicable.

NextEra current and proposed repair team ERO staffing is as follows:

Point Beach currently has one electrical technician and one mechanical technician in the OSC within 60 minutes of an Alert or greater emergency classification level, and one I&C technician in the OSC within 90 minutes of an Alert or greater emergency classification level.

Saint Lucie currently has one electrical technician and one I&C technician in the OSC within 30 minutes of an Alert or greater emergency classification level, and one additional electrical technician and two mechanical technicians in the OSC within 60 minutes of an Alert or greater emergency classification level.

Turkey Point currently has one electrical technician and one I&C technician responding to the OSC within 30 minutes of an Alert or greater emergency classification level, and one additional electrical technician and two mechanical technicians responding to the OSC within 60 minutes of an Alert or greater emergency classification level.

Seabrook currently has two electrical technicians, two mechanical technicians, and one I&C technician in the OSC within 60 minutes of an Alert or greater emergency classification level.

The proposed NextEra CEP with site-specific annexes requires the OSC FIN Supervisor to physically arrive on site by 60 minutes of an Alert or greater emergency classification level to address the Repair Team Activities function as an alternative approach. If an urgent/high priority repair activity is required prior to OSC activation at 90 minutes, the Site Emergency Director will direct the OSC FIN Supervisor to perform the required repair activity or provide assistance to operations to perform the repair activity.

NextEra states that the OSC FIN Supervisors are front line or greater supervisors at each nuclear site. ACAD 92-008, Guidelines for the Training and Qualification of Maintenance Personnel, drives the initial and continuing training of maintenance personnel, including the supervisors of maintenance personnel. NextEra further states that the OSC FIN Supervisors are trained, qualified and proficient to address equipment issues on emergency core cooling system equipment equivalent to maintenance personnel qualifications.

NextEra proposes to have one electrician, one mechanic, and one I&C technician in the OSC within 90 minutes of an Alert or greater emergency classification level.

Because the OSC FIN Supervisor is trained, qualified and proficient equivalent to both the mechanical and electrical technician and the OSC FIN Supervisor will respond within 60 minutes of an Alert or greater emergency classification level, with further augmentation of a mechanical, electrical and I&C technician within 90 minutes of an Alert or greater emergency classification level, the NRC staff finds the Repair Team Activities function is acceptable.

Based on the above evaluation, the NRC staff has determined that the proposed NextEra CEP with site-specific annexes will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Repair Team Activities function.

Supervision of Repair Team Activities NUREG-0654, Table B-1 recommends a lead OSC Supervisor to staff the OSC within 60 minutes with a mechanical supervisor, an RP supervisor, an electrical supervisor, and an I&C Supervisor (who may be combined with the electrical supervisor) to respond within 90 minutes of an Alert or greater emergency classification level.

NextEra current supervision of repair team activities ERO staffing is as follows:

Point Beach currently has one Lead OSC Supervisor and one Operations Supervisor in the OSC within 60 minutes of an Alert or greater emergency classification level, and one Electrical/I&C Supervisor and one Mechanical Supervisor in the OSC within 90 minutes of an Alert or greater emergency classification level.

Saint Lucie currently has one Lead OSC Supervisor and one FIN Supervisor in the OSC within 60 minutes of an Alert or greater emergency classification level.

Turkey Point currently has one Lead OSC Supervisor, one FIN supervisor in the OSC and one Maintenance Manager in the TSC responding within 60 minutes of an Alert or greater emergency classification level.

Seabrook currently has one Lead OSC Supervisor, one FIN Supervisor in the OSC, and one Maintenance Coordinator in the TSC responding within 60 minutes of an Alert or greater emergency classification level.

The proposed NextEra CEP with site specific annexes requires the OSC FIN Supervisor to physically arrive on site by 60 minutes of an Alert or greater emergency classification level to address the Repair Team Activities function as an alternative approach, with further augmentation by a Lead OSC Supervisor within 90 minutes of an Alert or greater emergency classification level.

NextEra states that OSC FIN Supervisors are front line or greater supervisors at each nuclear site. ACAD 92-008 drives the initial and continuing training of maintenance personnel, including the supervisors of maintenance personnel. OSC FIN Supervisors are trained, qualified and proficient to address equipment issues on ECCS equipment equivalent to maintenance personnel qualifications.

Because the OSC FIN Supervisor will respond to the site within 60 minutes of an Alert or greater emergency classification level and will be supporting the Repair Team Activities function until the augmentation of the Lead OSC Supervisor within 90 minutes from an Alert or greater emergency classification level, the NRC staff finds the Supervision of Repair Team Activities function is acceptable.

Based on the above evaluation, the NRC staff has determined that the proposed NextEra CEP with site-specific annexes would meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Repair Team Activities function.

Field Monitoring NUREG-0654, Table B-1 recommends one onsite FMT and one offsite FMT to be staffed within 60 minutes of an Alert or greater emergency classification level, and a second offsite FMT within 90 minutes of an Alert or greater emergency classification level. Each FMT would consist of a driver and one qualified individual (i.e., a field monitor) to assess the area for radiation and contamination. The field monitors for the offsite FMTs would also provide radioactive plume tracking.

NextEra current field monitoring team ERO staffing is as follows:

Point Beach currently has one onsite field monitoring technician and driver and one offsite field monitoring technician and driver responding within 60 minutes of an Alert or greater emergency classification level, and an additional offsite field monitoring technician and driver respond within 90 minutes of an Alert or greater emergency classification level.

Saint Lucie currently has two offsite field monitoring technicians responding within 30 minutes of an Alert or greater emergency classification level and two offsite field monitoring technicians, one onsite field monitoring technician and one onsite field monitoring driver responding within 60 minutes of an Alert or greater emergency classification level. Additionally, two onsite field monitoring technicians and two onsite field monitoring drivers would respond within 60 minutes of a Site Area Emergency or greater emergency classification level.

Turkey Point currently has two offsite field monitoring technicians responding within 30 minutes of an Alert or greater emergency classification level and two offsite field monitoring technicians responding within 60 minutes of an Alert or greater emergency classification level.

Seabrook has one onsite field monitoring technician and driver, two offsite field monitoring technicians and two offsite drivers responding within 60 minutes of an Alert or greater emergency classification level.

NextEra states that the FMT monitoring will be covered in two phases:

First phase, if a release is occurring, the interim Radiation Protection supervisor will direct an RP Technician to perform on-site (out-of-plant) Field Monitoring function at 60 minutes. The proposed NextEra CEP identifies an RP Technician performing the Field Monitoring function at 60 minutes as part of the RP function.

On-site (out-of-plant) is the area between site buildings and the Protected Area fence. The protected area of each NextEra site is small enough that a driver and vehicle are not required, so drivers and vehicles are not part of the first phase (Protected Area monitoring).

Second phase, two FMTs consisting of personnel qualified to perform FMT duties respond within 90 minutes of an Alert of greater emergency classification level.

These personnel are under the direction of the EOF RP Coordinator as they may or may not be American National Standards Institute fully qualified RP technicians.

At the direction of the EOF RP Coordinator, these FMTs can perform monitoring of the protected area, Owner Controlled Area, or the EPZ (offsite), depending on the release rate, duration, and distance. During the first phase, having RP Technicians performing the first phase of Protected Area monitoring is appropriate as they have the autonomy to perform the monitoring without the need for oversight from the Interim RP Supervisor. Additionally, an RP Technician can shift from identification to control and mitigation quickly to prevent the spread of any contamination noted from the release, protecting the responders who are arriving to the site at this time.

NextEra states that it has the capability to perform on site (out-of-plant) surveys as a means of early identification of releases and provide data inputs to dose assessment, with the augmentation of FMTs within 90 minutes of an Alert or greater emergency classification and, therefore, meets reasonable assurance of the FMT function.

Because NextEra is providing an RP Technician as a collateral duty within 60 minutes of an Alert or greater emergency classification level, RP Supervision support within 60 minutes of an Alert or greater emergency classification level, and augmentation by two FMT Technicians within 90 minutes of an Alert or greater emergency classification level, the NRC staff finds the Field Monitoring function is acceptable.

Based on the above evaluation, the NRC staff has determined that the proposed NextEra CEP with site-specific annexes would meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A with respect to the timely and effective performance of the Field Monitoring function.

Media Information The purpose of the media information function is to manage and coordinate media information related to the event. NUREG-0654, Table B-1 recommends that Joint Information Center (JIC)/Joint Information System (JIS) staff address media inquiries within 60 minutes of an Alert or greater emergency classification level but notes that this function does not need to be performed at the TSC or OSC but needs to be established at this point. NUREG-0654, Table B-1 further recommends additional staff to perform JIC/JIS-related functions within 60 minutes of a Site Area Emergency or greater classification. NUREG-0654 does not specify an on-shift capability and does not identify specific staff positions for the minimum staff for the JIC/JIS.

The proposed NextEra CEP with site-specific annexes includes augmentation of Remote JIS staff within 60 minutes of an Alert or greater emergency classification level, with further augmentation of a Site JIS Manager and a Site JIS Coordinator at the JIC, and a Remote JIS Manager-Remote within 90 minutes of an Alert or greater emergency classification level.

NextEra states that the NextEra Corporate Communications and key business units maintain a staff to operate a JIS for day-to-day operations and at all emergency classification levels. The NextEra Corporate Communications and key business units respond to media and public inquiries for abnormal conditions and events at any declared emergency classification level. The NextEra Corporate Communications and key business units coordinate with site management and ERO personnel, when staffed, to respond to media inquiries. Press releases are issued as appropriate from the NextEra Corporate Communications and key business units.

NextEra implements JIS practices that are capable of performing the media information function at all emergency classification levels. The near-site JIC is activated when determined appropriate with the offsite agencies (at an Alert or greater emergency classification level).

Because NextEra provides an organization to provide media information within 60 minutes an Alert or greater emergency classification level, with further augmentation within 90 minutes of an Alert or greater emergency classification level, the NRC staff finds the Media Information function is acceptable.

Based on the above, the NRC staff concludes that the proposed NextEra CEP with site-specific annexes will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.

Information Technology The purpose of the Information Technology (IT) function is to provide support for computer-based equipment if relied upon to perform emergency plan functions.

NUREG-0654, Table B-1 states that IT staffing is only required to be described in the emergency plan if critical digital assets (CDAs) are identified per 10 CFR 73.54, Protection of digital computer and communication systems and networks.

The proposed NextEra CEP relies on the Digital Control System/Emergency Response Data Acquisition and Display System for monitoring plant parameters, which NextEra has determined to be a CDA. The IT process for addressing issues with CDAs operates full time outside the emergency plan on a 24/7 basis. Additionally, NextEra maintains an IT Help Desk 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days a week. Many computer issues are addressed remotely with an IT specialist through the Help Desk.

NextEra states that each of the emergency plan-related digital assets were evaluated as part of implementation of the Cyber Security Rule, 10 CFR 73.54(b). Using the guidance in NEI 13-10, Cyber Security Control Assessments, Revision 7, dated October 2021(ML21342A203), that was endorsed by the NRC in letter dated May 22, 2022 (ML22112A139), EP Critical Digital Assets have been assessed and controls have been put in place to protect the assets against cyber-attack. In conjunction with these controls, alternate administrative, non-digital, or adequately independent means have been put in place for performing each EP function, should the digital component or program fail.

NextEra further states that performance of digital equipment used by the emergency plan has shown to be acceptable during drills and exercises, and through routine inventory and surveillance checks. Performance of digital assets is monitored through either the Corrective Action Program or the drill and exercise critique process. Performance trends are monitored, corrective actions are issued, and compensatory measures are taken as necessary. With the IT department process for 24/7 coverage and built-in redundancy for communication systems and digital EP assets, NextEra concludes that there is no need to maintain IT Technicians as minimum staff ERO positions.

Because NextEra maintains an IT department process for 24/7 coverage and built-in redundancy for communication systems and digital EP assets, the NRC staff finds the Information Technology function is acceptable.

Based on the above, the NRC staff concludes that the proposed NextEra CEP with site-specific annexes will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.

Radiological Assessment (Chemistry/Radiochemistry Task)

The chemistry/radiochemistry task was included under the radiological assessment function in the previous revision of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, dated November 1980 (ML040420012) (hereafter referred to as NUREG-0654, Revision 1), but is not included in NUREG-0654, Revision 2.

NextEra proposed to remove the chemistry/radiochemistry task, and chemistry technicians from the proposed NextEra CEP with site-specific annexes. NextEra states that chemistry functions are maintained in accordance with site technical specifications governed by licensing processes outside of the emergency plan. Additionally, NextEra states that on-shift responsibility for dose assessment is reassigned to a designated shift dose assessor in the proposed NextEra CEP with site-specific annexes.

Because the chemistry positions are not included in NUREG-0654, Revision 2, and the NextEra chemistry positions are not assigned emergency plan implementation functions, the NRC staff finds the proposed removal of the Radiological Assessment (Chemistry/Radiochemistry Task) function is acceptable.

Based on the above, the NRC staff concludes that the proposed NextEra CEP with site-specific annexes will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.

Firefighting/Rescue Operations and First Aid The firefighting/rescue operations and first aid functions were included in NUREG-0654, Revision 1, but are not included in NUREG-0654, Revision 2.

NextEra proposed to remove the firefighting/rescue operations and first aid functions from the proposed NextEra CEP with site specific annexes.

NUREG-0654, Table B-1 states that [t]he number of operations staff, security force staff, or fire brigade staff on-shift is controlled by the site-specific Technical Specifications or other licensing documents. NextEra proposes to remove the firefighting/rescue operations and first aid functions from the proposed NextEra CEP with site-specific annexes. NextEra will continue to maintain qualified fire brigade, rescue, and first aid personnel on shift controlled by applicable programs.

Because NextEra would continue to provide firefighting, rescue operations, and first aid in accordance with applicable programs and its proposal is consistent with NUREG-0654 guidance, the NRC staff finds the proposed removal of the Firefighting/Rescue Operations and First Aid functions is acceptable.

Based on the above, the NRC staff concludes that the proposed NextEra CEP with site-specific annexes will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.

Plant Operations and Assessment of Operational Aspects The plant operations and assessment of operational aspects function was included in NUREG-0654, Revision 1, but is not included in NUREG-0654, Revision 2. NUREG-0654, Table B-1 states that [t]he number of operations staff, security force staff, or fire brigade staff on-shift is controlled by the site-specific Technical Specifications or other licensing documents.

NextEra proposed to remove the plant operations and assessment of operational aspects function and associated operators from the proposed NextEra CEP with site-specific annexes.

Because NextEra would continue to provide operations staffing controlled by site-specific technical specifications or other licensing documents, and its proposal is consistent with NUREG-0654 guidance, the NRC staff finds the proposed removal of the Plant Operations and Assessment of Operational Aspects functions is acceptable.

Based on the above, the NRC staff concludes that the proposed NextEra CEP with site-specific annexes will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.

Minimum Augmenting ERO Positions NUREG-0654, Table B-1, Note iii states:

The minimum ERO staffing plan is that which is required to effectively implement the site-specific emergency plan (i.e., the emergency plan cannot be effectively implemented without this staff). The emergency plan should only describe the minimum ERO staffing plan, while supporting implementing procedures can describe any other staff response desired by the licensee, as this additional staff is not critical to effective emergency plan implementation. The augmentation times listed are intended to provide a model for applicants and licensees to consider in the development of their site-specific emergency plan.

NextEra states that the minimum augmenting ERO positions remaining in or added to the emergency plan are as follows:

TSC Site Emergency Director (previously Emergency Coordinator - TSC)

TSC Classification Advisor (previously Emergency Classification Advisor)

TSC RP Coordinator (previously Site RP Coordinator)

TSC ORO Communicator TSC ENS Communicator (previously NRC Communicator)

Reactor Engineer - Remote (previously Core/Thermal Engineer)

Electrical/I&C Engineer-Remote Mechanical Engineer-Remote Security Liaison OSC Lead OSC Supervisor FIN Supervisor (combined craft supervisors)

RPT Electrician I&C Technician Mechanic EOF EOF Manager (previously Emergency Director)

EOF RP Coordinator (previously EOF RP Manager)

EOF Dose Assessor Remote Dose Assessor-Remote (previously TSC Dose Assessor)

FMT Technician (previously onsite/offsite FMT)

FMT Driver (previously onsite/offsite FMT driver)

JIC Site JIS Manager (previously JIC Manager)

Site JIS Coordinator (previously JIC Coordinator)

Remote JIS Manager (previously Corporate JIC Manager)

Non-Minimum Augmenting ERO Positions (Support Positions)

NextEra states that non-minimum augmenting ERO positions that remain in the implementing procedures will be notified at the Alert emergency classification level, at the same time as the minimum augmenting ERO. However, non-minimum augmenting ERO positions are not required to be present to activate the facility and do not relieve the on-shift ERO of any emergency plan responsibilities. Non-minimum augmenting ERO positions have no augmentation time requirement.

Non-minimum augmenting ERO positions are being removed from the emergency plan but retained in the Emergency Plan Implementing Procedures. The tasks assigned to the non-minimum augmenting ERO positions in the current emergency plan were reviewed against current NRC guidance to ensure tasks for key functional areas are retained and performed by minimum augmenting ERO positions within the proposed emergency plan.

The non-minimum augmenting ERO will continue to be available and respond to declared emergencies. The non-minimum augmenting ERO will be notified at the same time as the minimum augmenting ERO to respond to their respective Emergency Response Facilities at an Alert or greater emergency classification level. As currently in place, the non-minimum augmenting ERO is not required to activate a facility.

In the supplement dated December 9, 2022, NextEra provided a table for each site that identified the current minimum and non-minimum staff ERO positions, by facility, in comparison to the proposed minimum and non-minimum staff ERO positions with a disposition for each position.

NextEra states that the proposed NextEra CEP with site-specific annexes includes title changes, and clarification of responsibilities. NextEra proposed changes to ERO staffing that were either not required or were performed by other individuals as discussed in the site-specific enclosures in the supplement dated December 9, 2022. NextEra states that all tasks previously assigned to eliminated ERO positions that involve response actions for key functions continue to be performed by the remaining ERO positions in the proposed emergency plan.

Based on the review of the site-specific ERO task disposition and assessment for positions removed from the NextEra CEP with site-specific annexes for each EP Function, the NRC staff finds the proposed minimum and non-minimum staff ERO positions are acceptable.

Based on the above, the NRC staff concludes that the proposed NextEra CEP with site-specific annexes will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.

3.2.2.2 Criterion II.B Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has defined on-shift responsibilities, provides adequate staffing to always maintain initial accident response in key functional areas, includes timely augmentation of response capabilities, and specifies the interfaces among various onsite and offsite response activities and support. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(2) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.3 Criterion II.C, Emergency Response Support and Resources NUREG-0654, Evaluation Criterion II.C, addresses the planning standard 10 CFR 50.47(b)(3),

which states:

Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensees Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.

Section IV.A.7 of Appendix E to 10 CFR Part 50 requires the identification of, and a description of the assistance expected from, appropriate State, local, and Federal agencies with responsibilities for coping with emergencies, including hostile action at the site.

Section IV.E of Appendix E to 10 CFR Part 50 requires in part, that adequate provisions shall be made and described for emergency facilities and equipment.

The requirements of 10 CFR 50.47(b)(3) and applicable requirements of Sections IV.A.7 and IV.E of Appendix E to 10 CFR Part 50 are addressed in portions of Section C, Emergency Response Support and Resources, of the proposed NextEra CEP with site-specific annexes.

3.2.3.1 NextEra CEP The proposed NextEra CEP states that the NextEra EOFs contain 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.

The proposed NextEra CEP states that 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.

The proposed NextEra CEP states that local support organizations may be called to assist onsite for events requiring firefighting, medical services, or law enforcement. Immediate assistance with firefighting, medical services, and law enforcement at the sites is initiated using pre-established site-specific communications systems. Agreements have been formally developed and documented through MOUs, contracts, and/or LOAs.

The proposed NextEra CEP states that 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 Emergency Operations Centers.

NextEra has radiological laboratories located at each site. The site laboratories are the central point for receipt and analysis of onsite samples and include 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.

The proposed NextEra CEP states that ERO personnel will activate and confirm activation of emergency response data system operation as soon as possible but no later than one hour of an Alert or greater emergency classification level.

The proposed NextEra CEP states that 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.

3.2.3.2 Emergency Plan Annexes Radiological laboratories, their general capabilities, and expected availability to provide radiological monitoring analysis services that can be used in an emergency are described in the site-specific annexes.

3.2.3.3 Proposed Changes to Site-Specific Emergency Plans NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.3.4 Criterion II.C Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has identified the arrangements for requesting and effectively using assistance resources, provided arrangements to accommodate State and local staff at the licensees EOF, and identified other organizations capable of augmenting the planned response. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(3) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.4 Criterion II.D, Emergency Classification System NUREG-0654, Evaluation Criterion II.D, addresses planning standard 10 CFR 50.47(b)(4),

which states:

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 local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Section IV.B.1 of Appendix E to 10 CFR Part 50 requires that [t]he means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining 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.

Section IV.C.2 of Appendix E to 10 CFR Part 50 requires that 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.

The requirements of 10 CFR 50.47(b)(4) and applicable requirements of Sections IV.B.1 and C.2 of Appendix E to 10 CFR Part 50, are addressed in Section D, Emergency Classification System, of the proposed NextEra CEP with site-specific annexes.

3.2.4.1 NextEra CEP The proposed NextEra CEP provides an overall discussion regarding classification of emergencies and the basis for emergency classification. The emergency action levels (EALs) for each site were developed in accordance with NRC endorsed guidance. Most recently, the industry developed NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6, dated November 21, 2012 (ML12326A805), which was endorsed by the NRC in a letter dated March 28, 2013 (ML13091A2090), as acceptable generic EAL scheme development guidance. The NextEra site EAL schemes have been approved by the NRC. The EALs for each respective site are documented in an EAL Technical Basis Document that is specific to each site. The EAL scheme for each site was agreed upon by State and local governmental authorities and is reviewed by State and local governmental authorities on an annual basis.

The proposed NextEra CEP states that 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.

3.2.4.2 Emergency Plan Annexes The site-specific annexes identify the EAL scheme document for each site.

3.2.4.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.4.4 Deviations NextEra identified deviations between the current site-specific emergency plan and the proposed NextEra CEP with site-specific annexes that could be considered a potential reduction in effectiveness:

Seabrook only Removal of Primary Responders at Unusual Event NextEra states that the NextEra CEP with site-specific annexes no longer differentiates the ERO by Primary, Subject to Call and Secondary responders. The NextEra CEP with site-specific annexes identifies the minimum staff positions and the non-minimum staff positions that will be identified in the implementing procedures.

NextEra states that the previous commitment in the current Seabrook Emergency Plan to call in several ERO positions at an Unusual Event is no longer required. NextEra stated that the review of licensing correspondence and commitments found no regulatory requirements for these actions. Changes in the EAL Scheme, communications systems and procedures ensure that the on-shift staff can address any emergency plan actions required for events classified as Unusual Events. The Seabrook Station and NextEra corporate offices maintain on-call duty personnel that may be contacted to assist the on-shift ERO as needed. ERO members will still be notified that an Unusual Event has been declared, to be prepared if a higher classification is necessary and may be called in at the discretion of the Shift Manager.

The guidance in NUREG-0654, Revision 1, states in part that the purpose of the Unusual Event classification level is to bring the operating staff to a state of readiness. Emergency facilities are typically not activated at the Unusual Event classification level. Additionally, there is no guidance in NUREG-0654, Revision 2 that calls for calling in personnel at the Unusual Event level, as activation of the TSC and OSC is performed at the Alert emergency classification level and EOF is performed at the Site Area Emergency classification level. Requiring the activation of the primary responders at the Unusual Event level represents a licensee self-imposed commitment that exceeds regulatory standards and requirements. Because the NextEra CEP with site-specific annexes activate the EOF, TSC and OSC at the Alert emergency classification level, the NRC staff finds that the proposed change to remove the activation of the primary responders at the Unusual Event emergency classification level is acceptable.

3.2.4.5 Criterion II.D Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has identified a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(4) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.5 Criterion II.E, Notification Methods and Procedures NUREG-0654, Evaluation Criterion II.E, addresses planning standard 10 CFR 50.47(b)(5),

which states:

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 Emergency Planning Zone [EPZ] have been established.

Section IV.D.1 of Appendix E to 10 CFR Part 50, requires that [a]dministrative and physical means for notifying local, State, and Federal officials 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.

Section IV.D.3 of Appendix E to 10 CFR Part 50 requires that [a] licensee shall have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency.

Section IV.D.3 further requires that [t]he design objective of the prompt public alert and notification system shall be 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 requirements of 10 CFR 50.47(b)(5) and applicable requirements of Section IV.D of Appendix E to 10 CFR Part 50, are addressed in Section E, Notification Methods and Procedures, of the proposed NextEra CEP with site-specific annexes.

3.2.5.1 NextEra CEP NextEra states that, in cooperation with the OROs, it has established mutually agreeable content, methods and procedures for notification of OROs. When an emergency classification 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.

NextEra states that the alert and notification system (ANS) is designed to provide an alerting signal to essentially 100 percent of the population on an area wide basis throughout the 10-mile EPZ. The OROs provide an informational or instructional message to the population via various methods as approved by the Federal Emergency Management Agency (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 local OROs or other responsible authority.

Detailed ANS information is maintained in the ANS design report for each site as listed in the site annexes.

In conjunction with OROs, NextEra nuclear sites have established the content of the initial notification message, as well as the follow-up notification message to be used during an emergency.

3.2.5.2 Emergency Plan Annexes The site-specific annexes identify the site-specific State and local OROs to be notified of a declared emergency. The annexes also provide a description of the site-specific ANS, and the responsibilities for activation of the ANS and the FEMA design report for each site.

3.2.5.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.5.4 Criterion II.E Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has established provisions for notification of State and local OROs and of licensee emergency personnel, the content of initial and follow-up messages to response organizations and means to provide early notification and clear instruction to the populace within the plume exposure pathway EPZ at each site. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(5) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.6 Criterion II.F, Emergency Communications NUREG-0654, Evaluation Criterion II.F, addresses planning standard 10 CFR 50.47(b)(6) which states:

Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.

Section IV.E of Appendix E to 10 CFR Part 50 requires that a licensee describe provisions for prompt communications among principal response organizations to emergency personnel and to the public.

Section IV.E.9 of Appendix E to 10 CFR Part 50 requires in part, [a]t 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.

Section IV.E.9.a of Appendix E to 10 CFR Part 50 requires [p]rovision for communications with contiguous State/local governments within the plume exposure pathway EPZ. Such communications shall be tested monthly.

Section IV.E.9.b of Appendix E to 10 CFR Part 50 requires [p]rovision for communications with Federal emergency response organizations. Such communications systems shall be tested annually.

Section IV.E.9.c of Appendix E to 10 CFR Part 50 requires [p]rovision for communications among the nuclear power reactor control room, the onsite technical support center, and the emergency operations facility; 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.

Section IV.E.9.d of Appendix E to 10 CFR Part 50 requires [p]rovisions for communications by the licensee with NRC Headquarters and the appropriate NRC Regional Office Operations Center from the nuclear power reactor control room, the onsite technical support center, and the emergency operations facility. Such communications shall be tested monthly.

The requirements of 10 CFR 50.47(b)(6) and applicable requirements of Section IV.E of Appendix E to 10 CFR Part 50 are addressed in Section F, Emergency Communications, of the proposed NextEra CEP with site-specific annexes.

3.2.6.1 NextEra CEP The proposed NextEra CEP states that each site maintains communications systems that are designed to facilitate normal and emergency communication. 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, and Data Systems.

The proposed NextEra CEP states, in part, that personnel within the Protected Area are notified of the emergency classification via the public address (PA) system. The sounding of alarms and announcement of the emergency classification and other pertinent data relating to the emergency classification are made over the PA system. 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.

NextEra states that the communication systems testing is accomplished in accordance with the proposed NextEra CEP Table F-1, Communication System Testing Requirements.

3.2.6.2 Emergency Plan Annexes The site-specific annexes list the available onsite and offsite emergency communication systems available at each site. Additionally, systems for coordinated communication methods for applicable fixed and mobile medical support facilities are described.

3.2.6.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.6.4 Deviations NextEra identified deviations between the site-specific current Emergency Plan and the proposed NextEra CEP with site-specific annexes that could be considered potential reductions in effectiveness:

Turkey Point and Saint Lucie Altered Annual Unannounced Communication Drills Requirement for an annual unannounced communications drill with the ORO has been removed.

NextEra states that ORO warning points are staffed 24/7 with communications tests required monthly. ERO performance of ORO notification are now monitored under the Reactor Oversight Process (ROP) inspection process by the drill/exercise performance indicator (DEP). Credited DEP notification is demonstrated on average more than 50 times per year. NextEra states, and the NRC staff agrees, that there is no regulation, guidance or inspection procedure that calls for an annual unannounced communications drill with the ORO.

NextEra concludes that restoring the scope and periodicity of communications drills and unannounced drills to consistency with the NUREG-0654 criteria does not impact the ability of the ERO or ORO to perform the notifications function, demonstrating full capability of the function.

Requirement for an annual unannounced communications drill with the ERO duty team has been changed to biennial.

NextEra states that NUREG-0654 calls for quarterly off-hours call-in drills, such that each ERO members normally expected response time is assessed at least biennially, with some drills being unannounced. The NextEra ERO notification is an all-call process, which for call-in drills will collect response time estimates from the entire ERO. This process validates all ERO members response time each time it is used. The NextEra CEP with site-specific annexes drill criteria requires that the biennial ERO call in drill to be unannounced.

NextEra concludes that this change aligns the NextEra CEP with site-specific annexes drill requirement with the intent of NUREG-0654 criteria and provides a shorter periodicity for the testing of the full ERO notification process (annual team testing results in full testing every four years vs. every two years under the new criteria). Adopting the NUREG-0654 criteria for ERO call-in drills does not impact the ability of the ERO to perform the augmentation function.

As described previously in this section, Table F-1, Communication System Testing Requirements, of the NextEra CEP with site-specific annexes provides the testing requirements for communication systems. The guidance in NUREG-0654 does not specify a frequency for the conducting communication drills. Requiring the unannounced communication drills annually represents a licensee self-imposed commitment that exceeds regulatory standards and requirements. Therefore, the NRC staff finds that the proposed change to the annual unannounced communication drills is acceptable.

3.2.6.5 Criterion II.F Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has established provisions for prompt communications among principal response organizations to emergency personnel and to the public. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(6) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.7 Criterion II.G, Public Education and Information NUREG-0654, Evaluation Criterion II.G, addresses planning standard 10 CFR 50.47(b)(7) which states:

Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dissemination of information during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of information to the public are established.

Section IV.D.2 of Appendix E to 10 CFR Part 50 requires a description of provisions for yearly dissemination to the public within the 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 population within the plume exposure pathway EPZ appropriate information that would be helpful if an accident occurs.

The requirements of 10 CFR 50.47(b)(7) and applicable requirements of Section IV.D.2 of Appendix E to 10 CFR Part 50 are addressed in Section G, Public Education and Information, of the proposed NextEra CEP with site-specific annexes.

3.2.7.1 NextEra CEP The proposed NextEra CEP states that NextEra, in coordination with the States and OROs, updates and distributes site-related emergency planning information annually to residents living within the plume-exposure pathway EPZ. Information disseminated to the public is in the form of printed or electronic materials. Public information for the transient population is also provided.

NextEra will conduct 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. The proposed NextEra CEP states that information for residents with special needs and non-English translations is incorporated per current federal guidance.

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.

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 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.

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 in media statements and at news conferences as appropriate.

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.

3.2.7.2 Emergency Plan Annexes A complete description of NextEras public education and information program is provided in the proposed NextEra CEP and is not addressed in the site-specific annexes.

3.2.7.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.7.4 Criterion II.G Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has established provisions for adequate public education and information to support the emergency response.

Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(7) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.8 Criterion II.H, Emergency Facilities and Equipment NUREG-0654, Evaluation Criterion II.H, addresses planning standard 10 CFR 50.47(b)(8),

which states:

Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Section IV.E.8.a of Appendix E to 10 CFR Part 50, requires that adequate provisions be made and described for emergency facilities and equipment, including a licensees onsite technical support center and an emergency operations facility from which effective direction can be given and effective control can be exercised during an emergency, and for a licensee onsite operational support center.

Section IV.E.8.b of Appendix E to 10 CFR Part 50 states in part, [f]or a nuclear power reactor licensees emergency operations facility required by paragraph 8.a of this section, either a facility located between 10 miles and 25 miles of the nuclear power reactor site(s).

Section IV.E.8.c.(1) of Appendix E to 10 CFR Part 50 requires that a facility have [t]he capability for obtaining and displaying plant data and radiological information for each reactor at a nuclear power reactor site and for each nuclear power reactor site that the facility serves;.

Section IV.E.8.c.(2) of Appendix E to 10 CFR Part 50 requires that a facility have [t]he capability to analyze plant technical information and provide technical 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;Section IV.E.8.d of Appendix E to 10 CFR Part 50 requires an alternative facility (for use when onsite emergency facilities cannot be safely accessed during hostile actions) that would be accessible and could function as a staging area for augmentation of emergency response staff.

Section IV.G of Appendix E to 10 CFR Part 50 requires a description of [p]rovisions to be employed to ensure that the emergency plan, its implementing procedures, and emergency equipment and supplies are maintained up to date.

The NRC staff evaluated the NextEra CEP with site-specific annexes against the guidance in NUREG-0654,Section II, Planning Standard H, which provides the detailed evaluation criteria that the NRC staff should consider when determining whether the emergency plan meets the applicable regulatory requirements in 10 CFR 50.47(b)(8).

The requirements of 10 CFR 50.47(b)(8) and applicable requirements of Sections IV.E.8 and IV.G of Appendix E to 10 CFR Part 50, are addressed in Section H, Emergency Facilities and Equipment, of the proposed NextEra CEP with site-specific annexes.

3.2.8.1 NextEra CEP The proposed NextEra CEP and site-specific annexes describe the emergency facilities, including the TSC, OSC, EOF, alternative facility, and various systems, equipment and capabilities supporting emergency response. The JIC and JIS concept described in the proposed NextEra CEP describes public education and information associated with emergency response. The site-specific annexes provide details for the JIC and JIS.

The proposed NextEra CEP describes various plant and environmental information sources, monitoring systems, analysis equipment and supplies, and field monitoring capabilities that are available at each site to support emergency response and are required by the applicable guidance. The NextEra CEP also describes the meteorological, hydrologic, seismic, and process monitoring systems and capabilities.

3.2.8.2 Emergency Plan Annexes The site-specific annexes provide locations of the TSC, OSC, EOF, alternate facility, and the JIC. These locations have not changed from those listed in the current site emergency plans.

3.2.8.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.8.4 Deviations NextEra identified deviations between the site-specific current emergency plans and the proposed NextEra CEP with site-specific annexes that could be considered a potential reduction in effectiveness:

Saint Lucie and Turkey Point Reduced Emergency Equipment and Kit Inventories Periodicity from Quarterly to Semiannually NextEra states that NUREG-0654 element H.11 calls for a description of the provisions made for the testing and maintenance of emergency use equipment and supplies. Previous versions (NUREG-0654 Revision 1 and draft Revision 2) specified a quarterly periodicity.

NextEra further states that requirements to calibrate emergency equipment and instruments are specified in site procedures [CEP - H.11.b] and continue to be performed per national standards or the manufacturers instructions. NextEra requires Ran operational check of emergency equipment and instruments prior to use by procedure. Historic records provide evidence that emergency use equipment and supplies inventories identify few, if any, issues such that an increased periodicity would not have an adverse effect on availability.

NextEra concludes that changing the inventory periodicity from quarterly to semi-annual does not degrade the capability of the equipment and supplies to perform their function.

The guidance in NUREG-0654 does not describe a frequency for the testing and maintenance of emergency use equipment and supplies. Initially, the NRC proposed a quarterly frequency in the draft version of NUREG-0654, but removed the frequency requirement based on adjudication of public comments (ML19350A378). Requiring an inventory periodicity quarterly represents a licensee self-imposed commitment that exceeds regulatory standards and requirements. Therefore, the NRC staff finds that the proposed change of the periodicity for the testing and maintenance of emergency use equipment and supplies is acceptable.

3.2.8.5 Criterion II.H Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has established provisions for adequate emergency facilities and equipment to support the emergency response. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(8) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.9 Criterion II.I, Accident Assessment NUREG-0654, Evaluation Criterion II.I, addresses planning standard 10 CFR 50.47(b)(9), which states:

Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Section IV.B.1 of Appendix E to 10 CFR Part 50, requires a description of [t]he means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials.

Section IV.E.2 of Appendix E to 10 CFR Part 50 requires a description of the [e]quipment

[used] for determining the magnitude of and for continually assessing the impact of the release of radioactive materials to the environment.

The requirements of 10 CFR 50.47(b)(9) and applicable requirements of Sections IV.B.1 and IV.E.2 of Appendix E to 10 CFR Part 50 are addressed in Section I, Accident Assessment, of the proposed NextEra CEP with site-specific annexes.

3.2.9.1 NextEra CEP The proposed NextEra CEP states that 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.

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, RASCAL 4: Description of Models and Methods, dated December 2012 (ML13031A448). 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 U.S. Environmental Protection Agency (EPA), EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, dated May 1992 (referred to as the EPA PAG Manual), 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 (CDE) 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.

Environmental surveys inside and outside the protected area are performed by FMT members under the direction of the EOF RP Coordinator. FMTs 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.

NextEra field monitoring equipment has the capability to detect and measure airborne radioiodine concentrations as low as 1 E-7 Ci/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 radiation prior to analyzing the sample cartridge.

NextEra maintains equipment for the NextEra FMTs. 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 FMTs is compared to data provided by state field monitoring teams that may be dispatched into the area. Data collected before State FMTs are in the field is made available to state dose assessment personnel.

3.2.9.2 Emergency Plan Annexes A description of 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 in the site-specific annexes.

3.2.9.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.9.4 Criterion II.I Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has established provisions for adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(9) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.10 Criterion II.J, Protective Response NUREG-0654,Section II.J, addresses planning standard 10 CFR 50.47(b)(10), which states:

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 (KI), as appropriate. Evacuation time estimates [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.

Sections IV.2 of Appendix E to 10 CFR Part 50 require nuclear power reactor licensees to provide an analysis of 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 of the applicant submits its application to the NRC.

Section IV.3 of Appendix E to 10 CFR Part 50 require nuclear power reactor licensees to use NRC-approved [ETEs] and updates to the ETEs in the formulation of [PARs], and to provide the ETEs and ETE updates to State and local governmental authorities for use in developing offsite protective action strategies.

Section IV.B.1 of Appendix E to 10 CFR Part 50 requires a description of the EALs 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.

Section IV.I of Appendix E to 10 CFR Part 50 requires that a range of protective 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 licensees emergency plan.

The requirements of 10 CFR 50.47(b)(10) and applicable requirements of Sections IV.2, IV.3, IV.B.1, and IV.I of Appendix E to 10 CFR Part 50 are addressed Section J, Protective Response, of the proposed NextEra CEP with site-specific annexes.

3.2.10.1 NextEra CEP The proposed NextEra CEP states that it 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 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 the owner-controlled area (OCA) for remaining individuals.

The proposed NextEra CEP states that 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 site. 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-specific annexes.

NextEra, in coordination with the site-specific OROs, developed site-specific protective action strategies, informed by the site-specific ETEs and based on the Federal guidance of NUREG-0654/FEMA-REP-1, Supplement 3, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants: Guidance for Protective Action Strategies, November 2011 (ML113010596) and the EPA PAG Manual.

The proposed NextEra CEP states that applicable plume exposure pathway EPZ PARs to evacuate, shelter, and take potassium iodide are developed at the General Emergency classification and provided to the ORO personnel responsible for making protective action decisions.

3.2.10.2 Emergency Plan Annexes Each site-specific annex contains a description of the evacuation processes and identifies the site-specific ETE report.

3.2.10.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.10.4 Criterion II.J Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has developed a range of protective actions for the plume exposure pathway EPZ for emergency workers and the public. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(10) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.11 Criterion II.K Evaluation, Radiological Exposure Control NUREG-0654, Evaluation Criterion II.K, addresses planning standard 10 CFR 50.47(b)(11),

which states:

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.

Sections IV.E.1 and IV.E.3 of Appendix E to 10 CFR Part 50 require [e]quipment at the site for personnel monitoring, and [f]acilities and supplies at the site for decontamination of onsite individuals.

The requirements of 10 CFR 50.47(b)(11) and applicable requirements of Sections IV.E.1 and IV.E.3 of Appendix E to 10 CFR Part 50 are addressed Section K, Radiological Exposure Control, of the proposed NextEra CEP.

3.2.11.1 NextEra CEP The proposed NextEra CEP states that the onsite exposure guidelines for emergency workers used in the CEP are consistent with Table 2-2, Guidance on Dose Limits for Workers Performing Emergency Services, of the EPA PAG Manual.

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, the proposed NextEra CEP states that 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. 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 RP procedures. RP 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.

The proposed NextEra CEP states that 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. 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.

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 RP personnel when responding to areas where a radiation dose may be received.

The proposed NextEra CEP states that 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.

3.2.11.2 Emergency Plan Annexes Each site-specific annex identifies the capability to decontaminate emergency workers, equipment, and vehicles, as follows:

Point Beach Facilities and supplies for decontaminating personnel are available at the RP station and OSC.

Saint Lucie Site Hot Locker Rooms - Showers and sinks available for the decontamination of personnel with no (or minor) injuries. One is located in the Auxiliary Building for each unit.

Site Decontamination Facility - The Site Assembly Station personnel decontamination capabilities consist of utilizing various types of decontamination agents, such as waterless cleaners and decontamination foams. A quantity of cloth material is available for use with these decontamination agents. Contamination monitoring is performed through the use of count rate instruments with beta sensitive probes. Extra clothing for personnel whose personal clothing has been contaminated is available in the form of disposable garments. Decontamination of vehicles will be handled following the accident. Methods for decontamination and monitoring are described in plant procedures.

Offsite Medical Centers - Lawnwood Regional Medical Center and Cleveland Clinic Martin Health are available for medical treatment and decontamination of contaminated injured individuals.

Turkey Point Personnel decontamination facilities are available in four locations. Their use will be governed by the nature of the incident.

Florida Power & Light Company Dress Out Building - Showers and sinks available for the decontamination of personnel with no (or minor) injuries.

Baptist Hospital of Miami - Decontamination shower and contaminated injury treatment room. For interim use to treat severely injured personnel. Located approximately 30 miles north of Turkey Point.

Mercy Hospital - Contaminated Injury Treatment Room. For interim use to treat severely injured personnel. Located approximately 30 miles north of Turkey Point.

Decontamination Facility - The Florida City Substation has personnel decontamination capabilities available.

Vehicles will be decontaminated with the use of Miami-Dade County Fire Department equipment.

Seabrook Station decontamination facilities are located in the Operations Support Center, specifically at the RCA Health Physics Control Point. The RCA shower is available for personnel decontamination purposes.

3.2.11.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.11.4 Criterion II.K Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has established appropriate means for controlling radiological exposures for emergency workers in an emergency. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(11) and applicable requirements of Section IV.E of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.12 Criterion II.L Evaluation, Medical and Public Health Support NUREG-0654, Evaluation Criterion II.L, addresses planning standard 10 CFR 50.47(b)(12),

which states:

Arrangements are made for medical services for contaminated injured individuals.

Sections IV.E.4 and E.5 of Appendix E to 10 CFR Part 50, require provisions for [f]acilities and medical supplies at the site for appropriate emergency first aid treatment, and [a]rrangements for medical service providers qualified to handle radiation emergencies onsite.

Sections IV.E.6 of Appendix E to 10 CFR Part 50, requires that arrangements are made for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary.

The requirements of 10 CFR 50.47(b)(12) and applicable requirements of Sections IV.E.4, E.5, and E.6 of Appendix E to 10 CFR Part 50 are addressed in portions of Section L, Medical and Public Health Support, of the proposed NextEra CEP with site-specific annexes.

3.2.12.1 NextEra CEP The proposed NextEra CEP describes medical and public health support. The proposed NextEra CEP states that 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 and injured persons. Descriptions of first aid equipment and supplies, and radiological monitoring and decontamination equipment and supplies are in site procedures. Arrangements have been made with local hospitals for the medical treatment of contaminated injured or overexposed 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. Primary and backup offsite medical facilities to treat contaminated injured personnel are described in the site-specific annexes to the proposed NextEra CEP. 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.

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.

3.2.12.2 Emergency Plan Annexes Each site-specific annex identifies the primary and backup offsite medical facilities to treat contaminated injured personnel, including arrangements for transportation of radiologically contaminated casualties, as follows:

Point Beach Primary - The Aurora Medical Center - Manitowoc County Backup - University Hospital and Clinics in Madison, Wisconsin Mishicot Ambulance Service is the primary provider for the transportation of contaminated, injured individuals. The City of Two Rivers may provide backup ambulance service to transport injured persons from Point Beach.

Saint Lucie Primary - Lawnwood Regional Medical Center in Ft. Pierce, Fl Backup - Cleveland Clinic Martin Health in Stuart, Fl St. Lucie County Fire District Rescue service, NextEra company, or private vehicle will provide transportation of personnel with injuries whether or not the injury is associated with radiation or contamination. The fire district rescue service is preferred, but in the case of injuries which require urgent transportation or external exposure without contamination, other transportation may be used.

Turkey Point Primary - Sheridan Emergency Physician Services of South Dade, located at Baptist Hospital of Miami Backup - Mercy Hospital of Miami Normal Miami-Dade County ambulance service, NextEra company vehicle, or private vehicle will provide transportation for injured personnel.

Seabrook Primary - The Exeter Hospital, Inc Backup - Wentworth-Douglass Hospital in Dover, NH The Seabrook Fire Department ambulance will be used for medical transportation of injured and contaminated personnel.

3.2.12.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.12.4 Deviations NextEra identified deviations between the site-specific current Emergency Plan and the proposed NextEra CEP that could be considered a potential reduction in effectiveness:

Seabrook only Reduced First Aid Responder Level NextEra states the current Seabrook Emergency Plan requires specific station personnel to be trained as Emergency Medical Technicians (EMTs). Additionally, a minimum of two Emergency Medical Technicians will be onsite at any one time to provide 24-hour emergency response coverage.

NextEra states that Nuclear System Operators (NSOs) will be trained in basic first aid and cardio-pulmonary resuscitation (CPR). All five NSOs assigned to a shift will be trained in first aid and CPR. Per site procedures, at least one trained NSO will be required to respond automatically with the Fire Brigade Leader to a medical emergency on back shifts. In cases where total involvement of the Fire Brigade Leader in patient care is required, Incident Command can be transferred to a responding NSO.

NextEra further states that Seabrook will retain the capability to provide first aid to contaminated injured individuals. The onsite capability to provide first aid on a continuous basis until local support arrives will continue. Two on-shift staff will continue to be available to provide rescue operations and first aid.

The guidance in NUREG-0654, Revision 2 does not describe a level of first aid training.

However, the current Seabrook Emergency Plan is based on the guidance in NUREG-0654, Revision 1 and the guidance did specify a level of training to include courses equivalent to Red Cross Multi-Media. Requiring training at the current EMT level represents a licensee self-imposed commitment that exceeds regulatory standards and requirements. Therefore, the NRC staff finds that the proposed change for personnel assigned as first aid responders to maintain qualifications equivalent to Red Cross Standard First Aid techniques would provide an onsite first aid capability with adequate medical equipment and supplies and is in accordance with NUREG-0654, Revision 2 and is therefore acceptable.

3.2.12.5 Criterion II.L Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has established arrangements for medical services for contaminated injured individuals. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(12) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.13 Criterion II.M Evaluation, Recovery, Reentry Planning and Post-Accident Operations NUREG-0654, Evaluation Criterion II.M, addresses planning standard 10 CFR 50.47(b)(13),

which states:

General plans for recovery and reentry are developed.

Section IV.H of Appendix E to 10 CFR Part 50 requires a description of the [c]riteria to be used to determine when, following an accident, reentry of the facility would be appropriate or when operation could be resumed.

The requirements of 10 CFR 50.47(b)(13) and applicable requirements of Section IV.H of Appendix E to 10 CFR Part 50 are addressed in portions of Section M, Recovery and Reentry Planning and Post-Accident Operations, of the proposed NextEra CEP.

3.2.13.1 NextEra CEP The proposed NextEra CEP addresses general principles that serve as guides for developing a recovery plan. NextEra states that 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. 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 Recovery Manager, Onsite Recovery Coordinator, Offsite Recovery Coordinator, Radiological Assessment Coordinator (if needed), and the Spokesperson.

The proposed NextEra CEP states that steps will be taken to terminate 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; and Site access not limited for personnel and support services.

The proposed NextEra CEP states that, 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.

3.2.13.2 Emergency Plan Annexes A complete description of NextEras recovery, reentry, and post-accident operations is provided in the proposed NextEra CEP and is not addressed in the site-specific annexes.

3.2.13.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.13.4 Criterion II.M Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has developed general plans for recovery and reentry. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(13) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.14 Criterion II.N Evaluation, Exercises and Drills NUREG-0654, Evaluation Criterion II.N, addresses planning standard 10 CFR 50.47(b)(14),

which states:

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.

Section IV.F of Appendix E to 10 CFR Part 50, requires a description of [t]he program to provide for: (a) The training of employees and exercising, by periodic drills, of emergency plans to ensure that employees of the licensee are familiar with their specific emergency response duties, and (b) The participation in the training and drills by other persons whose assistance may be needed in the event of a radiological emergency.

The requirements of 10 CFR 50.47(b)(14) and applicable requirements of Section IV.F of Appendix E to 10 CFR Part 50 are addressed in portions of Section N, Exercises and Drills, of the proposed NextEra CEP.

3.2.14.1 NextEra CEP The proposed NextEra CEP states that an exercise 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.

The proposed NextEra CEP states that following exercises and drills, a critique is conducted to evaluate areas and identify issues with performance, response procedures, and facility and equipment adequacy. It further states that provisions are made for federal and ORO representatives to observe and participate in drill and exercise critiques when present.

The proposed NextEra CEP states the licensee 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 key skills necessary to implement the principal functional areas of emergency response (those which test the adequacy of timing and content of implementing procedures, test equipment and communications networks, and ensure that the ERO personnel are familiar with their duties). State, local OROs and tribal authorities are invited to participate in performance enhancement program (PEP) exercises.

Additionally, the proposed NextEra CEP provides a description of the types of exercises and drills, as well as a description of the various required scenario elements to be conducted within the eight-year exercise cycle.

3.2.14.2 Emergency Plan Annexes A complete description of NextEras exercises and drills program is provided in the proposed NextEra CEP. Point Beach, St. Lucie and Turkey Point sites previously received license amendments for relief from the Technical Specification requirements for the Post-Accident Sampling system, however Seabrook maintains this requirement and therefore the requirement for a Post-Accident Sampling Drill is only addressed in the Seabrook annex. The Seabrook annex states that Post-Accident Sampling Drills will be conducted annually. These drills will address capabilities including analysis of liquid and containment atmosphere samples with simulated elevated radiation levels.

3.2.14.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.14.4 Deviations NextEra identified deviations between the site-specific current Emergency Plan and the proposed NextEra CEP that could be considered a potential reduction in effectiveness:

Point Beach only Eliminated Annual Site Assembly, Accountability, and Evacuation Drills NextEra proposes to remove the requirement for annual site assembly, accountability, and evacuation drills at Point Beach, to align the fleet with NUREG-0654 guidance. NextEra states that Point Beach installed an annual assembly drill in 2003 via the 10 CFR 50.54(q) process in response to questions from the NRC regarding the knowledge of the ERO and Non-ERO personnel on assembly locations. This was not a formal commitment to the NRC to maintain this activity. Through the following years, the annual assembly drill has been completed without incident. The drills have not had any issues of personnel not knowing expected actions and where to assemble. Initial training and continuing training for site access will retain information on locations of assemblies and expected personnel response. As part of the overall drill and exercise program the ERO is drilled to validate the site protective action processes, with limited participation of non-ERO personnel.

The guidance in NUREG-0654 does not describe annual site assembly, accountability, or evacuation drills. Requiring these drill requirements represents a licensee self-imposed commitment that exceeds regulatory standards and requirements. Therefore, the NRC staff finds that the proposed change to remove the requirements for annual site assembly, accountability, and evacuation drills is acceptable.

Point Beach only Changed Frequency of Augmentation Drill from Annually to Once per Eight-Year Cycle NextEra proposes to change the current Point Beach Emergency Plan requirement for an annual augmentation drill for the ERO duty team to once per eight-year cycle. NUREG-0654, Revision 2, Element N.4.h requires that off-hours report-in drills be unannounced and conducted biennially. The proposed NextEra CEP specifies that an unannounced off-hours report-in drill be performed once per 8-year cycle.

NextEra further states that the NextEra ERO notification is an all-call process, which for call-in drills will collect response time estimates from the entire ERO. This process validates all ERO members response time each time it is used. The proposed NextEra CEP drill criteria requires that the biennial ERO call in drill be unannounced. This change aligns the proposed NextEra CEP drill requirement with the intent of NUREG-0654 criteria.

NextEra concludes that performance of the Element N.4.h call-in drill biennially provides sufficient demonstration of off hours augmentation capability without significant impact on employees during late non-working hours. The proposed frequency for ERO call-in and report in drills will not impact the ability of the ERO to perform the augmentation function.

The adjudication of public comments for the draft version of NUREG-0654 (ML19350A378) states that a 2-year cycle is specified because plants have multiple teams and there is staff turnover in between drills. The 2-year cycle allows for testing of all teams during the 8-year exercise cycle and is consistent with the licensee exercise of its onsite emergency plan.

However, since NextEra uses an all-call process, which tests all teams simultaneously. This eliminates the need to test a different team every two years and meets the testing intent of the guidance in NUREG-0654. Therefore, the NRC staff finds that the proposed change to the frequency of augmentation drill from annually to once per eight-year cycle is acceptable.

Seabrook only Reduced ERO Testing Periodicity NextEra proposes to remove the notification of weekly primary responders and annual secondary responders pager test as the NextEra CEP no longer differentiates by Primary, Subject to Call and Secondary responders. The NextEra CEP identifies minimum staff positions; non-minimum staff positions will be identified in the implementing procedures. Neither 10 CFR 50.47, Appendix E, or NUREG-0654 Revision 1 or Revision 2 contain criteria requiring ERO pager testing periodicity to be contained in the emergency plan.

NextEra further states that the ERO notification system is tested several times a year during the conduct of drills and exercises. The ability to augment the on-shift response capabilities within a short period of time is demonstrated and evaluated during the drills and exercises. The call-in drills collect response time estimates from the entire ERO. This process validates all ERO members response times each time it is used. The current Seabrook Emergency Plan ERO pager tests are not required to comply with the 10 CFR 50.47 and Appendix E regulations.

The guidance in NUREG-0654 does not describe criteria requiring an ERO pager testing periodicity. Requiring this testing represents a licensee self-imposed commitment that exceeds regulatory standards and requirements. Therefore, the NRC staff finds that the proposed change remove the requirement for the criteria requiring ERO pager testing periodicity is acceptable.

3.2.14.5 Criterion II.N Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra will conduct periodic exercises to evaluate major portions of emergency response capabilities, conduct periodic drills to develop and maintain key skills, and adequately correct deficiencies identified as a result of exercises or drills. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(14) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.15 Criterion II.O, Radiological Emergency Response Training NUREG-0654, Evaluation Criterion II.O, addresses planning standard 10 CFR 50.47(b)(15),

which states:

Radiological emergency response training is provided to those who may be called on to assist in an emergency.

Section IV.F(1) of Appendix E to 10 CFR Part 50 requires in part, a description of [t]he program to provide for: (a) The training of employees and exercising, by periodic drills, of emergency plans to ensure that employees of the licensee are familiar with their specific emergency response duties, and (b) The participation in the training and drills by other persons whose assistance may be needed in the event of a radiological emergency.

The requirements of 10 CFR 50.47(b)(15) and applicable requirements of Section IV.F of Appendix E to 10 CFR Part 50 are addressed in portions of Section O, Radiological Emergency Response Training, of the proposed NextEra CEP.

3.2.15.1 NextEra CEP The proposed NextEra CEP states that initial training and annual retraining will be conducted for members of the ERO and offered 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.

The ERO training program is developed and evaluated based on position-specific responsibilities/tasks using Systems Approach to Training (SAT) principles, when applicable.

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. 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.

3.2.15.2 Emergency Plan Annexes A complete description of NextEras radiological emergency response training is provided in the proposed NextEra CEP and is not addressed in the site-specific annexes.

3.2.15.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.15.4 Deviations NextEra identified deviations between the site-specific current Emergency Plan and the proposed NextEra CEP that could be considered a potential reduction in effectiveness:

All Sites Removed EP Initial Training of Non-ERO Personnel NextEra proposes to remove EP initial training of non-ERO personnel. NextEra states that NUREG-0654 Revision 1 and Revision 2 do not contain criteria requiring a description of training for non-ERO/non-essential personnel within the emergency plan. NextEra further states, and the NRC agrees, that no regulation, other guidance document or inspection procedure calls for a description of non-ERO general employee training to be contained in the emergency plan.

NextEra states that general industrial safety information, which includes awareness and expectations for normal, off normal and emergency situations is provided to all personnel given unescorted access onto the site. General employee training for unescorted site access includes the topics of safety conscious work environment, stormwater pollution prevention, spill prevention and control, hearing conservation, emergency plan, and fire extinguishers and is presented in the National Academy for Nuclear Training e-Learning Generic Awareness and NextEra site-specific site access training courses.

NextEra further stated that site-specific general awareness training scope (industrial and emergency condition related) is governed and controlled outside the emergency plan.

Emergency plan awareness content review in general employee training by personnel knowledgeable of the emergency plan is provided in document controls processes and procedures. These processes and procedures are also applicable to changes to made by other non-EP departments that could potentially impact the emergency plan.

The guidance in NUREG-0654 provides for the training of emergency responders and other appropriate individuals with an operational role [to be] described in the emergency plan with

[i]nitial training and at least annual retraining to be provided. Requiring this training of non-ERO personnel represents a licensee self-imposed commitment that exceeds regulatory standards and requirements. Therefore, the NRC staff finds that the proposed change to not require initial emergency plan training for non-ERO/non-essential personnel is acceptable.

3.2.15.5 Criterion II.O Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has established radiological emergency response training for those who may be called on to assist in an emergency. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(15) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.2.16 Criterion II.P, Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans NUREG-0654, Evaluation Criterion II.P, addresses planning standard 10 CFR 50.47(b)(16),

which states:

Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

Section IV.G of Appendix E to 10 CFR Part 50, requires a description of the [p]rovisions to be employed to ensure that the emergency plan, its implementing procedures, and emergency equipment and supplies are maintained up to date.

The requirements of 10 CFR 50.47(b)(16) and applicable requirements of Section IV.G of Appendix E to 10 CFR Part 50 are addressed in Section P, Responsibility for the Preparedness Effort, of the proposed NextEra CEP with site-specific annexes.

3.2.16.1 NextEra CEP The proposed NextEra CEP states that 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. The NextEra Chief Nuclear Officer has the overall authority and responsibility for the NextEra Emergency Plan. The site Regulatory Affairs Managers are responsible for the development, maintenance, review, and updating of the emergency plan and site-specific annexes, as well as the coordination of the plan with other response organizations.

The proposed NextEra CEP states that the formal emergency plan and the emergency plan implementing procedures 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. LOAs will be reviewed and verified on an annual basis and updated if warranted. Emergency plan changes will be processed in accordance with 10 CFR 50.54(q) requirements and NextEra document control/records management procedures.

An independent review of the emergency plan will be conducted in accordance with the requirements of 10 CFR 50.54(t)(2).

A listing of emergency plan extension documents is included in the Introduction section of the NextEra CEP. Section A.1.a of the NextEra CEP lists external organizations having an operational role in supporting the NextEra CEP. Table P.7-1, Emergency Plan Implementing Procedures, will provide 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 upon approval of the NextEra CEP. A listing, by title, of the site-specific response and maintenance procedures required to implement the emergency plan is provided in the site annexes. The NextEra CEP contains a specific table of contents, and the NextEra CEP and site-specific annexes are numbered corresponding to NUREG-0654 evaluation criteria.

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.

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.

3.2.16.2 Emergency Plan Annexes Each site-specific annex lists the primary external emergency plans specific to the support that site. Additionally, table P.7-1 in each site-specific annex will provide a listing of the site-specific procedures required to maintain and implement the emergency plan following the common emergency plan and site-specific annex approval.

3.2.16.3 Proposed Changes to NextEra CEP with Site-Specific Emergency Annexes NextEra states that the proposed NextEra CEP with site-specific annexes standardizes the emergency plans across the fleet and aligns the wording among the existing plans without adding, removing or altering commitments or changing intent.

3.2.16.4 Deviations NextEra identified deviations between the site-specific current Emergency Plan and the proposed NextEra CEP that could be considered a potential reduction in effectiveness:

All Sites Reduced ERO Roster Review Periodicity from Quarterly to Semiannually NextEra states that due to the local relationships and the advancement of technology, the quarterly emergency telephone directory review is being changed to a semi-annual review.

Historically, little change between quarters has occurred such that changing to a semi-annually review would have little impact on accuracy.

With cellular phones being the primary notification tool for ERO personnel, there are not nearly as many changes of phone numbers. In the past, if an individual moved their residence, their phone number likely did not travel with them as the numbers were tied to geographical regions within the city or town they were moving (land lines). With cell phones and changes to long distance billing, many people keep their same cell phone number as they move, whether across town or across the country.

Most businesses or other support contacts that are listed in emergency telephone directory are established entities that do not change their business lines often enough to warrant a check every quarter. In addition, the internet is now the primary location to obtain business numbers.

With these numbers readily available, fewer numbers are required to be maintained in EP phone lists.

The guidance in NUREG-0654 does not describe a frequency for the process for updating and reviewing contact information. Initially, the NRC proposed a quarterly frequency in the draft version of NUREG-0654 but removed the frequency requirement based on adjudication of public comments (ML19350A378). Requiring this frequency for the process for updating and reviewing contact information represents a licensee self-imposed commitment that exceeds regulatory standards and requirements. Therefore, the NRC staff finds that the proposed change to the process for updating and reviewing contact information to semiannual is acceptable.

3.2.16.5 Criterion II.P Evaluation Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff concludes that NextEra has identified the responsibilities for plan development/review, for distribution of emergency plans, and that planners are properly trained. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(16) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.

3.3 Conclusion Based on the NRC staffs review and evaluation of the information in NextEras application and supplemental letters as described above, the NRC staff finds that the proposed changes in the NextEra CEP with site-specific annexes continue to meet the standards in 10 CFR 50.47(b)(1) through (b) (16), and the requirements in Appendix E to 10 CFR Part 50, and that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Point Beach, Turkey Point, Saint Lucie and Seabrook. Specifically, the staff concludes that the proposed NextEra CEP as supplemented by letter dated September 25, 2024, and the Point Beach, Turkey Point, Saint Lucie and Seabrook site-specific annexes as supplemented by letter dated September 16, 2024, are acceptable for implementation.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the NRC staff notified officials from the States of Wisconsin, New Hampshire, Florida, and the Commonwealth of Massachusetts on November 6, 2024, of the proposed issuance of the amendments. The State officials had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20, as well as recordkeeping, reporting, or administrative procedures or requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on February 21, 2023 (88 FR 10557). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

Based on the aforementioned considerations, the NRC staff concluded that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: M. Norris J. Herrera Date of Issuance: December 13, 2024

ML24285A103 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NSIR/DPR/RLB/BC OGC w/Comments NAME JPoole KZeleznock JQuichocho DRoth DATE 10/16/2024 10/16/2024 10/04/2024 11/12/2024 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NRR/DORL/D NRR/DD NAME HGonzález JPoole BPham MFranovich DATE 11/01/2024 11/20/2024 11/13/2024 12/13/2024