ML24361A094
| ML24361A094 | |
| Person / Time | |
|---|---|
| Issue date: | 01/21/2025 |
| From: | Michael Waters Policy and Oversight Branch |
| To: | Dobitsch S Federal Emergency Management Agency |
| References | |
| Download: ML24361A094 (1) | |
Text
Stephanie Dobitsch Assistant Administrator National Preparedness Directorate Federal Emergency Management Agency 400 C Street, SW Washington, DC 20024
SUBJECT:
SUSQUEHANNA STEAM AND ELECTRIC STATION ALERT AND NOTIFICATION SYSTEM EVALUATION REPORT
Dear Ms. Dobitsch:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated the letter August 27, 2024, which provided the Federal Emergency Management Agency (FEMA) approval of Revision 0 of the Susquehanna Steam and Electric Station (SSES) Alert and Notification System Evaluation Report (ANS Design Report) which was received on September 25, 2024.1 As described in Revision 0 of the SSES ANS Design Report, the station selected the Integrated Public Alert and Warning System (IPAWS) wireless emergency alerts and the emergency alert system as the primary alerting and notification methods for the 10-mile Emergency Planning Zone. Additionally, a mass notification system (MNS) was selected to be the independent back-up alerting and notification method.
Per Section V, Parts A and B of the Memorandum of Understanding (MOU) between the Department of Homeland Security (DHS/FEMA) and the NRC regarding radiological emergencies, planning, and preparedness, dated July 1, 20242:
FEMA coordinates all Federal planning for offsite impact of radiological emergencies and takes the lead for assessing offsite radiological emergency response plans and preparedness, makes findings and determinations as to the adequacy and capability of implementing offsite plans, and communicates those findings and determinations to the NRC. As outlined within Section V, Part A, FEMA Approves Alert and Notification System (ANS) design reports. When the ANS design report undergoes significant changes, including any changes to primary and back-up alert methods, FEMA will allow the NRC to review the ANS design report to ensure that the NRC-regulated aspects of ANS are maintained.
As outlined within Section V, Part B, The NRC reviews FEMA's findings and determinations in conjunction with the NRC onsite findings for the purpose of making 1 NRCs Agencywide Documents Access and Management System (ADAMS) Accession No. (ML22263A280) 2 ADAMS (ML24184A043)
January 21, 2025
S. Dobitsch determinations on the overall state of emergency preparedness. These overall findings and determinations are used by the NRC to make radiological health and safety decisions in the issuance of licenses and the continued operation of licensed utilization facility to include taking enforcement actions such as notices of violations, civil penalties, orders, or shutdown of operating reactors. This delineation of responsibilities avoids duplicative efforts by the NRC in preparedness matters. Additionally, as outlined within Part B, the NRC Reviews FEMA's findings and determinations of offsite plans to determine that the plans, including ANS design reports, are adequate and can be effectively implemented.
The NRC evaluated the updated SSES ANS Design Report received on September 25, 2024, and found that it contained sufficient information to be considered an adequate submittal for NRC to conduct its review. At this time, the NRC did not identify any licensing basis issues associated with the SSES ANS Design Report.
Consistent with the roles of each respective agency as set forth in the aforementioned MOU, the NRC conducted a review of the FEMA findings. To aid its review, the NRC utilized the FEMA evaluation criteria and sample template for ANS changes and use of IPAWS3. The NRC review focused on the applicable requirements in Title 10 of the Code of Federal Regulations (10 CFR)
Section 50, Appendix E,Section IV.D.3.
The SSES ANS Design Report utilizes internet or cellular based systems for both the primary and back-up ANS. The staff conducted a risk-informed assessment and thorough review to determine if there is reasonable assurance that backup capability for alert and notification would be available in the event the primary method is unavailable during an emergency. Therefore, the NRC considered the reliability of the SSES systems and potential common failure modes. In addition, the NRC also considered as defense-in-depth, the Realism rule in 10 CFR 50.47(c)(1),
which notes that under extreme circumstances and radiological emergencies (inclusive of both primary and back-up ANS failures), the Offsite Response Organizations (ORO) will deploy all available resources, technology, and personnel to support public messaging and safety.
In conclusion, the NRC accepts the findings of FEMA that Revision 0 of the SSES Alert and Notification System Evaluation Report meets the applicable requirements in 10 CFR 50, Appendix E, Section IV.D.3, and enables the NRC to make a finding of reasonable assurance for public health and safety.
Please feel free to contact my staff, Cindy Rosales-Cooper, Acting Chief, Policy and Oversight Branch at (301) 287-9500 or at Cindy.Rosales-Cooper@nrc.gov, if you have questions.
Sincerely, Michael Waters, Acting Director Division of Preparedness and Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission 3 ADAMS Accession No. ML19339G862, ADAMS Accession No. ML2107A238 Signed by Waters, Michael on 01/21/25