BSEP 17-0046, Revision to Radiological Emergency Response Plan and Implementing Procedure

Revision to Radiological Emergency Response Plan and Implementing Procedure

ML17137A104
Person / Time
Site:	Brunswick
Issue date:	05/16/2017
From:	Wooten B Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 17-0046
Download: ML17137A104 (292)

Text

( -, DUKE Brunswick Nuclear Plant P .0. Box 10429 ENERGY Southport, NC 28461 MAY *1 6 2017 10 CFR 50.4(b )(5)(iii) 10 CFR 50.54(q)(5)

Serial: BSEP 17-0046 10 CFR 72.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Revision to Radiological Emergency Response Plan and Implementing Procedure Ladies and Gentlemen:

In accordance with 10 CFR 50.4(b)(5)(iii); 10 CFR 50.54(q)(5); and 10 CFR 72.4; Duke Energy Progress, LLC (Duke Energy), is submitting a revision to OERP, Radiological Emergency Response Plan (ERP), and to Emergency Plan Implementing Procedure OPEP-02.1.1, Emergency Control - Unusual Event, Alert, Site Area Emergency, and General Emergency, both of which became effective April 18, 2017.

Duke Energy has evaluated these revisions, in accordance with 10 CFR 50.54(q), and determined that the revisions are not a reduction in the effectiveness of the Radiological Emergency Response Plan and that the Plan, as changed, continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. Enclosure 1 provides a 10 CFR 50.54(q)(5) summary for the revised Radiological Emergency Response Plan and implementing procedure. Enclosure 2 contains a copy of the revised Radiological Emergency Response Plan. Enclosure 3 contains a copy of the revised Emergency Plan implementing procedure.

This document contains no regulatory commitments.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.

Sincerely,

~ - 3. w~

Bryan7 .wooten Director - Organizational Effectiveness Brunswick Steam Electric Plant

U.S. Nuclear Regulatory Commission Page 2 of 2 WRM/wrm

Enclosures:

1. 10 CFR 50.54(q)(5) Summary for 0ERP, Revision 89 and 0PEP-02.1.1, Revision 29

2. Copy of 0ERP, Revision 89, Radiological Emergency Response Plan (ERP)

3. Copy of 0PEP-02.1.1, Revision 29, Emergency Control - Unusual Event, Alert, Site Area Emergency, and General Emergency cc (with Enclosures 1, 2, and 3):

U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 cc (with Enclosure 1 only):

U.S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 Andrew.Hon@nrc.gov U.S. Nuclear Regulatory Commission ATTN: Mr. John Nguyen (Mail Stop 3WFN 14A) (Electronic Copy) 11555 Rockville Pike Rockville, MD 20852-2738 cc (without Enclosures):

Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net U.S. Nuclear Regulatory Commission ATTN: Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001

BSEP 17-0046 Enclosure 1 Page 1 of 4 10 CFR 50.54(q)(5) Summary for 0ERP, Revision 89 and 0PEP-02.1.1, Revision 29 In accordance with 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is providing a summary of the revised Radiological Emergency Response Plan and Emergency Plan Implementing Procedure for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, being submitted with this letter. These revisions are summarized below and became effective on April 18, 2017.

1. 0ERP, Radiological Emergency Response Plan (ERP), Revision 89 Engineering Change (EC) 290407 for Unit 2 and EC 293339 for Unit 1 replaced the Telecon Sorrento Radiation Monitor with a new RM-1000 with an RD-2B detector to meet NRC Order EA-13-109, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions. The new RM-1000 is DC powered and qualified for the expected extended loss of AC power (ELAP) and severe accident environment associated with the Hardened Wetwell Vent (HWV) system.

The new RM-1000 system will continue to supply annunciation to the control operators as a validation of the HWV process stream being open.

BSEP maintains several means to perform off-site dose assessment. BSEP uses Unified RASCAL Interface (URI) as its radiological assessment program for off-site dose determinations. The use of URI is governed by procedure AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment. URI has five methodologies that may be available for a given dose assessment pathway: Monitored Release, Containment Leakage, Reactor Coolant System Leakage, Release Point Sample and Field Team Data. These provide adequate release rate determination. In lieu of using the monitored option and the HWV radiation monitor, AD-EP-ALL-0202 will direct the use of the Containment Leakage method, with the containment radiation monitor reading and a default release rate to calculate doses through the HWV. Procedure 0PEP-03.4.8, Offsite Dose Projections for Monitored Releases, will continue to be available for manual calculations for other types of releases.

This change does not impact meteorological assessment. Thus, the HWV change creates no Reduction in the Effectiveness of the Emergency Plan function of Dose Assessment.

Section 6, Maintaining Emergency Preparedness, Part 6.2, Review and Update of the Plan and Implementing Procedures, Section 6.2.2, Independent Review, was clarified to specify that the results of the review will be documented in the records management system in accordance with AD-NO-ALL-1001, Conduct of Audit. This more accurately reflects the implementation of the independent audit requirements of 10 CFR 50.54(t).

The second paragraph within Section 7.2, Recovery Organization, was editorially adjusted for consistency between the sentences. The statement that the Recovery Center "will be" established in the existing TSC/EOF/Training Building was altered to state "will normally be" established. The existing second sentence of this paragraph read "Other site facilities may be made available as necessary, if required to support an extensive recovery effort." This is not a change in intent but reflects the possibility that the building may not be available such as due to aircraft attack, other hostile action, or potential hurricane/flooding damage.

The Appendix B listing of agreements was updated to specify where the copies of the Letters of Agreement/Memorandums of Understanding are stored. At a point in the past the actual documents were maintained as pages within the Emergency Plan, but this had been

BSEP 17-0046 Enclosure 1 Page 2 of 4 10 CFR 50.54(q)(5) Summary for 0ERP, Revision 89 and 0PEP-02.1.1, Revision 29 altered to simply list the agreements. Specifying where the documents are retained was added to aid in locating the actual letters. The listing was also updated to align with the current agency names for City of Southport Services, Oak Island, and Boiling Springs Lake Fire Department titles. James R. Forstner, M.D., was removed as he has retired and Joseph Hatem, M.D., was added to fill the second support physician.

Appendix F, Technical Basis for Source Term Mixes, added NUREG/-6451, A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants, for completeness as this is a part of the basis for the current Unified RASCAL Interface Dose Assessment Software program in use within the Duke Energy fleet, including Brunswick.

Appendix H, Cross-Reference Between NUREG-0654 Evaluation Criteria and Brunswick Radiological Emergency Response Plan, added Section 3.8.4.1, Department of Energy, Savannah River Operations Office, as one of five elements in 0ERP that satisfy NUREG-0654 Item C.1, Emergency Response Support and Resources.

Appendix I, Minimum Design Criteria for Emergency Facilities and Equipment, for Appendix E to Part 50, II.F, (i.e., Training of Emergency Response Organization (ERO))

updated the governing BSEP procedure from 0EPM-210 to 0PEP-04.3 (i.e., the change made as part of the integration of Duke Energy and Progress Energy) and also for IV.A.9.

(i.e., analysis of on-shift personnel assigned emergency plan implementation functions) added reference to the fact that this is included within the Emergency Plan (i.e., 0ERP) as Attachment 2.

The following changes were also included in Revision 89 and are considered to be fully editorial in nature:

References to normal (i.e., non-emergency) organizational structure tiles were updated to align with the current Duke Energy titles (i.e., E&RC is now separate Environmental and Radiological Protection departments). The titles of Emergency Response Organization positions that included E&RC were not impacted as the ERO Position titles were not changed.

Referenced procedure numbers and titles were updated as part of the ongoing Duke Energy fleet integration and procedure alignment efforts. Also, other typographical errors in document numbers and procedure titles were included in this revision. Throughout the plan, procedure EMG-NGGC-0005 was updated to reference the new procedure designation of "AD-EP-ALL-0301, Activation of the Emergency Response Organization Notification System (ERONS)," which is now used fleet wide in place of the Brunswick Emergency Notification (BEN) System. References were updated from 0EPM-210 to procedure 0PEP-04.3 as the procedure that currently addresses the applicable items. Note b of Figure 3.1-1 was reworded to replace referenced procedure "BNP-FPP-0301" with the procedure "0PLP-01.2." This also included correcting "FSAR" to "UFSAR" throughout the procedure.

Section 4.4.7, Protective Actions - Off Site/Public, Item 2, General, had the third paragraph grammatically corrected by making this two sentences, with no change in intent.

BSEP 17-0046 Enclosure 1 Page 3 of 4 10 CFR 50.54(q)(5) Summary for 0ERP, Revision 89 and 0PEP-02.1.1, Revision 29 Table 4.4-1, Factors Related to Warning/Evacuation Time, Figure 7.2-1 changed "Progress Energy" to "Duke Energy.

Typographical errors were corrected (e.g., corrected "0PFP-13" to "0PFP-013," Continue Assessment block line in Figure 2.0-1. Table 4.4-4 Protection Factor (PF) for Corner of Basement, Under Table with 8" Concrete on top had a tab/alignment error causing it to display incorrectly in the previous revision).

References to the lowest Emergency Classification level (i.e., NOUE) were updated to be consistent with the Brunswick version of the Classification level by removing "Notification Of" from Unusual Event, except as used in the title of procedure 0PEP-02.1.1 as this document title currently still includes "Notification Of."

The gender specific terminology was modified throughout the document to more generic terms (e.g., change his to their).

The other changes do not result in a decrease in the effectiveness of the 0ERP, as currently written, and continue to ensure the:

capability to respond to an emergency; timely performance of a function; effectiveness of measures to ensure protection of the site personnel or public health and safety; and effectiveness of facilities, response organizations, response equipment, or response procedures.

Reference:

EREG AR Number 2107254

2. 0PEP-02.1.1, Emergency Control - Unusual Event, Alert, Site Area Emergency, and General Emergency, Revision 29 The changes to 0PEP-02.1.1 Revision 29 clarified the procedure by ensuring consistency in terminology and to enhance the steps or references to other existing guidance in response to lessons learned from training and use of the procedure. The items changed to establish consistency with other currently approved processes and documents include:

Updated the procedure title to remove "Notification of" from Unusual Event and f r o m steps 5.1.6, 5.2.29.a, and Attachment 1, for consistency with the on-site and off-site (i.e., State, County, and other Offsite Response Organizations) well-established and commonly understood description of the lowest Emergency Classicization Level referred to as Unusual Event, verses to the legacy "Notification of Unusual Event."

Added a Note to identify the location of megaphones/bullhorns as an aid in performance of Step 5.2.8 for making announcements if plant Public Adress system is not available. This has always been the location, but providing this in the

BSEP 17-0046 Enclosure 1 Page 4 of 4 10 CFR 50.54(q)(5) Summary for 0ERP, Revision 89 and 0PEP-02.1.1, Revision 29 procedure helps to ensure personnel can more readily locate and access the equipment needed to implement the contingency response action of Step 5.2.8.

Added Step 5.2.29.b for notifications of termination of emergency to address this action for event termination prior to activation and turnover of the Technical Support Center (TSC) and Emergency Operations Facility (EOF). This has been the expectation and aligns with the procedure steps within existing procedure 0PEP-02.6.21, Emergency Communicator, Revision 77, Step 4.6.2 and Attachment 1-A, Notification Checklist.

Updated the listed reference documents to add Carolina Power and Light Company and Florida Power Corporation's Response to Request for Information Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendation 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights From the Fukushima Daiichi Accident, dated March 12, 2012, as Reference 7.3.12. This has no impact on use or implementation of the procedure, but aids in ensuring proper and complete reviews of future revisions.

Attachment 1, Site Emergency Coordinator Actions Flow Chart, was updated to align with the same changes being made to the equivalent chart within the BSEP Emergency Plan, 0ERP, Revision 89. These include correcting the line termination (i.e., remove incoming direction arrow) from the right of the Continue Assessment block, changing the acronym for the Emergency Response Organization Notification system from BENS to ERONS, adding to the applicable procedure (i.e.,

AD-EP-ALL-0301) to the Notify Security blocks, and correcting a typographical error (i.e., "0PFP-13" to "0PFP-013") for the procedure number used to Realign Turbine Building Ventilation.

Note also that page margins were expanded, which resulted in improved readability with text occupying fewer lines, and some steps moved from the top of one page to the bottom of the preceding page. As such, there are some changes in appearance on most pages, but the actual text within the steps and the numbering of the steps did not change as a result of the margin changes. These have no impact other than ease of use.

The changes to 0PEP-02.1.1, Revision 29, clarify the procedure by ensuring consistency in terminology and enhance the steps or references to other existing guidance. As such, there is no impact to compliance, adherence, or effectiveness of this Emergency Plan Implementing procedure as validated through a review of 10 CFR 50.47(b)(1) and (2);

10 CFR Part 50, Appendix E, IV; and NUREG -0654/FEMA-REP-1, Revision 1,Section II, Items A.1.b, A.1.d, B.1 and B.5.

Reference:

EREG AR Number 2107292

BSEP 17-0046 Enclosure 2 Copy of 0ERP, Revision 89, Radiological Emergency Response Plan (ERP)

BRUNSWICK NUCLEAR PLANT I

Information Use PLANT OPERATING MANUAL VOLUME XIII EMERGENCY RESPONSE PLAN (0ERP)

RADIOLOGICAL EMERGENCY RESPONSE PLAN (ERP)

Revision 089 0ERP Rev. 089 1

TABLE OF CONTENTS Page 1 of 8 SECTION PAGE

1.0 INTRODUCTION

................................................................................................. 1-1 1.1 GENERAL INFORMATION ...................................................................... 1-2 1.1.1 Plant Site Description ................................................................ 1-2 1.1.2 Plume Exposure Emergency Planning Zone............................. 1-2 1.1.3 Ingestion Exposure Emergency Planning Zone ........................ 1-2 1.1.4 Demographic Information .......................................................... 1-3 1.1.5 Evacuation Time Estimate (ETE) Studies ................................... 1-3 1.2 SCOPE AND APPLICABILITY ................................................................. 1-4 1.3

SUMMARY

OF EMERGENCY PROGRAM ............................................. 1-4 1.3.1 Concept of Operations ............................................................... 1-4 1.3.1.1 Emergency Response Activities ....................................... 1-5 1.3.1.2 Emergency Response Resources .................................... 1-6 1.3.1.3 Emergency Response Facilities ....................................... 1-8 1.3.1.4 Emergency Response Plan Maintenance ........................ 1-8 1.4 BRUNSWICK PLANT EMERGENCY PROCEDURES ........................... 1-9 1.5 DEFINITIONS ......................................................................................... 1-10 2.0 EMERGENCY CLASSIFICATIONS .................................................................... 2-1 2.1 GENERAL CLASSIFICATION SYSTEM.................................................. 2-1 2.2 UNUSUAL EVENT ................................................................................... 2-3 2.3 ALERT ...................................................................................................... 2-3 2.4 SITE AREA EMERGENCY ...................................................................... 2-4 2.5 GENERAL EMERGENCY ........................................................................ 2-5 3.0 EMERGENCY RESPONSE ORGANIZATION.................................................... 3-1 3.1 NORMAL OPERATING ORGANIZATION ............................................... 3-3 3.2 ON-SITE EMERGENCY ORGANIZATION .............................................. 3-4 3.2.1 Site Emergency Coordinator...................................................... 3-5 3.2.2 Plant Operators .......................................................................... 3-7 3.3 Technical Support Center ......................................................................... 3-7 3.3.1 Plant Operations Director .......................................................... 3-8 3.3.2 Radiological Control Director ..................................................... 3-8 3.3.3 Technical Assessment Director ................................................. 3-9 3.3.4 Security Director ........................................................................ 3-9 3.3.5 Communications Director .......................................................... 3-9 3.3.6 Radiological Control Communicator .......................................... 3-9 3.3.7 Accident Assessment Team Leader........................................ 3-10 0ERP Rev. 089 2

TABLE OF CONTENTS Page 2 of 8 SECTION PAGE 3.4 Operational Support Center.................................................................... 3-10 3.4.1 Emergency Repair Director ..................................................... 3-10 3.4.2 Operational Support Center Mission Coordinator ................... 3-11 3.4.3 Operations Coordinator ........................................................... 3-11 3.4.4 Environmental & Radiological Control (E&RC)

Coordinator .............................................................................. 3-11 3.4.5 Radiological Emergency Teams .............................................. 3-12 3.4.6 Fire Brigade ............................................................................. 3-13 3.5 Emergency Operations Facility............................................................... 3-13 3.5.1 Emergency Response Manager .............................................. 3-13 3.5.2 Administrative and Logistics Manager ..................................... 3-13 3.5.3 Technical Analysis Manager .................................................... 3-14 3.5.4 Radiological Control Manager ................................................. 3-14 3.5.5 Environmental Monitoring Team Leader ................................. 3-14 3.5.6 Dose Projection Coordinator.................................................... 3-15 3.5.7 Communications Managers ..................................................... 3-15 3.5.8 Assistant to the Emergency Response Manager (AERM) ...... 3-15 3.6 Joint Information Center ......................................................................... 3-15 3.6.1 Company Spokesperson ......................................................... 3-16 3.6.2 JIC Director .............................................................................. 3-16 3.6.3 Company Technical Spokesperson......................................... 3-16 3.6.4 Administrative Coordinator ...................................................... 3-16 3.6.5 Public Information Director ...................................................... 3-16 3.7 OFFSITE ORGANIZATION ASSISTANCE............................................ 3-17 3.7.1 Contracted Services ................................................................ 3-17 3.7.2 Local Services Support ............................................................ 3-18 3.7.2.1 Medical Assistance ......................................................... 3-18 3.7.2.2 Ambulance Service ......................................................... 3-18 3.7.2.3 Fire Assistance ............................................................... 3-19 3.8 COORDINATION WITH PARTICIPATING GOVERNMENTAL AGENCIES ............................................................................................. 3-19 3.8.1 State of North Carolina ............................................................ 3-19 3.8.1.1 Governor's Office ............................................................ 3-19 3.8.1.2 Department of Crime Control and Public Safety ............ 3-20 3.8.1.3 Department of Environmental Health and Natural Resources, Division of Radiation Protection .................. 3-20 3.8.2 Brunswick County .................................................................... 3-20 3.8.2.1 Emergency Management Agency .................................. 3-20 3.8.2.2 Brunswick County Sheriff's Department ......................... 3-21 0ERP Rev. 089 3

TABLE OF CONTENTS Page 3 of 8 SECTION PAGE 3.8.3 New Hanover County............................................................... 3-21 3.8.3.1 Emergency Management Agency .................................. 3-21 3.8.3.2 New Hanover County Sheriff's Department ................... 3-22 3.8.4 Federal Agencies ..................................................................... 3-23 3.8.4.1 Department of Energy, Savannah River Operations Office............................................................................... 3-23 3.8.4.2 Federal Emergency Management Agency (FEMA) ....... 3-23 3.8.4.3 Nuclear Regulatory Commission (NRC) ......................... 3-24 3.8.4.4 U. S. Coast Guard (USCG) ............................................ 3-24 3.8.4.5 Meteorological Service ................................................... 3-24 3.8.4.6 Weather Service ............................................................. 3-24 3.8.4.7 Department of Homeland Security (DHS) ..................... 3-25 3.8.5 Agreements.............................................................................. 3-25 3.9 NOTIFICATION AND ACTIVATION....................................................... 3-26 4.0 EMERGENCY MEASURES ................................................................................ 4-1 4.1 ACTIVATION OF EMERGENCY ORGANIZATIONS .............................. 4-1 4.1.1 General ...................................................................................... 4-1 4.1.2 Unusual Event............................................................................ 4-2 4.1.3 Alert ............................................................................................ 4-2 4.1.4 Site Area Emergency ................................................................. 4-3 4.1.5 General Emergency ................................................................... 4-4 4.2 ACCIDENT ASSESSMENT ACTIONS .................................................... 4-4 4.2.1 General ...................................................................................... 4-4 4.2.2 Source Term Assessment ......................................................... 4-5 4.2.2.1 Effluent and Radiation Readings ...................................... 4-5 4.2.2.2 Potential Consequences Based on In-Plant Conditions ......................................................................... 4-6 4.2.2.3 Post Accident Sampling and Analysis of Reactor and Containment .............................................................. 4-7 4.2.3 Dose Projection and Meteorological Systems ........................... 4-8 4.2.4 Emergency Environmental Monitoring....................................... 4-9 4.2.5 Emergency Response Data System (ERDS) .......................... 4-10 4.3 CORRECTIVE ACTIONS ....................................................................... 4-10 4.4 PROTECTIVE ACTIONS ....................................................................... 4-10 4.4.1 Protective Action - Off Site....................................................... 4-11 4.4.2 Protective Action - On Site....................................................... 4-11 4.4.2.1 Warning and Notification ................................................ 4-11 4.4.2.2 Evacuation & Personnel Accountability .......................... 4-12 0ERP Rev. 089 4

TABLE OF CONTENTS Page 4 of 8 SECTION PAGE 4.4.3 Control of Personnel Radiation Exposures ............................. 4-13 4.4.3.1 Exposure Control Under Emergency Conditions ........... 4-14 4.4.3.2 Exposures During Repair/Reentry Efforts ...................... 4-15 4.4.4 Radioactive Contamination ...................................................... 4-16 4.4.4.1 On-Site Personnel .......................................................... 4-16 4.4.4.2 Equipment and Vehicles ................................................. 4-16 4.4.5 Treatment of Injured and Contaminated Persons ................... 4-17 4.4.6 Public Warning and Notification............................................... 4-18 4.4.7 Protective Actions - Off Site/Public .......................................... 4-19 4.4.7.1 Public Education and Information................................... 4-19 4.4.7.2 General ........................................................................... 4-20 4.4.7.3 Evacuation ...................................................................... 4-21 4.4.7.4 Shelter............................................................................. 4-21 4.4.7.5 Respiratory Protection .................................................... 4-22 5.0 EMERGENCY FACILITIES AND EQUIPMENT .................................................. 5-1 5.1 CONTROL ROOM .................................................................................... 5-2 5.2 TECHNICAL SUPPORT CENTER........................................................... 5-2 5.2.1 TSC/EOF EMERGENCY VENTILATION SYSTEM .................. 5-3 5.2.2 TSC/EOF EMERGENCY CONTAMINATED DRAIN SYSTEM 5-3 5.3 OPERATIONAL SUPPORT CENTER ..................................................... 5-4 5.4 EMERGENCY OPERATIONS FACILITY................................................. 5-4 5.5 JOINT INFORMATION CENTER ............................................................. 5-5 5.6 OFF-SITE EMERGENCY FACILITIES .................................................... 5-5 5.6.1 North Carolina Emergency Operations Center.......................... 5-5 5.6.2 Brunswick County Emergency Operations Center .................... 5-5 5.6.3 New Hanover County Emergency Operations Center............... 5-6 5.7 ASSESSMENT CAPABILITIES ............................................................... 5-6 5.7.1 General ...................................................................................... 5-6 5.7.2 Meteorological Instrumentation and Procedures ....................... 5-6 5.7.3 Seismic Monitoring..................................................................... 5-8 5.7.4 Radiological Monitors................................................................. 5-9 5.7.5 Process Monitors ..................................................................... 5-10 5.7.6 Laboratory Facilities ................................................................. 5-10 5.7.7 Dose Projection........................................................................ 5-11 0ERP Rev. 089 5

TABLE OF CONTENTS Page 5 of 8 SECTION PAGE 5.8 FIRE DETECTION.................................................................................. 5-11 5.9 PROTECTIVE FACILITIES AND EQUIPMENT ..................................... 5-12 5.10 FIRST AID AND MEDICAL FACILITIES ................................................ 5-12 5.11 DAMAGE CONTROL EQUIPMENT AND SUPPLIES ........................... 5-12 5.12 OFF-SITE ENVIRONMENTAL MONITORING EQUIPMENT AND SUPPLIES .............................................................................................. 5-12 6.0 MAINTAINING EMERGENCY PREPAREDNESS .............................................. 6-1 6.1 ORGANIZATIONAL PREPAREDNESS ................................................... 6-2 6.1.1 Training ...................................................................................... 6-2 6.1.2 Drills and Exercises ................................................................... 6-4 6.1.2.1 Drills .................................................................................. 6-5 6.1.2.2 Exercises .......................................................................... 6-7 6.1.3 Emergency Planning Coordinator.............................................. 6-8 6.1.4 Public Education ........................................................................ 6-9 6.2 REVIEW AND UPDATE OF THE PLAN AND IMPLEMENTATION PROCEDURES ........................................................................................ 6-9 6.2.1 Plan Updates ........................................................................... 6-10 6.2.2 Independent Review ................................................................ 6-10 6.2.3 Off-Site Agreements and Plans ............................................... 6-11 6.3 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT AND SUPPLIES ..................................................................................... 6-11 6.3.1 Emergency Equipment and Supplies ...................................... 6-11 6.3.2 Medical Equipment and Supplies ............................................ 6-11 6.4 PLANT NUCLEAR SAFETY COMMITTEE............................................ 6-12 7.0 RECOVERY ......................................................................................................... 7-1 7.1 GENERAL................................................................................................. 7-1 7.2 RECOVERY ORGANIZATION ................................................................. 7-1 7.2.1 Recovery Manager..................................................................... 7-2 7.2.2 Plant General Manager.............................................................. 7-2 7.2.3 Technical Analysis Manager ...................................................... 7-2 7.2.4 Engineering Director .................................................................. 7-3 7.2.5 Administrative and Logistics Manager ....................................... 7-3 7.2.6 Radiological Control Manager ................................................... 7-3 7.3 RECOVERY PLANNING .......................................................................... 7-3 7.4 ON-SITE RECOVERY ACTIVITIES ......................................................... 7-3 0ERP Rev. 089 6

TABLE OF CONTENTS Page 6 of 8 SECTION PAGE 7.5 OFF-SITE RECOVERY ACTIVITIES ....................................................... 7-4 7.5.1 General ...................................................................................... 7-4 7.5.2 Emergency Cleanup Operations ............................................... 7-4 7.5.3 Countermeasures ...................................................................... 7-5 7.5.4 Monitoring and Dose Assessment ............................................. 7-6

8.0 REFERENCES

.................................................................................................... 8-1 0ERP Rev. 089 7

TABLE OF CONTENTS Page 7 of 8 SECTION PAGE APPENDICES Number Title APP A Brunswick Communications System ........................................................ A-1 APP B Agreements .............................................................................................. B-1 APP C Brunswick Nuclear Plant (BNP) Off-Site Agency Support Summary ....... C-1 APP D Superseded ............................................................................................. D-1 APP E Medical Treatment and Assistance .......................................................... E-1 APP F Technical Basis for Source Term Mixes ................................................... F-1 APP G Minimum Procedures Required to Implement the Sections of the Plan ......................................................................................................... G-1 APP H Cross-Reference Between NUREG-0654 Evaluation Criteria and Brunswick Radiological Emergency Response Plan ............................... H-1 APP I Minimum Design Criteria for Emergency Facilities and Equipment ........... I-1 TABLES Number Title Section 3.0 3.5-1 Notification and Activation of Principal Emergency Response Organizations ......................................................................................... 3-31 Section 4.0 4.4-1 Factors Related to Warning/Evacuation Time ........................................ 4-23 4.4-2 Representative Shielding Factors for Surface Deposited Radionuclides ......................................................................................... 4-24 4.4-3 Representative Shielding Factors from Gamma Cloud Source .............. 4-25 4.4-4 PF of Various Vehicles and Structures................................................... 4-26 Section 5.0 5.0-2 Functional Objectives of Emergency Facilities ....................................... 5-13 5.7-1 On-site Meteorological Instrumentation .................................................. 5-14 5.7-2 Area Radiation Monitoring System Channel Identification & Meter Ranges ................................................................................................... 5-15 5.7-3 Process Radiation Monitoring System Channel Identification &

Meter Ranges ......................................................................................... 5-19 5.7-4 Typical Portable Survey Equipment ....................................................... 5-21 0ERP Rev. 089 8

TABLE OF CONTENTS Page 8 of 8 SECTION PAGE FIGURES Number Title 1.1-1 Brunswick Site Plan ................................................................................ 1-15 1.1-2 10-Mile Plume Exposure EPZ and Boundaries ...................................... 1-16 1.1-3 Brunswick Site Building and Onsite Emergency Facility Locations ........ 1-21 1.1-4 Wind Roses ............................................................................................ 1-22 1.1-5 50-Mile Ingestion Exposure EPZ ............................................................ 1-23 1.1-6 10 Mile Total Population ......................................................................... 1-24 1.1-6a 10 Mile Transient Population .................................................................. 1-25 1.1-6b Evacuation Times ................................................................................... 1-26 1.1-7 Concept of Emergency Planning Zones ................................................. 1-28 2.0-1 Response Sequence to Off-Normal Conditions ....................................... 2-6 3.1-1 Brunswick Shift Organization.................................................................. 3-27 3.2-1 Brunswick Emergency Organization ....................................................... 3-28 3.4-1 Operational Support Center (OSC) ........................................................ 3-29 3.6-1 Joint Information Center (JIC) ................................................................ 3-30 4.4-1 BNP Evacuation Routes ......................................................................... 4-27 4.4-2 Evacuation Times - Brunswick EPZ ....................................................... 4-28 4.4-3 Protection Factors of Shielding Materials ............................................... 4-29 7.2-1 Duke Energy Recovery Organization ....................................................... 7-7 ATTACHMENTS

1. Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 REVISION

SUMMARY

0ERP Rev. 089 9

DUKE ENERGY BRUNSWICK NUCLEAR PLANT (BNP)

RADIOLOGICAL EMERGENCY PLAN (ERP)

1.0 INTRODUCTION

The Emergency Program for the Brunswick Nuclear Plant consists of the Brunswick Radiological Emergency Plan and its implementing Plant Emergency Procedures. The Radiological Emergency Plan may also be referred to as the Emergency Response Plan (ERP) in other plant documents. Also included are the related radiological emergency plans and procedures of state and local organizations. The purpose of these programs is to provide for the protection of plant personnel and the general public and to prevent or mitigate property damage that could result from an emergency at the Brunswick Nuclear Plant.

The combined emergency preparedness programs have the following objectives:

1. Effective coordination of emergency activities among all organizations having a response role.

2. Early warning and clear instructions to the population-at-risk in the event of a serious radiological emergency.

3. Continued assessment of actual or potential consequences both on site and off site.

4. Effective and timely implementation of emergency measures.

5. Continued maintenance of an adequate state of emergency preparedness.

The Manager - Nuclear Emergency Planning is the BNP Emergency Planning Coordinator. The BNP Emergency Plan and Procedures are contained in the Plant Operating Manual (POM), Volume 13, which consists of the following parts:

Book 1, Radiological Emergency Plan (ERP)

Book 2, Plant Emergency Procedures (PEP)

A list of procedures required to implement the plan can be found in Book 2.

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1.1 GENERAL INFORMATION 1.1.1 Plant Site Description The Brunswick plant site is located in the southeastern portion of North Carolina 2 1/2 miles north of Southport in Brunswick County, and 16 miles south of Wilmington, North Carolina, in adjacent New Hanover County. (See Fig. 1.1-1 and Fig. 1.1-2.) The Brunswick Plant utilizes two General Electric Company boiling water reactors.

The major structures of the Brunswick plant which contain radioactive materials are the Units 1 and 2 reactor buildings, the turbine building, augmented off-gas building, radwaste building, and a dry fuel storage facility (Independent Spent Fuel Storage Installation (ISFS).

Figure 1.1-1 shows a site plan for the Brunswick plant and Figure 1.1-3 shows the location of the buildings at the site.

1.1.2 Plume Exposure Emergency Planning Zone The plume exposure Emergency Planning Zone (EPZ) is defined to be the area within an approximate ten-mile radius of the Brunswick plant.

Principal exposure sources from plume exposure pathways are:

(a) external exposure to gamma and beta radiation from the plume and deposited material and (b) exposure of internal organs to gamma and beta radiation from inhaled radioactive gases and/or radioactive particulates.

Figure 1.1-2 shows the ten-mile plume exposure EPZ in relation to the location of the Brunswick plant. The plume exposure EPZ includes portions of the North Carolina counties of Brunswick and New Hanover.

The prevailing winds around the Brunswick plant are from the southwest. Figure 1.1-4 presents wind roses for the Brunswick plant site.

1.1.3 Ingestion Exposure Emergency Planning Zone The ingestion exposure EPZ is defined to be the area within a 50-mile radius of the Brunswick plant.

The principal exposure sources from ingestion pathways are contaminated water or food, such as milk or fresh vegetables. The time of potential exposure can range in length from hours to months.

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Figure 1.1-5 shows the 50-mile ingestion exposure EPZ in relation to the location of the Brunswick plant. The ingestion exposure EPZ includes the North Carolina Counties of Bladen, Brunswick, Columbus, New Hanover, Onslow, Pender, and Sampson, and the South Carolina County of Horry.

The region within a 50-mile radius of the Brunswick plant site is predominantly rural, with less than one-half the land devoted to farming. The remainder of the region consists of undeveloped, non-utilized marshes and woodlands.

1.1.4 Demographic Information Demographic information for the 10-mile Emergency Planning Zone is presented in Figure 1.1-6, 1.1-6a and 1.1-6b.

The information is presented by (1) local planning zones and (2) distance from plant at 0-2 miles, 2-5 miles, and 5-10 miles, based on the longitude and latitude of the plant site. Since some of the local planning zones extend beyond the 10-mile radius, the total population for the local planning zones is greater than the total population for the 0-10 mile radius.

1.1.5 Evacuation Time Estimate (ETE) Studies An updated ETE analysis shall be provided to the NRC within 365 days of:

1) The later of the date of the availability of the 2010 decennial census data or the effective date of the emergency preparedness final rule;

2) The availability of subsequent decennial census data; and

3) When a population increase within the EPZ causes certain ETE values to increase by 25 percent or 30 minutes, whichever is less.

Licensees shall estimate EPZ permanent resident population changes at least annually during the years between decennial censuses using U. S. Census Bureau data. These estimates shall occur no more than 365 days apart. State/local government population data shall also be used, if available. Licensees shall maintain these estimates available for NRC inspection during the period between censuses and shall submit these estimates to the NRC with any updated ETEs.

BNP's 2010 decennial censuses, using U. S. Census Bureau data, was submitted December 13, 2012.

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1.2 SCOPE AND APPLICABILITY This document describes the Brunswick Radiological Emergency Plan (Plan) which has been prepared in accordance with Section 50.47 and Appendix E, of Title 10, Part 50, of the Code of Federal Regulations. The Plan shall be implemented whenever an emergency situation is indicated as defined in Section 2.0 Emergency Classifications. Radiological emergencies can vary in severity from the occurrence of an abnormal event, such as a minor fire with no radiological health consequences, to nuclear accidents having substantial on-site and/or off-site consequences.

In addition to emergencies involving a release of radioactive materials, events such as security threats or breaches, fires, electrical system disturbances, and natural phenomena that have the potential for involving radioactive materials are included in the Plan. Other types of emergencies that do not have a potential for involving radioactive materials are not included in the Plan.

The activities and responsibilities of outside agencies providing an emergency response role at the Brunswick plant are summarized in Appendix C and in the state's Emergency Plan.

1.3

SUMMARY

OF EMERGENCY PROGRAM The Brunswick radiological emergency program consists of the Brunswick Radiological Emergency Plan and its implementing procedures. The Plan provides the basis for performing advance planning and for defining specific requirements and commitments to be implemented by other documents and procedures. The Brunswick plant procedures provide the detailed actions and instructions that will be required to implement the Plan in the event of an emergency. The Plan and its implementing procedures are briefly described below.

1.3.1 Concept of Operations The Brunswick Radiological Emergency Plan describes the general nature of emergency response activities, the available emergency response resources and facilities, and the means for maintaining emergency preparedness. Specific plant implementing procedures have been developed (or existing ones modified) to describe in detail how involved plant and corporate personnel carry out their specific responsibilities as identified in the Plan.

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1.3.1.1 Emergency Response Activities The first step in responding to an emergency is recognizing and classifying the nature of the emergency. In order to standardize this process, the four emergency classifications described in NUREG-0654 and NRC Bulletin 2005-02 are adopted for use in this plan. Each class of emergency (Unusual Event, Alert, Site Area Emergency, and General Emergency) encompasses a predefined set of increasingly severe circumstances, including plant conditions, ISFSI conditions, instrument readings, and effectiveness of in-plant corrective actions, known as Emergency Action Levels. The process of properly classifying an emergency is important because the subsequent response activities are dependent on the severity of the emergency.

The next step is to notify (and activate as conditions warrant) the proper emergency organizations, both inside and outside Duke Energy. Proper integration of the efforts of the various response organizations is important to prevent omission or unnecessary duplication of key activities. Therefore, the emergency plan identifies in terms of information flow and communications links the interfaces between pertinent organizations, and identifies the role each is to perform. The emergency response measures to be taken by Duke Energy are discussed in detail in this Plan, while those taken by the state and local governments are summarized herein with details provided in the North Carolina State Emergency Plan.

Beyond the process of notification and activation of support groups, a variety of efforts must be made to assess and minimize the consequences of an emergency condition. These efforts include estimates of the radiation exposures that may occur to plant and off-site personnel if the emergency is not brought quickly under control. Such estimates can be used to initiate preplanned protective actions. The decisions on protective actions off site, such as taking shelter or evacuation, are the responsibility of state and local authorities. The Plan provides for technical assessments of the course and consequences of the emergency and the means for providing state and local agencies with adequate information upon which to make their decisions. Emergency response activities also include personnel accountability, search and rescue, first aid, personnel decontamination, fire fighting, and damage control.

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The final step is to declare the emergency over and perform any necessary post-accident recovery activities. The Plan describes post-accident recovery provisions and identifies the transition from the emergency phase to the recovery phase.

1.3.1.2 Emergency Response Resources The emergency response resources available to respond to an emergency consist of the personnel at Corporate Headquarters, at other Duke Energy facilities, and, in the longer term, at organizations involved in the nuclear industry.

The first line of defense in responding to an emergency lies with the normal operating shift on duty when the emergency begins. Therefore, members of the Brunswick staff are assigned defined emergency response roles that are to be assumed whenever an emergency is declared. The overall management of the emergency is normally performed by the Control Room Site Emergency Coordinator until relieved by the on-call Technical Support Center Site Emergency Coordinator.

Because of their overall knowledge, they are best able to bring the full resources of the plant to bear on controlling the emergency. On-site personnel have preassigned roles to support the Site Emergency Coordinator and to implement their directives. These roles, for the purpose of emergency planning, are cast in terms of emergency teams and assignments, each having a designated leader or primary person and alternate(s) assigned to it.

Each team and individual assignment carries with it specific emergency response duties and, where practical, each is provided with an on-shift person to perform those duties on an interim basis. This approach ensures under most conditions that an emergency response duty falls under some predesignated position and provides a smooth transition as additional people are called to the plant, since each one knows ahead of time what their area of responsibilities will be. The Site Emergency Coordinator will also have ready access to the Technical Support Center. This Emergency Facility is comprised of personnel who are knowledgeable of and responsible for engineering and management support. It will assemble shortly after a non-security related Alert, Site Area Emergency, or General Emergency is declared in order to assist the Site Emergency Coordinator and to carry out their directives.

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Upon declaration of an Alert, Site Area Emergency, General Emergency, or at the discretion of the Site Emergency Coordinator, the Emergency Operations Facility will be activated and staffed by personnel under the direction of the Emergency Response Manager. The position of Emergency Response Manager is staffed by qualified senior plant management personnel. Once the Emergency Operations Facility has been fully activated, the Emergency Response Manager will be responsible for all off-site emergency response including radiological and environmental assessment, determination of recommended public protective actions, and coordination of emergency response activities with federal, state, and local agencies. The Emergency Response Manager will manage the corporate response activities, to relieve the Brunswick plant personnel of any activities that could hamper their response efforts, and to marshal the corporate resources needed to properly respond to the emergency.

Duke Energy has a staff of well-trained and experienced engineers, analysts, and technicians. These personnel represent a pool of technical expertise which can be called upon to provide additional support to the emergency response and recovery organizations. Duke Energy personnel will staff an off-site Joint Information Center to interface with the media and general public in order to effectively communicate to the public the nature of an emergency in progress. Available to assist the Brunswick plant in responding to an emergency are Duke Energy personnel assigned to the Harris, Robinson, Crystal River, Oconee, Catawba, and McGuire nuclear plants and the Corporate Offices.

In addition as outlined in Appendix C, Duke Energy has arranged for support from outside Duke Energy in the areas of fire fighting, rescue and medical assistance, as well as that support delineated in the state and local emergency plans.

Assistance may also be available from the Nuclear Regulatory Commission, Federal Emergency Management Agency, Department of Energy, and General Electric. The industry resources identified by INPO are also available. Duke Energy is a signatory to the mutual assistance agreement developed by INPO for utilities in the nuclear power industry.

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1.3.1.3 Emergency Response Facilities Special provisions have been made to assure that ample space and proper equipment are available to effectively respond to the full range of possible emergencies.

The emergency facilities available include the Brunswick plant Control Room, Operational Support Center, Technical Support Center, Emergency Operations Facility, and Joint Information Center. Each of these facilities, as well as the North Carolina Emergency Operations Center, the Brunswick County Emergency Operations Center, and the New Hanover County Emergency Operations Center, are described in Section 5, Emergency Facilities and Equipment.

1.3.1.4 Emergency Response Plan Maintenance The Plan, as described in Section 6, provides for maintenance of emergency preparedness by establishing the framework and requirements for training, drills and exercises, and periodic updating. Each Brunswick employee having an emergency response role is trained, and annually retrained, in their area of responsibility and also how their duties fit in with those of others. Each individual must know what is expected of them and what they should expect of others while responding to an emergency. A basic description of the required training for emergency assignment is provided in the Plan. The effectiveness of such training is gauged by the use of drills and exercises. Drills are supervised instruction periods aimed at developing, maintaining, and testing skills in a specific operation such as communications or radiation monitoring. An exercise tests the overall capability of the integrated plant, state, and local emergency organizations to properly respond to an emergency. The Plan sets forth the frequency and content of such drills and exercises and also establishes how lessons learned will be used to improve the Plan.

The Plan also delineates the requirements for reviewing, updating, and auditing the Plan and for performing maintenance on and taking inventories of emergency equipment and supplies. An Emergency Planning Coordinator is designated to be responsible for overseeing this process as outlined in Section 6.2.

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1.4 BRUNSWICK PLANT EMERGENCY PROCEDURES Plant Emergency Procedures (PEPs) are implementing procedures which define the specific (i.e., step-by-step) actions to be followed in order to recognize and assess an emergency condition and to mitigate its consequences. Procedures to implement the Plan have been developed or existing procedures modified to provide the following information:

1. Specific instructions to the plant operating staff for the implementation of the Plan.

2. Specific authorities and responsibilities of plant operating personnel.

3. A source of pertinent information, forms, and data to ensure prompt actions are taken and that proper notifications and communications are carried out.

4. A record of the completed actions.

5. The mechanism by which emergency preparedness will be maintained at all times.

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1.5 DEFINITIONS Abnormal Operating Procedures (AOPs) - Specific procedures that provide step-by-step instructions to guide plant operations during potential or actual emergency situations.

Accident - Any unforeseen, or unintentional occurrence or mishap resulting in, or potentially resulting in, physical injury or injury due to radiation exposure or excessive exposure to radioactive materials.

Activated - To formally put on active duty with the necessary personnel and equipment to carry out the function required.

Activating - Key personnel are responding as a mandatory step to make the facility operational within the required time.

ALARA - Acronym for "As Low As Is Reasonably Achievable." Means making every reasonable effort to maintain exposures to radiation as far below the dose limits in this part as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest.

Alternate Emergency Facility (AEF) - The Alternate Emergency Facility is a near site alternative to the onsite emergency response facilities if the onsite emergency response facilities are not available or if travel to the site is unsafe and may endanger personnel.

Backup Route Alerting - General population alerting accomplished using Mobile Route Alerting should the primary alert system (or a portion of the system) have known or indications of sirens being out of service.

Confinement Systems - Those systems, including ventilation, that act as barriers between areas containing radioactive substances and the environment.

Corrective Actions - Those emergency measures taken to lessen or terminate an emergency situation at or near the source of the problem, to prevent an uncontrolled release of radioactive material, or to reduce the magnitude of a release (e.g., equipment shutdown, fire fighting, repair, and damage control.)

Emergency Action Levels - Plant conditions used to determine the existence of an emergency and to classify its severity. The conditions include specific instrument readings (e.g., radiation release rates out of a building vent) that may be used as thresholds for initiating emergency measures such as initiating a notification procedure.

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Emergency Classification - The characterization of emergency situations consisting of several groupings including the entire spectrum of possible radiological and hostile action based emergencies. The four classes of emergencies, listed in order of increasing severity (and decreasing probability), are (1) Unusual Event, (2) Alert, (3) Site Area Emergency, and (4) General Emergency.

Emergency Operations Centers - Designated facilities designed and equipped for effective coordination and control of emergency operations carried out within an organization's jurisdiction.

Emergency Operations Facility (EOF) - An on-site support facility for the management of overall licensee emergency response including coordination with federal, state, tribal, and local officials, coordination of off-site radiological and environmental assessment, and determination of recommended public protective actions. The EOF is located in the TSC/EOF/Training Building.

Emergency Operating Procedures (EOPs) - Specific operations procedures which provide specific technical guidance for operations during emergency conditions.

Emergency Planning Zones (EPZ) - A generic area defined about a nuclear plant to facilitate emergency planning off site. The plume exposure EPZ is described as an area with a 10-mile radius and the ingestion exposure EPZ is described as an area with a 50-mile radius in NUREG-0654. (See Figure 1.1-7)

Exclusion Area - Duke Energy-owned property that surrounds the reactor plants as defined in 10CFR100. The area is of such size that an individual located at any point on its boundary for two hours immediately following onset of the postulated fission product release would not exceed 25 rem whole body dose or 300 rem thyroid dose. This is the property boundary used for off-site dose projections. (See Figure 1.1-1)

Hostile Action - An act toward an Nuclear Power Plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the Nuclear Power Plant. Non-terrorism based EALs should be used to address such activities, (e.g., violent acts between individuals in the OCA).

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Hostile Force - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming or causing destruction Independent Spent Fuel Storage Installation (ISFSI) - A complex designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Ingestion Exposure Pathway - The potential exposure pathway to the public through consumption of radiologically contaminated water and foods such as milk or fresh vegetables. The basis for planning within the 50-mile EPZ.

Joint Information Center (JIC) - An off-site facility equipped and staffed by Duke Energy, State, County, and Federal Agencies to coordinate the dissemination of information to the news media and general public during an emergency.

Manning - A person is in the facility to respond to incoming calls.

Nuclear Incident - An event or series of events, either deliberate or accidental, leading to the release or potential release into the environment of radioactive materials in sufficient quantity to warrant consideration of protective actions.

Offsite Response Organization (ORO) - Any State and local government, supporting private industry and voluntary organizations and licensee offsite response organizations that are responsible for carrying out emergency functions during a radiological emergency.

Operational - The facility is executing its designed functions and tasks.

Operational Support Center (OSC) - The place to which emergency response support personnel report and standby in an emergency situation.

The OSC is located in the Operations and Maintenance (O&M) Building.

Plume Exposure Pathway - The potential exposure pathway to the public through (a) whole body external exposure from the plume and from deposited materials, and (b) inhalation of radioactive materials. The basis for planning within the 10-mile EPZ.

Population-at-Risk - Those persons for whom protective actions are being or would be taken.

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Primary Alert Notification - A fixed siren system at specific locations surrounding the Brunswick Nuclear Plant, with activation controls located in the applicable EPZ County Warning Point and/or EOC. These sirens will serve as the primary system for alerting the public to listen to local radio and television stations for information and instructions related to conditions at Brunswick Nuclear Plant. Along with the fixed siren system, the Emergency Alert System (EAS) will provide information or instructional messages via radio and TV on an area-wide basis throughout the land and water portion of the 10 mile EPZ.

Projected Dose - An estimate of the potential radiation dose which affected population groups could receive.

Protected Area - The double-fenced security area with intrusion detection devices immediately surrounding the plant structures. (See Figure 1.1-3.)

Protective Action - An activity conducted in response to an incident or potential incident to avoid or reduce radiation dose to members of the public (sometimes referred to as protective measure).

Protective Action Guide (PAG) - The projected dose to reference man, or other identified individual, from an accidental release of radioactive material at which a specific protective action to reduce or avoid that dose is warranted.

Radiological Emergency - An off-normal situation that has or may have a radiological impact on the public health and safety.

Recovery Actions - Those actions taken after an emergency to restore the Brunswick plant and the surrounding environment as nearly as possible to its pre-emergency radiological condition.

Restricted Area - Any area, access to which is controlled by Duke Energy for purposes of protection of individuals from exposure to radiation and radioactive materials.

Severe Accident Management Guidelines (SAMGs) - Severe Accident Management Guidelines are entered when Emergency Operating Procedures (EOPs) are not able to maintain adequate core cooling.

Special Facility Population - School, hospital and family care facility occupants located in the plume exposure EPZ.

Staffing - Key personnel are responding to the facilities as a proactive step to prepare for potential operational status.

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State - The State of North Carolina.

Summer - The months of June, July, and August during which the transient population is elevated and has an impact on the Evacuation Time Estimates. The remainder of the year including January, February, March, April, May, September, October, November, and December (i.e.,

September 1 - May 31 of the following year) is categorized as Non-summer.

Technical Support Center (TSC) - A center outside of the Control Room that supplies information on the status of the plant to those individuals who are knowledgeable or responsible for engineering and management support of reactor operations in the event of an emergency, and to those persons who are responsible for management of the emergency response.

The TSC is located in the TSC/EOF/Training Building.

Unrestricted Area - Any area to which access is not controlled by the licensee for protecting individuals from exposure to radiation and radioactive materials, and any area used by residential quarters.

Warning Point - A facility that receives warning and other information and disseminates or relays this information in accordance with prearranged plan.

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Figure 1.1-1 Brunswick Site Plan Page 1 of 1 0ERP Rev. 089 1-15

Figure 1.1-2 10-Mile Plume Exposure EPZ and Boundaries Page 1 of 5 0ERP Rev. 089 1-16

Figure 1.1-2 10-Mile Plume Exposure EPZ and Boundaries Page 2 of 5 Brunswick County:

ZONE A: Bordered on the north by Sunny Point Access Road and the southern border of the Sunny Point Military Ocean Terminal; on the east by the Cape Fear River (border centered in the Cape Fear River) to the N.C. Baptist Assembly east shore (eastern tip of Oak Island); on the south along a line from the N.C.

Baptist Assembly east shore north along the western side of Battery Island to Southport/Supply Road/ North Howe Street (NC 211), then west along Southport/Supply Road/North Howe Street (NC 211); and on the west to Oakview Dr (SR 1549). The western boundary follows Oakview Dr to Pineview Dr to Clearview Dr and continues northeast from the end of Clearview Dr to the intersection of NC 87 (George II Hwy), NC 133 (River Rd) and the Sunny Point Access Road. This zone includes those portions of Southport NORTH of Howe Street along with Snow Marsh and Battery Island.

ZONE B: Bordered on the north and east by Southport/Supply Road (NC 211) and North Howe Street (NC 87/211) to the end of the road in Southport; on the south along the north shore of the intracoastal waterway; west by Long Beach Road (NC 133). This zone includes those portions of Southport SOUTH of Howe Street.

ZONE C: The northern boundary follows the north shore of the Intracoastal Waterway from Long Beach Road (NC 133) to the end of Southport/Supply Road (NC 211) in Southport; then south along the western side of Battery Island to the N.C. Baptist Assembly east shore (eastern tip of Oak Island). The zone boundary moves around the N.C. Baptist Assembly east shore (eastern end of Oak Island) to meet the Atlantic Ocean. The southern border is the Atlantic Ocean coastline (Caswell Beach) to the intersection of Long Beach Rd/Country Club Dr (NC 133) and Jones Street. The western boundary moves north on Long Beach Rd/Country Club Dr (NC 133). This zone includes those portions of Oak Island EAST of Long Beach Rd/Country Club Dr (NC 133) along Caswell Beach Road - Community of Caswell Beach &

the N.C. Baptist Assembly.

ZONE D: The northern boundary follows the north shore of the Intracoastal Waterway from the western end of Sheep Island to NC 133 (Long Beach Road). The eastern boundary follows NC 133 (Long Beach Road) to the coast (at Jones Street) on the Atlantic Ocean. The southern boundary follows the coast on the Atlantic Ocean to Lockwood Folly Inlet on the west. The boundary turns north toward the western end of Sheep Island. This zone includes those portions of Oak Island WEST of NC 133 (Long Beach Road) -Town of Oak Island (formerly communities of Long Beach & Yaupon Beach).

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Figure 1.1-2 10-Mile Plume Exposure EPZ and Boundaries Page 3 of 5 ZONE E: Bordered on the north by Southport/Supply Road (NC 211); and on the east by the Long Beach Road (NC 133) to the Intracoastal Waterway. The southern boundary follows the north shore of the Intracoastal Waterway west to the intersection of Sunset Harbor Road (SR 1112) and Lockwood Folly Rd SE. The zone boundary turns north on Sunset Harbor Road (SR 1112) to intersect with Southport/Supply Road (NC 211).

ZONE F Bordered on the north by the southern Bolivia town limits and by SR 1513 (Danford Road); on the east by NC 87 (George II Hwy) to the intersection of NC 87 (George II Hwy), NC 133 (River Rd) and the Sunny Point Access Road. The eastern boundary continues southwest from the intersection of NC 87 (George II Hwy), NC 133 (River Rd) and the Sunny Point Access Road to the end of Clearview Rd. The southern boundary is Southport/Supply Road (NC 211) moving west to the intersection of Clemmons Rd. SE (SR 1505). Zone boundary on the west is along Clemmons Rd. SE (SR 1505) and (SR 1504). Boundary line moves north along a line from the intersection of Clemmons Rd. SE (SR 1504/1505) and Gilbert Rd SE (SR 1501) to the end of Albright Rd SE (SR 1508). Boundary follows Albright Rd (SE SR 1508) and Midway Rd SE (SR 1500) and Old Ocean Hwy (US 17) to the southern Bolivia town limit. Zone includes Boiling Springs Lakes SOUTHWEST of NC 87.

ZONE G Bordered on the north by Funston Road (SR 1518); on the east by the Sunny Point Railroad and NC 133; and on the west by NC 87. Zone includes the Boiling Springs Lakes BETWEEN NC 87 and the Sunny Point Railroad.

ZONE H Bordered on the north by a line extending east from the intersection of Funston Road (SR 1518) and Daws Creek Road (SR 1521) along Daws Creek Road (SR 1521) to NC 133 about one mile south of Pinelevel; on the east and south by NC 133 to the intersection of NC 133 and the Sunny Point Railroad; and on the west by the Sunny Point Railroad. The zone includes Girl Scout Camp Pretty Pond.

ZONE J Bordered on the north by a line extending east from the intersection of Daws Creek Road (SR 1521) and NC 133 to the Brunswick/New Hanover county line (centered in the Cape Fear River) just south of Campbell Island. The zone is bordered on the east by the Brunswick/New Hanover county line (centered in the Cape Fear River) moving south to the north end of Snow Marsh island and the southern boundary of Sunny Point Military Ocean Terminal. The zone boundary moves west following the southern boundary of Sunny Point Military Ocean Terminal to the intersection with NC 133 and NC 87, and is bordered on the west by NC 133. The zone includes the Sunny Point Military Ocean Terminal, Orton Plantation and Old Brunswick Town.

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Figure 1.1-2 10-Mile Plume Exposure EPZ and Boundaries Page 4 of 5 ZONE M The northern boundary is along a line from the intersection of the New Hanover/Brunswick county line (centered in the Cape Fear River north of Snows Marsh) moving southeast to the Ft Fisher/Southport ferry landing and following the New Hanover/Brunswick county line out to the coast on the Atlantic Ocean (Corncake Inlet area). The eastern boundary moves south along the Atlantic Ocean coast to a point east of the end of Cape Creek. The southern boundary turns west along Cape Creek to the mouth of Cape and Bay Creeks and across the Cape Fear River to the northern shore of Oak Island at the NC Baptist Assembly Grounds. The western boundary moves north centered in the Cape Fear River to the intersection of the New Hanover/Brunswick county line (north of Snows Marsh). The zone includes Zeke and Striking Islands.

ZONE N This zone is comprised of Bald Head Island. The northern border is from the mouth of Cape and Bay Creek along Cape Creek with the boundary extending to the east to meet the Atlantic Ocean once Cape Creek ends.

The eastern boundary then moves along the coast with the Atlantic Ocean on the east and south and then northwest until it meets the Cape Fear River.

The boundary then moves across the Cape Fear River to the southern shore of Oak Island at the NC Baptist Assembly Grounds. It turns north along the eastern end of Oak Island northern shore of Oak Island and back across the Cape Fear River to the mouth of Cape and Bay Creek.

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Figure 1.1-2 10-Mile Plume Exposure EPZ and Boundaries Page 5 of 5 New Hanover County:

ZONE K Bordered on the north along a line from the New Hanover/Brunswick county line intersection (centered in the Cape Fear River) along Sedgley Dr to West Telfair Circle. Along West Telfair Circle to Telfair Drive and Telfair Court.

From Telfair Court to Ocracoke Drive, extending east across US 421 South Seabreeze Rd to the coast on the Atlantic Ocean. The eastern boundary moves south along the Atlantic Ocean coast to Ocean Boulevard. The boundary moves west along Ocean Boulevard to the intersection of the New Hanover/Brunswick county line (centered in the Cape Fear River). The New Hanover/Brunswick county line (centered in the Cape Fear River) forms the western boundary of this zone. The zone includes Sea Breeze, Carolina Beach, and Carolina Beach State Park.

ZONE L Bordered on the north along a line from the New Hanover/Brunswick county line intersection (centered in the Cape Fear River) along Ocean Boulevard across US 421 to the coast on the Atlantic Ocean. The eastern boundary moves south along the Atlantic Ocean coast to the New Hanover/Brunswick county line (Corncake Inlet area). The boundary turns northwest toward the Ft Fisher/Southport ferry landing and continues out into the Cape Fear River to intersect the New Hanover/Brunswick county line. The New Hanover/

Brunswick county line (centered in the Cape Fear River) forms the western boundary of this zone. The zone includes Kure Beach, Fort Fisher and Federal Point.

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Figure 1.1-3 Brunswick Site Building and Onsite Emergency Facility Locations Page 1 of 1 0ERP Rev. 089 1-21

Figure 1.1-4 Wind Roses Page 1 of 1 0ERP Rev. 089 1-22

Figure 1.1-5 50-Mile Ingestion Exposure EPZ Page 1 of 1 0ERP Rev. 089 1-23

Figure 1.1-6 10 Mile Total Population Page 1 of 1 Emergency Planning Zone Population (10 Mile EPZ) 2010 Population Zone Permanent Peak Employees Total Residents Transients A 2,689 480 1,777 4,946 B 2,774 653 57 3,484 C 663 175 0 838 D 5,868 30,011 0 35,879 E 5,627 284 22 5,933 F 1,148 0 0 1,148 G 4,193 38 0 4,231 H 1,711 0 0 1,711 J 195 100 188 483 K 7,841 22,375 8 30,224 L 2,383 8,056 0 10,439 M 0 0 0 0 N 158 1,238 0 1,396 TOTAL 35,250 63,410 2,052 100,712 Source: Brunswick Nuclear Power Plant Development of Evacuation Time Estimates, prepared by KLD Associates, Inc., November 2012.

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Figure 1.1-6a 10 Mile Transient Population Page 1 of 1 2010 Estimated Transient Population within the Brunswick Nuclear Plant EPZ Recreational Areas Within the EPZ Brunswick County 31,668 New Hanover County 21,163 TOTAL 52,831 Labor Population Brunswick Nuclear Plant 1,805 Archer Daniels Midland Company (ADM) 250 Military Ocean Terminal Sunny Point 250 Miscellaneous Employees 985 TOTAL 3,290 Special Facility/School Population School/Day Care Centers 3,842 Hospitals/Nursing Homes 184 TOTAL 4,026 Lodging Facility Population Brunswick County 849 New Hanover County 9,268 TOTAL 10,117 Source: Brunswick Nuclear Power Plant Development of Evacuation Time Estimates, prepared by KLD Associates, Inc., November 2012.

0ERP Rev. 089 1-25

Figure 1.1-6b Evacuation Times Page 1 of 1 Time to Clear the Indicated Area of 90 Percent of the Affected Population Summer Summer Summer Non-summer Non-summer Non-summer Summer Summer Midweek Weekend Midweek Midweek Weekend Midweek Weekend Midweek Weekend Weekend Scenario (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12)

Midday Midday Evening Midday Midday Evening Midday Midday Wind From Good Rain Good Rain Good Good Rain Good Rain Good Special Roadway Weather Weather Weather Weather Weather Weather Event Impact Entire 2-Mile Region and EPZ 2-mile ring 2:35 2:35 2:35 2:35 2:40 2:35 2:35 2:40 2:40 2:45 3:35 2:35 Entire EPZ 3:45 3:50 5:05 5:35 3:25 3:30 3:40 3:55 4:10 3:20 5:45 6:05 2-Mile Region and Downwind to EPZ Boundary 180° - 195° 2:55 3:00 3:30 3:45 2:40 3:05 3:15 2:40 2:45 2:45 3:40 3:25 196° - 236° 2:35 2:35 4:25 4:50 2:35 2:40 2:40 2:55 3:15 2:45 4:15 2:35 237° - 271° 2:35 2:35 4:25 4:50 2:35 2:40 2:40 2:55 3:15 2:45 4:20 2:35 272° - 288° 2:30 2:35 2:20 2:20 2:35 2:35 2:35 2:30 2:30 2:40 3:45 2:30 289° - 316° 2:30 2:35 2:20 2:20 2:35 2:35 2:35 2:30 2:30 2:40 3:40 2:30 317° - 327° 2:30 2:35 2:30 2:30 2:40 2:35 2:35 2:35 2:35 2:45 3:50 2:30 328° - 009° 2:35 2:35 2:30 2:30 2:40 2:35 2:35 2:35 2:35 2:45 3:50 2:35 010° - 021° 2:50 3:00 4:25 5:00 2:45 2:35 2:45 3:00 3:20 2:40 5:00 3:35 022° - 038° 3:35 3:50 5:25 5:55 3:20 3:20 3:35 3:50 4:15 3:15 6:05 6:05 039° - 051° 3:30 3:50 5:20 5:50 3:20 3:20 3:35 3:55 4:15 3:15 6:00 6:00 052° - 090° 3:35 3:55 5:20 6:00 3:35 3:25 3:40 4:05 4:30 3:20 6:00 6:35 091° - 112° 3:40 3:50 5:25 5:50 3:25 3:20 3:40 4:00 4:25 3:15 5:55 6;20 113° - 179° 3:25 3:40 3:15 3:30 3:10 3:30 3:35 3:15 3:30 3:10 4:20 4:40 Source: Brunswick Nuclear Power Plant Development of Evacuation Time Estimates, prepared by KLD Associates, Inc., November 2012 0ERP Rev. 089 1-26

Figure 1.1-7 Concept of Emergency Planning Zones Page 1 of 1 0ERP Rev. 089 1-27

DUKE ENERGY BRUNSWICK NUCLEAR PLANT (BNP)

RADIOLOGICAL EMERGENCY PLAN (ERP) 2.0 EMERGENCY CLASSIFICATIONS A key element of this Plan is a preplanned system of notifying and activating various emergency response organizations. This system, in accordance with NRC recommendations, uses graded levels of emergency response where the actions specified are organized according to the general severity of the emergency condition.

This section discusses the criteria for determining the level of the emergency condition. It also illustrates how a decision is made to declare that an emergency exists by providing example initiating conditions that could correspond to each emergency class. Section 3 in turn will discuss the plans for notification of off-site agencies and mobilization of emergency teams and how they may vary with the level of the emergency.

2.1 GENERAL CLASSIFICATION SYSTEM The operating staff is provided formal training to recognize and respond in a logical manner to off-normal plant conditions. Plant abnormal and emergency procedures are designed to allow plant personnel to mitigate the consequences of and correct an off-normal condition as quickly as possible following its occurrence. The procedures identify the conditions requiring implementation of this Plan. Figure 2.0-1 shows the basic response sequence that is followed during any off-normal condition.

The types of potential emergencies vary in probability and consequences.

Accordingly, any system that categorizes emergencies must be both wide-ranged and flexible. This Plan adopts the NRC recommended standard of four general classes of emergencies and, as described below, includes the methods for determining the class in which a specific type of event should be placed.

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. Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.

0ERP Rev. 089 2-1

There are four basic tests or criteria that must be considered in deciding which emergency class exists. These are:

1. Radioactivity release: Is a release occurring; and if so, what is its magnitude?

2. Core damage: If no release to the environment is occurring, has there been a release of fission products from the fuel? Do the radiation levels in the coolant system or primary containment pose a potential danger to the public?

3. Plant degradation: Has the plant responded to equipment failures or external events as designed? If the plant has not responded as expected, what is the prognosis for a safe recovery, or alternately that further degradation will occur (e.g., corrective action is not likely to be successful or cannot be accomplished before a major release occurs)?

4. Site Specific Security Threats or Hostile Actions.

The categorization of events and combinations of events according to one of the four emergency classes is implemented through Emergency Action Levels (EALs). These are specific sets of plant conditions, instrument readings, and events which, unless promptly corrected, coincide with the conditions associated with one of the four emergency classes.

EALs for the Brunswick Nuclear Plant are included as an attachment to the Radiological Emergency Response Plan and are provided in 0PEP-02.1, Initial Emergency Actions, and 0PEP-02.2.1, Emergency Action Level Technical Bases.

The EALs have been selected with a view towards ensuring that a reasonable time is available to diagnose the specific cause of the emergency and attempt immediate corrective actions.

Once an emergency is declared, assessments of core and containment conditions, projected releases, and resultant exposures are performed.

The results, along with other plant status assessments, are reported to off-site agency officials who decide, based on these inputs, whether or not protective actions for the public are to be implemented. The relationship of dose assessment values to the Environmental Protection Agency (EPA)

Protective Action Guides (PAGs), and the possibility of approaching or exceeding the PAGs, will specifically be reported. Section 4 describes the relationships between emergency classes, PAGs, and various emergency measures.

0ERP Rev. 089 2-2

Each of the four emergency classes is discussed below.

2.2 UNUSUAL EVENT Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Determination of an Unusual Event (or any emergency condition) may be accomplished in one or more of the following ways:

• Observations/inspections

• Automatic alarms (e.g., Radiation and Process Monitoring Systems)

• Communications from others (e.g., warnings of severe natural phenomena by the National Weather Service)

As in all cases, the Site Emergency Coordinator will declare an Unusual Event in any circumstance where, in their judgment, the status of the plant warrants it. Initiating conditions are established as EALs for the determination of this class. Specific EALs for an Unusual Event are listed in 0PEP-02.1, Initial Emergency Actions, and 0PEP-02.2.1, Emergency Action Level Technical Bases.

An Unusual Event does not require the activation of the entire on-site emergency organization, but the Site Emergency Coordinator can direct that additional personnel come to the site to support shift workers. Off-site emergency organizations shall be notified as necessary for informational purposes and aid from off-site fire fighting, medical services, and security organizations can be requested. Notifications are discussed in Section 3.9, and emergency measures to be taken are described in Section 4. Specific emergency actions to be followed during an Unusual Event are contained in 0PEP-02.1.1, Emergency Control - Notification of Unusual Event, Alert, Site Area Emergency, and General Emergency.

2.3 ALERT Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

0ERP Rev. 089 2-3

Initiating conditions are established as EALs for determination of an Alert and are listed in 0PEP-02.1, Initial Emergency Actions, and 0PEP-02.2.1, Emergency Action Level Technical Bases. Additionally, the Site Emergency Coordinator will declare an Alert whenever they conclude that plant conditions so warrant.

Events in this class may reflect a significant degradation in the safety of the reactor. However, releases from such events will be small. Off-site mobilization and assessment actions will be initiated to ensure that emergency personnel are readily available to respond if situations become more serious and confirm that radiation levels in the environment do not require protective actions off-site. Notifications and activation of emergency organizations are discussed in Section 3.9, and the emergency measures to be taken are described in Section 4. Specific emergency actions to be followed during an Alert are contained in 0PEP-02.1.1, Emergency Control - Notification of Unusual Event, Alert, Site Area Emergency, and General Emergency.

2.4 SITE AREA EMERGENCY Events are in progress or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Initiating conditions are established as EALs for determination of the Site Area Emergency class and are listed in 0PEP-02.1, Initial Emergency Actions, and 0PEP-02.2.1, Emergency Action Level Technical Bases.

Additionally, the Site Emergency Coordinator will declare a Site Area Emergency whenever they conclude that plant conditions so warrant.

The Site Area Emergency class includes Alert conditions where the plant personnel have been initially unsuccessful in restoring the facility to a safe shutdown condition. It also includes Alert conditions where subsequent additional malfunctions have occurred. The Site Area Emergency class is more severe than the Alert class because significant radiation releases may occur. However, most of the initiating conditions associated with the Site Area Emergency class do not result in an immediate release and may never result in a significant release if emergency repairs are successful.

0ERP Rev. 089 2-4

Although immediate protective actions are not automatically required, declaration of a Site Area Emergency will set into motion all personnel on site and off site that would be required to perform actions up to and including the evacuation of a near-site area. If circumstances warrant, the process of public notification may begin as directed by the state plan.

Section 3.9 discusses the planned process of notification and activation of emergency organizations. Emergency measures to be taken are described in Section 4. Specific emergency actions to be followed during a Site Area Emergency are contained in 0PEP-02.1.1, Emergency Control -

Notification of Unusual Event, Alert, Site Area Emergency, and General Emergency.

2.5 GENERAL EMERGENCY Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Initiating conditions predictive of a major radiological release are established as Emergency Action Levels for determination of the General Emergency class and are listed in 0PEP-02.1, Initial Emergency Actions, and 0PEP-02.2.1, Emergency Action Level Technical Bases. Additionally, the Site Emergency Coordinator will declare a General Emergency whenever, in their judgment, conditions exist that warrant activation of emergency response efforts including off-site monitoring and prompt public notification.

The General Emergency class includes accident conditions that involve severe core damage or melting. Such conditions will result in major releases to the primary containment and extremely high levels of contamination in the reactor coolant. Releases to the environment may be kept low unless leak paths in the primary containment develop (as from containment failure or failures in pumps, valves and other equipment which circulate reactor coolant outside primary containment). If major releases do occur, it is probable that they will occur hours to days after the onset of the emergency and that off-site exposures will approach or exceed EPA recommended protective action guides unless protective measures are instituted. Notifications and activation of emergency organizations are discussed in Section 3.9. The emergency measures to be taken are described in Section 4. Specific emergency actions to be followed during a General Emergency are contained in 0PEP-02.1.1, Emergency Control - Notification of Unusual Event, Alert, Site Area Emergency, and General Emergency.

0ERP Rev. 089 2-5

Figure 2.0-1 Response Sequence to Off-Normal Conditions Page 1 of 1 Items identified with 3 Asterisks *** indicate that during security related events, consideration should be given in regards to personnel safety prior to performing the step. These steps may be deemed unsafe to perform due to the circumstances, and may be performed later in the event.

0ERP Rev. 089 2-6

DUKE ENERGY BRUNSWICK NUCLEAR PLANT (BNP)

RADIOLOGICAL EMERGENCY PLAN (ERP) 3.0 EMERGENCY RESPONSE ORGANIZATION There are requirements for action in an emergency that go beyond those encountered during routine operations. To meet these extra demands and provide an effective response to the emergency, the Brunswick Radiological Emergency Plan employs an organizational concept that has four features.

1. Whenever the Plan is activated (i.e., an EAL is exceeded), a single individual is charged with the responsibility for and authority to direct all actions necessary to respond to the emergency.

2. The primary responsibility of the individual in charge is to assure that all critical actions (emergency response functions) are carried out. Upon activation of the Plan, that individual is freed of all other responsibilities and thus able to devote their entire effort to managing the emergency response.

3. Specific individuals are assigned the responsibility of carrying out predefined critical actions.

4. There is a mechanism established to provide additional resources as necessary to respond to the emergency, which provides continuity of response on each critical action.

This concept of organization is compatible with and integrated into the normal mode of operation. There are a number of procedures to guide operators in responding to equipment malfunctions and instrument alarms. There are also procedures to maintain effective control over contamination and radiation exposures. Emergency procedures basically involve an extension of these existing plant procedures.

Organizational control of emergencies is accomplished in several steps. First, as is discussed in Section 2, conditions associated with the various emergency classes are clearly defined. Second, emergency response functions are specified with levels of action appropriate to each emergency class (e.g.,

notification, off-site radiation monitoring, etc.). Third, individuals are assigned to be responsible for carrying out each emergency response function, with the assignments to cover all phases of the emergency--from its initial declaration to the final recovery operations.

0ERP Rev. 089 3-1

Finally, the position of the Control Room Site Emergency Coordinator is established to be activated immediately on declaration of an emergency. To that individual is delegated the immediate and unilateral authority to act on behalf of the Company to manage and direct all emergency operations involving the facility. Upon activation of the EOF, the Emergency Response Manager assumes responsibility of overall emergency response and performs those requirements for all off-site related activities. The Technical Support Center Site Emergency Coordinator maintains overall on-site emergency response responsibilities and reports to the Emergency Response Manager.

Initially the Site Emergency Coordinator (SEC) would be the Operations Shift Manager (or other qualified Control Room personnel) who would act in that capacity until formally relieved by the designated On-Call Technical Support Center SEC or alternate (qualified SECs are listed in EPL-001) in the Technical Support Center. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but the emergency response organization On-Call Technical Support Center Site Emergency Coordinator is expected to assume management of the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency.

This section of the plan delineates the various emergency actions and separates them into groups of related functions. These functions are then assigned to designated emergency response personnel who are responsible to the Site Emergency Coordinator for the performance of the activities required to fulfill those functions.

Upon the declaration of an emergency, specified on-shift personnel assume the responsibility for performing the required emergency response actions until properly relieved by another emergency response organization member qualified for the position. All emergency response organization members are trained as described in Section 6.1.1.

If necessary, the Site Emergency Coordinator will allocate available resources based on existing plant conditions. Where necessary, additional personnel will be notified and requested to augment on-site personnel.

A current call list of emergency response organization members is maintained in the Control Room and procedures are available to make this notification.

0ERP Rev. 089 3-2

3.1 NORMAL OPERATING ORGANIZATION The greatest number of people on site occurs during day shift operations.

The plant crew available to respond to an emergency provides a broad spectrum of specialties including operations, maintenance, engineering, radiochemistry, health physics, fire protection and security. The Plan, as will be discussed, utilizes the basic plant organizational structure and cadre of available manpower as the principal means of responding to an emergency condition. This is accomplished by assigning the management of various emergency response functions to individuals in accordance with their routine operational responsibilities. To illustrate, Radiological Emergency Teams will be directed by Environmental & Radiation Control, management personnel, who are the individuals responsible for directing day-to-day radiation control programs. In the event of an emergency, they report directly to the Control Room Site Emergency Coordinator and continue to be responsible for radiological matters.

There are, of course, times when the full complement of staff is unavailable, just as there are times when one or a few key supervisory officials are away from the plant. Therefore, the shift organization as described in the Administrative Controls section of the BNP Technical Specifications must be prepared to provide the initial response to an emergency. The following on-shift expertise will be maintained 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day:

Each operating shift will normally consist of a Control Room Site Emergency Coordinator normally filled by the Shift Manager or other qualified Control Room personnel, two Senior Reactor Operators, four Reactor Operators, nine Auxiliary Operators, three Health Physics Technicians, two Chemistry Technicians, two Mechanical Maintenance Technicians, three I&C/Electrical Maintenance Technicians, and one Shift Technical Advisor (STA). See Figure 3.1-1, Brunswick Shift Organization. Shift crew composition may be less than the minimum requirements for a period of time not to exceed two (2) hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the requirements specified as referenced in UFSAR Table 13-1. Document any deviation from Figure 3.1-1 in the corrective action program.

0ERP Rev. 089 3-3

As will be described below, the general approach is to assign all necessary emergency response functions to the individuals on site. Each individual, on declaration of an emergency, would be responsible for carrying out one or more emergency actions until additional personnel arrive on site. It should be noted that they are initially responsible under all circumstances, and remain so until relieved. This arrangement provides for a clear and uniform assignment of responsibility and provides a mechanism to assure that all important emergency response functions are dealt with from the very beginning of the accident 3.2 ON-SITE EMERGENCY ORGANIZATION The minimum on-site emergency organization for non-normal working hours, backshifts, and holidays for the Brunswick Plant is described above in Section 3.1. Compliance with the requirements of NUREG-0654 Table B-1 has been assured, see Attachment 1, Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012. Guidance for augmenting the emergency organization is found in the notification checklists of the plant emergency procedures. Individuals' names and roles in the emergency organization, phone numbers, and alternates are described in the Emergency Phone List, EPL-001. EPL-001 lists the individuals and alternates qualified to fill the positions described for the TSC, OSC, EOF and JIC.

The Company is committed to provide staffing to effectively contain any emergency which might occur at its nuclear facilities. Depending on the emergency at hand, personnel will be contacted with required expertise on a priority basis. A Staffing Analysis was completed in December, 2012 which validated adequate on-shift staffing is available for worst case scenarios postulated at Brunswick Nuclear Plant. See Attachment 1, Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012, for details of on-shift staffing 24/7. The on-site organization will continue to be augmented such that within 60-75 minutes after notification, additional personnel will be added to provide the necessary support and will meet the intent of Table B-1 of NUREG-0654. Additional personnel will continue to supplement the plant emergency organization as necessary to meet the requirements of this Plan. Periodic drills will be conducted to determine that this augmentation schedule can be maintained.

As an aid toward assuring that critical emergency actions are given proper attention, the plant's emergency procedures provide for emergency response personnel to carry out specific types of functions such as accident assessment and off-site notification. As discussed below, emergency response organization personnel have been selected with an aim toward making a smooth and rapid transition to the emergency mode of operation. The Emergency Response Organization is shown in Figures 3.2-1, 3.4-1, and 3.6-1.

0ERP Rev. 089 3-4

The functions specifically assigned to each element of the Emergency Response Organization are intended to encompass all critical response functions, from command and control to communications. One function assigned to each is that of record keeping. Typical of the records to be maintained are the emergency communications, the radiation records, (i.e.,

surveys, projected dose calculations, personnel/population-at-risk evacuations, etc.), the sequence of events (i.e., the managerial decisions and essential occurrences that evolve throughout the emergency), and the security/accountability records (i.e., who is presently on each team or at each center and any security threats). The following sections describe the specific emergency assignments, which are in the Plan's implementing procedures. The Emergency Response Organization personnel telephone numbers are available in the Control Room. In all emergencies, the on-duty Shift Manager, or other qualified individual, is authorized and qualified to implement the Plan and to classify the emergency condition.

3.2.1 Site Emergency Coordinator As discussed in Section 3.1, direction and coordination of emergency actions on-site (and off-site until relieved by the Emergency Response Manager) are prime responsibilities of the Site Emergency Coordinator (SEC) in the Control Room. The initial determination that an emergency exists will be made in the Control Room, based on measured plant parameters. Therefore, the Shift Manager, or other qualified Control Room personnel, is initially the SEC. If the Shift Manager, or other qualified Control Room personnel, becomes incapacitated for any reason, another Control Room SEC qualified individual may assume this responsibility. This individual will be in command of the on-site emergency organization until relieved by a designated On-Call SEC. The Shift Manager will be relieved by the first qualified SEC to arrive on site so that their attention may be devoted to plant operations. The Shift Manager remains responsible for the decision making of Severe Accident Management Guidelines strategies.

Names and phone numbers of qualified Site Emergency Coordinators (SEC) are available in EPL-001. The SEC will also appoint an Emergency Communicator who will relay messages and maintain notification records throughout the emergency.

Any individual who may be required to serve, even temporarily, in the capacity of a Site Emergency Coordinator (SEC) must be qualified and trained in accordance with the training program described in Section 6.1.1.

0ERP Rev. 089 3-5

The primary responsibilities of the Site Emergency Coordinator include the following:

1. Coordinating and directing the combined activities of Brunswick personnel in the Control Room, Technical Support Center, Operational Support Center, and elsewhere on the site.

2. Classifying the emergency.

3. Notifying off-site plant, corporate, and local agency personnel, as well as on-site personnel, as delineated in the procedures which implement the Plan. (Upon activation of the Emergency Operations Facility, the Emergency Response Manager provides liaison between the Site Emergency Coordinator and all off-site agencies.)

4. Issuing instructions to emergency response personnel and assuring that the appropriate procedures are being followed.

5. Initiating protective actions to be taken on site, if required.

6. Determining the advisability of re-entry operations during or immediately following an emergency situation.

7. Directing health physics activities until the arrival at the site of the Radiological Control Director.

8. Assuring continuity of on-site resources.

9. Declaring the emergency over.

0ERP Rev. 089 3-6

Until relieved by the Emergency Response Manager, the Site Emergency Coordinator may not delegate the responsibility to make the decision to notify and make recommendations to authorities responsible for off-site emergency measures. Further, while they may consult with others, they may not delegate the responsibility to upgrade or downgrade the emergency classification or to declare that the emergency has been terminated. They may delegate the responsibility to announce that the emergency has been terminated.

They may delegate the responsibility and authority for mobilization of recovery efforts while that emergency still exists provided that such efforts in no way interfere with or detract from the response to the emergency. (Responsibility for mobilization of recovery efforts transfers to the Emergency Response Manager upon activation of the EOF.)

Other responsibilities may be delegated to other emergency organizational units as necessary for expeditiously carrying out the requirements of the Plan and procedures which implement the Plan.

3.2.2 Plant Operators During an emergency, the Plant Operators (including the Shift Manager) are the nucleus of the initial effort to control the plant and take steps to protect the public.

The Plant Operators' primary responsibility is to carry out assigned actions necessary during an emergency to provide initial emergency response per established emergency procedures and perform initial calculations of projected off-site consequences. The Operators are responsible for implementing actions (including Severe Accident Management Guidelines) as directed by the Shift Manager. Specific emergency response duties of the Plant Operators are found in the Plant Emergency Procedures which implement the Plan and in other Operations procedures.

3.3 Technical Support Center The Site Emergency Coordinator, as discussed above, is responsible for managing a wide range of activities at the plant. To assist the Site Emergency Coordinator in this effort and to implement their directives, a Technical Support Center has been established. Upon declaration of an Alert, Site Area Emergency, or General Emergency, the Technical Support Center will be notified to immediately assemble. The SEC and other TSC staff members perform monitoring and evaluations required for Severe Accident Management Guidelines, and provide advice and recommendations to the Shift Manager and Reactor Operators.

0ERP Rev. 089 3-7

The various technical and administrative functions to be performed at the plant have been grouped into five categories similar to the organization for routine operations. These are as follows:

Plant Operations NRC Communications Radiological Control Technical Assessment Security Directors are assigned to be responsible for activities within each category.

The Directors within the Technical Support Center may be relieved by designated qualified plant personnel (phone numbers are listed in EPL-001).

The TSC SEC position will also assemble at the Alternate Emergency Facility for a Security Threat and provide support per 0PEP-02.6.30, Alternate Emergency Facility Operation, until safe access to the site is assured.

3.3.1 Plant Operations Director The Plant Operations Director is responsible to the Site Emergency Coordinator for providing liaison with the Reactor Operators, Shift Manager, and Technical Support Center. This individual is responsible for providing technical and administrative assistance to the Reactor Operators. This position also performs monitoring and evaluations required for Severe Accident Management Guidelines.

Responsibilities of this position are contained in 0PEP-02.6.26, Activation and Operation of the Technical Support Center.

3.3.2 Radiological Control Director The Radiological Control Director is responsible to the Site Emergency Coordinator for managing the radiological monitoring and assessment aspects of the plant during an emergency; managing activities to control radiation exposure; providing technical and administrative direction to the Radiological Emergency Teams; and providing liaison with the Emergency Operations Facility and with the Radiological Control Manager. Responsibilities of this position are contained in 0PEP-02.6.26, Activation and Operation of the Technical Support Center.

0ERP Rev. 089 3-8

3.3.3 Technical Assessment Director The Technical Assessment Director is responsible to the Site Emergency Coordinator for providing technical and administrative direction to the Accident Assessment Team and for providing liaison with the Technical Analysis Manager after the EOF is activated. The Technical Assessment Director is responsible for performing the monitoring and evaluations required for Severe Accident Management Guidelines. Responsibilities of this position are contained in 0PEP-02.6.26, Activation and Operation of the Technical Support Center.

3.3.4 Security Director The Security Force is composed of personnel qualified in security, personnel accountability, and evacuation procedures and practices.

The Security Director is responsible to the SEC for providing direction to the Security Force during a declared emergency and providing liaison with the state and local law enforcement agencies.

Responsibilities of this position are contained in 0PEP-02.6.26, Activation and Operation of the Technical Support Center.

3.3.5 Communications Director The Communications Director in the TSC reports to the Site Emergency Coordinator. This position is responsible for making plant-wide announcements over the Public Address System, ensuring NRC notifications are performed, and supervising the administrative staff. Responsibilities of this position are contained in 0PEP-02.6.26, Activation and Operation of the Technical Support Center and 0PEP-02.6.21, Emergency Communicator.

3.3.6 Radiological Control Communicator The Radiological Control Communicator is responsible to the Radiological Control Director for expediting communications between the director and the Radiological Emergency Teams. The responsibilities and objectives of the Radiological Control Communicator are contained in 0PEP-02.6.26, Activation and Operation of the Technical Support Center.

0ERP Rev. 089 3-9

3.3.7 Accident Assessment Team Leader One of the principal groups housed within the Technical Support Center is the Accident Assessment Team. The specific responsibilities of the Accident Assessment Team are as follows:

A. Analyze mechanical, electrical, instrument and control problems and determine alternate solutions.

B. Analyze thermohydraulic and thermohydrodynamic problems and develop alternate courses of action to resolve them.

C. Analyze and evaluate accident conditions and develop guidance for the Site Emergency Coordinator and Operations personnel on protection of the core.

D. Perform monitoring and evaluations to support Severe Accident Management Guidelines.

The Accident Assessment Team Leader is responsible to the Technical Assessment Director and provides technical and administrative direction to the Accident Assessment Team.

Responsibilities of this position are contained in 0PEP-02.6.26, Activation and Operation of the Technical Support Center.

3.4 Operational Support Center 3.4.1 Emergency Repair Director The Emergency Repair Director is responsible to the Site Emergency Coordinator for the management of efforts to repair and maintain equipment during an emergency, install emergency structures, systems and components, and perform mitigation and cleanup activities during an emergency. These responsibilities include providing technical and administrative direction to any emergency repair team that may be formed during the emergency and to the Operational Support Center Mission Coordinator. Responsibilities of this position are contained in 0PEP-02.6.12, Activation and Operation of the Operational Support Center.

0ERP Rev. 089 3-10

3.4.2 Operational Support Center Mission Coordinator Upon the decision of the Site Emergency Coordinator to activate the Operational Support Center, an OSC Mission Coordinator will report to the Emergency Repair Director. This individual will direct the activities of the mechanical, electrical, and I&C personnel requested to report to the OSC. Responsibilities and objectives of this position are contained in 0PEP-02.6.12, Activation and Operation of the Operational Support Center. This position will coordinate OSC response activities with the E&RC and Operations Coordinators.

3.4.3 Operations Coordinator Upon the decision of the Site Emergency Coordinator to activate the Operational Support Center, an Operations Coordinator will report to the Emergency Repair Director. This individual will coordinate the activities of Operations and Fire Brigade personnel with the OSC Mission Coordinator and E&RC Coordinator. Responsibilities and objectives of this position are contained in 0PEP-02.6.12, Activation and Operation of the Operational Support Center.

3.4.4 Environmental & Radiological Control (E&RC) Coordinator Upon the decision of the Site Emergency Coordinator to activate the Operational Support Center, an E&RC Coordinator will report to the Emergency Repair Director. This individual will direct the activities of the radiological controls and chemistry personnel requested to report to the OSC. This position will coordinate OSC response activities with the OSC Mission Coordinator and the Operations Coordinator.

Responsibilities and objectives of this position are contained in 0PEP-02.6.12, Activation and Operation of the Operational Support Center.

0ERP Rev. 089 3-11

3.4.5 Radiological Emergency Teams The Radiological Emergency Teams consist of members of the Environmental & Radiation Control organization and of other plant or off-site personnel who have received necessary training. Members of the teams who have not completed such training may be assigned to tasks in which they assist a qualified team member under their direct guidance.

The general functions of the various Radiological Emergency Teams include:

1. Determine and report on-site radiological conditions.

2. Determine and report off-site radiological conditions.

3. Establish areas to which access should be controlled for the purpose of minimizing personnel exposures.

4. Issue protective equipment and personnel gear.

5. Personnel decontamination services.

6. Determine and maintain records of personnel exposure.

Radiological emergency teams are formed from the pool of available personnel who assemble in the Operational Support Center. These teams are in addition to the emergency repair teams that are formed from the pool of mechanics, electricians, and instrument technicians to perform repair missions in the plant.

The radiological emergency teams formed are determined by the radiological conditions that require their services. The following teams may be necessary:

1. Plant Monitoring - responsible for conducting in-plant and inside the protected area monitoring to include air sampling, direct radiation monitoring, and smear surveys to determine radiological conditions.

2. Post Accident Sample - responsible for obtaining and analyzing highly radioactive gas and/or liquid samples necessary for source term determination and core damage assessment.

3. Personnel Protection and Decontamination - responsible for monitoring and verifying that personnel and vehicles exiting the protected area and the site are free of radioactive contamination.

0ERP Rev. 089 3-12

3.4.6 Fire Brigade When conditions require activation of the emergency facilities, the on-shift Fire Brigade is incorporated into the Operational Support Center.

The Fire Brigade consists of a Shift Incident Commander, and a minimum of four fire brigade members who provide fire brigade, search and rescue, chemical/hazardous materials response, and confined space entry services. Fire Brigade members will be the on-shift operators, or other personnel qualified as Fire Brigade members.

The Fire Brigade, when incorporated into the OSC, functions as a team under the direction of the Operations Coordinator. The Fire Brigade is staffed on a 24-hour basis.

3.4.7 Medical Emergency Response Team (MERT)

MERT provides first aid to plant personnel and is made up from personnel in the Security department. MERT members will be the on-shift security officers qualified in first aid. MERT is staffed on a 24-hour basis. Upon activation of the Emergency Response Facilities, the Medical Emergency Response Team reports to the OSC, as a unit, and provides medical response as well as their other Security duties.

3.5 Emergency Operations Facility The Emergency Operations Facility is activated by the On-Call Emergency Response Manager when notified by the Site Emergency Coordinator that an Alert or higher emergency condition exists at Brunswick. Guidance for activation and operation of the EOF is contained in 0PEP-02.6.27, Activation and Operation of the Emergency Operations Facility.

3.5.1 Emergency Response Manager The Emergency Response Manager is responsible for providing liaison between the Site Emergency Coordinator and off-site support personnel (Corporate Headquarters, Joint Information Center, state and federal agencies) and marshalling off-site support as required to support the Site Emergency Coordinator. This position also assembles at the Alternate Emergency Facility for a Security Threat and provides support per 0PEP-02.6.30, Alternate Emergency Facility Operation, until safe access to the site is assured. The responsibilities and objectives of this position are contained in 0PEP-02.6.27, Activation and Operation of the Emergency Operations Facility.

0ERP Rev. 089 3-13

3.5.2 Administrative and Logistics Manager The Administrative and Logistics Manager is responsible to the Emergency Response Manager for providing assistance to the Emergency Response Manager and site personnel in administrative, logistics, communications, and personnel support, as requested. The responsibilities and objectives of this position are contained in 0PEP-02.6.27, Activation and Operation of the Emergency Operations Facility.

3.5.3 Technical Analysis Manager The Technical Analysis Manager is responsible to the Emergency Response Manager for coordinating technical information coming from the Technical Support Center, supplying the Emergency Response Manager with an assessment of the emergency, and providing interface for the Emergency Response Manager to consultants, regulatory agencies, architect-engineers, and General Electric. The responsibilities and objectives of this position are contained in 0PEP-02.6.27, Activation and Operation of the Emergency Operations Facility.

3.5.4 Radiological Control Manager The Radiological Control Manager is responsible to the Emergency Response Manager for coordinating off-site radiological and environmental assessment and recommending to the Emergency Response Manager protective actions necessary to protect the public health and safety. This position also assembles at the Alternate Emergency Facility for a Security Threat. The responsibilities and objectives of this position are contained in 0PEP-02.6.27, Activation and Operation of the Emergency Operations Facility.

3.5.5 Environmental Monitoring Team Leader The Environmental Monitoring Team Leader is responsible to the Radiological Control Manager when the EOF is activated, for providing technical and administrative direction to the Environmental Monitoring Team. Two Environmental Monitoring Teams will be made available for deployment. If additional monitoring teams are needed, they may be requested from the Harris, Robinson, Crystal River, Oconee, Catawba, and McGuire nuclear plants. The responsibilities and objectives of the environmental monitoring team are contained in 0PEP-02.6.6, Environmental Monitoring Team Leader.

0ERP Rev. 089 3-14

3.5.6 Dose Projection Coordinator The Dose Projection Coordinator is responsible to the Radiological Control Manager and provides technical and administrative direction to the Dose Projection Team when the EOF is activated.

Responsibilities of the Dose Projection Team include radiological dose projections and source term determination, contained in AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment, and acquisition and distribution of meteorological data for dose assessment and environmental monitoring purposes. The responsibilities and objectives of the Dose Projection Team are contained in 0PEP-02.6.20, Dose Projection Coordinator.

3.5.7 Communications Managers The Communications Managers report to the Emergency Response Manager. They function as liaison between the off-site organizations and agencies and the on-site emergency organization. Specifically, they relay messages between the ERM in the EOF, Technical Support Center, and the State Emergency Response Team, using the communication equipment discussed in Appendix A of this plan. This position also assembles at the Alternate Emergency Facility for a Security Threat. The responsibilities of this position are contained in 0PEP-02.6.27, Activation and Operation of the Emergency Operations Facility and 0PEP-02.6.21, Emergency Communicator.

3.5.8 Assistant to the Emergency Response Manager (AERM)

The Assistant to the Emergency Response Manager is responsible to the Emergency Response Manager for coordination of information within the Emergency Operations Facility. Reporting to the Assistant AERM are County EOC Representatives (utility representative) that respond to the New Hanover and Brunswick County EOCs. The responsibilities of this position are contained in 0PEP-02.6.27, Activation and Operation of the Emergency Operations Facility.

3.6 Joint Information Center The Joint Information Center is activated by the Emergency Response Manager when they are notified that a Site Area Emergency or General Emergency condition exists at Brunswick. Activation is discretionary for lesser emergency classifications. (Figure 3.6-1) 0ERP Rev. 089 3-15

3.6.1 Company Spokesperson The Company Spokesperson is responsible to the Emergency Response Manager for the coordination of plant information with County, State, and Federal representatives for dissemination to the news media and general public. The responsibilities of this position are contained in 0PEP-02.6.29, Activation and Operation of the Joint Information Center (JIC).

3.6.2 JIC Director The JIC Director is responsible to the Company Spokesperson as the primary interface with State, County, and Federal Public Information Coordinators and for the preparation and coordination of all news releases. The responsibilities of this position are contained in 0PEP-02.6.29, Activation and Operation of the Joint Information Center (JIC).

3.6.3 Company Technical Spokesperson The Company Technical Spokesperson is responsible to the JIC Director for the acquisition, coordination, and interpretation of plant technical information disseminated to the news media and general public. The responsibilities of this position are contained in 0PEP-02.6.29, Activation and Operation of the Joint Information Center (JIC).

3.6.4 Administrative Coordinator Administrative Coordinators are responsible to the JIC Director for initial JIC facility setup, and the coordination of logistical, security, and administrative duties. The responsibilities of this position are contained in 0PEP-02.6.29, Activation and Operation of the Joint Information Center (JIC).

3.6.5 Public Information Director Public Information Directors are responsible to the JIC Director for monitoring and coordinating the flow of media and general public information in the Joint Information Center. The responsibilities of this position are contained in 0PEP-02.6.29, Activation and Operation of the Joint Information Center (JIC).

0ERP Rev. 089 3-16

3.7 OFFSITE ORGANIZATION ASSISTANCE Should conditions at the plant degrade to the extent that further on-site assistance is needed, assistance is available from Corporate personnel, contracted services, and certain locally available service groups, as described in the following subsections.

3.7.1 Contracted Services A number of active outside contracts are maintained in order to ensure continuing access to qualified personnel when and if they are needed to supplement Duke Energy resources. These contracts provide the capability of obtaining, on an expedited basis, additional maintenance support personnel (such as mechanics, electricians, and I&C Technicians), other technical personnel (such as RP and Chemistry Technicians), and engineering and consulting services.

For example, contracts are maintained with General Electric (the NSSS vendor for the Brunswick plant) and URS Energy and Construction (formerly United Engineers the architect-engineer for the Brunswick plant).

General Electric will form a Technical Support Team upon request.

The team will be composed of personnel with the appropriate technical disciplines that can be dispatched to the plant site. General Electric will also establish dedicated telephone communications for data transmission until the arrival of the team.

The Institute of Nuclear Power Operations (INPO) serves as a clearinghouse for industry wide support during an emergency. When notified of an emergency situation at a nuclear plant, INPO will provide emergency response as requested. INPO will be able to provide the following emergency support functions:

a. Assistance to the affected utility in locating sources of emergency manpower and equipment.

b. Analysis of the operational aspects of the incident.

c. Dissemination to member utilities of information concerning the incident.

d. Organization of industry experts who could advise on technical matters. If requested, one or more suitably qualified members of the INPO staff will report to the Emergency Response Manager and will assist in coordinating INPO's response to the emergency.

0ERP Rev. 089 3-17

If requested, one or more suitably qualified members of the INPO staff will report to the Emergency Response Manager and will assist in coordinating INPOs response to the emergency.

3.7.2 Local Services Support The Brunswick Plant is equipped and staffed to cope with many types of emergency situations. However, if a fire or other type of incident occurs that requires outside assistance, such assistance is available as described in the following subsections.

3.7.2.1 Medical Assistance Dosher Memorial Hospital has medical facilities immediately available for the treatment of contaminated and non-contaminated injured personnel.

New Hanover Regional Medical Center will serve as a backup for Dosher Memorial if necessary.

In addition, medical assistance is available on, or off-site from physicians in the Southport area who have agreed to provide medical assistance to contaminated patients. (See Appendix E, Medical Treatment and Assistance, for more details.)

3.7.2.2 Ambulance Service The City of Southport Rescue Squad and Brunswick County EMS has agreed to respond to all emergency calls from the plant, just as they respond to other calls from the surrounding area. A copy of the response agreement is included in Appendix B.

0ERP Rev. 089 3-18

3.7.2.3 Fire Assistance Agencies with fire protection resources in the vicinity of Brunswick are as follows:

Southport Fire Department Boiling Spring Lakes Volunteer Fire Department Yaupon Beach Volunteer Fire Department Oak Island Fire and Rescue Department Sunny Point Fire Department The Southport Fire Department is the primary fire protection response agency for the Brunswick Plant and will coordinate assistance activities, if required, of the other above agencies.

Copies of agreements with local fire departments are contained in Appendix B.

3.8 COORDINATION WITH PARTICIPATING GOVERNMENTAL AGENCIES A summary of each governmental organization having major responsibilities for the planning and response to Brunswick Plant radiological emergencies is described below; comprehensive summary tables of emergency response organizations are included in Appendix C; and a detailed description of the authority, responsibilities, and duties of each organization is presented in their respective emergency plans. Each of these organizations having response duties is capable of providing such on a 24-hour-per-day basis.

3.8.1 State of North Carolina 3.8.1.1 Governor's Office The Governor has the authority to direct and control the State Emergency Management Program. During a declared State of Disaster, the governor has the authority to utilize all available state resources reasonably necessary to cope with emergencies. The governors representatives coordinate as necessary with Duke Energy, the Governor of South Carolina, and with local government officials.

0ERP Rev. 089 3-19

3.8.1.2 Department of Crime Control and Public Safety The Department of Crime Control and Public Safety functions as the State of North Carolina Emergency Planning Coordinator. In that capacity the Department has overall management responsibility for North Carolina's radiological emergency response planning, development, and updating of North Carolina's emergency response plan, and coordination with Duke Energy. The Department coordinates emergency response activities for the State of North Carolina and other government response agencies.

3.8.1.3 Department of Environmental Health and Natural Resources, Division of Radiation Protection The Radiation Protection Division performs radiological field monitoring and laboratory analysis of field samples. This section is responsible for dose assessments and projections and personnel radiological monitoring outside the Brunswick site and other functions as described in the State Emergency Plan.

3.8.2 Brunswick County 3.8.2.1 Emergency Management Agency The Brunswick County Emergency Management Agency has overall responsibility for Brunswick County's radiological emergency response planning, development, and updating of Brunswick County's emergency response plan, and coordination between the county and Duke Energy and other local government response agencies. It functions as the lead county agency for radiological monitoring and decontamination activities as directed by the State of North Carolina's Division of Radiation Protection. It also operates the county warning point on a 24-hour basis.

0ERP Rev. 089 3-20

3.8.2.2 Brunswick County Sheriff's Department The Sheriff's Department emergency response functions are:

A. Coordinate all local law enforcement and traffic control.

B. Provide immediate assistance to facility management and local authorities during initial onset of the emergency.

C. Provide traffic control in support of evacuation.

D. Establish road blocks, re-route traffic around contaminated areas and report traffic problems to the County Emergency Operations Center.

E. Provide traffic control in the vicinity of shelter areas.

F. Provide assistance to municipal law enforcement agencies in warning and evacuating persons in designated zones.

G. Provide security for county property.

3.8.3 New Hanover County 3.8.3.1 Emergency Management Agency A. The New Hanover County Emergency Management Agency has overall responsibility for New Hanover County's radiological emergency response planning, development, and updating of New Hanover County's emergency response plan, and coordination between the County, Duke Energy, and other local government response agencies. It functions as the lead county radiological response agency and provides any required radiological monitoring and decontamination activities as directed by the State of North Carolina's Division of Radiation Protection.

B. Operate the county warning point on a 24-hour basis.

0ERP Rev. 089 3-21

3.8.3.2 New Hanover County Sheriff's Department The Sheriff's Department emergency response functions are:

A. Coordinate all local law enforcement and traffic control.

B. Provide immediate assistance to facility management and local authorities during initial onset of the emergency.

C. Provide traffic control in support of evacuation.

D. Establish road blocks, re-route traffic around contaminated areas, and report traffic problems to the County Emergency Operations Center.

E. Provide traffic control in the vicinity of shelter areas.

F. Provide assistance to municipal law enforcement agencies in warning and evacuating persons in designated zones.

G. Provide security for county property.

0ERP Rev. 089 3-22

3.8.4 Federal Agencies 3.8.4.1 Department of Energy, Savannah River Operations Office The Savannah River Operations Office coordinates, under the Federal Radiological Monitoring and Assessment Center (FRMAC) or Consequence Management Response Team (CMRT), federal resources as required to: minimize accidental radiation exposure; minimize the spread of radioactive materials into the environment; and carry out countermeasures to control and eliminate radiation hazards. Upon request of the State of North Carolina, Department of Environmental Health and Natural Resources, Division of Radiation Protection, or the Nuclear Regulatory Commission (NRC); the Department of Energy will: provide equipment, supplies, and personnel to evaluate radiological hazards and to minimize radiation exposures; assist in carrying out emergency response operations and implementing protective actions; and provide an aerial radiological measuring system for mapping radioactive plumes. The Site Emergency Coordinator or Emergency Response Manager after activation of the Emergency Operations Facility may request this assistance via the NRC or the State. Resources available in the area to facilitate federal assistance include the New Hanover International Airport, located approximately twenty miles from the Brunswick Plant near Wilmington, North Carolina, which has two runways capable of supporting large commercial aircraft. Also located at the New Hanover International Airport is a National Guard Armory. This area could be used as a Federal Command Post meeting the requirements of FRMAC or CMRT.

3.8.4.2 Federal Emergency Management Agency (FEMA)

The Federal Emergency Management Agency coordinates, through the Atlanta, Georgia Regional IV Office, federal response as required to supplement that provided by FRMAC or CMRT. A representative from FEMA Region IV will be present at the SERT to coordinate any federal response requested by the state.

0ERP Rev. 089 3-23

3.8.4.3 Nuclear Regulatory Commission (NRC)

The Nuclear Regulatory Commission provides resident inspectors at Brunswick. At the request of Duke Energy, NRC provides additional technical advice, technical assistance, and personnel during and following a radiological emergency. The Director of Regulatory Operations will be notified of radiation incidents in accordance with 10CFR20.2202 and will conduct appropriate investigative activities. The NRC has the capability for independent assessment of plant conditions within approximately 1 - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> via data acquisition, and within approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> with an on-site team.

3.8.4.4 U. S. Coast Guard (USCG)

The Coast Guard controls access of navigable waterways in the vicinity of the Brunswick Plant and provides public warning and notification as described in the State Emergency Plan.

3.8.4.5 Meteorological Service Meteorological Services are under contract with Duke Energy to provide meteorological services during day to day and/or emergency operations.

3.8.4.6 Weather Service The National Weather Service in Wilmington, North Carolina will provide meteorological information during emergency situations, if required. Data available will include existing and forecasted surface wind directions, wind speed with azimuth variability, and ambient surface air temperature.

0ERP Rev. 089 3-24

3.8.4.7 Department of Homeland Security (DHS)

The Homeland Security Act of 2002 established DHS to prevent terrorist attacks within the United States; reduce the vulnerability of the United States to terrorism, natural disasters, and other emergencies; and minimize the damage and assist in the recovery from terrorist attacks, natural disasters, and other emergencies. The act also designates DHS as a focal point regarding natural and manmade crises and emergency planning. The Department of Homeland Security (DHS) is responsible for overall coordination of all actual and potential Incidents of National Significance. Incidents of National Security for commercial nuclear power plants include a declaring of a general emergency at a nuclear power plant resulting from an accident, an emergency declaration (Alert or higher classification) at a nuclear facility resulting from a terrorist incident. Terrorist incidents outside a nuclear facility boundary involving improvised nuclear device, radiological dispersal device, and/or radiological exposure device.

3.8.5 Agreements Appendix B presents copies of letters of agreement with agencies that would not normally be available for assistance through existing state or federal plans but will make certain services available.

0ERP Rev. 089 3-25

3.9 NOTIFICATION AND ACTIVATION Notification and activation of the on-site and off-site emergency response organizations is dependent upon the emergency classification and is listed in Table 3.5-1. Details of notification responsibilities, communications systems utilized to make the notifications, information required to be transferred to off-site agencies, and notification verification techniques are specifically described in the Plant Emergency Procedures (PEPs) and Appendix A of this Plan. Additional individuals and organizations who might be required to activate are contained in EPL-001.

Any time that an emergency is reclassified, the initial notification scheme will apply.

The State of North Carolina and the Counties of Brunswick and New Hanover are responsible for the process of notification of the public. The initial instructions to the public will consist of preestablished emergency messages which will be tailored to reflect whether the event is a Site Area Emergency or General Emergency classification. The following information is typical of that which would be provided in the initial message:

1. Identification of the agency issuing the information.

2. A statement that an emergency condition exists at the Brunswick Nuclear Plant.

3. Brief description of the type of emergency and the nature of the hazard.

4. Identification of the communities or geographical areas affected by the emergency.

5. Recommendations with regard to specific protective measures to be taken by residents of the affected areas.

6. A statement concerning how the public will receive further emergency information.

Prewritten emergency messages to be used for public notification are contained in the procedures of the State of North Carolina, and Brunswick and New Hanover Counties.

0ERP Rev. 089 3-26

Figure 3.1-1 Brunswick Shift Organization Page 1 of 1 Minimum Functional Area Major Tasks Emergency Positions Shift Size Shift Manager (SM) 1

1. Plant Operations and Control Room Supervisor 2 Assessment of Control Room Staff Reactor Operators 4 Operational Aspects Non-Licensed Operators 9 SEC-MCR (SM) 1 (a)

2. Emergency Direction

-- ERM --

and Control SEC-TSC --

3. Notification & Emergency (e)(d)

Non-Licensed Operator 1 Communication Communicator

4. Radiological Offsite Dose Dose Projection Coordinator --

Assessment Assessment Environmental Monitoring Offsite Surveys --

Team Personnel Radiological Control Team Onsite Surveys 1 Personnel In-plant Surveys Health Physics Technician 2 Chemistry Chemistry Technician 2

5. Plant Engineering Technical Support Shift Technical Advisor 1 Repair and Corrective Core Performance Actions Engineering Mechanical Engineering --

Electrical Engineering --

Repair and Mechanical Maintenance 2 Corrective Actions Electrical/I&C Maintenance 3

6. In-Plant Protective Radiation (a)

Health Physics Technician 2 Actions Protection (a)(b)(e)

7. Fire Fighting -- -- 5 (a)(f)

8. Rescue Operations -- Plant Personnel 2 9.First Aid Security MERT Security Team Personnel (c)

Security &

10. Site Access Control Security Team Personnel (c)

Accountability TOTAL (Less Security): 27 (a) May be provided by shift personnel assigned other functions.

(b) Fire Brigade per 0PLP-01.2, includes four Fire Brigade members and one Shift Incident Commander.

(c) Per Security Plan (d) Non-Licensed Operators also responsible for Notifications and Communications (1)

(e) Included in census of Non-Licensed Operators above.

(f) Rescue is a collateral duty of Fire Brigade/Non-Licensed Operators.

0ERP Rev. 089 3-27

Figure 3.2-1 Brunswick Emergency Organization Page 1 of 1 0ERP Rev. 089 3-28

Figure 3.4-1 Operational Support Center (OSC)

Page 1 of 1 0ERP Rev. 089 3-29

Figure 3.6-1 Joint Information Center (JIC)

Page 1 of 1 0ERP Rev. 089 3-30

BRUNSWICK TABLE 3.5-1 NOTIFICATION AND ACTIVATION OF PRINCIPAL EMERGENCY RESPONSE ORGANIZATIONS Page 1 of 1 Unusual Site General Agency Event Alert Emergency Emergency On site: Duke Energy Plant Operators Continuously Continuously Continuously Continuously Staffed Staffed Staffed Staffed Radiological Emergency Teams (a), (c) (a) Activate Activate Technical Support Center (a), (c) Activate Activate Activate Operational Support Center (a), (c) Activate Activate Activate Emergency Operations Facility (a), (c) Activate Activate Activate Corporate Headquarters Notify (a) Notify (a) Activate Activate Fire Brigade (a) (a) (a) (a)

Off site:

Joint Information Center (a), (c) (a), (c) Activate Activate State of North Carolina Notify Notify (a) Activate Activate Brunswick County Notify Notify (a) Activate Activate New Hanover County Notify Notify (a) Activate Activate USNRC Notify Notify Activate Activate American Nuclear Insurers Notify Notify (a) Activate U. S. Coast Guard (c) (c) Notify (a) Activate Dosher Memorial Hospital (b) (b) (b) (b)

Southport Fire Department (b) (b) (b) (b)

Southport Rescue Squad (b) (b) (b) (b)

General Electric (c) Notify (a) Activate Activate INPO (c) Notify Notify Notify (a) Mobilize, if deemed necessary.

(b) Request assistance, if required.

(c) Notify if deemed necessary.

0ERP Rev. 089 3-31

DUKE ENERGY BRUNSWICK NUCLEAR PLANT (BNP)

RADIOLOGICAL EMERGENCY PLAN (ERP) 4.0 EMERGENCY MEASURES This section identifies the measures to be taken for each class of emergency described in Section 2. The measures presented in this section are used as the basis for the detailed Plant Emergency Procedures which define the specific actions to be taken for each emergency class. Emergency measures begin with the recognition and declaration of an emergency class, notification of the applicable agencies for that emergency class, and mobilization of the appropriate portions of the emergency organization. Subsequent measures include damage assessment, corrective actions, protective actions, and aid to affected personnel.

Recovery activities are discussed in Section 7.

4.1 ACTIVATION OF EMERGENCY ORGANIZATIONS 4.1.1 General The Plant Operating Manual contains Emergency Operating Procedures (EOPs). These are intended to aid the plant operators in responding to an accident. The EOPs identify actions which should automatically occur to safely terminate the accident and manual actions which should be taken to verify that the automatic actions have produced the desired results. The EOPs also provide, for the operator's use, guidelines which alert the operators to conditions where inadequate cooling of the core exists or where radioactivity releases may occur. Accordingly, if it should appear that any of the Emergency Action Levels are exceeded, as described in 0PEP-02.1, Initial Emergency Actions, and 0PEP-02.2.1, Emergency Action Level Technical Bases, the Site Emergency Coordinator (SEC) is instructed to activate the Emergency Plan.

The Shift Manager, or other qualified Control Room personnel, shall activate the Emergency Plan, and assumes the SEC responsibilities, initially classifies the emergency, and ensures that the required notifications are made. The SEC will activate portions of, or the entire emergency organization, as warranted for the emergency situation. A more detailed discussion of the methodology that is used in activating the emergency organizations during each class of emergency is provided below and in the Plant Emergency Procedures. Additional detail of the communications networks to be used for notification requirements, for information reporting, and for decision-making with respect to taking protective action on site and for the general public is contained in Appendix A of this plan and 0PEP-03.1.3, Use of Communication Equipment.

0ERP Rev. 089 4-1

4.1.2 Unusual Event The Shift Manager, or other qualified Control Room personnel, when informed of conditions that meet emergencies that are classified as an Unusual Event, confirms that an Emergency Action Level has been exceeded and implements 0PEP-02.1.1, Emergency Control -

Notification of Unusual Event, Alert, Site Area Emergency, General Emergency. That individual is then responsible for assuming the role of the Site Emergency Coordinator and for notifying and activating those portions of the emergency organization as appropriate to the emergency class which then exists. The Site Emergency Coordinator can augment the on-site shift personnel by activating additional emergency personnel described in Section 3. Typical of the personnel that may be notified are OSC personnel and the Security Force.

4.1.3 Alert Section 2, Emergency Classifications, 0PEP-02.1, Initial Emergency Actions, and 0PEP-02.2.1, Emergency Action Level Technical Bases, describe the types of emergencies that are classified as an Alert.

Since the conditions in this emergency class indicate an actual or potential substantial degradation of the level of safety of the plant and has the potential for limited releases of radioactive material to the environment, off-site groups will be notified to standby so that if the emergency level is escalated, the essential off-site emergency organizational groups can be notified and readily mobilized to augment the on-site emergency groups.

Upon declaration of an Alert emergency classification the Shift Manager, or other qualified Control Room personnel, assumes the role of the Site Emergency Coordinator until relieved by a designated, qualified emergency response organization member. The transfer of the Control Room Site Emergency Coordinator responsibilities to the Technical Support Center (TSC) Site Emergency Coordinator occurs simultaneously with the activation of the Technical Support Center (TSC).

The Site Emergency Coordinator implements 0PEP-02.1.1, Emergency Control - Notification of Unusual Event, Alert, Site Area Emergency, General Emergency, and notifies the appropriate individuals or groups.

The Control Room Site Emergency Coordinator initiates the activation of the Technical Support Center, Operational Support Center, and the Emergency Operations Facility (EOF). The radiological emergency teams will be activated, as appropriate.

0ERP Rev. 089 4-2

The appropriate county and state emergency group leaders will be requested to remain in a readiness condition in case additional augmentation of support personnel is needed and alerting the population-at-risk is warranted.

A decision to go beyond the initial response associated with an Alert class would be based on further degradation of plant parameters, operational experience, or radiation releases that are projected to escalate beyond the Emergency Action Levels for an Alert.

4.1.4 Site Area Emergency Section 2, Emergency Classifications, 0PEP-02.1, Initial Emergency Actions, and 0PEP-02.2.1, Emergency Action Level Technical Bases, describe the types of emergencies classified as a Site Area Emergency. The Site Emergency Coordinator, when classifying the emergency, takes appropriate predefined steps to correct the situation as described in 0PEP-02.1.1, Emergency Control - Notification of Unusual Event, Alert, Site Area Emergency, General Emergency.

If not done earlier, the Shift Manager, or other qualified Control Room personnel, assumes the role of the Site Emergency Coordinator (SEC) until formally relieved. The SEC activates the necessary emergency organizations and directs that the essential emergency personnel be notified.

If they have not been previously requested to do so, the off-site groups will be mobilized as soon as possible; the Technical Support Center, Operational Support Center, and the Emergency Operations Facility will be activated. Radiation monitoring teams may be augmented to permit an expanded on-site and near site monitoring program.

The Joint Information Center will be activated for the purpose of providing information to the public.

If the plant parameters indicate possible further degradation of plant safety or projected radiation levels which exceed the recommended values, the emergency will be escalated to the General Emergency level.

0ERP Rev. 089 4-3

4.1.5 General Emergency Section 2, Emergency Classifications, 0PEP-02.1, Initial Emergency Actions, and 0PEP-02.2.1, Emergency Action Level Technical Bases, describe the types of emergencies classified as a General Emergency.

The Site Emergency Coordinator (SEC) upon classifying the situation as a General Emergency takes appropriate, predefined steps to respond to and correct the situation as described 0PEP-02.1.1, Emergency Control - Notification of Unusual Event, Alert, Site Area Emergency, General Emergency. This includes arranging for personnel to be available, both on site and off site, to perform actions up to and including evacuation of the affected sectors of the 10-mile EPZ.

If not done earlier, the Shift Manager, or other qualified Control Room personnel, assumes the role of the SEC until formally relieved. The SEC activates the necessary emergency organizations and directs that the essential emergency personnel be notified.

The activation and notification process should have begun well before a General Emergency is declared. Recommendations will be made for sheltering and/or evacuation in accordance with the guidelines in 0PEP-02.6.28, Off-Site Protective Action Recommendations.

4.2 ACCIDENT ASSESSMENT ACTIONS 4.2.1 General Effective coordination and direction of all elements of the emergency organization require continuing accident assessment throughout an emergency situation. The process of accident assessment involves several different types of activities, in-plant and off-site, depending on the nature and severity of the emergency.

The magnitude of releases of radioactive material can be determined using effluent and process monitors, meteorological data and other sources of information. Additionally, an independent confirmation of the magnitude of the release can be obtained based on the measured dose rates in the environment. Given these measured releases or environmental levels and estimates of the amount of dispersion between the plant and the various points of interest, projected doses can be estimated for other locations. These doses can then be compared to Protective Action Guides. The various steps in this process are discussed in the following sections and in the Plant Emergency Procedures. In the absence of measurable off-site dose rates, protective action recommendations will be made based on the guidelines 0PEP-02.1.1, Emergency Control - Notification of Unusual Event, Alert, Site Area Emergency, General Emergency.

0ERP Rev. 089 4-4

4.2.2 Source Term Assessment Source terms for assessment of off-site dose consequences to the public can be determined by using effluent and radiation monitor readings, evaluating plant conditions against predetermined scenarios, using analysis results of plant effluent samples, and by manually estimating curie inventories. A thorough discussion of source term development is provided in Appendix F.

4.2.2.1 Effluent and Radiation Readings The most direct indication of a radiological emergency is a high reading in the effluent radiation monitors. The radiation monitoring system monitors the airborne gaseous and particulate activity released from the Reactor Building and Turbine Building. Additional channels of the radiation monitoring system also monitor the gaseous activity in the air ejectors, primary containment (drywell atmosphere) ventilation system, and main steam line monitors. These channels indicate, record, and alarm in the main control room. The radiation monitoring system gives early warning of a plant malfunction and warns plant personnel of increasing radiation activity which might result in a radiation hazard. (See 0PEP-03.6.3 for procedures on source term assessments and estimates of core damage.)

0ERP Rev. 089 4-5

These monitors are also the primary means of determining that an emergency exists for accidents involving spills or leaks of contaminated liquids or gases from systems housing radioactive materials. Such leaks could lead to a release to the environment. In such instances, the following types of emergency actions would take place:

1. The Control Room would be notified.

2. Personnel from the affected plant area would be evacuated, if required.

3. Access to the plant area involved would be restricted.

4. All plant personnel directly involved would be monitored for contamination.

5. A determination would be made of the potential for an off-site release.

6. The Plant Emergency Procedures would be activated if an emergency is declared.

4.2.2.2 Potential Consequences Based on In-Plant Conditions The source term can be estimated by evaluating the plant condition against a number of preselected scenarios that best describes the effectiveness of containment, cleanup systems, subcooled, or saturated conditions in the torus, and other relevant parameters. A more thorough discussion of the determination of source terms from plant conditions is described in Appendix F.

0ERP Rev. 089 4-6

4.2.2.3 Post Accident Sampling and Analysis of Reactor and Containment To aid in the assessment of core damage, area-type monitors utilizing ion chamber detectors are available to monitor radiation levels in the drywell. These monitors have a range of up to 107 Rem/hr. The range of monitoring equipment in various locations of the plant is sufficient (e.g., high range noble gas vent monitor and improved procedures for iodine analyses) to monitor the applicable release point. This information can be used, together with the analyses of primary coolant system contamination levels, to develop an assessment of the types and quantities of various materials that have been released.

Additionally, capabilities have been provided to permit sampling for chemical and radioanalysis under a wide range of accident conditions. Samples can be taken from effluent streams such as the plant stack to determine total release quantity and radionuclide mix, or they can be taken from the RCS, drywell, and torus to determine radionuclide mix. The collection and analysis of samples can be performed without incurring radiation exposures to individuals in excess of 10CFR20.1201 limits.

The procedures for obtaining samples of gases and liquids during normal operation (such as a sample of primary coolant) can also be safely used during a wide spectrum of accident conditions. However, there are situations involving gross damage to the core where access to the sampling stations and handling of samples may be limited due to high radiation levels. Procedures have been developed and equipment has been installed at the sample panels to minimize the time required to obtain samples and to reduce the radiation levels during transport and analysis of samples. Beyond these measures, post accident sampling stations are located in the breezeway on the 20-foot level. This permits the collection of samples even if access to the Reactor Building is lost. This station can be used to safely withdraw samples of reactor coolant from the recirculation instrument racks in parallel with the jet pump flow indicator and to withdraw samples of water in the torus.

0ERP Rev. 089 4-7

4.2.3 Dose Projection and Meteorological Systems Once the source term is estimated, exposures to on-site and off-site individuals can be estimated as described in AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment, and 0PEP-03.4.8, Offsite Dose Projections for Monitored Releases. The technical basis for the methodology for performing dose projection is described in Appendix F. Prior to receipt of information from the environmental monitoring teams, exposure rates at various locations on site and off site will be estimated from the airborne concentrations of radioactive material as calculated from plant radiation monitors and the atmospheric dispersion characteristics.

Meteorological measurements, specifically the change in temperature with height and wind velocity, are used to determine the atmospheric dispersion conditions. Normally, the plant computer will provide a readout of the stability condition, but alternate methods are available.

Rapid evaluation of potential radiation levels of any downwind area can be made through the use of calculated dispersion factors and the calculated release rate of airborne radioactive material from the plant.

The Brunswick Nuclear Plant has an on-site meteorological station with a backup source of additional meteorological data to provide sufficient information for utilization in a dose assessment capability.

This system is further described in Section 5.7.2.

Currently, the BNP staff has an automated dose projection capability as described AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment, and manual dose projection capability as described in 0PEP-03.4.8, Offsite Dose Projections for Monitored Releases. By entering critical plant data and meteorological information obtained from the on-site meteorological station, dose projections can be made for various locations using the dose assessment program. This function has been designed and implemented to allow for the rapid determination of centerline doses for immediate use by plant personnel.

Additionally, contract meteorologists may be contacted by plant personnel.

Meteorological data display is available for remote integration as part of the Emergency Response Facility Information System (ERFIS).

This satisfies the NUREG-0654, Rev. 1 criteria for meteorological evaluation and remote interrogation.

0ERP Rev. 089 4-8

4.2.4 Emergency Environmental Monitoring The Site Emergency Coordinator is responsible for quickly evaluating meteorological conditions existing at the time of the incident and, where releases are or soon will be occurring, for dispatching monitoring teams to specified, predetermined downwind locations.

The prime objective of the initial emergency off-site monitoring is to confirm or modify the initial projections of the consequences of any release of radioactive material into the environment.

The Environmental Monitoring Teams collect samples and survey data and transmit information to and/or receive instructions from the Radiological Control Manager of the EOF staff (or Radiological Control Director, if the EOF is not activated).

Calculational aids, site maps, and actual radiation survey data collected by off-site survey teams define affected areas and assess the extent and significance of the release. Information is required for decision making with as little delay as possible; therefore, the initial environmental surveys involve simple-to-perform measurements so that the dose assessments based on plant parameters can be quickly confirmed or modified. Subsequent environmental monitoring efforts will be aimed at further defining the off-site consequences including estimates of total population exposure and instituting an expanded program to enable prompt assessments of any subsequent releases from the plant. Duke Energy Environmental Monitoring Teams will coordinate expanded environmental monitoring efforts to assist the agencies identified in Section 3.8. Field monitoring equipment will have at least the capability to detect and measure radioiodine in the

-8 3 vicinity of the plant site as low as 5 x 10 µCi/cm . The collected air sample can easily be measured by hand held survey meters, a simple test that can serve as an initial check of projected releases based on plant data and can confirm that significant quantities of elemental iodine have been released (the chemical form that would pose a health hazard). More detailed measurements (e.g., Sodium Iodide scintillation counters) can be quickly brought into service to provide the longer term higher capabilities to detect and measure very low levels of contamination in the environment, as would be planned for subsequent radiation monitoring efforts.

At least two environmental monitoring teams will initially be activated from the plant staff upon activation of the EOF by the Emergency Response Manager.

0ERP Rev. 089 4-9

4.2.5 Emergency Response Data System (ERDS)

The Emergency Response Data System will supply the NRC with selected ERFIS data points on a near real time basis. This function will be activated by the Shift Technical Advisor within an hour of the declaration of an Alert or higher classification. The selected data points are transmitted via Virtual Private Network (VPN) to the NRC at approximately 1-minute intervals. If the primary ERFIS system fails (failover) the backup ERFIS system will resume sending the data to the NRC.

4.3 CORRECTIVE ACTIONS Corrective actions that may be taken to mitigate the circumstances of various levels and types of emergencies identified in this plan are given in the Plant Operating Manual. Generally, corrective actions include any actions that are taken to repair damaged equipment, to install emergency structures, systems, and components, or to reduce the releases of radioactivity.

In order to maintain proficiency in implementing the various procedures and plans, there are training and retraining programs which in some cases are augmented by periodic drills and exercises. A description of this specialized training is given in Section 6.1.1.

4.4 PROTECTIVE ACTIONS Protective actions are defined for each emergency class. Protective actions must take into consideration the potential risks of implementing such measures versus the reduction of the radiological risk achieved by their use.

Analyses of the spectrum of emergencies show that only those in the General Emergency class are expected to have consequences in excess of one Rem whole body (TEDE).

Protective action recommendation guidelines for the general public are described in 0PEP-02.6.28, Off-Site Protective Action Recommendations.

Protective actions planned for on-site personnel are described in Section 4.4.2. Protective actions for the off-site population-at-risk are the responsibility of state and local agencies; however, representative actions at various dose levels are described in Section 4.4.7. The evaluation of Protective Action Guidelines for the intermediate phase and for ingestion pathways are the responsibility of the state.

0ERP Rev. 089 4-10

4.4.1 Protective Action - Off Site Notification of off-site agencies will take place when EALs are exceeded (see Section 3.9). Any incident that is projected to result in radiation doses to the general public in excess of the Protective Action Guidelines listed in 0PEP-02.6.28, Off-Site Protective Action Recommendations, requires the Site Emergency Coordinator to declare a General Emergency. The Emergency Response Manager will recommend to the state and counties protective measures for the public.

4.4.2 Protective Action - On Site 4.4.2.1 Warning and Notification The on-site PA system and appropriate alarms will be used to alert/warn and notify on-site personnel of an emergency and necessary protective actions as described in 0PEP-02.1.1, Emergency Control - Notification of Unusual Event, Alert, Site Area Emergency, and General Emergency. In addition to the alarms, PEPs and security instructions provide guidance for on-site warning and notification. Such warning and notification will include persons at the Media and Visitors Center and the recreation area(s). Outside the plant protected area, and adjacent buildings, warning will be accomplished as described in Section 4.4.6 for the public.

0ERP Rev. 089 4-11

4.4.2.2 Evacuation & Personnel Accountability For emergencies requiring protective actions in accordance with 0PEP-03.8.2, Personnel Accountability and Evacuation, personnel will proceed by the safest, most direct route to the designated assembly locations or as directed by the Site Emergency Coordinator.

1. Shift operating personnel will assemble in the Control Room.

2. All personnel not specifically involved in responding to the emergency (non-essential) will assemble as directed.

3. All visitors will report to the Security Office at the protected area central access control point.

A personnel accountability check will be carried out in accordance with 0PEP-03.8.2, Personnel Accountability and Evacuation. This procedure also provides instruction for the return of dosimeters and identifies the locations where contaminated individuals can be decontaminated.

Onsite medical care will be performed in accordance with 0PEP-03.9.3, First Aid, Medical Care and Transport for Injured Personnel.

Search for missing persons and rescue will be performed as described in 0PEP-03.9.6, Search and Rescue.

On-site personnel will evacuate the area when directed using transportation that was employed to arrive at the site.

Personnel without transportation will be identified during the assembly phase and provided transportation.

The secondary access road and the main plant access road may be used to depart from the site as advised, and evacuation from the 10-mile EPZ will be by way of evacuation routes identified in Figures 1.1-1, 1.1-2, and 4.4-1.

0ERP Rev. 089 4-12

4.4.3 Control of Personnel Radiation Exposures Although an emergency situation transcends the normal requirements for limiting exposures to ionizing radiation, guideline levels are established in 0PEP-03.7.7, Onsite Radiological Controls, for exposures that may be acceptable in emergencies. The maximum whole body (TEDE) dose received by any worker should not exceed established regulatory limits. Every reasonable effort will be used to ensure that an emergency is handled in such a manner that no worker exceeds these limits. The ERM or SEC can authorize exposure to radiation in excess of 10 CFR 20 limits.

The administration of radioprotective drugs such as potassium iodide (KI) to Duke Energy personnel may also be useful in mitigating the consequences of inhalation of radioactive materials such as radioiodines during an emergency.

Procedures for the administration of radioprotective drugs to Duke Energy and vendor employees are described in 0PEP-03.7.6, Emergency Exposure Controls.

Decision making is based on conditions at the time of an emergency and should always consider the probable effects of an exposure prior to allowing any individual to be exposed to radiation levels exceeding the established occupational limits. The probable high radiation exposure effects are:

1. Up to 50 Rem EDE in 1 day - no physiological changes are likely to be observed.

2. 50 to 100 Rem EDE - no impairment likely but some physiological changes, including possible temporary blood changes, may occur.

Medical observations would be required after exposure.

3. 100 to 300 Rem EDE - some physical impairment possible. Some lethal exposures possible.

0ERP Rev. 089 4-13

The following subsections describe the criteria to be considered for life-saving and facility protection actions.

4.4.3.1 Exposure Control Under Emergency Conditions Dose limit guidelines for workers in an emergency are taken from EPA 400-R-92-001, Manual of Protective Actions and Protective Action Guidelines for Nuclear Incidents, U. S.

Environmental Protection Agency, May 1992. Much of the discussion in this section is taken in whole from that document.

In emergency situations, workers may receive exposure under a variety of circumstances in order to assure protection of others and of valuable property. These exposures will be justified if the maximum risks or costs to others that are avoided by their actions outweigh the risks to which the workers are subjected.

The Emergency Worker Dose Limit Guidelines are as follows:

Dose Limit 1 (REM TEDE) Activity Condition 5 All 10 Protecting valuable property Lower dose is not practicable 25 Lifesaving or protection of large Lower dose is not populations practicable

>25 Lifesaving or protection of large Only on a voluntary basis to populations persons fully aware of the risks involved Routine dose limits shall not be extended to emergency dose limits for declared pregnant individuals. As in the case of normal occupational exposure, doses received under emergency conditions should be maintained as low as reasonably achievable.

1 Doses to the lens of the eye should be limited to three times the stated TEDE value and doses to any other organ (including skin and body extremities) should be limited to ten times the stated TEDE value.

0ERP Rev. 089 4-14

In the context of these guidelines, exposure of workers that is incurred for the protection of large populations may be considered justified for situations in which the collective dose avoided by the emergency operation is significantly larger than that incurred by the workers involved.

Persons undertaking any emergency operation in which the dose will exceed 25 Rem TEDE should do so only on a voluntary basis and with full awareness of the risks involved, including the numerical levels of dose at which acute effects of radiation will be incurred and numerical estimates of the risk of delayed effect.

4.4.3.2 Exposures During Repair/Reentry Efforts Each emergency worker entering a high radiation area shall wear dosimetry capable of measuring the expected exposure to be received.

Emergency teams that must enter areas where they might be expected to receive higher than normal doses will be fully briefed regarding their duties and actions and what they are to do while in the area. They will also be fully briefed as to expected dose rates, stay time, and other hazards. All such entries will include one Health Physics Technician, or other person adequately trained in health physics. All team members will use protective devices as specified by the Radiological Control Director. The team members will be instructed not to deviate from the planned route unless required by unanticipated conditions, such as rescue or performance of an operation that would minimize the emergency condition. If the monitored dose rates or stay times encountered during the entry exceed the limits set for the operation, the team will communicate with the OSC Mission Coordinator or will return to the area from where they were dispatched.

Once their operation has been completed, the team personnel will follow established monitoring and personnel decontamination procedures as specified by the Radiological Control Director.

0ERP Rev. 089 4-15

4.4.4 Radioactive Contamination 4.4.4.1 On-Site Personnel Radiation safety controls are established to contain the spread of loose surface radioactive contamination. Personnel leaving the contaminated areas are monitored to ensure that they or their clothing are not radioactively contaminated. Additionally, in the event of a site evacuation, no personnel will be allowed to leave the plant Owner Controlled Area (OCA) until they have been checked for contamination. In addition to the decontamination area of the Service Building, additional areas can be set up inside the entrance to the TSC/EOF Building.

Contaminated clothing or personal articles will be decontaminated or replaced. Drinking water and food supplies will be monitored and, during an emergency, permitted only in specified clean areas. Contamination on personnel will be removed in accordance with established E&RC procedures. If normal decontamination procedures do not reduce contamination to acceptable levels, the case will be referred to a competent medical authority.

4.4.4.2 Equipment and Vehicles Equipment and tools will be released for use outside of the contaminated areas only if loose surface radioactive contamination is within acceptable limits. All tools and items of equipment must be checked for contamination before being taken from a known contaminated area. If the item is found to be contaminated and decontamination is not practical, the item must remain in that area. In the event of a site evacuation, vehicles will be surveyed for contamination before they are allowed to leave the plant site. Contaminated vehicles will be decontaminated before being released. If the Low Level Radwaste Warehouse is not a suitable decontamination site due to radiological concerns, vehicles will be directed to an alternate area for decontamination. Brunswick County Emergency Management may provide assistance in this area.

0ERP Rev. 089 4-16

4.4.5 Treatment of Injured and Contaminated Persons Personnel showers and chemical decontamination agents are available on site and, except in cases of life-threatening/serious injury, established decontamination procedures will be employed on site prior to medical treatment. Decontamination showers and supplies are provided in the Service Building. Shower and sink drains in the Service Building are routed to the miscellaneous waste processing system where the liquid is processed and monitored prior to discharge.

Arrangements and facilities for medical treatment of injured plant personnel are described in detail in Appendix E - Medical Treatment and Assistance and in 0PEP-03.9.3, First Aid, Medical Care and Transport for Injured Personnel. Depending on the nature and severity of injury, injured personnel may be treated in-plant by individuals trained in first aid, treated in-plant by a physician, or transported to the hospital for treatment (see 0PEP-03.9.3, First Aid, Medical Care and Transport for Injured Personnel).

In cases of severe injury, lifesaving first aid or medical treatment will take precedence over personnel decontamination. In general, the order of medical treatment will be:

1. Care of severe physical injuries.

2. Personnel decontamination.

3. First aid to other injuries.

4. Ambulance Service

5. Definitive medical treatment and subsequent therapy as required.

Definitive medical treatment, therapy, and evaluation may include radioprotective drugs; urinary bio-assays or whole body counts on persons suspected of inhaling or ingesting a significant amount of radioactive material or may include surveillance and therapy for persons receiving a large whole body dose.

0ERP Rev. 089 4-17

4.4.6 Public Warning and Notification In the event of an emergency, the plant will notify designated emergency officials in Brunswick and New Hanover counties as well as state and federal officials in accordance with 0PEP-02.6.21, Emergency Communicator.

During the ALERT phase of an emergency, the appropriate county and state emergency group leaders will be requested to remain in a readiness condition to alert the population at risk if needed. The plant will recommend protective actions for the public upon declaration of a General Emergency.

Public warning when deemed necessary will be accomplished as described in the North Carolina Emergency Response Plan in Support of the BNP. Warning will be given by such methods as sirens supplemented by radio, television, sound trucks, bullhorns, and knocking on doors. The Coast Guard will be used in notifying people along the coast and other large bodies of water where appropriate and necessary.

Sirens mounted on utility poles have been installed by Duke Energy at 38 locations within a 10-mile radius of the Brunswick Nuclear Power Plant. Since the average ambient noise level throughout the EPZ is about 49dBA, the siren system is planned to provide a 59dBA minimum signal. The warning signal will be a 3-to-5-minute steady tone on the sirens.

Sirens will not be sited in the Sunny Point Army Terminal. Brunswick County will notify the terminal which will alert its personnel using on-site warning methods.

Sirens will not be sited in areas of no or low population. Large areas of Brunswick County consist of swamps and forests with no or low population. These areas include such tracts as the Orton Plantation, the western section of Boiling Springs Lakes, and some areas south of Route 211. Based on land use history, they show little promise of development. However, the warning system will be reviewed annually and upgraded when conditions warrant.

0ERP Rev. 089 4-18

Activation of the sirens will be accomplished from the Brunswick and New Hanover Counties Emergency Operation Centers. The sirens in each county are independently controlled, but may be activated by Duke Energy with permission from the counties. A feedback system immediately alerts Duke Energy and both counties of any siren failure.

The U.S. Coast Guard will perform the warning of people on bodies of water under their jurisdiction.

The population at risk in the 10-mile Emergency Planning Zone (EPZ) is subdivided into three general categories: resident (permanent) population, transient population, and special facility population as described in Brunswick Nuclear Power Plant Development of Evacuation Time Estimates, prepared by KLD Associates, November, 2012. The total resident population affected within the 10-mile EPZ is approximately 35,250. During the summer months, June through August, the daytime population of the EPZ is approximately 100,712 (see Figure 1.1-6, 1.1-6a and 1.1-6-b). The population is concentrated along the coast and a relatively few inland roads.

4.4.7 Protective Actions - Off Site/Public 4.4.7.1 Public Education and Information Occupants in the plume exposure pathway Emergency Planning Zone (EPZ) will be provided information prepared by Duke Energy in conjunction with the state and county agencies. This public education and information program is intended to ensure that members of the public are: (a) aware of the potential for an occurrence of a radiological emergency; (b) able to recognize a radiological emergency notification; and (c) knowledgeable of the proper, immediate actions to be taken upon notification.

This will be accomplished by: (1) distribution of the annual safety information brochure which contains educational information on emergency preparedness, sheltering, sirens, radiation, and telephone numbers of agencies to contact for more information; (2) availability of qualified personnel to address civic, religious, social and occupational organizations; and (3) distribution of news material to the media and numerous community and business newsletters.

0ERP Rev. 089 4-19

Emergency information will be made available to transient populations through the distribution of safety information brochures to commercial establishments in the 10-mile EPZ.

During an actual emergency, provisions will be established through the Joint Information Center to make available and distribute information to the news media. The Joint Information Center will also implement provisions for a number of telephones which members of the public, who hear rumors, can call for factual information.

The public education and information program is further described in Section 6.1.4.

4.4.7.2 General For emergencies requiring protective actions for the general public in designated off-site areas, state agencies will determine the advisability of any necessary evacuation or sheltering. Local agencies will conduct the protective actions as warranted. Assembly points would vary depending on the severity of the incident and on the prevailing weather conditions. To assist in this effort, Duke Energy will provide up-to-date assessments of the condition of the plant and of the quantity and rate of release of radioactivity. Duke Energy will also assist by performing dose assessments which will be compared to the protective action guidelines.

The protective actions that Duke Energy recommends to the state will be based upon current meteorological data such as wind direction, speed and stability class, and other factors.

Releases affecting off-site areas may not be of the magnitude requiring evacuation. These affected areas within the 10-mile EPZ that do not evacuate will be recommended to shelter.

Detailed procedures for public protective actions are contained in the North Carolina Emergency Response Plan in Support of BNP.

0ERP Rev. 089 4-20

4.4.7.3 Evacuation In the event that evacuation of zones within the 10-mile EPZ is required, the evacuation routes shown in Figure 1.1-2 and Figure 4.4-1 will be used by on-site and off-site personnel.

The time required to evacuate personnel from the 10-mile EPZ varies depending on whether a part of the EPZ is to be evacuated or all of it, on the time of year such as non-summer or summer, etc., as illustrated in Figure 4.4-2 and on other factors as shown in Table 4.4-1.

It should be noted that the evacuation process in itself involves risk to the public. Risks resulting from evacuation are discussed in US EPA Report, EPA 400-R-92-00, Appendix C.

4.4.7.4 Shelter Some zones that are not recommended to evacuate will be recommended to shelter. The state may consider sheltering for special populations or hazardous environmental conditions.

Special populations may include institutionalized or infirm persons. Hazardous environmental conditions may include the presence of severe weather or competing disasters.

The local housing consists primarily of wood framed dwellings, 1 and 2 stories that are over 10 years old. Very few houses have basements. There are a number of brick veneer dwellings of later construction and a fairly small even distribution of house trailers.

The term Protection Factor (PF) refers to a number used to express the relationship between the amount of gamma radiation that would be received by an unprotected person and the amount that would be received by a person in shelter. An occupant of a shelter with a PF of 40 would be exposed to l/40 (2.5 percent) of the dose or dose rate to which they would be exposed if their location were unprotected (Sheltered Dose = Unsheltered Dose ÷ PF).

Protection Factors/Shielding Factors for various shielding materials are given in Figure 4.4-3 and for various structures and vehicles in Tables 4.4-2, 4.4-3, and 4.4-4.

0ERP Rev. 089 4-21

4.4.7.5 Respiratory Protection It is unlikely that effective public respiratory protection can be provided by improvised devices. This problem will be studied and provisions incorporated in this plan in the event satisfactory systems are found.

0ERP Rev. 089 4-22

TABLE 4.4-1 FACTORS RELATED TO WARNING/EVACUATION TIME Page 1 of 1

1. Facility to Off-site Agencies Alert Phase

a. Decision-making time

b. Physical actions/calling time

2. Governmental Agencies to Public Alert Phase

a. Decision-making time

b. Physical actions/calling-alerting time

3. Public Alert and Notification Phase

a. Hear signal

b. Recognize signal

c. Seek confirmation of signal meaning and validity

d. Find confirmation of signal meaning

e. Relate signal meaning to self

f. Decide to act.

4. Movement Preparation Phase

a. Time between deciding to act and departing location

b. Shutting off utilities

c. Packing bags

d. Deciding on destination and routes

e. Taking care of livestock, etc.

f. Collecting other family members

g. Loading the automobile and departing

5. Movement/Travel Phase

a. Movement time is a function of road distance to the boundary of the evacuation area, vehicle used for evacuation, and auto traffic conditions (traffic volumes, road capacity, weather conditions, etc.).

b. Road capacity under emergency conditions per FEMA CPG-2-8-C, are assumed to be 850 vehicles per hour (vph) per lane; under foul weather conditions 450-500 vph.

c. Traffic volume is determined by: (1) dividing the EPZ population by the average number of persons per dwelling unit; or (2) obtaining statistical data on number of vehicles registered in the EPZ, or; (3) other.

6. Evacuation Verification Phase

a. Marker Technique (NRC NUREG-0654)

Auto check - Total road distances ÷ Ave. 15 mph Aircraft check

b. Telephone poll: 0.5 min. per residence 0ERP Rev. 089 4-23

TABLE 4.4-2 REPRESENTATIVE SHIELDING FACTORS FOR SURFACE DEPOSITED RADIONUCLIDES*

Page 1 of 1 Representative Representative (a)

Structure or Location Shielding Factor Range 1 m above ordinary ground 0.70 0.47-0.85 Cars on 50-ft. road:

Road fully contaminated 0.5 0.4-0.7 Road 50% decontaminated 0.5 0.4-0.6 Road fully decontaminated 0.25 0.2-0.5 Trains 0.40 0.3-0.5 (b)

One- and two-story wood-frame house 0.4 0.2-0.5 (no basement)

(b)

One- and two-story block and brick 0.2 0.04-0.40 house (no basement)

(b)

House basement, one or two walls 0.1 0.03-0.15 fully exposed:

(b)

One story, less than 2 ft of 0.05 0.03-0.07 basement, walls exposed (b)

Two stories, less than 2 ft. 0.03 0.02-0.05 of basement, walls exposed Three- or four-story structures, 2

5000 to 10,000 ft per floor:

(b)

First and second floors 0.05 0.01-0.08 (b)

Basement 0.01 0.001-0.07 Multistory structures, > 10,000 2

ft per floor:

(b)

Upper floors 0.01 0.001-0.02 (b)

Basement 0.005 0.001-0.015 (a) The ratio of dose received inside the structure to the dose that would be received outside the structure.

(b) Away from doors and windows.

(c) Shielding Factor = Shielded Dose Rate / Unshielded Dose Rate

• From: SAND 77-1725, Public Protection Strategies for Potential Nuclear Accidents, Sandia Laboratory 0ERP Rev. 089 4-24

TABLE 4.4-3 REPRESENTATIVE SHIELDING FACTORS FROM GAMMA CLOUD SOURCE Page 1 of 1 Shielding Representative Structure or Location Shielding Factor(a) Range Outside 1.0 --

Vehicles 1.0 --

Wood-frame house(b) 0.9 --

(no basement)

Basement of wood house 0.6 0.1 to 0.7(c)

Masonry house (no basement) 0.6 0.4 to 0.7(c)

Basement of masonry house 0.4 0.1 to 0.5(c)

Large office or industrial 0.2 0.1 to 0.3(c,d) building (a) The ratio of the dose received inside the structure to the dose that would be received outside the structure.

(b) A wood frame house with brick or stone veneer is approximately equivalent to a masonry house for shielding purposes.

(c) This range is mainly due to different wall materials and different geometries.

(c) The shielding factor depends on where the personnel are located within the building (e.g., the basement or an inside room).

(d) Shielding Factor = Shielded Dose Rate / Unshielded Dose Rate

• From: SAND 77-1725, Public Protection Strategies For Potential Nuclear Reactor Accidents, Sandia Laboratory 0ERP Rev. 089 4-25

TABLE 4.4-4 PF OF VARIOUS VEHICLES AND STRUCTURES Page 1 of 1 Average PF Aircraft Light (Cessna - 172 type) ................................................................................................ 1.25 Bus - Scenic Cruiser. ................................................................................................................... 7

" - Commercial Type ................................................................................................................... 1.7

" - School .................................................................................................................................... 1.6 Car - Passenger ........................................................................................................................... 1.6 Foxhole (3 ft. diameter x 4 ft. deep) ............................................................................................ 10.0 If an area 3 or 4 feet wide around the foxhole is kept free of fallout material, a protection factor of 100 or more is possible.

House, Wood Frame (Cape Cod/Colonial Types)

First Floor Center of House ............................................................................................ 2.0 Basement ....................................................................................................................... 10.0 Corner of Basement, Under Table with 8" Concrete on top ........................................ 100.0 House, Brick (Cape Cod/Colonial Type)

First Floor Center of House ............................................................................................ 10.0 Basement ....................................................................................................................... 30.0 Locomotive, Heavy, Engineers Seat .......................................................................................... 3.3 Normal Living, Home and Work as Usual .................................................................................. 2.0 Trucks l/4 Ton ............................................................................................................................ 1.3 3/4 Ton ........................................................................................................................... 1.4 2 l/2 Ton ......................................................................................................................... 1.7 4 to 7 Ton ....................................................................................................................... 2.0 Fire Truck, Drivers Side ................................................................................................. 2.9 Fire Truck, Standing Area in Back ................................................................................. 1.7 Roadway Underpass .................................................................................................................. 2 to 5 Urban Areas (In Open) ............................................................................................................... 1.4 Woods ........................................................................................................................................ 1.25 NOTE: Protection Factor (PF) = Unshielded Dose Rate ÷ Shielded Dose Rate. Above data pertains to deposited particulate radioactive material with gamma energy approx. 0.7 mev 0ERP Rev. 089 4-26

Figure 4.4-1 BNP Evacuation Routes Page 1 of 1 0ERP Rev. 089 4-27

Figure 4.4-2 Evacuation Times - Brunswick EPZ Page 1 of 1 Evacuation Time (hours / minutes)a Local Planning Zones Evacuated Summer Non-summer A,B,G,H,J,K 3:45 3:15 A,B,H,J,K,L 4:50 3:15 A,B,J,K,L,M 4:50 3:15 A,B,J,L,M 3:45 2:40 A,B,L,M,N 3:40 2:40 A,B,M,N 3:50 2:45 A,B,C,M,N 3:50 2:45 A,B,C,D,M,N 5:00 3:20 A,B,C,D,E,M,N 6:05 4:15 A,B,C,D,E 6:00 4:15 A,B,C,D,E,F 6:35 4:30 A,B,D,E,F 6:20 4:25 A,B,E,F,G,H,J 4:40 3:35 A,B,C,D,E,F,G,H,J,K,L,M,N 6:05 4:10

a. This range of evacuation times covers 12 scenarios:

1. Summer Midweek Midday Good Weather

2. Summer Midweek Midday Rain

3. Summer Weekend Midday Good Weather

4. Summer Weekend Midday Rain

5. Summer Midweek/Weekend Evening Good Weather

6. Non-summer Midweek Midday Good Weather

7. Non-summer Midweek Midday Rain

8. Non-summer Weekend Midday Good Weather

9. Non-summer Weekend Midday Rain

10. Non-summer Midweek/Weekend Evening Good Weather

11. Summer Weekend Midday Special Event

12. Summer Midweek Midday Roadway Impact 0ERP Rev. 089 4-28

Figure 4.4-3 Protection Factors of Shielding Materials Page 1 of 1 0ERP Rev. 089 4-29

DUKE ENERGY BRUNSWICK NUCLEAR PLANT (BNP)

RADIOLOGICAL EMERGENCY PLAN (ERP) 5.0 EMERGENCY FACILITIES AND EQUIPMENT To facilitate efficient and effective control and coordination of the numerous actions required during emergency situations, several facilities have been designated as emergency centers for Brunswick. These facilities are linked by a comprehensive communications network to allow accurate and timely communications between the facilities, outside agencies, and the public. The communications network uses AT&T systems, fiber optic, Duke Energy microwave net, data links, and radio to provide: (a) voice communication through normal telephone use, automatic ringdown between selected facilities, conference call capability, speaker phones and operator assistance where required; (b) radio communications between selected Duke Energy vehicles and appropriate fixed locations, as well as with state mobile units and fixed locations; (c) facsimile and computer local and wide area networks. (A detailed listing of the Brunswick emergency communications systems is presented as Appendix A.)

The purpose of emergency response facilities is to provide centralized locations for organized coordination and control of on-site and off-site activities during an emergency. Each emergency response organization must assure that a location is provided from where they may direct the activities for which they are responsible, while providing for coordination of activities with other organizations.

Facilities are needed to function as a center for the licensee's command and control functions of on-site operations, including coordination of all licensee activities, on site and off site. Also needed is a center for the analysis of plant effluent monitors, meteorological conditions, and off-site radiation measurements, and for off-site dose projections. As discussed in Section 3 additional facilities are needed where information regarding current and projected plant status needed by federal, state, and local authorities for implementation of off-site emergency plans can be transmitted, where key representatives of the agencies can meet and where the press can operate.

The above functions are carried out by the interaction of the Control Room, the Operational Support Center, the Technical Support Center, the Emergency Operations Facility, the Joint Information Center, and the State and Local Emergency Operations Centers. These centers are connected with a comprehensive, redundant communications network.

0ERP Rev. 089 5-1

In the emergency facilities, decisions and responses are based upon approved procedures and controlled drawings. Uncontrolled drawings and other documents may be used for reference if identified with "FOR INFORMATION ONLY" or "FOR TRAINING USE ONLY." Material identified as "FOR INFORMATION ONLY" or "FOR TRAINING USE ONLY" will not be used in place of approved procedures or controlled drawings.

The functional capabilities of the Brunswick emergency facilities are presented in Table 5.0-2, and the physical locations of on-site emergency facilities are shown on Figure 1.1-3. Specific information about the facilities and equipment available for dealing with emergencies at Brunswick is presented in the following sections.

5.1 CONTROL ROOM The function of the Control Room is plant control. All plant-related operations are directed from the Control Room. The Control Room is designed to meet habitability standards, as described in the Brunswick UFSAR and Technical Specification Section 5.5.13, Control Room Habitability Program.

Nuclear plant instrumentation, including area and process radiation monitoring system instrumentation, is provided in the Control Room to give early warning of a potential emergency and provides for a continuing evaluation of the emergency situation. The Control Room contains the controls and instrumentation necessary for operation of the reactors and turbine generators under normal and emergency situations.

Additional equipment such as portable radiation survey instruments, readout of meteorological instrumentation and communication equipment is available in the Control Room. A supply of protective clothing, respiratory equipment, and self-contained breathing apparatus will also be maintained in the Control Room.

5.2 TECHNICAL SUPPORT CENTER The Technical Support Center (TSC) provides a location to house personnel who are responsible for management and technical support of plant operations during emergency conditions. The TSC also functions to relieve the Reactor Operators of peripheral duties and communications not directly related to reactor system manipulations and preventing congestion in the Control Room. In the event of a loss of power, an auxiliary diesel generator is located near the building to supply an alternate source of power.

0ERP Rev. 089 5-2

The TSC will be activated for an alert or higher classification. Activation for an unusual event is optional.

If it should become necessary to expedite travel between the TSC and Control Room, Security has provisions in place to provide direct access between the TSC and the protected area.

The TSC and EOF share a common building which has been designed to have the same habitability as the Control Room, except that the TSC and EOF building does not have chlorine detectors. The north wall is 18 inches thick and the other walls and roof are 14 inches thick. The ventilation system is described in Section 5.2.1.

In the event the TSC is evacuated the Control Room will serve as the alternate location. If travel to the site is unsafe or may endanger personnel, the TSC staff will report to the Alternate Emergency Facility.

5.2.1 TSC/EOF EMERGENCY VENTILATION SYSTEM The TSC/EOF Building Ventilation System is equipped with two (2) filter systems (containing both HEPA and charcoal filters), one for each of the two ventilation intake locations (Mechanical Rooms 134 and 165). The TSC/EOF Building Ventilation System is equipped with two intake air monitors which are Eberline SRM-100 monitors with SPA-8 probes. The probes are installed in the intake air ducts where detection of a high level of radiation can automatically trigger the HVAC system to actuate emergency fans to direct intake air through the filter trains.

The intake air radiation monitors are provided with an audible local alarm that is located on the radiation monitor. When the alarm setpoint is reached, the monitor will energize its associated radiation monitor relay, which will automatically activate an emergency fan to redirect the intake air through the associated filtering system.

5.2.2 TSC/EOF EMERGENCY CONTAMINATED DRAIN SYSTEM During an emergency, contaminated drainage could occur at the decontamination shower. An emergency drain system is provided to isolate potential contaminated drainage which can be collected in a 1,000 gallon holding tank. For normal operating conditions, all drainage would be collected by the sanitary drain lines. The holding tank is located underground on the west side of the building. Manually operated valves allow the rerouting of potentially contaminated liquid to the 1,000 gallon holding tank.

0ERP Rev. 089 5-3

5.3 OPERATIONAL SUPPORT CENTER The purpose of the Operational Support Center (OSC) is to minimize congestion in the Control Room during emergencies by providing a location, separate from the Control Room, where plant maintenance, operations, RP, Chemistry, and other plant emergency support personnel will assemble and stand by to assist as needed. The Operational Support Center is located in the O&M Building.

When the OSC is activated, dosimetry, respiratory protection, radiation survey equipment, and RWPs will be provided. In the event of a personnel contamination, decontamination will be performed in the area normally designated for this purpose. In the event the OSC is evacuated, a backup can also be provided in the Simulator. The Simulator is within the habitability envelope of the TSC/EOF.

5.4 EMERGENCY OPERATIONS FACILITY The Emergency Operations Facility (EOF), located on site provides space for management of overall emergency response including coordination with federal, state, and local officials, coordination of off-site radiological and environmental assessment, and determination of recommended public protective actions. The EOF is activated at an alert or higher level. The EOF is in the same habitability envelope as the TSC. If the Joint Information Center (JIC) is not activated, conditions permitting, the media may go the BNP Media Center to be updated.

If radiological conditions prevent EOF personnel from traveling to the EOF for activation, the Duke Energy Progress Building in Leland, N.C. will serve as a meeting place for personnel until radiological conditions permit travel to the facility. The Duke Energy Progress Building may also be used as an alternate reporting location for TSC, OSC, and EOF personnel in the event of a security threat, and function as an Alternate Emergency Facility, until safe movement of personnel to the plant is assured.

0ERP Rev. 089 5-4

5.5 JOINT INFORMATION CENTER The Joint Information Center (JIC), located in the Duke Energy Progress Building in Leland, N.C., will serve as the primary location for the accumulation of accurate and current information regarding emergency conditions, and dissemination of information to news media and the general public. Work stations are provided for Company personnel and a media briefing room is available. Telephones are available for use by news media personnel. The center also contains work space and phones for public information personnel from the state, counties, NRC and industry-related organizations. Additional information can be found in 0PEP-02.6.29, Activation and Operation of the Joint Information Center (JIC). If the JIC is not activated, conditions permitting, the media may go to the BNP Media Center to obtain current information regarding emergency conditions.

5.6 OFF-SITE EMERGENCY FACILITIES 5.6.1 North Carolina Emergency Operations Center The North Carolina Emergency Operations Center (EOC) is located in Raleigh, North Carolina. When necessary, it will be activated and staffed to assist in coordinating emergency operations in support of the Brunswick Nuclear Plant.

5.6.2 Brunswick County Emergency Operations Center The Brunswick County Emergency Operations Center is located in the Brunswick County Administration Complex in Bolivia, North Carolina, about fifteen miles from the Brunswick site. It provides a location where Brunswick County authorities can direct off-site activities in Brunswick County. This facility presently has direct communications links with the Brunswick Nuclear Plant TSC and EOF, and will allow free interchange of information between government officials and those persons located in the TSC and EOF responsible for dose projection and management decision making.

0ERP Rev. 089 5-5

5.6.3 New Hanover County Emergency Operations Center The New Hanover County Emergency Operations Center is located in the New Hanover County Law Enforcement Center in Wilmington, North Carolina, about 20 miles from the Brunswick site. It provides a location where New Hanover County authorities can direct off-site activities in New Hanover County. This facility presently has direct communications links with the Brunswick Nuclear Plant TSC and EOF, and will allow free interchange of information between government officials and those persons located in the TSC and EOF responsible for dose projection and management decision making.

5.7 ASSESSMENT CAPABILITIES 5.7.1 General The instrumentation and control systems monitor, provide indication and recording, and automatically regulate the variables necessary for safe and orderly operation of the plant. These systems provide the operators with the information and controls needed to start up, operate at power, and shut down the plant. They further provide means to cope with all abnormal operating conditions. Plant control and display of information from these various systems are centralized in the Control Room at locations convenient to the operator. This instrumentation, in conjunction with projected off-site doses, provides the basis for initiation of protective actions.

R 5.7.2 Meteorological Instrumentation and Procedures 16 The Brunswick Nuclear Plant has a permanent meteorological monitoring station located within the site area boundary for display and recording of wind speed, wind direction, and temperature differences for use in making off-site dose projections, etc. Meteorological information is presented in the Control Room by means of the plant computer system. The meteorological parameters measured on the tower at the 10-meter and 100-meter levels above ground are listed in Table 5.7-1. In addition, barometric pressure, solar radiation, precipitation and dew point temperature data are recorded at the station to provide supplemental information on local meteorological conditions. This information is remotely interrogatable using a computer or other data access terminal.

0ERP Rev. 089 5-6

The meteorological sensors used at the BNP meteorological monitoring station are calibrated at least twice during an annual calendar year (approximately six months between calibrations).

Meteorological sensors which are removed from service are replaced with a recalibrated unit having met original equipment manufacturer specifications. Between calibrations, an electronic verification of system performance will be made and, if necessary, adjustments to the system will be performed. This electronic verification shall be performed at least once between calibrations. BNP personnel will make periodic visits to the monitoring station to assure that components are functioning as anticipated. Further checks of the data are made by remote interrogation of the monitoring station by a meteorological service provider, where the data is reviewed by the meteorological staff to determine system performance and the acceptability of the reported information. Historical records and data will be maintained with the Environmental Unit for effluent reporting.

The meteorological instrumentation which Duke Energy uses at the BNP meteorological monitoring station meets the requirements of NRC Regulatory Guide 1.23 (Rev. 0) and provides the meteorological parameters to the locations specified within NRC Regulatory Guide 1.97 (Rev. 2), Table 1 and Table 2. As specified within Section 8.2 of the Supplement Number 1 to NUREG-0737, Duke Energy maintains telephone numbers for voice communications to the nearest National Weather Service first order observation station (Wilmington, NC) for twenty-four hour per day access to this backup meteorological information should the on-site system fail. This backup source of meteorological data is the closest location which can provide reliable representative meteorological information for the BNP site.

Should the on-site meteorological data collection system exhibit suspect information, loss of data due to computer or instrument failure, or plant personnel require additional technical assistance, meteorologists are available to provide needed expertise.

Meteorologists can independently access on-site meteorological data, contact the National Weather Service to obtain additional synoptic scale weather data and compile a site specific atmospheric diffusion assessment for BNP site.

0ERP Rev. 089 5-7

5.7.3 Seismic Monitoring The Brunswick Seismic Monitoring System senses and records earthquake ground motion received in the Unit 2 Reactor Building.

The Seismic Monitoring System consists of a Passive Subsystem and an Active Subsystem. The Passive Subsystem has no immediate visual indication of an event, whereas the Active Subsystem actually displays an immediate visual indication.

The Passive Subsystem consists of three self-contained Multi-Element Triaxial Peak Accelerographs and are located as follows:

1. Unit 2 Reactor Building Basement/Equipment Drain Tank (Elevation -17 ft).

2. Unit 2 Reactor Building RHR Heat Exchanger Support (Elevation 20 ft).

3. Unit 2 Reactor Building Refueling Area (Elevation 117 ft).

The peak shock recorders measure and record the acceleration of the structure. The peak shock recorder senses and permanently records the information defining a response spectrum.

The Unit 2 Active Seismic Monitoring System senses and records earthquake ground motion in two areas of the Unit 2 Reactor Building where remote accelerometers are installed:

1. Basement foundation in North Core Spray Room (Elevation -17ft).

2. Containment structure (Elevation +89ft).

The Active Seismic Monitoring System consists of two remote accelerometers and a Seismic Monitoring Panel. The Seismic Monitoring Panel consists of a central controller, LCD display monitor, alarm and interconnect panel, battery backup dual recorder unit, printer, and UPS battery backup power supply for the central controller. Earthquakes produce low frequency accelerations which, when detected by the remote accelerometers, will activate the Seismic Monitoring Panel from a standby condition located in the Electronics Equipment Room to record and visually display the earthquake ground motion.

0ERP Rev. 089 5-8

A considerable array of seismometers is located in the region. A central point of contact to obtain information about a seismic event is the National Earthquake Information Center in Golden, Colorado.

5.7.4 Radiological Monitors The radiation monitoring system is available to give early warning of a possible emergency and provides for a continuing evaluation of the emergency situation in the Control Room. Radiation monitoring instruments are located at selected areas within the facility to detect, measure, and record radiation levels. In the event the radiation level should increase above a preset level, an alarm is initiated in the Control Room. Certain radiation monitoring instruments also alarm locally in selected areas of the facility. The radiation monitoring system is divided into four subsystems:

1. Process radiation monitoring system monitors various fluid streams in operating systems.

2. Area radiation monitors that monitor radiation levels at various locations within the operating area that can be read in the Control Room.

3. Continuous air monitors measure airborne particulate and/or airborne iodine activities at various locations within the operating areas.

4. Radiation monitoring equipment with readouts in various plant locations.

The types, ranges, and locations of monitors are listed in Tables 5.7-2 to 5.7-4. Typical portable radiation monitors are listed in Table 5.7-4.

The radiation monitors are designed to permit monitoring of activity releases during a broad spectrum of postulated emergency situations.

The locations of the off-site and on-site environmental monitoring stations and the location of the emergency TLD monitoring stations are contained in plant Environmental and Radiation Control Procedures and 0PEP-04.6, Radiological Emergency Kit Inventories.

0ERP Rev. 089 5-9

5.7.5 Process Monitors Instrumentation used to monitor vital plant parameters is described in Section 7 of the Brunswick UFSAR. This instrumentation is continuously monitored in the Control Room. Essential process monitoring (Critical Plant Variables) will also be available in the Technical Support Center.

5.7.6 Laboratory Facilities Support of the radiation monitoring and analysis effort is provided by an on-site laboratory. The on-site laboratory includes equipment for chemical analyses and for analysis of radioactivity.

The wet chemistry equipment is used to perform a variety of analyses (pH, conductivity, boron content of reactor coolant, etc.). It is also used to perform radiochemical analyses (preparation of samples to permit analysis of the radioactivity content).

Equipment used to analyze the type and amount of radioactivity in filters, smears, etc., is located adjacent to the chemistry lab. This includes a multichannel analyzer (Ge-Li) used to determine the isotopic content in a sample, a liquid scintillation counter for tritium analyses, and gas proportional counter for gross alpha, and gross beta activity.

Much of this equipment is rack mounted; some is readily portable.

Additional facilities for counting and analyses of Brunswick samples can be provided by laboratory facilities at the Harris Nuclear Plant, including the Harris Energy and Environmental Center (HEEC) located near New Hill, North Carolina, and by the Robinson Nuclear Plant located in Hartsville, South Carolina.

As described in the State of North Carolina Radiological Emergency Response Plan, the Division of Radiation Protection maintains a mobile radiological laboratory.

0ERP Rev. 089 5-10

5.7.7 Dose Projection The magnitude of releases of radioactive material can be determined from effluent and process monitors based on AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment, and 0PEP-03.4.8, Offsite Dose Projections for Monitored Releases. Additionally, an independent confirmation of the magnitude of a release can be obtained by environmental monitoring as described in 0PEP-02.6.6, Environmental Monitoring Team Leader and 0PEP-03.5.5, Environmental Monitoring and Plume Tracking. Given a source term, or the duration and rate of release to the environment, and meteorological data previously described, the Control Room can make the initial dose projections and is capable of performing this function on a 24-hour-per-day basis. After activation of the EOF, the Radiological Control Manager described in Section 3.5.4 is responsible to the Emergency Response Manager for determining dose projections from readily available data. AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment, describes computer programs which automate dose projection calculations when used in conjunction with the BNP meteorological systems.

5.8 FIRE DETECTION The Fire Detection System is designed to quickly detect visible or invisible smoke (or other products of combustion) and/or heat in designated areas of the plant.

The Fire Detection System consists primarily of fire/smoke detectors, control panel units, and annunciator panels. A fire signal initiated by a detector flows through a control panel unit to an annunciator panel. The control panel unit is located in the same building as the detector. The annunciator panel is located in the Control Room.

The types and number of detectors have been selected in accordance with the combustible materials and electrical equipment present in the area and the physical surroundings of each area. Smoke detectors sense the presence of products of combustion before they are visible in the form of smoke. Thermal detectors are sensitive to both temperature and the rate of rise of increasing temperature. SD-41, Fire Suppression System, provides a description of detector types, numbers, and locations.

0ERP Rev. 089 5-11

5.9 PROTECTIVE FACILITIES AND EQUIPMENT 0PEP-04.6, Radiological Emergency Kit Inventories, lists emergency equipment that is available for the various Brunswick emergency facilities.

Complete personnel decontamination facilities are included in the Service Building. These facilities include two decontamination showers. Alternate means for decontamination are also available.

5.10 FIRST AID AND MEDICAL FACILITIES First Aid is located on the first floor of the O&M Building. First aid kits and supplies are also placed at various locations throughout the plant.

Off-site medical facilities which have agreed to accept personnel are described in Appendix E, Medical Treatment and Assistance.

5.11 DAMAGE CONTROL EQUIPMENT AND SUPPLIES In the event of an emergency, certain immediate repairs may be necessary to minimize the further release of radioactivity and also insure the protection of plant equipment. Damage control equipment and supplies that would be used to effect repair would depend on the nature of the repairs to be performed.

Damage control equipment and supplies are located in the stockroom and the maintenance shops.

5.12 OFF-SITE ENVIRONMENTAL MONITORING EQUIPMENT AND SUPPLIES In the event of an emergency, the plant has the capability to deploy two off-site environmental monitoring teams as described in 0PEP-02.6.6, Environmental Monitoring Team Leader. Two environmental monitoring kits with the necessary equipment and supplies for off-site radiological monitoring are designated for use in the event of an emergency.

Transportation for off-site environmental monitoring teams will be supplied by plant vehicles and other Company trucks as available or private autos at the site. 0PEP-04.6, Radiological Emergency Kit Inventories, lists emergency equipment that is available.

0ERP Rev. 089 5-12

TABLE 5.0-2 FUNCTIONAL OBJECTIVES OF EMERGENCY FACILITIES Page 1 of 1 Facility Name Location Functional Objectives Technical Support Brunswick TSC/EOF/Training 1) Assembly location for technical personnel to Center (TSC) Building provide engineering and management support of plant operations following an accident.

2) Direction and coordination of overall plant emergency activities.

Operational Brunswick Operations and 1) Reporting place for emergency support personnel.

Support Center (OSC) Maintenance Building 2) Dispatching location of personnel to support actions as directed by the Site Emergency Coordinator.

Joint Information Located in the Duke Energy Progress Building 1) Provide immediate access to accurate emergency Center Leland, NC related information generated by all involved agencies by media representatives.

2) Provide equipment for document reproduction, telecopying, communications, and television electrical connections.

Emergency Operations Brunswick TSC/EOF/Training Building 1) Provide working space and communication links Facility (EOF) for the Emergency Response Manager and staff.

2) Provide primary interface point for Duke Energy and off-site support personnel (Federal and State).

3) Provide point of coordination for off-site radiological and environmental assessment.

New Hanover County Wilmington, North Carolina 1) Direction and coordination of New Hanover County Emergency Operations emergency and protective response actions.

Center (EOC)

Brunswick County Bolivia, North Carolina 1) Direction and coordination of Brunswick Emergency Operations County emergency and protective response Center (EOC) actions.

North Carolina State Raleigh, North Carolina 1) Direction and coordination of Brunswick and Emergency Operations New Hanover County emergency and Center (EOC) protective response actions.

0ERP Rev. 089 5-13

TABLE 5.7-1 ON-SITE METEOROLOGICAL INSTRUMENTATION Page 1 of 1 Approximate Height Recorded Above Tower Base (ft) Parameter Instrument 344 Windspeed, direction Threshold less than and direction variance 1 mph.

35 Windspeed, direction, Threshold less than and direction variance 1 mph.

344 Temperature difference Resistance thermobulb relative to 35 ft in aspirated radiation elevation shield at 344 and 35 ft elevation.

35 Ambient temperature Resistance thermobulb in aspirated radiation shield at 35 ft elevation.

0ERP Rev. 089 5-14

TABLE 5.7-2 AREA RADIATION MONITORING SYSTEM CHANNEL IDENTIFICATION & METER RANGES Page 1 of 4 Range Detector Channel (mRem/hr) Designation Location (Bldg.)

1-1 0.01 - 100 Control Room Operating Area Control 1-2 0.01 - 100 Unit 2 Mechanical Equipment Room

• Control 1-3 0.01 - 100 Unit 1 Mechanical Equipment Room

• Control 1-4 0.01 - 100 Stack Filter House Stack 1-5 0.01 - 100 Service Building Radiochemical Lab. Service 1-6 0.01 - 100 Service Building Personnel Decon Service Equipment Room 1-7 0.10 - 1000 Hot Machine Shop Hot Machine Shop 1-8 0.01 - 100 Service Building Equipment Room Service East/West Corridor 1-9 0.01 - 100 Unit 1 Turbine Hall Control Access Turbine Corridor 1-10 0.01 - 100 Unit 1 Feedwater Heater Bay Turbine Access Corridor 1-11 0.01 - 100 Unit 1 Turbine Building Sampling Station Turbine 1-14 0.1 - 1000 Unit 1 Turbine Rotor Washdown Area Turbine 1-15 0.1 - 1000 1A Core Spray Pump Room ESS I Reactor 1-16 0.1 - 1000 1B Core Spray Pump Room ESS II Reactor

• Detectors are located in mechanical equipment room (Control Building ventilation air intake plenum) 0ERP Rev. 089 5-15

TABLE 5.7-2 AREA RADIATION MONITORING SYSTEM CHANNEL IDENTIFICATION & METER RANGES Page 2 of 4 Range Detector Channel (mRem/hr) Designation Location (Bldg.)

1-17 0.1 - 1000 1A RHR System Heat Exchanger and Reactor Pump Room ESS I 1-18 0.1 - 1000 1B RHR System Heat Exchanger and Reactor Pump Room ESS II 1-19 0.01 - 100 Unit 1 Reactor Building Across from Reactor TIP Room Elevation 296 1-20 0.01 - 100 Unit 1 Drywell Entrance Elevation 26 Reactor 4

1-21 1.0 - 10 Unit 1 TIP Room Reactor 1-22 0.01 - 100 Unit 1 Decontamination Room. Reactor Elevation 200 1-23 0.01 - 100 Unit 1 Equipment Entry Elevation 200 Reactor 1-24 0.01 - 100 Unit 1 Reactor Building Sampling Station Reactor 1-25 0.01 - 100 Unit 1 Reactor Building Air Lock Reactor Elevation 500 1-26 0.01 - 100 Unit 1 Inside New Fuel Vault Reactor Elevation 988 1-27 0.01 - 100 Unit 1 North of Fuel Storage Pool Reactor 1-28 102 - 106 Unit 1 Between Reactor and Fuel Pool Reactor Elevation 1174 1-29 0.01 - 100 Unit 1 Cask Wash Area Refuel Floor Reactor 1-30 0.01 - 100 Unit 1 Spent Fuel Pool Cool System Reactor 0ERP Rev. 089 5-16

TABLE 5.7-2 AREA RADIATION MONITORING SYSTEM CHANNEL IDENTIFICATION & METER RANGES Page 3 of 4 Range Detector Channel (mRem/hr) Designation Location (Bldg.)

2-1 0.1 - 1000 Radwaste Building Elevation -30 Radwaste North MCC and Sump Area 2-2 0.1 - 1000 Radwaste Building Elevation -30 Radwaste South MCC and Sump Area 2-3 0.1 - 1000 Unit 2 Cond. Filter - Demin Aisle Radwaste 2-4 0.1 - 1000 Unit 1 Cond. Filter - Demin Aisle Radwaste 2-5 0.01 - 100 Radwaste Control Room Radwaste 2-6 0.01 - 100 Radwaste Sampling Station Radwaste 2-7 0.01 - 100 Radwaste Drum Capping Station Radwaste 2-8 1.0 - 104 Radwaste Drum Storage Radwaste 2-9 0.01 - 100 Unit 2 Turbine Hall Controlled Turbine Access Corridor 2-10 0.01 - 100 Unit 2 Feedwater Heater Bay Turbine Access Corridor 2-11 0.01 - 100 Unit 2 Turbine Building Sampling Station Turbine 2-14 0.1 - 1000 Unit 2 Turbine Rotor Washdown Area Turbine 2-15 0.1 - 1000 2A Core Spray Pump Room ESS I Reactor 2-16 0.1 - 1000 2B Core Spray Pump Room ESS II Reactor 0ERP Rev. 089 5-17

TABLE 5.7-2 AREA RADIATION MONITORING SYSTEM CHANNEL IDENTIFICATION & METER RANGES Page 4 of 4 Range Detector Channel (mRem/hr) Designation Location (Bldg.)

2-17 0.1 - 1000 2A RHR System Heat Exchanger and Reactor Pump Room ESS I 2-18 0.1 - 1000 2B RHR System Heat Exchanger and Reactor Pump Room ESS II 2-19 0.01 - 100 Unit 2 Reactor Building Across from Reactor TIP Room Elevation 29 2-20 0.01 - 100 Unit 2 Drywell Entrance Elevation 26 Reactor 4

2-21 1.0 - 10 Unit 2 TIP Room Reactor 2-22 0.01 - 100 Unit 2 Decontamination Room Reactor Elevation 200 2-23 0.01 - 100 Unit 2 Equipment Entry Elevation 200 Reactor 2-24 0.01 - 100 Unit 2 Reactor Building Sampling Station Reactor 2-25 0.01 - 100 Unit 2 Reactor Building Airlock Reactor Elevation 500 2-26 0.01 - 100 Unit 2 Inside New Fuel Vault Reactor Elevation 988 2-27 0.01 - 100 Unit 2 North of Fuel Storage Pool Reactor 2-28 102 - 106 Unit 2 Between Reactor and Fuel Pool Reactor Elevation 1174 2-29 0.01 - 100 Unit 2 Cask Wash Area Refuel Floor Reactor 2-30 0.01 - 100 Unit 2 Spent Fuel Pool Cool System Reactor 0ERP Rev. 089 5-18

TABLE 5.7-3 PROCESS RADIATION MONITORING SYSTEM CHANNEL IDENTIFICATION & METER RANGES Page 1 of 2 CHANNEL SUPPLIER RANGE Main Steam Line Radiation Monitors Channel A (D12-RM-K603A) GE 1-106 mRem/hr Channel B (D12-RM-K603B) GE 1-106 mRem/hr Channel C (D12-RM-K603C) GE 1-106 mRem/hr Channel D (D12-RM-K603D) GE 1-106 mRem/hr Condenser Off-Gas Radiation Monitors Log Channel A (D12-RM-K601A) GE 1-106 mRem/hr 6

Log Channel B (D12-RM-K601B) GE 1-10 mRem/hr Linear Channel (D12-RM-K602) GE 1-106 mRem/hr Main Stack Radiation Monitors

-7 5 1/2-D12-RM-23S General Atomics 10 -10 µCi/cc (Xe equivalent)

Liquid Process Radiation Monitors Radwaste Effluent (D12-RM-K604) GE 10-1-106 cps Service Water Discharge (D12-RM-K605) GE 10-1-106 cps Reactor Bldg Closed Cooling Water GE 10-1-106 cps (D12-RM-K606) 1 7 Storm Drain Collector Basin General Atomics 10 -10 cpm (2-DST-RM-5361)

Reactor Bldg Ventilation Radiation Monitors Channel A (D12-RM-K609A) GE 0.01-100 mRem/hr Channel B (D12-RM-K609B) GE 0.01-100 mRem/hr 0ERP Rev. 089 5-19

TABLE 5.7-3 PROCESS RADIATION MONITORING SYSTEM CHANNEL IDENTIFICATION & METER RANGES Page 2 of 2 CHANNEL SUPPLIER RANGE Gaseous Analyzer Radiation Monitors Reactor Building Roof Vent NMC 10-106 cpm (1/2-CAC-AQH-1264-3)

Turbine Building Vent General Atomics 10-7-105 µCi/cc (1/2-D12-RM-23) (Xe equivalent) 6 Drywell Primary Containment Atmosphere NMC 10-10 cpm (CAC-AQH-1260, 1262)

AOG Charcoal Absorber System Effluent General 101-107 cpm (AOG RM-103) Atomics 0ERP Rev. 089 5-20

TABLE 5.7-4 TYPICAL PORTABLE SURVEY EQUIPMENT Page 1 of 1 Type Of Radiation Type Range Measured Teletector / MGP Telepole 0.1 mRem/hr - 1,000 Rem/hr Ludlum Model 177 0 - 500,000 cpm ,

AMP-100 1 mr/hr - 999R/hr AMP-200 100 mr/hr - 9,999 R/hr ASP-1 With Neutron Ball 0 - 100 Rem/hr n Ludlum Model 12 With Neutron Ball 0 - 10 Rem/hr n Ludlum Ion Chamber Model 9-3 0.2 - 50,000 mR/hr ,

Ludlum Model 12 0 - 500,000 cpm ,

Ludlum Model 19 0 - 5 mR/hr Ludlum Model 2241 with 44-183 probe 0 - 8 R/hr Ludlum Model 3 0-500,000 cpm ,

0ERP Rev. 089 5-21

DUKE ENERGY BRUNSWICK NUCLEAR PLANT (BNP)

RADIOLOGICAL EMERGENCY PLAN (ERP) 6.0 MAINTAINING EMERGENCY PREPAREDNESS Emergency preparedness at Brunswick will be maintained by (a) preparing the emergency organization members and the public for proper emergency response actions through training, drills and exercises, and public education programs (Section 6.1); (b) periodic review and update of the Brunswick Radiological Emergency Plan and its implementation procedures (Section 6.2); (c) periodic inventory and calibration of emergency equipment and instrumentation (Section 6.3); and (d) cognizance of the Plant Nuclear Safety Committee over safety-related issues (Section 6.4).

The Manager - Nuclear Emergency Planning is the Emergency Planning Coordinator and is responsible for maintaining Emergency Preparedness at the Brunswick Nuclear Plant, as outlined in Section 6.1.3.

Each periodic requirement in this section and elsewhere in the plan and plant emergency procedures shall be performed within the specified time below:

a. Annually - At least once per 366 days

b. Monthly - At least once per 31 days

c. Quarterly - At least once per 92 days

d. Semiannually - At least once per 184 days

e. Calendar Year - Period of time beginning January 1 and ending December 31.

For the above intervals, a maximum allowable extension is permitted subject to the following restrictions:

o The maximum allowable extension shall not exceed 25% of the specified interval.

o The combined time interval for any three consecutive intervals shall not exceed 3.25 times the specified interval.

This definition for periodic requirements applies to all intervals in the emergency plan and plant emergency procedures except for the evaluated exercise which is conducted once every two calendar years, and off-site training which is conducted once per calendar year.

0ERP Rev. 089 6-1

6.1 ORGANIZATIONAL PREPAREDNESS Organizational preparedness is maintained through an integrated training program that includes general orientation of all persons at the site and detailed training of individuals and groups required to perform specific functions and actions during an emergency condition. The training program provides initial training and annual retraining of the emergency response organization. Significant changes in the content of this Plan and procedures which implement this Plan are distributed by memorandum to the appropriate plant groups.

6.1.1 Training The primary objectives of the training program are to:

1. Familiarize appropriate individuals with the Plan and the procedures that implement the Plan.

2. Instruct assigned individuals and their alternates in their duties and responsibilities.

3. When appropriate, train on significant changes in the scope or contents of the Plan or procedures which implement the Plan.

4. Provide annual refresher training and retesting to ensure that Emergency Plan personnel are familiar with their duties and responsibilities assigned by the Plan and procedures which implement the Plan.

Each individual, other than escorted personnel, is provided with initial orientation training on the notification and instruction methods used at the Brunswick plant in the event of an emergency. Appropriate actions for escorted individuals shall be the responsibility of the escort.

Each badged individual, other than escorted personnel, also receives initial orientation on the basic principles of radiological safety including the effects of radiation and the theory and use of radiation detection devices.

The Emergency Plan Training Program described in 0PEP-04.3 assures training of those individuals who may be called to respond to an emergency at the Brunswick plant by providing initial training and annual refresher training and retesting on the scope and content of the Plan and procedures which implement the Plan.

0ERP Rev. 089 6-2

The Emergency Plan Training Program provides training for the following groups of personnel to perform the specific tasks assigned to them in the emergency organization.

Site Emergency Coordinator TSC Staff Personnel Security Personnel Fire Brigade First Aid Personnel Dose Projection Personnel Radiological Emergency Teams Emergency Communicators EOF Personnel OSC Personnel JIC Personnel Plant Operators Off-site groups who may be requested to assist in an emergency.

Training of off-site organizations is described in their radiological emergency plans. Training by Duke Energy for hospital, ambulance, rescue, police, and fire personnel will include the procedures for notification, basic radiation protection, and their expected roles. For those local services support organizations who may enter the site, training by Duke Energy will also include site access procedures and the identity (by position and title) of the individual in the Brunswick organization who will control the organization's support activities.

Duke Energy will assist these off-site organizations in performing their radiological emergency response training as related to the Brunswick plant.

Duke Energy and the public information officials from the state and local governments will jointly make available an annual program to acquaint the news media with the company, state and county emergency plans and procedures. The program also includes information concerning radiation, nuclear plant operations and official points of contact for release of public information.

Severe Accident Management training and drills will be conducted in accordance with Severe Accident Management Program and Training Procedures.

0ERP Rev. 089 6-3

6.1.2 Drills and Exercises This section describes provisions for conducting periodic drills and exercises to test the adequacy of the Plan and implementing procedures, emergency equipment, and the preparation and training of emergency personnel.

Each exercise scenario will include the following:

1. The basic objective(s) of the exercise.

2. The date(s), time period, place(s), and participating organizations.

3. The simulated events.

4. A time schedule of simulated initiating events.

5. A narrative summary describing the conduct of the exercises to include such things as simulated casualties, off-site fire or police department assistance, rescue of personnel, use of protective clothing, deployment of radiological monitoring teams, and public information activities.

6. Arrangements for qualified observers.

0ERP Rev. 089 6-4

6.1.2.1 Drills Emergency drills are supervised instruction periods aimed at testing, developing and maintaining skills, and to ensure that adequate emergency response capabilities are maintained during the interval between evaluated exercises. Periodic drills will be conducted, in addition to the evaluated exercise as follows:

1. General: At least one drill shall be conducted during the interval between evaluated exercises involving a combination of some of the principal functional areas of the organizations onsite emergency response capabilities. The principal functional areas of emergency response include activities such as management and coordination of emergency response, accident assessment, protective action decision making, and plant system repair and corrective actions. During these drills, activation of all of the emergency response facilities (Technical Support Center (TSC), Operations Support Center (OSC), and the Emergency Operations Facility (EOF)) is not necessary. Participants have the opportunity to consider accident management strategies, supervised instruction is permitted, and participants have the opportunity to resolve problems (success paths) rather than have controllers intervene. The drills focus on onsite training objectives.

2. Communications Drills: A system to test the readiness of the communications network between the plant and state and county governments within the ten-mile EPZ and the NRC will be conducted monthly. Communications between the plant, federal emergency response organizations, and states within the 50-mile EPZ will be tested quarterly. Communications between the plant and state and local emergency operation centers and field assessment teams shall be conducted annually.

3. Fire Drills: Fire drills will be conducted in accordance with the Fire Protection Program.

4. Medical Emergency Drills: Medical emergency drills involving a simulated contaminated individual will be conducted annually. The actual off-site portions of these drills may be conducted once per calendar year.

0ERP Rev. 089 6-5

5. Radiological Monitoring Drills: Radiological monitoring drills will be conducted annually. These drills will include collection of the appropriate sample media both on site and off site as the drill scenario requires.

6. In-Plant Radiation Protection Drills: Radiation protection drills, including response to and analysis of simulated elevated airborne and liquid samples and direct radiation measurements will be conducted semiannually. This may be held in conjunction with the Radiological Monitoring Drills.

7. Augmentation Drills: Augmentation Drills requiring travel to the site shall be conducted twice every calendar year.

8. SAMG drills: Severe Accident Management Guideline table-top and/or inter-facility mini-drills will be conducted periodically and will involve a combination of some of the principal functional areas of the organizations onsite emergency response capabilities similar to that described in General drills (6.1.2.1.1) above.

9. Each organization should make provisions to start a drill between 6:00 p.m. and 4:00 a.m.

The above drills will be evaluated by a drill evaluator (communication drills will not require an evaluator). The degree of participation by outside agencies in conducting these drills may vary and their action may actually be simulated. Any state or local government located within the plume exposure pathway EPZ will be allowed to participate in the drills when requested by such State or local government.

0ERP Rev. 089 6-6

6.1.2.2 Exercises An exercise is an event that tests the integrated capability of major response organizations. An emergency exercise will be conducted once every two calendar years and will be based on a scenario which is ultimately declared at least as a Site Area Emergency. The scenario will be varied from exercise to exercise such that major elements of the plant, county, and state plans and emergency organizations are tested within an 8-year period. The plant will demonstrate an emergency response to a Hostile Action at least once within an 8 year period. Once every 8 years, the exercise will be expanded to allow involvement of the federal response organizations in addition to the state and local organizations. Advance knowledge of the scenarios and the times of the exercises will be kept to a minimum to ensure a realistic participation by those involved.

Each exercise scenario will include a list of performance objectives and a description of the expected responses.

Specific tasks to be evaluated are:

1. Condition recognition and reporting

2. Assessment

3. Off-site notification, including Duke Energy off-site personnel and protective action recommendations

4. Off-site response

5. Site response coordination, including logistics, center manning, information gathering and analysis, and coordination with off-site agencies

6. Corrective actions

7. Protective actions

8. Record keeping

9. Monitoring

10. Plant operation 0ERP Rev. 089 6-7

Qualified evaluators from Duke Energy, federal, state, or local governments will observe and critique each exercise. A critique will be scheduled at the conclusion of each exercise to evaluate the ability of all participating organizations to respond. The critique will be held as soon as possible after the exercise. A formal written evaluation of the exercise will be prepared by the Emergency Planning Coordinator, or designee, following the critique.

Exercise controllers, evaluators, and participants (if appropriate) will prepare written descriptions of the actions they observed and will comment as to how the part of the exercise they observed matched the performance criteria.

The Emergency Planning Coordinator or designee will determine the corrective actions necessary and the schedules for performing them and will evaluate the corrective actions taken.

Remedial exercises will be required if the emergency plan is not satisfactorily tested during the biennial exercise, such that NRC, in consultation with FEMA, cannot find reasonable assurance that adequate protective measures can be taken in the event of a radiological emergency. The extent of State and local participation in remedial exercises must be sufficient to show that appropriate corrective measures have been taken regarding the elements of the plan not properly tested in the previous exercises.

6.1.3 Emergency Planning Coordinator The Manager - Nuclear Emergency Planning is the Brunswick Emergency Planning Coordinator who is responsible for coordinating on-site and off-site radiological emergency response planning.

Specific responsibilities include the following:

1. Interfacing with federal, state, county, and local planners.

2. Revising and updating the Plan in response to new federal regulations, modifications identified during exercises and drills, and changes in hardware and personnel.

3. Coordinating the evaluated exercise and the periodic drills.

4. Identifying off-site training needs of state and local emergency support personnel and arranging for training to meet the identified needs.

0ERP Rev. 089 6-8

5. Identifying corrective actions needed following an exercise, assigning responsibility for implementing these actions, specifying a schedule for completion of these actions, and evaluating the adequacy of the actions taken. These corrective actions can be tracked by means of the Corrective Action Program.

6. Maintaining and negotiating agreements with state and county response agencies, federal assistance agencies, and medical and fire support agencies.

6.1.4 Public Education The North Carolina Department of Crime Control and Public Safety have overall responsibility for maintaining a continuing disaster preparedness public education program. Such a program, prepared by the State of North Carolina, with the cooperation of local governments and Duke Energy, is intended to ensure that members of the public are:

1. Aware of the potential threat of a radiological emergency;

2. Able to recognize radiological emergency notification; and

3. Knowledgeable of the proper, immediate actions (e.g., return to home, close windows, and tune to an Emergency Alert System station) to be taken.

A program of this type includes education on protective actions to be taken if shelter is prescribed, and the general procedures to follow if an evacuation is required. It also includes general educational information on radiation and how to learn more about emergency preparedness.

Additional information concerning public education can be found in Section 4.4.7.

6.2 REVIEW AND UPDATE OF THE PLAN AND IMPLEMENTATION PROCEDURES The Plan and its implementation procedures are intended to provide for continuous emergency preparedness. In addition to the training, drills, and exercises, regular reviews and audits are performed. The reviews and audits are described in the following sections.

0ERP Rev. 089 6-9

6.2.1 Plan Updates The Emergency Planning Coordinator is responsible for coordinating the updating of the Plan and implementing procedures. They schedule an annual review of the Plan by the Plant Nuclear Safety Committee (see Section 6.4). Any proposed changes to the Plan due to regulatory revisions, experiences of drills and exercises, or other requirements are approved by the Manager - Nuclear Emergency Planning. Approved changes to the Plan will be distributed to organizations and individuals with responsibility for implementation of the Plan. Phone listings in emergency procedures shall be updated quarterly, if required.

6.2.2 Independent Review In addition to the reviews conducted at the plant, the Nuclear Oversight Section will conduct an independent review of the Plan either:

At intervals not to exceed 12 months or, As necessary, based on an assessment by the licensee against performance indicators, and as soon as reasonably practicable after a change occurs in personnel, procedures, equipment, or facilities that potentially could adversely affect emergency preparedness, but no longer than 12 months after the change. In any case, all elements of the emergency preparedness program must be reviewed at least once every 24 months.

The review will include an evaluation for adequacy of interfaces with State and local governments and of drills, exercises, capabilities, and procedures. The results of the review, along with recommendations for improvements, will be documented, reported to the Corporate office and plant management, and retained for a period of 5 years. The part of the review involving the evaluation for adequacy of interface with the State and local governments will be made available to the appropriate State and local governments. Documentation of review results will be through the Corrective Action Program and/or meeting minutes and documented in the records management system in accordance with AD-NO-ALL-1001, Conduct of Audit. Corrective actions deemed necessary from the review will be implemented similar to the description in Section 6.1.3.5 of this Plan and the site Corrective Action Program.

0ERP Rev. 089 6-10

6.2.3 Off-Site Agreements and Plans Emergency response plans and agreements with supporting organizations will be reviewed and certified to be current on an annual basis and updated, if necessary. Changes will be incorporated in the annual revision of the Plan.

6.3 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT AND SUPPLIES To ensure that equipment and supplies are maintained in a readiness state, periodic maintenance and inventories are performed as described in the following sections.

6.3.1 Emergency Equipment and Supplies A listing of emergency equipment and supplies to be inventoried is included in 0PEP-04.6. This listing provides information on location and availability of emergency equipment and supplies.

An inventory of emergency equipment and supplies is held in accordance with 0PEP-04.6. During this inventory, radiation monitoring equipment is checked to verify that required calibration and location are in accordance with the inventory lists. Respiratory protection equipment, maintained for emergency purposes, is also inspected and inventoried.

6.3.2 Medical Equipment and Supplies At least twice each year and after use in an emergency, the contents of emergency medical equipment and supplies located in the First Aid Office and other selected areas are to be inventoried, inspected, replaced, and replenished per 0PT-34.2.2, First Aid Supplies and Rescue Equipment Inspection/Inventory.

0ERP Rev. 089 6-11

6.4 PLANT NUCLEAR SAFETY COMMITTEE The Plant Nuclear Safety Committee (PNSC) is a standing committee comprised of Brunswick plant personnel that provides timely and continuing review of plant operations to assist the Plant General Manager in maintaining cognizance of plant activities, with particular emphasis on safety-related matters.

The PNSC reviews all changes to the plant, or its documentation that involve a License Amendment. In addition, the PNSC reviews plant operations to detect any potential safety hazards. Each plant supervisor will monitor the activities within their areas of responsibility to detect unsafe practices, trends, or hazards. Also, the PNSC investigates and reports on Technical Specification violations or other situations involving safety.

0ERP Rev. 089 6-12

DUKE ENERGY BRUNSWICK NUCLEAR PLANT (BNP)

RADIOLOGICAL EMERGENCY PLAN (ERP) 7.0 RECOVERY 7.1 GENERAL Once the Site Emergency Coordinator has declared that the emergency condition has passed, steps will be taken to recover from the incident. The Emergency Response Manager will advise appropriate organizations that recovery activities are initiated and that the Recovery Organization as shown in Figure 7.2.1 will be assembled in the EOF. All recovery actions will be preplanned in order to minimize radiation exposure or other hazards to recovery personnel. Recovery activities are classified as described in Section 7.3.

The overall goals of the recovery effort are to assess the radiological consequences of the emergency and perform cleanup and repair operations necessary to restore normal access to the affected areas or identify and restrict access to those areas that must be controlled. This effort includes marshaling of the Corporate resources and interfacing with outside agencies.

7.2 RECOVERY ORGANIZATION The recovery organization consists of the Recovery Manager, managers of support functions who are responsible to the Recovery Manager, and supporting personnel. This organization may be modified during the recovery process to better respond to the conditions at the plant.

Recovery activities will be directed from the Recovery Center.

The Recovery Center at Brunswick will normally be established in the existing TSC/EOF/Training Building. Other site facilities may be made available as necessary, if required to support an extensive recovery effort.

0ERP Rev. 089 7-1

Activation of the recovery organization will be initiated by the Vice President - Brunswick Nuclear Plant (or their alternate) after consultation with the Plant General Manager (or his alternate). The recovery organization will then be established at Brunswick to provide for recovery of the facility. The recovery organization may begin to develop plans for recovery of the facility while the emergency is still in progress. However, these efforts will not be permitted to interfere with or detract from the efforts to control the emergency situation. During the emergency phases of the incident, the recovery organization resources will be available to assist and provide support for the Site Emergency Coordinator. A block diagram of the typical recovery organization is presented in Figure 7.2-1.

7.2.1 Recovery Manager The Recovery Manager is the senior position responsible for all on-site activities during the recovery phase following a radiological emergency. They are also responsible for providing the primary interface with State, local and Federal agencies including the coordination of Duke Energy resources during off-site recovery efforts.

The specific responsibilities of this position are contained in 0PEP-02.7, Recovery.

7.2.2 Plant General Manager The Plant General Manager is responsible to the Recovery Manager for implementation of in-plant activities during the Recovery phase with the objective of maintaining a safe shutdown condition and controlling sources of radioactivity in the plant. The specific responsibilities of this position are contained in 0PEP-02.7, Recovery.

7.2.3 Technical Analysis Manager The Technical Analysis Manager is responsible to the Recovery Manager for technical support, specifically in the analysis and development of plans and procedures to support recovery activities and to maintain the affected unit in a safe shutdown condition in a manner which minimizes the effect on the health and safety of the public. The specific responsibilities of this position are contained in 0PEP-02.7, Recovery.

0ERP Rev. 089 7-2

7.2.4 Engineering Director The Engineering Director is responsible to the Recovery Manager for directing and administratively controlling the Duke Energy Recovery Organization Engineering Staff while providing engineering, including civil, and design support to meet requirements of the recovery activities. The specific responsibilities of this position are contained in 0PEP-02.7, Recovery.

7.2.5 Administrative and Logistics Manager The Administrative and Logistics Manager, is responsible to the Recovery Manager for providing administrative, logistic, communications, and personnel support for recovery activities. The specific responsibilities of this position are contained in 0PEP-02.7, Recovery.

7.2.6 Radiological Control Manager The Radiological Control Manager is responsible to the Recovery Manager for providing radiation protection and waste disposal plans to support recovery activities. The specific responsibilities of this position are contained in 0PEP-02.7, Recovery.

7.3 RECOVERY PLANNING For convenience in planning, the recovery activities can be classified as follows:

1. On-site recovery

2. Off-site recovery 7.4 ON-SITE RECOVERY ACTIVITIES On-site recovery activities are performed in accordance with existing plant procedures. Radiation and contamination levels for determining the need for decontamination and for returning areas or items to normal use are included in these procedures. Additional procedures will be developed as appropriate on a case-by-case basis.

0ERP Rev. 089 7-3

7.5 OFF-SITE RECOVERY ACTIVITIES 7.5.1 General The Duke Energy Recovery Manager will coordinate with and assist off-site agencies in the recovery activities.

The State will be the lead organization for off-site recovery activities and put emergency regulations into effect to ensure that no food items in the contaminated area are consumed or put on the market without the required health physics monitoring, and to control access into contaminated areas. Authorization for reentry to off-site areas will be made by the senior elected official of the area concerned after consultation with the North Carolina Division of Radiation Protection.

7.5.2 Emergency Cleanup Operations The most urgent tasks will be to clear (i.e., partially decontaminate) emergency paths to allow access to critical facilities and inhabited areas. These clearing operations will be necessary particularly to:

1. Allow health physics teams to survey the contaminated areas,

2. Allow farmers to provide emergency care for livestock that had to be left in contaminated areas or to assist them in moving the stock to uncontaminated areas.

3. Allow emergency operations of utilities and services (power, water, telephone, sewage treatment, etc.) during the cleanup operation, and

4. Allow decontamination teams to perform the emergency and priority decontamination tasks (these emergency tasks will consist primarily of fire-hosing pavements, plowing or scraping unpaved areas adjacent to roads, and spraying paint or asphalt to fix loose contamination in place).

5. Stabilize the contaminated areas so that the radioactive materials are not spread to other areas or leached into streams. In particular, if public roads run through the area, cleanup of the road will be required, and cleanup of the area to some distance from the road will be needed to minimize exposure to travelers.

0ERP Rev. 089 7-4

After the main roads and utilities have been put back into service, the urgency of the cleanup tasks will drop. However, the population that was evacuated will be eager to return, and industrial operations that had to be shut down need to start up as soon as possible and business operations need to be resumed.

Some farmland may have to be removed from use, which would cause hardship primarily to the occupants. Thus, it may be feasible to permanently evacuate such areas and pay the owner the market value. Such a step would probably occur at contamination levels where future crops would not be marketable due to the uptake of long-lived isotopes (primarily strontium).

Some of the buildings and houses may be contaminated to such a high level that it is more economical to demolish them than to decontaminate them. Areas where this occurs can be kept vacated; in such cases, demolition and burial can be a routine task, and the work can be scheduled over a longer period of time. Decontamination of the agricultural land may or may not be feasible. Where it is feasible, the changes in agricultural operations that are required can be made on a routine basis.

7.5.3 Countermeasures Countermeasures will have serious impact on the economy of contaminated areas, so they must be applied judiciously. They must be no more restrictive than necessary; however, once determined, they will be applied quickly and equitably, and may consist of:

1. Reducing contamination on the surface of any fruits and vegetables that were in the field at the time of the accident by ensuring that the surfaces are washed, that the outer leaves of leafy vegetables are removed, and that more than normal preference is given to peeling.

2. Altering production, processing, or distribution practices that affect the movement of radioactive contamination through food chain and into the human body. This will include storage of some food (primarily milk products) and animal feed supplies to allow radioactive decay--particularly of Iodine 131.

3. Diverting affected products to uses other than human consumption.

J. A. Auxier and R. O. Chester, eds., Report of the Clinch Valley Study, ORNL-4835 (January 1973).

0ERP Rev. 089 7-5

4. Condemning food

5. Decontaminating farmland where practical.

6. Converting farmland to other uses for extended periods of time when decontamination is not practical.

7. Decontaminating industrial buildings, stores and shops, and residences and removing milk-producing cattle from the contaminated pastures should be priority items. The longer these activities are delayed, the greater will be the costs and consequently the claims.

7.5.4 Monitoring and Dose Assessment The North Carolina Division of Radiation Protection (DRP),

Department of Environment Health and Natural Resources, will be the lead agency in the collection and analysis of radiation monitoring reports and of environmental air, foliage, food, and water samples.

The DRP will be assisted by qualified personnel from the BNP, and the General Electric Company Wilmington Manufacturing Division.

Total population exposure will be periodically determined through a variety of procedures including:

1. Examination of prepositioned TLDs.

2. Bioassay.

3. Estimates based on release rates and meteorology.

4. Estimates based on environmental monitoring of food, water, and ambient dose rates.

0ERP Rev. 089 7-6

FIGURE 7.2.1 Duke Energy Recovery Organization Page 1 of 1 0ERP Rev. 089 7-7

DUKE ENERGY BRUNSWICK NUCLEAR PLANT (BNP)

RADIOLOGICAL EMERGENCY PLAN (ERP)

8.0 REFERENCES

1. Brunswick Steam Electric Plant Operating Manual, Carolina Power & Light Company (date varies by volume and by entry)

2. PD-RP-ALL-0001, Radiation Worker Responsibilities

3. Updated Final Safety Analysis Report (UFSAR), Duke Energy, Brunswick Steam Electric Plant Units 1 and 2

4. Environmental and Fallout Gamma Radiation Protection Factors Provided By Vehicles, Health Physics, 26, Pg. 41-44, 1974

5. EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, U. S. Environmental Protection Agency, May 1992

6. Brunswick Nuclear Power Plant Development of Evacuation Time Estimates prepared by KLD Associated, November 2012 (RMS Number 1284620)

7. North Carolina Emergency Response Plan in support of the Brunswick Steam Electric Plant

8. NUREG-0654/FEMA-REP-l, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants

9. U.S. Census Bureau data files for the year 2000

10. NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements

11. NUREG/CR-1433, Examination of the Use of Potassium Iodide (KI) as an Emergency Protective Measure for Nuclear Reactor Accidents, March 1990 0ERP Rev. 089 8-1

12. Title 10, Code of Federal Regulations

a. Part 20, Standards for Protection Against Radiation

b. Part 50, Licensing of Production and Utilization Facilities

c. Part 50, Appendix E, Emergency Plans for Production and Utilization Facilities

d. Part 100, Reactor Site Criteria

e. Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High Level Radioactive Waste, and Reactor Related Greater than Cass C Waste

13. NEI 91-04, Rev. 1, Severe Accident Issue Closure Guidelines

14. Memo, Warren Dorman to PNSC, dated August 11, 1999 Subject Operations Shift Staffing

15. Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendments No. 226 and 253, Elimination of Requirements for Post Accident Sampling System (Docket Nos. 50-325 and 50-324), February 11, 2003 R 16 16. SOER 02-1, Severe Weather Rec. 3 (12/03/02)

17. NRC Bulletin 2005-02, Emergency Preparedness and Response Actions for Security Based Events, July 18, 2005

18. Industry White Paper, Enhancements to EP Programs for Hostile Action, dated 11/15/05

19. NEI 04-04 Revision 1, Cyber Security Program for Power Reactors

20. NUREG/CR-6847, Cyber Security Self-Assessment Method for U.S. Nuclear Power Plants

21. BNP Cyber Security Assessment - 177254

22. Engineering Change EC65949, Installation of the Sodium Hypochlorite Injection System

23. NEI 99-01 Revision 5, Methodology for Development of Emergency Action Levels, February 2008 0ERP Rev. 089 8-2

24. NRC Letter Dated November 6, 2009

Subject:

Brunswick Steam Electric Plant, Units 1 And 2 -Revision to Emergency Action Levels (Tac Nos.

Me0117 and Me0118), Which includes, Safety Evaluation By The Office Of Nuclear Reactor Regulation Proposed Revisions To Emergency Action Levels Carolina Power & Light Company Brunswick Steam Electric Plant, Units 1 And 2 DOCKET NOS. 50-325 AND 50-324

25. NRC Letter 09-0198, Dated 12/24/2009,

Subject:

Brunswick Steam Electric Plant, Units 1 and 2 -Proposed Changes to the Emergency Planning Zones of the Emergency Response Plan (TAC NOS. ME1640 AND ME1641)

26. CP&L Letter, Response to Request for Additional Information Regarding Emergency Response Plan Revision - Modification of the Emergency Planning Zones, dated November 11, 2009 (ADAMS Accession No. ML093220067)

27. NUH-003, Final Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Amendment 10, December 2006

28. NRC Regulatory Issue Summary 2009-13, Emergency Response Data System Upgrade from Modem to Virtual Private Network Appliance, September 28, 2009

29. On-Shift Staffing Analysis for Brunswick Nuclear Plant, December 2012 (PRR 00527296, RMS Number 5074607)

30. Letter from Conrad S. Burnside (Federal Emergency Management Agency) to Carolina Power & Light Company regarding provisions for Emergency Plan Backup Alert and Notification, dated November 28, 2012 (Serial Number, FED 12-0001)

31. NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies, November 2011

32. Carolina Power & Light Company and Florida Power Corporation's Response to Request for Additional Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(F) Regarding Recommendation 2.1, 2.3, and 9.3 of the Near Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Dated March 12, 2012 0ERP Rev. 089 8-3

APPENDIX A BRUNSWICK COMMUNICATIONS SYSTEM Page 1 of 4 A.0 INTRODUCTION Communications systems are designed to facilitate emergency communications within the Brunswick Plant and between Brunswick and emergency facilities.

Redundant means of communication are provided to locations which provide a vital emergency response role.

A.1 PLANT COMMUNICATION SYSTEMS A.1.1 Public Address System The Brunswick Plant public address system provides paging and party line communications between stations located throughout the plant. Inside and outside type wall and desk-mounted stations are used to communicate between roaming personnel and fixed work locations. Plant-wide instructions are issued using the paging feature. This system is powered from the plant uninterruptible power supply which employs battery reserve as well as diesel generator emergency supply.

A.1.2 PBX Telephone System The Brunswick Site PBX telephone system provides communication capability between telephone stations located within the plant by dialing the four-digit telephone station code. The PBX telephone system also provides for outside communications as discussed in Sections A.2.1 and A.2.2.

A.1.3 Sound Powered Telephone System The sound powered telephone system is a communications system which uses the mechanical energy in the human voice to generate electrical pulses to power the system. It requires no outside source of power and is therefore very reliable. The system consists of phone jacks, wiring, and the sound-powered handsets. There is no separation in the circuits. A handset plugged into a jack is connected to all other handsets plugged into that circuit. Additional temporary circuits may be easily set up by attaching phone jacks to any unused cable between any points requiring sound-powered communications. Sound powered phone jacks are provided on selected instrument racks. Switch panels are provided in the control room to cross-tie any circuit with any other circuit providing sound-powered phone communications between several plant areas.

0ERP Rev. 089 A-1

APPENDIX A BRUNSWICK COMMUNICATIONS SYSTEM Page 2 of 4 A.1.4 Brunswick Emergency Telephone and Radio System The Brunswick Site emergency telephone system consists of dedicated telephone lines between emergency facilities at the Brunswick Plant through a switch which is provided with a primary and secondary source of power. Radio communications with mobile and portable units reserved for an emergency is possible through a repeater on a Duke Energy-assigned frequency as well as a local (UHF) short-distance frequency. A primary and secondary source of power is provided for fixed radio equipment, with mobiles and portables powered by battery.

A.1.5 Plant Security Communications A portable radio communication system for plant use is available. Specific channel assignments are designated for security force use.

A.1.6 Emergency Response Facility Information System (ERFIS)

During an emergency, this system provides information for each unit on a Video Display Terminal simultaneously in the control room, the Technical Support Center, and the Emergency Operations Facility. The data may also be printed out in hard- copy form. Primary and secondary power sources are supplied to this system.

A.1.7 Satellite Telephone Communications The Mitsubishi ST251 (OmniQuest) Mobile Terminal (MT) is a satellite based portable communications system and can utilize a fixed or portable antenna and AC, DC, or battery power supplies. The MT can be used in either of two modes. Using the handset, the MT operates similarly to a cellular telephone.

Using the Push to Talk (PTT) microphone, the MT operates similar to a conventional trunked radio system using Net Radio Service. North Carolina Emergency Management has talk groups set up with Net Radio Service known as the Statewide Emergency Communication Network (SECN) that are used for both routine and emergency communications.

0ERP Rev. 089 A-2

APPENDIX A BRUNSWICK COMMUNICATIONS SYSTEM Page 3 of 4 A.2 OFF-SITE COMMUNICATIONS SYSTEMS A.2.1 Corporate Telephone Communications System (Voicenet)

Interconnected through the site PBX and the emergency telephone system, the corporate telephone system provides a means to communicate with other corporate locations with which the plant has a need to communicate.

Corporate transmission facilities provide fiber optic, copper-wire, and microwave radio to ensure a high degree of system reliability. In addition to the redundancy provided by the three system options, backup power is provided for the systems.

A.2.2 Commercial Phone Lines Commercial telephone lines, which supply public telephone communications, are employed by Duke Energy in three ways: (1) tie-ins through the PBX to any other plant location, (2) lines to plant emergency facilities, and (3) lines to the Joint Information Center for public information purposes. AT&T provides primary and secondary power for their lines at the Central Office.

A.2.3 Dedicated Telephone System to Load Dispatcher This system provides direct links between the Control Room and the load dispatcher. Transmission facilities are microwave radio. These lines appear on several phones in the Control Room and are selected by pushing the appropriate button on a multibutton phone. The lines are automatically rung at the load dispatcher identifying Brunswick as the caller. Primary and secondary power is supplied at both ends.

A.2.4 Emergency Communications Network The Emergency Communications Network is a system, separate from other communications systems, which provides back-up dedicated telephone facilities between emergency response centers. The purpose of these facilities is to ensure priority communications at any time from Brunswick Plant to emergency response personnel at the federal, state, local governments, and other Duke Energy facilities, and General Electric Company.

A.2.5 Plant Security A plant security radio control station provides for radio communications to local law enforcement agencies (LLEA). Primary and secondary power is supplied.

0ERP Rev. 089 A-3

APPENDIX A BRUNSWICK COMMUNICATIONS SYSTEM Page 4 of 4 A.2.6 Corporate Informational Data Communications Large central computers are located at the Corporate headquarters. Smaller special purpose computers are located at other Corporate facilities, including the Brunswick Plant. The communications link between the Brunswick Plant and Corporate headquarters allows the interchange, storage, and processing of information.

A.2.7 NRC Emergency Telecommunications System The NRC uses a Duke Energy telephone line which allows direct telephone communications from the plant to NRC regional and national offices. The Duke Energy communications line provides a link independent of the local public telephone network. Telephones connected to this network are located in the Brunswick Control Room, Technical Support Center, and Emergency Operations Facility. There are also telephones connected to this system for use by Health Physics personnel. Primary and secondary sources of power are supplied.

0ERP Rev. 089 A-4

APPENDIX B AGREEMENTS NOTE: The followings Letters/Memorandums of agreement are Included by reference: (These documents are located in EDMS)

City of Southport Peter D. Almirall, M.D.

Joseph Hatem, M.D Dosher Memorial Hospital Brunswick County Brunswick County EMS Yaupon Beach Volunteer Fire Department Boiling Spring Lakes Volunteer Fire Department New Hanover Regional Medical Center Oak Island Fire and Rescue Department Sunny Point Fire Department Institute of Nuclear Power Operations (INPO)

State of North Carolina New Hanover County Wilmington International Airport Air Wilmington Leland NC Police Department Brunswick County Sheriff's Office 0ERP Rev. 089 B-1

APPENDIX C BRUNSWICK NUCLEAR PLANT (BNP)

OFF-SITE AGENCY SUPPORT

SUMMARY

Page 1 of 3 Function (NUREG-0654, II.A) Primary Responsibility Support Responsibility

1. Command and Control

a. Onsite BNP NRC

b. Offsite State, County FEMA, Duke Energy Corp

2. Accident Classification

a. Onsite BNP NRC

b. Offsite N/A N/A

3. Warning

a. Onsite BNP Local

b. Offsite County State, USCG

4. Notification

a. Onsite BNP Local

b. Offsite BNP State, Local, Media

5. Communications

a. Onsite BNP NRC Duke Energy Corp.

b. Offsite State, County Commercial Phone Co.,

Duke Energy

6. Transportation

a. Onsite BNP/Employees Local

b. Offsite Local/Residents FEMA, State, County

7. Traffic Control Security

a. Onsite BNP Security County

b. Offsite County State

8. Accident Assessment

a. Onsite BNP HEEC, HNP, RNP

b. Offsite State NRC, GE, County, Duke Energy Corp.,

FEMA, EPA, DOE, CAP 0ERP Rev. 089 C-1

APPENDIX C BRUNSWICK NUCLEAR PLANT (BNP)

OFF-SITE AGENCY SUPPORT

SUMMARY

Page 2 of 3 Function (NUREG-0654, II.A) Primary Responsibility Support Responsibility

9. Public Information Education

a. Onsite BNP, Corp, Comm. NRC, County

b. Offsite State Duke Energy Corp.,

Media, FEMA

10. Protective Response

a. Onsite BNP County, Duke Energy Corp.

b. Offsite County, State Duke Energy Corp.,

FEMA, EPA, USDA

11. Radiological Exposure Control

a. Onsite BNP Duke Energy Corp.

b. Offsite State County, FEMA, EPA, Duke Energy Corp.

12. Fire and Rescue

a. Onsite BNP County/Local Organ.

b. Offsite County State

13. Medical

a. Onsite BNP County/Local Organ.

b. Offsite Local State, U.S. DHHS

14. Public Health & Sanitation

a. Onsite BNP State, Local, Duke Energy Corp.

b. Offsite County State, FEMA, U.S. DHHS

15. Social Services

a. Onsite N/A N/A

b. Offsite State County, Red Cross, Salvation Army

16. Training

a. Onsite BNP NRC

b. Offsite County State, Duke Energy Corp., BNP 0ERP Rev. 089 C-2

APPENDIX C BRUNSWICK NUCLEAR PLANT (BNP)

OFF-SITE AGENCY SUPPORT

SUMMARY

Page 3 of 3 Function (NUREG-0654, II.A) Primary Responsibility Support Responsibility

17. Exercises

a. Onsite BNP Duke Energy Corp.,

NRC

b. Offsite State State, County, Duke Energy Corp., BNP

18. Recovery/Reentry

a. Onsite BNP BNP, RNP, HNP, Duke Energy Corp.,

NRC, GE, FEMA

b. Offsite State Local, Duke Energy Corp, DOE, EPA, U.S.

DHHS, USDA Note:

BNP Brunswick Nuclear Plant CAP Civil Air Patrol DOE U.S. Department of Energy EPA U.S. Environmental Protection Agency FEMA U.S. Federal Emergency Management Agency GE General Electric RNP Robinson Nuclear Plant HEEC Harris Energy & Environmental Center NRC U.S. Nuclear Regulatory Commission USCG United States Coast Guard USDA U.S. Department of Agriculture US DHHS U.S. Department of Health & Human Services HNP Harris Nuclear Plant 0ERP Rev. 089 C-3

APPENDIX D This Appendix has been superseded by the BNP Emergency Procedures.

0ERP Rev. 089 D-1

APPENDIX E MEDICAL TREATMENT AND ASSISTANCE Page 1 of 3 E.1. INTRODUCTION The Medical Treatment and Assistance Plan provides for several levels of treatment based on the severity of injury and degree of radioactive contamination involved, if any.

The first level of assistance will be given on scene or in the plant First Aid Office, if possible. Initial evaluation of the severity of the injury will be made by first-aid and medical personnel, and emergency treatment started.

Concurrently the degree of radiation exposure and/or contamination will be assessed by radiation safety personnel and decontamination begun. All injuries occurring in a contaminated area will be considered as contaminated until monitored and cleared.

If the severity of the injury requires more extensive or prolonged treatment, the patient can be transported to the second level of assistance located at the Dosher Memorial Hospital where special facilities for treatment of contaminated patients have been provided (see Section E.2.2).

Transfer from any level of assistance to the next higher level will be effected only after medical evaluation (unless the urgency of the patient's condition requires immediate action) and will be under the control of the attending physician or his alternate senior physician.

E.2. MEDICAL EMERGENCIES E.2.1 ON-SITE FIRST AID FACILITIES It is anticipated that contaminated personnel will not leave the facility for medical treatment except for cases thought to require immediate hospitalization. Emergency medical treatment of contaminated personnel will be handled at the Plant First Aid Office located in the O&M Building (if possible) by site medical personnel. This includes all injuries thought not to require immediate hospitalization.

0ERP Rev. 089 E-1

APPENDIX E MEDICAL TREATMENT AND ASSISTANCE Page 2 of 3 E.2.2 HOSPITALIZATION If emergency medical treatment can best be given at Dosher Memorial Hospital in Southport (or another facility as may be advised by a competent medical authority), the injured person may be transported to Dosher Memorial Hospital. Dosher Memorial Hospital is the primary hospital for treating medical emergencies occurring at the Brunswick Plant, with New Hanover Regional Medical Center being the backup.

0PEP-03.9.3, First Aid, Medical Care and Transport for Injured Personnel, will be followed to prevent the spread of radioactive contamination to off-site areas and facilities. If possible, contaminated clothing and equipment should be removed from the patient, or he should be wrapped in clean sheets or clothing to prevent contamination of the transporting personnel and vehicle.

Medical assistance is immediately available at the Southport area from two general practitioners on staff at Dosher Memorial Hospital who have agreed to provide medical assistance for contaminated patients.

Also, the U. S. Department of Energy Radiological Assistance Team will provide medical assistance, if required.

E.2.3 TREATMENT FACILITY A specially designated emergency area is maintained in readiness at Dosher Memorial Hospital for Duke Energy's use for the treatment of contaminated patients. Although this area will be utilized by the hospital when not required by Duke Energy, it will be made immediately available to Duke Energy when required. Equipment is available in the hospital for the emergency treatment of patients. With the facilities and equipment available, extensive decontamination and treatment of an injured patient could be performed, including surgical treatment that may be required.

E.2.4 ON-SITE MEDICAL SERVICES Agreement has been reached with doctors in Southport who will provide medical services at the plant site when required. Personnel who are contaminated and who require medical treatment may be treated by a doctor in the Plant's First Aid Office.

0ERP Rev. 089 E-2

APPENDIX E MEDICAL TREATMENT AND ASSISTANCE Page 3 of 3 E.2.5 EMERGENCY EQUIPMENT An emergency kit is maintained at Dosher Memorial Hospital containing supplies and equipment for personnel monitoring and the control of radioactive contamination. This kit contains the following:

a. Radiation monitoring instruments, one low-level instrument for determining contamination levels, and one intermediate- range instrument for determining dose rates.

b. Personnel monitoring equipment such as TLDs and self-reading dosimeters.

c. Decontamination equipment and supplies for both personnel and facility.

d. Contamination control equipment and supplies such as protective clothing, signs, ropes, tags, plastic bags, etc.

E.2.6 AMBULANCE SERVICE The City of Southport Rescue Squad has agreed to respond to all emergency calls from the plant, just as they respond to other calls from the Southport area.

0ERP Rev. 089 E-3

APPENDIX F TECHNICAL BASIS FOR SOURCE TERM MIXES Page 1 of 2 NUREG-1228, Table 2.2 describes the core inventory and coolant concentrations (BWR).

Source Term Categories Source terms are based upon the core melt sequences, four categories of core damage: 1) normal coolant leakage, 2) spiked coolant leakage, 3) gap release, and 4) in-vessel core melt. These categories have an associated release duration based upon the length of time that the core is uncovered. As a result, it is possible to construct a source term mix matrix that is dependent on two parameters, whether or not the fuel is uncovered, and the length of time that the fuel is uncovered. A separate isotopic release fraction is developed for each accident sequence. The major isotopic release fractions are those fractions of core inventory that are released either through failure of the fuel cladding and melting of the core within the reactor vessel. These fractions are values that when multiplied by the core inventory in curies of the particular isotopes, give curie amounts of isotopes immediately available for release from the containment.

The effects of cleanup and engineered safety features are taken into account to the extent consistent with the failures that led to the particular accident sequence. To make the results manageable, the accident sequence and the accident isotopic release are grouped. NUREG-1465 is utilized as a means to weigh the release fractions for that sequence category. The weighted release fractions are added up to determine a mean in-containment release fraction.

In order to have a dose assessment capability that can be utilized under many circumstances, the vast majority of which are less consequential than a melt of the core with no removal mechanisms, the effect of engineered safety features and removal phenomena must be included in the source term mix. RTM-96, Table C-5 lists the reduction factors, and Table C-6 escape fractions are used in developing source term categories that account for removal process. In order to select the proper mix, a release pathway and estimated time duration of core uncovery is determined.

Reduction factors are applied as scaling factors, as described in NUREG-1228.

There remain three source term special cases of accident mixes which are handled separately in the dose assessment process. 1) Fuel stored in a pool, and the fuel is uncovered; 2) Fuel stored in a pool that is damaged underwater; and 3) Damage to fuel cladding stored in a dry storage cask. Fuel release fractions used in these accidents are derived from NUREG/CR-6451.

0ERP Rev. 089 F-1

APPENDIX F TECHNICAL BASIS FOR SOURCE TERM MIXES Page 2 of 2 References

1. BNP Calc. 0B21-0556, Rev. 0

2. NUREG/CR-6451, A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants

3. NUREG-1228, Source Term Estimation during Incident Response to Severe Nuclear Power Plant Accidents. 1988

4. NUREG-1465, Accident Source Terms for Light Water Nuclear Power Plants, Draft Report for Comment, U.S. Nuclear Regulatory Commission, Washington, DC, June 1992

5. NUREG-1940, RASCAL 4.0: Description of Models and Methods

6. RTM-96, Response Technical Manual, Vol. 1, Rev. 4, U.S. Nuclear Regulatory Commission, Washington, DC, October 1996-NUREG/BR 0150 0ERP Rev. 089 F-2

APPENDIX G MINIMUM PROCEDURES REQUIRED TO IMPLEMENT THE SECTIONS OF THE PLAN Page 1 of 3 PLAN PROCEDURES Section 1:

Introduction N/A Section 2: 0PEP-02.1 Initial Emergency Actions Emergency Classifications 0PEP-02.1.1 Emergency Control - Notification of Unusual Event, Alert, Site Area, Emergency, and General Emergency 0PEP-02.2.1 Emergency Action Level Technical Bases Section 3: 0PEP-02.1.1 Emergency Control - Notification of Emergency Response Unusual Event, Alert, Site Area Organization Emergency, and General Emergency 0PEP-02.6 Severe Weather 0PEP-02.6.6 Environmental Monitoring Team Leader 0PEP-02.6.12 Activation and Operation of the Operational Support Center (OSC) 0PEP-02.6.20 Dose Projection Coordinator 0PEP-02.6.21 Emergency Communicator 0PEP-02.6.26 Activation and Operation of the Technical Support Center (TSC) 0PEP-02.6.27 Activation and Operation of the Emergency Operations Facility (EOF) 0PEP-02.6.28 Off-Site Protective Action Recommendations 0PEP-02.6.29 Activation and Operation of the Joint Information Center (JIC) 0PEP-02.6.30 Alternate Emergency Facility Operation 0ERP Rev. 089 G-1

APPENDIX G MINIMUM PROCEDURES REQUIRED TO IMPLEMENT THE SECTIONS OF THE PLAN Page 2 of 3 PLAN PROCEDURES Section 3: 0PEP-03.6.5 Collection and Analysis of Highly Emergency Response Radioactive Samples Organization AD-EP-ALL-0301 Activation of the Emergency Response Organization Notification System (ERONS)

Section 4: 0PEP-02.1 Initial Emergency Actions Emergency Measures 0PEP-02.2.1 Emergency Action Level Technical Bases 0PEP-02.1.1 Emergency Control - Notification of Unusual Event, Alert, Site Area Emergency, and General Emergency 0PEP-03.1.3 Use of Communication Equipment 0PEP-03.4.8 Offsite Dose Projections for Monitored Releases AD-EP-ALL-0202 Emergency Response Offsite Dose Assessment 0PEP-03.6.1 Release Estimates Based Upon Stack/Event Readings 0PEP-03.6.3 Estimate of the Extent of Core Damage Under Accident Conditions 0PEP-03.7.6 Emergency Exposure Controls 0PEP-03.7.7 Onsite Radiological Controls 0PEP-03.8.2 Personnel Accountability and Evacuation 0PEP-03.9.3 First Aid, Medical Care and Transport for Injured Personnel 0PEP-03.9.6 Search and Rescue 0PEP-04.5 Public Education and Information 0AOP-40.0 Security Events 0ERP Rev. 089 G-2

APPENDIX G MINIMUM PROCEDURES REQUIRED TO IMPLEMENT THE SECTIONS OF THE PLAN Page 3 of 3 PLAN PROCEDURES Section 5: 0PEP-03.4.8 Off-site Dose Projections for Emergency Facilities Monitored Releases and Equipment AD-EP-ALL-0202 Emergency Response Offsite Dose Assessment 0PEP-03.5.5 Environmental Monitoring and Plume Tracking 0PEP-04.2 Emergency Facilities and Equipment AD-EP-ALL-0301 Activation of the Emergency Response Organization Notification System (ERONS)

AD-EP-ALL-0400 Emergency Communication Equipment Section 6: 0PEP-04.1 Record Keeping and Maintaining Emergency Documentation Preparedness 0PEP-04.2 Emergency Facilities and Equipment 0PEP-04.3 Performance of Training, Exercises, and Drills 0PEP-04.5 Public Education and Information 0PEP-04.6 Radiological Emergency Kit Inventories 0PEP-04.08 Periodic Review of Emergency Plan Section 7: 0PEP-02.7 Recovery Recovery 0ERP Rev. 089 G-3

APPENDIX H CROSS-REFERENCE BETWEEN NUREG-0654 EVALUATION CRITERIA AND BRUNSWICK RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 1 of 10 NUREG-0654 Criterion Brunswick Section(s)

A.1.a 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 3.8 Appendix C A.1.b 3.0, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 3.8 A.1.c Figures 3.1-1, 3.2-1, 3.4-1, 3.6-1 A.1.d 3.0, 3.2.1 A.1.e 3.2, 3.9 A.2.a N/A A.2.b N/A A.3 Appendix B A.4 3.0, 3.2, 3.3, 3.4, 3.5 B.1 3.0, 3.1, 3.2 B.2 3.0, 3.2.1 B.3 3.0, 3.2.1 B.4 3.0, 3.2.1 B.5 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 3.8 B.6 Section 3 Appendices B, C, E Figures 3.2-1, 3.4-1, 3.6-1 0ERP Rev. 089 H-1

APPENDIX H CROSS-REFERENCE BETWEEN NUREG-0654 EVALUATION CRITERIA AND BRUNSWICK RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 2 of 10 NUREG-0654 Criterion Brunswick Section(s)

B.7 Section 3 B.7.a 3.3.5, 3.5.2 B.7.b 3.3.1, 3.3.3, 3.5.3 Section 7.0 B.7.c 3.2.1, 3.5.1 B.7.d 3.6.1 B.8 3.7.1, Table 3.5-1 B.9 3.7.2, Appendix B, Appendix C, Appendix E C.1.a 3.8.4.1 C.1.b 3.8.4 C.1.c 3.8.1, 3.8.2, 3.8.3, 3.8.4.1 Appendix A C.2.a N/A C.2.b 3.5.8, Figure 3.2-1 C.3 5.7.6, 3.7.1, 3.8 C.4 3.7, 3.8, Appendix B, Appendix C, Table 3.5-1 D.1 Section 2.0, EAL-1, EAL-2 D.2 Section 2.0, EAL-1, EAL-2 D.3 N/A D.4 N/A 0ERP Rev. 089 H-2

APPENDIX H CROSS-REFERENCE BETWEEN NUREG-0654 EVALUATION CRITERIA AND BRUNSWICK RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 3 of 10 NUREG-0654 Criterion Brunswick Section(s)

E.1 3.9, 4.1, 4.4.1 E.2 3.2, 3.3, 3.4, 3.5, 3.6, 3.9 E.3 3.9, 0PEP-02.6.21 E.4.a-n 3.9, 0PEP-02.6.21 E.5 N/A E.6 3.9, 4.4.6, 0PEP-02.6.21 E.7 3.9, 4.4.7 F.1.a 3.9, 0PEP-02.6.21 F.1.b 3.9, EPL-001, 0PEP-02.6.21 F.1.c 3.9, EPL-001, 0PEP-02.6.21 F.1.d 3.9, EPL-001, 0PEP-02.6.21, 0PEP-03.1.3 F.1.e 3.2, 3.9, EPL-001 0PEP-02.6.21, AD-EP-ALL-0301 F.1.f 3.9, EPL-001, 0PEP-02.6.21 F.2 EPL-001, Table 3.5-1 F.3 4.4.6, 6.1.2.1 0ERP Rev. 089 H-3

APPENDIX H CROSS-REFERENCE BETWEEN NUREG-0654 EVALUATION CRITERIA AND BRUNSWICK RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 4 of 10 NUREG-0654 Criterion Brunswick Section(s)

G.1 4.4.7.1, 6.1.4 G.2 4.4.7.1, 6.1.4 G.3.a 3.6, 5.5 G.3.b 5.4, 5.5 G.4.a 3.6.1 G.4.b 3.6 G.4.c 3.6, 4.4.7.1 G.5 4.4.7.1, 4.4.7.2, 6.7.7, 0PEP-04.3 H.1 3.3, 3.4, 5.2, 5.3 H.2 3.5, 5.4 H.3 N/A H.4 3.0, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.9 Table 3.5-1 H.5 5.7 H.5.a 5.7.2, 5.7.3 H.5.b 5.7.4 H.5.c 5.7.5 H.5.d 5.8 0ERP Rev. 089 H-4

APPENDIX H CROSS-REFERENCE BETWEEN NUREG-0654 EVALUATION CRITERIA AND BRUNSWICK RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 5 of 10 NUREG-0654 Criterion Brunswick Section(s)

H.6.a 5.7.2, 5.7.3 H.6.b 5.7.4 H.6.c 5.7.6 H.7 5.7.4, 5.12 H.8 5.7.2 H.9 5.3, Table 5.0-2, 6.3, 0PEP-04.6 H.10 6.3.1, Procedure 0PEP-04.6 H.11 6.3.1, Procedure 0PEP-04.6 H.12 5.0, 5.7.6, 0PEP-02.6.6 I.1 Section 2, Section 5.0 0PEP-02.1, 0PEP-02.2.1 I.2 4.2, Section 5.0 I.3.a 4.2.2, 0PEP-03.6.1, PEP 03.6.3, Appendix F I.3.b 4.2.2, 4.2.3, 0PEP-03.4.8, 0PEP-03.5.5, AD-EP-ALL-0202 I.4 4.2.2, 0PEP-03.4.8, 0PEP-03.6.1, AD-EP-ALL-0202 I.5 5.7.2 I.6 4.2.2.3 0ERP Rev. 089 H-5

APPENDIX H CROSS-REFERENCE BETWEEN NUREG-0654 EVALUATION CRITERIA AND BRUNSWICK RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 6 of 10 NUREG-0654 Criterion Brunswick Section(s)

I.7 4.2.4 I.8 4.2.1, 4.2.2, 4.2.3, 4.2.4 I.9 4.2 I.10 4.2 1.11 N/A J.1.a 4.4.2, 6.1.1, 0PEP-03.8.2 J.1.b 4.4.2, 6.1.1, 0PEP-03.8.2 J.1.c 4.4.2, 6.1.1 J.1.d 4.4.2, 4.4.6 J.2 4.4.2, 0PEP-03.8.2 J.3 4.4.2.2, 4.4.4.1, 4.4.4.2 J.4 4.4.2.2 J.5 4.4.2.2, 0PEP-03.8.2 J.6.a 4.4.3, 5.9 J.6.b 4.4.3, 5.9 J.6.c 4.4.3 J.7 4.1.5, 4.4.7 J.8 4.4.7.3, Table 4.4-1 J.9 N/A 0ERP Rev. 089 H-6

APPENDIX H CROSS-REFERENCE BETWEEN NUREG-0654 EVALUATION CRITERIA AND BRUNSWICK RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 7 of 10 NUREG-0654 Criterion Brunswick Section(s)

J.10.a 4.4.7.3, Figures 1.1-1, 4.4-1, Figure 1.1-2 J.10.b Figures 1.1-1, 1.1-2, 1.1-6 J.10.c 3.9, 4.4.6 J.10.d N/A J.10.e N/A J.10.f N/A J.10.g N/A J.10.h N/A J.10.i N/A J.10.j N/A J.10.k N/A J.10.l N/A J.10.m See item J.7, Figure 4.4-3; Tables 4.4-2, 4.4-3, and 4.4-4 J.11 N/A J.12 N/A K.1.a-g 4.4.3 K.2 4.4.3 K.3.a 4.4 K.3.b 4.4 0ERP Rev. 089 H-7

APPENDIX H CROSS-REFERENCE BETWEEN NUREG-0654 EVALUATION CRITERIA AND BRUNSWICK RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 8 of 10 NUREG-0654 Criterion Brunswick Section(s)

K.4 N/A K.5.a 4.4.4 K.5.b 4.4.4.1, 4.4.4.2, 4.4.5 K.6.a 4.4.4 K.6.b 4.4.4 K.6.c 4.4.4 K.7 4.4.4, 4.4.5 L.1 5.10, Appendix B, Appendix E, L.2 4.4.5, 5.10, Appendix B, Appendix E L.3 N/A L.4 3.7.2.1, 3.7.2.2, 4.4.5, Appendix B, Appendix E M.1 0PEP-02.7, Section 7.0 M.2 7.2, Figure 7.2.1, 0PEP-02.7 M.3 7.1, 0PEP-02.7 M.4 Figure 1.1-6, 1.1-6a, 1.1-6b, 0PEP-03.4.8, AD-EP-ALL-0202 N.1.a 6.1.2.2 N.1.b 6.1.2.2 N.2.a 6.1.2.1.2 0ERP Rev. 089 H-8

APPENDIX H CROSS-REFERENCE BETWEEN NUREG-0654 EVALUATION CRITERIA AND BRUNSWICK RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 9 of 10 NUREG-0654 Criterion Brunswick Section(s)

N.2.b 6.1.2.1.3 N.2.c 6.1.2.1.4 N.2.d 6.1.2.1.5 N.2.e 6.1.2.1.6 N.3.a-f 6.1.2 N.4 6.1.2.2 N.5 6.1.2.2 O.1 6.1.1 O.1.a 6.1.1 O.1.b N/A O.2 6.1.1 O.3 6.1.1 O.4.a-j 6.1.1 O.5 6.0, 6.1, 6.1.1 P.1 6.1.3 P.2 6.1.3 P.3 6.1.3 P.4 6.2.1, 6.2.3 P.5 6.2.1 P.6 6.2.3, Appendix G 0ERP Rev. 089 H-9

APPENDIX H CROSS-REFERENCE BETWEEN NUREG-0654 EVALUATION CRITERIA AND BRUNSWICK RADIOLOGICAL EMERGENCY RESPONSE PLAN Page 10 of 10 NUREG-0654 Criterion Brunswick Section(s)

P.7 Appendix G P.8 Table of Contents P.9 6.2.2 P.10 6.2.1 0ERP Rev. 089 H-10

APPENDIX I MINIMUM DESIGN CRITERIA FOR EMERGENCY FACILITIES AND EQUIPMENT Page 1 of 9 The purpose of this Appendix is to document the minimum design criteria for Emergency Facilities and Equipment which support implementation of the plant Radiological Emergency Plan (0ERP). This design criteria is listed in Appendix E to Part 50 - Emergency Planning and Preparedness for Production and Utilization Facilities.

Item: Appendix E Emergency to Part 50 Procedure Location SECTION II - The Preliminary Safety Analysis Report Onsite and offsite organizations for coping with emergencies and the II. A 0ERP means for notification, in the event of an emergency, of persons

• Section 3.0 assigned to the emergency organizations.

• Appendix C 0PEP-02.6.12 0PEP-02.6.26 0PEP-02.6.27 0PEP-02.6.29 Contacts and arrangements made and documented with local, State, II. B 0ERP and Federal governmental agencies with responsibility for coping

• Section 3.7 with emergencies, including identification of the principal agencies.

• Section 3.8

• Appendix C

• Appendix B EPL-001 Protective measures to be taken within the site boundary and within II. C 0ERP each EPZ to protect health and safety in the event of an accident;

• Section 4.4 procedures by which these measures are to be carried out (e.g., in 0PEP-02.6.26 the case of an evacuation, who authorizes the evacuation, how the 0PEP-02.6.27 public is to be notified and instructed, how the evacuation is to be 0PEP-02.6.28 carried out); and the expected response of offsite agencies in the 0PEP - 02.6.29 event of an emergency. 0PEP-03.8.2 Features of the facility to be provided for onsite emergency first aid II. D 0ERP and decontamination and for emergency transportation of onsite

• Section 5.10 individuals to offsite treatment facilities.

• Section 3.7.2

• Section 6.3

• Appendix E 0PEP-03.9.3 0PEP-03.9.6 Provisions to be made for emergency treatment at offsite facilities of II. E 0ERP individuals injured as a result of licensed activities

• Section 3.7.2

• Appendix E 0PEP-03.9.3 Provisions for a training program for employees of the licensee, II.F 0ERP including those who are assigned specific authority and responsibility

• Section 6.1.1 in the event of an emergency, and for other persons who are not 0EPM-04.3 employees of the licensee but whose assistance may be needed in the event of a radiological emergency.

0ERP Rev. 089 I-1

APPENDIX I MINIMUM DESIGN CRITERIA FOR EMERGENCY FACILITIES AND EQUIPMENT Page 2 of 9 Item: Appendix E Emergency to Part 50 Procedure Location A preliminary analysis that projects the time and means to be II. G 0ERP employed in the notification of State and local governments and the

• Section 3.8 public in the event of an emergency. A nuclear power plant applicant

• Section 3.9 shall perform a preliminary analysis of the time required to evacuate

• Table 3.5-1 various sectors and distances within the plume exposure pathway

• Figure 1.1-5 EPZ for transient and permanent populations, noting major

• Figure 1.1-6 impediments to the evacuation or taking of protective actions.

• Figure 1.1-6a

• Figure 1.1-6b

• Figure 1.1-7 0PEP - 02.6.27 0PEP - 02.6.28 A preliminary analysis reflecting the need to include facilities, II. H 0ERP systems, and methods for identifying the degree of seriousness and

• Section 3.5.4 potential scope of radiological consequences of emergency

• Section 3.5.6 situations within and outside the site boundary, including capabilities

• Section 4.1 for dose projection using real-time meteorological information and for

• Section 4.2 dispatch of radiological monitoring teams within the EPZs; and a

• Section 4.4 preliminary analysis reflecting the role of the onsite technical support 0PEP - 02.6.6 center and the emergency operations facility in assessing 0PEP - 02.6.26 information, recommending protective action, and disseminating 0PEP - 02.6.27 information to the public. 0PEP - 02.6.28 0PEP - 03.4.8 AD-EP-ALL-0202 SECTION IV - Content Of Emergency Plans Information needed to demonstrate compliance with the elements set IV. 1 0ERP forth below, i.e., organization for coping with radiological

• Section 3.0 emergencies, assessment actions, activation of emergency

• Section 4.0 organization, notification procedures, emergency facilities and

• Section 5.0 equipment, training, maintaining emergency preparedness, recovery,

• Section 6.0 and onsite protective actions during hostile action.

• Section 7.0 0PEP - 02.1.1 0PEP - 02.6.26 0PEP - 02.6.27 0PEP - 02.6.28 0PEP - 02.7 An analysis of the time required to evacuate various sectors and IV. 2 0ERP distances within the plume exposure pathway EPZ for transient and

• Section 1.1.2 permanent populations, using the most recent U.S. Census Bureau

• Section 1.1.3 data as of the date the applicant submits its application to the NRC.

• Section 1.1.4

• Section 1.1.5

• Figure 1.1-5

• Figure 1.1-6

• Figure 1.1-6a

• Figure 1.1-6b

• Figure 1.1-7 0PEP - 02.6.28 0ERP Rev. 089 I-2

APPENDIX I MINIMUM DESIGN CRITERIA FOR EMERGENCY FACILITIES AND EQUIPMENT Page 3 of 9 Item: Appendix E Emergency to Part 50 Procedure Location Use NRC approved evacuation time estimates (ETEs) and updates IV. 3 0ERP to the ETEs in the formulation of protective action recommendations

• Section 4.4.6 and shall provide the ETEs and ETE updates to State and local

• Section 4.4.7 governmental authorities for use in developing offsite protective

• Figure 1.1-5 action strategies.

• Figure 1.1-6

• Figure 1.1-6a

• Figure 1.1-6b

• Figure 1.1-7 0PEP - 02.6.28 Within 365 days of the later of the date of the availability of the most IV. 4 0ERP recent decennial census data from the U.S. Census Bureau or

• Section 1.1.2 December 23, 2011, nuclear power reactor licensees shall develop

• Section 1.1.3 an ETE analysis using this decennial data and submit it under § 50.4

• Section 1.1.4 to the NRC. These licensees shall submit this ETE analysis to the

• Section 1.1.5 NRC at least 180 days before using it to form protective action 0PEP - 02.6.28 recommendations and providing it to State and local governmental authorities for use in developing offsite protective action strategies.

Between decennial censuses, nuclear power reactor licensees shall IV. 5 0ERP estimate EPZ permanent resident population changes once a year,

• Section 1.1.2 but no later than 365 days from the date of the previous estimate,

• Section 1.1.3 using the most recent U.S. Census Bureau annual resident

• Section 1.1.4 population estimate and State/local government population data, if

• Section 1.1.5 available. These licensees shall maintain these estimates so that they are available for NRC inspection during the period between decennial censuses and shall submit these estimates to the NRC with any updated ETE analysis.

If at any time during the decennial period, the EPZ permanent IV. 6 0ERP resident population increases such that it causes the longest ETE

• Section 1.1.2 value for the 2-mile zone or 5-mile zone, including all affected

• Section 1.1.3 Emergency Response Planning Areas, or for the entire 10-mile EPZ

• Section 1.1.4 to increase by 25 percent or 30 minutes, whichever is less, from the

• Section 1.1.5 nuclear power reactor licensee's currently NRC approved or updated ETE, the licensee shall update the ETE analysis to reflect the impact of that population increase.

SECTION IV. A - Organization A description of the normal plant operating organization IV. A. 1 0ERP

• Section 3.1

• Section 3.2 A description of the onsite emergency response organization (ERO) IV. A. 2 0ERP with a detailed discussion of

• Section 3.2

• Authorities, responsibilities, and duties of the individual(s) who

• Section 3.3 will take charge during an emergency

• Section 3.4

• Plant staff emergency assignments

• Section 3.5 0PEP-02.6.12 0PEP-02.6.26 0PEP-02.6.27 0ERP Rev. 089 I-3

APPENDIX I MINIMUM DESIGN CRITERIA FOR EMERGENCY FACILITIES AND EQUIPMENT Page 4 of 9 Item: Appendix E Emergency to Part 50 Procedure Location A description, by position and function to be performed, of the IV. A. 3 0ERP licensee's headquarters personnel who will be sent to the plant site to

• Section augment the onsite emergency organization. 1.3.1.2 Identification, by position and function to be performed, of persons IV. A. 4 0ERP within the licensee organization who will be responsible for making

• Section 3.5.4 offsite dose projections, and a description of how these projections

• Section 3.5.6 will be made and the results transmitted to State and local

• Section 4.2.3 authorities, NRC, and other appropriate governmental entities.

• Section 5.6.2

• Section 5.6.3

• Section 5.7.7 0PEP-02.6.27 Identification, by position and function to be performed, of other IV. A. 5 0ERP employees of the licensee with special qualifications for coping with

• Section emergency conditions that may arise. Other persons with special 1.3.1.2 qualifications, such as consultants, who are not employees of the

• Appendix C licensee and who may be called upon for assistance for emergencies shall also be identified. The special qualifications of these persons shall be described A description of the local offsite services to be provided in support of IV. A. 6 0ERP the licensee's emergency organization.

• Section 3.7.2

• Section 3.8

• Appendix C By June 23, 2014, identification of, and a description of the IV. A. 7 0ERP assistance expected from, appropriate State, local, and Federal

• Section 3.7.2 agencies with responsibilities for coping with emergencies, including

• Section 3.8 hostile action at the site. For purposes of this appendix, "hostile

• Appendix C action" is defined as an act directed toward a nuclear power plant or Security Plan its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force.

Identification of the State and/or local officials responsible for IV. A. 8 0ERP planning for, ordering, and controlling appropriate protective actions,

• Section 3.7.2 including evacuations when necessary.

• Section 3.8

• Appendix C By December 24, 2012, for nuclear power reactor licensees, a IV. A. 9 0ERP detailed analysis demonstrating that on-shift personnel assigned

• Section 3.2 emergency plan implementation functions are not assigned

• Attachment 2 responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

0ERP Rev. 089 I-4

APPENDIX I MINIMUM DESIGN CRITERIA FOR EMERGENCY FACILITIES AND EQUIPMENT Page 5 of 9 Item: Appendix E Emergency to Part 50 Procedure Location SECTION IV. B - Assessment Actions The means to be used for determining the magnitude of, and for IV. B. 1 0ERP continually assessing the impact of, the release of radioactive

• Section 1.3 materials shall be described, including emergency action levels that

• Section 2.0 are to be used as criteria for determining the need for notification and

• Section 4.1 participation of local and State agencies, the Commission, and other 0PEP-02.1 Federal agencies, and the emergency action levels that are to be 0PEP-02.1.1 used for determining when and what type of protective measures 0PEP-02.6.26 should be considered within and outside the site boundary to protect 0PEP-02.6.27 health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC.

Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis.

A licensee desiring to change its entire emergency action level IV. B. 2 0ERP scheme shall submit an application for an amendment to its license

• Section 6.2 and receive NRC approval before implementing the change.

Licensees shall follow the change process in § 50.54(q) for all other emergency action level changes.

SECTION IV. C - Activation Of Emergency Organization The entire spectrum of emergency conditions that involve the alerting IV. C. 1 0ERP or activating of progressively larger segments of the total emergency

• Section 1.3 organization shall be described. The communication steps to be

• Section 2.0 taken to alert or activate emergency personnel under each class of

• Section 4.1 emergency shall be described. Emergency action levels (based not 0PEP-02.1 only on onsite and offsite radiation monitoring information but also on 0PEP-02.1.1 readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described. The existence, but not the details, of a message authentication scheme shall be noted for such agencies.

The emergency classes defined shall include: (1) unusual events, (2) alert, (3) site area emergency, and (4) general emergency.

0ERP Rev. 089 I-5

APPENDIX I MINIMUM DESIGN CRITERIA FOR EMERGENCY FACILITIES AND EQUIPMENT Page 6 of 9 Item: Appendix E Emergency to Part 50 Procedure Location By June 20, 2012, nuclear power reactor licensees shall establish IV. C. 2 0ERP and maintain the capability to assess, classify, and declare an

• Section 1.3 emergency condition within 15 minutes after the availability of

• Section 2.0 indications to plant operators that an emergency action level has

• Section 4.1 been exceeded and shall promptly declare the emergency condition

• Section 2.1 as soon as possible following identification of the appropriate 0PEP-02.1 emergency classification level. Licensees shall not construe these 0PEP-02.1.1 criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.

SECTION IV. D - Notification Procedures Administrative and physical means for notifying local, State, and IV. D. 1 0ERP Federal officials and agencies and agreements reached with these

• Section officials and agencies for the prompt notification of the public and for 1.3.1.1 public evacuation or other protective measures, should they become

• Section 3.7 necessary, shall be described. This description shall include

• Section 3.8 identification of the appropriate officials, by title and agency, of the

• Section 3.9 State and local government agencies within the EPZs.

• Appendix C

• 0PEP-03.8.2 EPL-001 Provisions shall be described for yearly dissemination to the public IV. D. 2 0ERP within the plume exposure pathway EPZ of basic emergency

• Section 6.1.4 planning information, such as the methods and times required for

• Section 4.4.7 public notification and the protective actions planned if an accident 0PEP-04.5 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.

A licensee shall have the capability to notify responsible State and IV. D. 3 0ERP local governmental agencies within 15 minutes after declaring an

• Section 3.9 emergency. The licensee shall demonstrate that the appropriate 0PEP-03.1.3 governmental authorities have the capability to make a public alerting and notification decision promptly on being informed by the licensee of an emergency condition.

SECTION IV. E - Emergency Facilities And Equipment Equipment at the site for personnel monitoring. IV. E. 1 0ERP

• Section 5.7

• Section 6.3.1

• Table 5.7-4 0PEP-03.7.7 0PEP-04.6 0ERP Rev. 089 I-6

APPENDIX I MINIMUM DESIGN CRITERIA FOR EMERGENCY FACILITIES AND EQUIPMENT Page 7 of 9 Item: Appendix E Emergency to Part 50 Procedure Location Equipment for determining the magnitude of and for continuously IV. E. 2 0ERP assessing the impact of the release of radioactive materials to the

• Section 5.7 environment. 0PEP-03.4.8 0PEP-03.5.5 AD-EP-ALL-0202 Facilities and supplies at the site for decontamination of onsite IV.E. 3 0ERP individuals.

• Section 5.7 0PEP-04.6 Facilities and medical supplies at the site for appropriate emergency IV.E. 4 0ERP first aid treatment.

• Section 5.10 0PEP-03.9.3 Arrangements for medical service providers qualified to handle IV.E. 5 0ERP radiological emergencies onsite.

• Section 5.7

• Appendix C

• Appendix E 0PEP-03.9.3 Arrangements for transportation of contaminated injured individuals IV.E. 6 0ERP from the site to specifically identified treatment facilities outside the

• Section 5.7 site boundary.

• Appendix C

• Appendix E 0PEP-03.9.3 Arrangements for treatment of individuals injured in support of IV.E. 7 0ERP licensed activities on the site at treatment facilities outside the site

• Section 5.7 boundary.

• Appendix C

• Appendix E 0PEP-03.9.3 A licensee onsite technical support center and an emergency IV.E. 8a 0ERP operations facility from which effective direction can be given and

• Section 5.2 effective control can be exercised during an emergency.

• Section 5.3 For nuclear power reactor licensees, a licensee onsite

• Section 5.4 operational support center 0PEP-02.6.12 0PEP-02.6.26 0PEP-02.6.27 0PEP-04.2 A primary facility located less than 10 miles from the nuclear power IV.E. 8b 0ERP reactor site(s) and a backup facility located between 10 miles and 25

• Section 5.4 miles of the nuclear power reactor site(s). 0PEP-02.6.30

• Space for members of an NRC site team and Federal, State, and local responders

• Additional space for conducting briefings with emergency response personnel

• Communication with other licensee and offsite emergency response facilities

• Access to plant data and radiological information

• Access to copying equipment and office supplies 0ERP Rev. 089 I-7

APPENDIX I MINIMUM DESIGN CRITERIA FOR EMERGENCY FACILITIES AND EQUIPMENT Page 8 of 9 Item: Appendix E Emergency To Part 50 Procedure Location A nuclear power reactor licensee's emergency operations facility IV.E. 8c 0ERP having the following capabilities.

• Section 5.4

• The capability for obtaining and displaying plant data and 0PEP-02.6.27 radiological information for each reactor at a nuclear power reactor site and for each nuclear power reactor site that the facility serves

• The 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

• The capability to support response to events occurring simultaneously at more than one nuclear power reactor site if the emergency operations facility serves more than one site An alternative facility (or facilities) that would be accessible even if IV.E.8d 0ERP the site is under threat of or experiencing hostile action, to function

• Section 5.4 as a staging area for augmentation of emergency response staff and 0PEP-02.6.30 collectively having the following characteristics: the capability for communication with the emergency operations facility, control room, and plant security; the capability to perform offsite notifications; and the capability for engineering assessment activities, including damage control team planning and preparation, for use when onsite emergency facilities cannot be safely accessed during hostile action.

At least one onsite and one offsite communications system; each IV.E.9 0ERP system shall have a backup power source. All communication plans

• Section 5.0 shall have arrangements for emergencies, including titles and

• Appendix A alternates for those in charge at both ends of the communication 0PEP-02.6.21 links and the primary and backup means of communication. Where 0PEP-04.2 consistent with the function of the governmental agency, these arrangements will include.

• Provision for communications with contiguous State/local governments within the plume exposure pathway EPZ. Such communications shall be tested monthly.

• Provision for communications with Federal emergency response organizations. Such communications systems shall be tested annually.

• Provision 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.

• Provisions 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.

0ERP Rev. 089 I-8

APPENDIX I MINIMUM DESIGN CRITERIA FOR EMERGENCY FACILITIES AND EQUIPMENT Page 9 of 9 Item: Appendix E Emergency To Part 50 Procedure Location SECTION VI - Emergency Response Data System The Emergency Response Data System (ERDS) is a direct near VI.1 0ERP real-time electronic data link between the licensee's onsite

• Section 4.2.5 computer system and the NRC Operations Center that provides

• Table 5 for the automated transmission of a limited data set of selected 0PEP-02.6.26 parameters. The ERDS supplements the existing voice 0PEP-02.6.27 transmission over the Emergency Notification System (ENS) by 0PEP-04.2 providing the NRC Operations Center with timely and accurate updates of a limited set of parameters from the licensee's installed onsite computer system in the event of an emergency.

When selected plant data are not available on the licensee's onsite computer system, retrofitting of data points is not required. The licensee shall test the ERDS periodically to verify system availability and operability. The frequency of ERDS testing will be quarterly unless otherwise set by NRC based on demonstrated system performance.

Except for Big Rock Point and all nuclear power facilities that are VI.2,3,4 0ERP shut down permanently or indefinitely, onsite hardware shall be

• Section 4.2.5 provided at each unit by the licensee to interface with the NRC

• Table 5 receiving system. Software, which will be made available by the 0PEP-04.2 NRC, will assemble the data to be transmitted and transmit data 0PT-96.0 from each unit via an output port on the appropriate data system.

The hardware and software must have the following characteristics:

• Data points, if resident in the in-plant computer systems, must be transmitted for four selected types of plant conditions: Reactor core and coolant system conditions; reactor containment conditions; radioactivity release rates; and plant meteorological tower data. A separate data feed is required for each reactor unit. While it is recognized that ERDS is not a safety system, it is conceivable that a licensee's ERDS interface could communicate with a safety system. In this case, appropriate isolation devices would be required at these interfaces.

0ERP Rev. 089 I-9

ATTACHMENT 1 BRUNSWICK NUCLEAR PLANT ON-SHIFT STAFFING ANALYSIS

SUMMARY

DECEMBER, 2012 0ERP Rev. 089 Attachment 1

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Table of Contents Page

1. INTRODUCTION .................................................................................................................................. 1

2. ANALYSIS

SUMMARY

......................................................................................................................... 1

3. ANALYSIS PROCESS ......................................................................................................................... 1

4. SCENARIO SELECTION AND ATTRIBUTES .................................................................................... 2

5. GENERAL ASSUMPTIONS AND LIMITATIONS................................................................................ 4 5.1 RP and Chemistry 4 5.2 Repair and Corrective Action 5 5.3 Rescue Operations and First Aid 5 5.4 10CFR50.54(hh) Aircraft Threat 5 5.5 ERO Response Time 5 5.6 NEI 10-05 General Assumptions 6

6. CONCLUSIONS ................................................................................................................................... 7

7. ATTACHMENTS .................................................................................................................................. 8

8. REFERENCES ..................................................................................................................................... 8 0ERP Rev. 089 Att. 1 - Page i

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachments Page

1. Attachment 1, Minimum On-Shift Staffing for Emergency Response .......................................... 9

2. Attachment 2, Event Staffing Analysis Tables ............................................................................ 11

• Attachment 2A, Design Basis Threat (DBT) 12

• Attachment 2B, Aircraft Probable Threat 17

• Attachment 2C, Control Room Fire With Evacuation 23

• Attachment 2D, Fuel Handling Accident in Mode 5 29

• Attachment 2E, Control Rod Drop 35

• Attachment 2F, Station Blackout (SBO) 41

• Attachment 2G, Steam System Piping Failure 48

• Attachment 2H, Large Break Loss of Coolant Accident (LOCA) 54

• Attachment 2I, SAMG Response Actions 60 0ERP Rev. 089 Att. 1 - Page ii

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012

1. INTRODUCTION This document describes the methodology used in the conduct of an On-shift Staffing Analysis (OSA) for Brunswick Nuclear Plant (BNP) and the results obtained by the OSA. The OSA was performed to ensure sufficient personnel are assigned to all operating shifts as required by Section IV.A.9 of 10 CFR 50, Appendix E [Ref. 1], which states that nuclear power reactor licensees shall include in their emergency plans a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. This document constitutes the detailed analysis required by the regulations and is based on the Final Report - NEI 10-05 On-shift Staffing Analysis for the Brunswick Nuclear Plant [Ref 2], which provides additional details regarding the analysis process.

A structured approach was utilized to perform this analysis using the guidance provided in NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities [Ref.

3]. The OSA examined the ability of the minimum staff, as identified in the site emergency plan (0ERP, Radiological Emergency Response Plan) [Ref. 4], to perform the actions necessary to respond to each of the specified event scenarios, as well as implement the actions required by the Emergency Plan.

2. ANALYSIS

SUMMARY

The on-shift staff consists of individuals necessary to support each of the following Emergency Plan functional areas:

• Plant Operations & Safe Shutdown

• Fire Fighting

• Radiation Protection & Chemistry

• Emergency Plan Implementation NEI 10-05 indicates it is acceptable for certain identified functions to be assigned to personnel already assigned other functions/tasks. The identified functions include Repair and Corrective Action, Rescue Operations, and First Aid. provides the OSA results presented in the NUREG-0654, Table B-1 format. Augmenting emergency response organization positions are not considered within the staffing analysis and therefore do not appear in Attachment 1. provides the final NEI 10-05 staffing analysis tables, as presented in Reference 2, providing the results of each scenario analysis.

3. ANALYSIS PROCESS NEI 10-05 separates the analysis into three phases:

• Phase I included identification of required scenarios and determination of On-Shift Minimum Staffing levels as found in 0ERP, Radiological Emergency Response Plan. Section 4 provides a discussion of the scenario identification process.

• Phase II (referred to in NEI 10-05 as On-Shift Staffing Analysis) was conducted by a multi-disciplined team using site procedures to determine if tasks have been sufficiently analyzed 0ERP Rev. 089 Att. 1 - Page 1 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 for performance by the minimum on-shift staff as designated in the Emergency Plan. Task areas analyzed included:

o Event Mitigation (EOP/AOP, other site procedures) o Fire Response (as determined by the scenario) o RP/Chemistry Functions (as specified in site response procedures) o Emergency Preparedness Functions (NUREG-0654 Table B-1)

Attachment 2 presents the results of Phase II.

• Phase III of the methodology is designed to perform task-based Time-Motion Studies, as needed, when concerns were identified in either of two areas. The first area involves emergency response function(s) that have not been previously analyzed by an existing performance-based assessment process. The second area includes functions assessed by existing JTA or performance-based assessment processes, where overlap is discovered and integrated performance of the functions has not been previously analyzed by an existing performance-based assessment process.

The emergency response to each event was determined by conducting a tabletop of the event using the emergency plan and procedures and applicable department procedures, such as Operations emergency and abnormal operating procedures.

Each scenario was reviewed by the cross-disciplinary team to identify the required operational actions and emergency plan implementation actions, based on plant procedures, prior to staff augmentation.

These actions were then compared to the minimum staffing as described in the Emergency Plan, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency plan roles or their dedicated operational roles, as appropriate. In cases where multiple tasks were assigned to an individual, the team evaluated timing of the tasks to ensure the tasks could be performed by the individual in series within any specified time requirements.

4. SCENARIO SELECTION AND ATTRIBUTES To ensure that the on-shift staff can carry out their assigned emergency response functions until the augmenting emergency response organization (ERO) arrives, NEI 10-05 indicates that each licensee should define the events that will be used in the OSA. These events should include the following:

• Postulated Design Basis Accidents (DBAs) (Condition IV events) presented in the FSAR, as updated, and which would result in an emergency declaration. At least one DBA should result in the declaration of a General Emergency and radiological doses to the public that exceed the EPA Protective Action Guides (PAGs) and necessitate licensee Protective Action Recommendations (PARs);

• Station Design Basis Threat (DBT);

• Response actions for an aircraft probable threat in accordance with 10 CFR 50.54(hh)(1) and as discussed in Regulatory Guide 1.214; and

• Control room fire leading to evacuation and remote shutdown, as referenced in NRC Information Notice 95-48.

0ERP Rev. 089 Att. 1 - Page 2 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 The Large Break Loss of Coolant Accident (LOCA) was selected as the DBA event to be taken to General Emergency with corresponding release exceeding EPA PAGs.

NSIR/DPR ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, (the ISG) [Ref. 5] specifies three additional scenarios for consideration. If those scenarios are not performed, justification must be provided in the final analysis. The three scenarios for consideration are:

• Station Blackout (Current Licensing Basis) - this scenario was performed in the Phase II analysis;

• Fire response; and

• Severe Accident Management Guideline (SAMG) Response -

Response was limited to actions performed prior to activation of the Technical Support Center (TSC) and SAMG augmented personnel.

This scenario was included in the Phase II analysis.

Prior to the analysis, Duke Energys Asset Management Group conducted a review of the BNP UFSAR Chapter 15 Design Basis Accident (DBA) events. This review validated those BNP UFSAR Chapter 15 DBA events meeting the guidance in the ISG as Condition IV Design Basis Accidents.

Condition II and III DBA events were excluded from the list. The Asset Management Group also evaluated additional events identified in the ISG. Those events identified for inclusion in the shift staffing analysis were the: Security DBT event; aircraft probable threat event; Control Room fire with evacuation; Station Blackout; and SAMG response prior to augmentation of the on-shift ERO. Other fire response events were not included because they are bounded by the Control Room fire with evacuation event.

The following table identifies the events requiring analysis as identified in Phase I using the NEI 10-05 methodology and by reviewing Chapter 15 of the UFSAR.

Event Plant Reference Summary Description of Event Event ECL Type Mode Document(s)

Land and/or waterborne HOSTILE ACTION directed against the Protected ISG IV.C; Site Area DBT Area by a HOSTILE FORCE. Assume Any AOP-40 Emergency adversary characteristics defined by the Design Basis Threat (DBT).

Response actions for an aircraft probable threat in accordance with 10 CFR ISG IV.C; Site Area ISG 50.54(hh)(1) and as discussed in RG Any AOP-40 Emergency 1.214, Guidance for Assessment of Beyond-Design-Basis Aircraft Impacts Control room fire leading to evacuation ISG IV; ISG and remote shutdown, as referenced in IN Any BNP-E-9.010 Alert 95-48 Results of On-Shift Staffing Study ASSD-02 FSAR,15.7.1; pg.40 General DBA Refueling Accident 5 AOP-05 Emergency Condition IV DBA 0ERP Rev. 089 Att. 1 - Page 3 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Event Plant Reference Summary Description of Event Event ECL Type Mode Document(s)

FSAR, 15.4.6; pg.26 Site Area DBA Control Rod Drop Accident 1-2 Condition IV Emergency DBA FSAR 8.3.1.1.6.1; pg.10 Site Area ISG Station Blackout Any Emergency 1(2)EOP-01-SBO ISG IV.C FSAR, 15.6.3; Main Steam Line Main Steam System pg. 31 General DBA 1-2 Piping Failure Event (MSLB) Condition IV Emergency DBA Large Break Loss of Coolant Accident FSAR, 15.6.4; pg. 26 Site Area -

DBA (LB LOCA) 1-2 General Condition IV Emergency DBA General ISG SAMG Any ISG IV.C Emergency The results of the analysis for each of the scenarios are included in Attachment 2, Event Staffing Analysis Tables. The selection of DBA accidents for inclusion in this assessment was based in part on the guidance contained in the ISG, which states that only DBA accidents which would result in an emergency declaration should be evaluated in the staffing assessment. Each of the plants DBAs was evaluated and classified according to its UFSAR description. Additionally, the projected accident dose rate at the site boundary was considered in classification. In cases where several projected dose rates were provided, the assessment used the radiological consequences associated with the realistic case in accordance with NEI 10-05.

Each scenario was assessed by the cross-disciplinary team to identify the plant actions and emergency plan implementation actions required by plant procedures prior to staff augmentation.

These actions were then compared to the minimum shift staffing as described in the Emergency Plan, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency plan role or their dedicated operational role as appropriate. In cases where multiple tasks were assigned to an individual in their role, the team considered task prioritization and duration to ensure that they could be performed by the individual in series within any specified time requirements.

5. GENERAL ASSUMPTIONS AND LIMITATIONS 5.1 Radiation Protection (RP) and Chemistry The team utilized the analysis approach described by NEI 10-05 to identify tasks assigned to on-shift radiation protection and chemistry technicians. Identified tasks were plotted on a timeline considering task duration and priority.

0ERP Rev. 089 Att. 1 - Page 4 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 The RP and Chemistry tasks reviewed were those directed by the Shift Manager to support actions in Abnormal Operating Procedures (AOPs), Emergency Operating Procedures (EOPs),

and Plant Emergency Procedures (PEPs). Any additional tasks directed by the TSC, Operations Support Center (OSC), or Emergency Operations Facility (EOF) procedures would occur following ERO augmentation and thus were not reviewed.

5.2 Repair and Corrective Action Per the guidance of NUREG-0654, Table B-1, repair and corrective action tasks may be performed by dedicated shift personnel or qualified shift personnel assigned other functions/tasks.

Repair and corrective action is defined as:

An action that can be performed promptly to restore a non-functional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and which does not require work planning or implementation of tag out controls to complete.

In accordance with NEI 10-05, Section 2.5, the OSA included a review of the maintenance and corrective action tasks. These tasks may be performed by personnel having other Emergency Preparedness (EP) functions. For the purpose of this analysis, the tasks were considered to fall into two broad categories:

• Unplanned/unexpected actions that address equipments failures. These actions are contingent in nature and cannot be specified in advance.

• Planned/expected actions performed in support of operating procedure implementation, including severe accident management guidelines.

5.3 Rescue Operations and First Aid In accordance with NEI 10-05, Section 2.6, the analysis also included a review of the Rescue Operations and First Aid responses. These functions may be performed by personnel assigned other EP functions. Rescue Operations and First Aid include the tasks of locating missing personnel, removing them from hazardous areas, if needed, and providing necessary initial medical treatment. These functions are performed by the Fire Brigade.

5.4 10 CFR 50.54(hh) Aircraft Threat The analysis included a review of the implementation of the requirement to maintain continuous communications with the notification source during an aircraft threat in accordance with 10 CFR 50.54(hh) and Regulatory Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. This review identified that there are sufficient personnel on-shift to perform this action during the aircraft event.

5.5 ERO Response Time As stated in NEI 10-05, Section 2.14, the staffing assessment methodology may be used to evaluate proposed changes to on-shift staffing levels or augmented ERO response times. The OSA team utilized the ERO response times identified in the Emergency Plan.

0ERP Rev. 089 Att. 1 - Page 5 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 5.6 NEI 10-05 General Assumptions

1. Response time used for this analysis was the maximum acceptable number of minutes elapsed between emergency declaration and the arrival of an augmented ERO position holder at a location necessary to relieve an on-shift position of the emergency response task.

2. The on-shift personnel complement was limited to the minimum required number and composition as described in the site emergency plan and other site documents. If the plan commitments allow for different minimum staffing levels (e.g., a variance between a normal dayshift and a backshift), the staffing with the smallest total number of personnel was used for the analysis.

3. Although the temporary absence of a position may be allowed by Tech Specs, the analysis was performed assuming that all required on-shift positions are filled.

4. Event occurred during off-normal work hours where ERO was offsite and all required minimum on-shift positions were filled.

5. On-shift personnel reported to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.

6. On-shift staff had necessary Radiation Worker qualification to obtain normal dosimetry and enter the radiological control area (RCA) (but not locked high or very high radiation areas) without the aid of an RP technician.

7. Personnel assigned plant operations and safe shutdown (SSD) met the requirements and guidance (analyzed through other programs such as operator training) and were not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.

8. In-plant (manual) safety-related operator actions to manipulate components and equipment from locations outside the Control Room to achieve and maintain safe shutdown was done by a member of the on-shift staff as defined in the units Tech Specs.

9. Fire brigade (FB) staff performance is analyzed through other station programs (e.g., fire drills) and was not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.

10. Individuals holding the position of RP technician or Chemistry technician are qualified to perform the range of tasks expected of their position.

11. Security was not evaluated unless a role or function from another major response area was assigned as a collateral duty.

12. Communications, briefings, and peer checks are acceptable collateral duties.

13. All on-shift staff positions were evaluated, even if they had no known collateral duties, to ensure they can perform the tasks assigned to them.

14. The OSA specified the resources available to perform Repair and Corrective Actions and Rescue Operations and First Aid, but these may be assigned as collateral duty to a designated on-shift responder.

0ERP Rev. 089 Att. 1 - Page 6 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012

15. For assessment purposes, NRC notifications were treated as a continuous action per 10CFR50.72(c)(3) and 73.71(b)(1). This means once the initial NRC communications are established, the NRC will request that an open line be maintained with the NRC Operations Center.

16. DBA (postulated accident, Condition IV event, or limiting fault) is considered as Unanticipated occurrences that are postulated for accident analysis purposes but not expected to occur during the life of the plant. A postulated accident could result in sufficient damage to preclude resumption of plant operation. As a result, a greater number and variety of actions would need to be implemented by plant personnel.

17. Unless otherwise specified in NSIR/DPR-ISG-01 or by the initial conditions of a DBA analysis, it was assumed that the unit was in Mode 1, Power.

18. DBT assumed a hostile force breached the protected area fence but was neutralized with no adverse consequences to plant safety. Damage inflicted on plant systems, structures and components was not sufficient to prevent safe shutdown or cause a radiological release.

There was no fire significant enough to warrant firefighting efforts prior to arrival of offsite resources and/or the augmented ERO.

19. The OSA used DBA analysis assumptions, inputs, timing of events as documented in the FSAR.

20. In cases where a DBA analysis included a radiological release, and the starting point of the release was not clearly defined, the OSA assumed that the release began at the time of declaration of the initiating event.

21. Severe Accident Management Guideline (SAMG) - It is sufficient to simply assume that the accident progressed to conditions requiring a severe accident response; it did not include determining specific failures and the accident sequence.

22. SAMG - The actions analyzed included those that implement the initial site-specific actions assuming the core is not ex-vessel (i.e., no reactor vessel failure), and there is no actual or imminent challenge to containment integrity.

Reference 2 provides additional information regarding assumptions used in the staffing analysis.

6. CONCLUSIONS presents the minimum shift staffing needed to support the analyzed event scenarios, as identified by the event analysis team. Identified discrepancies were entered into the corrective action program for resolution.

As discussed in Reference 2, three concerns identified during Phase 2 were referred to Phase 3 for further analysis. The results of the Phase 3 analyses are addressed in Reference 2.

The station is required to implement temporary compensatory measures within 30 days following approval of this report and to implement permanent corrective actions within 24 months.

Implementation of the corrective action process may result in the identification of corrective measures (e.g., technological or administrative measures) that will affect the final minimum shift staffing. Any such measures should be validated using the staffing analysis process and this report should be updated to reflect the identified corrective measures.

0ERP Rev. 089 Att. 1 - Page 7 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012

7. ATTACHMENTS Attachment 1, Minimum On-Shift Staffing for Emergency Response ............................................ 9 Attachment 2, Event Staffing Analysis Tables .............................................................................. 11

• Attachment 2A, Design Basis Threat (DBT) 12

• Attachment 2B, Aircraft Probable Threat 17

• Attachment 2C, Control Room Fire With Evacuation 23

• Attachment 2D, Fuel Handling Accident in Mode 5 29

• Attachment 2E, Control Rod Drop 35

• Attachment 2F, Station Blackout (SBO) 41

• Attachment 2G, Steam System Piping Failure 48

• Attachment 2H, Large Break Loss of Coolant Accident (LOCA) 54

• Attachment 2I, SAMG Response Actions 60

8. REFERENCES

1. Title 10, Code of Federal Regulations, Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, US Nuclear Regulatory Commission, November 2011

2. Final Report - NEI 10-05 On-shift Staffing Analysis for the Brunswick Nuclear Plant, Operations Support Services, Inc., December 2012

3. NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Nuclear Energy Institute, June 2011

4. 0ERP, Radiological Emergency Response Plan, Rev. 81, Duke Energy, Inc.,

Brunswick Nuclear Plant

5. NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, US Nuclear Regulatory Commission, November 2011 0ERP Rev. 089 Att. 1 - Page 8 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachment 1 Minimum On-Shift Staffing for Emergency Response 0ERP Rev. 089 Att. 1 - Page 9 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Minimum On-Shift Staffing for Emergency Response Minimum Functional Area Major Tasks Emergency Positions Shift Size Shift Manager (SM) 1

1. Plant Operations and Control Room Supervisor 2 Assessment of Control Room Staff Reactor Operators 4 Operational Aspects Non-Licensed Operators 9 SEC-MCR (SM) 1 (a)

2. Emergency Direction

-- ERM --

and Control SEC-TSC --

3. Notification & Emergency (e)(d)

Non-Licensed Operator 1 Communication Communicator

4. Radiological Offsite Dose Dose Projection Coordinator --

Assessment Assessment Environmental Monitoring Offsite Surveys --

Team Personnel Radiological Control Team Onsite Surveys 1 Personnel In-plant Surveys Health Physics Technician 2 Chemistry Chemistry Technician 2

5. Plant Engineering Technical Support Shift Technical Advisor 1 Repair and Corrective Core Performance Actions Engineering Mechanical Engineering --

Electrical Engineering --

Repair and Mechanical Maintenance 2 Corrective Actions Electrical/I&C Maintenance 3

6. In-Plant Protective Radiation (a)

Health Physics Technician 2 Actions Protection (a)(b)(e)

7. Fire Fighting -- -- 5

8. First Aid and Rescue (a)(f)

-- Plant Personnel 2 Operations Security &

9. Site Access Control Security Team Personnel (c)

Accountability TOTAL (Less Security): 27 (a) May be provided by shift personnel assigned other functions.

(b) Fire Brigade per BNP FPP-031, includes four (4) Fire Brigade members and one (1) Shift Incident Commander (all Non-Licensed Operators)

(c) Per Security Plan (d) Non-Licensed Operators also responsible for Notifications and Communications (1)

(e) Included in census of Non-Licensed Operators above.

(f) 1st Aid & Rescue is a collateral duty of Fire Brigade/Non-Licensed Operators.

0ERP Rev. 089 Att. 1 - Page 10 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachment 2 Event Staffing Analysis Tables 0ERP Rev. 089 Att. 1 - Page 11 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachment 2A: Design Basis Threat (DBT)

1. Event Summary:

A hostile force breaches the Protected Area fence, but is neutralized with no adverse consequences to plant safety.

2. Event Specific Assumptions:

• Security response is per Station Security plan

3. Procedures Reviewed for Accident Response Include:

• 0PEP-2.1 Initial Emergency Actions

• 0PEP-2.1.1 Emergency Control, UE, Alert, SAE, GE

• 0PEP-2.6.21 Emergency Communicator

• 0PEP-2.6.28 Protective Action Recommendations

• 0PEP-3.8.2 Personnel Accountability and Evacuation

• AOP-40 Security Events

• 1(2)EOP-01-RSP Reactor Scram Procedure

• AD-OP-ALL-1000, Fleet Conduct of Operations

• EMG-NGGC-0005 Activation of the Emergency Response Organization Notification System

• Physical Security Plan

• 0ERP Radiological Emergency Response Plan 0ERP Rev. 089 Att. 1 - Page 12 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Analysis #1: DBA/ISG Event #1 - Design Basis Threat ECL: Site Area Emergency TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

T2/L1 T5/L1 T5/L2 T5/L3

1. Shift Manager 0ERP Section 3.1 N/A No No T5/L4 T5 / L5 T5 / L8 T5/L10

2. Unit 1 Supervisor 0ERP Section 3.1 N/A T2/L2 No No

3. Unit 2 Supervisor 0ERP Section 3.1 N/A T2/L3 No No T2/L4

4. Shift Technical Advisor 0ERP Section 3.1 N/A No No T5/L11

5. Reactor Operator #1 0ERP Section 3.1 N/A T2/L5 No No

6. Reactor Operator #2 0ERP Section 3.1 N/A T2/L6 No No

7. Reactor Operator #3 0ERP Section 3.1 N/A T2/L7 No N/A

8. Reactor Operator #4 0ERP Section 3.1 N/A T2/L8 No Yes T5/L6 T5/L7

9. Auxiliary Operator #4 (CREC) 0ERP Section 3.1 N/A T5/L9 No No T5/L13 T5/L14 Auxiliary Operator #9 (CREC

10. 0ERP Section 3.1 N/A T5/L13 No No assist)

11. Security Officer #1 0SI-05 N/A T5/L15 No No

12. Security Officer #2 0SI-05 N/A T5/L16 No No 0ERP Rev. 089 Att. 1 - Page 13 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 2 - Plant Operations & Safe Shutdown Analysis # 1 BNP Nuclear Plant Two Units - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Generic Title/Role Task Analysis Line On-Shift Position Controlling Method Shift Manager Shift Manager Operator Training 1

2 Unit Supervisor #1 Unit 1 CRS Operator Training 3 Unit Supervisor #2 Unit 2 CRS Operator Training 4 Shift Technical Advisor STA Operator Training 5 Reactor Operator #1 Unit 1 RO 1 (OAC) Operator Training 6 Reactor Operator #2 Unit 2 RO 1(OAC) Operator Training 7 Reactor Operator #3 Unit 2 RO 2 (BOP) Operator Training 1

8 Reactor Operator #4 WCC Operator Training TABLE 3 - Firefighting Analysis # 1 Task Analysis Line Performed By Controlling Method 1 None per guidance in NEI 10-05 N/A 0ERP Rev. 089 Att. 1 - Page 14 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 4 - Radiation Protection & Chemistry Analysis # 1 Performance Time Period After Emergency Declaration (minutes)

Line Position Performing Function/Task 0- 5- 10 20 30 40 50 60 70 80- 85-5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 1 In-Plant Survey On-Shift Position: Shift RP Technician 2 On-Site Survey On-Shift Position: Shift RP Technician 3 Personnel Monitoring On-Shift Position:

4 Job Coverage On-Shift Position:

5 Offsite Radiological Assessment On-Shift Position:

6 Other Site-Specific RP - Describe:

On-Shift Position:

7 Chemistry function/task #1 - Describe:

On-Shift Position: Shift Chem Tech 8 Chemistry function/task #2 - Describe:

On-Shift Position: Shift Chem Tech 0ERP Rev. 089 Att. 1 - Page 15 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 5 - Emergency Plan Implementation Analysis # 1 Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Operations Training and 1 Shift Manager Classification Level (ECL) EP Drill Program Approve Offsite Protective Action Operations Training and 2 Shift Manager Recommendations EP Drill Program Approve content of State/local Operations Training and 3 Shift Manager notifications EP Drill Program Approve extension to allowable Operations Training and 4 Shift Manager dose limits EP Drill Program Notification and direction to on-shift Operations Training and 5 staff (e.g., to assemble, evacuate, Shift Manager EP Drill Program etc.)

Operations Training and 6 ERO notification Auxiliary Operator #4 (CREC)

EP Drill Program Abbreviated NRC notification for Operations Training and 7 Auxiliary Operator #4 (CREC)

DBT event EP Drill Program Complete State/local notification Operations Training and 8 Shift Manager form EP Drill Program Operations Training and 9 Perform State/local notifications Auxiliary Operator #4 (CREC)

EP Drill Program Complete NRC event notification Operations Training and 10 Shift Manager form EP Drill Program Operations Training and 11 Activate ERDS Shift Technical Advisor EP Drill Program 12 Offsite radiological assessment N/A N/A Auxiliary Operator #4 (CREC)

Operations Training and 13 Perform NRC notifications Auxiliary Operator #9 if needed EP Drill Program during upgrade Perform other site-specific event Operations Training and 14 Auxiliary Operator #4 (CREC) notifications (e.g., INPO, ANI, etc.) EP Drill Program Security Training and EP 15 Personnel accountability Security Officer #1 Drill Program Security Training and EP 16 Access Control to ERO and TSC Security Officer #2 Drill Program 0ERP Rev. 089 Att. 1 - Page 16 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachment 2B: Aircraft Probable Threat

1. Event Summary:

Notification is received from the NRC that a probable aircraft threat exists (> 5 minutes, < 30 minutes).

2. Event Specific Assumptions:

• Security response is per Station Security plan.

• All non-security on-shift personnel are inside the protected area and at their normal work stations.

3. Procedures Reviewed for Accident Response Include:

• AOP-40 Security Events

• 0PEP-2.1 Initial Emergency Actions

• 0PEP-2.1.1 Emergency Control, UE, Alert, SAE, GE

• AD-OP-ALL-1000, Fleet Conduct of Operations

• EMG-NGGC-0005 Activation of the Emergency Response Organization Notification System

• Physical Security Plan

• 0ERP Radiological Emergency Response Plan 0ERP Rev. 089 Att. 1 - Page 17 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Analysis #2: DBA/ISG Event #2 - Aircraft Probable Threat ECL: Site Area Emergency TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

T2/L1 T5/L1 T5/L2 T5/L3

1. Shift Manager 0ERP Section 3.1 N/A No No T5/L4 T5 / L5 T5 / L8 T5/L10

2. Unit Supervisor #1 0ERP Section 3.1 N/A T2/L2 No No

3. Unit Supervisor #2 0ERP Section 3.1 N/A T2/L3 No No T2/L4

4. Shift Technical Advisor 0ERP Section 3.1 N/A No No T5/L11

5. Reactor Operator #1 0ERP Section 3.1 N/A T2/L5 No No

6. Reactor Operator #2 0ERP Section 3.1 N/A T2/L6 No No T2/L7

7. Reactor Operator #3 0ERP Section 3.1 N/A No No T3 / L1 T2 / L8

8. Auxiliary Operator #1 0ERP Section 3.1 N/A No No T5/L13

9. Auxiliary Operator #2 0ERP Section 3.1 N/A T2 / L9 No No

10. Auxiliary Operator #3 0ERP Section 3.1 N/A T2 / L10 No No T5 / L7 T5 / L9

11. Auxiliary Operator #4 (CREC) 0ERP Section 3.1 N/A No No T5/L13 T5/L14

12. Auxiliary Operator #5 0ERP Section 3.1 T3 / L2 No No N/A

13. Auxiliary Operator #6 0ERP Section 3.1 T3 / L3 No No N/A

14. Auxiliary Operator #7 0ERP Section 3.1 T3 / L4 No No N/A 0ERP Rev. 089 Att. 1 - Page 18 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012

15. Auxiliary Operator #8 0ERP Section 3.1 T3 / L5 No No N/A

16. Auxiliary Operator #9 0ERP Section 3.1 T3 / L6 No No N/A Mechanical Maintenance No

17. 0ERP Section 3.1 N/A T3 / L7 No Technician #1

18. E&RC Technician #1 0ERP Section 3.1 T3 / L8 No No N/A

19. Security Officer #1 0SI-05 T5 / L6 No No N/A

20. Security Officer #2 0SI-05 T5/L15 No No N/A

21. Security Officer #3 0SI-05 T5/L16 No No N/A

22. Security Officer #4 0SI-05 T3/L9 No No N/A 0ERP Rev. 089 Att. 1 - Page 19 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Table 2 Plant Operations & Safe Shutdown Analysis # 2 BNP Nuclear Plant Two Units - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Generic Title/Role Task Analysis Line On-Shift Position Controlling Method 1 Shift Manager Shift Manager Operator Training 2 Unit Supervisor #1 Unit 1 CRS Operator Training 3 Unit Supervisor #2 Unit 2 CRS Operator Training 4 Shift Technical Advisor Shift Technical Advisor Operator Training 5 Reactor Operator #1 Unit 1 RO (OAC) Operator Training 6 Reactor Operator #2 Unit 2 RO (OAC) Operator Training 7 Reactor Operator #3 Unit 1/2 RO (BOP) Operator Training 8 Auxiliary Operator #1 Equipment Operator #1 Operator Training 9 Auxiliary Operator #2 Equipment Operator #2 Operator Training 10 Auxiliary Operator #3 Equipment Operator #3 Operator Training TABLE 3 - Firefighting Analysis # 2 Task Analysis Line Performed By Controlling Method

1. Fire Brigade Advisor (Reactor Operator #3) Firefighter Training Program

2. Auxiliary Operator #5 Firefighter Training Program

3. Auxiliary Operator #6 Firefighter Training Program

4. Auxiliary Operator #7 Firefighter Training Program

5. Auxiliary Operator #8 Firefighter Training Program

6. Auxiliary Operator #9 Firefighter Training Program

7. Mechanical Maintenance Technician #1 Mechanical Maintenance Technician #1

8. E&RC E&RC Training Program

9. Security Officer #4 Security Training Program 0ERP Rev. 089 Att. 1 - Page 20 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 4 - Radiation Protection & Chemistry Analysis # 2 Performance Time Period After Emergency Declaration (minutes)

Line Position Performing Function/Task 0- 5 15 25 35 45 55 65 75 85-5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey N/A - The performance of an in-plant survey is not necessary for initial implementation of the 1 Emergency Plan, and not required by any procedure. In-plant surveys may be dispatched after On-Shift Position: activation of the OSC.

On-Site Survey N/A - The performance of an on-site survey is not necessary for initial implementation of the 2 Emergency Plan, and not required by any procedure. An on-site survey team may be dispatched On-Shift Position: after activation of the OSC.

N/A - Personnel can out-process from the Radiologically Controlled Area (RCA) using portal and Personnel Monitoring small article monitors. On-shift personnel do not require monitoring support in order to perform in-3 On-Shift Position: plant EOP/shutdown actions. If necessary, site evacuees would be monitored at the Remote Monitoring Area after arrival of augmented ERO personnel.

Job Coverage 4

On-Shift Position:

Offsite Radiological Assessment 6 N/A - no radiological release for this event On-Shift Position:

Chemistry function/task #1 -

7 Describe:

On-Shift Position:

Chemistry function/task #2 -

8 Describe:

On-Shift Position:

0ERP Rev. 089 Att. 1 - Page 21 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 5 - Emergency Plan Implementation Analysis # 2 Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Operations Training and 1 Shift Manager Classification Level (ECL) EP Drill Program Approve Offsite Protective Action Operations Training and 2 Shift Manager Recommendations EP Drill Program Approve content of State/local Operations Training and 3 Shift Manager notifications EP Drill Program Approve extension to allowable Operations Training and 4 Shift Manager dose limits EP Drill Program Notification and direction to on-shift Operations Training and 5 staff (e.g., to assemble, evacuate, Shift Manager EP Drill Program etc.)

Security Training and EP 6 ERO notification Security Officer #1 Drill Program Abbreviated NRC notification for Operations Training and 7 Auxiliary Operator #4 (CREC)

DBT event EP Drill Program Complete State/local notification Operations Training and 8 Shift Manager form EP Drill Program Operations Training and 9 Perform State/local notifications Auxiliary Operator #4 (CREC)

EP Drill Program Complete NRC event notification Operations Training and 10 Shift Manager form EP Drill Program Operations Training and 11 Activate ERDS Shift Technical Advisor EP Drill Program 12 Offsite radiological assessment N/A N/A Auxiliary Operator #4 (CREC) Operations Training and 13 Perform NRC notifications 1 Auxiliary Operator #1 EP Drill Program Auxiliary Operator #4 (CREC)

Perform other site-specific event 14 INPO within 60 Min. N/A notifications (e.g., INPO, ANI, etc.)

ANI 240 Min.

Security Training and EP 15 Personnel accountability Security Officer #2 Drill Program Security Training and EP 16 Access Control to ERO and TSC Security Officer #3 Drill Program 0ERP Rev. 089 Att. 1 - Page 22 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachment 2C: Control Room Fire with Evacuation

1. Event Summary:

A fire occurs in the Control Room requiring the room to be evacuated and Remote Shutdown procedures to be implemented.

2. Event Specific Assumptions:

• Assumptions are that the MCR staff has less than five minutes to muster the Fire Brigade and scram the reactor prior to evacuating the MCR.

• There was no other plant damage and all equipment operated from the remote shutdown locations operates as designed.

3. Procedures Reviewed for Accident Response Include:

• 0PEP-2.1 Initial Emergency Actions

• 0PEP-2.1.1 Emergency Control, UE, Alert, SAE, GE

• 0PEP-2.6.21 Emergency Communicator

• 0PEP-3.8.2 Personnel Accountability and Evacuation

• PFP-013 General Fire Plan

• FPP-031 Fire Brigade Staffing roster and Equipment Requirements

• ASSD-01 Alternative Safe Shutdown Procedure Index

• ASSD-02 Control Building

• 1(2)EOP-01-RSP Reactor Scram Procedure

• AD-OP-ALL-1000, Fleet Conduct of Operations

• EMG-NGGC-0005 Activation of the Emergency Response Organization Notification System

• Physical Security Plan

• 0ERP Radiological Emergency Response Plan 0ERP Rev. 089 Att. 1 - Page 23 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Analysis #3: DBA/ISG Event # 3 - Control Room Fire with Evacuation ECL: Alert TABLE 1 - On-shift Positions Emergency Plan Augmentation Role in Unanalyzed TMS Line On-shift Position Reference Elapsed Time (min) Table#/Line# Task? Required?

T2/L1 T5/L1 T5/L2

1. Shift Manager 0ERP Section 3.1 N/A No No T5/L3 T5/L4 T5/L5

2. Unit Supervisor #1 0ERP Section 3.1 N/A T2/L2 No No

3. Unit Supervisor #2 0ERP Section 3.1 N/A T2/L3 No No T2/L4

4. Shift Technical Advisor 0ERP Section 3.1 N/A No Yes T5/L11

5. Reactor Operator #1 0ERP Section 3.1 N/A T2/L5 No No

6. Reactor Operator #2 0ERP Section 3.1 N/A T2/L6 No No Reactor Operator #3 (Per FPP-031, is not required to T2/L7

7. 0ERP Section 3.1 N/A No No respond as FB advisor in T3/L1 ASSD-02 and 05 Fire)

8. Auxiliary Operator #1 0ERP Section 3.1 N/A T2/L8 No No

9. Auxiliary Operator #2 0ERP Section 3.1 N/A T2/L9 No No

10. Auxiliary Operator #3 0ERP Section 3.1 N/A T2/L10 No No T5/L81 T5/L9

11. Auxiliary Operator #4 (CREC) 0ERP Section 3.1 N/A T5/L101 No No T5/L13 T5/L14

12. Auxiliary Operator #5 0ERP Section 3.1 N/A T3/L2 No No

13. Auxiliary Operator #6 0ERP Section 3.1 N/A T3/L3 No No

14. Auxiliary Operator #7 0ERP Section 3.1 N/A T3/L4 No No 0ERP Rev. 089 Att. 1 - Page 24 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Emergency Plan Augmentation Role in Unanalyzed TMS Line On-shift Position Reference Elapsed Time (min) Table#/Line# Task? Required?

15. Auxiliary Operator #8 0ERP Section 3.1 N/A T3/L5 No No

16. Auxiliary Operator #9 0ERP Section 3.1 N/A T3/L6 No No Mechanical Maintenance

17. 0ERP Section 3.1 N/A T3/L7 No No Technician #1 T3/L8

18. E&RC Technician #1 0ERP Section 3.1 N/A No No T4/L6

19. Security Officer #1 0SI-05 N/A T5/L6 No No

20. Security Officer #2 0SI-05 N/A T5/L15 No No

21. Security Officer #3 0SI-05 N/A T5/L16 No No

22. Security Officer #4 0SI-05 N/A T5/L17 No No

23. Security Officer #5 0SI-05 N/A T5/L18 No No

24. Security Officer #6 0SI-05 N/A T3/L9 No No 0ERP Rev. 089 Att. 1 - Page 25 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Table 2 Plant Operations & Safe Shutdown Analysis # 3 BNP Nuclear Plant Two Units - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Generic Title/Role Task Analysis Line On-Shift Position Controlling Method Site Emergency

1. Shift Manager Operator Training Coordinator

2. Unit Supervisor #1 Unit 1 CRS Operator Training

3. Unit Supervisor #2 Unit 2 CRS Operator Training

4. Shift Technical Advisor STA Operator Training Unit 1 Rx Bldg. MCC

5. Reactor Operator #1 Operator Training Operator Unit 2 Rx Bldg. MCC

6. Reactor Operator #2 Operator Training Operator Unit 1/Unit 2 RO BOP;

7. Reactor Operator #3 Operator Training FB Advisor

8. Auxiliary Operator #1 Diesel Operator Operator Training Emergency Switchgear

9. Auxiliary Operator #2 Operator Training Operator Service Water Building

10. Auxiliary Operator #3 Operator Training Operator TABLE 3 - Firefighting Analysis # 3 Task Analysis Line Performed By Controlling Method

1. Reactor Operator #3 Firefighter Training Program

2. Auxiliary Operator #5 Firefighter Training Program

3. Auxiliary Operator #6 Firefighter Training Program

4. Auxiliary Operator #7 Firefighter Training Program

5. Auxiliary Operator #8 Firefighter Training Program

6. Auxiliary Operator #9 Firefighter Training Program

7. Mechanical Maintenance Technician #1 Mechanical Maintenance Training Program

8. E&RC Technician #1 E&RC Technical Training Program

9. Security Officer #6 Security Training Program 0ERP Rev. 089 Att. 1 - Page 26 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 4 - Radiation Protection & Chemistry Analysis # 3 Performance Time Period After Emergency Declaration (minutes)

Lin Position Performing Function/Task 0- 5 15 25 35 45 55 65 75 85-e 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 N/A - The performance of an in-plant survey is not necessary for initial implementation of the In-Plant Survey Emergency Plan, and not required by any procedure. On-shift personnel do not require in-plant 1.

On-Shift Position: surveys in order to perform in-plant ASSD / Shutdown actions. An in-plant survey team may be dispatched after activation of the OSC On-Site Survey

2. N/A - No radiological release for this event.

On-Shift Position:

N/A - Personnel can out-process from the Radiologically Controlled Area (RCA) using portal and Personnel Monitoring small article monitors. On-shift personnel do not require monitoring support in order to perform in-3.

On-Shift Position: plant EOP/shutdown actions. If necessary, site evacuees would be monitored at the Remote Monitoring Area after arrival of augmented ERO personnel.

Job Coverage N/A - The performance of job coverage is not necessary for initial implementation of the Emergency

4. Plan, and not required by any procedures. On-shift personnel do not require job coverage in order to On-Shift Position: perform in-plant ASSD / shutdown actions.

Offsite Radiological Assessment

5. N/A - No radiological release for this event.

On-Shift Position:

Other Site Specific RP. Fire Brigade

6. Support X X X X X X X X X X X X X X X X X X On-Shift Position: RP Technician #1 0ERP Rev. 089 Att. 1 - Page 27 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 5 - Emergency Plan Implementation Analysis # 3 Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Operations Training and 1 Shift Manager Classification Level (ECL) EP Drill Program Approve Offsite Protective Action Operations Training and 2 Shift Manager Recommendations EP Drill Program Approve content of State/local Operations Training and 3 Shift Manager notifications EP Drill Program Approve extension to allowable Operations Training and 4 Shift Manager dose limits EP Drill Program Notification and direction to on-shift Operations Training and 5 staff (e.g., to assemble, evacuate, Shift Manager EP Drill Program etc.)

Security Officer #1 - From Security Training and EP 6 ERO notification SAS/ CAS Drill Program Abbreviated NRC notification for 7 N/A N/A DBT event Auxiliary Operator #4 (CREC)

Complete State/local notification Operations Training and 8 in TSC as directed by SM at form EP Drill Program RSDP Operations Training and 9 Perform State/local notifications Auxiliary Operator #4 (CREC)

EP Drill Program Auxiliary Operator #4 (CREC)

Complete NRC event notification Operations Training and 10 in TSC as directed by SM at form EP Drill Program RSDP Shift Technical Advisor from Operations Training and 11 Activate ERDS TSC EP Drill Program 12 Offsite radiological assessment N/A N/A Operations Training and 13 Perform NRC notifications Auxiliary Operator #4 (CREC)

EP Drill Program Perform other site-specific event 14 Auxiliary Operator #4 (CREC) N/A notifications (e.g., INPO, ANI, etc.)

Security Training and EP 15 Personnel accountability Security Officer #2 Drill Program Security Training and EP 16 Access Control to ERO and TSC Security Officer #3 Drill Program Security Training and EP 17 Emergency Vehicle Escort Security Officer #4 Drill Program Security Training and EP 18 Perimeter Control Security Officer #5 Drill Program 0ERP Rev. 089 Att. 1 - Page 28 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachment 2D: Fuel Handling Accident in Mode 5

1. Event Summary:

A spent fuel bundle is assumed to drop from the Refueling Platform grapple and land on the upper Rx Core guide. Notification from the refueling platform SRO is received, coincident with high Refuel floor, and Rx Bldg. effluent monitor alarms.

2. Event Specific Assumptions:

• There was no other plant damage and all equipment operates as designed.

3. Procedures Reviewed for Accident Response Include:

• 0PEP-2.1 Initial Emergency Actions

• 0PEP-2.1.1 Emergency Control, UE, Alert, SAE, GE

• 0PEP-2.6.21 Emergency Communicator

• 0PEP-2.6.28 Protective Action Recommendations

• 0PEP-3.8.2 Personnel Accountability and Evacuation

• 0PEP-03.7.7 Onsite Radio0logical Controls

• AOP-05 Radioactive Spills, High Radiation, and Airborne Activity

• 0AOP-05.4, Radiological Release

• AD-OP-ALL-1000, Fleet Conduct of Operations

• EMG-NGGC-0005 Activation of the Emergency Response Organization Notification System

• Physical Security Plan

• 0ERP Radiological Emergency Response Plan 0ERP Rev. 089 Att. 1 - Page 29 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Analysis #4: DBA/ISG Event - Fuel Handling Accident During Refueling Mode 5 ECL: General Emergency TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

T2/L1 T5/L1 T5/L2 T5/L3

1. Shift Manager BNP 0ERP; Figure 3-1 N/A No No T5/L4 T5/L5 T5/L8 T5/L10

2. Control Room Supervisor (SRO) BNP 0ERP; Figure 3-1 N/A T2/L2 No No T2/L3

3. Shift Technical Advisor BNP 0ERP; Figure 3-1 N/A No No T5/L11

4. Reactor Operator #1 (OAC) BNP 0ERP; Figure 3-1 N/A T2/L4 No No

5. Reactor Operator #2 (BOP) BNP 0ERP; Figure 3-1 N/A T2/L5 No No

6. Auxiliary Operator #1 BNP 0ERP; Figure 3-1 N/A T2/L6 No No T5/L9

7. Auxiliary Operator #4 (CREC) BNP 0ERP; Figure 3-1 N/A T5/L13 No No T5/L14 0ERP Rev. 089 Att. 1 - Page 30 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

8. Auxiliary Operator #5 BNP 0ERP; Figure 3-1 N/A T5/L13 No No T4/L1

9. Health Physics Technician #1 BNP 0ERP; Figure 3-1 N/A No No T4/L2

10. Health Physics Technician #2 BNP 0ERP; Figure 3-1 N/A T4/L3 No No

11. Health Physics Technician #3 BNP 0ERP; Figure 3-1 N/A T4/L4 No No T4/L6

12. Chemistry Technician #1 BNP 0ERP; Figure 3-1 N/A No No T4/L7

13. Chemistry Technician #2 BNP 0ERP; Figure 3-1 N/A No No T4/L8 T5/L6

14. Security BNP 0ERP; Figure 3-1 N/A No No T5/L15

15. Unaffected Unit CRS BNP 0ERP; Figure 3-1 N/A T5/L12 No No 0ERP Rev. 089 Att. 1 - Page 31 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Table 2 Plant Operations & Safe Shutdown Analysis # 4 BNP Nuclear Plant Two Units - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Performance Line Generic Title/Role On-Shift Position Validation

1. Shift Manager Shift Manager Operator Training

2. Unit Supervisor Control Room Supervisor (SRO) Operator Training

3. Shift Technical Advisor Shift Technical Advisor Operator Training

4. Reactor Operator #1 Reactor Operator #1 (OAC) Operator Training

5. Reactor Operator #2 Reactor Operator #2 (BOP) Operator Training

6. Auxiliary Operator #1 Auxiliary Operator #1 Operator Training TABLE 3 - Firefighting Analysis # 4 Task Analysis Line Performed By Controlling Method 1 No actions required for this event NA 0ERP Rev. 089 Att. 1 - Page 32 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 4 - Radiation Protection & Chemistry Analysis # 4 Performance Time Period After Emergency Declaration (minutes)

Line Position Performing Function/Task 0- 5- 10 20 30 40 50 60 70- 75- 80- 85-5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90

1. In-Plant Survey: Perform Surveys &

air sampling of affected area to determine reentry for damage X X X X X X assessment.

On-Shift Position: Shift HP Tech #1

2. On-Site Survey: On-Shift Position:

X X X X X X Shift Health Physics Technician #1

3. Personnel Monitoring: Post and control access to the affected area to reduce exposure and contamination X X X X X X X X X X X X X X X per applicable RP procedure AOP-05.

On-Shift Position: Shift HP Tech #2

4. Job Coverage: Chemistry Tech pulling Main Stack Effluent Sample X X X X X X On-Shift Position: Shift HP Tech #3

5. Offsite Radiological Assessment Performed by Unaffected Unit CRS - Ref. Table 5 On-Shift Position: Chemistry Tech

6. Chemistry function/task #1 Obtain Main Stack Effluent sample (30 min.) and analyze for release (30 X X X X X X X X X X X X min.) as directed by EOP-04 On-Shift Position: Shift Chem Tech #1

7. Chemistry function/task #2 Obtain Noble Gas Dose Rate and X X X X provide to MCR per EOP-04 On-Shift Position: Shift Chem Tech #2

8. Chemistry function/task #3 Sample and program Turbine WRGM Set points following realignment to X X X X X X X X X X X recirculation per EOP-04 On-Shift Position:Shift Chem Tech #2 0ERP Rev. 089 Att. 1 - Page 33 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 5 - Emergency Plan Implementation Analysis # 4 Task Analysis Line Function/Task On-Shift Position Controlling Method

1. Declare the Emergency EP/Ops Training and EP Shift Manager Classification Level (ECL) Drill Program

2. Approve Offsite Protective Shift Manager NA Action Recommendations

3. Approve content of State/local EP/Ops Training and EP Shift Manager notifications Drill Program

4. Approve extension to allowable Shift Manager NA dose limits

5. Notification and direction to on-Shift Manager EP/Ops Training and EP shift staff (e.g., to assemble, Drill Program evacuate, etc.)

6. EP/Ops Training and EP ERO notification Security Drill Program

7. Abbreviated NRC notification NA NA for DBT event

8. Complete State/local EP/Ops Training and EP Shift Manager notification form Drill Program

9. EP/Ops Training and EP Perform State/local notifications Auxiliary Operator #4 (CREC)

Drill Program

10. Complete NRC event EP/Ops Training and EP Shift Manager notification form Drill Program

11. EP/Ops Training and EP Activate ERDS Shift Technical Advisor Drill Program

12. Unaffected Unit CRS EP/Ops Training and EP Offsite radiological assessment Drill Program

13. Auxiliary Operator #4 (CREC) EP/Ops Training and EP Perform NRC notifications Auxiliary Operator #5 as req. Drill Program

14. Perform other site-specific event notifications (e.g., INPO, Auxiliary Operator #4 (CREC) N/A 1

ANI, etc.)

15. Personnel accountability Security Physical Security Plan 0ERP Rev. 089 Att. 1 - Page 34 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachment 2E: Control Rod Drop

1. Event Summary:

A single control rod drops out of the core to the full out rod drive position after becoming unlatched from the control rod drive.

2. Event Specific Assumptions:

• The control rod drop occurs subsequent to the withdrawal of the control rod to the sequence planned position 48.

3. Procedures Reviewed for Accident Response Include:

• 0PEP-2.1 Initial Emergency Actions

• 0PEP-2.1.1 Emergency Control, UE, Alert, SAE, GE

• 0PEP-2.6.21 Emergency Communicator

• 0PEP-2.6.28 Protective Action Recommendations

• 0PEP-3.8.2 Personnel Accountability and Evacuation

• 0E&RC 1006, Routine RCS, RHR Hx sampling

• 0E&RC-1505 PASS Sampling

• AD-OP-ALL-1000, Fleet Conduct of Operations

• EMG-NGGC-0005 Activation of the Emergency Response Organization Notification System

• Physical Security Plan

• 0ERP Radiological Emergency Response Plan 0ERP Rev. 089 Att. 1 - Page 35 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Analysis #5: DBA/ISG Event - Control Rod Drop ECL: Site Area Emergency TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

T2/L1 T5/L1 T5/L3

1. Shift Manager BNP 0ERP; Figure 3-1 N/A No No T5/L5 T5/L8 T5/L10

2. Control Room Supervisor (SRO) BNP 0ERP; Figure 3-1 N/A T2/L2 No No T2/L3

3. Shift Technical Advisor BNP 0ERP; Figure 3-1 N/A T5/L11 No No

4. Reactor Operator #1 (OAC) BNP 0ERP; Figure 3-1 N/A T2/L4 No No

5. Reactor Operator #2 (BOP) BNP 0ERP; Figure 3-1 N/A T2/L5 No No

6. Auxiliary Operator #1 BNP 0ERP; Figure 3-1 N/A T2/L6 No No T5/L9

7. Auxiliary Operator #4 (CREC) BNP 0ERP; Figure 3-1 N/A T5/L13 No No T5/L14

8. Auxiliary Operator #5 BNP 0ERP; Figure 3-1 N/A T5/L13 No No 0ERP Rev. 089 Att. 1 - Page 36 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

9. Unaffected U1 CRS BNP 0ERP; Figure 3-1 N/A T5/L12 No No

10. Health Physics Technician #1 BNP 0ERP; Figure 3-1 N/A T4/L1 No No

11. Health Physics Technician #2 BNP 0ERP; Figure 3-1 N/A T4/L4 No No

12. Chemistry Technician #1 BNP 0ERP; Figure 3-1 N/A T4/L6 No No N/A T4/L7

13. Chemistry Technician #2 BNP 0ERP; Figure 3-1 No No T4/L8 T5/L6

14. Security BNP 0ERP; Figure 3-1 NA No No T5/L15 0ERP Rev. 089 Att. 1 - Page 37 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Table 2 Plant Operations & Safe Shutdown Analysis # 5 BNP Nuclear Plant Two Units - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Performance Line Generic Title/Role On-Shift Position Validation

1. Shift Manager Shift Manager Operator Training

2. Unit Supervisor Control Room Supervisor (SRO) Operator Training

3. Shift Technical Advisor Shift Technical Advisor Operator Training

4. Reactor Operator #1 Reactor Operator #1 (OAC) Operator Training

5. Reactor Operator #2 Reactor Operator #2 (BOP) Operator Training

6. Auxiliary Operator #1 Auxiliary Operator #1 Operator Training TABLE 3 - Firefighting Analysis # 5 Task Analysis Line Performed By Controlling Method 1 No actions required for this event NA 0ERP Rev. 089 Att. 1 - Page 38 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 4 - Radiation Protection & Chemistry Analysis # 5 Performance Time Period After Emergency Declaration (minutes)

Line Position Performing Function/Task 0- 5 15 25 35 45 55 65 75- 80- 85-5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey: On-Shift Position: Shift 1 X X X X X X Health Physics Technician #1 N/A - The performance of an on-site survey is not necessary for initial implementation of the On-Site Survey: On-Shift Position: Shift 2 Emergency Plan, and not required by any procedure. An on-site survey team may be dispatched Health Physics Technician after activation of the OSC.

N/A - Personnel can out-process from the Radiologically Controlled Area (RCA) using portal and Personnel Monitoring: On-Shift Position: Shift small article monitors. On-shift personnel do not require monitoring support in order to perform in-3 Health Physics Technician plant EOP/shutdown actions. If necessary, site evacuees would be monitored at the Remote Monitoring Area after arrival of augmented ERO personnel.

Job Coverage: Chemistry Tech pulling Main Stack Effluent Sample 4 X X X X X X X X X X X X On-Shift Position: Shift Health Physics Technician #2 Offsite Radiological Assessment 5 Performed by Unaffected Unit CRS - Ref. Table 5 On-Shift Position: Chemistry Tech Chemistry function/task #1 Obtain Main Stack Effluent sample (30 min.)

6 and analyze for release (30 min.) as directed X X X X X X X X X X X X X X X by EOP-04 On-Shift Position: Shift Chem Technician #1 Chemistry function/task #2 Obtain Noble Gas Dose Rate and provide to 7 X X X X X MCR as directed by EOP-04 On-Shift Position: Shift Chem Technician #2 Chemistry function/task #3 Program Turbine WRGM Set points following 8 realignment to recirculation as directed by X X X X X X X X X X X EOP-04 On-Shift Position: Shift Chem Technician #2 0ERP Rev. 089 Att. 1 - Page 39 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 5 - Emergency Plan Implementation Analysis # 5 Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency EP/Ops Training and EP 1 Shift Manager Classification Level (ECL) Drill Program Approve Offsite Protective 2 NA NA Action Recommendations Approve content of State/local EP/Ops Training and EP 3 Shift Manager notifications Drill Program Approve extension to allowable 4 NA NA dose limits Notification and direction to on-EP/Ops Training and EP 5 shift staff (e.g., to assemble, Shift Manager Drill Program evacuate, etc.)

Security Training and EP 6 ERO notification Security Drill Program Abbreviated NRC notification 7 NA NA for DBT event Complete State/local EP/Ops Training and EP 8 Shift Manager notification form Drill Program EP/Ops Training and EP 9 Perform State/local notifications Auxiliary Operator 4 (CREC)

Drill Program Complete NRC event EP/Ops Training and EP 10 Shift Manager notification form Drill Program EP/Ops Training and EP 11 Activate ERDS Shift Technical Advisor Drill Program EP/Ops Training and EP 12 Offsite radiological assessment Unaffected U1 CRS Drill Program Auxiliary Operator 4 (CREC) EP/Ops Training and EP 13 Perform NRC notifications Auxiliary Operator #5 as req. Drill Program Perform other site-specific 14 Auxiliary Operator 4 (CREC) N/A event notifications Physical Security Plan 15 Personnel accountability Security 0ERP Rev. 089 Att. 1 - Page 40 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachment 2F: Station Blackout (SBO)

1. Event Summary:

A Loss of all Off-Site power occurs.

2. Event Specific Assumptions:

• Only EDG #2 starts and synchronizes to 4160 Emergency Bus E2.

• There was no other plant damage and all equipment operates as designed.

3. Procedures Reviewed for Accident Response Include:

• 0PEP-2.1 Initial Emergency Actions

• 0PEP-2.1.1 Emergency Control, UE, Alert, SAE, GE

• 0PEP-2.6.21 Emergency Communicator

• 0PEP-2.6.28 Protective Action Recommendations

• 0PEP-3.8.2 Personnel Accountability and Evacuation

• 1(2)EOP-01-SBO, Station Blackout

• 1(2)EOP-01-RSP Reactor Scram Procedure

• 1(2)EOP-01-RVCP Reactor Vessel Control Procedure

• 1(2)EOP-04 RRCP Radiation Release Control Procedure

• 0E&RC 1006 Routine RCS, RHR Hx sampling

• 0E&RC-1706 TB OTV alignment

• AD-OP-ALL-1000, Fleet Conduct of Operations

• EMG-NGGC-0005 Activation of the Emergency Response Organization Notification System

• Physical Security Plan

• 0ERP Radiological Emergency Response Plan 0ERP Rev. 089 Att. 1 - Page 41 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Analysis #6: DBA/ISG Event # 6 - SBO ECL: Site Area Emergency TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

T2/L1 T5/L1 T5/L2 T5/L3

1. Shift Manager 0ERP Section 3.1 N/A No No T5/L4 T5/L5 T5/L8 T5/L10

2. Unit Supervisor #1 0ERP Section 3.1 N/A T2/L2 No No

3. Unit Supervisor #2 0ERP Section 3.1 N/A T2/L3 No No T2/L4

4. Shift Technical Advisor 0ERP Section 3.1 N/A No No T5/L11

5. Reactor Operator #1 0ERP Section 3.1 N/A T2/L5 No No

6. Reactor Operator #2 0ERP Section 3.1 N/A T2/L6 No No

7. Reactor Operator #3 0ERP Section 3.1 N/A T2/L7 No Yes

8. Auxiliary Operator #1 0ERP Section 3.1 N/A T2/L8 No No

9. Auxiliary Operator #2 0ERP Section 3.1 N/A T2/L9 No No

10. Auxiliary Operator #3 0ERP Section 3.1 N/A T2/L10 No No T5 /L9

11. Auxiliary Operator #4 (CREC) 0ERP Section 3.1 N/A T5/L13 No No T5/L14

12. Auxiliary Operator #5 0ERP Section 3.1 N/A T2/L11 N/A N/A

13. Auxiliary Operator #6 0ERP Section 3.1 N/A T2/L12 N/A N/A

14. Auxiliary Operator #7 0ERP Section 3.1 N/A T2/L13 N/A N/A 0ERP Rev. 089 Att. 1 - Page 42 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

15. Auxiliary Operator #8 0ERP Section 3.1 N/A T5/L13 N/A N/A T4/L1 No No N/A

16. HP Technician #1 0ERP Section 3.1 T4/L5 T4/L6

17. HP Technician #2 0ERP Section 3.1 T4/L2 No No N/A

18. HP Technician #3 0ERP Section 3.1 T4/L4 No No N/A T4/L8 N/A

19. Chemistry Technician #1 0ERP Section 3.1 T4/L9 No No T4/L12 N/A T4/L10

20. Chemistry Technician #2 0ERP Section 3.1 No No T4/L11

21. Security Officer #1 0SI-05 N/A T5/L6 No No

22. Security Officer #2 0SI-05 N/A T5/L15 No No

23. Security Officer #3 0SI-05 N/A T5/L16 No No 0ERP Rev. 089 Att. 1 - Page 43 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Table 2 Plant Operations & Safe Shutdown Analysis # 6 BNP Nuclear Plant Two Units - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Generic Title/Role Task Analysis Line On-Shift Position Controlling Method Shift Manager

1. Shift Manager Operator Training

2. Unit Supervisor #1 Unit 1 CRS Operator Training

3. Unit Supervisor #2 Unit 2 CRS Operator Training

4. Shift Technical Advisor Shift Technical Advisor Operator Training RO1 Unit 1 OAC

5. Reactor Operator #1 Operator Training Operator RO2 Unit 1 BOP

6. Reactor Operator #2 Operator Training Operator RO3 Unit 2 OAC

7. Reactor Operator #3 Operator Training Operator

8. Auxiliary Operator #1 RB2 Equip Operator Operator Training

9. Auxiliary Operator #2 TB2 Equip Operator Operator Training

10. Auxiliary Operator #3 Outside Equip Operator Operator Training

11. Auxiliary Operator #5 RB1 Equip Operator Operator Training

12. Auxiliary Operator #6 TB1 Equip Operator Operator Training

13. Auxiliary Operator #7 WCC Auxiliary Operator Operator Training TABLE 3 - Firefighting Analysis # 6 Task Analysis Line Performed By Controlling Method 1 No actions required for this event NA 0ERP Rev. 089 Att. 1 - Page 44 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 4 - Radiation Protection & Chemistry Analysis # 6 Performance Time Period After Emergency Declaration (minutes)

Line Position Performing Function/Task 0- 5 15 25 35 45 55 65 75- 80- 85-5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90

1. In-Plant Survey: Perform RB surveys. On-Shift Position: Shift Health Physics Technician X X X

1. 1. Would also perform survey areas covered in line 5 and 6.

2. On-Site Survey: Perform Field Surveys for unmonitored release. On-Shift Position: Shift X X X X X X Health Physics Technician #2

3. Personnel Monitoring: On-Shift Position: Shift N/A - Personnel can out-process from the Radiologically Controlled Area (RCA) using portal and Health Physics Technician small article monitors. On-shift personnel do not require monitoring support in order to perform in-plant EOP/shutdown actions. If necessary, site evacuees would be monitored at the Remote Monitoring Area after arrival of augmented ERO personnel.

4. Job Coverage: Chemistry Tech pulling Main Stack Effluent Sample X X X X X X On-Shift Position: Shift Health Physics Technician #3.

5. Job Coverage: Operations verify RB Ventilation dampers closed. On-Shift X X X X Position: Shift Health Physics Technician #1 performed concurrent with line 1

6. Job Coverage: Operations defeat HPCI/RCIC auto swap (open breakers in RB). On-Shift X X X X Position: Shift Health Physics Technician #1 concurrent with line 1

7. Offsite Radiological Assessment Performed by Unaffected Unit CRS - Ref. Table 5 On-Shift Position: Chemistry Tech

8. Chemistry function/task #1 Initiate Alternate Sampling for loss of power to X X X X X X station Radiation Monitors On-Shift Position: Shift Chem Technician #1

9. Chemistry function/task #2 Obtain Noble Gas Dose Rate and provide to X X X X MCR as directed by EOP-04 On-Shift Position: Shift Chem Technician #1 0ERP Rev. 089 Att. 1 - Page 45 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Line Position Performing Function/Task Performance Time Period After Emergency Declaration (minutes)

10. Chemistry function/task #3 Obtain Main Stack Effluent sample (30 min.)

X X X X X X as directed by EOP-04 On-Shift Position: Shift Chem Technician #2

11. Chemistry function/task #4 Analyze Main Stack Effluent sample (30 min.)

X X X X X X as directed by EOP-04 On-Shift Position: Shift Chem Technician #2

12. Chemistry function/task #5 Program Turbine WRGM Set points following realignment to recirculation as directed by X X X X X X EOP-04 On-Shift Position: Shift Chem Technician #1 0ERP Rev. 089 Att. 1 - Page 46 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 5 - Emergency Plan Implementation Analysis # 6 Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Operations Training and 1 Shift Manager Classification Level (ECL) EP Drill Program Approve Offsite Protective Action Operations Training and 2 Shift Manager Recommendations EP Drill Program Approve content of State/local Operations Training and 3 Shift Manager notifications EP Drill Program Approve extension to allowable Operations Training and 4 Shift Manager dose limits EP Drill Program Notification and direction to on-shift Operations Training and 5 staff (e.g., to assemble, evacuate, Shift Manager EP Drill Program etc.)

Operations Training and 6 ERO notification Security Officer #1 EP Drill Program Abbreviated NRC notification for 7 N/A N/A DBT event Complete State/local notification Operations Training and 8 Shift Manager form EP Drill Program Operations Training and 9 Perform State/local notifications Auxiliary Operator #4 (CREC)

EP Drill Program Complete NRC event notification Operations Training and 10 Shift Manager form EP Drill Program Operations Training and 11 Activate ERDS Shift Technical Advisor EP Drill Program 12 Offsite radiological assessment N/A N/A Auxiliary Operator #4 (CREC) Operations Training and 13 Perform NRC notifications Auxiliary Operator #8 EP Drill Program Perform other site-specific event 14 Auxiliary Operator #4 (CREC) N/A notifications (e.g., INPO, ANI, etc.)

Security Training and EP 15 Personnel accountability Security Officer #2 Drill Program Security Training and EP 16 Access Control to ERO and TSC Security Officer #3 Drill Program 0ERP Rev. 089 Att. 1 - Page 47 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachment 2G: Steam System Piping Failure

1. Event Summary:

Unit 2 A Main Steam Line ruptures in Turbine Building in area outside MSL Tunnel but upstream of steam bypass header.

2. Event Specific Assumptions:

• Group 1 isolation on High Steam Flow or High Turbine Building Temperature

• Rx Scram initiated by MSIV limit switch position - All control rods insert successfully

3. Procedures Reviewed for Accident Response Include:

• 0PEP-2.1 Initial Emergency Actions

• 0PEP-2.1.1 Emergency Control, UE, Alert, SAE, GE

• 0PEP-2.6.21 Emergency Communicator

• 0PEP-2.6.28 Protective Action Recommendations

• 0PEP-3.8.2 Personnel Accountability and Evacuation

• 1(2)EOP-01-RSP Reactor Scram Procedure

• 1(2)EOP-01-RVCP Reactor Vessel Control Procedure

• 0AOP-05.4, Radiological Release

• 0E&RC 1006 Routine RCS, RHR Hx sampling

• 0E&RC-1505 PASS Sampling

• 0E&RC-1706 TB OTV Alignment

• AD-OP-ALL-1000, Fleet Conduct of Operations

• EMG-NGGC-0005 Activation of the Emergency Response Organization Notification System

• Physical Security Plan

• 0ERP Radiological Emergency Response Plan 0ERP Rev. 089 Att. 1 - Page 48 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Analysis #7: DBA/ISG Event #7 - Steam System Piping Failure ECL: General Emergency (Radiological Consequence)

TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

T2/L1 T5/L1 T5/L2 T5/L3

1. Shift Manager BNP 0ERP; Figure 3-1 N/A No No T5/L4 T5/L5 T5/L8 T5/L10

2. Control Room Supervisor (SRO) BNP 0ERP; Figure 3-1 N/A T2/L2 No No

3. Unaffected Unit Control Room BNP 0ERP; Figure 3-1 N/A T5/L12 No No Supervisor (SRO)

4. T2/L3 Shift Technical Advisor BNP 0ERP; Figure 3-1 N/A No No T5/L11

5. Reactor Operator #1 (OAC) BNP 0ERP; Figure 3-1 N/A T2/L4 No No

6. T2/L5 Reactor Operator #2 (BOP) BNP 0ERP; Figure 3-1 N/A No No T5/L5

7. Auxiliary Operator #2 BNP 0ERP; Figure 3-1 N/A T2/L6 No No 0ERP Rev. 089 Att. 1 - Page 49 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

8. T5/L9 Auxiliary Operator #4 (CREC) BNP 0ERP; Figure 3-1 N/A T5/L13 No No T5/L14

9. Auxiliary Operator #5 BNP 0ERP; Figure 3-1 N/A T5/L13 No No

10. Health Physics Technician #1 BNP 0ERP; Figure 3-1 N/A T4/L1 No No

11. Health Physics Technician #2 BNP 0ERP; Figure 3-1 N/A T4/L2 No No

12. Health Physics Technician #3 BNP 0ERP; Figure 3-1 N/A T4/L4 No No

13. Chemistry Technician #1 BNP 0ERP; Figure 3-1 N/A T4/L6 No No

14. T4/L7 Chemistry Technician #2 BNP 0ERP; Figure 3-1 N/A No No T4/L8

15. T5/L6 Security BNP 0ERP; Figure 3-1 N/A No No T5/L15 0ERP Rev. 089 Att. 1 - Page 50 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 2 Plant Operations & Safe Shutdown Analysis # 7 BNP Nuclear Plant Two Units - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Performance Line Generic Title/Role On-Shift Position Validation

1. Shift Manager Shift Manager Operator Training

2. Unit 2 Supervisor Control Room Supervisor 2 (SRO) Operator Training

3. Shift Technical Advisor Shift Technical Advisor Operator Training

4. Reactor Operator #1 Reactor Operator #1 (OAC) Operator Training

5. Reactor Operator #2 Reactor Operator #2 (BOP) Operator Training

6. Auxiliary Operator #2 Auxiliary Operator #2 (U2 Turbine) Operator Training TABLE 3 - Firefighting Analysis # 7 Task Analysis Line Performed By Controlling Method 1 No actions required for this event NA 0ERP Rev. 089 Att. 1 - Page 51 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 4 - Radiation Protection & Chemistry Analysis # 7 Performance Time Period After Emergency Declaration (minutes)

Line Position Performing Function/Task 0- 5 15 25 35 45 55 65 75- 80- 85-5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90

1. In-Plant Survey: Perform TB surveys as allowed by SIC. On-Shift Position: Shift X X X X X X X X X X X X Health Physics Technician #1

2. On-Site Survey: Perform Field Surveys for unmonitored Turbine Bldg. release. On-Shift X X X X X X X X X X X X Position: Shift Health Physics Technician #2

3. N/A - Personnel can out-process from the Radiologically Controlled Area (RCA) using portal and Personnel Monitoring: On-Shift Position: small article monitors. On-shift personnel do not require monitoring support in order to perform in-Shift Health Physics Technician plant EOP/shutdown actions. If necessary, site evacuees would be monitored at the Remote Monitoring Area after arrival of augmented ERO personnel.

4. Job Coverage: Chemistry Tech pulling Turbine Bldg. Effluent Sample X X X X X X X X X X X X On-Shift Position: Shift HP Technician #3

5. Offsite Radiological Assessment Performed by Unaffected Unit CRS - Ref. Table 5 On-Shift Position: Chemistry Tech

6. Chemistry function/task #1 Obtain Turbine Stack Effluent sample (30 min.) and analyze for release (30 min.) as X X X X X X X X X X X X directed by 0AOP-05.4.

On-Shift Position: Shift Chem Tech #1

7. Chemistry function/task #2 Obtain Noble Gas Dose Rate and provide to X X X X X MCR as directed by 0AOP-05.4.

On-Shift Position: Shift Chem Tech #2 8 Chemistry function/task #3 Perform E&RC-1706 Sampling of Once-Thru X X X X X X X X X X Ventilation as directed by 0AOP-05.4.

On-Shift Position: Shift Chem Tech #2 0ERP Rev. 089 Att. 1 - Page 52 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 5 - Emergency Plan Implementation Analysis # 7 Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency EP/Ops Training and 1 Shift Manager Classification Level (ECL) EP Drill Program Approve Offsite Protective Action EP/Ops Training and 2 Shift Manager Recommendations EP Drill Program Approve content of State/local EP/Ops Training and 3 Shift Manager notifications EP Drill Program Approve extension to allowable EP/Ops Training and 4 Shift Manager dose limits EP Drill Program Notification and direction to on-shift EP/Ops Training and 5 staff (e.g., to assemble, evacuate, Shift Manager EP Drill Program etc.)

EP/Ops Training and 6 ERO notification Security Officer EP Drill Program Abbreviated NRC notification for 7 NA NA DBT event Complete State/local notification EP/Ops Training and 8 Shift Manager form EP Drill Program EP/Ops Training and 9 Perform State/local notifications Auxiliary Operator #4 (CREC)

EP Drill Program Complete NRC event notification EP/Ops Training and 10 Shift Manager form EP Drill Program EP/Ops Training and 11 Activate ERDS Shift Technical Advisor EP Drill Program EP/Ops Training and 12 Offsite radiological assessment Unaffected Unit CRS EP Drill Program Auxiliary Operator #4 (CREC) EP/Ops Training and 13 Perform NRC notifications Auxiliary Operator #5 as req. EP Drill Program Perform other site-specific event EP/Ops Training and 14 Auxiliary Operator #4 (CREC) notifications EP Drill Program 15 Personnel accountability Security Physical Security Plan 0ERP Rev. 089 Att. 1 - Page 53 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachment 2H: Large Break Loss of Coolant Accident (LOCA)

1. Event Summary:

A complete circumferential break of one of the recirculation loop pipelines occurs. This accident has been established as the design basis LOCA.

2. Event Specific Assumptions:

• The reactor is operating at a condition at the time the recirculation pipe breaks

• A complete loss of normal AC power occurs simultaneously with the pipe break.

• The recirculation loop pipeline is considered to sever instantly.

3. Procedures Reviewed for Accident Response Include:

• 0PEP-2.1 Initial Emergency Actions

• 0PEP-2.1.1 Emergency Control, UE, Alert, SAE, GE

• 0PEP-2.6.21 Emergency Communicator

• 0PEP-2.6.28 Protective Action Recommendations

• 0PEP-3.8.2 Personnel Accountability and Evacuation

• AOP-36.1 Loss of Any 4160v Buses or 480v E-Buses

• 1(2)EOP-01-RSP Reactor Scram Procedure

• 1(2)EOP-01-RVCP Reactor Vessel Control Procedure

• 0AOP-05.4, Radiological Release

• 0E&RC 1006 Routine RCS, RHR Hx sampling

• 0E&RC-1505 PASS Sampling

• 0E&RC-1706 TB OTV Alignment

• AD-OP-ALL-1000, Fleet Conduct of Operations

• EMG-NGGC-0005 Activation of the Emergency Response Organization Notification System

• Physical Security Plan

• 0ERP Radiological Emergency Response Plan 0ERP Rev. 089 Att. 1 - Page 54 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Analysis #8: DBA/ISG Event #8 - Large Break LOCA ECL: Site Area escalates to General Emergency TABLE 1 - On-shift Positions Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

T2/L1 T5/L1 T5/L2 T5/L3

1. Shift Manager 0ERP Section 3.1 N/A No No T5/L4 T5/L5 T5/L8 T5/L10

2. Unit 2 CRS 0ERP Section 3.1 N/A T2/L2 No No T2/L3

3. Shift Technical Advisor 0ERP Section 3.1 N/A No No T5/L11

4. Reactor Operator #1 0ERP Section 3.1 N/A T2/L4 No No

5. Reactor Operator #2 0ERP Section 3.1 N/A T2/L5 No No

6. Unaffected Unit (1) CRS 0ERP Section 3.1 N/A T5/L12 No No

7. Auxiliary Operator #1 0ERP Section 3.1 N/A T2 / L6 No No

8. Auxiliary Operator #2 0ERP Section 3.1 N/A T2 / L7 No No

9. Auxiliary Operator #3 0ERP Section 3.1 N/A T2/L8 No No T5/L9

10. Auxiliary Operator #4 (CREC) 0ERP Section 3.1 N/A T5/L13 No No T5/L14

11. Auxiliary Operator #5 0ERP Section 3.1 N/A T2/L9 No No

12. Auxiliary Operator #6 0ERP Section 3.1 N/A T2/L10 No No

13. Auxiliary Operator #7 0ERP Section 3.1 N/A T2/L11 No No

14. Auxiliary Operator #8 0ERP Section 3.1 N/A T5/L13 No No 0ERP Rev. 089 Att. 1 - Page 55 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Augmentation Unanalyzed Role in TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

T4/L1

15. HP Technician #1 0ERP Section 3.1 N/A No No T4/L5

16. HP Technician #2 0ERP Section 3.1 N/A T4/L4 No No

17. HP Technician #3 0ERP Section 3.1 N/A T4/L6 No No

18. Chemistry Technician #1 0ERP Section 3.1 N/A T4/L8 No No T4/L9

19. Chemistry Technician #2 0ERP Section 3.1 N/A No No T4/L10

20. Security Officer #1 0SI-05 N/A T5 / L6 No No

21. Security Officer #2 0SI-05 N/A T5/L15 No No

22. Security Officer #3 0SI-05 N/A T5/L16 No No 0ERP Rev. 089 Att. 1 - Page 56 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Table 2 Plant Operations & Safe Shutdown Analysis # 8 BNP Nuclear Plant Two Units - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Generic Title/Role Task Analysis Line On-Shift Position Controlling Method Shift Manager Shift Manager Operator Training

• Unit Supervisor #2 Unit 2 CRS Operator Training

• Shift Technical Advisor Shift Technical Advisor Operator Training

• Reactor Operator #1 Unit 2 OAC Operator Training

• Reactor Operator #2 Unit 2 BOP Operator Training

• Auxiliary Operator #1 RB Auxiliary Operator Operator Training

• Auxiliary Operator #2 TB Auxiliary Operator Operator Training

• Auxiliary Operator #3 OS Auxiliary Operator Operator Training

• Auxiliary Operator #5 Equipment Operator #5 Operator Training

• Auxiliary Operator #6 Equipment Operator #6 Operator Training

• Auxiliary Operator #7 Equipment Operator #7 Operator Training TABLE 3 - Firefighting Analysis # 8 Task Analysis Line Performed By Controlling Method 1 No actions required for this event NA 0ERP Rev. 089 Att. 1 - Page 57 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 4 - Radiation Protection & Chemistry Analysis # 8 Performance Time Period After Emergency Declaration (minutes)

Line Position Performing Function/Task 0- 5 15 25 35 45 55 65 75- 80- 85-5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90

• In-Plant Survey: Perform RB surveys as allowed by SIC. On-Shift Position: Shift X X X X X X Health Physics Technician #1

• On-Site Survey: Perform Field Surveys for N/A - The performance of an on-site survey is not necessary for initial implementation of the unmonitored release. On-Shift Position: Shift Emergency Plan, and not required by any procedure. An on-site survey team may be dispatched Health Physics Technician after activation of the OSC.

• Personnel Monitoring: On-Shift Position: N/A - Personnel can out-process from the Radiologically Controlled Area (RCA) using portal and Shift Health Physics Technician small article monitors. On-shift personnel do not require monitoring support in order to perform in-plant EOP/shutdown actions. If necessary, site evacuees would be monitored at the Remote Monitoring Area after arrival of augmented ERO personnel.

• Job Coverage: Chemistry Tech pulling Main Stack Effluent Sample X X X X X X On-Shift Position: Shift HP Technician #2.

• Job Coverage: Ops close MS-3 per SEP-11.

X X X X On-Shift Position: Shift HP Technician #1

• Job Coverage: Operations maximize CRD injection in U2 RB per SEP-09. On-Shift X X X X X X Position: Shift HP Technician #3

• Offsite Radiological Assessment Performed by Unaffected Unit CRS - Ref. Table 5 On-Shift Position: Chemistry Tech

• Chemistry function/task #1 Obtain Main Stack Eff. sample (30 min.) and X X X X X X X X X X X X analyze for release (30 min.) per EOP-04.

On-Shift Position: Shift Chem Technician #1

• Chemistry function/task #2 Obtain Noble Gas Dose Rate and provide to X X X X X MCR as directed by EOP-04.

On-Shift Position: Shift Chem Technician #2

• Chemistry function/task #3 Sample TB effluent and program Turbine WRGM Set points following realignment to X X X X X X X X X X recirculation as directed by EOP-04.

On-Shift Position: Shift Chem Technician #2 0ERP Rev. 089 Att. 1 - Page 58 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 5 - Emergency Plan Implementation Analysis # 8 Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency Operations Training and 1 Shift Manager Classification Level (ECL) EP Drill Program Approve Offsite Protective Action Operations Training and 2 Shift Manager Recommendations EP Drill Program Approve content of State/local Operations Training and 3 Shift Manager notifications EP Drill Program Approve extension to allowable Operations Training and 4 Shift Manager dose limits EP Drill Program Notification and direction to on-shift Operations Training and 5 staff (e.g., to assemble, evacuate, Shift Manager EP Drill Program etc.)

Security Training and EP 6 ERO notification Security Officer #1 Drill Program Abbreviated NRC notification for 7 N/A N/A DBT event Complete State/local notification Operations Training and 8 Shift Manager form EP Drill Program Operations Training and 9 Perform State/local notifications Auxiliary Operator #4 (CREC)

EP Drill Program Complete NRC event notification Operations Training and 10 Shift Manager form EP Drill Program Operations Training and 11 Activate ERDS Shift Technical Advisor EP Drill Program Operations Training and 12 Offsite radiological assessment Unaffected Unit (1) CRS EP Drill Program Auxiliary Operator #4 (CREC) Operations Training and 13 Perform NRC notifications Auxiliary Operator #8 EP Drill Program Perform other site-specific event Operations Training and 14 Auxiliary Operator #4(CREC) notifications (e.g., INPO, ANI, etc.) EP Drill Program Security Training and EP 15 Personnel accountability Security Officer #2 Drill Program Security Training and EP 16 Access Control to ERO and TSC Security Officer #3 Drill Program 0ERP Rev. 089 Att. 1 - Page 59 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Attachment 2I: SAMG Response Actions

1. Event Summary:

As a continuation of Event #8, Large Break LOCA, this analysis assumes Control Room Operators were unable to restore and maintain Reactor Water level above -57.5 inches as an entry into the SAMG procedures.

2. Event Specific Assumptions:

• There was no other plant damage and all equipment operates as designed.

3. Procedures Reviewed for Accident Response Include:

• 0PEP-2.1 Initial Emergency Actions

• 0PEP-2.1.1 Emergency Control, UE, Alert, SAE, GE

• 0PEP-2.6.21 Emergency Communicator

• 0PEP-2.6.28 Protective Action Recommendations

• 0PEP-3.8.2 Personnel Accountability and Evacuation

• 1(2)EOP-01-RSP Reactor Scram Procedure

• 1(2)EOP-01-RVCP Reactor Vessel Control Procedure

• 0AOP-05.4, Radiological Release

• 0SAMG-01 RPV Level Control

• 0SAMG-02 Containment and Radioactivity Release Control

• 0EDMG-04 Depressurization of the Reactor Vessel and Injection using the Emergency Diesel Makeup Pump (EDMP)

• 0EDMG-08 Emergency Diesel Makeup Pump (EDMP) Setup and Operation

• 0E&RC-1006 Routine RCS, RHR Hx sampling

• 0E&RC-2020 Setpoint Determinations for Gaseous Radiation Monitors

• 0E&RC-1505 PASS Sampling

• 0E&RC-1706 TB OTV Alignment

• AD-OP-ALL-1000, Fleet Conduct of Operations 0ERP Rev. 089 Att. 1 - Page 60 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012

• EMG-NGGC-0005 Activation of the Emergency Response Organization Notification System

• Physical Security Plan

• 0ERP Radiological Emergency Response Plan 0ERP Rev. 089 Att. 1 - Page 61 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Analysis #9: DBA/ISG Event # 9 - SAMG ECL: General Emergency TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

T2/L1 T5/L1 T5/L2 T5/L3

1. Shift Manager BNP 0ERP; Figure 3-1 N/A No No T5/L4 T5/L5 T5/L8 T5/L10

2. Control Room Supervisor (SRO) BNP 0ERP; Figure 3-1 N/A T2/L2 No No T2/L3

3. Shift Technical Advisor BNP 0ERP; Figure 3-1 NA No No T5/L11

4. Unaffected Unit (1) CRS BNP 0ERP; Figure 3-1 N/A T5/L12 No No

5. U2 Reactor Operator #1 (OAC) BNP 0ERP; Figure 3-1 N/A T2/L4 No No

6. U2 Reactor Operator #2 (BOP) BNP 0ERP; Figure 3-1 N/A T2/L5 No No

7. Auxiliary Operator#1 (Reactor) BNP 0ERP; Figure 3-1 N/A T2/L6 No No

8. Auxiliary Operator#2 (Turbine) BNP 0ERP; Figure 3-1 N/A T2/L7 No No

9. Auxiliary Operator#3 (Outside) BNP 0ERP; Figure 3-1 N/A T2/L8 No No 0ERP Rev. 089 Att. 1 - Page 62 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

T5/L9

10. Auxiliary Operator #4 (CREC) BNP 0ERP; Figure 3-1 N/A T5/L13 No No T5/L14

11. Auxiliary Operator #5 BNP 0ERP; Figure 3-1 N/A T5/L13 No No T4/L1

12. Health Physics Technician #1 BNP 0ERP; Figure 3-1 N/A No No T4/L5

13. Health Physics Technician #2 BNP 0ERP; Figure 3-1 N/A T4/L4 No No

14. Health Physics Technician #3 BNP 0ERP; Figure 3-1 N/A T4/L6 No No T4/L8

15. Chemistry Technician #1 BNP 0ERP; Figure 3-1 N/A No No T4/L9 T4/L10

16. Chemistry Technician #2 BNP 0ERP; Figure 3-1 N/A T4/L11 No No T4/L12 Mechanical Maintenance

17. BNP 0ERP; Figure 3-1 N/A T2/L9 No No Technician #1 T5/L6

18. Security BNP 0ERP; Figure 3-1 N/A No No T5/L15 0ERP Rev. 089 Att. 1 - Page 63 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Table 2 Plant Operations & Safe Shutdown Analysis # 9 BNP Nuclear Plant Two Units - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Task Performance Line Generic Title/Role On-Shift Position Validation

1. Shift Manager Shift Manager Operator Training

2. Unit 2 Supervisor Control Room Supervisor (SRO) Operator Training

3. Shift Technical Advisor Shift Technical Advisor Operator Training

4. Reactor Operator #1 U2 Reactor Operator #1 (OAC) Operator Training

5. Reactor Operator #2 U2 Reactor Operator #2 (BOP) Operator Training

6. Auxiliary Operator #1 Auxiliary Operator#1 (Reactor) Operator Training

7. Auxiliary Operator #2 Auxiliary Operator#2 (Turbine) Operator Training

8. Auxiliary Operator #3 Auxiliary Operator#3 (Outside) Operator Training Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Line Generic Title/Role On-Shift Position Task Performance Validation Mechanical Maintenance Mechanical Maintenance

9. Mechanical Maintenance Technician #1 Technical Training TABLE 3 - Firefighting Analysis # 9 Task Analysis Line Performed By Controlling Method 1 No actions required for this event NA 0ERP Rev. 089 Att. 1 - Page 64 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 4 - Radiation Protection & Chemistry Analysis # 9 Performance Time Period After Emergency Declaration (minutes)

Line Position Performing Function/Task 0- 5 15 25 35 45 55 65 75- 80- 85-5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey: Perform RB surveys as

1. allowed by SIC. On-Shift Position: Shift X X X X X X Health Physics Technician #1 On-Site Survey: N/A - The performance of an on-site survey is not necessary for initial implementation of the

2. On-Shift Position: Emergency Plan, and not required by any procedure. An on-site survey team may be dispatched after activation of the OSC.

Personnel Monitoring: N/A - Personnel can out-process from the Radiologically Controlled Area (RCA) using portal and On-Shift Position: small article monitors. On-shift personnel do not require monitoring support in order to perform in-

3. plant EOP/shutdown actions. If necessary, site evacuees would be monitored at the Remote Monitoring Area after arrival of augmented ERO personnel.

Job Coverage: Chemistry Tech pulling Main

4. Stack Effluent Sample X X X X X X On-Shift Position: Shift HP Technician #2.

Job Coverage: Chemistry Tech Pulling

5. Primary Containment sample. On-Shift X X X X X X Position: Shift HP Technician #1 Job Coverage: OPS Support for EDMG-004 and EDMG-008 drafting water from Discharge

6. X X X X X X Canal. On-Shift Position: Shift HP Technician

1. 3 Offsite Radiological Assessment

7. Performed by Unaffected Unit CRS - Ref. Table 5 On-Shift Position: Chemistry Tech Chemistry function/task #1 -

Sample Primary Containment for venting

8. X X X X X X within release limits per E&RC 2020 & 1505 On-Shift Position: Shift Chem Tech #1 Chemistry function/task #2 -

Analyze and Primary Containment

9. X X X X X X X X X X atmospheric sample for venting. On-Shift Position: Shift Chem Tech #1 0ERP Rev. 089 Att. 1 - Page 65 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 Line Position Performing Function/Task Performance Time Period After Emergency Declaration (minutes)

Chemistry function/task #3 -

Determine Noble Gas Instantaneous Release

10. Rate for Gaseous Radiation Monitors directed X X X X by SAMG-02.

On-Shift Position: Shift Chem Tech #2 Chemistry function/task #4

11. Obtain Main Stack Effluent sample (30 min.) X X X X X X On-Shift Position: Shift Chem Tech #2 Chemistry function/task #5

12. Analyze Main Stack Effluent sample (30 min.) X X X X X X On-Shift Position: Shift Chem Tech #2 0ERP Rev. 089 Att. 1 - Page 66 of 67

Brunswick Nuclear Plant On-Shift Staffing Analysis Summary December, 2012 TABLE 5 - Emergency Plan Implementation Analysis # 9 Task Analysis Line Function/Task On-Shift Position Controlling Method Declare the Emergency EP/Ops Training and EP 1 Shift Manager Classification Level (ECL) Drill Program Approve Offsite Protective Action EP/Ops Training and EP 2 Shift Manager Recommendations Drill Program Approve content of State/local EP/Ops Training and EP 3 Shift Manager notifications Drill Program Approve extension to allowable EP/Ops Training and EP 4 Shift Manager dose limits Drill Program Notification and direction to on-shift EP/Ops Training and EP 5 staff (e.g., to assemble, evacuate, Shift Manager Drill Program etc.)

Security Training and EP 6 ERO notification Security Drill Program Abbreviated NRC notification for 7 NA NA DBT event Complete State/local notification EP/Ops Training and EP 8 Shift Manager form Drill Program Auxiliary Operator #4 EP/Ops Training and EP 9 Perform State/local notifications (CREC) Drill Program Complete NRC event notification EP/Ops Training and EP 10 Shift Manager form Drill Program EP/Ops Training and EP 11 Activate ERDS Shift Technical Advisor Drill Program EP Training and EP Drill 12 Offsite radiological assessment Unaffected Unit CRS Program Auxiliary Operator #4 EP/Ops Training and EP 13 Perform NRC notifications (CREC) & Auxiliary Drill Program Operator #5 Perform other site-specific event Auxiliary Operator #4 14 N/A notifications (e.g., INPO, ANI, etc.) (CREC)

Physical Security Plan 15 Personnel accountability Security 0ERP Rev. 089 Att. 1 - Page 67 of 67

REVISION

SUMMARY

Page 1 of 1 Revision 089: PRR 2021755 and EC 290407, removes radiation monitors 1-CAC-RM-80 and 2-CAC-RM-80 from Table 5.7-3. Revised by M. Lee Edmonds PRR 692736 Revised Step 3.5.1 to add actions for security threat and use of Alternate Emergency Facility until safe access to site is assured.

PRR 715324 updated Figure 1.1-3 to show placement of the 2 FLEX diesels and enclosures.

PRR 736572 Added location of letters/memoranda of agreement to Appendix B PRR 756506 added on Attachment H that 0ERP section 3.8.4.1 satisfies NUREG 0654 item C.1c.

PRR 757968 changed E&RC Manager, Coordinators, and Technicians to RP or Chem Manager, Coordinators, and Technicians throughout.

PRR 758619 fourth paragraph second to last sentence of Step 6.2.2 on page 6-10 added "and documented in the records management system in accordance with AD-NO-ALL-1001, Conduct of Audit."

PRR 1953229 (only parts of PRR were implemented and new PRR 2098831 was written for the remainder to be included in a future revision) eliminated gender specific terminology throughout. Appendix I, changed 0EPM-210 to 0PEP-04.3 for item II.F and added 0ERP for item IV.A.9. Corrected the title of 0PEP-02.6.30 throughout the procedure.

Corrected procedure number for 0PEP-04.08 in Appendix G. Added AD-EP-ALL-0400 to Appendix G for Section 5. Added DEC sites to pg 1-7 Step 1.3.1.2 4th paragraph. Removed "notification of " from Unusual even except as used in 0PEP-02.1.1 title (to be changed when 0PEP-02.1.1 is revised). Modified Figure 2.0-1 to adjust the Continue Assessment block line; change BENS to ERONS and add AD-EP-ALL-0301 to Notify Security blocks; add to NRC notification blocks "immediately following notification to State and Local Governments, not to exceed"; change Realign TB Ventilation blocks to corrected "0PFP-13" to "0PFP-013" and added "in the event of a radiological release or as deemed necessary by the SEC". Added JIC to last sentence in the first paragraph of Step 3.2 on page 3-4. Added DEC sites to Step 3.5.5 on page 3-14. Reworded note b of Figure 3.1-1 to replace referenced procedure from "BNP-FPP-0301" to "0PLP-01.2". Step 4.4.7.2 3rd paragraph on page 4-20 removed the comma and started the following Sentence with "These affected areas". Corrected table alignment for items 3.f and 4.f of Table 4.4-1. Changed "FSAR" to "UFSAR" throughout. Step 6.1.2.2 on page 6-7 Changed "all" to "major" elements are tested. Page 7-1 Step 7.2 changed Recovery Center "will be" to "will normally be" located Figure 7.2-1 changed "Progress" to "Duke" Energy. Added NUREG/CR-6451 to Appendix F References. Corrected Table 4.4-4 PF for Corner of Basement, Under Table with 8" Concrete on top. Page 3-19 corrected Oak island and BSL fire department titles. Reworded the last two paragraphs of Section 5.7.3 on page 5-8 for clarification of how seismic monitoring works.

PRR 02047127 modified Section 3.4.6 to remove first aid duties, Added Section 3.4.7 for MERT and modified Figure 3.1-1 to separate first aid from fire brigade.

PRR 2085814 removed James R. Forstner, M.D. from Appendix B as he is retired. Replaced him with Joseph Hatem, M.D per Tech Reviewer comment.

Per Tech Review Comment, removed First Aid/Medical from Fire Brigade under Operations Coordinator in Figure 3.4-1 Prepared by Fred Litten 0ERP Rev. 089 1

BSEP 17-0046 Enclosure 3 Copy of 0PEP-02.1.1, Revision 29, Emergency Control - Unusual Event, Alert, Site Area Emergency, and General Emergency

Reference Use BRUNSWICK UNIT 0 PLANT EMERGENCY PROCEDURE 0PEP-02.1.1 EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, SITE AREA EMERGENCY, AND GENERAL EMERGENCY REVISION 29

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 2 of 32 REVISION

SUMMARY

PRR 2050640 DESCRIPTION DO NOT DELETE THIS NOTE. When this procedure is revised, the following Instructional Aids for Attachment 1 and Attachment 2 are also required to be updated:

• Unit 1/1119

• Unit 2/1120

• Simulator S/1121 Refer to 0AI-97 for instructions for revising the Instructional Aids.

PRR 2050640 added Step 5.2.29.b for follow-up notifications of termination of emergency and changed the originally suggested "15 minutes" to "60 minutes and "initial" to "follow-up" per Tech Review comment.

PRR 739509 added note at Step 5.2.8 about location of megaphones/bullhorns for making announcements if plant PA system is not available.

PRR 739512 added reference 7.3.12 Carolina Power and Light Company and Florida Power Corporation's Response to Request for Information Pursuant to Title 10 of the Code of Federal Regulation 50.54(F) Regarding Recommendation 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights From the Fukushima Daiichi Accident, Dated March 12, 2012 PRR 2098834 removed "Notification of" from the Title and also from Step 5.1.6, Step 5.2.29.a, and Attachment 1.

PRR 2081589 corrected the line direction from the Continue Assessment block of Attachment 1 flow chart. Other changes to Attachment 1 include: change BENS to ERONS and add AD-EP-ALL-0301 to Notify Security blocks; changed Realign TB Ventilation blocks to corrected "0PFP-13" to "0PFP-013". These changes were made to agree with same figure (Figure 2.0-1) in 0ERP Rev 89.

Prepared by Fred Litten

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 3 of 32 TABLE OF CONTENTS SECTION .......................................................................................................................... PAGE 1.0 PURPOSE ..................................................................................................................... 4 2.0 SCOPE .......................................................................................................................... 4 3.0 DEFINITIONS ................................................................................................................ 4 4.0 RESPONSIBILITIES ...................................................................................................... 6 5.0 INSTRUCTIONS ............................................................................................................ 8 5.1 General Guidance ......................................................................................................... 8 5.2 Emergency Declaration ............................................................................................... 11 6.0 RECORDS................................................................................................................... 22

7.0 REFERENCES

............................................................................................................ 23 ATTACHMENTS 1 0PEP-02.1.1 Site Emergency Coordinator Actions Flow Chart ................................... 25 2 0PEP-02.1.1 Site Emergency Coordinator Actions Checklist ...................................... 26 3 SEC Turnover Briefing Worksheet ............................................................................... 27 4 Emergency Response Data System (ERDS) Activation .............................................. 29

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 4 of 32 1.0 PURPOSE

1. This procedure is implemented by the Shift Manager or alternate qualified Control Room Site Emergency Coordinator (SEC), in the Shift Managers absence. The SEC has immediate, unilateral authority to carry out this procedure upon recognition of an off-normal condition.

2.0 SCOPE

1. This procedure defines the responsibilities and actions of the Site Emergency Coordinator (SEC) during a declared emergency, including the initial and continued coordination of resources to respond to an emergency on site. This procedure has primary applicability during the initial stages of a classified emergency when the SEC position resides in the Control Room, but the requirements and direction continue to apply throughout an emergency. SEC responsibilities following activation of the Technical Support Center are addressed in 0PEP-02.6.26, Activation and Operation of the Technical Support Center (TSC).

3.0 DEFINITIONS

1. Adequate Core Cooling - Heat removal from the reactor sufficient to prevent rupturing the fuel clad. Four viable mechanisms of adequate core cooling exist within the EOPs:

• Core submergence

• Steam cooling with injection of makeup water to the reactor

• Steam cooling without injection of makeup water to the reactor

• Reactor water level at jet pump suction with at least one core spray pump injecting into the reactor vessel at 5000 gpm.

2. Emergency Response Organization (ERO) - All Call/All Come - At a declared ALERT or higher, or as directed by the SEC, all ERO members are expected to respond to their designated emergency response facility (regardless of on-call status) unless they are on vacation or assignment out of the area of the plant, NOT fit for duty, unable to leave family members unattended, or are unable to safely respond.

3. Fire - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires.

Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 5 of 32 3.0 DEFINITIONS (continued)

4. Hostile Action - An act toward a Nuclear Power Plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

Hostile Action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the Nuclear Power Plant.

Non-terrorism based EALs should be used to address such activities, (e.g.,

violent acts between individuals in the OCA).

5. Plant Operator - Any qualified Senior Reactor Operator (SRO) or Site Emergency Coordinator (SEC).

6. Radiological Release - Any unplanned quantifiable discharge to the environment of radioactive effluent attributable to a declared emergency.

7. Security Condition - Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a hostile action.

8. Toxic Gases - A gas that is dangerous to life or health by reason of inhalation or skin contact (e.g. chlorine). Asphyxiants can also become toxic in large enough quantities (e.g. CO2).

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 6 of 32 4.0 RESPONSIBILITIES NOTE

• "" Triangle - identified items are performed by the Emergency Operation Facility (EOF) when activated.

• The SEC may delegate specific steps as necessary, but shall not delegate the responsibility for classification of an event.

• Emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present.

• When the site has declared an event due to exceeding an EAL threshold and, subsequently, another EAL of equal or lesser value is exceeded on either unit, it is not required, however permissible, to annotate in the "Remarks" section of the next Emergency Notification Form any additional EAL(s) which have been met. The site should NOT declare another emergency classification.

4.1 Site Emergency Coordinator (SEC)

1. Declares and terminates emergency classifications.

2. Notifies appropriate personnel of the activation of the Site Emergency Coordinator (SEC) position and informs them of plant status.

3. Maintains a log of all activities.

4. Assigns a Control Room Emergency Communicator.

5. Notifies Security (SAS) to activate the Emergency Response Organization Notification System (ERONS).

6. Ensures immediate and follow-up off-site notifications are made.

7. Ensures that the Emergency Response Data System (ERDS) is initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following the declaration of an ALERT or higher.

8. Directs and coordinates of the combined activities of plant personnel in the Control Room, Technical Support Center (TSC), Operational Support Center (OSC), or elsewhere on site, when activated.

9. Approves news release

10. Notifies Chemistry to energize Post Accident Sample System Heat Trace, when conditions warrant.

11. Coordinates plant activities with the Emergency Operations Facility (EOF), when activated.

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 7 of 32 4.1 Site Emergency Coordinator (SEC) (continued)

12. Activates the required emergency teams and facilities for the TSC, OSC and EOF.

13. Augments on-shift staff.

14. Requests emergency assistance from offsite agencies.

15. Conducts periodic briefings to emergency response organization personnel.

16. Continuously assesses emergency conditions for possible reclassification or termination.

17. Performs accident mitigation activities.

18. Coordinates off-site activities of plant emergency response personnel.

19. Develops and communicates protective action recommendations to off-site authorities.

4.2 Control Room Emergency Communicator (CREC)

1. Until the emergency response facilities are activated, the Control Room Emergency Communicator (CREC) is responsible to the Site Emergency Coordinator (SEC) for communications, in accordance with 0PEP-02.6.21, Emergency Communicator.

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 8 of 32 5.0 INSTRUCTIONS 5.1 General Guidance

1. This procedure is implemented when an Emergency Action Level (EAL), as described in 0PEP-02.1, Initial Emergency Actions, or 0PEP-02.2.1, Emergency Action Level Technical Bases, has been met or exceeded.

2. Once implemented, this procedure remains in effect until both of the following:

a. All EAL criteria are determined to be less than event classification threshold values.

b. The off-normal conditions have been resolved.

3. While this procedure is in effect, the position of Site Emergency Coordinator will be activated.

4. The Site Emergency Coordinator shall NOT delegate the following until the Emergency Response Manager is activated:

a. The responsibility for Protective Action Recommendations to off-site authorities.

b. Approving Emergency Notification forms (0PEP-02.6.21, Emergency Communicator, Attachment 1).

c. Approving press/news releases.

5. When the EOF is activated, the Emergency Response Manager assumes the responsibility for:

a. Protective Action Recommendations to off-site authorities

b. Approval of Emergency Notification forms (0PEP-02.6.21, Emergency Communicator, Attachment 1)

c. Approval of press/news releases

d. Off-site communications

e. Environmental monitoring

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 9 of 32 5.1 General Guidance (continued)

6. The following activities are sequenced in a progression for the declaration of an UNUSUAL EVENT through a GENERAL EMERGENCY in the most likely order of priority.

NOTE

• Two attachments, a flowchart, and a checklist, are provided with this procedure for use as aids in the implementation of emergency plan actions. These attachments are not to be considered as all inclusive and are not intended as stand-alone documents. Therefore, the appropriate specific procedures should be referenced to ensure satisfaction of all requirements for the emergency conditions.

• There may be cases in which a plant condition that exceeded an EAL threshold was not recognized at the time of occurrence, but is identified well after the condition has occurred (e.g., as a result of routine log or record review) and the condition no longer exists. In these cases, an emergency should not be declared. Normal reporting requirements (e.g., 10 CFR 50.72) are applicable in these cases. (Ref. NEI 99-01).

7. Emergency Declaration Timeliness:

a. The emergency declaration "time clock" begins when indications on plant instrumentation, alarms, computer displays, or verbal reports that correspond to an EAL become available to any SRO or Site Emergency Coordinator.

b. Emergency declaration will be made within 15 minutes after the availability of indications to any qualified SRO or Site Emergency Coordinator that an emergency action level has been exceeded.

c. When two or more EALs have been exceeded, the highest appropriate emergency classification level will be declared.

d. Emergency declaration will be made as soon as possible following identification of the appropriate emergency classification level.

e. The 15-minute period includes all assessment, classification, and declaration actions, including communications to and from remote locations.

f. Validation or confirmation of plant indications is to be completed within the 15-minute period as part of the assessment.

g. For EALS that require completion of analyses, including chemistry sampling or dose assessment, the required analyses are to be completed with a reasonable sense of urgency.

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h. For EALS that require completion of analyses, including chemistry sampling or dose assessment, the 15-minute period begins with the availability of the analysis results.

i. The 15-minute period ends when the "plant operator" determines that an EAL has been exceeded and upon identification and declaration of the appropriate emergency classification.

j. The emergency declaration is to be made promptly following identification of the emergency classification. ("Promptly" means the next available opportunity unimpeded by activities not related to emergency classification, except for activities needed to protect health and safety.)

k. The 15-minute period is not to be used to restore plant conditions to avoid declaring an emergency.

l. For EALs that specify a duration of the conditions (e.g., certain fires and releases), the 15-minute period runs concurrently with the specified duration and is not added on to the end of the specified duration.

m. If access to plant information is not available electronically due to loss of off-site power, hard copy documents (e.g., procedures, drawings) are maintained in Vital File Locations that include the Control Room, Technical Support Center, Emergency Operations Facility, and the Operational Support Center. {7.1.2}

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 11 of 32 5.2 Emergency Declaration NOTE Items identified with 3 Asterisks "***" indicate that during security related events, consideration is given in regards to personnel safety prior to performing the step. These steps may be deemed unsafe to perform due to the circumstances, and may be performed later in the event.

EXAMPLE Making a PA announcement for personnel to evacuate while in a SITE AREA EMERGENCY, but the SITE AREA EMERGENCY was declared due to a Hostile Action occurring on site.

1. Ensure appropriate Emergency Operating Procedures and plant procedures are implemented concurrently.

NOTE Emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present.

2. It is not necessary to activate the Emergency Response Organization Notification System (ERONS) for a classified emergency if the Emergency Response Organization (ERO) is staffed on site (e.g., for severe weather) unless additional ERO personnel are required to respond to the emergency.

3. Formally declare the appropriate emergency classification, as determined by 0PEP-02.1, Initial Emergency Actions, or 0PEP-02.2.1, Emergency Action Level Technical Bases, and log the event.

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 12 of 32 5.2 Emergency Declaration (continued)

4. If the emergency is due to a Security threat, then perform actions in 0AOP-40.0, Security Events, concurrently with this procedure. Otherwise continue at Step 5.

{7.1.1}

a. The SEC should notify, or direct notification to, the Security Secondary Alarm Station (SAS) at x3747 to activate the Emergency Response Organization Notification System (ERONS), within 5 minutes of declaration:

(1) Use the appropriate Template ID and Message Title.

Security Event Template ID Message Title Classification 210 Security Event - UE - ERO Standby Security - UE 211 Security Event - UE - ERO Activation Security - Alert 220 Security Event - ALERT - ERO Activation Security - SAE 230 Security Event - SAE - ERO Activation Security - GE 240 Security Event - GE - ERO Activation

b. If Security cannot activate ERONS, direct the Control Room Emergency Communicator (CREC) to initiate ERONS to activate the ERO in accordance with AD-EP-ALL-0301, Activation of the Emergency Response Organization Notification System (ERONS):

(1) Use the appropriate Template ID and Message Title.

Security Event Template ID Message Title Classification 210 Security Event - UE - ERO Standby Security - UE 211 Security Event - UE - ERO Activation Security - Alert 220 Security Event - ALERT - ERO Activation Security - SAE 230 Security Event - SAE - ERO Activation Security - GE 240 Security Event - GE - ERO Activation

c. If necessary, once safe movement at the plant is assured, Key ERO members already on-site (ERM, TSC-SEC, CM, and RCM) can proceed to the Alternate Emergency Facility.

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 13 of 32 5.2 Emergency Declaration (continued)

5. SEC, ensure that help needed to augment the on shift staff for event mitigation is consistently implemented. Consider all factors when determining whether to activate the emergency facilities, and instead of trying to reason why, rather reason why not to activate the facilities.

a. Upon declaration of an Unusual Event (UE) with Facilities not activated, the following options are available to assist in the response:

• Utilizing the Site Duty Manager (SDM) for onsite assistance.

• Utilizing the SDM to call in resources from offsite specific for the given situation.

• Staffing the Operations Command Center (OCC).

• Utilizing a Conference Call for technical support/ guidance [utilizing the Plant General Manager (PGM), Operations Manager, Maintenance Manager, SDM, et al. as required].

• Utilize the Emergent Work Response Checklist in accordance with AD-WC-ALL-0200 Attachment 16.

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 14 of 32 5.2 Emergency Declaration (continued)

NOTE When ERONS has been initiated for the purpose of activating emergency facilities (i.e., ERO response to the site), it is not necessary to reinitiate ERONS for subsequent additional emergency classifications, unless the ERO needs to be redirected to the Alternate Emergency Facility due to a Hostile Action.

b. Within 5 minutes of event declaration, notify, or direct notification of, the Securitys Secondary Alarm Station (SAS) at x3747, to activate the Emergency Response Organization Notification System (ERONS):

{7.1.1}

(1) If NO impediments to site access, then use the appropriate Template ID and Message Title.

Classification Template ID Message Title 110 UE - ERO Standby Unusual Event 111 UE - ERO Activation Alert 120 ALERT - ERO Activation Site Area Emergency 130 SAE - ERO Activation General Emergency 140 GE - ERO Activation (2) If access to the site IS impeded, such as blocked access roads, toxic gas cloud, etc. then use the appropriate Template ID and Message Title.

Classification Template ID Message Title 110 UE - ERO Standby UE 114 UE - ERO Activation - Alt Assembly Alert 123 ALERT - ERO Activation - Alt Assembly SAE 133 SAE - ERO Activation - Alt Assembly GE 143 GE - ERO Activation - Alt Assembly

6. Monitor activation of the emergency facilities, including the notification and response of emergency response organization members to ensure facility activation occurs within 75 minutes of the declaration of emergency classification.

7. If primary emergency facilities are NOT available then Go To Step 9.

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 15 of 32 5.2 Emergency Declaration (continued)

NOTE If the Plant Public Address System is not available for use due to a Beyond Design Basis Event (BDBE), megaphones/bullhorns are available in the FLEX Dome for making announcements.

8. ***Conduct or direct one of the following announcements over the plant Public Address (PA) System.

a. Declared UNUSUAL EVENT, facilities are not being activated:

"Attention all personnel, the site is in a(n) (event classification) due to (brief description). The Site Emergency Coordinator is (name). No ERO Facilities are being activated at this time"

b. ***Declared UNUSUAL EVENT or ALERT, facilities are accessible and are being activated:

"Attention all personnel, the site is in a(n) (event classification) due to (brief description). Activate the TSC, OSC, EOF and JIC. Minimum staffing Emergency Response Organization personnel report to your facility immediately. Joint Information Center personnel report to the JIC.

All other ERO positions report to the Technical Training Center auditorium immediately. The Site Emergency Coordinator is (name). (event classification) declared".

c. Acquire Met Tower data and determine safe assembly area for site evacuation.

(1) Sound the evacuation alarm prior to the announcement of the site evacuation.

d. ***Declared SITE AREA EMERGENCY or GENERAL EMERGENCY and facilities have NOT been activated then:

"Attention all personnel, the site is in a(n) (event classification) due to (brief description). Activate the TSC, OSC, EOF and JIC. Minimum staffing Emergency Response Organization personnel report to your facility immediately. Joint Information Center personnel report to the JIC.

All other ERO positions report to the Technical Training Center auditorium immediately. The Site Emergency Coordinator is (name). Attention all personnel, all non-essential personnel are to exit the protected area and report to your (primary or alternate) assembly location."

(1) Refer to 0PEP-03.8.2, Personnel Accountability and Evacuation.

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 16 of 32 5.2 Emergency Declaration (continued)

e. If the TSC/EOF/Simulator building is available, but the OSC is NOT habitable/accessible, then contact Security to notify arriving OSC personnel to report to the alternate OSC in the Simulator area of EOF/TSC Building.

f. Go To Step 10.

9. ***If primary emergency facilities are NOT available then conduct or direct one of the following announcements over the plant Public Address (PA) System.

a. ***Declared UNUSUAL EVENT or ALERT, respond to alternate facilities:

"Attention all personnel, the site is in a(n) (event classification) due to (brief description). ERO personnel assigned emergency response duties are to proceed immediately to the Alternate Emergency Facility. The Site Emergency Coordinator is (name). (Event classification) declared."

b. Acquire Met Tower data and determine safe assembly area for site evacuation.

(1) Sound the evacuation alarm prior to the announcement of the site evacuation.

c. ***Declared SITE AREA EMERGENCY or GENERAL EMERGENCY and facilities have NOT been activated then:

"Attention all personnel, the site is in a(n) (event classification) due to (brief description). ERO personnel assigned emergency response duties are to proceed immediately to the Alternate Emergency Facility. The Site Emergency Coordinator is (name). Attention all personnel, all non-essential personnel are to exit the protected area and report to your (primary or alternate) assembly location."

(1) Refer to 0PEP-03.8.2, Personnel Accountability and Evacuation.

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 17 of 32 5.2 Emergency Declaration (continued)

10. Assign a Control Room Emergency Communicator to make immediate notifications.

NOTE If the declared emergency is the result of an emergency action level requiring a high classification (e.g., SITE AREA EMERGENCY) that after a brief period is downgraded to a lower classification (e.g. UNUSUAL EVENT), the off-site notification must indicate the current classification, and it must also indicate the period of time that the higher classification existed and the mitigating conditions that caused the emergency classification to be downgraded.

a. ***Within 15 minutes of the declaration of the emergency classification, make initial notification to State and local governments . A GENERAL EMERGENCY classification requires the inclusion of a Protective Action Recommendation; provide in accordance with 0PEP-02.6.28, Off-Site Protective Action Recommendations.

b. Complete, or direct the completion of, an Emergency Notification Form, in accordance with 0PEP-02.6.21, Emergency Communicator, and approve for transmittal.

c. Immediately following the notification to State and local governments, but not to exceed 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, notify, or direct notification to, the Nuclear Regulatory Commission (NRC) of the emergency condition in accordance with 0PEP-02.6.21, Emergency Communicator.

(1) As an aid to direct communications with the NRC, use 0OI-01.07, Notifications, Attachment 3, Event Notification Worksheet, when making the notification if it has been completed by a licensed SRO.

(2) If the TSC is activated, fax the completed 0OI-01.07, Notifications, Attachment 3, Event Notification Worksheet, to the Emergency Notification System (ENS) Communicator in the TSC.

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 18 of 32 5.2 Emergency Declaration (continued)

NOTE For long lasting events caused by natural phenomenon (e.g., hurricane, severe storms, and earthquake), regular follow-up notifications to the State and counties MAY BE SUSPENDED, if both of the following criteria are met:

• The State and Counties agree to the suspension; and,

• There is no significant change in plant status

d. Conduct, or direct, follow-up notifications to off-site agencies with a periodicity of 60 minutes (or less), or more frequently, if warranted by changing conditions.

e. Any reclassification of an emergency requires notification to State and local governments within 15 minutes of the classification and to the NRC immediately following, but not to exceed 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from classification.

11. Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the declaration of an ALERT or higher classification, activate, or direct activation of, the Emergency Response Data System (ERDS) using Attachment 4, Emergency Response Data System (ERDS) Activation.

12. ***For reports of a fire, ensure implementation of 0PFP-013, General Fire Plan.

13. ***For reports of injured or missing personnel, ensure implementation of 0PEP-03.9.3, First Aid, Medical Care, and Transport for Injured Personnel; or 0PEP-03.9.6, Search and Rescue, as appropriate.

14. ***In the event of a radiological release, or as deemed necessary by the SEC, ensure the Unit 2 Turbine Building ventilation systems is NOT in once-through line-up, in accordance with 2OP-37.3, Turbine Building Heating and Ventilation System Operating Procedure.

15. ***Notify, or direct notification of, Chemistry to energize the Post Accident Sample System for classifications of a SITE AREA EMERGENCY or GENERAL EMERGENCY, and if conditions warrant at an ALERT.

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 19 of 32 5.2 Emergency Declaration (continued)

16. If a radiological release has occurred, or the potential exists for a radiological release, then ensure implementation of AD-EP-ALL-0202, Emergency Response Offsite Dose Projection.

a. A radiological release should be considered occurring when there is a measurable increase in activity beyond that existing prior to the event and the increase is attributable to the event.

(1) As a minimum, evaluate the following parameters, if a release is suspected:

• Main Stack Rad monitor.

• Reactor Bldg Vent Rad monitors.

• Turbine Bldg Vent Rad monitors.

• Onsite/Offsite Field team Rad readings (if available).

17. ***Evaluate the need for outside agency assistance and, if needed, direct the Emergency Communicator to notify the appropriate agencies. All offsite agency response to the site must be coordinated with the Control Room, Security, and the EOF (when activated).

18. ***If necessary, helicopter landing zones are identified to assist with evacuation or mobilization of personnel. If a request is made for helicopter assistance, then notify site security immediately and the Brunswick County 911 Center. Numbers are located in EPL-001. The helicopter landing zones are:

a. BNP TAC Parking Lot: 33° 57 19" N, 78° 00 36" W

b. BNP Contractor Parking Lot: 33° 57 28" N, 78° 00 49" W

c. South Brunswick High School: 34° 00 30" N, 78° 02 58" W

d. Brunswick County Airport: 33° 55 47" N, 78° 04 29" W

e. Brunswick County EOC: 34° 03 15" N, 78° 09 54" W

19. ***Direct NLOs not providing immediate support for the Control Room to report to the OSC, upon activation.

20. Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of declaration, verify the Emergency Communicator has validated INPO receipt of the initial event notification via ERONS (INPO normally calls back in response to the automated notification).

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21. ***Ensure periodic reports over the plant PA system are made to inform plant personnel of the emergency classification and situation.

22. Conduct initial and periodic briefings for emergency organization personnel at 30 to 60 minute intervals, or as required by changing conditions and personnel assignments. Briefings should contain the following information:

• Current emergency classification.

• Current plant/spent fuel pool status and conditions.

• Status of radiological releases or probability of a release.

• Status of on-site activities.

• Facility habitability and access requirements.

• Current radiological conditions, dose projections, and meteorological data.

• Status of actions initiated by off-site agencies.

• Other information pertinent to the emergency.

23. Continuously monitor and evaluate plant conditions, using 0PEP-02.1, Initial Emergency Actions, or 0PEP-02.2.1, Emergency Action Level Technical Bases, and compare to EAL criteria for reclassification or termination of the emergency.

24. Perform accident mitigation activities by evaluating plant conditions, determining appropriate EOP/SAMG mitigation strategies, and implementing EOP/SAMG actions.

25. Review and approve any press/news releases associated with the emergency.

26. If an Alert or higher emergency has been declared, verify the Emergency Communicator has notified American Nuclear Insurers per EPL-001, or that the responsibility has been turned over to the EOF.

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NOTE

• Turnover should occur via conference call between the Control Room SEC and qualified individuals in the TSC and EOF assuming the SEC and ERM responsibilities. The TSC SEC should also include the ERD in the initial turnover briefing.

• Conference call can be established early and phone placed on "Mute" until the attendee is ready to participate in brief.

• Attendees may enter or exit conference call at any time without effect on remaining attendees other than an audible beep when dialing in and a short dial tone and beep when hanging up. Up to 24 attendees may participate in the conference call.

27. Establish a conference call:

a. Contact all expected attendees for the call (CR SEC, ERD, and ERM):

(1) Establish the time for the brief.

(2) Direct attendees to call X3235 (910/457-3235 from off-site) prior to the start of the brief.

b. Dial X3235 prior to start of the brief.

c. To prevent background noise, request the ERD and POD to mute or turn off the OSC intercom in the OSC and TSC during briefings.

28. When relinquishing the responsibilities of the Site Emergency Coordinator position (activation of the TSC or position relief), provide a formal turnover briefing on emergency status and notify all appropriate personnel of the position turnover. (Attachment 3, SEC Turnover Briefing Worksheet).

29. When all EAL criteria are determined to be less than event classification threshold values, coordinate with State and local agencies to terminate the classification and notify the NRC.

a. If no actions were taken by the State or local agencies in response to the emergency classification (i.e., UNUSUAL EVENT without facility activation), then the event may be terminated and the off-site agencies informed without concurrence to terminate.

b. Within 60 minutes of the termination of the emergency make follow-up notification to State and Local governments.

c. Complete and approve an Emergency Notification Form, in accordance with 0PEP-02.6.21, Emergency Communicator, for transmittal to State and local agencies to terminate the emergency.

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d. Conduct or direct, a PA system announcement to inform plant personnel of event termination.

NOTE Reportability in accordance with 0OI-01.07, Notifications, is in addition to the requirement for notifying the NRC of an Emergency Classification.

e. Review 0RCI-06.1, Reportable Event Evaluation Criteria and Processing, and 0OI-01.07, Notifications, to determine reportability requirements.

f. Complete or direct completion of 0OI-01.07, Notifications, Attachment 3, Event Notification Worksheet.

6.0 RECORDS Documentation generated from implementation of this procedure is forwarded to the Supervisor - Emergency Preparedness for submittal to Document Services for retention.

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7.0 REFERENCES

7.1 Commitments

1. IER 11-39 Lack of Timely Emergency Response Organization and Emergency Response Facility Activation

2. SOER 99-1, Loss of Grid - Addendum 7.2 Procedures

1. 0AOP-40.0, Security Events

2. 0E&RC-2020, Setpoint Determinations For Gaseous Radiation Monitors

3. 0OI-01.07, Notifications

4. 0OI-60, ERFIS Data Display System

5. 0PEP-02.1, Initial Emergency Actions

6. 0PEP-02.2.1, Emergency Action Level Technical Bases

7. 0PEP-02.6.21, Emergency Communicator

8. 0PEP-02.6.26, Activation and Operation of the Technical Support Center (TSC)

9. 0PEP-02.6.28, Off-Site Protective Action Recommendations

10. 0PEP-03.1.3, Use of Communications Equipment

11. 0PEP-03.8.2, Personnel Accountability and Evacuation

12. 0PEP-03.9.3, First Aid, Medical Care, and Transport for Injured Personnel

13. 0PEP-03.9.6, Search and Rescue

14. 0PFP-013, General Fire Plan

15. 0RCI-06.1, Reportable Event Evaluation Criteria and Processing

16. 2OP-37.3, Turbine Building Ventilation System Operating Procedure

17. AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment

18. AD-EP-ALL-0301, Activation of the Emergency Response Organization Notification System (ERONS)

19. AD-WC-ALL-0200, On-Line Work Management

EMERGENCY CONTROL - UNUSUAL EVENT, ALERT, 0PEP-02.1.1 SITE AREA EMERGENCY, AND GENERAL Rev. 29 EMERGENCY Page 24 of 32 7.3 Miscellaneous Documents

1. 10 CFR-50.72 Immediate Notification Requirements For Operating Nuclear Power Reactors

2. (ODCM), BSEP Off-Site Dose Calculation Manual

3. EC 63657 Repair of RPV internal Core Spray piping adjacent to nozzle N5B

4. EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear, Incidents, U. S. EPA, May 1992

5. EPL-001, Emergency Phone List, Brunswick

6. NEI 99-01 Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, (ADAMS Accession Number ML12326A805)

7. NEI White Paper - Enhancements to Emergency Preparedness Programs for Hostile Actions May 2005 (Revised November 18, 2005)

8. NRC Bulletin 2005-02: Emergency Preparedness and Response Actions for Security-Based Events

9. NRC Letter Dated November 6, 2009

Subject:

Brunswick Steam Electric Plant, Units 1 And 2 -Revision to Emergency Action Levels (Tac Nos. Me0117 and Me0118). Which includes, Safety Evaluation By The Office Of Nuclear Reactor Regulation Proposed Revisions To Emergency Action Levels Carolina Power &

Light Company Brunswick Steam Electric Plant, Units 1 And 2 DOCKET NOS.

50-325 and 50-324

10. SD-60, ERFIS Data Acquisition, Processing, and Display

11. Unit 1 (Unit 2), BSEP Technical Specifications

12. Carolina Power and Light Company and Florida Power Corporation's Response to Request for Information Pursuant to Title 10 of the Code of Federal Regulation 50.54(F) Regarding Recommendation 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights From the Fukushima Daiichi Accident, Dated March 12, 2012

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<< 0PEP-02.1.1 Site Emergency Coordinator Actions Flow Chart >>

Items identified with 3 Asterisks "***" indicate that during security related events, consideration should be given in regards to personnel safety prior to performing the step. These steps may be deemed unsafe to perform due to the circumstances, and may be performed later in the event.

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<< 0PEP-02.1.1 Site Emergency Coordinator Actions Checklist >>

COMPLETE ACTION UE ALERT SAE GE COMMENT

1. ** Declare event and logged X X X X

2. ** Within 5 minutes of declaration Security notified to activate ERONS {7.1.1} X X X X

3. ***Make PA announcement alerting site of declared event X X X X

4. Emergency Communicator Assigned X X X X

5. ** Within 15 min. Notify State and County. Event notification form complete, X X X X approved, and transmitted (0PEP-02.6.21)

6. ** ***Within 15 min. of GE, Protective Action Recommendations X (0PEP-02.6.28)

7. ** NRC notified immediately following notification to State and local X X X X governments, not to exceed 1 hr. (0OI-01.07, Att. 3)

8. ** Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ERDS activated X X X

9. ** Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, INPO X X X

10. ***Ensure activation of the EOF, TSC and OSC within 75 min X X X

11. Dose projection initiated for a radiological release or a potential release (AD- X X X EP-ALL-0202)

12. ***Chemistry notified to energize PASS heat trace X X X

13. ***Site accountability and protected area evacuation initiated (0PEP-03.8.2) X X

14. ***Realign TB Ventilation to Recirculation Lineup IAW 2OP-37.3 in the event X X X X of a radiological release or as deemed necessary by the SEC

15. ***Direct NLOs not involved in mitigating actions to report to the OSC X X X

16. News Releases Approved X X X X

17. ** Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, ANI X X X

• • Items are Time Sensitive.

• • • Indicates that during security related events, consideration should be given in regards to personnel safety prior to performing the step. These steps may be deemed unsafe to perform due to the circumstances, and may be performed later in the event.

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<< SEC Turnover Briefing Worksheet >>

A. EMERGENCY CLASSIFICATION STATUS: (CHECK Applicable Unit)

UNIT 1 UNIT 2 BOTH (CHECK): UNUSUAL EVENT ALERT SITE AREA EMERGENCY GENERAL EMERGENCY

1. INITIATING EVENTS & EALs EXCEEDED: (cause, history & initiating events leading to emergency declaration)

2. STATUS OF EMERGENCY PROCEDURE IMPLEMENTATION AND MITIGATING ACTIONS:

(status of progress in emergency procedures, corrective actions taken)

B. PLANT/REACTOR/SPENT FUEL POOL STATUS: (CHECK APPLICABLE UNIT)

UNIT 1 UNIT 2

1. (CHECK) Stable Degrading Improving 1. (CHECK) Stable Degrading Improving

2. Fission Product Barrier (Fuel, RCS, Containment)/ 2. Fission Product Barrier (Fuel, RCS, Containment)/

Spent Fuel Cladding and Safety System Spent Fuel Cladding and Safety System alignments and status (flow rates, etc.): alignments and status (flow rates, etc.):

3. Evolutions In Progress: (Control Room activities, 3. Evolutions In Progress: (Control Room activities, in plant activities [NLOs, I&C, Mechanics]) in plant activities [NLOs, I&C, Mechanics])

4. Radiological Conditions: (known in plant 4. Radiological Conditions: (known in plant conditions [ARMS, RMS, etc.], known releases conditions [ARMS, RMS, etc.], known releases and duration) and duration)

Release In Progress (CHECK): YES NO Release In Progress (CHECK): YES NO

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<< SEC Turnover Briefing Worksheet >>

C. ON SITE PROTECTIVE ACTIONS: (existing personnel hazards; evacuations [local, site]; status of accountability or assembly; status of KI administration)

D. OFF-SITE PROTECTIVE ACTIONS: (status of dose assessment activities; PARs made to State, County Agencies)

E. OFF-SITE ASSISTANCE REQUESTS: (fire, rescue squad, law enforcement)

F. OFF-SITE NOTIFICATIONS: (status of notifications made to State, Counties, NRC, INPO, any others)

G. STATUS OF ERO ACTIVATION:

H. STATUS OF OUTSIDE AGENCY MOBILIZATION: (any reports that the State, Counties, NRC, etc. are activating; requests from State, Counties, NRC, etc.; time, content of any news releases)

I. TRANSFER OF NON-DELEGATABLE DUTIES: (classification, notification, PARs, and news release approval)

Direct the TSC SEC and EOF ERM to announce in the EOF and TSC (AEF, if applicable) that applicable duties have been assumed.

Announce in the Control Room that duties have been transferred to the TSC and EOF.

Time: _________________

J. SYNCHRONIZE CLOCKS WITH OTHER FACILITIES YES Time:

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<< Emergency Response Data System (ERDS) Activation >>

1. Display the ERDS activation application by one of the following methods:

a. If using a Windows XP Desktop:

• Using a Business LAN PC in the Control Room, choose Start >

Unit "X" ERDS Activation ("X" represents the Unit 1 or 2)

• Using a Business LAN PC outside the Control Room, choose Start

> NGG OSI-PI Displays > BNP Qualified > Operations tab > Unit "X" ERDS Activation ("X" represents the Unit 1 or 2)

• Using a Business LAN PC outside the Control Room choose: Start

> Programs > Business Apps > PI System > BNP QPIM >

Operations tab > Unit "X" ERDS Activation ("X" represents the Unit 1 or 2)

b. If using a Windows 7 Desktop perform one of the following:

• Select Start>All Programs>DAE>Shortcuts Tab>enter ERDS in Search field and press search button. Then select the ERDS Shortcuts Nuclear BNP Unit 1 (RUN)" for Unit 1, or "ERDS Shortcuts Nuclear BNP Unit 2 (RUN)" for Unit 2, and select the Run Application link to the right of it to begin ERDS activation.

• Select Start>All Programs>DAE>Shortcuts Tab>enter QPIM - BNP in Search Field and press search button. Select QPIM - BNP and select the Run Application link to the right of "QPIM - BNP" to begin Unit selection and ERDS activation.

2. If the ERDS application launches and displays, then proceed to Step 4.

3. If the ERDS application does NOT launch, then perform the following:

a. Choose Start > All Programs > DAE > Installations.

b. In the left column category, choose "Nuclear Generation".

c. Select "PI-Processbook 3.2.0.0 and Datalink 4.2.0 Nuclear Bundle" from the application list.

d. Choose Install.

e. Choose Yes to the confirmation popup.

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<< Emergency Response Data System (ERDS) Activation >>

f. Wait for installation to finish.

g. Repeat Step 1.b.

4. Select the "Click To Activate" button.

a. When window appears, "ERDS is deactivated. Do you want to activate?"

- click "yes."

b. Log the current OSI-PI ERDS activation time.

c. If either Mode or ERDS Status light becomes yellow for a period exceeding 2 minutes, then contact Nuclear Computing Systems (NCS) for assistance.

d. If either Mode or ERDS Status light remains yellow for a period exceeding 5 minutes, then select the "Click to Deactivate" button and ensure NCS has been notified.

e. If ERDS fails to activate, then initiate measures to send ERDS Data manually to the NRC upon activation of the TSC, utilizing forms for recording data located in 0PEP-02.6.21, Emergency Communicator.

5. When presented with a confirmation dialog box, select "yes" to activate ERDS and verify the following:

a. Mode Button text will change to "Click to Deactivate". Mode status light will change from "Red" to "Green".

b. ERDS status message will change to "Transmitting Data", and the time stamp will update. ERDS Status light will change to "Green".

c. Within a minute of the ERDS Status changing to "Transmitting Data", the Messages Sent field should increment as each data set is sent to the NRC.

NOTE After ERDS is transmitting data, buttons at the bottom of the activation screen may be used to close the window or transition to the ERDS Data sheet to view the data.

6. If necessary to activate ERDS on the opposite unit, then select the "close" button at the bottom of the screen, and go to Step 1 for the opposite Unit.

7. Terminating the OSI/PI ERDS Datalink

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<< Emergency Response Data System (ERDS) Activation >>

a. Obtain permission from the NRC to Terminate the OSI/PI ERDS Datalink.

b. Display the ERDS activation application by one of the following methods:

(1) If using a Windows XP Desktop:

• Using a Business LAN PC in the Control Room choose:

Start > Unit "X" ERDS Activation ("X" represents the Unit 1 or 2).

• Using a Business LAN PC outside the Control Room choose: Start > NGG OSI-PI Displays > BNP Qualified >

Operations tab > Unit "X" ERDS Activation ("X" represents the Unit 1 or 2)

• Using a Business LAN PC outside the Control Room choose: Start > Programs > Business Apps > PI System >

BNP QPIM > Operations tab > Unit "X" ERDS Activation ("X" represents Unit 1 or 2)

(2) If using a Windows 7 Desktop perform one of the following:

• Click Shortcuts tab and put ERDS in search field and press search button. Then select the ERDS Shortcuts Nuclear BNP Unit 1 (RUN) for Unit 1 or ERDS Shortcuts Nuclear BNP Unit 2 (RUN) for Unit 2, and select the Run Application link to the right of it to begin ERDS activation.

• Click Shortcuts tab and put QPIM - BNP in search field and press search button. Select QPIM - BNP and select the Run Application link to the right of QPIM - BNP to begin Unit selection and ERDS activation.

c. Ensure that the Mode button reads "Click to Deactivate" and the Mode light is "Green".

d. Ensure the ERDS Status field indicates "Transmitting Data" and the ERDS Status light is "Green".

e. Select the "Click to Deactivate" button (1) Mode Button text will change to "Click to Activate". Mode status light will change to "Red".

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<< Emergency Response Data System (ERDS) Activation >>

(2) ERDS status message will change to "Disconnected" and the time stamp will update. ERDS Status light will change to "Red".

(3) Messages Sent field will reset to 0.