ML16032A405
| ML16032A405 | |
| Person / Time | |
|---|---|
| Site: | Harris, Brunswick, Robinson  |
| Issue date: | 01/28/2016 |
| From: | Duc B Duke Energy Corp |
| To: | Andrew Hon Plant Licensing Branch II |
| References | |
| Download: ML16032A405 (23) | |
Text
NRR-PMDAPEm Resource From: Duc, Joshua Brian <Joshua.Duc@duke-energy.com>
Sent: Thursday, January 28, 2016 12:05 PM To: Hon, Andrew Cc: Zaremba, Arthur H.
Subject:
[External_Sender] RE: RE: RE: Common EOF Pre-Submittal Attachments: Duke Energy Consolidated EOF Presentation 2-1-16.pdf
- Andy, Ive attached the presentation for this meeting. Please let me know if you need anything else.
Thanks Joshua B Duc Nuclear Fleet Licensing Engineer Fleet Regulatory Affairs Duke Energy (980)373-2011 (office)
Joshua.Duc@duke-energy.com From: Hon, Andrew [1]
Sent: Wednesday, January 20, 2016 9:30 AM To: Duc, Joshua Brian
Subject:
RE: RE: RE: Common EOF Pre-Submittal Thanks Joshua, I dont need title for now to do badging.
Andy From: Duc, Joshua Brian [2]
Sent: Wednesday, January 20, 2016 8:32 AM To: Hon, Andrew <Andrew.Hon@nrc.gov>
Cc: Zaremba, Arthur H. <Arthur.Zaremba@duke-energy.com>
Subject:
[External_Sender] RE: RE: Common EOF Pre-Submittal
- Andy, Also, if you need titles of the individuals, Ive added them below.
Thanks Joshua B Duc Nuclear Fleet Licensing Engineer Fleet Regulatory Affairs Duke Energy (980)373-2011 (office)
Joshua.Duc@duke-energy.com From: Duc, Joshua Brian Sent: Wednesday, January 20, 2016 8:10 AM To: 'andrew.hon@nrc.gov' 1
Cc: Zaremba, Arthur H.
Subject:
RE: RE: Common EOF Pre-Submittal
- Andy, The full names of the attendees are below. Also, we will send the slides to you by the end of next week. Let me know if you have any other questions.
Michael Austin Fleet Emergency Preparedness CFAM Bryan Nanney Fleet Emergency Preparedness Manager Arthur Zaremba Fleet Licensing Manager Joshua Duc Fleet Licensing Engineer Thanks Joshua B Duc Nuclear Fleet Licensing Engineer Fleet Regulatory Affairs Duke Energy (980)373-2011 (office)
Joshua.Duc@duke-energy.com From: Zaremba, Arthur H.
Sent: Wednesday, January 20, 2016 7:45 AM To: Duc, Joshua Brian
Subject:
FW: RE: Common EOF Pre-Submittal Josh, Please provide Andy the info he requested. Also, plan on sending slides end of next week. Thanks, Art From: Hon, Andrew [3]
Sent: Wednesday, January 20, 2016 7:42 AM To: Zaremba, Arthur H.
Subject:
RE: RE: Common EOF Pre-Submittal
- Art, Please send me full names next week to pre-register visitors badge.
Also, when can you send us the slides to preview to make the meeting more productive?
Thanks Andy From: Zaremba, Arthur H. [4]
Sent: Wednesday, January 20, 2016 7:40 AM To: Hon, Andrew <Andrew.Hon@nrc.gov>
Subject:
[External_Sender] RE: Common EOF Pre-Submittal Andy, Thank you. We plan on coming to the meeting in person. Probably 3 or 4 Duke participants, myself and Mike Austin, EP CFAM as a minimum.
From: Hon, Andrew [5]
Sent: Wednesday, January 20, 2016 7:30 AM To: Zaremba, Arthur H.
Cc: Miller, Ed
Subject:
Common EOF Pre-Submittal 2
- Art, As we discussed yesterday, Joe Anderson is not available in the morning. The public meeting is now scheduled for 2-4PM.
Call in # is 877-563-8411, Participant passcode: 25589 Andy From: Zaremba, Arthur H. [6]
Sent: Tuesday, January 19, 2016 9:25 AM To: Hon, Andrew <Andrew.Hon@nrc.gov>
Subject:
[External_Sender] RE: Common EOF Submittal Andy, Feb 1st is good. Can we schedule 10:00 to noon ????
From: Hon, Andrew [7]
Sent: Tuesday, January 19, 2016 8:37 AM To: Zaremba, Arthur H.
Subject:
RE: Common EOF Submittal
- Exercise caution. This is an EXTERNAL email. DO NOT open attachments or click links from unknown senders or unexpected email. ***
- Art, Joe Anderson will be off during these two dates. Can we do Feb 1, 2, or 3? Also we need to include discussion on Lee and Levy COL impact.
Andy From: Zaremba, Arthur H. [8]
Sent: Monday, January 18, 2016 10:33 AM To: Hon, Andrew <Andrew.Hon@nrc.gov>
Subject:
[External_Sender] Common EOF Submittal Andy, Would it be possible to have a pre-submittal meeting either on 2/4 or 2/9 to discuss use of the EOF here in Charlotte for Brunswick, Harris and Robinson. Our desire is to have one EOF for the fleet. We have used the Charlotte facility for several years now in support of the McGuire, Catawba and Oconee stations.
Art Zaremba Fleet Licensing Manager Charlotte, NC 28202 Office: 980-373-2062 Cell: 315-777-6832 arthur.zaremba@duke-energy.com 3
Hearing Identifier: NRR_PMDA Email Number: 2628 Mail Envelope Properties (F5B9DECD43D7984885BEB8747425F9464B64EBED)
Subject:
[External_Sender] RE: RE: RE: Common EOF Pre-Submittal Sent Date: 1/28/2016 12:05:09 PM Received Date: 1/28/2016 12:05:39 PM From: Duc, Joshua Brian Created By: Joshua.Duc@duke-energy.com Recipients:
"Zaremba, Arthur H." <Arthur.Zaremba@duke-energy.com>
Tracking Status: None "Hon, Andrew" <Andrew.Hon@nrc.gov>
Tracking Status: None Post Office: IMCLTEXCP64.nam.ent.duke-energy.com Files Size Date & Time MESSAGE 4877 1/28/2016 12:05:39 PM Duke Energy Consolidated EOF Presentation 2-1-16.pdf 1325398 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
LAR Pre-submittal Meeting - Consolidation of Robinson, Harris, and Brunswick Emergency Operations Facilities February 1, 2016
Duke Energy Attendees Mike Austin (CFAM, Emergency Preparedness)
Bryan Nanney (Manager, Emergency Preparedness)
Art Zaremba (Manager, Nuclear Fleet Licensing)
Josh Duc (Fleet Licensing) 2
Outline Purpose Scope Justification Schedule 3
Purpose Consolidate Robinson (RNP), Harris (HNP), and Brunswick (BSEP) EOFs into the Duke Energy corporate EOF in Charlotte, NC, which currently serves Catawba (CNS),
McGuire (MNS) and Oconee (ONS) Nuclear Stations Increased efficiency Improved response capability Increased site Emergency Response Organization (ERO) resources 4
Scope Request NRC approval to locate the EOFs farther than 25 miles from the plant -
Commission approval required per 10 CFR 50, Appendix E, IV.E.8.b Distance to EOF Reactor Site (Approximate Air Miles)
Existing Proposed (Charlotte)
Brunswick Steam Electric Plant On-site 184 Shearon Harris Nuclear Power Plant 2 110 H. B. Robinson Steam Electric Plant On-site 69 Request NRC approval to increase ERO augmentation time to match CNS/MNS/ONS:
All 60-75 minute responders (from notification) increase to 75 minutes (from declaration)
All 30-45 minute responders (from notification) increase to 45 minutes (from declaration)
Associated Emergency Plan changes will be included in the submittal 5
6 Justification Justification addresses NUREG-0696 Section 4, Emergency Operations Facility (as updated by NSIR/DPR-ISG-01):
Functions Location, structure, and habitability Staffing and training Size Radiological monitoring Communications Instrumentation, data system equipment, and power supplies Technical data and data system Records availability and management 7
Justification Functions Management of overall licensee emergency response Well-established processes/procedures; Standard ERO to be implemented Coordination of radiological and environmental assessment Unified RASCAL Interface (URI) used at all sites Determination of recommended public protective actions Training will be provided Notification of offsite agencies Duke Emergency Management Network (DEMNET) used at all sites Coordination of information provided to public information staff Near-site JICs will remain; Corporate JIC intends to provide support 8
Justification Functions (contd)
Staffing and activation within time frames and at emergency classification levels defined in E-Plan Augmentation time increase of all 60-75 min (from notification) responders to 75 min (from declaration)
Augmentation time increase of all 30-45 min (from notification) responders to 45 min (from declaration)
Coordination of emergency response activities with Federal, State, tribal, and local agencies States currently respond to Charlotte, local does not - same for current BSEP/HNP/RNP EOFs State/local concurrence letters will be obtained Anticipated locations of near-site facilities for NRC and offsite agency staff BSEP - Duke Energy Progress Building, Leland, NC HNP - Harris E&E Center, New Hill, NC RNP - Remote Emergency Response Facility, Hartsville, SC 9
Justification Functions (contd)
Obtaining and displaying key plant data and radiological information for each unit ERFIS data will be obtained via a cyber security compliant method Analyzing plant technical information and providing technical briefings on event conditions and prognosis to licensee staff and offsite agency responders for each type of unit or plant Existing Charlotte EOF equipment/space supports this function Effectively responding to and coordinating response efforts for events occurring simultaneously at more than one site for a consolidated EOF Charlotte EOF will continue to maintain the capability to respond to a two-site event
- ONS E-Plan requires a two-site drill every 6 years LAR will recognize the request of Lee Station to utilize the Charlotte EOF but treat it as a separate request Levy Station does not intend to utilize the Charlotte EOF 10
Justification Location, structure, and habitability The existing facility is an approved EOF Backup power is available Charlotte EOF was recently upgraded Staffing and training Existing Charlotte staff will be used BSEP/HNP/RNP specific training will be provided Size Total EOF space is ~8900 sf. Working space is ~7600 sf Radiological monitoring is not required due to >10 miles from any nuclear station 11
Justification 12
13 14 Justification Communications DEMNET, commercial phone lines, emergency telecommunications system, radio system (field monitoring teams), satellite phones Instrumentation, data system equipment, and power supplies & technical data / data system New plant communication voice and data network will be installed to provide a cyber security compliant method of accessing and displaying plant data for BSEP/HNP/RNP Records availability and management Key reference material will be available via either hard copy or electronic access 15
Justification Markups of the Emergency Plans will show:
Changes directly related to the change in EOF location New near-site facility description Changes directly related to the change in augmentation time Precedent Six-site EOF - Exelon 75 minute augmentation - Catawba, McGuire, Oconee, Grand Gulf, Hatch/Farley/Vogtle LAR 16
Justification Applicable regulations and guidance for EOF location:
10 CFR 50, Appendix E, IV.E.8.b - LAR required for EOF > 25 miles; near-site facility requirements 10 CFR 50, Appendix E, IV.E.8.c - capability for data acquisition and display, technical analysis of event conditions, and support response for multiple reactor sites 10 CFR 50.47(b)(1) - licensee/State/local responsibilities assigned and staffing available 10 CFR 50.47(b)(3) - arrangements are made at EOF for State and local staff 10 CFR 50.47(b)(8) - adequate emergency facilities are provided and maintained 10 CFR 50.47(b)(9) - adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences NUREG-0696, Functional Criterial for Emergency Response Facilities Applicable regulations and guidance for EOF augmentation time:
10 CFR 50.47(b)(2) - timely augmentation of response capabilities is available NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 17
Schedule LAR submittal March 2016 Commission approval required NRC approval requested one year from submittal date Implementation period of 120 days 18
19 NRR-PMDAPEm Resource From: Duc, Joshua Brian <Joshua.Duc@duke-energy.com>
Sent: Thursday, January 28, 2016 12:05 PM To: Hon, Andrew Cc: Zaremba, Arthur H.
Subject:
[External_Sender] RE: RE: RE: Common EOF Pre-Submittal Attachments: Duke Energy Consolidated EOF Presentation 2-1-16.pdf
- Andy, Ive attached the presentation for this meeting. Please let me know if you need anything else.
Thanks Joshua B Duc Nuclear Fleet Licensing Engineer Fleet Regulatory Affairs Duke Energy (980)373-2011 (office)
Joshua.Duc@duke-energy.com From: Hon, Andrew [9]
Sent: Wednesday, January 20, 2016 9:30 AM To: Duc, Joshua Brian
Subject:
RE: RE: RE: Common EOF Pre-Submittal Thanks Joshua, I dont need title for now to do badging.
Andy From: Duc, Joshua Brian [10]
Sent: Wednesday, January 20, 2016 8:32 AM To: Hon, Andrew <Andrew.Hon@nrc.gov>
Cc: Zaremba, Arthur H. <Arthur.Zaremba@duke-energy.com>
Subject:
[External_Sender] RE: RE: Common EOF Pre-Submittal
- Andy, Also, if you need titles of the individuals, Ive added them below.
Thanks Joshua B Duc Nuclear Fleet Licensing Engineer Fleet Regulatory Affairs Duke Energy (980)373-2011 (office)
Joshua.Duc@duke-energy.com From: Duc, Joshua Brian Sent: Wednesday, January 20, 2016 8:10 AM To: 'andrew.hon@nrc.gov' 1
Cc: Zaremba, Arthur H.
Subject:
RE: RE: Common EOF Pre-Submittal
- Andy, The full names of the attendees are below. Also, we will send the slides to you by the end of next week. Let me know if you have any other questions.
Michael Austin Fleet Emergency Preparedness CFAM Bryan Nanney Fleet Emergency Preparedness Manager Arthur Zaremba Fleet Licensing Manager Joshua Duc Fleet Licensing Engineer Thanks Joshua B Duc Nuclear Fleet Licensing Engineer Fleet Regulatory Affairs Duke Energy (980)373-2011 (office)
Joshua.Duc@duke-energy.com From: Zaremba, Arthur H.
Sent: Wednesday, January 20, 2016 7:45 AM To: Duc, Joshua Brian
Subject:
FW: RE: Common EOF Pre-Submittal Josh, Please provide Andy the info he requested. Also, plan on sending slides end of next week. Thanks, Art From: Hon, Andrew [11]
Sent: Wednesday, January 20, 2016 7:42 AM To: Zaremba, Arthur H.
Subject:
RE: RE: Common EOF Pre-Submittal
- Art, Please send me full names next week to pre-register visitors badge.
Also, when can you send us the slides to preview to make the meeting more productive?
Thanks Andy From: Zaremba, Arthur H. [12]
Sent: Wednesday, January 20, 2016 7:40 AM To: Hon, Andrew <Andrew.Hon@nrc.gov>
Subject:
[External_Sender] RE: Common EOF Pre-Submittal Andy, Thank you. We plan on coming to the meeting in person. Probably 3 or 4 Duke participants, myself and Mike Austin, EP CFAM as a minimum.
From: Hon, Andrew [13]
Sent: Wednesday, January 20, 2016 7:30 AM To: Zaremba, Arthur H.
Cc: Miller, Ed
Subject:
Common EOF Pre-Submittal 2
- Art, As we discussed yesterday, Joe Anderson is not available in the morning. The public meeting is now scheduled for 2-4PM.
Call in # is 877-563-8411, Participant passcode: 25589 Andy From: Zaremba, Arthur H. [14]
Sent: Tuesday, January 19, 2016 9:25 AM To: Hon, Andrew <Andrew.Hon@nrc.gov>
Subject:
[External_Sender] RE: Common EOF Submittal Andy, Feb 1st is good. Can we schedule 10:00 to noon ????
From: Hon, Andrew [15]
Sent: Tuesday, January 19, 2016 8:37 AM To: Zaremba, Arthur H.
Subject:
RE: Common EOF Submittal
- Exercise caution. This is an EXTERNAL email. DO NOT open attachments or click links from unknown senders or unexpected email. ***
- Art, Joe Anderson will be off during these two dates. Can we do Feb 1, 2, or 3? Also we need to include discussion on Lee and Levy COL impact.
Andy From: Zaremba, Arthur H. [16]
Sent: Monday, January 18, 2016 10:33 AM To: Hon, Andrew <Andrew.Hon@nrc.gov>
Subject:
[External_Sender] Common EOF Submittal Andy, Would it be possible to have a pre-submittal meeting either on 2/4 or 2/9 to discuss use of the EOF here in Charlotte for Brunswick, Harris and Robinson. Our desire is to have one EOF for the fleet. We have used the Charlotte facility for several years now in support of the McGuire, Catawba and Oconee stations.
Art Zaremba Fleet Licensing Manager Charlotte, NC 28202 Office: 980-373-2062 Cell: 315-777-6832 arthur.zaremba@duke-energy.com 3
Hearing Identifier: NRR_PMDA Email Number: 2628 Mail Envelope Properties (F5B9DECD43D7984885BEB8747425F9464B64EBED)
Subject:
[External_Sender] RE: RE: RE: Common EOF Pre-Submittal Sent Date: 1/28/2016 12:05:09 PM Received Date: 1/28/2016 12:05:39 PM From: Duc, Joshua Brian Created By: Joshua.Duc@duke-energy.com Recipients:
"Zaremba, Arthur H." <Arthur.Zaremba@duke-energy.com>
Tracking Status: None "Hon, Andrew" <Andrew.Hon@nrc.gov>
Tracking Status: None Post Office: IMCLTEXCP64.nam.ent.duke-energy.com Files Size Date & Time MESSAGE 4877 1/28/2016 12:05:39 PM Duke Energy Consolidated EOF Presentation 2-1-16.pdf 1325398 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
LAR Pre-submittal Meeting - Consolidation of Robinson, Harris, and Brunswick Emergency Operations Facilities February 1, 2016
Duke Energy Attendees Mike Austin (CFAM, Emergency Preparedness)
Bryan Nanney (Manager, Emergency Preparedness)
Art Zaremba (Manager, Nuclear Fleet Licensing)
Josh Duc (Fleet Licensing) 2
Outline Purpose Scope Justification Schedule 3
Purpose Consolidate Robinson (RNP), Harris (HNP), and Brunswick (BSEP) EOFs into the Duke Energy corporate EOF in Charlotte, NC, which currently serves Catawba (CNS),
McGuire (MNS) and Oconee (ONS) Nuclear Stations Increased efficiency Improved response capability Increased site Emergency Response Organization (ERO) resources 4
Scope Request NRC approval to locate the EOFs farther than 25 miles from the plant -
Commission approval required per 10 CFR 50, Appendix E, IV.E.8.b Distance to EOF Reactor Site (Approximate Air Miles)
Existing Proposed (Charlotte)
Brunswick Steam Electric Plant On-site 184 Shearon Harris Nuclear Power Plant 2 110 H. B. Robinson Steam Electric Plant On-site 69 Request NRC approval to increase ERO augmentation time to match CNS/MNS/ONS:
All 60-75 minute responders (from notification) increase to 75 minutes (from declaration)
All 30-45 minute responders (from notification) increase to 45 minutes (from declaration)
Associated Emergency Plan changes will be included in the submittal 5
6 Justification Justification addresses NUREG-0696 Section 4, Emergency Operations Facility (as updated by NSIR/DPR-ISG-01):
Functions Location, structure, and habitability Staffing and training Size Radiological monitoring Communications Instrumentation, data system equipment, and power supplies Technical data and data system Records availability and management 7
Justification Functions Management of overall licensee emergency response Well-established processes/procedures; Standard ERO to be implemented Coordination of radiological and environmental assessment Unified RASCAL Interface (URI) used at all sites Determination of recommended public protective actions Training will be provided Notification of offsite agencies Duke Emergency Management Network (DEMNET) used at all sites Coordination of information provided to public information staff Near-site JICs will remain; Corporate JIC intends to provide support 8
Justification Functions (contd)
Staffing and activation within time frames and at emergency classification levels defined in E-Plan Augmentation time increase of all 60-75 min (from notification) responders to 75 min (from declaration)
Augmentation time increase of all 30-45 min (from notification) responders to 45 min (from declaration)
Coordination of emergency response activities with Federal, State, tribal, and local agencies States currently respond to Charlotte, local does not - same for current BSEP/HNP/RNP EOFs State/local concurrence letters will be obtained Anticipated locations of near-site facilities for NRC and offsite agency staff BSEP - Duke Energy Progress Building, Leland, NC HNP - Harris E&E Center, New Hill, NC RNP - Remote Emergency Response Facility, Hartsville, SC 9
Justification Functions (contd)
Obtaining and displaying key plant data and radiological information for each unit ERFIS data will be obtained via a cyber security compliant method Analyzing plant technical information and providing technical briefings on event conditions and prognosis to licensee staff and offsite agency responders for each type of unit or plant Existing Charlotte EOF equipment/space supports this function Effectively responding to and coordinating response efforts for events occurring simultaneously at more than one site for a consolidated EOF Charlotte EOF will continue to maintain the capability to respond to a two-site event
- ONS E-Plan requires a two-site drill every 6 years LAR will recognize the request of Lee Station to utilize the Charlotte EOF but treat it as a separate request Levy Station does not intend to utilize the Charlotte EOF 10
Justification Location, structure, and habitability The existing facility is an approved EOF Backup power is available Charlotte EOF was recently upgraded Staffing and training Existing Charlotte staff will be used BSEP/HNP/RNP specific training will be provided Size Total EOF space is ~8900 sf. Working space is ~7600 sf Radiological monitoring is not required due to >10 miles from any nuclear station 11
Justification 12
13 14 Justification Communications DEMNET, commercial phone lines, emergency telecommunications system, radio system (field monitoring teams), satellite phones Instrumentation, data system equipment, and power supplies & technical data / data system New plant communication voice and data network will be installed to provide a cyber security compliant method of accessing and displaying plant data for BSEP/HNP/RNP Records availability and management Key reference material will be available via either hard copy or electronic access 15
Justification Markups of the Emergency Plans will show:
Changes directly related to the change in EOF location New near-site facility description Changes directly related to the change in augmentation time Precedent Six-site EOF - Exelon 75 minute augmentation - Catawba, McGuire, Oconee, Grand Gulf, Hatch/Farley/Vogtle LAR 16
Justification Applicable regulations and guidance for EOF location:
10 CFR 50, Appendix E, IV.E.8.b - LAR required for EOF > 25 miles; near-site facility requirements 10 CFR 50, Appendix E, IV.E.8.c - capability for data acquisition and display, technical analysis of event conditions, and support response for multiple reactor sites 10 CFR 50.47(b)(1) - licensee/State/local responsibilities assigned and staffing available 10 CFR 50.47(b)(3) - arrangements are made at EOF for State and local staff 10 CFR 50.47(b)(8) - adequate emergency facilities are provided and maintained 10 CFR 50.47(b)(9) - adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences NUREG-0696, Functional Criterial for Emergency Response Facilities Applicable regulations and guidance for EOF augmentation time:
10 CFR 50.47(b)(2) - timely augmentation of response capabilities is available NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 17
Schedule LAR submittal March 2016 Commission approval required NRC approval requested one year from submittal date Implementation period of 120 days 18
19