ML19214A056

Presentation: Duke Energy Presubmittal Meeting - August 7, 2019

ML19214A056
Person / Time
Site:	Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire
Issue date:	08/07/2019
From:	Duke Energy Corp
To:	Office of Nuclear Reactor Regulation
Galvin D, 415-6256
References
EPID L-2019-LRM-0048
Download: ML19214A056 (12)

Text

Duke Energy Pre-Submittal Meeting - August 7, 2019 License Amendment Request Duke Energy Common Emergency Plan Brunswick Steam Electric Plant (BNP)

Catawba Nuclear Station (CNS)

Harris Nuclear Power Plant (HNP)

McGuire Nuclear Station (MNS)

Oconee Nuclear Station (ONS)

Robinson Steam Electric Plant (RNP) 2

Duke Energy Participants David Thompson, Emergency Preparedness CFAM Eric White, Emergency Preparedness Specialist Art Zaremba, Fleet Licensing Director Josh Duc, Fleet Licensing Engineer 3

Agenda I. Description of Change II. Regulatory Requirements and Guidance III. Evaluation Approach IV. Precedents V. Conclusion / Schedule 4

I. Description of Change Combine BNP/CNS/HNP/MNS/ONS/RNP emergency plans into a Duke Energy Common Emergency Plan (DECEP) with site-specific annexes DECEP developed consistent with draft 2015 NUREG-0654 Rev. 2 (as updated by alternative guidance in June 12, 2018 NRC letter), with exceptions Each NUREG-0654 evaluation criterion (planning element) is explicitly stated, followed by a description of how the DECEP addresses that criterion TSC/OSC/EOF activated at Alert declaration, augmentation within 75 minutes DECEP defers to ANS Design Report for description of alert methods (future Wireless Emergency Alerts / Integrated Public Alert & Warning System)

Potential reductions in effectiveness (RIE) with respect to the current emergency plan or NUREG-0654 Rev. 2 are justified to show continued adequate emergency preparedness Staffing changes; maintain 75 min augmentation; other site-specific changes 5

I. Description of Change RIE with respect to current emergency plan (all sites)

Changes that align with NUREG-0654 Rev. 2 (exceptions noted below)

RIE with respect to NUREG-0654 Rev. 2 (all sites)

Maintain existing 75 minute augmentation response time NUREG-0654 Rev. 2 augmenting ERO positions not included in the DECEP:

TSC Offsite Communicator (Communications function)

TSC Dose Assessor (Dose Assessment function)

OSC Electrical Supervisor (Supervision of Repair Team Activities function)

OSC I&C Supervisor (Supervision of Repair Team Activities function)

OSC On-site FMT Driver (Field Monitoring Teams function)

TSC IT Lead (Information Technology function)

EOF IT Lead (Information Technology function)

Off-hours report-in drill once per 8 year cycle (vs. biennial)

Biennial Period for the Off-hours Call-in Drills (vs. quarterly - each ERO member biennially) 6

I. Description of Change Site-specific RIE with respect to current emergency plan

[BNP/HNP/RNP] Removed computers staged for offsite agency use at near-site facility

[CNS/MNS/ONS] Replaced FMT radios with cell phones

[CNS/MNS] Discontinued monthly phone check to National Weather Service

[MNS/ONS] Removed semiannual site assembly drill requirement

[BNP/ONS] Off-hours report-in drill once per 8 year cycle

[BNP] Removed US Coast Guard as initial notification agency

[HNP] Removed tone alert radios from Alert and Notification System

[HNP] Revised TSC design characteristic description of Seismic Category I, tornado, wind and missile safety-related criteria Site-specific RIE with respect to NUREG-0654 Rev. 2

[HNP/RNP] One (1) on-shift Radiation Protection Technician (vs. two (2) specified in NUREG-0654 Rev. 2) 7

II. Regulatory Requirements and Guidance 10 CFR 50.47, Emergency Plans 10 CFR 50 Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities 10 CFR 50.54(q), Conditions of Licenses - Emergency Plans NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants NRC Regulatory Issue Summary 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation 8

III. Evaluation Approach Side-by-side comparison of each current emergency plan against the DECEP identified potential RIE Potential RIE with respect to the current emergency plan or NUREG-0654 Rev. 2 are justified to show continued adequate emergency preparedness Description of technological advancements to support staffing changes Functional analysis performed to support staffing changes RIS 2016-10 reviewed with respect to 75 minute augmentation time Offsite Response Agency concurrence letters included 9

IV. Precedents Southern Nuclear, 2015 - Standard Emergency Plan Sites: Farley, Hatch, Vogtle Units 1, 2, 3, and 4 Merged site emergency plans into Standard Emergency Plan with site-specific annexes Did not modify emergency plans to be consistent with NUREG-0654 Rev. 2 The amendment was issued by the NRC on March 14, 2017.

Exelon, 2018 - Change to Effluent Threshold and to a Loss of Fuel Clad Barrier Threshold.

January 2018 - Braidwood, Byron, Clinton, Dresden, LaSalle, Quad Cities May 2018 - Limerick and Peach Bottom Modified ERO staffing consistent with NUREG-0654 Rev. 2 (June 12, 2018 NRC letter)

Did not merge emergency plans nor update to NUREG-0654 Rev. 2 beyond staffing The amendment was issued by the NRC on March 21, 2019 and May 24, 2019.

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V. Conclusion / Schedule LAR will request approval of a Duke Energy Common Emergency Plan developed consistent with NUREG-0654 Rev. 2 (Draft 2015), as updated by alternative guidance in June 12, 2018 NRC letter Submittal to the NRC 3rd Quarter 2019 Request 1 year NRC review 11

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