ML21322A326
| ML21322A326 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire  |
| Issue date: | 11/29/2021 |
| From: | Duke Energy Corp |
| To: | Andrew Hon Plant Licensing Branch II |
| Hon A | |
| References | |
| Download: ML21322A326 (13) | |
Text
Duke Energy Pre-Submittal Meeting November 29, 2021
Pre-Submittal Meeting License Amendment Request for Relocation of the Duke Energy Emergency Operations Facility (EOF)
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)
William States Lee Nuclear Station (WLS) 2 Relocation of the Duke Energy EOF
Relocation of the Duke Energy EOF Duke Energy Participants David Thompson, Emergency Preparedness CFAM Geoff Pihl, Emergency Preparedness Manager Eric White, Emergency Preparedness Specialist Andy Kalchik, Senior Nuclear Engineer, Emergency Preparedness Lee Grzeck, Fleet Licensing Director (acting)
Chris Courtenay, Lead Nuclear Engineer, Fleet Licensing 3
Relocation of the Duke Energy EOF Agenda I.
Description of Change II.
Regulatory Requirements and Guidance III.
Evaluation Approach IV.
Precedents V.
Conclusion / Schedule 4
I. Description of Change Relocate the Duke Energy Common Emergency Operations Facility (EOF) for BNP, CNS, HNP, MNS, ONS, RNP, and WLS*
Current EOF located at 526 South Church Street, Charlotte, NC New EOF located at 9700 David Taylor Drive, Charlotte, NC New EOF is approximately 9 miles north-east of current EOF Per evaluation with 10 CFR 50.54(q), relocation to the new EOF does NOT result in a Reduction In Effectiveness (RIE)
NRC Commission vote is required per 10 CFR 50 Appendix E, IV.E.8.b since EOF is located greater than 25 miles from any of the Duke Energy nuclear sites
- WLS site is included because the Combined Licenses issued for Unit 1 and Unit 2 (and being maintained) refer to the current EOF. Note that WLS is not an operational facility and is not expected to begin activities that would require physical or operational implementation into the EOF within the implementation period of this license amendment request.
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I. Description of Change CNS and MNS credit the current EOF as the near-site location for NRC and offsite responders New EOF is greater than 25 miles from CNS, therefore the Corporate Headquarters in Uptown Charlotte is credited as the new near-site location New EOF is closer to MNS than current EOF so MNS will maintain EOF as near-site location CNS and MNS credit the current EOF as the Alternate Emergency Response Facility (ERF) for Duke Energy responders to a hostile action event No changes, other than address, for CNS and MNS since the new EOF is within 30 miles of each site per NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants,Section IV.D BNP, HNP, ONS, and RNP near-site locations and Alternate ERFs are unchanged by this EOF relocation 6
I. Description of Change 7
II. Regulatory Requirements and Guidance Regulations 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 NUREG-0696, Functional Criteria for Emergency Response Facilities as modified by NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants 8
III. Evaluation Approach Description of new EOF capabilities with respect to criteria in NUREG-0696, Functional Criteria for Emergency Response Facilities as modified by NSIR/DPR-ISG-01:
Functions Location, Structure, and Habitability Emergency Response Organization (ERO) Staffing and Training Size Radiological Monitoring Communications Instrumentation, Data System Equipment, and Power Supplies Technical Data and Data System Records Availability and Management 9
III. Evaluation Approach Facility walk-through activities and familiarization drills will be conducted prior to implementation of this license amendment request Provides existing EOF staff an opportunity to occupy and activate the facility Planning a two-site simultaneous demonstration drill for April 27, 2022, using Catawba and Harris Drill at each site will involve activation of the emergency response organization and facilities, offsite notifications, dose assessment, protective action recommendations, and field monitoring team coordination Duke Energy will provide the opportunity for offsite response organizations to participate and for the NRC and FEMA to observe the drill at the new EOF North Carolina and South Carolina concurrence letters included 10
IV. Precedents Duke Energy, 2017 - Consolidated Emergency Operations Facility Consolidated Brunswick, Harris, and Robinson into the Duke Energy Common EOF that previously served Catawba, McGuire, and Oconee, as well as the future William States Lee site EOF location-related changes evaluated the same as in this license amendment request The amendment was issued by the NRC on August 21, 2017 Southern Nuclear Company, 2018 - Relocated Common EOF Sites: Farley, Hatch, Vogtle Units 1, 2, 3, and 4 Relocated EOF approximately 1 mile due to relocation of corporate headquarters Evaluation performed same as in this license amendment request The amendment was issued by the NRC on July 26, 2018 11
V. Conclusion / Schedule Conclusion LAR will request approval and Commission vote for relocation of the Duke Energy Common Emergency Operations Facility NRC Commission vote is required per 10 CFR 50 Appendix E, IV.E.8.b LAR Submittal to the NRC planned by December 31, 2021 Request 1 year NRC review from acceptance review 12
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