RA-19-0410, Revision to Radiological Emergency Response Plan Implementing Procedure

Revision to Radiological Emergency Response Plan Implementing Procedure

ML19296D079
Person / Time
Site:	Brunswick
Issue date:	10/22/2019
From:	Salazar S Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-19-0410
Download: ML19296D079 (3)

Text

Brunswick Nuclear Plant e/_~ DUKE 8470 River Rd SE

~ ENERGY Southport, NC 28461 October 22, 2019 10 CFR 50.4(b)(5)(ii) 10 CFR 50.54(q)(5)

Serial: RA-19-041 O 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 Implementing Procedure Ladies and Gentlemen:

In accordance with 10 CFR 50.4(b)(5)(ii), 10 CFR 50.54(q)(5), and 1o CFR 72.4, Duke Energy Progress, LLC (Duke Energy), is submitting an analysis summary for Revision 82 of OPEP-02.6.21, Control Room Offsite Communicator, a Radiological Emergency Response Plan (ERP) Implementing Procedure.

Duke Energy has evaluated this revision in accordance with 10 CFR 50.54(q) and determined that it does not result in a reduction in the effectiveness of the ERP. The ERP continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E.

This document contains no regulatory commitments.

Please refer any questions regarding this submittal to Mr. Stephen Yodersmith, Brunswick Regulatory Affairs, at (910) 832-2568.

Sincerely, Sabrina Salazar Manager- Nuclear Support Services Brunswick Steam Electric Plant

U.S. Nuclear Regulatory Commission Page 2 of 2

Enclosure:

10 CFR 50.54(q)(5) Summary for 0PEP-02.6.21, Revision 82 cc (with Enclosure):

U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Laura Dudes, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U.S. Nuclear Regulatory Commission ATTN: Mr. John Nguyen 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATTN: Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001 Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net

RA-19-0410 Enclosure Page 1 of 1 10 CFR 50.54(q)(5) Summary for 0PEP-02.6.21, Revision 82 In accordance with 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is providing a summary of the revision analysis for 0PEP-02.6.21, Control Room Offsite Communicator, Revision 82, which became effective on October 3, 2019.

The changes to 0PEP-02.6.21, Control Room Offsite Communicator, include eliminating confusing language and administrative overhead to remove error traps. In addition, timing standards for follow-up notifications and the default release point to use if there is no release were aligned with Duke Fleet procedures.

The time requirement for making follow-up notifications to off-site organizations was modified from within 60 minutes to approximately 60 minutes to align this procedure with the requirements of the Duke Fleet standard for State and County Notifications. Initial notifications of declaration of emergencies, or determination or changes in Protective Action Recommendations will still be made with 15 minutes as required.

The default release point reported on the Emergency Notification Form in the event there is no release, or a most likely release point is not identified, was changed from upper to lower.

This guidance aligns with the Duke Fleet standard for Offsite Protective Action Recommendations. If the release point is known, then the appropriate release point (upper or lower) will still be entered on the Emergency Notification Form.

The changes implemented by 0PEP-02.6.21, Revision 82, were evaluated in accordance with 10 CFR 50.54(q). The evaluation concluded that these changes do not result in a reduction in the effectiveness of the ERP; the ERP continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. The process and capability to activate the Emergency Response Organization are not impacted by this revision. The changes in terminology do not affect the activation or function of the Emergency Response Facilities.

Follow up notifications will continue to be made in a timely manner as outlined in the Duke Fleet standard for State and County Notifications. Meteorological conditions at appropriate levels will continue to be recorded on the Emergency Notification Form. As such, there is no impact to compliance, adherence, or effectiveness of the Emergency Plan.

Reference:

EREG AR Number 2279691