RA-19-0474, Revision to Radiological Emergency Response Plan and Implementing Procedures

Revision to Radiological Emergency Response Plan and Implementing Procedures

ML20006E737
Person / Time
Site:	Brunswick
Issue date:	01/06/2020
From:	Salazar S Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-19-0474
Download: ML20006E737 (5)

Text

Brunswick Nuclear Plant

~ ~ DUKE 8470 River Rd SE

~ ENERGY~ Southport, NC 28461 January 6, 2020 10 CFR 50.4(b)(5)(ii) 10 CFR 50.54(q)(5)

Serial: RA-19-0474 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 Procedures Ladies and Gentlemen:

In accordance with 10 CFR 50.4(b)(5)(ii), 10 CFR 50.54(q)(5), and 10 CFR 72.4, Duke Energy Progress, LLC (Duke Energy), is submitting an analysis summary for Revision 93 of the Radiological Emergency Response Plan (ERP) (i.e., OERP, Radiological Emergency Response Plan). In addition, analysis summaries are being provided for the Radiological ERP Implementing Procedures OPEP-02.1, Initial Emergency Actions, and OPEP-02.2.1, Emergency Action Level Technical Bases, which were superseded by procedures CSD-EP-BNP-0101-02, EAL Wal/chart (Both Hot and Cold), and CSD-EP-BNP-0101-01, EAL Technical Basis Document, respectively.

Duke Energy has evaluated these changes in accordance with 10 CFR 50.54(q) and determined that they 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.

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

Enclosures:

1. 10 CFR 50.54(q)(5) Summary for 0ERP, Revision 93

2. 10 CFR 50.54(q)(5) Summary for CSD-EP-BNP-0101-02, Revision 0

3. 10 CFR 50.54(q)(5) Summary for CSD-EP-BNP-0101-01, Revision 0 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-19-0474 Enclosure 1 Page 1 of 1 10 CFR 50.54(q)(5) Summary for 0ERP, Revision 93 In accordance with 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is providing a summary of the revision analysis for 0ERP, Radiological Emergency Response Plan, Revision 93, which became effective on December 17, 2019.

The changes to 0ERP, Radiological Emergency Response Plan, include editorial changes with no change to intent and changes that are not associated with a planning standard and do not affect the Brunswick Emergency plan functions. In addition to these changes, the Operator at the Controls (OAC) Support responsibilities and procedure steps were moved to Information Technology (IT) Support and the NRC Communicator in the Technical Support Center (TSC).

Also, the Administrative Support position and the Registration Liaison position were deleted from the Joint Information Center (JIC) operations. The deletion of these positions requires some tasks from the deleted positions to move to other positions in the JIC. These changes in the OAC Support responsibilities and the deletion of the Administrative Support position and the Registration Liaison position were due to personnel changes and efficiency gains.

The changes implemented by 0ERP, Revision 93, 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. Responsibilities for dissemination of public information during emergencies continue to be defined and timely. The ERO continues to be staffed to augment initial response on a continuous basis. Additionally, the process for timely augmentation of on shift staff is established and maintained. As such, there is no impact to compliance, adherence, or effectiveness of the Emergency Plan.

Reference:

EREG AR Number 02307258

RA-19-0474 Enclosure 2 Page 1 of 1 10 CFR 50.54(q)(5) Summary for CSD-EP-BNP-0101-02, Revision 0 In accordance with 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is providing a summary of the revision analysis for 0PEP-02.1, Initial Emergency Actions, which was superseded by CSD-EP-BNP-0101-02, EAL Wallchart (Both Hot and Cold), Revision 0, on December 16, 2019.

On July 1, 2019, the Nuclear Regulatory Commission (NRC) issued license amendments for the Brunswick Steam Electric Plant, Units 1 and 2, to revise Emergency Action Level (EAL) schemes to incorporate clarifications provided by Emergency Preparedness Frequently Asked Questions (EPFAQ) 2015-013 and 2016-002 (Reference ML19058A632). CSD-EP-BNP-0101-02, Revision 0, implemented changes per this approved License Amendment Request (LAR) to incorporate EPFAQ 2015-013 and EPFAQ 2016-002 which eliminated the Hostile Event General Emergency and revised the Hazardous Event Affecting Safety Systems EALs. Along with these changes, Table F-1, Fission Product Barrier Threshold Matrix, was modified for Human Factoring by splitting a compound statement into two statements for RPV Water Level under Fuel Clad Barrier Potential Loss and RCS Barrier Loss. Changes to formatting were also implemented, including separating the Hot and Cold boards into separate boards, moving the location of the notes box to make it more readable, and adding a colored box with BNP inside for Human Factoring at the Common EOF.

The changes implemented by CSD-EP-BNP-0101-02, Revision 0, were evaluated in accordance with 10 CFR 50.54(q). The EPFAQ LAR changes were approved by the NRC and the other 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. As such, there is no impact to compliance, adherence, or effectiveness of the Emergency Plan.

Reference:

EREG AR Numbers 2303384 and 2302912

RA-19-0474 Enclosure 3 Page 1 of 1 10 CFR 50.54(q)(5) Summary for CSD-EP-BNP-0101-01, Revision 0 In accordance with 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is providing a summary of the revision analysis for 0PEP-02.2.1, Emergency Action Level Technical Bases, which was superseded by CSD-EP-BNP-0101-01, EAL Technical Basis Document, Revision 0, on December 16, 2019.

On July 1, 2019, the Nuclear Regulatory Commission (NRC) issued license amendments for the Brunswick Steam Electric Plant, Units 1 and 2, to revise Emergency Action Level (EAL) schemes to incorporate clarifications provided by Emergency Preparedness Frequently Asked Questions (EPFAQ) 2015-013 and 2016-002 (Reference ML19058A632). CSD-EP-BNP-0101-01, Revision 0, implemented changes per this approved License Amendment Request (LAR) to incorporate EPFAQ 2015-013 and EPFAQ 2016-002 which eliminated the Hostile Event General Emergency and revised the Hazardous Event Affecting Safety Systems bases statements. In addition to these changes, clarification was made to the Seismic Event Unusual Event classification basis to define the initiating point for the event as receipt of the annunciator to eliminate potential for delays in making this classification. The Control Room Evacuation basis statement wording was changed from Control Room inoperable to uninhabitable to align with the intent that the Control Room would need to be evacuated for this classification to apply. Fission Product Barrier Matrix changes were made to ensure the basis statements matched the definition of unisolable in Reactor Coolant System Loss B1 (per approved EPFAQ 2018-002; Reference ML18338A308) and Primary Containment Loss E1 by removing comments indicating isolation from the Control Room only was credited, while ensuring classification is still made within 15 minutes of initial event indications. Fission Product Barrier Matrix Reactor Coolant System Loss for Primary Containment Conditions added a statement that the clock start for classification begins when containment pressure exceeds 1.7 psig to eliminate potential for delays in making this classification. The statement sentences were also rearranged for logical continuity. Confusing wording was removed from Fission Product Barrier Matrix Primary Containment Barrier Loss for Primary Containment Conditions to ensure consistent response to the initiating events for containment failure. Editorial changes were made throughout to update references and correct grammar.

The changes implemented by CSD-EP-BNP-0101-01, Revision 0, were evaluated in accordance with 10 CFR 50.54(q). The EPFAQ LAR changes were approved by the NRC and the other 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. An Emergency Classification System using a standard scheme of emergency classification and action levels continues to be maintained, and the changes do not affect the standard scheme of emergency classification and action levels in use. As such, there is no impact to compliance, adherence, or effectiveness of the Emergency Plan.

Reference:

EREG AR Numbers 2304267, 2297373, and 2300344