RA-20-0375, Revision to Radiological Emergency Response Plan Implementing Procedure

Revision to Radiological Emergency Response Plan Implementing Procedure

ML20343A266
Person / Time
Site:	Brunswick
Issue date:	12/07/2020
From:	Salazar S Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0375
Download: ML20343A266 (3)

Text

Brunswick Nuclear Plant

( ~ DUKE 8470 River Rd SE ENERGY Southport, NC 28461 10 CFR 50.4(b)(5)(ii)

December 7, 2020 10 CFR 50.54(q)(5)

Serial: RA-20-0375 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 10 CFR 72.4, Duke Energy Progress, LLC (Duke Energy), is submitting an analysis summary for Revision 2 of CSD-EP-BNP-0101-01, EAL Technical Basis Document, and Revision 2 of CSD-EP-BNP-0101-02, EAL Wal/chart (Both Hot And Cold), Radiological Emergency Response Plan (ERP) Implementing Procedures.

Duke Energy has evaluated these revisions 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, S rina 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 CSD-EP-BNP-0101-01, Revision 2, and CSD-EP-BNP-0101-02, Revision 2 cc (with Enclosure):

Ms. Laura Dudes, NRC Regional Administrator, Region II Mr. Andrew Hon, NRC Project Manager Mr. Gale Smith, NRC Senior Resident Inspector Mr. John Nguyen, NRC Director Spent Fuel Management Division, NRC Nuclear Material Safety / Safeguards Office Chair - North Carolina Utilities Commission

RA-20-0375 Enclosure Page 1 of 1 10 CFR 50.54(q)(5) Summary for CSD-EP-BNP-0101-01, Revision 2, and CSD-EP-BNP-0101-02, Revision 2 In accordance with 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is providing a summary of the revision analysis for CSD-EP-BNP-0101-01, EAL Technical Basis Document, Revision 2, and CSD-EP-BNP-0101-02, EAL Wallchart (Both Hot And Cold), Revision 2, which both became effective on November 19, 2020.

The changes to CSD-EP-BNP-0101-01, EAL Technical Basis Document, and CSD-EP-BNP-0101-02, EAL Wallchart (Both Hot And Cold), 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, CSD-EP-BNP-0101-01 and CSD-EP-BNP-0101-02 Spent Fuel Pool Emergency Action Level (EAL) threshold values for RS2.1 and RG2.1 were revised taking into account potential obstructions and instrument uncertainty. The Level 3 value prior to this revision was determined to be accurate and appropriate to meet NEI 12-02 requirements. However, site-specific constraints and limitations were not considered in determining the appropriate threshold value for EALs RS2.1 and RG2.1. These EAL modifications do not alter the intent of any specific EAL described in NEI 99-01, Rev. 6. The updated level still represents the Level 3 value because this is a level "where the spent fuel remains covered and action to implement make-up water addition should no longer be deferred". Additional changes to CSD-EP-BNP-0101-01 included the addition of clarification to the technical basis document for EALs CA6.1 and SA8.1. Clarifying information was added such as the addition of a sentence to the beginning of these bases sections to clarify that the EAL is based off the significance of the event that caused damage, bolding portions of the original technical basis information for emphasis, and adding a table of nonspecific equipment scenarios to provide clarifying examples of what does and what does not meet Alert classifications under these EALs to help ensure predictable and accurate classification. These clarifications are intended to minimize the potential for an under or over-classification of equipment failure.

The changes implemented by CSD-EP-BNP-0101-01, Revision 2, and CSD-EP-BNP-0101-02, Revision 2, 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 changes do not reduce the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in a site-specific application or from the endorsed industry EAL scheme that had been approved. The meaning or intent of the basis of the approved EAL is unchanged. As such, there is no impact to compliance, adherence, or effectiveness of the Emergency Plan.

Reference:

EREG AR Number 2355075