RA-21-0208, Revision to Radiological Emergency Response Plan Implementing Procedures. Includes 10 CFR 50.54(q)(5) Summary for AD-EP-BNP-0407, Revision 0

Revision to Radiological Emergency Response Plan Implementing Procedures. Includes 10 CFR 50.54(q)(5) Summary for AD-EP-BNP-0407, Revision 0

ML21196A418
Person / Time
Site:	Brunswick
Issue date:	07/15/2021
From:	Dewire M Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-21-0208
Download: ML21196A418 (3)

Text

f DUKE Brunswick Nuclear Plant 8470 River Rd SE

"' ENERGY Southport, NC 28461 July 15. 2021 10 CFR 50.4(b)(5)(ii) 10 CFR 50.54(q)(5)

Serial: RA-21-0208 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 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 0 of AD-EP-BNP-0407, Emergency Facilities and Equipment. As a result of implementation of AD-EP-BNP-0407, 0PEP-04.2, Emergency Facilities and Equipment, Revision 50,and 0PEP-04.6, Radiological Emergency Kit Inventories, Revision 36, have been superseded.

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. Mark DeWire, Manager - Nuclear Support Services, at (910) 832-6641 .

Mark R. DeWire Manager - Nuclear Support Services Brunswick Steam Electric Plant MAT/mat

U.S. Nuclear Regulatory Commission Page 2 of 2

Enclosure:

10 CFR 50.54(q)(5) Summary for AD-EP-BNP-0407, Revision 0 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-21-0208 Enclosure Page 1 of 1 10 CFR 50.54(q)(5) Summary for AD-EP-BNP-0407, Revision 0 In accordance with 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is providing a summary of the revision analysis for AD-EP-BNP-0407, Emergency Facilities and Equipment, Revision 0.

As a result of implementation of AD-EP-BNP-0407, 0PEP-04.2, Emergency Facilities and Equipment, Revision 50,and 0PEP-04.6,Radiological Emergency Kit Inventories, Revision 36, have been superseded. These changes became effective on July 12, 2021.

AD-EP-BNP-0407 is a site procedure superseding 0PEP-04.2 and 0PEP-04.6 into a single implementing procedure that establishes guidelines for the maintenance of the Emergency Response Facilities equipment and documentation. Guidelines for maintenance of the emergency response facilities equipment and documentation from 0PEP-04.2 and 0PEP-04.6 have been incorporated into AD-EP-BNP-0407. Changes made to the relocated guidelines were primarily administrative in nature or reflected the relocation of the site Emergency Operations Facility (EOF) to a Fleet Common EOF, as approved by the NRC on August 27, 2017, for Brunswick Units 1 and 2 by Amendments 279 and 307, respectively (ADAMS Accession Number ML17188A387).

The changes associated with superseding 0PEP-04.2 and 0PEP 04.6 with AD-EP-BNP-0407 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:

1. EREG AR Number 2382217