Text

Submittal of Emergency Plan Implementing Procedure Revisions
	ML16287A409
Person / Time
Site:	Catawba
Issue date:	10/10/2016
From:	Simril T; Duke Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CNS-16-068
	Download: ML16287A409 (182)
	v • d • e

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CNS-16-068 10CFR 50.54(q)

October 10, 2016 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC Catawba Nuclear Station Units 1 and 2 Docket Nos. 50-413 and 50-414 Emergency Plan Implementing Procedures Please find enclosed for NRG Staff use the following 10CFR 50.54(q) Evaluations for Catawba Nuclear Station, Emergency Plan Implementing Procedure (EPIP) Revisions:

RP/O/A/5000/002 Notification of Unusual Event Revision 046 RP/O/A/5000/003 Alert Revision 051 RP/O/A/5000/004 Site Area Emergency Revision 054 RP/O/A/5000/005 General Emergency Revision 056 RP/O/A/5000/006 A Notifications to States and Counties Revision 035 From the Control Room RP/O/A/5000/006 B Notifications to States and Counties Revision 039 From the Technical Support Center RP/O/A/5000/020 Technical Support Center (TSC) Revision 041 Activation Procedure These revision evaluations are being submitted in accordance with 10CFR 50.54(q) and do not cause a reduction in the effectiveness of the Emergency Plan Implementing Procedures or the Emergency Plan.

U.S. Nuclear Regulatory Commission October 10, 2016 Page 2 There are no new regulatory commitments in these documents. By copy of this letter, two copies of these documents are being provided to the NRC, Region II.

If there are any questions, please call Tom Arlow at 803-701-4027.

Sincerely,

IOYY\~

Tom Simril Vice President, Catawba Nuclear Station Attachments: 1. 10CFR50.54 (q) Evaluation of RP/O/A/5000/002, Rev. 046

2. 10CFR50.54 (q) Evaluation of RP/O/A/5000/003, Rev. 051

3. 10CFR50.54 (q) Evaluation of RP/O/A/5000/004, Rev. 054

4. 10CFR50.54 (q) Evaluation of RP/O/A/5000/005, Rev. 056

5. 10CFR50.54 (q) Evaluation of RP/O/A/5000/006A, Rev. 035

6. 10CFR50.54 (q) Evaluation of RP/O/A/5000/0068, Rev. 039

7. 10CFR50.54 (q) Evaluation of RP/O/A/5000/020, Rev. 041

U.S. Nuclear Regulatory Commission October 10, 2016 Page 3 xc (w/attachments):

Catherine Haney, Regional Administrator U. S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 (w/o attachments):

Michael Orenak NRC Project Manager (CNS)

U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 0-8G9A 11555 Rockville Pike Rockville, MD 20852-2738 Joseph D. Austin NRC Senior Resident Inspector (CNS)

Christian B. Scott NRC Resident Inspector (CNS)

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ATTACHMENT 4 Page 1of5

<< 10 CFR 50.54(q) Screening Evaluation Form>>

Sqre8,nihg and Eyatu.ati611 Num~er BNP D EREG #: _ _ _~2055115 _ _ __ CNS

CR3 D HNP D MNS D 5AD #: _ _ _ _----'20501 oo ___ ONS D RNP D GO D Document and Revision RP/0/A/5000/002, Notification of Unusual Event, rev 046 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

Note prior to 2.8 changed from "NOTE: Turnover of command and control to the TSC or EOF relieves the OSM/Emergency Coordinator of classification, notification and Protective Action Recommendations (PAR) responsibilities allowing a focused effort on plant response."

to "NOTE: 1. Turnover of command and control to the TSC relieves the SM/Emergency Coordinator of Classification, Notification and Protective Action Recommendations (PAR) responsibilities.

2. Turnover to the EOF relieves the SM/Emergency Coordinator ofNotification and Protective Action Recommendation (PAR) responsibilities ONLY."

2.8.1 changed from "Provide turnover to the TSC Emergency Coordinator using Enclosure 4.2" to "IF the emergency situation does NOT prevent activation of the TSC within 75 minutes, provide turnover to the TSC Emergency Coordinator using Enclosure 4.2" 2.8.2 changed from "IF the emergency situation prevents activation of the TSC within 75 minutes of declaration, contact the EOF Director and perform the following:

A turnover using Enclosure 4.2

IF time allows, refer to EOF Director Turnover Form in RP/O/A/5000/020, "Technical Support Center (TSC) Activation", Enclosure 4.1, for a job aid that provides additional turnover detail for the EOF."

to "IF the emergency situation prevents activation of the TSC within 75 minutes of declaration, contact the EOF Director and perform the following:

A turnover for Notification and Protective Action Recommendation (PAR) ONLY using Enclosure 4.2

__ .~

Maintain command and control of classification until TSC is capable of accepting turnover" Part I. Description of Proposed Change (continued):

2.8.3 changed from "IF neither facility can take turnover, maintain command and control until one of the facilities is capable of accepting turnover.".

to "IF neither facility can take turnover, maintain command and control until the facility is capable of accepting turnover." .1, Note prior to step 1.1 added "2. A Job Aid for ERONS is located in the communicator's area that directs the Operator to notify Security to activate the ERO." .2, Emergency Coordinator/EOF Director Turnover Form Replaced the entirety of the enclosure with a new fleet standard turnover form Part II. Activity Previously Reviewed? Yes ID No I*

Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or 10 CFR 50.54(q) Continue to Alert and Notification System Design Report? Effectiveness Attachment 4 Evaluation is not , 10 CFR If yes, identify bounding source document number or approval reference and required. Enter 50.54(q) ensure the basis for concluding the source document fully bounds the proposed justification Screening change is documented below: below and Evaluation complete Form, Part Ill Justification: Attachment 4, Part V.

Bounding document attached (optional) 10

Part Ill. Editorial Change Yes 10 No

Is this activity an editorial or typographical change only, such as formatting, 10 CFR 50.54(q) Continue to paragraph numbering, spelling, or punctuation that does not change intent? Effectiveness Attachment 4, Evaluation is not Part IV and required. Enter address non Justification:

justification and editorial complete changes Attachment 4, PartV & VI.

Part IV. Emergency Planning Element and Function Screen (Reference Attachment 1, Considerations for Addressing Screening Criteria)

Does this activity involve any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If answer is yes, then check box.

1a Responsibility for emergency response is assigned.

1b The response organization has the staff to respond and to augment staff on a continuing basis 0 (24-7 staffing) in accordance with the emergency plan.

2a Process ensures that onshift emergency response responsibilities are staffed and assigned 0 2b The process for timely augmentation of onshift staff is established and maintained.

3a Arrangements for requesting and using off site assistance have been made. 0 3b State and local staff can be accommodated at the EOF in accordance with the emergency plan. 0 (NA for CR3) 4.

4a A standard scheme of emergency classification and action levels is in use. 0 (Requires final approval of Screen and Evaluation by EP CFAM.)

5a Procedures for notification of State and local governmental agencies are capable of initiating notification 0 of the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.

5b Administrative and physical means have been established for alerting and providing prompt instructions 0 to the public within the plume exposure pathway. (NA for CR3) 5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 0 Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. (NA for CR3)

I Part IV. Emergency Pla11ning Element cind Function Screen (cont.)

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.. -=.~~=::.=.~~""-*..=.:=:.'*=-7=--~===~.""_.*-"'".~"":*:_=*__=_,=**=,*"'":*~--*1 6a Systems are established for prompt communication among principal emergency response D organizations.

6b Sy,stems are established for prompt communication to E:lmergency respqnse personnel. D

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?a Emergency preparedness information is rhac:je avaii'able to the public on a periodic basis within the D plume ,exposure pcithway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established. D Ba Ad~quate facilities are maintained to support emergency response. D 8b Adeguate eqUipment is maintain'i:id to support emergency response. D 9a Me~h9ds! sxstems, and e9uipm~ntfor assessment of radioactive releases are in use. D 1Oa A range of public PARs is available for implementation during emergencies. (NA for CR3) D 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available D to support the formulation of PARs and have been provided to State and local governmental authorities.

(NA for CR3) 1Oc A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events.

1Od Kl is available for implementation as a protective action recommendation in those jurisdictions that D chose to provide Kl to th~ pu~lic.

11 a The reso.urces for controlling radiological exposures for emergency workers are established. D

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12a Arrangeme.nts are made for medic.al services for contaminated, injured individuals. D

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1?a Plans for recovery arid reentry are c:jeveloped. D

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14a A drill and exercise program (including radiological, medical, health physics and other program areas) D is established.

14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, D and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.

14c Identified weaknesses are corrected. D 15a Training is provided to emergency responders. D

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Part IV. Emergency Planning Element and Function Screen (cont.)

16 . 1_o CFR *§9~!+Z(b)( 16) Errr~f"Q~ncy Plan M~in~~Jj~n~e - -*- ... .. - __ , __ -

16a Responsibility for emergency plan development and review is established. D 16b Planners responsible for emergency plan develqpment and maintenance are properly trained. D

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PART IV. Conclusion If no Part IV criteria are checked, a 10 CFR 50.54(q) Effectiveness Evaluation is not required, then complete D

Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part V. Go to Attachment 4, 10 CFR 50.54(q)

Screening Evaluation Form, Part VI for instructions describing the NRC required 30 day submittal.

If any Attachment 4, 10 CFR 50.54( q) Screening Evaluation Form, Part IV criteria are checked, then complete Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part Vand perform a 10 CFR 50.54(q)

Effectiveness Evaluation. Shaded block requires final approval of Screen and Evaluation by EP CFAM.

. P<!rtV. S_i£)_~atures: .. . . .. ..

Preparer Name (Print):

~g~re: Date:

Staci Fischer *~ fl I:> ._rI Ir;,

Reviewer Name (Print): Reviewer Signature: Date:

White, Jeffery M. (electronic signature attached) 8/24/16 Approver (EP Manager) Name (Print): Approver Signature: Date:

Ar/ow, Tom A. (electronic signature attached) 8/24/16 Approver (CF AM, as required) Name (Print) Approver Signature: Date:

Part VI. NRC Emergency Plan and Implementing Procedure Submittal Actions Create two EREG General Assignments.

One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q),

to Licensing.

One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect.

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EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 5 Page 1 of 14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

_ Screening and_Evalu~Jion f\jLimtJer BNP 0 EREG #: _ _2055115_ _ _ _ __ CNS

CR3 0 HNP 0 MNS 0 5AD #: _ _ _2050100 _ _ _ __ ONS 0 RNP 0 GO 0 Document and Revision I RP/0/N5000/002, Notification of Unusual Event, rev 046 Part I. Description of Proposed Change:

Note prior to 2.8 changed from "NOTE: Turnover of command and control to the TSC or EOF relieves the OSM/Emergency Coordinator of classification, notification and Protective Action Recommendations (PAR) responsibilities allowing a focused effort on plant response."

to "NOTE: 1. Turnover of command and control to the TSC relieves the SM/Emergency Coordinator of Classification, Notification and Protective Action Recommendations (PAR) responsibilities.

2. Turnover to the EOF relieves the SM/Emergency Coordinator of Notification and Protective Action Recommendation (PAR) responsibilities ONLY."

2.8.1 changed from "Provide turnover to the TSC Emergency Coordinator using Enclosure 4.2" to "IF the emergency situation does NOT prevent activation of the TSC within 75 minutes, provide turnover to the TSC Emergency Coordinator using Enclosure 4.2" 2.8.2 changed from "IF the emergency situation prevents activation of the TSC within 75 minutes of declaration, contact the EOF Director and perform the following:

A turnover using Enclosure 4.2

IF time allows, refer to EOF Director Turnover Form in RP/0/N5000/020, "Technical Support Center (TSC) Activation", Enclosure 4.1, for a job aid that provides additional turnover detail for the EOF."

to "IF the emergency situation prevents activation of the TSC within 75 minutes of declaration, contact the EOF Director and perform the following:

A turnover for Notification and Protective Action Recommendation (PAR) ONLY using Enclosure 4.2

Maintain command and control of classification until TSC is capable of accepting turnover"

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 5 Page 2of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part I. Description of Proposed Change (continued):

2.8.3 changed from "IF neither facility can take turnover, maintain command and control until one of the facilities is capable of accepting turnover."

to "IF neither facility can take turnover, maintain command and control until the facility is capable of accepting turnover."

Enclosure 4.1, Note prior to step 1.1 added "2. A Job Aid for ERONS is located in the communicator's area that directs the Operator to notify Security to activate the ERO."

Enclosure 4.2, Emergency Coordinator/EOF Director Turnover Form Replaced the entirety of the enclosure with a new fleet standard turnover form.

In summary, two general changes are being made in revision 46 of RP/O/A/5000/002, Notification of Unusual Event.

The first is the change is relat_ed to the responsibility for classification. This responsibility will now remain either in the Control Room with the Shift Manager, or after the TSC is activated, in the Technical Support Center with the Emergency Coordinator.

The second change is an additio_n to a note to remind the onshift operations personnel where to obtain a job aid that contains site-specific information on how to contact Security, who will activate the ERO using the automated system.

Attachment 6, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes D Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change) No

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.1 ATTACHMENT 5 Page 3of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

Three licensing basis documents were reviewed for applicability, 1) the Catawba Emergency plan, Revision 2, as the original plan approved by the NRC, 2) the current Catawba Emergency plan, revision 148, and 3) "Duke Power Company Response to Supplement 1 to NUREG-0737, Emergency Response Capability for Catawba Nuclear Station, Volume 1."

Applicable sections of the Emergency Plan titled, "Catawba Nuclear Station Emergency Plan, revision 2 - January 1983:

Section A, Assignment of Responsibility, and section B, Onsite Emergency Organization.

Section A.1.b, Concept of Operations, states, "All emergencies or accident situations at the station are handled initially by the Shift Supervisor. When an abnormal situation occurs, the Shift Supervisor is able, utilizing station operating and emergency procedures and from background training and experience, to determine if the abnormal situation is an emergency condition. During the course of the emergency condition and as response personnel are notified, and emergency centers are activated (O.S.C., T.S.C., C.M.C), the Shift Supervisor is the person in charge, and assumes the position of the Emergency Coordinator until the arrival of the Station Manager.

When the Station Manager arrives and relieves the Shift Supervisor of the Emergency Coordinator function, he becomes the person in charge or the decision maker. When the Crisis Management center (CMC) is activated and operational, the Recovery Manager at the CMC is responsible for company emergency response. The Control Room at the station is the initial center for coordination of the emergency response for all emergency conditions. For emergencies classified as Alert, Site Emergency and General Emergency, the Emergency Coordinator shall activate the Technical Support Center (TSC) and the Crisis Management Center (CMC).

The TSC acts in support of the command and control function of the Control Room and provides an area for other station personnel who have expertise in all areas of plant operation to support the emergency condition ...

As the C.M.C. becomes operational, it will assume many of the functions of the T.S.C. and will rely on the T.S.C. as a vital link to the station. The T.S.C. will provide the C.M.C. with up-to-date plant parameters, which will allow this facility to perform its assigned tasks in accordance with the Crisis Management Plan."

Section A.1.d, Key Decision Making, states, "During the course of any emergency condition at Catawba, several persons have the potential to be "in charge" or to be the "Key Decision Maker". Prior to the T.S.C. activation and arrival of the Station Manager, the Shift Supervisor becomes the Emergency Coordinator at the Station and is in charge. When the Station Manager arrives on-site and assumes the Emergency Coordinator positions, he becomes the person in charge of emergency response and becomes the key decision maker. After C.M.C. is activated and becomes operational, the Recovery Manager is responsible for company emergency response."

Section B.2, Station Emergency Coordinator, states, "Initial activities at Catawba during any emergency condition are directed by the Shift Supervisor from the Control Room. The Shift Supervisor shall assume the functions of the Emergency Coordinator until the arrival of the Station Manager or his designee at which time the Station Manager will assume the responsibility of the Emergency Coordinator. The Emergency Coordinator will have the authority and responsibility to immediately and unilaterally initiate any emergency actions including:

a. Provide protective action recommendations to authorities responsible for implementing off-site emergency measures. This authority shall not be delegated to other elements of the emergency organization.

.~*.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 5 Page 4of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part II. Description and Review of Licensing Basis Affected by the Proposed Change (continued)

b. Notification and activation of the Station, Corporate, County/City, South Carolina, North Carolina and the Nuclear Regulatory Commission emergency organizations having a response role.

c. Continued assessment of actual or potential consequences both on-site and off-site throughout the evolution of the emergency condition.

d. Effective implementation of emergency measures in the environs including protective actions for affected areas, implementation of emergency monitoring teams and facilities to evaluate the environmental consequences of the emergency condition, prompt notification and communications to off-site authorities.

e. Continued maintenance of an adequate state of emergency preparedness until the emergency situation has been effectively managed and the station is returned to a normal or safe operating condition."

Section B.3, Station Emergency Coordinator (Line of Succession), states, "The Emergency Coordinator function as described above in paragraph B.2 will later be assumed by the Recovery manager as the Crisis Management Center as this corporate organization is staffed and ready to take over its functions. This assumption of the Emergency Coordinator functions will take place for the Alert, Site Area Emergency and General Emergency categories."

Section B.4, Protective Action Recommendation, states, "The functional responsibilities of the Emergency Coordinator as described in paragraph B.2. Protective Action recommendations to state and local authorities is initially vested with the Shift Supervisor/Emergency Coordinator. As the Crisis Management Center becomes operational, the Recovery Manager is the person who is responsible for making protective action recommendations."

Section E. 2, Activation of the Emergency Organization, states, (applicable excerpts only)

"a. Notification of Unusual Event The Emergency Coordinator shall augment onshift resources to assess and respond to the emergency situation as needed to ensure the protection of property and persons.

b. Alert The Emergency Coordinator shall augment onsite resources by notification and activation of the onsite Technical Support center, and the onsite Operations Support Center in accordance with Catawba Nuclear Station Directive 3.8.4. He shall also activate the Crisis Management Center in accordance with the appropriate emergency procedure.

c. Site Area Emergency The Emergency Coordinator shall augment onsite resources by notification and activation of the onsite Technical Support center, and the onsite Operations Support Center in accordance with Catawba Nuclear Station Directive 3.8.4. He shall also activate the Crisis Management Center in accordance with the appropriate emergency procedure.

d. General Emergency The Emergency Coordinator shall augment onsite resources by notification and activation of the onsite Technical Support center, and the onsite Operations Support Center in accordance with Catawba Nuclear Station Directive 3.8.4. He shall also activate the Crisis Management Center in accordance

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.1 ATTACHMENT 5 Page 5of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part II. Description and Review of Licensing Basis Affected by the Proposed Change (continued) with the appropriate emergency procedure" The current revision of the Catawba Emergency Plan is revision 148. The following sections are affected by the two changes described in this evaluation:

Section A.1.b, Concept of Operations, states "All emergencies or accident situations at the station are handled initially by the Shift Manager. When an abnormal situation occurs, the Shift Manager is able, utilizing station operating and emergency procedures and from background, training and experience, to determine if the abnormal situation is an emergency condition. During the course of the emergency condition and as response personnel are notified, and emergency centers are staffed (OSC, TSC, EOF), the Shift Manager is the person in charge, and assumes the functions of the Emergency Coordinator until the arrival of the Station Manager/designee. When the Station Manager/designee arrives and relieves the Shift Manager of the Emergency Coordinator function, he/she becomes the person in charge or the decision-maker. When the Emergency Operations Facility (EOF) is activated and operational, the EOF Director at the EOF is responsible for company emergency response. The Control Room at the station is the initial center for coordination of emergency response for all emergency conditions. For emergencies classified as Alert, Site Area Emergency and General Emergency, the Emergency Coordinator shall activate the Emergency Response Organization. The TSC acts in support of the command and control function of the Control Room and provides an area for other station personnel who have expertise in all areas of plant operation to support the emergency response.

After the EOF is operational and activated, it will assume many of the functions of the TSC and will rely on the TSC as a vital link to the station. The TSC will provide the EOF with up-to-date plant parameters, which will allow this facility to perform its assigned tasks."

Section A.1.d Key Decision-Making, states, "During the course of any emergency condition at Catawba, several persons have the potential to be "in charge" or to be the "Key Decision Maker". Prior to TSC activation and arrival of the Station Manager/designee, the Shift Manager assumes the functions of the Emergency Coordinator at the Station and is in charge. When the Station Manager/designee arrives on-site and assumes the Emergency Coordinator function, he/she becomes the person in charge of emergency response and becomes the key decision-maker. After EOF is operational and activated, the EOF Director is responsible for company emergency response."

Section B.2 Emergency Coordinator, states, "Initial activities at Catawba during any emergency condition are directed by the Operations Shift Manager from the Control Room. The Operations Shift Manager shall assume the functions of the Emergency Coordinator until the arrival of the Station Manager/designee at which time the Station Manager/designee will assume the functions of the Emergency Coordinator. The Emergency Coordinator will have the authority and the responsibility to immediately and unilaterally initiate any emergency actions including:

a. Provide protective action recommendations to authorities responsible for implementing off-site emergency measures, implement event classification, notification, and event escalation/de-escalation/termination. THIS AUTHORITY SHALL NOT BE DELEGATED TO OTHER ELEMENTS OF THE EMERGENCY ORGANIZATION.

b. Notification and activation of the Station, Corporate, County/City, South Carolina, North Carolina and the Nuclear Regulatory Commission emergency organizations having a response role.

c. Continued assessment of actual or potential consequences both on- site and off-site throughout

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 1 ATTACHMENT 5 Page 6of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part II. Description and Review of Licensing Basis Affected by the Proposed Change (continued) the evolution of the emergency condition.

d. Effective implementation of emergency measures in the environs including protective actions for affected areas, implementation of emergency monitoring teams and facilities to evaluate the environmental consequences of the emergency condition, prompt notification and communications with off-site authorities.

e. Continued maintenance of an adequate state of emergency preparedness until the emergency situation has been effectively managed and the station is returned to a normal or safe operating condition."

Section B.3 Emergency Coordinator (Line of Succession), states, "The Emergency Coordinator function as described above in paragraph B.2 will later be assumed by the EOF Director at the Emergency Operations Facility as this organization is staffed and ready to take over its functions."

Section B.4 Functional Responsibilities of the Emergency Coordinator "The functional responsibilities of the Emergency Coordinator are described in paragraph B.2. Protective Action recommendations to state and local authorities is initially vested with the Operations Shift Manager/

Emergency Coordinator. As the Emergency Operations Facility (EOF) becomes operational, the EOF Director is the person who is responsible for making protective action recommendations."

Section E. 2, Activation of the Emergency Organization, states, (applicable excerpts only)

"a. Notification of Unusual Event The Shift Manager shall augment on-shift resources to assess and respond to the emergency situation as needed to ensure the protection of property and persons.

b. Alert The Shift Manager shall assure notification and activation of the Emergency Response Organization for any initiating condition in this classification listed in Section D.

The Emergency Coordinator shall augment on-site resources by notification and activation of the Emergency Response Organization in accordance with RP/0/A/5000/003, Alert.

The Emergency Response Organization personnel will be notified by text and/or voice message upon the initial emergency declaration via a mass communication system using AD-EP-ALL-0301 (Activation of the Emergency Response Organization Notification System [ERON SJ). Redundant notification is provided by the on-site public address system, Nuclear Callout System and/or an automated telephone system which will allow timely alerting of Emergency Response Organization personnel.

c. Site Area Emergency The Shift Manager shall assure notification and activation of the Emergency Response Organization for any initiating condition in this classification listed in Section D.

The Emergency Coordinator shall augment on-site resources by notification and activation of the

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.1 ATTACHMENT 5 Page 7of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part II. Description and Review of Licensing Basis Affected by the Proposed Change (continued)

Emergency Response Organization in accordance with RP/O/N5000/004, Site Area Emergency.

The Emergency Response Organization personnel will be notified by text and/or voice message upon the initial emergency declaration via a mass communication system using AD-EP-ALL-0301 (Activation of the Emergency Response Organization Notification System [ERONS]). Redundant notification is provided by the on-site public address system, Nuclear Callout System and/or an automated telephone system which will allow timely alerting of Emergency Response Organization personnel.

d. General Emergency The Shift Manager shall assure notification and activation of the Emergency Response Organization for any initiating condition in this classification listed in Section D.

The Emergency Coordinator shall augment on-site resources by notification and activation of the Emergency Response Organization in accordance with RP/0/N5000/005, General Emergency.

The Emergency Response Organization personnel will be notified by text and/or voice message upon the initial emergency declaration via a mass communication system using AD-EP-ALL-0301 (Activation of the Emergency Response Organization Notification System [ERONS]). Redundant notification is provided by the on-site public address system, Nuclear Callout System and/or an automated telephone system which will allow timely alerting of Emergency Response Organization personnel."

Duke Power Company Response to Supplement 1 to NUREG-0737, Emergency Response Capability for Catawba Nuclear Station, Volume 1 does not contain applicable sections related to assignment of responsibility or augmentation of the onsite ERO.

RIS 2005-02, Revision 1, states that for the purposes of determining whether a change to a licensee's emergency plan constitutes a decrease in effectiveness, the licensee should use the last emergency plan reviewed and approved by the NRC. If the emergency plan change process has been properly implemented over the years, comparing a proposed emergency plan change to either the latest emergency plan reviewed and approved by the NRC or the emergency plan as changed by the licensee should result in the same decrease in effectiveness determination. The original Emergency Plan citations are listed to illustrate the differences between the last emergency plan reviewed and approved by NRC, revision 2, and the emergency plan as changed by the licensee, revision 148. Changes include variations in the titles of the ERO facilities and ERO positions, along with additional detail for making ERO notifications. No significant changes that alter the intent of these sections have been made over the course of the revisions.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 5 Page 8of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments.

If the emergency plan, modified as proposed, no longer complies with planning standards on 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensures the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exceptions, rather than under 10 CFR 50.54(q):

The changes related to the responsibility for classification affect 10 CFR 50.47(b)(1) and 10 CFR 50.47(b)(2) 10 CFR 50.47(b)(1 ), "Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis."

10 CFR 50.47(b)(2), "Onshift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified."

Appendix E to 10 CFR Part 50 Section IV.A (applicable excerpts only):

A. Organization

The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

1. A description of the normal plant operating organization.

2. A description of the onsite emergency response organization (ERO) with a detailed discussion of:

a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

b. Plant staff emergency assignments;

c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

3. A description, by position and function to be performed, of the licensee's headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.

The change related to the activation of the ERO affects 10 CFR 50.47(b )(2) 10 CFR 50.47(b)(2), "On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified."

Appendix E to 10 CFR Part 50 Section IV.C (applicable excerpts only):

C. Activation of Emergency Organization

1. The entire spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described. The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described ...

-~-. *.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 1 ATTACHMENT 5 Page 9of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments (continued)

Conclusion The changes related to the responsibility of classification continue to comply with Regulations and Commitments because the authorities, responsibilities and duties (Classification, Notification and Protective Action recommendations) remain unambiguously defined as assigned to the Shift Manager, the TSC Emergency Coordinator, or the EOF Director, dependent upon which emergency facilities are activated/operational.

The change related to the augmentation of the ERO continues to comply with the Regulation and Commitments because the steps to be taken to activate the ERO remain described and unchanged in approved procedures. This change includes a new note to remind the onshift operations personnel where to obtain a job aid that contains site-specific information on how to contact Security, who will activate the ERO using the automated system

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 5 Page 10 of 14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part IV. Description of Emergency Plan PLANNING STANDARDS, FUNCTIONS AND PROGRAM ELEMENTS Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen):

The changes related to the responsibility for classification affect 10 CFR 50.47(b )(1) and 10 CFR 50.47(b )(2)

PLANNING STANDARDS The regulation at 10 CFR 50.47(b)(1) states the following:

"Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis."

The regulation at 10 CFR 50.47(b)(2) states the following:

"[Onshift] " ... facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified."

FUNCTIONS Two emergency planning functions have been defined for 10 CFR 50.47(b)(1 ):

(1) Responsibility for emergency response is assigned.

(2) The response organization has the staff to respond and to augment staff on a continuing basis (i.e.,

24/7 support) in accordance with the emergency plan.

Two emergency planning functions have been defined for 10 CFR 50.47(b)(2):

(1) The process ensures that onshift emergency response responsibilities are staffed and assigned.

(2) The process for timely augmentation of onshift staff is established and maintained.

Appendix E to 10 CFR Part 50 Section IV.A provides supporting requirements (applicable excerpts only):

A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

1.A description of the normal plant operating organization.

2. A description of the onsite emergency response organization (ERO) with a detailed discussion of:

c. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

d. Plant staff emergency assignments;

c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

3.A description, by position and function to be performed, of the licensee's headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev.1 ATTACHMENT 5 Page 11of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part IV. Description of Emergency Plan PLANNING STANDARDS, FUNCTIONS AND PROGRAM ELEMENTS Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen) (continued):

PROGRAM ELEMENTS Section II.A of NUREG-0654/FEMA-REP-1, Rev 1, contains the following informing criteria:

II, A. Assignment of Responsibility (Organization Control) (applicable excerpts only) 1a. Each plan shall identify the State, local, Federal and private sector organizations (including utilities), that are intended to be part of the overall response organization for Emergency Planning Zones.

1b. Each organization and sub-organization having an operational role shall specify its concept of operations, and its relationship to the total effort.

Section 11.B of NUREG-0654/FEMA-REP-1, Rev 1, contains the following informing criteria:

II, B. Onsite Emergency Organization

1. Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement.

2. Each licensee shall designate an individual as emergency coordinator who shall be on shift at all times and who shall have the authority and responsibility to immediately and unilaterally initiate any emergency actions, including providing protective action recommendations to authorities responsible for implementing offsite emergency measures.

3. Each licensee shall identify a line of succession for the emergency coordinator position and identify the specific conditions for higher level utility officials assuming this function.

4. Each licensee shall establish the functional responsibilities assigned to the emergency coordinator and shall clearly specify which responsibilities may not be delegated to other elements of the emergency organization. Among the responsibilities which may not be delegated shall be the decision to notify and to recommend protective actions to authorities responsible for offsite emergency measures.

The change related to the activation of the ERO affects 10 CFR 50.47(b)(2)

PLANNING STANDARDS "On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified."

FUNCTIONS Two emergency planning functions have been defined for this planning standard:

(1) The process ensures that onshift emergency response responsibilities are staffed and assigned.

(2) The process for timely augmentation of onshift staff is established and maintained.

Appendix E to 10 CFR Part 50 Section IV.C provides supporting requirements (applicable excerpts only):

C. Activation of Emergency Organization

1. The entire spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described. The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described ...

". ~ ...

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 5 Page 12of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part IV. Description of Emergency Plan PLANNING STANDARDS, FUNCTIONS AND PROGRAM ELEMENTS Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen) (continued):

PROGRAM ELEMENTS Section 11.B of NUREG-0654/FEMA-REP-1, Rev 1, contains the following informing criteria:

II, B. Onsite Emergency Organization

7. Each licensee shall specify the corporate management, administrative, and technical support personnel who will augment the plant staff as specified in the table entitled "Minimum Staffing Requirements for Nuclear Power Plant Emergencies," (Table B-1 ) ...

Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

Two emergency planning functions have been defined for 10 CFR 50.47(b)(1):

( 1) Responsibility for emergency response is assigned.

(2) The response organization has the staff to respond and to augment staff on a continuing basis (i.e.,

2417 support) in accordance with the emergency plan.

Two emergency planning functions have been defined for 10 CFR 50.47(b)(2):

(1) The process ensures that onshift emergency response responsibilities are staffed and assigned.

(2) The process for timely augmentation of onshift staff is established and maintained The changes related to the responsibility of classification continue to comply with Emergency Plan Functions because the responsibilities (Classification, Notification and Protective Action recommendations) remain unambiguously defined as assigned to the Shift Manager, the TSC Emergency Coordinator, or the EOF Director, dependent upon which emergency facilities are activated/operational.

The change related to the augmentation of the ERO continues to comply with the Emergency Plan Functions because the steps to be taken to activate the ERO remain described and unchanged in approved procedures. This change includes a new note to remind the onshift operations personnel where to obtain a job aid that contains site-specific information on how to contact Security, who will activate the ERO using the automated system.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.1 ATTACHMENT 5 Page 13of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>

Part VI. Evaluation Conclusion.

Answer the following questions about the proposed change.

1 Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? Yes* NoD 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes* NoD reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes* NoD 4 Choose one of the following conclusions:

a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current Emergency Action Level (EAL) scheme. Therefore, the activity can be implemented without prior NRC

approval.

b The activity does not continue to comply with the requirements of 10 CFR 50.47(b) or 10 CFR 50 Appendix E or the activity does constitute a reduction in effectiveness or EAL scheme change. D Therefore, the activity cannot be implemented without prior NRC approval.

Part VII. Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change determined to require prior NRC approval be either revised or rejected?

I Yes D I No D If No, then initiate a License Amendment Request in accordance 10 CFR 50.90 and AD-LS-ALL-0002, Regulatory Correspondence, and include the tracking number:

. I EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.1 ATTACHMENT 5 Page 14of14

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

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Part VIII. Signatures: EP CFAM Final Approval is required for changes affecting risk significant planning standard 10 CFR 50.47(b)(4).

Preparer Name (Print): Pr~ignatu~ Date:

Staci Fischer _,A~HS~ 8/::>'lf((,

Reviewer Name (Print): Reviewer Signature: Date:

White, Jeffery M. (electronic signature attached) 8/24/16 Approver (EP Manager) Name (Print): Approver Signature: Date:

Ar/ow, Tom A. (electronic signature attached) 8/24/16 Approver (CFAM, as required) Name (Print): Approver Signature: Date:

If the proposed activity is a change to the E-Plan or implementing procedures, then create two EREG General Assignments.

One for EP to provide the 10 CFR 50.54( q) summary of the analysis, or the completed 10 CFR 50.54(q),

to Licensing. -

One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect.

QA RECORD

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Q EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 4 Page 1of5

<< 10 CFR 50.54(q) Screening Evaluation Form >>

$'ct~e_ning and ~"'.al~ation N_u_mt:rer ---

__Applicable Sites .. *- . -

BNP D EREG#: 2055121 CNS

CR3 D HNP D MNS D

'5AD#: 2050125 ONS D RNP D GO D Document and Revision RP/O/N5000/003, Alert, rev 051

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Part I. Description of Activity Being Reviewed (event or action, or series of actions that may resultin a change to the emergency plan or affect the implementation of the emergency plan):

Note prior to 3.9 changed from "NOTE: Turnover of command and control to the TSC or EOF relieves the OSM/Emergency Coordinator of classification, notification and Protective Action Recommendations (PAR) responsibilities allowing_ a focused effort on plant response."

to "NOTE: 1. Turnover of command and control to the TSC relieves the SM/Emergency Coordinator of Classification, Notification and Protective Action Recommendations (PAR) responsibilities.

2. Turnover to the EOF relieves the SM/Emergency Coordinator of Notification and Protective Action Recommendation (PAR) responsibilities ONLY."

3.9.1 changed from "Provide turnover to the TSC Emergency Coordinator using Enclosure 4.2" to "IF the emergency situation does NOT prevent activation of the TSC within 75 minutes, provide turnover to the TSC Emergency Coordinator using Enclosure 4.2"

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.1 ATTACHMENT 4 Page 2 of 5

<< 10 CFR 50.54(q} Screening Evaluation Form >>

Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan) (continued):

3.9.2 changed from "IF the emergency situation prevents activation of the TSC within 75 minutes of declaration, contact the EOF Director and perform the following:

A turnover using Enclosure 4.2 IF time allows, refer to EOF Director Turnover Form in RP/O/N5000/020, "Technical Support Center (TSC) Activation", Enclosure 4.1, for a job aid that provides additional turnover detail for the EOF" to "IF the emergency situation prevents activation of the TSC within 75 minutes of declaration, contact the EOF Director and perform the following:

A turnover for Notification and Protective Action Recommendation (PAR) ONLY using Enclosure 4.2 Maintain command and control of classification until TSC is capable of accepting turnover" 3.9.3 changed from "IF neither facility can take turnover, maintain command and control until one of the facilities is capable of accepting turnover."

to "IF neither facility can take turnover, maintain command and control until the facility is capable of accepting turnover." .1, Note prior to step 1.1 added "2. A Job Aid for ERONS is located in the communicator's area that directs the Operator to notify Security to activate the ERO." .2, Emergency Coordinator/EOF Director Turnover Form Replaced the entirety of the enclosure with a new fleet standard turnover form

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev.1 ATTACHMENT 4 Page 3 of 5

<< 10 CFR 50.54(q) Screening Evaluation Form>>

Pa_rt II. Activity Previously Reviewed?

Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or Yes ID No

10 CFR 50.54(q) Continue to Alert and Notification System Design Report? Effectiveness Attachment 4, Evaluation is not 10 CFR If yes, identify bounding source document number or approval reference and required. Enter 50.54(q) ensure the basis for concluding the source document fully bounds the proposed justification Screening change is documented below: below and Evaluation complete Form, Part Ill Justification: Attachment 4, Part V.

Bounding document attached (optional) 10--

~-- ----*- **-** < ~ - --

Part Ill. Editorial Change Yes I D No I*

Is this activity an editorial or typographical change only, such as formatting, 10 CFR 50.54(q) Continue to paragraph numbering, spelling, or punctuation that does not change intent? Effectiveness Attachment 4, Evaluation is not Part IV and required. Enter address non Justification:

justification and editorial complete changes Attachment 4, Part V & VI.

Part IV. Emergency Planning Element and Function Screen (Reference Attachment 1, Considerations for Addressing Screening Criteria)

Does this activity involve any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If answer is yes, then check box.

1. -

16 GPR _5d}7(h)(1) Asst9riinei1t _of"f{espon:~il:Ji.i"ity {C;frganii~t"ton co}l_fro1) . '" - . .. . ..

1a Responsibility for emergency response is assigned.

1b The response organization has the staff to respond and to augment staff on a continuing basis D (24-7 staffing) in accordance with the emergency plan.

2: ~o CfR 5(f~f7(b )(2) oA$it~ -~m8i'9§ncy dtQ~ri_iza,tidh .. -* -*- -- --*- .- -

2a Process ensures that onshift emergency response responsibilities are staffed and assigned D 2b The process for timely augmentation of onshift staff is established and maintained.

~ 16 ci=rf5cL47(b)(3) Erner~ency Re.~ponsei ~u:p_port aJ,d Re~ciurc~~ - . -*

3a Arrangements for requesting and using off site assistance have been made. D 3b State and local staff can be accommodated at the EOF in accordance with the emergency plan. D (NA for CR3) 4 9 1_ QFR~-5Q.4 7(b )(4) Emergency Cl~E;sific?tion Syst~in 4a A standard scheme of emergency classification and action levels is in use. D (Requires final approval of Screen and Evaluation by EP CFAM.)

5 10 CFR_!?0~47(b)(5) Notific~tibn Methods a11C:f Procedures

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EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 4 Page 4 of 5

<< 10 CFR 50.54(q) Screening Evaluation Form >>

5a Procedures for notification of State and local governmental agencies are capable of initiating notification D of the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency anp providing follow-up notification.

5b Administrative arid physical means have b!'ien established for alerting and providing prompt instructions D to the public within the plume exposw~ pathway. (NA for CR3) 5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval)etter. (NA for CR3)

Part IV. ~mergency Plannipg Element aod ~u_nction Screen (cont.)

6a Systems are established for prompt communication among principal emergency response D orga_ni_zations.

6b ~yste:ins ?re-estqblish~d for prompt comm~~i¢ation to ~mergency respon~~ pf'.rsonnel. D 7a Emergency prep~redness intormatior:i is made available to the pubiic on a periodic basis within the plume expos1,1re pathway erri~rg~ncy planning zon~ (EPZ). (NA for CR3)

_7b _ c6or,9i11ated dissE;Jminatiori of public inf()rrilation during emergencies is established. D Ba Adequate facilities are maintained to support emergency response. D

~b Ai:J,equate equipment is maintained to support emergency response. D 9a Methods, systems, and eguipment for assessment of radioactive releases are in use. D

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10a A range of public PARs is available for implementation

- during emergencies. (NA for CR3) .

D 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available D to support the formulation of PARs and have been provided to State and local governmental authorities.

(NA fo-r CR3) 10c A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events.

10d Kl is available for implementation as a protective action recommendation in those jurisdictions that D cho_se to provide Kl to the public.

11a The_resources for controlling radiol9gica1 exposures for emergency workers are established. D 12a Arrangements are made for medic~! services for contaminated, injured individuals. D 13a Plans for recovery and reentry are developed. D 14a A drill and exercise program (including radiological, medical, health physics and other program areas) D is established.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 4 Page 5 of 5

<< 10 CFR 50.54(q) Screening Evaluation Form>>

14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, 0 and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.

14c Identified weaknesses are corrected. 0 15a Training is provided to emergency responders. 0 16a Responsibility for emergency plan development and review is established. 0 16b Planners responsible for emergency plan development and maintenance are properly trained. 0 PART IV. Conclusion If no Part IV criteria are checked, a 10 CFR 50.54(q) Effectiveness Evaluation is not required, then complete 0 , 10 CFR 50.54(q) Screening Evaluation Form, Part V. Go to Attachment 4, 10 CFR 50.54(q)

Screening Evaluation Form, Part VI for instructions describing the NRC required 30 day submittal.

If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete , 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q)

Effectiveness Evaluation. Shaded block requires final approval of Screen and Evaluation by EP CFAM .

. ~ .-

P~rt V, SJ~ratures: _ ..

Preparer Name (Print):

Staci Fischer Reviewer Name (Print): Reviewer Signature: Date: /

White, Jeffery M. (electronic signature attached) 8/24/16 Approver (EP Manager Name (Print): Approver Signature: Date:

Ar/ow, Tom A. (electronic signature attached) 8/24/16 Approver (CFAM, as required) Name (Print) Approver Signature: Date:

Part VI. NRC Emergency Plan and Implementing Procedure Submittal Actions Create two EREG General Assignments.

One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54( q),

to Licensing.

., One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect.

QA RECORD

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EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.1 ATTACHMENT 5 Page 1 of 13

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

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CR3 D HNP D MNS D 5AD #: _ _ _2050125_ _ __ ONS D RNP D GO D Document and Revision RP/O/A/5000/003, Alert, rev 051 Part I. Description of Proposed Change:

Note prior to 3.9 changed from "NOTE: Turnover of command and control to the TSC or EOF relieves the OSM/Emergency Coordinator of classification, notification and Protective Action Recommendations (PAR) responsibilities allowing a focused effort on plant response."

to "NOTE: 1. Turnover of command and control to the TSC relieves the SM/Emergency Coordinator of Classification, Notification and Protective Action Recommendations (PAR) responsibilities.

2. Turnover to the EOF relieves the SM/Emergency Coordinator of Notification and Protective Action Recommendation (PAR) responsibilities ONLY."

3.9.1 changed from "Provide turnover to the TSC Emergency Coordinator using Enclosure 4.2" to "IF the emergency situation does NOT prevent activation of the TSC within 75 minutes, provide turnover to the TSC Emergency Coordinator using Enclosure 4.2" 3.9.2 changed from "IF the emergency situation prevents activation of the TSC within 75 minutes of declaration, contact the EOF Director and perform the following:

A turnover using Enclosure 4.2

IF time allows, refer to EOF Director Turnover Form in RP/O/A/5000/020, "Technical Support Center (TSC) Activation", Enclosure 4.1, for a job aid that provides additional turnover detail for the EOF."

to "IF the emergency situation prevents activation of the TSC within 75 minutes of declaration, contact the EOF Director and perform the following:

A turnover for Notification and Protective Action Recommendation (PAR) ONLY using Enclosure 4.2

Maintain command and control of classification until TSC is capable of accepting turnover"

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part I. Description of Proposed Change (continued):

3.9.3 changed from "IF neither facility can take turnover, maintain command and control until one of the facilities is capable of accepting turnover."

to "IF neither facility can take turnover, maintain command and control until the facility is capable of accepting turnover."

Enclosure 4.1, Note prior to step 1.1 added "2.A Job Aid for ERONS is located in the communicator's area that directs the Operator to notify Security to activate the ERO."

Enclosure 4.2, Emergency Coordinator/EDF Director Turnover Form Replaced entirety of the enclosure with a new fleet standard turnover form.

Attachment 6, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verificption (V&V) Form , is attached (required for IC or EAL change)

Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

Three licensing basis documents were reviewed for applicability, 1) the Catawba Emergency plan, Revision 2, as the original plan approved by the NRC, 2) the current Catawba Emergency plan, revision 148, and 3) "Duke Power Company Response to Supplement 1 to NUREG-0737, Emergency Response Capability for Catawba Nuclear Station, Volume 1."

Applicable sections of the Emergency Plan titled, "Catawba Nuclear Station Emergency Plan, revision 2 - January 1983:

Section A, Assignment of Responsibility, and section B, Onsite Emergency Organization.

Section A.1.b, Concept of Operations, states, "All emergencies or accident situations at the station are handled initially by the Shift Supervisor. When an abnormal situation occurs, the Shift Supervisor is able, utilizing station operating and emergency procedures and from background training and experience, to determine if the abnormal situation is an emergency condition. During the course of the emergency condition and as response personnel are notified, and emergency centers are activated (O.S.C., T.S.C., C.M.C), the Shift Supervisor is the person in charge, and assumes the position of the Emergency Coordinator until the arrival of the Station Manager.

When the Station Manager arrives and relieves the Shift Supervisor of the Emergency Coordinator function, he becomes the person in charge or the decision maker. When the Crisis Management center (CMC) is activated and operational, the Recovery Manager at the CMC is responsible for company emergency response. The Control Room at the station is the initial center for coordination of the emergency response for all emergency conditions. For emergencies classified as Alert, Site Emergency and General Emergency, the Emergency Coordinator shall activate the Technical Support Center (TSC) and the Crisis Management Center (CMC).

The TSC acts in support of the command and control function of the Control Room and provides an area for other station personnel who have expertise in all areas of plant operation to support the emergency condition ...

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<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part II. Description and Review of Licensing Basis Affected by the Proposed Change (continued)

As the C.M.C. becomes operational, it will assume many of the functions of the T.S.C. and will rely on the T.S.C. as a vital link to the station. The T.S.C. will provide the C.M.C. with up-to-date plant parameters, which will allow this facility to perform its assigned tasks in accordance with the Crisis Management Plan."

Section A.1.d, Key Decision Making, states, "During the course of any emergency condition at Catawba, several persons have the potential to be "in charge" or to be the "Key Decision Maker". Prior to the T.S.C. activation and arrival of the Station Manager, the Shift Supervisor becomes the Emergency Coordinator at the Station and is in charge. When the Station Manager arrives on-site and assumes the Emergency Coordinator positions, he becomes the person in charge of emergency response and becomes the key decision maker. After C.M.C. is activated and becomes operational, the Recovery Manager is responsible for company emergency response."

Section B.2, Station Emergency Coordinator, states, "Initial activities at Catawba during any emergency condition are directed by the Shift Supervisor from the Control Room. The Shift Supervisor shall assume the functions of the Emergency Coordinator until the arrival of the Station Manager or his designee at which time the Station Manager will assume the responsibility of the Emergency Coordinator. The Emergency Coordinator will have the authority and responsibility to immediately and unilaterally initiate any emergency actions including:

a. Provide protective action recommendations to authorities responsible for implementing off-site emergency measures. This authority shall not be delegated to other elements of the emergency organization.

b. Notification and activation of the Station, Corporate, County/City, South Carolina, North Carolina and the Nuclear Regulatory Commission emergency organizations having a response role. '

c. Continued assessment of actual or potential consequences both on-site and off-site throughout the evolution of the emergency condition.

d. Effective implementation of emergency measures in the environs including protective actions for affected areas, implementation of emergency monitoring teams and facilities to evaluate the environmental consequences of the emergency condition, prompt notification and communications to off-site authorities.

e. Continued maintenance of an adequate state of emergency preparedness until the emergency situation has been effectively managed and the station is returned to a normal or safe operating condition."

Section B.3, Station Emergency Coordinator (Line of Succession), states,

The Emergency Coordinator function as described above in paragraph B.2 will later be assumed by the Recovery manager as the Crisis Management Center as this corporate organization is staffed and ready to take over its functions. This assumption of the Emergency Coordinator functions will take place for the Alert, Site Area Emergency and General Emergency categories."

Section B.4, Protective Action Recommendation, states,

The functional responsibilities of the Emergency Coordinator as described in paragraph B.2. Protective Action recommendations to state and local authorities is initially vested with the Shift Supervisor/Emergency Coordinator. As the Crisis Management Center becomes operational, the Recovery Manager is the person who is responsible for making protective action recommendations."

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part II. Description and Review of Licensing Basis Affected by the Proposed Change (continued)

Section E. 2, Activation of the Emergency Organization, states, (applicable excerpts only)

"a. Notification of Unusual Event The Emergency Coordinator shall augment onshift resources to assess and respond to the emergency situation as needed to ensure the protection of property and persons.

b. Alert The Emergency Coordinator shall augment onsite resources by notification and activation of the onsite Technical Support center, and the onsite Operations Support Center in accordance with Catawba Nuclear Station Directive 3.8.4. He shall also activate the Crisis Management Center in accordance with the appropriate emergency procedure.

c. Site Area Emergency The Emergency Coordinator shall augment onsite resources by notification and activation of the onsite Technical Support center, and the onsite Operations Support Center in accordance with Catawba Nuclear Station Directive 3.8.4. He shall also activate the Crisis Management Center in accordance with the appropriate emergency procedure.

d. General Emergency The Emergency Coordinator shall augment onsite resources by notification and activation of the onsite Technical Support center, and the onsite Operations Support Center in accordance with Catawba Nuclear Station Directive 3.8.4. He shall also activate the Crisis Management Center in accordance with the appropriate emergency procedure" The current revision of the Catawba Emergency Plan is revision 148. The following sections are affected by the two changes described in this evaluation:

Section A.1.b, Concept of Operations, states "All emergencies or accident situations at the station are handled initially by the Shift Manager. When an abnormal situation occurs, the Shift Manager is able, utilizing station operating and emergency procedures and from background, training and experience, to determine if the abnormal situation is an emergency condition. During the course of the emergency condition and as response personnel are notified, and emergency centers are staffed (OSC, TSC, EOF), the Shift Manager is the person in charge, and assumes the functions of the Emergency Coordinator until the arrival of the Station Manager/designee. When the Station Manager/designee arrives and relieves the Shift Manager of the Emergency Coordinator function, he/she becomes the person in charge or the decision-maker. When the Emergency Operations Facility (EOF) is activated and operational, the EOF Director at the EOF is responsible for company emergency response. The Control Room at the station is the initial center for coordination of emergency response for all emergency conditions. For emergencies classified as Alert, Site Area Emergency and General Emergency, the Emergency Coordinator shall activate the Emergency Response Organization. The TSC acts in support of the command and control function of the Control Room and provides an area for other station personnel who have expertise in all areas of plant operation to support the emergency response.

After the EOF is operational and activated, it will assume many of the functions of the TSC and will rely on the TSC as a vital link to the station. The TSC will provide the EOF with up-to-date plant parameters, which will allow this facility to perform its assigned tasks."

EMERGENCY PLAN CHANGE SCREENING AND. AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

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<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part II. Description and Review of Licensing Basis Affected by the Proposed Change (continued)

Section A.1.d Key Decision-Making, states, "During the course of any emergency condition at Catawba, several persons have the potential to be "in charge" or to be the "Key Decision Maker". Prior to TSC activation and arrival of the Station Manager/designee, the Shift Manager assumes the functions of the Emergency Coordinator at the Station and is in charge. When the Station Manager/designee arrives on-site and assumes the Emergency Coordinator function, he/she becomes the person in charge of emergency response and becomes the key decision-maker. After EOF is operational and activated, the EOF Director is responsible for company emergency response."

Section B.2 Emergency Coordinator, states, "Initial activities at Catawba during any emergency condition are directed by the Operations Shift Manager from the Control Room. The Operations Shift Manager shall assume the functions of the Emergency Coordinator until the arrival of the Station Manager/designee at which time the Station Manager/designee will assume the functions of the Emergency Coordinator. The Emergency Coordinator will have the authority and the responsibility to immediately and unilaterally initiate any emergency actions including:

a. Provide protective action recommendations to authorities responsible for implementing off-site emergency measures, implement event classification, notification, and event escalation/de-escalation/termination. THIS AUTHORITY SHALL NOT BE DELEGATED TO OTHER ELEMENTS OF THE EMERGENCY ORGANIZATION.

b. Notification and activation of the Station, Corporate, County/City, South Carolina, North Carolina and the Nuclear Regulatory Commission emergency organizations having a response role.

c. Continued assessment of actual or potential consequences both on- site and off-site throughout the evolution of the emergency condition.

d. Effective implementation of emergency measures in the environs including protective actions for affected areas, implementation of emergency monitoring teams and facilities to evaluate the environmental consequences of the emergency condition, prompt notification and communications with off-site authorities.

e. Continued maintenance of an adequate state of emergency preparedness until the emergency situation has been effectively managed and the station is returned to a normal or safe operating condition."

Section B.3 Emergency Coordinator (Line of Succession), states, "The Emergency Coordinator function as described above in paragraph B.2 will later be assumed by the EOF Director at the Emergency Operations Facility as this organization is staffed and ready to take over its functions."

Section B.4 Functional Responsibilities of the Emergency Coordinator "The functional responsibilities of the Emergency Coordinator are described in paragraph B.2. Protective Action recommendations to state and local authorities is initially vested with the Operations Shift Manager/

Emergency Coordinator. As the Emergency Operations Facility (EOF) becomes operational, the EOF Director is the person who is responsible for making protective action recommendations."

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 1 J

ATTACHMENT 5 Page 6of13

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part II. Description and Review of Licensing Basis Affected by the Proposed Change (continued)

Section E. 2, Activation of the Emergency Organization, states, (applicable excerpts only)

"a. Notification of Unusual Event The Shift Manager shall augment on-shift resources to assess and respond to the emergency situation as needed to ensure the protection of property and persons.

b. Alert The Shift Manager shall assure notification and activation of the Emergency Response Organization for any initiating condition in this classification listed in Section D.

The Emergency Coordinator shall augment on-site resources by notification and activation of the Emergency Response Organization in accordance with RP/0/A/5000/003, Alert.

The Emergency Response Organization personnel will be notified by text and/or voice message upon the initial emergency declaration via a mass communication system using AD-EP-ALL-0301 (Activation of the Emergency Response Organization Notification System [ERONS]). Redundant notification is provided by the on-site public address system, Nuclear Callout System and/or an automated telephone system which will allow timely alerting of Emergency Response Organization personnel.

c. Site Area Emergency The Shift Manager shall assure notification and activation of the Emergency Response Organization for any initiating condition in this classification listed in Section D.

The Emergency Coordinator shall augment on-site resources by notification and activation of the Emergency Response Organization in accordance with RP/O/A/5000/004, Site Area Emergency.

The Emergency Response Organization personnel will be notified by text and/or voice message upon the initial emergency declaration via a mass communication system using AD-EP-ALL-0301 (Activation of the Emergency Response Organization Notification System [ERONS]). Redundant notification is provided by the on-site public address system, Nuclear Callout System and/or an automated telephone system which will allow timely alerting of Emergency Response Organization personnel.

d. General Emergency The Shift Manager shall assure notification and activation of the Emergency Response Organization for any initiating condition in this classification listed in Section D.

The Emergency Coordinator shall augment on-site resources by notification and activation of the Emergency Response Organization in accordance with RP/0/A/5000/005, General Emergency.

The Emergency Response Organization personnel will be notified by text and/or voice message upon the initial emergency declaration via a mass communication system using AD-EP-ALL-0301 (Activation of the Emergency Response Organization Notification System [ERONS]). Redundant notification is provided by the on-site public address system, Nuclear Callout System and/or an automated telephone system which will allow timely alerting of Emergency Response Organization personnel."

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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<< 1 O CFR 50.54(q) Effectiveness Evaluation Form >>

Part II. Description and Review of Licensing Basis Affected by the Proposed Change (continued)

Duke Power Company Response to Supplement 1 to NUREG-0737, Emergency Response Capability for Catawba Nuclear Station, Volume 1 does not contain applicable sections related to assignment of responsibility or augmentation of the onsite ERO.

RIS 2005-02, Revision 1, states that for the purposes of determining whether a change to a licensee's emergency plan constitutes a decrease in effectiveness, the licensee should use the last emergency plan reviewed and approved by the NRC. If the emergency plan change process has been properly implemented over the years, comparing a proposed emergency plan change to either the latest emergency plan reviewed and approved by the NRC or the emergency plan as changed by the licensee should result in the same decrease in effectiveness determination. The original Emergency Plan citations are listed to illustrate the differences between the last emergency plan reviewed and approved by NRC, revision 2, and the emergency plan as changed by the licensee, revision 148. Changes include variations in the titles of the ERO facilities and ERO positions, along with additional detail for making ERO notifications. No significant changes that alter the intent of these sections have been made over the course of the revisions.

Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments.

If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q):

The changes related to the responsibility for classification affect 10 CFR 50.47(b)(1) and 10 CFR 50.47(b)(2) 10 CFR 50 .4 7(b )( 1), "Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis."

10 CFR 50.47(b)(2), "Onshift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified."

Appendix E to 10 CFR Part 50 Section IV.A (applicable excerpts only):

A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

1. A description of the normal plant operating organization.

2. A description of the onsite emergency response organization (ERO) with a detailed discussion of:

a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

b. Plant staff emergency assignments;

c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

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EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 1 ATTACHMENT 5 Page 8of13

<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments (continued)

3. A description, by position and function to be performed, of the licensee's headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.

The change related to the activation of the ERO affects 10 CFR 50.47(b)(2) 10 CFR 50.47(b)(2), "On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified."

Appendix E to 10 CFR Part 50 Section IV.C (applicable excerpts only):

C. Activation of Emergency Organization

1. The entire spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described. The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described ...

Conclusion The changes related to the responsibility of classification continue to comply with Regulations and Commitments because the authorities, responsibilities and duties (Classification, Notification and Protective Action Coordinator, or the EOF Director, dependent upon which emergency facilities are activated/operational.

The change related to the augmentation of the ERO continues to comply with the Regulation and Commitments because the steps to be taken to activate the ERO remain described and unchanged in approved procedures. This change includes a new note to remind the onshift operations personnel where to obtain a job aid that contains site-specific information on how to contact Security, who will activate the ERO using the automated system

EMERGENCY PLAN CHANGE SCREENING AND AD-EP.:ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>

Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen):

The changes related to the responsibility for classification affect 10 CFR 50.47(b)(1) and 10 CFR 50.47(b)(2)

PLANNING STANDARDS The regulation at 10 CFR 50.47(b)(1) states the following:

"Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis."

The regulation at 10 CFR 50.47(b)(2) states the following:

"[Onshift] " ... facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified."

FUNCTIONS Two emergency planning functions have been defined for 10 CFR 50.47(b)(1 ):

(1) Responsibility for emergency response is assigned.

(2) The response organization has the staff to respond and to augment staff on a continuing basis (i.e.,

24/7 support) in accordance with the emergency plan.

Two emergency planning functions have been defined for 10 CFR 50.47(b)(2):

(1) The process ensures that onshift emergency response responsibilities are staffed and assigned.

(2) The process for timely augmentation of onshift staff is established and maintained.

Appendix E to 10 CFR Part 50 Section IV.A provides supporting requirements (applicable excerpts only):

A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

1. A description of the normal plant operating organization.

2. A description of the onsite emergency response organization (ERO) with a detailed discussion of:

a. Authorities, responsibilities, and duties of the ind.ividual(s) who will take charge during an emergency;

b. Plant staff emergency assignments;

c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

3. A description, by position and function to be performed, of the licensee's headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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