Text

CFR 50.54(q) Evaluations
	ML18036A894
Person / Time
Site:	Harris
Issue date:	02/05/2018
From:	Bradley Jones; Duke Energy Progress
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	HNP-18-017
	Download: ML18036A894 (195)
	v • d • e

Bentley K. Jones Director, Organizational Effectiveness Harris Nuclear Plant 5413 Shearon Harris Rd New Hill, NC 27562-9300 919.362.2305 10 CFR 50.4(b)(5)(ii) 10 CFR 50.54(q)(5)

February 5, 2018 Serial: HNP-18-017 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63

Subject:

10 CFR 50.54(q) Evaluations

Reference:

Letter from Dennis J. Galvin (NRC) to Kelvin Henderson (Duke Energy), Brunswick Steam Electric Plant, Units 1 and 2; Shearon Harris Nuclear Power Plant, Unit 1; H.B. Robinson Steam Electric Plant Unit No. 2; and Oconee Nuclear Station, Units 1, 2, and 3 - Issuance of Amendments to Consolidate Emergency Operations Facilities and Associated Emergency Plan Changes, dated August 21, 2017, Agencywide Documents Access and Management System (ADAMS) Accession Number ML17188A387 Ladies and Gentlemen:

In accordance with 10 CFR 50.4(b)(5)(ii) and 10 CFR 50.54(q)(5), Duke Energy Progress, LLC (Duke Energy), is submitting 10 CFR 50.54(q) Effectiveness Evaluation Forms for revisions to the Shearon Harris Nuclear Power Plant, Unit 1 (HNP), Emergency Plan, Implementing Procedures, and Emergency Program Maintenance Procedures. Specifically, PLP-201, Emergency Plan, Revision 69; PEP-110, Emergency Classification and Protection Action Recommendations, Revision 28; PEP-310, Notifications and Communications, Revision 39; EPM-200, ERO Training Program, Revision 22; and EPM-420, Emergency Equipment Inventory, Revision 18, have been issued. Additionally, PEP-240, Activation and Operation of the Technical Support Center, Revision 24; PEP-241, Technical Support Center (TSC) Emergency Ventilation System Operation, Revision 7; PEP-250, Activation and Operation of the Joint Information Center, Revision 22; PEP-260, Activation and Operation of the Operations Support Center, Revision 19; PEP-270, Activation and Operation of the Emergency Operations Facility, Revision 36; PEP-330, Radiological Consequences, Revision 13; and PEP-500, Recovery, Revision 15, have been superseded by Duke Energy fleet procedures. These changes were effective on January 4, 2018.

The above revisions implement, in part, the Duke Energy Common Emergency Operations Facility for HNP License Amendment No. 160 as issued by the NRC on August 21, 2017, referenced above. Duke Energy has evaluated these revisions, in accordance with 10 CFR 50.54(q), and determined that the revisions are not a reduction in the effectiveness of the Emergency Plan and that the Plan, as changed, continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. The Enclosure to this letter provides the 10 CFR 50.54(q) Effectiveness Evaluation Forms for the changes identified above.

U.S. Nuclear Regulatory Commission Serial: HNP-18-017 This submittal contains no regulatory commitments.

Please refer any questions regarding this submittal to Jeff Robertson, Manager - Regulatory Affairs, at (919) 362-3137.

Sincerely,

~\~

Bentley K. Jones

Enclosure:

10 CFR 50.54(q) Effectiveness Evaluation Forms for PLP-201, Revision 69; PEP-110, Revision 28; PEP-310, Revision 39; EPM-200, Revision 22; EPM-420, Revision 18; and the Superseding of PEP-240, Revision 24; PEP-241, Revision 7; PEP-250, Revision 22; PEP-260, Revision 19; PEP-270, Revision 36; PEP-330, Revision 13; PEP-500, Revision 15 cc: J. Zeiler, NRC Sr. Resident Inspector, HNP M. Barillas, NRC Project Manager, HNP NRC Regional Administrator, Region II

U.S. Nuclear Regulatory Commission Serial: HNP-18-017 This submittal contains no regulatory commitments.

Please refer any questions regarding this submittal to Jeff Robertson, Manager - Regulatory Affairs, at (919) 362-3137.

Sincerely, Bentley K. Jones

Enclosure:

10 CFR 50.54(q) Effectiveness Evaluation Forms for PLP-201, Revision 69; PEP-110, Revision 28; PEP-310, Revision 39; EPM-200, Revision 22; EPM-420, Revision 18; and the Superseding of PEP-240, Revision 24; PEP-241, Revision 7; PEP-250, Revision 22; PEP-260, Revision 19; PEP-270, Revision 36; PEP-330, Revision 13; PEP-500, Revision 15 cc: J. Zeiler, NRC Sr. Resident Inspector, HNP M. Barillas, NRC Project Manager, HNP NRC Regional Administrator, Region II

U.S. Nuclear Regulatory Commission Serial: HNP-18-017 Enclosure SERIAL HNP-18-017 ENCLOSURE SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400/RENEWED LICENSE NUMBER NPF-63 10 CFR 50.54(Q) EFFECTIVENESS EVALUATION FORMS FOR PLP-201, REVISION 69; PEP-110, REVISION 28; PEP-310, REVISION 39; EPM-200, REVISION 22; EPM-420, REVISION 18; AND THE SUPERSEDING OF PEP-240, REVISION 24; PEP-241, REVISION 7; PEP-250, REVISION 22; PEP-260, REVISION 19; PEP-270, REVISION 36; PEP-330, REVISION 13; PEP-500, REVISION 15 (191 PAGES TOTAL PLUS COVER)

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Screening and Evaluation Number Applicable Sites BNP EREG #: 2174957 CNS CR3 HNP MNS 5AD #: 2174934 ONS HNP GO Document and Revision Emergency Plan PLP-201 Revision 69 Part I. Description of Proposed Change:

The NRC approved implementation of the Duke Fleet Common EOF as an element of the HNP Emergency Plan in HNP license amendment 160 dated August 21, 2017, with Enclosure 8 being the Safety Evaluation Report (SER) related to this request. In conjunction with the common EOF, a program initiative was undertaken by Duke Energy to standardize the augmenting ERO positions, functions, and responsibilities (tasks) across the fleet for effective and efficient use of the Common EOF. This involves changes to the current HNP augmenting ERO, based on the number of responders and their titles identified in the site emergency plan and implementing procedures. Included in the standard ERO initiative is the development of fleet standard ERO checklists, procedures and forms.

Note - this initiative makes no changes to the on-shift ERO.

1. Enclosure 1 is the mark up of the HNP emergency plan reflecting the standard augmenting ERO

2. Enclosure 2 is the HNP ERO Position Comparison and Evaluation - TSC/OSC/EOF

3. Enclosure 3 is the HNP ERO Position Comparison and Evaluation - JIC The following changes were implemented in this revision to support implementation of the Standard ERO/Common EOF Project:

From:

2.4.1 Main Control Room A. Shift Manager (SM): Until an emergency is declared, the Shift Manager (SM) has the following responsibilities relating to the Emergency Plan:

1) Direct the activities of the Operations staff.

2) Recognize an off-normal condition as indicated by instrument readings or observation.

3) Implement any Emergency Operating Procedures.

4) Determine when an Emergency Action Level has been met or exceeded, declare an emergency, and assume the position of Site Emergency Coordinator-MCR.

B. Site Emergency Coordinator-MCR: The primary person assigned to the position of Site Emergency Coordinator-MCR during the initial stages of an emergency is the Shift Manager (SM). The assigned alternates are on-shift Licensed Senior Reactor Operators as designated in accordance with operations procedures. Once the Technical Support Center is activated the responsibilities of Site Emergency Coordinator-MCR are turned over to the Site Emergency Coordinator-TSC and the Emergency Response Manager in accordance with the implementing procedures.

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The Site Emergency Coordinator-MCR, shall not delegate the following responsibilities:

1) Classification of the emergency.

2) Approval of required notifications made to the State/Counties and the NRC.

3) Establishment of on-site mission priorities in response to the emergency.

4) Approval of planned radiation exposures for HNP personnel in excess of 5 Rem TEDE or entry into radiation fields greater than 25 Rem/hr.

5) Review and approval of deviations from Technical Specifications or license conditions.

6) Authorization of the administration of Potassium Iodide to on-site emergency workers.

7) Approval of Protective Action Recommendations made to the State/Counties.

8) Termination of the emergency.

C. Plant Operations Director: The Plant Operations Director, located in the Main Control Room after activation of the Technical Support Center, is responsible to the Site Emergency Coordinator-TSC for providing direction to the Main Control Room Staff, the Fire Brigade, and the First Aid Teams (MERT). The POD is trained as a SAMG decision maker whose focus is on the operational aspect of the strategy developed by the TSC.

D. Site Incident Commander: A Site Incident Commander is established on all shifts. When a fire occurs, the Site Incident Commander is the on-scene commander for fighting the fire and directs the activities of the Fire Brigade.

The Site Incident Commander reports to the Site Emergency Coordinator-MCR or to the Plant Operations Director after activation of the Technical Support Center.

E. Fire Brigade: When a fire is announced, the Fire Brigade reports to the Site Incident Commander. If a fire occurs, the Fire Brigade reports to the Fire Staging Area where fire-fighting equipment is located, and then responds to the fire scene. The fire brigade is composed of on-shift personnel trained in fighting fires as described in Section 5.2.

F. First Aid Team (MERT): A First Aid Team (MERT) is established on all shifts. The First Aid Team (MERT) performs/coordinates emergency first aid and search and rescue activities. The First Aid Team (MERT) reports to the Site Emergency Coordinator-MCR or to the Plant Operations Director after activation of the Technical Support Center.

G. Emergency Communicator-MCR: Initially filled with on-shift personnel, is appointed by and reports to the Site Emergency Coordinator-MCR and is responsible for communicating with:

1) Off-site authorities (County, State, NRC, and so forth) to perform required notifications of the declaration, upgrading, termination of an emergency prior to the activation of the TSC and EOF.

2) The plant Emergency Response Organization (during off-hours) when HNP emergency facilities are being activated.

3) Local Immediate Response Organizations (medical, fire, law enforcement, and so forth) if their assistance is needed.

2.4.2 Technical Support Center A. Site Emergency Coordinator-TSC: The Site Emergency Coordinator-TSC is responsible for overall command and control of the on-site response to the emergency. The Site Emergency Coordinator is also responsible for providing guidance to the Technical Analysis Director, Radiological Control Director, Communications Director, Security Director, Plant Operations Director and the Emergency Repair Director.

Upon activation of the Technical Support Center the Site Emergency Coordinator-TSC relieves the Site Emergency Coordinator-MCR of the following major responsibilities:

1) Classification of the emergency.

2) Establishment of on-site mission priorities in response to the emergency.

3) Approval of planned radiation exposures for on-site personnel in excess of 5 Rem TEDE or entry into radiation fields greater than 25 Rem/hr.

4) Review and approval of deviations from Technical Specifications or license conditions. [7.0.U, Recommendation 5i]

5) Authorization of the administration of Potassium Iodide to on-site emergency workers.

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6) A trained SAMG decision maker whose focus is on the development and prioritization aspect of the SAMG strategy.

7) Termination of the emergency.

B. TSC-Senior Reactor Operator: The TSC-Senior Reactor Operator is located in the Technical Support Center and reports to the Site Emergency Coordinator-TSC and directs the TSC-ERFIS Operator. The TSC-Senior Reactor Operator is responsible for providing technical assistance related to plant conditions and operations and to perform monitoring and evaluations required for Severe Accident Management Guidelines.

C. TSC-ERFIS Operator: The Technical Support Center ERFIS Operator reports to the TSC-SRO and is located in the Technical Support Center. The position is responsible for providing/displaying any information from ERFIS requested by Technical Support Center personnel.

D. Technical Analysis Director: The Technical Analysis Director reports to the Site Emergency Coordinator-TSC and is located in the Technical Support Center. The Technical Analysis Director is responsible for providing direction to the Technical Support Center Accident Assessment Team, performing, monitoring and evaluation required for core cooling flow paths, Severe Accident Management Guidelines, and directing AAT members to evaluate strategies that maintain or restore core cooling flow paths and implementing Severe Accident Management Guidelines. [7.0.U, Recommendation 4]

E. TSC-Accident Assessment Team: The TSC-Accident Assessment Team reports to the Technical Analysis Director and is located in the Technical Support Center. The team is composed of a Shift Technical Advisor, Core Performance Engineer, Electrical/I&C Engineer, and Mechanical Engineer. They are responsible for providing recommendations to the Technical Analysis Director on problems as assigned.

F. Communications Director: The Communications Director, located in the Technical Support Center, reports to the Site Emergency Coordinator TSC. The Communications Director is responsible for ensuring notification and communications to Offsite Authorities including the NRC and providing direction to the Emergency Communicator-NRC, TSC-Telecomm/Computer Support, TSC Logkeeper and the Admin Team.

G. Emergency Communicator-NRC: The Emergency Communicator-NRC is located in the Technical Support Center and reports to the Communications Director. The Emergency Communicator-NRC is responsible for:

1) Generating required written notifications to the NRC in a timely manner.

2) Establishing contact with the NRC via the Emergency Telecommunications System and providing any requested information of the status of the emergency.

H. TSC-Telecomm/Computer Support: TSC-Telecomm/Computer Support personnel are located in the Technical Support Center and report to the Communications Director. They are responsible for providing technical assistance required in the areas of telecommunications or computer support.

I. TSC Admin Team: The TSC Admin Team is located in the Technical Support Center and is composed of a Librarian and Admin Support personnel. They report to the Communications Director and are responsible for providing any documents, prints or other clerical services as requested by personnel in the Technical Support Center.

J. TSC Logkeeper: The TSC Logkeeper is located in the Technical Support Center and reports to the Communications Director. The TSC Logkeeper is responsible for recording the major activities that occur in the Technical Support Center during an emergency.

K. Radiological Control Director: The Radiological Control Director is located in the Technical Support Center and reports to the Site Emergency Coordinator-TSC. The Chemistry Coordinator and the Radiological Control Coordinator, both located in the Operations Support Center, report to the Radiological Control Director. The Radiological Control Director is responsible for:

1) Providing direction to onsite health physics and chemistry emergency response actions.

2) Ensuring that the Site Emergency Coordinator and other Directors in the Technical Support Center are kept informed of radiological/chemical conditions on and off site.

L. TSC HP Technician: The TSC HP Technician, normally located in the Technical Support Center, reports to the Radiological Control Director and is responsible for providing radiological support and monitoring activities within the TSC.

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M. Security Director: The Security Director, normally located in the Technical Support Center, reports to the Site Emergency Coordinator-TSC and has the following major responsibilities:

1) Maintaining plant security in accordance with the provisions of the HNP Security Plan and Safeguards Contingency Plan.

2) Coordinating the accountability of personnel inside the Protected Area.

3) Providing Security Force personnel in support of emergency activities.

2.4.3 Operations Support Center A. Emergency Repair Director: The Emergency Repair Director, located in the Operations Support Center, reports to the Site Emergency Coordinator-TSC. The Emergency Repair Director is responsible for providing direction to the total on-site maintenance and equipment restoration effort from the Operations Support Center.

B. Damage Control Coordinator: The Damage Control Coordinator, located in the Operations Support Center, reports to the Emergency Repair Director. The Damage Control Coordinator is responsible for providing direction to the Damage Control Team Leaders, Maintenance Planners, and OSC Logkeeper.

C. Damage Control Team Leaders: The Damage Control Team Leaders are appointed by the Damage Control Coordinator. They are responsible to the Damage Control Coordinator for on-the-scene supervision of the Damage Control Teams to which they are assigned.

D. Damage Control Teams: The Damage Control Teams are dispatched by the Damage Control Coordinator, from their initial assembly point in the Operations Support Center, to the scene of an emergency repair or damage assessment requirement. The Damage Control Teams report to the on-scene Damage Control Team Leader and are composed of mechanical, instrument and control, and electrical maintenance personnel.

E. Maintenance Planners: Maintenance Planners, located in the Operations Support Center, report to the Damage Control Coordinator. The Maintenance Planners are responsible for developing plans for emergency repair, determining spare parts needed to make the repairs and estimating the amount of time required to perform the emergency repairs.

F. OSC Logkeeper: The OSC Logkeeper, located in the Operations Support Center, reports to the Damage Control Coordinator. The OSC Logkeeper is responsible for recording the major activities that occur in the Operations Support Center during an emergency.

G. Radiological Control Coordinator: The Radiological Control Coordinator, located in the Operations Support Center, is responsible to the Radiological Control Director for providing direction to the Radiological Control Teams during an emergency.

H. Radiological Control Teams: Radiological Control Teams report to the Radiological Control Coordinator and are composed of health physics personnel. They assemble initially in the Operations Support Center and are subsequently dispatched wherever personnel radiation control and decontamination functions are needed.

I. Chemistry Coordinator: The Chemistry Coordinator, located in the OSC, is responsible to the Radiological Control Director for providing direction to the Chemistry Team during an emergency.

J. Chemistry Team: Chemistry Teams report to the Chemistry Coordinator and are composed of plant chemistry personnel. They assemble initially in the Operations Support Center and are subsequently dispatched to sampling stations and the laboratory.

2.4.4 Emergency Operations Facility A. Emergency Response Manager: The Emergency Response Manager, located in the Emergency Operations Facility, is responsible for overall command and control of the HNP response to the emergency. The Emergency Response Manager is also responsible for providing guidance to the Technical Analysis Manager, Radiological Control Manager, Communications Manager, and the Admin and Logistics Manager.

Upon activation of the Emergency Operations Facility the Emergency Response Manager relieves the Site Emergency Coordinator-MCR of the following major responsibilities:

1) Approval of required notifications to the State/Counties.

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2) Approval of planned radiation exposures for off-site HNP personnel in excess of 5 Rem TEDE or entry into radiation fields greater than 25 Rem/hr.

3) Approval of the administration of Potassium Iodide to off-site HNP emergency workers.

4) Approval of Protective Action Recommendations.

5) Direct interface with offsite authorities.

6) Coordination of Dose Projection and Environmental Monitoring activities.

7) A trained SAMG decision maker whose focus is on the offsite consequences of the strategy recommended by the TSC. The ERM has the ultimate approval authority for strategy implementation.

B. EOF-Senior Reactor Operator: The EOF-Senior Reactor Operator is located in the Emergency Operations Facility and reports to the Emergency Response Manager. The EOF-Senior Reactor Operator is responsible for providing technical information and assistance related to plant conditions and operations.

C. Emergency Preparedness Advisor: The Emergency Preparedness Advisor, located in the Emergency Operations Facility, reports to the Emergency Response Manager in the EOF and advises the Emergency Response Manager and other Emergency Response Organization personnel on implementation of the Emergency Plan and implementing procedures.

D. News Coordinator: The News Coordinator, located in the Emergency Operations Facility, reports to the Emergency Response Manager. The News Coordinator has the responsibility for preparing and coordinating the approval of news releases.

E. Administrative and Logistics Manager: The Administrative and Logistics Manager, located in the Emergency Operations Facility, reports to the Emergency Response Manager and is responsible for direction of activities of the Administrative Team Leader and Admin Building Assembly Area Leader.

F. EOF Telecomm/Computer Support: EOF Telecommunications/Computer Support personnel are located in the EOF and report to the Administrative and Logistics Manager. They are responsible for providing technical assistance required in the areas of telecommunications or computer support.

G. Admin Team Leader: The Admin Team Leader, located in the Emergency Operations Facility, reports to the Administrative and Logistics Manager and is responsible for directing the actions of the Admin Team.

H. Admin Team: The Admin Team, located in the Emergency Operations Facility, consists of a Setup Leader, Librarian and Admin Support personnel. They report to the Admin Team Leader and are responsible for providing any documents, prints or other clerical services as requested by personnel in the Emergency Operations Facility.

I. EOF Logkeeper: The EOF Logkeeper is located in the Emergency Operations Facility and reports to the Admin Team Leader. The EOF Logkeeper is responsible for recording the major activities that occur in the Emergency Operations Facility during an emergency.

J. Assembly Area Leader: The Assembly Area Leader is responsible to the Admin and Logistics Manager, or prior to activation of this position, the Site Emergency Coordinator, for coordinating the activities in the Admin Building Assembly Area.

K. Technical Analysis Manager: The Technical Analysis Manager reports to the Emergency Response Manager and is responsible for direction of activities of the Emergency Operations Facility Accident Assessment Team.

L. EOF Accident Assessment Team: The EOF Assessment Team reports to the Technical Analysis Manager and is located in the Emergency Operations Facility. The team is composed of a Civil Engineer, Electrical Engineer, I&C Engineer, and Mechanical Engineer. They are responsible for providing recommendations to the Technical Analysis Manager on problems as assigned.

M. Radiological Control Manager: The Radiological Control Manager, located in the Emergency Operations Facility, reports to the Emergency Response Manager. The Radiological Control Manager is responsible for providing direction to the Dose Projection Team Leader, Technical Advisor and the EOF Health Physics Technician. The Radiological Control Manager is also responsible for:

1) Providing direction to offsite health physics emergency response actions.

2) Ensuring that the Emergency Response Manager and other Managers in the EOF are kept informed of radiological/chemical conditions on and off site.

N. Technical Advisor: The Technical Advisor, located in the Emergency Operations Facility, reports to the

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Radiological Control Manager. The Technical Advisor assists the Radiological Control Manager and staffs the HPN Line when requested by the NRC.

O. Dose Projection Team Leader: The Dose Projection Team Leader, located in the Emergency Operations Facility, reports to the Radiological Control Manager. The Dose Projection Team Leader provides guidance to the Environmental Field Coordinator and the Dose Projection Team.

P. Dose Projection Team: The Dose Projection Team reports to the Dose Projection Team Leader and is located in the Emergency Operations Facility. The Dose Projection Team is responsible for performing source term and offsite dose calculations.

Q. Environmental Field Coordinator: The Environmental Field Coordinator, located in the Emergency Operations Facility, is responsible to the Dose Projection Team Leader. The Environmental Field Coordinator is responsible for providing direction to the Environmental Monitoring Teams.

R. Environmental Monitoring Teams: Environmental Monitoring Teams report to the Environmental Field Coordinator after activation of the Emergency Operations Facility, or, prior to activation of the Emergency Operations Facility, to the Site Emergency Coordinator -MCR. Teams assemble at HE&EC and are subsequently dispatched in vehicles to the surrounding area. They are responsible for offsite plume tracking, monitoring and other sampling activities.

S. Communications Manager: The Communications Manager, located in the Emergency Operations Facility, reports to the Emergency Response Manager. The Communications Manager is responsible for ensuring notification and communication to offsite authorities and providing direction to the Emergency Communicator-State/County and the Representatives to the State and County EOCs.

T. Emergency Communicator-State/Counties: The Emergency Communicator-State/Counties, located in the Emergency Operations Facility, reports to the Communications Manager. The Emergency Communicator-State/Counties is responsible for conducting timely notification and transfer of emergency information to the State and Counties.

U. Emergency Communicator-Corporate Comm/JIC: The Emergency Communicator-Corporate Comm/JIC, located in the Emergency Operations Facility, reports to the Communications Manager. The Emergency Communicator-Corporate Comm/JIC is responsible for providing information to support public information emergency response activities.

V. Representatives to the State/County EOCs: The Representatives to the State/County EOCs are located at the following:

N.C. State EOC Joint Force Headquarters (JFHQ) building, 1636 Gold Star Drive, Raleigh North Carolina and is the principle Emergency Operations Center.

Wake County EOC Wake County Courthouse, Raleigh, N.C.

Chatham County EOC Emergency Operations Center, Pittsboro, N.C.

Harnett County EOC Emergency Operations Center, Lillington, N.C.

Lee County EOC Lee County Courthouse, Sanford, N.C.

Chatham County Alternate EOC 3760 Alston Bridge Rd., Siler City, NC Harnett County Alternate EOC 126 Alexander Dr., Lillington, NC Lee County Alternate EOC, 225 E. Weatherspoon, Sanford, NC These representatives act as technical liaisons to facilitate communications and the coordination of information flow between the Site Emergency Coordinator or Emergency Response Manager and State/local authorities. They report to the Communications Manager in the Emergency Operations Facility.

2.4.5 Joint Information Center A. Company Spokesperson: The Company Spokesperson, located in the Joint Information Center, reports to the Emergency Response Manager. The Company Spokesperson is responsible for providing guidance to the JIC Director, Admin Coordinator and Public Information Coordinator. The Company Spokesperson also has the following major responsibilities:

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1) Maintain command and control of the Joint Information Center.

2) Coordinates and directs responses to media inquiries.

3) Ensure that the composition and timeliness of Duke Energy News Releases are adequate.

4) Conduct periodic briefings with the news media.

5) Provide for timely exchange of information between other spokespersons.

B. Technical Specialist: The Technical Specialist, located in the Joint Information Center, reports to the Company Spokesperson. The Technical Specialist is responsible for obtaining and developing technical emergency information.

1) Gather information from the EOF for Duke Energy news media briefings.

2) Provide timely and accurate technical information to the media during formal briefings.

C. JIC Director: The JIC Director, located in the Joint Information Center, reports to the Company Spokesperson.

The JIC Director is responsible for the development and coordination of news releases and dissemination of information.

D. Administrative Coordinator: The Administrative Coordinator, located in the Joint Information Center, reports to the Technical Specialist. The Administrative Coordinator provides guidance to the Administrative Assistants and Media Badging Specialist.

E. Administrative Assistant: The Administrative Assistant, located in the Joint Information Center, reports to the Administrative Coordinator. The Administrative Assistant is responsible for providing administrative services and supplies to Joint Information Center personnel.

F. Media Badging Specialist: The Media Badging Specialist, located in the Joint Information Center, reports to the Administrative Coordinator. The Media Badging Specialist is responsible for controlling access to the Media Briefing Area and distributing information.

G. Public Information Coordinator: The Public Information Coordinator, located in the Joint Information Center, reports to the Company Spokesperson and interfaces with the Customer Service Center.

H. Customer Service Center: The Customer Service Center is responsible for staffing telephone lines to respond to calls from the media and public.

4.5.2.C. Possible recommendations issued by HNP at a General Emergency include, but are not limited to:

1) Evacuation of the general public within the two (2) mile radius and five (5) miles downwind. All other areas within the EPZ are sheltered (minimum PAR issued).

2) Evacuation of the general public within the five (5) mile radius and ten (10) miles downwind. All other areas within the EPZ are sheltered To:

2.4.1 Main Control Room A. Shift Manager (SM): Until an emergency is declared, the Shift Manager (SM) has the following responsibilities relating to the Emergency Plan:

1) Direct the activities of the Operations staff.

2) Recognize an off-normal condition as indicated by instrument readings or observation.

3) Implement any Emergency Operating Procedures.

4) Determine when an Emergency Action Level has been met or exceeded, declare an emergency, and assume the position of Emergency Coordinator-MCR.

B. Emergency Coordinator-MCR: The primary person assigned to the position of Emergency Coordinator-MCR during the initial stages of an emergency is the Shift Manager (SM). The assigned alternates are on-shift Licensed Senior Reactor Operators as

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designated in accordance with operations procedures. Once the Technical Support Center is activated the responsibilities of Emergency Coordinator-MCR are turned over to the Emergency Coordinator-TSC and the EOF Director in accordance with the implementing procedures.

The Emergency Coordinator-MCR, shall not delegate the following responsibilities:

1) Classification of the emergency.

2) Approval of required notifications made to the State/Counties and the NRC.

3) Establishment of on-site mission priorities in response to the emergency.

4) Approval of planned radiation exposures for HNP personnel in excess of 5 Rem TEDE or entry into radiation fields greater than 25 Rem/hr.

5) Review and approval of deviations from Technical Specifications or license conditions.

6) Authorization of the administration of Potassium Iodide to on-site emergency workers.

7) Approval of Protective Action Recommendations made to the State/Counties.

8) Termination of the emergency.

C. Site Incident Commander: A Site Incident Commander is established on all shifts. When a fire occurs, the Site Incident Commander is the on-scene commander for fighting the fire and directs the activities of the Fire Brigade. The Site Incident Commander reports to the Emergency Coordinator-MCR or to the Plant Operations Director after activation of the Technical Support Center.

D. Fire Brigade: When a fire is announced, the Fire Brigade reports to the Site Incident Commander. If a fire occurs, the Fire Brigade reports to the Fire Staging Area where fire-fighting equipment is located, and then responds to the fire scene. The fire brigade is composed of on-shift personnel trained in fighting fires as described in Section 5.2.

E. First Aid Team (MERT): A First Aid Team (MERT) is established on all shifts. The First Aid Team (MERT) performs/coordinates emergency first aid and search and rescue activities. The First Aid Team (MERT) reports to the Emergency Coordinator-MCR or to the Plant Operations Director after activation of the Technical Support Center.

F. Emergency Communicator-MCR: Initially filled with on-shift personnel, is appointed by and reports to the Emergency Coordinator-MCR and is responsible for communicating with:

1) Off-site authorities (County, State, NRC, and so forth) to perform required notifications of the declaration, upgrading, termination of an emergency prior to the activation of the TSC and EOF.

2) The plant Emergency Response Organization (during off-hours) when HNP emergency facilities are being activated.

3) Local Immediate Response Organizations (medical, fire, law enforcement, and so forth) if their assistance is needed.

2.4.2 Technical Support Center The TSC Organization Chart is show in Figure 2.4-2.

A. Emergency Coordinator/Assistant Emergency Coordinator:

The Emergency Coordinator reports to the EOF Director and supervises and directs the site ERO. The Assistant Emergency Coordinator reports to the Emergency Coordinator and manages the operation of the TSC. The Emergency Coordinator and Assistant Emergency Coordinator positions are equally qualified. Key responsibilities include:

1) Coordinate response activities with offsite response agencies (EM, ICP, Field Mon, etc.)

2) Verify that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list has been completed

3) Coordinate ERO/facility shift turnover

4) Assume/maintain command and control

5) Transfer command and control

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6) Manage all onsite emergency response activities

7) Manage facility emergency response activities

8) Coordinate integration of the NRC site team

9) Prioritize and authorize requests for external assistance (technical, craft, admin, etc.)

10) Approve equipment, supply, and logistics expenditures for response to the event

11) Arrange for equipment and supply resources

12) Arrange for logistics support

13) Request Federal support and resources

14) Classify and declare emergencies

15) Assist with emergency classification

16) Approve and direct offsite emergency notifications to state and local authorities

17) Direct notifications and ENS communications with the NRC

18) Ensure flow of information within and between the emergency response facilities

19) Perform or direct emergency PA announcements

20) Ensure minimum staff is available (facility staffed)

21) Determine current/projected staff needs

22) Ensure facility staff is prepared to perform their activities (facility ready)

23) Activate the facility (facility activated)

24) Direct/coordinate facility relocation

25) Determine and direct site response priorities

26) Support determination of site response priorities

27) Determine and direct the actions for mitigation strategies and contingency plans

28) Coordinate between CR, OSC and TSC to set OSC Team task priorities

29) Direct/support site assembly, accountability and search & rescue activities

30) Establish and maintain facility accountability

31) Coordinate site evacuation

32) Approve use of KI

33) Approve offsite Protective Action Recommendations

34) Approve emergency exposures

35) Ensure habitability is established and maintained for occupied areas

36) Terminate the emergency event

37) Develop recovery plans

38) Authorize and direct extreme measures (FLEX, EDMG, SAMG, §50.54(x) or security controls)

39) Conduct facility briefs and updates

40) Provide input for facility briefs and updates

41) Review and approval of deviations from Technical Specifications or license conditions.

[7.0.U, Recommendation 5i]

B. Offsite Communicator The Offsite Communicator reports to the Emergency Coordinator. Key responsibilities include:

1) Perform offsite emergency notifications to state and local authorities

2) Distribute forms, reports, etc. as needed C. Log Keeper The Log Keeper reports to the Emergency Coordinator. Key responsibilities include:

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1) Maintain status and information boards/displays D. ICP Liaison The ICP Liaison position is only filled during a security related event in which the offsite agencies activate the ICP. The ICP Liaison reports to the Emergency Coordinator. Key responsibilities include:

1) Communicate with ICP to provide information and coordination E. Security Coordinator The Security Coordinator reports to the Assistant Emergency Coordinator. Key responsibilities include:

1) Manage assigned group emergency response activities

2) Request and coordinate emergency activities with law enforcement agencies

3) Develop requests and coordinate external assistance (technical, craft, admin, etc.)

4) Arrange for equipment and supply resources

5) Communicate with ICP to provide information and coordination

6) Provide security related information to the NRC

7) Participate with OSC Team dispatch and control

8) Direct/support site assembly, accountability and search & rescue activities

9) Establish and maintain accountability for security personnel

10) Provide support and logistics for site evacuation activities

11) Direct site access controls activities

12) Ensure radiological conditions are known for occupied areas

13) Support MERT activities

14) Coordinate security activities

15) Provide input for facility briefs and updates F. Site Evacuation Coordinator The Site Evacuation Coordinator reports to the Assistant Emergency Coordinator. Key responsibilities include:

1) Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list

2) Establish and maintain facility accountability

3) Coordinate site evacuation G. OAC Support The OAC Support position reports to the Assistant Emergency Coordinator. Key responsibilities include:

1) Monitor facility equipment (e.g., computer, communications) for proper operation

2) Activate ERDS or confirm ERDS Operation H. IT Support The IT Support position reports to the Assistant Emergency Coordinator. Key responsibilities include:

1) Monitor facility equipment (e.g., computer, communications) for proper operation I. Engineering Manager The Engineering Manager reports to the Emergency Coordinator. Key responsibilities include:

1) Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list

2) Manage assigned group emergency response activities

3) Develop requests and coordinate external assistance (technical, craft, admin, etc.)

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4) Arrange for equipment and supply resources

5) Monitor status and information boards/displays/systems

6) Perform event detection and assessment activities

7) Support determination of site response priorities

8) Support development of mitigation strategies and contingency plans

9) Analyze and develop extreme measures actions (FLEX, EDMG, SAMG, §50.54(x))

10) Provide input for facility briefs and updates J. Reactor Engineer The Reactor Engineer reports to the Engineering Manager. Key responsibilities include:

1) Communicate on assigned communication line and provide information to facility staff

2) Monitor status and information boards/displays/systems

3) Perform event detection and assessment activities

4) Support development of mitigation strategies and contingency plans

5) Provide analysis of core damage and fission product release potential.

K. Electrical Engineer The Electrical Engineer reports to the Engineering Manager. Key responsibilities include:

1) Monitor status and information boards/displays/systems

2) Perform event detection and assessment activities

3) Support development of mitigation strategies and contingency plans L. Mechanical Engineer The Mechanical Engineer reports to the Engineering Manager. Key responsibilities include:

1) Monitor status and information boards/displays/systems

2) Perform event detection and assessment activities

3) Support development of mitigation strategies and contingency plans M. Operations Manager The Operations Manager reports to the Emergency Coordinator. Key responsibilities include:

1) Monitor status of the Emergency Operations Procedures

2) Manage assigned group emergency response activities

3) Develop requests and coordinate external assistance (technical, craft, admin, etc.)

4) Arrange for equipment and supply resources

5) Assist with emergency classification

6) Support completion of the ENF to state and local authorities

7) Monitor status and information boards/displays/systems

8) Perform event detection and assessment activities

9) Support determination of site response priorities

10) Support development of mitigation strategies and contingency plans

11) Coordinate between CR, OSC and TSC to set OSC Team task priorities

12) Evaluate conditions and develop offsite Protective Action Recommendations

13) Analyze and develop extreme measures actions (FLEX, EDMG, SAMG, §50.54(x))

14) Provide input for facility briefs and updates N. Assistant Operations Manager The Assistant Operations Manager reports to the Operations Manager. Key responsibilities include:

1) Monitor status of the Emergency Operations Procedures

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2) Assist with emergency classification

3) Communicate on assigned communication line and provide information to facility staff

4) Monitor status and information boards/displays/systems

5) Maintain status and information boards/displays

6) Perform event detection and assessment activities

7) Support development of mitigation strategies and contingency plans

8) Coordinate between CR, OSC and TSC to set OSC Team task priorities

9) Provide input for facility briefs and updates O. NRC Communicator The NRC Communicator reports to the Operations Manager. Key responsibilities include:

1) Provide event data and plant information to the NRC via the ENS

2) Activate ERDS or confirm ERDS operation

3) Monitor status and information boards/displays/systems P. CR Operations Bridge The CR Operations Bridge reports to the Operations Manager. Key responsibilities include:

1) Communicate on assigned communication line and provide information to facility staff

2) Perform event detection and assessment activities

3) Support development of mitigation strategies and contingency plans

4) Communicate the activities of Ops personnel dispatched out of the CR to the OSC Q. RP Manager The RP Manager reports to the Emergency Coordinator. Key responsibilities include:

1) Manage assigned group emergency response activities

2) Develop requests and coordinate external assistance (technical, craft, admin, etc.)

3) Arrange for equipment and supply resources

4) Assist with emergency classification

5) Support completion of the ENF to state and local authorities

6) Maintain status and information boards/displays

7) Perform event detection and assessment activities

8) Monitor, evaluate and communicate conditions involving any release of radioactivity

9) Direct/perform dose assessment

10) Brief and dispatch the onsite/offsite radiation monitoring teams

11) Provide support and logistics for site assembly activities

12) Provide support and logistics for site evacuation activities

13) Evaluate the need for and ensure proper use of KI

14) Evaluate conditions and develop offsite Protective Action Recommendations

15) Ensure approved emergency exposure controls are issued

16) Direct personnel monitoring and decontamination activities

17) Ensure habitability is established and maintained for occupied areas

18) Establish contamination controls for occupied areas

19) Support MERT activities

20) Provide input for facility briefs and updates R. Dose Assessor The Dose Assessor reports to the RP Manager. Key responsibilities include:

1) Assist with emergency classification

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2) Provide event data and plant information to the NRC via the HPN

3) Communicate on assigned communication line and provide information to facility staff

4) Monitor status and information boards/displays/systems

5) Prepare for facility activation (rooms, work area, equipment, etc.)

6) Maintain status and information boards/displays

7) Monitor, evaluate and communicate conditions involving any release of radioactivity

8) Direct/perform dose assessment

9) Direct field monitoring team activities

10) Evaluate conditions and develop offsite Protective Action Recommendations

11) Establish facility ventilation and monitoring for habitability controls 2.4.3 Operations Support Center The OSC Organization Chart is show in Figure 2.4-3.

A. OSC Manager/Assistant OSC Manager The OSC Manager reports to the Emergency Coordinator. The Assistant OSC Manager reports to the OSC Manager. The OSC Manager and Assistant OSC Manager positions are equally qualified. Key responsibilities include:

1) Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list

2) Verify that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list has been completed

3) Coordinate ERO/facility shift turnover

4) Manage facility emergency response activities

5) Develop requests and coordinate external assistance (technical, craft, admin, etc.)

6) Arrange for equipment and supply resources

7) Ensure flow of information within and between the emergency response facilities

8) Prepare for facility activation (rooms, work area, equipment, etc.)

9) Ensure minimum staff is available (facility staffed)

10) Determine current/projected staff needs

11) Ensure facility staff is prepared to perform their activities (facility ready)

12) Activate the facility (facility activated)

13) Direct/coordinate facility relocation

14) Support facility relocation

15) Support determination of site response priorities

16) Coordinate between CR, OSC and TSC to set OSC Team task priorities

17) Coordinate OSC Team dispatch and control

18) Participate with OSC Team dispatch and control

19) Direct/support site assembly, accountability and search & rescue activities

20) Establish and maintain facility accountability

21) Ensure habitability is established and maintained for occupied areas

22) Conduct facility briefs and updates

23) Provide input for facility briefs and updates B. Log Keeper The Log Keeper reports to the OSC Manager. Key responsibilities include:

1) Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list

2) Ensure minimum staff is available (facility staffed)

3) Maintain status and information boards/displays

4) Participate with OSC Team dispatch and control

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C. Maintenance Supervisor The Maintenance Supervisor reports to the OSC Manager. Key responsibilities include:

1) Manage assigned group emergency response activities

2) Develop requests and coordinate external assistance (technical, craft, admin, etc.)

3) Arrange for equipment and supply resources

4) Participate with OSC Team dispatch and control

5) Provide input for facility briefs and updates D. Operations Supervisor The Operations Supervisor reports to the OSC Manager. Key responsibilities include:

1) Manage assigned group emergency response activities

2) Develop requests and coordinate external assistance (technical, craft, admin, etc.)

3) Arrange for equipment and supply resources

4) Monitor status and information boards/displays/systems

5) Participate with OSC Team dispatch and control

6) Provide input for facility briefs and updates E. Operations Liaison The Operations Liaison reports to the Operations Supervisor. Key responsibilities include:

1) Communicate on assigned communication line and provide information to facility staff

2) Monitor status and information boards/displays/systems

3) Participate with OSC Team dispatch and control F. RP Supervisor The RP Supervisor reports to the OSC Manager. Key responsibilities include:

1) Manage assigned group emergency response activities

2) Develop requests and coordinate external assistance (technical, craft, admin, etc.)

3) Arrange for equipment and supply resources

4) Communicate on assigned communication line and provide information to facility staff

5) Monitor status and information boards/displays/systems

6) Perform radiological sampling and surveys

7) Record/review radiological sampling and survey data

8) Participate with OSC Team dispatch and control

9) Establish and maintain facility accountability

10) Track emergency worker exposure and evaluate the need for dose extensions

11) Coordinate the monitoring of site evacuees

12) Ensure habitability is established and maintained for occupied areas

13) Establish contamination controls for occupied areas

14) Provide input for facility briefs and updates G. Field Monitoring Team Member The Field Monitoring Team members initially report to the RP Supervisor, until turned over to the TSC Dose Assessor or EOF Field Team Coordinator. Key responsibilities include:

1) Communicate on assigned communication line and provide information to facility staff

2) Performs radiological sampling and surveys

3) Record/review radiological sampling and survey data

4) Identify airborne plumes or liquid effluents

5) Participate with OSC Team dispatch and control

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H. Chemistry Supervisor The Chemistry Supervisor reports to the OSC Manager. Key responsibilities include:

1) Manage assigned group emergency response activities

2) Develop requests and coordinate external assistance (technical, craft, admin, etc.)

3) Arrange for equipment and supply resources

4) Perform event detection and assessment activities

5) Perform chemical sampling and analysis

6) Record/review chemical sampling and analysis

7) Participate with OSC Team dispatch and control

8) Provide input for facility briefs and updates I. Operations and Craft Personnel Additional Ops, Maintenance, RP and Chemistry personnel report to their associated supervisor in the OSC. Response activities involve their current job tasks.

1) Participate with OSC Team dispatch and control J. Generation Supply Chain Liaison The Generation Supply Chain Liaison reports to the OSC Manager. Key responsibilities include:

1) Develop requests and coordinate external assistance (i.e., technical, craft, admin)

2) Arrange for equipment and supply resources

3) Arrange for logistics support

4) Prepare for facility activation (i.e., rooms, work area, equipment)

5) Participate with OSC Team dispatch and control

6) Serve as primary point of contact for SAFER and FLEX support K. Fire Brigade When conditions require activation of the emergency facilities, the on-shift Fire Brigade is incorporated into the Operational Support Center.

The Fire Brigade consists of a Shift Incident Commander, and a minimum of four fire brigade members who provide fire brigade, search and rescue, chemical/hazardous materials response, and confined space entry services. Fire Brigade members will be the on-shift operators, or other personnel qualified as Fire Brigade members. The Fire Brigade, when incorporated into the OSC, functions as a team under the direction of the Operations Supervisor. The Fire Brigade is staffed on a 24-hour basis.

L. Medical Emergency Response Team (MERT)

MERT provides first aid to plant personnel and is made up from personnel in the Security department. MERT members will be the on-shift security officers qualified in first aid. MERT is staffed on a 24-hour basis. Upon activation of the Emergency Response Facilities, the Medical Emergency Response Team reports to the OSC, as a unit, and provides medical response as well as their other Security duties.

2.4.4 Emergency Operations Facility (EOF)

The EOF Organization Chart is show in Figure 2.4-4.

A. EOF Director/Assistant EOF Director The EOF Director is the head of the ERO and directs the overall response. The Assistant EOF Director reports to the EOF Director and manages the operation of the EOF. The EOF Director and Assistant EOF Director positions are equally qualified. Key responsibilities include:

1) Coordinate response activities with offsite response agencies (i.e., EM, ICP, Field Mon)

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2) Verify that the 24-hour staffing list has been completed

3) Coordinate ERO/facility shift turnover

4) Perform position turnover when a shift change occurs

5) Assume/maintain command and control

6) Transfer command and control

7) Manage facility emergency response activities

8) Coordinate integration of the NRC site team

9) Prioritize and authorize requests for external assistance (i.e., technical, craft, admin)

10) Approve equipment, supply, and logistics expenditures for response to the event

11) Request Federal support and resources

12) Assist with emergency classification

13) Approve and direct offsite emergency notifications to state and local authorities

14) Ensure flow of information within and between the emergency response facilities

15) Perform or direct emergency PA announcements

16) Provide technical assistance for the development of news releases and statements

17) Ensure minimum staff is available (facility staffed)

18) Determine current/projected staff needs

19) Ensure facility staff is prepared to perform their activities (facility ready)

20) Activate the facility (facility activated)

21) Direct/coordinate facility relocation

22) Determine and direct the actions for mitigation strategies and contingency plans

23) Approve offsite Protective Action Recommendations

24) Terminate the emergency event

25) Develop recovery plans

26) Conduct facility briefs and updates B. Log Keeper The Log Keeper reports to the EOF Director. Key responsibilities include:

1) Distribute forms, reports, etc. as needed

2) Maintain status and information boards/displays C. Data Coordinator The Data Coordinator reports to the EOF Director. Key responsibilities include:

1) Monitor facility equipment (computer, communications, etc.) for proper operation D. Emergency Planner The Emergency Planner reports to the EOF Director. Key responsibilities include:

1) Coordinate information and activities with offsite agency personnel in the facility

2) Coordinate integration of the NRC site team

3) Support State/County EOC Liaisons

4) Support completion of the ENF to state and local authorities

5) Prepare for facility activation (rooms, work area, equipment, etc.)

6) Provide input for facility briefs and updates E. State and County Liaisons The State and County Liaisons are staffed by site personnel and report to the Emergency Planner. Key responsibilities include:

1) Coordinate information with government officials/agencies

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2) Report status of state and county emergency response activities from the EOCs F. Accident Assessment Manager The Accident Assessment Manager reports to the EOF Director. Key responsibilities include:

1) Develop requests and coordinate external assistance (i.e., technical, craft, admin)

2) Arrange for equipment and supply resources

3) Assist with emergency classification

4) Perform event detection and assessment activities

5) Evaluate conditions and develop offsite Protective Action Recommendations

6) Provide input for facility briefs and updates G. Accident Assessment Interface The Accident Assessment Interface reports to the Accident Assessment Manager. Key responsibilities include:

1) Monitor status of the Emergency Operations Procedures

2) Assist with emergency classification

3) Communicate on assigned communication line and provide information to facility staff

4) Monitor status and information boards/displays/systems

5) Maintain status and information boards/displays

6) Perform event detection and assessment activities

7) Provide analysis of core damage and fission product release potential

8) Evaluate conditions and develop offsite Protective Action Recommendations

9) Analyze and develop extreme measures actions (FLEX, EDMG, SAMG, §50.54(x))

H. Radiological Assessment Manager The Radiological Assessment Manager reports to the EOF Director. Key responsibilities include:

1) Manage assigned group emergency response activities

2) Develop requests and coordinate external assistance (i.e., technical, craft, admin)

3) Assist with emergency classification

4) Support completion of the ENF to state and local authorities

5) Communicate on assigned communication line and provide information to facility staff

6) Monitor status and information boards/displays/systems

7) Perform event detection and assessment activities

8) Monitor, evaluate and communicate conditions involving any release of radioactivity

9) Direct/perform dose assessment

10) Brief and dispatch the onsite/offsite radiation monitoring teams

11) Provide support and logistics for site evacuation activities

12) Evaluate conditions and develop offsite Protective Action Recommendations

13) Direct post-accident environmental sampling and exposure activities

14) Provide input for facility briefs and updates I. Dose Assessor The Dose Assessor reports to the Radiological Assessment Manager. Key responsibilities include:

1) Assist with emergency classification

2) Support completion of the ENF to state and local authorities

3) Provide event data and plant information to the NRC via the HPN

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4) Communicate on assigned communication line and provide information to facility staff

5) Monitor status and information boards/displays/systems

6) Prepare for facility activation (i.e., rooms, work area, equipment)

7) Monitor, evaluate and communicate conditions involving any release of radioactivity

8) Direct/perform dose assessment

9) Evaluate conditions and develop offsite Protective Action Recommendations J. Field Monitoring Coordinator The Field Monitoring Coordinator reports to the Radiological Assessment Manager. Key responsibilities include:

1) Maintain status and information boards/displays

2) Brief and dispatch the onsite/offsite radiation monitoring teams

3) Direct field monitoring team activities

4) Coordinate activities with the external agency field monitoring teams.

5) Coordinate the receipt, analysis, storage and transfer of field monitoring samples

6) Record/review radiological sampling and survey data K. Offsite Communicator The Offsite Communicator reports to the EOF Director. Key responsibilities include:

1) Provide event notification/information to industry groups (i.e., INPO, ANI)

2) Perform offsite emergency notifications to state and local authorities

3) Support completion of the ENF to state and local authorities

4) Distribute forms, reports, etc. as needed L. Services Manager The Services Manager reports to the EOF Director. Key responsibilities include:

1) Develop requests and coordinate external assistance (i.e., technical, craft, admin)

2) Arrange for equipment and supply resources

3) Provide event notification/information to industry groups (i.e., INPO, ANI)

M. Services Admin/Commissary The Services Admin / Commissary reports to the Services Manager. Key responsibilities include:

1) Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list

2) Manage assigned group emergency response activities

3) Arrange for logistics support

4) Provide administrative support for facility operation

5) Distribute forms, reports, et al, as needed 2.4.5 Nuclear Public Information Group The JIC Organization Chart is show in Figure 2.4-5.

A. Company Spokesperson (MC/Near Site JIC/Corporate JIC)

The Company Spokesperson reports to the EOF Director. Key responsibilities include:

1) Coordinate information with government officials/agencies

2) Coordinate information to the Incident Support Team

3) Approve/review news releases, statements and messages

4) Perform media briefings and interviews

5) Correct rumors in media briefings and interviews

6) Provide input for facility briefs and updates B. Information Gathering Lead (Near-Site JIC)

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The Information Gathering Lead reports to the Corporate Communications Lead PIO (a corporate non-nuclear position not part of the site emergency plan). Key responsibilities include:

1) Manage assigned group emergency response activities

2) Coordinate distribution of news releases, statements and messages

3) Coordinate development of a communications strategy

4) Assist the Company Spokesperson in gathering information for media briefings and interviews

5) Coordinate the conduct of media briefings and interviews

6) Coordinate information flow between the station, corporate JIC and Federal, State &

local PIOs

7) Perform rumor control activities C. Media Monitor (Near Site JIC)

The Media Monitor reports to the Information Gathering Lead. Key responsibilities include:

1) Monitor media outlets for event related information

2) Coordinate monitoring activities with public information personnel

3) Perform rumor control activities

4) Monitor facility equipment (computer, communications, etc.) for proper operation D. JIC Technical Liaison (Near Site JIC)

The JIC Technical Liaison reports to the Information Gathering Lead. Key responsibilities include:

1) Communicate on assigned communication line and provide information to facility staff

2) Provide technical assistance for the development of news releases and statements

3) Provide support for the development of the chronology of events

4) Provide site event and response information for public information staff

5) Perform rumor control activities

6) Provide input for facility briefs and updates E. News Writer (EOF)

The News Writer reports to the Corporate Communications Lead PIO (a corporate non-nuclear position not part of the site emergency plan). Key responsibilities include:

1) Develop news releases, statements and messages

2) Coordinate distribution of news releases, statements and messages F. EOF Technical Liaison (EOF)

The EOF Technical Liaison reports to the Corporate Communications Lead PIO (a corporate non-nuclear position not part of the site emergency plan). Key responsibilities include:

1) Communicate on assigned communication line and provide information to facility staff

2) Provide technical assistance for the development of news releases and statements

3) Provide site event and response information for public information G. Media Center Coordinator (Media Center)

The Media Center Coordinator reports to the Logistics Lead. Key responsibilities include:

1) Arrange for equipment and supply resources

2) Arrange for logistics support

3) Coordinate distribution of news releases, statements and messages

4) Register personnel at the assigned location

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5) Coordinate accommodation of news media personnel

6) Monitor facility entrance areas

7) Prepare for facility activation (rooms, work area, equipment, etc.)

H. Site JIC Manager (Near Site JIC)

The Site JIC Manager reports to the Corporate Communications Lead PIO (a corporate non-nuclear position not part of the site emergency plan). Key responsibilities include:

1) Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list

2) Manage facility emergency response activities

3) Coordinate integration of the NRC site team

4) Ensure flow of information within and between the emergency response facilities

5) Coordinate information flow between the station, corporate JIC and Federal, State &

local PIOs

6) Prepare for facility activation (rooms, work area, equipment, etc.)

7) Ensure minimum staff is available (facility staffed)

8) Ensure facility staff is prepared to perform their activities (facility ready)

9) Activate the facility (facility activated)

10) Develop recovery plans

11) Conduct facility briefs and updates I. Logistics Lead (Near Site JIC)

The Logistics Lead reports to the Site JIC Manager. Key responsibilities include:

1) Coordinate ERO/facility shift turnover

2) Manage assigned group emergency response activities

3) Arrange for logistics support

4) Make staffing notifications

5) Coordinate JIC security and media badging

6) Prepare for facility activation (rooms, work area, equipment, etc.)

7) Determine current/projected staff needs

8) Provide administrative support for facility operation J. Admin Support (Near Site JIC)

The Admin Support position reports to the Logistics Lead. Key responsibilities include:

1) Coordinate distribution of news releases, statements and messages K. Government Liaison (Near Site JIC)

The Government Liaison reports to the Logistics Lead. Key responsibilities include:

1) Coordinate information and activities with offsite agency personnel in the facility

2) Coordinate information with government officials/agencies

3) Arrange for logistics support

4) Coordinate distribution of news releases, statements and messages

5) Coordinate information flow between the utility, corporate JIC and Federal, State and local PIOs L. Registration Liaison (Near Site JIC)

The Registration Liaison reports to the Logistics Lead. Key responsibilities include:

1) Register personnel at the assigned location

2) Monitor facility entrance areas

3) Prepare for facility activation (rooms, work area, equipment, etc.)

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4.5.2 Protective Action Recommendations (PARs)

A. Protective action guidelines for the plume pathway EPZ are based on NUREG-0654 Supplement 3, "Criteria for Protective Action Recommendations for Severe Accidents."

B. Plant conditions, projected dose and dose rates, and/or field monitoring data are evaluated to develop PARs for the purpose of preventing or minimizing exposure to the general public. PARs are made to the State and County agencies that are responsible for implementing protective actions for the general public wherever PAGs are exceeded. PARs are approved by the EOF Director. In an emergency which requires immediate protective actions be taken prior to activation of the emergency facilities, notification approval is given by the EC-MCR directly to the State and County agencies.

4.5.2.C. Possible recommendations issued by HNP at a General Emergency include, but are not limited to:

1) Evacuation of the general public within the two (2) mile radius and five (5) miles downwind.

2) Evacuation of the general public within the five (5) mile radius and ten (10) miles downwind. (This specific change was evaluated under EREG 2172381) , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change) No Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

Licensing Basis of the Structure, Positions and Responsibilities of Augmentation Personnel ERO:

HNP Emergency Plan revision 68 reflects the current NRC approved augmenting ERO and is used as the basis for the detailed comparison and evaluation provided in enclosures 1, 2, and 3.

The proposed changes included a review of the following HNP emergency plan licensing basis documents:

PLP-201, Harris Nuclear Plant Emergency Plan (Revision 3)

Harris Nuclear Plant Updated Final Safety Analysis Report

NRC approval of Emergency Plan changes in HNP amendment 160 dated August 21, 2017 This review concludes that changes described do not adversely affect the licensing basis of the emergency plan.

List Commitments Associated with the Change:

A search to identify site specific commitments related to the ERO positions and their assigned responsibilities was performed. No site specific commitments regarding any position or associated responsibility were identified.

Licensing Basis of the EOF for Harris Nuclear Plant was adjusted in HNP amendment 160 dated August 21, 2017. The adjustment of the response time requirements for augmented ERO was also approved in this same amendment. The proposed changes to the Emergency Plan PLP-201 revision 68 implement these adjusted licensing basis for the adjusted augmentation time limits and for the Duke fleet Common EOF in Charlotte NC.

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RG 1.219 Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Rev 1. (July 2016) 3.5 Emergency Plan

a. Emergency plan means the document(s) that the licensee prepared and maintains that identifies and describes its methods for maintaining emergency preparedness and responding to emergencies. An emergency plan includes the plan that the NRC originally approved and all subsequent changes that the licensee made with and without prior NRC review and approval under 10 CFR 50.54(q). See 10 CFR 50.54(q)(1)(ii) for additional information.

b. This definition highlights that emergency plan includes the documents that describes the programmatic methods that the licensee uses to maintain emergency preparedness and to respond to emergencies. These methods, or program elements, are the implementation aspects of the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 and generally correspond to the evaluation criteria of NUREG-0654 or approved alternatives that supply specific acceptable methods for complying with the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50. Such programmatic documents are subject to the 10 CFR 50.54(q) change process. Non-programmatic documents, such as training rosters, equipment and maintenance test reports, lesson plans, and other documents that document the performance of the program elements, as opposed to those that establish the program elements, are not included.

c. Ordinarily, sub-tier documents such as emergency plan implementing procedures (EPIPs) are not considered to be part of an emergency plan for the purpose of evaluating proposed changes. If a licensee relocates a programmatic description from the emergency plan to a sub-tier document, that programmatic description continues to be subject to the 10 CFR 50.54(q) change process. For example, licensees have relocated the details of emergency classification schemes from the emergency plan to an EPIP or to large wall charts maintained in the control room. Because the EPIP or wall chart is now the means to demonstrate compliance with the planning standards in 10 CFR 50.47(b)(4), these sub-tier documents are subject to 10 CFR 50.54(q). Repeating, as opposed to relocating, program element descriptions in sub-tier documents do not necessarily make the sub-tier documents subject to the 10 CFR 50.54(q) change process. However, the descriptions in the various documents must remain consistent.

d. As a simple test, a licensee can consider what programmatic document(s), in addition to its emergency plan, it would supply during an inspection to demonstrate that its emergency plan meets the regulatory requirements, as informed by the evaluation criteria in NUREG-0654 or by approved alternatives. These documents would likely be subject to the 10 CFR 50.54(q) change process.

e. This definition also highlights the need to consider the NRC-approved plan and the subsequent changes in reviewing against 10 CFR 50.54(q) to ensure that a series of incremental changes (each determined not to reduce the effectiveness of the plan) do not reduce the effectiveness of the plan when compared to the NRC-approved plan.

The listed changes to the HNP Emergency Plan have been reviewed and determined to meet the regulatory requirements and will adhere to the requirements as amended via HNP license amendment 160 dated August 21, 2017.

Given that the changes associated with the adoption of the Common EOF and response times have already been approved by the NRC in HNP license amendment 160; the balance of this effectiveness evaluation will be limited to the non-editorial changes to the Emergency Plan associated with the changes to ERO position titles, responsibilities, and actions.

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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 number of ERO responders for facility and response time changes resulting from the adoption of the standard ERO establish a closer relationship between risk significant / key functions and the positions assigned those functions. The objective of the changes is to ensure that those functions and their processes are linked directly to the augmented minimum staffing positions to allow for optimum relief of on shift personnel and less complicated response execution following facility activation.

Refer to enclosures 2 and 3 for a detailed review of the differences between the current HNP augmenting ERO and the standard augmenting ERO, and the evaluation of those changes from the organizational hierarchy, position and response, and task-by-task levels.

The adoption of the standard augmenting ERO into the HNP emergency plan implementing procedures: (1) provides a response organization defined by specific structure and responsibilities, which is consistent with regulations and industry guidance, and (2) maintains an efficient augmentation capability for both minimum staffing and full staffing positions.

The adoption of the standard augmenting ERO into the HNP emergency plan implementing procedures does not alter the licensing basis and continues to meet the regulatory requirements of 10CFR50.47(b)(1), (b)(2), (b)(7), and 10CFR50 Appendix E, Section IV.A. This change does not alter, add or remove previous site specific commitments with regards to the augmenting ERO.

The adoption of a fleet standard recovery organization and plan into the HNP emergency plan implementing procedures provides a flexible recovery organization based on the complexity of the event or recovery plan. This new recovery organization and plan is based on the current recovery organization and plan in place at HNP which has been evaluated in numerous drills and exercises. The adoption of a fleet standard recovery organization into the HNP emergency plan implementing procedures does not alter the licensing basis and continues to meet the regulatory requirements of 10CFR50.47(b)(13). This change does not alter, add or remove previous site specific commitments with regards to the recovery organization and plan.

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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 following portion of planning standard §50.47(b)(1) is associated with the proposed changes:

Primary responsibilities for emergency response by the nuclear facility licensee have been assigned, and each principal response organization has staff to augment its initial response on a continuous basis.

The functions for §50.47(b)(1) related to this change are:

a. Responsibility for emergency response is assigned.

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

The following portions of §50 Appendix E,Section IV.A are associated with the proposed changes:

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.

4. Identification, by position and function to be performed, of persons within the licensee organization who will be responsible for making offsite dose projections, and a description of how these projections will be made and the results transmitted to State and local authorities, NRC, and other appropriate governmental entities.

5. Identification, by position and function to be performed, of other employees of the licensee with special qualifications for coping with emergency conditions that may arise. Other persons with special qualifications, such as consultants, who are not employees of the licensee and who may be called upon for assistance for emergencies shall also be identified. The special qualifications of these persons shall be described.

6. A description of the local offsite services to be provided in support of the licensee's emergency organization.

The NUREG-0654 Part II.A elements for §50.47(b)(1) related to this change are:

1.d. Each organization shall identify a specific individual by title who shall be in charge of the emergency response.

4. Each principal organization shall be capable of continuous (24-hour) operations for a protracted period. The individual in the principal organization who will be responsible for assuring continuity of resources (technical, administrative, and material) shall be specified by title.

The following portion of planning standard §50.47(b)(2) is associated with the proposed changes:

, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

The function for §50.47(b)(2) related to this change is:

b. Process for timely augmentation of on shift staff is established and maintained.

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The following portions of §50 Appendix E,Section IV.A are associated with the proposed changes:

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:

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.

4. Identification, by position and function to be performed, of persons within the licensee organization who will be responsible for making offsite dose projections, The NUREG-0654 Part II.B elements for §50.47(b)(2) related to this change are:

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.

5. Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1.

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)

The following portion of planning standard §50.47(b)(7) is related to the change in adopting the standard augmenting ERO:

Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dissemination of information during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of information to the public are established.

The function for §50.47(b)(7) related to this change are:

b. Coordinated dissemination of public information during emergencies is established.

The NUREG-0654 Part II.G elements for §50.47(b)(5) related to this change are:

4.a Each principal organization shall designate a spokesperson who should have access to all necessary information.

The following portion of planning standard §50.47(b)(13) is associated with the change in adopting the standard recovery organization and plan:

General plans for recovery and reentry are developed.

The function for §50.47(b)(13) related to this change are:

a. Plans for recovery and reentry are developed.

There are no applicable portions of §50 Appendix E, associated with the proposed changes

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The NUREG-0654 Part II.M elements for §50.47(b)(13) related to this change are:

M.1 Each organization, as appropriate, shall develop general plans and procedures for reentry and recovery and describe the means by which decisions to relax protective measures (e.g., allow reentry into an evacuated area) are reached. This process should consider both existing and potential conditions.

M.2 Each licensee plan shall contain the position/title, authority and responsibilities of individuals who will fill key positions in the facility recovery organization. This organization shall include technical personnel with responsibilities to develop, evaluate and direct recovery and reentry operations.

M.3 Each licensee and State plan shall specify means for informing members of the response organizations that a recovery operation is to be initiated, and of any changes in the organizational structure that may occur.

M.4 Each plan shall establish a method for periodically estimating total population exposure.

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

1. Capability Assessment All emergency response related functions and tasks performed by the current HNP augmenting ERO have been dispositioned against the standard ERO positions as documented in enclosures 2 and 3. Changes to ERO task assignments categorized as deviations were evaluated and determined not to degrade the capability to perform their particular function.

Additionally, all ERO tasks for each position have been formally defined, indexed to their corresponding planning standard, and listed in the body of the emergency plan. These tasks can now be readily adopted into the ERO systematic approach to training (SAT) based qualification process and easily associated with the drill and exercise evaluation performance objectives and demonstration criteria. Thus, the capability to determine performance vs.

process issues and feedback to training of task level items is significantly improved.

2. Timeliness Assessment The standard augmenting ERO, with minor modification, is based on the current augmenting ERO in place at CNS, MNS and ONS which has been evaluated in numerous drills and exercises. There are no changes to the on-shift ERO as part of the standard augmenting ERO initiative.

The aspect of timeliness with regard to the ability of any position to perform their assigned responsibilities was further evaluated by a review of the impact of any new tasks assigned to a position by a process similar to that used in the on-shift staffing study task analysis (it was assumed there was no timeliness impact for positions that were not assigned new tasks or were only assigned new tasks which were determined to be undocumented and were actually performed by the position. New tasks are categorized as deviations). The aspects of overburden and overlap were considered in the determination of whether there was a potential adverse impact on timeliness to any assigned task. No position was identified with task overburden or overlap with regard to the addition of any responsibilities.

To adopt the standard ERO, the HNP ERO number of 75 minute response positions was increased in the Notification and Communications functional area (State/County) and reduced in the area of middle level ERF supervisors primarily in the Plant System Engineering, Repair, and Corrective Actions functional area. Accident Analysis engineers and repair and corrective action craft personnel minimum staffing requirements were not altered, which maintains the ability to perform those functions in a timely manner.

Adoption of the standard augmenting ERO will allow HNP to utilize the common EOF that is staffed by personnel in the corporate office. This will provide a significant pool of personnel, from senior management to craft level, previously assigned to the EOF which are now available for response positions in the HNP TSC or OSC. This will provide the opportunity to improve augmentation of the 75 minute minimum staffing positions for the site ERO.

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The adoption of the standard ERO made changes to the functional procedures for Field Monitoring, Classification, Protective Action Recommendations (PARs), and Notification.

Classification - The EAL scheme, based on NEI 99-01 rev. 6, is not changing. Therefore, this is not a Reduction in Effectiveness (RIE)

PARs - PARs are still based on NUREG-0654 Supplement 3. Current PAR flow charts were moved to new Fleet PAR procedures so this is not a RIE.

Notification - The ENF is not changing and HNP is still using WebEOC and DEMNET to transmit the information so this is not a RIE.

Field Monitoring - HNP will still have the capability, radiological equipment, and communication methods.

The coordination of team activities will continue to be performed from the EOF, only from a different location with capable communications, and back-up systems available. Therefore this is not a RIE.

Proposed changes described under the 'Standard ERO Changes" are in conjunction with the common EOF LAR submittal, and a program initiative undertaken by Duke Energy to standardize the augmenting ERO positions, functions and responsibilities (tasks), and procedures across the fleet. The proposed changes do not affect the emergency planning functions associated with 10 CFR 50.47(b) described in Part IV of this evaluation.

Based on the above, the adoption of the standard augmenting ERO will continue to maintain or improve the capability and timeliness of the HNP augmenting ERO to respond to an event and effectively perform their assigned tasks.

The changes described provide additional assurance that the normal plant operating organization and ERO has the ability and capability to:

respond to an emergency;

perform functions in a timely manner;

effectively identify and take measures to ensure protection of the public health and safety; and

effectively use response equipment and emergency response procedures These changes support the Harris Nuclear Plant Emergency Plan, PLP-201 by ensuring that procedures used during response to a classified emergency are available. Effective use of these procedures helps ensure emergency response capabilities described in the Harris Nuclear Plant Emergency Plan are adequately maintained and demonstrated.

The changes described do not reduce the effectiveness of the Harris Nuclear Plant Emergency Plan, as written and approved; and continue to meet NRC requirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.

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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 No 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes No reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes No 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.

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 Yes No rejected?

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:__________________________________________________.

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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). If CFAM approval is NOT required, then mark the CFAM signature block as not applicable (N/A) to indicate that signature is not required.

Preparer Name (Print): Preparer Signature: Date:

Jamey Sharlow signed electronically in CAS 01/04/18 Reviewer Name (Print): Reviewer Signature: Date:

David Stih signed electronically in CAS 01/04/18 Approver (EP Manager) Name (Print): Approver Signature: Date:

Gregg Simmons signed electronically in CAS 01/04/18 Approver (CFAM, as required) Name (Print): Approver Signature: Date:

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

If required by Section 5.6, Submitting Reports of Changes to the NRC, 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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Screening and Evaluation Number Applicable Sites BNP EREG #:____2172381_______________ CNS CR3 HNP MNS 5AD #:_____2163338________________ ONS RNP GO Document and Revision PEP-110, rev 28 Emergency Classification and Protective Action Recommendations Part I. Description of Proposed Change:

This screening and evaluation will review specific changes not covered by EREG 2163340. EREG 2163340 was performed prior to the latest changes identified in this description of changes. The changes identified here will be incorporated in revision 28 of PEP-110 Emergency Classification and Protective Action Recommendations. Both EREGS (2172381 and 2163340) will screen and evaluate all changes identified and will be cross referenced together to maintain the total revision screen and evaluation.

The description of activities that is being reviewed by this screening and evaluation are:

Section 3.3.3.a changed from:

For Rapidly Progressing Severe Accident (RPSA)

Evacuate 2 mile radius and 10 miles downwind

Shelter remaining subzones to For Rapidly Progressing Severe Accident (RPSA)

Evacuate 2 mile radius and 10 miles downwind Section 3.3.3.c changed from:

If no RPSA, HAB, OR known offsite impediment is present:

Evacuate 2 mile radius and 5 miles downwind

Shelter remaining subzones to If no RPSA, HAB, OR known offsite impediment is present:

Evacuate 2 mile radius and 5 miles downwind

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Section 3.3.4.b changed from:

If no RPSA, HAB, known offsite impediment, OR short term release is present AND General Emergency conditions still exist:

Evacuate 2 mile radius and 5 miles downwind

Shelter remaining subzones to If no RPSA, HAB, known offsite impediment, OR short term release is present AND General Emergency conditions still exist:

Evacuate 2 mile radius and 5 miles downwind Section 4.2.2 changed from:

Evacuation of a 2 mile radius and 10 miles downwind (with sheltering of all other Subzones) will be recommended for plant conditions which meet the following Rapidly Progressing Severe Accident (RPSA) criteria:

to Evacuation of a 2 mile radius and 10 miles downwind will be recommended for plant conditions which meet the following Rapidly Progressing Severe Accident (RPSA) criteria:

Section 4.3.3.a changed from:

IF General Emergency conditions still exist, THEN evacuate a two mile radius and five miles downwind. Shelter the remaining subzones.

to IF General Emergency conditions still exist, THEN evacuate a two mile radius and five miles downwind. - Protective Action Recommendation Process (Sheet 1 of 3)

Changed block wording from:

Table 1

Evacuate 2 mile radius and 10 miles downwind

Shelter remaining subzones to

Evacuate 2 mile radius and 10 miles downwind Table 3

Evacuate 2 mile radius and 5 miles downwind

Shelter remaining subzones to

Evacuate 2 mile radius and 5 miles downwind

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Changed block wording from:

Table 3

Evacuate 2 mile radius and 5 miles downwind

Shelter remaining zones to

Evacuate 2 mile radius and 5 miles downwind - Protective Action Recommendation Process (Sheet 3 of 3)

Changed Table 1 from:

Table 1 Rapidly Progressing Severe Accident (RPSA) 2 Mile Radius and 10 Miles Downwind Wind Direction (From °) Evacuate Subzones Shelter Subzones 011°-034° A, H, I, J, K B, C, D, E, F, G, L, M, N 035°-056° A, I, J, K, M B, C, D, E, F, G, H, L, N 057°-079° A, I, J, K, L, M B, C, D, E, F, G, H, N 080°-101° A, J, K, L, M B, C, D, E, F, G, H, I, N 102°-124° A, J, K, L, M, N B, C, D, E, F, G, H, I 125°-146° A, B, L, M, N C, D, E, F, G, H, I, J, K 147°-191° A, B, E, L, M, N C, D, F, G, H, I, J, K 192°-214° A, B, E, N C, D, F, G, H, I, J, K, L, M 215°-236° A, B, C, E, F D, G, H, I, J, K, L, M, N 237°-259° A, B, C, E, F, G D, H, I, J, K, L, M, N 260°-281° A, B, C, D, F, G, H E, I, J, K, L, M, N 282°-304° A, C, D, F, G, H B, E, I, J, K, L, M, N 305°-326° A, C, D, F, G, H, K B, E, I, J, L, M, N 327°-347° A, D, G, H, I, K B, C, E, F, J, L, M, N 348°-010° A, D, H, I, K B, C, E, F, G, J, L, M, N to Table 1 Rapidly Progressing Severe Accident (RPSA) 2 Mile Radius and 10 Miles Downwind Wind Direction (From °) Evacuate Subzones 011°-034° A, H, I, J, K 035°-056° A, I, J, K, M 057°-079° A, I, J, K, L, M 080°-101° A, J, K, L, M 102°-124° A, J, K, L, M, N 125°-146° A, B, L, M, N 147°-191° A, B, E, L, M, N 192°-214° A, B, E, N 215°-236° A, B, C, E, F 237°-259° A, B, C, E, F, G 260°-281° A, B, C, D, F, G, H 282°-304° A, C, D, F, G, H 305°-326° A, C, D, F, G, H, K 327°-347° A, D, G, H, I, K 348°-010° A, D, H, I, K

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Changed Table 2 from:

Table 2 Shelter - 2 Mile Radius and 5 Miles Downwind Wind Direction (From °) Shelter Subzones No Action Subzones 327° - 010° A,D,K B,C,E,F,G,H,I,J,L,M,N 011° - 056° A,K B,C,D,E,F,G,H,I,J,L,M,N 057° - 124° A,K,L B,C,D,E,F,G,H,I,J,M,N 125° - 191° A,B,L C,D,E,F,G,H,I,J,K,M,N 192° - 214° A,B C,D,E,F,G,H,I,J,K,L,M,N 215° - 259° A,B,C D,E,F,G,H,I,J,K,L,M,N 260° - 281° A,C B,D,E,F,G,H,I,J,K,L,M,N 282° - 304° A,C,D B,E,F,G,H,I,J,K,L,M,N 305° - 326° A,D B,C,E,F,G,H,I,J,K,L,M,N To Table 2 Shelter - 2 Mile Radius and 5 Miles Downwind Wind Direction Shelter Subzones (From °)

327° - 010° A,D,K 011° - 056° A,K 057° - 124° A,K,L 125° - 191° A,B,L 192° - 214° A,B 215° - 259° A,B,C 260° - 281° A,C 282° - 304° A,C,D 305° - 326° A,D Changed Table 3 from:

Table 3 Shelter - 2 Mile Radius and 5 Miles Downwind Wind Direction (From °) Evacuate Subzones Shelter Subzones 327° - 010° A,D,K B,C,E,F,G,H,I,J,L,M,N 011° - 056° A,K B,C,D,E,F,G,H,I,J,L,M,N 057° - 124° A,K,L B,C,D,E,F,G,H,I,J,M,N 125° - 191° A,B,L C,D,E,F,G,H,I,J,K,M,N 192° - 214° A,B C,D,E,F,G,H,I,J,K,L,M,N 215° - 259° A,B,C D,E,F,G,H,I,J,K,L,M,N 260° - 281° A,C B,D,E,F,G,H,I,J,K,L,M,N 282° - 304° A,C,D B,E,F,G,H,I,J,K,L,M,N 305° - 326° A,D B,C,E,F,G,H,I,J,K,L,M,N

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To Table 3 Shelter - 2 Mile Radius and 5 Miles Downwind Wind Direction (From °) Evacuate Subzones 327° - 010° A,D,K 011° - 056° A,K 057° - 124° A,K,L 125° - 191° A,B,L 192° - 214° A,B 215° - 259° A,B,C 260° - 281° A,C 282° - 304° A,C,D 305° - 326° A,D , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change) No Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

NUREG 1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear power Plant Units 1 and 2 13.3.2.10 Protective Response Standard A range of protective actions have been developed for the plume exposure pathway emergency planning zone for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway emergency planning zone appropriate to the locale have been developed.

Evaluation The plan establishes the means and times to alert and notify onsite personnel of an emergency, and identifies the assembly areas adjacent to each of the gate houses. Personnel will be monitored for contamination at the assembly area.

If it is necessary to evacuate further, evacuation routes and means of transportation are identified. Holding areas for additional decontamination will be identified if necessary. Supervisors will account for all persons evacuated from within the protected area at the assembly area and report missing persons to appropriate supervision within 30 minutes. Security search procedures will be implemented to locate missing persons. The plan provides individual respiratory protection, protective clothing, and physician-supervised radio-protective drugs for the emergency workers. The applicant will provide the state and local governments with appropriate information necessary to make a decision concerning public protective measures. The applicant will also provide an independent recommendation for protective actions for the population at risk based on the Protective Action Guides provided in Table 4.5-l for plume exposure and Table 4.5-2 for ingestion EPZ. The information in these tables is consistent with EPA 520/l-75-001 and the FDA guidelines on contamination of human food and animal feed.

The plan provides for prompt notification of state and local authorities upon declaration of an emergency. Alerting, warning, and notifying the population at-risk will be accomplished by sirens and supplemented by radio and television announcements, sound trucks, bullhorns, and knocking on doors. Aircraft and patrol boats will alert people on Lake Jordan and the Shearon Harris main reservoir. Public warning will be accomplished per the NCERP when the state and local governments deem it appropriate.

The plan includes a map showing local emergency planning zones, population by zones, and evacuation routes,

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but does not show radiological sampling or monitoring points, or relocation and shelter areas.

PLP-201 Emergency Plan , Rev. 3 4.5 Protective Actions for the Public 4.5.1 Protective Action Guides

a. For incidents involving actual or imminent releases of radioactive material to the atmosphere, protective action recommendations will be based upon core and containment conditions as indicated Figure 4.5-1or based upon the protective action guidelines indicated in Table 4. 5-1.

b. For incidents involving contamination of food, water, or milk, protective action recommendations will be consistent with the guidance of the U. S. Food and Drug Administration (FDA) published in the Federal Register, Vol. 43, No. 242, December 15, 1978. The FDA guidance is summarized in Table 4.5-2.

4.5.2 CP&L Recommendations to Local Authorities The decision to implement protective actions for the off-site population at risk is the responsibility of the State and local governments. Detailed procedures for public protective actions are contained in the North Carolina Emergency Response Plan in Support of the SHNPP.

The decision to evacuate or remain (in shelter) will be based on an evaluation of many factors including the imminence and duration of the passing plume, the protection afforded by dwellings, public fallout shelters, and other structures that might provide protection from surface deposited radio nuclides and from a gamma cloud source in the 10-mile EPZ.

The local housing consists primarily. of wood framed dwellings, one and two stories, that are over ten years old*.

Very few houses have basements. There are a number of brick or brick veneer dwellings of later construction and several parks of house trailers. The representative protection factors for surface deposited radionuclides and for a gamma cloud source are, respectively, for wood frame houses with no basements (2.5 and 1.1) and for masonry houses with no basement (5 and 1.7).

Carolina Power and Light Company will provide the State and local governments with recommendations for protective actions for the public based on the guidance contained in Figure 4.5-1, in which recommendations are based upon the plant conditions, or on projected offsite doses in relation to the protective action guides contained in Table 4.5-l.

PLP-201 Emergency Plan, Rev 67 4.5.2 Protective Action Recommendations (PARs)

A. Protective action guidelines for the plume pathway EPZ are based on NUREG 0654 Supplement 3, "Criteria for Protective Action Recommendations for Severe Accidents."

B. Plant conditions, projected dose and dose rates, and/or field monitoring data are evaluated to develop PARs for the purpose of preventing or minimizing exposure to the general public. PARs are made to the State and County agencies that are responsible for implementing protective actions for the general public wherever PAGs are exceeded. PARs are approved by the Emergency Response Manager. In an emergency which requires immediate protective actions be taken prior to activation of the emergency facilities, notification approval is given by the SEC-CR directly to the State and County agencies.

C. Possible recommendations issued by HNP at a General Emergency include, but are not limited to:

1) Evacuation of the general public within the two (2) mile radius and five (5) miles downwind. All other areas within the EPZ are sheltered (minimum PAR issued).

2) Evacuation of the general public within the five (5) mile radius and ten (10) miles downwind. All other areas within the EPZ are sheltered.

3) Consideration of the use of KI (potassium iodide).

4.5.3 Ingestion Pathway Protective Measures HNP is required to issue PARs wherever PAGs are exceeded, but the State is responsible for specifying long term protective measures to be used throughout the ingestion pathway. These measures include the methods for protecting the public from exposure due to deposited radioactive materials and the consumption of contaminated water and foodstuffs.

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RG 1.219 Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Rev 1. (July 2016) 3.5 Emergency Plan

a. Emergency plan means the document(s) that the licensee prepared and maintains that identifies and describes its methods for maintaining emergency preparedness and responding to emergencies. An emergency plan includes the plan that the NRC originally approved and all subsequent changes that the licensee made with and without prior NRC review and approval under 10 CFR 50.54(q). See 10 CFR 50.54(q)(1)(ii) for additional information.

b. This definition highlights that emergency plan includes the documents that describes the programmatic methods that the licensee uses to maintain emergency preparedness and to respond to emergencies. These methods, or program elements, are the implementation aspects of the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 and generally correspond to the evaluation criteria of NUREG-0654 or approved alternatives that supply specific acceptable methods for complying with the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50. Such programmatic documents are subject to the 10 CFR 50.54(q) change process. Non-programmatic documents, such as training rosters, equipment and maintenance test reports, lesson plans, and other documents that document the performance of the program elements, as opposed to those that establish the program elements, are not included.

c. Ordinarily, sub-tier documents such as emergency plan implementing procedures (EPIPs) are not considered to be part of an emergency plan for the purpose of evaluating proposed changes. If a licensee relocates a programmatic description from the emergency plan to a sub-tier document, that programmatic description continues to be subject to the 10 CFR 50.54(q) change process. For example, licensees have relocated the details of emergency classification schemes from the emergency plan to an EPIP or to large wall charts maintained in the control room. Because the EPIP or wall chart is now the means to demonstrate compliance with the planning standards in 10 CFR 50.47(b)(4), these sub-tier documents are subject to 10 CFR 50.54(q). Repeating, as opposed to relocating, program element descriptions in sub-tier documents do not necessarily make the sub-tier documents subject to the 10 CFR 50.54(q) change process. However, the descriptions in the various documents must remain consistent.

d. As a simple test, a licensee can consider what programmatic document(s), in addition to its emergency plan, it would supply during an inspection to demonstrate that its emergency plan meets the regulatory requirements, as informed by the evaluation criteria in NUREG-0654 or by approved alternatives. These documents would likely be subject to the 10 CFR 50.54(q) change process.

e. This definition also highlights the need to consider the NRC-approved plan and the subsequent changes in reviewing against 10 CFR 50.54(q) to ensure that a series of incremental changes (each determined not to reduce the effectiveness of the plan) do not reduce the effectiveness of the plan when compared to the NRC-approved plan.

The differences in implementing revisions and the current revisions of the Emergency Plans have been reviewed and they have been determined to meet the regulatory requirements required during the course of revisions. Each revision has been evaluated in the regulatory process has met the approval of the NRC during the inspection process.

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The adoption of the standard augmenting ERO will continue to maintain or improve the capability and timeliness of the HNP augmenting ERO to respond to an event and effectively perform their assigned tasks. HNP continues to maintain the capability to provide protective action recommendations to the offsite agencies and allow them to develop Protective Action Guidelines in a timely manner using the recommendation. Removing the "Shelter Subzones" from the process continues to maintain the functions while streamlining the process for the offsite agencies. The offsite agencies will still be able to recommend "sheltering" to the public, if they deem it necessary based on the severity of the accident. This will be accomplished though the Protective Action Guideline process.

The removal of the "shelter subzones" was agreed to by the state and counties during a task force meeting held 12/12/2017.

These changes do not reduce the effectiveness of the emergency plan or reduce the capability to meet the licensing bases as described in:

NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2

PLP-201, Emergency Plan, Revision 3

PLP-201, Emergency Plan, Revision 67 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):

10 CFR 50.47(b)(10), Emergency Protective Actions A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI), as appropriate. Evacuation time estimates have been developed by applicants and licensees. Licensees shall update the evacuation time estimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.

10 CFR Part 50, Appendix E does not contain any supporting requirements.

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Evaluation HNP will continue to have adequate methods for assessing the actual or potential offsite consequences of a radiological emergency condition and protect the public as the accident progresses. The changes described maintains compliance with the applicable sections of 10CFR50.47(b).

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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):

10 CFR 50.47(b)(10), Emergency Protective Actions A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI), as appropriate. Evacuation time estimates have been developed by applicants and licensees. Licensees shall update the evacuation time estimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.

Function A range of public PARs is available for implementation during emergencies.

Element NUREG 0654 II.J.7 Each licensee shall establish a mechanism for recommending protective actions to the appropriate State and local authorities. These shall include Emergency Action Levels corresponding to projected dose to the population-at-risk, in accordance with Appendix 1 and with the recommendations set forth in Tables 2.1 and 2.2 of the Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA-520/1-75-001). As specified in Appendix 1, prompt notification shall be made directly to the offsite authorities responsible for implementing protective measures within the plume exposure pathway Emergency Planning Zone.

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

The adoption of the standard augmenting ERO will continue to maintain or improve the capability and timeliness of the HNP augmenting ERO to respond to an event and effectively perform their assigned tasks. HNP continues to maintain the capability to provide protective action recommendations to the offsite agencies and allow them to develop Protective Action Guidelines in a timely manner using the recommendation. Removing the "Shelter Subzones" from the process continues to maintain the functions while streamlining the process for the offsite agencies. The offsite agencies will still be able to recommend "sheltering" to the public, if they deem it necessary based on the severity of the accident. This will be accomplished though the Protective Action Guideline process.

The removal of the "shelter subzones" was agreed to by the state and counties during a task force meeting held 12/12/2017.

The changes described do not affect the emergency planning functions listed in Part IV associated with 10 CFR 50.47(b) because the changes ensure adequate personnel, as well as emergency facilities and equipment to support the emergency response are provided and maintained to protect the emergency worker and the general public. The changes do not affect supporting requirements described in 10 CFR 50, Appendix E.IV. The changes continue to ensure that adequate provisions shall be made and described for emergency facilities and equipment and the changes continue to ensure the organization for coping with radiological emergencies is described.

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The changes described provide additional assurance that the normal plant operating organization and ERO has the ability and capability to:

respond to an emergency;

perform functions in a timely manner;

effectively identify and take measures to ensure the protection of the public

effectively use response equipment and emergency response procedures to evaluate conditions and protect the public.

These changes support the HNP Emergency Plan, by ensuring that procedures used during response to a classified emergency are available. Effective use of these procedures helps ensure emergency response functions as described in the Emergency Plan are adequately maintained and demonstrated. Some functions identified in this procedure were relocated to applicable fleet procedures to standardize ERO task and functions across the Duke Energy Fleet. This procedure will continue to be used by the HNP Main Control Room to analyze and provide protective Action Recommendations to the Site and the general pubic.

The changes described maintain the functions as described in the HNP Emergency Plan, as written and approved; and continue to meet NRC requirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.

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 No 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes No reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes No 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.

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 Yes No rejected?

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:__________________________________________________.

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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). If CFAM approval is NOT required, then mark the CFAM signature block as not applicable (N/A) to indicate that signature is not required.

Preparer Name (Print): Preparer Signature: Date:

Jeffery White signed electronically in CAS 01/03/18 Reviewer Name (Print): Reviewer Signature: Date:

Jamey Sharlow signed electronically in CAS 01/03/18 Approver (EP Manager) Name (Print): Approver Signature: Date:

Greg Simmons signed electronically in CAS 01/03/18 Approver (CFAM, as required) Name (Print): Approver Signature: Date:

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

If required by Section 5.6, Submitting Reports of Changes to the NRC, 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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Screening and Evaluation Number Applicable Sites BNP EREG #:___2163280__________________ CNS CR3 HNP MNS 5AD #:______2163278_____________ ONS RNP GO Document and Revision PEP-310 rev 39 Notifications and Communications Part I. Description of Proposed Change:

Deleted attachment 13, INPO/ANI/Global Risk Management Notification Form and updated references to attachments throughout the body of the procedure. (responsibility moved to AD-EP-ALL-0103, Attachment 12 step 2.2.1.c) Renumbered attachments.

Step 4.3.2 changed from:

Any qualified ERO Communicator shall make an accelerated call to the NRC using Attachment 16.

to Any qualified ERO member shall make an accelerated call to the NRC using Attachment 15.

Step 4.6.1 NOTE changed from:

A qualified Emergency Communicator-NRC (EC-NRC) or SRO must be available to continuously communicate with the NRC via the Emergency Telecommunications System (ETS) or commercial telephone line within one hour of the initial event declaration.

to A qualified NRC Communicator or SRO must be available to continuously communicate with the NRC via the Emergency Telecommunications System (ETS) or commercial telephone line within one hour of the initial event declaration.

Step 4.9.1 (New step 4.8.1) changed from:

WHEN the EOF is activated, THEN the Admin and Logistics Manager (ALM) shall AUGMENT the existing MCR Staff with the following additional personnel, while continuing with this procedure:

to AUGMENT the existing MCR Staff with the following additional personnel, while continuing with this procedure:

Step 4.9.3 (New step 4.8.3) changed from:

TSC and EOF administrative personnel should post information as follows:

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to TSC and EOF personnel should post information as follows:

Step 4.9.4 (New step 4.8.4) changed from:

TSC-EP-NET Operator and EOF-EP-NET Operator will:

to TSC and EOF OAC Support will: Request for Offsite Support step 5 changed from Notify EP Duty Specialist of the following information to Notify EP Duty Manager (contact information located on the Site Duty Roster) of the following information 1 page 1 changed from:

Communicating the Emergency Notification Form (ENF) to the Off-Site Agencies NOTE:

For non-functioning Telecomm systems, refer to EPL-001, Emergency Phone List, for alternate means of contacting State and Counties.

NOTE:

Notify the Enterprise Help Desk (PICASSO) to report a telecomm problem.

NOTE:

State/County notifications are usually performed by the MCR-Emergency Communicator or EOF-State/County Emergency Communicator To access the WebEOC Emergency Notification Form (ENF)

1. If already logged in to WebEOC, go to the "Emergency Notification Messages" panel and Click "view" in the appropriate EN Form column.

a. The "Emergency Notification Fax Management" panel will open with the "Government Agencies Notified" auto-populated

b. Go to step 3

2. If not logged in to WebEOC, then Log on to computer using your ID and password

a. Access Duke Application Environment (DAE) on the desktop:

b. Select Shortcuts tab

c. Type WebEOC in search box, then Enter

d. Click WebEOC

e. Click Run Application

f. In the Position: field, using the pull-down menu, select your ERO position.

g. Click OK, the WebEOC Control Panel will open.

h. On the Control Panel under the Boards header, select EN Form the Emergency Notification Messages panel will open.

i. Click "view" in the appropriate EN Form column.

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to Communicating the Emergency Notification Form (ENF) to the Off-Site Agencies NOTE:

For non-functioning Telecomm systems, refer to EPL-001, Emergency Phone List, and CSD-EP-ALL-0104-01, Fleet Emergency Telephone Directory, for alternate means of contacting State and Counties.

NOTE:

Notify the Enterprise Help Desk (PICASSO) to report a telecomm problem.

NOTE:

State/County notifications are usually performed by the Emergency Communicator or Offsite Communicator.

To access the WebEOC Emergency Notification Form (ENF)

1. IF already logged in to WebEOC, THEN GO TO the "Emergency Notification Messages" panel and CLICK "view" in the appropriate EN Form column.

a. The "Emergency Notification Fax Management" panel will open with the "Government Agencies Notified" auto-populated.

b. GO TO step 3.

2. IF not logged in to WebEOC, THEN LOG ON to computer using your ID and password.

a. ACCESS Duke Application Environment (DAE) on the desktop.

b. SELECT Shortcuts tab.

c. TYPE WebEOC in search box and THEN PRESS Enter.

d. CLICK WebEOC .

e. CLICK Run Application.

f. In the Position: field, using the pull-down menu, SELECT your ERO position.

g. CLICK OK, the WebEOC Control Panel will open.

h. On the Control Panel under the Boards header, SELECT EN Form; the Emergency Notification Messages panel will open.

i. CLICK View in the appropriate EN Form column. 1 page 2 changed from:

Contacting State and Counties NOTE:

The State and County Authentication Code Words are located in the EC-MCRs position notebook, in the Key locker at the Auxiliary Control Panel (ACP) and in the Emergency Response Facility (EOF) Supply Cabinet. An automated version is also contained in WebEOC.

NOTE:

Notification to off site agencies shall be completed within 15 minutes of an emergency declaration or event termination. If this time will be challenged, it is permissible to contact the State and Counties on the phone and take roll call after an emergency has been declared, but prior to receiving the emergency message.

3. If requested by the State, provide the authentication code word.

4. Prior to making the notification call, review the ENF.

a. Go to Step 7 and annotate (1) the classification of emergency, (2) has been declared for initial notification (3) remains in effect for follow up notification.

(4) Protective Action Recommendations

b. Go to step 11 and annotate the message number.

5. Using DEMNET, use the "HNP Notify" button on the DEMNET display. This initiates a group call to the Warning

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Points and EOCs.

6. Wait for the initial response and say, This is the Harris Nuclear Plant, stand by for an emergency message.

7. After the responses cease, say, This is the Harris Nuclear Plant, An Unus ua l E ve nt ha s be e n de cla re d/ re m a ins in e ffe ct An Ale rt ha s be e n de cla re d/re m a ins in e ffe ct A S ite Are a Em e rge nc y ha s be e n declared/remains in effect A G e ne ra l Em e rge nc y ha s be e n de cla re d/re m a ins in e ffe ct; P rote ctive Action re com m e nda tions a re evacuate subzones and shelter subzones _______________

Em e rge nc y E ve nt ha s be e n te rm ina te d

8. Record the current time and date (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months clock). ___________________________ (This is ENF Notification time) to Contacting State and Counties NOTE:

The State and County Authentication Code Words are located in Emergency Communicator's position notebook, in the Key locker at the Auxiliary Control Panel (ACP) and in the Emergency Response Facility (EOF) Supply Cabinet.

An automated version is also contained in WebEOC.

NOTE:

Notification to off site agencies shall be completed within 15 minutes of an emergency declaration or event termination. If this time will be challenged, it is permissible to contact the State and Counties on the phone and take roll call after an emergency has been declared, but prior to receiving the emergency message.

3. Prior to making the notification call, REVIEW the ENF.

a. GO TO Step 9 and ANNOTATE the following:

(1) The classification of emergency (2) has been declared for initial notification (3) remains in effect for follow up notification.

(4) Protective Action Recommendations

b. GO TO Step 11 and ANNOTATE the message number.

NOTE:

Steps 4 through 10 are completed in quick succession.

4. Using DEMNET, USE the "HNP Notify" button on the DEMNET display.

5. WHEN the first agency answers/comes on the line, RECORD the current time and date (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months clock).

6. MARK which agencies you have on the phone as they join the line.

S ta te W a ke County Cha tha m County Ha rne tt C ounty Le e County

7. IF one or more organizations did not join the line, THEN CONTINUE with the notification process.

8. WHEN agencies join the line, PERFORM the following:

a. PRESS and HOLD the push to talk (PTT) button in the receiver.

b. SAY This is the Harris Nuclear Plant; stand by for an emergency message.

c. RELEASE PTT button when not speaking.

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9. Determine which agencies you have on the phone by taking roll call.

S ta te W a ke County Cha tha m County Ha rne tt C ounty Le e County

10. If one or more organizations did not respond to roll call, then continue with the notification process.

11. Determine which agencies have received the WebEOC Emergency Notification Form. Say, Emergency Notification Message Number was sent using WebEOC. Please confirm a legible copy has been received by answering to roll call.

S ta te W a ke County Cha tha m County Ha rne tt C ounty Le e County

a. IF anyone has not yet received their fax or WebEOC copy, THEN WAIT to allow the agency to retrieve the fax.

b. IF any agency responds that they are having difficulty reading the ENF or still has not received a fax, THEN REQUEST that agency to remain on the line at the end of the notification.

(1) Refer to Step 15 to read the ENF to the agency remaining on the phone.

c. If requested by the State, supply an authentication code word.

(1) RECORD Authentication number provided by State: ______________

(2) If using WebEOC for Authentication, then ENTER the Authentication number in the AUTHENTICATION field on the "Emergency Notification Fax Management" panel (a) CLICK on the "Get Authentication Code" button; the corresponding authentication code words will automatically appear (b) RESPOND to the State with the authentication code words (3) If using the State and County Authentication Code Words List, RESPOND to the State with the corresponding word from the list of authentication code words to

9. After the responses cease, SAY This is the Harris Nuclear Plant, An Unus ua l E ve nt ha s be e n de cla re d/ re m a ins in e ffe ct An Ale rt ha s be e n de cla re d/re m a ins in e ffe ct A S ite Are a Em e rge nc y ha s be e n de c la re d/re m a ins in e ffe ct A G e ne ra l Em e rge nc y ha s be e n de cla re d/re m a ins in e ffe ct; P rote ctive Action re com m e nda tions a re evacuate subzones and shelter subzones _______________

Em e rge nc y E ve nt ha s be e n te rm ina te d."

10. IF all agencies have joined the line, THEN RECORD the current time and date (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months clock).

_____________________________________________________ (This is the official ENF Notification time.)

11. DETERMINE which agencies have received the WebEOC Emergency Notification Form. SAY Emergency Notification Message Number was sent using WebEOC. Please confirm a legible copy has been received by answering to roll call and state your name.

S ta te

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W a ke County Cha tha m County Ha rne tt C ounty Le e County

a. IF anyone has not yet received their fax or WebEOC copy, THEN WAIT to allow the agency to retrieve the fax.

b. IF any agency responds that they are having difficulty reading the ENF or still has not received a fax, THEN REQUEST that agency to remain on the line at the end of the notification.

c. IF requested by the State, THEN SUPPLY an authentication code word.

(1) RECORD Authentication number provided by State: ______________

(2) If using WebEOC for Authentication, THEN ENTER the Authentication number in the AUTHENTICATION field on the "Emergency Notification Fax Management" panel (a) CLICK on the "Get Authentication Code" button; the corresponding authentication code words will automatically appear (b) RESPOND to the State with the authentication code words.

(3) IF using the State and County Authentication Code Words List, THEN RESPOND to the State with the corresponding word from the list of authentication code words. 1 page 4 changed from:

12. Say Are there any questions?

a. If necessary, correct any errors or clarify misunderstood information.

13. Perform the roll call as appropriate. Say "Respond to roll call with your name."

S ta te W a ke County Cha tha m County Ha rne tt C ounty Le e County

14. When completed, say, "This is the end of the emergency notification. You may leave the network. This is the Harris Nuclear Plant, out."

15. If any agency previously responded that they are having difficulty reading the ENF or still have not received a fax, then perform the following:

a. Read the entire form beginning at Line 1 to the responding locations as follows:

(1) Identify each line by number before communicating the content.

(2) Spell difficult words.

b. Say "Are there any questions?"

(1) If necessary, correct any errors or clarify misunderstood information.

c. Say "Copies of this notification will be sent by fax."

16. If a fax needs to be sent to any agency/location, then notify Communications Manager.

17. If one or more organizations did not respond to roll call, then contact missing agency(ies) using DEMNET or commercial phones.

a. Inquire if ENF fax was received.

b. If fax was not received, then resend fax or provide information manually.

18. Enter the Notification Time and date recorded in step 8 into the WebEOC Notification Time and Date field on the "Emergency Notification Fax Management" panel.

to

12. SAY Are there any questions?

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a. If identified, CORRECT any errors or CLARIFY misunderstood information.

13. WHEN completed, SAY "This is the end of the emergency notification. You may leave the network. This is the Harris Nuclear Plant, out."

14. IF one or more organizations did not respond to roll call, THEN PERFORM the following:

a. CONTACT missing agency(ies) using DEMNET or commercial phones.

Agency Phone Alternate Phone NC State Warning Point 800-858-0368 828-466-5501 Chatham County Warning Point 919-542-2911 919-545-8162 Harnett County Warning Point 910-893-9111 910-893-0630 Lee County Warning Point 919-775-5531 919-775-8268 Wake County Warning Point 919-856-6911 919-856-7033

b. RECORD current date and time. ______________________________ (This is the official ENF Notification time.)

15. IF any agency previously responded that they are having difficulty reading the ENF OR still have not received a fax, THEN PERFORM the following:

a. READ the entire form, beginning at Line 1, to the responding locations as follows:

(1) IDENTIFY each line by number before communicating the content.

(2) SPELL difficult words.

b. SAY "Are there any questions?"

(1) If identified, CORRECT any errors or CLARIFY misunderstood information.

c. SAY "Copies of this notification will be sent by fax."

d. WHEN completed, SAY "This is the end of the emergency notification. You may leave the network. This is the Harris Nuclear Plant, out."

e. FAX copies of ENF to agencies that did not receive initial fax. 1 page 5 changed from:

19. Enter the first and last names of the roll call into the WebEOC Government Agencies Notified "Received By" column on the "Emergency Notification Fax Management" panel.

a. Click on the Date/Time button to auto-populate the Date/Time field.

20. Click Save.

21. In Off-Site Communications module of WebEOC, add entry (initial or follow-up) of notification.

22. If performed from the EOF, then on the Communications Room board, add entry (initial or follow-up) of notification.

to

16. WHEN all agencies have responded AND have received the ENF, THEN PERFORM the following:

a. In WebEOC, CLICK EN Form.

b. SELECT Notification Management for the Current Message.

c. CLICK View.

d. SCROLL to the bottom of the screen to Government Agencies Notified.

e. TYPE in the first and last names recorded in Step 11 for each agency.

(1) CLICK on the Date/Time button to auto-populate the Date/Time field.

(2) CLICK Update.

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f. SCROLL to the top of the screen and CLICK Save. 2 - Instructions for State/County Notification Manual Method 2 page 1 changed from:

Communicating the Emergency Notification Form (ENF) to the Off-Site Agencies Contacting State and Counties NOTE:

For non-functioning Telecomm systems refer to EPL-001, Emergency Phone List, for alternate means of contacting State and Counties.

NOTE:

Notify the Enterprise Help Desk (PICASSO) to report a telecomm problem.

NOTE:

The State and County Authentication Code Words are located in the EC-MCRs position notebook, in the Key locker at the Auxiliary Control Panel (ACP) and in the Emergency Response Facility (EOF) Supply Cabinet. An automated version is also contained in WebEOC.

1. If requested by the State, provide the authentication code word.

2. Prior to making the notification call, review the ENF.

a. Go to Step 5 and annotate (1) the classification of emergency (2) has been declared for initial notification (3) remains in effect for follow up notification (4) Protective Action Recommendations

3. Using DEMNET, use the "HNP Notify" button on the DEMNET display. This initiates a group call to the Warning Points and EOCs.

4. Wait for the initial response and say: "This is the Harris Nuclear Plant, stand by for an emergency message.

5. After the responses cease, say, This is the Harris Nuclear Plant, An Unus ua l E ve nt ha s be e n de cla re d/ re m a ins in e ffe ct An Ale rt ha s be e n de cla re d/re m a ins in e ffe ct A S ite Are a Em e rge nc y ha s be e n de c la re d/re m a ins in e ffe ct A General Emergency has been declared/remains in effect; Protective Action recommendations are evacuate subzones and shelter subzones _______________

Em e rge nc y e ve nt ha s be e n te rm ina te d

6. Record the current time and date (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months clock) on line 2 of the ENF.

to Communicating the Emergency Notification Form (ENF) to the Off-Site Agencies Contacting State and Counties NOTE:

For non-functioning Telecomm systems refer to EPL-001, Emergency Phone List, and CSD-EP-ALL-0104-01, Fleet Emergency Telephone Directory, for alternate means of contacting State and Counties.

NOTE:

The State and County Authentication Code Words are located in the Emergency Communicator's position notebook, in the Key locker at the Auxiliary Control Panel (ACP) and in the Emergency Response Facility (EOF)

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Supply Cabinet. An automated version is also contained in WebEOC.

1. If requested by the State, THEN PROVIDE the authentication code word.

a. RECORD Authentication number provided by State: _________________.

b. IF using the State and County Authentication Code Words List, THEN RESPOND to the State with the corresponding word from the list of authentication code words.

2. Prior to making the notification call, REVIEW the ENF.

a. GO TO Step 8 and ANNOTATE the following:

(1) the classification of emergency (2) has been declared for initial notification (3) remains in effect for follow up notification (4) Protective Action Recommendations

b. GO TO Step 11 and ANNOTATE the message number.

c. GO TO Step 13 and ANNOTATE the Protective Action Recommendations.

NOTE:

Steps 3 through 9 are completed in quick succession.

3. Using DEMNET, USE the "HNP Notify" button on the DEMNET display.

4. WHEN the first agency answers/comes on the line, RECORD the current time and date (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months clock).

5. MARK which agencies you have on the phone as they join the line.

S ta te W a ke County Cha tha m County Ha rne tt C ounty Le e County

6. IF one or more organizations did not join the line, THEN CONTINUE with the notification process. 2 page 2 changed from:

7. Determine which agencies you have on the phone by taking roll call.

S ta te W a ke County Cha tha m County Ha rne tt C ounty Le e County

8. If one or more organizations did not respond to roll call, then continue with the notification process.

9. Say, "This is the Harris Nuclear Plant, Please record the following information on an Emergency Notification Form." (Pause to allow the locations to retrieve a form).

10. Say Line 1, Emergency Notification message number ____________________

11. Say, Line 4, (classification)

An Unus ua l E ve nt ha s be e n de cla re d/ re m a ins in e ffe ct An Ale rt ha s be e n de cla re d/re m a ins in e ffe ct A S ite Are a Em e rge nc y ha s be e n de c la re d/re m a ins in e ffe ct A G e ne ra l Em e rge nc y ha s be e n de cla re d/re m a ins in e ffe ct

12. Say Line 5, Protective Action recommendations are evacuate subzones and shelter the subzone which this recommendation applies

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13. Read the entire form beginning at line 1 to the responding locations as follows:

a. Identify each line by number before communicating the content.

b. Spell difficult words.

c. Complete reading the remainder of the form (from line 3).

d. Print and enter your name on line 17 of the form for "Notified By:"

to

7. WHEN agencies join the line, THEN PERFORM the following:

a. PRESS and HOLD the push to talk (PTT) button in the receiver.

b. SAY This is the Harris Nuclear Plant; stand by for an emergency message.

c. RELEASE PTT button when not speaking.

8. After the responses cease, SAY This is the Harris Nuclear Plant, An Unus ua l E ve nt ha s be e n de cla re d/ re m a ins in e ffe ct An Ale rt ha s be e n de cla re d/re m a ins in e ffe ct A S ite Are a Em e rge nc y ha s be e n de c la re d/re m a ins in e ffe ct A G e ne ra l Em e rge nc y ha s be e n declared/remains in effect; Protective Action recommendations are evacuate subzones _____________ and shelter subzones _______________

Em e rge nc y E ve nt ha s be e n te rm ina te d."

9. IF all agencies have joined the line, THEN RECORD the current time and date (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months clock).

_____________________________________________________ (This is the official ENF Notification time.)

10. SAY "This is the Harris Nuclear Plant, Please record the following information on an Emergency Notification Form." (PAUSE to allow the locations to retrieve a form.)

11. SAY Emergency Notification Message Number ____________________________

12. SAY "Line 3, (Emergency Classification)."

An Unus ua l E ve nt ha s be e n de cla re d/ re m a ins in e ffe ct An Ale rt ha s be e n de cla re d/re m a ins in e ffe ct A S ite Are a Em e rge nc y ha s be e n de c la re d/re m a ins in e ffe ct A G e ne ra l Em e rge nc y ha s be e n de cla re d/re m a ins in e ffe ct

13. SAY "Line 6, Protective Action recommendations are evacuate subzones _____________ and shelter subzones _______________."

14. READ the entire form beginning at line 1 to the responding locations as follows:

a. IDENTIFY each line by number before communicating the content.

b. SPELL difficult words.

c. COMPLETE reading the remainder of the form (from line 3).

d. PRINT and ENTER your name on line 17 of the form for "Notified By:" 2 page 3 changed from:

14. Say, Are there any questions?

a. If necessary, correct any errors or clarify misunderstood information.

15. Say, Copies of this notification will be sent to you via Fax.

16. Say, "Respond to roll call with your name.

a. Call roll and record the information below. Identify the applicable location for each agency.

S ta te W a ke County Cha tha m County Ha rne tt County

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Le e County

17. End the call by saying, This is the end of the emergency notification. You may leave the network. Harris Nuclear Plant out.

18. If performed from the MCR, fax the Emergency Notification Form to the WPs, EOCs, TSC and EOF using the button labeled DEL.

19. If performed from the TSC or EOF, fax a copy of the ENF to the applicable WPs and/or EOCs utilizing the applicable rapid dial buttons.

20. If one or more organizations did not respond to roll call, then contact missing agency(ies) using DEMNET or commercial phones.

a. Inquire if ENF fax was received.

b. If fax was not received, then resend fax or provide information manually.

21. In Off-Site Communications module of WebEOC, add entry (initial or follow-up) of notification.

22. If performed from the EOF, then on the Communications Room board, add entry (initial or follow-up) of notification.

to

15. SAY Are there any questions?

a. IF identified, CORRECT any errors or CLARIFY misunderstood information.

16. SAY "Copies of this notification will be sent by fax."

17. SAY "Respond to roll call with your name.

a. CALL roll and RECORD the information below.

S ta te W a ke County Cha tha m County Ha rne tt C ounty Le e County

18. END the call by saying This is the end of the emergency notification. You may leave the network. Harris Nuclear Plant out.

19. IF performed from the MCR, THEN FAX the Emergency Notification Form to the WPs, EOCs, TSC, and EOF using the button labeled DEL.

20. IF performed from the TSC or EOF, THEN FAX a copy of the ENF to the applicable WPs or EOCs utilizing the applicable rapid dial buttons.

21. IF one or more organizations did not respond to roll call, THEN PERFORM the following:

a. CONTACT missing agency(ies) using DEMNET or commercial phones.

Agency Phone Alternate Phone NC State Warning Point 800-858-0368 828-466-5501 Chatham County Warning Point 919-542-2911 919-545-8162 Harnett County Warning Point 910-893-9111 910-893-0630 Lee County Warning Point 919-775-5531 919-775-8268 Wake County Warning Point 919-856-6911 919-856-7033

b. RECORD current date and time. ______________________________ (This is the official ENF Notification time.)

22. In Off-Site Communications module of WebEOC, ADD entry (initial or follow-up) of notification.

23. IF performed from the EOF, THEN ADD entry (initial or follow-up) of notification on the Communications Room board.

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<< 10 CFR 50.54(q) Effectiveness Evaluation Form >> , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change) No Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

(Planning Standard 2)

NUREG 1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant Units 1 and 2 (Applicable Excerpts)

Section 13.3.2.2 Onsite Emergency Organization Standard 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 responsive capabilities is available, and the interfaces among various onsite response activities and offsite support and response activities are specified.

Evaluation Station staff personnel have been assigned emergency positions with responsibilities and duties commensurate with their normal activities.

PLP-201 Emergency Plan, Rev. 3 2.0 ORGANIZATION AND RESPONSIBILITIES 2.1 General The plant emergency organization is composed of a broad spectrum of personnel with specialties in operations, maintenance, engineering, radiochemistry, health physics, material control, fire protection, security, and emergency planning. The greatest number of personnel with these specialties are available during day shift operations; however, specialists who are needed can be recalled to the site at any time.

The Company is committed to providing staffing to effectively contain any emergency which might occur at its nuclear facilities.

Depending on the emergency at hand, personnel with required expertise will be contacted on a priority basis as shown in Table 2.2-1. Minimum staffing requirements for activation of each facility are indicated in Figures 2.2-1 and 2.4-1. Additional personnel will be available to provide communications, on-site and off-site radiological assessment, repair and corrective actions, and technical support within a short period of time PLP-201 Emergency Plan, Rev 67 2.0 ORGANIZATION AND RESPONSIBILITIES 2.2 Emergency Organization (Excerpts only)

The plant Emergency Response Organization (ERO) is composed of a broad spectrum of personnel with specialties in operations, maintenance, engineering, radiochemistry, health physics, material control, fire protection, security, and emergency planning. The greatest numbers of personnel with these specialties are available during day shift operations; however, specialists who are needed can be recalled to the site at any time.

The Company is committed to providing staffing to effectively contain any emergency which might occur at its nuclear facilities.

Depending on the emergency at hand, personnel with required expertise will be contacted on a priority basis as shown in Table 2.2-1. Minimum staffing requirements for activation of each facility are indicated in Figures 2.2-1 and 2.4-1. Additional personnel will be available to provide communications, on-site and off-site radiological assessment, repair and corrective actions, and technical support within a short period of time

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(Planning Standard 5)

NUREG 1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear power Plant Units 1 and 2 13.3.2.5 Notification Methods and Procedures Standard Procedures have been established for notification by the licensee of state and local response organizations and for notification of emergency personnel by all response organizations; the content of initial and followup messages to response organizations and the public have been established and means to provide early notification and clear instructions to the populace within the plume exposure pathway emergency planning zone have been established.

Evaluation Immediately upon declaring an emergency, the SEC activates the emergency plan and initiates the procedures for notification of onsite emergency organization. The SEC also fills out the "Immediate Notification Form," contained in Annex F of the plan, and provides it to the Emergency Communicator. Using the Automatic Ring Down (ARD) phone, within 15 minutes, the Emergency Communicator will read the message simultaneously to all counties within the EPZ and the state warning point for all emergency classifications, except for the Unusual Event class for which the time is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

PLP-201 Emergency Plan , Rev. 3 4.2 Notification

b. The Emergency communicator will use the Automatic Ring Down (ARD) phone to simultaneously notify the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day, manned, State and County warning points with the notification message. This message will be read to all counties and the state within 15 minutes for all emergency classifications.

PLP-201 Emergency Plan, Rev 67 4.2 Notification A. The Emergency Communicator will use the electronic Emergency Notification Form (ENF) on WebEOC, hard copy ENF contained in PEP-310, or the Selective Signaling System phone to simultaneously notify the 24-hour-per-day, staffed, State Warning Point, State EOC and County Warning Points with the notification message. Emergency Operations Centers will be notified upon activation at the State and Counties in lieu of the Warning Points. This message will be initiated to all Counties and the State within 15 minutes for all emergency classifications.

RG 1.219 Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Rev 1. (July 2016) 3.5 Emergency Plan

a. Emergency plan means the document(s) that the licensee prepared and maintains that identifies and describes its methods for maintaining emergency preparedness and responding to emergencies. An emergency plan includes the plan that the NRC originally approved and all subsequent changes that the licensee made with and without prior NRC review and approval under 10 CFR 50.54(q). See 10 CFR 50.54(q)(1)(ii) for additional information.

b. This definition highlights that emergency plan includes the documents that describes the programmatic methods that the licensee uses to maintain emergency preparedness and to respond to emergencies. These methods, or program elements, are the implementation aspects of the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 and generally correspond to the evaluation criteria of NUREG-0654 or approved alternatives that supply specific acceptable methods for complying with the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50. Such programmatic documents are subject to the 10 CFR 50.54(q) change process. Non-programmatic documents,

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such as training rosters, equipment and maintenance test reports, lesson plans, and other documents that document the performance of the program elements, as opposed to those that establish the program elements, are not included.

c. Ordinarily, sub-tier documents such as emergency plan implementing procedures (EPIPs) are not considered to be part of an emergency plan for the purpose of evaluating proposed changes. If a licensee relocates a programmatic description from the emergency plan to a sub-tier document, that programmatic description continues to be subject to the 10 CFR 50.54(q) change process. For example, licensees have relocated the details of emergency classification schemes from the emergency plan to an EPIP or to large wall charts maintained in the control room. Because the EPIP or wall chart is now the means to demonstrate compliance with the planning standards in 10 CFR 50.47(b)(4), these sub-tier documents are subject to 10 CFR 50.54(q). Repeating, as opposed to relocating, program element descriptions in sub-tier documents do not necessarily make the sub-tier documents subject to the 10 CFR 50.54(q) change process. However, the descriptions in the various documents must remain consistent.

d. As a simple test, a licensee can consider what programmatic document(s), in addition to its emergency plan, it would supply during an inspection to demonstrate that its emergency plan meets the regulatory requirements, as informed by the evaluation criteria in NUREG-0654 or by approved alternatives. These documents would likely be subject to the 10 CFR 50.54(q) change process.

e. This definition also highlights the need to consider the NRC-approved plan and the subsequent changes in reviewing against 10 CFR 50.54(q) to ensure that a series of incremental changes (each determined not to reduce the effectiveness of the plan) do not reduce the effectiveness of the plan when compared to the NRC-approved plan.

The differences in implementing revisions and the current revisions of the Emergency Plans have been reviewed and they have been determined to meet the regulatory requirements required during the course of revisions. Each revision has been evaluated in the regulatory process has met the approval of the NRC during the inspection process.

The changes described in this procedure revision were made to reflect the changes for the EOF relocation to Charlotte and the changes made for Standard ERO. These changes do not reduce the effectiveness of the emergency plan or reduce the capability to meet the licensing bases as described in:

NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2

PLP-201, Emergency Plan, Revision 3

PLP-201, Emergency Plan, Revision 67

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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):

10 CFR50.47(b)(2), Onsite Emergency Organization 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.

10 CFR 50, Appendix E, Section IV. A. Organization (applicable excerpts only)

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:

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.

7. By June 23, 2014, identification of, and a description of the assistance expected from, appropriate State, local, and Federal agencies with responsibilities for coping with emergencies, including hostile action at the site. For purposes of this appendix, "hostile action" is defined as an act directed toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force.

10 CFR 50.47(b)(5)Emergency Notifications Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow-up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

10CFR50 Appendix E IV. Content of Emergency Plans D. Notification Procedures

3. A licensee shall have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency. The licensee shall demonstrate that the appropriate governmental authorities have the capability to make a public alerting and notification decision promptly on being informed by the licensee of an emergency condition.

The changes identified in this revision continue to comply with 10 CFR 50.47(b)(2)-Onsite Emergency Organization and 10 CFR 50.47(b)(5)Emergency Notifications and 10CFR50 Appendix E.IV - Content of Emergency Plans. HNP retains the capability required by regulation to notify the responsible State and local government agencies within 15 minutes of declaring an emergency.

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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):

Standard 10 CFR50.47(b) (2), Onsite Emergency Organization The regulation at 10 CFR 50.47(b)(2) states the following:

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.

Function The process for timely augmentation of on-shift staff is established and maintained.

10 CFR 50, Appendix E, Section IV. A. Organization (applicable excerpts only)

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:

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.

7. By June 23, 2014, identification of, and a description of the assistance expected from, appropriate State, local, and Federal agencies with responsibilities for coping with emergencies, including hostile action at the site. For purposes of this appendix, "hostile action" is defined as an act directed toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force.

Element NUREG-0654/FEMA-REP-1 Rev 1, II, B. Onsite Emergency Organization (applicable excerpts only)

5. Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site.

6. Each licensee shall specify the interfaces between and among the onsite functional areas of emergency activity, licensee headquarters support, local services support, and State and local government response organization.

Standard 10 CFR 50.47(b)(5), Emergency Notifications The regulation at 10 CFR 50.47(b)(5) states the following:

Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow-up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

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Function The emergency planning functions defined for this planning standard:

(1) Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications.

10CFR50 Appendix E IV. Content of Emergency Plans D. Notification Procedures

3. A licensee shall have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency. The licensee shall demonstrate that the appropriate governmental authorities have the capability to make a public alerting and notification decision promptly on being informed by the licensee of an emergency condition.

Elements NUREG-0654/FEMA-REP-1 Rev 1, II, E. Notification Methods and Procedures Criteria (applicable excerpts only )

Each organization shall establish procedures which describe mutually agreeable bases for notification of response organizations consistent with the emergency classification and action level scheme set forth in Appendix 1. These procedures shall include means for verification of messages. The specific details of verification need not be included in the plan.

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

The changes in this revision meet the NRC approved LAR RA-16-0002 for a Duke Common EOF and changes made for the standard ERO structure - position changes, position title changes, and moving functions from one position to another position in that standard ERO structure.

The changes identified in this revision continue to comply with NUREG 1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear power Plant Units 1 and 2 Section 13.3.2.5 Notification Methods and Procedures, PLP-201 Emergency Plan , Rev. 3 section 4.2 Notification, and PLP-201 Emergency Plan, Rev 67 section 4.2 Notification.

HNP retains the function required by regulation to notify the responsible State and local government agencies within 15 minutes of declaring an emergency. HNP also retains the ability to augment the on shift staff as directed by this procedure. These changes do not reduce the effectiveness of the emergency plan or reduce the function of the Emergency Plan notify the ERO and the Offsite Agencies of an emergency at HNP.

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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 No 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes No reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes No 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.

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 Yes No rejected?

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:__________________________________________________.

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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): Preparer Signature: Date:

Jeffery White signed electronically in CAS 11/28/17 Reviewer Name (Print): Reviewer Signature: Date:

David Stih signed electronically in CAS 11/29/17 Approver (EP Manager) Name (Print): Approver Signature: Date:

Jamey Sharlow signed electronically in CAS 11/29/17 Approver (CFAM, as required) Name (Print): Approver Signature: Date:

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

If required by Section 5.5, Submitting Reports of Changes to the NRC, 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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Screening and Evaluation Number Applicable Sites BNP EREG #:____2166201________ CNS CR3 HNP X MNS 5AD #:______2166200______ ONS RNP GO Document and Revision ERO Training Program EPM-200 REV 022 Part I. Description of Proposed Change:

EPM-200 ERO Training Program is being revised to reflect changes required for the transition to the common EOF and the Standard ERO.

In conjunction with the common EOF, an initiative was undertaken by Duke Energy to standardize the augmenting ERO positions, functions and responsibilities (tasks) across the fleet. This involves changes to the current Harris Nuclear Plant (HNP) augmenting ERO, based on the number of responder and their titles identified in the site emergency plan and implementing procedures. Included in the standard ERO initiative is the development of fleet standard ERO checklists, procedures and forms.

This initiative makes no changes to the on-shift ERO.

The table of contents was revised to reflect the changes made throughout the procedure.

Re-numbered steps throughout based on revision.

Throughout the procedure, titles were changed to reflect the new nomenclature.

Revised section 4.7 to removed a staff member's ERO requirements as part of their Performance Development Plan.

Revised section 4.9 to reflect maintaining five ERO teams versus four. Removed note referencing attachment 4, which is being deleted.

Revised section 5.3.1.b.removing the Plant Operations Director (POD). This position was changed to the Control Room Ops Bridge in the Standard ERO. The Ops Bridge responsibilities are now contained in AD-EP-ALL-0105 and in AD-EP-ALL-0500.

Removed section 5.3.2 for the Technical Support Center (TSC) personnel. The roles and responsibilities for the TSC are now contained in AD-EP-ALL-0105 and in AD-EP-ALL-0500.

Removed section 5.3.3 for the Operational Support Center (OSC) personnel. The roles and responsibilities for the OSC are now contained in AD-EP-ALL-0106 and in AD-EP-ALL-0500.

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Removed section 5.3.4 for the Emergency Operations Facility (EOF) personnel. The roles and responsibilities for the EOF are now contained in AD-EP-ALL-0103 and in AD-EP-ALL-0500.

Removed section 5.3.5 for the Joint Information Center (JIC) personnel. The roles and responsibilities for the JIC are now contained in AD-EP-ALL-0108 and in AD-EP-ALL-0500.

Revised section 5.4 removing Sections 5.4.1 to Section 5.4.2. AD-EP-ALL-0500 provides the new framework.

Removed attachments 1 to 4. Information in these Attachments is superseded by AD-EP-ALL-0500. , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change) No X Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

NUREG-1038 Safety Evaluation Report Related to the Operation of Shearon Harris Nuclear power Plant, Units 1 and 2, section 13.3.2.15 Radiological Emergency Response training.

Standard Radiological emergency response training is provided to those who may be called upon to assist in an emergency.

Evaluation The Emergency Plan Training Program, as described in Corporate Emergency Plan Implementation Procedures, CEPEP-19, ensures that the individuals who may be called on to assist in an emergency will be trained. Initial training and annual retraining are provided. Provisions have been made to train offsite response organizations, such as hospital ambulances and police and fire personnel, who may be called upon to provide assistance.

Training will include site-access procedures and the identity by position/title of the person in the Shearon Harris organization who will control the support activity.

The plan provides for specialized training for individuals assigned specific responsibilities in the emergency plan, such as Red Cross multi-media training for first aid team members.

The followings items require resolution:

(1) The plan should incorporate the information from CEPIP-19 in sufficient detail to allow evaluation of the plan.

(2) The Damage Control Teams, described in Section 2.4.4 of the Shearon Harris plan as part of the emergency organization, are not listed as receiving any training in the plan or in CEPIP-19. The specific training and retraining needs for this group should be detailed in the plan.

From NUREG 1038 Supplement 1:

The applicant's response to these issues is as follows:

(1) The applicant has provided details of the training to be provided to specific categories of emergency response personnel in the revised plan. The plan specifies that initial training and annual retraining will be provided. It also provides assistance with the training of offsite emergency response personnel according to the radiological emergency plan. and supplemental training as related to Shearon Harris. The Emergency Plan Training Program is-described in detail Procedure PEP-403 and in the Plant Emergency Plan Training Program Lesson Plans.

(2) The applicant has specifically addressed the training of Damage Control Team personnel in Section 5.2.3.7 of the revised plan

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On the basis of its evaluation of the applicant's response, the staff finds the applicants training program acceptable.

PLP-201, Emergency Plan, Rev 3 5.2. Emergency Plan Training Program 5.2.1 General Requirements The Emergency Plan Training Program, described in detail in the Emergency Plan Implementation Procedure PEP-403, assures training of individuals who may be called on to assist in an emergency. Initial training and annual retraining is provided. Responsibilities for implementing the training program are also contained in PEP-403.

5.2.2 Training Objectives The primary objectives of the training program are to:

a) Familiarize appropriate individuals with the Plan and the procedures that implement the Plan b) Instruct individuals and their alternates in their duties and responsibilities c) Periodically present significant changes in the scope or contents of the Plan or procedures which implement the Plan d) Provide annual refresher training to ensure that personnel are familiar with their duties and responsibilities assigned by the Plan and procedures which implement the Plan 5.2.3 Training Course Descriptions The Emergency Plan Training Program makes provisions for training the categories of personnel listed in the following paragraphs in order to perform the specific tasks within their assigned responsibilities in the Emergency Plan 5.2.3.1 General Employee Training Each individual authorized unescorted access to the Protected Area is provided with information concerning evacuation alarms and procedures used at the SHNPP in the event of an emergency and also receives initial orientation on the basic principles of radiological safety.

5.2.3.2 Site Emergency Coordinator Those personnel who may be assigned to perform the functions of the Site Emergency Coordinator will receive training in the following areas:

Emergency organization and responsibilities

Basic concepts of the emergency plans and procedures

Emergency facility location, layout, organization, and functions

Emergency communications systems and data displays

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Emergency classifications and emergency action levels

Protective actions for on-site personnel and the public

Interfaces with other emergency facilities and organizations

Personnel emergency exposure limits

Procedures for notification of plant personnel and outside agencies

Procedures for relief of position and turnover of off-site responsibilities to the Emergency Response Manager

Record keeping requirements 5.2.3.3 Senior Control Operators and Shift Technical Advisors The Senior Control Operators and Shift Technical Advisors receive training in the following areas:

Emergency operating procedures

Basic concepts of the emergency plans and procedures

Emergency facility location, layout, organization, and functions

Control Room communications systems and data displays

Emergency classifications and emergency action levels

Dose projection procedures and protective action recommendations for the public

Control Room interfaces with the TSC, EOF and other facilities/organizations

Emergency procedures during use of Auxiliary Control Panel

Emergency notification procedures

On-site alerting, warning, and evacuation procedures

Record keeping requirements 5.2.3.4 TSC Staff Personnel The Plant Operations Director, the Emergency Repair Director, the Logistics Support Director, the Radiological Control Director, and other staff and team leaders in the TSC receive training in the following areas:

Basic concepts of the emergency plans and procedures

Emergency facility location, layout, organization, and functions

TSC communications systems and data displays

Emergency classifications and emergency action levels

Protective actions for on-site personnel

TSC interfaces with other facilities and organizations

Record keeping requirements

Offsite protective action recommendations

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5.2.3.5 Emergency Communicator The Emergency Communicator training includes:

Use of emergency communications systems and equipment

Emergency notification procedures

Emergency organization

Emergency team rosters and call-in procedures

Outside agencies and notification procedures

Record keeping requirements 5.2.3.6 Radiological Emergency Teams The Dose Projection Teams, Environmental Monitoring Teams, Personnel Protection and Decontamination Teams and Plant Monitoring Teams receive instruction in the following areas in addition to the specific training required to perform their assigned function:

The functions performed by each radiological emergency team

The range of radiological condit1ons that may be encountered

Emergency classifications and emergency exposure limits

Emergency facility location, layout, and functions

Description, storage location, and application of emergency supplies

and equipment

Geographic familiarity of site. environs, and roads for use by

off-site teams

Communications systems and their use

Specific procedures relating to the team function

Record keeping requirements 5.2.3.7 Damage Control Team Personnel Damage Control Team Personnel receive training in the following areas in addition to general employee emergency plan training:

Emergency classifications and emergency exposure limits

Emergency facilities and their locations and functions

Site communications systems and their use

Description, storage location, and application of emergency supplies and equipment 5.2.3.8 Emergency Security Team The Emergency Security Team training includes:

Personnel accountability procedures

Site access and egress control procedures

Deployment of security personnel

Evacuation and perimeter control

On-site traffic control

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Applicable communication links and methods Training topics are selected in accordance with job assignments per the SHNPP Security Personnel Training &

Qualification Plan and Implementing Procedures supporting the SHNPP Security Plan.

5.2.3.9 Fire Brigade Fire Brigade training is in accordance with commitments contained in Section 9.5.1 of the FSAR. This training includes:

Use of fire suppression equipment

Personnel protection equipment

Fire fighting in radiation areas

Emergency worker exposure guides

Emergency facilities, their locations and functions

Site communications systems and their use

Access and egress control for offsite fire departments Offsite fire agreements 5.2.3.10 First Aid Team Personnel First Aid Team Personnel will receive training in the following areas in addition to general employee emergency plan training:

Red Cross Multi-media First Aid

Emergency classifications

Emergency facilities and their locations and functions

Site communications systems and their use

Description, storage location, and use of First Aid supplies and *

equipment

Procedures for First Aid and rescue

Procedures for transporting injured (contaminated or not) off-site 5.2.3.11 Accident Assessment Team Personnel Personnel on the Accident Assessment Team will receive training in the following areas:

Emergency action levels and emergency classifications

TSC Staff Personnel training items

Plant systems training courses 5.2.3.12 EOF Personnel The Emergency Response Manager, Technical Analysis Manager, Administrative and Logistics Manager, and Radiological Control Manager, and their staffs receive training in the following areas.

Basic concepts of the emergency plans and procedures

Emergency facility location, layout, organization, and functions

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EOF communications systems and data displays

Emergency Classifications

Protective actions for the public

EOF interfaces with other facilities and organizations

Record keeping requirements 5.2.3.13 CP&L Media Personnel Personnel who may fill positions in the Plant Media Center receive training in the following areas:

Emergency Plan concepts

Emergency classification

Notification procedures

Emergency facilities, functions, and interfaces

Media center job functions

Basics of nuclear power plants 5.2.3.14 Corporate Emergency Operating Center Personnel Corporate Emergency Operating Center personnel will receive training in the following areas:

Basic concepts of the emergency plans and procedures

Emergency facility location and functions

Emergency classifications

Communications systems 5.2.3.15 Off-Site Organization Training of off-site organizations is described in their respective radiological emergency plans. Additional training provided by CP&L for hospital, ambulance, rescue, police, and fire personnel is described in Plan Emergency Plan Training Program Lesson Plans and PEP-403. Such training will include the procedures for notification, basic radiation protection, and their expected roles. For those local services support organizations who may enter the site, training by CP&L will also include site access procedures and the identity {by position and title) of the individual in the SHNPP organization who will control the organization's support activities. Carolina Power & Light Company will assist these off-site organization's in performing their radiological emergency response training as related to SHNPP as requested.

Training of medical support personnel at the agreement hospitals will include basic training on the nature of radiological emergencies, diagnosis and treatment, and follow-up medical care.

PLP-201, Emergency Plan, Rev 67 5.2 Emergency Response Organization Training Program 5.2.1 General Requirements HNP ensures the training of appropriate company personnel to support the Harris Plant Emergency Plan. Initial training and annual retraining is provided for the following categories of personnel:

A. Directors, Coordinators, and Managers in the Emergency Response Organization.

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B. Personnel responsible for accident assessment.

C. Radiological monitoring teams and radiological analysis personnel D. Damage Control Teams E. First Aid Team (MERT), Search and Rescue, and Fire Brigade Teams F. Personnel responsible for transmission of emergency information and instruction G. Personnel responsible for communicating with the media and public H. Offsite medical support personnel I. Local support services personnel, including emergency management personnel J. Police, security and offsite fire-fighting personnel who may be required to assist at the plant Company personnel not assigned to the site are utilized and trained as members of the program.

Individuals assigned to First Aid Teams (MERT) will include courses equivalent to the Red Cross Multimedia First Aid Course.

Designated ERO positions are also required to be qualified in the use of appropriate respiratory equipment.

Plant Access Training is provided to all personnel before they have unrestricted access to the Protected Area. This training includes general knowledge of alarms and actions required for non-ERO member during a declared emergency.

Site specific emergency response training shall be offered to offsite emergency organizations and local support services individuals who may be called upon to provide assistance to HNP in the event of an emergency. Training will include site access procedures and the identity (by position and title) of the individual in the HNP ERO who will control their organizations' support activities. Training for hospital personnel, ambulance/rescue, police and fire departments shall also include the procedures for notification, basic radiation protection, and their expected roles.

5.2.2 Conduct of Training The Manager - Emergency Preparedness is responsible for the overall content and administration of the emergency plan training program.

EPM-200, ERO Training Program, will include knowledge based and/or performance based training and evaluation components.

A. Knowledge based training may be provided in a classroom setting or self directed study modules and document reviews. Examination and/or interviews will be given for initial qualifications to ensure trainee has a good base knowledge of the ERO and their assigned responsibilities.

B. Performance based training and evaluations will be conducted for most ERO members (exceptions are made for pool personnel whose normal job functions closely matches their emergency functions and they are directed by qualified ERO Managers or Coordinators, such as operations, E&RC, maintenance, administrative and security pool personnel). This is done during conduct of exercises, drills or walkthroughs and documented on ERO qualification record forms.

Review The differences in PLP-201, Revision 3, and PLP-201, Revision 67 have been determined to meet the regulatory requirements of the course of revisions. Each revision has been evaluated in the regulatory process has met the approval of the NRC during the inspection process.

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RG 1.219 Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Rev 1. (July 2016) 3.5 Emergency Plan

a. Emergency plan means the document(s) that the licensee prepared and maintains that identifies and describes its methods for maintaining emergency preparedness and responding to emergencies. An emergency plan includes the plan that the NRC originally approved and all subsequent changes that the licensee made with and without prior NRC review and approval under 10 CFR 50.54(q). See 10 CFR 50.54(q)(1)(ii) for additional information.

b. This definition highlights that emergency plan includes the documents that describes the programmatic methods that the licensee uses to maintain emergency preparedness and to respond to emergencies. These methods, or program elements, are the implementation aspects of the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 and generally correspond to the evaluation criteria of NUREG-0654 or approved alternatives that supply specific acceptable methods for complying with the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50. Such programmatic documents are subject to the 10 CFR 50.54(q) change process. Non-programmatic documents, such as training rosters, equipment and maintenance test reports, lesson plans, and other documents that document the performance of the program elements, as opposed to those that establish the program elements, are not included.

c. Ordinarily, sub-tier documents such as emergency plan implementing procedures (EPIPs) are not considered to be part of an emergency plan for the purpose of evaluating proposed changes. If a licensee relocates a programmatic description from the emergency plan to a sub-tier document, that programmatic description continues to be subject to the 10 CFR 50.54(q) change process. For example, licensees have relocated the details of emergency classification schemes from the emergency plan to an EPIP or to large wall charts maintained in the control room. Because the EPIP or wall chart is now the means to demonstrate compliance with the planning standards in 10 CFR 50.47(b)(4), these sub-tier documents are subject to 10 CFR 50.54(q). Repeating, as opposed to relocating, program element descriptions in sub-tier documents do not necessarily make the sub-tier documents subject to the 10 CFR 50.54(q) change process. However, the descriptions in the various documents must remain consistent.

d. As a simple test, a licensee can consider what programmatic document(s), in addition to its emergency plan, it would supply during an inspection to demonstrate that its emergency plan meets the regulatory requirements, as informed by the evaluation criteria in NUREG-0654 or by approved alternatives. These documents would likely be subject to the 10 CFR 50.54(q) change process.

e. This definition also highlights the need to consider the NRC-approved plan and the subsequent changes in reviewing against 10 CFR 50.54(q) to ensure that a series of incremental changes (each determined not to reduce the effectiveness of the plan) do not reduce the effectiveness of the plan when compared to the NRC-approved plan.

The differences in implementing revisions and the current revisions of the Emergency Plans have been reviewed and they have been determined to meet the regulatory requirements required during the course of revisions. Each revision has been evaluated in the regulatory process has met the approval of the NRC during the inspection process.

The changes being made to EPM-200 support the transition to a fleet common ERO and the common Emergency Operations Facility (EOF) in Charlotte, NC. New fleet procedures incorporate procedure content that is being removed from this procedure.

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These changes do not reduce the effectiveness of the emergency plan or reduce the capability to meet the applicable planning standards as described in:

NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2

PLP-201, Emergency Plan, Revision 3

PLP-201, Emergency Plan, Revision 67 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):

10 CFR 50.47(b)(15)

a. The regulation at 10 CFR 50.47(b)(15) states the following:

Radiological emergency response training is provided to those who may be called on to assist in an emergency.

10 CFR Part 50 Appendix E Section IV.F.1 F. Training

1. The program to provide for: (a) The training of employees and exercising, by periodic drills, of emergency plans to ensure that employees of the licensee are familiar with their specific emergency response duties, and (b) The participation in the training and drills by other persons whose assistance may be needed in the event of a radiological emergency shall be described. This shall include a description of specialized initial training and periodic retraining programs to be provided to each of the following categories of emergency personnel:

i. Directors and/or coordinators of the plant emergency organization; ii. Personnel responsible for accident assessment, including control room shift personnel; iii Radiological monitoring teams; iv. Fire control teams (fire brigades);

v. Repair and damage control teams; vi. First aid and rescue teams; vii. Medical support personnel;

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viii. Licensee's headquarters support personnel; ix. Security personnel.

The adoption of a fleet standard procedure for emergency response organization training at HNP ensures that radiological emergency response training is provided to those who may be called on to assist in an emergency, including periodic drill participation, to meet the requirements of 10CFR50.47(b)(15) and 10CFR50 Appendix E, Section IV.F.

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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):

Standard 10 CFR 50.47(b) (15)

Radiological emergency response training is provided to those who may be called on to assist in an emergency.

Function Regulatory Guide 1.219 describes the following planning function for this standard:

Training is provided to emergency responders.

Elements NUREG-0654 describes the following elements for this standard:

1. Each organization shall assure the training of appropriate individuals.

2. The training program for members of the onsite emergency organization shall, besides classroom training, include practical drills in which each individual demonstrates ability to perform his assigned emergency function.

During the practical drills, on-the-spot correction of erroneous performance shall be made and a demonstration of the proper performance offered by the instructor.

4. Each organization shall establish a training program for instructing and qualifying personnel who will implement radiological emergency response plans. The specialized initial training and periodic retraining programs (including the scope, nature and frequency) shall be provided in the following categories:

a. Directors or coordinators of the response organizations;

b. Personnel responsible for accident assessment;

c. Radiological monitoring teams and radiological analysis personnel;

d. Radiological monitoring teams and radiological analysis personnel;

e. Repair and damage control/correctional action teams (onsite);

f. First aid and rescue personnel;

g. Local support services personnel including Civil Defense/Emergency Service personnel;

h. Medical support personnel;

i. Licensee's headquarters support personnel

j. Personnel responsible for transmission of emergency information and instructions.

5. Each organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities.

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

Revised section 4.7 to removed a staff member's ERO requirements as part of their Performance Development Plan. Step 4.7.4.b was removed. The Performance Development Plan program is no longer governed at the site level. Performance objectives are generated at the Fleet level and are identical to all individuals within the company. This is a removal of an administrative step and does not affect the effectiveness of the emergency plan.

Revised section 4.9 to reflect maintaining five ERO teams versus four.

The number of individual ERO teams was increased to five to reflect the Fleet Standard ERO standard.

Revised section 5.3.1.b.removing the Plant Operations Director (POD) position.

This position was changed to the Control Room Operations Bridge in the Standard ERO as described in AD-EP-ALL-0500. Attachment 4.

Removed section 5.3.2 for the Technical Support Center (TSC) personnel.

The roles and responsibilities for the TSC are listed in AD-EP-ALL-0105 and in AD-EP-ALL-0500, Attachment 4.

Removed section 5.3.3 for the Operational Support Center (OSC) personnel.

The roles and responsibilities for the OSC are listed in AD-EP-ALL-0106 and in AD-EP-ALL-0500, Attachment 4.

Removed section 5.3.4 for the Emergency Operations Facility (EOF) personnel.

The roles and responsibilities for the EOF are listed in AD-EP-ALL-0103 and in AD-EP-ALL-0500. HNP will no longer be employing a near site Emergency Operations Facility. The Common EOF will be staffed to support HNP in the event of an emergency.

Removed section 5.3.5 for the Joint Information Center (JIC) personnel.

The roles and responsibilities for the JIC are listed in AD-EP-ALL-0108 and in AD-EP-ALL-0500.

Revised section 5.4 removing Sections 5.4.1 to Section 5.5.2.

This section listed the individual training modules needed for ERO training. AD-EP-ALL-0500 provides the new framework. The new Fleet procedure gives description on the individual training classes needed for each position in Attachment 4.

Removed attachments 1 to 4. Information is superseded by AD-EP-ALL-0500 or other Fleet level procedures.

Attachment 1 reflects a table of the HNP ERO qualification requirements. This is superseded by Fleet Procedure AD-EP-ALL-0500, Attachment 4.

Attachment 2 is used for student feedback. A standard student feedback form is in AD-TQ-ALL-0400 as Attachment 5.

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Attachment 3 gives information on identifying new ERO members and checklist to complete. This is now governed by AD-EP-ALL-0500 and the individual Position Specific Guides.

Attachment 4 lists the current HNP ERO positions. These are superseded by the new ERO positions as listed in AD-EP-ALL-0500, Attachment 4.

These changes are being made to ensure compliance with the implementation of Fleet Standard ERO and Common EOF. These changes do not reduce the effectiveness of the emergency plan or reduce the capability to meet the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E.

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 X No 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes X No reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes X No 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 X

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.

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 Yes No rejected?

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:__________________________________________________.

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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): Preparer Signature: Date:

David Stih signed electronically in CAS 1/2/18 Reviewer Name (Print): Reviewer Signature: Date:

Jamey Sharlow signed electronically in CAS 1/2/18 Approver (EP Manager) Name (Print): Approver Signature: Date:

Greg Simmons signed electronically in CAS 1/3/18 Approver (CFAM, as required) Name (Print): Approver Signature: Date:

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

If required by Section 5.5, Submitting Reports of Changes to the NRC, 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),

X 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. X QA RECORD

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Screening and Evaluation Number Applicable Sites BNP EREG #:___2166189_______ CNS CR3 HNP MNS 5AD #:_____2166186_______ ONS RNP GO Document and Revision Emergency Equipment Inventory EPM-420 Rev 18 Part I. Description of Proposed Change:

EPM-420 Emergency Equipment Inventory is being revised to reflect changes required for the transition to a common EOF.

Removed attachments for the EOF. The HNP local EOF is being replaced by a common fleet EOF.

The Joint Information Center (JIC) inventory checklist has also been revised to support the relocation of the JIC from a conference room at the Customer Service Center that required extensive setup when used to a dedicated area in the Regional Headquarters Building in Raleigh.

Added review signature lines to the attachments to require responsible organization management review.

Added remarks throughout the attachments to require validation that applicable equipment is operable and that expiration dates are not expired or will not expire during the quarter.

Removed controlled documents from the attachments. These documents are distributed and controlled by the controlled document process.

Removed the position specific books that are being replaced with fleet standard controlled documents.

Revised the attachments to reflect removal and addition of items required for the inventory.

Removed flashlights from on-site kits that had both flashlights and lanterns.

Removed clocks from the kits.

Removed batteries from the kits that are readily available throughout the site.

Removed table position name plates that are being replaced with signage for the common ERO positions.

Removed rad rope, duct tape and step off pads from the Main Control Room kit. These items are readily available throughout the site.

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Removed work coveralls and paper coveralls from the on-site kits. These items are readily available throughout the site.

Removed pens, markers and like items from on-site kits. These items are readily available throughout the site.

Replaced forms in the Field Monitoring and Boat Shed Kits with the new fleet procedure forms.

Revised the Joint Information Center (JIC) Kit to reflect the items needed for the JIC to perform kits Emergency Plan functions. The JIC is being relocated to a facility that will allow it to be always set up and in a ready status. , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change) No X Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

NUREG-1038 Safety Evaluation Report Related to the Operation of Shearon Harris Nuclear power Plant, Units 1 and 2 Section 13.3.2.8 Emergency Facility and Equipment Standard Adequate emergency facilities and equipment to support the emergency response provided and maintained.

Evaluation Emergency facilities to support an emergency response have been established as follows:

(1) The control room (CR) contains those controls, instruments, and communications facilities necessary for operation of the plant under both normal and emergency conditions. The ventilation system, shielding, and the structure's Integrity are designed to permit continuous occupancy during postulated accidents. Storage is provided for food and water sufficient for 7 days.

(2) The TSC is located within the plant protected area in the fuel-handling building, approximately 400 feet (walking distance) from the CR. Traffic between the TSC and CR is entirely within buildings that are equipped with HEPA and charcoal filters and are built to seismic Category I, tornado, and missile safety-related criteria, with radiation protection equivalent to the CR. The TSC will have all the necessary equipment and supplies when fully functional to operate as the command center for the SEC and his staff.

(3) The OSC is located in the service building inside the protected area and functions as an assembly and dispatch area for all emergency teams.

(4) The EOF is located in the Shearon Harris Emergency and Environmental Center (SHEEC), approximately 2 miles from the plant, with space for approximately 70 people including 10 NRC personnel. The EOF is designed to have the same habitability as the CR, and will be provided with industrial security to maintain readiness and to restrict access during an emergency. The EOF is activated by the ERM when it is adequately staffed to perform offsite notification, environmental monitoring, and dose protection functions. The EOF has emergency equipment and supplies to perform as the command center for the ERM with plant system drawings, three Emergency Response Facility Information System (ERFIS) consoles displaying plant data, the Safety Parameter Display System (SPOS), the Radiological Monitoring System (RMS), dose projections, all pertinent emergency plans, telecopies, photocopies, and maps.

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(5) The Plant Media Center is also located at the SHEEC. The Site Public Information Coordinator directs the activities of the center to provide (1) a controlled point of contact and physical location near the plant for the news media and (2) immediate access to accurate emergency information generated by all involved agencies.

(6) The Corporate Emergency Operation Center (CEOC) and the Corporate Headquarters Media Center are located at the Corporate Headquarters and Civic Center in Raleigh, approximately 16 miles northeast of the plant on Highway 1.

(7) The North Carolina State Emergency Operations Center (SEOC) is also located in Raleigh at the Division of Emergency Management Headquarters.

The emergency response facilities appear to be adequately staffed, and the response times designated for the various staffing levels agree with the guide-lines of Table B-l of NUREG-0654.

The ERFs were evaluated as interim facilities in accordance with applicable portions of 10 CFR 50 and NUREG-0654 and found to be adequate. The applicant stated in a letter dated April 15, 1983, in response to Generic Letter 82-33, that the final facilities will be completed before fuel load, and then will be evaluated in accordance with Supplement 1 to NUREG-0737.

The plan states that equipment and systems for seismic monitoring, radiation monitoring, meteorological instrumentation, fire detection, gross failed fuel, loose parts monitoring, and security systems will be installed. The plan further states that additional information can be found in noted sections of the FSAR. A summary of the FSAR information should be included in the Emergency Plan so the emergency plan can stand as an independent document.

The fixed and mobile laboratory facilities available for support of SHNPP are discussed in Section 13.3.2.3 above.

The applicant's radiological monitoring program meets the staff's requirements.

A permanent meteorological monitoring station containing wind speed, direction and temperature differential instrumentation is located on the site. Provisions have been made to acquire back-up meteorological data from the National Weather-Service at the Raleigh-Durham Airport, a first order station operating 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day. The staff has reviewed the meteorological program and finds that it satisfies the planning standard on an interim basis; it will be evaluated during the Emergency Preparedness Implementation Analysis.

The plan provides in the implementing procedures a resource list for the inventory and calibration of emergency equipment and supplies. The plan also specifies the frequency of inventory and calibration.

The following items require resolution:

(1) The plan does not indicate if arrangements have been made to obtain or have access to seismic and hydrologic data from offsite sources.

(2) The plan implies that the OSC has the capacity to handle assigned personnel and equipment but fails to address the subject. Table 3.1-1 does not indicate the availability of portable lighting or cameras in the OSC emergency supply kits.

(3) The plan does not discuss in any detail which emergency facility will be established as the central point for receipt and analysis of all radiological samples.

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PLP-201 Emergency Plan Revision 3 3.1 General The purpose of emergency response facilities is to provide centralized locations for organized command and control of on-site activities, and off-site activities performed by the Company such as environmental monitoring.

Each emergency response organization is provided with a location from where they may direct or perform the activities for which they are responsible while providing for coordination of activities with other organizations.

Adequate emergency facilities, communications, and equipment to support emergency response are provided and maintained. Carolina Power & Light Company (CP&l) Emergency Plans include provision for emergency response facilities as follows:

Control Room

Technical Support Center (TSC)

Operational Support Center (OSC)

Emergency Operations Facility (EOF)

Plant Media Center (PMC)

Corporate Emergency Operation~ Center (CEOC) 3.2 Control Room 3.2.3 Emergency Equipment and Supplies

a. Main Control Board

b. Emergency Response Facility Information System (ERFIS)

c. Safety Parameter Display System (SPDS) (Part of ERFIS)

d. Measurement and Indication of Regulatory Guide 1.97 (Rev. 2) variables (ERFIS)

e. Radiation Monitoring System (RMS)

f. Fire Detection System (adjacent room)

g. Seismic Monitoring Cabinet

h. Gross Failed Fuel Detector Console

i. Food and Water Storage for seven days

j. Basic medical supplies, kitchen and sanitary facilities

k. Reliable voice communications with the TSC, OSC, EOF, NRC Operations Centers and State and local government 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months warning points.

l. Respirators and anti-Cs

m. See Table 3.1-1 3.3 Technical Support Center (TSC)

3. 3. 3 Emergency Equipment and Supplies

a. Reliable voice communications with the Control Room, EOF, OSC, NRC Operations Center and State and local government 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months warning points as described in Section 3.8 which follows

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b. Four ERFIS consoles capable of displaying plant data, SPDS, RMS and dose projections as discussed in Section 3.9.1.

c. Mechanical systems, electrical systems drawings; Plant Operating Manual; FSAR; Corporate, plant, state & local emergency plans; photocopier, telecopier (also Document Control Library nearby)

d. Decontamination and monitoring area

e. Survey meter, area radiation monitor and constant air monitors f. Maps showing evacuation routes, evacuation areas, preselected radiological sampling and monitoring points, relocation centers in host areas, and shelter areas

g. Maps showing population distribution around the nuclear facility by evacuation areas (See Annex H)

h. See Table 3.1-1 3.4 Operational Support Center (OSC) 3.4.3 Emergency Equipment and Supplies

a. Reliable voice communications with the Control Room, EOF and TSC

b. Supplies and equipment as shown in Table 3.1-1 3.5 Emergency Operations Facility (EOF) 3.5.3 Emergency Equipment and Supplies

a. Reliable voice communications with the TSC, Control Room, OSC, NRC Operations Centers and State and local government 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months warning points as described in Section 3.8

b. Three ERFIS consoles capable of displaying plant data, SPDS, RMS and dose projections as discussed in Section 3.9.1

c. Mechanical Systems, Electrical Systems Drawings; Plant Operating Manual; FSAR; Corporate, Plant, State &

Local Emergency Plans; telecopier; photocopier

d. Decontamination and monitoring area

e. Survey meter, dosimeters and TLDs

f. Maps showing evacuation routes, evacuation areas. preselected radiological sampling and monitoring points, relocation centers in host areas, and shelter areas

g. Maps showing population distribution around the nuclear facility by evacuation areas

h. Additional equipment as discussed in Section 3.7.2.

i. See Table 3.1-1 3.6 Plant Media Center (PMC) 3.6.3 Emergency Equipment and Supplies

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a. Provided with additional telephone lines for media use

b. Provide equipment for document reproduction, telecopying, communications, and television electrical connections Table 3.1-1 Typical Emergency Supplies Available For Emergency Facilities Supplies Control Tech. Plant OSC EOF Room Support Media Center Center A supply of food and water adequate for 7 days Protective Clothing (Anti-Cs)

High and low range portable radiation survey instruments Air Sampling Equipment Emergency personnel monitoring equipment such as high and low range self-reading dosimeters and TLDs Area Maps Miscellaneous contamination control supplies such as signs, tags, rope, tape, various forms, etc First Aid Kit Portable Communications Equipment Radio Radio* Radio*

Remotes Remotes Remotes Full Face Respirators Environmental Monitoring Kit Self-contained breathing equipment Battery-Powered Lanterns Megaphone Polaroid Camera Decontamination Supplies Mechanical systems & electrical systems drawings, Plant Operation Manual, FSAR, Corporate, State &

Local Emergency Plans Copy of Plant Emergency Plan and Procedures (b) 10-mile EPZ Area maps (c)

Copy of Plant Emergency Plan and Procedures

Portable transceivers can be supplied to any emergency center

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PLP-201 Emergency Plan Revision 67 3.1 General The purpose of emergency response facilities is to provide centralized locations for organized command and control of on-site activities and off-site activities performed by the Company such as environmental monitoring.

Different groups within the Emergency Response Organization are provided with a location from where they may direct or perform the activities for which they are responsible while providing for coordination of activities with other organizations.

Adequate emergency facilities, communications, and equipment to support emergency response are provided and maintained. Duke Energy Emergency Plans include provision for emergency response facilities as follows:

Main Control Room (MCR)

Technical Support Center (TSC)

Operations Support Center (OSC)

Emergency Operations Facility (EOF)

Joint Information Center (JIC) 3.2 Main Control Room 3.2.3 Emergency Equipment and Supplies A. Main Control Board.

B. Emergency Response Facility Information System (ERFIS).

C. Safety Parameter Display System (SPDS is part of ERFIS).

D. Measurement and Indication of Regulatory Guide 1.97 (Rev. 2) variables (ERFIS).

E. Radiation Monitoring System (RMS).

F. Fire Detection System (adjacent room).

G. Seismic Monitoring Cabinet.

H. Gross Failed Fuel Detector Console.

I. Kitchen and sanitary facilities.

J. Reliable voice communications with the TSC, OSC, EOF, NRC Operations Centers, and State and local government 24-hour warning points and State EOC.

K. See Table 3.1-1.

3.3 Technical Support Center 3.3.3 Emergency Equipment and Supplies A. Reliable voice communications with the Main Control Room, EOF, OSC, NRC Operations Center and State and

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local government 24-hour warning points and State EOC as described in Section 3.8 which follows.

B. Video System capable of displaying ERFIS information (such as, plant data, SPDS, and RMS) as discussed in Section 3.9.1.

C. All reference materials, including Mechanical and Electrical Systems Drawings; Controlled Procedure Manual; FSAR; Corporate, Plant, State, and Local Emergency Plans, are available.

D. Decontamination and monitoring area.

E. Survey meter and area radiation monitor.

F. Photocopier equipment and reliable facsimile transmission capability to the EOF and NRC Operations Center.

G. See Table 3.1-1.

3.4 Operations Support Center 3.4.3 Emergency Equipment and Supplies A. Reliable voice communications with the Main Control Room, EOF, and TSC.

B. Supplies and equipment as shown in Table 3.1-1.

3.5 Emergency Operations Facility 3.5.3 Emergency Equipment and Supplies A. Reliable voice communications with the TSC, Main Control Room, OSC, NRC Operations Centers and State and local government 24-hour warning points and State EOC as described in Section 3.8.

B. Video system capable of displaying ERFIS information (such as, plant data, SPDS, and RMS) as discussed in Section 3.9.1. ERFIS HMI Display terminals are continuously disconnected from ERFIS except during drills and emergencies to meet the cyber security rule. Procedure PEP-240, Activation and Operation of the Technical Support Center, directs telecommunications and computer support to connect and verify ERFIS is communicating to the EOF when the TSC is activated. This configuration helps eliminate potential cyber threats when the EOF is not activated.

C. All Reference materials, including Mechanical and Electrical Systems Drawings; Controlled Procedure Manual; FSAR; Corporate, Plant, State, and Local Emergency Plans, are available.

D. Decontamination and monitoring area.

E. Survey meter and dosimetry.

F. Maps showing evacuation routes, evacuation areas, preselected radiological sampling and monitoring points, relocation centers in host areas, and shelter areas.

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G. Photocopier equipment and reliable facsimile transmission capability to the TSC and NRC Operations Center.

H. Additional equipment as discussed in Section 3.8.2.

I. See Table 3.1-1.

Table 3.1-1 Typical Emergency Supplies Available For Emergency Facilities Supplies MCR TSC JIC OSC EOF 7 Day supply of food and water.

Protective Clothing (Anti-Cs)

Air Sampling equipment Full face respirators Self-contained breathing equipment High and low range portable radiation survey instruments Emergency personnel monitoring dosimetry Contamination control supplies such as signs, tags, rope, tape, various forms Decontamination supplies (a) (a)

Portable Communications Equipment Radio Radio Radio (a)

Remotes Remotes Remotes Battery-Powered Lanterns Camera Mechanical and electrical systems drawings, Controlled Procedure Manual, FSAR, Corporate, State & Local Emergency Plans (b) 10-mile EPZ Area maps (c)

Copy of Plant Emergency Plan and Procedures Environmental Monitoring Kits (d)

Potassium Iodide Tablets Indicates equipment/supplies available in this facility (a)

Portable radio transceivers can be supplied to any emergency facility (b)

Figure 1.5-2 of Emergency Plan in the MCR, wall maps in other facilities.

(c)

Procedures Only (d)

Stored near the Harris E&E Center Review RG 1.219 Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Rev 1. (July 2016) 3.5 Emergency Plan

a. Emergency plan means the document(s) that the licensee prepared and maintains that identifies and describes its methods for maintaining emergency preparedness and responding to emergencies. An

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emergency plan includes the plan that the NRC originally approved and all subsequent changes that the licensee made with and without prior NRC review and approval under 10 CFR 50.54(q). See 10 CFR 50.54(q)(1)(ii) for additional information.

b. This definition highlights that emergency plan includes the documents that describes the programmatic methods that the licensee uses to maintain emergency preparedness and to respond to emergencies. These methods, or program elements, are the implementation aspects of the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 and generally correspond to the evaluation criteria of NUREG-0654 or approved alternatives that supply specific acceptable methods for complying with the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50. Such programmatic documents are subject to the 10 CFR 50.54(q) change process. Non-programmatic documents, such as training rosters, equipment and maintenance test reports, lesson plans, and other documents that document the performance of the program elements, as opposed to those that establish the program elements, are not included.

c. Ordinarily, sub-tier documents such as emergency plan implementing procedures (EPIPs) are not considered to be part of an emergency plan for the purpose of evaluating proposed changes. If a licensee relocates a programmatic description from the emergency plan to a sub-tier document, that programmatic description continues to be subject to the 10 CFR 50.54(q) change process. For example, licensees have relocated the details of emergency classification schemes from the emergency plan to an EPIP or to large wall charts maintained in the control room. Because the EPIP or wall chart is now the means to demonstrate compliance with the planning standards in 10 CFR 50.47(b)(4), these sub-tier documents are subject to 10 CFR 50.54(q). Repeating, as opposed to relocating, program element descriptions in sub-tier documents do not necessarily make the sub-tier documents subject to the 10 CFR 50.54(q) change process. However, the descriptions in the various documents must remain consistent.

d. As a simple test, a licensee can consider what programmatic document(s), in addition to its emergency plan, it would supply during an inspection to demonstrate that its emergency plan meets the regulatory requirements, as informed by the evaluation criteria in NUREG-0654 or by approved alternatives. These documents would likely be subject to the 10 CFR 50.54(q) change process.

e. This definition also highlights the need to consider the NRC-approved plan and the subsequent changes in reviewing against 10 CFR 50.54(q) to ensure that a series of incremental changes (each determined not to reduce the effectiveness of the plan) do not reduce the effectiveness of the plan when compared to the NRC-approved plan.

The differences in implementing revisions and the current revisions of the Emergency Plans have been reviewed and they have been determined to meet the regulatory requirements required during the course of revisions. Each revision has been evaluated in the regulatory process has met the approval of the NRC during the inspection process.

The changes described in this procedure revision were made to reflect changes required for the transition to a common EOF and standard ERO structure.

EPM-420 is being revised to remove inventory checklists for the near site EOF and Alternate EOF because those facilities are being deactivated and the functions moved to the common EOF in Charlotte. Other changes are being made to the inventory checklists to remove items that no longer need to be included in the inventories.

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HNP will continue to have access to the equipment and supplies required by regulations. These changes do not reduce the effectiveness of the emergency plan or reduce the capability to meet the licensing bases as described in:

NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2

PLP-201, Emergency Plan, Revision 3

PLP-201, Emergency Plan, Revision 67 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):

10 CFR 50.47(b)(8)

Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

10 CFR 50 Appendix E IV.E Emergency Facilities and Equipment Adequate provisions shall be made and described for emergency facilities and equipment, including:

1. Equipment at the site for personnel monitoring;

2. Equipment for determining the magnitude of and for continuously assessing the impact of the release of radioactive materials to the environment;

3. Facilities and supplies at the site for decontamination of onsite individuals; EPM-420 is being revised to remove inventory checklists for the near site EOF and Alternate EOF because those facilities are being deactivated and the functions moved to the common EOF in Charlotte.

The Joint Information Center (JIC) inventory checklist has also been revised to support the relocation of the JIC from a conference room at the Customer Service Center that required extensive setup when used to a dedicated area in the Regional Headquarters Building in Raleigh. Since this new location is dedicated for the JIC, the inventory list was revised.

Other changes are being made to the inventory checklists to remove items that no longer need to be included in the inventories and to reflect changes required to move to a standard ERO structure. An enhancement to the checklists to require validation that applicable equipment is operable and that expiration dates are not expired or will not expire during the quarter will help to ensure that the equipment remains functional and that dates do not expire. Also added line management review/approval to the inventory checklists, which will help to ensure that plant management is aware of emergency response facility equipment status.

HNP will continue to have access to the required supplies and equipment in the emergency response facilities to perform their functions as required by regulations and commitments.

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

Rev. 3 ATTACHMENT 5 Page 12 of 15

<< 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):

Planning Standard 10 CFR 50.47(b)(8)

Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Planning Function Regulatory Guide 2.219 Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors identifies the following standard for this standard:

4.8.b(2) Adequate equipment is maintained to support emergency response.

Planning Elements NUREG-0654 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants identifies the following elements for this standard:

Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

9. Each licensee shall provide for an onsite operations support center (assembly area) which shall have adequate capacity, and supplies, including, for example, respiratory protection, protective clothing, portable lighting, portable radiation monitoring equipment, cameras and communications equipment for personnel present in the assembly area.

10. Each organization shall make provisions to inspect, inventory and operationally check emergency equipment/instruments at least once each calendar quarter and after each use. There shall be sufficient reserves of instruments/equipment to replace those which are removed from emergency kits for calibration or repair.

Calibration of equipment shall be at intervals recommended by the supplier of the equipment.

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

Rev. 3 ATTACHMENT 5 Page 13 of 15

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

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

EEPM-420 Emergency Equipment Inventory is being revised to reflect changes required for the transition to a common EOF.

Removed attachments for the EOF. The HNP local EOF is being replaced by a common fleet EOF.

The Joint Information Center (JIC) inventory checklist has also been revised to support the relocation of the JIC from a conference room at the Customer Service Center that required extensive setup when used to a dedicated area in the Regional Headquarters Building in Raleigh.

The EOF and JIC are being relocated to new locations. These moves support a fleet initiative for a common ERO structure. As a result, the equipment in the near site EOF and Alternate EOF is no longer needed and has been removed form this procedure. The JIC inventory has been adjusted to reflect a relocation from a conference room in the Customer Service Center that required extensive setup when used to a dedicated JIC in the Regional Headquarters Building.

Added review signature lines to the attachments to require responsible organization management review.

Added remarks throughout the attachments to require validation that applicable equipment is operable and that expiration dates are not expired or will not expire during the quarter.

The addition of line management review and validation that equipment is functional and within the required dates will help to ensure that equipment remains ready for an emergency and that line management has an awareness of emergency response facility equipment status.

Removed controlled documents from the attachments. These documents are distributed and controlled by the controlled document process.

Removed the position specific books that are being replaced with fleet standard controlled documents.

Controlled documents have their own process and therefore do not need to be included in the facility inventory.

There are also readily available libraries that have required hard copies of documents. Also, the positon books that were in use prior to moving to the common ERO were not controlled documents. The common ERO documents that are replacing the position books are now controlled documents.

Revised the attachments to reflect removal and addition of items required for the inventory.

Removed flashlights from on-site kits that had both flashlights and lanterns.

Removed clocks from the kits.

Removed batteries from the kits that are readily available throughout the site.

Removed table position name plates that are being replaced with signage for the common ERO positions.

Removed rad rope, duct tape and step off pads from the Main Control Room kit. These items are readily available throughout the site.

Removed work coveralls and paper coveralls from the on-site kits. These items are readily available throughout the site.

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

Rev. 3 ATTACHMENT 5 Page 14 of 15

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

Removed pens, markers and like items from on-site kits. These items are readily available throughout the site.

Replaced forms in the Field Monitoring and Boat Shed Kits with the new fleet procedure forms.

These changes remove items from the checklists that are readily available throughout the site. In addition, forms and signage are being replaced with the new procedure forms and signage for the common ERO.

The emergency planning function for the changes being made to this procedure that adequate equipment is maintained to support emergency response remains intact.

The changes being made to this procedure does not affect compliance with planning standard 10 CFR 50.47(b)(8) because HNP continues to have the equipment and supplies required by regulation in the emergency response facilities.