RA-21-0136, Supplemental Information Regarding License Amendment Request for Common Emergency Plan

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Supplemental Information Regarding License Amendment Request for Common Emergency Plan
ML21124A180
Person / Time
Site: Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire  Duke Energy icon.png
Issue date: 05/04/2021
From: Hamilton T
Duke Energy Corp
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-21-0136
Download: ML21124A180 (24)


Text

TANYA HAMILTON Senior Vice President Nuclear Corporate 526 South Church Street, EC-07H Charlotte, NC 28202 704-382-4035 Tanya.Hamilton@duke-energy.com 10 CFR 50.90 10 CFR 50.54(q)

Serial: RA-21-0136 May 4, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325, 50-324 / RENEWED LICENSE NOS. DPR-71 AND DPR-62 CATAWBA NUCLEAR STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-413, 50-414 / RENEWED LICENSE NOS. NPF-35 AND NPF-52 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 MCGUIRE NUCLEAR STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-369, 50-370 / RENEWED LICENSE NOS. NPF-9 AND NPF-17 OCONEE NUCLEAR STATION, UNIT NOS. 1, 2 AND 3 DOCKET NOS. 50-269, 50-270, AND 50-287 / RENEWED LICENSE NOS. DPR-38, DPR-47, AND DPR-55 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23

SUBJECT:

Supplemental Information Regarding License Amendment Request for Common Emergency Plan

REFERENCES:

1. Duke Energy letter, License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2, dated September 3, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20247J468)
2. Duke Energy letter, Response to Request for Additional Information (RAI) Regarding License Amendment Request for Common Emergency Plan, dated March 11, 2021 (ADAMS Accession No. ML21071A152)

Ladies and Gentlemen:

In Reference 1, Duke Energy Carolinas, LLC and Duke Energy Progress, LLC (collectively referred to as Duke Energy) requested approval of a new fleet common emergency plan with site-specific annexes for Brunswick Steam Electric Plant Units 1 and 2 (BNP), Catawba Nuclear Station Units 1 and 2 (CNS), Shearon Harris Nuclear Power Plant, Unit 1 (HNP), McGuire Nuclear Station Units 1 and 2 (MNS), Oconee Nuclear Station Units 1, 2, and 3 (ONS), and H.B.

U.S. Nuclear Regulatory Commission RA-21-0136 Page 2 Robinson Steam Electric Plant, Unit 2 (RNP). In Reference 2, Duke Energy submitted response to Nuclear Regulatory Commission (NRG) RAI regarding Reference 1.

Duke Energy has removed non-minimum Emergency Response Organization (ERO) staff from the BNP, CNS, HNP, MNS, ONS, and RNP site Emergency Plans under 10 CFR 50.54(q) since the revisions provided in Reference 1. Supplemental information pertaining to ERO staff removed from site Emergency Plans under 10 CFR 50.54(q) is contained in Enclosure 1.

In Reference 1, Duke Energy proposed modifying the alert and notification system methods of the HNP Emergency Plan, including removal of tone alert radios, identified as Reduction In Effectiveness (RIE) 13 of Reference 1. Duke Energy no longer requests approval of RIE 13 and hereby withdraws the request to modify the alert and notification system methods. Due to the withdraw of RIE 13, the specific commitment described in Reference 1, Enclosure 3, Sections 3.4.5 and Attachment 3E, is no longer necessary and also withdrawn. provides the revised HNP Site Annex impacted by the withdrawal of RIE 13 from Reference 1, as revised by RAI responses in Reference 2. Changes to the HNP Site Annex as a result of this supplement are indicated by revision bars in the margin and red text. The changes restore current HNP Emergency Plan requirements regarding the RIE 13 tone alert radios and route alerting.

The conclusions of the No Significant Hazards Consideration and Environmental Consideration in the original license amendment request are unaffected by the additional information provided.

No new regulatory commitments have been made in this submittal.

Duke Energy is notifying the states of North Carolina and South Carolina by transmitting a copy of this letter to the designated state officials. If you have additional questions, please contact Mr. Art Zaremba, Manager - Regulatory Affairs, at 980-373-2062.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on May 4, 2021.

Sincerely, Tanya Hamilton Senior Vice President - Nuclear Corporate

Enclosures:

1.

Additional Information on ERO Staff Removed from Duke Energy Site Emergency Plans

2. HNP Site Annex (EP-HNP-EPLAN)

U.S. Nuclear Regulatory Commission RA-21-0136 Page 3 cc:

L. Dudes, Regional Administrator USNRC Region II G. Smith, USNRC Senior Resident Inspector - BNP J. D. Austin, USNRC Senior Resident Inspector - CNS J. Zeiler, USNRC Senior Resident Inspector - HNP G. A. Hutto, USNRC Senior Resident Inspector - MNS J. Nadel, USNRC Senior Resident Inspector - ONS M. Fannon, USNRC Senior Resident Inspector - RNP A. Hon, NRR Project Manager - BNP K. R. Cotton, NRR Project Manager - CNS M. Mahoney, NRR Project Manager - HNP J. Klos, NRR Project Manager - MNS S. A. Williams, NRR Project Manager - ONS T. E. Hood, NRR Project Manager - RNP W. L. Cox, III, Section Chief, NC DHSR L. Garner, Manager, Radioactive and Infectious Waste Management Section (SC)

A. Wilson, Attorney General (SC)

A. Nair, Director, Nuclear Response (SC)

Chair - North Carolina Utilities Commission RA-21-0136 Additional Information on ERO Staff Removed from Duke Energy Site Emergency Plans RA-21-0136 Page 1 Duke Energy has performed a review of changes to ERO staffing made under 10 CFR 50.54(q) since the revisions of the site Emergency Plans provided in Reference 1. Table 1-1 shows positions that have been removed over this period:

Table 1-1 Position Title Location Affected Sites OAC Support TSC BNP, CNS, HNP, MNS, ONS, RNP Chemistry Supervisor OSC BNP, CNS, HNP, MNS, ONS, RNP Generation Supply Chain Liaison OSC BNP, CNS, HNP, MNS, ONS, RNP Administration Support NOTE JIC BNP, HNP, ONS, RNP Registration Liaison NOTE JIC BNP, HNP, ONS, RNP TSC: Technical Support Center OSC: Operations Support Center JIC: Joint Information Center OAC: Operator Aid Computer NOTE:

The JIC Administration Support and Registration Liaison positions are not described in the CNS and MNS Emergency Plans.

Removal of these positions from the current site Emergency Plans under 10 CFR 50.54(q) does not affect the justifications for ERO staffing changes made in Reference 1. The current site Emergency Plans identify all the Table 1-1 positions as non-minimum augmenting ERO positions, therefore they do not perform key functions that are required to effectively implement the Emergency Plan. Additionally, Reference 1 identifies Reduction in Effectiveness (RIE) 3 for removing all non-minimum augmenting ERO positions from the Emergency Plans based on NUREG-0654, Revision 2 (Reference 2) staffing. The ERO staff shown in Table 1-1 are included in RIE 3, and each is evaluated for removal from the applicable site Emergency Plans as part of the Non-Minimum Augmenting ERO Functional Analysis performed in Reference 1.

Each non-minimum augmenting ERO positions tasks are evaluated to ensure key functions are retained and performed by minimum augmenting ERO positions within the proposed Duke Energy Common Emergency Plan. The justification for removal of the positions in Table 1-1 is based on each positions tasks being categorized as either:

(1) performed by a proposed Duke Energy Common Emergency Plan minimum augmenting ERO position; (2) did not support a NUREG-0654, Revision 2, function; or (3) administrative in nature.

Additionally, no new tasks were assigned to minimum augmenting ERO positions as a result of the analysis of the Table 1-1 positions. Therefore, the justification in Reference 1 for removing the Table 1-1 positions remains valid as their assigned tasks do not support key functions required to effectively implement the proposed Duke Energy Common Emergency Plan, or are already performed by other positions.

References:

1. Duke Energy letter, License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2, dated September 3, 2020 (ADAMS Accession No. ML20247J468)
2. NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 2, December 2019 (ADAMS Accession No. ML19347D139)

RA-21-0136 HNP Site Annex (EP-HNP-EPLAN) provides the revised HNP Site Annex. Changes to the HNP Site Annex as a result of this supplement are indicated by revision bars in the margin and red text. The changes restore current HNP Emergency Plan requirements regarding the RIE 13 tone alert radios and route alerting.

Duke Energy Harris Emergency Plan Annex EP-HNP-EPLAN REVISION 0

Duke Energy HNP Emergency Plan Annex 2

Rev. 0 Table of Contents INTRODUCTION....................................................................................................................... 3 A: Assignment of Responsibility................................................................................................ 4 B: Onsite Emergency Organization........................................................................................... 6 D: Emergency Classification System........................................................................................ 7 E: Notification Methods and Procedures................................................................................... 8 F: Emergency Communications................................................................................................ 9 G: Public Education and Information........................................................................................10 H: Emergency Facilities and Equipment..................................................................................11 I:

Accident Assessment..........................................................................................................14 J: Protective Response...........................................................................................................15 L: Medical and Public Health Support......................................................................................16 P: Responsibility for the Planning Effort: Development, Periodic Review, and Distribution of Emergency Plans................................................................................................................17

Duke Energy HNP Emergency Plan Annex 3

Rev. 0 INTRODUCTION This Duke Energy Harris Emergency Plan Annex supplements the Duke Energy Common Emergency Plan by providing site specific information unique to the site. It is subject to the same change and audit requirements as the Common Emergency Plan.

This document matches the structure of the Duke Energy Common Emergency Plan in following the format of NUREG-0654, Rev 2. It only contains the guidance elements that have site specific information therefore the numbering may not always be sequential.

Emergency Planning for the Harris Nuclear Plant (HNP) is performed within the following two Emergency Planning Zones (EPZ):

Plume Exposure Pathway EPZ - The HNP Plume Exposure Pathway EPZ approximates a 10-mile radius around the plant site and is described and illustrated in the station's Evacuation Time Estimate Study report.

Ingestion Pathway EPZ - The HNP Ingestion Pathway EPZ approximates a 50-mile radius around the plant site as illustrated below.

Duke Energy HNP Emergency Plan Annex 4

Rev. 0 A: Assignment of Responsibility Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the EPZs have been assigned, the emergency responsibilities of the various supporting organization have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Regulatory

References:

10 CFR 50.47(b)(1); 44 CFR 350.5(a)(1)

A.1.a The organizations having an operational role specify their concept of operations and relationship to the total effort.

4. County Organizations The county and municipal governments (within the counties) with emergency service departments and other agencies interrelated to these local governments within the 10-mile EPZ (plume exposure pathway) of HNP are:

Chatham County Harnett County Lee County Wake County The county and municipal governments (within the counties) with emergency service departments and other agencies interrelated to these local governments within the 50-mile EPZ (ingestion exposure pathway) of HNP are:

North Carolina Alamance Franklin Johnston Orange Vance Caswell Granville Lee Person Wake Chatham Guilford Montgomery Randolph Wayne Cumberland Harnett Moore Robeson Wilson Durham Hoke Nash Sampson

Duke Energy HNP Emergency Plan Annex 5

Rev. 0 A.4 Written agreements with the support organizations having an emergency response role within the EPZs are referenced. The agreements describe the concept of operations, emergency response measures to be provided, mutually acceptable criteria for their implementation, and arrangements for exchange of information.

Site specific letters of agreement (LOAs) or memorandums of understanding (MOUs), located in the Electronic Document Management System, are maintained by HNP with the following organizations:

Chatham County Harnett County Lee County Wake County Wake County Sheriff Apex Volunteer Fire Department Rex Healthcare WakeMed Raleigh State of North Carolina

Duke Energy HNP Emergency Plan Annex 6

Rev. 0 B: 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.

Regulatory

References:

10 CFR 50.47(b)(2); 44 CFR 350.5(a)(2);

10 CFR Part 50, Appendix E.IV.A B.1.a The site-specific emergency response organization (ERO) is developed. Note that while other site programs, such as operations, fire response, rescue and first aid, and security, may be controlled via other licensing documents, it is only when these personnel are assigned EP functions that they become part of this regulatory standard. Consideration is given to ensure that EP functions are not assigned to individuals who may have difficulties performing their EP function(s) simultaneously with their other assigned (non-EP) duties. Appendix E to 10 CFR Part 50 requires licensees to perform an on-shift staffing analysis to ensure on-shift staff can support the EP functions assigned, as well as other assigned duties.

The HNP on-shift staffing analysis report has been developed in accordance with 10 CFR 50 Appendix E.IV.A.9 and NEI 10-05.

Refer to CSD-EP-HNP-0603-02, Harris Plant On-Shift Staffing Analysis.

B.5 The external organizations, including contractors, that may be requested to provide technical assistance to and augmentation of the ERO, as applicable, are specified.

2. Contractor Support A. Westinghouse (the NSSS vendor for HNP): Westinghouse will form a Technical Support Team upon request. The team will be composed of personnel with the appropriate technical disciplines that can be dispatched to the plant site. Westinghouse will also establish dedicated telephone communications for data transmission until the arrival of the team.

B. AECOM (the architect-engineer for HNP): AECOM (formerly URS Energy and Construction) will form a Technical Support Team upon request.

Duke Energy HNP Emergency Plan Annex 7

Rev. 0 D: Emergency Classification System A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Regulatory

References:

10 CFR 50.47(b)(4); 44 CFR 350.5(a)(4);

10 CFR Part 50 Appendix E.IV.B and C D.1 A standard emergency classification and action level scheme is established and maintained. The scheme provides detailed EALs for each of the four ECLs in Section IV.C.1 of Appendix E to 10 CFR Part 50.

The HNP EAL scheme is documented in CSD-EP-HNP-0101-01, HNP EAL Technical Basis Document.

Duke Energy HNP Emergency Plan Annex 8

Rev. 0 E: Notification Methods and Procedures 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 EPZ have been established.

Regulatory

References:

10 CFR 50.47(b)(5); 44 CFR 350.5(a)(5)

E.1.a Provisions for notification of response organizations are established, including the means for verification of messages.

The site-specific state and county entities (24/7 warning points) notified of a declared emergency at HNP are as follows:

State of North Carolina Chatham County Harnett County Lee County Wake County E.2 The alert and notification systems (ANSs) used to alert and notify the general public within the plume exposure pathway EPZ and methods of activation are described. This description includes the administrative and physical means, the time required for notifying and providing prompt instructions to the public within the plume exposure pathway EPZ, and the organizations or titles/positions responsible for activating the system.

Detailed information on the FEMA approved system used to alert and notify the general public is maintained in CSD-EP-HNP-0603-01, Harris Plant Alert and Notification System Design Report.

At HNP, alerting, warning, and notification will be provided by sounding sirens, activation of tone-activated radios within five miles of the plant, and supplemented by announcements made through radio and television (EAS), sound trucks, bullhorns, and knocking on doors. The tone alert radios provide an indoor alerting signal within a 5-mile radius of the plant.

Activation of the ANS will be accomplished from county ANS activation equipment located in Emergency Operation Centers or warning points in Chatham, Harnett, Lee, and Wake counties.

Each county can control the sirens within their boundaries, or the ANS for the entire EPZ can be controlled from one county. Any part of the ANS may be controlled by Duke Energy, with a request from the counties. Activation of the tone alert radios by the National Weather Service will be accomplished after they receive a request from Wake County or the State of North Carolina.

Duke Energy HNP Emergency Plan Annex 9

Rev. 0 F:

Emergency Communications Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.

Regulatory

References:

10 CFR 50.47(b)(6); 44 CFR 350.5(a)(6)

F.3 The testing method and periodicity for each communication system used for the functions identified in evaluation criteria E.2, F.1, and F.2 are described.

Tone Alert Radio Distribution Tone Alert Radios are distributed to households within a 5-mile radius of the plant. The radios are tested prior to distribution and provided to each residence by a trained HNP representative.

Tone Alert Radio Maintenance Residences receiving a Tone Alert radio are provided with information on who to contact if the radio malfunctions.

Duke Energy annually distributes a new battery to each residence possessing a Tone Alert Radio.

Duke Energy annually distributes guidance to each residence on the purpose and operation of the Tone Alert radio.

Tone Alert Radio System Testing The Tone Alert Radio System is tested annually.

An independent contractor is retained by Duke Energy to develop and conduct a survey to assess the effectiveness of the Tone Alert Radio System.

Tone Alert Radio System Operability The Tone Alert Radio System is considered effective if at least 66% of those households surveyed received the test signal during the annual test.

Duke Energy HNP Emergency Plan Annex 10 Rev. 0 G: Public Education and Information 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.

Regulatory

References:

10 CFR 50.47(b)(7); 44 CFR 350.5(a)(7);

G.1 Provisions are made for a coordinated annual dissemination of information to the public within the plume exposure pathway EPZ, including transient populations and those with access and functional needs, regarding how they will be notified and what actions should be taken. The information is disseminated using multiple methods, to include non-English translations per current Federal guidance.

In addition to the public information distribution methods described in the common plan, HNP will also:

Provide an annual distribution of a school brochure to school bus drivers and students; Periodic publication of information for 10-mile EPZ residents, at least annually.

Lake warning signs are posted at boat ramps, or access roads to boat ramps, at Harris and Jordan Lakes. These signs describe the activities which would be taken to initiate an evacuation of the lake and actions which should be taken in response to the evacuation. The posting of these signs is verified semiannually.

Duke Energy HNP Emergency Plan Annex 11 Rev. 0 H: Emergency Facilities and Equipment Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Regulatory

References:

10 CFR 50.47(b)(8); 44 CFR 350.5(a)(8)

H.1 A TSC is established, using current Federal guidance, from which NPP conditions are evaluated and mitigative actions are developed.

The TSC has the following characteristics/capabilities:

1. The TSC is located within the Protected Area at elevation 324'-0" in the Fuel Handling Building, Section "K," approximately 400 feet walking distance from the Main Control Room (MCR) (primary route).
2. The TSC provides at least 75 square feet per person for the required TSC augmenting responders plus five (5) NRC personnel.
3. Exterior walls, roof, and floor are built to Seismic Category I, tornado, wind, and missile safety-related criteria. The exceptions are several penetrations on the west exterior wall which are not constructed to Seismic Category I standards and various roof penetrations that are not tornado missile protected. The TSC penetrations on the west exterior wall comply with the minimum standards required of the NC Building Code and will therefore withstand the most adverse conditions reasonably expected during the design life of the plant. Equipment is non-safety related and nonredundant. The TSC was designed taking into account good human factors engineering principles.
4. Provided with radiation protection equivalent to Main Control Room habitability requirements such that the dose to an individual in the TSC for the duration of a design basis accident is less than 5 Rem TEDE. The Emergency Ventilation System includes HEPA and carbon filtration. The TSC is also environmentally controlled to provide room air temperature, humidity and cleanliness appropriate for personnel and equipment.

Decontamination and monitoring area is available.

5. Video System capable of displaying Emergency Response Facility Information System (ERFIS) information (such as, plant data, SPDS, and RMS).
6. Reliable power for habitability systems and battery pack emergency lighting are provided. Power to the TSC is supplied from 2 reliable and diverse offsite power sources available through an automatic transfer switch.
7. The TSC has access to drawings and other records, including general arrangement diagrams, piping and instrumentation diagrams (P&IDs), electrical schematics and plant procedures.

In the event the TSC must be evacuated, the backup location is the 305 Shift Manager, Shift Technical Advisor, and the Auxiliary Operator office area.

Duke Energy HNP Emergency Plan Annex 12 Rev. 0 H.2 An OSC is established, using current Federal guidance, from which repair team activities are planned and teams are dispatched to implement actions.

The OSC located in the Waste Processing Building inside the Protected Area. The total area is approximately 1500 square feet in the Waste Processing Building HP Tech Work Area. This area includes a separate Command and Control area for coordinating and planning of OSC activities in addition to sufficient area for team members to standby for activities. Additional space in excess of 8500 square feet is available in adjacent offices and locker rooms to accommodate additional personnel as may be required.

In the event the OSC must be evacuated, a backup location has been established in the Fuel Handling Building, Section "K," near the TSC.

H.3.a For an EOF that is located more than 25 miles away from the NPP site, provisions are made for locating NRC and offsite responders closer to the NPP site.

The Duke Energy EOF is located greater than 25 miles from the site. The Harris Energy &

Environmental Center (HEEC) is used as a near site location for the NRC and other off-site agency staff.

This location will provide for conference areas with white boards, separate briefing/debriefing areas, telephones, ERO telephone contact lists, computers with internet access, necessary office supplies and photocopier access, and access to plant radiological information.

H.4 An alternative facility (or facilities) is established, using currently provided and/or endorsed guidance, which would be accessible even if the NPP site is under threat of or experiencing hostile action.

The Harris Energy & Environmental Center (HEEC) located on New Hill Holleman Road has been designated as the HNP Alternate Emergency Facility.

H.8 Provisions are made to acquire data from offsite monitoring and analysis equipment, including data on geophysical phenomena (e.g., meteorological, hydrologic, and seismic monitors) and radiological data (e.g., from FMTs, environmental dosimeters, and laboratory analyses).

1. Meteorological Monitoring HNP has a permanent meteorological monitoring station located within the exclusion area boundary for display and recording of wind speed, wind direction, and differential temperature for use in making off-site dose projections. Meteorological information is presented in the Main Control Room, the TSC, and the EOF by means of a communication interface. Additional information on the on-site meteorological monitoring system can be found in UFSAR Section 2.3.3.
2. Hydrologic Monitoring The design basis flood, probable maximum precipitation, and other improbable, conceivable extremes in hydrologic natural phenomena are well below any design limits for this site.

Refer to UFSAR Sections 2.4.2 and 2.4.3.

Duke Energy HNP Emergency Plan Annex 13 Rev. 0

3. Seismic Monitoring HNP has a seismic monitoring system, described in UFSAR Section 3.7.4 and procedure PLP-114, that is located inside safety-related structures and measures horizontal and vertical acceleration. A seismic event is digitally recorded, analyzed, and displayed by the seismic monitor computer in the Main Control Room. The digital record can also be sent off site for additional analysis.
4. Radiation Monitoring The Radiation Monitoring System (RMS) is a plant-wide radiation information gathering and control system encompassing the process and effluent monitors and the area and airborne monitors. Radiological monitors are provided for plant systems as described in UFSAR Sections 11.5 and 12.3.4. The types, ranges, and locations of monitors are listed in USFAR Tables 11.5.2-1, 11.5.2-2 and 12.3.4-1.

Duke Energy HNP Emergency Plan Annex 14 Rev. 0 I: Accident Assessment Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Regulatory

References:

10 CFR 50.47(b)(9); 44 CFR 350.5(a)(9)

I.4.a The contingency arrangements to obtain and analyze highly radioactive samples from the reactor coolant system, containment atmosphere and sump, and spent fuel pool storage area are described.

Changes have been made to reflect the NRC approved License Amendment Request received from the NRC via letter dated 01/14/02. The NRC issued Amendment No. 108 (Facility Operating License NPF-FP). The amendment deletes TS Section 6.8.4.e, "Post Accident Sampling," and thereby eliminates the requirement to have and Maintain the Post-Accident Sampling System at HNP.

A Chemistry Management Procedure describes post-accident contingency plans for obtaining Reactor Coolant, and Residual Heat Removal, and Containment Sump samples. Procedures are in place to assess core damage under accident condition.

Duke Energy HNP Emergency Plan Annex 15 Rev. 0 J: Protective Response 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. ETEs have been developed by applicants and licensees.

Licensees shall update the ETEs 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.

Regulatory

References:

10 CFR 50.47(b)(10); 44 CFR 350.5(a)(10)

J.2 Provisions are made and coordinated with appropriate offsite entities for evacuation routes and transportation for onsite individuals to a suitable offsite location. Selection of location considers the potential for inclement weather, high traffic density, and potential radiological conditions. Alternate location(s) and route(s) are identified.

The main plant access road and the secondary access road may be used to depart from the site, and evacuation from the 10-mile EPZ and to reception centers will be by way of evacuation routes identified in CSD-EP-HNP-0603-03, Harris Plant Evacuation Time Estimate Study.

J.8.a Incorporated either by reference or in their entirety into the emergency plan.

The HNP site specific ETE report is documented in CSD-EP-HNP-0603-03, Harris Plant Evacuation Time Estimate Study.

J.8 The latest ETEs are:

Duke Energy HNP Emergency Plan Annex 16 Rev. 0 L: Medical and Public Health Support Arrangements are made for medical services for contaminated injured individuals.

Regulatory

Reference:

10 CFR 50.47(b)(12); 44 CFR 350.5(a)(12)

L.2.b Primary and backup offsite medical facilities.

The primary and backup offsite medical facilities to treat contaminated, injured personnel from HNP are:

Primary - Rex Healthcare Raleigh, N.C.

Backup - WakeMed Raleigh, N.C.

L.4 Each organization arranges for the transportation of contaminated, injured individuals and the means to control contamination while transporting victims of radiological incidents to medical support facilities and the decontamination of transport vehicle following use.

The Wake County EMS is used to provide ambulance service for individuals transported from HNP. They have the means to control contamination while transporting victims.

Duke Energy HNP Emergency Plan Annex 17 Rev. 0 P: Responsibility for the Planning Effort: Development, Periodic Review, and Distribution of Emergency Plans Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

Regulatory

References:

10 CFR 50.47(b)(16); 44 CFR 350.5(a)(16)

P.6 A listing of annexes, appendices, and supporting plans and their originating agency is included in the emergency plan.

External emergency plans specific to the support of HNP include the following:

Chatham County's Plan to Support the Harris Nuclear Power Plant Harnett County's Plan to Support the Harris Nuclear Power Plant Lee County Plan to Support the Harris Nuclear Power Plant Wake County Emergency Operations Plan Emergency Response Plan, Water Reactors Division, Westinghouse Electric Corporation P.7 An appendix containing a listing by title of the procedures required to maintain and implement the emergency plan is included. The listing includes the section(s) of the emergency plan to be implemented by each procedure.

Table P.7-1 provides a listing of the HNP site-specific procedures required to maintain and implement the emergency plan, and the section(s) of the emergency plan implemented by each procedure.

Duke Energy HNP Emergency Plan Annex 18 Rev. 0 Table P.7-1: HNP Emergency Plan Response and Administrative Procedures Document ID Document Title Plan Sections Implemented(1)

AD-EP-HNP-0105 HNP Specific TSC Support H

AD-EP-HNP-0106 HNP Specific OSC Support H

AD-EP-HNP-0203 HNP Site Specific Field Monitoring I

PEP-342 Core Damage Assessment D, I EPM-400 Public Notification and Alerting System E.4 EPM-410 Communication and Facility Performance Tests F, H, P EPM-420 Emergency Equipment Inventory F, H EPM-601 Core Damage Assessment Technical Basis I

EPL-001 Emergency Phone List P

(1) All letters refer to Sub-Sections of Plan Section II, Planning Standards and Elements