ML25148A446

Procedures: CSD-CNS-0101-01, EAL Technical Basis Document, Revision 006 CSD-EP-CNS-0101-02, EAL Wallcharts, Revision 003 Summary of Changes

ML25148A446
Person / Time
Site:	Catawba
Issue date:	05/28/2025
From:	Ellis K Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
A-25-0126
Download: ML25148A446 (1)

Text

KEVIN M. ELLIS General Manager Nuclear Regulatory Affairs, Policy &

Emergency Preparedness 13225 Hagers Ferry Rd., MG011E Huntersville, NC 28078 843-951-1329 Kevin.Ellis@duke-energy.com 10 CFR 50.54(q)

Serial: RA-25-0126 May 28, 2025 United States Nuclear Regulatory Commission (NRC)

ATTN: Document Control Desk Washington, DC 20555-0001 Catawba Nuclear Station, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. NPF-35 and NPF-52 Docket Nos. 50-413 and 50-414

SUBJECT:

Procedures:

CSD-EP-CNS-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 006 CSD-EP-CNS-0101-02, EAL WALLCHARTS, Revision 003 Summary of Changes Ladies and Gentlemen:

In accordance with 10 CFR 50.54(q), Duke Energy Carolinas, LLC (referred to as Duke Energy), is submitting a revision summary for the following procedures:

CSD-EP-CNS-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 006 CSD-EP-CNS-0101-02, EAL WALLCHARTS, Revision 003 The Emergency Action Level (EAL) Technical Basis Document Procedure provides explanation and rationale for each EAL and provides historical documentation for future reference. Decision-makers responsible for Classification of Emergency may use this document as a technical reference in support of EAL interpretation. The EAL Wallchart is the primary tool used to determine the Emergency Classification Level.

This revision was initiated as a result of the implementation of a staggered, fleetwide transition to the State and County Offsite Emergency Notification System (SCOENS) from the Duke Emergency Management Network (DEMNET). SCOENS has replaced DEMNET as the primary means of communication for the Main Control Room and Emergency Operations Facility when contacting Offsite Response Organizations. Other minor and editorial changes are also incorporated as shown in the Review Form attached.

The changes described above have been evaluated in accordance with 10 CFR 50.54(q) and have been determined to not result in a reduction in the effectiveness of the Emergency Plan. The Duke Energy Common Emergency Plan continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. In accordance with 10 CFR 50.54(q)(5), a summary of analysis is included as Attachment 1: 10 CFR 50.54(q) Review Form.

This document contains no new regulatory commitments.

U.S. Nuclear Regulatory Commission Serial: RA-25-0126 Page 2 Should you have any questions concerning this letter, or require additional information, please contact Ryan Treadway, Fleet Licensing Director, at (980) 373-5873.

Sincerely, Kevin M. Ellis General Manager - Nuclear Regulatory Affairs, Policy & Emergency Preparedness

U.S. Nuclear Regulatory Commission Page 3 Serial: RA-25-0126

10 CFR 50.54(q) Review Form cc:

USNRC, Region II Regional Administrator USNRC NRR Project Manager for CNS USNRC Senior Resident Inspector for CNS

U.S. Nuclear Regulatory Commission Serial: RA-25-0126

10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 1 of 24

<< 10 CFR 50.54(q) Review Form >>

Section I: 10 CFR 50.54(q) Review Number: (EREG #):

02531503 Applicable Sites and Applicability Determination # (5AD)

BNP CNS 02531501 HNP MNS ONS RNP Document #, EC #, or N/A Revision # or N/A Document or Activity Title CSD-EP-CNS-0101-01 CSD-EP-CNS-0101-02 6

3 EAL Technical Basis Document EAL Wallcharts Section II: Identify/Describe All Proposed Activities/Changes being Reviewed Event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan (Use attachments or continue additional pages as necessary): Continue to Section III.

Activity/Changes:

CSD-EP-CNS-0101-01 is the Emergency Action Level (EAL) technical basis document for Catawba Nuclear Station (CNS). CSD-EP-CNS-0101-02 is the EAL Wallcharts for Catawba Nuclear Station.

Changes include:

Updated revision summary and revision number. Updated page numbers due to addition of pages and information.

Added Attachment 4, CNS Site Map, which provides a visual representation of the Protected Area (PA) and Owner Controlled Area. Also updated the definitions to reference the new attachment for clarification. This change is for EALs, HA1.1, HA1.2, HS1.1, HU3.1, HU3.3, HU4.3, and HU4.4.

Updated EALs CU5.1 and SU7.1 to address the replacement of the Duke Emergency Management Network (DEMNET) with State and County Offsite Emergency Notification System (SCOENS). DEMNET is the system used to notify the State and Local agencies of a declared emergency. This change replaces Table C-4/S-4 Communication methods DEMNET with SCOENS and associated communication method description.

Clarified EALs CU5.1 and SU7.1 PBX description to state PBX phones are every phone onsite that start with 803-701.

Clarify EAL HU4.1 and HU4.2 applicable fire areas to state that Reactor Building includes containment and annulus and Auxiliary Building includes Spent Fuel Building and Control Room. This change also includes clarification that these fire areas include structures containing function and systems required for safe plant operation and safe shutdown of the plant vice just safe shutdown of the plant.

Corrected table summarizing ECLs resulting from primary to secondary leakage with or without a steam release from the faulted steam generator.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 2 of 24

<< 10 CFR 50.54(q) Review Form >>

Changes for CSD-EP-CNS-0101-01 only unless noted otherwise (bolded) in Section or Step # column:

Change Section or Step Change From Change to 1

Throughout Revision 5 revision number, effective dates, revision summary, page numbering Revision 6 revision number, effective dates, revision summary, updated page numbering due to added attachment 2

EAL Wallcharts Revision 2 Revision 3 3

Table of Contents 7.0 Attachments Added to document new attachment 4 CNS Site Map.

4 5.1 Definitions Owner Controlled Area Area outside the PROTECTED AREA fence that immediately surrounds the plant. Access to this area is generally restricted to those entering on official business. (ref. 4.1.13).

Owner Protected Area Area outside the PROTECTED AREA fence that immediately surrounds the plant as depicted in Attachment 4, CNS Site Map. Access to this area is generally restricted to those entering on official business. (ref. 4.1.13).

5 5.1 Definitions Protected Area An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan (ref. 4.1.7).

Protected Area An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan (ref. 4.1.7) and in Attachment 4, CNS Site Map.

6 Att. 1 EAL CU5.1 RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 3 of 24

<< 10 CFR 50.54(q) Review Form >>

7 EAL Wallcharts CU5.1 Table C-4 8

Att. 1 EAL CU5.1 Basis Private Branch Exchange (PBX)

A PBX is a full featured telephone system that provides internal calling services for one or more locations. The PBX terminates commercial phone lines from a carrier (AT&T, Verizon, CenturyLink, etc.) to provide inbound and outbound calling capabilities between Duke Energy and external parties. PBX systems have a number of mechanisms which make them resistant to failure including, redundant power connections, redundant network connections, and server hardware installed in geographically diverse locations.

Private Branch Exchange (PBX)

A PBX is a full featured telephone system that provides internal calling services for one or more locations. The PBX terminates commercial phone lines from a carrier (AT&T, Verizon, CenturyLink, etc.) to provide inbound and outbound calling capabilities between Duke Energy and external parties. PBX systems have a number of mechanisms which make them resistant to failure including, redundant power connections, redundant network connections, and server hardware installed in geographically diverse locations. PBX phones are every phone onsite that start with 803-701.

9 Att. 1 EAL CU5.1 Basis Duke Emergency Management Network (DEMNET)

The DEMNET consists of equipment and circuits linking Duke Energy nuclear sites with the offsite agencies involved in initial emergency notifications. This system can quickly conference the offsite agencies for notifications.

CNS MCR, TSC, and the EOF have this system. It is also located in CNS Alternate TSC and EOF.

DEMNET is the primary means of communication for the MCR and EOF when contacting OROs.

State and County Offsite Emergency Notification System (SCOENS)

SCOENS consists of a cloud-based service used to develop and deliver emergency and follow up notifications to all required offsite State and local agencies. Being cloud based, the system can be accessed from any Duke Energy Control Room, the EOF, or other facility with Duke LAN access.

SCOENS is the primary means of communication for the MCR and EOF when notifying OROs of a declared emergency.

10 Att. 1 EAL HA1.1 Definitions OWNER CONTROLLED AREA - Area outside the PROTECTED AREA fence that immediately surrounds the plant.

Access to this area is generally restricted to those entering on official business.

OWNER CONTROLLED AREA - Area outside the PROTECTED AREA fence that immediately surrounds the plant as depicted in Attachment 4, CNS Site Map.

Access to this area is generally restricted to those entering on official business.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 4 of 24

<< 10 CFR 50.54(q) Review Form >>

11 Att. 1 EAL HA1.2 Definitions OWNER CONTROLLED AREA - Area outside the PROTECTED AREA fence that immediately surrounds the plant.

Access to this area is generally restricted to those entering on official business.

OWNER CONTROLLED AREA - Area outside the PROTECTED AREA fence that immediately surrounds the plant as depicted in Attachment 4, CNS Site Map.

Access to this area is generally restricted to those entering on official business.

12 Att. 1 EAL HS1.1 Definitions PROTECTED AREA - An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan.

PROTECTED AREA - An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan and in, CNS Site Map.

13 Att. 1 EAL HU3.1 Definitions PROTECTED AREA - An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan.

PROTECTED AREA - An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan and in, CNS Site Map.

14 Att. 1 EAL HU3.3 Definitions PROTECTED AREA - An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan.

PROTECTED AREA - An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan and in, CNS Site Map.

15 Att. 1 EAL HU4.1 and HU4.2 RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 5 of 24

<< 10 CFR 50.54(q) Review Form >>

16 EAL Wallcharts HU4.1 and HU4.2 Table H-1 17 Att. 1 EAL HU4.1 and HU4.2 Basis 2nd paragraph Table H-1 Fire Areas are based on CNS-1465.00-00-0006 Design Basis Specification for the Plant Fire Protection and AP/0/A/5500/045 Plant Fire. Table H-1 Fire Areas include those structures containing functions and systems required for safe shutdown of the plant (SAFETY SYSTEMS) (ref. 1, 2).

Table H-1 Fire Areas are based on CNS-1465.00-00-0006 Design Basis Specification for the Plant Fire Protection and AP/0/A/5500/045 Plant Fire. Table H-1 Fire Areas include those structures containing functions and systems required for safe plant operation and safe shutdown of the plant (SAFETY SYSTEMS) (ref. 1, 2).

18 Att. 1 EAL HU4.3 Definitions PROTECTED AREA - An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan.

PROTECTED AREA - An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan and in, CNS Site Map.

19 Att. 1 EAL HU4.4 Definitions PROTECTED AREA - An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan.

PROTECTED AREA - An area encompassed by physical barriers and to which access is controlled. The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-19.2 Master Site Plan and in, CNS Site Map.

20 Att. 1 EAL SU7.1 RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 6 of 24

<< 10 CFR 50.54(q) Review Form >>

21 EAL Wallcharts SU7.1 Table S-4 22 Att. 1 EAL SU7.1 Basis Private Branch Exchange (PBX)

A PBX is a full featured telephone system that provides internal calling services for one or more locations. The PBX terminates commercial phone lines from a carrier (AT&T, Verizon, CenturyLink, etc.) to provide inbound and outbound calling capabilities between Duke Energy and external parties. PBX systems have a number of mechanisms which make them resistant to failure including, redundant power connections, redundant network connections, and server hardware installed in geographically diverse locations.

Private Branch Exchange (PBX)

A PBX is a full featured telephone system that provides internal calling services for one or more locations. The PBX terminates commercial phone lines from a carrier (AT&T, Verizon, CenturyLink, etc.) to provide inbound and outbound calling capabilities between Duke Energy and external parties. PBX systems have a number of mechanisms which make them resistant to failure including, redundant power connections, redundant network connections, and server hardware installed in geographically diverse locations. PBX phones are every phone onsite that start with 803-701.

23 Att. 1 EAL SU7.1 Basis Duke Emergency Management Network (DEMNET)

The DEMNET consists of equipment and circuits linking Duke Energy nuclear sites with the offsite agencies involved in initial emergency notifications. This system can quickly conference the offsite agencies for notifications.

CNS MCR, TSC, and the EOF have this system. It is also located in CNS Alternate TSC and EOF.

DEMNET is the primary means of communication for the MCR and EOF when contacting OROs.

State and County Offsite Emergency Notification System (SCOENS)

SCOENS consists of a cloud-based service used to develop and deliver emergency and follow up notifications to all required offsite State and local agencies. Being cloud based, the system can be accessed from any Duke Energy Control Room, the EOF, or other facility with Duke LAN access.

SCOENS is the primary means of communication for the MCR and EOF when notifying OROs of a declared emergency.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 7 of 24

<< 10 CFR 50.54(q) Review Form >>

24 Att. 2, Barrier -

Containment, Category - A.

NCS or SG Tube Leakage, Degradation Threat - Loss 25 New Att. 4 CNS Site Map Added to document New Att. 4 CNS Site Map. See for copy of Att 4.

Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:

List all emergency plan sections that were reviewed for this activity by number and title.

IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.

Licensing Basis for NEI 99-01 Rev 6 EALs CNS: ML16082A038 Letter Dated April 18, 2016.

Subject:

Catawba Nuclear Station, Units 1 and 2 - Issuance of Amendments regarding Emergency Action Level Scheme Change (CAC NOS. MF6166 and MF6167).

Amendment No. 279 to Renewed Facility Operating License (RFOL) No. NPF-35 and Amendment No. 275 to RFOL No. NPF-52 for the Catawba Nuclear Station, Units 1 and 2, respectively.

Additional Licensing basis to implement FAQs ML19058A632 Letter dated July 1, 2019.

Subject:

Catawba Nuclear Station, Units 1 And 2; McGuire Nuclear Station, Units 1 And 2; Oconee Nuclear Station, Units 1, 2, And 3; Brunswick Steam Electric Plant, Units 1 And 2; Shearon Harris Nuclear Power Plant, Unit 1; And H. B. Robinson Steam Electric Plant, Unit No. 2 - Issuance of Amendments To Revise Emergency Action Level Schemes To Incorporate Clarifications Provided By Emergency Preparedness Frequently Asked Questions 2015-013, 2015-014, And 2016-002 (EPID L-2018-LLA-0174)

Amendment Nos. 303 and 299 to Renewed Facility Operating License Nos. NPF-35 and NPF-52 for the Catawba Nuclear Station, Units 1 and 2 (Catawba), respectively; Amendment Nos. 315 and 294 to Renewed Facility Operating License Nos. NPF-9 and NPF-17 for the McGuire Nuclear Station, Units 1 and 2 (McGuire), respectively; Amendment Nos. 412, 414, and 413 to Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55 for the Oconee Nuclear Station, Units 1, 2, and 3 (Oconee), respectively; Amendment Nos. 291 and 319 to Renewed Facility Operating License Nos. DPR-71 and DPR-62 for Brunswick Steam Electric Plant, Units 1 and 2 (Brunswick), respectively; Amendment No. 172 to Renewed Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris); and Amendment No. 264 to Renewed Facility Operating License No.

DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (Robinson).

Current EALs Catawba Nuclear Station Emergency Action Levels, CSD-EP-CNS-0101-01 Revision 005 RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 8 of 24

<< 10 CFR 50.54(q) Review Form >>

Licensing Basis EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 0 EP-CNS-EPLAN-ANNEX, Duke Energy Catawba Emergency Plan Annex Revision 0 Current Emergency Plan EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 6 Section D-Emergency Classification System EP-CNS-EPLAN-ANNEX, Duke Energy Catawba Emergency Plan Annex Revision 2 Section D-Emergency Classification System The differences in approved 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.

Section IV: Ability to Maintain the Emergency Plan.

Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.

1. Do any of the elements of the proposed activity change information or intent contained in the Emergency Plan?

Yes No

2. Do any elements of the proposed activity change the process or capability for alerting or notifying the public as described in the FEMA-approved Alert and Notification System Design Report?

Yes No

3. Do any elements of the proposed activity change the Evacuation Time Estimate results?

Yes No

4. Do any elements of the proposed activity change the On-Shift Staffing Analysis results?

Yes No

5. Does the Proposed activity require a change to the Emergency Plan Programmatic Description?

Yes No If Question 5 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.

Section IV conclusion:

If questions 1-5 in Section IV marked NO, then complete Section V.

If any question 1-5 of Section IV marked yes, then continue at Section VI.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 9 of 24

<< 10 CFR 50.54(q) Review Form >>

Section V: Maintaining the Emergency Plan Conclusion.

The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.

1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.

2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.

I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).

==

Conclusion:==

Section VI: Activity Previously Reviewed?

Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?

Yes 10 CFR 50.54(q) Evaluation is not required.

Identify bounding source document below and continue to Section XIV.

No Continue to Section VII.

Partially If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.

Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.

Bounding source document and list of bounded changes:

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 10 of 24

<< 10 CFR 50.54(q) Review Form >>

Section VII: Editorial Changes Yes All Activities/Changes identified in Section II are editorial/typographical changes such as formatting, paragraph numbering, spelling, or punctuation that does not change intent.

No None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to Section VIII.

Partially Some Activities/Changes are editorial/typographical.

If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XII.

If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.

Justification:

The change(s) below are defined as editorial in accordance with AD-EP-ALL-0602, and do not change the intent of the Emergency Plan as written.

Proposed changes 1, 2 and 3, updates the revision number, effective date, revision summary, table of contents, and page numbering of the document. These changes are a result of Duke Energy's procedure formatting and require updating during the revision process. These proposed changes do not change intent of the Emergency Plan therefore, these changes are considered editorial.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 11 of 24

<< 10 CFR 50.54(q) Review Form >>

Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)

Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate box.

1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.

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

2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned 2b The process for timely augmentation of onshift staff is established and maintained.

3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.

3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.

4 10 CFR 50.47(b)(4) Emergency Classification System RS 4a A standard scheme of emergency classification and action levels is in use. (Requires V/V (Attachment 3) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS 5a Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.

5b Administrative and physical means have been established for alerting and providing prompt instructions to public within the plume exposure pathway.

5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter 6

10 CFR 50.47(b)(6) Emergency Communications 6a Systems are established for prompt communication among principal emergency response organizations.

6b Systems are established for prompt communication to emergency response personnel.

7 10 CFR 50.47(b)(7) Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ).

7b Coordinated dissemination of public information during emergencies is established.

8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response 8b Adequate equipment is maintained to support emergency response.

9 10 CFR 50.47(b)(9) Accident Assessment RS RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 12 of 24

<< 10 CFR 50.54(q) Review Form >>

9a Methods, systems, and equipment for assessment of radioactive releases are in use.

10 10 CFR 50.47(b) (10) Protective Response RS 10a A range of public PARs is available for implementation during emergencies.

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

10c A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.

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

11 10 CFR 50.47(b) (11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.

12 10 CFR 50.47(b) (12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.

13 10 CFR 50.47(b) (13) Recovery Planning and Post-Accident Operations 13a Plans for recovery and reentry are developed.

14 10 CFR 50.47(b) (14) Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program areas) is established.

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

14c Identified weaknesses are corrected.

15 10 CFR 50.47(b) (15) Emergency Response Training 15a Training is provided to emergency responders.

16 10 CFR 50.47(b) (16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.

16b Planners responsible for emergency plan development and maintenance are properly trained.

Section VIII: Conclusion If any Section VIII criteria are checked, document the basis for conclusion below for any changes that are more than editorial, however not impacted by any of the identified criteria in Section VIII and continue the 50.54(q) Review in Section IX.

If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document justification below for any changes that are more than editorial and continue to Section XIV.

Justification for changes that are more than editorial, however, not impacted by any of the identified criteria in Section VIII:

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 13 of 24

<< 10 CFR 50.54(q) Review Form >>

Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.

Planning Standard 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.

Function (1) A standard scheme of emergency classification and action levels is in use.

Supporting requirements from Appendix E to 10 CFR Part 50 B. Assessment Actions

1. The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC.

Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis.

2. A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change.

Licensees shall follow the change process in § 50.54(q) for all other emergency action level changes.

C. Activation of Emergency Organization

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

Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described. The existence, but not the details, of a message authentication scheme shall be noted for such agencies. The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG-0654/FEMA-REP-1.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

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<< 10 CFR 50.54(q) Review Form >>

2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.

The applicable program elements:

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.

D.1.a The EALs are developed using guidance provided or endorsed by the NRC that is applicable to the reactor design.

D.1.b The initial emergency classification and action level scheme is discussed and agreed to by the licensee and OROs, and approved by the NRC. Thereafter, the scheme is reviewed with OROs on an annual basis.

D.2 The capability to assess, classify, and declare the emergency condition within 15 minutes after the availability of indications to NPP operators that an EAL has been met or exceeded is described.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

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<< 10 CFR 50.54(q) Review Form >>

Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC 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). Address each Planning Standard identified in Section IX. Continue to Section XI.

Proposed changes 4, 5, 10, 11, 12, 13, 14, 18, 19, and 25 enhances definition of OCA and PA:

These changes clarify that Security Owners Controlled Area (SOCA) and Owners Controlled Area (OCA) are the same for EAL determinations. Some EALs reference plant area locations including Protected Area and Owner Controlled Area as part of the basis for declaration and upgrades. The Owner Controlled Area has been modified by security with the installation of the SOCA (Security Owner Controlled Area) physical barrier monitored by detection and assessment system technology.

Change 25 adds the new Attachment 4 of the CNS site maps to the list of attachments in the document to align with Duke Energy procedure format. The addition of the map is also associated with updating the definitions of OCA and PA repeated throughout the document to reference the new map.

The addition of the Attachment 4 CNS Site Map to the document enhances the accuracy and timeliness of EAL declarations dealing with specific plant areas. No changes were made to the intent or actions in the EALs as a result.

Proposed changes 6, 7, 9, 20, 21, and 23 update CU5.1 and SU7.1 communication methods:

This updates EAL Matrix and bases document Communication Methods table and bases definitions to match CNS Emergency Plan. The update removes Duke Emergency Management Network (DEMNET) and replaces it with State and County Offsite Emergency Notification System (SCOENS). DEMNET is described as a closed network voice over internet protocol (VOIP) system. DEMNET uses a group call within this network, calling specific devices in the same network, to get all OROs in a conference call.

This conference call provides the ability to verbally notify all OROs at the same time of a declared emergency or provide them with follow up notifications. This verbal notification is considered the official notification to the OROs. By process, the Emergency Notification Form (ENF) is transmitted to the OROs via email or fax concurrently with this verbal notification. DEMNET was installed and placed in service in 2015 replacing a degraded and outdated copper wire system. Since 2015 technology has evolved and has provided different solutions to provide notifications to offsite agencies. DEMNET is being replaced with a solution that will provide the OROs the same notification over multiple platforms instead of using a closed VOIP network.

The replacement for DEMNET is a vendor supplied mass notification system. In addition to automated verbal notification via phone calls to land lines, recipients are able to receive calls to designated cell phones, text messages, emails or push notifications through the vendors application, automatically notifying them of the event. This mass notification system is already in use at Duke Energy to notify and mobilize the Emergency Response Organization. The mass notification system has 2 geographically diverse, data centers located in the United States. These data centers have redundant power supplies, and communication paths able to backup and provide notification without interruption should one of the data centers become unavailable. The ORO warning points will continue to be notified, however, because this system does not require recipient devices to be on a specific network, SCOENS is able to notify additional contacts should OROs request them. Should SCOENS not be available to make notification, alternate methods to notify the offsite agencies continue to be described RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 16 of 24

<< 10 CFR 50.54(q) Review Form >>

in EPIPs to contact the offsite agencies. Once initiated, mass notification of all contacts is completed almost simultaneously and within a very short time, meeting the required 15-minute notification from declaration. Additional contacts allow for more notification redundancy. Once the ORO receives the message, the ORO will "acknowledge" receipt of the message by following the prompts provided in the message. However, if acknowledgement is not received, site personnel designated to monitor acknowledgements will place a call to the individual ORO or OROs to transmit the notification prior to the 15-minute notification requirement. OROs have received training on this new method of notification and acknowledgment for continuity of notification.

The Emergency Notification Form (ENF) will continue to be transmitted to the OROs via email, and/or fax (if requested). SCOENS provides equivalent notification to the OROs as the DEMNET system did without compromising timeliness of notification. The replacement of DEMNET will eliminate the need for the governing procedure of DEMNET AD-EP-ALL-0406, Duke Emergency Management Network (DEMNET). SCOENS notification process is described within EPIPs and does not require generation of a specific governing procedure.

The communication method replacement from DEMNET to SCOENS for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6 and lists communications methods as described in CNS Emergency Plan. The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Section III. Implementation of the changes will maintain the accuracy and timeliness of a classification following a loss of all communications methods used to communicate with OROs. The meaning or intent of the basis of the approved EAL is unchanged.

Therefore, these proposed changes continue to comply with 10 CFR50.47 (b)(4).

The DEMNET removal and SCOENS addition to the Duke Energy Common Emergency Plan was completed in revision 6 and evaluated under EREG 2527650.

Proposed changes 8 and 22 clarify description of PBX:

These changes add clarification to the EAL basis description of PBX. Based on EAL reviews, an enhancement was identified to specifically state which phones belong to the group of phones defined in EALs as PBX phones. At CNS, all phones connected to the PBX start with the prefix 803-701.

The addition of the statement PBX phones are every phone onsite that start with 803-701. to the document enhances the accuracy and timeliness of EAL declarations dealing with plant communication systems. No changes were made to the intent or actions in the EALs as a result.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 17 of 24

<< 10 CFR 50.54(q) Review Form >>

Proposed changes 15, 16, and 17 clarify EAL HU4.1 and HU4.2 applicable fire areas:

EAL HU4.1 and HU4.2 applicable fire areas listed in Table H-1 are being clarified to state that the Reactor Building includes Containment and Annulus and the Auxiliary Building includes Spent Fuel Building and Control Room based on building identifications in the Catawba UFSAR and Design Specification for the Plant Fire Protection. This change also includes clarification that these fire areas include structures containing function and systems required for safe plant operation and safe shutdown of the plant vice just safe shutdown of the plant.

CNS UFSAR section 3.8.4 describes the Auxiliary Building as a structure that includes the Control Room and Spent Fuel Building. The Table H-1 fire areas are based on CNS-1465.00-00-0006 Design Basis Specification for the Plant Fire Protection which lists the Control Room and areas withing the Spent Fuel Building as fire area. Clarifying in parentheses that the Auxiliary Building includes the Control Room and Spent Fuel Building is an enhancement and continues to meet the intent of the EALs HU4.1 and HU4.2 since the clarification continues to align with UFSAR descriptions and the design basis specification for the Plant Fire Protection program. Fires in the Auxiliary Building will continue to be assessed for emergency declaration regardless of the fire being located inside the control room or the spent fuel building.

The second sentence of the second paragraph for the basis section of EALs HU4.1 and HU4.2 contained a truncated definition of safety systems Table H-1 Fire Areas include those structures containing functions and systems required for safe shutdown of the plant. This truncated definition could cause confusion when assessing plant fires so the definition was clarified to state Table H-1 Fire Areas include those structures containing functions and systems required for safe plant operation and safe shutdown of the plant. This enhancement to the basis more accurately aligns with the EAL definition of Safety Systems which states A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. This enhancement ensures confusion is removed and plant fires will continue to be accurately assessed for emergency declarations regardless of the fire affecting plant systems that are required for safe operation or safe shutdown of the plant as defined in CNS EALs.

These additions of clarifying information to the document enhances the accuracy and timeliness of EAL declarations dealing with plant fires. No changes were made to the intent or actions in the EALs as a result.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 18 of 24

<< 10 CFR 50.54(q) Review Form >>

Proposed change 24 corrects table summarizing ECLs resulting from primary to secondary leakage with or without steam release from the faulted steam generator:

The basis for Containment Loss Threshold A A leaking or RUPTURED SG is FAULTED outside of containment contained the following summary table of ECLs resulting from primary-to-secondary leakage:

The row Requires operation of a standby charging (makeup) pump (NCS Barrier Potential Loss) was removed. The deleted row was factually correct because any leak large enough to require an additional charging pump is also large enough to require a manual Safety Injection (SI). So, any leak requiring an additional charging pump is large enough to declare a loss of NCS. However, the deleted row has created more confusion than it has resolved during Operator training and Drills. There is not an equivalent NCS Barrier Potential Loss threshold at CNS. This creates an apparent contradiction between this table and the NCS Barrier Potential Loss threshold. Since there is not an EAL threshold associated with this row, the row was removed to prevent any confusion when using the table. This table was not used to declare a loss of containment. The table was only for additional information.

This EAL was previously and will remain applicable anytime there is a leaking or ruptured steam generator that is also faulted outside containment. Removal of this row from the document makes no changes to the accuracy and timeliness of EAL declarations dealing with ruptured faulted steam generators. No changes were made to the intent or actions in the EALs as a result.

These proposed changes continue to comply with 10 CFR 50.47(b)(4) because the changes continue to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by Catawba Nuclear Station (CNS).

These proposed changes continue to comply with 10 CFR Part 50 Appendix E, IV.C.2, because CNS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. These changes continue to ensure CNS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

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<< 10 CFR 50.54(q) Review Form >>

Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.

Proposed changes 4, 5, 10, 11, 12, 13, 14, 18, 19, and 25 enhances definition of OCA and PA:

These changes clarify that Security Owners Controlled Area (SOCA) and Owners Controlled Area (OCA) are the same for EAL determinations. Some EALs reference plant area locations including Protected Area and Owner Controlled Area as part of the basis for declaration and upgrades. The Owner Controlled Area has been modified by security with the installation of the SOCA (Security Owner Controlled Area) physical barrier monitored by detection and assessment system technology.

Change 25 adds the new Attachment 4 of the CNS site maps to the list of attachments in the document to align with Duke Energy procedure format. The addition of the map is also associated with updating the definitions of OCA and PA repeated throughout the document to reference the new map.

The addition of the Attachment 4 CNS Site Map to the document enhances the accuracy and timeliness of EAL declarations dealing with specific plant areas. No changes were made to the intent or actions in the EALs as a result.

Proposed changes 6, 7, 9, 20, 21, and 23 update CU5.1 and SU7.1 communication methods:

This updates EAL Matrix and bases document Communication Methods table and bases definitions to match CNS Emergency Plan. The update removes Duke Emergency Management Network (DEMNET) and replaces it with State and County Offsite Emergency Notification System (SCOENS). DEMNET is described as a closed network voice over internet protocol (VOIP) system. DEMNET uses a group call within this network, calling specific devices in the same network, to get all OROs in a conference call.

This conference call provides the ability to verbally notify all OROs at the same time of a declared emergency or provide them with follow up notifications. This verbal notification is considered the official notification to the OROs. By process, the Emergency Notification Form (ENF) is transmitted to the OROs via email or fax concurrently with this verbal notification. DEMNET was installed and placed in service in 2015 replacing a degraded and outdated copper wire system. Since 2015 technology has evolved and has provided different solutions to provide notifications to offsite agencies. DEMNET is being replaced with a solution that will provide the OROs the same notification over multiple platforms instead of using a closed VOIP network.

The replacement for DEMNET is a vendor supplied mass notification system. In addition to automated verbal notification via phone calls to land lines, recipients are able to receive calls to designated cell phones, text messages, emails or push notifications through the vendors application, automatically notifying them of the event. This mass notification system is already in use at Duke Energy to notify and mobilize the Emergency Response Organization. The mass notification system has 2 geographically diverse, data centers located in the United States. These data centers have redundant power supplies, and communication paths able to backup and provide notification without interruption should one of the data centers become unavailable. The ORO warning points will continue to be notified, however, because this system does not require recipient devices to be on a specific network, SCOENS is able to notify additional contacts should OROs request them. Should SCOENS not be available to make notification, alternate methods to notify the offsite agencies continue to be described in EPIPs to contact the offsite agencies. Once initiated, mass notification of all contacts is completed almost simultaneously and within a very short time, meeting the required 15-minute notification from RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

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<< 10 CFR 50.54(q) Review Form >>

declaration. Additional contacts allow for more notification redundancy. Once the ORO receives the message, the ORO will "acknowledge" receipt of the message by following the prompts provided in the message. However, if acknowledgement is not received, site personnel designated to monitor acknowledgements will place a call to the individual ORO or OROs to transmit the notification prior to the 15-minute notification requirement. OROs have received training on this new method of notification and acknowledgment for continuity of notification.

The Emergency Notification Form (ENF) will continue to be transmitted to the OROs via email, and/or fax (if requested). SCOENS provides equivalent notification to the OROs as the DEMNET system did without compromising timeliness of notification. The replacement of DEMNET will eliminate the need for the governing procedure of DEMNET AD-EP-ALL-0406, Duke Emergency Management Network (DEMNET). SCOENS notification process is described within EPIPs and do not require generation of a specific governing procedure.

The communication method replacement from DEMNET to SCOENS for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6 and lists communications methods as described in CNS Emergency Plan. The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Section III. Implementation of the changes will maintain the accuracy and timeliness of a classification following a loss of all communications methods used to communicate with OROs. The meaning or intent of the basis of the approved EAL is unchanged.

The DEMNET removal and SCOENS addition to the Duke Energy Common Emergency Plan was completed in revision 6 and evaluated under EREG 2527650.

Proposed changes 8 and 22 clarify description of PBX:

These changes add clarification to the EAL basis description of PBX. Based on EAL reviews, an enhancement was identified to specifically state which phones belong to the group of phones defined in EALs as PBX phones. At CNS, all phones connected to the PBX start with the prefix 803-701.

The addition of the statement PBX phones are every phone onsite that start with 803-701. to the document enhances the accuracy and timeliness of EAL declarations dealing with plant communication systems. No changes were made to the intent or actions in the EALs as a result.

Proposed changes 15, 16, and 17 clarify EAL HU4.1 and HU4.2 applicable fire areas:

EAL HU4.1 and HU4.2 applicable fire areas listed in Table H-1 are being clarified to state that the Reactor Building includes Containment and Annulus and the Auxiliary Building includes Spent Fuel Building and Control Room based on building identifications in the Catawba UFSAR and Design Specification for the Plant Fire Protection. This change also includes clarification that these fire areas include structures containing function and systems required for safe plant operation and safe shutdown of the plant vice just safe shutdown of the plant.

CNS UFSAR section 3.8.4 describes the Auxiliary Building as a structure that includes the Control Room and Spent Fuel Building. The Table H-1 fire areas are based on CNS-1465.00-00-0006 Design RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

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<< 10 CFR 50.54(q) Review Form >>

Basis Specification for the Plant Fire Protection which lists the Control Room and areas within the Spent Fuel Building as fire areas. Clarifying in parentheses that the Auxiliary Building includes the Control Room and Spent Fuel Building is an enhancement and continues to meet the intent of the EALs HU4.1 and HU4.2 since the clarification continues to align with UFSAR descriptions and the design basis specification for the Plant Fire Protection program. Fires in the Auxiliary Building will continue to be assessed for emergency declaration regardless of the fire being located inside the control room or the spent fuel building.

The second sentence of the second paragraph for the basis section of EALs HU4.1 and HU4.2 contained a truncated definition of safety systems Table H-1 Fire Areas include those structures containing functions and systems required for safe shutdown of the plant. This truncated definition could cause confusion when assessing plant fires so the definition was clarified to state Table H-1 Fire Areas include those structures containing functions and systems required for safe plant operation and safe shutdown of the plant. This enhancement to the basis more accurately aligns with the EAL definition of Safety Systems which states A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. This enhancement ensures confusion is removed and plant fires will continue to be accurately assessed for emergency declarations regardless of the fire affecting plant systems that are required for safe operation or safe shutdown of the plant as defined in CNS EALs.

These additions of clarifying information to the document enhances the accuracy and timeliness of EAL declarations dealing with plant fires. No changes were made to the intent or actions in the EALs as a result.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 22 of 24

<< 10 CFR 50.54(q) Review Form >>

Proposed change 24 corrects table summarizing ECLs resulting from primary to secondary leakage with or without steam release from the faulted steam generator:

The basis for Containment Loss Threshold A A leaking or RUPTURED SG is FAULTED outside of containment contained the following summary table of ECLs resulting from primary-to-secondary leakage:

The row Requires operation of a standby charging (makeup) pump (NCS Barrier Potential Loss) was removed. The deleted row was factually correct because any leak large enough to require an additional charging pump is also large enough to require a manual Safety Injection (SI). So, any leak requiring an additional charging pump is large enough to declare a loss of NCS. However, the deleted row has created more confusion than it has resolved during Operator training and Drills. There is not an equivalent NCS Barrier Potential Loss threshold at CNS. This creates an apparent contradiction between this table and the NCS Barrier Potential Loss threshold. Since there is not an EAL threshold associated with this row, the row was removed to prevent any confusion when using the table. This table was not used to declare a loss of containment. The table was only for additional information.

This EAL was previously and will remain applicable anytime there is a leaking or ruptured steam generator that is also faulted outside containment. Removal of this row from the document makes no changes to the accuracy and timeliness of EAL declarations dealing with ruptured faulted steam generators. No changes were made to the intent or actions in the EALs as a result.

The proposed changes described provide 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 proposed changes continue to meet NRC requirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E as well as the requirements of the Duke Energy Common Emergency Plan as written and approved. Therefore, the proposed changes do not reduce the effectiveness of the Duke Energy Common Emergency Plan or the Catawba Emergency Plan Annex.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

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<< 10 CFR 50.54(q) Review Form >>

Section XII: 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 reduction in effectiveness)?

Yes No

3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme?

Yes No Section XII: Conclusion Questions 1, 2 and 3 are answered YES, complete step below to create a General CAS assignment, and then continue on to Section XIV and implement change(s).

General CAS assignment created - Licensing submit changes in accordance with 10 CFR 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XIII and Section XIV.

Section XIII: Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change be submitted to the NRC for prior approval?

If No, reject the proposed change, or modify the proposed change and perform a new evaluation.

Continue to Section XIV for this evaluation.

Yes No If YES, then initiate a License Amendment Request in accordance 10 CFR 50.90, AD-LS-ALL-0002, Regulatory Correspondence, and AD-LS-ALL-0015, License Amendment Request and Changes to SLC, TRM, and TS Bases, and include the tracking number: ___________________________________. Complete Section XIV.

RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form

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AD-EP-ALL-0602 Rev. 9 ATTACHMENT 2 Page 24 of 24

<< 10 CFR 50.54(q) Review Form >>

Section XIV: Signatures:

EP CFAM Final Approval is required for changes affecting Program Element 4a of Section VIII. If CFAM approval is NOT required, then mark the EP CFAM signature block as not applicable (N/A) to indicate that signature is not required.Section XIV as applicable.

Preparer Name (Print):

Matthew Nelson Preparer Signature: See NAS Date:

See NAS Reviewer Name (Print):

Ryder Coyle Reviewer Signature: See NAS Date:

See NAS Approver Name (Print): Scott Milton Approver Signature: See NAS Date:

See NAS Approver (EP CFAM, as required) Name (Print):

David Thompson Approver Signature: See NAS Date:

See NAS QA RECORD RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form RA-25-0126 Attachment 1: 10 CFR 50.54(q) Review Form