ONS-2017-006, Emergency Plan Revision 2016-003

Emergency Plan Revision 2016-003

ML17013A671
Person / Time
Site:	Oconee
Issue date:	01/12/2017
From:	Teresa Ray Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ONS-2017-006
Download: ML17013A671 (84)

Text

ef'DUKE * . Thomas D. Ray

~;ENERGY Vice President Oconee Nuclear Station Duke Energy ON01 VP J 7800 Rochester Hwy Seneca, SC 29672 ONS-2017-006 o: 864.873.5016

f. 864.873. 4208 Tom.Ray@duke-energy.com January 12, 2017 10 CFR 50.54(q)

Attn: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852-27 46

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Emergency Plan Revision 2016-003 Please find attached for your use and review copies of the revisions to the Oconee Nuclear Station Emergency Plan along with the associated revision instructions and 10 CFR 50.54( q) evaluation.

This revision is being submitted in accordance with 10 CFR 50.54(q) and does not reduce the effectiveness of the Emergency Plan. If there are any questions or concerns pertaining to this revision please call Pat Street, Emergency Preparedness Manager, at 864-873-3124.

By copy of this letter, two copies of this revision are being provided to the NRC, Region II, Atlanta, Georgia.

Sincerely, 6~

Vice President Oconee Nuclear Station Attachments:

Revision Instructions Emergency Plan Revision 2016-003 10 CFR 50.54(q) Evaluation(s) www.duke-energy.com

ONS-2017-006 U.S. Nuclear Regulatory Commission January 12, 2017 xc: w/2 copies of attachments Ms. Catherine Haney Administrator, Region II Marquis One Tower 245 Peachtree Center., NE Suite 1200 Atlanta GA 30303-1257 w/copy of attachments Mr. James R. Hall, Senior Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 11555 Rockville Pike Mailstop: 0-8G9A Rockville, MD 20852 2738 (send via E-mail) w/o attachments Mr. Eddy Crowe NRG Senior Resident Inspector Oconee Nuclear Station ELL-EC2ZF

OCONEE NUCLEAR STATION EMERGENCY PLAN Date Approved REVISION 2016-003 December, 2016

December 15, 2016 OCONEE NUCLEAR STATION

SUBJECT:

Emergency Plan Revision 2016-003 Please make the following changes to the Emergency Plan:

REMOVE INSERT Cover Sheet Rev. 2016-002 Cover Sheet Rev 2016-003 Record of Changes Rev. 2016-002 Record of Changes 2016-003 LOEP Rev. 2016-0-02, Sept. 2016 LOEP 2016-003, Dec. 2016 Section B Rev. 2016-002, Sept. 2016

• Section B, Rev 2016-003, Dec. 2016 Section F Rev. 2015-007, Nov. 2015 Section F, Rev 2016-003, Dec. 2016 Section P Rev. 2016-002, Sept. 2016 Section P, Rev 2016-003, Dec. 2016 Appendix 09 - July 2010 Appendix 09, Cover Sheet (Dec 2016)

Appendix 1O Rev. 2010-01, February. 2010 Appendix 10, Cover Sheet (Dec 2016)

Pat Street ONS Emergency Preparedness Manager

Oconee Emergency Plan List Of Effective Pages SECTION PAGE NUMBER REVISION NO. DATE Emergency Plan Approval Cover Sheet Rev. 2016-002 September 2016 List of Effective Pages Page 1 - 3 Rev. 2016-003 December 2016 List Of Figures Page 1 - 5 Rev. 2014-02 October 2014 Record Of Changes Page 1 - 10 Rev. 2016-003 December 2016 Table of Contents Page 1 Rev. 2012-05 December 2012 I. Introduction Page 1 - 5 Rev. 2012-05 December 2012 Page i-6 Rev. 2008-02 October 2008 Page i-6a Rev. 2012-05 December 2012 II. Planning Standards and Evaluation Criteria A. Assignment of Responsibility Page A-1 -A-8 Rev. 2016-002 September 2016 B. Onsite Emergency Organization Page B B-21 Rev. 2016-003 December 2016 C. Emergency Response Support And Resources Page C-1 & C-2 Rev. 2012-05 December 2012 D. Emergency Classification System Page D D-101 Rev. 2015-007 November 2015 E. Notification Page E-1 & E-2 Rev. 2008-02 December 2008 F. Emergency Communications Page F F-8 Rev. 2016-003 December 2016 G. Public Information and Education Page G G-5 Rev. 2014-02 October 2014 1 Rev. 2016-003 December, 2016

Oconee Emergency Plan List Of Effective Pages SECTION PAGE NUMBER REVISION NO. DATE H. Emergency Facilities And Equipment Page H H-39 Rev. 2016-002 September 2016 I. Accident Assessment Page I I-37 Rev. 2015-002 March 2015 J. Protective Response Page J J-12 Rev. 2015-007 November 2015 K. Radiological Exposure Control Page K K-12 Rev. 2015-004 April 2015 L. Medical And Public Health Support Page L L-5 Rev. 2015-007 November 2015 M. Recovery And Reentry Planning And Post-Accident Operations Page M M-5 Rev. 2016-02 September 2016 N. Exercises and Drills Page N N-3 Rev. 2015-007 November 2015

0. Emergency Response Training Page 0 0-3 Rev. 2012-05 December 2012 P. Responsibility For The Planning Effort:

Development, Periodic Review and Distribution Of The Emergency Plans PageP-l -P-18 Rev. 2016-003 December 2016 III. APPENDICIES APPENDIX 1 Definitions Page 1 - 5 Rev. 2012-05 December 2012 APPENDIX2 Meteorology And Offsite Dose Assessment Program Page 1 -4 Rev. 2014-03 December 2014 2 Rev. 2016-003 December, 2016

Oconee Emergency Plan List Of Effective Pages SECTION PAGE NUMBER REVISION NO. DATE APPENDIX3 Alert And Notification

System Description

Page 1 - 4 Rev. 2015-004 May2015 APPENDIX4 Evacuation Time Estimates Page 1 Rev. 2013-01 October 2013 APPENDIXS Letters of Agreement Page 1 Rev. 2016-002 September 2016 Page2 Rev. 2016-002 September 2016 APPENDIX6 Distribution List Page 1 - 4 Rev. 2014-02 October 2014 APPENDIX7 Emergency Data Transmittal System Page 1 Rev. 2012-01 June 2012 APPENDIXS Spill Prevention Control Page 1 Rev. 2016-001 June 2016 And Countermeasure Plan ONS Pollution Prevention Plan -cover sheet APPENDIX9 Page 1 Rev. 2016-003 December 2010 ONS Chemical Treatment Ponds 1, 2 and 3, Groundwater Monitoring Sampling And Analysis Plan APPENDIX 10 Hazardous Materials Response Plan Page 1 Rev. 2016-003 December 2016 3 Rev. 2016-003 December, 2016

RECORD OF CHANGES REVISION EFFECTIVE NUMBER DATE REASON FOR REVISIONS Revision 1 April 1, 1981 Meteorological Update Revision 2 December 31, 1981 Rewrite Emergency Plan in Nureg 0654 Format Revision 3 March, 1982 Update Emergency Plan Revision4 April, 1982 Revisions & Changes to update Emergency Plan Revision 5 September 1, 1982 Revision to coincide with Crisis Management Plan Revision 6 November 1, 1982 Revision update Revision 7 December 14, 1982 Review and update 83-1 June 10, 1983 Changes required by action items due to annual exercise and revi<ew and general update 83-2 November 17, 1983 Changes required by review and general update 84-1 March 26, 1984 Revisions as determined by QA audit and minor editing 84-2 November 15, 1984 Revisions as determined by annual review 85-1 June 7, 1985 Revisions/ changes/editing 85-2 ------------- Revisions/ changes/editing-annual review 86-1 March 8, 1986 New Oconee Brochure 86-2 November 13, 1986 Revisions/ changes/editing-annual review 86-3 December 9, 1986 Correct changes identified as deficiencies by the NRC in Rev. 85-2.

87-1 February 4, 1987 Revision update, minor editing changes, included failed fuel accident assessment information.

87-2 ------------- Revision update, minor editing changes Review Section D. Agreement letters updated.

87-4 December 10, 1987 Incorporate alternate TSC and OSC into Emergency Plan 88-1 June 7, 1988 Revised EALS in Section D.

88-2 October 14, 1988 Annual review. Minor editorial revisions.

89-1 February 28, 1989 Major revision to Section D. Added Appendix 7. Minor editorial changes.

89-2 August 14, 1989 Change to Section D. Minor editorial revisions.

89-3 January 5, 1990 Annual Review 1

Rev. 2016-003 December 2016

RECORD OF CHANGES (Continued)

REVISION EFFECTIVE NUMBER DATE REASON FOR REVISIONS 90-1 March 1, 1990 Changes to Section D as required by NRC commitment.

90-2 June 1, 1990 Changes reflect upgrade of radiation monitor system and minor editing.

90-3 July 2, 1990 Change to Section D, Emergency Classification.

90-4 October 31, 1990 Annual Review 91-1 January21, 1991 Section D revision. (RIA upgrade) 91-2 February 20, 1991 Section D revision. (TS to SLC) 91-3 March 22, 1991 Section D revision. (RIA upgrade); Section D revision. (SLB revision) 91-5 September 19, 1991 Section Prevision. (RIA upgrade) 91-6 December 16, 1991 Annual review.

92-1 March 1, 1992 Section D (RIA upgrade). Minor editorial changes.

92-2 June 30, 1992 Major Revision 92-3 October 29, 1992 Annual review 92-4 12/31/92 Section B, D, H, J, Appendix 4, 5 & 6 changes.

93-1 03/01/93 Sections D, G, H, N, P, and Appendix 6 93-2 05/07/93 Sections A, B, D, Appendix 5 and 6 93-3 07/23/93 Sections A, B, G, H, I, J, L, M, N, & Appendix 6 93-4 08/11/93 Sections B, D, and Appendix 5 93-05 01/01/94 Annual Review, Incorporation ofEPA-400 guidelines.

94-01 03/15/94 Additions of Appendix 8 and 9. - (Minor revisions) 94-02 05/09/94 Changes to Appendix 5, Pages 1 and 2; Changes to Appendix 6, Pages 2 and 4; State of South Carolina Agreement Letter 94-03 05/25/94 Changes to Appendix 5, Page 2; Changes to Appendix 6, Pages 4 and 5; INPO Agreement Letter 94-04 06/06/94 Changes to Appendix 5, Page 2; Change Teledyne Isotopes Badge Service agreement letter to Northeast Utilities Service Company 94-05 08/08/94 Changes to Section D 94-06 12/29/94 Annual review. Editorial changes, minor revisions.

2 Rev. 2016-003 December 2016

RECORD OF CHANGES (Continued)

REVISION EFFECTIVE NUMBER DATE REASON FOR REVISIONS 95-01 02123195 Changes to Sections B, G, Appendix 5.

95-02 10/23/95 Annual review and changes 95-03 11/01/95 Section D. Change, Incorporated new EAL'S.

95-04 12/31/95 Calendar 1996, HAZMAT Changes, RP/14 deleted 96-01 02/13/96 Changes to Sections B, D, and N.

96-02 06125196 Changes to Section D 96-03 07/96 Changes to Section D 96-04 12/96 Annual review, editorial changes, minor changes with major change to Appendix 10.

97-01 07-97 Section B, I, Appendix 5 & 7, with editorial/minor changes to SectionH & P 97-02 12-97 Annual review and editorial/minor changes 98-01 02-98 Section D, page 35. Correction of title on Enclosure 4.3 98-02 03-98 Section N, page 1 & 2, Added part a (General) to Section N.2 to ensure drills conducted between NRC evaluated exercises are performed in accordance with 10CFR50, Appendix E, Section IV.F.2.b 98-03 04-98 List of Figures page number corrections, Added Emergency Operation Facility to Figure H-15, Figure H-20 reformatted. Added Agreement Letter with Keowee-Key Volunteer Fire Department, Appendix 5, #24. Appendix 10 - Hazardous Materials Response Plan, corrections on Table of Contents with minor revisions. Headings on Appendix 10, Figure 2 with minor revisions.

98-04 12-98 Annual review and editorial/minor changes.

99-01 03-99 The ONS Technical Specifications have been converted to a set of Technical Specifications based on NUREG 1430. "Standard Technical Specifications Babcock and Wilcox Plants."

Replaced the description phrases (titles) in Section D for Operating Modes with the Mode number from Improved Technical Specifications. In Section I the portion describing leak rate volume percent per day was changed to percent of the containment air weight per day. The reference to Tech Spec 4.4.1. l was changed to reference Improved Technical Specification 5.5.2.

NOTE: The implementation date oflmproved Tech Specs was moved from March 4, 1999 to March 27, 1999, therefore the revision date for revision 99-01 will depict February when the actual administrative changes were completed.

3 Rev. 2016-003 December 2016

RECORD OF CHANGES (Continued)

REVISION EFFECTIVE NUMBER DATE REASON FOR REVISIONS 99-02 12-99 Annual review and editorial/minor changes 2000-01 04-2000 Addition of List of Effective Pages 2000-02 0512000 Editorial /minor changes 2000-03 12/2000 Annual review and editorial/minor changes 2001-01 02/07/2001 Additions and corrections as result of 50.54(t) audit.

Additional information added to Basis Document and additional EAL's resulting from EP drill critiques.

2001-02 08/2001 Changes in areas ofresponsibility. Added note concerning RVLS to Fission Product Barrier Matrix; 2001 calendar; information added to EP Functional Area Manual; added/updated information on*annual average meteorology; Appendix 5; Appendix 6; editorial/minor changes.

2001-03 12/2001 Added information in Basis Document concerning a reactor building containment break. Replaced the 2001 calendar with the 2002 calendar. Editorial/minor changes.

2002-01 01/02 The present Oconee Nuclear Station Emergency Operating Procedure is written in a different format and with some different terms than the earlier version. The term PTS (Pressurized Thermal Shock) has replaced TSOR (Thermal Shock Operating Range). This is only a change in terminology.

The additional EAL is to ensure a site specific credible threat results in a declaration of a notification of Unusual Event (NOUE). This change is also intended to achieve an appropriate level and consistent response Nationwide.

2002-02 06/02 Section B - minor changes; Section D - Added information requested by Emergency Coordinators to Enclosure 4.1; Section G - Rewrite of entire section; Section H - Updated information on Figure H-4 relating to Met Data; Appendix 5 -

Updated Letters of Agreement; and miscellaneous spelling/grammar errors.

2002-03 09/02 Section A - Compliance with the NRC Security Interim Compensatory Measure (ICM) issued 02/25/02; Section P -Audit frequencies per revised 10 CFR 50.54 (t) as stated in Federal Register Vol 64, 03129199.

Appendix 1 - Added definition of monthly and Semi-Annual; Appendix 5, Agreement Letters, updated #17, Appendix 6 - Changed name on 78A.

Miscellaneous corrections.

2003-01 02103 Section D - RIA setpoints change, Section G - 2003 Calendar, Appendix 3 - Siren upgrade, new map (i-5); Appendix 5 - Agreement Letters, Appendix 6 - Issued To change, Section B, E, F editorial/minor changes 2003-02 08/03 Section D - incorporates additional guidance for the Emergency Coordinator/EOF Director related to classification of a high energy line break, such as a Main Steam Line Break. In addition, Section D has been retyped using a consistent font style -

no changes in content resulted from the retype.

4 Rev. 2016-003 December 2016

RECORD OF CHANGES (Continued)

REVISION EFFECTIVE NUMBER DATE REASON FOR REVISIONS 2004-01 02/04 Incorporates a retype of the majority of the sections as an editorial change to adopt a consistent format: Section G - Added information concerning One Mile Exclusion Area Signs; Section H - Strip Chart Recorders were removed under an NSM; Section J - Incorporated guidance on the use of KI as a protective action recommendation; Section K - changed KI dose to 5 REM CDE from 25 REM; Appendix 4 - Incorporate results of Evacuation Time Estimate; Appendix 5 -

Revised Agreement Letters 2004-02 12/21/04 Editorial changes to correct typos, drawings, and title/organizational names. This revision also incorporates clarifying information from the latest Evacuation Time Estimate (ETE); clarification of offsite agency responsibilities for protective actions for impediments and special populations; revised EAL #2 for Enclosure 4.3, Unusual Event IC #2; clarification of ERO activation after normal working hours; and revisions to the site's SPCC Plan included in Appendix 8. In addition to these changes, applicable references have replaced generic references in Figure P-1. This revision also incorporates the 2005 Calendar distributed to the 10 mile EPZ population.

2005-01 02/01/05 Section D, Enclosure 4.7, Page 66 - Duke Power Hydro-Electric Group has revised the Lake Keowee water level from 807 to 815.5 feet for initiating a Condition B. This elevation is used in Enclosure 4.7 for classifying the event as an Unusual Event. The Hydro -Electric Group notifies the Control Room when Condition B has been declared. No protective actions by the plant are changed.

2005-02 05/17 /05 Section I & Letters of Agreement - Incorporates an editorial revision that describes the makeup of Field Monitoring Teams and updated Agreement Letters.

I. 7 &8 replaced ".... personnel from Radiation Protection and Chemistry." with " .. a RP Technician and a Driver." Editorial Change - Chemistry personnel no longer perform the function ofFMT Driver. FMT Drivers are now provided by other groups.

2005-03 08/24/05 Revision 2005-03 incorporates an addendum for the Fire Department/Volunteer Fire Department Agreement Letters. This addendum was added as a result of NRC guidance provided to utilities. The addendum to these letters provides guidance on the use of the Incident Command System at ONS and identifies the ONS Fire Brigade Leader as the on-scene commander and site-interface for responding offsite fire departments.

2005-04 09/15/05 Revision 2005-04 is a change to Page 66, Enclosure 4.7, Emergency Action Levels #1 - Reservoir elevation greater than or equal to 807.0 feet with all spillway gates open and the lake elevation continues to rise. This change undoes Revision 2005-01 which changed Keowee Lake level from 807 feet elevation to 815 .5 feet elevation. This revision was determined to be a non conservative change in that it delayed the Unusual Event emergency classification. Appendix 5, Agreement Letter #21 has been updated.

2005-05 01/09/06 Revision 2005-05 incorporates editorial changes that clarify organizational charts/responsibilities, revise procedure references, replaces public information calendar, and replaces obsolete survey instruments. Agreement Letters #16 and

1. 19 were updated.

5 Rev. 2016-003 December 2016

RECORD OF CHANGES (Continued)

REVISION EFFECTIVE NUMBER DATE REASON FOR REVISIONS 2006-03 06/8/06 Section D - Change #1 Revised initiating condition #2 for the Alert classification for Enclosure 4.6 (Fire/Explosions and Security Events). This change is based on a correction to the NEI White Paper, Enhancements to Emergency Preparedness Programs For Hostile Actions which was endorsed in a letter from the NRC on December 8, 2005. Change #2 - Renumbered Emergency Action Levels throughout Section D to match the numbering scheme found in RP/O/B/1000/001 (Emergency Classification) procedure - Renumbering makes it easier for procedure users to locate the correct emergency action level in the Basis Document. Appendix 5 - Agreement Letters #8, 14,15 & 23 were updated.

2006-04 11/06 Reference changes to the deletion of the Clemson EOF and incorporates reference to the Charlotte EOF. In addition, miscellaneous editorial changes are included in this revision.

2007-01 03/07 Appendix 5 Agreement Letters that have been updated/revised.

2007-02 12/07 Editorial changes including a revised 50 mile radius map (Figure B), a revision to the Emergency Classification Basis Section D , the 2008 Emergency Planning Calendar, a revised layout drawing for the JIC, a revised listing of portable survey instruments, the latest renewal of existing agreement letters and a revised Ground Water Monitoring Plan 2008-01 09/08 The original order of the EALs created a human performance trap. The first fission barrier column that the procedure user reviews is the RCS Barrier column which is on the left side of the page. The second fission barrier column that is reviewed is the Fuel Clad Barrier which is in the center of the page. This order gives the procedure user the mindset that the EALs are listed in the same order: RCS EAL followed by the Fuel Clad EAL. Changing the order of the EALs is not a deviation from the approved EAL scheme but is a difference. This change does not constitute a decrease in the effectiveness of the EPLAN since the EALs are exactly the same.

2008-02 10/08 As of this change 2008-02, the Emergency Plan is now available on NEDL/SCRIBE and has been completely re-issued. All changes in the future to the Emergency Plan will be completed thru NEDL/SCRIBE. The following Agreement Letters were also updated: 1, 2, 3, 4, 5, 6, 7, 9, 10, 11, 19 and 21.

2009-01 02109 Revised existing information relating to organization names that have changed, removed specific names and replaced with a title to mitigate the need for future revisions due to personnel changes, and changed staging location names based on changes made to area designation names; however staging will still occur in same area. Changes made only reflect actual organization names, functional position names, and current location names being used to make the E-Plan more accurately reflect current information. No changes are being made to the process or conduct of the how the E-Plan is to be implemented.

6 Rev. 2016-003 December 2016

RECORD OF CHANGES (Continued)

REVISION EFFECTIVE NUMBER DATE REASON FOR REVISIONS 2010-10 02/10 Revised existing information relating to changes made to the callback system, who performs the dose assessments, the basis information for the Containment Barrier EAL based on NEI 99-01 Rev 5 FAQ lessons learned. Made name change for Oconee Medical Center, corrected information relating to testing frequency for major elements referenced in the E-Plan, the new neutron instrument used by radiation protection, and street name change for figure H-3A. Changes made are the result of the Annual Review process and no changes are being made to the process or conduct of how the E-Plan is to be implemented. The following Agreement Letters were also updated: Number - 6, 8, 13, 14, 15, 16, 18, 20, 22, & 23.

2011-01 05/11 Figure B Redistribution of support for Field Monitoring Teams from Chemistry to Business Management and Work Control. Section D - Basis corrected to delete reference to USFAR Table 15-114 which has been deleted, revised ICs 4.3.A.3 and 4.4.A.3, EAL A to align with RP/O/B/1000/001, revised ICs and EALs fo add levels of operating modes that represent the operating levels of hot shutdown, cold shutdown and hot standby were listed, added "AC" back to IC 4.5.A.1 where it had been inadvertently deleted, add SSF to IC 4.6.U.1, correct IC 4.5.G.l, EAL 1 to reflect SSF maintaining Mode 3 (hot standby) rather than hot shutdown, add new ICs for Jocassee Dam condition A and B declarations, correct misprint in IC 4.7.A.2, EAL B, correct formatting errors, and add Security EALs. Section F - deleted onsite areas requiring phone notifications for site assembly due to new wireless system being installed in those areas. Section G - replace 2010 calendar with 2011 calendar.

Figure H revised room layout to reflect current arrangement. Section N - Revised the testing cycle for the EPLAN from a 5 year cycle to a 6 year cycle. Appendix 5 -

update letters of agreement.

2011-02 10/11 This evaluation supports a request to revise the Oconee (ONS), McGuire (MNS), and Catawba (CNS) Emergency Plans to allow for an alternate approach for compliance with 10 CFR 50.47(b)(2) relative to meeting the minimum staffing requirement during emergencies for site Radiation Protection (RP) personnel and the Emergency Operations Facility (EOF) position staffing to that in Table B-1 in NUREG-0654, endorsed by Regulatory Guide 1.101.

2012-01 06/12 Section F - A change to the process for answering the 4911 emergency phone calls.

The new process will have both Operations and Security(SAS) answering the phone.

Appendix 7 -Will clarify the ERDS related system description verbiage from the modem based data transfer system to the new VPN System.

2012-02 06/12 The NRC published Federal Register notice [RIN 3150-AllO], "Enhancements to Emergency Preparedness Regulations" on November 23, 2011. The amendments contained in the rule are summarized as twelve (XII) topics with varying implementation due dates. Emergency Plan changes to the following sections (C, D, H, I, J, P, and Appendix 1) are made in accordance with the rule and the appropriate guidance documents pertaining to Topic V - Emergency Action Level for Hostile Action, Topic VI - Emergency Declaration Timeliness, Topic VIII - Emergency Operation Facility (Performance Based), Topic IX - Emergency Response Organization Augmentation at Alternate Facility, and Topic XI - Protective Actions for On-site Personnel.

7 Rev. 2016-003 December 2016

RECORD OF CHANGES (Continued)

REVISION EFFECTIVE NUMBER DATE REASON FOR REVISIONS 2012-03 06/13 Added Agreement Letter 25 - G&G Metal Fabrication to provide Hale pump technical support and Agreement Letter 26 Operating Agreement between Duke Energy's Lincoln Combustion Turbine Facility & MNS, CNS and ONS Nuclear Supply Chain concerning an Emergency Supply of Diesel Fuel.

2012-04 12/12 Section B - This change is to incorporate the new staffing analysis for the new EP rule and editorial changes.

2012-05 12112 Revised Section D, Enclosure 4.3 to add threshold values for unit vent sampling as a compensatory

• measure. Unit vent sampling is performed on the 6th floor auxiliary building at sampling equipment where manual grab samples are retrieved per HP/O/B/1000/060-D. Additionally, the use of RIA 56 was added as a compensatory measure for Site Area Emergency and General Emergency Classifications.

This change allows for classification of gaseous radiological releases in the event of a loss of either RlA-45 or 46. This change only clarifies the values to be used in the event normal monitoring is not available.

The plan is also being revised based on annual review requirements, changes are mainly editorial or formatting. Additional changes are being made to reflect current name changes, update Agreement letters, Spill Prevention and Control, and Groundwater monitoring programs.

2013-01 10/13

• Section D - Added clarification in the basis for Loss of Shutdown function.

• Section I - Revised to reference procedures versus RPSM 11. 7 which has been deleted.

• Section J - Revised to incorporate latest revision to ETE. Deleted climate data tables which were duplicative to information contained within the ETE (Appendix 4).

• Section P - Updated appropriate references.

• Appendix 4 - Added latest ETE as reference.

2014-01 03/14

• Section B - Removed reference to having home addresses listed in the emergency telephone directory as these were never listed in the telephone directory and clarified EOF Services Group actions. Updated titles of ERO positions in the TSC and OSC consistent with duty roster.

• Section D - Added clarification for which RlA-45 is to be used. Respectively, it is expected that lRlA-45, 2RlA-45 and 3RlA-45 would be used in connection with Enclosure 4.3, Abnormal Rad Level/Radiological Effluent. 4R1A-45 is not specifically related to a unit and therefore it is not applicable to Enclosure 4.3.

• Section G - Removed Calendar and replaced with Note that the calendar is retained on file with EP Staff.

• Section H - Eliminated drawings of Alternate TSC and Alternate OSC as these are for implementation and not needed in Emergency Plan. Removed implementation details from Primary TSC and Primary OSC drawings. Corrected Figure H-20 and shifted table alignment.

• Section J - Provided editorial corrections to procedure numerical references where applicable.

• Section M - Provided clarification ofEOF Services listed on Figure M-2.

• Section P - Provided editorial corrections to procedure numerical references where applicable, and changed a reference from the EP Functional Area Manual to a fleet administrative procedure reference (EP FAM to AD-EP-ALL-0001). Eliminated reference to HR Emergency Plan.

• Appendix 5 - Removed all copies of the Letters of Agreement and indicated they are included by reference. The actual Letters of Agreement are retained on file by the EP Staff.

8 Rev. 2016-003 December 2016

RECORD OF CHANGES (Continued)

REVISION EFFECTIVE NUMBER DATE REASON FOR REVISIONS 2014-02 10/14

• Section A - Revised for change from pagers to notify the ERO to using cell phones. Shift Manager delegates actual activation of notification device to Security if available or qualified operator if security is unable.

• Section B - Revised responsibility for Radwaste function from Chemistry Group to Operations Group.

• Section D - Revised responsibility for Radwaste function from Chemistry Group to Operations Group, including reference to chemistry procedures to operation procedures.

• Section F - Revised for change from pagers to notify the ERO to using cell phones. Shift Manager delegates actual activation of notification device to Security if available or qualified operator if security is unable.

• Section G - Procedure number changes

• Section H - Removed specific locations of kits as these were insufficiently detailed and did not contain all kit locations.

• Section I - Procedure.number changes.

• Section J - Procedure number changes.

• Section M - Procedure number changes, title changes.

• Section N - Changes to show new rules including 8 year cycle, consistency with fleet documents practices, and format.

• Section P - Revised responsibility for independent audit from NSRB to NOS Manager, deleted duplicated paragraph and updated the listing of the implementing procedures.

• Appendix 6 - Updated distribution list to reflect new format ofE Plan and associated implementing procedures.

2014-003 12/14 Changes made associated with the modification from Raddose V to URI, and updates to WEBEOC.

2015-001 01/15 Changes made to Section F, EOF Communications and Figure F-1.

2015-002 03/15 Changes made as a result of superseding SH/O/B/2005/002, EP Fam 3.19 and Appendix 5.

2015-003 04/15 Changes made to Section D consisting of Protected Service Water replacing the Station Auxiliary Service Pump as a result of system modification. Replaced Selective Signaling with DEMNET 2015-004 5/15 E-Plan changes made to Sections App 3, D, F, H, K, & P and the Table of Contents consisting of AD-EP ALL-0203 & AD-EP ALL-0204 procedure reference changes and changes from Selective Signaling to DEMNET. Also includes title changes from Operations Shift Manager to Shift Manager.

• Appendix 3: Revised Selective Signaling to DEMNET

• Section D: Revised Selective Signaling to DEMNET and removed OSM

• Section F: Revised Selective Signaling to DEMNET, removed OSM, and SH/O/B/2005/002 to AD-EP ALL-0203

• Section H: Removed specific equipment reference to reduce E-plan revisions

• Section K: Implementation for AD-EP-ALL-0204 for administration of KI, and title changes from Operations Shift Manager to Shift Manager

• Section P: Reference updates SH/O/B/2005/003 to AD-EP ALL-0204 2015-006 9/15 E-Plan changes made to Section Hand Section P, consisting of Emergency Operating Facility (EOF) changes and revised ONS floor plans to correctly indicate ERO positions within ERFs in Section H and update procedure references in Section P.

9 Rev. 2016-003 December 2016

RECORD OF CHANGES (Continued)

REVISION EFFECTIVE NUMBER DATE REASON FOR REVISIONS 2015-007 4/16 Changes to update Letters of Agreements and references throughout; State of SC supersedes SC Highway Patrol and SC Law Enforcement Division, Greenville Health System has acquired Oconee Medical Center and Blue ridge Physicians. Change to enhance the BASIS of 4.6.U. l to add damage to 'nearby' equipment in response to AR 01910385, clarifies damage isolated to non-safety components would not necessitate entry in to an Unusual Event. Enhancement in Section D to the terms 'Condition A', which will be replaced by the term 'Imminent Failure' and 'Condition B' which will be replaced by 'Potential Failure' in 2016. The change was driven by FERC in order to minimize confusion when communicating with offsite organizations in accordance with Hydro Emergency Action Plans. Change corrected spelling from Manger to Manager on p. F-4. change 15 updated Figure J-5 to current Site Layout, added Site Support Complex, PSW Building and labeled RP Building.

2016-001 6/16 E-Plan change made to Appendix 8, Spill Prevention, Control and Countermeasure Plan (SPCC Plan), 1) revised contents of the SPCC due to change in inventory on site, addition of new used oil storage area, update to contact information and name change from Duke Power to Duke energy. 2) Moved the contents of the SPCC out of the Emergency Plan and include by reference the location as an implementing program of the Emergency Plan. Hard copy to be maintained by Environmental Services and retrievable electronically in Fusion. AR 02031855.

2016-002 9/16 Section A/Appendix 5; Revised wording to remove the requirement to update Letters of Agreement (LOA) and Memoranda ofUnderstanding(MOA) every three years, changed to review annually and revise as necessary during Emergency Plan certification review Section B; Change to keep responsibility for 'Classification' on site by SM/EC or TSC/EC after EOF is activated.

Section H; Title change from 'Backup' ERF's back to 'Alternate', changed in error in revision 2014-002 due to misinterpretation of definitions. This change will be in compliance with the definitions found in NEI 13-01, no change to the facilities.

Section M; 1) Revised ONS Spill Response procedure to Fleet Spill Response Procedure. 2) Added description ofrecovery activities following Beyond Design Basis Natural Event from INPO L4-13-3 Section P; 1) Title change to revise ONS Spill Response procedure to Fleet Spill Response Procedure.

2016-003 12/16 Section B; Revised to clarify the requirements for minimum staffing in Figure B-8b, Offsite Communicators (2), one of the Communicators is the NRC Communicator.

Section F, Clarify that ERO activation is at the discretion of the SM/EC for UE, required at Alert and higher. Clarify Site Assembly is required at an Alert or higher. Change Backup to Alternate TSC housekeeping issue per the guidance in NEI 13-01. (PRR 02080151)

Section P; 1) Title change to revise ONS Spill Response procedure to Fleet Spill Response Procedure.

Appendix 9, Removed the Ground Water Monitoring Plan from the Emergency Plan and implemented by reference, 50.54q statement added to the document and documented location in Fusion.

Appendix 10, Removed the Hazardous Materials Response Plan from the Emergency Plan and implemented by reference, 50.54q statement added to the document and documented location in Fusion.

10 Rev. 2016-003 December 2016

B. ONSITE EMERGENCY ORGANIZATION Adequate staffing to provide for initial emergency 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.

B.1. Emergency Response Organization Figures B-1 through B-6 shows the Oconee Nuclear Site Emergency Response Organization that would be established during an incident along with the duties the different groups would assume. Designation of personnel to the Emergency Response organization is determined by the particular job expertise of an individual. This assures that these personnel are qualified to carry out their responsibilities during an emergency. The normal staffing assignments at the Oconee Nuclear Site include emergency response responsibilities. See Figures B-l 0 for emergency responsibilities for designated groups.

The Emergency Response Organization is outlined in Division/Section Directives.

These directives establish the duties, responsibilities and alternates for each required emergency response position. Response procedures have been established for each section through these Directives.

B.2. Emergency Coordinator - (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />)

As a result of training and day-to-day experiences in the normal operating mode at the Oconee Nuclear Site, the Operations Shift Manager will assume authority and responsibility for any emergency that may arise at the site. He will assume control of the situation, alert and warn personnel and others, take necessary onsite remedial action, obtain necessary outside aid and notify management and appro-priate offsite agencies. The authority vested in this position by Duke Energy management enables the Operations Shift Manager to declare an emergency as necessary to protect the plant, site personnel, and the general public. He is vested with the authority to provide protective action recommendations to state and local agencies for implementing offsite emergency measures.

The Operations Shift Manager will continue with these responsibilities until relieved by the Station Manager (alternate).

B-1 Rev. 2016-003 December 2016

B.3. Alternates for Emergency Coordinator In an emergency situation where the Station Manager/Emergency Coordinator is unavailable, for whatever reason, and an acting Station Manager has not been designated in writing, an alternate will be contacted. Alternates are personnel with intimate knowledge of plant operations and will fulfill the position as TSC Emergency Coordinator when assigned duty. Alternates are designees appointed by the Station Manager.

Note: Emergency Telephone Directory, provides names and phone numbers for the Emergency Coordinators listed above.

B.4 Functional Responsibilities of the Emergency Coordinator Figure B-5 defines the duties and responsibilities of the Emergency Coordinator within the emergency response organization.

The Emergency Coordinator and the EOF Director are the individuals responsible for making protective action recommendations to the state and county agencies.

Once the Emergency Operations Facility is activated, only the EOF Director has this responsibility. Prior to the activation of the EOF, the Emergency Coordinator is responsible for making protective action recommendations, classifying/

downgrading/ escalating/terminating events, and approving notification forms to offsite agencies. Once the EOF is activated, the Emergency Coordinator will retain responsibility for making classifications. These responsibilities may not be delegated.

IF AT ANY TIME the EOF is Activated, THEN the following applies:

• Classification of events are performed by either the TSC or Control Room

• Immediate communication to the EOF is required upon upgrade of a classification of an event either the TSC or Control Room

• Notification of Offsite Agencies are performed by the EOF Protective Action Recommendations (PAR) are performed by the EOF.

B.5 Minimum Staffing Requirements for Nuclear Power Plant Emergencies Figure B-8(a/b) identifies the positions by title and major tasks to be performed by the persons assigned to the functional areas of emergency activity within 45 to 75 minutes. The TSC and OSC will be activated within 75 minutes of event classification. The EOF (Figure B-9) will also be staffed and operational by a minimum staff within 75 minutes of event classification.

A detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in Figure B-8a is located in ONS-OSSA-12212012 Rev: 0.

B-2 Rev. 2016-003 December 2016

B.6 Interface - Onsite, Offsite Organizations (Figure A-1) shows the interfaces between and among the onsite functional areas of emergency activity, site support, local services support, and State and Local government response organizations. The onsite Technical Support Center, Operational Support Center, and the Emergency Operations Facility is shown.

B. 7 Minimum Staffing Requirements - Corporate Level Personnel from the corporate location will provide assistance to the Oconee Nuclear Station in the areas of dose assessment, coordination of news media and severe accident analysis. These people will respond on an as needed basis.

The Emergency Response Facility Organization is shown on Figures B-4A through B-4D. Division/Section Directives detail the emergency response organization and are included as implementing procedures.

Should an event occur at another Duke Energy nuclear facility concurrent with an event at Oconee Nuclear Site, additional resources would be required to support the EOF Organization. Figure B-11 shows the supplemental EOF organization that would be required to manage a multi-site event. An additional Assistant EOF Director would function as the lead manager to support the second site. The EOF Director would have overall emergency management responsibility for both events.

B.8 Contractor/Private Organizations - Technical Assistance Private Contractors and/or companies that would be available to augment and support the emergency organization:

Waste Management Chem Nuclear Bartlett Nuclear Emergency Equipment Supplier SEG (e.g. Safe Industries, Inc.)

Alaron AREVA Additional groups that could respond to emergencies would be contacted by the EOF Services Group at the Emergency Operations Facility.

B-3 Rev. 2016-003 December 2016

B.9 Local Agency Support Agreements with local agency support groups have been made to assist the Oconee Nuclear Site during emergency situations.

POLICE-Oconee Sheriffs Department Pickens Sheriffs Department State of South Carolina - S. C. Highway Patrol and S. C. Law Enforcement Division AMBULANCE-Oconee Memorial Hospital - Emergency Medical Services MEDICAL-Oconee Memorial Hospital - Greenville Health System

. FIRE FIGHTING -

Oconee Rural Fire Association Keowee-Ebenezer Fire Department Corinth-Shiloh Fire Department Six-Mile Fire Department Keowee Fire Department RADIOLOGICAL MONITORING -

Pickens County Emergency Management Agency Oconee County Emergency Management Agency EVACUATION OF POPULATION -

Oconee County Emergency Management Agency Pickens County Emergency Management Agency HOSPITAL-Oconee Memorial Hospital USE OF BUILDINGS -

Oconee County School District Pickens County School District B-4 Rev. 2016-003 December 2016

FIGUREB-1 OCONEE NUCLEAR STATION EMERGENCY RESPONSE ORGANIZATION FUNCTIONAL AREAS OF EMERGENCY RESPONSE

1. Emergency Response Coordination Operations Shift Manager Station Manager Division Managers Section Managers

2. Plant Systems Operations Superintendent of Operations Operations Shift Managers Operations Engineers On Shift Staff (Operations)

Engineering

3. Accident Assessment Emergency Coordinators Operations Shift Managers Operations Engineers Shift Managers Site Engineering Severe Accident Analysis Group (GO)

4. Radiological Environmental Survey and Monitoring Contract service Radiation Protection Section

5. First Aid/Rescue, Firefighting Medical Emergency Response Team Members Fire Brigade

6. Personnel Monitoring Radiation Protection Section

7. Decontamination Radiation Protection Section B-5 Rev. 2016-003 December 2016

FIGUREB-1 OCONEE NUCLEAR STATION EMERGENCY RESPONSE ORGANIZATION

8. Security of Plant and Access Control Duke Security (ONS and Oconee JIC)

Building Security/Access & Control (Charlotte EOF)

9. Repair/Corrective Actions Nuclear Supply Chain Site Services Group

10. Personnel Accountability Division Managers Section Managers Supervisors Duke Security

11. Radiological Accident Assessment Radiation Protection Section (ONS/GO/CNS/MNS)

Site Engineering Operations Group Chemistry Group Severe Accident Analysis Group (GO)

12. Communications Operations Safety Assurance Training Nuclear Assurance

13. Radiation Protection Section Radiation Protection Section

14. Plant Chemistry Chemistry Group B-6 Rev. 2016-003 December 2016

FIGUREB-1 OCONEE NUCLEAR STATION EMERGENCY RESPONSE ORGANIZATION

15. Radwaste Operations Operations Group

16. Technical Support Site Engineering

17. Manpower Planning and Logistical Support Work Control Group Nuclear Supply Chain Site Services Group

18. Public Information Corporate Communications - Joint Information Center

19. Licensee Representative to State County EOC Site Engineering B-7 Rev. 2016-003 December 2016

FIGUREB-2 OCONEE NUCLEAR STATION TECHNICAL SUPPORT CENTER ORGANIZATION CHART I! Assistant Coordinator Emergency I Emergency WOE-News

- r JIC/Public

• Spokesperson Coordinator Group Liaison ~

(located at JI C)

~ ........................................................... .!

Asst. Engineer. Mgr. Offsite (Mech/Civil Eng) Communicators Emergency NRC Planner Communicator I I I I Operations TSC/OSC - Engineering Dose Assessment Data Coordination Superintendent Liaison Manager Liaison (as required)

I I I 2-SRO Onsite FMT Information 1-NRC Nuclear Engineering

. Coordinator Technology 1 - EOF Liaison I

Accident Assessment FMT Corporate GO (EOF) Radio Operator

............... Desired Position

- Interface Link Field Monitoring Teams B-8 Rev. 2016-003 December2016

FIGUREB-3 OCONEE NUCLEAR STATION OPERATIONAL SUPPORT CENTER ORGANIZATION CHART OSC Manager Technical Assistant I (Work Control)

Technical Assistant II Nuclear Supply Chain (Work Control) (NSC Liaison)

Security Liaison Operations Maintenance Elect. Equip. Manager RPManager Chemistry Manager Liaison Manager (Engineering)

I -SRO Shift RP Staff Chemistry Staff SPOCTeam assigned with NLO's Radiological Assessment Corporate GO (as needed)

B-9 Rev. 2016-003 December 2016

FIGUREB-4A OCONEE NUCLEAR STATION Emergency Operations Facility Assistant EOF EOF I DJ.rector I Director I

EOF Services Admin/Commissary EOF Log Emergency Recorder Planning Accident I

Radiological I

EOF Offsite I

EOF Services Assessment Assessment Agency Manager Manager Manager Communicators I

EOF Dose Assessors B-10 Rev. 2016-003 December 2016

FIGURE B-48 DUKE ENERGY COMPANY OCONEE NUCLEAR STATION EMERGENCY OPERATIONS FACILITY EOF Services Manager I I I I Food &

Administrative Communications Logistics Transportation Lodging B-11 Rev. 2016-003 December 2016

FIGUREB-4C

. OCONEE NUCLEAR STATION EMERGENCY OPERATIONS FACILITY Radiological Assessment - -

Meteorological Manager (GO Support)

I I I I Field Monitoring Dose Assessors HPN RP Status State/SC Coordinator (1) Communicator Boards Communicator I

Radio Operator I

5FMTs (2 people each team)

B-12 Rev. 2016-003 December 2016

FIGUREB-5 OCONEE NUCLEAR STATION EMERGENCY COORDINATOR DUTIES Duties and Responsibilities:

1. Activate the Emergency Response Organization (Technical Support Center, Operational Support Center and the Emergency Operations Facility).

2. Coordinate technical assistance for remedial actions to mitigate circumstances surrounding plant operations.

3. Designate individual to communicate with offsite agencies promptly. Approve all information released via the emergency notification form. Approval (signature) of contents of message form may not be delegated to others in the emergency organization.

4. Initiate emergency actions within the provisions of the Oconee Nuclear Site Emergency Plan.

5. Classify emergency events. Escalate/de-escalate or terminate from an emergency status. Responsibility may not be delegated.

6. Make senior technical and management staff available onsite for consultation with NRC and State on periodic basis ifEOF has not been activated.*

7. Coordinate all emergency actions concerning the technical aspects of the corrective actions taken within the Technical Support Center.

8. Evacuate all non-essential personnel on site if a radiological emergency exists. Be aware of exposure guidelines of personnel.

9. Recommend protective action guides for the safety and welfare of the public to the appropriate offsite agency if the Emergency Operations Facility/EOF Director is not in a position to do so. This authority may not be delegated.

10. Authorize exposures in excess of routine yearly exposure limits for lifesaving and equipment repair missions in accordance with RP /O/B/10001011. This responsibility can be delegated to the RP Manager in the OSC.

B-13 Rev. 2016-003 December 2016

FIGUREB-6 OCONEE NUCLEAR STATION EMERGENCY OPERATIONS FACILITY DIRECTOR Duties and Responsibilities:

1. Overall Management of the offsite emergency response activities of Duke Energy (Oconee Nuclear Site).

2. Recommend protective action guides for the safety and welfare of the public to the appropriate offsite agency. This authority may not be delegated.

3. Approve all information released via the emergency notification form.

Approval (signature) of contents of message form may not be delegated to others in the emergency organization.

4. Coordination with federal, state and local government agencies.

5. Provide approval of news releases if Public Spokesperson is unavailable.

B-14 Rev. 2016-003 December 2016

FIGUREB-8a OCONEE NUCLEAR STATION MINIMUM ON-SHIFT STAFFING LEVELS

, 1f'fM,aj6t Tasf<~

1. Plant Operations and CR Supervisor (SRO) 3 Assessment of Control Room Operator (RO) 6 Operational Aspects a Non-Licensed Operator NLO) 3

2. Emergency Direction Command and Control Ops Shift Manager 1 and Control

3. Notification &

Communication Dose

................... Assessment

-................ RP Qualified Individual_,_,_,,,...............................................................

- ........................................................- ...................................................................................................................................... 1 .

4. Radiological .!!!:Pl§!!.~_§!:l_i:Y.~Y~-- _------*----- _B.E_Q!:l al ifLe_<i!r.:i_g_i.':d~!:l-~-----------*-- __._J ____

Assessment Onsite §.~~X.~--------*--*--- _RP Qualifie~_!!Q)yid_uaL ___________1__

Chemistry Chemistry Technician 1 Tech Support - OPs Shift Technical Advisor 1

5. Plant System Engineering, Repair, *---**-----***-- __ ::_9..~~~.-~?.Et.~_?9.~ :§.6Hff.~.~fr6.I~~L~~0§.9.r.=:::::=::***::*::=:: ::~:~J~~*:=

Repair and Corrective Mechanical Maintenance 2 and Corrective Actions Actions IAE Maintenance 2 Radiation Protection

6. In-Plant PAs (such as access control, job RP Qualified Individual 2(b) coverage and personnel monitoring Fire Brigade Lead (SRO/NLO) 1

7. Fire Fighting (c) Fire Brigade Member (NLO) 4 Fire Bri ade Member 5(b,c) 5

8. 1 Aid and Rescue MERT d 2

9. SAS Operator 1 Securit Personnel e (a) The Control Room staff complement is reflective of 3 Units in operation.

(b) May be performed by an individual filling another position provided they are qualified to do the collateral function.

(c) The Fire Brigade requirement of ten members is met by using five personnel from Operations (including the Fire Brigade Leader) and five personnel from either SPOC, Radiation Protection, Chemistry or Security (SLC 16.13.1).

(d) The Medical Emergency Response Team (MERT) can be filled by any qualified technician.

(e) Per Duke Energy ONS Security Plan.

B-15 Rev. 2016-003 December 2016

FIGUREB-8b OCONEE NUCLEAR STATION MINIMUM AUGMENTED ERO STAFFING LEVELS MAJOR FUNCTIONAL AREA MAJOR TASKS POSITION TITLE OR CAPABILITY EXPERTISE FOR ADDITIONS*

WITHIN45 WITHIN75 MINUTES MINUTES Emergency Director and Control Station Manager - 1 (Emergency. Coordinator) ***

Notification/Communication Notify Company Personnel, State, State/County Communicator 1 County, Federal Agencies and NRC Communicator 1 maintain communication EOF/Radiological Accident Assessment EOF Director (Protective Action DPC Senior Manager - 1 and Offsite Agency Support Recommendation, Offsite Agency Interface, ENF approval)

EOF Plant Assessment Accident Assessment Manager - 1 Dose Assessment and EOF Offsite Dose Assessment/ Radiological Assessment Protective Action Protective Action Manager - 1 Recommendations Recommendations Offsite Notifications EOF Offsite Agency Notifications Offsite Agency Communicator - 1 Offsite. Agency Communicator - 1 EOF Access Control Electronic Card Reader - #

Dose Assessment and TSC Dose Assessment/Protective Radiological Assessment - 1 Protective Action Action Recommendations Recommendations Offsite Surveys Field Monitoring Teams (2) 4 ****

Onsite Surveys (Out-of-Plant) RP Qualified Individuals 1 1 In-Plant Surveys RP Qualified Individuals 1 1 Chemistry/Radio Chemistry Rad/Chem Technician 1 Plant System Engineering, Repair and Technical Support Core/Thermal Hydraulics - 1 Corrective Actions Electrical - 1 Mechanical 1 Repair and Corrective Actions Mechanical Maintenance - 1 Rad/Waste Operator - 1 l&E Technician 2 Protective Actions Radiation Protection RP Qualified Individuals - 4 (In-Plant) A. Access Control B. RP Coverage for Repair Corrective Actions, Search and Rescue, First Aid & Firefighting C. Personnel Monitoring D. Dosimetry E. On-Shift Dose Assessment Firefighting - Fire Brigade Local Support Rescue Operations & First-Aid - MERTTeam Local Support B-16 Rev. 2016-003 December 2016

FIGUREB-8b OCONEE NUCLEAR STATION MINIMUM STAFFING LEVELS

• Consideration is given to the fact that many of the Oconee Nuclear Site Emergency Response Organization personnel do not live within a radius of the station which will allow a response time of 30 minutes or less under ideal conditions. Factors such as weather conditions, road capacity and traffic density, and the distance to travel from residence to the emergency response facility, indicate a realistic response time from a few minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes for most employees. Consideration is also given to personnel on shift who are qualified and sufficient in number to handle any emergency condition until response personnel begin to arrive on site.

• • • Management of the Offsite Emergency Response will be assumed by the EOF Director when the Emergency Operations Facility is activated.

Management of the Onsite Emergency Response is assumed by the Station Manager/alternate acting as the Emergency Coordinator when the Technical Support Center and Operational Support Centers are activated.

• • • • The Field Monitoring Teams will initially report to the Body Burden Analysis (BBA)

Room. If needed, the Field Monitoring Teams will dispatch from the Body Burden Analysis (BBA) Room. Once the Emergency Operations Facility (EOF) Field Monitoring Coordinator is ready he/she will assume control of the Field Monitoring Teams. A FMT consists of one RP qualified individual and one vehicle driver.

1. An electronic card reader in conjunction with a posted building security officer fulfills the function for controlling access to the EOF during emergencies.

B-17 Rev. 2016-003 December 2016

FIGUREB-9 OCONEE NUCLEAR STATION MINIMUM STAFFING REQUIREMENTS EOF DIRECTOR I I Accident Assessment Radiological Assessment Manager Offsite Agency Communicator (2)

I Manager B-18 Rev. 2016-003 December 2016

FIGURE B-10 OCONEE NUCLEAR STATION ONSITE EMERGENCY RESPONSE DUTIES RADIATION CHEMISTRY MAINTENANCE OPERATIONS WORK CONTROL BUSINESS PROTECTION GROUP Onsite Monitoring Post-accident liquid Repair/calibration of Plant Operations OSC Coordination Provide personnel sampling electrical and for field mechanical equipment monitoring teams Initial dose assessment Chemistry analysis StaffOSC with onshift Accident assessment Recovery implementation personnel Decontamination Augment OSC with Safe shut-down of Provide personnel for field additional personnel reactor monitoring teams Post-accident gaseous Liaison with OSC sampling Dose Control Fire brigade response Provide personnel for Initial Emergency field monitoring teams Management Evacuation coordination NRC Communications RP support for work tasks Fire Support in the field Tank Farm Operation Radwaste Operation B-19 Rev. 2016-003 December 2016

FIGUREB-10 OCONEE NUCLEAR STATION ONSITE EMERGENCY RESPONSE DUTIES Organizational Effectiveness ENGINEERING SECURITY SAFETY NUCLEAR SUPPLY CHAIN SITE SERVICES GROUP TSCLOG ACCESS & CONTROL COMMUNICATIONS EQUIPMENT OFF SITE TSC/OSC LIAISON EVACUATION SUPPLY/PARTS COMMUNICATIONS TECHNICAL ASSISTANT COORDINATION ASSIST WITH ENGINEERING SUPPORT MEDICAL (MERT) PERSONNEL HEAVY EQUIPMENT ACCOUNTABILITY SAFETY OPERATORS REPORTING ASSIST WITH EVACUATION LIAISON WITH CORPORATE COMMISSARY ACCIDENT ASSESSMENT GROUP EMERGENCY PLANNING TSC STATUS BOARDS B-20 Rev. 2016-003 December 2016

FIGUREB-11 OCONEE NUCLEAR STATION Common EOF - Multi-Site Event Staffmg Assistant EOF I I EOF Director (1)

I Director (2)

I I I I Log Reco.rder (2)

FMT Coordinator (2) FMT Radio EOF Emergency - Operator (2)

Planner (2)

I I I Accident EOF Radiological EOF Off site Agency EOF Services Assessment Manager (2)

Assessment Manager (2)

I Communicators (6)

I I Manager (1)

I I I I I EOF Dose Accident CNS/MNS Ops Assessors (4)

Assessment Interface (1)

Intertace (2)

1. Notification Devices activated for second unit - all call response

2. Assistant EOF Director assumes responsibility as lead manager for designated Site

3. Additional Log Keeper retained to support 2nd Site

4. Additional Accident Assessment Manager retained to support 2nd Site

5. Additional Dose Assessor retained to support 2nd Site 6 Additional FMT Coordinator retained to support 2nd Site

7. Additional FMT Radio Operator retained to support 2nd Site

8. Four additional Offsite Communicators as needed to support both Sites

9. Additional Emergency Planner as needed to support 2nd Site

10. Additional Radiological Assessment Manager as needed to support 2nd Site

11. Additional Assistant EOF Director as needed to support 2nd Site

12. Oconee Ops Interface position is staffed in the ONS TSC

13. Additional Accident Assessment Interface as needed to support 2nd Site B-21 Rev. 2016-003 December 2016

F. EMERGENCY COMMUNICATIONS Provisions exist for prompt communications among principal response organizations, emergency personnel, and to the public.

F .1 Emergency Response Organization The Emergency Response Organization has been developed in such a manner to list primary and alternate personnel. Primary and backup means of communication have been established between the Site, local government agencies, and State response organizations (Figure F-1 ).

F.l.a Calls to activate State/County agency's emergency function are the responsibility of the Shift Manager/Emergency Coordinator. These calls are made by:

1. Duke Emergency Management Network (DEMNET).

2. The site telephone system to a 24-hour emergency number.

Some agencies have numbers for designated work schedules. Numbers can be found in the Emergency Telephone Directory.

A back-up radio system provides alternate communications with Oconee and Pickens Counties emergency response organizations. (Figure F-2)

F.1.b On a monthly basis, a communication check is made to state and local government warning points within the Emergency Planning Zone.

Communications during an emergency situation would be by DEMNET, site telephone system/commercial phone service, or by radio (where appropriate).

F. l .c The EOF organization has the responsibility to ask for federal response.

However, communication with the Nuclear Regulatory Commission from the emergency response facilities, would be by use of the Emergency Telecommunication System (ETS) located in the Control Room areas, Technical Support Center, or the Emergency Operations Facility.

F-1 Rev. 2016-003 December 2016

F. EMERGENCY COMMUNICATIONS F. l .d The Emergency Response Organization has the following communications systems available for use during emergencies:

1) Oconee Nuclear Station Telephone System (Generator backed and battery backed)

Fiber-Optic to Charlotte GO (65 lines)

Telephone line to Easley (6 circuits)

Anderson (4 lines)

Six-Mile (4 lines)

Site Telephone System - Inward and outward direct dial available from the Control Room, TSC, and OSC

2) _Commercial phone service does not go through the site telephone system

3) Duke Emergency Management Network (DEMNET)

DEMNET is the primary means of communication with the offsite agencies.

DEMNET uses digital voice manager technology and IP connectivity through either the internet or a dedicated satellite connection, resulting in redundant paths to ensure operability. DEMNET allows intercommunication among the EOF, TSC, control room, counties, and states.

Oconee County Pickens County State Warning Point State Emergency Operations Center (Columbia)

Emergency Operations Facility (Charlotte)

Technical Support Center Control Rooms 1&2, Alternate TSC/OSC (OOB)

Alternate Reporting Location (Issaqueena Trail)

4) Emergency Radio System (Offsite System-Battery Backed)

Control Room Units 1&2 (48.5 MHZ)

Technical Support Center Field Monitoring Teams (800 MHZ)

Pickens County (48.5 MHZ)

Oconee County (48.5 MHZ)

State of South Carolina F-2 Rev. 2016-003 December 2016

F. EMERGENCY COMMUNICATIONS

5) Radio Systems (Onsite) (Emergency Back-up Power by Keowee Hydro Units)

Control Room 1&2, 3 Fire Brigade Chemistry Safety Radiation Protection Maintenance Medical Emergency Response Team Hazardous Materials Response Team

6) Security *Radio System (Emergency Back-up Power by Standby Shutdown Facility)

CAS/SAS All Security Guards Oconee County LEC Control Room 1&2, 3

7) Public Address (PA) System Oconee Nuclear Station (Protected Area)

Oconee Office Building Oconee Administration Building Oconee Complex Oconee Maint. Training Facility (Unique Page Number)

Oconee Garage (Unique Page Number)

Oconee Training Facility (Unique Page Number)

Keowee Hydro Station (Unique Page Number)

World of Energy

8) Site Assembly Warning System Paging by Control Room Warble Tone over PA Siren Assembly Hom (Outside Warning)

F-3 Rev. 2016-003 December 2016

F. EMERGENCY COMMUNICATIONS

9) EOF Communication System (Energy Center has back-up generator power)

The emergency communications systems at the Charlotte EOF are designed to ensure the reliable, timely flow of information between all parties having an emergency response role. The DEMNET is the primary means of communicating changes in event classification and protective action recommendations to the state and counties. The Decision Line provides the state and counties with a dedicated line to discuss and coordinate protective action recommendations. Existing commercial telephone service will serve as the designated backup means for communications in the event of a DEMNET/

Decision Line failure.

Duke Telephone System (battery backed)

DEMNET (for state/county notifications)

Decision Line (for discussions/coordination of PARs)

Commercial telephones from the Charlotte switch network Radio System to communicate with the Field Monitoring Teams NRC Emergency Telecommunications System phones Satellite Telephone F. l .e Recall of Emergency Response Organization Activation of the ERO is at the discretion of the SM/EC for an Unusual Event.

Activation of the ERO is required at an Alert or higher. Should an emergency occur that will require activation of the Emergency Response Organization, the Shift Manager will require the following actions to occur:

Normal Working Hours (Figure A-2A)

1. Have announced over the Public Address system that the Emergency Response Organization (Technical Support Center and Operational Support Center) are to be staffed.

2. Security will activate the ERO. If security is unable to activate the ERO, the SM (or designee) will activate the ERO.

3. Notify Duty Operations Engineer who verifies Plant Manager and Superintendent of Operations have been notified.

4. Initiate a Site Assembly (Required at an Alert or higher).

5. Individual groups will contact corporate personnel for support.

F-4 Rev. 2016-003 December 2016

EMERGENCY COMMUNICATIONS Weekends, Holidays, Backshift (Figure A-2B)

1. Security will activate the ERO. If security is unable to activate the ERO, the SM (or designee) will activate the ERO.

2. Duty Operations Engineer who verifies Plant Manager and Superintendent of Operations have been notified.

3. Announce over the PA system that the Emergency Response Organization (Technical Support Center and Operational Support Center) is to be activated.

4. Initiate a Site Assembly (Required at an Alert or higher).

5. Individual groups will contact corporate personnel for support.

F. l .f Redundant two way communication exists for communication with the Nucle.ar Regulatory Commission. The ETS system, the regular site or EOF telephone system exists for the communication link with NRC. (Figure F-1)

F .2 Medical Support Communication Link Operations and/or Security will utilize the public address system and radio pager system to activate the Medical Emergency Response Team to respond to a medical emergency to assess the situation and render first aid. If an ambulance is needed, Operations and/or Security will call for an ambulance to be dispatched from the Oconee Memorial Hospital by one of several ways:

1. Regular ONS switchboard line

2. Outside line (Commercial Phone Service)

3. DEMNET to Oconee County who then would contact Oconee Memorial Hospital. (Operations only)

4. Radio in the Control Room and/or CAS/SAS to Oconee County, who then would contact the Oconee Memorial Hospital.

F-5 Rev. 2016-003 December 2016

EMERGENCY COMMUNICATIONS However, should an emergency at the Oconee Nuclear Station cause the Emergency Response Organization to be activated, personnel will staff the Operational Support Center who can respond to a medical emergency.

Calls will be made from the Operational Support Center for additional medical assistance (i.e. ambulance transport and hospital contact).

F.3 Periodic Testing of the Emergency Communications System Testing of the Emergency Communications System will be tested on a monthly and a quarterly basis in accordance with site procedures. Phones and radios will be checked to determine their availability.

F-6 Rev. 2016-003 December 2016

FIGURE F-1 DUKE ENERGY COMPANY OCONEE NUCLEAR STATION EMERGENCY COMMUNICATIONS SYSTEM Organization Commercial ONS DEMNET DPC DPC DPC State Decision ETS EOFPhone Phone Site Offsite Onsite Mcrwav. LGR Line System System Service Phone Radio Radio System Radio Private Line System System System System Control Room x x x x x x x x Technical Support Center x x x x x x x x Operational Support x x x x Center Emergency Operations x x x x x x x Facility Pickens LEC x x x x x x Pickens BOC x x x x x x x OconeeLEC x x x x x x Oconee BOC x x x x x x State BOC x x x x x x State FEOC x x x x x x x NRC Headquarters x x x x NRC Region II x x x x F-7 Rev. 2016-003 December 2016

FIGUREF-2 DUKE ENERGY COMPANY OCONEE NUCLEAR STATION EMERGENCY RADIO NETWORK The offsite emergency radio network at the Oconee Nuclear Station (ONS) is specifically limited to use in an emergency event. The network consists of two radio frequencies which provide the following services:

A. 48.5 MHZ Backup communications between ONS, Pickens County Emergency Preparedness Agency and Oconee County Emergency Preparedness Agency.

Operating instructions are shown in the Emergency Telephone Directory and AD-EP-ALL-0203 (Protocol for the Field Monitoring Coordinator During Emergency Conditions)

B. 800MHZ Provide communications between Field Monitoring Team Coordinator and field teams.

Base station radios are located in the TSC and Alternate TSC Operating instructions are located in AD-EP-ALL-0203 (Protocol for the Field Monitoring Coordinator During Emergency Conditions)

F-8 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of the Emergency Plans To assure that responsibilities for plan development, review and distribution of emergency plans are established and that planners are properly trained:

P .1 Training for Emergency Preparedness Personnel Training for emergency preparedness personnel shall be provided in the form of workshop/seminar sessions on an annual basis. Courses developed by the Duke Training Center are also available in technically related subjects that will enhance the working knowledge of these people .

P.2 & P.3 .Overall Authority The Site Vice-President has the overall authority and responsibility for all hazards emergency response planning. The planning effort is delegated to the Manager, Emergency Preparedness.

The Manager of Emergency Preparedness at the Oconee Nuclear Site shall have the responsibility for the development, review and coordination of the site emergency plans with other response organizations and shall be responsible for conducting the biennial exercise, drills and training sessions to test the Oconee Nuclear Site Emergency Plan. This person is employed in the Safety Assurance Group.

P.4 & P.5 Review and Update of Emergency Plan The ONS Emergency Plan shall be reviewed and updated annually. An in-depth review of the Emergency Plan will be made to determine if any/all changes have been made as a result of drills, exercises, commitments, audits, new regulatory requirements, and any other identified mechanism used to determine the appropriateness of the Emergency Plan. The Manager of Emergency Preparedness or designee is responsible for conducting the review and updating/revising the Emergency Plan and/or Implementing Procedures, as required. Once the review has been completed and changes made as determined, the Emergency Plan shall be certified as current.

Approved revisions of the Emergency Plan and Implementing Procedures shall be distributed according to Appendix 6, (Distribution of Emergency Plan and Implementing Procedures). Appendix 6 carries an itemized list of all organizations and individuals receiving copies of the Emergency Plan and Implementing Procedures. Revised pages of the Emergency Plan shall be dated and marked to show where changes have been made.

P-1 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES P .6 Supporting: Plans Figure P-2 lists plans in support of the ONS Emergency Plan.

P. 7 Implementing Procedures Written procedures will be established, implemented and maintained covering the activities associated with emergency plan implementation. Each procedure and changes thereto, shall be approved by the responsible manager prior to implementation.

Implementing procedures are indexed and cross referenced to the section applicable in NUREG 0654. (Figure P-1)

P .8 Table of Contents The Oconee Nuclear Site Emergency Plan and Implementing Procedures contain a table of contents and an index tab system.

P.9 Independent Audit The NOS Audit Manager will arrange for an independent review of Oconee Nuclear Station's Emergency Preparedness Program as necessary, based on an assessment against performance indicators, and as soon as reasonably practicable after a change occurs in personnel, procedures, equipment, or facilities that potentially could adversely affect emergency preparedness, but no longer than 12 months after the change. In any case, all elements of the emergency preparedness program will be reviewed at least once every 24 months. Guidance for performing the assessment against the performance indicators is provided in the Emergency Preparedness Administrative Procedure AD-EP-ALL-0001. The independent review will be conducted by the Independent Nuclear Oversight Division, which will include the following plans, procedures, training programs, drills/exercises, equipment, and State/local government interfaces:

1. Oconee Nuclear Station Emergency Plan

2. Oconee Nuclear Station Emergency Plan Implementing Procedures

3.

• State/Local Support Agency Training Program

4. Site Emergency Response Training Program

5. Public & Media Training/Awareness

6. Equipment: Communications, Monitoring, Meteorological, Public Alerting

7. State/Local Plan Interface The review findings will be submitted to the appropriate corporate and nuclear site management. The part of the review involving the evaluation of the adequacy of P-2 Rev.2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES interface with State and local governments will be reported to the appropriate State and local governments. Corporate or nuclear site management, as appropriate, will evaluate the findings affecting their area of responsibility and ensure effective corrective actions are taken. The results of the review, along with recommendations for improvements, will be documented, and retained for a period of five (5) years.

P .10 Phone Number Update The Emergency Telephone Directory is updated quarterly.

P-3 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented Assignment of Responsibility A1a ONS E Plan ONS Emergency Plan, Appendix 5 Agreement Letters A1b RP/O/A/1000/002 Control Room Emergency Coordinator Procedure RP/O/A/1000/019 Technical Support Center Emergency Coordinator Procedure RP/O/A/1000/025 Operational Support Center Manager Procedure AD-EP-ALL-0107 Standard Procedure for EOF Services SR/O/A/2000/003 Activation of the Emergency Operations Facility A1c ONS E Plan ONS Emergency Plan, Fig A 1 A1d RP/O/A/1000/002 Control Room Emergency Coordinator Procedure SR/O/A/2000/003 Activation of the Emergency Operations Facility A1e RP/O/A/1000/002 Control Room Emergency Coordinator Procedure A2a NA State/County Responsibility A2b NA State/County Responsibility A3 ONS E Plan ONS Emergency Plan, Appendix 5 A4 RP/O/A/1000/002 Control Room Emergency Coordinator Procedure RP/O/A/1000/019 Technical Support Center Emergency Coordinator Procedure RP/O/A/1000/025 Operational Support Center ManaQer Procedure SR/O/A/2000/003 Activation of the Emergency Operations Facility On-Site Emergency Organization 81 ONS E Plan ONS Emergency Plan NSD-117 Emergency Response Organization Staffing, Training, and Responsibilities RP/O/A/1000/002 Control Room EmerQency Coordinator Procedure RP/O/A/1000/019 Technical Support Center Emergency Coordinator Procedure RP/O/A/1000/022 Procedure For Major Site Damage Assessment And Repair RP/O/A/1000/029 Fire Brigade Response AD-EP-ALL-0107 Standard Procedure for EOF Services 82 RP/O/A/1000/002 Control Room EmerQency Coordinator Procedure RP/O/A/1000/019 Technical Support Center Emergency Coordinator Procedure SR/O/A/2000/003 Activation of the Emergency Operations Facility 83 RP/O/A/1000/002 Control Room Emergency Coordinator Procedure RP/O/A/1000/019 Technical Support Center Emergency Coordinator Procedure SR/O/A/2000/003 Activation of the Emergency Operations Facility 83 NSD-117 Emergency Response Organization Staffing, Training, P-4 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented and Responsibilities 84 RP/O/N1000/002 Control Room Emergency Coordinator Procedure RP/O/N1000/019 Technical Support Center Emergency Coordinator Procedure SR/O/N2000/003 Activation of the Emerqency Operations Facility NSD-117 Emergency Response Organization Staffing, Training, and Responsibilities 85 OMP 2-16 Shift Turnover NSD-117 Emergency Response Organization Staffing, Training, and Responsibilities RP/O/N1000/019 Technical Support Center Emergency Coordinator Procedure RP/0/N1000/025 Operational Support Center Manager Procedure SR/O/N2000/003 Activation of the Emergency Operations Facility 86 ONS E Plan ONS Emergency Plan NSD-117 Emergency Response Organization Staffing, Training, and Responsibilities SR/O/N2000/003 Activation of the Emergency Operations Facility AD-EP-ALL-0107 Standard Procedure for EOF Services 87a-d NSD-117 Emergency Response Organization Staffing, Training, and Responsibilities SR/O/N2000/003 Activation of the Emergency Operations Facility AD-EP-ALL-0107 Standard Procedure for EOF Services RP/O/N1000/027 Re-Entry Recovery Procedure RP/O/N1000/031 Joint Information Center Emergency Response Plan 88 ONS E Plan ONS Emergency Plan, Appendix 5 89 ONS E Plan ONS Emergency Plan, Appendix 5 Emergency Response Support and Resources C1a, b,c ONS E Plan ONS Emergency Plan, Appendix 5 SR/O/N2000/003 Activation of the Emergency Operations Facility RP/O/N1000/031 Joint Information Center Emergency Response Plan RP/O/N1000/037 Incident Command Post (ICP) Operations and Radiation Protection Liaison Guidelines C2a NA State/County Responsibility C2b EP FAM 3.11 State/County EOC Liaison Reference Manual RP/O/N1000/037 Incident Command Post (ICP) Operations and Radiation Protection Liaison Guidelines C3 HP/0/8/1009/026 Environmental Monitoring For Emergency Conditions C4 ONS E Plan ONS Emergency Plan, Appendix 5 SR/O/N2000/003 Activation of the Emergency Operations Facility Emergency Classification System P-5 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented 01a, b, c ONS E Plan ONS Emergency Plan RP/O/A/1000/001 Emerqencv Classification 02 RP/O/A/1000/001 Emergency Classification 03 NA State/County Responsibility 04 NA State/County Responsibility Notification Methods and Procedures E1 RP/O/A/1000/002 Control Room Emergency Coordinator Procedure RP/O/A/1000/015A Offsite Communications From The Control Room RP/O/A/1000/0158 Offsite Communications From The Technical Support Center RP/0/Al 1000/019 Technical Support Center Emergency Coordinator Procedure RP/O/A/1000/024 Protective Action Recommendations SR/O/A/2000/003 Activation of the Emergency Operations Facility E2 RP/O/A/1000/002 Control Room Emergency Coordinator Procedure E3 RP/O/A/1000/002 Control Room Emergency Coordinator Procedure RP/O/A/1000/015A Offsite Communications From The Control Room RP/O/A/1000/0158 Offsite Communications From The Technical Support Center RP/O/A/1000/019 Technical Support Center Emergency Coordinator Procedure RP/O/A/1000/024 Protective Action Recommendations SR/O/A/2000/003 Activation of the Emergency Operations Facility SR/O/A/2000/004 Notification to States and Counties Facility for Catawba, McGuire, and Oconee E4a-n RP/O/A/1000/002 Control Room Emergency Coordinator Procedure RP/O/A/1000/015A Offsite Communications From The Control Room RP/O/A/1000/0158 Offsite Communications From The Technical Support Center RP/O/A/1000/019 Technical Support Center Emergency Coordinator Procedure RP/O/A/1000/024 Protective Action Recommendations SR/O/A/2000/003 Activation of the Emergency Operations Facility E5 NA State/County Responsibility E6 EP FAM 3.3 Alert and Notification System (Siren Program)

E? RP/O/A/1000/024 Protective Action Recommendations SR/O/A/2000/003 Activation of the Emerqency Operations Facility ES RP/O/A/1000/017 Spill Response Emergency Communications F1a RP/O/A/1000/002 Control Room Emergency Coordinator Procedure F1a RP/O/A/1000/015A Offsite Communications From The Control Room RP/O/A/1000/0158 Offsite Communications From The Technical Support Center P-6 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented RPIOIA/10001019 Technical Support Center Emergency Coordinator Procedure SRIOIA/20001003 Activation of the Emergency Operations Facility F1b PTIOIA/20001002 Periodic Test of Emergency Response Communications Equipment F1c RPIOIA/10001002 Control Room Emergency Coordinator Procedure RPIOIA/1 OOOI015A Offsite Communications From The Control Room RPIOIA/100010158 Offsite Communications From The Technical Support Center RPIOIA/10001019 Technical Support Center Emergency Coordinator Procedure RPIOIA/1 OOOI003A EROS Operation PTIOIA/20001009 EmerQency Response Data System Quarterly Test SRIOIA/20001003 Activation of the Emergency Operations Facility F1d PTIOIA/20001002 Periodic Test of Emergency Response Communications Equipment STIOIA/46001086 Standard Procedure For Periodic Verification of EOF Communication Equipment Operation and Equipment/

Supply Inventory-STIOIA/46001094 Standard Procedure For Periodic Test Of The EOF Selective Signaling, ENS and ETS F1e RPIOIA/10001002 Control Room Emergency Coordinator Procedure F1f PTIOIA/20001002 Periodic Test of Emergency Response Communications Equipment RPIOIA/10001003 A EROS Operation PTIOIA/20001009 Emergency Response Data System Quarterly Test F2 PTIOIA/20001002 Periodic Test of Emergency Response Communications Equipment RPIOIA/10001016 MERT Activation Procedure For Medical, Confined Space, and High Angle Rescue Emergencies RPIOIA/10001025 Operational Support Center ManaQer Procedure F3 PTIOIA/20001002 Periodic Test of Emergency Response Communications Equipment PTIOIA/20001009 Emergency Response Data System Quarterly Test Public Education and Information G1a,b,c EP FAM 3.6 Alert and Notification System - Oconee Specific Supplement NPM Chapter 15 Corporate Communications Departmental Interface AQreement G2 EP FAM 3.6 Alert and Notification System - Oconee Specific Supplement NPM Chapter 15 Corporate Communications Departmental Interface AQreement G3a, b RPIOIA/10001028 Nuclear Communications Emergency Response P-7 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented Plan RP/O/A/1000/031 Joint Information Center Emergency Response Plan SR/O/A/2000/001 Standard Procedure For Corporate Communications Response To The Emergency Operations Facility G4a, b, c RP/O/A/1000/028 Nuclear Communications Emergency Response Plan RP/O/A/1000/031 Joint Information Center Emergency Response Plan SR/O/A/2000/001 Standard Procedure For Corporate Communications Response To The Emergency Operations Facility GS NPM Chapter 15 Corporate Communications Departmental Interface Agreement Emergency Facilities and Equipment H1a, b,c RP/O/A/1000/019 Technical Support Center Emergency Coordinator Procedure RP/O/A/1000/025 Operational Support Center Manager Procedure HP/O/B/1009/001 Emergency Equipment Inventory and Instrument Check PTIOIA/2000/002 Periodic Test of Emergency Response Communications Equipment PTIOIA/2000/008 Procedure to Verify the Availability of Supplies and Equipment in the Emergency Response Facilities PT/O/A/2000/010 Review of Emergency Plan and Implementing Procedures H2 SR/O/A/2000/003 Activation of the Emergency Operations Facility ST/O/A/4600/086 Standard Procedure For Periodic Verification of EOF Communication Equipment Operation and Equipment/Supply Inventory ST/O/A/4600/094 Standard Procedure For Periodic Test Of The EOF Selective Signaling, ENS and ETS H3 NA State/County Responsibility H4 NSD-117 Emergency Response Organization Staffing, Training, and Responsibilities RP/O/A/1000/002 Control Room Emergency Coordinator Procedure H4 RP/O/A/1000/019 Technical Support Center Emergency Coordinator Procedure RP/O/A/1000/025 Operational Support Center Manager Procedure RP/O/A/1000/031 Joint Information Center Emergency Response Plan SR/O/A/2000/003 Activation of the Emergency Operations Facility SR/O/A/2000/001 Standard Procedure For Corporate Communications P-8 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented Response To The Emerqency Operations Facility AD-EP-ALL-0107 Standard Procedure for EOF Services HS RPIOIA/10001001 Emergency Classification H5a, b,c,d ONS E Plan ONS Emergency Plan IP1018116011003 Meteorological Equipment Checks H6a, b,c ONS E Plan ONS Emergency Plan IPIOIBl16011003 Meteorological Equipment Checks ONS ODCM ONS Offsite Dose Calculation Manual HPIOIBl10091001 Emergency Equipment Inventory and Instrument Check HPIOIBl10091023 Radiation Protection Emergency Response PTIOIA/20001008 Procedure to Verify the Availability of Supplies and Equipment in the Emergency Response Facilities STIOIA/46001086 Standard Procedure For Periodic Verification of EOF Communication Equipment Operation and Equipment/Supply Inventory PT1018102501030 Quarterly Fire Briqade Equipment Inspection PT1018102501032 Quarterly Inspection Of Emergency Medical Equipment PT1018102501045 Quarterly Inspection Of Hazardous Materials Response Team Equipment CPIOIBl20011008 Chemistry Safety Equipment And Spill Control

Response

RPIOIA/10001017 Spill Response H7 HPIOIBl10091001 Emergency Equipment Inventory and Instrument Check HPIOIBl10091023 Radiation Protection Emergency Response H8 ONS E Plan ONS Emerqency Plan IPIOIBl16011003 Meteorological Equipment Checks AD-EP-ALL-0202 Emergency Response Offsite Dose Assessment RPIOIA/10001024 Protective Action Recommendations H9 ONS E Plan ONS Emerqency Plan IPIOIBl16011003 Meteoroloqical Equipment Checks ONS ODCM ONS Offsite Dose Calculation Manual HPIOIBl10091001 Emergency Equipment Inventory and Instrument Check H9 PTIOIA/20001008 Procedure to Verify the Availability of Supplies and Equipment in the Emergency Response Facilities STIOIA/46001086 Standard Procedure For Periodic Verification of EOF Communication Equipment Operation and Equipment/Supply Inventory PT1018102501030 Quarterly Fire Brigade Equipment Inspection PT1018102501032 Quarterly Inspection Of Emergency Medical P-9 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented Equipment PT/O/B/0250/045 Quarterly Inspection Of Hazardous Materials Response Team Equipment CP/O/B/2001/008 Chemistry Safety Equipment And Spill Control Response RP/O/A/1000/025 Operational Support Center Manager Procedure H10 ONS E Plan ONS Emergency Plan IP/O/B/1601/003 Meteorological Equipment Checks ONS ODCM ONS Offsite Dose Calculation Manual HP/O/B/1009/001 Emergency Equipment Inventory and Instrument Check PTIOIA/20001008 Procedure to Verify the Availability of Supplies and Equipment in the Emen::1ency Response Facilities ST/O/A/4600/086 Standard Procedure For Periodic Verification of EOF Communication Equipment Operation and Equipment/Supply Inventory PT/O/B/0250/030 Quarterly Fire Brigade Equipment Inspection PT/O/B/0250/032 Quarterly Inspection Of Emergency Medical Equipment PT/O/B/0250/045 Quarterly Inspection Of Hazardous Materials Response Team Equipment CP/O/B/2001/008 Chemistry Safety Equipment And Spill Control

Response

H11 ONS E Plan ONS Emergency Plan, Section H.11 H12 HP/O/B/1009/023 Radiation Protection Emergency Response AD-EP-ALL-0203 Protocol for the Field Monitoring Coordinator During Emergency Conditions SR/O/A/2000/003 Activation of the Emergency Operations Facility Accident Assessment 11 ONS E Plan ONS Emerqencv Plan, Section D RP/O/A/1000/001 Emergency Classification 12 ONS E Plan ONS Emergency Plan RP/O/A/1000/018 Core Damage Assessment CSM 5.1 Emergency Response Guidelines 12 CSM 5.2 Procedure Use Guidelines During Emergency

Response

CP/1/A/2002/002 Rheodyne Sample Via Post Accident Liquid Sampling System (PALSS)

CP/2/A/2002/002 Rheodyne Sample Via Post Accident Liquid Sampling System (PALSS)

CP/3/A/2002/002 Rheodyne Sample Via Post Accident Liquid Sampling System (PALSS)

HP/O/B/1009/009 Procedure For Determining The lnplant P-10 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented Radioiodine Concentration During Accident Conditions HP/O/B/1009/015 Procedure For Sampling And Quantifying High Level Gaseous, Radioiodine And Particulate Radioactivity HP/O/B/1009/026 Environmental Monitoring For Emergency Conditions AD-EP-ALL-0202 Emergency Response Offsite Dose Assessment AD-EP-ALL-0203 Protocol for the Field Monitoring Coordinator During Emergency Conditions 13a, b RP/O/A/1000/001 Emergency Classification RP/O/A/1000/024 Protective Action Recommendations HP/O/B/1009/022 On-Shift Off-Site Dose Projections ONS ODCM ONS Offsite Dose Calculation Manual AD-EP-ALL-0202 Emergency Response Offsite Dose Assessment 14 HP/O/B/1009/018 Off-Site Dose Projections HP/O/B/1009/022 On-Shift Off-Site Dose Projections AD-EP-ALL-0202 Emergency Response Offsite Dose Assessment 15 RP/O/A/1000/002 Control Room Emergency Coordinator Procedure RP/O/A/1000/003 A EROS Operation RP/O/A/1000/015 A Offsite Communications From The Control Room RP/O/A/1000/015 B Offsite Communications From The Technical Support Center RP/O/A/1000/019 Technical Support Center Emergency Coordinator Procedure SR/O/A/2000/003 Activation of the Emergency Operations Facility SR/O/A/2000/004 Notification to States and Counties from the Emergency Operations Facility for Catawba, McGuire, and Oconee 16 AD-EP-ALL-0202 EmerQencv Response Offsite Dose Assessment 17 SR/O/A/2000/003 Activation of the Emergency Operations Facility 17 AD-EP-ALL-0203 Protocol for the Field Monitoring Coordinator During Emergency Conditions HP/O/B/1009/026 Environmental Monitoring For Emergency Conditions 18 SR/O/A/2000/003 Activation of the Emergency Operations Facility AD-EP-ALL-0203 Protocol for the Field Monitoring Coordinator During Emergency Conditions HP/O/B/1009/026 Environmental Monitoring For Emergency Conditions 19 HP/O/B/1009/026 Environmental Monitoring For Emergency Conditions P-11 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented AD-EP-ALL-0203 Protocol for the Field Monitoring Coordinator During EmerQency Conditions 110 AD-EP-ALL-0202 Emergency Response Offsite Dose Assessment HP/O/B/1009/020 Estimating Food Chain Doses Under Post-Accident Conditions HP/O/B/1009/026 Environmental MonitorinQ For EmerQency Conditions 111 NA State/County Responsibility Protective Response J1 AP/O/A/1700/045 Site Security Threats RP/O/A/1000/009 Procedure For Site Assembly RP/O/A/1000/010 Procedure For Emergency Evacuation/Relocation Of Site Personnel J2 NSD-114 Site Assembly/Site Evacuation HP/O/B/1009/016 Procedure For Emergency Decontamination Of Personnel And Vehicles On-Site And From Off-Site Remote Assembly Areas RP/O/A/1000/010 Procedure For Emergency Evacuation/Relocation Of Site Personnel AD-EP-ALL-0202 EmerQency Response Offsite Dose Assessment J3 NSD-114 Site Assembly/Site Evacuation AP/O/A/1700/045 Site Security Threats HP/O/B/1009/018 Off-Site Dose Projections RP/O/A/1000/009 Procedure For Site Assembly RP/O/A/1000/010 Procedure For Emergency Evacuation/Relocation Of Site Personnel AD-EP-ALL-0202 Emergency Response Offsite Dose Assessment J4 HP/O/B/1009/016 Procedure For Emergency Decontamination Of Personnel And Vehicles On-Site And From Off-Site Remote Assembly Areas AD-EP-ALL-0202 EmerQency Response Offsite Dose Assessment RP/O/A/1000/009 Procedure For Site Assembly J4 RP/O/A/1000/010 Procedure For Emergency Evacuation/Relocation Of Site Personnel J5/J6 NSD-114 Site Assembly/Site Evacuation AP/O/A/1700/045 Site Security Threats HP/O/B/1009/009 Procedure For Determining The lnplant Airborne Radioiodine Concentration During Accident Conditions RP/O/A/1000/009 Procedure For Site Assembly AD-EP-ALL-0204 Distribution of Potassium Iodide Tablets in the Event of a Radioiodine Release RPM Radiation Protection Manual J7 RP/O/A/1000/024 Protective Action Recommendations SR/O/A/2000/003 Activation of the Emergency Operations Facility P-12 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented J8 ONS-ETE- ONS Evacuation Time Estimates (ETE) Dated 12142012 12/14/2012 J9 NA State/County Responsibility AP/O/A/1700/045 Site Security Threats RP/O/A/1000/009 Procedure For Site Assembly RP/O/A/1000/010 Procedure For Emergency Evacuation/Relocation Of Site Personnel J10a, b, c ONS E Plan ONS Emergency Plan RPM Radiation Protection Manual J10d - I NA State/County Responsibility J10m RP/O/A/1000/024 Protective Action Recommendations SR/O/A/2000/003 Activation of the Emergency Operations Facility J11 NA State/County Responsibility J12 NA State/County Responsibility Radiological Exposure Control K1a - g RP/O/B/1000/011 Planned Emergency Exposure AD-EP-ALL-0204 Distribution of Potassium Iodide Tablets in the Event of a Radioiodine Release K2 RP/O/B/1000/011 Planned Emergency Exposure K3a RPM Radiation Protection Manual K3a HP/O/B/1009/001 Emergency Equipment Inventory and Instrument Check HP/0/B/1009/023 Radiation Protection Emergency Response K3b RPM Radiation Protection Manual HP/O/B/1009/023 Radiation Protection Emergency Response K4 NA State/County Responsibility K5a, b, RPM Radiation Protection Manual K5a, b, HP/O/B/1009/016 Procedure For Emergency Decontamination Of Personnel And Vehicles On-Site And From Off-Site Remote Assembly Areas HP/0/B/1009/024 Radiation Protection Response To A Medical Emergency K6a, b, c RPM Radiation Protection Manual HP/O/B/1009/016 Procedure For Emergency Decontamination Of Personnel And Vehicles On-Site And From Off-Site Remote Assembly Areas K7 HP/O/B/1009/001 Emergency Equipment Inventory and Instrument Check HP/O/B/1009/016 Procedure For Emergency Decontamination Of Personnel And Vehicles On-Site And From Off-Site Remote Assembly Areas Medical and Public Health Support L1 ONS E Plan ONS Emergency Plan, Appendix 5 P-13 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented HP/O/B/1009/001 Emergency Equipment Inventory and Instrument Check L2 RP/O/A/1000/016 MERT Activation Procedure For Medical, Confined Space, and High Angle Rescue Emerqencies HP/O/B/1009/001 Emergency Equipment Inventory and Instrument Check HP/O/B/1009/024 Radiation Protection Response To A Medical Emergency PT/O/B/0250/032 Quarterly Inspection Of Emergency Medical Equipment L3 NA State/County Responsibility L4 ONS E Plan ONS Emergency Plan, Appendix 5 RP/O/A/1000/016 MERT Activation Procedure For Medical, Confined Space, and Hiqh Anqle Rescue Emerqencies HP/O/B/1009/001 Emergency Equipment Inventory and Instrument Check HP/O/B/1009/024 Radiation Protection Response To A Medical Emerqency Recovery and Reentry Planning and Post Accident Operations M1 RP/O/A/1000/024 Protective Action Recommendations RP/O/A/1000/027 Re-Entry Recovery Procedure RP/O/A/1000/028 Nuclear Communications Emergency Response Plan M2 ONS E Plan ONS Emergency Plan, Section M RP/O/A/1000/027 Re-Entry Recovery Procedure RP/O/A/1000/028 Nuclear Communications Emergency Response Plan M3 RP/O/A/1000/019 Technical Support Center Emergency Coordinator .

Procedure RP/O/A/1000/025 Operational Support Center Manager Procedure RP/O/A/1000/027 Re-Entry Recovery Procedure SR/O/A/2000/003 Activation of the Emergency Operations Facility RP/O/A/1000/031 Joint Information Center Emergency Response Plan AD-EN-ALL-0200 Spill Response .

M4 RP/O/A/1000/027 Re-Entry Recovery Procedure Exercises and Drills N1a, b AD-EP-ALL-0801 Desiqn and Development of Drills and Exercises AD-EP-ALL-0802 Conducting Drills and Exercises AD-EP-ALL-0803 Evaluation and Critique of Drills and Exercises N2, c, d, e, f, g, AD-EP-ALL-0801 Design and Development of Drills and Exercises h, i AD-EP-ALL-0802 Conductinq Drills and Exercises AD-EP-ALL-0803 Evaluation and Critique of Drills and Exercises P-14 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented N2a PTIOIA/20001002 Periodic Test of Emergency Response Communications Equipment STIOIA/46001086 Standard Procedure For Periodic Verification of EOF Communication Equipment Operation and Equipment/Supply Inventory STIOIA/46001094 Standard Procedure For Periodic Test Of The EOF Selective Signaling, ENS and ETS N2b PT1018120001050 Fire Drill - Performance and Evaluation N3 AD-EP-ALL-0801 Design and Development of Drills and Exercises AD-EP-ALL-0802 Conducting Drills and Exercises AD-EP-ALL-0803 Evaluation and Critique of Drills and Exercises N4a, b AD-EP-ALL-0801 Design and Development of Drills and Exercises AD-EP-ALL-0802 Conducting Drills and Exercises AD-EP-ALL-0803 Evaluation and Critique of Drills and Exercises N5 AD-EP-ALL-1000 Conduct Of Emergency Preparedness AD-EP-ALL-0801 Design and Development of Drills and Exercises AD-EP-ALL-0802 Conductinq Drills and Exercises AD-EP-ALL-0803 Evaluation and Critique of Drills and Exercises Radiological Emergency Response Training 01 NSD-117 Emergency Response Organization Staffing, Training, and Responsibilities ERTG-001 Emergency Response Organization and Emergency Services Training Program ETQS7111.0 Emerqencv Response Traininq 02 NSD-117 Emergency Response Organization Staffing, Training, and Responsibilities 02 ERTG-001 Emergency Response Organization and Emergency Services Training Proqram ETQS 7111.0 Emergency Response Training 03 NSD-119 Medical Emergency Response Team (MERT) Program Organization, Training, and Responsibilities ERTG-001 Emergency Response Organization and Emergency Services Training Program 04.1, .2 NSD-117 Emergency Response Organization Staffing, Training, and Responsibilities ERTG-001 Emergency Response Organization and Emergency Services Training Program ETQS7111.0 Emergency Response Training 04.3 ETQS 3104.0 Radiation Protection Training and Qualifications ETQS 7104.0 Radiation Protection Staff Professional Development Program 04.4 ETQS 7111.0 Emergency Response Training 04.5, .7 NSD-119 Medical Emergency Response Team (MERT) Program Orqanization, Training, and Responsibilities P-15 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Emergency Procedure Procedure Title Plan Section(s)

Implemented 04.6 ETQS7111.0 Emerqencv Response Traininq 04.8 ETQS 7111.0 Emergency Response Training 04.9 ETQS 7111.0 Emergency Response Traininq 04.10 OCl507-N Appendix R Training OC6792-N Maint SPOC Team Emergency Response Training TTC 471-N Annual ERO Refresher /Update 04.11 ERTG-001 Emergency Response Organization and Emergency Services Training Program 05 ERTG-001 Emergency Response Organization and Emergency Services Training Program Responsibility for the Planning Effort:

Development, Periodic Review and Distribution of Emergency Plans P1 AD-EP-ALL-0501 Emergency Planner Staff Training and Qualification P2 & P3 ONS E Plan ONS Emergency Plan P4& P5 PT/O/A/2000/010 Review of Emergency Plan and Implementing Procedures AD-EP-ALL-1000 Conduct Of Emergency Preparedness P6 ONS E Plan ONS Emergency Plan P7 ONS E Plan ONS Emergency Plan P8 ONS E Plan ONS Emergency Plan pg AD-EP-ALL-0001 Emergency Preparedness Key Performance Indicators P-16 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES Cross Reference Appendices Appendix 1 Definitions Appendix 2 Meteorology and Offsite Dose Assessment Program Appendix 3 Alert and Notification System Description Appendix 4 Evacuation Time Estimates Appendix 5 Letters of Agreement Appendix 6 Distribution List Appendix 7 Emergency Data Transmittal System Appendix 8 Spill Prevention Control and Countermeasure Plan ONS Pollution Prevention Plan Rev 11 Site Drawing Appendix 9 ONS Chemical Treatment Ponds 1,2 and 3 Groundwater Monitoring Sampling and Analysis Plan Appendix 10 Hazardous Materials Response Plan P-17 Rev. 2016-003 December 2016

FIGURE P1 EMERGENCY PLAN IMPLEMENTING PROCEDURES FIGUREP-2 DUKE ENERGY OCONEE NUCLEAR SITE SUPPORTING PLANS State of South Carolina Oconee County Pickens County DOE-IRAP Plan INPO-Fixed Facility Agreement NRC Region II P-18 Rev. 2016-003 December 2016

APPENDIX9 Oconee Nuclear Station Chemical Treatment Ponds 1, 2 and 3 Groundwater Monitoring Sampling And Analysis Plan Note: This procedure is an implementing program to the Oconee Nuclear Site Emergency Plan and shall be:

1. Reviewed in accordance with 10CFR50.54(q) prior to approval.

2. Forwarded to Emergency Preparedness within seven (7) days of approval.

The Chemical Treatment Ponds 1, 2 and 3 Groundwater Monitoring Sampling And Analysis Plan for the Oconee Nuclear Station, was submitted under separate cover and is considered to be incorporated as part of this document byreference.

Hard copy of the Chemical Treatment Ponds 1, 2 and 3 Groundwater Monitoring Sampling And Analysis Plan is located and maintained in the ONS Nuclear Environmental Field Support Office and is available in Fusion: Record Retention- 421734 & File Code- 705.05

Duke Energy Corporation, LLC Oconee Nuclear Site Hazardous Materials Response Plan (Hazardous Waste Contingency Plan)

Appendix 10 Emergency Response Plan Note: This procedure is an implementing program to the Oconee Nuclear Site Emergency Plan and shall be:

1. Reviewed in accordance with 10CFRS0.54(q) prior to approval.

2. Forwarded to Emergency Preparedness within seven (7) days of approval.

The HAZARDOUS MATERIAL RESPONSE PLAN for the Oconee Nuclear Station, was submitted under separate cover and is considered to be incorporated as part of this document by reference.

Hard copy of the HAZARDOUS MATERIAL RESPONSE PLAN is located and maintained in the ONS Nuclear Environmental Field Support Office and is available in Fusion: Record Retention- 421734 & File Code - 722.01 .

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

Rev. 1 ATTACHMENT 4 Page 1 of 9 10 CFR 50.54(q) Screening Evaluation Form

• Screening and Evaluation Number Applicable Sites:

BNP D EREG#: 02083004 CNS D CR3 D HNP D MNS D 5AD#: N/A ONS x RNP D GO D Document and Revision ONS Emergency Plan Rev 20*16-003 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

1. Page Current Proposed Change

/Sectio n

1. B-6 Safety Assurance Organizationa I Effectiveness B-20

2. Figure TSC/OSC Liaison Tech Assistant Deleted (Mod. Engineering)

B-2

3. Figure Operator 1(b) Operator Licensee Licensee (SRO/RO/NLO) (SRO/RO/NLO)

B-8a 3.Notification &

3.Notification & ***---**-****---*-**

Local/

Communica

• • • • • -**----*-**--***- ***- ***--- .......... **ar;eratcr:****--*-**-----

Communi State SRO 1 Loeal/ State ti on (SRO/RO/NLOJ cation Operator 1(b)

Federal **aP-eraior(sROf____

Federal (SRO/RO/NLO)

4. Figure Notification/Co Notify State 2 Notification/Co Notify State/County mmunication Company Communicat mmunication Company Comm uni cat B-8b Personnel, ors Personnel, or State, County, State, County, Federal Federal NRC Agencies and Agencies and Cornmunicat maintain maintain or communicatio cornmunicatio ll n

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602

' EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 4 Page 2 of 9 10 CFR 50.54(q) Screening Evaluation Form

5. Figure N/A Added a line above the TSC Dose Assessor to B-8b distinguish position from the EOF positions

6. Offsite Field 4 Offsite Field 4 Surveys Monitoring **** Surveys Monitoring ****

Teams (2) l Teams (2) l Onsite l Onsite l Surveys (Out- l Surveys (Out- RP Qualified l ot:Plant) l of-Plant) Individuals l RP Qualified - -

In-Plant Individuals l In-Plant RP Qualified l Surveys Surveys Individuals Rad/Chem Chemistry/Ra Technician Chemistry/Ra Rad/Chem dio Chemistry dio Chemistry Technician

7. F-2 Backup TSC/OSC (OOB) Alternate TSC/OSC (OOB)

F-8

8. F-4 F.1.e Recall of Emergency Response Organization F.1.e Recall of Emernencv Resoonse Omani, ation Should an emergency occur Activation of the ERO sat that will require activation of the Emergency the discretion of the SM/EC for an Unusual EVE nt.

Response Organization, the Activation of the ERO s Shift Manager will require the following actions to required at an Alert or higher. Should an occur: emergency occur that will require activation of the Emergency Response Organization, the Shift Manager will require the following actions to occur:

9. F-4 4. Initiate a Site Assembly. 4. Initiate a Site Assembly (Required at a~

Alert or higher).

F-5 lC P-4 A1b AD-EP- Standard Procedure for EOF AD-EP- Standard Procedure for EC DF DEC- Services ALL- Services 0107 0107 11 P-4 81 AD-EP- Standard Procedure for EOF AD-EP- Standard Procedure for EC DF DEC- Services ALL- Services 0107 0107 12 P-5 86 AD-EP- Standard Procedure for EOF AD-EP- Standard Procedure for EC DF DEC- Services ALL- Services 0107 0107

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602

-* EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 4 Page 3 of 9 10 CFR 50.54(q) Screening Evaluation Form 13 P-5 B7a-d AD-EP- Standard Procedure for EOF AD-EP- Standard Procedure for EC~F DEC- Services ALL- Services 0107 0107 14 P-9 H4 AD-EP- Standard Procedure for EOF AD-EP- Standard Procedure for EC~F DEC- Services ALL- Services 0107 0107 15 P-15 N5 EPFAM Administration of Emergency N5 AD-EP- Conduct Of Emergency 3.1 Plan and Emergency ALL- Preparedness 1000 Plan Implementing Procedures 16 P-16 P4&P5 EPFAM Administration of Emergency P4&P5 AD-EP- Conduct Of Emergency 3.1 Plan and Emergency ALL- Preparedness 1000 Plan Implementing Procedures 17 Appen Chemical Treatment Ponds 1, 2 and 3 Removed content from E-Plan and added following dix 9 Goundwater Monitoring Sampling And Analysis Plan bullets to Appendix 9 coversheet; Note: This procedure is an implementing program to the Oconee Nuclear Site Emergency Plan and shall be: 1. Reviewed in accordance with 10CFRS0.54(q) prior to approval. 2. Forward ~d to Emergency Preparedness within seven (7) d< ys of approval.

The Chemical Treatment Ponds 1, 2 and 3 Goundwater Monitoring Sampling And Anal\ sis Plan for the Oconee Nuclear Station, was submitted under separate cover and is considered to be incorporated as part of thic document by reference. Hard copy of the Chemical Treatment Ponds 1, 2 and 3 Goundwater Monitoring Sampling And Anal\ sis Plan is located and maintained in the ONS Nuclear Environmental Field Support Office imd is available in Fusion: Record Retention- 42H34

& File Code - 705.05

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

Rev. 1 ATTACHMENT 4 Page 4 of 9 10 CFR 50.54(q) Screening Evaluation Form 1B Appen Appendix 10 Removed content from E-Plan and added following dix 10 Emergency Response Plan bullets to Appendix 10 coversheet Revision 2010-01 Appendix 10 February 2010 Emergency Response Plan Note: This procedure is an implementing program to the Oconee Nuclear Site Emerg ~ncy Plan and shall be:

1. Reviewed in accordance with 10CFRS0.54(q) prior to approval.

2. Forwarded to Emergency Preparedness within seven (7) days of approval The HAZARDOUS MATERIAL RESPO 'J"SE PLAN for the Oconee Nuclear Station, v as submitted under separate cover and is considered to be incorporated as part oft 1is document by reference.

Hard copy of the HAZARDOUS MATERIAL RESPONSE PLAN is located and mainta ned in the ONS Nuclear Environmental Fie d Support Office and is available in Fusio tl:

Record Retention- 421734 & File Code -

722.01 .

Section B; Revised to clarify the requirements for minimum staffing in Figure B-8b, Offsite Communicators (2), one of the Communicators is the NRC Communicator.

Section F, Clarify that ERO activation is at the discretion of the SM/EC for UE, required at Alert and higher. Clarify Site Assembly is required at an Alert or higher. Change Backup to Alternate TSC housekeeping issue per the guidance in NEI 13-01. (PRR 02080151)

Section P; 1) AD-EP-DEC-0107, Administration of Emergency Plan and Emergency revised to AD-EP-ALL-1000, Conduct Of Emergency Preparedness .

Appendix 9, Removed the Ground Water Monitoring Plan from the Emergency Plan and implemented by reference, 50.54q statement added to the document and documented location in Fusion.

Appendix 10, Removed the Hazardous Materials Response Plan from the Emergency Plan and implemented by reference, 50.54q statement added to the document and documented location in Fusion.

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

Rev. 1 ATIACHMENT 4 Page 5 of 9 10 CFR 50.54(q) Screening Evaluation Form Part II. Activity Previously Reviewed? Yes 10 No Ix Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or 10 CFR 50.54(q) Continue to A!ert and Notification System Design Report? Effectiveness Attachment 4, Evaluation is not 10 CFR If yes, identify bounding source document number or approval reference and required. Enter 50.54(q) ensure the basis for concluding the source document fully bounds the proposed justification Screening change is documented below: below and Evaluation complete Form, Part Ill Justification: Attachment 4, Part V.

I 10

~-

Bounding document attached (optional)

-~ ;. ., .. . ,.

Part Ill. Editorial Change Yes lo No Ix Is this activity an editorial or typographical change only, such as formatting, 10 CFR 50.54(q) Continue to paragraph numbering, spelling, or punctuation that does not change intent? Effectiveness Attachment 4, Evaluation is not Part IV and required. Enter address non Justification:

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

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

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

1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control)*: ..

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

2. 10 CFR 50.4 7(b )(2) On site Emergency Oi"ganization

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

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

Rev. 1 ATTACHMENT 4 Page 6 of 9 10 CFR 50.54(q) Screening Evaluation Form 3a Arrangements for requesting and using off site assistance have been made. D 3b State and local staff can be accommodated at the EOF in accordance with the emergency plan. D (NA for CR3) 4a A standard scheme of emergency classification and action levels is in use. D (Requires final approval of Screen and Evaluation by EP CFAM.)

5 1o CFR50:4 7(b}(5) NotificationMethods;andPr9cedures:, " x* ., .. : .:.;. ** * \> *. .

• i'; * ;*** .. F; ::~: '. *.

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

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

~--

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602

. EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.1 ATTACHMENT 4 Page 7 of 9 10 CFR 50.54(q) Screening Evaluation Form Part IV. Emergency Planning Element and Function Screen (cont.)

,**. ,..... ;  :/

Emergency,Communications~< :.'***'*,

ff: .f"1 1.0 CFR .. 50A7(b)(6) "*<*

... ; ,:' .. :*(,,**

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

6b Systems are established for prompt communication to emergency response personnel. D 7 'joCFR50A7(b)f?').PUblic*Education.*and*lnforril~~ion:;/.' : , .* ;~:.L,* .*:* . ......... ,,

' ,*, *\'

?a Emergency preparedness information is made available to the public on a periodic basis within the D plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established. D 8'*'*:.

• 10< CFR5P'.47(b)(8) Emergency:Facilities*aJ1d Equipm~nt/ .. :r. "'> .

• ,*.... ,/ ' .*:y  :: ,'. ,,: *:~ '.

"" v

...* ~ '*

Ba Adequate facilities are maintained to support emergency response. D 8b Adequate equipment is maintained to support emergency response. D 9'.'.c'? ; +p:cFR:S.0:47(b)(9):A~cident"Assessment<;:i'.* :Y\i.: :**, ./,'D.+ ,:,,' *::,>::*' <;:;::.:, '/( < '*"*. *  ;

• ':\'

' \, *,*

• • . ' "*'*' r;y*

9a Methods, systems, and equipment for assessment of radioactive releases are in use. D to \ \1QCf~l50'.'47(b)(to):Protective:Res,'pon~~;*;.,>i;*s :<;::;;.rt'*.,~;~ ;c> Y*:. *.:,t:.::I";.:,~~;,\\'<1~::.;:;' .,!'."} . *F,:::':*:*;;;:'8'. , * . ~*t~i.

10a A range of public PARs is available for implementation during emergencies. (NA for CR3) D 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available D to support the formulation of PARs and have been provided to State and local governmental authorities. (NA for CR3) 10c A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events.

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

~

.:.J.::': ~

'11> \. * . 10: CFR 50':4 7(b KH)' Radiologi~l'Exposure: >*,,'\ .:;it'.i .,

ConttoF>> * * );c .* .....  !. '.)

11a The resources for controlling radiological exposures for emergency workers are established. D 12> . 10 CFR50.47(b)(12)MedicaLand P.ublic.Healtll Support,; , :':':( i; , .. ,, ' ~,y  :. ,: ': /. ,'<:.*.,. ' \  :  ; ,\/; .

12a Arrangements are made for medical services for contaminated, injured individuals. D 13\* 1oGFFf50.47(b)(,1'3)Recoveiyplannin~fand*Po~t-acddehtOperations';;<:,". .. , <-:-  :' ,;;:;:'.'".,,... ,

-, ~;:' /:;, ):.

13a Plans for recovery and reentry are developed. D 14*:' .10.CFR50.47(b)(14)Drills:and Exercises,,: .....

~-'

. ' *..~* '* *; }/

i.*

~:

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

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

14c Identified weaknesses are corrected. D

• , ..  : '_; .'-~: ~- ..*

15:' 1o*cFR50.47(b )(15J Ehiergency; Response Training . ::*. *"'*'

15a Training is provided to emergency responders. D

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

Rev. 1 ATTACHMENT 4 Page 8 of 9 10 CFR 50.54(q) Screening Evaluation Form Part IV. Emergency Planning Element and Function Screen (cont.)

16;> : .10'CFR50.47(b)(16) Erilergency.PlanMainteri~rfoe.

16a Responsibility for emergency plan development and review is established. x 16b Planners responsible for emergency plan development and maintenance are properly trained. D PART IV. Conclusion If no Part IV criteria are checked, a 10 CFR 50.54(q) Effectiveness Evaluation is not required, then complete D , 10 CFR 50.54(q) Screening Evaluation Form, Part V. Go to Attachment 4, 10 CFR 50.54(q)

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

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

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

Section F, Clarify that ERO activation is at the discretion of the SM/EC for UE, required at Alert and higher.

Clarify Site Assembly is required at an Alert or higher. Change Backup to Alternate TSC housekeeping issue per the guidance in NEI 13-01. (PRR 02080151 ). No changes to the systems or methods that would affect Planning Standard 10 CFR 50.47(b)(6) Provisions existfor prompt communications among principal response organizations to emergency personnel and to the public.

Functions:

(1) Systems are established for prompt communication among principal emergency response organizations.

(2) Systems are established for prompt communication to emergency response personnel.

Note that the (Appendix 10) Hazardous Materials Response Plan ensures compliance with 29 CFR 1910.120 and is not related to and does not ensure compliance with NUREG 0654, 10CFR47, 10CFR50 or FEMA-REP-10.

Given there is no interrelationship between the Hazardous Materials Response Plan and NUREG 0654, 10CFR47, 10CFR50 or FEMA-REP-10, changes to the Hazardous Materials Response Plan cannot result in a reduction in effectiveness in ONS's ability to implement the sixteen planning standards detailed above. A x review of both the current and proposed revisions to this document reaffirmed that there is no interrelationship between the ONS Hazardous Materials Response Plan and any structure, component, procedure or process utilized to implement the sixteen planning standards. Therefore, this revision to the ONS Emergency Plan does not result in a reduction in effectiveness.

Note that the (Appendix 9) Groundwater Sampling and Analysis Plan(SAP) establishes field protocols for Duke energy to ensure the quality of data generated during groundwater sampling events at the Oconee Nuclear Station Chemical Treatment Ponds (NPDES Permit number SC0000515). This SAP has been prepared in accordance with the EPA Environmental Investigations Standard Operating Procedures and Quality Assurance Manual (November 2001 ), and by the EPA in "Interim Guidelines and Specifications for Preparing Quality Assurance Plans"(QAMS-500/800). The SAP provides guidance to the field personnel concerning methodologies of field sampling, proper record-keeping protocols, data quality objectives, and data validation procedures. The SAP is not related to and does not ensure compliance with NUREG 0654, 10CFR47, 10CFR50 or FEMA-REP-10.

Given there is no interrelationship between the Groundwater Stlmpling and Analysis Plan(SAP) and NUREG 0654, 10CFR47, 10CFR50 or FEMA-REP-10, changes to the Groundwater Sampling and Analysis Plan(SAP) cannot result in a reduction in effectiveness in ONS's ability to implement the sixteen planning standards detailed above. A review of both the current and ro osed revisions to this document reaffirmed that there is

. EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

AD-EP-ALL-0602 Rev. 1 ATTA CH ME NT 4 Page 9of9 10 CFR 50.54(q) Screening Evaluation Form no interrelationship between the ONS Groundwater Sampling and Analysis Plan(SAP) and any structure, component, procedure or process utilized to implement the sixteen planning standards. Therefore, this revision to the ONS Emergency Plan does not result in a reduction in effectiveness.

• Partv,:signatures:, ,' .*

• Preparer Name (Print): Peter Kuhlman Date:

P* 1 tlP Reviewer Name (Print): Don Crowl Date:

/ ff hw Approver (EP Manager Name (Print):

Pat Street Approver (CFAM, as required) Name (Print) Date:

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

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

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

put in effect. D QA RECORD

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

Rev. 1 ATTACHMENT 5 Page 1 of 9

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

' Screening and' Evaluation Number' Applicable Sites* ..

BNP D EREG #: 02083004 CNS D CR3 D HNP D MNS D 5AD#: ONS x RNP D GO D Document and Revision ONS Emergency Plan Rev 2016-003

.. **.** ./

.:*>.; -~,

Part I. Description of Proposed Change:

1. Page Current Proposed Change

/Secti on

1. B-6 Safety Assurance Organizational Effectiveness B-20

2. Figur TSC/OSC Liaison Tech Assistant Deleted, combined with TSC/OSC (Mod. Engineering) e 8-2 Liaison position (PRR 02083339)

3. Figur Operator Operator 1(b)

License 1(b) Licensee

..-* . (§_f.39.!.R9.!.~b.9..L.

(SRO/RO/NL 3.Notification & **--****-..*-****-..

e 8- 3.Notification e

"Ia-cair*

9.L______ ,, __ ,, ..,.. Comm uni Local/ State

--**-***"*~-**-

Operator 1

Ba &

_________ SRO 1 cation

• F=eaer:ar-----*--- J§_f39.LB.Q/~~QL 1(bl" Com mu State

_,,_.. ... , Operator (SRO)

-operator---*-

nication Federal (SRO/RO/NL 1(b) o)

Notification/C Notify State 2 Notification/C Notify State/Count l

4. Figur ommunication Company Communica ommunication Company y I e 8- Personnel, tors Personnel, Communic State, State, ator 8b County, County, NRC Federal Federal Communic Agencies Agencies ator and maintain and communicat maintain ion communicat ion

5. Figur N/A Added a line above the TSC Dose e 8- Assessor to distinguish position from 8b the EOF positions

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

Rev. 1 ATTACHMENT 5 Page 2 of 9

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

Offsite Field 4 Offsite Field 4

6. Surveys Monitoring 1 *** Surveys Monitoring I ***

Onsite Teams (2) 1

• Onsite Teams (2) I

• Surveys - I Surveys RP - I (Out-of- RP I (Out-of- Qualified I Plant) Qualified 1 Plant) Individuals I In-Plant Individuals In-Plant RP Surveys Rad/Chem Surveys Qualified Chemistiy/R Technician Chemistiy/R Individuals adio adio Rad/Chem Chemistry Chemistrv Technician

7. P-4 I A1b AD-EP-DEC-Standard Procedure for EOF Services AD-EP-ALL-Standard Procedure for EOF Services 81 0107 AD-EP- Standard Procedure for I 0107 AD-EP- Standard Procedure for

8. P-4 ALL- EOF Services DEC- EOF Services 0107 0107

9. P-5 I 86 AD-EP-DEC-Standard Procedure for EOF Services AD-EP-ALL-Standard Procedure for EOF Services 0107 I 0107

10. P-5 I 87a-d AD-EP-DEC-Standard Procedure for EOF Services AD-EP-ALL-Standard Procedure for EOF Services 0107 0107

11. P-9 I H4 AD-EP-DEC-Standard Procedure for EOF Services AD-EP-ALL-Standard Procedure for EOF Services NS 0107 EP FAM Administration of I NS 0107 AD-EP- Conduct Of Emergency

12. P-15 Emergency Plan and ALL- Preparedness 3.1 Emergency 1000 Plan Implementing Procedures P-16 P4&P EP FAM Administration of P4&P AD-EP- Conduct Of Emergency 13.

s 3.1 Emergency Plan and 5 ALL- Preparedness Emergency 1000 Plan Implementing Procedures , 10 CFR 50.54(q) lnitiat!ng Condition (IC) and Emergency Action Level (EAL) and EAL Yes D Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change)

No x Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

Oconee Emergency Plan Revision 81-2December1981

8. ONSITE EMERGENCY ORGANIZATION Adequate staffing to provide for initial emergency 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.

8.1. Onsite Emergenc~ Organization Figures 8-1 through 8-11 shows the Onsite organization for emergencies. These charts also show the responsibilities and the duties of the normal staff to complement and how they would interface with the Emergency Organization.

B.5 Minimum Staffing Reguirements for Nuclear Power Plant Emergencies Figure 8-12 specifies the positions by title and major tasks to be performed by the persons assigned to the functional areas of emergency activity. For emergency situations, specific assignments have been made for all shifts and for plant staff members, both onsite and away from the site.

P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of the Emergency Plans

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

Rev. 1 ATTACHMENT 5 Page 3 of 9

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

P.6 Supporting: Plans Figure P-1 gives a listing of supporting plans to the Oconee Nuclear Station Emergency Plan.

Oconee Emergency Plan Revision 2016-002 B. ONSITE EMERGENCY ORGANIZATION Adequate staffing to provide for initial emergency 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.

B.1. Emergency Response Organization Figures B-1 through B-6 shows the Oconee Nuclear Site Emergency Response Organization that would be established during an incident along with the duties the different groups would assume. Designation of personnel to the Emergency Response organization is determined by the particular job expertise of an individual. This assures that these personnel are qualified to carry out their responsibilities during an emergency. The normal staffing assignments at the Oconee Nuclear Site include emergency response responsibilities. See Figures B-1 O for emergency responsibilities for designated groups. The Emergency Response Organization is outlined in Division/Section Directives. These directives establish the duties, responsibilities and alternates for each required emergency response position. Response procedures have been established for each section through these Directives.

B.5 Minimum Staffing Requirements for Nuclear Power Plant Emergencies Figure 8-8(a/b) identifies the positions by title and major tasks to be performed by the persons assigned to the functional areas of emergency activity within 45 to 75 minutes. The TSC and OSC will be activated within 75 minutes of event classification. The EOF (Figure B-9) will also be staffed and operational by a minimum staff within 75 minutes of event classification.

A detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in Figure 8-8a is located in ONS-OSSA-12212012 Rev: 0.

P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of the Emergency Plans P.6 Supporting: Plans Figure P-2 lists plans in support of the ONS Emergency Plan.

RIS 2005-02, Clarifying the Process for Making Emergency Plan Changes, Rev. 1 states,

2) Emergency plan a) The document prepared and maintained by the licensee that identifies and describes the licensee's methods for maintaining emergency preparedness, and responding to emergencies. An emergency plan includes the plan as originally approved by the NRC, and all subsequent changes made by the licensee with, and without, prior NRC review and approval under 10 CFR 50.54(q).

i) The licensee's emergency plan consists of:

(1) The emergency plan as approved by the NRC via a Safety Evaluation Report (SE), or license amendment (LA) from the Office of Nuclear Reactor Regulation (NRR) or the Office of Federal and State Materials and Environmental Management Programs (FSME).

(2) Any subsequent changes to the emergency plan explicitly reviewed by the NRC through an SE, or LA from NRR or FSME, and found to meet the applicable regulations.

(3) Any subsequent changes made by the licensee without NRC review and approval after the licensee concluded that the change(s) do not constitute a decrease in effectiveness under 10 CFR 50.54(q).

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

Rev. 1 ATTACHMENT 5 Page 4 of 9

<< 10 CFR 50.54 q Effectiveness Evaluation Form >>

The differences in ONS Emergency Plan, Revision 81-2, and the current revision of the ONS Emergency Plan have been determined to meet the regulatory requirements of the course of revisions. Each revision has been evaluated in the regulatory process has met the approval of the NRC during the inspection process.

The changes described in this evaluation do not reduce the effectiveness of the emergency plan.

Section B, there is no staffing reduction to the minimum staffing described in Figures B-8a/b, changes were made for clarification of roles. The combination of the TSC/OSC and TSC/OSC Tech Assist was due to efficient use of personnel and requested via drill critique feedback, both positions use the same personnel qualification guide ..

Section P was a housekeeping change to update procedures that have been revised or superseded by fleet procedure. The changes in this revision do not change methods or ability to staff the Emergency Response Organization with principal response organizations and emergency personnel.

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

Rev. 1 ATTACHMENT 5 Page 5 of 9

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

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

If the emergency plan, modified as proposed, no longer complies with planning standards 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 process~d as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q):

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

10 CFR 50.47(b)(16) Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

10CFRSO Appendix E IV. Content of Emergency Plans A. Organization (states, in part)

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

1. A description of the normal plant operating organization.

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

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

b. Plant staff emergency assignments; C. Activation of Emergency Organization (states, in part)

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 ........

G. Maintaining Emergency Preparedness Provisions to be employed to ensure that the emergency plan, its implementing procedures, and emergency equipment and supplies are maintained up to date shall be described.

The changes identified in this revision continue to comply with regulation ONS retains the capability required by regulation to staff the minimum required positions to staff the Emergency Response Facilities with the Emergency Response Organization within the specified time period and have the descriptions of those personnel in addition to when the activation of the ERO is required.

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

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

Functions:

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

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

Elements NUREG-0654/FEMA-REP-1 Rev 1, II, B. Onsite Emergency Organization 1 . Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement

5. Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, 11 Minimum Staffing Requirements for Nuclear Power Plant Emergencies ... The minimum on-shift staffing levels shall be as indicated in Table 8-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1. The implementation schedule for licensed operators, auxiliary operators and the shift technical advisor on shift shall be as specified in the July 31, 1980 letter to all power reactor licensees. Any deficiencies in the other staffing requirements of Table B-1 must be capable of augmentation within 30 minutes by September 1, 1981, and such deficiencies must be fully removed by July 1, 1982.

10 CFR 50.47(b)(16) Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

Function:

(1) Responsibility for emergency plan development and review is established.

Elements NUREG-0654/FEMA-REP-1 Rev 1, II, P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans

7. Each plan shall contain as an appendix listing, by title, procedures required to implement the plan. The listing shall include the section(s) of the plan to be implemented by each procedure.

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

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

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Functions:

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

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

Elements NUREG-0654/FEMA-REP-1 Rev 1, II, 8. Onsite Emergency Organization

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

5. Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table 8-1 entitled, 11 Minimum Staffing Requirements for Nuclear Power Plant Emergencies ... The minimum on-shift staffing levels shall be as indicated in Table 8-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table 8-1. The implementation schedule for licensed operators, auxiliary operators and the shift

• technical advisor on shift shall be as specified in the July 31, 1980 letter to all power reactor licensees. Any deficiencies in the other staffing requirements of Table 8-1 must be capable of augmentation within 30 minutes by September 1, 1981, and such deficiencies must be fully removed by July 1, 1982.

10 CFR 50.47(b)(16) Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

Function:

(1) Responsibility for emergency plan development and review is established.

Elements NUREG-0654/FEMA-REP-1 Rev 1, II, P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans

7. Each plan shall contain as an appendix listing, by title, procedures required to implement the plan. The listing shall include the section(s) of the plan to be implemented by each procedure.

The changes made to the Emergency Plan clarify roles of the Offsite Communicator to State/County Communicator and NRC Communicator for minimum staffing requirements, no change to implementation. Filled in blanks on the 8-8b table for consistency throughout the table, no change in roles or methods to maintain minimum staffing. The additional information added to Section Fis restating and clarifying information contained in Section A on requirements to activate Emergency Response Organization and perform Site Assembly, no change in methods used. Changes to Section Pare updates to pro,cedures referenced in the Emergency Plan that have been superseded by fleet procedures.

The changes identified in this revision maintain the effectiveness of the Emergency Plan functions. ONS retains the capability required by regulation to notify and staff the Emergency Response Organization when required to activate.

Part VI. Evaluation Conclusion.

Answer the following questions about the proposed change.

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

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

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

approval.

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

Part VII. Disposition of Proposed Change Requiring Prior NRG Approval Will the proposed change determined to require prior NRG approval be either revised or Yes D No D rejected?

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

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

Preparer Name (Print): Peter Kuhlman Date:

I'- 1 \I.,

Reviewer Name (Print): Don Crowl Date:

/. ~j1,.

Approver (EP Manager) Name (Print):

Pat Street Approver (CFAM, as required) Name (Print):

N/A ~

' .' - ~ *.

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

• One for EP to provide the 10CFR50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q), 0 to Licensing.

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