ONS-2017-070, Emergency Plan Implementing Procedures, Volume 2, Revision 2017-002

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Emergency Plan Implementing Procedures, Volume 2, Revision 2017-002
ML17285A033
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 09/05/2017
From: Hubbard D
Duke Energy Carolinas
To:
Office of Nuclear Reactor Regulation
References
ONS-2017-070
Download: ML17285A033 (31)
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Text

OCONEE NUCLEAR STATION EMERGENCY PLAN IMPLEMENTING PROCEDURES VOLUME 2 l ' , '*. '

APPROVED:

Dean Hubbard Director Nuclear Org Effectiveness Date Approved VOLUME 2 REVISION 2017-002 September 2017

September 5, 2017 OCONEE NUCLEAR STATION

SUBJECT:

Emergency Plan Implementing Procedures Volume 2 Revision 2017-002 Please make the following changes to the Emergency Plan Implementing Procedures, Volume 2:

REMOVE INSERT Cover Sheet Rev. 2017-001 Cover Sheet Rev. 2017-002 Instruction 2017-001 Instruction 2017-002 HP/O/B/1009/020 Rev 005 HP/O/B/1009/020 Rev 006 William R. Mcintyre ONS Emergency Preparedness Manager

Duke Energy Company Procedure No.

Oconee Nuclear Station HP/0/B/1009/020 Revision No.

Estimating Food Chain Doses Under 006 Post-Accident Conditions Electronic Reference No.

Reference Use OX002SD9

~*

HP/0/B/1009/020 Page 2of12_

REVISION

SUMMARY

PRR 01921441 DESCRIPTION

  • Reference2.2 HP/O/B/1009/018 superse::loo by flOO: proc;ajureAD-EP-ALL-0202
  • Reference2.3 RPSIVI 11.7 supersa:loo by HP/O/B/1009/026 PRR 01911935
  • Removoo Purpose Step 1.2 and repl a::ed the fol Iowing in Note under

Purpose:

This proc;ajure is i denti fi oo as an Emergency Pl an I mpl ementi ng Proc;ajure. Prior to finalizing and ~proving any revisions, it must beforwardoo to Emergency Preparooness for review in accordance with 10CFR50.54q Emergency Plan Effa;tiveness Review PRR 01911485

  • Repla::ed "should" with "shall" in the Notes before and after Step 4.5 to improve human performance aspa;t of RP proc;ajures
  • Repla::ed "~propriate persons" with" Dose Assessors, man~ement, and others as necessary" in the Notes before and after Step 4.5 to improve human performance aspa;t of RP proc;ajures M is:ellaneous
  • Enclosure 5.4 was deletoo, Ra:ldose progrcm is no longer use:!
  • Repla::ed PIP4-0-93-0701 with CR 01896725 in Reference2.5
  • Repla::ed "Duke Power" with "Duke Energy" on the cover shOO:
  • Edi t0ri al changes for enhancement

HP/0/B/1009/020 Page 3of12 Estimating Food Chain Doses Under Post-Accident Conditions

1. Purpose NOTE: This procedure is identified as an Emergency Plan Implementing Procedure. Prior to finalizing and approving any revisions, it must be forwarded to Emergency Preparedness for review in accordance with 10CFR50.54q Emergency Plan Effectiveness Review.

1.1 This procedure describes the method to be used in order to estimate off-site doses through significant food chain dose pathways under post-accident conditions.

2. Reference 2.1 U.S. NRC Regulatory Guide 1.109 2.2 AD-EP-ALL-0202, EMERGENCY RESPONSE OFFSITE DOSE ASSESSMENT 2.3 HP/O/B/1009/026, Environmental Monitoring for Emergency Conditions 2.4 Off-Site Dose Calculation Manual 2.5 CR 01896725, Distribution of Emergency Plan Implementing Procedures
3. Limits And Precautions 3.1 The determination of potential areas of concern in the ingestion pathway under post-accident conditions will be made by the Radiological Assessment Manager based upon station release, prevailing meteorological and hydro-logical conditions, and confirmatory measurements of dose rates and air samples results by field monitoring teams.

3 .2 This procedure covers only the calculation of the food chain pathway doses most likely to be limiting under post-accident conditions. Other food chain doses must be calculated using the methods of US NRC Regulatory Guide 1.109 and Off-Site Dose Calculation Manual.

3.3 The errors in the doses calculated through the use of this procedure are NOT necessarily conservative.

3 .4 The assumptions outlined in this procedure should be carefully compared with existing post-accident conditions before this procedure is used.

3 .5 It is expected that samples will be collected by off-site monitoring teams under the direction of the Field Monitoring Coordinator.

HP/0/B/1009/020 Page 4of12 3.6 Whole body doses due to radioiodine ingestion will always be much smaller than the thyroid dose, therefore, this procedure does NOT consider iodine whole body dose.

3.7 Contribution ofl-132 and I-134 to dose is negligible due to the short half-lives and small dose factors for these radionuclides.

3.8 Doses calculated on the basis of milk radioiodine concentrations will be much more accurate than those calculated on the basis of vegetation radioiodine concentrations.

However, the measurement of vegetation radioiodine concentrations permits the prediction of approximate doses due to milk consumption two days later.

3.9 Contribution of Cs-138 to dose is negligible because of the short half-life and small dose factors for this radionuclide.

NOTE: In any one day, a person may consume five or ten times the assumed daily quantity of fish.

3 .10 Doses calculated on the basis of fish radiocesium concentrations will be much more accurate than those calculated on the basis of water radiocesium concentrations.

However, the measurement of water radiocesium concentrations permits the prediction of doses due to future consumption of fish.

3.11 CDE (Liver) doses due to radiocesium ingestion are about two times the TEDE. The TEDE limit is 5 rem, and the liver dose limit is 50 rem; therefore, the TEDE is limiting.

3.12 Food Chain Protective Action Guides (PAGs) are:

3.12.1 Preventative:

3.12.1.1 0.5 REM to the whole body, bone marrow or any other organ.

3.12.1.2 1.5 REM to the thyroid.

3.12.2 Emergency:

3.12.2.1 5 REM to the whole body, bone marrow or any other organ.

3.12.2.2 15 REM to the thyroid.

HP/0/B/1009/020 Page 5of12 3 .13 Ground deposition and Relocation PAGs (ie: relocate if necessary to keep doses less than the following values), based on Deep Dose Equivalent, are:

3.13.1 2 REM in first year after accident; 3.13.2 0.5 REM in second year after accident; 3.13.3 5 REM for fifty year Effective Dose Equivalent.

4. Procedure 4.1 Vegetation --+ Cow or Goat Milk--+ Consumer Dose Pathway for Radioiodine:

4.1.1 Use the following assumptions for the dose calculation:

  • Milk Consumption: infant - 900 ml/day(~ 2 pints), adult- 850 ml/day.
  • Decay time between iodine deposition on vegetation and milk consumption: 2 days.
  • Percent of milk animals' feed from fresh pasture vegetation: 100% -

unless known to be different. The concentration eaten by the animal can be modified by multiplying the concentration in the pasture vegetation by the fraction of feed which is from fresh pasture.

4.1.2 Calculate doses from radioiodine concentrations measured either in OR on vegetation consumed by milk animals per Step 4.1.3 or measured in milk per Step 4.1.4.

HP/0/B/1009/020 Page 6of12 NOTE: All calculations for vegetation samples are done for cows; however, ifthe dose from goat milk is desired, multiply the dose from cow milk by 1.2.

4.1.3 Calculate dose from radioiodine through vegetation analysis per the following steps:

4.1.3.1 Collect and analyze samples of typical vegetation eaten by milk animals.

4.1.3.2 Compute radioiodine concentrations in µCi/gm of undried vegetation.

4.1.3.3 Calculate CDE (thyroid) using one of the following equations:

.A. Drrv 3200 Cr-13lv + 180 C1-133v + 1.1 C1-l35v B. DTAV 420 C1-13lv + 20 C1-133v + 0.1 C1-135v

  • D11v Human infant CDE (thyroid) in Rem/day where milk animal consumes contaminated vegetation
  • D1Av Same as above for human adult
  • Cr-13lv concentration ofl-131 in vegetation

(µCi/gm)

  • C1-133v concentration of 1-13 3 in vegetation

(µCi/gm)

  • C1-l3sv concentration ofl-135 in vegetation

(µCi/gm) 4.1.3.4 Record results on Enclosure 5 .1, Page 1.

HP/0/B/1009/020 Page 7of12

4. i .4 Calculate dose from radioiodine through milk analysis per the following steps:

4.1.4.1 Collect and analyze samples of milk.

4.1.4.2 Compute radioiodine concentrations in µCi/ml of milk.

4.1.4.3 Calculate CDE (thyroid) using one of the following equations:

A. DnM 13000 Cr-13Im + 3000 Cr-133m + 590 Cr-135m 1700 Cr-13lm + 300 Cr-133m + 65 Cr-135m Human infant CDE (thyroid) in Rem/day consumption of contaminated milk Same as above for huma~ adult

  • Cr-Blm concentration of 1-131 in milk (µCi/ml)
  • Cr-133m concentration ofl-133 in milk (µCi/ml)
  • Cr-I35m concentration ofl-135 in milk (µCi/ml) 4.1.4.4 Record results on Enclosure 5.1, Page 2.

HP/0/B/1009/020 Page 8of12 4.2 Drinking Water~ Consumer Pathway for Radioiodine:

4.2.1 Use the following assumptions for the dose calculation:

  • Water Consumption: infant - 900 ml/day(~ 2 pints) , adult - 2000 ml/day
  • Decay time in water distribution system: 1 day 4.2.2 Calculate dose from radioiodine through water analysis per the following steps:

4.2.2.1 Collect and analyze water samples.

4.2.2.2 Compute radioiodine concentrations in µCi/ml.

4.2.2.3 Calculate CDE (thyroid) using one of the following equations:

A. Drrw =12000 Cr-13lw + 1400 Cr-t33w + 50 Cr-13sw B. DTAW =3700 Cr-13Iw + 320 Cr-133w + 12 Cr-135w Human child (infant) CDE (thyroid) in Rem/day of consumption of contaminated water Same as above for human adult

  • Cr-I3Iw = concentration ofl-131 in water (µCi/ml)
  • Cr-I33w concentration ofl-133 in water (µCi/ml)
  • Cr-135w concentration of I-135 in water (µCi/ml) 4.2.2.4 Record result on Enclosure 5.1, Page 3.

4.3 Water~ Fish~ Consumer Pathway for Radiocesium:

4.3.1 Use the following assumptions for the dose calculation:

  • Fish Consumption: teen - 44 g/day, adult - 56 g/day.
  • Bioaccumulation factor for cesium in fish: 2000.

4.3.2 Calculate dose from radiocesium concentrations measured either in water per Step 4.3.3 or measured in fish per Step 4.3.4.

HP/0/B/1009/020 Page 9of12 4.3 .3 Calculate dose from radiocesium through water analysis per the following steps:

4.3.3.1 Collect and analyze water samples.

4.3.3.2 Compute radiocesium concentrations in µCi/ml.

4.3.3.3 Calculate CEDE doses using one of the following equations:

A. DBTW =8000 Ccs-134w + 2000 Ccs-136w + 4600 Ccs-137w B. DBAW =14000 Ccs-134w + 2200 Ccs-136w + 8200 Ccs-137w human teen CEDE in Rem/day where fish are exposed to contaminated water same as above for human adult

  • Ccs-134w concentration of Cs-134 in water (µCi/ml)
  • Ccs-136w concentration of Cs-13 6 in water (µCi/ml)
  • Ccs-137w concentration of Cs-13 7 in water (µCi/ml) 4.3.3.4 Record results on Enclosure 5 .2, Page 1.

HP/0/B/1009/020 Page 10of12 4.3.4 Calculate dose from radiocesium through fish analysis per the following steps:

4.3.4.1 Collect and analyze fish samples.

4.3.4.2 Compute radiocesium concentrations in µCi/gm (wet weight).

4.3.4.3 Calculate CEDE using one of the following equations:

A. DBTF = 4.0 Ccs-134f+ 1.0 Ccs-136f+ 2.3 Ccs-137f B. DBAF = 6.9 Ccs-134f + 1.1 Ccs-136f + 4.1 Ccs-137f

  • DBTF human teen CEDE in Rem/day of consumption of contaminated fish (44 gm/day) human adult CEDE in Rem/day of consumption of contaminated fish (57 gm/day)
  • Ccs-134f concentration of Cs-134 in fish (µCi/gm)
  • Ccs-136f concentration of Cs-136 in: fish (µCi/gm)
  • Ccs-137f concentration of Cs-13 7 in fish (µCi/ gm) 4.3.4.4 Record results on Enclosure 5.2, Page 2.

HP/0/B/1009/020 Page 11of12 4.3.5 Calculate dose due to ground plane pathway according to the following steps:

4.3.5.1 Obtain data as required in one of the equations in Step 4.3.5.2.

4.3.5.2 Calculate Deep Dose Equivalent (WB) using one of the following equations, depending upon data available from Field Monitoring:

A. DBoP =(survey instrument reading mrem/hr) X (6.132 hr*rem/yr*mrem) OR B. DBGP = (contamination level dpm/100cm2)

(5.53E-3dpm*uCi*pCi*cm2 *hr*mrem*m2/cm2 *dpm*uCi*

m2 *yr*pCi*hr) OR C. DBGP =(isotopic results uCi/g)(DF)

(3.l 15E14 pCi*gm*hr/ uCi*m2 *yr)

  • DBGP = DDE (WB) due to ground plary.e in Rem/yr
  • Survey Instrument Reading = Field Monitoring reading at 1 meter above the ground in mRad/hr
  • 6.132; 5.53E-3; 3.115E14 =Unit conversion factors, including shielding and occupancy factor, 0.7
  • Contamination level = Field Monitoring value in dpm/100cm2
  • Isotopic results = Isotopic of soil sample from Field Monitoring in uCi/gm of each nuclide identified in sample
  • DF = Dose Conversion Factor from US NRC Regulatory Guide 1.109 OR Off-Site Calculation Manual for the nuclide(s) identified in the Isotopic results above

HP/0/B/1009/020 Page 12of12 4.4 Compare calculated doses from Enclosures 5.1and5.2 to Limit and Precaution 3.12:

NOTE: The Radiological Assessment Manager should discuss the above results with Dose Assessors, management, and others as necessary to develop recommendations.

4.4.1 Report results of comparison to the Radiological Assessment Manager.

4.5 Compare calculated doses from Enclosure 5.3 to Limit and Precaution 3.13:

NOTE: The Radiological Assessment Manager should discuss the above results with Dose Assessors, management, and others as necessary to develop recommendations.

4.5 .1 Report results of comparison to the Radiological Assessment Manager.

5. Enclosures 5.1 CDE (Thyroid) From Radioiodine Worksheet 5.2 CEDE From Radiocesium Worksheet 5.3 DDE (WB) From Ground Plane Pathway

Enclosure 5.1 HP/0/B/1009/020 CDE (Thyroid) From Radioiodine Worksheet Page 1of3 Date: - - - - - - Performed by: _ _ _ _ _ _ _ _ _ _ _ __

1. VEGETATION--+ COW/GOAT MILK-+ CONSUMER DOSE PATHWAY 1.1 Vegetation Analysis: Date Sampled - - - - Location - - - -

NOTE:

  • All multiplying factors for vegetation are for cow milk, if dose from goat milk is desired, multiply the dose from cow milk by 1.2.
  • Dose is per day animals eat contaminated vegetation.

Age Vegetation Dose Factor Dose Group Isotope Concentration(µCi/ g) (rem/d/µCi/g) (rem/d)

Infant I-131

  • 3200 I-133
  • 180 I-135
  • 1.1 TOTAL DOSE
===================================================

Adult I-131

  • 420 =

I-133

  • 20 I-135
  • 0.1 TOTAL DOSE

Enclosure 5.1 HP/0/B/1009/020 CDE (Thyroid) From Radioiodine Worksheet Page 2of3 1.2 Milk Analysis: Date Sampled Location Age Milk Dose Factor Dose Group Isotope Concentration (µCi/ml) (rem/d/µCi/ml) (rem/d)

Infant I-131

  • 13000 I-133
  • 3000 I-135
  • 590 TOTAL DOSE

~---------------------------------

~~----------------------------------

Adult I-131

  • 1700 I-133
  • 300 I-135
  • 65 TOTAL DOSE

Enclosure 5.1 HP/0/B/1009/020 CDE (Thyroid) From Radioiodine Worksheet Page 3of3 1.3 Drinking Water Analysis: Date Sampled _ _ _ Location _ __

Age Water Dose Factor Dose Group Isotope Concentration (µCi/ml) (rem/d/µCi/ml) (rem/d)

Infant I-131

  • 12000 I-133
  • 1400 =

I-135

  • 50 TOTAL DOSE
===================================================

Adult I-131

  • 3700 I-133
  • 320 I-135
  • 12 =

TOTAL DOSE

Enclosure 5.2 HP/0/B/1009/020 CEDE From Radiocesium Worksheet Page 1 of2 Date: - - - - - Performed by: _ _ _ _ _ _ _ _ _ __

1. WATER~ FISH ~ CONSUMER DOSE PATHWAY 1.1 Water Analysis: Date Sampled _ _ _ Location _ __

NOTE: Dose is per day fish are exposed to contaminated water.

Age Water Dose Factor Dose Group Isotope Concentration (µCi/ml) (rern/d/µCi/ml) (rern/d)

Teen Cs-134

  • 8000 Cs-136
  • 4600 TOTAL DOSE
===================================================

Adult Cs-134

  • 14000 Cs-136
  • 8200 TOTAL DOSE

Enclosure 5.2 HP/0/B/1009/020 CEDE From Radiocesium Worksheet Page 2 of2 1.2 Fish Analysis: Date Sampled Location Age Fish Dose Factor Dose Group Isotope Concentration (µCi/g) (rem/d/µCi/g) (rem/d)

Teen

  • Cs-134
  • 4.0 Cs-136
  • 2.3 TOTAL DOSE
===================================================

Adult Cs-134

  • 6.9 Cs-136
  • 4.1 TOTAL DOSE

Enclosure 5.3 HP/0/B/1009/020 DDE (WB) From Ground Plane Pathway Page 1 of 1 Date:- - - - Performed by: _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

External irradiation from contaminated Ground Plane NOTE: Calculations apply to all age groups.

Survey/Sample Date: _ __ Location:

Depending upon available data, utilize one of the following calculations:

(Survey Instrument Reading mRad/hr) (Unit Conversions) (Dose REM/yr)

  • (6.132)

(Contamination Level dpm/100cm2) (Unit Conversions) (Dose REM/yr)

(________) * (5.53E-3)

(Isotopic Results uCi/g) (DF) (Unit Conversions) (Dose REM/yr)

( *( ) * (3.115E14)

( )*( ) * (3.115E14)

( )*( ) * (3.115E14)

( )*( ) * (3.l 15E14)

( )*( ) * (3.115E14)

TOTAL DOSE

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

Rev. 1 ATTACHMENT 4 Page 1 of 5

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

Screening and Evaluation Number Applicable Sites BNP 0 EREG #: 02143874 CNS 0 CR3 0 HNP 0 MNS 0 5AD#: 02115680 ONS ffi RNP 0 GO 0 Document and Revision Estimating Food Chain Doses Under Post-Accident Conditions HP/O/B/1009/020 Revision 06 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):

Change# Document Current Wording Proposed Wording Number I Section I. Procedure Duke Power Duke Energy cover sheet

2. Purpose step This procedure is an Emergency Plan NOTE: This procedure is identified as an 1.2 Implementing Procedure (EPIP}. It must Emergency Plan Implementing Procedure. Prior be forwarded to the Emergency Planning to finalizing and approving any revisions, it must Group within three working days of be forwarded to Emergency Preparedness for approval by the responsible group. {PIP review in accordance with 10CFR50.54q 4-0-93-0701} Emergency Plan Effectiveness Review.
3. Reference 2.2 HP/O/B/l 0091018, Offsite Dose Projections AD-EP-ALL-0202, Emergency Response Offsite dose Assessment
4. Reference 2.3 Radiation Protection Section Manual.11.7 HP/O/B/1009/026, Environmental Monitoring for Emerqencv Condition
5. Reference 2.5 PIP 4-0-93-0701, Distribution of CR 01896725, Distribution of Emergency Plan Emergency Plan Implementing Implementing Procedures Procedures
6. NOTE before "... discuss the above results with "... discuss the above results with Dose and after appropriate persons ... " Assessors, management, and others as procedure step necessary ... "

4.5

7. Enclosure 5.4 "Instructions For Use of Raddose-V Deleted Enclosure Ingestion Pathway Program" Part II. Activity Previously Reviewed?

Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or Yes I 0 No I ffi 10 CFR 50.54(q) Continue to Alert and Notification System Design Report? Effectiveness Attachment 4, 10 Evaluation is not CFR 50.54(q)

If yes, identify bounding source document number or approval reference and required. Enter Screening ensure the basis for concluding the source document fully bounds the justification below Evaluation Form, proposed change is documented below: and complete Part Ill Attachment 4, Part

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

Rev. 1 ATTACHMENT 4 Page 2 of 4

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

Justification: v.

Bounding document attached (optional) ID Part Ill. Editorial Change Yes I D No I ~

Is this activity an editorial or typographical change only, such as formatting, 10 CFR SO.S4{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 changes complete Attachment 4, Part V & VI.

' l 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-06S4/FEMA REP-1 Section II? If answer is yes, then check box.

1 1o CFR S0.47{b){1) Assignment of Responsibility (Organization Control) *, . I I

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 S0.47{b){2) Orisite Emergency.Organization  !

2a Process ensures that onshift emergency response responsibilities are staffed and assigned D 2b The process for timely augmentation of onshift staff is established and maintained. D 3 10 CFR S0.47{b)(~) Emergency Rel)ponse Support and Resource~ .

  • o"', '

., I 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)

', *' ,.. . ' I 4

  • 10 CFR S0.4 7{b )(4) Emergency Cl$ssiflcation s'ystem ' '

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

$ 10 9FR S0.47(b)($) NotifiGation M~thodl) and Proc~dures .I Sa Procedures for notification of State and local governmental agencies are capable of initiating notification D of the declared emergency within 1S minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.

Sb 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)

Sc 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 3 of 4

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

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

i o CFR 50.4 7(0)(6) Emergency Communications 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 10 CFR 50.47(b)(7) Public Edu~atiqn ~rd lnforma,tion ., ,  :.. ,,

?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) I 7b Coordinated dissemination of public information during emergencies is established. D

  • 8 *10 CFR50.47(b)(8)*Emergency Facilities and Equipment Ba Adequate facilities are maintained to support emergency response. D D

8b 9

Adequate equipment is maintained to support emergency response.

10 CFR 50.47(b)(9) Accident Asses$ment .,

9a Methods, systems, and equipment for assessment of radioactive releases are in use. ffi 10 10 CFR50.47(b)(10) Protectiv~ Response .

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.

11 ' 10 Cl7R 50.4,7(b)(11)' Radloiogical Exposure Control*

11a The resources for controlling radiological exposures for emergency workers are established. D 12 10 CFR50.47(b)(12) Medical and Public Health Supporj 12a Arrangements are made for medical services for contaminated, injured individuals. D 13 , 10 GFR 50.47(b)(13) Recovery Planning and* Post-accident Operations* '*

13a Plans for recovery and reentry are developed. D

)4 10 CFR 50,.47(b)(14) Drills and Exercise!:l .,

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

  • . i*

15 .10 CFR 50.47(b){15)EmergencyResponse Training.

15a Training is provided to emergency responders. D

\ I I ,

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

Rev. 1 ATTACHMENT 4 Page 4 of 4

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

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

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

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

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

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

>I<

Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q)

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

Part V. Signatures:

Preparer Name (Print): Peter Kuhlman Preparer Signature: Date:

~\-ec.~ol\\C.. .S\~~e <Y"'~\-e.

Reviewer Name (Print): Don Crowl Reviewer Signature: Date:

E \.ec +-roni c.. 6\ ~ t>A-4.t 'C.-

Approver (EP Manager Name (Print): Approver Signature: {!i Date:

William Mcintyre Ekc.\<of"'lic... ~-s.~re.. on LAL Approver (CFAM, as required) Name (Print) Approver Signature: Date:

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

  • 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 7

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

BNP D EREG #: 02143874 CNS D CR3 D HNP D MNS D SAD#: 02115680 ONS RNP D GO D Document and Revision Estimating Food Chain Doses Under Post-Accident Conditions HP/O/B/1009/020 Revision 06 Part I. Description of Proposed Change:

~---

Change# Document Current Wording Proposed Wording Number/

Section

1. Procedure Duke Power 'Puke Energy cover sheet
2. Purpose step This procedure is an Emergency Plan NOTE: This procedure is identified as an 1.2 Implementing Procedure (EPIP). It must t;mergency Plan Implementing Procedure. Prior be forwarded to the Emergency to finalizing and approving any revisions, it must Planning Group within three working t?e forwarded to Emergency Preparedness for days of approval by the responsible review in accordance with 10CFR50.54q Qroup. {PIP 4-0-93-0701} ~merQencv Plan Effectiveness Review.
3. Reference 2.2 HPJO/Bil 009/018, Offsite Dose Projections 'AD-EP-ALL-0202, Emergency Response Offsite dose Assessment
4. Reference 2.3 Radiation Protection Section Manual HP/O/B/1009/026, Environmental Monitoring for 11.7 EmerQencv Condition
5. Reference 2.5 PIP 4-0-93-0701, Distribution of CR 01896725, Distribution of Emergency Plan Emergency Plan Implementing Implementing Procedures Procedures
6. NOTE before " ... discuss the above results with --" ... discuss the above results with Dose and after appropriate persons ... " Assessors, management, and others as procedure step necessary ... II 4.5
7. Enclosure 5.4 " Instructions For Use of Raddose-V Deleted Enclosure lnaestion Pathwav Proaram 11 -.*.~ , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes D Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change) No ~

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

Oconee Emergency Plan

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

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

Section I, Accident Assessment, Rev 2017-002 (Applicable Excerpts) 1.10 Relationship Between Contamination Levels and Integrated Dose/Dose Rates Duke Energy Company has developed a means for relating the various measured parameters (e.g. contamination levels, air and water) and gross radioactivity levels.

Section I, Accident Assessment, Revision 81-2 (Applicable Excerpt~)

1.10 Relationship Between Contamination Levels and Integrated Dose/Dose Rates Duke Power Company is developing a means for relating the various measured parameters (e.g. contamination levels, air and water) and gross radioactivity levels. The initial procedures that will be developed will address 1-131 and XE-133. As further guidance on this situation is developed, Duke will review and revise its procedures as appropriate.

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

a. "Emergency plan" means the document(s) that the licensee prepared and maintains that identifies and describes its methods for maintaining emergency preparedness and respond ins to emergencies. An emergency plan includes the plan that the NRC originally approved and all subsequent change~ that the licensee made with and without prior NRC review and approval under 10 CFR 50.54(q). See 10 CFR 50.54(q)(1)(ii) for additional information.
b. This definition highlights that "emergency plan" includes the docunH~nts that describes the programmatic methods that the licensee uses to maintain emergency preparednes$ ~nd to respond to emergencies. These methods, or program elements, are the implementation aspects of the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 and generally correspond to the evaluation criteria of NUREG-0654 or approved alternatives that supply specific acceptable methodig for complying with the planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50. Such programmatic documents are subject to the 10 CFR 50.54(q) change process. Non-programmatic d9cuments, such as training rosters, equipment and maintenance test reports, lesson plans, and other doeuments that "document the performance" of the program elements, as opposed to those that "establish" the progra.m elements, are not included.
c. Ordinarily, sub-tier documents such as emergency plan implementing procedures (EPIPs) are not considered to be part of an emergency plan for the purpose of evaluating proposed changes. If a licensee relocates a programmatic description from the emergency plan to a sub-tier doc1.,1ment, that programmatic description continues to be subject to the 10 CFR 50.54(q) change process. For example, licensees have relocated the details of emergency classification schemes from the emergency plan to an EPIP or to large wall charts maintained in the control room. Because the EPIP or wall chart is now the means to d~monstrate compliance with the planning standards in 10 CFR 50.47(b)(4), these sub-tier documents are subject to 10 CFR 50.54(q). Repeating, as opposed to relocating, program element descriptions in sub-tier documents do not necessarily make the sub-tier documents subject to the 10 CFR 50.54(q) change process. However, the descriptions in the various documents must remain consistent.
d. As a simple test, a licensee can consider what programmatic document(s), in addition to its emergency plan, it would supply during an inspection to demonstrate that its emergency plan meets the regulatory requirements, as informed by the evaluation criteria in NUREG-0654 or by approved alternatives. These documents would likely be subject to the 10 CFR 50.54(q) change process.
e. This definition also highlights the need to consider the NRC-approved plan and the subsequent changes in reviewing against 1O.CFR 50.54(q) to ensure that a series of incremental changes (each determined not to reduce the effectiveness of the plan) do not reduce the effectiveness of the pl~m when compared to the NRC-approved plan.

The differences in implementing revisions and the current revisions of the Emergency Plans have been reviewed and they have been determined to meet the regulatory requirements required during the course

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

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<< 10 CFR 50.54 q Effectiveness Evaluation Form >>

of revisions. Each revision has been evaluated in the regulatory process has met the approval of the NRC during the inspection process.

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 ghr;:inge is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q):

10 CFR 50.47 Emergency plans.

(b)(9) Adequate methods, systems, and equipment for assessing ang monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Appendix E to Part SO-Emergency Planning and Preparedness for Production and Utilization Facilities IV. Content of Emergency Plans B. Assessment Actions

1. The means to be used for determining the magnitude of, and for c9ntinually assessing the impact of, the release of radioactive materials shall be described, including emergency acti9n levels that are to be used as criteria for determining the need for notification and participation of local and St~te agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and in~trumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC.

Thereafter, emergency action levels shall be reviewed with the State, 111nd local governmental authorities on an annual basis.

Change 1 updated the procedure coversheet to reflect the name of the company to Duke Energy Change 2 clarified the note to state the procedure had to be reviewed prior to approval in accordance with 10CFR50.54q versus routed to Emergency Preparedness following ~pproval and is consistent with other implementing procedures that are listed in the ONS Emergency Plan; Section P.

Changes 3,4 and 5 updated references to superseded procedures. Condition Report numbers corresponding to the legacy PIP numbers updated for easier identification in the Consolid@ted Asset Suite program.

Change 6 clarified the appropriate personnel to be contacted is the Oose Assessor and management.

Changed 7 deleted Instructions For Use of The Ingestion Pathway C~lculation Spreadsheet. Ingestion pathway calculations are the responsibility of State and Local agencies which are addressed in the ONS Emergency Plan Section J.11 and references South Carolina, North Carolina and Geqrsia Fixed Nuclear Facility Plans. The previous Offsite Dose Assessment program, Raddose-V, could be used to calculate ingestion pathway dose. In 2014 Raddose-V was upgraded to URI, the instructions for the program functions are no longer applicable to the software in use.

Conclusion:

The procedure in its entirety continues to comply with Regulation ang Commitments. The proposed changes continue to comply with planning standard (b)(9) and Appendix E IVS because they do not change the methods, systems and equipment used for assessing and monitoring offsite consequences of a radiological emergency condition. The procedure continues to describe the methods to be U$t;ld to estimate off-site doses through significant food chain pathways under post accident conditions.

The changes in this revision update the company name on the cover~heet, update procedure references that have been su erseded and clarif notes as a human erformance im rovement. These chan es do not reduce the

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EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) .. o,*-~.-.*

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<< 10 CFR 50.54 q Effectiveness E;valuation Form>>

effectiveness of the emergency plan or reduce the capability to meeftfie above referenced planning standards.

Part IV. Description of Emergency Plan Planning Standards, Function§ 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)(9)-Emergency Assessment Capability Adequate methods, systems, and equipment for assessing and monitQring actual or potential offsite consequences of a radiological emergency condition are in use.

Appendix E to Part 50-Emergency Planning and Preparedness for Production and Utilization Facilities IV. Content of Emergency Plans B. Assessment Actions

1. The means to be used for determining the magnitude of, and for cgntinually assessing the impact of, the release of radioactive materials shall be described, including emergency actiQn levels that are to be used as criteria for determining the need for notification and participation of local and Stg1te agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be us@d for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and in~trumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, th@i;;e action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergemc;:y action levels shall be discussed and agreed on by the applicant or licensee and state and local governmemt{:ll authorities, and approved by the NRC.

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

Function; Methods, systems, and equipment for assessment of radioactive rele~ses are in use.

Element; NUREG - 0654 I. Accident Assessment

10. Each organization shall establish means for relating the various m@asured parameters (e.g., contamination levels, water and air activity levels) to dose rates for key isotopes (i.e,, those given in Table 3, page 18) and gross radioactivity measurements. Provisions shall be made for estimating integrated dose from the projected and actual dose rates and for comparing these estimates with the protective actl9n guides. The detailed provisions shall be described in separate procedures.

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

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<< 10 CFR 50.54 q Effectiveness Evaluation Form >>

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

The following emergency planning function has been defined for this i;>lanning standard:

Methods, systems, and equipment for assessment of radioactive reletilses are in use.

Change 1 updated the procedure coversheet to reflect the name of the company to Duke Energy Change 2 clarified the note to state the procedure had to be reviewed prior to approval in accordance with 10CFR50.54q versus routed to Emergency Preparedness following ~pproval and is consistent with other implementing procedures that are listed in the ONS Emergency Plan, Section P.

Changes 3,4 and 5 updated references to superseded procedures. C(mdition Report numbers corresponding to the legacy PIP numbers updated for easier identification in the Consolidated Asset Suite program.

Change 6 clarified the appropriate personnel to be contacted is.the Oo$e Assessor and management.

Changed 7 deleted Instructions For Use of The Ingestion Pathway Clf!lculation Spreadsheet. Ingestion pathway calculations are the responsibility of State and Local agencies which @re addressed in the ONS Emergency Plan Section J.11 and references South Carolina, North Carolina and Georgia Fixed Nuclear Facility Plans. The previous Offsite Dose Assessment program, Raddose-V, could be used to calculate ingestion pathway dose. In 2014 Raddose-V was upgraded to URI, the instructions for the program functions are no longer applicable to the software in use.

Conclusion The procedure in its entirety continues to comply with the Emergency Plan Functions. No changes were made to the methods, systems and equipment required for estimating food ch~ln doses and remains unambiguously defined in the procedure.

The changes in this revision update references, clarify notes to provide the user with the appropriate contacts and removed outdated instructions for programs that have been upgraded and previously evaluated in 2014. These changes do not reduce the effectiveness of the emergency plan or reduce the capability to meet the applicable planning standards.

  • Part VI. Evaluation Conclusion.

Answer the following questions about the proposed change.

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

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes~ No D 4 Choose one of the following conclusions:

a The activity does continue to comply with the requirements of 10CFR50.47(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 o@n be implemented without prior NRG approval.

b The activity does not continue to comply with the requirements of 10 CFR 50.47(b) or 10 CFR 50

_J Appendix E or the activity does constitute a reduction in effectivem~ss or EAL scheme change. D Therefore, the activity cannot be implemented without prior NRG 1;1pproval.

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

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

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

I

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Rev.1 ATTACHMENT 5 Page 7 of 7 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 Preparer Signature: Date:

"f\ ko-t\i ~ re.,~ Fr~

Reviewer Name (Print): Don Crowl Reviewer Signature;*- - Date:

t\e.c...\-ron\c. O"Y\ F,\~.

Approver (EP Manager) Name (Print): Approver Signature: Date:

William Mcintyre E\-!c:\.<o<--iC 'S\ >Y'A.4-u.tt.. o" \:"*~

Approver (CFAM, as required) Name (Print): Approver Signature: Date:

N/A If the proposed activity is a change to the E-Plan or implementing prQcedures, then create two EREG General Assignments. *

  • 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
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