ONS-2018-006, Summary of Changes to Emergency Plan

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Summary of Changes to Emergency Plan
ML18012A054
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 01/04/2018
From:
Duke Energy Carolinas
To:
Office of Nuclear Reactor Regulation
Shared Package
ML18012A045 List:
References
ONS-2018-006
Download: ML18012A054 (13)
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Text

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 OCONEE NUCLEAR STATION EMERGENCY PLAN 10 CFR 50.54 (q)

SUMMARY

OF CHANGES ATIACHMENT 1 Page 1 of 13

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 NOTE: Any changes that did not require Evaluation under 10CFR 50.54( q) are noted at the end each section. All other changes have been evaluated in EREG #2162386 (available upon request).

Activity Description for EPA Section A (ONS Emergency Plan Section A* Assignment of Responsibility (Organizational Control)) Rev 2018-001 (DRR 02146146)

Entire Section

1. Changed revision number from 2016-002 to 2018-001; changed date from September 2016 to January 2018.

Section A.1.b

2. Updated position title from "Operations Shift Manager" to "Shift Manager" Section A.1.d
3. Deleted "(Figure 8-5)" from title of section.
4. Updated position title from "Operations Shift Manager" to "Shift Manager"
5. Updated to reflect revised tables/figures from EPA Section 8. Changed "8-6" to "Section 8.5.c.1 )"

Section A.1.e

6. Updated position title from "Operations Shift Manager" to "Shift Manager" Figure A-3
7. Updated position title from "Operations Shift Manager" to "Shift Manager" Changes 1 through 7 above are editorial and do NOT require evaluation.

Activity Description for EPA Section B (ONS Emergency Plan Section B- Onsite Emergency Organization) Rev 2018-001 (DRR 02146159)

Entire Section

1. Changed revision number from 2017-002 to 2018-001; changed date from March 2017 to January 2018.
2. This was a major rewrite to adopt the Standard ERO. Significant changes include:

o Revised to incorporate the Fleet Standard Organization.

o Deleted Figure 8-1 which provided a listing of the groups that staff the various functional areas.

o Renumbered Figures 8-2 through 8-4 as 8-1 through 8-3 and updated facility organization structure per Standard ERO. Also added new Figure 8-4 with organization for the JIC.

o Moved responsibilities of the Emergency Coordinator and EOF Director from Figures 8-5 and 8-6 to steps 8.5.a.1 and 8.5.c.1 of the body. Also added description of responsibilities for various other positions in the Emergency Response Organization.

o Replaced Figure 8-8a and 8-8b with Table 8-1a and 8-1 b for consistency with the fleet.

  • These figures/tables continue to outline Minimum On-Shift Staffing levels and Minimum Augmented ERO Staffing levels respectively.

Page 2 of 13

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287

  • Added OSC Manager as a 75 minute (minimum staffing) responder.
  • Added typical Full Staffing positions to Table 8-1 b.

o Contents of old Figures 8-9 and 8-11 were merged with old 8-4 in the new 8-3.

o Figures 8-10 which provided which site groups typically perform various duties was deleted. As individuals with various backgrounds have moved into other site organizations, assignments to ERO positions is based on knowledge and abilities versus which group an individual works in.

Change 1 above is editorial and does NOT require evaluation.

Activity Description for EPA Section D (Emergency Action Level Technical Basis) Rev.

2018-001 (DRR 02151860)

Entire Section

1. Changed revision number from 2017-002 to 2018-001; changed date from March 2017 to January 2018.
2. Updated title of AD-EP-ALL-0203 from "Protocol for Field Monitoring Coordinator During Emergency Conditions" to "Field Monitoring During Declared Emergency" on pages D-38, D-39, D-44, D-45, D-50, D-51 Changes 1 and 2 above are editorial and do NOT require further evaluation.

Activity Description for EPA Section F (ONS Emergency Plan Section F

  • Emergency Communications) Rev 2018-001 (DRR 02146167)

Entire Section

1. Changed rev number from 2016-003 to 2018-001; changed date from December 2016 to January 2018.

Figure F-2

2. 48.5 MHZ - Deleted "and AD-EP-ALL-0203 (Protocol for Field Monitoring Coordinator During Emergency Conditions)."
3. 800 MHZ - Updated title of AD-EP-ALL-0203 from "Protocol for Field Monitoring Coordinator During, Emergency Conditions" to "Field Monitoring During Declared Emergency" Changes 1 and 3 above are editorial and do NOT require further evaluation.

Activity Description for EPA G (ONS Emergency Plan Section G - Public Information and Education) Rev 2018-001 (DRR 02146172)

Entire Section

1. Changed rev number from 14-02 to 2018-001; change date from October 2014 to January.

2018 Section G.3 Page 3 of 13

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287

2. First paragraph, last sentence, changed "The news manager and public spokesperson are the primary contacts for the news media." to "A company spokesperson will be designated to act as the primary contact with the news media."
3. Second paragraph, last sentence, revised from "If the EOF is activated, then the Standard Procedure for Public Affairs Response To The Emergency Operations Facility (SR/O/A/2000/001 ), and the Duke Energy Company Communications and Community Relations World of Energy Emergency Response Plan (RP/0/A/1000/028) are implemented for gathering and disseminating information." to "If the EOF is activated, then the Joint information Center (JIC) implements procedures for gathering and disseminating information."

Section G.4.a

4. Changed "Public Spokesperson" to "Company Spokesperson" throughout.

Change 1 above is editorial and does NOT require further evaluation.

Activity Description for EPA Section H (ONS Emergency Plan Section H - Emergency Facilities and Equipment) Rev 2018-001 (DRR 02146175)

Entire Section

1. Changed Rev number from 2017-002 to 2018-001; changed date from March 2017 to January 2018 Sections H.1.a, H.1.b, and H.1.c
2. Changed "Operational Support Center" to "Operations Support Center" Section H.9
3. Changed "Operational Support Center" to "Operations Support Center" Figure H-1
4. Updated Typical Technical Support Center (TSC) Primary Location Unit 1&2 Ops Center drawing to reflect Standard ERO Position Titles.

Figure H-2

5. Changed "Operational Support Center" to "Operations Support Center"
6. Updated Typical Operations Support Center (OSC) Primary Location Unit 3 Operations Center drawing to reflect Standard ERO Position Titles.

Figure H-15

7. Changed "Operational Support Center" to "Operations Support Center"
8. Updated procedure reference from ST/O/A/4600/086 to TE-EP-ALL-0407.

Figure H-17

9. Changed "Operational Support Center" to "Operations Support Center" Changes 1 and 8 above are editorial and do NOT require further evaluation.

Page 4 of 13

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Activity Description for EPA Section I (ONS Emergency Plan Section I - Accident Assessment) Rev 2018-001 (DRR 02146180)

Entire Section

1. Changed Rev number from 2017-002 to 2018-00°1; changed date from March 2017 to January 2018 Section 1.1
2. First paragraph, fourth sentence, changed "The Emergency Classification procedure (RP/O/A/1000/001) identifies" to" Emergency Classification procedure(s) identify" Section 1.3.a
3. Deleted "of RP/O/A/1000/001"Section I. 7/1.8
4. Changed the second sentence from, "These teams are comprised of a RP Technician and a FMT Driver." to "These teams are comprised of a Field Monitor Team (FMT) Qualified Technician and a FMT Driver."
5. Third sentence, added "AD-EP-ONS-0203" after "AD-EP-ALL-0203"
6. Replaced superseded procedure SH/0/8/2005/003 with AD-EP-ALL-0204.

Section 1.9 Detect and Measure Radioiodine Concentration in EPZ

7. Change "uCi" to "µCi" Section 1.11
8. Deleted "Company" after "Duke Energy" Changes 1, 6, 7 and 8 above are editorial and do NOT require further evaluation.

Change 4 was previously evaluated in EREG 2146280 and does NOT require further evaluation.

Activity Description for EPA Section J (ONS Emergency Plan Section J

  • Protective Response) Rev 2018-001 (DRR 02146183)

Entire Section

1. Changed Rev number from 2015-007 to 2018-001; changed date from November 2015 to January 2018 Section J.1
2. Second paragraph - Corrected grammar and punctuation.

Section J.3

3. Third paragraph - Corrected grammar and punctuation.

Section J.5 & J.6

4. Changed "Operational Support Center" to "Operations Support Center" throughout
5. Third paragraph - Corrected punctuation.

Page 5 of 13

Duke Energy Carolinas, LLC Oconee.Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Section J.7

6. Updated Section title from "Protective Action Recommendations" to "Offsite Protective Action Recommendations"
7. Updated position title from "Operations Shift Manager" to "Shift Manager"
8. First paragraph, second sentence, revised from "Procedure RP/0/A/1000/024, 'Protective Action Recommendations,' and SR/O/A/2000/003, 'Activation of the Emergency Operations Facility" has been written" (sic) to "Procedure AD-EP-ALL-0109, Offsite Protective Action Recommendations, has been written" and deleted the word "respectively."
9. Second paragraph - Corrected punctuation.

Section J.9

10. Second paragraph - Corrected punctuation.

Figure J-1

11. Replaced Protective Action Recommendation Flow Chart to reflect the NUREG-0654 Supplement 3 PARs implemented in December 2014 and changes made to the PAR flow chart to update EAL references following implementation of NEl-99-01 Rev. 6 EALs in March 2017.

This change is in response to 75771 Federal Register/ Vol. 76, No. 233 / Monday, December 5, 2011 / Rules and Regulations where the U.S. Nuclear Regulatory Commission (NRC) issued Supplement 3, Guidance for Protective Action Strategies, to NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. NUREG-0654, Supplement 3, provides guidance for addressing new EP requirements for nuclear power plants based on changes to EP regulations in 10 CFR 50.47 and Appendix E to Part 50,Section IV.3, in the November 23, 2011, final rule. Specifically, the guidance of Supplement 3 provides an acceptable method to comply with Appendix E to Part 50, Title 1O of the Code of Federal Regulations (10 CFR)Section IV, paragraph 3 in the use of evacuation time estimates in the formulation of protective action recommendations (PARs) for the plume exposure emergency planning zone, and provides guidance for the provisions of 10 CFR 50.47(b)(10) in the development of a range of PARs.

This revision provides Protective Action Recommendations (PAR) based upon three new scenarios: Rapidly Progressing Severe Accident (RPSA), Hostile Action and Impediments to Evacuation during a General Emergency (GE). A new recommendation is to Shelter instead of immediate evacuation for given times and type of events. RPSA only applies to first PAR on initial General Emergency declaration. RPSA is based upon the following criterion: loss of containment barrier per EALs with a potential loss of containment barrier per containment radiation monitors per EALs OR projected radiological release at site boundary to exceed PAGs within one hour.

Figure J-1 contains the following initial PARs:

  • If event is a Rapidly Progressing Severe Accident (RPSA), then the PARs are Evacuate 2 mile Radius, Evacuate 2 - 5 miles Downwind and Shelter 5 -10 miles Downwind.

Page 6 of 13

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287

  • If event is a Hostile Action, then the PARs are Shelter 2 mile Radius and Shelter 2 - 5 miles Downwind.
  • If there is a known offsite impediment to evacuation, then the PARs are Shelter 2 mile Radius and Shelter 2 - 5 miles Downwind.
  • If any other event has generated a General Emergency, then the PARs are evacuate 2 mile Radius and evacuate 2 - 5 miles Downwind.

In the case of an RPSA or any other event has generated a General Emergency, if offsite dose projections or field measurements are greater than or equal to 5 Rem COE Thyroid, recommend the consideration of use of Kl by the public.

Figure J-1 includes the following expanded PARs:

  • If event is a Hostile Action, a known offsite impediment to evacuation, or a short term release is in progress, then the PARs are Shelter 2 mile Radius, Shelter 2 - 5 miles Downwind and Shelter additional zones that exceed PAGs.
  • If General Emergency conditions exist, then the PARs are evacuate 2 mile Radius and evacuate 2 -5 miles Downwind.
  • If offsite dose projections or field measurements are greater than PAGs, Evacuate zones that exceed PAGs.
  • If offsite dose projections of field measurements are greater than or equal to 5 Rem COE Thyroid, recommend the consideration of use of Kl by the public.

Changes 1, 2, 3, 5, 7, 8 1 9, and 10 above are editorial and do NOT require further evaluation.

Activity Description for EPA Section K (ONS Emergency Plan Section K - Radiological Exposure Control) Rev 2018-001 (DRR 02146190)

Entire Section

1. Changed rev number from 2015-004 to 2018-001; change date from April 2015 to January 2018 Section K.1
2. ** Note, second sentence, changed location of Radiation Protection Manager from OSC to TSC.

Section K.2

3. First paragraph, first sentence, updated position title from "Operations Shift Manager" to "Shift Manager"
4. First paragraph, first sentence and third paragraph second sentence, changed location of Radiation Protection Manager from OSC to TSC.

Section K.3.a

5. Changed "Operational Support Center" to "Operations Support Center" Page 7 of 13

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Section K.3.b

6. Changed positon title from "Surveillance and Control Coordinator " to "RP Supervisor"
7. Changed "Operational Support Center" to "Operations Support Center" throughout Section K.5.a
8. Change "the Radiation Protection Policy Manual" to "Radiation Protection Procedures"
9. Made "contamination control" lower case.
10. Deleted last sentence, "Preplanning efforts have been established by the Surveillance and Control Coordinator."

Section K.5.b

11. First paragraph, Emergency Personnel wounds, added "Potentially contaminated wounds shall be addressed per AD-RP-ALL-2018, Response to a Contaminated Wound. "
12. First paragraph, last sentence, deleted sentence which read, "See Radiation Protection Policy Manual, Section Vl-04, Investigation of Unusual Radiological Occurrences."
13. Third paragraph, Instruments and equipment, changed "For specific information refer to Radiation Protection Policy Manual Section 111-9, Contamination Control." to "Contamination control is accomplished using equipment and processes employed during routine operation.

If emergency conditions dictate, alternate contamination control measures will be implemented by the Radiation Protection Manager on a case-by-case basis."

Section K.6.b

14. Third sentence, changed "as evidenced by the Radiation Protection Policy Manual" to "described in AD-RP-ALL-2009" Changes 1, 3, and 9 above are editorial and do NOT require further evaluation.

Activity Description for EPA Section M (ONS Emergency Plan Section M - Recovery and Re-entry Planning and Post-Accident Operations) Rev 2018-001 (DRR 02146214)

Entire Section

1. Changed rev number from 2016-002 to 2018-001; changed date from September 2016 to January 2018.

Section M.2

2. Second sentence - Changed "Figure M-1 and M-2 describe" to "Figure M-1 describes a"
3. Third sentence - Changed "They" to "It" Section M.3
4. Changed "the following procedures" to "procedure AD-EP-ALL-0110, Recovery"
5. Deleted references to the following procedures:
  • TSC/OSC - RP/0/A/1000/019, RP/0/A/1000/027
  • EOF - SR/O/A/2000/003
  • JIC - RP/O/A/1000/031 Page 8 of 13

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Figures M-1 and M-2

6. Deleted existing figures and replaced with new Figure M-1, Recovery Organization Changes 1, 2, 3, 4, and 5 above are editorial and do NOT require further evaluation.

Activity Description for EPA Section N (ONS Emergency Plan Section N- Exercises and Drills} Rev 2018-001 (DRR 02146216)

Entire Section

1. Changed rev number from 2015-007 to 2018-001; change date from November 2015 to January 2018 Section N.2.h
2. Changed frequency of Multi-Station Event Drills from once every six years to once every eight years.
3. Last sentence, deleted "This drill will be rotated between participation with Catawba and McGuire."

Change 1 above is editorial and does NOT require further evaluation.

Changes 2 and 3 are fully bounded by an NRC approved 10CFR50.90 submittal. See 10CFR50.54(q) screening Part II.

Activity Description for EPA Section O (ONS Emergency Plan Section 0- Emergency Response Training} Rev 2018-001 (DRR 02151236)

Entire Section

1. Changed rev number from 12-05 to 2018-001; change date from December 2012 to January 2018 Section 0.1
2. Third paragraph, last sentence, replaced "the Oconee Training Division Training Guide ERTG-001, 'Emergency Response Organization and Emergency Services Training Program' "with "AD-EP-ALL-0500, Emergency Response Training."

Section 0.2

3. Second paragraph, replaced "Nuclear Generation Department 'Employee Training and Qualification System (ETQS)' Standard 7111.0" with "AD-EP-ALL-0500, Emergency Response Training."

Section 0.5

4. Replaced "Oconee Training Division Training Guide ERTG-001, 'Emergency Response Organization and Emergency services Training Program' "with "AD-EP-ALL-0500, Emergency Response Training."

Figure 0-1

5. Replaced "Oconee Training Division Training Guide ERTG-001, 'Emergency Response Organization and Emergency services Training Program' "with "AD-EP-ALL-0500, Emergency Response Training."

Page 9 of 13

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Changes 1, 2, 3, 4, and 5, above are editorial and do NOT require further evaluation.

Activity Description for EPA Section P (ONS Emergency Plan Section P - Responsibility for the Planning Effort: Development, Periodic Review, and Distribution of the Emergency Plans) Rev 2018-001 (DRR 02146221)

Entire Section

1. Changed rev number from 2017-004 to 2018-001; change date from October 2017 to January 2018 Figure P1
2. Revised table to delete and add procedures as a result of the Fleet Standard ERO Project and JIC procedures and to correct other outdated procedure references and incorrect procedure titles.

Old Procedure Old Procedure Title New Procedure New Procedure Title Number Number Standard Procedure AD-EP-ALL-0107 Emergency AD-EP-ALL~0107 for EOF Services Operations Facility (EOF) Services Protocol for Field AD-EP-ALL-0203 Field Monitoring Monitoring During Declared Coordinator During Emergency AD-EP-ALL-0203 Emergency AD-EP-ONS-0203 ONS Site Specific Conditions Field Monitoring Information EP FAM 3.11 State/County EOC AD-EP-ALL-0103 Activation and Liaison Reference Operations of the Manual Emergency Operations Facility ERTG-001 Emergency Response AD-EP-ALL-0500 Emergency Response Organization and Training Emergency Services AD-TQ-ALL-0086 Fire Brigade and Training HAZMAT Training AD-SY-ALL-0520 Security Training ETQS 3104.0 Radiation Protection AD-TQ-ALL-0040 Radiation Protection Training and Training Program Qualifications ETQS 7104.0 Radiation Protection AD-RP-ALL-1104 Radiation Protection Staff Professional Staff Professional Development Development Program Program ETQS7111.0 Emergency Response AD-EP-ALL-0500 Emergency Response Training Training HP/0/8/1009/009 Procedure For HP/0/8/1009/009 Procedure For Determining The Determining The lnplant Radioiodine lnplant Airborne Page 10 of 13

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Old Procedure Old Procedure Title New Procedure New Procedure Title Number Number Concentration During Radioiodine Accident Conditions Concentration During Accident Conditions HP/0/B/1009/018 Off-Site Dose AD-EP-ALL-0202 Emergency Response Projections Offsite Dose Assessment HP/0/B/1009/022 On-Shift Off-Site AD-EP-ALL-0202 Emergency Response Dose Projections Offsite Dose Assessment HP/0/B/1009/026 Environmental AD-EP-ONS-0203 ONS Site Specific Monitoring for Field Monitoring Emergency Information Conditions NPM Chapter 15 Corporate IA-AD-ALL-0002 Corporate Communications Communications Departmental Departmental Interface Interface Agreement Agreement NSD-117 Emergency Response AD-EP-ALL-0100 Emergency Response Organization Staffing, Organization Training, and Responsibilities NSD-119 Medical Emergency AD-SY--ALL-0280 Medical Emergency Response Team Response and (MERT) Program Technical Rescue Organization, Program Training, and Responsibilities RP/0/A/1000/001 1 Emergency AD-EP-ALL-0101 Emergency Classification Classification RP/0/A/1000/0158 Offsite AD-EP-ALL-0304 State and County Communications from Notifications the Technical Support Center RP/0/A/1000/019 Technical Support AD-EP.:ALL-0105 Activation and Center Emergency Operation of the Coordinator Technical Support Procedure Center AD-EP-ONS-0105 ONS Site Specific TSC Support RP/0/A/1000/024 Protective Action AD-EP-ALL-0109 Protective Action Recommendations Recommendations 1

Procedure RP/0/A/1000/001 is not being deleted at this time; AD-EP-ALL-0101 has been added for use by TSC and EOF for all sections where RP/O/A/1000/001 was listed.

Page 11 of 13

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Old Procedure Old Procedure Title New Procedure New Procedure Title Number Number RPIOIA/10001025 Operations Support AD-EP-ALL-0106 Activation and Center Manager Operation of the Procedure Operations Support Center AD-EP-ONS-0106 ONS Site Specific OSC Support RPIOIA/10001027 Re-Entry Recovery AD-EP-ALL-0110 Recovery Procedure RPIOIA/10001028 Nuclear AD-EP-ALL-0108 Joint Information Communications System Support Emergency Response Plan.

RPIOIA/10001031 Joint Information AD-EP-ALL-0108 Joint Information Center Response System Support Plan RPIOIA/10001037 Incident Command AD-EP-ALL-0105 Activation and Post Operations and Operation of the Radiation protection Technical Support Liaison Guidelines Center RPIOIB110001011 Planned Emergency AD-EP-ALL-0205 Emergency Exposure Exposure Controls S R/01A/20001001 Corporate AD-EP-ALL-0108 Joint Information Communications System Support response to the Emergency Operations Facility SR/01A/20001003 Activation of the AD-EP-ALL-0103 Activation and Emergency Operations of the Operations Facility Emergency Operations Facility SR/01A/20001004 Notification to States AD-EP-ALL-0304 State and County and Counties from the Notifications Emergency Operations Facility for Catawba, McGuire and Oconee STIOIA/46001086 Standard Procedure TE-EP-ALL-0407 Verification of for Periodic Emergency Verification of EOF Operations Facility Communication Communication Equipment Operation Equipment Operation and Equipment/ and Equipment/

Supply Inventory Supply Inventory Standard Procedure Periodic Test Of The STIOIA/46001094 TE-EP-ALL-0408 for Periodic Test Of Emergency Page 12 of 13

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Old Procedure Old Procedure Title New Procedure New Procedure Title Number Number The EOF Selective Operations Facility Signaling, ENS and DEMNET, ENS and ETS ETS ERO Common NIA NIA AD-EP-ALL-0104 Guidelines and Forms Changes 1 and 2 above are editorial and do NOT require further evaluation.

Activity Description for EPA Appendix 1 (ONS Emergency Plan Appendix 1 - Definitions)

Rev 2018-001 (DRR 02146225)

Entire Section

1. Changed rev number from 2012-05 to 2018-001; change date from December 2012 to January 2018 Joint Information Center
2. Deleted "in the Oconee EOF" Media Center
3. Change "Co-Located" to "Located" and deleted "to the Oconee EOF" Operational Support Center
4. Changed "Operational Support Center" to "Operations Support Center" Change 1 above is editorial and does NOT require further evaluation.

Activity Description for EPA Appendix 6 (ONS Emergency Plan Appendix 6 - Distribution of Emergency Plan and Implementing Procedures) Rev 2018-001 (DRR 02066176)

Entire Section

1. Changed rev number from 14-02 to 2018-001; change date from October 2014 to January 2018 Distribution list
2. Updated Fleet Emergency Preparedness mail code Changes 1 and 2 above are editorial and do NOT require further evaluation.

Page 13 of 13

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