RA-20-0043, Station. Units 1, 2, and 3 - Emergency Plan Revision 2020-001

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Station. Units 1, 2, and 3 - Emergency Plan Revision 2020-001
ML20037B418
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 02/06/2020
From: Burchfield J
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0043
Download: ML20037B418 (18)


Text

(_-, DUKE

~ ENERGY J. Ed Burchfield, Jr.

Vice President Oconee Nuclear Station Duke Energy ON01 VP I 7800 Rochester Hwy RA-20-0043 Seneca SC 29672 864.873 3478 864 873 4208 Ed Burchfield@duke-energy com February 6, 2020 10 CFR 50.54(q) 10 CFR 72.44(f)

Attn: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852-2746

Subject:

Duke Energy Carolinas. LLC Oconee Nuclear Station. Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Emergency Plan Revision 2020-001 Pursuant to 10 CFR 50.54(q), and 10 CFR 72.44(f) . Duke Energy is submitting the attached summary of changes to the Oconee Nuclear Station (ONS) Emergency Plan which became effective January 9, 2020.

This revision has been evaluated in accordance with 10 CFR 50.54(q) and it was determined that the change did not reduce the effectiveness of the ONS Emergency Plan. The revised ONS Emergency Plan continues to meet the requirements of Appendix E to 10 CFR 50 and the planning standards of 10 CFR 50.47(b).

If there are any questions or concerns pertaining to this revision please call Sheila Dalton, Manager Nuclear Support Services, at 864-873-3657.

Sincerely, JGI fLJ/J,I/

J. Ed Burchfield , Jr.

Vice President Oconee Nuclear Station Attachments EPLAN CHANG E SUMMA RY 2020-001 - Sections A,B,E,F,H,J,L,P EPLAN CHANG E SUMMA RY 2020-001 - Appendices 2,3,4,5

RA-20-043 U. S. Nuclear Regulatory Commission February 6, 2020 Page2 xc: Ms. Laura Dudes Administrator, USNRC Region II Marquis One Tower 245 Peachtree Center., NE Suite 1200 Atlanta GA 30303-1257 Ms. Andrea Kock Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Audrey Klett Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Mike Mahoney Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Jared Nadel NRC Senior Resident Inspector Oconee Nuclear Station

EPLAN CHANGE

SUMMARY

2020-001 - Sections A,B,E,F,H,J,L,P Attachmen t to 50.54q CHANGE MATRIX

  1. Page Current Proposed Change Reason

/Section

1. Section A See State of South Carolina FNF See State of South Carolina editorial, Plan Fixed Nuclear Facility (FNF) Plan spelled out
p. A-1 initial A.l.a acronym, FNF
2. Section A Duty personnel are assigned to Duty personnel are assigned to Consolidated the Emergency Response the Emergency Response Recall
p. A-3 Organizations as first responders Organizations as first procedure, A.l.e since they can be readily reached responders since they can be same after after hours and weekends. Recall readily reached after hours and hours as procedures for emergency weekends. Recall procedures normal response is shown as Figure A-2A for emergency response is business (weekdays Monday-Thursday shown as Figure A-2 . Security hours.

0700-1730), Figure A-2B (after will activate the ERO hours, weekends, holidays). notificatio n device. In the event Security will activate the ERO Security is not available to notificatio n device. In the event perform the activities such as Security is not available to during a security threat the SM perform the activities such as or designee will activate the during a security threat the SM ERO.

or designee will activate the ERO.

EPLAN CHANGE

SUMMARY

2020-001 - Sections A,B,E,F,H,J,L,P Attachment to 50.54q CHANGE MATRIX

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/Section

3. Section A FIGUREA-2A deleted merged Figures 2A old p. A-6 m:u: ENERGY CmIPANY OCONEE Nl:CLEAR SITE and 2B,

~ - - - -~E.,::IJuE..R,.,.GuE..~,.,,

-c..J*yccoi.Ri:>G *clul..,l=-===..ll.=....,,.,._.u~ ""-"'-""-"'----~

IM4N~~:~~KSRO II+*--------

renumber ,._,,.,.,

~.. 1z"'4.._.J"l""

Q.,'<..1R,.E.,,c"'

standard ed *

  • CR OFFSITE.'N~C OPE~~IONS CEPJTfR recall process COMMUNICATOR remaining OPER ... TIONS SUPERINTENDENT
  • OFFSITE 4.GENCIES SWPOEMPEM regardless of SM pages. ACTNATES ERO IF SECURITY IS business UNABLE hours.

STATION MaNAGER SITE SERVK:ES RA.OIA'ilOf~ WOE/COMMUNITY PROTECTION A.FFAIRS CHEMISffl

"-ORK CONTROL 1 1

  • ~....tbod-PA.Amtt'!mC.....m, S~bo:i.0.-.'1..:t B.amp =*i!iad- Nuc~ C.ill,mt Sy, MAINTENANCE 1 EH4.S Section A FIGl'RI: A-2B see next old p. A-7 DUKE ENERGY CO!IP.A...,"Y OCO!S"EE NUCll.-\ll. SIIT line EMERCE~*cy ORG.A:.'llZ:-tTIQS RECAll - BACKSBifT BQLIDAYS \\'"£EKE..1'iD;S*

3ECU,UTY ACTNATE3TWE

  • Pnmaiy Method -PA Announcement' Noniic:mon De,,,ce Bad: up Method - Kudear C,allont S,,ti,m

EPLAN CHANGE SUMMAR Y 2020-001 - Sections A,B,E,F,H,J,L,P Attachment to 50.54q CHANGE MATRIX

  1. Page Current Proposed Change Reason

/Section Section A see previous FIGUREA-2 merged line Figures 2A old p. A-7 Dt,AE E.'iE.RGY COl\11'_-u\-Y OCONEE i\TC'LE.utSITE N i"t;n'Vll.f.J.T "'*n'D"'-"n\:'l".!:UnT"!'DC: 3ndD ,,...._.... TTT'P"'I"'

and 28, n~m*

ATW" 11121;uui~

new p. A-6 standard I

[::] ~

OPERAnotl I CROfFSITEJNRC 3ECUl'ffY I COl,MlJNICATOR c~

OFFSfTE recall process AGENCIES regardless of I -~IN

-'CTIVATES,THE - ~ -

AClJVATl;B~OtF *I -OEM business I

iiRO SECURl1Y IS t.V1Ke1SPA AHNOUNCbf.ENT u~

l hours.

Updated H*w"""'"°"I SPOCT£MI H 0eEAAOONO I 1 SITE&ERVlCE.S r organizationa H IRADlftTION P-JIOT£CllON H OVPF<<PlYC>IAIN y I Y~-*I 5T-'l10N D"1Y NRCRE61DENT INSPECTOR

~

  • Primary M°'thod - PA Amruntementl NotificationOe,,,ce Back up ~tbod - Nuclear Callrut System
5. Section A .... For any classification above an .... For any classification above editorial, an Unusual Event, the removed old p. A-8 Unusual Event, the Emergency Emergency Response spacing in Response Organization will be new p. A-7 Organization will be activated. sentence.

activated .

6. Section 8 ... Figures A-1 [RMl]illustra tes ... ... Figures A-1 illustrates ... editorial,
p. 8-20 removed unintended 1st rendering sentence inject.
7. Section 8 ... The EOF Director would have ... The EOF Director would have editorial, overall emergency management overall emergency management removed
p. 8-20 responsibility for both responsibility for both events. unintended 8.7 events.[RM2] rendering inject.
8. Section 8 Oconee Memorial Hospital - Oconee Memorial Hospital - editorial,

EPLAN CHANGE

SUMMARY

2020-001 - Sections A,B,E,F,H,J,L,P Attachment to 50.54q CHANGE MATRIX

  1. Page Current Proposed Change Reason

/Section

p. B-20 Greenville Health System Prisma Health System name change B.9
9. Section E Figures A-2A and A-2B illustrate Figure A-2 illustrates the merged the methods used by method used by the Shift Figures 2A
p. E-1 Manager/Emergency and 2B, the Shift Manager/Emergency E-1 & E.2 Coordinator to activate the standard Coordinator to activate the Emergency Response recall process Emergency Response Organization. regardless of Organization. business hours
10. Section F A back-up radio system provides deleted 48.5 MHz alternate communications with radio
p. F-1 Oconee and Pickens Counties removed f.l.a emergency response from service.

organizations. (Figure F-2)

11. Section F On a monthly basis, a On a monthly basis, a 48.5 MHz communication check is made to communication check is made radio
p. F-1 state and local to state and local government removed f .1.b warning points within the from service.

government warning points Emergency Planning Zone.

within the Emergency Planning Communications during an Zone.

emergency situation would be Communications during an by DEM NET, site telephone emergency situation would be by system/commercial phone DEMNET, site service.

telephone system/commercial phone service, or by radio (where appropriate).

12. Section F Emergency Radio System {Offsite Emergency Radio System 48.5 MHz System-Batte!Y Backed} {Offsite System-Batte[Y Backed} radio
p. F-2 removed Control Room Units 1&2 (48.5 Technical Support Center

EPLAN CHANGE

SUMMARY

2020-001- Sections A,B,E,F,H,J,L,P Attachment to 50.54q CHANGE MATRIX

  1. Page Current Proposed Change Reason

/Section f.l.d4) MHZ) Field Monitoring Teams (800 from service.

MHZ)

Technical Support Center State of South Carolina Field Monitoring Teams (800 MHZ)

Pickens County (48.5 MHZ)

Oconee County (48.5 MHZ)

State of South Carolina

13. Section F Normal Working Hours (Figure A- Normal Working Hours and merged
p. F-4 ' Weekends, Holidays, Backshift Figures 2A and 28,
1. Have announced over the 1. Have announced over the f.1.e standard Public Address system that the Public Address system that the recall process renumber Emergency Response Emergency Response regardless of ed Organization (Technical Support Organization (Technical Support business remaining Center and Operations Support Center and Operations Support hours.

pages Center) are to be staffed. Center) are to be staffed.

Site Assembly

2. Security will activate the ERO. 2. Security will activate the ERO.

changed to If security is unable to activate If security is unable to activate the ERO, the SM (or designee) Site Area the ERO, the SM (or designee)

Emergency will activate the ERO . will activate the ERO.

3. Notify Duty Operations 3. Notify Shift Technical Engineer who verifies Plant Advisor(STA) who verifies Plant Manager and Nuclear Operations Manager and Nuclear Manager have been notified. Operations Manager have been notified.
4. Initiate a Site Assembly (Required at an Alert or higher). 4. Initiate a Site Assembly (Required at a Site Area
5. Individual groups will contact Emergency or higher).

corporate personnel for support.

5. Individual groups will contact Section F Weekends, Holidays, Backshift corporate personnel for (Figure A-28) old p. F-5 support.
1. Security will activate the ERO.

new F-4 If security is unable to activate

EPLAN CHANGE

SUMMARY

2020-001 - Sections A,B,E,F,H,J,L,P Attachmen t to 50.54q CHANGE MATRIX

  1. Page Current Proposed Change Reason

/Section f.1.e the ERO, the SM (or designee) will activate the ERO.

2. Duty Operations Engineer who verifies Plant Manager and Nuclear Operations Manager have been notified.
3. Announce over the PA system that the Emergency Response Organization (Technical Support Center and Operations 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.
14. Section F DPC Qffsite Radig S~stem DPC Qffsite Radig S~stem 48.5 MHz Fig. F-1 Pickens LEC radio X Pickens LEC removed Pickens EOC. ... X Pickens EOC from service.

Oconee LEC. ... X Oconee LEC

15. Section F ... The network consists of two The network consists of a radio 48.5 MHz radio frequencies which provide frequency which provides the radio Fig. F-2 the following services: following services: removed from service.
16. Section F A. 48.5 MHZ deleted 48.5 MHz Fig. F-2 ** Backup communications radio between ONS, Pickens County removed re-lettered

EPLAN CHANGE

SUMMARY

2020-001- Sections A,B,E,F,H,J,L,P Attachment to 50.54q CHANGE MATRIX

  1. Page Current Proposed Change Reason

/Section remaining Emergency Preparedness Agency from service.

step and Oconee County Emergency Preparedness Agency .

.. Operating instructions are shown in the Emergency Telephone Directory ..

17. Section H Division/Section Directives Division/Section Directives editorial, fix describe the Emergency describe the Emergency reference
p. H-4 Response Organization. Figures Response Organization. Figure step H.4 A2A, A-2B depicts the procedure A2A depicts the procedure for for recall of the Emergency recall of the Emergency Organization. Organization.
18. Section H Emergency Medical Supplies L- Emergency Medical Supplies editorial, 1, L-2, L-3 L.2, L.4 correct
p. H-9 reference H.11 steps
19. Section H Nuclear Eng Reactor Eng editorial, title
p. H-10 change Fig H-1
20. Section J ... Procedure AD-EP-ALL-0109, ... Procedure AD-EP-ALL-0109, AD-EP-ALL-Offsite Protective Action Offsite Protective Action 0109
p. J-3 Recommendations, has been Recommendations, has been implemented J.7 written to provide specific written to provide specific in the Main guidance for issuing protective guidance for issuing protective Control Room action recommendatio ns under action recommendations under variousp~ntco ndlt~nstothe various plant conditions to the Emergency Coordinator in the Emergency Coordinator in the TSC and the EOF Director in the Control Room/TSC and the EOF EOF Figure (J-1) .... Director in the EOF Figure (J
1) ....
21. Section J Per Appendix 2, initial protective deleted AD-EP-ALL-

EPLAN CHANGE

SUMMARY

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/Section

p. J-3 actions are predetermined for 0109 Control Room use for general implemented J.7 emergency conditions. in the Main Meteorological conditions at Control Room Oconee require a complex method for determining appropriate sectors to evacuate.

The Control Room will typically recommend evacuation out to five miles and shelter out to ten miles which simplifies the process for determining the appropriate sectors to evacuate and to shelter.

22. Section J . (ONS-ETE-12142012, Rev. 000; (CSD-EP-ONS-0603-03, Oconee editorial, ONS Evacuation Time Estimates Evacuation Time Estimate reference
p. J-3 (ETE) Dated 12/14/2012.) Study) title change J.8
23. Section J The Evacuation Time Estimates The Evacuation Time Estimates ETE will be considered in evaluating will be considered in evaluating considered in
p. J-3 protective action protective action all the ERF's J.8 recommendations from the recommendations.

Technical Support Center or the Emergency Operations Facility.

24. Section J ONS' ETE analysis, using the 2010 deleted paragraph decennial census data from the not required
p. J-4 U.S. Census Bureau, was J.8 submitted to the NRC via §50.4 on December 14, 2012.
25. Section J For hostile action events, a range deleted paragraph of protective actions for onsite not
p. J-4 workers including evacuation of applicable to J.9 essential personnel from Licensee potential target buildings, timely

EPLAN CHANGE SUMMAR Y 2020-001 - Sections A,B,E,F,H,J,L,P Attachment to 50.54q CHANGE MATRIX

  1. Page Current Proposed Change Reason

/Section evacuation or relocation of non- NUREG-0654 essential site personnel, dispersal Supp 4 of critical personnel to safe locations, sheltering of personnel away from potential site targets and accountability of personnel after the attack are provided in emergency plan implementing procedures AP/0/A/1700 /045, "Site Security Threats,"

RP/0/A/1000/010, "Procedure for Emergency Evacuation/Relocation of Site Personnel," RP/0/A/1000/009, "Procedure for Site Assembly".

26. Section L N/A deleted editorial, blank blank page cover
27. Section L Local - Greenville Health System Local - Prisma Health System editorial, p.L-1 name change L.1
28. Section L .. .Figures L-1 and L-2 show ... PT/0/8/0250/0 32, Quarterly editorial, locations and contents of trauma Inspection Of Emergency move
p. L-2 kits that are available for use by Medical Equipment, shows reference L.2 MERT personnel. locations and contents of from Figure trauma kits that are available to respective for use by MERT personnel. paragraph, deleted figure .
29. Section L ... (Figure L-3) ... (HP/0/8/100 9/001, editorial, Emergency Equipment move

EPLAN CHANGE

SUMMARY

2020-001 - Sections A,B,E,F,H,J,L,P Attachment to 50.54q CHANGE MATRIX

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/Section

p. L-2 Inventory and Instrument reference Check) from Figure L.4 to respective paragraph, deleted figure.
30. Section L deleted editorial, FIGURE*L-1 1 reference old p. L-3 'If DUKE*ENERGY*COMPANY'lf moved to OCONEE*NUCLEAR*SITE'ii appropriate

'If paragraph.

TRAUMA*KITS'lf

'If

,r Contents,r

'If See*PT/0/B/0250/032'1f for*location *of-kits.'If

31. Section L FIGURE*L-2 1 deleted editorial, old p. L-4 'If reference DUKE*ENERGY*COMPANYi[ moved to OCONEE *NUCLEAR*SITE'lf appropriate

'If MEDICAL *EQUIPMENr! paragraph.

'If

'If

'If

,r See*PT/0/B/0250/032'1f i;

,r t

EPLAN CHANGE

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2020-001 - Sections A,B,E,F,H,J,L,P Attachment to 50.54q CHANGE MATRIX

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/Section

32. Section L deleted FIGURE*L-31 editorial, reference I

DUKE*ENERGY*COM PANY.-

old p. L-5 OCONEE *NUCLEAR*SITE.-

tJ moved to RADIATION *PROTECTION HOSPITAL *KIT--

appropriate

.. paragraph .

See*HP/0/Bi 1009/00 If

'II Location: *Oconee*MemorialHosp1tal.-

'II

33. Section P P.2 & P.3 Overall Authority P.2 Overall Authority editorial, split
p. P-1 paragraph P.3 The Support Services numbering to Manager...

align to standards.

34. Section P P.4 & P.S Review and UQdate of P.4 Review and UQdate of editorial, split Emergency Plan Emergency Plan paragraph
p. P-1 numbering to P.S Approved revisions ....

align to standards.

35. Section P The NOS Audit Manager will The Nuclear Oversight (NOS) ensures arrange for an independent Audit Manager will arrange for independenc
p. P-2 review of Oconee Nuclear an independent review of e of NOS P.9 Station's Emergency Oconee Nuclear Station's Audits and Preparedness Program as Emergency Preparedness aligned to remaining necessary, based on an Program at a frequency planning pages assessment against performance specified in 10CFRS0.54(t). NOS standards.

renumber indicators, and as soon as will audit the Plan, Emergency ed reasonably practicable after a Plan Implementing Procedures, change occurs in personnel, Training programs, Drills and procedures, equipment, or Exercises, facilities and

EPLAN CHANGE

SUMMARY

2020-001 - Sections A,B,E,F,H,J,L,P Attachmen t to 50.54q CHANGE MATRIX

  1. Page Current Proposed Change Reason

/Section facilities that potentially could equipmen t for conformance adversely affect emergency with 10CFRS0.47, 10CFRS0.54 preparedness, but no longer than and 10CFRS0 Appendix E. The 12 months after the change. In independent review will include any case, all elements of the the following plans, procedures, emergency preparedness training programs, program will be reviewed at least drills/exercises, equipment, and once every 24 months. Guidance State/local government for performing the assessment interfaces:

against the performance indicators is provided in Administrative Procedure AD-NO-ALL-1001. 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 governme nt interfaces:

36. Section P 4. Site Emergency Response 4. Emergency Response Training Training Training Program Program programs are
p. P-2 fleet process.

P.9 (4)

37. Fig Pl RP /0/A/1000/00 2 AD-EP-ALL-0111 Superseded Alb, Ald, Control Room Emergency by Control Room Activation of the Ale, A4, Coordinator Procedure implemen tati ERO Bl, B2, B3, on of fleet B4, El, E2, procedure.

E3, E4a-n, Fla, Flc, Fle, H4, 15,

EPLAN CHANGE SUMMAR Y 2020-001 - Sections A,B,E,F,H,J,L,P Attachment to 50.54q CHANGE MATRIX

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38. Fig Pl ONS E Plan CSD-EP-ONS-0101-01 moving EAL Dla, b, c Tech Basis ONS Emergency Plan ONS EAL Technical Basis from EPLAN Document to CSD
39. Fig Pl RP/0/A/1000 /001 deleted Main Control Dla,b,c, Room Emergency Classification D2, HS, 11, implementa ti 13a,b on of fleet classification fixed procedure, remaining AD-EP-ALL-table cells 0101. Already a reference.

~o. Fig Pl RP /0/A/1000/015 A deleted Main Control El, E3, Room Offsite Communications From E4a-n, implementa ti The Control Room Fla, Flc, on of fleet 15 notification procedure, fixed AD-EP-ALL-remaining 0304. Already table cells a reference.

~l. Fig Pl AD-NO-ALL-1001 ONS E Plan Preserve P.9 independenc Conduct of Audit ONS Emergency Plan e of audits and align to planning standard.

~2. Fig Pl ONS-ETE-12142012 CSD-EP-ONS-0603-03 editorial, J.8 reference ONS Evacuation Time Estimates Oconee Evacuation Time title change (ETE) Dated 12/14/2012 Estimate Study

~3. Fig Pl AP /0/A/1700/045 deleted Not Site Security Threats applicable to J.9 Licensee RP/0/A/1000 /009 Procedure For Site

EPLAN CHANGE

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2020-001- Sections A,B,E,F,H,J,L,P Attachment to 50.54q CHANGE MATRIX

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/Section Assembly RP /0/ A/1000/010 Procedure For Emergency Evacuation/Relocation Of Site Personnel

EPLAN CHANGE

SUMMARY

2020-001 - Appendices 2,3,4,5 Attachment to S0.54q CHANGE MATRIX

  1. Page Current Proposed Change Reason

/Section

1. App 2 FAD - ON - EP-EAL-EALMATRIX, CSD-EP-ONS-0101-02, ONS EAL Matrix wallchart ONS NEI 99-01 REV 6 WALLCHART provides the Shift renamed to CSD for p.3 WALLCHART provides the Shift Manager in the Control Room with a fleet consistency Manager in the Control Room conservative method of determining with a conservative method of general emergency conditions based determining general emergency on reactor building and unit vent conditions based on reactor radiation monitors.

building and unit vent radiation monitors.

2. App 2 Initial protective actions are Protective Action Implementation of predetermined for Control Room Recommendations(PARs) are standard control p.3 use for general emergency determined in the Control Room room procedures.

conditions. Meteorological using AD-EP-ALL-0109, OFFSITE conditions at Oconee require a PROTECTIVE ACTION complex method for determining RECOMMENDATIONS.

appropriate sectors to evacuate .

The control room will evacuate out to five miles and shelter out to ten miles which will simplify the process for determining the appropriate sectors to evacuate and to shelter.

3. App 3 N/A Removed editorial, removed blank page that was blank first a legacy NEDL page printing item .

~- App 3 A. Concept of Operations (Figure A. Concept of Operations editorial, figure 2

2) was removed in p.1 previous revisions.

l5 . App 3 Full Cycle Test Quarterly Growl Test* Quarterly correct error made in previous revision .

p.3 Restore to FEMA Design Report testing guidance.

6. App3 Full-cycle* Annually Full-cycle Annually correct placement of asterisk.

p.3

7. App4 N/A deleted deleted blank cover page, not required.

cover page

EPLAN CHANGE

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2020-001 - Appendices 2,3,4,5 Attachment to 50.54q CHANGE MATRIX

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/Section

8. App4 See ONS-ETE-12142012, Rev. See ONS-ETE-12142012, Rev. 000: editorial, added new p.1 000: ONS EVACUATION TIME ONS EVACUATION TIME ESTIMATES reference document ESTIMATES (ETE) (ETE) DATED 12/14/2012. (CSD-EP- that the ETE will be DATED 12/14/2012. ONS-0603-03) placed in for fleet consistency.
9. App 5 N/A reduced spacing between lines listing formatting, no p.1 LOA 's in order to fit the entire list on content change.

renumbered one page.

pages.

10. AppS Duke Energy's Lincoln deleted Supply Chain p.1 Combustion Turbine Facility contingency, LOA was unnecessary.