RA-20-0065, Emergency Plan, Revision 20-02

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Emergency Plan, Revision 20-02
ML20054A124
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 02/20/2020
From: Simril T
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0065
Download: ML20054A124 (46)
v • d • e


Text

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Tom Simril Vice President Catawba Nuclear Station Duke Energy CN01VP 14800 Concord Road York, SC 29745 o: 803,701 .3340 f: 803.701 .3221 tom.simril@duke-energy.com RA-20-0065 10CFR 50.54(q)

February 20, 2020 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington , DC 20555-0001

Subject:

Duke Energy Carolinas, LLC Catawba Nuclear Station Units 1 and 2 Docket Nos. 50-413 and 50-414 Emergency Plan, Revision 20-02 Enclosed for NRC Staff use is Revision 20-02 to the Cataw ba Nuclear Station Emergency Plan.

This revision is effective as of January 30, 2020. All chang es have been specifically highlighted (side-barred). Also enclosed, is the 50.54(q) evaluation for the revision.

This revision is being submitted in accordance with 10CF R 50.54(q) and does not constitute a reduction in the effectiveness of the Emergency Plan for Catawba Nuclear Station. The 10CFR 50.54(q) Evaluation for Revision 20-02 to the Emergency Plan is provided as Attachment 1.

If there are any questions1 please contact Staci White at 803-701-5191 .

Sincerely, Tom Simril Vice President, Catawba Nuclear Station Attachments: 1. Emergency Plan 10CFR50.54 (q) Evaluation(s) and scree n(s)

2. Plan update instructions
3. Emergency Plan, Revision 20-02 w ww.duke*energy.com

Catawba Nuclear Station E-Plan Revision 20-02 RA-20-0065 February 20, 2020 Page 2 xc (w/attachments):

Laura Dudes, Regional Administrator U. S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 xc (w/o attachments):

Michael Mahoney NRC Project Manager (CNS)

U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop O8B1A 11555 Rockville Pike Rockville, MD 20852-2738 Joseph D. Austin NRC Senior Resident Inspector (CNS)

Catawba Nuclear Station E-Plan Revision 20-02 RA-20-0065 February 20, 2020 Page 3 bxc (with attachments):

Electronic Licensing Library, EC2ZF RGC Licensing File, CN01RC S. White, CN01EP bxc (w/o attachments):

North Carolina Municipal Power Agency Number 1 North Carolina Electric Membership Corporation Piedmont Municipal Power Agency M. Hare, CN01OR S. Andrews, CN01RC C. Moore, EC04C CN-750.25, CN04DM

Catawba Nuclear Station Attachment 1 Emergency Plan Revision 20-02 10CFR 50.54(q) Evaluation(s) and screen(s)

Duke Energy ACTION REQUEST - 02299017 ASSIGNMENT NBR - 01 Action Request Assignment Details AR NUMBER : 02299017 ASSIGNMENT NUMBER : 01 Type  : EP01 Due Date  : 01/23/2020 Pri Resp Fac  :

Status  : COMPLETE Reschedule :1 Pri Resp Group  :

Assigned To  : STACI N WHITE Sec Resp Fac  :

Subject  : 50.54(Q) SCREEN Sec Resp Group  :

Aff Facility  : CN Unit  : System  :

UCR  : Schedule Ref  :

Organization  : Department  : 18255 Discipline  :

Est Manhrs :0 Est Comp Date  :

Description COMPLETE 50.54(Q) SCREEN IN ACCORDANCE WITH AD-EP-ALL-0602.

Action Request Assignment Completion Notes I have reviewed and approve the 50.54Q screen for EPA N 151.

Action Request Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 10/24/2019 I44004 INPROG 10/24/2019 I44004 11/14/2019 10/24/2019 I44004 NTFY/ASG 10/24/2019 I44004 ACC/ASG 12/16/2019 I44004 01/23/2020 01/13/2020 I44004 AWAIT/C 01/14/2020 MRCOYL1 ACC/ASG 01/14/2020 I44004 AWAIT/C 01/14/2020 MRCOYL1 ACC/ASG 01/14/2020 I44004 AWAIT/C 01/21/2020 MEHARE ACC/ASG 01/21/2020 I44004 AWAIT/C 01/28/2020 MEHARE ACC/ASG 01/28/2020 I44004 AWAIT/C 01/29/2020 MEHARE COMPLETE Printed  : 02/10/2020 Page :1

Duke Energy ACTION REQUEST - 02299017 ASSIGNMENT NBR - 01 Action Request Assignment Routing/Return Comments Routing Comments from the X601 Panel Updated On Updated By insert chart. 20200114 MRCOYL1 change numbers 20200114 MRCOYL1 additional changes need per mark up/discussion 20200121 MEHARE Per our discussion - mark up provided. 20200128 MEHARE Routing Comments from the X602 Panel Updated On Updated By

      • No Return Comments Found ***

Action Request Assignment Completion Approval Route List  : 001 Route List Initiator  : I44004 Send Send Action Action Passport Fac Group / Type Date Time Taken Date / Time Last Name MRCOYL1 A 01/13/2020 1626 RETURNED 01/14/2020 1704 COYLE MEHARE A 01/14/2020 1802 RETURNED 01/21/2020 1318 HARE MRCOYL1 A 01/14/2020 1758 APPROVED 01/14/2020 1802 COYLE MEHARE A 01/21/2020 1614 RETURNED 01/28/2020 1527 HARE MRCOYL1 A 01/21/2020 1455 APPROVED 01/21/2020 1614 COYLE MRCOYL1 A 01/14/2020 1753 RETURNED 01/14/2020 1756 COYLE MEHARE A 01/28/2020 1622 APPROVED 01/29/2020 1801 HARE MRCOYL1 A 01/28/2020 1559 APPROVED 01/28/2020 1622 COYLE I44004 I 01/28/2020 1559 01/28/2020 1559 WHITE Action Request Assignment Cause/Action Printed  : 02/10/2020 Page :2

Duke Energy ACTION REQUEST - 02299017 ASSIGNMENT NBR - 01 Action Request Assignment Reference Documents Doc Sub Minor Facility Type Type Document Sheet Rev Rev Title Action Request Assignment Reference Equipment Equip Equip Equip Equip Rev Facility Unit System Type Number Tag Status Rev Status Action Request Assignment Cross References Ref Ref Ref Ref Nbr Limit Type Nbr Sub Type Status AS Cls Description Action Request Assignment Appendices APPENDIX 1 Printed  : 02/10/2020 Page :3

EMERGENCY PLAN CHANGE SCREENING AD-EP-ALL-0602 AND EFFECTIVENESS EVALUATIONS 10 Rev. 6 CFR 50.54(Q)

ATTACHMENT 4 Page 1 of 5

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

Screening and Evaluation Number Applicable Sites BNP o EREG #: 02299017 CNS l CR3 o HNP o MNS o 5AD #: 02271764 ONS o RNP o GO o Document and Revision Emergency Plan Section N, Exercises and Drills, Rev 151 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

  1. E-Plan Current (Existing) Text Proposed (Change) Text Section Reference 1 N.1.b The exercise will be initiated at various <deleted>

times of the day, but in every eight-calendar year exercise cycle, one exercise will begin between 6:00 P.M. and 4:00 A.M.

2 N.5 The verbal evaluations made during the Deficiencies identified during verbal critique and any follow-up written evaluation evaluation are to be entered as condition will be compiled using the Corrective Action reports in the Corrective Action Program Program (CAP). (CAP) or work request for appropriate resolution.

3 N.2 PIP G-15-0258 AR# 01900418 4 N.2.b AD-OP-ALL-0207 (Fire Brigade and AD-OP-ALL-0207 (Fire Brigade HAZMAT Team Administrative Controls) Administrative Controls)

Part II. Activity Previously Reviewed? Yes o No l Printed  : 02/10/2020 Page  : 4 Back

EMERGENCY PLAN CHANGE SCREENING AD-EP-ALL-0602 AND EFFECTIVENESS EVALUATIONS 10 Rev. 6 CFR 50.54(Q)

ATTACHMENT 4 Page 2 of 5

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

Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or 10 CFR 50.54(q) Continue to Alert and Notification System Design Report? Effectiveness Attachment 4, Evaluation is not 10 CFR If yes, identify bounding source document number or approval reference and required. Enter 50.54(q) ensure the basis for concluding the source document fully bounds the proposed justification Screening change is documented below: below and Evaluation complete Form, Part III Attachment 4, Justification: Part V.

Bounding document attached (optional) o Part III. Editorial Change No or Yes o l Is this activity an editorial or typographical change only, such as formatting, Partially paragraph numbering, spelling, or punctuation that does not change intent? 10 CFR 50.54(q) Continue to Effectiveness Attachment 4, Evaluation is not Part IV and Justification:

required. Enter address non AD-EP-ALL-0602, EMERGENCY PLAN CHANGE SCREENING AND justification and editorial EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q), Section 3.0.6, defines complete changes editorial changes as "Correct procedures and references or annotations that are Attachment 4, no longer applicable," and "Correct references to steps, pages, attachments, forms, documents, tables, exhibits." Part V.

Change 3 reflects the change in identification of the condition report when the PIP system was converted to the CAS/NCR system. The PIP reference is no longer applicable.

Change 4 corrects the reference to the procedure title.

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

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

1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned. o 1b The response organization has the staff to respond and to augment staff on a continuing o basis (24-7 staffing) in accordance with the emergency plan.

2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned o 2b The process for timely augmentation of on shift staff is established and maintained. o Printed  : 02/10/2020 Page  : 5

EMERGENCY PLAN CHANGE SCREENING AD-EP-ALL-0602 AND EFFECTIVENESS EVALUATIONS 10 Rev. 6 CFR 50.54(Q)

ATTACHMENT 4 Page 3 of 5

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

3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made. o 3b State and local staff can be accommodated at the EOF in accordance with the emergency o plan. (NA for CR3) 4 10 CFR 50.47(b)(4) Emergency Classification System 4a A standard scheme of emergency classification and action levels is in o use. (Requires final approval of Screen and Evaluation by EP CFAM.)

5 10 CFR 50.47(b)(5) Notification Methods and Procedures 5a Procedures for notification of State and local governmental agencies are capable of alerting them of o the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.

5b Administrative and physical means have been established for alerting and providing prompt o instructions to the public within the plume exposure pathway. (NA for CR3) 5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert o and 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) 6 10 CFR 50.47(b)(6) Emergency Communications 6a Systems are established for prompt communication among principal emergency o response organizations.

6b Systems are established for prompt communication to emergency response personnel. o 7 10 CFR 50.47(b)(7) Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within o the plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established. o 8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response. o 8b Adequate equipment is maintained to support emergency response. o 9 10 CFR 50.47(b)(9) Accident Assessment 9a Methods, systems, and equipment for assessment of radioactive releases are in use. o 10 10 CFR 50.47(b) (10) Protective Response 10a A range of public PARs is available for implementation during emergencies. (NA for CR3) o 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are o available 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, o including those for hostile action events.

Printed  : 02/10/2020 Page  : 6

EMERGENCY PLAN CHANGE SCREENING AD-EP-ALL-0602 AND EFFECTIVENESS EVALUATIONS 10 Rev. 6 CFR 50.54(Q)

ATTACHMENT 4 Page 4 of 5

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

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

11 10 CFR 50.47(b) (11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established. o 12 10 CFR 50.47(b) (12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals. o 13 10 CFR 50.47(b) (13) Recovery Planning and Post-Accident Operations 13a Plans for recovery and reentry are developed. o 14 10 CFR 50.47(b) (14) Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program l areas) is established.

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

14c Identified weaknesses are corrected. l 15 10 CFR 50.47(b) (15) Emergency Response Training 15a Training is provided to emergency responders. o 16 10 CFR 50.47(b) (16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established. o 16b Planners responsible for emergency plan development and maintenance are properly trained. o PART IV. Conclusion If no Part IV criteria are checked, then provide Justification and complete Part V below. o Justification:

If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete , 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q) l Effectiveness Evaluation. Program Element 4a requires final approval of Screen and Evaluation by EP CFAM.

Printed  : 02/10/2020 Page  : 7

EMERGENCY PLAN CHANGE SCREENING AD-EP-ALL-0602 AND EFFECTIVENESS EVALUATIONS 10 Rev. 6 CFR 50.54(Q)

ATTACHMENT 4 Page 5 of 5

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

Part V. Signatures:

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

Preparer Name (Print): Preparer Signature: Date:

Staci White See CAS See CAS Reviewer Name (Print): Reviewer Signature: Date:

Michael Ryder Coyle See CAS See CAS Approver (Manager, Nuclear Support Services) Approver Signature: Date:

Name (Print): See CAS See CAS Mandy Hare Approver (EP CFAM, as required) Name (Print): Approver Signature: Date:

N/A N/A N/A If the proposed activity is a change to the E-Plan, then initiate PRRs. l If the proposed activity is a change to the E-Plan, then create two EREG General assignments If required by Section 5.6, Submitting Reports of Changes to the NRC, then create two EREG General Assignments. l One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q),

to Licensing.

l 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.

QA RECORD Printed  : 02/10/2020 Page  : 8

      • END OF REPORT***

2020-02-10 12:57:58.061

Duke Energy ACTION REQUEST - 02299017 ASSIGNMENT NBR - 06 Action Request Assignment Details AR NUMBER : 02299017 ASSIGNMENT NUMBER : 06 Type  : EP02 Due Date  : 01/23/2020 Pri Resp Fac  :

Status  : COMPLETE Reschedule :1 Pri Resp Group  :

Assigned To  : STACI N WHITE Sec Resp Fac  :

Subject  : 50.54(Q) Evaluation Sec Resp Group  :

Aff Facility  : CN Unit  : System  :

UCR  : Schedule Ref  :

Organization  : Department  : 18255 Discipline  :

Est Manhrs :0 Est Comp Date  :

Description 50.45(q) evaluation Action Request Assignment Completion Notes I have reviewed and approve the 50.54Q Eval for EPA N 151.

Action Request Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 12/18/2019 I44004 INPROG 01/15/2020 12/18/2019 I44004 ACC/ASG 01/13/2020 I44004 AWAIT/C 01/14/2020 MRCOYL1 ACC/ASG 01/14/2020 I44004 AWAIT/C 01/21/2020 MEHARE ACC/ASG 01/21/2020 MEHARE 01/23/2020 01/21/2020 I44004 AWAIT/C 01/21/2020 MRCOYL1 ACC/ASG 01/21/2020 I44004 AWAIT/C 01/28/2020 MEHARE ACC/ASG 01/28/2020 I44004 AWAIT/C 01/29/2020 MEHARE COMPLETE Action Request Assignment Routing/Return Comments Printed  : 02/10/2020 Page :1

Duke Energy ACTION REQUEST - 02299017 ASSIGNMENT NBR - 06 Routing Comments from the X601 Panel Updated On Updated By insert chart 20200114 MRCOYL1 additional changes need per mark up/discussion 20200121 MEHARE s on commitments 20200121 MRCOYL1 Per our discussion - mark up provided. 20200128 MEHARE Routing Comments from the X602 Panel Updated On Updated By

      • No Return Comments Found ***

Action Request Assignment Completion Approval Route List  : 001 Route List Initiator  : I44004 Send Send Action Action Passport Fac Group / Type Date Time Taken Date / Time Last Name MRCOYL1 A 01/14/2020 1752 APPROVED 01/14/2020 1801 COYLE MRCOYL1 A 01/13/2020 1624 RETURNED 01/14/2020 1705 COYLE MEHARE A 01/14/2020 1801 RETURNED 01/21/2020 1319 HARE MEHARE A 01/28/2020 1715 APPROVED 01/29/2020 1802 HARE MRCOYL1 A 01/28/2020 1605 APPROVED 01/28/2020 1715 COYLE MRCOYL1 A 01/21/2020 1626 APPROVED 01/21/2020 1628 COYLE MEHARE A 01/21/2020 1628 RETURNED 01/28/2020 1527 HARE MRCOYL1 A 01/21/2020 1457 RETURNED 01/21/2020 1624 COYLE I44004 I 01/28/2020 1605 01/28/2020 1605 WHITE Action Request Assignment Cause/Action Action Request Assignment Reference Documents Doc Sub Minor Facility Type Type Document Sheet Rev Rev Title Printed  : 02/10/2020 Page :2

Duke Energy ACTION REQUEST - 02299017 ASSIGNMENT NBR - 06 Action Request Assignment Reference Equipment Equip Equip Equip Equip Rev Facility Unit System Type Number Tag Status Rev Status Action Request Assignment Cross References Ref Ref Ref Ref Nbr Limit Type Nbr Sub Type Status AS Cls Description Action Request Assignment Appendices APPENDIX 1 Printed  : 02/10/2020 Page :3

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

Rev. 6 ATTACHMENT 5 Page 1 of 6 ATTACHMENT 5 Page 1 of 6

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

Screening and Evaluation Number Applicable Sites BNP o EREG #:________02299017_____________ CNS l CR3 o HNP o MNS o 5AD #:____02271764_______________ ONS o RNP o GO o Document and Revision Emergency Plan Section N, Exercises and Drills, Rev 151 Part I. Description of Proposed Change:

  1. E-Plan Current (Existing) Text Proposed (Change) Text Section Reference 1 N.1.b The exercise will be initiated at various <deleted>

times of the day, but in every eight-calendar year exercise cycle, one exercise will begin between 6:00 P.M. and 4:00 A.M.

2 N.5 The verbal evaluations made during the Deficiencies identified during verbal critique and any follow-up written evaluation evaluation are to be entered as condition will be compiled using the Corrective Action reports in the Corrective Action Program Program (CAP). (CAP) or work request for appropriate resolution.

Attachment 6, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes o Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change) No l Printed  : 02/10/2020 Page  : 4 Back

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

Rev. 6 ATTACHMENT 5 Page 2 of 6 Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

CNS Emergency Plan, Rev 2, dated January 1983, does not address Section N.1.b, Exercise Scenario Response, stating. "See Crisis Management Plan Section N.1.a/N.1.b" and section N.5 states, "See Crisis Management Plan Section N.5" CNS Emergency Plan, Section N.1.b, Rev 150 states, "The exercise will be initiated at various times of the day, but in every eight calendar year exercise cycle, one exercise will begin between 6:00 P.M. and 4:00 A.M". Section N.5 states, "The verbal evaluations made during the critique and any follow-up written evaluation will be compiled using the Corrective Action Program (CAP)."

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

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

Rev. 6 ATTACHMENT 5 Page 3 of 6 Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments.

If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q):

Change 1:

With the removal of the statement, "The exercise will be initiated at various times of the day, but in every eight calendar year exercise cycle, one exercise will begin between 6:00 P.M. and 4:00 A.M," the CNS Emergency Plan continues to comply with regulation and commitments because NSIR/DPR-ISG-01, Interim Staff Guidance Emergency Planning for Nuclear Power Plants, Rev 0, (November 2011) states, "Revised Evaluation Criterion N.1.b applies to licensee, State and local organizations. Because FEMA no longer requires offsite organizations to participate in off-hours or unannounced exercises, the portion of Evaluation Criterion N.1.b. regarding these types of exercises was relocated to new Evaluation Criterion N.1.c applicable to licensees only. The timeframe for conducting off-hours or exercises was also modified to align with Supplement 1 to NUREG-0654 as shown below:

N.1.c Provisions must be made to start a drill or exercise between 6:00 p.m. and 4:00 a.m.

at least once in every eight-year exercise cycle. Some drills or exercises should be unannounced.

CNS Emergency Plan section N.2, Drills, indicates that drills will be conducted in accordance with PD-EP-ALL-0800, Drills and Exercises; AD-EP-ALL-0801, Design and Development of Drills and Exercises; AD-EP-ALL-0802, Conducting Drills and Exercises; and AD-EP-ALL-0803, Evaluation and Critique of Drills and Exercises.

AD-EP-ALL-0801, Design and Development of Drills and Exercises, Attachment 11, Augmentation Drills, section 1.2, includes the direction for a drill beginning after 6:00 PM and before 4:00 AM, Monday through Thursday.

Compliance with the guidance in the ISG is maintained.

Change 2:

Change 2 was initiated to clarify that only deficiencies should be entered into the corrective action program (CAP) or as work requests. Documentation of the Drill/Exercise Critique Report, described as "verbal evaluations" and "follow-up written evaluation" is not an appropriate use of CAP. Drill/Exercise records packages are maintained per AD-EP-ALL-0803, Evaluation and Critique of Drills and Exercises, section 5.4. CNS maintains all original drill/exercise records as hard copies.

The changes described continue to meet NRC requirements as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.

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

Rev. 6 ATTACHMENT 5 Page 4 of 6 Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen):

Changes 1 and 2 impact Emergency Planning Standard 10 CFR 50.47(b)(14).

The regulation at 10 CFR 50.47(b)(14) states the following:

Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

Three emergency planning functions have been defined for this planning standard:

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

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

Identified weaknesses are corrected.

Program elements are contained in Section II.N of NUREG-0654 Section II.N.1.c, "Provisions must be made to start a drill or exercise between 6:00 p.m.

and 4:00 a.m. at least once in every eight-year exercise cycle. Some drills or exercises should be unannounced. "

Section II.N.5, "Each organization shall establish means for evaluating observer and participant comments on areas needing improvement, including emergency plan procedural changes, and for assigning responsibility for implementing corrective actions.

Each organization shall establish management control used to ensure that corrective actions are implemented."

Printed  : 02/10/2020 Page  : 7

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

Rev. 6 ATTACHMENT 5 Page 5 of 6 Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

Changes 1 and 2 continue to support the establishment of a drill and exercise program, including conducting unannounced off-hours drills, and the appropriate use of the Corrective Action Program and other record retention methods. Drills/exercises continue to provide performance opportunities to develop, maintain and demonstrate key skills, and drills/exercises are assessed via a formal critique process. The Corrective Action Program continues to be the method by which identified deficiencies are corrected and documented.

The changes described provide assurance that the normal plant operating organization and ERO has the ability and capability to:

  • respond to an emergency;
  • perform functions in a timely manner;
  • effectively identify and take measures to ensure protection of the public health and safety; and
  • effectively use response equipment and emergency response procedures.

Thus, there is no reduction in effectiveness of the Emergency Plan.

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 l No o 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes l No o reduction in effectiveness)?

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

a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current l

Emergency Action Level (EAL) scheme. Therefore, the activity can be implemented without prior NRC approval.

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

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

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

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

Rev. 6 ATTACHMENT 5 Page 6 of 6 Part VIII. Signatures: EP CFAM Final Approval is required for changes affecting risk significant planning standard 10 CFR 50.47(b)(4) (i.e., Emergency Action Levels and Emergency Action Level Bases). If CFAM approval is NOT required, then mark the CFAM signature block as not applicable (N/A) to indicate that signature is not required.

Preparer Name (Print): Preparer Signature: Date:

Staci White See CAS See CAS Reviewer Name (Print): Reviewer Signature: Date:

Michael Ryder Coyle See CAS See CAS Approver (Manager, Nuclear Support Approver Signature: Date:

Services) Name (Print): See CAS See CAS Mandy Hare Approver (CFAM, as required) Name (Print): Approver Signature: Date:

N/A N/A N/A If the proposed activity is a change to the E-Plan, then initiate PRRs.

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

If required by Section 5.6, Submitting Reports of Changes to the NRC, then create two EREG General Assignments.

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

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

QA RECORD Printed  : 02/10/2020 Page  : 9

      • END OF REPORT***

2020-02-10 12:57:58.061

Duke Energy ACTION REQUEST - 02299040 ASSIGNMENT NBR - 01 Action Request Assignment Details AR NUMBER : 02299040 ASSIGNMENT NUMBER : 01 Type  : EP01 Due Date  : 01/30/2020 Pri Resp Fac  :

Status  : COMPLETE Reschedule :1 Pri Resp Group  :

Assigned To  : STACI N WHITE Sec Resp Fac  :

Subject  : 50.54(Q) SCREEN Sec Resp Group  :

Aff Facility  : CN Unit  : System  :

UCR  : Schedule Ref  :

Organization  : Department  : 18255 Discipline  :

Est Manhrs :0 Est Comp Date  :

Description COMPLETE 50.54(Q) SCREEN IN ACCORDANCE WITH AD-EP-ALL-0602.

Action Request Assignment Completion Notes I have reviewed and approve the 50.54Q screen for EPA O 145.

Action Request Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 10/24/2019 I44004 INPROG 10/24/2019 I44004 11/14/2019 10/24/2019 I44004 NTFY/ASG 10/24/2019 I44004 ACC/ASG 12/16/2019 I44004 AWAIT/C 12/16/2019 MRCOYL1 ACC/ASG 12/16/2019 I44004 01/30/2020 12/18/2019 I44004 AWAIT/C 01/28/2020 MEHARE ACC/ASG 01/28/2020 I44004 AWAIT/C 01/29/2020 MEHARE COMPLETE Action Request Assignment Routing/Return Comments Routing Comments from the X601 Panel Updated On Updated By empty 20191216 MRCOYL1 Per our discussion - mark up provided. 20200128 MEHARE Printed  : 02/10/2020 Page :1

Duke Energy ACTION REQUEST - 02299040 ASSIGNMENT NBR - 01 Routing Comments from the X602 Panel Updated On Updated By

      • No Return Comments Found ***

Action Request Assignment Completion Approval Route List  : 001 Route List Initiator  : I44004 Send Send Action Action Passport Fac Group / Type Date Time Taken Date / Time Last Name MEHARE A 01/28/2020 1606 APPROVED 01/29/2020 1804 HARE MRCOYL1 A 01/28/2020 1542 APPROVED 01/28/2020 1606 COYLE MRCOYL1 A 12/18/2019 0912 APPROVED 12/23/2019 1035 COYLE MRCOYL1 A 12/16/2019 1955 RETURNED 12/16/2019 1956 COYLE MEHARE A 12/23/2019 1035 RETURNED 01/28/2020 1528 HARE Action Request Assignment Cause/Action Action Request Assignment Reference Documents Doc Sub Minor Facility Type Type Document Sheet Rev Rev Title Action Request Assignment Reference Equipment Equip Equip Equip Equip Rev Facility Unit System Type Number Tag Status Rev Status Action Request Assignment Cross References Ref Ref Ref Ref Nbr Limit Type Nbr Sub Type Status AS Cls Description Action Request Assignment Appendices APPENDIX 1 Printed  : 02/10/2020 Page :2

Duke Energy ACTION REQUEST - 02299040 ASSIGNMENT NBR - 01 Printed : 02/10/2020 Page :3

EMERGENCY PLAN CHANGE SCREENING AD-EP-ALL-0602 AND EFFECTIVENESS EVALUATIONS 10 Rev. 6 CFR 50.54(Q)

ATTACHMENT 4 Page 1 of 5

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

Screening and Evaluation Number Applicable Sites BNP o EREG #: 02299040 CNS l CR3 o HNP o MNS o 5AD #: 02299037 ONS o RNP o GO o Document and Revision EMERGENCY PLAN SECTION O, REV 145 (DRR 2253080)

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):

Section O.2.d changed from, "A practice drill session may be held to allow the individuals to perform their assigned functions (See PT/0/B/4600/006 Emergency Exercises and Drills). The drill instructor may make on the spot corrections and/or demonstration of the proper performance.

to "A practice drill session may be held to allow the individuals to perform their assigned functions. The drill instructor may make on the spot corrections and/or demonstration of the proper performance."

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

Bounding document attached (optional) o Printed  : 02/10/2020 Page  : 4 Back

EMERGENCY PLAN CHANGE SCREENING AD-EP-ALL-0602 AND EFFECTIVENESS EVALUATIONS 10 Rev. 6 CFR 50.54(Q)

ATTACHMENT 4 Page 2 of 5

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

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

required. Enter address non Removal of "(See PT/0/B/4600/006 Emergency Exercises and Drills)" is editorial justification and editorial per AD-EP-ALL-0602, step 3.0.g, "Correct references or annotations that are no complete changes longer applicable."

Attachment 4, PT/0/B/4600/006 was superseded on 12/18/2017 by the AD-EP-ALL-0800 series Part V.

of procedures. (AR 2169971)

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

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

1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned. o 1b The response organization has the staff to respond and to augment staff on a continuing o basis (24-7 staffing) in accordance with the emergency plan.

2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned o 2b The process for timely augmentation of on shift staff is established and maintained. o 3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made. o 3b State and local staff can be accommodated at the EOF in accordance with the emergency o plan. (NA for CR3) 4 10 CFR 50.47(b)(4) Emergency Classification System 4a A standard scheme of emergency classification and action levels is in o use. (Requires final approval of Screen and Evaluation by EP CFAM.)

5 10 CFR 50.47(b)(5) Notification Methods and Procedures 5a Procedures for notification of State and local governmental agencies are capable of alerting them of o the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.

5b Administrative and physical means have been established for alerting and providing prompt o instructions to the public within the plume exposure pathway. (NA for CR3) 5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert o and 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)

Printed  : 02/10/2020 Page  : 5

EMERGENCY PLAN CHANGE SCREENING AD-EP-ALL-0602 AND EFFECTIVENESS EVALUATIONS 10 Rev. 6 CFR 50.54(Q)

ATTACHMENT 4 Page 3 of 5

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

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

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

6b Systems are established for prompt communication to emergency response personnel. o 7 10 CFR 50.47(b)(7) Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within o the plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established. o 8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response. o 8b Adequate equipment is maintained to support emergency response. o 9 10 CFR 50.47(b)(9) Accident Assessment 9a Methods, systems, and equipment for assessment of radioactive releases are in use. o 10 10 CFR 50.47(b) (10) Protective Response 10a A range of public PARs is available for implementation during emergencies. (NA for CR3) o 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are o available 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, o including those for hostile action events.

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

11 10 CFR 50.47(b) (11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established. o 12 10 CFR 50.47(b) (12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals. o 13 10 CFR 50.47(b) (13) Recovery Planning and Post-Accident Operations 13a Plans for recovery and reentry are developed. o 14 10 CFR 50.47(b) (14) Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program o areas) is established.

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

14c Identified weaknesses are corrected. o Printed  : 02/10/2020 Page  : 6

EMERGENCY PLAN CHANGE SCREENING AD-EP-ALL-0602 AND EFFECTIVENESS EVALUATIONS 10 Rev. 6 CFR 50.54(Q)

ATTACHMENT 4 Page 4 of 5

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

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

15 10 CFR 50.47(b) (15) Emergency Response Training 15a Training is provided to emergency responders. o 16 10 CFR 50.47(b) (16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established. o 16b Planners responsible for emergency plan development and maintenance are properly trained. o PART IV. Conclusion If no Part IV criteria are checked, then provide Justification and complete Part V below. l Justification:

If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete , 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q) o Effectiveness Evaluation. Program Element 4a requires final approval of Screen and Evaluation by EP CFAM.

Part V. Signatures:

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

Preparer Name (Print): Preparer Signature: Date:

Staci White See CAS See CAS Reviewer Name (Print): Reviewer Signature: Date:

Michael Ryder Coyle See CAS See CAS Approver (Manager, Nuclear Support Services) Approver Signature: Date:

Name (Print): See CAS See CAS Mandy Hare Approver (EP CFAM, as required) Name (Print): Approver Signature: Date:

N/A N/A N/A If the proposed activity is a change to the E-Plan, then initiate PRRs. l If the proposed activity is a change to the E-Plan, then create two EREG General assignments If required by Section 5.6, Submitting Reports of Changes to the NRC, then create two EREG General Assignments. l One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q),

to Licensing.

l 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.

Printed  : 02/10/2020 Page  : 7

EMERGENCY PLAN CHANGE SCREENING AD-EP-ALL-0602 AND EFFECTIVENESS EVALUATIONS 10 Rev. 6 CFR 50.54(Q)

ATTACHMENT 4 Page 5 of 5

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

QA RECORD Printed : 02/10/2020 Page : 8

      • END OF REPORT***

2020-02-10 12:57:58.061

Catawba Nuclear Station Attachment 2 Emergency Plan Revision 20-02 Plan Update Instructions Replace Revision 20-01 Coversheet with Revision 20-02 Coversheet List of Effective Pages (LOEP)

Replace all pages of this section Tab N - Exercise and Drills Replace all pages of this section Tab O - Radiological Emergency Response Training Replace all pages of this section

Catawba Nuclear Station Attachment 3 Emergency Plan Emergency Plan Revision 20-02

LIST OF EFFECTIVE PAGES (LOEP)

This page intentionally left blank.

Rev. 160 Page 1 of 5 February 2020

LIST OF EFFECTIVE PAGES (LOEP)

EMERGENCY PLAN SECTION PAGE NUMBER REVISION NUMBER DATE Emergency Plan Approval Cover Sheet 16-1 March 2016 Table of Contents 1 150 February 2019 2 150 February 2019 3 150 February 2019 4 150 February 2019 5 150 February 2019 6 150 February 2019 List of Figures, Tables and Attachments 7 16-1 March 2016 8 16-1 March 2016 9 16-1 March 2016 Introduction i-1 16-1 March 2016 i-2 16-1 March 2016 i-3 16-1 March 2016 i-4 16-1 March 2016 i-5 16-1 March 2016 i-6 16-1 March 2016 Section A A-1 150 September 2017 A-2 150 September 2017 A-3 150 September 2017 A-4 150 September 2017 A-5 150 September 2017 Section B B-1 167 September 2019 B-2 167 September 2019 B-3 167 September 2019 B-4 167 September 2019 B-5 167 September 2019 B-6 167 September 2019 B-7 167 September 2019 B-8 167 September 2019 B-9 167 September 2019 B-10 167 September 2019 B-11 167 September 2019 B-12 167 September 2019 B-13 167 September 2019 B-14 167 September 2019 B-15 167 September 2019 Section C C-1 16-1 March 2016 C-2 16-1 March 2016 Section D 1-258 (all pages) SUP December 2019 Section E E-1 150 December 2019 E-2 150 December 2019 Rev. 160 Page 2 of 5 February 2020

LIST OF EFFECTIVE PAGES (LOEP)

EMERGENCY PLAN SECTION PAGE NUMBER REVISION NUMBER DATE E-3 150 December 2019 E-4 150 December 2019 E-5 150 December 2019 E-6 150 December 2019 E-7 150 December 2019 E-8 150 December 2019 E-9 150 December 2019 E-10 150 December 2019 Section F F-1 16-1 March 2016 F-2 16-1 March 2016 F-3 16-1 March 2016 F-4 16-1 March 2016 F-5 16-1 March 2016 F-6 16-1 March 2016 F-7 16-1 March 2016 Section G G-1 161 February 2019 G-2 161 February 2019 G-3 161 February 2019 Section H H-1 150 October 2019 H-2 150 October 2019 H-3 150 October 2019 H-4 150 October 2019 H-5 150 October 2019 H-6 150 October 2019 H-7 150 October 2019 H-8 150 October 2019 H-9 150 October 2019 H-10 150 October 2019 H-11 150 October 2019 H-12 150 October 2019 H-13 150 October 2019 H-14 150 October 2019 Section I I-1 148 December 2019 I-2 148 December 2019 I-3 148 December 2019 I-4 148 December 2019 Section J J-1 148 December 2019 J-2 148 December 2019 J-3 148 December 2019 J-4 148 December 2019 J-5 148 December 2019 J-6 148 December 2019 J-7 148 December 2019 Rev. 160 Page 3 of 5 February 2020

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EMERGENCY PLAN SECTION PAGE NUMBER REVISION NUMBER DATE J-8 148 December 2019 J-9 148 December 2019 Section K K-1 144 September 2017 K-2 144 September 2017 K-3 144 September 2017 K-4 144 September 2017 Section L L-1 11-1 May 2011 L-2 11-1 May 2011 Section M M-1 162 October 2019 M-2 162 October 2019 M-3 162 October 2019 M-4 162 October 2019 M-5 162 October 2019 Section N N-1 151 January 2020 N-2 151 January 2020 N-3 151 January 2020 Section O O-1 145 January 2020 O-2 145 January 2020 Section P P-1 150 December 2019 P-2 150 December 2019 P-3 150 December 2019 P-4 150 December 2019 P-5 150 December 2019 P-6 150 December 2019 P-7 150 December 2019 Section Q Q-1 154 November 2019 Appendix 1 Q-1.1 154 November 2019 Q-1.2 154 November 2019 Q-1.3 154 November 2019 Q-1.4 154 November 2019 Q-1.5 154 November 2019 Q-1.6 154 November 2019 Q-1.7 154 November 2019 Q-1.8 154 November 2019 Q-1.9 154 November 2019 Section Q, Appendix 2 Q-2.1 154 November 2019 Q-2.2 154 November 2019 Q-2.3 154 November 2019 Q-2.4 154 November 2019 Q-2.5 154 November 2019 Appendix 3 Q-3.1 154 November 2019 Q-3.2 154 November 2019 Rev. 160 Page 4 of 5 February 2020

LIST OF EFFECTIVE PAGES (LOEP)

EMERGENCY PLAN SECTION PAGE NUMBER REVISION NUMBER DATE Q-3.3 154 November 2019 Q-3.4 154 November 2019 Q-3.5 154 November 2019 Appendix 4 Q-4.1 154 November 2019 Appendix 5 Q-5.1 154 November 2019 Q-5.2 154 November 2019 Q-5.3 154 November 2019 Rev. 160 Page 5 of 5 February 2020

INTENTIONAL BLANK PAGE Catawba Nuclear Station Emergency Plan Section N - Exercises and Drills N. EXERCISES AND DRILLS N.1.a Exercises Catawba Nuclear Station will conduct emergency exercises in accordance with requirements of 10CFR50, Appendix E.

The Emergency Operations Facility will participate in all exercises involving full participation by the affected state or local governments N.1.b Exercise Scenario Response The exercises will be designed to test the integrated capability of those involved and a major portion of the basic elements existing within the plans and organizations. The scenario for these exercises will be varied from exercise to exercise such that all major elements of the plans and organizations will be tested within an eight-year exercise cycle.

N.2 Drills Catawba Nuclear Station will conduct drills in accordance with requirements of 10CFR50, Appendix E. Drills shall be conducted to test, develop and maintain skills in a particular operation. Drills may be a component of an exercise. Drills will be conducted and evaluated by a designated drill director. Drills will be held in accordance with PD-EP-ALL-0800, Drills and Exercises, AD-EP-ALL-0801, Design and Development of Drills and Exercises, AD-EP-ALL-0802, Conducting Drills and Exercises and AD-EP-ALL-0803, Evaluation and Critique of Drills and Exercises.

(AR#01900418)

N.2.a Communications

1. Monthly Checks are conducted with the states of North and South Carolina and with York, Mecklenburg and Gaston Counties.
2. Monthly Checks are conducted with the NRC Headquarters from the Control Room, TSC, and EOF.

Also monthly calls to the NRC Region II Operations Rev. 151 N-1 January 2020

Center and National Weather Service will be made to ensure accessibility.

3. Quarterly Checks with Federal emergency response organizations are considered complete with the monthly call to the NRC. The states in the ingestion pathway are contacted in the monthly call to North & South Carolina.
4. Annual Communications Checks are performed between the Control Room, the TSC, and the EOF; North and South Carolina EOCs; York, Mecklenburg, and Gaston County EOCs and the field monitoring team.
5. Annual Checks are conducted with Federal emergency response organizations, Dept. of Energy's Savannah River Plant and REAC/TS in Oak Ridge, Tenn. See PT/0/B/4600/005C, Annual Communications Verification.

N.2.b Fire drills shall be conducted in accordance with AD-TQ-ALL-0086 (Fire Brigade and HAZMAT Training), AD-OP-ALL-0207 (Fire Brigade Administrative Controls) and AD-EG-ALL-1531 (Selection, Care and Maintenance of Firefighting Ensembles).

N.2.c Medical emergency drills involving a simulated contaminated and injured individual which contains provisions for participation by the local ambulance service shall be conducted annually. The off-site portion of the medical drill may be performed as part of the required exercise.

N.2.d Station environs and radiological monitoring drills (on-site and off-site) shall be conducted annually. These drills shall include collection and analysis of all sample media (e.g. water, vegetation, soil and air).

Rev. 151 N-2 January 2020

N.2.e Radiation Protection drills shall be conducted semi-annually which involve response to and analysis of, simulated elevated airborne and liquid samples and direct radiation measurements in the environment.

Analysis of samples may be simulated in Radiation Protection drills.

NOTES: 1. Due to ALARA considerations actual elevated samples will not be used in drills.

2. Radiation Protection and Chemistry personnel perform analyses of similar nature routinely and therefore are not required to perform the analysis for drills.

N.3 Exercise and Drill Execution The Emergency Preparedness Group is responsible for the overall development and direction of the exercise. An Exercise Director and a key group of controllers will develop the exercise scenario, exercise messages, and simulated data for the station and off-site areas. The Exercise Director will, for each exercise, develop an exercise plan. This plan will include objectives of the exercise and evaluation criteria, the date, time, place, and participating organizations, the exercise scenario, a narrative summary of the event including such things as emergency classification at various times in the simulated accident, off-site assistance, some detail on plant conditions, and a description of the arrangements for official observers.

N.4 Exercise Critique A critique will be held following each exercise. The critique will be a closed session between Duke and the Nuclear Regulatory Commission. During the critique, the Manager, Nuclear Support Services, the Exercise Director, the NRC and other official observers from state, federal or local governments will make preliminary evaluations of on-site and corporate emergency response.

Critiques are held after each drill. Drill critiques are open to all drill participants, drill evaluators and drill observers.

N.5 Critique Action Items Deficiencies identified during verbal evaluation are to be entered as condition reports in the Corrective Action Program (CAP) or work request for appropriate resolution. CAP will also be used to assign corrective actions and expected completion dates to the appropriate groups. The Manager, Nuclear Support Services, acting under the authority of the Site Vice President will ensure resolution of each item.

Rev. 151 N-3 January 2020

INTENTIONAL BLANK PAGE Catawba Nuclear Station Emergency Plan Section O - Radiological Emergency Response Training O. RADIOLOGICAL EMERGENCY RESPONSE TRAINING O.1 Off-site Support Agency Training O.1.a. Emergency response training is provided to those Off-site Support Agencies that may be called upon to provide assistance in the event of an emergency at Catawba Nuclear Station. Off-Site Support Agencies receive training and retraining per EP Group Manual Guideline 5.4.1. Training objectives and lesson plans are maintained in the site training files. This training is given by site/corporate personnel and documented on Duke Energy forms per AD-EP-ALL-0500, Emergency Response Training.

O.1.b. A separate training session is offered annually to state and local government emergency planning officials responsible for emergency plans within the plume exposure EPZ.

O.2 Emergency Organization Training O.2.a. The training program for members of the Emergency Organization is outlined in AD-EP-ALL-0500. Training objectives and lesson plans are maintained in the site training files. Prior to inclusion in the Emergency Organization, all individuals must satisfy training requirements for his/her position as outlined in AD-EP-ALL-0500.

O.2.b. Members of the Catawba Security Organization receive training as specified in the Duke Energy Nuclear Security and Contingency Plan.

O.2.c. Fire Brigade personnel are trained per AD-TQ-ALL-0086, Fire Brigade and Hazmat Training.

O.2.d. A practice drill session may be held to allow the individuals to perform their assigned functions. The drill instructor may make on the spot corrections and/or demonstration of the proper performance.

O.3 First Aid Training Rev 145 O-1 January 2020

First Responder training is given to the Medical Emergency Response Team (MERT) members per AD-SY-ALL-0280, Medical Emergency Response Team (MERT) and Technical Rescue Training.

O.4 Training For Radiological Emergency Response Personnel Training requirements for the following groups are described in EP Group Manual 5.4.1 and AD-EP-ALL-0500. Training objectives and lesson plans are maintained in training files.

a. Directors and Coordinators of Response Organizations
b. Personnel Responsible for Radiological Assessment
c. Radiological Monitoring Teams
d. Police, Security and Fire Fighting Personnel
e. Repair and Recovery Teams
f. First Aid and Rescue Personnel
g. Site Services Support Personnel
h. Medical Support Personnel
i. All Emergency Response Organization Personnel
j. Personnel Responsible for Transmission of Emergency Information and Instructions
k. Personnel Responsible for Data Coordination O.5 Retraining of Radiological Emergency Response Personnel Initial and retraining requirements for each Emergency Response Organization position are defined in AD-EP-ALL-0500.

Rev 145 O-2 January 2020

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