RA-21-0023, 10 CFR 50 .54(q) Screening Evaluation Form and 10 CFR 50 .54(q) Effectiveness Evaluation Form for PLP-201, Revision 73

From kanterella
(Redirected from RA-21-0023)
Jump to navigation Jump to search
10 CFR 50 .54(q) Screening Evaluation Form and 10 CFR 50 .54(q) Effectiveness Evaluation Form for PLP-201, Revision 73
ML21034A448
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 02/03/2021
From: Riley K
Duke Energy Progress
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-21-0023
Download: ML21034A448 (31)
v • d • e


Text

( ~ DUKE Kevin P. RIiey

~ ENERGY Nuclear Support Services Manager Harris Nuclear Plant 5413 Shearon Harris Road New Hill. NC 27562-9300 10 CFR 50.4(b)(5)(ii) 10 CFR 50.54(q)(5)

February 3 . 2021 Serial : RA-21 -0023 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63

Subject:

10 CFR 50.54(q) Evaluation Ladies and Gentlemen:

In accordance with 10 CFR 50.4(b)(5)(ii) and 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is submitting the 10 CFR 50.54(q) Screening Evaluation Form and the 10 CFR 50.54(q)

Effectiveness Evaluation Form for a revision to the Shearon Harris Nuclear Power Plant. Unit 1, Emergency Plan . PLP-201 , "Emergency Plan ," Revision 73, was issued on January 19, 2021 .

This submittal contains no regulatory commitments . Please refer any questions regarding this submittal to Sarah McDaniel at (984) 229-2002.

Sincerely.

~tf?£/

Kevin P. Riley

Enclosure:

10 CFR 50.54(q) Screening Evaluation Form and 10 CFR 50.54(q) Effectiveness Evaluation Form for PLP-201 , Revision 73 cc: J. Zeiler, NRC Senior Resident Inspector, HNP M. Mahoney, NRG Project Manager, HNP NRC Regional Administrator, Region II

Document Control Desk Serial: RA-21-0023 Enclosure ENCLOSURE SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400/RENEWED LICENSE NUMBER NPF-63 10 CFR 50.54(Q) SCREENING EVALUATION FORM AND 10 CFR 50.54(Q) EFFECTIVENESS EVALUATION FORM FOR PLP-201, REVISION 73 (29 PAGES PLUS COVER)

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

Rev. 7 ATTACHMENT 4 Page 1 of 13

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

Screening and Evaluation Number Applicable Sites BNP EREG #: 2351581 CNS HNP MNS ONS 5AD #: 2351580 RNP GO Document and Revision PLP-201, Harris Emergency Plan Revision 73 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):

The table provided on the following pages contains changes incorporated in PLP-201, Revision 73.

Change Section Changed From Changed To EP Impact 1 Throughout Rev. 72 Changed to "Rev. 73" None; editorial throughout change.

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

Rev. 7 UATTACHMENT 4 Page 2 of 13

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

2 1.2 The HNP Emergency The following HNP This change Preparedness Controlled Emergency Preparedness corrects the Documents are contained in Documents are Tier 2 description of the Controlled Procedure Documents and are EP document Manual (CPM) and consist of controlled using PD-DC-ALL- control to the following: 0001: reference PD-

  • Plant Emergency
  • Plant Emergency reference to the Procedures (PEP and Procedures (PEP and EP documents considered to AD-EP-HNP) and CSD- AD-EP-HNP) be Tier 2 and EP-HNP-0101-01
  • Fleet Emergency Tier 3
  • Fleet Emergency Procedures (AD-EP-ALL) documents.

Procedures (AD-EP-ALL)

  • Emergency Program The EAL
  • Emergency Program Maintenance (EPM) Wallchart Maintenance (EPM) document is The following HNP also added to The Emergency Phone Lists, Emergency Preparedness this description.

EPL-001 and CSD-EP-ALL- Documents are Tier 3 This change 0104-01,are documents Documents: has no impact controlled outside the CPM.

  • EPL-001, Emergency on EP Phone List standards.
  • CSD-EP-ALL-0104-01, Emergency Telephone Directory
  • CSD-EP-HNP-0101-01, EAL Technical Basis Document

development, review, and development, review, and periodic update is assigned periodic update is assigned to the Manager - Site to the Manager, Nuclear Support Services who serves Support Services, who as the HNP Emergency serves as the HNP Planning Coordinator. Emergency Planning Coordinator.

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

Rev. 7 UATTACHMENT 4 Page 3 of 13

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

4 3.4.1.a Located in the Waste Located on the 2nd floor of This change is Processing Building inside the Service Building inside evaluated the Protected Area (Figure the Protected Area (Figure under EREG 1.5 3). 1.5 3). AR 2351581-02.

5 3.4.1.b The total area is The total area is This change is approximately 1500 square approximately 1200 square evaluated feet in the Waste Processing feet in the Service Building. under EREG Building HP Tech Work Area. This area includes a AR 2351581-This area includes a Command and Control area, 02.

separate Command and co-located with the Outage Control area for coordinating Command Center (OCC), for and planning of OSC coordinating and planning of activities in addition to OSC activities, as well as sufficient area for team sufficient area in adjacent members to standby for conference rooms for team activities. Additional space in members to standby for excess of 8500 square feet is activities. Additional space in available in adjacent offices excess of 2000 square feet is and locker rooms to available in adjacent offices accommodate additional to accommodate additional personnel as may be personnel as may be required. required.

6 3.10.1 4th sentence: 4th sentence: This change is Data from ERFIS is Data from ERFIS is evaluated transmitted to the Technical transmitted to the Technical under EREG Support Center (TSC), Support Center (TSC) and AR 2351581-Emergency Operations Emergency Operations 02.

Facility (EOF), and the Facility (EOF) via EP-NET Operation Support Center thin client terminals.

(OSC) via EP-NET thin client terminals.

7 Table 3.1- Fifth column header: Fifth column header: This change is 1, fifth OSC OSC (f) evaluated column under EREG Adjusted column width from 0.44" to 0.7" to accommodate AR 2351581-new text. 02.

8 Table 3.1-1 Battery-Powered Lanterns Battery-Powered Flashlights This change is evaluated under EREG AR 2351581-02.

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

Rev. 7 UATTACHMENT 4 Page 4 of 13

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

9 Table 3.1- N/A Added to document: This change is 1, Notes Note (f): Stored in the Waste evaluated section Processing Building in the under EREG HP Work Area AR 2351581-02.

Adjusted Notes section paragraph spacing from 12 point to 6 point to accommodate new note.

10 4.1 HNP decision-makers HNP decision-makers This change responsible for responsible for adds a fleet EP implementation of implementation of AD-EP- procedure Emergency Classification ALL-0111, Control Room reference and and Protective Action Activation of the ERO, may adds the Recommendations, may use use CSD-EP-HNP-0101-01, document ID of the EAL Basis Document as EAL Technical Basis the EAL a technical reference in Document, as a technical Technical Basis support of EAL interpretation. reference in support of EAL Document. This interpretation. change has no impact on EP standards.

11 4.2.b The Emergency The Emergency None; editorial Communicator will use the Communicator will use the change since electronic Emergency electronic Emergency this change Notification Form (ENF) on Notification Form (ENF) on only removed a WebEOC, hard copy ENF WebEOC, hard copy ENF reference to a contained in PEP-310 and contained in AD-EP-ALL- site procedure AD-EP-ALL-0304, or the 0304, State and County no longer used.

Duke Emergency Notifications, or the Duke Management Network Emergency Management (DEMNET) phone to Network (DEMNET) phone to simultaneously notify the 24- simultaneously notify the 24-hour-per-day, staffed, State hour-per-day, staffed, State Warning Point, State EOC Warning Point, State EOC and County Warning Points and County Warning Points with the notification with the notification message.

message.

12 Table 4.0- "Support Responsibility" "Support Responsibility" Vendor title 1, Reentry column: column: change only.

section HNP, W, URS Energy and HNP, W, AECOM, Inc., This change Construction, FEMA, County, FEMA, County, Duke Energy, has no impact Duke Energy, DOE DOE on EP standards.

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

Rev. 7 UATTACHMENT 4 Page 5 of 13

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

13 4.6.3.F.1 1st paragraph: 1st paragraph: This change is WakeMed Raleigh and WakeMed Raleigh serves as evaluated WakeMed Cary serve as a backup medical facility for under EREG backup medical facilities for HNP personnel should UNC AR 2351581-HNP personnel should UNC Rex Healthcare become 02.

Rex Healthcare become unavailable.

unavailable.

3rd paragraph: 3rd paragraph:

An emergency kit is An emergency kit is maintained at UNC Rex maintained at UNC Rex Healthcare, WakeMed Healthcare and WakeMed Raleigh, and WakeMed Cary Raleigh containing supplies containing supplies and and equipment for personnel equipment for personnel monitoring and the control of monitoring and the control of radioactive contamination.

radioactive contamination.

4th paragraph:

4th paragraph: Agreements with UNC Rex Agreements with UNC Rex Healthcare and WakeMed Healthcare, WakeMed Raleigh are maintained on Raleigh and WakeMed Cary file by HNP Emergency are maintained on file by Preparedness. These HNP Emergency hospitals are listed in Annex Preparedness. These three A, "Letters of Agreement".

hospitals are listed in Annex A, "Agreements".

14 Table 4.2- Request Assistance (if Removed from document: This change is 1, Section necessary)

  • WakeMed Cary evaluated D
  • UNC Rex Healthcare under EREG
  • WakeMed Raleigh AR 2351581-
  • WakeMed Cary 02.
  • Fire and Rescue Departments 15 Table 4.2- Request Assistance (if Removed from document: This change is 2, Section necessary)
  • WakeMed Cary evaluated D
  • UNC Rex Healthcare under EREG
  • WakeMed Raleigh AR 2351581-
  • WakeMed Cary 02.
  • Fire and Rescue Departments

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

Rev. 7 UATTACHMENT 4 Page 6 of 13

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

16 Table 4.2- Request Assistance (if Removed from document: This change is 3, Section necessary)

  • WakeMed Cary evaluated D
  • UNC Rex Healthcare under EREG
  • WakeMed Raleigh AR 2351581-
  • WakeMed Cary 02.
  • Fire and Rescue Departments 17 Table 4.2- Request Assistance (if Removed from document: This change is 4, Section necessary)
  • WakeMed Cary evaluated D
  • UNC Rex Healthcare under EREG
  • WakeMed Raleigh AR 2351581-
  • WakeMed Cary 02.
  • Fire and Rescue Departments 18 5.1.1 The HNP Manager - Site The HNP Manager, Nuclear None; editorial Support Services is Support Services, is change.

responsible for coordinating responsible for coordinating on-site and selected off-site on-site and selected off-site radiological emergency radiological emergency response planning. The HNP response planning. The HNP Manager - Site Support Manager, Nuclear Support Services is also responsible Services, is also responsible for performing the following for performing the following planning functions: planning functions:

19 5.1.2 The Manager - Site Support The Manager, Nuclear None; editorial Services will coordinate the Support Services, will change.

updating of the Plant coordinate the updating of Emergency Plan, Plant the Plant Emergency Plan, Emergency Procedures, and Plant Emergency Supporting Agreements as Procedures, and Supporting needed and will review and Agreements as needed and certify them to be current on will review and certify them to an annual basis. be current on an annual basis.

20 5.1.2 Changes to the E-Plan, or Changes to the E-Plan, or None; editorial CSD-EP-HNP-0101-01 shall CSD-EP-HNP-0101-01, EAL change.

be forwarded to the NRC Technical Basis Document, within 30 days after approval. shall be forwarded to the NRC within 30 days after approval.

21 5.2.2 The Manager - Site Support The Manager, Nuclear None; editorial Services is responsible for Support Services, is change.

the overall content and responsible for the overall administration of the content and administration of emergency plan training the emergency plan training program. program.

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

Rev. 7 UATTACHMENT 4 Page 7 of 13

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

22 5.2.4 Section title: Section title: None; editorial 5.2.4 Manager - Site 5.2.4 Manager, Nuclear change.

Support Services and Staff Support Services and Staff Training Training 23 5.5.2.B A growl test should be A growl test should be This change is performed at least once per performed at least once per evaluated calendar quarter. calendar quarter. Since this under EREG is a silent siren test followed AR 2351581-by a short-duration audible 02.

siren test, a growl test exceeds the performance requirements of a silent test.

Thus, a growl test can be performed in lieu of a silent test.

24 Annex A, WakeMed Cary Removed from document: This change is Item 5 WakeMed Cary evaluated under EREG AR 2351581-02.

25 Annex A, Murray and Trettel, Inc. Removed from document: This change is Item 16 Murray and Trettel, Inc. evaluated under EREG AR 2351581-02.

26 Annex A, A copy of the Manager - Site A copy of the Manager, None; editorial paragraph Support Services annual Nuclear Support Services change.

at bottom certification that the annual certification that the of page agreements are applicable agreements are applicable 114 and have been reconfirmed and have been reconfirmed when necessary is kept on when necessary is kept on file by HNP Emergency file by HNP Emergency Preparedness. Preparedness.

27 Annex E CSD-EP-HNP-0101-01,EAL CSD-EP-HNP-0101-01, EAL None; editorial TECHNICAL BASIS Technical Basis Document change.

DOCUMENT

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

Rev. 7 UATTACHMENT 4 Page 8 of 13

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

28 Annex E AD-EP-ALL-0101-001, AD- AD-EP-ALL-0101, None; editorial EP-ALL-0109, Emergency Emergency Classification, change.

Classification and Protective and AD-EP-ALL-0109, Offsite Action Recommendations Protective Action Recommendations AD-EP-ALL-0101, AD-EP-ALL-0109, and AD-EP-ALL-0111 references were also relocated from the site EP procedure section to the fleet EP procedure section of this Annex.

29 Annex G, A number of active contracts A number of active contracts This change is 4.0 are maintained in order to are maintained in order to evaluated ensure continuing access to ensure continuing access to under EREG qualified personnel when and qualified personnel when and AR 2351581-if they are needed to if they are needed to 02.

supplement Duke Energy supplement Duke Energy resources. These contracts resources. These contracts provide the capability of provide the capability of obtaining, on an expedited obtaining, on an expedited basis, additional basis, additional maintenance support maintenance support personnel (such as personnel (such as mechanics, electricians, and mechanics, electricians, and I&C Technicians), other I&C Technicians), other technical personnel (such as technical personnel (such as HP and Chemistry HP and Chemistry Technicians), and Technicians), and engineering and consulting engineering and consulting services. For example, services. For example, contracts are maintained with contracts are maintained with Westinghouse, DZ Atlantic, Westinghouse, DZ Atlantic, and AECOM, Inc. A contract and AECOM, Inc.

is maintained with Murray and Trettel, Inc., which provide localized weather forecasts for the system or for HNP area as requested.

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

Rev. 7 UATTACHMENT 4 Page 9 of 13

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

30 Annex G, Medical assistance is Medical assistance is This change is 6.1 available through available through evaluated agreements with the agreements with the under EREG following organizations as following organizations as AR 2351581-described in Section 4.6.3.7 described in Section 4.6.3.7 02.

of this plan. HNP agreements of this plan. HNP agreements with the listed agencies are with the listed agencies are on file at Duke Energy. on file at Duke Energy.

Annex A lists each Annex A lists each agreement: agreement:

  • Local area physicians
  • Local area physicians
  • UNC Rex Healthcare
  • UNC Rex Healthcare
  • WakeMed Raleigh
  • WakeMed Raleigh
  • WakeMed Cary 31 Table G.1- 2nd row: Removed from document: These changes 1 Murray and Trettel are evaluated Murray and Trettel, Inc. under EREG AR 2351581-5th row, 1st column: WakeMed Cary (WMC) 02.

WakMed Raleigh (WMR) 6th row:

WakeMed Cary (WMC) 32 Figure G-1 Right column, 3rd block from Right column, 3rd block from Vendor title top: top: change only.

This change URS Energy and AECOM, Inc. or DZ Atlantic has no impact Construction, Inc. or on EP DZ Atlantic standards.

33 Figure G-1 Right column, 5th block from Removed from document: This change is top: evaluated Murray and Trettel, Inc. under EREG Murray & Trettel AR 2351581-02.

34 Figure G-2 Right column, 2nd block from Right column, 2nd block from Vendor title top: top: change only.

This change URS Energy and AECOM, Inc. has no impact Construction, Inc. on EP standards.

35 Figure G-2 Right column, 5th block from Removed from document: This change is top: evaluated Murray and Trettel, Inc. under EREG Murray & Trettel AR 2351581-02.

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

Rev. 7 UATTACHMENT 4 Page 10 of 13

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

36 Throughout AECOM AECOM, Inc. None; this vendor title change was made for consistency of reference within this document.

37 Annex F PEP-310 AD-EP-ALL-0304 None; editorial. , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes Bases Validation and Verification (V&V) Form is attached (required for IC or EAL change) No Part II. Activity Previously Reviewed? Yes No 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)

Part III. Editorial Change No or Yes 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 The change(s) below are defined as editorial in accordance with justification and editorial AD-EP-ALL-0602, and do not change the intent of the steps as written. complete changes Attachment 4, Changes # - 1, 3, 11, 18-22, and 26-28 Part V.

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.

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

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

Rev. 7 UATTACHMENT 4 Page 11 of 13

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

2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that onshift emergency response responsibilities are staffed and assigned 2b The process for timely augmentation of onshift staff is established and maintained.

3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.

3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.

4 10 CFR 50.47(b)(4) Emergency Classification System 4a A standard scheme of emergency classification and action levels is in 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 the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notification.

5b Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway.

5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter.

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 response organizations.

6b Systems are established for prompt communication to emergency response personnel.

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 the plume exposure pathway emergency planning zone (EPZ).

7b Coordinated dissemination of public information during emergencies is established.

8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response.

8b Adequate equipment is maintained to support emergency response.

9 10 CFR 50.47(b)(9) Accident Assessment 9a Methods, systems, and equipment for assessment of radioactive releases are in use.

10 10 CFR 50.47(b)(10) Protective Response 10a A range of public PARs is available for implementation during emergencies.

10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities.

10c A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.

10d KI is available for implementation as a protective action recommendation in those jurisdictions that

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

Rev. 7 UATTACHMENT 4 Page 12 of 13

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

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.

12 10 CFR 50.47(b)(12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.

13 10 CFR 50.47(b)(13) Recovery Planning and Post-accident Operations 13a Plans for recovery and reentry are developed.

14 10 CFR 50.47(b)(14) Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program areas) is established.

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

14c Identified weaknesses are corrected.

15 10 CFR 50.47(b)(15) Emergency Response Training 15a Training is provided to emergency responders.

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

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

16b Planners responsible for emergency plan development and maintenance are properly trained.

PART IV. Conclusion If no Part IV criteria are checked, then provide Justification and complete Part V below.

Justification:

N/A 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)

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): Sarah McDaniel Preparer Signature: See CAS Date:

See CAS Reviewer Name (Print): Jamey Sharlow Reviewer Signature: See CAS Date:

See CAS Approver Name (Print): Kevin Riley Approver Signature: See CAS Date:

See CAS Approver (EP CFAM, as required): n/a Approver Signature: n/a Date: n/a

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

Rev. 7 UATTACHMENT 4 Page 13 of 13

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

If the proposed activity is a change to the E-Plan, then initiate PRRs. PRR Number(s):

n/a If required by Section 5.6, Submitting Reports of Changes to the NRC, then create two EREG EREG Due Date:

General Assignments.

2/18/21

  • One for Licensing to submit the 10 CFR 50.54(q) information to the NRC in accordance EREG Due Date:

with 10 CFR 50.4(b)(5)(ii) within 30 days after the change is put in effect. 2/18/21 QA RECORD

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

Rev. 7 ATTACHMENT 5 Page 1 of 16

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

Screening and Evaluation Number Applicable Sites BNP EREG #: 2351581 CNS HNP MNS 5AD #: 2351580 ONS RNP GO Document and Revision PLP-201, Harris Emergency Plan Revision 73 Part I. Description of Proposed Change: The PLP-201, Revision 73, changes that require evaluation are shown on pages 1-4 of this form.

Change Section Changed From Changed To 4 3.4.1.a Located in the Waste Processing Located on the 2nd floor of the Service Building inside the Protected Area Building inside the Protected Area (Figure 1.5 3). (Figure 1.5 3).

5 3.4.1.b The total area is approximately 1500 The total area is approximately 1200 square feet in the Waste Processing square feet in the Service Building. This Building HP Tech Work Area. This area includes a Command and Control area includes a separate Command area, co-located with the Outage and Control area for coordinating Command Center (OCC), for and planning of OSC activities in coordinating and planning of OSC addition to sufficient area for team activities, as well as sufficient area in members to standby for activities. adjacent conference rooms for team Additional space in excess of 8500 members to standby for activities.

square feet is available in adjacent Additional space in excess of 2000 offices and locker rooms to square feet is available in adjacent accommodate additional personnel offices to accommodate additional as may be required. personnel as may be required.

6 3.10.1 4th sentence: 4th sentence:

Data from ERFIS is transmitted to Data from ERFIS is transmitted to the the Technical Support Center (TSC), Technical Support Center (TSC) and Emergency Operations Facility Emergency Operations Facility (EOF)

(EOF), and the Operation Support via EP-NET thin client terminals.

Center (OSC) via EP-NET thin client terminals.

7 Table Fifth column header: Fifth column header:

3.1-1, fifth OSC OSC (f) column Adjusted column width from 0.44" to 0.7" to accommodate new text.

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

Rev. 7 UATTACHMENT 5 Page 2 of 16

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

8 Table Battery-Powered Lanterns Battery-Powered Flashlights 3.1-1 9 Table N/A Added to document:

3.1-1, Note (f): Stored in the Waste Notes Processing Building in the HP Work section Area.

Adjusted Notes section paragraph spacing from 12 point to 6 point to accommodate new note.

13 4.6.3.F.1 1st paragraph: 1st paragraph:

WakeMed Raleigh and WakeMed WakeMed Raleigh serves as a backup Cary serve as backup medical medical facility for HNP personnel facilities for HNP personnel should should UNC Rex Healthcare become UNC Rex Healthcare become unavailable.

unavailable.

3rd paragraph: 3rd paragraph:

An emergency kit is maintained at An emergency kit is maintained at UNC UNC Rex Healthcare, WakeMed Rex Healthcare and WakeMed Raleigh Raleigh, and WakeMed Cary containing supplies and equipment for containing supplies and equipment personnel monitoring and the control of for personnel monitoring and the radioactive contamination.

control of radioactive contamination.

4th paragraph:

4th paragraph: Agreements with UNC Rex Healthcare Agreements with UNC Rex and WakeMed Raleigh are maintained Healthcare, WakeMed Raleigh and on file by HNP Emergency WakeMed Cary are maintained on Preparedness. These hospitals are file by HNP Emergency listed in Annex A, "Letters of Preparedness. These three hospitals Agreement".

are listed in Annex A, "Agreements".

14 Table Request Assistance (if necessary) Request Assistance (if necessary) 4.2-1,

  • UNC Rex Healthcare
  • UNC Rex Healthcare Section D
  • WakeMed Raleigh
  • WakeMed Raleigh
  • WakeMed Cary
  • Fire and Rescue Departments
  • Fire and Rescue Departments 15 Table Request Assistance (if necessary) Request Assistance (if necessary) 4.2-2,
  • UNC Rex Healthcare
  • UNC Rex Healthcare Section D
  • WakeMed Raleigh
  • WakeMed Raleigh
  • WakeMed Cary
  • Fire and Rescue Departments
  • Fire and Rescue Departments

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

Rev. 7 UATTACHMENT 5 Page 3 of 16

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

16 Table Request Assistance (if necessary) Request Assistance (if necessary) 4.2-3,

  • UNC Rex Healthcare
  • UNC Rex Healthcare Section D
  • WakeMed Raleigh
  • WakeMed Raleigh
  • WakeMed Cary
  • Fire and Rescue Departments
  • Fire and Rescue Departments 17 Table Request Assistance (if necessary) Request Assistance (if necessary) 4.2-4,
  • UNC Rex Healthcare
  • UNC Rex Healthcare Section D
  • WakeMed Raleigh
  • WakeMed Raleigh
  • WakeMed Cary
  • Fire and Rescue Departments
  • Fire and Rescue Departments 23 5.5.2.b A growl test should be performed at A growl test should be performed at least once per calendar quarter. least once per calendar quarter. Since this is a silent siren test followed by a short-duration audible siren test, a growl test exceeds the performance requirements of a silent test. Thus, a growl test can be performed in lieu of a silent test.

24 Annex A, WakeMed Cary Removed from document:

Item 5 WakeMed Cary.

25 Annex A, Murray and Trettel, Inc. Removed from document:

Item 16 Murray and Trettel, Inc.

29 Annex G, A number of active contracts are A number of active contracts are 4.0 maintained in order to ensure maintained in order to ensure continuing access to qualified continuing access to qualified personnel personnel when and if they are when and if they are needed to needed to supplement Duke Energy supplement Duke Energy resources.

resources. These contracts provide These contracts provide the capability the capability of obtaining, on an of obtaining, on an expedited basis, expedited basis, additional additional maintenance support maintenance support personnel personnel (such as mechanics, (such as mechanics, electricians, electricians, and I&C Technicians),

and I&C Technicians), other other technical personnel (such as HP technical personnel (such as HP and and Chemistry Technicians), and Chemistry Technicians), and engineering and consulting services.

engineering and consulting services. For example, contracts are maintained For example, contracts are with Westinghouse, DZ Atlantic, and maintained with Westinghouse, DZ AECOM, Inc.

Atlantic, and AECOM, Inc. A contract is maintained with Murray and Trettel, Inc., which provide localized weather forecasts for the system or for HNP area as requested.

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

Rev. 7 UATTACHMENT 5 Page 4 of 16

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

30 Annex G, Medical assistance is available Medical assistance is available through 6.1 through agreements with the agreements with the following following organizations as described organizations as described in Section in Section 4.6.3.7 of this plan. HNP 4.6.3.7 of this plan. HNP agreements agreements with the listed agencies with the listed agencies are on file at are on file at Duke Energy. Annex A Duke Energy. Annex A lists each lists each agreement: agreement:

  • Local area physicians
  • Local area physicians
  • UNC Rex Healthcare
  • UNC Rex Healthcare
  • WakeMed Raleigh
  • WakeMed Raleigh
  • WakeMed Cary 31 Table 2nd row: Removed from document:

G.1-1 Murray and Trettel Murray and Trettel 5th row, 1st column:

WakMed Raleigh (WMR) WakeMed Cary (WMC) 6th row:

WakeMed Cary (WMC) 33 Figure G- Right column, 5th block from top: Removed from document:

1 Murray & Trettel Murray and Trettel 35 Figure G- Right column, 5th block from top: Removed from document:

2 Murray & Trettel Murray and Trettel Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

PLP-201, Harris Emergency Plan (Revision 3, dated 1984) (Original License Basis)

PLP-201, Harris Emergency Plan (Revision 72, dated 2020) (Current License Basis)

NUREG-1038, Safety Evaluation Report related to the operation of Shearon Harris Nuclear Power Plant, Units 1 and 2, Section 13.3 (dated 1983)

FEMA Alert and Notification System Design Report WPS2900 Operation and Troubleshooting Guide-2005 Edition EPM-400 Revision 023, Public Notification and Alerting System Changes 4-7 and 9 are related to the OSC relocation. The following are the applicable sections of the license basis (PLP-201):

3.4 Operations Support Center (OSC) 3.4.1 Characteristics

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

Rev. 7 UATTACHMENT 5 Page 5 of 16

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

A. Located in the Waste Processing Building inside the Protected Area (Figure 1.5-3).

B. The total area is approximately 1500 square feet in the Waste Processing Building HP Tech Work Area. This area includes a separate Command and Control area for coordinating and planning of OSC activities in addition to sufficient area for team members to standby for activities. Additional space in excess of 8500 square feet is available in adjacent offices and locker rooms to accommodate additional personnel as may be required.

C. Alternate location is in the Fuel Handling Building, Section "K," near the Technical Support Center. [7.0.U, Recommendation 5h]

3.4.2 Functions A. Assembly location for emergency teams for receipt of special equipment and assignments.

B. Dispatching of emergency teams.

3.4.3 Emergency Equipment and Supplies A. Reliable voice communications with the Main Control Room, EOF, and TSC.

B. Supplies and equipment as shown in Table 3.1-1.

Change 8 is related to equipment updates. The following are the applicable sections of the license basis (PLP-201): Table 3.1-1, which is shown below.

Changes 13-17, 24, 30, and 31 are related to MS-1 Hospitals. The following are the applicable sections of the license basis (PLP-201):

4.6.3.F Medical Treatment

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

Rev. 7 UATTACHMENT 5 Page 6 of 16

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

1) Hospital Facilities A specially designated emergency area is maintained in readiness at UNC Rex Healthcare for HNP's use for the treatment of contaminated or overexposed patients from the plant. Although this area will be utilized by the hospital when not required by HNP, it will be made available to HNP when required. Equipment is available in the hospital for the emergency treatment of patients. With the facilities and equipment available, extensive decontamination and treatment of an injured patient could be performed, including any surgical treatment that may be required. WakeMed Raleigh and WakeMed Cary serve as backup medical facilities for HNP personnel should UNC Rex Healthcare become unavailable.

WakeMed Raleigh serves as the primary medical facility for trauma patients from HNP. Betsy Johnson Regional Hospital, in Dunn, N.C., also possesses the capability for the treatment of contaminated and/or overexposed members of the public.

An emergency kit is maintained at UNC Rex Healthcare, WakeMed Raleigh, and WakeMed Cary containing supplies and equipment for personnel monitoring and the control of radioactive contamination. These kits contain the following:

  • Low-range radiation monitoring instruments for determining contamination levels.
  • Personnel monitoring equipment such as self-reading pocket dosimeters and TLDs.
  • Decontamination equipment and supplies for both personnel and facility.
  • Contamination control equipment and supplies such as protective clothing, signs, ropes, tags, plastic bags.

Agreements with UNC Rex Healthcare, WakeMed Raleigh and WakeMed Cary are maintained on file by HNP Emergency Preparedness. These three hospitals are listed in Annex A, "Agreements".

Changes 23 is related to Siren testing. The following are the applicable sections of the license basis (PLP-201):

5.5.2 Siren System Testing The sirens are tested as follows:

A. A silent test should be performed every two weeks (Bi-weekly).

B. A growl test should be performed at least once per calendar quarter.

C. A full volume test of the system shall be conducted annually. Since this is a 3-minute audible test, a full volume test exceeds the requirements of a growl test. Thus, a full volume test can be performed in lieu of a growl test.

Changes 25,29,31,33, and 35 is related to Weather Data. The following are the applicable sections of the license basis (PLP-201):

Annex G 3.4 Weather Service The National Weather Service at the Raleigh-Durham International Airport, Raleigh, North Carolina, will provide meteorological information during emergency situations, if required. Data available will include existing and forecasted surface wind directions, wind speed with azimuth variability, and ambient surface air temperature.

4.0 Contracted Services A number of active contracts are maintained in order to ensure continuing access to qualified personnel when and if they are needed to supplement Duke Energy resources. These contracts provide the capability of obtaining, on an expedited basis, additional maintenance support personnel (such as mechanics, electricians, and I&C Technicians), other technical personnel (such as HP and Chemistry Technicians), and engineering and consulting services. For example, contracts are maintained with Westinghouse, DZ Atlantic, and AECOM, Inc.

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

Rev. 7 UATTACHMENT 5 Page 7 of 16

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

A contract is maintained with Murray and Trettel, Inc., which provide localized weather forecasts for the system or for HNP area as requested.

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

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):

Changes 4-7 and 9, Operations Support Center (OSC) Relocation from the Waste Processing Building to the Service Building Outage Command Center (OCC):

As part of a planned remodel/upgrade to the OCC, there was a opportunity to add elements to the remodel to create an enhanced OSC, with newer technology. The legacy OSC met the needs of the OSC team, however a larger, modern space allows the OSC to utilize technology more effectively. The design needs of the new OSC were developed by the ERO stakeholders. Briefing rooms, upgraded audio visual technology, and the proximity to the maintenance shop areas provided many efficiencies. The overall mission of an OCC and OSC are similar in nature. Combining the facilities increased the visibility and material condition of the complex. The new complex is identified as an OSC first, OCC second. If the OCC is in use and an emergency is declared the transition to an OSC would be seamless. The OCC manages all field work and activities which would transfer into the OSC processes.

NUREG-0696 requirements for an OSC are met based upon this change. NUREG-0696, section 1.3.2, requires that the OSC is an onsite assembly area separate from the control room and the TSC where licensee operations support personnel shall report in an emergency. There shall be direct communications between the OSC and the control room and between the OSC and the TSC so that the personnel reporting to the OSC can be assigned to duties in support of emergency operations.

NUREG-0696, Section 3 also contains the following requirements for the OSC:

3.1 Functions

The operational support center (OSC) is an onsite area separate from the control room and the TSC where licensee operations support personnel will assemble in an emergency. The OSC shall:

Provide a location where plant logistic support can be coordinated during an emergency, and Restrict control room access to those support personnel specifically requested by the shift supervisor.

When the OSC is activated, it shall be supervised by licensee operations management personnel designated in the licensee's emergency plan to perform these functions.

3.2 Habitability

No specific habitability criteria are established for the OSC. If the OSC habitability is not comparable to that of the control room, the licensee's emergency plan shall include procedures for evacuation of OSC personnel in the event of a large radioactive release. These procedures also shall include provisions for the performance of the OSC functions by essential support personnel from other onsite locations.

3.3 Communications

The OSC shall have direct communications with the control room and with the TSC so that the personnel reporting to the OSC can be assigned to duties in support of emergency operations.

The OSC communications system shall consist of one dedicated telephone extension to the control room, one

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

Rev. 7 UATTACHMENT 5 Page 8 of 16

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

dedicated telephone extension to the TSC, and one dial telephone capable of reaching onsite and offsite locations, as a minimum. Direct voice intercommunications and/or reliable direct radio communications may be used to supplement these telephone communication links.

This change can be made as the readiness of the OSC is enhanced. By co-locating the OSC and OCC in the same complex, this dedicates the use of this space to supporting operations, tracking field work, and command/control of craft workers. This is the same mission of the OSC and OCC respectively. RG-1.219, 4.8.C.1.e states "a change to an ERF use that allows nonemergency uses that would decrease the readiness of the ERF for emergency use" could require prior approval. The readiness of the OSC is enhanced by this change since more frequent use of the facility as an OCC will ensure the technology and tools are at a state of readiness, and familiar with the end user. The new OSC is close to the maintenance shop locations where all tools, equipment, and facilities are housed. This will facilitate the decrease in dispatch time of damage control missions to the field.

Change 6 involves the removal of the EP-NET thin-client terminals to the OSC. As part of the OSC relocation project, it was noted that a qualified ERFIS data source was not needed for OSC functionality. The qualified ERFIS data source is only needed for the Control Room, TSC, and EOF as identified in NUREG-0696, since decisions impacting emergency response are made in these facilities. The OSC is responsible for managing assigned duties in support of emergency operations and has direct communication with the control room and TSC, but does not rely on plant data from EP-NET for emergency assessment.

The PLP-201 changes for the OSC relocation comply with planning standard, (8) Adequate emergency facilities and equipment to support the emergency response are provided and maintained. The new OSC has the technology, equipment staged, and proximity to the maintenance shops to enhance the OSC overall response.

The maintenance of the OSC continues to be governed by site procedures.

Change 8 are related to equipment updates:

Battery-Powered Lanterns, with Battery-Powered Flashlights. The battery-powered flashlights provide lighting to ERO personnel when needed for ERO response. The previously used battery-powered lanterns also provided lighting to ERO personnel when needed for ERO response, however lanterns are no longer procured. Flashlight use is needed to support ERO personnel lighting needs in the future.

This change can be made because we are replacing existing ERF equipment with equipment of like quality, reliability, performance, and user interface. This is specifically outlined in RG-1.219, 4.8.d.

This change complies with planning standard (8) Adequate emergency facilities and equipment to support the emergency response are provided and maintained. The new terminology continues to ensure the end user's ability to light an area if the permanent lighting is lost.

Changes 13-17, 24, 30, and 31 are related to MS-1 Hospitals.

Wake County Emergency Management has requested that Wake Med Cary be removed as an MS-1 (Medical Services) agreement hospital. Wake Med Cary has been listed as a secondary (Backup) location due to its location to the plant. When Wake County Emergency Management started the discussion of the removal of Wake Med Cary from the Emergency Plan it was largely based on the capabilities of the hospital. Wake Med Raleigh, and UNC Rex Raleigh are designated as Trauma Centers. This designation allows them to stabilize and treat all injuries and then transport to higher care if needed. UNC Rex Raleigh, and Wake Med Raleigh are MS-1 Hospitals already and fully trained, prepared, and practiced in MS-1 type events (contaminated injured patient).

The removal of Wake Med Cary allows the transport protocols for EMS responders to be simplified with two destination locations. If a contaminated injured patient was critical in nature (multi-system trauma) Wake Med

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

Rev. 7 UATTACHMENT 5 Page 9 of 16

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

Cary would not be the transport decision, but Wake Med Raleigh, or UNC Rex Raleigh would. Additionally, it allows more time to be allocated for training and practice to the required two hospitals per II.L of NUREG-0654.

Sections IV.E.5-7 of Appendix E to 10 CFR Part 50 supply supporting requirements.

This change can be made because two hospitals, with similar treatment capabilities, and identical radiological control capabilities exist at Wake Med Raleigh, and UNC Rex Hospital Raleigh. Transport capabilities are enhanced as the two hospitals mentioned above can handle all medical cases and stabilize accordingly. The third hospital is not needed for the successful implementation of the emergency plan . RG-1.219, 4.12.d states "d. A change in the designation of a replacement offsite medical facility would generally not require prior NRC approval provided that the new facility has equivalent capabilities and is accessible within a timeframe consistent with the urgency of emergency medical treatment (the licensees 10 CFR 50.54(q) evaluation must document the basis of this equivalency conclusion)". The remaining hospitals in the Emergency Plan (UNC Rex and Wake Med Raleigh) exceed the capabilities of Wake Med Cary and continue to be at the appropriate transport time from the Harris Plant.

Planning Standard (12) Arrangements are made for medical services for contaminated injured individuals is met as HNP has two agreement hospitals, and multiple EMS agencies in the Wake County Mutual Aid System in place and trained to respond/treat/transport contaminated injured individuals.

Changes 23 is related to Siren testing.

The current license basis states a growl test should be performed at least once per calendar quarter. Current programming of a growl test is a silent siren test followed by a short-duration audible siren test. Considering a growl test includes a silent test; a growl test exceeds the performance requirements of a silent test. Thus, a growl test can be performed in lieu of a silent test. This change is being made so that the siren system is cycled less.

By cycling the sirens less frequently it reduces the wear and tear on the drivers and amplifiers of the system.

Planning Standard (5) states: Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow-up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established. This change does not deviate from the methodology or design of the approved FEMA Siren (ANS) design report. This change specifically involves HNPs method of siren periodic testing for equipment reliability.

Changes 25,29,31,33, and 35 is related to Weather Data.

With the merger of Progress Energy and Duke Energy, many efficiencies were gained related to Meteorological Services. Prior to the merger Murray Trettle, a contract weather provider was on retainer to provide the site with weather forecasts. This was used for normal weather monitoring as well as dose assessment forecasting. Live weather data was and continues to be pulled from the onsite Meteorological Tower (MET Tower). Historically in the event the MET Tower was out of service, Murray Trettle would be able to postulate local forecast to HNP 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Duke Energy has an internal Meteorological Team that supports the enterprise 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.

Local forecasting, local MET Tower Access for live conditions, and forecasting capabilities continue to be provided for HNP, from Duke Energy's internal Meteorological Team. With this internal company service available to HNP, there is no longer a need for a third-party vendor.

Planning Standard (9) states: Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use. Duke Meteorology maintains the same capabilities of Murray Trettle as they can access our MET Tower live and provide real time insights if needed. HNP still procedurally maintains full backup weather data capabilities with the National Weather Service

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

Rev. 7 UATTACHMENT 5 Page 10 of 16

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

in Raleigh, NC.

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 4-7 and 9 are related to the OSC relocation. The following are the applicable sections of the license basis (PLP-201):

Planning Standard (8) Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Planning Function: (1) Adequate facilities are maintained to support emergency response.

8.a. (i) A licensee onsite technical support center and an emergency operations facility from which effective direction can be given and effective control can be exercised during an emergency; (ii) For nuclear power reactor licensees, a licensee onsite operational support center.

Planning Element H. 9. Each licensee shall provide for an onsite operations support center (assembly area) which shall have adequate capacity, and supplies, including, for example, respiratory protection, protective clothing, portable lighting, portable radiation monitoring equipment, cameras and communications equipment for personnel present in the assembly area.

Change 8 is related to equipment updates:

Planning Standard (8) Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Planning Function:(2) Adequate equipment is maintained to support emergency response.

E. Emergency Facilities and Equipment Adequate provisions shall be made and described for emergency facilities and equipment, including:

1. Equipment at the site for personnel monitoring;
2. Equipment for determining the magnitude of and for continuously assessing the impact of the release of radioactive materials to the environment;
3. Facilities and supplies at the site for decontamination of onsite individuals;
4. Facilities and medical supplies at the site for appropriate emergency first aid treatment;
5. Arrangements for medical service providers qualified to handle radiological emergencies onsite;
6. Arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary;
7. Arrangements for treatment of individuals injured in support of licensed activities on the site at treatment facilities outside the site boundary; 8.a. (i) A licensee onsite technical support center and an emergency operations facility from which effective direction can be given and effective control can be exercised during an emergency; (ii) For nuclear power reactor licensees, a licensee onsite operational support center.

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

Rev. 7 UATTACHMENT 5 Page 11 of 16

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

Planning Element 11. Each plan shall, in an appendix, include identification of emergency kits by general category (protective equipment, communications equipment, radiological monitoring equipment and emergency supplies).

Changes 13-17, 24, 30, and 31 are related to MS-1 Hospitals:

Planning Standard (12) Arrangements are made for medical services for contaminated injured individuals.

Planning Function: Arrangements are made for medical services for contaminated, injured individuals.

Arrangements for treatment of individuals injured in support of licensed activities on the site at treatment facilities outside the site boundary.

Planning Element L. 1. Each organization shall arrange for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.

Changes 23 is related to Siren testing:

Planning Standard (5) Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

Planning Function: The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants (Ref. 16), or is compliant with the licensees FEMA-approved ANS design report and supporting FEMA approval letter.

D. 3. a licensee shall have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency. The licensee shall demonstrate that the appropriate governmental authorities have the capability to make a public alerting and notification decision promptly on being informed by the licensee of an emergency condition. Prior to initial operation greater than 5 percent of rated thermal power of the first reactor at a site, each nuclear power reactor licensee shall demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ. The design objective of the prompt public alert and notification system shall be to have the capability to essentially complete the initial alerting and initiate notification of the public within the plume exposure pathway EPZ within about 15 minutes. The use of this alerting and notification capability will range from immediate alerting and notification of the public (within 15 minutes of the time that State and local officials are notified that a situation exists requiring urgent action) to the more likely events where there is substantial time available for the appropriate governmental authorities to make a judgment whether or not to activate the public alert and notification system. The alerting and notification capability shall additionally include administrative and physical means for a backup method of public alerting and notification capable of being used in the event the primary method of alerting and notification is unavailable during an emergency to alert or notify all or portions of the plume exposure pathway EPZ population.

The backup method shall have the capability to alert and notify the public within the plume exposure pathway EPZ, but does not need to meet the 15-minute design objective for the primary prompt public alert and notification system. When there is a decision to activate the alert and notification system, the appropriate governmental authorities will determine whether to activate the entire alert and notification system simultaneously or in a graduated or staged manner. The responsibility for activating such a public alert and notification system shall

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

Rev. 7 UATTACHMENT 5 Page 12 of 16

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

remain with the appropriate governmental authorities.

Planning Element E. 6. Each organization shall establish administrative and physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone. (See Appendix 3.) It shall be the licensee's responsibility to demonstrate that such means exist, regardless of who implements this requirement. It shall be the responsibility of the State and local governments to activate such a system.

Changes 25,29,31,33, and 35 is related to Weather Data:

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

Planning Function: Methods, systems, and equipment for assessment of radioactive releases are in use.

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

Planning Element I. 5. Each licensee shall have the capability of acquiring and evaluating meteorological information sufficient to meet the criteria of Appendix 2. There shall be provisions for access to meteorological information by at least the near site Emergency Operations Facility, the Technical Support Center, the Control Room and an offsite NRC center. The licensee shall make available to the State suitable meteorological data processing interconnections which will permit independent analysis by the State, of facility generated data in those States with the resources to effectively use this information.

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

Changes 4-7 and 9, OSC Relocation from the Waste Processing Building to the Service Building OCC:

As part of a planned remodel/upgrade to the Outage Control Center (OCC), there was a chance to add elements to the remodel to create an enhanced OSC. The legacy OSC met the needs of the OSC team, however a larger, modern space allows the OSC to utilize technology more effectively. The design needs of the new OSC were developed by the ERO stakeholders. Briefing rooms, upgraded audio visual technology, and the proximity to the maintenance shop areas made sense. The overall mission of an OCC and OSC are similar in nature. Combining the facilities increased the visibility and material condition of the complex. The new complex is identified as an OSC first, OCC second. If the OCC is in use and an emergency is declared the transition to an OSC would be seamless. The OCC manages all field work and activities which would transfer

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

Rev. 7 UATTACHMENT 5 Page 13 of 16

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

into the OSC processes.

This change can be made as the readiness of the OSC is enhanced. By co-locating the OSC and OCC in the same complex, this dedicates the use of this space to supporting operations, tracking field work, and command/control of craft workers. This is the same mission of the OSC and OCC respectively. The readiness of the OSC is enhanced by this change since more frequent use of the facility as an OCC will ensure the technology and tools are at a state of readiness, and familiar with the end user. The new OSC location is close to the maintenance shop locations where all tools, equipment, and facilities are housed. This will facilitate the decrease in dispatch time of damage control missions to the field.

Change 6 involves the removal of the EP-NET thin-client terminals to the OSC. As part of the OSC relocation project, it was noted that a qualified ERFIS data source was not needed for OSC functionality. The qualified ERFIS data source is only needed for the Control Room, TSC, and EOF as identified in NUREG-0696, since decisions impacting emergency response are made in these facilities. The OSC is responsible for managing assigned duties in support of emergency operations and has direct communication with the control room and TSC, but does not rely on plant data from EP-NET for emergency assessment.

The changes to the emergency plan as a result of the OSC relocation are not a reduction in effectiveness because adequate facilities are maintained to support emergency response.

Change 8 are related to equipment updates:

Battery-Powered Lanterns, with Battery-Powered Flashlights. The battery-powered flashlights provide lighting to ERO personnel when needed for ERO response. The previously used battery-powered lanterns also provided lighting to ERO personnel when needed for ERO response, however lanterns are no longer procured.

Flashlight use is needed to support ERO personnel lighting needs in the future.

This change can be made because we are replacing existing ERF equipment with equipment of like quality, reliability, performance, and user interface. This is not a reduction in effectiveness because adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Changes 13-17, 24, 30, and 31 are related to MS-1 Hospitals.

Wake County Emergency Management has requested that Wake Med Cary be removed as an MS-1 (Medical Services) agreement hospital. Wake Med Cary has been listed as a secondary (Backup) location due to its location to the plant. When Wake County Emergency Management started the discussion of the removal of Wake Med Cary from the Emergency Plan it was largely based on the capabilities of the hospital. Wake Med Raleigh, and UNC Rex Raleigh are designated as Trauma Centers. This designation allows them to stabilize and treat all injuries and then transport to higher care if needed. UNC Rex Raleigh, and Wake Med Raleigh are MS-1 Hospitals already and fully trained, prepared, and practiced in MS-1 type events (contaminated injured patient). The removal of Wake Med Cary allows the transport protocols for EMS responders to be simplified with two destination locations. Additionally, it allows more time to be allocated for training and practice to the required two hospitals per II.L of NUREG-0654.

This change can be made because two hospitals, with similar treatment capabilities, and identical radiological control capabilities exist at Wake Med Raleigh, and UNC Rex Hospital Raleigh. Transport capabilities are enhanced as the two hospitals mentioned above can handle all medical cases and stabilize accordingly. The third hospital is not needed for the successful implementation of the emergency plan and causes administrative burden to Wake County EMS The remaining hospitals in the Emergency Plan (UNC Rex and Wake Med

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

Rev. 7 UATTACHMENT 5 Page 14 of 16

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

Raleigh) exceed the capabilities of Wake Med Cary and continue to be at the appropriate transport time from the Harris Plant.

Changes 23 is related to Siren testing.

The current license basis states a growl test should be performed at least once per calendar quarter. Since this is a silent siren test followed by a short-duration audible siren test, a growl test exceeds the performance requirements of a silent test. Thus, a growl test can be performed in lieu of a silent test. This change is being made so that the siren system is cycled less. By cycling the sirens less frequently it reduces the wear and tear on the drivers and amplifiers of the system. Historical data shows that cycling the tests more frequently led to replacement amplifiers and drivers of individual sirens. Since this test is functionally equivalent and needs to be performed anyways, it is prudent to take credit for this test. Additionally, the HNP system completes an automatic interrogation every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to ensure functionality of the system. Additionally, every Wednesday the system completes a full silent test. These touchpoints are in addition to scheduled PMs or surveillances.

Planning Standard (5) Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow-up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established. This change does not deviate from the methodology or design of the approved FEMA Siren (ANS) design report. This change specifically involves HNPs method of siren periodic testing for equipment reliability.

Changes 25,29,31,33, and 35 is related to Weather Data.

With the merger of Progress Energy and Duke Energy, many efficiencies were gained related to Meteorological Services. Prior to the merger Murray Trettle, a contract weather provider was on retainer to provide the site with weather forecasts. This was used for normal weather monitoring as well as dose assessment forecasting. Live weather data was and continues to be pulled from the onsite Meteorological Tower (MET Tower). Historically in the event the MET Tower was out of service, Murray Trettle would be able to postulate local forecast to HNP 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Duke Energy has a internal Meteorological Team that supports the enterprise 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.

Local forecasting, local MET Tower Access for live conditions, and forecasting capabilities enhance the process for HNP. With this service available to HNP there is no longer a need for a third party vendor.

HNP still has full backup weather data capabilities with the National Weather Service in Raleigh, NC.

The proposed changes do not reduce the effectiveness of Harris Nuclear Plant Emergency Plan. These changes continue to provide assurance that the Emergency Response Organization 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.

These changes continue to meet NRC requirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E as well as the requirements of the Duke Energy Sites Emergency Plans as written and approved.

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

Rev. 7 UATTACHMENT 5 Page 15 of 16

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

Part VI. Evaluation Conclusion.

Answer the following questions about the proposed change.

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

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

a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current Emergency Action Level (EAL) scheme. Therefore, the activity can be implemented without prior NRC approval. If Yes, then mark Part VII as not applicable (N/A).

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.

Therefore, the activity cannot be implemented without prior NRC approval.

NOTE: If prior NRC approval required, then complete Part VII.

Part VII. Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change determined to require prior NRC approval be either revised or N/A Yes No 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:__________________________________________________.

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

Rev. 7 UATTACHMENT 5 Page 16 of 16

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

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): Sarah McDaniel Preparer Signature: See CAS Date:

See CAS Reviewer Name (Print): Jamey Sharlow Reviewer Signature: See CAS Date:

See CAS Approver Name (Print): Kevin Riley Approver Signature: See CAS Date:

See CAS Approver (CFAM, as required): n/a Approver Signature: n/a Date: n/a If the proposed activity is a change to the E-Plan, then initiate PRRs. PRR Number(s):

N/A If required by Section 5.6, Submitting Reports of Changes to the NRC, then create two EREG Due Date:

EREG General Assignments. 2/18/21

  • One for Licensing to submit the 10 CFR 50.54(q) information to the NRC in accordance EREG Due Date:

with 10 CFR 50.4(b)(5)(ii) within 30 days after the change is put in effect. 2/18/21 QA RECORD

Retrieved from "https://kanterella.com/w/index.php?title=RA-21-0023,_10_CFR_50_.54(q)_Screening_Evaluation_Form_and_10_CFR_50_.54(q)_Effectiveness_Evaluation_Form_for_PLP-201,_Revision_73&oldid=3417322"