RA-21-0130, 10 CFR 50.54(q) Evaluations

From kanterella
(Redirected from RA-21-0130)
Jump to navigation Jump to search
10 CFR 50.54(q) Evaluations
ML21117A027
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 04/27/2021
From: Riley K
Duke Energy Progress
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-21-0130
Download: ML21117A027 (34)


Text

(_~ DUKE ENERGY.

April 27, 2021 Serial: RA-21-0130 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) Evaluations Ladies and Gentlemen:

Kevin P. Riley Nuclear Support Services Manager Harris Nuclear Plant 5413 Shearon Harris Road New Hill, NC 27562-9300 10 CFR 50.4(b )(S)(ii) 10 CFR 50.54(q)(5)

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) Review Forms for revisions to the Shearon Harris Nuclear Power Plant, Unit 1, Emergency Plan. PLP-201, "Emergency Plan," Revision 74, was issued on March 30, 2021. PLP-201, Revision 75, and PLP-201, Revision 76, were issued on April 20, 2021.

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

Sincerely,

Enclosure:

10 CFR 50.54(q) Review Form for PLP-201, Revision 74 10 CFR 50.54( q) Review Form for PLP-201, Revision 75 10 CFR 50.54( q) Review Form for PLP-201, Revision 76 cc:

J. Zeiler, NRC Senior Resident Inspector, HNP M. Mahoney, NRC Project Manager, HNP NRC Regional Administrator, Region II

Document Control Desk Serial: RA-21-0130 Enclosure ENCLOSURE SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400/RENEWED LICENSE NUMBER NPF-63 10 CFR 50.54(Q) REVIEW FORM FOR PLP-201, REVISION 74 10 CFR 50.54(Q) REVIEW FORM FOR PLP-201, REVISION 75 10 CFR 50.54(Q) REVIEW FORM FOR PLP-201, REVISION 76 (32 PAGES PLUS COVER)

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 1 of 11

<< 10 CFR 50.54(q) Review Form >>

Section I: 10 CFR 50.54(q) Review Number: (EREG #):

2375486 Applicable Sites and Applicability Determination # (5AD)

BNP CNS HNP 2375473 MNS ONS RNP Document #, EC #, or N/A Revision # or N/A Document or Activity Title PLP-201 74 Emergency Plan Section II: Identify/Describe All Proposed Activities/Changes 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 (Use attachments or continue additional pages as necessary): Continue to Section III.

The procedure revision incorporates PRRs 2339863, 2357738, and 2374507. The changes remove the Generation Supply Chain Liaison (OSC) from augmented ERO full staffing and update various procedure references in Annex E. These changes are further illustrated in the table below.

E-Plan Section Reference Current (Existing) Text Proposed (Change) Text 1

Footer Rev. 73 Rev. 74 2

Table of Contents Corrected a formatting issue throughout document. Note space between 1.0. Space present with all major headers.

Also, page numbers will change based on Change 3 below.

Corrected a formatting issue throughout document. Spacing corrected for the major headings within the Table of Contents Page numbers updated to reflect current page numbers of each section.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 2 of 11

<< 10 CFR 50.54(q) Review Form >>

3 Section 2.4.3.I Generation Supply Chain Liaison The Generation Supply Chain Liaison reports to the OSC Manager. Key responsibilities include:

1. Develop requests and coordinate external assistance (i.e., technical, craft, admin)
2. Arrange for equipment and supply resources
3. Arrange for logistics support
4. Prepare for facility activation (i.e., rooms, work area, equipment)
5. Participate with OSC Team dispatch and control
6. Serve as primary point of contact for SAFER and FLEX support Deleted this section in its entirety.

Moved numbered items not previously duplicated to other document locations.

(Reference changes 4 and 5.)

Renumbered subsequent sections. (Sections previously 2.4.3.J and 2.4.3.K are now Sections 2.4.3.I and 2.4.3.J.)

4 Section 2.4.3.C Maintenance Supervisor The Maintenance Supervisor reports to the OSC Manager. Key responsibilities include:

1. Manage assigned group emergency response activities
2. Develop requests and coordinate external assistance (technical, craft, admin, etc.)
3. Arrange for equipment and supply resources
4. Participate with OSC Team dispatch and control
5. Provide input for facility briefs and updates Maintenance Supervisor The Maintenance Supervisor reports to the OSC Manager. Key responsibilities include:
1. Manage assigned group emergency response activities
2. Develop requests and coordinate external assistance (technical, craft, admin, etc.)
3. Arrange for equipment and supply resources
4. Participate with OSC Team dispatch and control
5. Provide input for facility briefs and updates
6. Arrange for logistics support [emphasis added to show added text]

5 Section 2.4.3.D Operations Supervisor The Operations Supervisor reports to the OSC Manager. Key responsibilities include:

1) Manage assigned group emergency response activities
2) Develop requests and coordinate external assistance (technical, craft, admin, etc.)
3) Arrange for equipment and supply Operations Supervisor The Operations Supervisor reports to the OSC Manager. Key responsibilities include:
1) Manage assigned group emergency response activities
2) Develop requests and coordinate external assistance (technical, craft, admin, etc.)
3) Arrange for equipment and supply

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 3 of 11

<< 10 CFR 50.54(q) Review Form >>

resources

4) Monitor status and information boards/displays/systems
5) Participate with OSC Team dispatch and control
6) Provide input for facility briefs and updates
7) Perform chemical sampling and analysis
8) Record and review chemical sampling and analysis resources
4) Monitor status and information boards/displays/systems
5) Participate with OSC Team dispatch and control
6) Provide input for facility briefs and updates
7) Perform chemical sampling and analysis
8) Record and review chemical sampling and analysis
9) Serve as primary point of contact for SAFER and FLEX support [emphasis added to show added text]

6 Figure 2.2-1 Currently, Figure 2.2-1, HNP Emergency Response Organization Augmented includes the position Generation Supply Chain Liaison under the entry for Plant System Engineering, Repair, and Corrective Actions.

This position is being removed from the organization as captured per Change 3.

Removed position from the figure.

7 Figure 2.4-3 Currently, Figure 2.4-3, Operations Support Center (OSC) includes the position Generation Supply Chain Liaison.

This position is being removed from the organization as captured per Change 3.

Removed position from the figure.

8 Annex E Currently, the List of Emergency Preparedness Documents, under Emergency Program Maintenance and Administration (EPMs), include the following:

TE-EP-ALL-0407, Verification of Emergency Operations Facility Communication Equipment Operation and Equipment/Supply Inventory TE-EP-ALL-0408, Periodic Test of the Emergency Operations Facility DEMNET, ENS, and ETS Revise the List of Emergency Preparedness Documents, under Emergency Program Maintenance and Administration (EPMs), to remove TR-EP-ALL-0407 and TE-EP-ALL-0408 and include the following:

AD-EP-ALL-0407, Emergency Operations Facility Surveillance 9

Annex E Currently, the List of Emergency Add to the List of Emergency Preparedness

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 4 of 11

<< 10 CFR 50.54(q) Review Form >>

Preparedness Documents, under Emergency Program Maintenance and Administration (EPMs), include the following:

EPM-400, Public Notification and Alerting System This procedure is linked to Plan Section 5.5, Testing and Maintenance of the Public Notification and alerting System Reference below.

Documents, under Emergency Program Maintenance and Administration (EPMs), the following document, below EPM-400:

AD-EP-ALL-0305, Fleet Emergency Preparedness (EP) Alert and Notification System (ANS) Siren Program This procedure is also linked to Plan Section 5.5, Testing and Maintenance of the Public Notification and alerting System Reference below.

Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:

List all emergency plan sections that were reviewed for this activity by number and title.

IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.

Licensing Basis PLP-201, Harris Nuclear Plant Emergency Plan (Revision 3)

Current Emergency Plan PLP-201, Harris Nuclear Plant Emergency Plan (Revision 73)

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 5 of 11

<< 10 CFR 50.54(q) Review Form >>

Section IV: Ability to Maintain the Emergency Plan.

Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.

1. Do any of the elements of the proposed activity change information or intent contained in the Emergency Plan?

Yes No

2. Do any elements of the proposed activity change an Initiating Condition (IC), Emergency Action Level (EAL), associated EAL note or basis, including underlying calculation or basis?

Yes No, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is required to be completed as part of this review if "Yes" is selected above in question 2.

3. Do any elements of the proposed activity change the process or capability for alerting or notifying the public as described in the FEMA-approved Alert and Notification System Design Report?

Yes No

4. Do any elements of the proposed activity change the Evacuation Time Estimate results?

Yes No

5. Do any elements of the proposed activity change the On-Shift Staffing Analysis results?

Yes No

6. Does the Proposed activity require a change to the Emergency Plan Programmatic Description?

Yes No If Question 6 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.

Section IV conclusion:

If questions 1-6 in Section IV marked NO, then complete Section V.

If any question 1-6 of Section IV marked yes, then continue at Section VI.

Section V: Maintaining the Emergency Plan Conclusion.

The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.

1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.
2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.

I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).

==

Conclusion:==

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 6 of 11

<< 10 CFR 50.54(q) Review Form >>

Section VI: Activity Previously Reviewed?

Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?

Yes 10 CFR 50.54(q) Evaluation is not required.

Identify bounding source document below and continue to Section XIV.

No Continue to Section VII.

Partially If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.

Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.

Section VII: Editorial Changes Yes All Activities/Changes identified in Section II are editorial/typographical changes such as formatting, paragraph numbering, spelling, or punctuation that does not change intent.

No None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to Section VIII.

Partially Some Activities/Changes are editorial/typographical.

If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XIV.

If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.

Justification:

The changes below are defined as editorial in accordance with AD-EP-ALL-0602, and do not change the intent of the steps as written.

Change 1 - Editorial because the change updates revision footer information based on this revision.

Change 2 - Editorial as it corrects the spacing in the Table of Contents (typographical change to formatting) and updates the page numbers for each section.

Change 8 - Editorial change as the change corrects references that are no longer applicable. TE-EP-ALL-0407 and TE-EP-ALL-0408 have been superseded by AD-EP-ALL-0407. (Note that a separate screen and evaluation was performed to address differences between TE-EP-ALL-0407 /

0408 and AD-EP-ALL-0407. Reference EREG 2363184.)

Change 9 - Editorial change. Information from EPM-400 was transferred to AD-EP-ALL-0305 as this new fleet procedure will govern activities related to the Siren Program going forward. This change was evaluated per EREG 2374211. The change being considered per this EREG is limited to the addition of the reference to PLP-201 Annex E. This change assures all applicable references are correctly annotated to the emergency plan. There is no change to the intent of the guidance per this change.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 7 of 11

<< 10 CFR 50.54(q) Review Form >>

Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)

Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate 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.

2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned 2b 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.

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 RS 4a A standard scheme of emergency classification and action levels is in use. (Requires V/V (Attachment 5) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS 5a Procedures for notification of State and local governmental agencies are capable of alerting them of 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 instructions to 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 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 RS 9a Methods, systems, and equipment for assessment of radioactive releases are in use.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 8 of 11

<< 10 CFR 50.54(q) Review Form >>

10 10 CFR 50.47(b) (10) Protective Response RS 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 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.

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.

Section VIII: Conclusion If any Section VIII criteria are checked, continue the 50.54(q) Review Section IX.

If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document the basis for conclusion below and continue to Section XIV.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 9 of 11

<< 10 CFR 50.54(q) Review Form >>

Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.

Proposed Changes 3, 4, 5, 6, and 7 Standard 10CFR50.47(b)(2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

Function The associated EP Function is Function 2b, "The process for timely augmentation of on shift staff is established and maintained."

Element Program Elements NUREG-0654 Section II.B B.1 Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement.

B.5 Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1. The implementation schedule for licensed operators, auxiliary operators and the shift technical advisor on shift shall be as specified in the July 31, 1980 letter to all power reactor licensees. Any deficiencies in the other staffing requirements of Table B-1 must be capable of augmentation within 30 minutes by September 1, 1981, and such deficiencies must be fully removed by July 1, 1982.

B.9 Each licensee shall identify the services to be provided by local agencies for handling emergencies, e.g.,

police, ambulance, medical, hospital, and fire-fighting organizations shall be specified. The licensee shall provide for transportation and treatment of injured personnel who may also be contaminated. Copies of the arrangements and agreements reached with contractor, private, and local support agencies shall be appended to the plan. The agreements shall delineate the authorities, responsibilities, and limits on the actions of the contractor, private organization, and local services support groups.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 10 of 11

<< 10 CFR 50.54(q) Review Form >>

Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC 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). Address each Planning Standard identified in Section IX. Continue to Section XI.

Proposed changes 3, 4, 5, 6, and 7 remove the Generation Supply Chain Liaison (GSCL) from the Emergency Plan and moves functions not previously duplicated to other positions to maintain the Emergency Plan. These functions can be conducted without impacting the timeliness of other functions already assigned to these positions. This change is an efficiency gain. Nuclear Supply Chain maintains a 24/7 duty rotation that can be contacted at any time for specific needs that arise during an Emergency and support the site. That support is defined in an Interface Agreement. This change ensures functions are met by other positions in the OSC and will be supported by the 24/7 duty position. The EOF Services Manager is the contact for external help during an emergency and that supports the maintenance of the Planning Standard. The ERO continues to be staffed to augment initial response on a continuous basis. Thus, the HNP Emergency Plan will continue to comply with 10 CFR 50.47(b)(2), Onsite Emergency Organization, and 10 CFR Part 50 Appendix E, Section IV.A Organization.

Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.

Function The associated EP Function is Function 2b, "The process for timely augmentation of onshift staff is established and maintained."

Proposed changes 3, 4, 5, 6, and 7 remove the Generation Supply Chain Liaison (GSCL) from the Emergency Plan and moves functions not previously duplicated to other positions to maintain the Emergency Plan. This change is an efficiency gain. Nuclear Supply Chain maintains a 24/7 duty rotation that can be contacted at any time for specific needs that arise during an Emergency. That support is defined in an Interface Agreement. This change ensures functions are met by other positions in the OSC and will be supported by the 24/7 duty position. The EOF Services Manager is the contact for external help during an emergency and that supports the function of augmentation for on shift staff.

The proposed changes do not reduce the effectiveness of the Shearon 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 Shearon Harris Nuclear Plant Emergency Plan as written and approved.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 11 of 11

<< 10 CFR 50.54(q) Review Form >>

Section XII: 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 reduction in effectiveness)?

Yes No

3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme?

Yes No Section XII: Conclusion Questions 1, 2 and 3 are answered YES, complete step below to create CAS assignment EP03, and then continue on to Section XIV and implement change(s).

Complete CAS assignment EP03 - Licensing submit changes in accordance with 10 CFR 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XIII and Section XIV.

Section XIII: Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change be submitted to the NRC for prior approval?

If No, reject the proposed change, or modify the proposed change and perform a new evaluation.

Continue to Section XIV for this evaluation.

Yes No If YES, 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:___________________________________. Complete Section XIV.

Section XIV: Signatures:

EP CFAM Final Approval is required for changes affecting Program Element 4a of Section VIII. 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.Section XIV as applicable.

Preparer Name (Print): Chuck Yarley Preparer Signature: See CAS Date:

See CAS Reviewer Name (Print): Sarah McDaniel Reviewer Signature: See CAS Date:

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

See CAS Approver (EP CFAM, as required) Name (Print):

N/A Approver Signature: N/A Date: N/A QA RECORD

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 1 of 13

<< 10 CFR 50.54(q) Review Form >>

Section I: 10 CFR 50.54(q) Review Number: (EREG #):

2372747 Applicable Sites and Applicability Determination # (5AD)

BNP CNS HNP 2372745 MNS ONS RNP Document #, EC #, or N/A Revision # or N/A Document or Activity Title PLP-201 75 Harris Emergency Plan Section II: Identify/Describe All Proposed Activities/Changes 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 (Use attachments, or continue additional pages as necessary): Continue to Section III.

Proposed Change 1: PLP-201, Harris Emergency Plan Section 3.3 Technical Support Center, Subsection 3.3.1 Characteristics, I.

From: "Alternate location is the 305 Shift Manager, Shift Technical Advisor, and the Auxiliary Operator office area.

To: "A Backup location is inside the Main Control Room within the ventilation boundary."

Proposed Change 2: PLP-201, Annex C, Technical Support Center (TSC) definition.

From: A center outside of the Main Control Room in which information is supplied on the status of the plant to those individuals who are knowledgeable or responsible for engineering and management support of reactor operations in the event of an emergency, and to those persons who are responsible for management of the on-site emergency response.

To: A center outside of the Main Control Room crew operating area in which information is supplied on the status of the plant to those individuals who are knowledgeable or responsible for engineering and management support of reactor operations in the event of an emergency, and to those persons who are responsible for management of the on-site emergency response.

Proposed Change 3: Update Revision Number from, 74 to 75.

Proposed Change 4: Update summary of changes per PRR 2376202.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 2 of 13

<< 10 CFR 50.54(q) Review Form >>

Additional Information: In the event the TSC becomes uninhabitable, non-functional, or inaccessible, a Backup TSC will be established in the Main Control Room (MCR). This proposed change establishes a Backup TSC around the exterior area of the MCR away from the crew operating area. This proposed change is being made to ensure emergency assessment capability is not impaired if the primary TSC is not available.

Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:

List all emergency plan sections that were reviewed for this activity by number and title.

IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.

PLP-201, Harris Emergency Plan, Revision 74 (Current), Section 3.3.1 and Annex C PLP-201, Harris Emergency Plan, Revision 3 (Original License Basis), Section 3.3.1 and Annex C 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.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 3 of 13

<< 10 CFR 50.54(q) Review Form >>

Section IV: Ability to Maintain the Emergency Plan.

Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.

1. Do any of the elements of the proposed activity change information or intent contained in the Emergency Plan?

Yes No

2. Do any elements of the proposed activity change an Initiating Condition (IC), Emergency Action Level (EAL), associated EAL note or basis, including underlying calculation or basis?

Yes No, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is required to be completed as part of this review if "Yes" is selected above in question 2.

3. Do any elements of the proposed activity change the process or capability for alerting or notifying the public as described in the FEMA-approved Alert and Notification System Design Report?

Yes No

4. Do any elements of the proposed activity change the Evacuation Time Estimate results?

Yes No

5. Do any elements of the proposed activity change the On-Shift Staffing Analysis results?

Yes No

6. Does the Proposed activity require a change to the Emergency Plan Programmatic Description?

Yes No If Question 6 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.

Section IV conclusion:

If questions 1-6 in Section IV marked NO, then complete Section V.

If any question 1-6 of Section IV marked yes, then continue at Section VI.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 4 of 13

<< 10 CFR 50.54(q) Review Form >>

Section V: Maintaining the Emergency Plan Conclusion.

The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.

1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.
2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.

I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).

==

Conclusion:==

Section VI: Activity Previously Reviewed?

Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?

Yes 10 CFR 50.54(q) Evaluation is not required.

Identify bounding source document below and continue to Section XIV.

No Continue to Section VII.

Partially If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.

Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.

Section VII: Editorial Changes Yes All Activities/Changes identified in Section II are editorial/typographical changes such as formatting, paragraph numbering, spelling, or punctuation that does not change intent.

No None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to Section VIII.

Partially Some Activities/Changes are editorial/typographical.

If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XIV.

If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.

Justification: Changes 3 and 4 for updating revision number and revision summary are editorial per AD-EP-ALL-0602.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 5 of 13

<< 10 CFR 50.54(q) Review Form >>

Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)

Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate 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.

2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned 2b 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.

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 RS 4a A standard scheme of emergency classification and action levels is in use. (Requires V/V (Attachment 5) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS 5a Procedures for notification of State and local governmental agencies are capable of alerting them of 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 instructions to 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 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 RS 9a Methods, systems, and equipment for assessment of radioactive releases are in use.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 6 of 13

<< 10 CFR 50.54(q) Review Form >>

10 10 CFR 50.47(b) (10) Protective Response RS 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 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.

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.

Section VIII: Conclusion If any Section VIII criteria are checked, continue the 50.54(q) Review Section IX.

If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document the basis for conclusion below and continue to Section XIV.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 7 of 13

<< 10 CFR 50.54(q) Review Form >>

Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.

Planning Standard 10 CFR 50.47(b)(8) - Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Supporting requirements of Appendix E to 10 CFR Part 50 Adequate provisions shall be made and described for emergency facilities and equipment, including:

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; Emergency Plan Planning Function 8a - Adequate facilities are maintained to support emergency response.

Emergency Plan Planning Function 8b - Adequate equipment is maintained to support emergency response.

Program Elements from NUREG-0654 II.H 1.Each licensee shall establish a Technical Support Center and an onsite operations support center (assembly area) in accordance with NUREG-0696, Revision 1.

Program Elements from NUREG-0696 1.3.1 Technical Support Center The technical support center (TSC) is an onsite facility located close to the control room that shall provide plant management and technical support to the reactor operating personnel located in the control room during emergency conditions. It shall have technical data displays and plant records available to assist in the detailed analysis and diagnosis of abnormal plant conditions and any significant release of radioactivity to the environment. The TSC shall be the primary communications center for the plant during an emergency. A senior official, designated by the licensee, shall use the resources of the TSC to assist the control room operators by handling the administrative items, technical evaluations, and contact with offsite activities, relieving them of these functions.

The TSC facilities may also be used for performing normal functions, such as shift technical supervisor and plant operations/maintenance analysis functions, as well as for emergencies.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 8 of 13

<< 10 CFR 50.54(q) Review Form >>

2. TECHNICAL SUPPORT CENTER 2.1 Function The onsite technical support center (TSC) will provide the following functions:

Provide plant management and technical support to plant operations personnel during emergency conditions.

Relieve the reactor operators of peripheral duties and communications not directly related to reactor system manipulations.

Prevent congestion in the control room.

Perform EOF functions for the Alert Emergency class and for the Site Area Emergency class and General Emergency class until the EOF is functional.

Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC 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). Address each Planning Standard identified in Section IX. Continue to Section XI.

NUREG-0696, Functional Criteria for Emergency response Facilities, was used to ensure HNP Main Control Room, used as Backup TSC, would be an adequate emergency facility to support emergency response and from which effective direction can be given and effective control can be exercised during an emergency. Ten TSC criteria are listed in NUREG-0696:

Function The Backup TSC using approved TSC procedures will provide the following functions:

Provide plant management and technical support to plant operations personnel during emergency conditions.

Relieve the reactor operators of peripheral duties and communications not directly related to reactor system manipulations.

Prevent congestion in the Main Control Room crew operating area.

Backup TSC will be located along the exterior perimeter of the Main Control Room away from the control board.

Perform EOF functions for the Alert, Site Area Emergency, and General Emergency classifications until the EOF is functional.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 9 of 13

<< 10 CFR 50.54(q) Review Form >>

Location The Backup TSC will provide a facility near the Main Control Room operating area for detailed analyses of plant conditions during abnormal conditions or emergencies by trained and competent technical staff. This will allow for adequate telephone communications and face-to-face communications if needed. Since the Backup TSC is inside the MCR complex this will allow for face to face communications, as well as live alarm response for key decision making by the Emergency Coordinator-TSC.

Staffing and Training The Backup TSC will be staffed and activated by same individuals trained to staff and activate the Primary TSC. Activation of the Backup TSC away from the Main Control Room operating area (Control Board) shall ensure that only designated operating personnel are in the Main Control Room operating area during the emergency and that needed technical support will be provided without obstructing actual plant manipulations or overcrowding the Main Control Room.

Size Per NUREG-0696, TSC working space should be sized to accommodate for ERO personnel assigned to the TSC and NRC personnel. The Backup TSC has sufficient space for minimum staff personnel and NRC personnel. It is large enough to provide:

Working space, without crowding, for the personnel.

Space for the TSC data system equipment (laptop computers) needed to acquire, process, and display data used in the TSC. Since the Back Up TSC is located inside the MCR complex, alarms, data, and plant conditions will be provided directly to the Emergency Coordinator-TSC, from MCR staff when possible and via the Control Room OPS Bridge position who does this action for the main TSC as well. The Control Room OPS Bridge ERO position is assigned to the MCR operating area during all TSC (Primary or Backup) activations. This position is responsible for providing timely updates from the MCR operating area. When the Backup TSC is in use, these updates will be conducted face to face, as well as telephone bridge lines with the OSC/EOF.

Sufficient space to perform repair, maintenance, and service of equipment, displays, and instrumentation.

Space for data transmission equipment needed to transmit data originating in the TSC to other locations. Printers, computers, and facsimile capability exists in the MCR. The TSC will have assigned laptops for use in addition to installed MCR IT infrastructure.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 10 of 13

<< 10 CFR 50.54(q) Review Form >>

Space for personnel access to functional displays (laptop computers) of TSC data. Since the Back Up TSC is located inside the MCR complex, alarms, data, and plant conditions will be provided directly to the Emergency Coordinator-TSC. The Control Room OPS Bridge ERO position is assigned to the MCR operating area during all TSC (Primary or Backup) activations. This position is responsible for providing timely updates from the MCR operating area. When the Backup TSC is in use, these updates will be conducted face to face, as well as telephone bridge lines with the OSC/EOF.

Space for unhindered access to communications equipment by all TSC personnel who need communications capabilities to perform their functions. Existing IT infrastructure is able to be utilized by Back Up TSC personnel. In addition there are prestaged ASCOM devices (one for each minimum staff position) for external/internal telephone communications.

Space for storage of and/or access to plant records and historical data.

The MCR has a library and has hard copy procedures, as well as access to the electronic data and plant records system.

A separate area adequate for at least three persons to be used for private NRC consultations.

Structure The Backup TSC is able to withstand the most adverse conditions reasonably expected during the design life of the plant including adequate capabilities for (1) earthquakes, (2) high winds (other than tornadoes), and (3) floods.

Habitability Backup TSC is located in the MCR so it has equivalent radiological habitability and environmental conditions as the MCR during an accident.

Communications The Backup TSC will be the primary onsite communications center for HNP when in use during an emergency. It has reliable voice communications to the Main Control Room, OSC, EOF, and the NRC. Provisions for communications with State and local operations centers are provided. Communication methods include Duke Emergency Management Network (DEMNET), Voice Over IP, Cellular Phones, Business Lines, and onsite radios.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 11 of 13

<< 10 CFR 50.54(q) Review Form >>

Instrumentation, Data System Equipment, and Power Supplies Computers are available to gather, store, and display data needed in the Backup TSC to analyze plant conditions. Data will be accessed with qualified OSI-PI displays and Control Board indications via the Control Room OPS Bridge ERO position who is stationed next to the Shift Manager. Data can be accessed independent of actions in the Main Control Room and without degrading or interfering with Main Control Room and plant functions. Backup power sources (Emergency Diesel Generators) are available for the Control Room complex that contains the Backup TSC. In areas where there is a loss of lighting, pre-staged flashlights, and portable desks are available to deploy and relocate to a lighted area inside the MCR complex.

Technical Data and Data System The Backup TSC will utilize the qualified OSI-PI displays and the Main Control Board for TSC function. This data enables the plant management, engineering, and technical personnel assigned in TSC to aid the control room operators in handling emergency conditions. A sufficient number of computers will be available for ERO personnel to perform their assigned tasks with unhindered access to data.

Records Availability and Management Backup TSC personnel will have access to plant records and procedures to aid in their technical analysis and evaluation of emergency conditions. These records include drawings of plant systems needed to diagnose sensor data, evaluate data inconsistencies, and identify and counteract faulty plant system elements.

Since all 10 NUREG-0696 criteria can be met using the Backup TSC, emergency assessment capability would not be impaired if the primary TSC is not available and the Backup TSC had to be utilized. This proposed change does not impact 10 CFR 50.47(b)(8) because this change continues to ensure adequate emergency facilities and equipment to support the emergency response are provided and maintained.

This proposed change does not impact Appendix E to 10 CFR 50 because adequate provisions are made and described including an onsite technical support center from which effective direction can be given and effective control can be exercised during an emergency.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 12 of 13

<< 10 CFR 50.54(q) Review Form >>

Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.

In the event the TSC becomes uninhabitable or inaccessible, a Backup TSC will be established in the Main Control Room complex. This proposed change establishes a Backup TSC around the exterior area of the Main Control Room away from the control room operating area. This change is being made to ensure emergency assessment capability is not impaired if the primary TSC is not available. The primary TSC will continue to be maintained to the same level of readiness. Adequate equipment to support emergency response will be maintained in primary TSC and Backup TSC. The Backup TSCs space, structure, habitability requirements, communication capabilities, data system equipment, and records availability for ERO personnel establish the same function as the primary TSC. Therefore, the Backup TSC continues to ensure adequate facilities and equipment are maintained to support emergency response. Since NUREG-0696 criteria can be met using the Backup TSC, emergency assessment capability would not be impaired if the primary TSC is not available and the Backup TSC had to be utilized.

The Emergency Plan function of Emergency Facilities and Equipment is improved by adding a Backup TSC in cases where primary TSC is not available. The proposed change does not reduce the effectiveness of Harris Emergency Plan.

The proposed change continues 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.

This proposed change continues 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 Harris Emergency Plan as written and approved.

Section XII: 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 reduction in effectiveness)?

Yes No

3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme?

Yes No Section XII: Conclusion

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 13 of 13

<< 10 CFR 50.54(q) Review Form >>

Questions 1, 2 and 3 are answered YES, complete step below to create CAS assignment EP03, and then continue on to Section XIV and implement change(s).

Complete CAS assignment EP03 - Licensing submit changes in accordance with 10 CFR 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XIII and Section XIV.

Section XIII: Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change be submitted to the NRC for prior approval?

If No, reject the proposed change, or modify the proposed change and perform a new evaluation.

Continue to Section XIV for this evaluation.

Yes No If YES, 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:___________________________________. Complete Section XIV.

Section XIV: Signatures:

EP CFAM Final Approval is required for changes affecting Program Element 4a of Section VIII. 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.Section XIV as applicable.

Preparer Name (Print):

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

Sarah McDaniel Reviewer Signature: See CAS Date:See CAS Approver Name (Print):

Kevin Riley Approver Signature: See CAS Date:See CAS Approver (EP CFAM, as required) Name (Print):

N/A Approver Signature: N/A Date: N/A QA RECORD

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 1 of 8

<< 10 CFR 50.54(q) Review Form >>

Section I: 10 CFR 50.54(q) Review Number: (EREG #):

02379000 Applicable Sites and Applicability Determination # (5AD)

BNP CNS HNP 02378999 MNS ONS RNP Document #, EC #, or N/A Revision # or N/A Document or Activity Title PLP-201 76 Harris Emergency Plan Section II: Identify/Describe All Proposed Activities/Changes 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 (Use attachments, or continue additional pages as necessary): Continue to Section III.

Revision 76 of PLP-201 is to correct the footer of this document so that it shows on all pages (PRR 2378081) and to add continuation headings for numerous sections of the document to improve formatting. These changes are the only changes being made in PLP-201, Revision 76, and are both considered to be editorial changes in accordance with AD-EP-ALL-0602.

Licensing Basis PLP-201, Harris Nuclear Plant Emergency Plan Current Emergency Plan PLP-201, Harris Nuclear Plant Emergency Plan (Revision 75)

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.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 2 of 8

<< 10 CFR 50.54(q) Review Form >>

Section IV: Ability to Maintain the Emergency Plan.

Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.

1. Do any of the elements of the proposed activity change information or intent contained in the Emergency Plan?

Yes No

2. Do any elements of the proposed activity change an Initiating Condition (IC), Emergency Action Level (EAL), associated EAL note or basis, including underlying calculation or basis?

Yes No, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is required to be completed as part of this review if "Yes" is selected above in question 2.

3. Do any elements of the proposed activity change the process or capability for alerting or notifying the public as described in the FEMA-approved Alert and Notification System Design Report?

Yes No

4. Do any elements of the proposed activity change the Evacuation Time Estimate results?

Yes No

5. Do any elements of the proposed activity change the On-Shift Staffing Analysis results?

Yes No

6. Does the Proposed activity require a change to the Emergency Plan Programmatic Description?

Yes No If Question 6 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.

Section IV conclusion:

If questions 1-6 in Section IV marked NO, then complete Section V.

If any question 1-6 of Section IV marked yes, then continue at Section VI.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 3 of 8

<< 10 CFR 50.54(q) Review Form >>

Section V: Maintaining the Emergency Plan Conclusion.

The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.

1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.
2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.

I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).

==

Conclusion:==

The only proposed changes in Revision 76 of PLP-201 are to correct the footer of this document so that it shows on all pages (PRR 2378081) and to add continuation headings for numerous sections of the document to improve formatting. These changes are considered to be editorial changes in accordance with AD-EP-ALL-0602. The proposed 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.

This proposed change continues 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 Harris Emergency Plan as written and approved.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 4 of 8

<< 10 CFR 50.54(q) Review Form >>

Section VI: Activity Previously Reviewed?

Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?

Yes 10 CFR 50.54(q) Evaluation is not required.

Identify bounding source document below and continue to Section XIV.

No Continue to Section VII.

Partially If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.

Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.

Section VII: Editorial Changes Yes All Activities/Changes identified in Section II are editorial/typographical changes such as formatting, paragraph numbering, spelling, or punctuation that does not change intent.

No None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to Section VIII.

Partially Some Activities/Changes are editorial/typographical.

If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XIV.

If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.

Justification:

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 5 of 8

<< 10 CFR 50.54(q) Review Form >>

Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)

Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate 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.

2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned 2b 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.

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 RS 4a A standard scheme of emergency classification and action levels is in use. (Requires V/V (Attachment 5) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS 5a Procedures for notification of State and local governmental agencies are capable of alerting them of 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 instructions to 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 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 RS 9a Methods, systems, and equipment for assessment of radioactive releases are in use.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 6 of 8

<< 10 CFR 50.54(q) Review Form >>

10 10 CFR 50.47(b) (10) Protective Response RS 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 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.

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.

Section VIII: Conclusion If any Section VIII criteria are checked, continue the 50.54(q) Review Section IX.

If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document the basis for conclusion below and continue to Section XIV.

Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 7 of 8

<< 10 CFR 50.54(q) Review Form >>

Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC 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). Address each Planning Standard identified in Section IX. Continue to Section XI.

Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.

Section XII: 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 reduction in effectiveness)?

Yes No

3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme?

Yes No Section XII: Conclusion Questions 1, 2 and 3 are answered YES, complete step below to create CAS assignment EP03, and then continue on to Section XIV and implement change(s).

Complete CAS assignment EP03 - Licensing submit changes in accordance with 10 CFR 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XIII and Section XIV.

Section XIII: Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change be submitted to the NRC for prior approval?

If No, reject the proposed change, or modify the proposed change and perform a new evaluation.

Continue to Section XIV for this evaluation.

Yes No If YES, 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:___________________________________. Complete Section XIV.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

AD-EP-ALL-0602 Rev. 8 ATTACHMENT 2 Page 8 of 8

<< 10 CFR 50.54(q) Review Form >>

Section XIV: Signatures:

EP CFAM Final Approval is required for changes affecting Program Element 4a of Section VIII. 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.Section XIV as applicable.

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) Name (Print):

N/A Approver Signature:

N/A Date:

N/A QA RECORD