Text

Emergency Plan Annex, Revision 1, Emergency Action Level (EAL) Technical Basis Document, Revision 3, and EAL Wallchart, Revision 2
	ML22041B799
Person / Time
Site:	Oconee
Issue date:	02/10/2022
From:	Snider S; Duke Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RA-22-0070
	Download: ML22041B799 (38)
	v • d • e

Steven M. Snider Vice President Oconee Nuclear Station Duke Energy ON01VP l 7800 Rochester Hwy Seneca, SC 29672 RA-22-0070 o: 864.873.3478 f: 864.873.4208 Steve.Snider@duke-energy.com February 10, 2022 10 CFR 50.54(q) 10 CFR 72.44(f)

Attn: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852-2746 Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Renewed License Nos. DPR-38,-47, and -55

SUBJECT:

Oconee Emergency Plan Annex, Revision 1, Emergency Action Level (EAL)

Technical Basis Document, Revision 3, and EAL Wallchart, Revision 2.

Pursuant to 10 CFR 50.54(q) and 10 CFR 72.44(f), Duke Energy is submitting revision summaries for the Oconee Nuclear Station (ONS) Emergency Plan Annex (EP-ONS-EPLAN-ANNEX, Revision 1), EAL Technical Bases (CSD-EP-ONS-0101-01, Revision 3) and EAL Wallchart (CSD-EP-ONS-0101-02, Revision 2). The effective date for the changes is January 11, 2022.

EP-ONS-EPLAN-ANNEX, Duke Energy Oconee Emergency Plan Annex is the ONS specific compliment to the Duke Energy Common Emergency Plan. The Annex has been revised from Revision 0 to update the format, make editorial changes such as updating revision number, table of contents, page numbers, make changes to titles and words to make them current, and correct procedure references.

CSD-EP-ONS-0101-01 is the ONS EAL Technical Basis Document, and CSD-EP-ONS-0101-02 is the EAL Wallchart (both Hot and Cold) for ONS. These documents have been revised from revision 2 to include editorial changes such as updating revision number, table of contents, page numbers, and reference corrections. Communication system definitions in CU5.1 and SU7.1 have been updated to align with Common Emergency Plan communication methods.

In accordance with 10 CFR 50.54(q)(5), Attachment 1 includes a summary of analyses associated with the issuance of EP-ONS-EPLAN-ANNEX, Revision 1. Attachment 2 includes a summary of analyses associated with issuance of CSD-EP-ONS-0101- 01, Revision 3, and CSD-EP-ONS-0101-02, Revision 2.

This document contains no new regulatory commitments.

RA-22-0070 February 10, 2022 Page 2 If there are any questions or concerns pertaining to these revisions please call David Wilson, Manager Nuclear Support Services, at 864-873-3451.

Sincerely, Steven M. Snider Site Vice President Oconee Nuclear Station Attachments:

1. 10 CFR 50.54(q) - EP-ONS-EPLAN-ANNEX, Revision 1

2. 10 CFR 50.54(q) - CSD-EP-ONS-0101-01, EAL Technical Bases, Revision 003 and CSD-EP-ONS-0101-02, EAL Wallchart, Revision 002

RA-22-0070 February 10, 2022 Page 2 cc: Ms. Laura Dudes Administrator, USNRC Region II Marquis One Tower 245 Peachtree Center., NE Suite 1200 Atlanta GA 30303-1257 Ms. Shana Helton Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Shawn Williams Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Jared Nadel NRC Senior Resident Inspector Oconee Nuclear Station

ATTACHMENT 1 10 CFR 50.54(q) - EP-ONS-EPLAN-ANNEX, Revision 1

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

Rev. 8 ATTACHMENT 2 Page 1 of 12

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

Section I: 10 CFR 50.54(q) Review Number: (EREG #): 02407702 Applicable Sites and Applicability Determination # (5AD)

BNP CNS HNP MNS ONS 02407701 RNP Document #, EC #, or Revision # or N/A N/A Document or Activity Title EP-ONS-EPLAN-ANNEX Revision 1 Duke Energy Oconee Emergency Plan Annex 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 Duke Energy Oconee Emergency Plan Annex supplements the Duke Energy Common Emergency Plan by providing site-specific information unique to the site.

This document matches the structure of the Duke Energy Common Emergency Plan in following the format of NUREG-0654, Rev 2. It only contains the guidance elements that have site-specific information therefore the numbering may not always be sequential.

Changes include:

Procedure formatting changes to meet Duke Energy procedure standards.

Editorial changes such as updating revision number, table of contents, revision summary, page numbers, and correcting references.

Changes to titles and words in the procedure to match current titles and words.

Remove referenced documents that have been superseded.

Change Section or Current (Existing) Text Proposed (Change) Text

Step #

1 Cover Page NA Replaced with Duke Energy procedure compliant cover page.

2 Cover Page EP-ONS-EPLAN EP-ONS-EPLAN-ANNEX 3 Throughout Old revision number New revision number 4 Throughout Table of contents and old revision Updated table of contents verbiage as a summary. result of procedure changes, updated revision summary identifying the changes made from the procedure revision request, and page numbers as a result of the changes to the procedure.

5 TOC NA Formatted and updated page numbers.

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

Rev. 8 ATTACHMENT 2 Page 2 of 12

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

Change Section or Current (Existing) Text Proposed (Change) Text

Step #

6 Procedure NA Reformatted entire annex to comply with Formatting Duke Energy procedure standard formatting - numbering, page alignment, bulleting, hyperlinks, page headers, page footers.

7 Procedure NA Updated grammar issues found in review Formatting (added/removed spaces, semicolons, periods, and hyphens where needed; changed capitalization; deleted underlining).

8 Procedure NA Added standard number formatting Formatting throughout as well as paragraph formatting without changing content (e.g., bulleted regulatory references, added the word 'Section' to section headings, placing columnized information in tables).

9 Section A.4 Oconee Emergency Medical Service Removed from document.

10 Section B.1.a The ONS on-shift staffing analysis The ONS on-shift staffing analysis has report has been been 11 Section B.1.a Refer to CSD-EP-ONS-0603-02, Refer to EP-ONS-OSSA, Oconee Oconee Plant On-Shift Staffing On-Shift Staffing Analysis.

Analysis.

12 Section E.2 Detailed information on the FEMA Detailed information on the FEMA approved system used to alert and approved system used to alert and notify notify the general public is maintained in the general public is maintained in CSD-EP-ONS-0603-01, Oconee Plant EP-ONS-ANS, Oconee Alert and Alert and Notification System Design Notification System Design Report.

Report.

13 Section H.3.a The Duke Energy EOF is located The Duke Energy Common EOF is greater than 25 miles from the site. located greater than 25 miles from the site.

14 Section J.2 Evacuation routes and designated Evacuation routes and relocation areas relocation areas are identified in are shown in EP-ONS-ETE, Oconee CSD-EP-ONS-0603-03, Oconee Plant Evacuation Time Estimate.

Evacuation Time Estimate Study.

15 Section J.8.a The ONS site specific ETE report is The ONS site-specific ETE report is documented in CSD-EP-ONS-0603-03, documented in EP-ONS-ETE, Oconee Oconee Plant Evacuation Time Evacuation Time Estimate.

Estimate Study.

16 Table P.7-1, Plan Sections Implemented(1) Plan Sections Implemented 3rd column header and (1) All letters refer to Sub-Sections of Removed from document associated Plan Section II, Planning Standards footnote below and Elements the table

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

Rev. 8 ATTACHMENT 2 Page 3 of 12

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

Change Section or Current (Existing) Text Proposed (Change) Text

Step #

17 Table P.7-1 RP/0/A/1000/009 Removed as a reference.

Procedure for Site Assembly E, J 18 Table P.7-1 RP/0/A/1000/010 Removed as a reference.

Procedure for Emergency Evacuation/Relocation of Site Personnel E, J 19 Table P.7-1 RP/0/A/1000/018 Removed as a reference.

Core Damage Assessment D, I 20 Table P.7-1 TE-EP-ALL-0408 Removed as a reference.

Periodic Test of The Emergency Operations Facility DEMNET, ENS, and ETS F, H 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 EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 0 EP-ONS-EPLAN-ANNEX, Duke Energy Oconee Emergency Plan Annex Revision 0 Current Emergency Plan EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 1 EP-ONS-EPLAN-ANNEX, Duke Energy Oconee Emergency Plan Annex Revision 0 The differences in the approved and the current revision of the Duke Energy Common Emergency Plan and Oconee Sites Emergency Plan (EP-ONS-EPLAN-ANNEX) have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions.

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

Rev. 8 ATTACHMENT 2 Page 4 of 12

<< 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 Yes Emergency Plan? No

2. Do any elements of the proposed activity change an Initiating Condition (IC), Emergency Action Yes Level (EAL), associated EAL note or basis, including underlying calculation or basis? 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 Yes the public as described in the FEMA-approved Alert and Notification System Design Report? 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.

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<< 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?

10 CFR 50.54(q) Evaluation is not required.

Yes Identify bounding source document below and continue to Section XIV.

No Continue to Section VII.

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.

Partially 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.

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

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

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

None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to No 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 change(s) below are defined as editorial in accordance with AD-EP-ALL-0602, and do not change the intent of the emergency plan as written.

Proposed changes 1, 3-6, and 8 update procedure format to align with the standard Duke Energy Procedure Automated System (PAS) formatting. This includes updates on the cover page, document number, table of contents, and standard header to each page and updates the revision number, layout of document and the addition of some hyperlinks.

Proposed changes 2, 11, 14, and 15 update references to the procedures to the correct number and title. These changes do not change the intent or purpose of the procedural steps.

Proposed change 7 revises grammar mistakes in revision 0. Added/removed spaces, semicolons, periods, and hyphens where needed. Changed capitalization and deleted underlining from the document in places where appropriate. These changes do not change intent of the Emergency Plan Annex.

Proposed change 9 removes reference to an MOU for Oconee County Emergency Medical Service (EMS).

Oconee county does not provide Emergency "Medical Service" or EMS. Emergency Medical Service is provided by Prisma Health, details of which are located in the Oconee Memorial Hospital Letter of Agreement. Instead of Emergency Medical Service, the Oconee MOU was understood to have meant "Emergency Services", which is described in the MOU between Duke Energy and Oconee County. This MOU is being removed because there is an existing MOU between Duke Energy and Oconee County, and this MOU between Duke Energy and Oconee County Emergency Medical Service was a typographical error carried over into the new Oconee Emergency Plan and considered redundant. Oconee county has not provided Emergency Medical Service to Oconee county.

Emergency Medical Service has always been provided by the local hospital provider. There is no reduction in service provided in support of the emergency plan nor impact to response time related to this proposed change.

Proposed changes 10 and 12 revised to align with the titles of the documents the words are referring to without changing the intent or purpose of the statements.

Proposed change 13 updates the title of the EOF to be consistent with approved documents and procedures. This change does not change intent or purpose. The functions, roles, responsibilities and location remain unchanged for the EOF.

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

Proposed changes 17-20 remove procedures that have been superseded by fleet procedures. Fleet procedure AD-EP-ALL-0112, Site Assembly and Accountability superseded site procedures RP/0/A/1000/009, Procedure for Site Assembly, and RP/0/A/1000/010, Procedure for Emergency Evacuation/Relocation of Site Personnel. Fleet procedure AD-EP-PWR-0206, Core Damage Assessment During An Emergency, superseded site procedure RP/0/A/1000/018, Core Damage Assessment. Fleet procedure AD-EP-ALL-0407, Emergency Operations Facility Surveillance, superseded fleet procedure TE-EP-ALL-0408, Periodic Test of The Emergency Operations Facility DEMNET, ENS, and ETS.

Removing these procedures from the reference section, and updating referenced documents as needed, does not reduce the effectiveness of the Oconee Emergency Plan and does not change the intent of the Plan.

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<< 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.

The response organization has the staff to respond and to augment staff on a continuing basis (24-7 1b 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 The response organization has the staff to respond and to augment staff on a continuing basis (24-7 2b 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 A standard scheme of emergency classification and action levels is in use. (Requires V/V 4a (Attachment 5) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS Procedures for notification of State and local governmental agencies are capable of alerting them of 5a the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.

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

The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 5c 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 Systems are established for prompt communication among principal emergency response 6a organizations.

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

7 10 CFR 50.47(b)(7) Public Education and Information Emergency preparedness information is made available to the public on a periodic basis within the 7a 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.

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<< 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.

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

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

KI is available for implementation as a protective action recommendation in those jurisdictions that 10d 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 A drill and exercise program (including radiological, medical, health physics and other program areas) 14a is established.

Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, 14b 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.

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

16b 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.

Proposed change 16 is more than editorial, however does not impact any emergency planning function identified in Appendix E to Part 50-Emergency Planning and Preparedness for Production and Utilization Facilities.

Proposed change 16 removes a note that is not needed. Updating procedure format to align with PAS formatting added Section to each of the plan sections thus eliminating need to have a note stating letters refer to sub sections of plan. This change does not change intent of the Emergency Plan.

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<< 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.

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.

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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 Yes effectiveness)? 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?

Yes If No, reject the proposed change, or modify the proposed change and perform a new evaluation. No Continue to Section XIV for this evaluation.

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.

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<< 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): Preparer Signature: Date:

WR McIntyre See CAS See CAS Reviewer Name (Print): Reviewer Signature: Date:

Lee Jackson See CAS See CAS Approver Name (Print): Approver Signature: Date:

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

NA NA NA QA RECORD

ATTACHMENT 2 10 CFR 50.54(q) - CSD-EP-ONS-0101-01, EAL Technical Bases, Revision 003 and CSD-EP-ONS-0101-02, EAL Wallchart, Revision 002

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

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

Section I: 10 CFR 50.54(q) Review Number: (EREG #): 02406273 Applicable Sites and Applicability Determination # (5AD)

BNP CNS HNP MNS ONS 02406288 RNP Document #, EC #, or Revision # or N/A N/A Document or Activity Title CSD-EP-ONS-0101-01 003 Emergency Action Level Technical Bases CSD-EP-ONS-0101-02 002 EAL Wallchart (Both Hot and Cold)

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.

CSD-EP-ONS-0101-01 is the EAL technical bases document and CSD-EP-ONS-0101-02 is the EAL Wallcharts for ONS.

Changes include:

Editorial changes such as updating revision number, table of contents, revision summary, page numbers, and correcting references.

Update communication system definitions in CU5.1 and SU7.1 to align with Common Emergency Plan communication methods. No physical changes to the communications equipment were made.

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

Changes are for CSD-EP-ONS-0101-01 unless noted otherwise (bolded) in Section or Step # column:

Change Section or Step Change From Change to 1 Throughout Table of contents updates due to Updated revision summary identifying changes in the procedure, old revision the changes made from the procedure summary, page numbers. revision request, and page numbers as a result of the changes to the procedure.

2 Throughout Old revision number New revision number Change applicable to BOTH documents 3 Att. 1 EAL CU5.1 Change applicable to CSD-EP-ONS-0101-01 4 EAL Wallcharts CU5.1 Table C-5

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5 Att. 1 EAL Basis: Basis:

CU5.1 Basis Change Onsite, offsite and NRC Onsite, offsite and NRC communications applicable to communications include one or more of include one or more of the systems listed CSD-EP-ONS- the systems listed in Table in Table C-5 (ref. 1).

0101-01 C-5 (ref. 1).

1. Commercial phone service 1. Public Address (PA) System The PA System can broadcast a The Commercial phone service message via speakers located does not go through the site throughout the site. It is used to telephone system. notify site personnel of emergency declarations, provide additional

2. ONS site phone system means to notify the ERO, and The site phone system is generator facilitate on-site protective actions and battery backed with: for personnel.

Fiber-Optic to Charlotte GO

2. Onsite Radio System (65 lines)

Standard fixed and mobile Telephone line to Easley (6 transceivers that allow point-to-point circuits) communications onsite. Radios are an alternate means of Anderson (4 lines) communication between the CR, Six Mile (4 lines) TSC, and OSC.

Site Telephone System: 3. Duke Energy Emergency Inward and outward direct Management Network (DEMNET) dial available from the The DEMNET consists of Control Room, TSC, and equipment and circuits linking Duke OSC Energy nuclear sites with the offsite agencies involved in initial emergency notifications. This

3. EOF phone system system can quickly conference the offsite agencies for notifications. All The emergency communications CRs, the Alternate TSC and the systems at the Charlotte EOF are EOF have this system. DEMNET is designed to ensure the reliable, the primary means of timely flow of information between communication for the CR and EOF all parties having an emergency when contacting Offsite Response response role. Organizations (OROs).

4. Public Address (Paging) system

4. Private Branch Exchange (PBX)

The paging system provides paging A PBX is a full featured telephone and party line communications system that provides internal calling between stations located services for one or more locations.

throughout the plant. Inside and The PBX terminates commercial outside type wall and desk-mounted phone lines from a carrier (AT&T, stations are used to communicate Verizon, CenturyLink, etc.) to between roaming personnel and provide inbound and outbound fixed work locations. Plant-wide calling capabilities between Duke instructions are issued using the Energy and external parties. PBX paging feature. systems have a number of

5. Onsite radio system mechanisms which make them resistant to failure including,

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

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redundant power connections, The onsite radio system receives redundant network connections, emergency backup power from and server hardware installed in Keowee Hydro Units supporting geographically diverse locations.

communications with: Control Room PBX is the primary means of 1&2, 3, Fire Brigade, Chemistry, communication between the CR, Safety, Radiation Protection, TSC, OSC, and EOF.

Maintenance, Medical Emergency PBX is the alternate means of Response Team, and Hazardous communication for the CR and EOF Materials Response Team.

when contacting OROs.

6. DEMNET NRC Communications Links PBX is the primary means of DEMNET is the primary means of communication with the NRC.

offsite communication. This circuit Extensions designated for NRC allows intercommunication among communications are located in the the EOF, TSC, control room, CRs, TSCs, and EOF.

counties, and states. DEMNET operates as an internet based Telephones have been designated (VoIP) communications system with for the following NRC a satellite back-up. Should the communications:

internet transfer rate become slow

a. NRC Emergency Notification or unavailable, the DEMNET will System (ENS) - This automatically transfer to satellite communications line provides a mode.

communications link to the

7. NRC Emergency Telephone NRC Operations Center in System (ETS) Rockville, Maryland, and is used for initial notifications and The NRC uses a Duke Energy continuous communications in dedicated telephone line which a declared emergency.

allows direct telephone communications from the plant to b. NRC Health Physics Network NRC regional and national offices. (HPN) - This communications The Duke Energy communications line provides a communications line provides a link independent of link with the NRC to provide the local public telephone network. radiological information.

Telephones connected to this Normally available from the network are located in the Oconee TSC and the EOF.

Control Rooms, Technical Support

c. NRC Reactor Safety Center, and Emergency Operations Counterpart Link (RSCL) - This Facility and can be used to communications line provides a establish NRC Emergency communications link for the Notification System (ENS) and NRC to conduct internal NRC Health Physics Network (HPN) discussions on plant equipment capability.

conditions separate from the

8. Satellite Phone licensee.

Satellite Phones can be used for d. Protective Measures external communications. Counterpart Link (PMCL) - This communications line provides a communications link for the This EAL is the cold condition NRC to conduct internal NRC equivalent of the hot condition EAL discussions on radiological SU7.1. releases, meteorological

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conditions, and the need for This IC addresses a significant loss of protective actions.

on-site or offsite communications capabilities. While not a direct e. Management Counterpart Link challenge to plant or personnel safety, (MCPL) (Executive Bridge Line) this event warrants prompt notifications - This communications line to OROs and the NRC. provides a communications link for any NRC internal This IC should be assessed only when discussions between the NRC extraordinary means are being utilized Executive Team Director or to make communications possible (e.g.,

Executive Team members and use of non-plant, privately owned the NRC response team leader equipment, relaying of on-site or top-level licensee information via individuals or multiple management at the site.

radio transmission points, individuals being sent to offsite locations, etc.).

5. Business Line The first EAL condition addresses a A direct single telephone line (i.e.

total loss of the communications copper) from a carrier (AT&T, methods used in support of routine Verizon, CenturyLink, etc.) directly plant operations.

to an end point within the plant.

The second EAL condition addresses a These lines do not pass through total loss of the communications any other phone systems (i.e.

methods used to notify all OROs of an PBX).

emergency declaration. The OROs referred to here are the State EOC and The Business line is an alternate FEO, Pickens County LEC and EOC, means of communication for the CR and Oconee County LEC and EOC. when contacting OROs or NRC.

The third EAL addresses a total loss of the communications methods used to 6. Cellular Phones notify the NRC of an emergency Any mobile telephone (non-Duke declaration. Energy or Duke Energy provided) capable of sending and receiving phone calls through ground based cell sites.

Cellular phones are an alternate means of communication between the CR, TSC, and EOF.

Cellular phones are an alternate means of communication for the CR and EOF when contacting OROs.

Cellular phones are an alternate means of communication for the CR and TSC when contacting NRC.

Cellular phones are the primary means of communication for the CR and EOF when contacting Field Monitor Teams (FMTs)..

7. Satellite Phones

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Any mobile telephone capable of sending and receiving phone calls through orbiting satellites.

Satellite phones are an alternate means of communication between the CR, TSC, and EOF.

Satellite phones are an alternate means of communication for the CR and EOF when contacting OROs.

Satellite phones are an alternate means of communication for the CR and TSC when contacting NRC.

Satellite phones are an alternate means of communication for the CR and EOF when contacting FMTs.

This EAL is the cold condition equivalent of the hot condition EAL SU7.1.

This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to OROs and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g.,

use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.

The second EAL condition addresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are the State EOC, Pickens County LEC and EOC, and Oconee County LEC and EOC.

The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

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6 Att. 1 EAL CU5.1 Basis ONS Basis Reference(s): ONS Basis Reference(s):

References

1. ONS Emergency Plan, Section 7.2 1. EP-ALL-EPLAN, Duke Energy Change Communications Systems Common Emergency Plan, Section applicable to F Emergency Communications

2. NEI 99-01 CU5 CSD-EP-ONS-

2. NEI 99-01 CU5 0101-01 7 Att. 1 EAL SU7.1 Change applicable to CSD-EP-ONS-0101-01 8 EAL Wallcharts SU7.1 Table S-4

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9 Att. 1 EAL Basis: Basis:

SU7.1 Basis Change Onsite, offsite and NRC Onsite, offsite and NRC communications applicable to communications include one or more of include one or more of the systems listed CSD-EP-ONS- the systems listed in Table S-4 (ref. 1). in Table S-4 (ref. 1).

0101-01 1. Commercial phone service

1. Public Address (PA) System The Commercial phone service The PA System can broadcast a does not go through the site message via speakers located telephone system. throughout the site. It is used to notify site personnel of emergency

2. ONS site phone system declarations, provide additional The site phone system is generator means to notify the ERO, and and battery backed with: facilitate on-site protective actions for personnel.

Fiber-Optic to Charlotte GO (65 lines)

2. Onsite Radio System Telephone line to Easley (6 Standard fixed and mobile circuits) transceivers that allow point-to-point communications onsite.

Anderson (4 lines) Radios are an alternate means of Six Mile (4 lines) communication between the CR, TSC, and OSC.

Site Telephone System:

Inward and outward direct 3. Duke Energy Emergency dial available from the Management Network (DEMNET)

Control Room, TSC, and The DEMNET consists of OSC equipment and circuits linking Duke

3. EOF phone system Energy nuclear sites with the offsite agencies involved in initial The emergency communications emergency notifications. This systems at the Charlotte EOF are system can quickly conference the designed to ensure the reliable, offsite agencies for notifications.

timely flow of information between Both CRs, the Alternate TSC and all parties having an emergency the EOF have this system.

response role. DEMNET is the primary means of

4. Public Address (Paging) system communication for the CR and EOF when contacting Offsite Response The paging system provides paging Organizations (OROs).

and party line communications between stations located 4. Private Branch Exchange (PBX) throughout the plant. Inside and A PBX is a full featured telephone outside type wall and desk-mounted system that provides internal calling stations are used to communicate services for one or more locations.

between roaming personnel and The PBX terminates commercial fixed work locations. Plant-wide phone lines from a carrier (AT&T, instructions are issued using the Verizon, CenturyLink, etc.) to paging feature. provide inbound and outbound

5. Onsite radio system calling capabilities between Duke Energy and external parties. PBX The onsite radio system receives systems have a number of emergency backup power from mechanisms which make them Keowee Hydro Units supporting resistant to failure including,

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communications with: Control Room redundant power connections, 1&2, 3, Fire Brigade, Chemistry, redundant network connections, Safety, Radiation Protection, and server hardware installed in Maintenance, Medical Emergency geographically diverse locations.

Response Team, and Hazardous PBX is the primary means of Materials Response Team. communication between the CR, TSC, OSC, and EOF.

6. DEMNET PBX is the alternate means of DEMNET is the primary means of communication for the CR and EOF offsite communication. This circuit when contacting OROs.

allows intercommunication among NRC Communications Links the EOF, TSC, control room, PBX is the primary means of counties, and states. DEMNET communication with the NRC.

operates as an internet based Extensions designated for NRC (VoIP) communications system with communications are located in the a satellite back-up. Should the CRs, TSCs, and EOF.

internet transfer rate become slow Telephones have been designated or unavailable, the DEMNET will for the following NRC automatically transfer to satellite communications:

mode.

a. NRC Emergency Notification System (ENS) - This

7. NRC Emergency Telephone communications line provides a System (ETS) communications link to the The NRC uses a Duke Energy NRC Operations Center in dedicated telephone line which Rockville, Maryland, and is allows direct telephone used communications from the plant to for initial notifications and NRC regional and national offices. continuous communications in The Duke Energy communications a declared emergency.

line provides a link independent of

b. NRC Health Physics Network the local public telephone network.

(HPN) - This communications Telephones connected to this line provides a communications network are located in the Oconee link with the NRC to provide Control Rooms, TSC, and EOF and radiological information.

can be used to establish NRC Normally available from the Emergency Notification System TSC and the EOF.

(ENS) and Health Physics Network (HPN) capability. c. NRC Reactor Safety Counterpart Link (RSCL) - This

8. Satellite Phone communications line provides a Satellite Phones can be used for communications link for the external communications NRC to conduct internal NRC discussions on plant equipment conditions separate from the This EAL is the hot condition equivalent licensee.

of the cold condition EAL CU5.1.

d. Protective Measures This IC addresses a significant loss of Counterpart Link (PMCL) - This on-site or offsite communications communications line provides a capabilities. While not a direct communications link for the challenge to plant or personnel safety, NRC to conduct internal NRC discussions on radiological releases, meteorological

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this event warrants prompt notifications conditions, and the need for to OROs and the NRC. protective actions.

This IC should be assessed only when e. Management Counterpart Link extraordinary means are being utilized (MCPL) (Executive Bridge Line) to make communications possible (e.g., - This communications line use of non-plant, privately owned provides a communications link equipment, relaying of on-site for any NRC internal information via individuals or multiple discussions between the NRC radio transmission points, individuals Executive Team Director or being sent to offsite locations, etc.). Executive Team members and the NRC response team leader The first EAL condition addresses a or top-level licensee total loss of the communications management at the site.

methods used in support of routine plant operations.

5. Business Line The second EAL condition addresses a A direct single telephone line (i.e.

total loss of the communications copper) from a carrier (AT&T, methods used to notify all OROs of an Verizon, CenturyLink, etc.) directly emergency declaration. The OROs to an end point within the plant.

referred to here are the State EOC and FEO, Pickens County LEC and EOC, These lines do not pass through and Oconee County LEC and EOC. any other phone systems (i.e.

PBX).

The third EAL addresses a total loss of the communications methods used to The Business line is an alternate notify the NRC of an emergency means of communication for the CR declaration. when contacting OROs or NRC.

6. Cellular Phones Any mobile telephone (non-Duke Energy or Duke Energy provided) capable of sending and receiving phone calls through ground based cell sites.

Cellular phones are an alternate means of communication between the CR, TSC, and EOF.

Cellular phones are an alternate means of communication for the CR and EOF when contacting OROs.

Cellular phones are an alternate means of communication for the CR and TSC when contacting NRC.

Cellular phones are the primary means of communication for the CR and EOF when contacting Field Monitor Teams (FMTs).

7. Satellite Phones Any mobile telephone capable of

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sending and receiving phone calls through orbiting satellites.

Satellite phones are an alternate means of communication between the CR, TSC, and EOF.

Satellite phones are an alternate means of communication for the CR and EOF when contacting OROs.

Satellite phones are an alternate means of communication for the CR and TSC when contacting NRC.

Satellite phones are an alternate means of communication for the CR and EOF when contacting FMTs.

This EAL is the hot condition equivalent of the cold condition EAL CU5.1.

This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to OROs and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g.,

use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

The first EAL condition addresses a total loss of the communications methods used in support of routine plant operations.

The second EAL condition addresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are the State EOC, Pickens County LEC and EOC, and Oconee County LEC and EOC.

The third EAL addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

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10 Att. 1 EAL ONS Basis Reference(s): ONS Basis Reference(s):

SU7.1 Basis References 1. ONS Emergency Plan, Section 7.2 1. EP-ALL-EPLAN, Duke Energy Change Communications Systems Common Emergency Plan, Section applicable to 2. NEI 99-01 SU6 F Emergency Communications CSD-EP-ONS- 2. NEI 99-01 SU6 0101-01 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 EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Section D, Revision 0 EP-ONS-EPLAN-ANNEX, Duke Energy Oconee Emergency Plan Annex, Section D, Revision 0 Licensing Basis for NEI 99-01 Rev 6 EALS ONS: ML16109A093 Letter Dated May 26, 2016.

Subject:

Oconee Nuclear Station, Units 1, 2, and 3-Issuance of license amendments regarding Emergency Action Level scheme change (CAC NOS. MF6454, MF6455, AND MF6456) Amendment Nos. 399, 401, and 400 to Renewed Facility Operating License Nos.

DPR-38, DPR-47, and DPR-55, for the Oconee Station, Units 1, 2, and 3, respectively.

ML19058A632 Letter dated July 1, 2019.

Subject:

Oconee Nuclear Station, Units 1, 2, And 3; - Issuance of Amendments To Revise Emergency Action Level Schemes To Incorporate Clarifications Provided By Emergency Preparedness Frequently Asked Questions 2015-013, 2015-014, And 2016-002 (EPID L-2018-LLA-0174)

Amendment Nos. 412, 414, and 413 to Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55 for the Oconee Nuclear Station, Units 1, 2, and 3 (Oconee), respectively.

Current Emergency Plan EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Section D, Revision 1 EP-ONS-EPLAN-ANNEX, Duke Energy Oconee Emergency Plan Annex, Section D, Revision 1 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.

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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 Yes Emergency Plan? No

2. Do any elements of the proposed activity change an Initiating Condition (IC), Emergency Action Yes Level (EAL), associated EAL note or basis, including underlying calculation or basis? 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 Yes the public as described in the FEMA-approved Alert and Notification System Design Report? 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:

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Section VI: Activity Previously Reviewed?

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

10 CFR 50.54(q) Evaluation is not required.

Yes Identify bounding source document below and continue to Section XIV.

No Continue to Section VII.

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.

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

None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to No 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 change(s) below are defined as editorial in accordance with AD-EP-ALL-0602, and do not change the intent of the steps as written.

Changes 1 and 2 - Editorial because the changes update revision number and page numbers.

Changes 6, 10 - Editorial because it updates the reference from the document being superseded, the ONS Emergency Plan, Section 7.2 Communications Systems to the new Common Emergency Plan.

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