RA-23-0222, On-Shift Staffing Analysis (Ossa), Revision 1

On-Shift Staffing Analysis (Ossa), Revision 1

ML23235A314
Person / Time
Site:	Oconee
Issue date:	08/23/2023
From:	Denise Wilson Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RA-23-0222
Download: ML23235A314 (1)

Text

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~ ENERGY David A. Wilson Manager, Nuclear Support Services Oconee Nuclear Station Duke Energy ON01 SC 17800 Rochester Hwy RA-23-0222 Seneca, SC 29672 o: 864.873.3451 f: 864.873.5791 David.Wilson2@duke-energy.com August23,2023 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 On-Shift Staffing Analysis (OSSA), Revision 1 Pursuant to 10 CFR 50.54(q) and 10 CFR 72.44{f), Duke Energy is submitting the attached evaluation of changes to the Oconee Nuclear Station (ONS) Emergency Plan On-Shift Staffing Analysis (EP-ONS-OSSA, Revision 1). The effective date for the changes is July 26, 2023.

These changes have been evaluated in accordance with 10 CFR 50.54(q) and it was determined that the changes did not reduce the effectiveness of the ONS Emergency Plan .

If there are any questions or concerns pertaining to these revisions please call Samuel Adams, Oconee Regulatory Affairs, at 864-873-3348.

Sincerely, L57~tf~

David A Wilson Manager, Nuclear Support Services Oconee Nuclear Station Attachment 10CFR 50.54(q) Review Form -Oconee On-Shift Staffing Analysis, Revision 001

RA-23-0222 August 23, 2023 Page2 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

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

Rev. 8 Attachment 2 Page 1 of 15 10 CFR 50.54(q) Review Form 2434481 a

Ev~nt or aptiorl, orseries of actions that may rnsu It.in. change to the emergency plan or affectthe implemer1tation of the en,ergency plan (Use attachments or continue additional pages as necessary): Continue to Section Ill.

Activity/Changes:

This document provides the on shift staffing analysis regulatory basis and guidance, the staffing compliment used in the analysis, the events and tasks used during the analysis, applicable time motion studies and the analysis results for Oconee Nuclear Station.

Revision 1 of EP-ONS-OSSA, Oconee On-Shift Staffing Analysis is being rewritten to update position requirements for technical specifications, and the Fire Plan. The "SPOC Supervisor", which had no role in the OSSA, is being removed from the staffing analysis, as well as two fire brigade members are being deleted from the fire plan, necessitating the revision to the OSSA. Additional changes include position (e.g. RP Technician to RP Qualified Individual), procedure (e.g. RP/0/B/1000/001 to AD-EP-ALL-0101) changes to align to Emergency Plan terminology or superseded procedures.

Editorial changes made throughout the document include updating the revision number, revision summary, table of contents, correction of grammatical errors, use of Oconee specific nomenclature and updating scenarios and tables based off of new position names. Editorial changes are addressed in section VII.

Change 1 - Staffing tables in section 2.1, On-Shift Staffing Required by Technical Specification/ UFSAR, and section 2.2, On-Shift ERO Staffing Complement Used in the Analysis, and the list of on-shift personnel from section 3.4.1, were updated to reflect the current staffing listed in Oconee's Technical Specifications, FSAR, Fire Protection Program, and Emergency Plan. Some position names in section 2.2, On-Shift ERO Staffing Complement used in the Analysis were updated to align with the position name listed in the Emergency Plan. Table 3.4.1 also reflects the removal of SPOC Supervisor, SPOC Technician, Mechanical Technician #2, and the SPOC Security Guard was replaced with Security Officer (SO1) all of which are not part of the ERO staffing. A short section of "Additional Staffing Assumptions" was added after the table in section 2.2 to further clarify staffing listed in the tables. Notes below each of the tables were updated to clarify conditions for staffing some positions.

Change 2 - Updated section 3.2.11 to reflect the current status of protected service water (PSW).

Change 3 - Section 3.2.12 SAMG, updated site-specific nomenclature, "Oconee Severe Accident Guideline (OSAG)" with "Oconee Severe Accident Management Guideline (SAMG)". Removed 3.2.12.3) "TSC is ready to provide mitigation guidance". Placed specific Oconee procedures in the third paragraph to provide where the guidance comes from when SAMG conditions are met.

Change 4 - Section 3.5, Procedures Used for Event Task Analysis were updated to add procedures used in staffing analysis and to reflect current documents for events.

Change 5 - Updated Section 6, list of references to include all procedures utilized in the staffing analysis Change 6 - Attachment 1 - revised EP Drill Program Task Analysis Controlling Method revising identified objectives to the new objectives implemented Jan 1, 2023, and to identify the controlling method at the objective level versus

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

Rev. 9 Attachment 2 Page 2 of 15 10 CFR 50.54(q) Review Form the demonstration criteria level.

Change 7 - Attachment 2 - Analyzed scenarios were updated reflecting the changes made to the staffing tables, updated position names, procedures, steps and enclosures referenced during the analysis as well as additional information relating to the step being performed.

A copy of the OSSA with changes identified is in the Efolder of this assignment.

List all emergehcyplan sections that were reviewed for this activitybynumber.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 .continl!e 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 Plans:

• EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Rev 3

• EP-ONS-EPLAN-ANNEX, Duke Energy Oconee Emergency Plan Annex, Rev 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.

Do any ofthe elements of the proposed activity change information or intent contained in the Yes Emergency.Plan? No II

2. Do any elements of the proposed JlCtivity change the process or capability foralerting or notifying Yes the public as described in the FEMA-approved Alert and Notification System Design Report? No 11111

3. Do any elements of the proposed activity change the Evacuation Time Estimate results? Yes No 1111

4. Do any elements of the proposed activity change the on~Shift Staffing Analysis results? Yes 11111 No

5. Does the Proposed activity require a change tothe Emergency Plan Pmgraminatic Description? Yes

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

Rev. 9 Attachment 2 Page 3 of 15 The.quesUons in Sectioh1Vdo*notrepresentt he total of all conditions that may cau~e achange*toor.impadthe ability tomaintainJhe emergency plan. Originator a.nd rnviewer signatures in Section XIVdocument that a review of all elerr1entsof the proposed change havebeen considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.

1. Provide abrie.f cond~sion below that describes hpw the conditions, as described in the emergency plan, are maintained with this activity. * * *

2. Select the box 9~1owwhen the review completes all actions forall elernents of the activity and no 10CFR50.54 screening or evaluation is required forany element Continue to Section XIV.

I have completed a review of this activity inaccordance 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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10 CFR 50.54(q) Evaluation is not required.

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

Iii 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)

Rev. 9 Attachment 2 Page 4 of 15 AHP.ctivities/Changes identi.fiedin ~ection II are.editorial/typographicarchanges such as formatting, paragraph numbering, speHing, or punctm:;\tio9tt,at does not change intent None pf the Activities/Chahges listed in Secfion/1 are editorial/typographical changef Continue to Section VIII.*

II Some Activities/

Justification:

Editorial changes made throughout the document include updating the revision number, revision summary, table of contents, formatting resulting in the document aligning to the Duke Energy standard procedure layout, grammar changes and updating scenarios and tables based off of new position names.

Editorial changes to Table 2.1 updated the table to spell out the position names followed by the abbreviation of the position names. These changes are editorial and can be made because they are changes in title only, and no responsibilities or functions have changed as a result.

The following are considered editorial and can be made because these changes are considered typographical changes:

• Table of contents section 3.5 and the title of section 3.5 Capitalized "Used"

• Table of contents section 2.1 and the title of section 2.1 to update "FSAR" to UFSAR"

• Section 3.2.8 second paragraph changed "CNS" to "ONS"

• Section 3.2.9 first paragraph change "florescent" to "fluorescent" Updated the grammar in the paragraph of section 3.2 changing the reading of the sentence from reading " ... to determine whether they met required for analysis .... " to reading " ... to determine whether they met the requirements for analysis ... ". This change is considered editorial as it updates the grammar of the sentence to make sense.

There is no change in intent with this change.

Position names throughout the document were updated to reflect the correct nomenclature of positions listed in the Emergency Plan, and Technical Specifications. Positions affected include RP technician change to RP Qualified Individual, SPOC Security Guard to Security Officer, and Emergency Communicator to Shift Communicator.

Responsibilities and functions of these positions have not changed because of these position name changes.

Therefore, these changes are considered editorial.

Updated the following procedures throughout the document. These updates are considered editorial because these procedures were superseded by other procedures:

• RP/0/B/1000/001, Emergency Classification superseded by AD-EP-ALL-0101, Emergency Classification

• Oconee Severe Accident Guideline (OSAG) superseded by Oconee Severe Accident Management Guideline (SAMG)

• AP/0/A/1700/008, Loss of Control Room was not the correct procedure number as unit specificity for this procedure in not a "0". However, this procedure was superseded by AP/1,2/A/1700/050, Challenging Plant Fire, as the actions for evacuating the control room for a fire were broken out and put in this procedure.

The changes above are defined as editorial IAW AD-EP-ALL-0602. They do not change the intent of the document, cause a reduction in effectiveness, and do not require further evaluation.

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

Rev. 9 Attachment 2 Page 5 of 15 10 CFR 50.54(q) Review Form

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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 .* to CFR 50.47(b)(2) Onsite Ernergency Organization .*. ** *..* .*. . . *. ..*

• 2a Process ensures that on shift emergency response responsibilities are staffed and assigned Ill 2b The process for timely augmentation of onshift staff is established and maintained.

3 10CFR 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 . .

ClassificaUon System . *.* RS A standard scheme of emergency classification and action levels is in use. (Requires VN 4a (Attachment 3) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR50.47(b)(5) Notification Methods and Procedures RS Procedures for notification of State and local governmental agencies are capable of alerting them of Sa 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 Sb 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 Sc 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 CFR50.47(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.

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

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

Rev. 9 Attachment 2 Page 6 of 15 10 CFR 50.54(q) Review Form authorities.

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

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

11 1O.****. CFR 50.47(b) * ... * ... *.*

(11)

... .. ***Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.

12 10 CFR50.47(b)(12) Medical and:" Public*--- Health Support  ; . .*

12a Arrangements are made for medical services for contaminated, injured individuals.

13 10 CFRS0.47(b)(13) Recovery Planning and Post-Accident ..

• Operations 13a Plans for recovery and reentry are developed.

14 10 CFR50.47(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

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1111 If any Section VIII criteria are checked, *document the basis for conclusion below for any changes that are more th.an editorial, however not impacted by any of the identified criteria in Section VIII and continue the 50.54(q) Review in Section IX If no Section VII/criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document justification below for any changes that are more than editorial and continue to Section XIV.

Justification for changes that are more than editorial, however, not impacted by any of the identified criteria in Section VIII:

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

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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.

List affected Emergency Planning Standards, Functions, and Program Elements:

Planning Standard The regulation at 10 CFR 50.47(b)(2) states the following:

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 applicable emergency planning function identified for this planning standard:

(1) The process ensures that onshift emergency response responsibilities are staffed and assigned.

Applicable sections of Appendix E to 10 CFR Part 50 IV.A of Appendix E to 10 CFR Part 50 The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency.

IV.A.9 of Appendix E to 10 CFR Part 50 By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

Informing Criteria from NUREG-0654 The applicable program elements describe in NUREG-0654, Section 11.B state:

8.1.a - The site-specific emergency response organization (ERO) is developed. Note that while other site programs, such as operations, fire response, rescue and first aid, and security, may be controlled via other licensing documents, it is only when these personnel are assigned EP functions that they become part of this regulatory standard. Consideration is given to ensure that EP functions are not assigned to individuals who may have difficulties performing their EP function(s) simultaneously with their other assigned (non-EP) duties.

Appendix E to 10 CFR Part 50 requires licensees to perform an on-shift staffing analysis to ensure on-shift staff can support the EP functions assigned, as well as other assigned duties.

B.3 - A table is developed depicting the site-specific on-shift staffing plan, as well as the ERO staffing augmentation plan. Table B-1, "Emergency Response Organization (ERO) Staffing and Augmentation Plan,"

provides a model for licensees to consider.

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

Rev.9 Attachment 2 Page 8 of 15 10 CFR 50.54 Review Form

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If the en,ergency plan, modified c:lS propqsed, no longe("cbrnplieswithplanning standards in 10 CFR 50.47(b)and the r~quirements jn Appendix E to 10 CFR Part 50, then ensurethe change is rejected, modified, or pmcessed as an exemption requestunder10 CFR 50.12, SpecificExemptions,ratherth an under 10 CFR 50.54(q). Address each Planning Standard identified in Section IX Continue to Section XI.

Justification:

Change 1 - The changes for each table and staff listing are as follows:

The table for on-shift staffing required by Technical Specification/UFSAR, table in section 2.1, was revised to reflect the requirements in ONS Selected License Commitments (SLC) Section 16.13.1. SLC 16.13.1 is being revised causing the OSSA to be revised. The SLC is being updated for readability and to remove 2 members of maintenance from the ONS 10-person fire brigade, as well as update the position nomenclature within the table. The changes are as follows:

• The positions that were removed from the ONS SLC 16.13.1 include The SPOC (also referred to as the SPOC Technician, and MT1, MT2, IE1, IE2), and SPOC Supervisor is legacy nomenclature for shift maintenance team. The SPOC team did not have a role in the analysis, these individuals were designated by their position as MT1, MT2, IAET1, IAET2 and members of the fire brigade. The SPOC Supervisor was listed as a member of the fire brigade.

• Notes were revised to clarify position numbers under specific conditions that would require additional positions required per the SLC to ensure overall staffing when qualified personnel from multiple disciplines can perform the function.

• Previous notes relating to SPOC and SPOC Supervisor are no longer applicable with the implementation of the common emergency plan, as these positions are no longer required by the E-Plan.

• Additional editorial changes were made that were identified in section VII of this document.

Changes to table 2.1 does not affect emergency plan staffing or cause any of the functional areas or major tasks identified in the emergency plan to be unassigned. These changes reflect positions required by SLC and removed positions that were not required by the SLC. The Fire Protection program at ONS was revised to reduce the number of fire brigade members from 10 down to 8. As listed in Revision 1 of the OSSA, 4 members of the fire brigade come from operations, and 3 will come from either Mechanical Maintenance or l&E maintenance. The Fire Brigade leader is also from operations, however, can be from the AO or SRO ranks depending on shift staffing as noted. The fire Protection Program reduced the number of fire brigade members citing no further need of two (2) person attack teams. There will still be 2 attack teams, however those teams will only have 2 members per team. NFPA 805 states, in part, "3.4.1 On-Site Fire-Fighting Capability. All of the following requirements shall apply. (a) A fully staffed, trained, and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site. This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standards as applicable:" The revised compliment of fire brigade members continues to be trained and is greater than the required minimum number of 5 members. Fire Brigade member requirements are not specified in the Emergency Plan. These requirements are part or the Fire Protection Program. The changes in this table do not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement required by the ONS Emergency Plan is unaffected by these changes.

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

Rev.9 Attachment 2 Page 9 of 15 10 CFR 50.54(q) Review Form The previous revision of the OSSA required the SPOC supervisor to be onsite per the Emergency Plan to staff and manage the maintenance personnel of the ose. This is no longer required since the implementation of the Duke Energy Common Emergency Plan. Per the Duke Energy Common Emergency Plan ERO staffing Table B-1 required staffing to perform repairs is 1 Mechanical Maintenance, 2 l&E technicians, and 1 Maintenance Supervisor. These positions are required to be on-site within 75 minutes of a declared ALERT or higher classification and are not required to be on-site as part of the on-shift required ERO compliment.

The on-shift ERO staffing complement used in the analysis, table in section 2.2, was changed to align with table B-1 in EP-ALL-EPLAN, Duke Energy Common Emergency plan. The common EPLAN was implemented after the original Rev O of the staffing analysis. The Radiological Protection position nomenclature was changed from technician to qualified individual. All notes below table 2.2 were simply rearranged. No Changes were made to the wording of the notes. These changes to table 2.2 do not cause any of the major functional areas or major tasks identified in the emergency plan to be unassigned. These changes reflect positions required by Duke Energy Common Emergency Plan. The changes in this table does not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

The on-shift personnel and location listing located in section 3.4.1 was revised to remove personnel not required in the analysis or through other staffing requirements (i.e. tech specs, E-Plan, Fire Protection program, etc), and updated position names and locations. The changes are as follows:

• wee SRO - Emergency Communicator was revised to wee SRO/Shift Communicator (SC) to align with the position title of communicator with the Emergency Plan title. This is an editorial change identified in section VII of this review.

• wee SRO/AO - Fire Brigade Team Leader (FBTL) was revised to list the normal shift alignment of an Auxiliary Operator - Fire Brigade Team Leader (FBTL). The location of this position did not change.

• SPOe Supervisor - Fire Brigade (SPOC1) is being removed from the table. This fire brigade member is being removed from the ONS Fire Protection Plan. Removing this person does not decrease the number of fire brigade responders (now 8) below the required fire brigade staffing listed in NFPA 0805 (5) according to the ONS Fire Protection Program

• SPOC Technician (SPOC2) is being removed from the table. This fire brigade member is being removed from the ONS Fire Protection Plan. Removing this person does not decrease the number of fire brigade responders (now 8) below the required fire brigade staffing listed in NFPA 0805 (5) according to the ONS Fire Protection Program

• Mechanical Technician #2 (MT2) is being revised to "Additional Maintenance Individual (any discipline) (MNT1). This change is being made to reflect the required ERO response personnel per the Emergency Plan. The Emergency Plan requires 1 Mechanical Maintenance technician, and 2 l&E technicians. This revision identifies 1 "additional" maintenance technician can be from any discipline and is above and beyond the Emergency Plan requirements. This additional maintenance person is needed to support operations procedures, and not required by the Emergency Plan.

• Other nomenclature changes were made to this table that are considered editorial because they change the title only, but not the role, responsibility or function of the position.

These changes to table 3.4.1 do not cause any of the functional areas or major tasks identified in the Emergency Plan to be unassigned. The Emergency Plan does not require any Maintenance discipline to be on shift. The Emergency Plan requires these positions to be staffed no later than 75 minutes of a declared ALERT. The positions remain on shift to assist operations with actions in other operations procedures and support the ONS fire protection program. The changes to table 3.4.1 do not eliminate key positions identified in the Emergency Plan nor reassign the responsibilities of the eliminated positions to other key positions or ERO on shift member. The eliminated positions are a result of changes to the ONS fire protection plan where there is a reduction in staffing the fire attack team from 3 members each to 2 members per team. The changes in this table do not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

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

Rev.9 Attachment 2 Page 10 of 15 10 CFR 50.54(q) Review Form Change 2 - This change updates the status of the Protected Service Water (PSW) system. At the time of the previous revision writing and approval, PSW was not in-service, but being installed. The PSW system installation has been completed and is in operation. This change updates section 3.2.11 to reflect that operation. This change does not add any role, responsibility or function to any Emergency Plan on-shift ERO position. This change does not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

Change 3 - Replaced superseded site-specific procedure references and nomenclature with current procedures and documents. The change provides clarification to the user on the procedures or documents and the titles of them. The third entry condition for SAMG "TSC is ready to provide mitigation guidance" was removed, as this statement is already implied in the SAMG implementation strategy in the following paragraph. Removing this statement does not remove the TSC from supporting mitigating strategies. These changes do not reduce the amount of information available to the user and does not change the intent of the analysis of this event. The change does not affect Emergency Plan ERO on-shift staffing, therefore there is no reduction in effectiveness of the emergency plan.

Change 4 - The list of procedures in section 3.5 used for task analysis were revised and reordered due to revisions in operating procedures. Operating procedures used during the analysis not used in Rev O were added to Rev 1, as some steps in the scenarios were referred to generically and not previously included. This change does not add any role, responsibility or function to any Emergency Plan on-shift ERO position. This change does not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

Change 5 - The list of reference documents is being updated and reorganized because procedures were added or removed based on current procedures used in the scenarios. This change does not add any role, responsibility or function to any Emergency Plan on-shift ERO position, or unidentified actions in the scenarios. This change does not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

Change 6-The table in Attachment 1, NEI 10-05 Table 5 Controlling Method Correlation, is being revised under the EP Drill Program Task Analysis Controlling Method column to correct the objective considering EP Drill Program Objectives were recently revised and to identify the controlling method at the objective level versus the demonstration criteria level. Lower level, more specific demonstration criteria, can change over time. Removing this lower level and moving the controlling method to a higher, more general level, continues to meet the drill objectives listed in the demonstration criteria. Considering the objective level covers all demonstration criteria, there is no change of intent in the controlling methods. This change does not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

Change 7 - All scenarios in Attachment 2, NEI 10-05 Appendix B On-shift staffing analysis results table, were updated due to the changes made to the staffing tables listed in sections 2.1, and 3.4.1. Attachment 2 updated removed positions not required by the scenarios, position names, and the specific procedures referenced during the analysis. Combined, these changes in attachment 2 update scenarios for the staffing study. These changes do not cause any of the major functional areas or major tasks identified in the emergency plan to be unassigned.

The changes do not eliminate key positions identified in the Emergency Plan nor reassign the responsibilities of the eliminated positions to other key positions. The changes do not result in an ERO member being assigned duties that could be expected to be performed concurrently rather than sequentially. The changes in this section do not omit any of the accident sequences included in the staffing analysis submitted to the NRC, and therefore do not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

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

Rev.9 Attachment 2 Page 11 of 15 Justification:

Change 1 - The changes for each table and staff listing are as follows:

The table for on-shift staffing required by Technical Specification/UFSAR, table in section 2.1, was revised to reflect the requirements in ONS SLC Section 16.13.1. SLC 16.13.1 is being revised causing the OSSA to be revised. The SLC is being updated for readability and to remove 2 members of maintenance from the ONS 10-person fire brigade, as well as update the position nomenclature within the table. The changes are as follows:

• The positions that were removed from the ONS SLC 16.13.1 include The SPOC (also referred to as the SPOC Technician, and MT1, MT2, IE1, IE2), and SPOC Supervisor. The SPOC did not have a role in the analysis, in the analysis, these individuals were designated as MT1, MT2, IAET1, IAET2 and members of the fire brigade. The SPOC Supervisor was listed as a member of the fire brigade.

• Notes were revised to clarify position numbers under specific conditions that would require additional positions required per the SLC.

• Previous notes relating to SPOC and SPOC Supervisor are no longer applicable with the implementation of the common emergency plan as these positions are no longer delineated in the new E-Plan.

• Additional editorial changes were made that were identified in section VII of this document.

Changes to table 2.1 does not affect emergency plan staffing or cause any of the functional areas or major tasks identified in the emergency plan to be unassigned. These changes reflect positions required by SLC and removed positions that were not required by the SLC. The Fire Protection program at ONS was revised to reduce the number of fire brigade members from 10 down to 8. As listed in Revision 1 of the OSSA, 4 members of the fire brigade come from operations, and 3 will come from either Mechanical Maintenance or l&E maintenance. The Fire Brigade leader is also from operations, however, can be from the AO or SRO ranks depending on shift staffing as noted. The fire Protection Program reduced the number of fire brigade members citing no further need of two (2) person attack teams. There will still be 2 attack teams, however those teams will only have 2 members per team. NFPA 805 states, in part, "3.4.1 On-Site Fire-Fighting Capability. All of the following requirements shall apply. (a) A fully staffed, trained, and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site. This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standards as applicable:" The revised compliment of fire brigade members continues to be trained and is greater than the required minimum number of 5 members. Fire Brigade member requirements are not specified in the Emergency Plan. These requirements are part or the Fire Protection Program. The changes in this table do not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement required by the ONS Emergency Plan is unaffected by these changes.

The previous revision of the OSSA required the SPOC supervisor to be onsite per the Emergency Plan to staff and manage the maintenance personnel of the OSC. This is no longer required since the implementation of the Duke Energy Common Emergency Plan. Per the Duke Energy Common Emergency Plan ERO staffing Table B-1 required staffing to perform repairs is 1 Mechanical Maintenance, 2 l&E technicians, and 1 Maintenance Supervisor. These positions are required to be on-site within 75 minutes of a declared ALERT or higher and are not required to be on-site as part of the on-shift required ERO compliment.

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

Rev. 9 Attachment 2 Page 12 of 15 10 CFR 50.54(q) Review Form The on-shift ERO staffing complement used in the analysis, table in section 2.2, was changed to align with table B-1 in EP-ALL-EPLAN, Duke Energy Common Emergency plan. The common EPLAN was implemented after the original Rev O of the staffing analysis. The Radiological Protection position nomenclature was changed from technician to qualified individual. All notes below table 2.2 were simply rearranged. No Changes were made to the wording of the notes. These changes to table 2.2 do not cause any of the major functional areas or major tasks identified in the emergency plan to be unassigned. These changes reflect positions required by Duke Energy Common Emergency Plan. The changes in this table does not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

The on-shift personnel and location listing located in section 3.4.1 was revised to remove personnel not required in the analysis or through other staffing requirements, and updated position names and locations.

The changes are as follows:

• wee SRO - Emergency Communicator was revised to wee SRO/Shift Communicator (SC) to align with the position title of communicator with the Emergency Plan title. This is an editorial change identified in section VII of this review.

• WCC SRO/AO - Fire Brigade Team Leader (FBTL) was revised to list the normal shift alignment of an Auxiliary Operator - Fire Brigade Team Leader (FBTL). The location of this position did not change.

• SPOC Supervisor- Fire Brigade (SPOC1) is being removed from the table. This fire brigade member is being removed from the ONS Fire Protection Plan. Removing this person does not decrease the number of fire brigade responders (now 8) below the required fire brigade staffing listed in NFPA 0805 (5) according to the ONS Fire Protection Program

• SPOC Technician (SPOC2) is being removed from the table. This fire brigade member is being removed from the ONS Fire Protection Plan. Removing this person does not decrease the number of fire brigade responders (now 8) below the required fire brigade staffing listed in NFPA 0805 (5) according to the ONS Fire Protection Program

• Mechanical Technician #2 (MT2) is being revised to "Additional Maintenance Individual (any discipline) (MNT1). This change is being made to reflect the required ERO response personnel per the Emergency Plan. The Emergency Plan requires 1 Mechanical Maintenance technician, and 2 l&E technicians. This revision identifies 1 "additional" maintenance technician can be from any discipline and is above and beyond the Emergency Plan requirements. This additional maintenance person is needed to support operations procedures, and not required by the Emergency Plan.

• Other nomenclature changes were made to this table that are considered editorial because they change the title only, but not the role, responsibility or function of the position.

These changes to table 3.4.1 do not cause any of the functional areas or major tasks identified in the Emergency Plan to be unassigned. The Emergency Plan does not require any Maintenance discipline to be on shift. The Emergency Plan requires these positions to be staffed no later than 75 minutes of a declared ALERT. The positions remain on shift to assist operations with actions in other operations procedures and support the ONS fire protection program. The changes to table 3.4.1 do not eliminate key positions identified in the Emergency Plan nor reassign the responsibilities of the eliminated positions to other key positions or ERO on shift member. The eliminated positions are a result of changes to the ONS fire protection plan where there is a reduction in staffing the fire attack team from 3 members each to 2 members per team. The changes in this table do not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

Change 2 - This change updates the status of the Protected Service Water (PSW) system. At the time of the previous revision writing and approval, PSW was not in-service, but being installed. The PSW system installation has been completed and is in operation. This change updates section 3.2.11 to reflect that operation. This change does not add any role, responsibility or function to any Emergency Plan on-shift ERO position. This change does not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

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

Rev. 9 Attachment 2 Page 13 of 15 10 CFR 50.54(q) Review Form Change 3 - Replaced superseded site-specific procedure references and nomenclature with current procedures and documents. The change provides clarification to the user on the procedures or documents and the titles of them. The third entry condition for SAMG "TSC is ready to provide mitigation guidance" was removed, as this statement is already implied in the SAMG implementation strategy in the following paragraph. Removing this statement does not remove the TSC from supporting mitigating strategies. These changes do not reduce the amount of information available to the user and does not change the intent of the analysis of this event. The change does not affect Emergency Plan ERO on-shift staffing, therefore there is no reduction in effectiveness of the emergency plan.

Change 4 - The list of procedures in section 3.5 used for task analysis were revised and reordered due to revisions in operating procedures. Operating procedures used during the analysis not used in Rev O were added to Rev 1, as some steps in the scenarios were referred to generically and not previously included. This change does not add any role, responsibility or function to any Emergency Plan on-shift ERO position. This change does not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

Change 5 - The list of reference documents is being updated and reorganized because procedures were added or removed based on current procedures used in the scenarios. This change does not add any role, responsibility or function to any Emergency Plan on-shift ERO position, or unidentified actions in the scenarios. This change does not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

Change 6 - The table in Attachment 1, NEI 10-05 Table 5 Controlling Method Correlation, is being revised under the EP Drill Program Task Analysis Controlling Method column to correct the objective considering EP Drill Program Objectives were recently revised and to identify the controlling method at the objective level versus the demonstration criteria level. Lower level, more specific demonstration criteria, can change over time. Removing this lower level and moving the controlling method to a higher, more general level, continues to meet the drill objectives listed in the demonstration criteria. Considering the objective level covers all demonstration criteria, there is no change of intent in the controlling methods. This change does not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

Change 7 -All scenarios in Attachment 2, NEI 10-05 Appendix B On-shift staffing analysis results table, were updated due to the changes made to the staffing tables listed in sections 2.1, and 3.4.1. Attachment 2 updated removed positions not required by the scenarios, position names, and the specific procedures referenced during the analysis. Combined, these changes in attachment 2 update scenarios for the staffing study. These changes do not cause any of the major functional areas or major tasks identified in the emergency plan to be unassigned.

The changes do not eliminate key positions identified in the Emergency Plan nor reassign the responsibilities of the eliminated positions to other key positions. The changes do not result in an ERO member being assigned duties that could be expected to be performed concurrently rather than sequentially. The changes in this section do not omit any of the accident sequences included in the staffing analysis submitted to the NRC, and therefore do not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.

The proposed changes to Oconee's On Shift Staffing Analysis continue to show the capability of implementing the site's emergency plan to address a spectrum initiating events and consequences. The key emergency response functions and tasks as described in NUREG-0654 include:

• Shutdown the reactor and maintain safe shutdown

• Mitigate event consequences

• Notify augmented ERO staff and Offsite Response Organizations (OROs)

• Determine Protective Action Recommendations (PARs) for site personnel and the public

• Perform firefighting

• Provide medical assistance if needed The changes listed above do not change ERO staffing as set forth in EP-ALL-EPLAN, Duke Energy Common Emergency Plan as on-shift emergency response responsibilities are staffed and assigned. The changes do not

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

Rev. 9 Attachment 2 Page 14 of 15 10 CFR 50.54(q) Review Form reduce the availability of personnel relied upon in the plan. Therefore, the changes do not reduce the effectiveness of the Duke Energy Common Emergency Plan. These changes continue to provide assurance that the Emergency Response Organization has the ability and capability to:

• respond to an emergency;

• perform functions in a timely manner;

• effectively identify and take measures to ensure protection of the public health and safety; and

• effectively use response equipment and emergency response procedures.

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

1. Does the.proposed change comply with 10CFR 50.47(b) ancl 10 CFR 50 Appendix E? Yes 11111 No

2. [)oes the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in Yes 11111 effecUveness )? No

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

Questions 112 and3 are answered YES, completestep belowto create a General CAS assignment, 11111 and then continue on to Section X/Vand implement change(s).

General CAS assignment created - Licensing submit changes inaccordance with 10 CFR 11111 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XII/ and SectionXIV.

Will the proposed change be submitted to the NRC for prior approval?

Yes If No, reject the proposed change 1 or modify the pmposed 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.

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

Rev. 9 Attachment 2 Page 15 of 15 10 CFR 50.54 Review Form

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• Preparer Name (Print): Eric White Preparer Signature: See CAS Date:

SeeCAS Reviewer Name (Print): Lee Jackson Reviewer Signature: See GAS Date:

See CAS Approver Name (Print): David Wilson Approver Signature: See CAS Date:

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

QA RECORD