Text

10 CFR 50 .54(q) Evaluation
	ML24064A200
Person / Time
Site:	Harris
Issue date:	03/04/2024
From:	Gunter W; Duke Energy Progress
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	RA-24-0062
	Download: ML24064A200 (1)
	v • d • e

(_~ DUKE William Gunter Nuclear Support Services Manager ENERGY Harris Nuclear Plant 5413 Shearon Harris Road New Hill, NC 27562-9300

10 CFR 50.4(b)(5)(ii) 10 CFR 50.54(q)(5)

March 4, 2024 Serial : RA-24-0062

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63

Subject:

10 CFR 50.54(q) Evaluation

Ladies and Gentlemen:

In accordance with 10 CFR 50.4(b)(5)(ii) and 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is submitting the 10 CFR 50.54(q) Review Form for a revision to the Shearon Harris Nuclear Power Plant, Unit 1 (HNP), Emergency Action Level (EAL) Technical Basis Document. CSD-EP - HNP-0101 - 01, "EAL Technical Basis Document," Revision 5, was issued on February 22, 2024. A revision to a previous 10 CFR 50.54( q) Review Form completed for CSD - EP-HNP - 0101-01,

Revision 4, issued on December 12, 2023, which was submitted to the NRC on January 8, 2024 (reference Agencywide Documents Access and Management System (ADAMS) Accession number ML24009A106), and a revision to a previous 10 CFR 50.54(q) Review Fo rm completed for EP-HNP-OSSA, "Harris On-Shift Staffing Analysis, " Revision 1, issued on December 14, 2023, which was submitted to the NRC on January 4, 2024 (reference ADAMS Accession number ML24004A243), are included in this submittal.

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

Sincerely,

William Gunter

Enclosure:

10 CFR 50.54(q) Review Form for CSD-EP-HNP -0101-01, Revision 5 10 CFR 50.54(q) Review Form for CSD-EP-HNP-0101-01, Revision 4 10 CFR 50.54(q) Review Form for EP-HNP-OSSA, Revision 1

cc: P. Boguszewski, NRC Senior Resident Inspector, HNP M. Mahoney, NRC Project Manager, HNP NRC Regional Administrator, Region II Document Control Desk Serial: RA-24-0062 Enclosure

ENCLOSURE

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1

DOCKET NO. 50 -400/RENEWED LICENSE NUMBER NPF-63

10 CFR 50.54(q) REVIEW FORM FOR CSD-EP-HNP-0101- 01, REVISION 5

10 CFR 50.54(q) REVIEW FORM FOR CSD-EP-HNP-0101- 01, REVISION 4

10 CFR 50.54(q) REVIEW FORM FOR EP-HNP-OSSA, REVISION 1

(75 PAGES PLUS COVER)

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 1 of 10

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

Section I: 10 CFR 50.54(q) Review Number: (EREG #): I 02504297 Applicable Sites and Applicability Determination # (5AD)

BNP I I I I I CNS HNP 02504275

MNS I I I I I ONS RNP Document #, EC #, or Revision # or N/A N/A Document or Activity Title CSD-EP-HNP-0101- 01 005 EAL Technical Basis Document

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.

Activity/Changes:

CSD-EP-HNP-0101- 01, EAL Technical Basis Document, provides explanation and rationale for each Emergency Action Level (EAL) for the Harris Nuclear Plant (HNP).

Revision 005 corrects inadvertent changes to the document that were introduced during processing of Revision 004. These changes include:

Updating the revision summary and revision number.

Reinserting abbreviation definitions that were inadvertently deleted.

Removing an abbreviation definition that was inadvertently added.

Reinserting a HNP EAL to NEI 99-01, Rev 6, cross-reference that was inadvertently deleted.

Correcting bold formatting that was inadvertently added.

Correcting text box formatting that was partially obscuring the associated text.

Change Section or Step Change From Change to 1 Throughout Old revision summary. Updated revision summary identifying the changes made from the document revision request.

2 Throughout Old revision number (004) New revision number (005) 3 5.2 N/A Inserted:

1st column: "CHRRM" 2nd column: "Containment High Range Radiation Monitors" 4 5.2 N/A Inserted:

1st column: "HNP" 2nd column: "Harris Nuclear Plant" EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 2 of 10

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

Change Section or Step Change From Change to 5 5.2 N/A Inserted:

1st column: "RAB" 2nd column: "Reactor Auxiliary Building" 6 5.2 "RNP Deleted Robinson Nuclear Plant" 7 5.2 N/A Inserted:

1st column: "TIC" 2nd column: "Thermally Induced Current" 8 6.0, HNP to NEI N/A Inserted:

99- 01 Rev. 6 EAL column: "HU1.1" cross-reference IC column: "HU1" table Example EAL column: "1" 9 Att. 1, RA1.4 4. AD-EP-HNP-0106, HNP Site Specific 4. AD-EP-HNP-0106, HNP Site Specific Basis, OSC Support OSC Support Reference 4 (The word "Support" is in Bold font.) (The word "Support" is no longer bolded.

No text change.)

10 Att. 1, RS1.3 4. AD-EP-HNP-0106, HNP Site Specific 4. AD-EP-HNP-0106, HNP Site Specific Basis, OSC Support OSC Support Reference 4 (The word "Support" is in Bold font.) (The word "Support" is no longer bolded.

No text change.)

11 Att. 2, Fig. 1 In bottom right of figure, the text box The text box containing the words containing the words "Closed Cooling "Closed Cooling Water System" was Water System" was formatted so that reformatted so that all words are visible.

the words "Water System" were only No text change.

partially visible

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 for NEI 99- 01 Rev 6 EALs

Letter from U.S. Nuclear Regulatory Commission to Duke Energy, "Shearon Harris Nuclear Power Plant Unit 1 -

Issuance of Amendment [149] to Adopt Emergency Action Level Scheme Pursuant to NEI 99- 01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors," dated April 13, 2016 (ADAMS Accession No. ML16057A838).

License Amendment 149 was implemented in EP-EAL, Emergency Actions Levels, Revision 17.

Letter from U.S. Nuclear Regulatory Commission to Duke Energy, "Catawba Nuclear Station, Units 1 and 2; McGuire Nuclear Station, Units 1 and 2; Oconee Nuclear Station, Units 1, 2, and 3; Brunswick Steam Electric plant,

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 3 of 10

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

Units 1 and 2; Shearon Harris Nuclear Power Plant, Unit 1; and H.B. Robinson Steam Electric Plant, Unit No. 2 -

Issuance of Amendments [172 for HNP] 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)," dated July 1, 2019 (ADAMS Accession No. ML19058A632).

Letter from U.S. Nuclear Regulatory Commission to Duke Energy, "Shearon Harris Nuclear Power Plant Unit 1 -

Issuance of Amendment No. 173 Regarding Emergency Plan Emergency Action Level Scheme Change (EPID L-2018-LLA-0216)," dated July 18, 2019 (ADAMS Accession No. ML19108A173).

License Amendments 172 and 173 were implemented in EP-EAL, Emergency Actions Levels, Revision 20.

Current EALs

CSD-EP-HNP-0101- 01, EAL Technical Basis Document, Revision 004

Licensing Basis

EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 0

EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, Revision 0

Current Emergency Plan

EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Section D - Emergency Classification System

EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, Revision 1, Section D - Emergency Classification System

The differences in the approved and the current revision of the Emergency Plan and EALs 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. 9

ATTACHMENT 2 Page 4 of 10

<< 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 the process or capability for alerting or notifying Yes the public as described in the FEMA-approved Alert and Notification System Design Report? No

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

4. Do any elements of the proposed activity change the On-Shift Staffing Analysis results? Yes No

5. Does the Proposed activity require a change to the Emergency Plan Programmatic Description? Yes No

If Question 5 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 1-5 in Section IV marked NO, then complete Section V.

If any question 1-5 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).

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 5 of 10

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

Section VI: Activity Previously Reviewed?

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

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

Identify bounding source document below and continue to Section XIV.

No Continue to Section VII.

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.

Bounding source document and list of bounded changes:

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

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

Partially Some Activities/Changes are editorial/typographical.

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

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 proposed changes below are defined as editorial in accordance with AD-EP-ALL-0602, Emergency Plan Change Screening and Effectiveness Evaluations 10 CFR 50.54(Q), and do not change the intent of the guidance as written.

Proposed change 1 updates the revision summary. Updating the revision summary based on the new revision is editorial because it makes no changes to the intent of the guidance.

Proposed change 2 updates the revision number from 004 to 005 for the EAL Technical Basis Document. Updating the revision number is editorial because it makes no changes to the intent of the guidance.

Proposed changes 9 and 10 remove bold formatting that was inadvertently added during processing of Revision 004without making any changes to the text. Correcting formatting without changes to the text is editorial because it does not make any changes to the intent, purpose, or order of the guidance.

Proposed change 11corrects the formatting of a text box in the lower right of the image that was partially obscuring the associated text. No changes were made to the text contained in the text box. Correcting formatting without changes to the text is editorial because it does not make any changes to the intent, purpose, or order of the guidance.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 6 of 10

<< 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 bo x.

1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.

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

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

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

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

4 10 CFR 50.47(b)(4) Emergency Classification System RS 4a A standard scheme of emergency classification and action levels is in use. (Requires V/V (Attachment 3) 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.

5b Administrative and physical means have been established for alerting and providing prompt 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 6a Systems are established for prompt communication among principal emergency response organizations.

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

7 10 CFR 50.47(b)(7) Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ).

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

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

8b Adequate equipment is maintained to support emergency response.

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

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 7 of 10

<< 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.

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

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

11 10 CFR 50.47(b) (11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.

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

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

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

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

14c Identified weaknesses are corrected.

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

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

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

Section VIII: Conclusion

If any Section VIII criteria are checked, document the basis for conclusion below for any changes that are more than 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 VIIIcriteri a 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:

Proposed changes 3, 4, 5, and 7 reinsert abbreviation definitions that were inadvertently deleted during processing of Revision 004. These changes are more than editorial; however, these changes can be made because they do not change the intent of the guidance as written.

Proposed change 6 deletes an abbreviation definition that was inadvertently added during processing of Revision 004. This change is more than editorial; however, this change can be made because it does not change the intent of the guidance as written.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 8 of 10

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

Proposed change 8 reinserts the "HU1.1" HNP EAL to NEI 99- 01, Rev 6, cross-reference into the cross-reference table. This cross-reference was inadvertently deleted during processing of Revision 004. This change is more than editorial; however, this change can be made because it does not change the intent of the guidance.

The proposed changes above can be made because these changes return the document to its state prior to the processing errors introduced when implementing Revision 004. These changes do not affect the EAL scheme or affect the timeliness or accuracy of emergency declarations.

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.

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

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.

Justification:

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.

Justification:

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 a General CAS assignment, and then continue on to Section XIV and implement change(s).

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 9 of 10

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

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

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 10 of 10

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

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.

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:

David Bell See NAS See NAS Reviewer Name (Print): Reviewer Signature: Date:

Sarah McDaniel See NAS See NAS Approver Name (Print): Approver Signature: Date:

William Gunter See NAS See NAS Approver (EP CFAM, as required) Name (Print): Approver Signature: Date:

N/A N/A N/A

QA RECORD

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 1 of 42

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

Section I: 10 CFR 50.54(q) Review Number: (EREG #): 02490584 02504846 Applicable Sites and Applicability Determination # (5AD)

BNP I I I I I CNS HNP 02490554

MNS I I I I I ONS RNP Document #, EC #, or Revision # or N/A N/A Document or Activity Title CSD-EP-HNP-0101- 01 4 EAL Technical Basis Document

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.

This is a revised 50.54(q) review. Changes to the original 50.54(q) review can be identified by:

Additions to this revised 50.54(q) review will appear in Bold and Italicized format.

Deletions to this revised 50.54q) review will appear in struck through format.

CSD-EP-HNP-0101- 01 is the Emergency Action Level (EAL) technical basis document for Harris Nuclear Plant (HNP).

Changes include:

Updated revision summary and revision number.

Various reference updates and formatting changes.

Updated EAL SU5.1 basis definitions of Reactor Coolant System (RCS) leakage as a result of revised Technical Specifications (TSs) related to reactor coolant system operational leakage and the definition of the term "LEAKAGE" based on Technical Specifications Task Force (TSTF) Traveler TSTF -554, Revision 1, "Revise Reactor Coolant Leakage Requirements."

Change Section or Step Change From Change to 1 Throughout Old revision summary. Updated revision summary identifying the changes made from the document revision request.

2 Throughout CSD-EP-HNP-0101 Old revision CSD-EP-HNP-0101 New revision number (003) number (004) 3 Throughout Old page numbers and Table of Updated page numbers and Table of Contents Contents 4 Throughout PEP-110, Emergency Classification and AD-EP-ALL-0101, Emergency Protective Action Recommendations Classification, and AD-EP-ALL-0109, Offsite Protective Action Recommendations EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 2 of 42

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

Change Section or Step Change From Change to 5 Throughout Shearon Harris Nuclear Power Plant O/S Dose Calc Manual, Shearon Harris Offsite Dose Calculation Manual Nuclear Power Plant Off-site Dose (ODCM) Calculation Manual (ODCM) 6 Throughout EP-EALCALC-HNP-1401, HNP CSD-EP-HNP-0101-04, EAL Calculation Radiological Effluent EAL Values - Radiological Effluent EAL Values 7 Throughout AOP-20, Loss of RCS Inventory or AOP-020, Loss of RCS Inventory or Residual Heat Removal While Residual Heat Removal While Shutdown Shutdown

8 Throughout AOP-20, Loss of RCS Inventory or AOP-020-BD, Loss of RCS Inventory or Residual Heat Removal While Residual Heat Removal While Shutdown Shutdown - Basis Document 9 Throughout AOP-21, Seismic Disturbances AOP-021, Seismic Disturbances 10 Throughout PEP-342, Core Damage Assessment AD-EP-PWR-0206, Core Damage Assessment During An Emergency 11 Throughout AOP-16, Excessive Primary Plant AOP-016, Excessive Primary Plant Leakage Leakage 12 Throughout judgement judgment 13 Throughout OP-125, Hydrogen Monitoring System OP-125, Hydrogen Monitoring System (HSM) (HMS) 14 Throughout Old formatting throughout document Updated formatting throughout document in accordance with AD-DC-ALL-0301, Development and Maintenance of Controlled Supporting Documents. Changes include:

Changing outline and substep bullets from "A.", "B", "C", to "1.", "2.", "3."

Placing periods "." after step numbers

Bolding step numbers

Adding section continuation headers

Removing underline from substep numbers

Reformatting attachment titles so that they are below the attachment number

Reformatting fonts

(Formatting changes only. No change to text)

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 3 of 42

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

Change Section or Step Change From Change to 15 2.6, Operating 1 Power Operations (Reformatted into table format only. No Mode definitions Keff 0.99 and reactor thermal power > change to text.)

5% and average coolant temperature 350ºF 1 P~rQ~tiQfJS; Keff ~ 0. 99 and reactor thermal power >5% and average coolant temperature 2 Startup ~ 350° f 2 ~

Keff 0.99 and reactor thermal power Ken :2!: 0.99 and reactor thermal power :S: 5% average COOiant temperature 5% average coolant temperature ~350° F 3 Hot standby 350ºF Ken < 0.99 and average coolant temperature~ 35QOF 3 Hot Standby 4 Hot Shutdown K~ < 0.99 and average coolant temperature 350°F > T avg > 200°F (exduding Keff < 0.99 and average coolant decay hea l) 5 ~

temperature 350ºF Keff < 0.99 and average coolant temperat ure Tavg :S: 200"F 4 Hot Shutdown 6 Refueling Ken < 0.95 and average coolant temperature T -a s 140°F; fuel in the reactor Keff < 0.99 and average coolant vessel wittl tne vessel head closure bolts less tnan flllly tenSioned or with the head removed temperature 350ºF > Tavg > 200 ºF D Defueled (excluding decay heat) All reactor fuel removed from reactor pressure vessel (full core off load during refUeling or extended outage) 5 Cold Shutdown Keff < 0.99 and average coolant temperature Tavg 200ºF 6 Refueling Keff < 0.95 and average coolant temperature Tavg 140°F; fuel in the reactor vessel with the vessel head closure bolts less than fully tensioned or with the head removed D Defueled All reactor fuel removed from reactor pressure vessel (full core off load during refueling or extended outage) 16 4.1.9 4.1.9 PRO-NGGC-0201, NGG 4.1.9 AD-DC-ALL-0202, Writer's Manual Procedure Writer's Guide for Procedures and Work Instructions 17 4.2 4.2.1 PEP-110, Emergency 4.2.1 AD-EP-ALL-0101, Emergency Classification and Protective Action Classification Recommendations 4.2.2 AD-EP-ALL-0109, Offsite 4.2.2 NEI 99- 01 Rev. 6 to HNP EAL Protective Action Recommendations Comparison Matrix 4.2.3 NEI 99- 01 Rev. 6 to HNP EAL 4.2.3 HNP EAL Matrix Comparison Matrix 4.2.4 HNP EAL Matrix 18 5.1 See Enclosure 1 (Numbered Definitions only. No change to text.)

See Enclosure 2 19 5.2 See Enclosure 3 (Reformatted Abbreviations/Acronyms to table format only. No change to text.) --

See Enclosure 4 EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

ATTACHMENT 2 Page 4 of 42

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

Change Section or Step Change From Change to 20 7.0 7.1 Attachment 1, Emergency Action Attachment 1, EAL Bases Level Technical Bases Attachment 2, Fission Product Barrier 7.2 Attachment 2, Fission Product Loss/Potential Loss Matrix and Bases Barrier Matrix and Basis Attachment 3, Safe Operation &

7.3 Attachment 3, Safe Operation & Shutdown Room/Areas Tables R-3/H-2 Shutdown Areas Tables R-3/H-2 Bases Bases 21 Att. 1, RA1.4 PEP-270, Activation and Operation of AD-EP-ALL-0103, Activation and Basis, the Emergency Operations Facility and Operation of the Emergency Operations Paragraph 1 PEP-330, Radiological Consequences Facility, AD-EP-ALL-0204, Distribution of provide guidance for emergency or Potassium Iodide Tablets in the Event of Att. 1, RS1.3 post-accident radiological a Radioiodine Release, AD-EP-ALL-Basis, environmental monitoring (ref. 1, 2). 0205, Emergency Exposure Controls, Paragraph 1 AD-EP-HNP-0106, HNP Site-Specific OSC Support, AD-EP-HNP-0203, HNP Att. 1, RG1.3 Site-Specific Field Monitoring, AD-RP-Basis, ALL-2000, Preparation and Management Paragraph 1 of Radiation Work Permits (RWP), and AD-RP-ALL-4010, Internal Dose Assessment provides guidance for emergency or post-accident radiological environmental monitoring (ref. 1 - 7).

22 Att. 1, RA1.4 1. PEP-270, Activation and Operation of 1. AD-EP-ALL-0103, Activation and Basis the Emergency Operations Facility Operation of the Emergency Operations Reference(s) 2. PEP-330, Radiological Facility Consequences 2. AD-EP-ALL-0204, Distribution of

3. NEI 99- 01 AA1 Potassium Iodide Tablets in the Event of a Radioiodine Release,

3. AD-EP-ALL-0205, Emergency Exposure Controls

4. AD-EP-HNP-0106, HNP Site-Specific OSC Support

5. AD-EP-HNP-0203, HNP Site-Specific Field Monitoring

6. AD-RP-ALL-2000, Preparation and Management of Radiation Work Permits (RWP)

7. AD-RP-ALL-4010, Internal Dose Assessment

8. NEI 99-01 AA1 EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

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Change Section or Step Change From Change to 23 Att. 1, RS1.3 1. PEP-270, Activation and Operation of 1. AD-EP-ALL-0103, Activation and Basis the Emergency Operations Facility Operation of the Emergency Operations Reference(s) 2. PEP-330, Radiological Facility Consequences 2. AD-EP-ALL-0204, Distribution of

3. NEI 99- 01 AS1 Potassium Iodide Tablets in the Event of a Radioiodine Release,

3. AD-EP-ALL-0205, Emergency Exposure Controls

4. AD-EP-HNP-0106, HNP Site-Specific OSC Support

5. AD-EP-HNP-0203, HNP Site-Specific Field Monitoring

6. AD-RP-ALL-2000, Preparation and Management of Radiation Work Permits (RWP)

7. AD-RP-ALL-4010, Internal Dose Assessment

8. NEI 99-01 AS1 24 Att. 1, RG1.3 1. PEP-270, Activation and Operation of 1. AD-EP-ALL-0103, Activation and Basis the Emergency Operations Facility Operation of the Emergency Operations Reference(s) 2. PEP-330, Radiological Facility Consequences 2. AD-EP-ALL-0204, Distribution of

3. NEI 99- 01 AG1 Potassium Iodide Tablets in the Event of a Radioiodine Release,

3. AD-EP-ALL-0205, Emergency Exposure Controls

4. AD-EP-HNP-0106, HNP Site-Specific OSC Support

5. AD-EP-HNP-0203, HNP Site-Specific Field Monitoring

6. AD-RP-ALL-2000, Preparation and Management of Radiation Work Permits (RWP)

7. AD-RP-ALL-4010, Internal Dose Assessment

8. NEI 99-01 AG1 EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

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

Change Section or Step Change From Change to 25 Att. 1, SU5.1 Identified Leakage: Identified Leakage:

Basis, a. Leakage (except controlled leakage) a. Leakage, such as that from pump Paragraph 2 into closed systems, such as pump seal seals or valve packing (except controlled or valve packing leaks that are captured leakage), that is captured and conducted and conducted to a sump or collecting to a sump or collecting tank, or tank, or b. Leakage into the containment

b. Leakage into the containment atmosphere from sources that are both atmosphere from sources that are both specifically located and known to not specifically located or known either not interfere with the operation of leakage to interfere with the operation of detection systems, or leakage detection systems or not to be c. RCS leakage through a steam pressure boundary leakage, or generator to the Secondary Coolant

c. RCS leakage through a steam System (primary-to-secondary leakage).

generator to the Secondary Coolant Unidentified Leakage:

System (primary-to-secondary leakage). All leakage which is not identified Unidentified Leakage: leakage or controlled leakage.

All leakage which is not identified (Controlled leakage is that seal water Leakage or controlled leakage. flow supplied to the reactor coolant (Controlled leakage is that seal water pump seals.)

flow supplied to the reactor coolant Pressure Boundary Leakage:

pump seals.) Leakage (except primary-to-secondary Pressure Boundary Leakage: leakage) through a fault in a RCS Leakage (except primary-to-secondary component body, pipe wall, or vessel leakage) through a non-isolable fault inwall. Leakage past seals, packing, and a RCS component body, pipe wall, or gaskets is not pressure boundary vessel wall. leakage.

26 Att. 1, SU5.1 The first and second EAL conditions are The first and second EAL conditions are Basis, focused on a loss of mass from the focused on a loss of mass from the RCS Paragraph 6 RCS due to "unidentified leakage", due to "unidentified leakage", "pressure "pressure boundary leakage" or boundary leakage" or "identified "identified leakage" (as these leakage leakage" (as these leakage types are types are defined in the plant Technical defined in the plant Technical Specifications). The third condition Specifications). The third condition addresses an RCS mass loss caused addresses an RCS mass loss caused by by an UNISOLABLE leak through an a leak through an interfacing system.

interfacing system. These conditions These conditions thus apply to leakage thus apply to leakage into the into the containment, a secondary-side containment, a secondary-side system system (e.g., steam generator tube (e.g., steam generator tube leakage) or leakage) or a location outside of a location outside of containment. containment.

27 5.2 AP 1st column: "AOP"

................................................................2nd column: "Abnormal Operating

.................... Abnormal Operating Procedure" Procedure 28 5.2 CHRRM Deleted Containment High Range Radiation Monitors EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

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Change Section or Step Change From Change to 29 5.2 HNP Deleted

................................... Harris Nuclear Plant 30 5.2 RAB Deleted

.......................... Reactor Auxiliary Building 31 5.2 N/A Added:

1st column: "RNP" 2nd column: "Robinson Nuclear Plant" 32 5.2 N/A Added:

1st column: "RPV" 2nd column: "Reactor Pressure Vessel" 33 5.2 TIC Deleted

........................... Thermally Induced Current 34 6.0 EAL column: "HU1.1" Deleted IC column: "HU1" Example EAL column: "1"

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

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

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 for NEI 99 -01 Rev 6 EALs

Letter from U.S. Nuclear Regulatory Commission to Duke Energy, "Shearon Harris Nuclear Power Plant Unit 1 -

Issuance of Amendment [149] to Adopt Emergency Action Level Scheme Pursuant to NEI 99- 01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors," dated April 13, 2016 (ADAMS Accession No. ML16057A838).

License Amendment 149 was implemented in EP-EAL, Emergency Actions Levels, Revision 17.

Letter from U.S. Nuclear Regulatory Commission to Duke Energy, "Catawba Nuclear Station, Units 1 and 2; McGuire Nuclear Station, Units 1 and 2; Oconee Nuclear Station, Units 1, 2, and 3; Brunswick Steam Electric plant, Units 1 and 2; Shearon Harris Nuclear Power Plant, Unit 1; and H.B. Robinson Steam Electric Plant, Unit No. 2 -

Issuance of Amendments [172 for HNP] 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)," dated July 1, 2019 (ADAMS Accession No. ML19058A632).

Letter from U.S. Nuclear Regulatory Commission to Duke Energy, "Shearon Harris Nuclear Power Plant Unit 1 -

Issuance of Amendment No. 173 Regarding Emergency Plan Emergency Action Level Scheme Change (EPID L-2018-LLA-0216)," dated July 18, 2019 (ADAMS Accession No. ML19108A173).

License Amendments 172 and 173 were implemented in EP-EAL, Emergency Actions Levels, Revision 20.

Current EALs

Harris Nuclear Plant EAL Technical Basis Document, CSD-EP-HNP-0101- 01, Revision 003

Licensing Basis

EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 0

EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, Revision 0

Current Emergency Plan

EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Section D - Emergency Classification System

EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, Revision 1, Section D - Emergency Classification System

The differences in the approved and the current revision of the Emergency Plan and EALs 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. 9

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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 the process or capability for alerting or notifying Yes the public as described in the FEMA-approved Alert and Notification System Design Report? No

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

4. Do any elements of the proposed activity change the On-Shift Staffing Analysis results? Yes No

5. Does the Proposed activity require a change to the Emergency Plan Programmatic Description? Yes No

If Question 5 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 1-5 in Section IV marked NO, then complete Section V.

If any question 1-5 of Section IV marked yes, then continue at Section VI.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

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Section V: Maintaining the Emergency Plan Conclusion.

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

1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.

2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.

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

Conclusion:

Section VI: Activity Previously Reviewed?

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

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

Identify bounding source document below and continue to Section XIV.

No Continue to Section VII.

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

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

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

Partially Some Activities/Changes are editorial/typographical.

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

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 proposed changes below are defined as editorial in accordance with AD-EP-ALL-0602, Emergency Plan Change Screening and Effectiveness Evaluations 10 CFR 50.54(Q), and do not change the intent of the steps as written.

Proposed change 1 updates revision summary. Updating revision summary based on revision is editorial because it makes no changes to intent of the guidance.

Proposed change 2 updates revision number from 3 to 4 for EAL Technical Basis Document. Updating revision number is editorial because it makes no changes to intent of the guidance.

Proposed change 3 updates page numbers and the Table of Contents. Updating page numbers and the Table of Contents is editorial because it makes no changes to intent of the guidance.

Proposed changes 4 - 11, 16, 17, and 21 - 24 update references to procedures and correct references that are no longer applicable. Updating references to procedures and correcting references that are no longer applicable is editorial because it makes no changes to intent of the guidance.

Proposed change 12 corrects a misspelled word. Correcting misspelled words is editorial because it makes no changes to intent of the guidance.

Proposed change 13 corrects a typographical error in the system abbreviation. Correcting typographical errors is editorial because it makes no changes to intent of the guidance.

Proposed changes 14, 15, 18, and 19 are formatting changes only to comply with the guidance of AD-DC-ALL- 0301, Development and Maintenance of Controlled Supporting Documents. These changes include:

Changing outline and substep bullets from "A.", "B", "C", to "1.", "2.", "3."

Adding numbering to Definitions

Reformatting items into table-style format

Placing periods "." after step numbers

Bolding step numbers

Adding section continuation headers

Removing underline from substep numbers

Reformatting attachment titles so that they are below the attachment number

Reformatting fonts EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

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These changes make no change to intent, purpose, or order of the document steps. These formatting changes are editorial because there is no change to intent, purpose, or order of the document steps.

Proposed change 20 corrects the titles of Attachments 1, 2, and 3 to correspond to the titles used for these items in CSD-EP-ALL-0101- 02, EAL Wallchart (Both Hot and Cold). Correcting references to steps, pages, attachments, forms, documents, tables, exhibits, and procedures is editorial because it makes no changes to intent of the guidance.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. 9

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

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

1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.

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

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