RA-22-0214, 10 CFR 50.54(Q) Review Form for Revisions to the Shearon Harris Nuclear Power Plant, Unit 1, Emergency Action Level (EAL) Technical Basis Document and the EAL Wallchart Document

10 CFR 50.54(Q) Review Form for Revisions to the Shearon Harris Nuclear Power Plant, Unit 1, Emergency Action Level (EAL) Technical Basis Document and the EAL Wallchart Document

ML22193A318
Person / Time
Site:	Harris
Issue date:	07/12/2022
From:	Sharlow J Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-22-0214 AD-EP-ALL-0602, Rev 9
Download: ML22193A318 (34)

Text

(_~ DUKE Jamey Sharlow Acting 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)

July Jl, 2022 Serial: RA-22-0214 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 revisions to the Shearon Harris Nuclear Power Plant, Unit 1, Emergency Action Level (EAL) Technical Basis Document and the EAL Wallchart Document. CSD-EP-HNP-0101 -01, "EAL Technical Basis Document," Revision 3, and CSD-EP-HNP-0101-02, "EAL Wallchart (Both Hot and Cold) ," Revision 2, were issued on June 16, 2022.

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

75{)

Jamey Sharlow

Enclosure:

10 CFR 50.54(q) Review Form for CSD-EP-HNP-0101-01, Revision 3, and CSD-EP-HNP-0101-02, Revision 2 cc: C. Smith, NRG Senior Resident Inspector, HNP M. Mahoney, NRC Project Manager, HNP NRC Regional Administrator, Region II

Document Control Desk Serial: RA-22-0214 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 3, AND CSD-EP-HNP-0101-02, REVISION 2 (32 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 32

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

Section I: 10 CFR 50.54(q) Review Number: (EREG #): 2384809 Applicable Sites and Applicability Determination # (5AD)

BNP CNS HNP 2397188, 2397201, 2402279 MNS ONS RNP Document #, EC #, or Revision # or N/A N/A Document or Activity Title CSD-EP-HNP-0101-01 Revision 3 EAL [Emergency Action Level] Technical Basis Document CSD-EP-HNP-0101-02 Revision 2 EAL Wallchart (Both Hot and Cold)

Section II: Identify/Describe All Proposed Activities/Changes being Reviewed Event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan (Use attachments, or continue additional pages as necessary): Continue to Section III.

Activity/Changes:

CSD-EP-HNP-0101-01, EAL Technical Basis Document, is the EAL technical basis document for Harris and CSD-EP-HNP-0101-02, EAL Wallchart (Both Hot and Cold), is the EAL Wallchart for Harris Nuclear Plant (HNP). This proposed change incorporates several Document Revision Requests (DRRs), with changes detailed below. Major changes proposed include the following.

• The reference to the Residual Heat Removal (RHR) pump area, Reactor Auxiliary Building (RAB) 190, was removed from Table R-3/H-2, Safe Operation & Shutdown Rooms/Areas. This table listed the area as one in which operators need to physically access for normal shutdowns in Mode 4. Also, the Boric Acid Injection Tank (BIT) area, RAB 216, is no longer listed as an area requiring operator access for normal shutdowns in Modes 5 and 6. Operations review identified these areas as not requiring access by personnel during normal plant shutdowns.

• The EAL basis for CA3.1, used to declare events that cause unplanned RCS pressure increases while in Cold Shutdown, included the RCS wide range instruments as the recommended instrumentation for verifying a greater than 10 psig pressure increase occurred. The proposed change will list narrow range instruments instead, as these are more suitable for declaring an increase in RCS pressure of more than 10 psig.

• EAL SU8.1 is used to declare an event where an actual containment isolation signal was received and containment was not properly isolated. The proposed change clarifies potential confusion concerning receipt of a Main Steam Line Isolation signal.

• Numerous other more minor or editorial changes are also being made. Each change is detailed in the table below.

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

Rev. 9 ATTACHMENT 2 Page 2 of 32

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

1. Document, Current (Existing) Text Proposed (Change) Text Section, Reference 1 CSD-EP-HNP-0101-01, Rev. 002 Rev. 003 Footer 2 CSD-EP-HNP-0101-01, Page numbers changed based on Table of Contents updated.

Table of Contents changes as documented below.

3 CSD-EP-HNP-0101-02, Rev. 001 Rev. 002 Footer 4 CSD-EP-HNP-0101-01, Minimum bus voltage is 105 VDC (ref. Minimum bus voltage is 105 VDC (ref.

EAL Basis SG1.2 (Page 7, 9). 7, 8).

149) 5 CSD-EP-HNP-0101-01, 1 Power Operations 1 Power Operations Section 2.6 Keff 0.99 and reactor thermal Keff 0.99 and reactor thermal (Page 13) power > 5% and average coolant power > 5% and average coolant temperature 350ºF temperature 350ºF 2 Startup 2 Startup Keff 0.99 and reactor thermal Keff 0.99 and reactor thermal power 5% average coolant power 5% average coolant temperature 350ºF temperature 350ºF 3 Hot Standby 3 Hot Standby Keff < 0.99 and average coolant Keff < 0.99 and average coolant temperature 350ºF temperature 350ºF 3 Hot Shutdown 4 Hot Shutdown Keff < 0.99 and average coolant Keff < 0.99 and average coolant temperature 350ºF > Tavg > 200 temperature 350ºF > Tavg > 200 ºF

ºF (excluding decay heat) (excluding decay heat) 4 Cold Shutdown 5 Cold Shutdown Keff < 0.99 and average coolant Keff < 0.99 and average coolant temperature Tavg 200ºF temperature Tavg 200ºF 5 Refueling 6 Refueling Keff < 0.95 and average coolant Keff < 0.95 and average coolant temperature Tavg 140°F; fuel in temperature Tavg 140°F; fuel in the reactor vessel with the vessel the reactor vessel with the vessel head closure bolts less than fully head closure bolts less than fully tensioned or with the head tensioned or with the head removed removed D Defueled D Defueled All reactor fuel removed from reactor All reactor fuel removed from reactor pressure vessel (full core off load pressure vessel (full core off load during refueling or extended during refueling or extended outage) outage) 6 CSD-EP-HNP-0101-01, PLP 201, Emergency Plan, Section EP-ALL-EPLAN, Duke Energy EAL CU5.1 and EAL 3.8 Common Emergency Plan, Section 8.0 SU7.1 Basis (Pages 96 and 171)

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

Rev. 9 ATTACHMENT 2 Page 3 of 32

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

7 CSD-EP-HNP-0101-01, PLP 201 Emergency Plan EP-ALL-EPLAN Duke Energy Section 4.1.11 (Page Common Emergency Plan and EP-

18) HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex 8 CSD-EP-HNP-0101-01, PLP-201, HNP Emergency Plan EP-ALL-EPLAN, Duke Energy EAL HU7.1, HA7.1, section 2.4, Assignment of Common Emergency Plan, Section HS7.1 and HG7.1 Responsibility 3.0, Assignment of Responsibility Bases (Pages 131, 132, 134, and 136) 9 CSD-EP-HNP-0101-01, Loss of RCS inventory as indicated by Loss of RCS inventory as indicated by EAL CA1.1 Basis (Page LI-403 or RCS standpipe level < -82 LI-403 or RCS standpipe level < -82 in.

65) in. (Figure C-RVLIS) 10 CSD-EP-HNP-0101-01, Added Figure C-RVLIS, from CSD-EAL CA1.1 Basis (Page EP-HNP-0101-02, to the listed

66) document and section.

EAL CS1.1 Basis (Page 70)

EAL CS1.2 Basis (Page 72)

EAL CG1.1 Basis (Page 78) 11 CSD-EP-HNP-0101-01, With CONTAINMENT CLOSURE not With CONTAINMENT CLOSURE not EAL CS1.1 Basis (Page established, RCS level < 70% RVLIS established, RCS level < 70% RVLIS

69) Full Range Full Range (Figure C-RVLIS) 12 CSD-EP-HNP-0101-01, With CONTAINMENT CLOSURE With CONTAINMENT CLOSURE EAL CS1.2 Basis (Page established, RCS level < 63% RVLIS established, RCS level < 63% RVLIS

71) Full Range Full Range (Figure C-RVLIS) 13 CSD-EP-HNP-0101-01, RCS level < 63% RVLIS Full Range RCS level < 63% RVLIS Full Range for EAL CG1.1 Basis for 30 min. (Note 1) AND Any 30 min. (Note 1) (Figure C-RVLIS)

(Page 76) Containment Challenge indication, AND Any Containment Challenge Table C-2 indication, Table C-2 14 CSD-EP-HNP-0101-02, EAL CA1.1 15 CSD-EP-HNP-0101-02, Loss of RCS inventory as indicated by Loss of RCS inventory as indicated by EAL CA1.1 LI-403 or RCS standpipe level < -82 LI-403 or RCS standpipe level < -82 in.

in. (Figure C-RVLIS) 16 CSD-EP-HNP-0101-02, With CONTAINMENT CLOSURE not With CONTAINMENT CLOSURE not EAL CS1.1 established, RCS level < 70% RVLIS established, RCS level < 70% RVLIS Full Range Full Range (Figure C-RVLIS)

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

Rev. 9 ATTACHMENT 2 Page 4 of 32

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

17 CSD-EP-HNP-0101-02, With CONTAINMENT CLOSURE With CONTAINMENT CLOSURE EAL CS1.2 established, RCS level < 63% RVLIS established, RCS level < 63% RVLIS Full Range Full Range (Figure C-RVLIS) 18 CSD-EP-HNP-0101-02, RCS level < 63% RVLIS Full Range RCS level < 63% RVLIS Full Range for EAL CG1.1 for 30 min. (Note 1) AND Any 30 min. (Note 1) (Figure C-RVLIS)

Containment Challenge indication, AND Any Containment Challenge Table C-2 indication, Table C-2 19 CSD-EP-HNP-0101-01, Table R-3/H-2 Safe Operation & Table R-3/H-2 Safe Operation &

EAL RA3.2 Basis (Page Shutdown Rooms/Areas Shutdown Rooms/Areas 58),

Room/Area Mode(s) Room/Area Mode(s)

EAL HA5.1 Basis (Page 127), RAB 190 (RHR 4 RAB 216 (BIT) 1, 2, 3 pumps)

RAB 236 (CSIP, 1, 2, 3, 4, 5 and Attachment 3 RAB 216 (BIT) 1, 2, 3, 4, 5 Primary Sample Sink, (Page 233) AFW pumps, CCW RAB 236 (CSIP, 1, 2, 3, 4, 5 pumps and HX, Boric Primary Sample Sink, Acid Transfer Pumps, AFW pumps, CCW Mezzanine Area) pumps and HX, Boric Acid Transfer Pumps, RAB 261 (RHR Heat 1, 2, 3, 4, 5 Mezzanine Area) Exchangers, Demin.

Valve Gallery, VCT RAB 261 (RHR Heat 1, 2, 3, 4, 5 Valve Gallery)

Exchangers, Demin.

Valve Gallery, VCT RAB 286 (Switchgear) 1, 2, 3, 4, 5 Valve Gallery)

Steam Tunnel 1, 2, 3, 4 RAB 286 (Switchgear) 1, 2, 3, 4, 5 ESW intakes 1, 2, 3, 4, 5 Steam Tunnel 1, 2, 3, 4 ESW intakes 1, 2, 3, 4, 5 20 CSD-EP-HNP-0101-01, MODE 4 (Hot Shutdown)/Mode 5 MODE 4 (Hot Shutdown)/Mode 5 (Cold Basis Document (Cold Shutdown) Shutdown)

Attachment 3 (Page 232)

• RAB 190 (RHR pumps)

• RAB 236 (CSIP, Primary Sample

• RAB 216 (BIT) Sink, AFW Pumps, CCW Pumps

• RAB 236 (CSIP, Primary Sample and HX, Boric Acid Transfer Sink, AFW Pumps, CCW Pumps Pumps, Mezzanine Area) and HX, Boric Acid Transfer

• RAB 261 (RHR Heat Exchangers, Pumps, Mezzanine Area) Demin Valve Gallery, VCT Valve

• RAB 261 (RHR Heat Exchangers, Gallery)

Demin Valve Gallery, VCT Valve

• RAB 286 (Switch Gear)

Gallery)

• Steam Tunnel

• RAB 286 (Switch Gear)

• ESW Structure (intakes)

• Steam Tunnel

• ESW Structure (intakes)

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

Rev. 9 ATTACHMENT 2 Page 5 of 32

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

21 CSD-EP-HNP-0101-01, [Text located in two places;] Deleted the duplicate description under EAL Basis RA3.2 If the equipment in the listed room or RA3.2 EAL Basis.

(Pages 58 - 59) area was already inoperable, or out-of-service, before the event Added a bullet () in front of the occurred, then no emergency should remaining description.

be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.

22 CSD-EP-HNP-0101-02, Table R-3/H-2 23 CSD-EP-HNP-0101-01, Table F-2 Containment Radiation Table F-2 Containment Radiation Attachment 2, Table F- Time FC Barrier Loss: Time After FC Barrier Loss:

2 (Page 188) After S/D RM-1CR-3589SA or S/D RM-1CR-3589SA or RM-1CR-3590SB RM-1CR-3590SB 0 - 1 hr 130 R/hr 0 - 1 hr 130 R/hr 1 - 2 hrs 110 R/hr (Note 12) 2 - 8 hrs 70 R/hr 1 - 2 hrs 110 R/hr

> 8 hrs 21 R/hr 2 - 8 hrs 70 R/hr

> 8 hrs 21 R/hr Note 12: Use the 0-1 hr values when evaluating containment radiation readings with the reactor not shutdown.

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

Rev. 9 ATTACHMENT 2 Page 6 of 32

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

24 CSD-EP-HNP-0101-01, Table F-2 Containment Radiation Table F-2 Containment Radiation Attachment 2, EAL Fuel Time FC Barrier Loss: Time After FC Barrier Loss:

Clad, C.1 Loss Bases After S/D RM-1CR-3589SA or S/D RM-1CR-3589SA or (Page 194) RM-1CR-3590SB RM-1CR-3590SB 0 - 1 hr 130 R/hr 0 - 1 hr 130 R/hr 1 - 2 hrs 110 R/hr (Note 12) 2 - 8 hrs 70 R/hr 1 - 2 hrs 110 R/hr

> 8 hrs 21 R/hr 2 - 8 hrs 70 R/hr Note 9: RM-1CR-3589-SA and > 8 hrs 21 R/hr RM-1CR-3590-SB may not provide Note 9: RM-1CR-3589-SA and accurate indications for up to RM-1CR-3590-SB may not provide approximately 4 minutes following a accurate indications for up to sudden significant Containment approximately 4 minutes following a temperature change, caused by a sudden significant Containment Loss of Primary or Secondary temperature change, caused by a Loss Coolant. Diverse indications such as, of Primary or Secondary Coolant.

but not limited to, RM-1CR-3561A- Diverse indications such as, but not SA, RM-1CR-3561B-SB, RM-1CR- limited to, RM-1CR-3561A-SA, RM-3561C-SA, or RM-1CR-3561D-SB 1CR-3561B-SB, RM-1CR-3561C-SA, readings should be referenced to or RM-1CR-3561D-SB readings should validate radiation levels inside be referenced to validate radiation Containment during this 4-minute levels inside Containment during this period. Negative TIC will subside in 4-minute period. Negative TIC will the event of fuel damage. subside in the event of fuel damage.

Note 12: Use the 0-1 hr values when evaluating containment radiation readings with the reactor not shutdown.

25 CSD-EP-HNP-0101-01, Table F-2 Containment Radiation Table F-2 Containment Radiation Attachment 2, EAL Time After FC Barrier Loss: Time After FC Barrier Loss:

Reactor Coolant S/D RM-1CR-3589SA or S/D RM-1CR-3589SA or System, C.1 Loss RM-1CR-3590SB RM-1CR-3590SB (Page 207) 0 - 1 hr 130 R/hr 0 - 1 hr 130 R/hr 1 - 2 hrs 110 R/hr (Note 12) 2 - 8 hrs 70 R/hr 1 - 2 hrs 110 R/hr

> 8 hrs 21 R/hr 2 - 8 hrs 70 R/hr

> 8 hrs 21 R/hr Note 12: Use the 0-1 hr values when evaluating containment radiation readings with the reactor not shutdown.

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

Rev. 9 ATTACHMENT 2 Page 7 of 32

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

26 CSD-EP-HNP-0101-01, Table F-2 Containment Radiation Table F-2 Containment Radiation Attachment 2, EAL Time After FC Barrier Loss: Time After FC Barrier Loss:

CNMT, C.1 Potential S/D RM-1CR-3589SA or S/D RM-1CR-3589SA or Loss (Page 220) RM-1CR-3590SB RM-1CR-3590SB 0 - 1 hr 130 R/hr 0 - 1 hr 130 R/hr 1 - 2 hrs 110 R/hr (Note 12) 2 - 8 hrs 70 R/hr 1 - 2 hrs 110 R/hr

> 8 hrs 21 R/hr 2 - 8 hrs 70 R/hr Note 9: RM-1CR-3589-SA and > 8 hrs 21 R/hr RM-1CR-3590-SB may not provide Note 9: RM-1CR-3589-SA and accurate indications for up to RM-1CR-3590-SB may not provide approximately 4 minutes following a accurate indications for up to sudden significant Containment approximately 4 minutes following a temperature change, caused by a sudden significant Containment Loss of Primary or Secondary temperature change, caused by a Loss Coolant. Diverse indications such as, of Primary or Secondary Coolant.

but not limited to, RM-1CR-3561A- Diverse indications such as, but not SA, RM-1CR-3561B-SB, RM-1CR- limited to, RM-1CR-3561A-SA, RM-3561C-SA, or RM-1CR-3561D-SB 1CR-3561B-SB, RM-1CR-3561C-SA, readings should be referenced to or RM-1CR-3561D-SB readings should validate radiation levels inside be referenced to validate radiation Containment during this 4-minute levels inside Containment during this period. Negative TIC will subside in 4-minute period. Negative TIC will the event of fuel damage. subside in the event of fuel damage.

Note 12: Use the 0-1 hr values when evaluating containment radiation readings with the reactor not shutdown.

27 CSD-EP-HNP-0101-02, Table F-2 Containment Radiation Table F-2 Containment Radiation Table F-2 Time After FC Barrier Loss: Time After FC Barrier Loss:

S/D RM-1CR-3589SA or S/D RM-1CR-3589SA or RM-1CR-3590SB RM-1CR-3590SB 0 - 1 hr 130 R/hr 0 - 1 hr 130 R/hr 1 - 2 hrs 110 R/hr (Note 12) 2 - 8 hrs 70 R/hr 1 - 2 hrs 110 R/hr

> 8 hrs 21 R/hr 2 - 8 hrs 70 R/hr

> 8 hrs 21 R/hr

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

Rev. 9 ATTACHMENT 2 Page 8 of 32

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

28 CSD-EP-HNP-0101-02, NOTES table (4 places, Front and Back of both EAL - Hot chart and the EAL - Cold chart.)

29 CSD-EP-HNP-0101-01, EAL SU7.1, Table S-3 (Page 170) 30 CSD-EP-HNP-0101-01, EAL CU5.1, Table C-4 (Page 95) 31 CSD-EP-HNP-0101-02, EAL SU7.1, Table S-3

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

Rev. 9 ATTACHMENT 2 Page 9 of 32

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

32 CSD-EP-HNP-0101-02, EAL CU5.1, Table C-4 33 CSD-EP-HNP-0101-01, The NRC ETS Phone and HPN The NRC communication links (ENS, EAL SU7.1 (Page 171) Phone are part of the PABX and will HPN, RSCL, PMCL, and MCPL) are and CSD-EP-HNP- be unavailable if the PABX is part of the PBX and will be 0101-01, EAL CU5.1 unavailable. unavailable if the PBX is unavailable.

(Page 96) 34 CSD-EP-HNP-0101-01, For the first condition, the For the first condition, the containment EAL Basis SU8.1 (Page containment isolation signal must be isolation signal must be generated as 172) generated as the result on an the result on an off-normal/accident off-normal/accident condition (e.g., a condition (e.g., a safety injection or safety injection or high containment high containment pressure); a failure pressure); a failure resulting from resulting from testing or maintenance testing or maintenance does not does not warrant classification. Note warrant classification. The that Containment Isolation Signals are determination of containment and defined per Shearon Harris Technical penetration status - isolated or not Specifications as Phase A Isolation, isolated - should be made in Phase B Isolation, and Containment accordance with the appropriate Ventilation Isolation. Other signals, criteria contained in the plant AOPs such as Main Steam Isolation signal, and EOPs. The 15-minute criterion is do not count as a containment isolation included to allow operators time to signals. The determination of manually isolate the required containment and penetration status -

penetrations, if possible. isolated or not isolated - should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible.

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

Rev. 9 ATTACHMENT 2 Page 10 of 32

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

35 CSD-EP-HNP-0101-01, 1. EOP-CSFST, CSF-5 1. EOP-CSFST, CSF-5 EAL Basis SU8.1 (Page 2. OP-112, Containment Spray 2. OP-112, Containment Spray 173) System System

3. FSAR 6.2.1.1.3.2 3. FSAR 6.2.1.1.3.2

4. EOP-ECA-1.2, LOCA Outside 4. EOP-ECA-1.2, LOCA Outside Containment Containment

5. AOP-023, Loss of Containment 5. AOP-023, Loss of Containment Integrity Integrity

6. NEI 99-01 SU7 6. NEI 99-01 SU7

7. Shearon Harris Technical Specification Table 3.3-3, Engineered Safety Features Actuation System Instrumentation, Functional Unit 3, Containment Isolation.

36 CSD-EP-HNP-0101-01, A 10 psig RPV pressure increase can A 10 psig RPV pressure increase can EAL Basis CA3.1 be read on various instruments be read on ERFIS RCS pressure (Page 92) including narrow range RCS pressure indicators PRC0440 or PRC0441.

indicators PI-402.1SA and PI- Also, using installed MCB meters, a 403.1SB (ref. 5). greater than 10 psig RPV pressure increase can be determined by a 10 psig increase on RCS narrow range pressure indicator PI-01RC-0402AW, which has 20 psig increments allowing reading to the half marking (ref. 5).

37 CSD-EP-HNP-0101-01, simulator walkdown. MST-I0080, Reactor Coolant System EAL Basis CA3.1 Wide Range Pressure (P-0402)

Reference 5 (Page 92) Calibration 38 CSD-EP-HNP-0101-02, Loss of all offsite and all onsite AC Loss of all offsite and all onsite AC EAL SG1.1 power capability to 6.9 KV emergency power capability to 6.9 KV emergency buses 1A-SA and 1B-SB AND buses 1A-SA and 1B-SB AND EITHER: EITHER:

- Restoration of at least one - Restoration of at least one emergency bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is emergency bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely not likely (Note1)

- Core Cooling Red Path entry - Core Cooling Red Path entry conditions met conditions met

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

Rev. 8 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.

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 [186 for HNP] for Common Emergency Plan Consistent with NUREG-0654, Revision 2 (EPID L-2020-LLA-0198), dated August 26, 2021 (ADAMS Accession No. ML21155A213).

License Amendment 186 was implemented in EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 0, issuance and EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, Revision 0, issuance.

Licensing Basis for Emergency Plan

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

• EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, Revision 0 Current EALs CSD-EP-HNP-0101-01, Harris Nuclear Plant Emergency Action Levels Technical Basis Document, Revision 002

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

Rev. 9 ATTACHMENT 2 Page 12 of 32

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

Current Emergency Plan

• EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 1

• EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, Revision 1 The differences in the approved and the current revision of the Emergency Plan have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions.

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 ATTACHMENT 2 Page 13 of 32

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

Section V: Maintaining the Emergency Plan Conclusion.

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

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

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

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

Conclusion:

Section VI: Activity Previously Reviewed?

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

10 CFR 50.54(q) Evaluation is not required.

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

No Continue to Section VII.

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

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

Bounding source document and list of bounded changes:

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

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

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

Rev. 9 ATTACHMENT 2 Page 14 of 32

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

Justification: The 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.

Changes 1 and 3 - This change is editorial because the change updates revision footer information to the new revision.

Change 2 - This change is editorial as it updates the Table of Contents section page numbers based on the changes made per revision 3 to this document.

Change 4 - The references currently listed in SG1.2 for minimum battery bus voltage is Reference 7 and 9, which correspond to the Shearon Harris Final Safety Analysis Report (FSAR) Table 8.3.1-1 and NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Initiating Condition (IC) number SG8.

This change corrects these references to Reference 7 and 8, which correspond to FSAR Table 8.3.1-1 and MST-E0013, 1E Battery Performance Test. (NEI 99-01 SG8 does not include a reference to HNP minimum battery bus voltage. This reference number was a typographical error.) This change is editorial in nature, as it is correcting references associated with equipment to be consistent with approved plant documents.

Change 5 - Section 2.6 lists the Modes of plant operation by number and includes a description that matches the supplied reference, 4.1.17, HNP Technical Specifications Table 1.2 Operational Modes. However, there was a typographical error in Section 2.6, in that Mode 3 was listed twice, with the second Mode 3 matching the description from Technical Specifications of Mode 4. As a result, Mode 5 was also mislabeled as Mode 4 and Mode 6 was mislabeled as Mode 5. The intent was for the second Mode 3 to be labeled Mode 4 and all other Modes after Mode 3 to be labeled sequentially.

This change is editorial in nature, in that it corrects an obvious typographical error in the section. There is only one accepted definition for Mode 3 per HNP Technical Specification Table 1.2, with what is labeled as the second Mode 3 matching the definition of Mode 4. This is consistent with the definitions of editorial per AD-EP-ALL-0602 Section 3.6.a, Obvious step or section number errors or Correct references This also updates Section 2.6 to be consistent with the Mode definitions used through-out the remainder of CSD-EP-HNP-0101-01, the wall charts per CSD-EP-HNP-0101-02, and the mode definitions submitted per HNP-15-025, License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors" (ML15126A117).

Changes 6, 7, and 8 - These changes are editorial and updates the references in the document to support the implementation of the Duke Energy Common Emergency Plan. Accordingly, references to PLP-201, Emergency Plan, are being replaced with references to EP-ALL-EPLAN, Duke Energy Common Emergency Plan and EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex.

Change 21 - This change is editorial as it is correcting an unintentional duplication of information. The section included an identical paragraph at the beginning and the end of the section. Including the paragraph a second time did not convey any new information or benefit. Further, the second occurrence of the paragraph was located after a bulleted list. From context, the paragraph was meant to be an item included in the list. Thus, the proposed change deletes the duplicate paragraph at the beginning of the basis section and adds a bullet () to the second occurrence of the paragraph, signaling its inclusion in the list of items. This change is editorial, as it corrects a typographical error and does not change the information presented.

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

Rev. 9 ATTACHMENT 2 Page 15 of 32

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

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

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

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

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

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

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

4 10 CFR 50.47(b)(4) Emergency Classification System RS A standard scheme of emergency classification and action levels is in use. (Requires V/V (Attachment 3) and 4a 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 the declared 5a 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 instructions to 5b 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 Emergency preparedness information is made available to the public on a periodic basis within the plume 7a 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 available to 10b support the formulation of PARs and have been provided to State and local governmental authorities.

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

Rev. 9 ATTACHMENT 2 Page 16 of 32

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

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

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

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

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

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

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

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

14c Identified weaknesses are corrected.

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

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

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

16b Section VIII: Conclusion If any Section VIII criteria are checked, 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 VIII 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)

Rev. 9 ATTACHMENT 2 Page 17 of 32

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

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

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

Planning Standard 10 CFR 50.47(b)(4) states: A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Function The emergency planning function associated with 10 CFR 50.47(b)(4) states: A standard scheme of emergency classification and action levels is in use.

Appendix E Supporting requirements which are described in 10 CFR 50, Appendix E states:

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

IV.C: 1. The entire spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described. The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described. Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described. The existence, but not the details, of a message authentication scheme shall be noted for such agencies. The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG-0654/FEMA-REP-1.

IV.C: 2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of

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

Rev. 9 ATTACHMENT 2 Page 18 of 32

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

indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.

Informing Criteria from NUREG-0654 The applicable program elements described in NUREG-0654,Section II.D state:

• D.1: An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee. The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, in the in-plant emergency procedures. The plan shall identify the parameter values and equipment status for each emergency class.

• D.2: The initiating conditions shall include the example conditions found in Appendix 1 and all postulated accidents in the Final Safety Analysis Report (FSAR) for the nuclear facility.

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:

Changes 9, 11, 12, and 13 modify EAL declaration thresholds CA1.1, CS1.1, CS1.2, and CG1.1, each associated with Initiating Conditions stemming from loss of Reactor Coolant System (RCS) inventory, to include a reference to Figure C-RVLIS, as already included in CSD-EP-HNP-0101-02.

Change 10 adds Figure C-RVLIS from CSD-EP-HNP-0101-02 to the EAL basis section in CSD-EP-HNP-0101-01 for use as the reference for EAL declaration thresholds CA1.1, CS1.1, CS1.2, and CG1.1. This figure illustrates the location of various RCS levels as indicated by RVLIS and by the RCS standpipe relative to the level of the reactor vessel, as indicated by plant elevation. This figure will be used as an operator aid to ensure the declaration threshold is understood and correctly applied to conditions resulting in a loss of RCS inventory. This figure does not change the intent of EAL thresholds and will help ensure consistent operator performance. The illustration within Figure C-RVLIS is already contained in CSD-EP-HNP-0101-02.

Changes 9, 11, 12, and 13 are supported by Change 14, which labels the existing copy of the figure on the EAL - Cold Chart in CSD-EP-HNP-0101-02 as Figure C-RVLIS and Changes 15, 16, 17, and 18 which revises CA1.1, CS1.1, CS1.2, and CG1.1 in the EAL Wallchart (CSD-EP-HNP-0101-02) to match the EAL Technical Basis Document CSD-EP-HNP-0101-01.

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

Rev. 9 ATTACHMENT 2 Page 19 of 32

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

Thus, the Emergency Plan, as modified by these proposed changes, will still comply with planning standard 10 CFR 50.47(b)(4) for having an emergency classification system. The proposed changes do not negatively impact the accuracy or the timeliness of the classification. The inclusion of the existing figure in the EAL basis will provide a useful tool for ensuring ongoing accurate EAL declarations made in a timely manner.

Changes 19 and 20 revise Table R-3/H-2, Safe Operation and Shutdown Rooms/Areas, to remove RAB 190 (RHR [residual heat removal] pumps), applicable in Mode 4 only, and RAB 216 (BIT [boron injection tank]), entries for Modes 4 and 5. These changes are based upon an operator review of CSD-EP-HNP-0101-01 which identified changes to the EAL bases for declarations of impeded operator access to equipment necessary for normal operations, cooldown, or shutdown of the facility in the current operating mode. Change 22 supports these changes by making the same associated change to CSD-EP-HNP-0101-02.

The operator review validated the equipment listed in Table R-3/H-2, Safe Operation and Shutdown Rooms/Areas relative to the requirements as listed in NEI 99-01 Revision 6 for the associated EAL.

The review identified two table entries listing equipment in modes that do not need to be accessed physically by operators performing normal operations, cooldown, or shutdown of the facility.

Specifically, access to the RHR pumps in Mode 4 and to the BIT for Modes 4 and 5 is not needed for normal operations, cooldown, or shutdown.

The two EALs impacted by this change are EAL RA3.2, An UNPLANNED event results in radiation levels that prohibit or impede access to any Table R-3/H-2 rooms or areas and EAL H5.1, Release of a toxic, corrosive, asphyxiant or flammable gas into any Table R-3/H-2 rooms or areas AND Entry into the room or area is prohibited or IMPEDED.

CSD-EP-HNP-0101-01 incorporates guidance from NEI 99-01 Revision 6 related to declaration of the associated EALs for impeded access. Per this guidance, The site-specific list of plant rooms or areas with entry-related mode applicability identified should specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Do not include rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations). In addition, the list should specify the plant mode(s) during which entry would be required for each room or area. This note was copied from NEI 99-01 Revision 6 and is associated with items AA3 and HA5.

Sections AA3 and HA5 further elaborate that a declaration is not warranted if The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode Thus, the current intention for declaration of events per RA3.2 and HA5.1 is to declare events where operators are impeded from entering locations with equipment required for a given mode of operation and have proceduralized manual or local actions. If the equipment in a listed area for a given mode is operated remotely per normal operating procedures, a declaration would not be warranted.

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

Rev. 9 ATTACHMENT 2 Page 20 of 32

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

A review of the Table R-3/H-2 identified the potential to over-classify based on the guidance as captured above. A review of the site operating procedures used for normal plant operation, cooldown and shutdown identified entries in Table R-3/H-2 which included rooms with no equipment requiring manual or local action in the listed mode. Reviews included GP-006, Normal Plant Shutdown from Power Operation to Hot Standby (Mode 1 to Mode 3), GP-007, Normal Plant Cooldown (Mode 3 to Mode 5), and GP-008, Draining the Reactor Coolant System. GP-006 and GP-007 are the procedures listed as reviewed per CSD-EP-HNP-0101-01 Attachment 3 to make the initial determination as to equipment required per Mode 4, 5, and 6 operation.

Thus, declarations based on impeded access to RHR in Mode 4 and BIT in Modes 4 and 5 would be overconservative and not based on current licensing basis of the Harris Emergency Plan. Removing these table entries eliminates the potential to declare an emergency where one is not warranted.

Thus, the Emergency Plan, as modified by these proposed changes, will still comply with planning standard 10 CFR 50.47(b)(4) for having an emergency classification system. The proposed changes do not negatively impact the accuracy or the timeliness of the classification. Removal of the overly conservative guidance for declaring impeded access will improve EAL declaration accuracy and will have no effects on making timely declarations for remaining rooms or areas which are rightly associated with the EAL.

Changes 23, 24, 25, and 26 add a note to Table F-2 in CSD-EP-HNP-0101-01, which is used to declare the status (loss or potential loss) of fission product barriers based on radiation levels in containment, with thresholds based on time since the unit was shut-down. The note states, Use the 0-1 hr values when evaluating containment radiation readings with the reactor not shutdown.

This table is referenced by Table F-1, Fission Product Barrier Threshold Matrix, which is used in declaring Fission Product Barrier degradation per FA1.1, FS1.1, and FG1.1. The table entries begin at a time of 0-1 hours to cover the time immediately following a reactor shutdown, which does not take into account any decay time or changes in core conditions since the unit was operating. Thus, the predicted radiation levels at T=0 for shutdown are the same as the levels expected when the reactor is still operating, and would be consistent with the T=0 threshold as calculated per EP-EALCALC-HNP-1701, Containment Radiation EAL Threshold Values. While this was already understood among operators utilizing the table, this note removes potential for error and ensures the consistent use by Operations staff. Changes 27 and 28 incorporates this change into the wall boards per CSD-EP-HNP-0101-02.

The addition of this note to the EAL Technical Basis Document and EAL Wallchart does not change the Emergency Plan, an Initiating Condition, or an EAL. The intent of the EALs (Category F - Fission Product Barrier Degradation) will remain the same, with no change to Category F declarations as a result of the change to the EAL bases discussed. The Emergency Plan, as modified by these proposed changes, will still comply with planning standard 10 CFR 50.47(b)(4) for having an emergency classification system. The proposed changes do not negatively impact the accuracy or the timeliness of the classification. The note will remove a potential source of confusion, ensuring accuracy in declarations and preventing delays in making timely declarations.

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

Rev. 9 ATTACHMENT 2 Page 21 of 32

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

Changes 29 and 30: These changes update the EAL Basis document, CSD-EP-HNP-0101-01, Tables C-4 and S-3, Communications Methods, which are tied to EAL declarations CU5.1 and SU7.1 respectively. These EALs are for declaring Unusual Events due to loss of all onsite or offsite communications ability while either in cold conditions or hot conditions respectively. Changes 31 and 32 support these changes by updating the EAL Wall Chart per CSD-EP-HNP-0101-02 to include the revised versions of the communications methods table.

Finally, change 33 revises a statement in the both the CU5.1 and SU7.1 bases to better reflect the language of the current Emergency Plan. Currently, the bases explain, The NRC ETS [Emergency Telecommunications System] Phone and the NRC HPN [Health Physics Network] Phone are part of the PABX [Private Automatic Branch Exchange] and will be unavailable if the PABX is unavailable. The revised statement expands this statement to include the other NRC communications links currently listed in the Emergency Plan, The NRC communication links (ENS [Emergency Notification System], HPN, RSCL [Reactor Safety Counterpart Link], PMCL [Protective Measures Counterpart Link], and MCPL

[Management Counterpart Link]) are part of the PBX [Private Branch Exchange] and will be unavailable if the PBX is unavailable.

This change supports implementation of the approved fleet emergency plan which was approved by the NRC for use at Shearon Harris per NRC Safety Evaluation Report, dated August 26, 2021, per ML21155A213. This change is being made per the sites change management plan to shift from PLP-201 to EP-ALL-EPLAN. Per the submittal (License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2, ADAMS Ascension Number ML20247J468, dated 9/3/2020),

the change is an administrative change, and the wording change does not change intent or level of commitment concerning the credited site communications systems.

The proposed change includes changing the Table C-4 and Table S-3 entry from PABX telephone (desk phones) to PBX. Also, the current table entries for NRC ETS phone and NRC HPN phone are being removed, as these phones are part of and routed through the PBX. From EP-ALL-EPLAN, PBX is the primary means of communication with the NRC. Extensions designated for NRC communications are located in the MCRs, TSCs, and EOF. Included in the list of extensions are telephones that have been designated for specific uses in NRC communications, including the NRC ENS and the NRC HPN. Thus, the removal of the ENS (part of the NRC ETS in the current E-Plan) and the HPN from the communications table is not a change in intent to the EAL. There is no change to the equipment or how the equipment is being utilized. A loss of PBX would render the ENS and HPN unavailable, and inclusion of the PBX in the table includes the ENS and HPN also.

Further, there are other NRC communication links listed in EP-ALL-EPLAN that are also part of and routed through the PBX. Change 33 revises a statement in the EAL bases to be more consistent with the communications links found in EP-ALL-EPLAN. There is no change to the equipment or how the equipment is being utilized, and no change to the intent of either EALs.

The Site paging system is renamed Public Address System to be more consistent with EP-ALL-EPLAN. The Radio communications networks is renamed Onsite Radio System to be more consistent with EP-ALL-EPLAN. There is no change to the equipment or how the equipment is being utilized. Finally, cellular phones are added to Table C-4 and Table S-3. This change is consistent with EP-ALL-EPLAN and adds credit for another commonly used communication device.

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

Rev. 9 ATTACHMENT 2 Page 22 of 32

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

Thus, the Emergency Plan, as modified by these proposed changes, will still comply with planning standard 10 CFR 50.47(b)(4) for having an emergency classification system. The proposed changes do not negatively impact the accuracy or the timeliness of the classification. Aligning the table with EP-ALL-EPLAN insured accurate declarations based on the current emergency plan made in a timely manner.

Changes 34 and 35 add clarity to SU8.1 (Any penetration is not isolated within 15 min. of a VALID containment isolation signal) to ensure consistent operator performance and to ensure Unusual Events are not declared in instances not supported by the current licensing basis. Specifically, the proposed change, captured per change 34, adds the following note to the EAL Basis for SU8.1.

Note that Containment Isolation Signals are defined per Shearon Harris Technical Specifications as Phase A Isolation, Phase B Isolation, and Containment Ventilation Isolation. Other signals, such as Main Steam Isolation signal, do not count as a containment isolation signals.

Change 35 supports the statement above by adding an additional HNP Basis Reference to SU8.1.

Specifically, Basis 7 is added to provide the Shearon Harris Technical Specification which defines containment isolation signals as show below.

7. Shearon Harris Technical Specification Table 3.3-3, Engineered Safety Features Actuation System Instrumentation, Functional Unit 3, Containment Isolation.

The additions provide amplifying information to define what is a valid containment isolation signal to ensure declarations are consistent with the current licensing basis for SU8.1 as defined by NEI 99-01 Revision 6 and the current EAL basis document for the site. The guidance will reduce the likelihood of an over classification of events not currently warranting declaration of SU8.1, such as an instance of a stuck open Main Steam Isolation Valve after receipt of a valid Main Steam Isolation signal.

Per NEI 99-01 Revision 6 for SU7, to meet this threshold, the containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure). This aligns to signals defined in the sites technical specifications as containment isolation, which have several triggers including containment pressure (Phase A and Phase B isolation), containment radiation levels (Containment Ventilation isolation), and safety injection (Phase A isolation and Containment Ventilation isolation), among others. These signals support the Containment Isolation System, which is designed to provide a reliable barrier against the escape of fission products under various environmental conditions following a LOCA. (FSAR Section 1.2.2.3).

In contrast, Main Steam Isolation serves to prevent the continuous, uncontrolled blowdown of more than one steam generator and thereby control RCS cooldown (FSAR 7.3.1.1.1). The signal is therefore not credited for protection of the public by preventing fission product release from containment. These valves also prevent overpressurization of containment from reverse flow, caused by a fault inside containment (FSAR Section 10.3.2.1.e). This could lead to initiation of a containment isolation signal on containment high pressure but does not itself constitute a containment isolation signal.

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

Rev. 9 ATTACHMENT 2 Page 23 of 32

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

This is also consistent with Shearon Harris Technical Specifications 3.3.2, Engineered Safety Features Actuation System Instrumentation, which does not list Main Steam Isolation Signal as a containment isolation signal. Only Phase A Isolation, Phase B Isolation, and Containment Ventilation Isolation are listed.

Consideration was given to scenarios involving steam generator tube rupture coupled to a failure of main steam to isolate on Main Steam isolation signal. Consistent with NEI 99-01 Revision 6 guidance for SU7 and for FA1, as well as the guidance in CSD-EP-HNP-0101-01 Revision 2 for SU8.1 and FA1.1, the SG Tube Rupture is classifiable as a loss of RCS per FA1.1, Table F-1 Category A.1 for RCS Barrier. (This corresponds to NEI 99-01 Revision 6 FA1 PWR RCS Barrier Threshold Loss 1.A.)

Steam generator tube integrity impacts the RCS barrier, not containment. (This assumes that while main steam is unisolated, the impacted steam generator is not faulted.) Further, if a steam generator is faulted through a failed open main steam isolation valve, the threshold is met for FS1.1 as a loss or potential loss of Containment.

These proposed changes are consistent with CSD-EP-HNP-0101-01 Revision 2 as currently written, and NEI 99-01 Revision 6, which is the licensing basis for the Shearon Harris EAL scheme.

Therefore, the changes described do not constitute a change to the Emergency Plan EAL scheme as currently written. The intent of the EAL remains the same with the additional guidance provided in the basis. The Emergency Plan, as modified by these proposed changes, will still comply with planning standard 10 CFR 50.47(b)(4) for having an emergency classification system. The proposed changes do not negatively impact the accuracy or the timeliness of the classification. The guidance removes a potential source of confusion, ensuring accuracy in declarations and preventing delays in making timely declarations.

Changes 36 and 37: CA3.1 contains the following EAL threshold for declaration of inability to maintain the plant in cold shutdown, UNPLANNED RCS [Reactor Coolant System] pressure increase >10 psig. Change 36 improves a statement in the basis section to clarify available instrumentation for declaration of this threshold. Change 37 revises Reference 5 captured in the basis to reflect a better source of information for current instrumentation capabilities.

CA3.1 is based on NEI 99-01 IC# CA3. Per the guidance, the purpose is to declare loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. This provides a pressure-based indication of RCS heat-up, as credited per HNP-15-025, License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. Per HNP-15-025, 10 psig is the site-specific pressure increase readable by Control Room indication.

Currently, the EAL Basis document for CA3.1 elaborates, In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on the RCS pressure increase criteria when in Mode 5. Further, the EAL states, A 10 psig RPV [Reactor Pressure Vessel] pressure increase can be read on various instruments including narrow range RCS pressure indicators PI-402.1SA and PI-403.1SB (ref. 5). This statement has several opportunities for improvement that will enhance the basis statement supporting the EAL, as detailed below. To improve this statement, and to remind operators of the additional capability to measure RCS pressure by using the Emergency Response Facility Information System (ERFIS)

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

Rev. 9 ATTACHMENT 2 Page 24 of 32

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

displays, the statement is being revised per Change 36 to state, A 10 psig RPV pressure increase can be read on ERFIS RCS pressure indicators PRC0440 or PRC0441. Also, using installed MCB

[Main Control Board] meters, a greater than 10 psig RPV pressure increase can be determined by a 10 psig increase on RCS narrow range pressure indicator PI-01RC-0402AW, which has 20 psig increments allowing reading to the half marking (ref. 5).

This change accomplishes two improvements on the current language of this statement.

1) The change defines more explicitly the various instruments mentioned in the original sentence.

By changing A 10 psig RPV pressure increase can be read on various instruments to A 10 psig RPV pressure increase can be read on ERFIS RCS pressure indicators PRC0440 or PRC0441, the Operators are given more explicit instructions as to what various instruments are available.

These ERFIS computer points are available as they process signals from the pressure transmitters similar to the control board recorders and are available in the control room. Per HNP-I/INST-1009, Reactor Coolant Wide Range and RVLIS Pressure: EOP Set Points, The ERFIS computer displays a pressure reading with no decimal points. Since the computer does not round the data displayed, the accuracy is approximated as +/-1 psig.

2) The change identifies the narrow range RCS pressure indicator.

Currently, the statement in question identifies as narrow range RCS pressure indicators PI-402.1SA and PI-403.1SB. These two instruments (tagged in the Engineering Database (EDB) as PI-01RC-402.1SAW and PI-01RC-403.1SBW respectively) are RCS pressure wide range instruments. This is aligned with the designated range per EDB of 0-3000 psig. Per HNP-I/INST-1009, the wide range instruments utilize a scaled recorder with the smallest marked graduation of 50 psig. Thus, the assumed error caused by human factoring is equal to half the smallest graduation, or 25 psig. This makes the wide range instruments not ideal for use in declarations per CA1.3 for RCS pressure rise >

10 psig.

The narrow range RCS pressure instrument, PI-01RC-0402AW, has a range of 700 psig per EDB.

Per HNP/I/INST-1009, the instruments smallest graduation is 20 psig, which allows reading to the half marking or 10 psig when accounting for human factoring. This makes this instrument more ideal for being able to reliably read a pressure increase of 10 psig from the control board. By referencing the actual narrow range instrument in the EAL Basis document, declarations based on a 10 psig increase in RCS pressure will be more accurate and be based on better human factoring for control board gauges.

Finally, the current Reference 5 utilized by the basis for CA3.1 is simulator walkdown. This reference should be changed per Change 37 to a design control document. MST-I0080, Reactor Coolant System Wide Range Pressure (P-0402) Calibration, will be referenced instead, as this document contains information on the pressure transmitter and the three pressure indicators impacted (both wide range and the narrow range.)

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

Rev. 9 ATTACHMENT 2 Page 25 of 32

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

This revision to the basis will result in listing the narrow range instrument. This instrument will meet all requirements for RCS pressure monitoring during Cold Shutdown per both the current EAL scheme and NEI 99-01 Revision 6. Further, ERFIS computer points PRC0440 and PRC0441 will also provide the necessary indication to determine if a 10 psig pressure increase has occurred. This now provides a total of three listed instruments relative to the original two, ensuring better redundancy. Finally, Reference 5 will be updated to a more rigorously controlled reference, MST-I0080. These changes do not constitute a change to the Emergency Plan, an Initiating Condition, or an EAL, but represent an improvement to the EAL basis guidance only. The intent of the EAL CA3.1 will remain the same with the changes to the EAL basis discussed.

These proposed changes are consistent with CSD-EP-HNP-0101-01 Revision 2 as currently written, and NEI 99-01 Revision 6, which is the licensing basis for the Shearon Harris EAL scheme.

Therefore, the changes described do not constitute a change to the Emergency Plan EAL scheme as currently written. The Emergency Plan, as modified by these proposed changes, will still comply with planning standard 10 CFR 50.47(b)(4) for having an emergency classification system. The proposed changes do not negatively impact the accuracy or the timeliness of the classification. By referencing instruments with a more suitable range, accuracy will be improved and less time will be lost by attempting to read the pressure increase of 10 psig on the wide range instruments.

Change 38: This change revised the EAL Wall Chart per CSD-EP-HNP-0101-02 to match the EAL Basis document per CSD-EP-HNP-0101-01 for EAL SG1.1:

Loss of all offsite and all onsite AC power capability to 6.9 KV emergency buses 1A-SA and 1B-SB AND EITHER:

• Restoration of at least one emergency bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely (Note 1)

• Core Cooling RED Path entry conditions met.

The EP-EAL Basis document for EAL SG1.1 includes a reference in the EAL to Note 1, The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded, per the first bullet. The wall chart did not include a reference to Note 1. (This condition only impacts SG1.1. SG1.2 includes a declaration for loss of all AC power without DC power, but it already includes a reference to Note 1 in both the EAL basis document and the wall chart.) Adding this note to SG1.1 is also consistent with generic existing guidance in the EAL Basis document, per Section 3.1.3, Imminent Conditions, For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

Thus, the Emergency Plan, as modified by these proposed changes, will still comply with planning standard 10 CFR 50.47(b)(4) for having an emergency classification system. The proposed changes do not negatively impact the accuracy or the timeliness of the classification. The addition of the note will serve as a reminder of the rules concerning EAL declarations, which will ensure continued accuracy in declaring the threshold exceeded and ensure timeliness of declarations by helping to ensure operators do not inappropriately wait to declare the EAL.

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

Rev. 9 ATTACHMENT 2 Page 26 of 32

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

Thus, the Emergency Plan, as modified by all proposed changes listed in the above section, will still comply with planning standard 10 CFR 50.47(b)(4) for having an emergency classification system.

The proposed changes do not negatively impact the accuracy of the classification or the timeliness of the classification. The proposed changes add clarifying information that is intended to minimize the potential for an under or over-classification of equipment failure. The proposed changes do not reduce the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would not be different from that approved by the NRC in a site-specific application or from the endorsed industry EAL scheme that had been approved for licensee use. The proposed changes can be made because the meaning or intent of the basis of the approved EAL is unchanged.

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:

Changes 9, 11, 12, and 13 modify EAL declaration thresholds CA1.1, CS1.1, CS1.2, and CG1.1, each associated with Initiating Conditions stemming from loss of Reactor Coolant System (RCS) inventory, to include a reference to Figure C-RVLIS, as already in included in CSD-EP-HNP-0101-02.

Change 10 adds Figure C-RVLIS from CSD-EP-HNP-0101-02 to the EAL basis section in CSD-EP-HNP-0101-01 for use as the reference for EAL declaration thresholds CA1.1, CS1.1, CS1.2, and CG1.1. This figure does not change the intent of EAL thresholds and will help ensure consistent operator performance.

Changes 9, 11, 12, and 13 are supported by Change 14, which labels the existing copy of the figure on the EAL - Cold Chart in CSD-EP-HNP-0101-02 as Figure C-RVLIS and Changes 15, 16, 17, and 18 which revises CA1.1, CS1.1, CS1.2, and CG1.1 in the EAL Wallchart (CSD-EP-HNP-0101-02) to match the EAL Technical Basis Document CSD-EP-HNP-0101-01.

Changes 9, 10, 11, 12, 13, 14, 15, 16, 17, and 18 do not constitute a change to the Emergency Plan, an Initiating Condition, or an EAL. The intent of the EALs will remain the same with the changes to the EAL basis discussed. The proposed changes maintain the current EAL scheme with no reduction in effectiveness.

Changes 19 and 20 revise Table R-3/H-2, Safe Operation and Shutdown Rooms/Areas, to remove RAB 190 (RHR pumps), applicable in Mode 4 only, and RAB 216 (BIT), entries for Modes 4 and 5.

These changes are based upon an operator review of CSD-EP-HNP-0101-01 which identified changes to the EAL bases for declarations of impeded operator access to equipment necessary for normal operations, cooldown, or shutdown of the facility in the current operating mode. Change 22 supports these changes by making the same associated change to CSD-EP-HNP-0101-02.

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

Rev. 9 ATTACHMENT 2 Page 27 of 32

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

This review validated the equipment listed in Table R-3/H-2 relative to the requirements as listed in NEI 99-01 Revision 6 for the associated EAL. The review identified two table entries listing equipment in modes that do not need to be accessed physically by operators performing normal operations, cooldown, or shutdown of the facility. Thus, including these items in the table does not conform with the bases listed in the associated EAL and could lead to overclassification.

The two EALs impacted by this change are EAL RA3.2, An UNPLANNED event results in radiation levels that prohibit or impede access to any Table R-3/H-2 rooms or areas and EAL H5.1, Release of a toxic, corrosive, asphyxiant or flammable gas into any Table R-3/H-2 rooms or areas AND Entry into the room or area is prohibited or IMPEDED.

As demonstrated above, changes 19, 20, and 22 do not constitute a change to the Emergency Plan, an Initiating Condition, or an EAL. The intent of the EALs will remain the same with the changes to the EAL basis discussed. The proposed changes maintain the current EAL scheme with no reduction in effectiveness.

Changes 23, 24, 25, and 26 add a note to Table F-2 in CSD-EP-HNP-0101-01, which is used to declare the status (loss or potential loss) of fission product barriers based on radiation levels in containment, with thresholds based on time since the unit was shut-down. The note states, Use the 0-1 hr values when evaluating containment radiation readings with the reactor not shutdown.

This table is referenced by Table F-1, Fission Product Barrier Threshold Matrix, which is used in declaring Fission Product Barrier degradation per FA1.1, FS1.1, and FG1.1. The table entries begin at a time of 0-1 hours to cover the time immediately following a reactor shutdown, which does not take into account any decay time or changes in core conditions since the unit was operating. Thus, the predicted radiation levels at T=0 for shutdown are the same as the levels expected when the reactor is still operating, and would be consistent with the T=0 threshold as calculated per EP-EALCALC-HNP-1701, Containment Radiation EAL Threshold Values. While this was already understood among operators utilizing the table, this note removes potential for error and ensures the consistent use by Operations staff. Changes 27 and 28 incorporates this change into the wall boards per CSD-EP-HNP-0101-02.

The addition of this note to the EAL Technical Basis Document and EAL Wallchart does not change the Emergency Plan, an Initiating Condition, or an EAL. The intent of the EALs (Category F - Fission Product Barrier Degradation) will remain the same, with no change to Category F declarations as a result of the change to the EAL bases discussed. The proposed changes maintain the current EAL scheme with no reduction in effectiveness.

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

Rev. 9 ATTACHMENT 2 Page 28 of 32

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

Changes 29 and 30: These changes update the EAL Basis document, CSD-EP-HNP-0101-01, Tables C-4 and S-3, Communications Methods, which are tied to EAL declarations CU5.1 and SU7.1 respectively. These EALs are for declaring Unusual Events due to loss of all onsite or offsite communications ability while either in cold conditions or hot conditions respectively. Changes 31 and 32 support these changes by updating the EAL Wall Chart per CSD-EP-HNP-0101-02 to include the revised versions of the communications methods table. Finally, change 33 expounds on a sentence in the basis description, describing the NRC communication links currently carried over the PABX.

This change supports implementation of the approved fleet emergency plan which was approved by the NRC for use at Shearon Harris per NRC Safety Evaluation Report, dated August 26, 2021, per ML21155A213. This change is being made per the sites change management plan to shift from PLP-201 to EP-ALL-EPLAN. Per the submittal (License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2, ADAMS Ascension Number ML20247J468, dated 9/3/2020),

the change is an administrative change, and the wording change does not change intent or level of commitment concerning the credited site communications systems. Note that this change is not a result of or reflective of any physical changes to the communications systems of HNP.

As demonstrated above, changes 29, 30, 31, 32, and 33 do not constitute a change to the Emergency Plan, an Initiating Condition, or an EAL. The intent of the EALs will remain the same with the changes to the EAL basis discussed. The proposed changes maintain the current EAL scheme with no reduction in effectiveness.

Changes 34 and 35 add clarity to SU8.1 to ensure consistent operator performance and to ensure Unusual Events are not declared in instances not supported by the current licensing basis.

Specifically, the proposed change, captured per change 34, adds the following note to the EAL Basis for SU8.1.

Note that Containment Isolation Signals are defined per Shearon Harris Technical Specifications as Phase A Isolation, Phase B Isolation, and Containment Ventilation Isolation. Other signals, such as Main Steam Isolation signal, do not count as a containment isolation signals.

Change 35 supports the statement above by adding an additional HNP Basis Reference to SU8.1.

Specifically, Basis 7. Is added to provide the Shearon Harris Technical Specification which defines containment isolation signals.

7. Shearon Harris Technical Specification Table 3.3-3, Engineered Safety Features Actuation System Instrumentation, Functional Unit 3, Containment Isolation.

These additions are to support declarations per the first criteria of SU8.1, specifically Any penetration is not isolated within 15 min. of a VALID containment isolation signal. The additions provide amplifying information to define what is a valid containment isolation signal to ensure declarations are consistent with the current licensing basis for SU8.1 as defined by NEI 99-01 Revision 6 and the current EAL basis document for the site. The guidance will reduce the likelihood of an over classification of events not currently warranting declaration of SU8.1, such as an instance of a stuck open Main Steam Isolation Valve after receipt of a valid Main Steam Isolation signal.

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

Rev. 9 ATTACHMENT 2 Page 29 of 32

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

As demonstrated above, changes 34 and 35 do not constitute a change to the Emergency Plan, an Initiating Condition, or an EAL. The intent of the EALs will remain the same with the changes to the EAL basis discussed. The proposed changes maintain the current EAL scheme with no reduction in effectiveness.

Changes 36 and 37: CA3.1 contains the following EAL threshold for declaration of inability to maintain the plant in cold shutdown, UNPLANNED RCS [Reactor Coolant System] pressure increase >10 psig Change 36 improves a statement in the basis section to clarify available instrumentation for declaration of this threshold. Change 37 revises Reference 5 captured in the basis to reflect a better source of information for current instrumentation capabilities.

Currently, the EAL Basis document for CA3.1 elaborates, In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on the RCS pressure increase criteria when in Mode 5. Further, the EAL states, A 10 psig RPV [Reactor Pressure Vessel] pressure increase can be read on various instruments including narrow range RCS pressure indicators PI-402.1SA and PI-403.1SB (ref. 5). This statement has several opportunities for improvement that will enhance the basis statement supporting the EAL, as detailed below. To improve this statement, and to remind operators of the additional capability to measure RCS pressure by using the Emergency Response Facility Information System (ERFIS) displays, the statement is being revised per Change 36 to state, A 10 psig RPV pressure increase can be read on ERFIS RCS pressure indicators PRC0440 or PRC0441. Also, using installed MCB

[Main Control Board] meters, a greater than 10 psig RPV pressure increase can be determined by a 10 psig increase on RCS narrow range pressure indicator PI-01RC-0402AW, which has 20 psig increments allowing reading to the half marking (ref. 5).

Finally, the current Reference 5 utilized by the basis for CA3.1 is simulator walkdown. This reference will be changed per Change 37 to a design control document. MST-I0080, Reactor Coolant System Wide Range Pressure (P-0402) Calibration.

As demonstrated above, changes 36 and 37 do not constitute a change to the Emergency Plan, an Initiating Condition, or an EAL. The intent of the EALs will remain the same with the changes to the EAL basis discussed. The proposed changes maintain the current EAL scheme with no reduction in effectiveness.

Change 38: This change revised the EAL Wall Chart per CSD-EP-HNP-0101-02 to match the EAL Basis document per CSD-EP-HNP-0101-01 for EAL SG1.1:

Loss of all offsite and all onsite AC power capability to 6.9 KV emergency buses 1A-SA and 1B-SB AND EITHER:

• Restoration of at least one emergency bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely (Note 1)

• Core Cooling RED Path entry conditions met.

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

Rev. 9 ATTACHMENT 2 Page 30 of 32

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

The EP-EAL Basis document for EAL SG1.1 includes a reference in the EAL to Note 1, The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded, per the first bullet. The wall chart did not include a reference to Note 1. This note will therefore be added to the wallchart.

Change 38 does not constitute a change to the Emergency Plan, an Initiating Condition, or an EAL.

The intent of the EALs will remain the same with the changes to the EAL basis discussed. The proposed changes maintain the current EAL scheme with no reduction in effectiveness.

None of the changes evaluated above constitute a change to the Emergency Plan, an Initiating Condition, or an EAL. The intent of the impacted EALs will remain the same with the changes to the EAL basis discussed. The proposed changes maintain the current EAL scheme, and the Emergency Plan will continue to comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E. The effectiveness of the Emergency Plan will be maintained with no reduction in effectiveness.

The proposed changes do not reduce the effectiveness of the Duke Energy HNP's Emergency Plan because a standard scheme of emergency classification and action levels is in use. 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.

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

Rev. 9 ATTACHMENT 2 Page 31 of 32

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

Section XII: Evaluation Conclusion Answer the following questions about the proposed change:

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

2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in 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).

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

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

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

If YES, then initiate a License Amendment Request in accordance 10 CFR 50.90, AD-LS-ALL-0002, Regulatory Correspondence, and AD-LS-ALL-0015, License Amendment Request and Changes to SLC, TRM, and TS Bases, and include the tracking number:___________________________________. Complete Section XIV.

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

Rev. 9 ATTACHMENT 2 Page 32 of 32

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

Section XIV: Signatures:

EP CFAM Final Approval is required for changes affecting Program Element 4a of Section VIII. If CFAM approval is NOT required, then mark the EP CFAM signature block as not applicable (N/A) to indicate that signature is not required.Section XIV as applicable.

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

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

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

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

David Thompson See CAS QA RECORD