ML14364A045

McGuire, Units 1 and 2 - Submittal of Emergency Plan, Revision 14-5

ML14364A045
Person / Time
Site:	McGuire, Mcguire
Issue date:	12/16/2014
From:	Capps S D Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
MNS-14-103, FOIA/PA-2015-0025
Download: ML14364A045 (258)

Text

(~DUKEENERGY,Steven D. CappsVice President McGuire Nuclear StationDuke EnergyMG01VP 1 12700 Hagers Ferry RoadHuntersville, NC 280780: 980.875.4805 f: 980.875.4809 Steven.Ca pps@d uke-energy.com December 16, 2014Serial No: MNS-14-103 10 CFR 50.54(q)U. S. Nuclear Regulatory Commission Attn: Document Control DeskWashington, D. C. 20555-0001

Subject:

Duke Energy Carolinas, LLCMcGuire Nuclear Station, Units 1 and 2Docket Nos. 50-369, 50-370Emergency Plan, Revision 14-5Please find attached Revision 14-5 to the McGuire Nuclear Station Emergency Plan. Thisrevision is submitted in accordance with the requirements of 10 CFR 50.54(q) and does notresult in a reduction in the effectiveness of the Emergency Plan or the Emergency PlanImplementing Procedures.

Questions regarding this submittal should be directed to Kay Crane, McGuire Regulatory Affairs,at (980) 875-4306.

Steven D. CappsAttachments www.duke-energy.com U. S. Nuclear Regulatory Commission December 16, 2014Page 2(Two Copies)cc: Mr. V.M. McCree, Regional Administrator, Region IIU. S. Nuclear Regulatory Commission Marquis One Tower245 Peachtree Center Ave., NE, Suite 1200Atlanta, GA 30303-1257 (One Copy)Catherine Haney, DirectorOffice of Nuclear Material Safety and Safeguards Mail Stop 14 A12Washington, D. C. 20555-0001 (w/o attachments)

Mr. G.E. MillerNRC Project Manager (McGuire)

U. S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08C211555 Rockville PikeRockville, MD 20852-2738 Mr. John ZeilerNRC Senior Resident Inspector McGuire Nuclear Station DUKE ENERGYMcGUIRE NUCLEAR SITEEMERGENCY PLANAPPROVED:

4 e enSITE VICE PRESIDENT DATE APPROVED:

_ z__ _lqREVISION 14-5: December, 2014EFFECTIVE DATE: December, 2014ORIGINAL DATE: August 25, 1980Rev. 14-5December, 2014 December 10, 2014MEMORANDUM To:All Holders of the McGuire Emergency Plan

Subject:

McGuire Emergency PlanEnclosed please find Revision 14-5 to the McGuire Nuclear Site Emergency Plan. Refer toAttachment 1 to complete the revision to the manual.If there are any questions, please call me at 980-875-4672.

Sincerely, Kevin MurrayEmergency Preparedness ManagerMcGuire Nuclear StationKLM/jcm

Attachment:

Emergency Plan Revisioncc: EP File 1502eprevltr.doc Attachment 1December 10, 2014Page 1 of 1SECTIONCoversheet Emergency PlanRevision ListList of Effective Pages (LOEP)Table of ContentsList of FiguresSection DSection HREMOVE PAGESRevision 14-4Revision 14-4INSERT PAGESRevision 14-5Revision 14-5Complete

Section, Rev. 14-4Pages 1 thru 4Complete

Section, Rev. 14-4Pages 1 thru 6Complete

Section, Rev. 14-3Pages 1-2Complete

Section, Rev. 14-1Pages DI thru D83Complete

Section, Rev. 14-2Pages HI thru H17Complete

Section, Rev. 12-1Pages I1 thru 13Complete

Section, Rev. 13-3Pages J I thru J22Complete

Section, Rev. 10-2Pages NI thru N3Complete

Section, Rev. 14-3Pages P1 thru P10Complete Section Rev. 14-4Pages QI thru Q20Complete

Section, Rev. 14-5Pages 1 thru 4Complete

Section, Rev. 14-5Pages 1 thru 6Complete

Section, Rev. 14-5Pages 1-2Complete

Section, Rev. 14-5Pages DI thru D83Complete

Section, Rev. 14-5Pages H1 thru H17Complete

Section, Rev. 14-5Pages I1 thru 3Complete

Section, Rev. 14-5Pages JI thru J22Complete

Section, Rev. 14-5Pages N1 thru N3Complete

Section, Rev. 14-5Pages P1 thru P 10Complete Section Rev. 14-5Pages Q1 thru Q20Section ISection JSection NSection PSection Q DUKE ENERGY COMPANYMcGUIRE NUCLEAR SITEEMERGENCY PLANREVISION LISTAugust 25, 1980 Date IssuedChange 1, October, 1980Change 2, February, 1981Change 3, June, 1981Change 4, August, 1981Revision 1, November 16, 1981Revision 2, February, 1982Revision 3, February, 1982Revision 4, April, 1982Revision 5, June, 1982Revision 6, July, 1982Revision 7, September, 1982Revision 8, November, 1982Revision 9, January, 1983Revision 10, February, 1983Revision 11, June, 1983Revision 12, November, 1983Revision 13, March, 1984Revision 14, August, 1984Revision 15, January, 1985Revision 16, March, 1985Revision 17, May, 1985Revision 18, November, 1985Revision 19, January, 1986Revision 20, July, 1986Revision 21, May, 1987Revision 22, June, 1987Revision 23, November, 1987Revision 24, March, 1988Revision 25, July, 1988Revision 26, July, 1989Revision 27, September, 1989Revision 28, October, 1989Revision 29, November, 1989Revision 30, March, 1990Revision 31, April, 1991Revision 32, July, 1991Revision 33, September, 1991Revision 34, October, 1991Revision 35, December, 1991Revision 36, January, 1992Revision 37, March 1992Revision 92-1, August 1992Revision 92-2, October 1992Rev. 93-1, April 1993Rev. 93-2, June, 1993Rev. 93-3, December 1993Rev. 94-1, January, 1994Rev. 94-2, June, 1994Rev. 94-3, August 1994Rev. 94-4, October 1994Rev. 95-1, February 1995Rev. 95-2, April 1995Rev. 96-1, April 1996Rev. 96-2, July 1996Rev. 97-1, April 1997Rev. 97-2, May 1997Rev. 97-3, July, 1997Rev. 98-1, January, 1998Rev. 98-2, February, 1998Rev. 98-3, May, 1998Rev. 98-4, July, 1998Rev. 98-5, August, 1998Rev. 98-6, November, 1998Rev. 99-1, March, 1999Rev. 99-2, July, 1999Rev. 99-3 November, 1999Rev. 00-1, April, 2000Rev. 00-2, May, 2000Rev. 00-3, November, 2000Rev. 01-1, January, 2001Rev. 01-2, June, 2001Rev. 02-1, March, 2002Rev. 02-2, August, 2002Rev. 03-1, April, 2003Rev. 03-2, June, 2003Rev. 04-1, February, 2004Rev. 04-2, July, 2004Rev. 05-1, July, 2005Rev. 06-1, January, 2006Rev. 06-2, September, 2006Rev. 07-1, May, 20071Rev. 14-5December, 2014 Rev. 07-2, December, 2007Rev. 08-1, September, 2008Rev. 09-1, July, 2009Rev. 09-2, December, 2009Rev. 10-1, May, 2010Rev. 10-2, November, 2010Rev. 11 -1, March, 2011Rev. 11-2, August, 2011Rev. 11-3, October, 2011Rev. 12-1, May, 2012Rev. 12-2, June, 2012Rev. 12-3, November, 2012Rev. 12-4, December, 2012Rev. 13-1, March, 2013Rev. 13-2, June, 2013Rev. 13-3, October, 2013Rev. 14-1, January, 2014Rev. 14-2, June 2014Rev. 14-3, September, 2014Rev. 14-4, October, 2014Rev. 14-5, December, 20142Rev. 14-5December, 2014 McGuire Emergency PlanList of Effective PagesEmergency Plan Approval Cover SheetCoversheet Rev. 14-5Emergency Plan Revision ListPage 1 thru 2 Rev. 14-5Table of ContentsPage 1 thru 6 Rev. 14-5List of FiguresPage 1 thru 2 Rev. 14-5Introduction Pages i-I thru i-7 Rev. 13-3A. Assignment of Responsibility Pages A-1 thru A-5 Rev. 14-3B. Onsite Emergency Organization Pages B-i thru B-13 Rev. 14-2C. Emergency Response Support & Resources Pages C- I thru C-2 Rev. 09-1D. Emergency Class System/EAL Basis DocumentPages D-1 thru D-83 Rev. 14-5E. Notification Methods & Procedures Pages E- 1 thru E- 1I Rev. 14-4December, 2014December, 2014December, 2014December, 2014October, 2013September, 2014June, 2014July, 2009December, 2014October, 2014Rev. 14-5December, 2014 McGuire Emergency PlanList of Effective PagesF. Emergency Communications Pages F-I thru F-7 Rev. 06-2G. Public Education

& Information Pages G-1 thru G-4 Rev. 14-3H. Emer2ency Facility

& Equipment Pages H-I thru H-17 Rev. 14-5September, 2006September, 2014December, 2014I. Accident Assessment Pages I-i thru 1-3J. Protected ResponsePages J-1 thru J-22Rev. 14-5December, 2014Rev. 14-5December, 2014K. Radiological Exposure ControlPages K-1 thru K-4 Rev. 00-3L. Medical & Public Health SupportPages L- 1 thru L-2 Rev. 13-3M. Recovery

& Re-entry PlanninPages M-I thru M-5 Rev. 06-2November, 2000October, 2013September, 2006N. Exercises

& DrillsPages N-I thru N-3Rev. 14-5December, 2014Rev. 14-5December, 2014 McGuire Emergency PlanList of Effective Pages0. Radiological Emergency Response TrainingPages 0-1 thru 0-2Rev. 10-2November, 2010P. Development Periodic Review & Distribution of Emergency PlansPages P-I thru P-10 Rev. 14-5December, 20140. Appendices 1-4Pages Q- 1 thru Q- 15Rev. 14-5Appendix 5 Agreement LettersIndex -Page Q-16Agreement Letter 1Agreement Letter 2Agreement Letter 3Agreement Letter 4Agreement Letter 5Agreement Letter 6Agreement Letter 7Agreement Letter 8Agreement Letter 9Agreement Letter 10Agreement Letter 11Agreement Letter 12Agreement Letter 13Agreement Letter 14Agreement Letter 15Agreement Letter 16Agreement Letter 17Agreement Letter 18Agreement Letter 19Agreement Letter 20Agreement Letter 21Agreement Letter 22Agreement Letter 23Rev. 14-5Rev. 13-1Rev. 14-2Rev. 14-2Rev. 13-1Rev. 00-1 (Deleted)

Rev. 14-2Rev. 14-2Rev. 14-2Rev. 14-2Rev. 14-2Rev. 14-2Rev. 14-2Rev. 14-2Rev. 14-2Rev. 13-3Rev. 14-2Rev. 14-3Rev. 12-2Rev. 12-2Rev. 14-2Rev. 12-2Rev. 12-2Rev. 14-2December, 2014December, 2014March, 2013June, 2014June, 2014March, 2013May, 2000June, 2014June, 2014June, 2014June, 2014June, 2014June, 2014June, 2014June, 2014June, 2014October, 2013June, 2014September, 2014June, 2012June, 2012June, 2014June, 2012June, 2012June, 2014Rev. 14-5December, 2014 McGuire Emergency PlanList of Effective PagesAppendix 6 Emergency Plan Distribution Page Q-17 thru Q-20 Rev. 14-5December, 2014Appendix 7 SPCC PlanCoversheet Table of ContentsPages 1 thru 75Rev. 12-3Rev. 12-3Rev. 12-3November, 2012November, 2012November, 2012Appendix 8 Hazardous Waste Contingency PlanPages 1 thru 19 Rev. 13-1Appendix 9 Hazardous Materials Response PlanPages 1 thru 14 Rev. 13-3March, 2013October, 2013Rev. 14-5December, 2014 DUKE ENERGYMCGUIRE NUCLEAR SITEEMERGENCY PLANTable of Contentsi. Introduction Page #A.B.C.PurposeScopePlanning Basisi-ii-1i-3A. Assignment of Responsibility A. l.a Organization A. 1.b Concept of Operations A. 1.c Block Diagram Interrelationships A. 1 .d Key Decisionmaking A. i.e 24 Hour Emergency ResponseA.2.a Responsibility for and Functions of Emergency Response Organization A.2.b Legal Basis for Authority A.3 Agreement Letters for Emergency Response SupportA.4 Individuals Responsible for Continuity of Resources B. On-site Emergency Organization A-iA-3A-3A-3A-4A-4A-4A-4A-5B.1B.2B.3B.4B.5B.6B.7B.8B.9B.9.aB.9.bB.9.cB.9.dB.9.eB.9.fB.9.gB.9.hPlant Staff Under Emergency Conditions Emergency Coordinator Emergency Coordinator (line of succession)

Functional Responsibilities of Emergency Coordinator Minimum Staffing Requirements On-site Functional Area Interfaces Augmented Support of On-site Emergency Organization Contractor and Private Organizations Local Agency Support ServicesLaw Enforcement, Emergency Traffic Control, RelatedPolice MattersEarly Warning or Evacuation of the PopulaceRadiological Emergency Monitoring Assistance Hospitals, Medical SupportAmbulance ServiceFire-fighting Public Health and Safety, Evaluation of theRadiological Situation Local, State and Federal Support Responsibilities B-1B-1B-1B-2B-2B-2B-2B-3 thru B-4B-4B-4B-5B-5B-5B-5B-5B-5B-6Rev. 14-5December, 2014I Table of ContentsPage#C. Emergency Response Support and Resources C. .a Individuals Authorized to Request Federal Assistance C-1C. 1 .b Federal Resources Arrival Time C-1C. 1 .c Emergency Operations Facility Resources C-1Available to Federal Response Organizations C.2.a State and County Representation at the Emergency C-1Operations Facility (EOF)C.2.b Licensee Representation at the Off-Site EOC's C-1C.3 Radiological Laboratories-Availability and Capability C-2C.4 Emergency Support From Other Organizations C-2D. Emergency Classification System/EAL Basis DocumentEmergency Classification System/EAL D-1 thru D-83Basis DocumentE. Notification Methodology E. 1 Notification of Response Organization E-1E.2 Activation of Emergency Organization E-1E.2.a Notification of Unusual Event E-1E.2.b Alert E-2E.2.c Site Area Emergency E-4E.2.d General Emergency E-6E.3 Emergency Message Format (Initial)

E-8E.4 Emergency Message Format (Follow-up)

E-9E.5 State and Local Organizations-Disseminating Public E-9Information E.6 Alert and Notification System E-9E.7 Supporting Information for Public Information Message E-9F. Emergency Communications F. L.a 24 Hour Notification Capability F-1F. .b Communications With State/Local Governments F-1F. 1.c Communications With Federal Organizations F-2F. 1 .d Communications Between Site, EOF, EOC's F-2and Monitoring TeamF. i.e Activation of Emergency Personnel F-2F.l.f Communications Between NRC, EOC and F-2Monitoring TeamsF. 1.g ERDS Data Transfer F-2F.2 Medical Support Communications F-3F.3 Communications System Testing F-3Rev. 14-5December, 20142 Table of ContentsPage #G. Public Education and Information G. 1/G.2 Public Education and Information ProgramG.3.a News Group -Location and ContactsG.3.b News Group -Media CenterG.4.a Public Spokesperson G.4.b Spokesperson Information ExchangeG.4.c Rumor ControlG.5 News Media Training SessionsH. Emergency Facilities and Equipment G-1G-1G-1G-2G-2G-2G-2H.1H.l.aH.l.bH.l.cH.l.dH.2H.3H.4H.5H.5.aH.5.bH.5.cH.5.dH.6H.7H.8H.9H.10H.l1H.12Technical Support Center/Operations Support CenterControl RoomTechnical Support Center (TSC)Operations Support Center (OSC)Alternate Facilities Emergency Operations Facility (EOF)State and Local Government Emergency Operations CenterActivation and StaffingAssessment ActionsMeteorological, Hydrologic and SeismicRadiological MonitorsPlant Parameters Fire Detection Data, Monitoring Equipment and Analysis Facilities Off-site Radiological Monitoring Meteorology Instrumentation and Procedures Operations Support CenterEmergency Equipment/Instrumentation Inspection, Inventory, Operational Check, Calibration Emergency KitsReceipt and Analysis of Field Monitoring DatassmentEmergency Action Level Procedures On-site Capability and Resources to Provide InitialValues and Continuing Assessment Post Accident SamplingRadiation and Effluent MonitorsIn-plant Iodine Instrumentation Method for Determining Release Source TermEffluent Monitor Readings Vs On-site/Off-site ExposureMeteorological Information Availability Release Rates/Projected Doses for Offscale Instrumentation H-1H-1H-1H-2H-2H-2 thru H-3H-4H-4H-4H-4 thru H-5H-6H-6H-6H-6H-7H-7H-7H-7H-7H-71-1I-iI-iI-21-21-2I-2I-2I-2I. Accident Asse1.11.2I.2.a1.2.b1.2.cI.3.a/I.3.b1.41.51.6Rev. 14-5December, 20143 Table of ContentsPage#1.7/ Field Monitoring Within EPZ 1-31.81.9 Detect and Measure Radioiodine Concentration in the EPZ 1-3I. 10 Relationship Between Contamination Levels 1-3and Integrated Dose/Dose Rates1.11 Plume Tracking 1-3J. Protective ResponseJ. L.a Onsite Alerting and Notification J- 1thruJ.l.dJ.2 Evacuation Routes and Transportation J-1J.3 Personnel Monitoring J- 1J.4 Site Evacuation Procedures

-Decontamination J-2J.5 Personnel Accountability J-2J.6 Protective Equipment Breathing Apparatus, Protective J-2Clothing, KIJ.7 Protective Action Recommendations J-3J.8 Evacuation Time Estimates J-4J.9 Implementing Protective Measures J-4J. 10 Implementation of Protective Measures for Plume J-5Exposure PathwayJ.10.a EPZ Maps J-6J. 10.b EPZ Population Distribution Map J-6J.10.c EPZ Population Alerting and Notification J-6J. 10.d EPZ Protecting Immobile Persons J-6J. 10.e Use of Radioprotective Drugs for Persons in EPZ J-6J. 10.f Conditions for Use of Radioprotective Drugs J-6J. 1 0.g State/County Relocation Plans J-6J. 10.h Relocation Center Locations J-6J. 10.i Evacuation Route -Traffic Capacities J-6J. I 0.j Evacuated Area Access Control J-6J. 1 O.k Planning for Contingencies in Evacuation J-6J. 10.1 State/County Evacuation Time Estimates J-6J. 10.m Bases for Protective Action Recommendations J-6J. 11 Ingestion Pathway Planning J-7J. 12 Relocation Center -Registering and Monitoring J-7Rev. 14-5December, 20144 Table of Contents Page#K. Radiological Exposure ControlK. 1 Onsite Exposure Guidelines K-1K.2 Doses in Excess of 1 OCFR Part 20 K-1K.3 Emergency Personnel Exposure and Records K-1K.3.a Distribution of Dosimetry K-1K.3.b Dose Records K-2K.4 State/Local Plan for Authorizing Doses Exceeding PAG's K-2K.5 Decontamination K-2K.5.a Action Levels for Determining the Need for Decontamination K-2K.5.b Radiological Decontamination K-2K.6 Contamination Control Measures K-2K.6.a Area Access Control K-2K.6.b Drinking Water and Food Supplies K-2K.6.c Recovery Efforts K-3K.7 Decontamination of Personnel at Relocation K-3Assembly AreaL. Medical and Public Health SupportL. 1 Hospital and Medical Support L-1L.2 On-site First Aid Capability L-1L.3 Public, Private, Military Hospitals, Emergency Medical L-1Facilities L.4 Transport of Accident Victims L-2M. Recovery and Reentry Planning and Post-Accident Operations M. 1 Recovery/Reentry Plans and Procedures M-1M. L.a Outline of Site Recovery Plans M-1M. 1 .b Outline of Recovery Plans M-2M.2 Recovery Organization M-3M.3 Information to Members of Recovery Organization M-4M.4 Total Population Exposure Estimates M-4N. Exercises and DrillsN. L.a Exercises N-1N. 1 .b Exercise Scenario/Response N-iN.2 Drills N-iN.2.a Communications N-1N.2.b Fire Drills N-2N.2.c Medical Emergency Drills N-2N.2.d Radiological Monitoring Drills N-2N.2.e Radiation Protection Drills N-2N.3 Exercise and Drill Execution N-3N.4 Exercise Critique N-3N.5 Critique Action Items N-3Rev. 14-5December, 20145 Table of ContentsPage #0. Radiological Emergency Response Training0.1 Offsite Agency Training0.1 .a Emergency Response Training (Offsite Agency)0. .b Off-site Support Agency -Participation in Training0.2 Site Organization Training0.3 First Aid Training0.4 Training For Radiological Emergency ResponsePersonnel 0.5 Training PeriodP. Responsibility for the Planning EffortP. 1 Emergency Planning Staff TrainingP.2 Emergency Response PlanningP.3 Site Emergency Planning ManagerP.4 Review of Emergency PlanP.5 Distribution of Revised PlansP.6 Supporting PlansP.7 Implementing Procedures P.8 Table of ContentsP.9 Audit of Emergency PlanP.10 Telephone Number Updates0-10-10-10-10-10-20-2P-1P-1P-1P-1P-1P-2P-2P-2P-2P-3Q. Appendices Appendix 1Appendix 2Appendix 3Appendix 4Appendix 5Appendix 6Appendix 7Appendix 8Appendix 9IndexDefinitions Meteorological ProgramAlert and Notification System Description Evacuation Time Estimates Agreement LettersMcGuire Nuclear Site Emergency Plan Distribution SPCC PlanHazardous Waste Contingency PlanHazardous Materials Response PlanQ-1Q-2Q-6Q-10Q-15Q-16Q-17Rev. 14-5December, 20146 LIST OF FIGURESFIGURENO. TITLE PAGE #i-i 10 Mile EPZ i-6i-2 50 Mile EPZ i-7A-1 Responsibility for Emergency Response Functions A-6B-i a Minimumn On-Shift ERO Staffing Requirements for Emergencies B-7B-lb Minimum Augmented ERO Staffing Requirements for Emergencies B-8 & 9B-2 Site Emergency Organization B-10B-3 EOF Organization

-Minimum Staffing Requirements B- 1IB-4 Inter-Relationships of Response Organizations

-B-12Unusual EventB-5 Inter-Relationships of Response Organizations

-B-13Alert, Site Area Emergency, General Emergency E- 1 Emergency Notification E- 10F-1 Emergency Communication Layout Prior to TSC/EOF Activation F-4F-2 Emergency Comnunication Layout After TSC Activation, F-5and During EOF Activation F-3 Emergency Response Radio System F-6F-4 Emergency Operations Facility Communications F-7G-1 Corporate Communications Initial Emergency Response Organization G-3G-2 Corporate Communications Emergency Response Organization G-4H-1 McGuire Nuclear Site Technical Support Center H-8H-2 McGuire Nuclear Site Operations Support Center H-9H-3 McGuire/Catawba/Oconee EOF General Location H-10Rev. 14-5December, 2014 LIST OF FIGURESFIGURENO.H-4H-5H-6H-7H-8H-9H-10J-1J-2J-3J-4J-5J-6K-1M-1P-1P-2TITLEMcGuire/Catawba/Oconee EOF LocationMcGuire/EOF General Arrangement Media CenterJoint Information CenterGeneralized Met SystemAlternate TSCAlternate OSCGuidance for Offsite Protective ActionsDescription of Evacuation RegionsMNS ETE Based on 2010 Census -90% Effected Population MNS ETE Based on 2010 Census -100% Effected Population Evacuation Route Map for MNSSummary of Population and DemandEmergency Workers Exposure Guidelines Recovery Organization Supporting PlansEmergency Plan Implementing Procedures Emergency Plan Implementing Procedures Distribution Meteorological Parameters of the Upgraded SystemSiren Range in FeetSiren Locations PAGE #H-1IH-12H-13H-14H-15H-16H-17J-8J-l 1J-13J-17J-21J-22K-4M-5P-4P-5 thruP-8P-9P-10Q-9Q-13Q-14P-32-1Q-1Q-2Rev. 14-5December, 20142 D. EMERGENCY CLASSIFICATION SYSTEMRegulatory Guide 1.101, Rev. 3, August 1992, approved the guidance provided byNUMARC/NESP-007, Revision 2, as an alternative methodology for the development ofEmergency Action Levels. McGuire Nuclear Site used the NUMARC guidance for thedevelopment of initiating conditions and emergency action levels. The emergency actionlevels provided in this section have been modified to implement the guidance provided in NRCBulletin 2005-02, NEI guidance as endorsed in Regulatory Issue Summary 2006-12 and tosupport the implementation of NEI 03-12.The emergency classification system utilizes four categories for classification of emergency events.D.l.a UNUSUAL EVENTEvents are in process or have occurred which indicate a potential degradation of the level ofsafety of the plant or indicate a security threat to facility protection has been initiated.

Noreleases of radioactive material requiring offsite response or monitoring are expected unlessfurther degradation of safety systems occurs.The purpose of this class is to provide notification of the emergency to the station staff, Stateand Local Government representatives, and the NRC.Specific initiating conditions and their corresponding emergency action levels are provided inthis Basis Document.

D.I.b ALERTEvents are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable lifethreatening risk to site personnel or damage to site equipment because of hostile action. Anyreleases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.The purpose of this class is to assure that emergency personnel are readily available to:1. Activate the onsite response centers.2. Respond if the situation becomes more serious or to perform confirmatory radiation monitoring if required.

3. Provide offsite authorities current status information.

Specific initiating conditions and their corresponding emergency action levels are provided inthis Basis Document.

Rev. 14-5December, 2014D1 D.I.c. SITE AREA EMERGENCY Events are in process or have occurred which involve actual or likely major failures of plantfunctions needed for protection of the public or hostile action that results in intentional damageor malicious acts; (1) toward site personnel or equipment that could lead to the likely failure ofor; (2) that prevent effective access to equipment needed for protection of the public. Anyreleases are not expected to result in exposure levels which exceed EPA Protective ActionGuideline exposure levels beyond the site boundary.

The purpose of the Site Area Emergency is to:1. Activate the offsite response centers.2. Assure that monitoring teams are mobilized.

3. Assure that personnel required for taking protective actions of near site areas are atduty stations should the situation become more serious.4. Provide current information to the public and be available for consultation with offsiteauthorities.

Specific initiating conditions and their corresponding emergency action levels are provided inthis Basis Document.

D.I.d. GENERAL EMERGENCY Events are in process or have occurred which involve actual or imminent substantial coredegradation or melting with potential for loss of containment integrity or hostile action thatresults in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than theimmediate site area.The purpose of the General Emergency is to:1. Initiate predetermined protective actions for the public.2. Provide continuous assessment of information from onsite and offsite measurements.

3. Initiate additional measures as indicated by event releases or potential releases.

4. Provide current information to the public and be available for consultation with offsiteauthorities.

Specific initiating conditions and their corresponding emergency action levels are provided inthis Basis Document.

Rev. 14-5December, 2014D2 D.2. INITIATING CONDITIONS The initiating conditions and their corresponding emergency action levels are contained in theBasis Document beginning on page D6. Classification procedure (RP/O/A/5700/O00) providesthe guidance necessary to classify events and promptly declare the appropriate emergency conditions within 15 minutes after the availability of indications to cognizant facility staff that anemergency action level threshold has been exceeded.

Specific response procedures are inplace which delineate the required response during the appropriate classification.

D.3. ALPHABETICAL LIST OF IMPORTANT DEFINED TERMS FOR EVENT CLASSIFICATION

{5}ALL -(As relates to Operating Mode Applicability)

-At all times.BOMB -Refers to a explosive device suspected of having sufficient force to damage plantsystems or structures.

CIVIL DISTURBANCE

-A group of ten (10) or more people violently protesting stationoperations or activities at the site. A civil disturbance is considered to be violent when force hasbeen used in an attempt to injure site personnel or damage plant property.

COGNIZANT FACILITY STAFF -Any member of facility staff, who by virtue of training andexperience, is qualified to assess the indications or reports for validity and to compare the sameto the EALs in the licensee's emergency classification scheme. (Does not include staff whosepositions require they report, rather than assess, abnormal conditions to the facility.)

CONFINEMENT BOUNDARY

-The barrier(s) between areas containing radioactive substances and the environment.

EXPLOSION

-A rapid, violent unconfined combustion, or a catastrophic failure ofpressurized/energized equipment that imparts energy of sufficient force to potentially damagepermanent structures, systems or components.

EXTORTION

-An attempt to cause an action at the site by threat of force.FIRE -Combustion characterized by heat and light. Sources of smoke such as slipping drivebelts or overheated electrical equipment do not constitute fires. Observation of flames ispreferred but is NOT required if large quantities of smoke and heat are observed.

An electrical breaker flash that creates high temperatures for a short duration and merely localized scorching to that breaker and its compartment should not be considered a fire.HOSTAGE -A person(s) held as leverage against the station to ensure demands will be met bythe station.HOSTILE ACTION -An act toward a NPP or its personnel that includes the use of violent forceto destroy equipment, take HOSTAGES, and / or intimidate the licensee to achieve an end.This includes attack by air, land, or water using guns, explosives, PROJECTILEs,

vehicles, orother devices used to deliver destructive force. Other acts that satisfy the overall intent may beincluded.

HOSTILE ACTION should not be construed to include acts of civil disobedience orfelonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALsRev. 14-5December, 2014D3 should be used to address such activities, (i.e., this may include violent acts betweenindividuals in the owner controlled area).HOSTILE FORCE -One or more individuals who are engaged in a determined

assault, overtlyor by stealth and deception, equipped with suitable weapons capable of killing,

maiming, orcausing destruction.

IMMINENT

-Mitigation actions have been ineffective, additional actions are not expected to besuccessful, and trended information indicates that the event or condition will occur. WhereIMMINENT time frames are specified, they shall apply.INABILITY TO DIRECTLY MONITOR -Operational Aid Computer data points are unavailable or gauges/panel indications are not readily available to the operator.

INTRUSION

-A person(s) present in a specified area without authorization.

Discovery of aBOMB in a specified area is indication of INTRUSION into that area by a HOSTILE FORCE.ISFSI -Independent Spent Fuel Storage Installation.

NO MODE -Defueled.

PROJECTILE

-An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROLONGED

-a duration beyond normal limits, defined as "greater than 15 minutes" or asdetermined by the judgement of the Emergency Coordinator.

PROTECTED AREA -Typically the site specific area which normally encompasses allcontrolled areas within the security PROTECTED AREA fence.REACTOR COOLANT SYSTEM (RCS/NCS)

LEAKAGE -RCS Operational Leakage asdefined in the Technical Specification Basis B 3.4.13.RUPTURED

-(As relates to Steam Generator)

-Existence of primary to secondary leakage of amagnitude sufficient to require or cause a reactor trip and safety injection.

SABOTAGE

-Deliberate damage, misalignment, or mis-operation of plant equipment with theintent to render the equipment inoperable.

Equipment found tampered with or damaged due tomalicious mischief may not meet the definition of SABOTAGE until this determination is madeby security supervision.

SECURITY CONDITION

-Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or apotential degradation to the level of safety of the plant. A SECURITY CONDITION does notinvolve a HOSTILE ACTION.SIGNIFICANT TRANSIENT-An unplanned event involving one or more of the following:

(I)automatic turbine runback >25% thermal reactor power, (2) electrical load rejection

>25% fullelectrical load; (3) reactor trip, (4) safety injection, (5) thermal power oscillations

>10%.Rev. 14-5December, 2014D4 SITE BOUNDARY

-That area, including the protected area, in which Duke Power Companyhas the authority to control all activities, including exclusion or removal of personnel andproperty.

SLC -Selected Licensee Commitments.

SUSTAINED

-A duration of time long enough to confirm that the CSF is valid (not momentary).

TOTAL EFFECTIVE DOSE EQUIVALENT (TEDE) -The sum of external dose exposure to aradioactive plume, to radionuclides deposited on the ground by the plume, and the internalexposure from inhaled radionuclides deposited in the body.TOXIC GAS -A gas that is dangerous to life or health by reason of inhalation or skin contact(e.g. chlorine).

UNCONTROLLED

-Event is not the result of planned actions by the plant staff.UNPLANNED

-An event or action is UNPLANNED if it is not the expected result of normaloperations,

testing, or maintenance.

Events that result in corrective or mitigative actions beingtaken in accordance with abnormal or emergency procedures are UNPLANNED.

VALID -An indication or report or condition is considered to be VALID when it is conclusively verified by: (I ) an instrument channel check, or (2) indications on related or redundant instrumentation, or (3) by direct observation by plant personnel such that doubt related to theinstrument's operability, the condition's existence or the report's accuracy is removed.

Implicit inthis definition is the need for timely assessment.

VIOLENT -Force has been used in an attempt to injure site personnel or damage plantproperty.

VISIBLE DAMAGE -Damage to equipment or structure that is readily observable withoutmeasurements,

testing, or analyses.

Damage is sufficient to cause concern regarding thecontinued operability or reliability of affected safety structure, system, or component.

Exampledamage: deformation due to heat or impact, denting, penetration,

rupture, cracking, paintblistering.

VITAL AREA -Areas within the PROTECTED AREA that house equipment important fornuclear safety. Access to a VITAL AREA is allowed only if an individual has been authorized tobe in that area per the Security plan, therefore VITAL AREA is a Security term.Rev. 14-5December, 2014D5 Enclosure 4.1FISSION PRODUCT BARRIER MATRIXUse EALs to determine Fission Product Barrier status (Intact, Potential Loss, or Loss). Add points for all 3 barriers.

Classifyaccording to the table on page D7.Note 1: This table is only applicable in Modes 1-4.Note 2: Also, an event (or multiple events) could occur which results in the conclusion that exceeding the Loss or Potential Loss thresholds is imminent (i.e., within 1-3 hours). In this imminent loss situation, use judgement and classify as if thethresholds are exceeded.

Note 3: When determining Fission Product Barrier status, the Fuel Clad Barrier should be considered to be lost, or potentially lost, if the conditions for the Fuel Clad Barrier loss or potential loss EALs were met previously (validated and sustained) during the event, even if the conditions do not currently exist.Note 4: Critical Safety Function (CSF) indications are not meant to include transient alarm conditions which may appear duringthe start-up of engineered safeguards equipment.

A CSF condition is satisfied when the alarmed state is valid and sustained.

The STA should be consulted to affirm if any CSF has been validated and an appropriate function restoration procedure implemented prior to that CSF being used as the basis to classify an emergency.

{1}EAL # Unusual Event EAL # Alert EAL # Site Area Emergency EAL # General Emergency 4.1.U.1 Potential Loss of 4.1.A.1 Loss OR Potential 4.1.S.1 Loss OR Potential Loss 4.1.G.1 Loss of All ThreeContainment Loss of of Both BarriersNuclear Coolant Nuclear Coolant SystemSystem ANDFuel Clad4.1.U.2 Loss of Containment 4.1.A.2 Loss OR Potential 4.1.S.2 Loss 4.1.G.2 Loss of Any TwoLoss of AND Barriers ANDFuel Clad Potential Loss Potential Loss of theCombinations of Both ThirdNuclear Coolant SystemANDFuel Clad4.1 .A.3 Potential Loss of 4.1.S.3 Loss of Containment Containment ANDAND Loss OR Potential LossLoss OR Potential of Any Other BarrierLoss of Any OtherBarrierRev. 14-5December, 2014D6 Enclosure 4.1FISSION PRODUCT BARRIER MATRIXNOTE: If a barrier is affected, it has a single point value based on a "potential loss" or a "loss". "NotApplicable" is included in the matrix as a place holder only, and has no point value assigned.

Points (1-5) Potential Loss Loss (X) Total Points Classification Barrier __ _ _ _ _ _ _ _(X) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Containment 1 3 1 -3 Unusual EventNCS 4 5 4-6 AlertFuel Clad 4 5 7-10 Site AreaEmergency Total Points 11 -13 GeneralI__ I=Emergency

1. Compare plant conditions against the Fission Product Barrier Matrix on page D8.2. Determine the "potential loss" or "loss" status for each barrier (Containment, NCS and Fuel Clad) based on the EALsymptom description.

3. For each barrier, write the highest single point value applicable for the barrier in the "Points" column and mark theappropriate "potential loss" OR "loss" column.4. Add the points in the "Points" column and record the sum as "Total Points".5. Determine the classification level based on the number of "Total Points".6. In the table on page D6, under one of the four "classification"

columns, select the event (e.g. 4.1 .A.1 for Loss of NuclearCoolant System) that best fits the loss of barrier description.

7. Using that EAL number (e.g. 4.1.A.1) select the preprinted notification form OR a blank form and complete the requiredinformation for Emergency Coordinator/EOF Director approval and transmittal.

Rev. 14-5December, 2014D7 4.1.C CONTAINMENT BARRIERPOTENTIAL LOSS -LOSS -(3 Points)(1 Point) I4.1.N NCS BARRIERPOTENTIAL LOSS -j LOSS -(5 Points)(4 Points) I4.1.F FUEL CLAD BARRIERPOTENTIAL LOSS -LOSS -(5 Points)(4 Points)II II1. Critical Safety Function Status1. Critical Safety Function Status0 Containment-RED.

0 Not applicable.

Core cooling -RED path isindicated for > 15 min.2. Containment Conditions.

" Containment Pressure> 15 PSIG.* H2 concentration

> 9%.* NCS Integrity-RED.

• Heat Sink-RED.

2. NCS Leak RateNot applicable.

1. Critical Safety Function Status" Core Cooling-ORANGE.

• Heat Sink-RED.

2. Primary Coolant Activity Level.Core Cooling-RED.

Rapid unexplained decrease incontainment pressure following initial increase.

Unisolable leak exceeding thecapacity of one charging pumpin the normal charging modewith letdown isolated.

GREATER THAN available makeup capacity as indicated by a loss of NCS subcooling.

.Not applicable.

• Coolant Activity GREATER THAN300 pCi/cc Dose Equivalent Iodine(DEI) 1-131.* Containment pressure or sump* Containment pressure greater than level response not consistent 3 psig with either a failure of both with LOCA conditions.

trains of NS OR a failure of bothtrains of VX-CARF3. Containment Isolation Valves Status After Containment Isolation Actuation

3. SG Tube Rupture3. Containment Radiation Monitoring

• Not applicable.

• Containment isolation isincomplete and a release pathfrom containment exists.* Primary-to-Secondary leakrate exceeds the capacity ofone charging pump in thenormal charging mode withletdown isolated.

4. Containment Radiation Monitoring a Not applicable.

• Indication that a SG isRuptured and has a Non-Isolable secondary line fault.* Indication that a SG is rupturedand a prolonged release ofcontaminated secondary coolant is occurring from theaffected SG to theenvironment.

Not applicable.

• Not applicable.

• Containment radiation monitor 51A or 51 B reading at time sinceshutdown; 0-0.5 hrs. > 99 R/hr0.5 -2 hrs > 43R/hr2-4 hrs > 31 Rihr4-8 hrs > 22 R/hr>8 hrs > 13 R/hr4. Emergency CoordinatorIEOF Director Judgement Any condition, including inability to monitor the barrier, that in the opinionof the Emergency Coordinator/EOF Director indicates LOSS orPOTENTIAL LOSS of the fuel clad barrier.4. SG Secondary Side Release With Primary-to-Secondary LeakageNot applicable.

Release of secondary side tothe environment with primary tosecondary leakage GREATERTHAN Tech Spec allowable.

6 Sinnifinnt Irndinarflua Inuantnru In

• Containment Rad. Monitor

• NotEMF51A or 51BReading @ time since shutdown:

> 390 R/hr @ 0 -0.5 hr> 170 R/hr @ 0.5- 2 hr> 125R/hr @ 2-4 hr> 90R/hr @4-8 hr> 53 R/hr @ >8 hr.6. Emergency Coordinator IEOF Director Judgement applicable.

5. Emergency Coordinator/EOF Director Judgement

• Any condition, including inability to monitor the barrier, that in the opinionof the Emergency Coordinator

/EOF Director indicates LOSS orPOTENTIAL LOSS of the NCS barrier.* Any condition, including inability to monitor the barrier, that in the opinion ofthe Emergency Coordinator/EOF Director indicates LOSS or POTENTIAL LOSS of the containment barrier.Rev. 14-5December, 2014D8 ENCLOSURE 4.1BASIS INFORMATION FORFISSION PRODUCT BARRIER REFERENCE TABLECONTAINMENT BARRIER EALs:The Containment Barrier includes the containment

building, its connections up to and including the outermost containment isolation valves. This barrier also includes the main steam,feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve.Critical Safety Function (CSF) indications are not meant to include transient alarn conditions which may appear during the start-up of engineered safeguards equipment.

A CSF condition issatisfied when the alarmed state is valid and sustained.

4.1.C.1 Critical Safety Function Status* Contaimnent

-RED indicates containment conditions which may challenge thecontaimnent integrity.

Therefore, this condition represents a potential loss of thecontainment barrier." Core Cooling -RED for greater than 15 minutes in this potential loss EALrepresents imminent core damage that, if not tenninated, could lead to reactorvessel failure and an increased potential for containment failure.

The potential forcontainmnent challenge as a result of events at reactor vessel failure makes itprudent to consider an unmitigated core damage condition as a potential loss ofthe containment barrier.Severe accident analyses (e.g., NUREG- 1150) have concluded that functionrestoration procedures can arrest core degradation within the reactor vessel in asignificant fraction of the core damage scenarios, and that the likelihood ofcontainment failure is very small in these events. Given this, it is appropriate toprovide a reasonable period to allow function restoration procedures to arrest thecore melt sequence.

Whether or not the procedures will be effective should beapparent within 15 minutes.

The Emergency Coordinator/EOF Director shouldmake the declaration as soon as it is determined that the procedures have been, orwill be, ineffective.

" There is no "Loss" EAL associated with this item.4.1.C.2 Containment Conditions Containment pressure above 15 psig (the design pressure) indicates that thecontainment or its heat removal systems are not functioning as intended.

Thisdegradation of containment pressure control represents a potential loss ofcontainment integrity.

Rev. 14-5December, 2014D9

• A containment hydrogen concentration of 9 volume percent is sufficient to expectthat any ignition would result in complete combustion of the hydrogen incontainment and a significant pressure rise. At some initial containment pressures, this pressure rise may exceed the capacity of the contaimnent.

Therefore, this level of hydrogen in the containment represents a potential loss ofcontairnent integrity.

" Once the Residual Heat Removal system is taking suction from the containment sump, with containment pressure greater than 3 psig and procedural

guidance, onetrain of containment spray is manually aligned to the containment sump. Ifunable to place one NS train in service or without an operating train of VX-CARF(the CARF with a 10-minute delay) a potential loss of containment exists. At thispoint a significant portion of the ice in the ice condenser would have melted andthe NS system would be needed for containment pressure control.This EAL for a potential loss of containment applies after automatic or manualalignment of the containment spray system has been attempted with containment pressure greater than 3 psig and less than one full train of NS is operating.

This EAL for a potential loss of containment also applies if containment pressureis greater than 3 psig and at least one train of VX-CARF is not operating after a10 minute delay. Without a single train of VX-CARF in service following actuation, the potential loss should be credited regardless of whether ECCS is ininjection or sump recirculation mode.* Rapid unexplained loss of pressure (i.e., not attributable to containment spray orcondensation effects) following an initial pressure increase indicates a loss ofcontainment integrity.

" Containment pressure and sump levels should increase as a result of the mass andenergy release into containment from a Loss of Coolant Accident (LOCA).Thus, sump level or containment pressure not increasing indicates an interfacing systems LOCA which is a containment bypass and a loss of containment integrity, or some other containment pressure boundary failure.4.1.C.3 Containment Isolation Valve Status After Containment Isolation Actuation

" There is no "Potential Loss" EAL associated with this item." Failure to isolate those containment pathways which would allow containment atmosphere to be released from containment is a loss of the containment barrier.(Containment Isolation Valve(s) not closed AND downstream pathway to theenvironment exists after Containment Isolation Signal.)

PIP G 08-00333Rev. 14-5December, 2014D10 4.1.C.4 Steam Generator (SG) Secondary Side Release With Primary To Secondary Leakage" There is no "Potential Loss" EAL associated with this item." Secondary side releases to the environment include those from the condenser airejectors, CA turbine exhaust, SG Power Operated Relief Valves (PORVs),atmospheric dump valves, faulted steam lines, and main steam safety valves.Steam releases, in combination with primary to secondary

leakage, constitute abypass of the containment and, therefore, a loss of the containment barrier.

Theappropriate classification can be determined in combination with the SG TubeRupture EAL under the Reactor Coolant System (NCS) barrier.4.1.C.5 Significant Radioactive Inventory in Containment NOTE: If EMF-51A and EMF-51B are unavailable, readings can be calculated from procedure HP/0/B/1 009/02, "Alternative Method for Determining DoseRates within the Reactor Building."

• These values indicate significant fuel damage well in excess of the EALsassociated with both loss of Fuel Clad and loss of NCS Barriers.

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power PlantAccidents, indicates that such conditions do not exist when the amount of claddamage is less than 20%. This amount of activity in containment, if released, could have such severe consequences that it is prudent to treat this as a potential loss of containment.

By treating the radioactive inventory in containment as a potential loss, a GeneralEmergency will be declared when the conditions of the fuel clad and NCS barriersare included in the evaluation.

This will allow the appropriate protective actionsto be recommended.

• There is no "Loss" EAL associated with this item.4.1.C.6 Emergency Coordinator/EOF Director Judgement This EAL addresses any other factors that are to be used by the Emergency Coordinator/EOF Director in determining whether the containment barrier is lostor potentially lost. In addition, the inability to monitor the barrier should also beincorporated in this EAL as a factor in Emergency Coordinator/EOF Directorjudgement that the barrier may be considered lost or potentially lost.REACTOR COOLANT SYSTEM (NCS) BARRIER EALs:Rev. 14-5December, 2014Dl1 The NCS Barrier includes the NCS primary side and its connections up to and including thepressurizer safety and relief valves, and other connections up to and including the primaryisolation valves.4.1.N.1 Critical Safety Function Status* NCS Integrity

-RED indicates NCS pressure and temperature conditions whichmay challenge the Reactor Vessel integrity.

Heat Sink -RED indicates theultimate heat sink function is under extreme challenge.

Either of these conditions indicate a potential loss of the NCS Barrier." There is no "Loss" EAL associated with this item.4.1.N.2 NCS Leak Rate" Small leaks may result in the inability to maintain normal liquid inventory withinthe NCS by operation of the Chemical and Volume Control System, which isconsidered as one centrifugal charging pump discharging to the charging headerwith the letdown line isolated.

If letdown cannot be isolated, and a secondcharging pump is required, this is still considered a potential loss of the NCSbarrier.

The need for compensatory action to maintain normal liquid inventory isan indication of a degraded NCS barrier and is considered to be a potential loss ofthe barrier." The loss of subcooling is the fundamental indication that the inventory loss fromthe primary system exceeds the capacity of the inventory control systems.

If theloss of subcooling is indicated, the NCS barrier is considered lost.4.1.N.3 SG Tube Rupture" Small Steam Generator tube leaks may result in the inability to maintain normalliquid inventory within the Reactor Coolant System (NCS) by operation of theChemical and Volume Control System, which is considered as one centrifugal charging pump discharging to the charging header with the letdown line isolated.

If letdown cannot be isolated, and a second charging pump is required, this is stillconsidered a potential loss of the NCS barrier.

The need for compensatory actionto maintain normal liquid inventory is an indication of a degraded NCS barrierand is considered to be a potential loss of the barrier.* A tube rupture with an unisolable secondary line fault is generally indicated by areduction in primary coolant inventory, increased secondary radiation levels, andan uncontrolled or complete depressurization of the ruptured SG. This set ofconditions represents a loss of the NCS and containment fission product barriers.

In conjunction with containment barrier loss #4, this condition will result in theRev. 14-5December, 2014D12 declaration of a Site Area Emergency.

Escalation to a General Emergency wouldbe indicated by at least a potential loss of the fuel clad barrier.Secondary radiation increases should be observed via radiation monitoring ofCondenser Air Ejector Discharge, SG Blowdown, Main Steam, and/or SGSampling System. Determination of the "uncontrolled" depressurization of theruptured SG should be based on indication that the pressure decrease in theruptured steam generator is not a function of operator action. This should preventdeclaration based on a depressurization that results from an EOP inducedcooldown of the NCS that does not involve the prolonged release of contaminated secondary coolant from the affected SG to the environment.

This EAL shouldencompass steam breaks, feed breaks, and stuck open safety or relief valves.These conditions represents a loss of the NCS and containment fission productbarriers.

4.1.N.4 Containment Radiation Monitoring

• This EAL has been deleted for the following reasons.

The containment processradiation monitors (EMF-38, 39, and 40) serve to provide early indication ofreactor coolant (NC) leaks in containment to ensure compliance with Technical Specifications and Selected Licensee Commitments.

These monitors alarm onsmall NC leaks in and below the Unusual Event (IC 4.2.U.4) range. Also, thesemonitors automatically isolate on a safety injection.

For these reasons, it is notappropriate to use these monitors as an indication of a loss of the reactor coolantsystem barrier.

The reactor building monitors (EMF-5 1 A and 51 B) used for theFuel Clad EAL 4.1 .F.3 are not able to indicate clearly the lower levels of activityin containment resulting from a leak of reactor coolant with normal activitylevels. Thus, this EAL will be omitted and other indication will be used todetermine a potential loss or loss of the Reactor Coolant System Barrier.4.1.N.5 Emergency Coordinator/EOF Director Judgement This EAL addresses any other factors that are to be used by the Emergency Coordinator/EOF Director in determining whether the NCS barrier is lost orpotentially lost. In addition, the inability to monitor the barrier should also beincorporated in this EAL as a factor in Emergency Coordinator/EOF Directorjudgement that the barrier may be considered lost or potentially lost.FUEL CLAD BARRIER EALs:The Fuel Clad Barrier is the zircalloy tubes that contain the fuel pellets.4.1.F.1 Critical Safety Function StatusRev. 14-5December, 2014D13

" Core Cooling -ORANGE indicates subcooling has been lost and that some claddamage may occur. Heat Sink -RED indicates the ultimate heat sink function isunder extreme challenge.

Either of these conditions indicate a potential loss ofthe Fuel Clad Barrier." Core Cooling -RED indicates significant reactor coolant superheating and coreuncovery.

Clad damage under these conditions is likely; therefore, this isindication of loss of the Fuel Clad Barrier.4.1.F.2 Primary Coolant Activity Level" There is no equivalent "Potential Loss" EAL for this item.* The value of 300 ýtCi/cc 1-131 equivalent coolant activity is well above thatexpected for iodine spikes and corresponds to about 2% to 5% fuel clad damage.This amount of clad damage indicates significant clad damage and thus the FuelClad Barrier is considered lost.4.1.F.3 Containment Radiation Monitoring

" There is no "Potential Loss" EAL associated with this item.NOTE: If EMF-51A and EMF-51B are unavailable, readings can be calculated from procedure HP/0/B/1 009/02, "Alternative Method for determining DoseRates within the Reactor Building."

" These values indicate the release of reactor coolant, with elevated activityindicative of fuel damage, into the containment.

Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within technical specifications and aretherefore indicative of fuel damage (approximately 5% clad failure depending oncore inventory and NCS volume).

This EAL indicates a loss of both the fuel cladbarrier and a loss of NCS barrier.4.1.F.4 Emergency Coordinator/EOF Director Judgement This EAL addresses any other factors that are to be used by the Emergency Coordinator/EOF Director in determining whether the Fuel Clad barrier is lost or potentially lost. In addition, the inability to monitor the barrier should also be incorporated in this EAL as a factor inEmergency Coordinator/EOF Director judgement that the barrier may be considered lost orpotentially lost.

REFERENCE:

NUMARC/NESP-O07, REV. 2, 01/92, BASIS INFORMATION FOR TABLE 4Rev. 14-5December, 2014D14 ENCLOSURE 4.2SYSTEM MALFUNCTIONS UNUSUAL EVENTALERT4.2.U.1 Inability to ReachRequired ShutdownWithin Technical Specification Limits.4.2.U.2 Unplanned Loss of Mostor All Safety SystemAnnunciation or Indication in the Control Room forGreater Than 15 Minutes.4.2.U.3 Fuel Clad Degradation.

4.2.U.4 Reactor Coolant System(NCS) Leakage.4.2.U.5 Unplanned Loss of AllOnsite or OffsiteCommunications.

4.2.A.1 Unplanned Loss of Mostor All Safety SystemAnnunciation or Indication in Control Room WithEither (1) a Significant Transient in Progress, or(2) Compensatory Non-Alarming Indicators Unavailable.

SITE AREA EMERGENCY 4.2.S.1 Inability to Monitor aSignificant Transient inProgress.

GENERAL EMERGENCY N/ARev. 14-5December, 2014D15 ENCLOSURE 4.2SYSTEM MALFUNCTIONS UNUSUAL EVENT4.2.U.1 Inability to Reach Required Shutdown Within Technical Specification Limits.OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:4.2.U.1-1 Plant is not brought to required operating mode within Technical Specifications LCOAction Statement Time.BASIS:Limiting Conditions of Operation (LCOs) require the plant to be brought to a required shutdownmode when the Technical Specification required configuration cannot be restored.

Depending on the circumstances, this may or may not be an emergency or precursor to a more severecondition.

In any case, the initiation of plant shutdown required by the site Technical Specifications requires a one hour report under 10 CFR 50.72 (b) Non-emergency events. Theplant is within its safety envelope when being shut down within the allowable action statement time in the Technical Specifications.

An immediate Notification of an Unusual Event is requiredwhen the plant is not brought to the required operating mode within the allowable actionstatement time in the Technical Specifications.

Declaration of an Unusual Event is based onthe time at which the LCO-specified action statement time period elapses under the siteTechnical Specifications and is not related to how long a condition may have existed.

Otherrequired Technical Specification shutdowns that involve precursors to more serious events areaddressed by other System Malfunction,

Hazards, or Fission Product Barrier Degradation ICs.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, SU2Rev. 14-5December, 2014D16 SYSTEM MALFUNCTIONS UNUSUAL EVENT4.2.U.2 Unplanned Loss of Most or All Safety System Annunciation or Indication inthe Control Room for Greater Than 15 Minutes.OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:4.2.U.2-1 The following conditions exist:a. Unplanned loss of most (>50%) annunciators associated with safety systemsfor greater than 15 minutes.ANDb. In the opinion of the Operations Shift Manager/Emergency Coordinator/EOF

Director, the loss of the annunciators or indicators requires additional personnel (beyond normal shift compliment) to safely operate the unit.BASIS:This IC and its associated EAL are intended to recognize the difficulty associated withmonitoring changing plant conditions without the use of a major portion of the annunciation orindication equipment.

"Unplanned" loss of annunciators or indicator excludes scheduled maintenance and testing activities.

Quantification of "most" is arbitrary;

however, thisjudgement is supported by the specific opinion of the Operations Shift Manager/Emergency Coordinator/EOF Director that additional operating personnel will be required to provideincreased monitoring of system operation to safely operate the unit. Fifteen minutes wasselected as a threshold to exclude transient or momentary power losses.This Unusual Event will be escalated to an Alert if a transient is in progress during the loss ofannunciation or indication.

Due to the limited number of safety systems in operation during cold shutdown, refueling, anddefueled modes, no IC is indicated during these modes of operation.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SU3Rev. 14-5December, 2014D17 SYSTEM MALFUNCTIONS UNUSUAL EVENT4.2.U.3 Fuel Clad Degradation.

OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

Mode 5 (Cold Shutdown)

EMERGENCY ACTION LEVEL:4.2.U.3-1 Dose Equivalent 1-131 greater than the Technical Specification allowable limit.BASIS:This IC is included as an Unusual Event because it is considered to be a potential degradation inthe level of safety of the plant and a potential precursor of more serious problems.

The EALaddresses coolant samples exceeding coolant technical specifications for iodine spike.Escalation of this IC to the Alert level is via the Fission Product Barrier Degradation Monitoring ICs. This EAL applies in Modes 1, 2, 3, 4, and 5

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, SU4Rev. 14-5December, 2014D18 SYSTEM MALFUNCTIONS UNUSUAL EVENT4.2.U.4 Reactor Coolant System (NCS) Leakage.OPERATING MODE APPLICABILITY:

Mode 1 (Power Operations)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVELS:4.2.U.4-1 Unidentified leakage>

10 gpm.4.2.U.4-2 Pressure boundary leakage > 10 gpm.4.2.U.4-3 Identified leakage > 25 gpm.BASIS:This IC is included as an Unusual Event because it may be a precursor of more serious conditions and, as aresult, is considered to be a potential degradation of the level of safety of the plant. NCS leakage isleakage into the containment area or outside the containment area from the Reactor Coolant PressureBoundary (RCPB). The RCPB is defined by 1OCFR50.2 (Definitions) and from this definition the RCPBapplicability at McGuire is:RCPB means all those pressure-containing components of pressurized water-cooled

reactors, such aspressure

vessels, piping, pumps, and valves, which are:1. Part of the Reactor Coolant System, or2. Connected to the Reactor Coolant System, up to and including any and all of the following:

a. The outermost containment isolation valve in system piping which penetrates containment,

b. The second of two valves normally closed during normal reactor operation in system pipingwhich does not penetrate containment (MNS has not currently identified any examples),

c. The pressurizer safety valves and PORVs.Interconnected system leakage (ie: letdown, RHR) that can be easily detected and readily isolated is notincluded in this IC. This IC applies to any leak source that cannot be readily detected or isolated (ie:intersystem LOCA, letdown that cannot be isolated).

NCS leakage, identified and unidentified, are used inthis IC as their Tech Spec definitions.

The 10 gpm value for the unidentified and pressure boundaryleakage was 'selected as it is observable with normal control room indications.

Lesser values mustgenerally be determined through time-consuming surveillance tests (e.g., mass balances).

The EAL foridentified leakage is set at a higher value due to the lesser significance of identified leakage in comparison to unidentified or pressure boundary leakage.

In either case, escalation of this IC to the Alert level is viaFission Product Barrier Degradation ICs or IC, "Inability to Maintain Plant in Cold Shutdown."

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SU5Rev. 14-5December, 2014D19 SYSTEM MALFUNCTIONS UNUSUAL EVENT4.2.U.5 Unplanned Loss of All Onsite or Offsite Communications.

OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:4.2.U.5-1 Loss of all onsite communications capability (internal phone system, PA system,onsite radio system) affecting the ability to perform routine operations.

4.2.U.5-2 Loss of all offsite communications capability (DEMNET, NRC ETS lines, offsiteradio system, commercial phone system) affecting the ability to communicate withoffsite authorities.

BASIS:The purpose of this IC and its associated EALs is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate problems with offsite authorities.

The loss ofoffsite communications ability is expected to be significantly more comprehensive than thecondition addressed by 10 CFR 50.72.This EAL is intended to be used only when extraordinary means are being utilized to makecommunications possible (relaying of information from radio transmissions, individuals beingsent to offsite locations, etc.).

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, SU6Rev. 14-5December, 2014D20 SYSTEM MALFUNCTIONS ALERT4.2.A.1 Unplanned Loss of Most or All Safet, System Annunciation or Indication inControl Room With Either (1) a Significant Transient in Progress, or (2)Compensatory Non-Alarming Indicators Unavailable.

OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:4.2.A.1-1 The following conditions exist:a. Unplanned loss of most (>50%) annunciators associated with safety systemsfor greater than 15 minutes.ANDb. In the opinion of the Operations Shift Manager/Emergency Coordinator/EOF

Director, the loss of the annunciators or indicators requires additional personnel (beyond normal shift compliment) to safely operate the unit.ANDc. Either of the following:

• A significant plant transient is in progress.

• Loss of the Operator Aid Computer (OAC).BASIS:This IC and its associated EAL are intended to recognize the difficulty associated withmonitoring changing plant conditions without the use of a major portion of the annunciation orindication equipment during a transient.

Quantification of "Most" is arbitrary;

however, thisjudgement is supported by the specific opinion of the Operations Shift Manager/Emergency Coordinator/EOF Director that additional operating personnel will be required to provideincreased monitoring of system operation to safely operate the unit. Fifteen minutes wasselected as a threshold to exclude transient or momentary power losses.Rev. 14-5December, 2014D21 "Significant Transient" includes response to automatic or manually initiated functions such asreactor trips, runbacks involving greater than 25% thermal power change, ECCS injections, orthermal power oscillations of 10% or greater.Significant indication is available from the OAC. Loss of the OAC in conjunction with the lossof other indications would further impair the ability to monitor plant parameters.

Due to the limited number of safety systems in operation during cold shutdown, refueling anddefueled modes, no IC is indicated during these modes of operation.

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor thetransient in progress.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, SA4Rev. 14-5December, 2014D22 SYSTEM MALFUNCTIONS SITE AREA EMERGENCY 4.2.S.1 Inability to Monitor a Significant Transient in Progress.

OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:4.2.S.1-1 The following conditions exist:a. Loss of most (>50%) annunciators associated with safety systems.ANDb. A significant plant transient is in progress.

ANDc. Loss of the OAC.ANDd. Inability to provide manual monitoring of any of the following Critical SafetyFunctions:

• subcriticality

• core cooling* heat sink* containment.

BASIS:This IC and its associated EAL are intended to recognize the inability of the control room staff tomonitor the plant response to a transient.

A Site Area Emergency is considered to exist if thecontrol room staff cannot monitor safety functions needed for protection of the public."Significant Transient" includes response to automatic or manually initiated functions such astrips, runbacks involving greater than 25% thermal power change, ECCS injections, or thermalpower oscillations of 10% or greater.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, SS6Rev. 14-5December, 2014D23 SYSTEM MALFUNCTIONS GENERAL EMERGENCY Not Applicable Rev. 14-5December, 2014D24 ENCLOSURE 4.3ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENTUNUSUAL EVENTALERTSITE AREA EMERGENCY 4.3.U.1 Any Unplanned Releaseof Gaseous or LiquidRadioactivity to theEnvironment thatExceeds Two Times theSLC Limits for 60 Minutesor Longer.4.3.U.2 Unexpected Increase inPlant Radiation orAirborne Concentration.

4.3.A.1 Any Unplanned Release 4.3.S.1of Gaseous or LiquidRadioactivity to theEnvironment thatExceeds 200 Times theSLC Limits for 15 Minutesor Longer.Boundary Dose Resulting from an Actual orImminent Release ofRadioactivity thatExceeds 100 mRemTEDE or 500 mRem CDEAdult Thyroid for theActual or Projected Duration of the Release.GENERAL EMERGENCY 4.3.G.1 Boundary Dose Resulting from an Actual orImminent Release ofRadioactivity thatExceeds 1000 mRemTEDE or 5000 mRemCDE Adult Thyroidfor the Actual orProjected Duration of the Release.4.3.A.2 Major Damage toIrradiated Fuel or Loss ofWater Level that Has orWill Result in theUncovering of Irradiated Fuel Outside the ReactorVessel.4.3.A.3 Release of Radioactive Material or Increases inRadiation Levels Withinthe Facility That ImpedesOperation of SystemsRequired to MaintainSafeOperations or to Establish or Maintain ColdShutdown.

Rev. 14-5December, 2014D25 ENCLOSURE 4.3ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENTUNUSUAL EVENT4.3.U.1 Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds Two Times the SLC Limits for 60 Minutes or Longer.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:NOTE: If monitor reading is sustained for the time period indicated in the EALsAND the required assessments (procedure calculations) cannot be completed withinthis period, declaration must be made based on the valid radiation monitor reading.4.3.U.1-1 A valid indication on radiation monitor EMF-49L, EMF-44L, or EMF-31 (whenaligned to RC) of> 5.45E+06 cpm for > 60 minutes or will likely continue for >60minutes, which indicates that the release may have exceeded the initiating condition and indicates the need to assess the release with procedure AD-EP-ALL-0202.

4.3.U.1-2 A valid indication on radiation monitor EMF-36L of> 2.05E+04 cpm for > 60minutes or will likely continue for >60 minutes, which indicates that the release mayhave exceeded the initiating condition and indicates the need to assess the releasewith procedure HP/0/B/ 1009/010 or AD-EP-ALL-0202.

4.3.U.1-3 A valid indication on radiation monitor EMF-31 (when aligned to WC or WWCB) of>_ 9.174E+03 cpm for _ 60 minutes or will likely continue for >60 minutes, whichindicates that the release may have exceeded the initiating condition and indicates theneed to assess the release with procedure HP/0/B/1009/010 or AD-EP-ALL-0202.

4.3.U.1-4 Gaseous effluent being released exceeds two times SLC 16.11-6 for > 60 minutes asdetermined by Radiation Protection (RP) procedure.

4.3.U.1-5 Liquid effluent being released exceeds two times SLC 16.11-1 for > 60 minutes asdetermined by Radiation Protection (RP) procedure.

Rev. 14-5December, 2014D26 BASIS:The term "Unplanned",

as used in this context, includes any release for which a liquid wasterelease (LWR) or gaseous waste release (GWR) package was not prepared, or a release thatexceeds the conditions (e.g., minimum dilution flow, maximnum discharge flow, alarm set points,etc.) on the applicable package.Valid means that a radiation monitor reading has been confirnmed to be correct.Unplanned releases in excess of two times the site Selected Licensee Commitments (SLC) thatcontinue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. It is not intended that the release be averaged over 60 minutes.The event should be declared as soon as it is determined that the release duration has or willlikely exceed 60 minutes.The gaseous release rate SLC and Technical Specification (TS) are based on limiting gaseousrelease rates to the SITE BOUNDARY to 500 mr/year total body.The liquid release rate SLC and TS are based on limiting liquid release rates to theUNRESTRICTED AREA to 10 times the Effluent Concentration (EC) valves given inIOCFR20.1001-20.2401, Appendix B, Table 2, Column 2.Monitor indications are based on the methodology of the site Offsite Dose Calculation Manual(ODCM). Annual average meteorology has been used. Radiation Protection will useHP/0/B/1009/010, "Release of Radioactive Effluents Exceeding Selected LicenseeCommitments"or AD-EP-ALL-0202 "Emergency Response Offsite Dose Assessments" toquantify a release.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, AU1Rev. 14-5December, 2014D27 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENTUNUSUAL EVENT4.3.U.2 Unexpected Increase in Plant Radiation or Airborne Concentration.

OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:4.3.U.2-1 Indication of uncontrolled water level decrease of greater than 6 inches in the reactorrefueling cavity with all irradiated fuel assemblies remaining covered by water.4.3.U.2-2 Uncontrolled water level decrease of greater than 6 inches in the spent fuel pool andfuel transfer canal with all irradiated fuel assemblies remaining covered by water.4.3.U.2-3 Unplanned valid area EMF reading exceeds the levels shown in Enclosure 4.10 ofRP/0/A/5700/000.

BASIS:Valid means that a radiation monitor reading has been confirmed to be correct.All of the above events tend to have long lead times relative to potential for radiological release outside the site boundary; thus, impact to public health and safety is very low.In light of reactor cavity seal failure incidents, explicit coverage of these types of events viaEALs 1 and 2 is appropriate given their potential for increased doses to plant staff. Athreshold value of 6 inches is used to allow time for mitigating actions to successfully terminate the inventory loss. Credit should not be taken for inventory additions to maintainlevel above the 6 inch threshold.

Classification as an Unusual Event is warranted as aprecursor to a more serious event.EAL 3 addresses unplanned increases in in-plant radiation levels that represent a degradation in the control of radioactive

material, and represent a potential degradation in the level ofsafety of the plant. The EMF readings for an Unusual Event are 1000 times the normalvalue. Enclosure 4.10 of RP/0/A/5700/000 will provide the actual readings for thesemonitors.

This EAL escalates to an Alert if the increases impair safe operation.

REFERENCE:

NUMARC/NESP-0 7, REV. 2, 01/92, A U2Rev. 14-5December, 2014D28 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENTALERT4.3.A.1 Any Unplanned Release of Gaseous or Liquid Radioactivity to theEnvironment that Exceeds 200 Times the SLC limits for 15 Minutes orLonger.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:NOTE: If monitor reading is sustained for the time period indicated in the EALsAND the required assessments (procedure calculations) cannot be completed withinthis period, declaration must be made based on the valid radiation monitor reading.4.3.A.1-1 A valid indication on radiation monitor EMF-49H of>_ 1.56E+03 cpm for >_ 15minutes or will likely continue for >15 minutes, which indicates that the release mayhave exceeded the initiating condition and indicates the need to assess the releasewith procedure HP/0/B/1 009/010 or AD-EP-ALL-0202.

4.3.A.1-2 A valid indication on radiation monitor EMF-36L of> 2.05E+06 cpm for > 15minutes or will likely continue for >_15 minutes, which indicates that the release mayhave exceeded the initiating condition and indicates the need to assess the releasewith procedure HP/0/B/1 009/010 or AD-EP-ALL-0202.

4.3.A.1-3 Gaseous effluent being released exceeds 200 times the level of SLC 16.11-6 for > 15minutes as determined by Radiation Protection (RP) procedure.

4.3.A.1-4 Liquid effluent being released exceeds 200 times the level of SLC 16.11-1 for > 15minutes as determined by Radiation Protection (RP) procedure.

BASIS:The term "Unplanned",

as used in this context, includes any release for which a liquid wasterelease (LWR) or gaseous waste release (GWR) package was not prepared, or a release thatexceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm set points,etc.) on the applicable package.Valid means that a radiation monitor reading has been confirmed to be correct.This event escalates from the Unusual Event by escalating the magnitude of the release by afactor of 100.Rev. 14-5December, 2014D29 It is not intended that the release be averaged over 15 minutes.

The event should be declared assoon as it is determined that the release duration has or will likely exceed 15 minutes.The gaseous release rate SLC and Technical Specification (TS) are based on limiting gaseousrelease rates to the SITE BOUNDARY to 500 mr/year total body.The liquid release rate SLC and TS are based on limiting liquid release rates to theUNRESTRICTED AREA to 10 times the Effluent Concentration (EC) valves given in10CFR20.1001-20.2401, Appendix B, Table 2, Column 2.Monitor indications are based on the methodology of the site Offsite Dose Calculation Manual(ODCM). Annual average meteorology has been used. Radiation Protection will useHP/0/B/1 009/010, "Release of Radioactive Effluents Exceeding Selected LicenseeCommitments,"

or AD-EP-ALL-0202 "Emergency Response Offsite Dose Assessment" toquantify a release.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, AAIRev. 14-5December, 2014D30 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENTALERT4.3.A.2 Major Damage to Irradiated Fuel or Loss of Water Level that Has or WillResult in the Uncovering of Irradiated Fuel Outside the Reactor Vessel.Does not apply to spent fuel in dry cask storage.

Refer to basis for additional information.

OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:4.3.A.2-1 An unplanned valid trip II alarm on any of the following radiation monitors:

a. Spent Fuel Building Refueling BridgeIEMF-172EMF-4.b. Spent Fuel Pool Ventilation 1EMF-422EMF-42.c. Reactor Building Refueling Bridge1EMF-16 (Applies to Mode 6 and No Mode Only)2EMF-3 (Applies to Mode 6 and No Mode Only).d. Containment Noble Gas Monitors1EMF-39 (Applies to Mode 6 and No Mode Only)2EMF-39 (Applies to Mode 6 and No Mode Only).4.3.A.2-2 Plant personnel report that water level drop in reactor refueling cavity, spent fuelpool, or fuel transfer canal has or will exceed makeup capacity such that anyirradiated fuel will become uncovered.

4.3.A.2-3 NC system wide range level < 358 inches after initiation of NC system make-up.ANDAny irradiated fuel assembly not capable of being lowered into spent fuel pool orreactor vessel.Rev. 14-5December, 2014D31 4.3.A.2-4 Spent Fuel Pool or Fuel Transfer Canal level decrease of>2 feet after initiation ofmake-up.ANDAny irradiated fuel assembly not capable of being fully lowered into the spentfuel pool racks or transfer canal fuel transfer system basket.BASIS:This IC applies to spent fuel requiring water coverage and does not apply to spent fuel in drycask storage.

There is time available to take corrective

actions, and there is little potential forsubstantial fuel damage. Thus, an Alert Classification for this event is appropriate.

Escalation, if appropriate, would occur via Abnormal Rad Level/Radiological Effluent orEmergency Coordinator/EOF Director Judgement.

The intent of the "does not apply to spent fuel in dry cask storage" statement is to ensure thatspent fuel in dry cask storage is not considered for application under Initiating Condition 4.3.A.2.Spent fuel in dry cask storage can be defined as spent fuel assemblies stored in an Independent Spent Fuel Storage Installation (ISFSI) cask which has been totally evacuated of liquid coolantand completely sealed to preclude leakage to the environment.

It is NOT the intent of the "does not apply to spent fuel in dry cask storage" statement toeliminate any or all consideration of Initiating Condition 4.3.A.2 where spent fuel or otherequipment is being manipulated to support loading, evacuating,

sealing, or preparing a dry caskfor transportation to the ISFSI pads. Several examples of this include:1) Spent fuel is physically damaged during handling operations to support loading a cask withspent fuel, resulting in a valid trip II alarm on a listed radiation monitor.

EAL 4.3.A.2-1 wouldapply in this case.2) A dry cask which has been loaded, evacuated, and sealed is tipped over or dropped greaterthan 12 inches while still in the Spent Fuel Building, resulting in a valid trip II alarm on a listedradiation monitor.

In this case, EAL 4.3.A.2-1 would not apply, but EAL 4.7.U. 1-6 Independent Spent Fuel Cask tipped over or dropped greater than 12 inches would apply because the cask hasbeen loaded, evacuated, and sealed as a unit.3) During dry cask operations, actual spent fuel damage occurs prior to evacuating and sealingthe cask due to other unassociated events, resulting in a valid trip II alarm on a listed radiation monitor.

EAL 4.3.A.2-1 would apply in this case.The key to evaluating such an event is when the spent fuel damage occurs. After a dry cask hasbeen evacuated and sealed, this IC does not apply, but IC 4.7.U. 1 could apply. Damage to spentfuel that may occur in the dry cask storage process prior to completion of evacuation and sealingof the dry cask should be considered under this IC.Rev. 14-5December, 2014D32 EAL 2: Due to concerns for ALARA and personnel safety, personnel should not remain inthe area to observe that irradiated fuel is uncovered.

Personnel should exit the area asquickly as possible and report the occurrence to the Control Room.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, AA2Rev. 14-5December, 2014D33 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENTALERT4.3.A.3 Release of Radioactive Material or Increases in Radiation Levels Within theFacility That Impedes Operation of Systems Required to Maintain SafeOperations or to Establish or Maintain Cold Shutdown.

OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:4.3.A.3-1 Valid reading on EMF-12 greater than 15 mR/1hr in the Control Room.4.3.A.3-2 Valid indication of radiation levels greater than 15 mR/hr in the Central AlarmStation (CAS) or Secondary Alarn Station (SAS).4.3.A.3-3 Valid area EMF reading exceeds the limits shown in Enclosure 4.10 ofRP/0/A/5700/000.

BASIS:Valid means that a radiation monitor reading has been confirmed to be correct.This initiating condition (IC) addresses increased radiation levels that impede necessary access tooperating

stations, or other areas containing equipment that must be operated

manually, in orderto maintain safe operation or perform a safe shutdown.

It is this impaired ability to operate theplant that results in the actual or potential substantial degradation of the level of safety of theplant. This situation is indicative of a significant radiological problem that warrants additional resources to assess and mitigate.

This IC is not intended to apply to anticipated temporary increases due to planned events (e.g., incoredetector

movement, radwaste container

movement, depleted resin transfers, etc.)The Control Room, CAS, and SAS are areas that require continuous occupancy.

The value of 15mR/hr is derived from the GDC 19 (general design criteria) value of 5 Rem in 30 days withadjustment for expected occupancy times.Rev. 14-5December, 2014D34 McGuire has chosen to use a generic emergency action level of greater than or equal to 5000mRad/hr for areas in the plant that are nomally accessible as low dose rate areas that haveequipment installed,

operated, and used for safe operation or safe shutdown of the unit.Radiation levels at or above this range may make it difficult to complete tasks necessary for safeoperation of the plant or to establish or maintain cold shutdown without exceeding normaloccupational dose limits of 5 Rein per year TEDE. Enclosure 4.10 of RP/O/A/5700/000 providesthe monitor number and the location of the area monitor.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, AA3Rev. 14-5December, 2014D35 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENTSITE AREA EMERGENCY 4.3.S.1 Boundary Dose Resulting from an Actual or Imminent Release ofRadioactivity that Exceeds 100 mRem TEDE or 500 mRem CDE AdultThyroid for the Actual or Projected Duration of the Release.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:NOTE 1: These EMF readings are calculated based on average annual meteorology, site boundary dose rate, and design unit vent flow rate. Calculations by the doseassessment team use actual meteorology, release duration, and unit vent flow rate.Therefore, these EMF readings should not be used if dose assessment teamcalculations are available.

NOTE 2: If dose assessment team calculations cannot be completed in 15minutes, then valid monitor readings should be used for emergency classification.

4.3.S.1-1 A valid indication on radiation monitor EMF-36H of>_ 3.4E +03 cpm sustained for > 15 minutes.4.3.S.1-2 Dose assessment team calculations indicate dose consequences greater than 100mRem TEDE or 500 mRem CDE Adult Thyroid at the site boundary.

4.3.S.1-3 Analysis of field survey results or field survey samples indicates doseconsequences greater than 100 mRem TEDE or 500 mRem CDE Adult Thyroid atthe site boundary.

BASIS:Valid means that a radiation monitor reading has been confirmed to be correct.The 100 mRem integrated dose in this initiating condition is based on 10 CFR 20 annualaverage population exposure.

This value also provides a desirable gradient (one order ofmagnitude) between the Alert, Site Area Emergency, and General Emergency classes.

Thesevalues are 10% of the EPA Protective Action Guide (PAG) values given in EPA-400-R 001.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, AS]Rev. 14-5December, 2014D36 ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENTGENERAL EMERGENCY 4.3.G.1 Boundary Dose Resulting from an Actual or Imminent Release ofRadioactivity that Exceeds 1000 mRem TEDE or 5000 niRem CDE AdultThyroid for the Actual or Projected Duration of the Release.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:NOTE 1: These EMF readings are calculated based on average annual meteorology, site boundary dose rate, and design unit vent flow rate. Calculations by the doseassessment team use actual meteorology, release duration, and unit vent flow rate.Therefore, these EMF readings should not be used if dose assessment teamcalculations are available.

NOTE 2: If dose assessment team calculations cannot be completed in 15minutes, then valid monitor readings should be used for emergency classification.

4.3.G.1-1 A valid indication on radiation monitor EMF-36H of>_ 3.4 E +04 cpm sustained for > 15 minutes.4.3.G.1-2 Dose assessment team calculations indicate dose consequences greater than 1000mRem TEDE or 5000 mRem CDE Adult Thyroid at the site boundary.

4.3.G.1-3 Analysis of field survey results or field survey samples indicates doseconsequences greater than 1000 mRem TEDE or 5000 mRem CDE Adult Thyroidat the site boundary.

BASIS:Valid means that a radiation monitor reading has been confirmed to be correct.The 1000 mRem TEDE and 5000 mRem CDE thyroid integrated doses are based on the EPAPAG values given in EPA-400-R-92-00 1, which indicates that public protective actions areindicated if doses exceed these values. This is consistent with the emergency classdescription of a general emergency.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, AG]Rev. 14-5December, 2014D37 ENCLOSURE 4.4LOSS OF SHUTDOWN FUNCTIONS UNUSUAL EVENTN/AALERT4.4.A.1 Failure of ReactorProtection SystemInstrumentation toComplete or Initiate anAutomatic Reactor TripOnce a ReactorProtection SystemSetpoint Has BeenExceeded and ManualTrip WAS Successful.

4.4.A.2 Inability to Maintain Plantin Cold Shutdown.

SITE AREA EMERGENCY 4.4.S.1 Failure of ReactorProtection System Instrumentation to Complete or Initiate anAutomatic Reactor TripOnce a ReactorProtection SystemSetpoint Has BeenExceeded and ManualTrip WAS NOTSuccessful.

4.4.S.2 Complete Loss ofFunction Needed toAchieve or Maintain HotShutdown.

4.4.S.3 Loss of Water Level inthe Reactor Vessel ThatHas or Will Uncover Fuelin the Reactor Vessel.GENERAL EMERGENCY 4.4.G.1 Failure of the ReactorProtection System toComplete an Automatic Trip and Manual TripWAS NOT Successful and There is Indication ofan Extreme Challenge tothe Ability to Cool theCore.Rev. 14-5December, 2014D38 ENCLOSURE 4.4LOSS OF SHUTDOWN FUNCTIONS UNUSUAL EVENTNot Applicable Rev. 14-5December, 2014D39 LOSS OF SHUTDOWN FUNCTIONS ALERT4.4.A.1 Failure of Reactor Protection System Instrumentation to Complete or Initiate anAutomatic Reactor Trip Once a Reactor Protection System Setpoint Has BeenExceeded and Manual Trip WAS Successful.

OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)EMERGENCY ACTION LEVEL:4.4.A.1-1 The following conditions exist:a. Valid reactor trip signal received or required and automatic reactor trip was notsuccessful.

ANDb. Manual reactor trip from the control room is successful and reactor power isless than 5% and decreasing.

BASIS:This condition indicates failure of the automatic protection system to trip the reactor.

Thiscondition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient and thus the plant safety hasbeen compromised, and design limits of the fuel may have been exceeded.

An Alert is indicated because conditions exist that lead to potential loss of fuel clad or NCS. Reactor protection system setpoint being exceeded (rather than limiting safety system setpoint being exceeded) isspecified here because failure of the automatic protection system is the issue. A manual trip isany set of actions by the reactor operator(s) at the reactor control console which causes controlrods to be RAPIDLY inserted into the core and brings the reactor subcritical.

Operator action todrive rods does NOT constitute a reactor trip, i.e. does not meet the rapid insertion criterion.

Failure of manual trip would escalate the event to a Site Area Emergency.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, SA2Rev. 14-5December, 2014D40 LOSS OF SHUTDOWN FUNCTIONS ALERT4.4.A.2 Inability to Maintain Plant in Cold Shutdown.

OPERATING MODE APPLICABILITY:

Mode 5 (Cold Shutdown)

Mode 6 (Refueling)

EMERGENCY ACTION LEVEL:4.4.A.2-1 Total loss of Residual Heat Removal (ND) and/or Nuclear Service Water (RN) and/orComponent Cooling (KC)ANDOne of the following:

S0Inability to maintain reactor coolant temperature below 200 OFUncontrolled reactor coolant temperature rise to >I 80'F.BASIS:This EAL addresses loss of functions required for core cooling during cold shutdown andrefueling conditions.

This IC and associated EALs are based on concerns raised by GenericLetter 88-17, "Loss of Decay Heat Removal."

A number of phenomena such as pressurization, vortexing, steam generator U-tube draining, NCS level differences when operating at a mid-loopcondition, decay heat removal system design, and level instrumentation problems can lead toconditions where decay heat removal is lost and core uncovery can occur. NRC analyses showthat sequences that can cause core uncovery in 15 to 20 minutes and severe core damage withinan hour after decay heat removal is lost.Escalation to the Site Area Emergency is by, "Loss of Water Level in the Reactor Vessel ThatHas or Will Uncover Fuel in the Reactor Vessel,"

or by Abnormal Rad Levels/Radiological Effluent ICs.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SA3Rev. 14-5December, 2014D41 LOSS OF SHUTDOWN FUNCTIONS SITE AREA EMERGENCY 4.4.S.1 Failure of Reactor Protection System Instrumentation to Complete or Initiate anAutomatic Reactor Trip Once a Reactor Protection System Setpoint Has BeenExceeded and Manual Trip WAS NOT Successful.

OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

EMERGENCY ACTION LEVEL:4.4.S.1-1 The following conditions exist:a. Valid reactor trip signal received or required and automatic reactor trip wasnot successful.

ANDb. Manual reactor trip from the control room was not successful in reducingreactor power to less than 5% and decreasing.

BASIS:Automatic and manual trip are not considered successful if action away from the reactor controlconsole is required to trip the reactor.

This EAL is equivalent to the Subcriticality CSF-RED.Under these conditions, the reactor is producing more heat than the maximum decay heat loadfor which the safety systems are designed.

A Site Area Emergency is indicated becauseconditions exist that lead to imminent loss or potential loss of both fuel clad and NCS. Althoughthis IC may be viewed as redundant to the Fission Product Barrier Degradation IC, its inclusion is necessary to better assure timely recognition and emergency response.

Escalation of this eventto a General Emergency would be via Fission Product Barrier Degradation or Emergency Coordinator/EOF Director Judgement ICs.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, SS2Rev. 14-5December, 2014D42 LOSS OF SHUTDOWN FUNCTIONS SITE AREA EMERGENCY 4.4.S.2 Complete Loss of Function Needed to Achieve or Maintain Hot Shutdown.

OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVELS:4.4.S.2-1 Subcriticality CSF-RED.4.4.S.2-2 Heat Sink CSF-RED.BASIS:This EAL addresses complete loss of functions, including ultimate heat sink and reactivity

control, required for hot shutdown with the reactor at pressure and temperature.

Under theseconditions, there is an actual major failure of a system intended for protection of the public.Thus, declaration of a Site Area Emergency is warranted.

Escalation to General Emergency would be via Abnormal Rad Levels/Radiological

Effluent, Emergency Coordinator/EOF Director Judgement, or Fission Product Barrier Degradation ICs.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SS4Rev. 14-5December, 2014D43 LOSS OF SHUTDOWN FUNCTIONS SITE AREA EMERGENCY 4.4.S.3 Loss of Water Level in the Reactor Vessel That Has or Will Uncover Fuel in theReactor Vessel.OPERATING MODE APPLICABILITY:

Mode 5 (Cold Shutdown)

Mode 6 (Refueling)

EMERGENCY ACTION LEVELS:4.4.S.3-1

a. Failure of heat sink causes loss of cold shutdown conditions.

ANDb. Lower range Reactor Vessel Level Indication System (RVLIS) decreasing afterinitiation of NC system makeup.4.4.S.3-2

a. Failure of heat sink causes loss of cold shutdown conditions.

ANDb. Reactor Coolant (NC) system narrow range level less than 6 inches anddecreasing after initiation of NC system makeup.4.4.S.3-3

a. Failure of heat sink causes loss of cold shutdown conditions.

ANDb. Either train ultrasonic level indication less than 6 inches and decreasing afterinitiation of NC system makeup.BASIS:Under the conditions specified by this IC, severe core damage may be imminent due toprolonged boiling following loss of decay heat removal.Thus, declaration of a Site Area Emergency is warranted under the conditions specified by theIC. Escalation to a General Emergency is via radiological effluent IC.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SS5Rev. 14-5December, 2014D44 LOSS OF SHUTDOWN FUNCTIONS GENERAL EMERGENCY 4.4.G.1 Failure of the Reactor Protection System to Complete an Automatic Trip andManual Trip WAS NOT Successful and There is Indication of an ExtremeChallenge to the Ability to Cool the Core.OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

EMERGENCY ACTION LEVEL:4.4.G.1-1 The following conditions exist:a. Valid reactor trip signal received or required and automatic reactor trip wasnot successful.

ANDb. Manual reactor trip from the control room was not successful in reducingreactor power to less than 5% and decreasing.

ANDc. Either of the following conditions exist:" Core Cooling CSF-RED" Heat Sink CSF-RED.BASISAutomatic and manual trip are not considered successful if action away from the reactor controlconsole is required to trip the reactor.Under the conditions of this IC and its associated EALs, the efforts to bring the reactorsubcritical have been unsuccessful and, as a result, the reactor is producing more heat than themaximum decay heat load for which the safety systems were designed.

The extreme challenge to the ability to cool the core is intended to mean that the core exittemperatures are at or approaching 1200°F or that the reactor vessel water level is below the topof active fuel. This equates to a Core Cooling-RED condition.

Another consideration is the inability to initially remove heat during the early stages of thissequence.

If emergency feedwater flow is insufficient to remove the amount of heat required byRev. 14-5December, 2014D45 design from at least one steam generator, an extreme challenge should be considered to exist.This equates to a Heat Sink-RED condition.

In the event either of these challenges occurs during or following a time that the reactor has notbeen brought below the power associated with the safety system design, core damage may beimminent.

For this reason, the General Emergency declaration is intended to be anticipatory ofthe fission product barrier matrix declaration to penrmit maximum offsite intervention time.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, SG2Rev. 14-5December, 2014D46 ENCLOSURE 4.5LOSS OF POWERUNUSUAL EVENTALERTSITE AREA EMERGENCY GENERAL EMERGENCY 4.5.U.1 Loss of All Offsite Powerto Essential Busses forGreater Than 15 Minutes.4.5.U.2 Unplanned Loss ofRequired DC PowerDuring ColdShutdown or Refueling Mode for Greater than 15Minutes.4.5.A.1 Loss of All Offsite Powerand Loss of All OnsiteAC Power to Essential Busses During ColdShutdown Or Refueling Mode.4.5.A.2 AC Power to Essential Busses Reduced to aSingle Power Source forGreater Than 15 MinutesSuch That an Additional Single Failure CouldResult in StationBlackout.

4.5.S.1 Loss of All Offsite Power 4.5.G.1 Prolonged Loss of Alland Loss of All Onsite AC (Offsite and Onsite) ACPower to Essential Power.Busses.4.5.S.2 Loss of All Vital DCPower.Rev. 14-5December, 2014D47 ENCLOSURE 4.5LOSS OF POWERUNUSUAL EVENT4.5.U.1 Loss of All Offsite Power to Essential Busses for Greater Than 15 Minutes.OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:4.5.U.1-1 The following conditions exist:a. Loss of offsite power to essential buses ETA and ETB for greater than 15minutes.ANDb. Both emergency diesel generators are supplying power to their respective essential busses.OPERATING MODE APPLICABILITY:

Mode 5 (Cold Shutdown)

Mode 6 (Refueling)

No Mode (Defueled)

EMERGENCY ACTION LEVEL:4.5.U.1-2 The following conditions exist:a. Loss of offsite power to essential buses ETA and ETB for greater than 15minutes.ANDb. One emergency diesel generator is supplying power to its respective essential bus.Rev. 14-5December, 2014D48 BASIS:Prolonged loss of AC power reduces required redundancy and potentially degrades the level ofsafety of the plant by rendering the plant more vulnerable to a complete Loss of AC Power(Station Blackout).

When in cold shutdown, refueling, or defueled mode the event can beclassified as an Unusual Event, because of the significantly reduced decay heat, lowertemperature and pressure, increasing the time to restore one of the essential busses, relative tothat specified for the Alert EAL The event will escalate to an Alert in these modes if bothessential busses are lost. Fifteen minutes was selected as a threshold to exclude transient ormomentary power losses.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SUJRev. 14-5December, 2014D49 LOSS OF POWERUNUSUAL EVENT4.5.U.2 Unplanned Loss of Required DC Power During Cold Shutdown or Refueling Mode for Greater than 15 Minutes.OPERATING MODE APPLICABILITY:

Mode 5 (Cold Shutdown)

Mode 6 (Refueling)

EMERGENCY ACTION LEVEL:4.5.U.2-1 The following conditions exist:a. Unplanned loss of both unit related EVDA and EVDD busses as indicated by busvoltage less than 110 VDC.ANDb. Failure to restore power to at least one required DC bus within 15 minutes fromthe time of loss.BASIS:The purpose of this IC and its associated EALs is to recognize a loss of DC power compromising the ability to monitor and control the removal of decay heat during Cold Shutdown or Refueling operations.

This EAL is intended to be anticipatory in as much as the operating crew may nothave necessary indication and control of equipment needed to respond to the loss."Unplanned" is included in this IC and EAL to preclude the declaration of an emergency as aresult of planned maintenance activities.

If this loss results in the inability to maintain cold shutdown, the escalation to an Alert is via"Inability to Maintain Plant in Cold Shutdown."

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, SU7Rev. 14-5December, 2014D50 LOSS OF POWERALERT4.5.A.1 Loss of All Offsite Power and Loss of All Onsite AC Power to Essential BussesDuring Cold Shutdown Or Refueling Mode.OPERATING MODE APPLICABILITY:

Mode 5 (Cold Shutdown)

Mode 6 (Refueling)

No Mode (Defueled)

EMERGENCY ACTION LEVEL:4.5.A.1-1 Loss of all offsite and onsite AC power as indicated by:a. Loss of power on essential buses ETA and ETB.ANDb. Failure to restore power to at least one essential bus within 15 minutes.BASIS:Loss of all AC power compromises all plant safety systems requiring electric power including Residual Heat Removal (RHR), Emergency Core Cooling Systems (ECCS), Containment HeatRemoval, Spent Fuel Heat Removal and the Ultimate Heat Sink. When in cold shutdown, refueling, or defueled mode the event can be classified as an Alert, because of the significantly reduced decay heat, lower temperature and pressure, increasing the time to restore one of theessential busses, relative to that specified for the Site Area Emergency EAL. Escalating to SiteArea Emergency, if appropriate, is by Abnormal Rad Levels/Radiological

Effluent, orEmergency Coordinator/EOF Director Judgement ICs. Fifteen minutes was selected as athreshold to exclude transient or momentary power losses.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, SA1Rev. 14-5December, 2014D51 LOSS OF POWERALERT4.5.A.2 AC Power to Essential Busses Reduced to a Single Power Source for GreaterThan 15 Minutes Such That an Additional Single Failure Could Result inStation Blackout.

OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:4.5.A.2-1 The following condition exists:AC power capability has been degraded to one essential bus powered from a singlepower source for > 15 min. due to the loss of all but one of:SATASATBATCATDD/G AD/G B.BASIS:This IC and the associated EAL is intended to provide an escalation from IC, "Loss of AllOffsite Power To Essential Busses for Greater Than 15 Minutes."

The condition indicated bythis IC is the degradation of the offsite and onsite power systems such that an additional singlefailure could result in a station blackout.

This condition could occur due to a loss of offsitepower with a concurrent failure of one emergency generator to supply power to its essential busses. Another related condition could be the loss of all offsite power and loss of onsiteemergency diesels with only one train of essential busses being back fed from the unit maingenerator, or the loss of onsite emergency diesels with only one train of essential busses beingback fed from offsite power. The subsequent loss of this single power source would escalate theevent to a Site Area Emergency in accordance with IC, "Loss of All Offsite and Loss of AllOnsite AC Power to Essential Busses."

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SA5Rev. 14-5December, 2014D52 LOSS OF POWERSITE AREA EMERGENCY 4.5.S.1 Loss of All Offsite Power and Loss of All Onsite AC Power to Essential Busses.OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:4.5.S.1-1 Loss of all offsite and onsite AC power as indicated by:a. Loss of power on essential buses ETA and ETB.ANDb. Failure to restore power to at least one essential bus within 15 minutes.BASIS:Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of all ACpower will cause core uncovering and loss of containment integrity; thus, this event can escalateto a General Emergency.

Escalation to General Emergency is via Fission Product Barrier Degradation or IC, "Prolonged Loss of All Offsite Power and Prolonged Loss of All Onsite AC Power."

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SS1Rev. 14-5December, 2014D53 LOSS OF POWERSITE AREA EMERGENCY 4.5.S.2 Loss of All Vital DC Power.OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:4.5.S.2-1 The following conditions exist:a. Loss of both unit related EVDA and EVDD busses as indicated by busvoltage less than 110 VDC.ANDb. Failure to restore power to at least one required DC bus within 15 minutesfrom the time of loss.BASIS:Loss of all DC power compromises ability to monitor and control plant safety functions.

Prolonged loss of all DC power will cause core uncovering and loss of containment integrity when there is significant decay heat and sensible heat in the reactor system. Escalation to aGeneral Emergency would occur by Abnormal Rad Levels/Radiological

Effluent, FissionProduct Barrier Degradation, or Emergency Coordinator/EOF Director Judgement ICs. Fifteenminutes was selected as a threshold to exclude transient or momentary power losses.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, SS3Rev. 14-5December, 2014D54 LOSS OF POWERGENERAL EMERGENCY 4.5.G.1 Prolonged Loss of All (Offsite and Onsite) AC Power.OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

EMERGENCY ACTION LEVEL:4.5.G.1-1 Prolonged loss of all offsite and onsite AC power as indicated by:a. Loss of power on essential buses ETA and ETB for greater than 15 minutes.ANDb. Standby Shutdown Facility (SSF) fails to supply NC pump seal injection OR CA supply to steam generators.

ANDc. At least one of the following conditions exist:* Restoration of at least one essential bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is NOT[ likely." Indication of continuing degradation of core cooling based on FissionProduct Barrier monitoring.

BASIS:Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of allthose functions necessary to maintain hot shutdown will lead to loss of fuel clad, NCS, andcontainment.

The SSF is capable of providing the necessary functions (reactor coolant pump seal injection andauxiliary feedwater supply to the steam generators) to maintain a hot shutdown condition for upto 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. No fission product barrier degradation would be expected if the SSF is functioning as intended.

Rev. 14-5December, 2014D55 Analysis in support of the station blackout coping study indicates that the plant can cope with astation blackout for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> without core damage.The likelihood of restoring at least one essential bus should be based on a realistic appraisal ofthe situation since a delay in an upgrade decision based on only a chance of mitigating the eventcould result in a loss of valuable time in preparing and implementing public protective actions.In addition, under these conditions, fission product barrier monitoring capability may bedegraded.

Although it may be difficult to predict when power can be restored, it is necessary togive the Emergency Coordinator/EOF Director a reasonable idea of how quickly (s)he may needto declare a General Emergency based on two major considerations:

I. Are there any present indications that core cooling is already degraded to the point that Lossor Potential Loss of Fission Product Barriers is IMMINENT?

2. If there are no present indications of such core cooling degradation, how likely is it thatpower can be restored in time to assure that a loss of two barriers with a potential loss of thethird barrier can be prevented?

Thus, indication of continuing core cooling degradation must be based on Fission ProductBarrier monitoring with particular emphasis on Emergency Coordinator/EOF Director judgement as it relates to IMMINENT Loss or Potential Loss of fission product barriers and degradedability to monitor fission product barriers.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, SG1Rev. 14-5December, 2014D56 ENCLOSURE 4.6FIRE/EXPLOSION AND SECURITY EVENTSUNUSUALEVENT ALERTSITE AREA EMERGENCY 4.6.S.1 HOSTILE ACTION withinthe PROTECTED AREA4.6.U.1 Fire Within Protected Area Boundary NOTExtinguished Within15 Minutes of Detection OR Explosion Within theProtected AreaBoundary.

4.6.U.2 Confirmed SECURITYCONDITION or threatWhich Indicates aPotential Degradation inthe Level of Safety of thePlant.4.6.U.2 Confirmed SECURITYCONDITION or threatWhich Indicates aPotential Degradation inthe Level of Safety of thePlant.4.6.A.1 Fire or Explosion Affecting the Operability of PlantSafety Systems Requiredto Establish or MaintainSafe Shutdown.

GENERAL EMERGENCY 4.6.G.1 HOSTILE ACTIONResulting in Loss ofPhysical Control o ftheFacility.

4.6.A.2 Fire or Explosion Affecting the Operability of PlantSafety Systems Requiredto Establish or MaintainSafe Shutdown.

4.6.A.2 Fire or Explosion Affecting the Operability of PlantSafety Systems Requiredto Establish or MaintainSafe Shutdown.

4.6.A.3 HOSTILE ACTION withinthe OWNERCONTROLLED AREA orAirborne Attack ThreatRev. 14-5December, 2014D57 ENCLOSURE 4.6FIRE/EXPLOSION AND SECURITY EVENTSUNUSUAL EVENT4.6.U.1 Fire Within Protected Area Boundary Not Extinguished Within 15 Minutes ofDetection OR Explosion Within the Protected Area Boundary.

OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVEL:4.6.U.1-1 Fire in any of the following areas not extinguished within 15 minutes of control roomnotification or verification of a control room fire alann." Reactor Building* Auxiliary Building* Diesel Generator Rooms* Control Room" Standby Shutdown Facility (SSF)" Central Alarm Station (CAS)" Secondary Alarm Station (SAS)" Doghouses

• Refueling Water Storage Tank (FWST)* Turbine Building" Service Building" Interim Radwaste Building" Equipment Staging Building" ISFSI.4.6.U.1-2 Report by plant personnel of an unanticipated explosion within protected areaboundary resulting in visible damage to permanent structures or equipment or to aloaded cask in the ISFSI.BASIS:EAL 1: The purpose of this EAL is to address the magnitude and extent of fires that may bepotentially significant precursors to damage to safety systems.

Fire is combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flames is preferred but is NOT required iflarge quantities of smoke and heat are observed.

This excludes such items as fires withinadministration buildings outside the protected area. Waste-basket fires, and other small fires ofno safety consequence should easily be extinguished within 15 minutes of detection.

This ICapplies to buildings and areas contiguous to plant vital areas or other significant buildings orRev. 14-5December, 2014D58 areas. Verification of the alarm in this context means those actions taken in the control room todetermine that the control room alarm is not spurious.

EAL 2: Only those explosions of sufficient force to damage permanent structures or equipment within the protected area or to a loaded cask in the ISFSI area should be considered.

As usedhere, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure ofpressurized equipment, that potentially imparts significant energy to near-by structures andmaterials.

No attempt is made in this EAL to assess the actual magnitude of the damage. Theoccurrence of the explosion with reports of evidence of damage (e.g., defornation, scorching) issufficient for declaration.

The Emergency Coordinator/EOF Director also needs to consider anysecurity aspects of the explosion, if applicable.

Escalation to a higher emergency class is by, "Fire or Explosion Affecting the Operability ofPlant Safety Systems Required to Establish or Maintain Safe Shutdown".

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) These ICs arecategorized on the basis of the occurrence of an event of sufficient magnitude that a loaded caskCONFINEMENT BOUNDARY is damaged or violated.

This includes classification based on aloaded fuel storage cask CONFINEMENT BOUNDARY loss leading to the degradation of thefuel during storage or posing an operational safety problem with respect to its removal fromstorage.ISFSI Technical Specifications allow time to complete required actions if cask seal integrity isnot maintained; therefore, classification should not be made based on a loss of seal integrity byitself. However, loss of seal integrity coincident with an accident condition affecting a caskwould justify classification.

For these EALs the results of the ISFSI Safety Analysis Report (SAR) per NUREG 1536 wasused to develop the site-specific list of accident conditions.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, HU2, NEI 99-01 (Methodology forDevelopment of Emergency Action Levels) Draft Final Rev 4, McGudre ISFSI Safety AnalysisReport.Rev. 14-5December, 2014D59 FIRE/EXPLOSION AND SECURITY EVENTSUNUSUAL EVENT4.6.U.2 Confirmed SECURITY CONDITION or Threat Which Indicates a Potential Degradation in the Level of Safety of the Plant.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:4.6.U.2-1 A SECURITY CONDITION that does NOT involve a HOSTILE ACTION asreported by the MNS Security shift supervision.

4.6.U.2-2 A credible site-specific security threat notification.

4.6.U.2-3 A validated notification from NRC providing information of an aircraft threat.BASIS:Note: Timely and accurate communication between security shift supervision and the ControlRoom is crucial for the implementation of effective Security EALs.Security events which do not represent a potential degradation in the level of safety of the plantare reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72. Security events assessedas HOSTILE ACTIONS are classifiable under 4.6.A.3, 4.6.S. I and 4.6.G. 1.A higher initial classification could be made based upon the nature and timing of the securitythreat and potential consequences.

The licensee shall consider upgrading the emergency response status and emergency classification level in accordance with the site's Safeguards Contingency Plan and Emergency Plan.EAL #1Reference is made to site specific security shift supervision because these individuals are thedesignated personnel on-site qualified and trained to confirm that a security event is occurring orhas occurred.

Training on security event classifcation confirmation is closely controlled due tothe strict secrecy controls placed on the plant Safeguards Contingency Plan.The threshold is based on site specific security plans. Site specific Safeguards Contingency Plans are based on guidance provided by NEI 03-12.Rev. 14-5December, 2014D60 EAL #2This threshold is included to ensure that appropriate notifications for the security threat are madein a timely manner. This includes information of a credible threat. Only the plant to which thespecific threat is made need declare the Notification of an Unusual Event.The determination of "credible" is made through use of information found in the site specificSafeguards Contingency Plan.EAL #3The intent of this EAL is to ensure that notifications for the aircraft threat are made in a timelymanner and thatOROs and plant personnel are at a state of heightened awareness regarding thecredible threat. It is not the intent of this EAL to replace existing non-hostile related EALsinvolving aircraft.

This EAL is met when a plant receives information regarding an aircraft threat from NRC.Validation is perfonned by calling the NRC or by other approved methods of authentication.

Only the plant to which the specific threat is made need declare the Unusual Event.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an airliner (airliner is meant to be a large aircraft with the potential for causingsignificant damage to the plant). The status and size of the plane may be provided by NORADthrough the NRC.Escalation to Alert emergency classification level would be via 4.6.A.3 would be appropriate ifthe threat involves an airliner within 30 minutes of the plant.

REFERENCE:

NEI 99-01 rev 5, (HU4) Methodology for Developement of Emergency ActionLevels. This change is to support NEI 03-12 implementation.

(PIP G-09-0360]

Rev. 14-5December, 2014D61 FIRE/EXPLOSION AND SECURITY EVENTSALERT4.6.A.1 Fire or Explosion Affecting the Operability of Plant Safety Systems Required toEstablish or Maintain Safe Shutdown.

OPERATING MODE APPLICABILITY:

Mode 1 (Power Operation)

Mode 2 (Startup)

Mode 3 (Hot Standby)Mode 4 (Hot Shutdown)

Mode 5 (Cold Shutdown)

Mode 6 (Refueling)

EMERGENCY ACTION LEVEL:4.6.A.1-1 The following conditions exist:(includes non-security events)a. Fire or explosion in any of the following areas:" Reactor Building* Auxiliary Building* Diesel Generator Rooms" Control Room* Standby Shutdown Facility* CAS* SAS* FWST* Doghouses (Applies in Mode 1, 2, 3, 4 only).ANDb. One of the following:

Note: Only one train of a system needs to be affected or damaged in order to satisfythis condition.

• Affected safety system parameter indications show degraded performance o Plant personnel report visible damage to permanent structures or equipment within the specified area.Rev. 14-5December, 2014D62 BASIS:With regard to explosions, only those explosions of sufficient force to damage permanent structures or equipment required for safe operation within the identified plant area should beconsidered.

As used here, an explosion is a rapid, violent, unconfined combustion, or acatastrophic failure of pressurized equipment, that potentially imparts significant energy to near-by structures and materials.

Fire is combustion characterized by heat and light. Sources ofsmoke such as slipping drive belts or overheated electrical equipment do not constitute fires.Observation of flames is preferred but is NOT required if large quantities of smoke and heat areobserved.

The inclusion of a "report of visible damage" should not be interpreted as mandating alengthy damage assessment prior to classification.

The key to classifying fires/explosions as an Alert is the damage as a result of the incident.

Thefact that safety-related equipment required for safe shutdown of the unit has been affected ordamaged as a result of the fire/explosion is the driving force for declaring the Alert. It isimportant to note that this EAL addresses a fire/explosion and not just the degradation of asafety system. The reference to damage of the systems is used to identify the magnitude ofthe fire/explosion and to discriminate against minor fires/explosions.

Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Levels/Radiological

Effluent, orEmergency Coordinator/EOF Director Judgement ICs.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, HA2Rev. 14-5December, 2014D63 FIRE/EXPLOSION AND SECURITY EVENTSALERT4.6.A.2 Fire or Explosion Affecting the Operability of Plant Safety Systems Required toEstablish or Maintain Safe Shutdown.

OPERATING MODE APPLICABILITY:

No Mode (Defueled)

EMERGENCY ACTION LEVEL:4.6.A.2-1 The following conditions exist:(includes non-security events)a. Fire or explosion in any of the following areas:* Spent Fuel Pool" Auxiliary Building.

ANDb. One of the following:

Note: Only one train of a system needs to be affected or damaged in order tosatisfy this condition.

• Spent Fuel Pool level and/or temperature show degraded performance.

• Plant personnel report visible damage to permanent structures or equipment supporting Spent Fuel Pool cooling.BASIS:In a Defueled condition, the plant safety systems of interest are those that support Spent FuelPool inventory and cooling.With regard to explosions, only those explosions of sufficient force to damage permanent structures or equipment required for safe operation within the identified plant area should beconsidered.

As used here, an explosion is a rapid, violent, unconfined combustion, or acatastrophic failure of pressurized equipment, that potentially imparts significant energy to near-by structures and materials.

Fire is combustion characterized by heat and light. Sources ofsmoke such as slipping drive belts or overheated electrical equipment do not constitute fires.Observation of flames is preferred but is NOT required if large quantities of smoke and heat areRev. 14-5December, 2014D64 observed.

The inclusion of a "report of visible damage" should not be interpreted as mandating alengthy damage assessment prior to classification.

The key to classifying fires/explosions as an Alert is the damage as a result of the incident.

Thefact that safety-related equipment required for safe shutdown of the unit has been affected ordamaged as a result of the fire/explosion is the driving force for declaring the Alert. It isimportant to note that this EAL addresses a fire/explosion and not just the degradation of asafety system. The reference to damage of the systems is used to identify the magnitude ofthe fire/explosion and to discriminate against minor fires/explosions.

Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Levels/Radiological

Effluent, orEmergency Coordinator/EOF Director Judgement ICs.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, HA2Rev. 14-5December, 2014D65 FIRE/EXPLOSION AND SECURITY EVENTSALERT4.6.A.3 HOSTILE ACTION within OWNER CONTROLLED AREA or airborneattack threat.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVEL:4.6.A.3-1 A HOSTILE ACTION is occurring or has occurred within the OWNERCONTROLLED AREA as reported by the MNS Security Shift Supervision.

4.6.A.3-2 A validated notification from NRC of an airliner attack threat within 30 minutes ofthe site.BASIS:Note: Timely and accurate communication between Security Shift Supervision and the ControlRoom is crucial for the implementation of effective Security EALs.These EALs address the contingency for a very rapid progression of events, such as thatexperienced on September 11, 2001. They are not premised solely on the potential forradiological release.

Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.

The fact that the site is under serious attack or is an identified attack target with minimal timeavailable for further preparation or additional assistance to arrive requires a heightened state ofreadiness and implementation of protective measures that can be effective (such as on-siteevacuation, dispersal or sheltering).

EAL #1This EAL addresses the potential for a very rapid progression of events due to a HOSTILEACTION. It is not intended to address incidents that accidental events or acts of civildisobedience, such as small aircraft impact, hunters, or physical disputes between employees with the OCA. Those events are adequately addressed by other EALs.Note that this EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, inthe OWNER CONTROLLED AREA. This includes ISFSI's that may be outside thePROTECTED AREA but still within the OWNER CONTROLLED AREA.Rev. 14-5December, 2014D66

[Although nuclear plant security officers are well trained and prepared to protect againstHOSTILE ACTION, it is appropriate for OROs to be notified and encouraged to beginactivation (if they do not normally) to be better prepared should it be necessary to considerfurther actions.]

[If not previously notified by the NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federalagency would follow. In this case, appropriate federal agency is intended to be NORAD, FBIFAA or NRC. However, the declaration should not be unduly delayed awaiting Federalnotification.]

EAL #2This EAL addreses the immediacy of an expected threat arrival or impact on the site within arelatively short time.The intent of this EAL list to ensure that notifications for the airliner attack threat are made in atimely manner and that OROs and plant personnel are at a state of heightened awareness regarding the credible threat. Airliner is meant to be a large aircraft with the potential forcausing significant damage to the plant.This EAL is met when a plant receives information regarding a airliner attack threat from NRCand the airliner is within 30 minutes of the plant. Only the plant to which the specific threat ismade need declare the Alert.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an airliner (airliner is meant to be a large aircraft with the potential for causingsignificant damage to the plant). The status and size of the plane may be provided by NORADthrough the NRC.

REFERENCE:

EI 99-01 rev 5 (HA4) Methodology for Development of Emergency Action Levels.This change is to support NEI 03-12 implementation.

(PIP G-09-0360)

Rev. 14-5December, 2014D67 FIRE/EXPLOSION AND SECURITY EVENTSSITE AREA EMERGENCY 4.6.S.1 HOSTILE ACTION within the PROTECTED AREA.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:4.6.S.1-1 A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the MNS Security Shift Supervision.

BASIS:This condition represents an escalated threat to plant safety above that contained in the Alert inthat a HOSTILE FORCE has progressed from the OWNER CONTROLLED AREA to thePROTECTED AREA.This EAL addresses the cotingency for a very rapid progression of events, such as thatexperienced on September 11, 2001. It is not premised solely on the potential for a radiological release.

Rather the issue includes the need for rapid assistance due to the possibility forsignificant and inderterminate damage from additional air, land or water attack elements.

The fact that the site is under serious attack with minimal time available for further preparation or additional assistance to arrive requires ORO readiness and preparation for the implementation of protective measures.

This EAL addresses the potential for a very rapid progression of events due to a HOSTILEACTION. It is not intended to address incidents that are accidental events or acts of civildisobedience, such as small aircraft impact, hunters, or physical disputes between employees within the PROTECTED AREA. Those events are adequately addressed by other EALs.[Although nuclear plant security officers are well trained and prepared to protect againstHOSTILE ACTION, it is appropriate for OROs to be notified and encouraged to beginpreparations for public protective actions (if they do not normally) to be better prepared should itbe necessary to consider further actions.]

[If not previously notified by NRC that the airborne HOSTILE ACTION was intentional, thenit would be expected, although not certain, that notification by an appropriate Federal agencywould follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA orNRC. However, the declaration should not be unduly delayed awaiting Federal notification.]

Escalation of this emergency classifcation level, if appropriate, would be based on actual plantstatus after impact or progression of attack.

REFERENCE:

EI 99-01 rev 5 (HS4) Methodology for Development of Emergency Action Levels.This change is to support NEI 03-12 implementation.

(PIP G-09-0360}

Rev. 14-5December, 2014D68 FIRE/EXPLOSION AND SECURITY EVENTSGENERAL EMERGENCY 4.6.G.1 HOSTILE ACTION resulting in loss of physical control of the facility.

OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:4.6.G.1-1 A HOSTILE ACTION has occurred such that plant personnel are uable to operateequipment required to maintain safety functions.

4.6.G.1-2 A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems andIMMINENT fuel damage is likely for a freshly off-loaded reactor core in pool.BASIS:EAL #1This EAL encompasses conditions under which a HOSTILE ACTION has resulted in a loss ofphysical control of VITAL AREAS (containing vital equipment or controls of vital equipment) required to maintain safety functions and control of that equipment cannot be transferred to andoperated from another location.

[Typically, these safety functions are reactivity control (ability to shut down the reactor and keepit shutdown) reactor water level (ability to cool the core), and decay heat removal (ability tomaintain a heat sink) for a BWR. The equivalent functions for a PWR are reactivity control,RCS inventory, and secondary heat removal.]

[Loss of physical control of the control room or remote shutdown capability alone may notprevent the ability to maintain safety functions per se. Design of the remote shutdown capability and the location of the transfer switches should be taken into account.

Primary emphasis shouldbe placed on those components and instruments that supply protection for and information aboutsafety functions.]

If control of the plant equipment necessary to maintain safety functions can be transferred toanother location, then the threshold is not met.EAL #2This EAL addresses failure of spent fuel cooling systems as a result of HOSTILE ACTION ifIMMINENT fuel damage is likely, such as when a freshly off-loaded reactor core is in the spentfuel pool.A freshly off-loaded reactor core is: The complete removal and relocation of all fuel assemblies from the reactor core and placed in the spent fuel pool. (Typical of a "No Mode" operation during a refuel outage that allows safety system maintenance to occur and results in maximumdecay heat load in the spent fuel pool system).

REFERENCE:

NEI 99-01 rev 5 (HG1) Methodology for Development of Emergency ActionLevels. This change is to support NEI 03-12 implementation.

(PIP G-09-0360]

Rev. 14-5December, 2014D69 ENCLOSURE 4.7NATURAL DISASTERS, HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYUNUSUALEVENT ALERT4.7.U.1 Natural and Destructive Phenomena Affecting theProtected Area.4.7.A.1 Natural and Destructive Phenomena Affecting thePlant Vital Area.SITE AREA EMERGENCY 4.7.S.1 Control Room Evacuation Has Been Initiated andPlant Control Cannot BeEstablished.

GENERAL EMERGENCY 4.7.G.1 Other Conditions ExistingWhich in the Judgement ofthe Emergency Coordinator/EOF DirectorWarrant Declaration ofGeneral Emergency.

4.7.U.2 Release of Toxic orFlammable Gases DeemedDetrimental to SafeOperation of the Plant.4.7.U.3 Other Conditions ExistingWhich in the Judgement ofthe Emergency Coordinator/EOF DirectorWarrant Declaration of anUnusual Event.4.7.A.2 Release of Toxic orFlammable Gases Within aFacility Structure WhichJeopardizes Operation ofSystems Required toMaintain Safe Operations or to Establish or MaintainCold Shutdown.

4.7.A.3 Control Room Evacuation Has Been Initiated.

4.7.A.4 Other Conditions ExistingWhich in the Judgement ofthe Emergency Coordinator/EOF DirectorWarrant Declaration of anAlert.4.7.S.2 Other Conditions ExistingWhich in the Judgement ofThe Emergency Coordinator/EOF DirectorWarrant Declaration of SiteArea Emergency.

Rev. 14-5December, 2014D70 ENCLOSURE 4.7NATURAL DISASTERS.

HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYUNUSUAL EVENT4.7.U.1 Natural and Destructive Phenomena Affecting the Protected Area.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:4.7.U.1-1 Tremor felt and valid alarm on the Syscom Seismic Monitoring System (OACMI D2422).4.7.U.1-2 Report by plant personnel of tornado striking within protected area boundaryincluding the ISFSI.4.7.U.1-3 Vehicle crash into plant structures or systems within protected area boundaryincluding the ISFSI.4.7.U.1-4 Report of turbine failure resulting in casing penetration or damage to turbine orgenerator seals.4.7.U.1-5 ISFSI cask tipped over or dropped greater than 12 inches.4.7.U.1-6 Uncontrolled flooding in the ISFSI area.4.7.U.1-7 Tornado generated missile(s) impacting the ISFSI.BASIS:The protected area boundary is typically that part within the security isolation zone and isdefined in the site security plan.EAL 1: Damage may be caused to some portions of the site, but should not affect ability ofsafety functions to operate.

Method of detection can be based on instrumentation, validated by areliable source, or operator assessment.

As defined in the EPRI-sponsored "Guidelines forNuclear Plant Response to an Earthquake",

dated October 1989, a "felt earthquake" is:An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt atthe nuclear plant site and recognized as an earthquake based on a consensus of controlroom operators, and (b) valid alarm on seismic instrumentation occurs.Rev. 14-5December, 2014D71 EAL 2: A tornado striking (touching down) within the protected boundary may have potentially damaged plant structures containing functions or systems required for safe shutdown of the plant.If such damage is confirmed visually or by other in-plant indications, the event may be escalated to Alert. See ISFSI information covered under EAL 5, 6 & 7.EAL 3: Addresses such items as a car, truck, plane, helicopter, or train crash that may potentially damage plant structures containing functions and systems required for safe shutdown of theplant. If the crash is confirmed to affect a plant vital area, the event may be escalated to Alert.See ISFSI infonnation covered under EAL 5, 6 & 7.EAL 4: Addresses main turbine rotating component failures of sufficient magnitude to causeobservable damage to the turbine casing or to the seals of the turbine generator.

Of majorconcern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs.

Actual fires and flammable gas build up are appropriately classified via other EALs. This EAL is consistent with the definition of an Unusual Event whilemaintaining the anticipatory nature desired and recognizing the risk to non-safety relatedequipment.

Escalation of the emergency classification is based on potential damage done by themissiles generated by the failure or by the radiological releases in conjunction with a steamngenerator tube rupture.

These latter events would be classified by the Radiological ICs orFission Product Barrier ICs.EALs 5, 6 & 7: These ISFSI related ICs are categorized on the basis of the occurrence of anevent of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged orviolated.

This includes classification based on a loaded fuel storage cask CONFINEMENT BOUNDARY loss leading to the degradation of the fuel during storage or posing an operational safety problem with respect to its removal from storage.ISFSI Technical Specifications allow time to complete required actions if cask seal integrity isnot maintained; therefore, classification should not be made based on a loss of seal integrity byitself. However, loss of seal integrity coincident with an accident condition affecting a caskwould justify classification.

For these EALs the results of the ISFSI Safety Analysis Report (SAR) per NUREG 1536 wasused to develop the site-specific list of accident conditions.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, HUI, NE199-01 (Methodology forDevelopment of Emergency Action Levels) Draft Final Rev 4, McGuire ISFSI Safety AnalysisReport.NOTE: NUMARC EAL #5 moved to Fire/Security Recognition CategoryRev. 14-5December, 2014D72 NATURAL DISASTERS, HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYUNUSUAL EVENT4.7.U.2 Release of Toxic or Flammable Gases Deemed Detrimental to Safe Operation ofthe Plant.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:4.7.U.2-1 Report or detection of toxic or flammable gases that could enter within the site areaboundary in amounts that can affect safe operation of the plant.4.7.U.2-2 Report by Local, County or State Officials for potential evacuation of site personnel based on offsite event.BASIS:This IC is based on releases in concentrations within the site boundary that will affect the healthof plant personnel or the safe operation of the plant with the plant being within the evacuation area of an offsite event (i.e., tanker truck accident releasing toxic gases, etc.).Gases within the owner controlled area that are below life threatening or flammable concentrations do not meet this EAL.

REFERENCE:

NUMARC/NESP-007, REV 2,01/92, HU3Rev. 14-5December, 2014D73 NATURAL DISASTERS, HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYUNUSUAL EVENT4.7.U.3 Other Conditions Existing Which in the Judgement of the Emergency Coordinator/EOF Director Warrant Declaration of an Unusual Event.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVEL:4.7.U.3-1 Other conditions exist which in the judgement of the Emergency Coordinator/EOF Director indicate a potential degradation of the level of safety of the plant.BASIS:This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere butthat warrant declaration of an emergency because conditions exist which are believed by theEmergency Coordinator/EOF Director to fall under the Unusual Event emergency class.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, HU5Rev. 14-5December, 2014D74 NATURAL DISASTERS, HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYALERT4.7.A.1 Natural and Destructive Phenomena Affecting the Plant Vital Area.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:4.7.A.1-1 Valid "OBE Exceeded" Alarm on IAD-13, E-74.7.A.1-2 Tornado or high winds:Tornado striking plant structures within the vital area* Reactor Building* Auxiliary Building* Refueling Water Storage Tank (FWST)* Diesel Generator Rooms* Control Room* Standby Shutdown Facility (SSF)* Doghouses

• Central Alann Station (CAS)* Secondary Alarm Station (SAS)ORSustained winds > 74 mph for > 15 minutes.

{4}4.7.A.1-3 Visible structural damage caused by either: vehicle crashes, or turbine failuregenerated

missiles, or other catastrophic events on any of the following plantstructures:

" Reactor Building" Auxiliary Building" Refueling Water Storage Tank (FWST)" Diesel Generator Rooms" Control Room" Standby Shutdown Facility (SSF)" Doghouses

" Central Alarm Station (CAS)" Secondary Alarm Station (SAS)" Ultimate Heat Sink (Standby Nuclear Service Water Pond Dam and Dikes).Rev. 14-5December, 2014D75 BASIS:EAL 1: Based on the FSAR design basis. Seismic events of this magnitude

(> OBE) can causedamage to safety functions.

EAL 2: Based on the available instrumentation and the FSAR design basis. Wind loads of thismagnitude can cause damage to safety functions.

EAL 3: This EAL is intended to address the threat to safety related structures or equipment fromuncontrollable and possibly catastrophic events. This list of areas includes areas containing safety-related equipment, their controls, and their power supplies.

This EAL is, therefore, consistent with the definition of an ALERT in that if events have damaged areas containing safety-related equipment the potential exists for substantial degradation of the level of safety ofthe plant.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, HAIRev. 14-5December, 2014D76 NATURAL DISASTERS, HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYALERT4.7.A.2 Release of Toxic or Flammable Gases Within a Facility Structure WhichJeopardizes Operation of Systems Required to Maintain Safe Operations or toEstablish or Maintain Cold Shutdown.

OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVELS:Structures for both EALs:* Reactor Building" Auxiliary Building* Diesel Generator Rooms* Control Room" Standby Shutdown Facility* Doghouses

• CAS* SAS.4.7.A.2-1 Report or detection of toxic gases within a Facility Structure in concentrations thatwill be life threatening to plant personnel.

4.7.A.2-2 Report or detection of flammable gases within a Facility Structure in concentrations that will affect the safe operation of the plant.BASIS:This IC is based on gases that have entered a plant structure affecting the safe operation of theplant. Safe operations are affected when the area can not be accessed by plant personnel toensure continued operability or availability of safety systems/components.

This IC applies tobuildings and areas contiguous to plant Vital Areas or other significant buildings or areas. Theintent of this IC is not to include buildings (i.e., warehouses) or other areas that are notcontiguous or immediately adjacent to plant Vital Areas. It is appropriate that increased monitoring be done to ascertain whether consequential damage has occurred.

Escalation to ahigher emergency class, if appropriate, will be based on System Malfunction, Fission ProductBarrier Degradation, Abnormal Rad Levels/Radioactive

Effluent, or Emergency Coordinator/EOF Director Judgement ICs.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, HA3Rev. 14-5December, 2014D77 NATURAL DISASTERS, HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYALERT4.7.A.3 Control Room Evacuation Has Been Initiated.

OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVEL:4.7.A.3-1 Control Room evacuation has been initiated per AP/1(2)/A/5500/017 orAP/1 (2)/A/5500/024.

{2}BASIS:With the control room evacuated, additional

support, monitoring and direction through theTechnical Support Center and/or Emergency Operations Facility is necessary.

Inability toestablish plant control from outside the control room, as evidenced by the inability to maintainNCS or SG inventories, will escalate this event to a Site Area Emergency.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, HA5Rev. 14-5December, 2014D78 NATURAL DISASTERS, HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYALERT4.7.A.4 Other Conditions Existing Which in the Judgement of the Emergency Coordinator/EOF Director Warrant Declaration of an Alert.OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVEL:4.7.A.4-1 Other conditions exist which in the Judgement of the Emergency Coordinator/EOF Director indicate that plant safety systems may be degraded and that increased monitoring of plant functions is warranted.

BASIS:This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere butthat warrant declaration of an emergency because conditions exist which are believed by theEmergency Coordinator/EOF Director to fall under the Alert emergency class.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, HA6Rev. 14-5December, 2014D79 NATURAL DISASTERS, HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYSITE AREA EMERGENCY 4.7.S.1 Control Room Evacuation Has Been Initiated and Plant Control Cannot BeEstablished.

OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVEL:4.7.S.1-1 The following conditions exist:a. Control room evacuation has been initiated per AP/1(2)/A/5500/017 orAP/1 (2)/A/5500/024.

{2}ANDb. Control of the plant cannot be established from the Auxiliary Shutdown Panel orthe Standby Shutdown Facility within 15 minutes.BASIS:The timely transfer of control to alternate control areas has not been accomplished.

This failureto transfer control would be evidenced by deteriorating reactor coolant system or steam generator parameters.

For purposes of classification, the 15 minutes begins at the time that thedetermination to staff the alternate location is made. For most conditions, Reactor Coolant Pumpseal LOCAs or steam generator dryout would be indications of failure to accomplish the transferin the necessary time.Escalation of this event, if appropriate, would be by Fission Product Barrier Degradation, Abnormal Rad Levels/Radiological

Effluent, or Emergency Coordinator/EOF DirectorJudgement ICs.

REFERENCE:

NUMARC/NESP-007, REV. 2, 01/92, HS2Rev. 14-5December, 2014D80 NATURAL DISASTERS, HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYSITE AREA EMERGENCY 4.7.S.2 Other Conditions Existing Which in the Judgement of the Emergency Coordinator/EOF Director Warrant Declaration of Site Area Emergency.

OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVEL:4.7.S.2-1 Other conditions exist which in the judgement of the Emergency Coordinator/EOF Director indicate actual or likely major failures of plant functions needed forprotection of the public.BASIS:This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere butthat warrant declaration of an emergency because conditions exist which are believed by theEmergency Coordinator/EOF Director to fall under the emergency class description for Site AreaEmergency.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, HS3Rev. 14-5December, 2014D81 NATURAL DISASTERS, HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYGENERAL EMERGENCY 4.7.G.1 Other Conditions Existing Which in the Judgement of the Emergency Coordinator/EOF Director Warrant Declaration of General Emergency.

OPERATING MODE APPLICABILITY:

AllEMERGENCY ACTION LEVEL:4.7.G.1-1 Other conditions exist which in the judgement of the Emergency Coordinator/EOF Director indicate:

(1) actual or imminent substantial core degradation with potential for loss of containment, or (2) potential for uncontrolled radionuclide releases.

Thesereleases can reasonably be expected to exceed Environmental Protection AgencyProtective Action Guideline levels outside the site boundary.

BASIS:This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere butthat warrant declaration of an emergency because conditions exist which are believed by theEmergency Coordinator/EOF Director to fall under the General Emergency class.

REFERENCE:

NUMARC/NESP-007, REV 2, 01/92, HG2Rev. 14-5December, 2014D82 Commitment Reference for Emergency Action Levels{ 1{2}{3}{4}{5}PIP-M-00-2138, CA #18PIP-M-01

-2860, CA #2PIP-M-05-3403, CA #3,PIP-M-03-4281, CA #3PIP-M-06-5137, CA #2nultiple changes in enclosure 4.6Rev. 14-5December, 2014D83 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 10CFR 50.54(q)

Evaluations

§50.54(q)

Screening Evaluation Form Activity Description and

References:

MNS BLOCK.1Emergency Plan Section D (Emergency Classification System) Rev 14-5December 2014 .-Page D-20 for 4.2.U.5-2 changed from "Selective Signaling" to "DEMNET".

To support a Duke Energy fleetwide initiative, replacing references and instructions associated with Selective Signaling toDuke Emergency Management Network (DEMNET) which is used for notifications to state/county agencies.

The Selective Signaling to DEMNET replacement work is being performed under Engineering Change(EC)# 112636.Fleet procedure, AD-EP-ALL-0406, Duke Emergency Management Network (DEMNET),

Revision 0, includesinformation on how to operate DEMNET.DEMNET was incorporated to remove the Selective Signaling System and on the use of the new communication network,for making emergency notifications to off-site agencies by initiating group calls to the government agencies usingDEMNET "M'N Notify".Planning Standards 50.47(b)(5) and 50.47(b)(6),

are impacted by the new DEMNET process therefore a 1OCFR50.54(q)

Effectiveness Evaluation must be performed.

Activity Scope:E The activity is a change to the emergency planEl The activity is not a change to the emergency planBLOCK 2Revision 12 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 1OCFR 50.54(q)

Evaluations Change Type: BLOCK 3 Change Type: BLOCK4E1 The change is editorial or typographical El The change does conform to an activity that has[ The change is not editorial or typographical prior approvalZ The change does not conform to an activity that has___________________________________

prior approvalPlanning Standard Impact Determination:

BLOCKE] §50.47(b)(1)

-Assignment of Responsibility (Organization Control)El §50.47(b)(2)

-Onsite Emergency Organization E] §50.47(b)(3)

-Emergency Response Support and Resources E] §50.47(b)(4)

-Emergency Classification System*Z §50.47(b)(5)

-Notification Methods and Procedures*

E §50.47(b)(6)

-Emergency Communications El §50.47(b)(7)

-Public Education and Information El §50.47(b)(8)

-Emergency Facility and Equipment E] §50.47(b)(9)

-Accident Assessment*

El §50.47(b)(10)

-Protective Response*

El §50.47(b)(1

1) -Radiological Exposure ControlEl §50.47(b)(12)

-Medical and Public Health SupportEl §50.47(b)(13)

-Recovery Planning and Post-accident Operations

[] §50.47(b)(14)

-Drills and Exercises El §50.47(b)(15)

-Emergency Responder Training[] §50.47(b)(16)

-Emergency Plan Maintenance

• Risk Significant Planning Standards El The proposed activity does not impact a Planning StandardCommitment Impact Determination:

BLOCK6El The activity does involve a site specific EP commitment Record the commitment or commitment reference:

The activity does not involve a site specific EP commitment I. " Screening Evaluation Results:

L:El The activity can be implemented without performing a §50.54(q) effectiveness evaluation

[ The activity cannot be implemented without perfor~ing a §50.54(q) effectiveness evaluation Pr-pajer Name: P reper ..... ..DateBLOCK 7Y -_2-2 -t y ... .........

.. .. .........

............

Date:/ 012,-311

ý/-

Emergency Planning Functional Area Manual3.10 OCFR 50.54(q)

Evaluations Attachment 3.10.7.3§50.54(q)

Effectiveness Evaluation FormActivity Description and

References:

Emergency Plan Section D BLOCK I(Emergency Classification System) Rev 14-5 December 2014On page D-20 for 4.2.U.5-2 changed "Selective Signaling to "DEMNET".

To support a Duke Energy fleetwide initiative, replacing references and instructions associated with Selective Signaling to Duke Emergency Management Network (DEMNET) which is used for notifications to state/county agencies.

The Selective Signaling to DEMNET replacement work is being performed under Engineering Change(EC)# 112636.ew Fleet procedure, AD-EP-ALL-0406, Duke Emergency Management Network (DEMNET),

Revision 0, willalso be issued. The new Fleet procedure includes information on how to operate DEMNET.DEMNET changes were incorporated to remove the Selective Signaling System and add instructions on theuse of the new communication

network, DEMNET. Step details for using the old Selective Signaling systemwere deleted or replaced with instructions for using DEMNET. Step details for using DEMNET include thefollowing:

Initiating group calls to the government agencies with the DEMNET "MSMtl Notify" button, use of theAlternate DEMNET buttons, and notes containing supplemental information.

rfhU05Additional information regarding this change: i --JThe Selective Signaling emergency communications system has been the primary method of promptcommunication to State and local Offsite Response Organizations (OROs) from the McGuire NuclearStation (MNS) for many years. Within the confines of MNS, Selective Signaling operates as part of thenormal plant communications system (i.e. internal extensions, commercial phones, etc.). Beyond theboundaries of MNS, Selective Signaling transmits over analog lines that are leased from localtelephone providers.

In the past, these lines have been subject to damage by natural and man-madecauses or other failures such that all or part of communication ability of MNS to or from some or all ofthe OROs via Selective Signaling has been lost for various periods of time.Since Selective Signaling is an unmonitored system, it is typically not known that problems exist untilthe system is used (i.e., during periodic

testing, communication checks, drills, etc.). When problemsare identified and reported, it is up to the local telephone provider to determine when the repair(s) canbe made. In addition to the less than reliable service for the Selective Signaling system, Duke Energyhas been notified by local telephone providers that due to the frequency of failures and the everincreasing difficulty in obtaining repair parts / materials, they will no longer be able to provide repair /maintenance support of the antiquated system beyond 2014.As a solution for this, Duke Energy has selected Emergency Management Network (EMnet) asprovided by the vendor, Communications Laboratories (Comlabs).

EMnet is currently in use by anumber of Federal, State, and local government

agencies, and is being implemented by an increasing number of nuclear stations

/ utilities.

EMnet will be referenced as DEMNET for the remainder of thisevaluation.

Comlabs provides

hardware, software,

training, installation and other services necessary for DEMNET to operate.

DEMNET is being implemented across the Duke Energy Fleet as areplacement for Selective Signaling.

DEMNET allows the Control Room, Technical Support Center (TSC), Emergency Operations Center(EOF), and alternative response facilities to communicate with Offsite Response Organizations and/orwith each other using VolP (voice-over-internet protocol) as the primary method. In the event ofinternet related problems (i.e., slow data transfer rate, unavailability, etc.), the system automatically transfers to satellite communication as a backup. Like Selective Signaling, DEMNET allows internaland external point-to-point contact between individual stations as well as simultaneous conferencing with multiple stations.

This ability is a valuable backup to existing telephone circuits.

The point-to-point Revision 12 Emergency Planning Functional Area ManualAttachment 3.10.7.33.10 1OCFR 50.54(q)

Evaluations capability also allows DEMNET to continue to provide Decision Line capability, which enables OROdecision makers to use the system to discuss public protective actions over dedicated

/ controlled access communication links.Via the dedicated DEMNET computer, historical and real-time system status can be readilydetermined.

DEMNET is also monitored by the vendor, Comlabs.

This allows for a more proactive approach in identification and resolution of problems associated with the system should they occur. Inthe event of failure, the application of suitable compensatory measures (i.e., use of back upcommunications) can be made in a more efficient and effective manner.No changes are made to the communications systems that currently serve as a backup to Selective Signaling or the associated implementation process(es) for employing them.DEMNET equipment installed and operated at Duke Energy nuclear plants and support facilities isinstalled and maintained to meet cyber security requirements in accordance with 10 CFR 73.54 andother related guidance.

As part of the installation

process, DEMNET has been extensively tested to ensure connectivity Ioperability before being placed in service.

Duke Energy Emergency Response Organization andEmergency Preparedness, along with personnel from Offsite Response Organizations have receivedtraining on the new system as well.As configured, the network that DEMNET resides within MNS causes the system to be powered fromvarious sources based upon the physical location of the individual components within the network.

Inthe event normal and/or backup power supplies become unavailable, and as a result, DEMNET and allother backup communications system become non-functional, MNS and the OROs have a number ofbattery powered portable satellite phones available that can be placed into service in an effort tomaintain the capability of providing prompt communications between MNS and the OROs.Upon implementation across the Duke Energy Fleet and its State and local Offsite ResponseOrganizations, the product name "EMNet" is replaced with the new system name "Duke Emergency Management Network (DEMNET)".

The name "Selective Signaling" will no longer be used, while thename "Decision Line" will continue to be used.Activity Type: BLOCK2E The activity is a change to the emergency planD1 The activity affects implementation of the emergency plan, but is not a change to the emergency planImpact and Licensing Basis Determination:

I BLOCK3* 10 CFR 50.47(b)(5)

-Notification Methods and Procedures (Risk Significant Planning Standard) states:"Procedures have been established for notification, by the licensee, of State and local responseorganizations and for notification of emergency personnel by all organizations; the content of initial andfollow up messages to response organizations and the public has been established; and means toprovide early notification and clear instruction to the populace within the plume exposure pathwayEmergency Planning Zone have been established."

The applicable emergency planning function associated with 10 CFR 50.47(b)(5) states:,"Procedures for notification of State and local governmental agencies are capable of alerting them ofthe declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications."

• 10 CFR 50.47(b)(6)

-Emergency Communications states: "Provisions exist for promptcommunications among principal response organizations to emergency personnel and to the public."

Emergency Planning Functional Area Manual3.10 l0CFR 50.54(q)

Evaluations Attachment 3.10.7.3The applicable emergency planning functions associated with 10 CFR 50.47(b)(6) state:" Systems are established for prompt communication among principal emergency responseorganizations.

• Systems are established for prompt communication to emergency response personnel Licensing Basis:This evaluation included a search of McGuire Nuclear Station (MNS) licensing basis documents forreferences to the Selective Signaling system. The search concluded that a review of the Duke EnergyMcGuire Nuclear Station (MNS) Emergency Plan was warranted.

While the MNS Emergency Plan contains several references to Selective Signaling, there are no detailswithin the Emergency Plan regarding usage of the system, other than to indicate that it is the primarysystem used for prompt communications to the offsite response organizations.

DEMNET is replacing Selective Signaling as the primary system used for prompt communications to the offsite responseorganizations.

Other references within the MNS Emergency Plan include facility diagrams which indicate the location ofSelective Signaling telephones.

DEMNET equipment is replacing Selective Signaling in each locationwhere Selective Signaling was present.The MNS Emergency Plan also references periodic testing of Selective Signaling.

DEMNET will be testedin a similar manner and frequency as was Selective Signaling.

Consequently, the replacement of the Selective Signaling system with DEMNET within the MNSEmergency Plan will constitute a name change only.This review concludes that changes to this document relative to the replacement of Selective Signaling withDEMNET do not affect the licensing basis of the MNS Emergency Plan. The changes in this revisionsupport replacement of the Selective Signaling telephone system, which is used for notifications tostate/county

agencies, with a new dedicated telephone system called the Duke Emergency Management Network (DEMNET).

These changes support a Duke Energy fleet-wide initiative to upgrade the dedicated telephone system for notifying state/county agencies of a declared emergency as an overall enhancement to emergency preparedness.

These changes meet or exceed all emergency preparedness requirements based on NRC regulations and requirements.

Compliance Evaluation and

Conclusion:

BLOCK 4I. Evaluation:

10 CFR Part 50, Appendix E, Section IV.D.1 states the following:

Administrative and physical means for notifying local, State, and Federal officials and agencies andagreements reached with these officials and agencies for the prompt notification of the public and for publicevacuation or other protective

measures, should they become necessary, shall be described.

Thisdescription shall include identification of the appropriate officials, by title and agency, of the State and localgovernment agencies within the EPZs.10 CFR Part 50, Appendix E, Section IV.D.3 states the following, in part:A licensee shall have the capability to notify responsible State and local governmental agencies within 15minutes after declaring an emergency.

The licensee shall demonstrate

...10 CFR Part 50, Appendix E, Section IV.E.8.d states the following, in part:For nuclear power reactor licensees, an alternative facility (or facilities) that would be accessible even if thesite is under threat of or experiencing hostile action, to function as a staging area for augmentation ofemergency response staff and collectively having the following characteristics:

... the capability to performoffsite notifications;

....NUREG-0696 (Functional Criteria for Emergency Response Facilities),

Section 2.7, states, in part:The TSC voice communication equipment shall include:* Hotline telephone

...* Dedicated telephone

...* Dial telephones

...

Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.3* Intercommunications systems ...* Communications

... to State and local operations center prior to EOF activation.

NUREG-0696 (Functional Criteria for Emergency Response Facilities),

Section 4.6, states, in part:The EOF shall have reliable voice communications facilities to the TSC, the control room, NRC, and Stateand local emergency operations centers.

The normal communication path between the EOF and thecontrol room will be through the TSC. The primary functions of the EOF voice communications facilities willbe:* EOF management...

• Communications

...* Communications

...* Communications to coordinate offsite emergency response activities, and* Communications

....NUREG-0654 (Criteria for Preparation and Evaluation of Radiological Emergency Response Plans andPreparedness in Support of Nuclear Power Plants),

Section II.F, states, in part:1. The communications plans for emergencies shall include organizational titles and alternates for bothends of the communication links. Each organization shall establish reliable primary and backup meansof communication for licensees, local, and State response organizations.

Such systems should beselected to be compatible with one another.

Each plan shall include:a. provision for 24-hour per day notification to and activation of the State/local emergency responsenetwork; and at a minimum, a telephone link and alternate, including 24-hour per day manning ofcommunications links that initiate emergency response actions.b. provision for communications with contiguous State/local governments within the Emergency Planning Zones;c. provision for communications

...d. provision for communications

...e. provision for alerting or activating emergency personnel in each response organization; andprovision for communication

...The replacement of Selective Signaling and Decision Line (SS/DL) with DEMNET continues to comply withapplicable regulations and commitments by providing a dedicated method of contacting State and localauthorities in a timely manner during an emergency.

Compliance is maintained in the following manner:1. DEMNET is a dedicated system for communication with OROs that is capable of establishing contactwithin 15 minutes of emergency declaration.

This is consistent with the capability of the SS/DLsystem.2. DEMNET stations are present in the Control Room, TSC, EOF, and alternative facilities which arecapableof initiating or receiving point-to-point or conference calls with any ORO site similarly equipped.

Thisis consistent with the capability of the SS/DL system.3. Compatible DEMNET stations are installed in all ORO locations that were serviced by the SS/DLsystem.4. The TSC has an DEMNET station to allow communication with State and local OROs prior to EOFactivation.

This capability existed with the existing SS/DL system.5. DEMNET is a voice communications system with dedicated stations located in the Control Room, TSC,EOF, alternative facilities, and State/local emergency operations centers and is capable of coordinating Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.3offsite response activities via point-to-point or conference calling.

Communications with NRC isconducted using a separate system unrelated to DEMNET. This is consistent with the SS/DL system.NOTE: In addition to voice communications, DEMNET is also capable of transmitting data. The voicecommunications feature of DEMNET is the replacement for SS/DL voice communications capability.

6. DEMNET has redundant features to maintain communication capability in the event of system failure ordegradation.

During normal operation, DEMNET employs voice-over-internet protocol (VoIP)technology to establish contact between stations.

Should internet problems (unavailability, slow transfer rate, etc.)occur, the system will automatically shift to satellite communication as a backup. This backup featureis an enhancement that SS/DL did not have. Failure of the SS/DL system required the use of thecommercial telephone system to re-establish communications.

7. By locating an DEMNET station in the continuously staffed Control Room, the licensee provides 24-hour per day capability to establish links to initiate emergency response actions.8. DEMNET stations are established at each contiguous State/local emergency response agency withinthe EPZ. This is consistent with the usage of the SS/DL system.* 10 CFR 50.47(b)(5) states the following:

"Procedures have been established for notification, by the licensee, of State and local responseorganizations and for notification of emergency personnel by all organizations; the content of initial andfollow-up messages to response organizations and the public has been established; and means to provideearly notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established."

The function of this planning standard pertinent to this change is the establishment of procedures for Stateand local governmental agencies that are capable of initiating notification of the declared emergency within15 minutes after declaration of an emergency and providing follow-up notification.

• 10 CFR 50.47(b)(6) states the following:

"Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public."The function of this planning standard pertinent to the change is that systems be established for promptcommunications among principal response organizations.

==

Conclusion:==

The proposed activity Z does / E] does not continue to comply with the requirements.

Reduction in Effectiveness (RIE) Evaluation and

Conclusion:

BLOCK 51. Evaluation:

The screening of this change has identified two (2) affected planning standard functions described above:1. Procedures for notification of State and local government agencies are capable of initiating notification of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notification.

Additional procedures are currently in effect for notification of State and local agencies following adeclared emergency.

These procedures explicitly require that such notification occur within 15 minutesof emergency declaration.

Station procedures were originally intended to address notifications using the Selective Emergency Planning Functional Area Manual3. 10 1OCFR 50.54(q)

Evaluations Attaclunent 3.10.7.3Signaling/Decision Line (SS/DL) system and have likewise been revised to address the change toDEMNET. The functionality and utility of the procedures remain unaffected by the proposed change.Consequently, this evaluation concludes that the change presents no undesirable impact on thisplanning function.

2. Systems are established for prompt communication to emergency response personnel.

The SS/DL system suffered from obsolescence and eroding vendor support.

The communications carriers currently providing service for the system informed the licensee that all support will terminate atthe end of 2014. This prompted the change to DEMNET, a communications system widely used in theemergency response community.

As described above, DEMNET possesses all of the capabilities of SS/DL with additional enhancements not found in the former system. Significant among these is the use of robust VolP technology andautomatic "failover" to satellite communications in the event of a failure or degradation of the primaryinternet flowpath.

Consequently, this evaluation concludes that the change presents no undesirable impact on this planning function.

The evaluation concludes that the change does not impact either applicable planning function negatively and therefore does not constitute a reduction in effectiveness.

==

Conclusion:==

The proposed activity El does / Z does not constitute a RIE.Effectiveness Evaluation Results BLOCK6Z The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E and theactivity does not constitute a reduction in effectiveness.

Therefore, the activity can be implemented withoutprior approval.

LII The activity does not continue to comply with the requirements of §50.47(b) and §50 Appendix E or theactivity does constitute a reduction in effectiveness.

Therefore, the activity cannot be implemented withoutprior approval.

P paer Nme: G b....... ..............

................................................

Date:/......./.... ...........

.

Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 10CFR 50.54(q)

Evaluations

§50.54(q)

Screening Evaluation Form Activity Description and

References:

BLOCKMNS Emergency Plan Section D (Emergency Classification System) Rev 14-5 December 2014Ciick here to enter text.Pages D-26, D-27, D-29 and D-30 -Deleted procedures HP/0/B/1009/029 and SH/0/B/2005/001 andreplaced with AD-EP-ALL-0202.

This change supports a fleetwide initiative to replace the dose assessment tools that are currently in place at the DukeEnergy Carolinas sites (using RADDOSE-V) and the Duke Energy Progress sites (using RASCAL) with UnifiedRASCAL Interface (URI) in order to align dose assessment tools at all Duke Energy nuclear plant sites. A new fleetprocedure AD-EP-ALL-0202, Emergency Response Dose Assessment, has been developed which provides instructions forperforming dose projections using Unified RASCAL Interface (URI) at MNS and the other nuclear plant sites.Planning Standards 50.47(b)(1),

50.47(b)(8) and 50.47(b)(9),

are impacted by the new URI process therefore a10CFR50.54(q)

Effectiveness Evaluation must be performed.

Activity Scope: BLOCK 2[ The activity is a change to the emergency plan[] The activity is not a change to the emergency planChange Type: BLOCK 3 Change Type: -BLOC 4E] The change is editorial or typographical EL The change does conform to an activity that hasZ The change is not editorial or typographical prior approvalZ The change does not conform to an activity that hasprior approvalPlanning Standard Impact Determination:

BLCK5El §50.47(b)(1)

-Assignment of Responsibility (Organization Control)LI §50.47(b)(2)

-Onsite Emergency Organization El §50.47(b)(3)

-Emergency Response Support and Resources

[] §50.47(b)(4)

-Emergency Classification System*El §50.47(b)(5)

-Notification Methods and Procedures*

El §50.47(b)(6)

-Emergency Communications El §50.47(b)(7)

-Public Education and Information Z §50.47(b)(8)

-Emergency Facility and Equipment Z §50.47(b)(9)

-Accident Assessment*

El §50.47(b)(10)

-Protective Response*

[E §50.47(b)(1

1) -Radiological Exposure ControlEl §50.47(b)(12)

-Medical and Public Health SupportEl §50.47(b)(13)

-Recovery Planning and Post-accident Operations El §50.47(b)(14)

-Drills and Exercises El §50.47(b)(1

5) -Emergency Responder TrainingEl §50.47(b)(16)

-Emergency Plan Maintenance

• Risk Significant Planning Standards

[E The proposed activity does not impact a Planning StandardRevision 12 Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.2Commitment Impact Determination:

BLOCKD1 The activity does involve a site specific EP commitment Record the commitment or commitment reference:

Z The activity does not involve a site specific EP commitment Screening Evaluation Results:

BLOCK 7.[ The activity can be implemented without performing a §50.54(q) effectiveness evaluation Z The activity cannot be implemented without perfo0 *ng a §50.54(q) effectiveness evaluation Pr ar Name- , -Prepe , inare Date:N a.e......

...a.u......

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41Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.350.54(q)

Effectiveness Evaluation FormActivity Description and

References:

MNS Emergency Plan Section D BLOCKI(Emergency Classification System) Rev 14-5 December 2014Pages D-26, D-27, D-29 and D-30 -Deleted procedures HP/0/B/1009/029 and SH/0/B/2005/001 andreplaced with AD-EP-ALL-0202.

To support a Duke Energy fleetwide initiative, replacing instructions associated with the RADDOSE doseassessment tool with Unified RASCAL Interface (URI).This change supports a fleetwide initiative to replace the dose assessment tools that are currently in place atthe Duke Energy Carolinas sites (using RADDOSE-V) and the Duke Energy Progress sites (using RASCAL)with Unified RASCAL Interface (URI) in order to align dose assessment tools at all Duke Energy nuclear plantsites. A new fleet procedure AD-EP-ALL-0202, Emergency Response Dose Assessment, has been developed which provides instructions for performing dose projections using Unified RASCAL Interface (URI) at MNS andthe other nuclear plant sites. As a result, specific site procedures for performing dose projections aresuperseded by AD-EP-ALL-0202.

Additional information supportinq this change:RADDOSE is the current application used for dose assessment and projection of radiological releases duringan emergency.

The proposed change will replace RADDOSE with the Unified RASCAL Interface (URI) as thestandard fleet-wide dose assessment tool.RADDOSE is designed to estimate dose rates and deposition rates at 15-minute time intervals.

From theseestimates, integrated doses (using EPA 400-R-92-001 (EPA-400)[14]

dose factors and methodologies) andtotal deposition are calculated for the length of time covering the release of radioisotopes.

Doses are determined at radial grid and special receptor locations in the Plume Exposure Pathway Emergency Planning Zone while deposition is calculated to fifty miles surrounding the facility, based on radiological andmeteorological data collected at the plant.The RADDOSE model is designed to provide real-time (as the release is occurring) and projected site specificpredictions of atmospheric transport and diffusion as required by NUREG-0654, Revision 1, Appendix.

Atmospheric transport and diffusion are performed using a variable trajectory plume simulation model alongwith realtime meteorological data entered either directly from the PI server or manually.

Likewise, the sourceterm component of RADDOSE uses plant specific radiological data, for a number of accident types, entered viathe PI server or manually.

Using this information along with EPA-400 dose conversion

factors, the modeldetermines dose rates, doses, deposition rates and total deposition.

URI is a computer code intended for use at nuclear generating stations and other emergency response facilities in the event of an actual or potential release of airborne radioactivity to the environment at levels warranting declaration of an Emergency specified in the Radiological Emergency Plan. URI is a replacement for the userinterface normally delivered with the computer code Radiological Assessment System for Consequence AnaLysis

("RASCAL")

maintained and distributed by the by the Nuclear Regulatory Commission (NRC).The URI program:" Provides a user interface specifically designed for users for nuclear power station events." Allows input of all required dose assessment model parameters including meteorological data, planteffluent monitor data, and plant condition and status.Revision 12 Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.3* Develops source terms based on user input.* Creates RASCAL data files based on the specific user input* Invokes the RASCAL met data processor, plume model processor, and puff model processors.

• Reads and interprets RASCAL results files and provide reports to the user of doses, affected areas,and other information relevant to emergency plan implementation.

The code has three modes: Rapid Assessment, Detailed Assessment, and Sum Assessment.

RapidAssessment enables on-shift staff to meet regulatory requirements for quick, simplified dose assessments inthe initial phases of an event. Detailed Assessment enables the Emergency Response Organization staff tomake more detailed dose assessments.

Sum Assessment adds multiple concurrent assessment results.Because certain aspects of the interface must be site or unit specific, particularly the release pathways, separate programs are used for each unit, or when possible, multi-unit site if the units are identical.

Themajority of the code forms and modules are common to all these separate

programs, with the pathways andsite specific setup parameters different for each site / unit.The program utilizes two types of data:* User inputs" Constants stored in external encrypted xml format files unique to each site.User inputs are values needed to run dose assessments that vary from assessment to assessment.

Thesewould consist of items such as meteorological data and effluent monitor readings.

Constants are values set internally by the system administrators.

These would consist of items such as siteboundary distances and monitor response factors that define the site and do not change for each assessment.

A separate computer program called "Interface Maintenance" is used to control and generate these constants and maintain the SQL data table files that these constants are stored in. The URI computer programs cannotchange constant values or their related encrypted xml files.The dose assessment computer programs will only be run when a user needs to perform a dose assessment.

The code does not generate any data that needs to be retained by the program after an assessment iscompleted, though reports can be printed or saved to individual files for later retrieval if required.

There are no interfaces with plant safety systems.The URI programs are specifically designed to interface with versions 4.0 to 4.2 of the NRC computer programRASCAL. It is expected that future revisions will remain compatible but would need to be verified for each newRASCAL release.

RASCAL is designed to produce emergency release dose assessments.

RASCALcommunicates between its own separate modules (.exe and .dll modules) using ASCII text data files. The URIprograms interface with RASCAL by creating the same data files in the same format based on the information stored in the xml data tables and the user input. These RASCAL data files are modified or retrieved

'on-the-fly' for each assessment performed.

Activity Type: BLOCK 2El The activity is a change to the emergency planZ The activity affects implementation of the emergency plan, but is not a change to the emergency planImpact and Licensing Basis Determination:

BLOCK 310 CFR 50.47(b)(8) states: "Adequate emergency facilities and equipment to support the emergency response are provided and maintained."

The emergency planning functions associated with 10 CFR 50.47(b)(8) state:

Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.3* Adequate facilities are maintained to support emergency response.

• Adequate equipment is maintained to support emergency response.

The applicable supporting requirement which is described in 10 CFR 50, Appendix E.IV.E states (inpart): Adequate provisions shall be made and described for emergency facilities and equipment, including:

2. Equipment for determining the magnitude of and for continuously assessing the impact of the release ofradioactive materials to the environment; The applicable informing criteria described in NUREG-0654,Section II.H.8 states:Each licensee shall provide meteorological instrumentation and procedures which satisfy the criteria inAppendix 2, and provisions to obtain representative current meteorological information from other sources.10 CFR 50.47(b)(9) states: "Adequate

methods, systems and equipment for assessing and monitoring actualor potential offsite consequences of a radiological emergency condition are in use."The emergency planning function associated with 10 CFR 50.47(b)(9) states:* Methods, systems and equipment for assessment of radioactive releases are in use.The applicable supporting requirements which are described in 10 CFR 50, Appendix E state:Section IV.B (in part):1. The means to be used for determining the magnitude of, and for continually assessing the impact of, therelease of radioactive materials shall be described,Section IV.E (in part):Adequate provisions shall be made and described for emergency facilities and equipment, including:

2. Equipment for determining the magnitude of and for continuously assessing the impact of the release ofradioactive materials to the environment; The applicable informing criteria described in NUREG-0654, Section 11.1 states (in part):8. Each organization, where appropriate, shall provide methods, equipment and expertise to make rapidassessments of the actual or potential magnitude and locations of any radiological hazards through liquid orgaseous release pathways.

This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.9. Each organization shall have a capability to detect and measure radioiodine concentrations in air in theplume exposure EPZ as low as 10-7 uCi/cc (microcuries per cubic centimeter) under field conditions.

Interference from the presence of noble gas and background radiation shall not decrease the stated minimumdetected activity.

The applicable informing criteria described in NUREG-0696, Section 4.8 states (in part):The EOF technical data system will receive, store, process and display information sufficient to performassessments of the actual and potential onsite and offsite environmental consequences of an emergency condition.

Data providing information...

The EOF data set shall include radiological, meteorological, and other environmental data needed to:" Assess environmental conditions,

• Coordinate radiological monitoring activities, and* Recommend implementation of offsite emergency plans.Licensing Basis:This evaluation included a search of MNS licensing basis documents for references to Dose Assessment, and Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.3specifically for references to RADDOSE-V.

The search concluded that while the dose assessment function isdiscussed, specific references to the dose assessment tool and how to perform dose assessments are notdiscussed.

As a result, the MNS licensing basis is not impacted by the change to replace RADDOSE-V withURI as the dose assessment tool. The change is which supports replacement of RADDOSE V with URI and isstrictly administrative and does not affect the licensing basis.Compliance Evaluation and

Conclusion:

BLOCK 41. Evaluation:

The replacement of RADDOSE with URI will continue to comply with applicable regulations and commitments by providing a means of assessing offsite radiation dose during an emergency.

Compliance with the requirements identified above is maintained in the following manner:Item 1URI uses plant effluent monitor values and meteorological instrumentation input for the calculation of doseassessment results.

These results are then used to determine the environmental impact of radioactive materialreleases and to direct the activities of field monitoring teams in plume tracking.

Licensee emergency responsepersonnel also use the assessment results to make protective action recommendations to state and localauthorities.

These features of URI are consistent with the current capabilities of RADDOSE.RADDOSE employs an automatic data download from selected meteorological and radiation monitoring instrumentation to make dose projections.

Typically, these downloads occur at 15-minute intervals.

The userperforming the assessment is responsible for validating the downloaded information against current plantconditions.

While URI has no provision for automatic data downloading, it does allow the user to "drag anddrop" meteorological and radiation parameters into the fields used by the application.

This does not result in asignificant delay since most of the time spent for data input in both RADDOSE and URI is for data validation.

Field syntax restrictions reject out-of-range data to prevent erroneous information from being used in projection calculations.

This feature, coupled with continual validation by the user, minimizes the risk of incorrect dataentry.Item 2The portion of this requirement pertinent to the proposed change is that the licensee provide the method toperform rapid radiological assessments.

RADDOSE uses a Gaussian dispersion model and employs dose conversion factors taken from EPA 400,Manual of Protective Action Guides and Protective Actions for Nuclear Incidents.

URI uses a similar modelwith the same dose conversion factors.

Empirical comparisons of both applications yield similar doseprojection results when subjected to the same radiological and meteorological conditions.

Calculation time ofboth applications is approximately the same. In addition, RASCAL (the underlying calculational base of URI) issanctioned by the NRC and accepted as an industry standard application for dose projection.

Item 3The portion of this requirement pertinent to the proposed change is that the emergency plan will contain adescription of how offsite dose projections are made. This description appears in Section I of the McGuireNuclear Station (MNS) Emergency Plan.Item 4The portion of this requirement pertinent to the proposed change is that the emergency plan will contain adescription of the equipment used for assessing the impact of the release of radioactive materials to theenvironment.

This description appears in Section I of the McGuire Nuclear Station (MNS) Emergency Plan.The replacement of the Raddose-V dose assessment tool with URI involved rigorous testing and walkdowns toensure the tool was ready for implementation.

Duke Energy and the URI vendor performed a Validation and Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.3Verification of the program to support implementation of the change. In addition, MNS ERO members qualified in dose projections received training on the changes and differences in dose projection methodology betweenRADDOSE-V and URI. This change to replace Raddose-V with URI does not change intent. This changesupports the Duke Energy fleetwide initiative to replace the dose projection tool used for dose assessment andfor protective action decision-making at all nuclear sites with an enhanced and improved methodology.

Thefleet procedure AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment" will now provide MNS doseassessment personnel with instructions for performing dose projections at the MNS site. The implementation of AD-EP-ALL-0202 ensures the correct software program for performing dose projections is used. Thischange continues to comply with planning standards, as described in 10 CFR 50.47(b) and 10 CFR 50,Appendix E requirements.

The change which supports the replacement of Raddose-V with URI is strictly administrative and continues tocomply with planning standards, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E requirements.

==

Conclusion:==

The proposed activity Z does / E3 does not continue to comply with the requirements.

Reduction in Effectiveness (RIE) Evaluation and

Conclusion:

BL 51. Evaluation:

The screening of the change from Raddose-V to URI identified two affected emergency planning functions associated with 10 CFR 50.47(b)(8) and 10 CFR 50.47(b)(9),

as described above in the Impact and Licensing Basis Determination.

The change replaces RADDOSE with URI as the principal dose assessment tool. While the user interface forURI differs from that of RADDOSE, the assessment methodologies of both applications are essentially thesame. Both employ the same dose conversion factors for determining source term dose. Both applications also use similar meteorological models of Gaussian plume dispersion.

URI provides a site specific overlay on the existing RASCAL meteorological, dispersion, and dose assessment models for all required input for emergency dose assessment as well as reports and plume graphics.

Using theURI interface, the user does not interact with any part of the original RASCAL input or output screens.Three of the primary purposes of URI are to make an interface that includes significant additional site specificprocesses (e.g. site specific effluent monitors),

to simplify the input process for the user, and to use an industrycommon dose assessment model.URI operates by providing a single input / result display form with non-serial input, and uses a 'pathway' release condition process rather than requiring the user to answer repetitive questions about the release.

Byselecting a 'pathway',

options are set including default meteorological towers, release heights, applicable effluent

monitors, etc. to limit the number of sequential questions the user must answer and to preventselections that do not match. While all emergency effluent dose assessment systems require similarinformation (met data, isotopic mix, release magnitude),

URI minimizes the effort required and significantly limits the opportunity for inappropriate selections.

Options selections are defined for each specific pathway,which both prevent inappropriate selections and highlight to the user the available options for defining theengineered active and passive particulate and iodine removal processes that affect the mix appropriate for theselected pathway.Numerous additional

reports, data displays, etc. are provided for details when needed. Plume plots areprovided, and a graphical display of areas exceeding the protective action guideline (PAG) limit is available.

The PAG graphic can be based on either the standard 16 sectors and 3 distances or on geo-political emergency response areas.One distinction between RADDOSE and URI deals with the identification of protective action recommendations (PARs). A feature of RADDOSE automatically flags the user when a dose projection determines that a PAR Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.3threshold has been met. The user is then expected to refer to approved procedures to confirm the validity ofthis indication.

Experience has shown that the automatic feature can be misleading under certain conditions and has led to incorrect PAR recommendations, particularly when the dose projection was performed by a lessexperienced user.URI does not have this automatic flagging feature.

PAR determination is made solely on approved procedural guidance without reliance on a potentially misleading indication.

Multiple options for source term basis are provided including monitored with single channel effluent

monitors, monitored with multi-channel group monitors, or release point samples, and numerous unmonitored optionsincluding containment high radiation

monitors, containment leakrate without monitors, RCS leakrate, or fieldteam back calculation.

Three assessment methods are provided; a "Detailed" option for more experienced users, a "Rapid" option thatmakes more fundamental assumptions that is intended for immediate on-shift

response, and a "Summation" option that allows for adding multiple concurrent releases.

While the "Detailed" and "Rapid" options areconsistent with current RASCAL assessment modes, the "Summation" option is an enhancement resulting fromFukushima experience.

The URI application, using site-specific inputs, has been evaluated against the software quality assurance criteria of NSD-800.

Comparison of test cases for RADDOSE and URI show consistently satisfactory results.The two applications showed no significant difference in the timeliness or accuracy of dose assessment information.

In summary, URI is characterized by:* a user-friendly input interface,

• graphical overlays displaying projected plume paths and dose values,* the ability to perform dose projections using multiple simultaneous

releases, and* wide acceptance by both the industry and the NRC as an effective dose assessment application.

The change does not result in a reduction in effectiveness of facilities, response organizations, or responseequipment.

This change is strictly administrative and does not change intent. This change supports thereplacement of the RADDOSE dose assessment tool with Unified RASCAL Interface (URI). This change doesnot affect the timeliness, accuracy or capability to determine or process dose projections and supports afleetwide initiative to align dose assessment tools at all Duke Energy nuclear plant sites.This change does not affect the emergency planning functions associated with 10 CFR 50.47(b)(8),

becausethis change continues to ensure that adequate facilities and equipment are maintained at MNS to supportemergency

response, including equipment used for performing dose projections.

This change does not affectthe applicable supporting requirement which is described in 10 CFR 50, Appendix E.IV.E, because this changecontinues to ensure that adequate provisions shall be made and described for emergency facilities andequipment.

In addition, this change continues to meet informing criteria described in NUREG-0654, SectionII.H.8.This change does not affect the emergency planning function associated with 10 CFR 50.47(b)(9),

because thechange continues to ensure that methods,

systems, and equipment for assessment of radioactive releases arein use at MNS. This change does not affect the applicable supporting requirement described in 10 CFR 50,Appendix E.IV.B and E, because this change continues to ensure that equipment is available for determining magnitude and assessment of releases to the environment.

In addition, this change continues to meetinforming criteria described in NUREG-0654, Section 11.1 (8-9) and NUREG-0696, Section 4.8.As stated above, this change does not reduce the effectiveness of the MNS Emergency Plan. Instead, thechange described in this revision continues to provide additional assurance that the ERO has the ability andcapability to:e respond to an emergency;

• perform functions in a timely manner; Emergency Planning Functional Area ManualAttachment 3.10.7.33.10 10CFR 50.54(q)

Evaluations

" effectively identify and take measures to ensure protection of the public health and safety; and" effectively use response equipment and emergency response procedures.

This change enhances ERO readiness to support a classified emergency, resulting in an improved capability toensure health and safety of plant personnel and the general public. This change continues to meet NRCrequirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.This change is an overall improvement to the MNS Emergency Preparedness Program.Conclusion:

The proposed activity E does / Z does not constitute a RIE.Effectiveness Evaluation Results .LOCK6Z The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E and theactivity does not constitute a reduction in effectiveness.

Therefore, the activity can be implemented withoutprior approval.

U The activity does not continue to comply with the requirements of §50.47(b) and §50 Appendix E or theactivity does constitute a reduction in effectiveness.

Therefore, the activity cannot be implemented withoutprior approval.

Pr r Name: -,........

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Reviewer N me-Approver Name:/2'? ~Kevin L. Murray .Prepr-- atRev' intA]V Si nature.................................

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.Date- 4-1/- .Date:Date:// -//-/V-II-/

H. Emergency Facilities and Equipment H. 1 Technical Support Center (TSC)/Operations Support Center (OSC)H. L.a Control Room. The Control Room is utilized for evaluation and control of the initialphase of an emergency, including corrective actions and notification and activation ofMcGuire, Duke Energy, state and local emergency response organizations.

TheControl Room has redundant (telephone and alternate) two-way communications withemergency centers and off-site agencies.

See Figure F-I for communication scheme.H. i.b Technical Support Center. (Figure H-i) The Technical Support Center (TSC) isutilized for evaluation of plant status by knowledgeable plant, vendor, NRC and othersupport groups during an emergency.

This center will also be utilized to direct the on-site and initial off-site aspects of an emergency.

Anticipated occupants are defined inEmergency Planning Group Manual Section 1.1, On-site Emergency Organization.

The TSC has the following capabilities:

1. Redundant two-way communications with the Control Room, the OSC, theEmergency Operations Facility and the Nuclear Regulatory Commission Operations Center. See Figure F-2 for communication scheme.2. Monitoring for direct radiation and airborne radioactive materials with localreadout of radiation level and alarms if levels are exceeded.

3. Display, printout or trend record of comprehensive data necessary to monitorreactor system status and to evaluate plant system abnormalities, in-plant andoff-site radiological parameters and meteorological parameters are available.

This capability is provided via the operator aid computer.

Capabilities to accessand display parameters, individually or in groups is provided.

4. Ready access to as-built plant drawings such as general arrangements, flowdiagrams, electrical one-lines, instrument

details, etc.5. Radiological habitability during postulated radiological accidents to the samedegree as the Control Room.6. Provisions for staffing by the Station Manager (Emergency Coordinator),

advisors and representatives from the site as necessary.

Room is also providedfor NRC personnel.

Space for up to 35 persons plus instrumentation displaysare provided.

The TSC is located near the Control Room, on elevation 767, in the ServiceBuilding.

The TSC is within one (1) minute walking distance from the ControlRoom. This is a permanent facility.

Rev. 14-5H-1 December, 2014 H. i.c Operations Support Center. (Figure H-2) The Operations Support Center (OSC) is thatplace designated for Operations, Radiation Protection, Chemistry, Maintenance, IAE,and others as necessary, to report to in an emergency condition.

This center will beused to brief and prepare site personnel for work assignments in support of theemergency condition.

The OSC is located on the Auxiliary Building roof office,elevation 784'. Workspace and resources are shared with the Outage Control Center(OCC). The OSC shall have priority over the OCC if any emergency is declared duringan outage. The OSC has adequate capacity and supplies including provisions forrespiratory protection, protective

clothing, portable

lighting, portable radiation monitoring equipment and communications equipment.

H.l.d Alternate Facilities.

(Figures H-9 and H-10) Alternate TSC and OSC facilities havebeen established in the McGuire Admin Building as a contingency.

Communications equipment similar to that provided in the designated TSC and OSC facilities is available but not all regulatory required equipment/capability is provided.

H.2 Emergency Operations Facility (EOF)The Emergency Operations Facility (EOF) is utilized for direction and control of all emergency and recovery activities with emphasis on the coordination of off-site activities such ascommunications with local, state and federal agencies, and coordination of corporate and otheroutside support.

Anticipated occupants are the EOF organization and appropriate state andfederal agency representatives.

The EOF has the following capabilities:

a. The capability for obtaining and displaying plant data and radiological information foreach reactor at a nuclear power reactor site and for each nuclear power reactor site thatthe facility serves.b. The capability to analyze plant technical information and provide technical briefings onevent conditions and prognosis to licensee and offsite response organizations for eachreactor at a nuclear power reactor site and for each nuclear power reactor site that thefacility serves.c. The capability to support response to events occurring simultaneously at more than onenuclear power reactor site if the emergency operations facility serves more than onesite.Rev. 14-5H-2 December, 2014 The Common EOF in Charlotte serves as an alternate facility that would be accessible even ifthe site is under threat of or experiencing hostile action, to function as a staging area foraugmentation of emergency response staff and having the following characteristics requiredcollectively of the alternate facilities for use when onsite emergency facilities cannot be safelyaccessed during hostile action:* The capability for communication with the emergency operations

facility, control room,and plant security.

" The capability to perform offsite notifications.

• The capability for engineering assessment activities, including damage control teamplanning and preparation.

The EOF has redundant two-way communications with the Technical Support Center andappropriate off-site support agencies.

(See Section F).The EOF is located at 526 South Church Street, Charlotte, NC in the Energy Center Phase I,first floor (ECI-0120 through 0134). The EOF layout and location are shown on Figures H-3thru H-5.The Joint Information Center and Media Center are utilized for the origination of newsbriefings and interviews.

Anticipated staffing includes the News Group personnel, industry andgovernment representatives and support personnel.

News media personnel can beaccommodated for press conferences, etc., in the Media Center. (See Figure H-6 and H-7.)The Joint Information Center has two-way communications with the Emergency Operations Facility and corporate headquarters.

The Joint Information Center (JIC) is located in Duke's Energy Center, 526 South ChurchStreet, Charlotte, N.C. The JIC is located on the first floor, room ECI-0 172.The facilities and resources in the JIC include:* Work space* Telephones

• Facsimile machines* Copy machines* Podium and PA system* Tone alert radio* TV monitor and VCR for real time viewing of the press conferences and taped reviewof news broadcasts from all three major networks* Status board* Wall charts dealing with nuclear site systems and evacuation zones* Name tags* Limited clerical support as needed* Meals during long term activation

• Security escort to other JIC facilities as neededRev. 14-5H-3 December, 2014 The media center is located in Duke's Energy Center, 526 South Church Street, Charlotte, N.C.The center is located on the first floor in the O.J. Miller Auditorium.

The facilities and resources in the Media Center include:* PA system and direct access to recording

• 18 telephones for news media* Court recorders for prompt press conference transcripts

• Charts dealing with nuclear site systems and evacuation zones* Modern/computer connections for the news media* Overhead projector

• Slide projector

• Screen* Press kits* News releases* Technical resources

• Security, registration and badgingH.3 State and Local Government Emergency Operations CentersSee County and State Plans.H.4 Activation and StaffingMcGuire emergency centers (TSC, OSC) are activated as required by the appropriate Emergency Response Procedure.

Activation of the TSC and OSC is required for Alert andabove emergency conditions.

Timely activation and staffing of the Emergency Operations Facility is important to allow the Nuclear Site staff the ability to correct the situation withminimal interference from outside organizations.

The Emergency Coordinator will perform therole and function of the EOF Director until activation of the EOF has taken place. The EOFOrganization will be alerted and staffed for Alert and higher emergency classifications.

TheEOF will be staffed using 75 minutes as a goal for the minimum staff to be in place andoperational.

H.5 Assessment ActionsOnsite monitoring systems used to initiate emergency measures are defined in Section I. Thoseused for conducting assessment evaluations during any emergency condition are listed below:H.5.a Meteorological.

A description of the primary meteorological measurement facility isfound in Appendix

2. These basic meteorological parameters are displayed in theControl Room, see Figure H-8, Generalized Meteorological System.1. During periods of primary system unavailability, an alternate source ofmeteorological data is established as the NWS (NATIONAL WEATHERSERVICE) office. Wind direction and speed are from standard NWSinstrumentation at conventional heights.Rev. 14-5H-4 December, 2014 Wind direction from the NWS can replace the tower (40 m) wind direction.

Wind speed from the NWS can replace the lower tower (10 m) wind speed fordose calculation purposes; it can also replace the tower (40 m) wind speed fortransport speed considerations.

A monthly telephone

contact, initiated by plant personnel, with the NWS officewill be established to insure that this basic meteorological information can beaccessed.

See PT/0/A/4600/089.

2. The following field checks will be performed each week by plant personnel:

Wind Direction (a) Recorder Time Accuracy(b) Recorder Zero(c) Translator Zero(d) Translator Full ScaleWind Speed(a) Recorder Time Accuracy(b) Recorder Zero(c) Translator Zero(d) Translator Full ScaleDelta -Temperature (a) Recorder Time Accuracy3. Onsite meteorological instruments will be calibrated at a frequency specified byTechnical Specifications.

During calibration

periods, basic meteorological data,characteristic of site conditions, will be accessible from the NWS. Theseinstruments will be calibrated in accordance with approved procedures.

Hydrologic A hydrological description of the McGuire Nuclear Site is located in the MNS FSAR,Section 2.4.SeismicA description of the seismic monitoring instrumentation and area seismology studiesare found in McGuire FSAR, Sections 3.7 and 2.5 respectively.

Rev. 14-5H-5 December, 2014 H.5.b Radiological MonitorsRadiological monitors including process monitors, area monitors, post-accident monitoring equipment, effluent

monitors, personnel monitoring

devices, portablemonitors and sampling equipment are described in various Radiation Protection procedures, the McGuire FSAR, Emergency Plan Implementing Procedures and SafetyEvaluation Report.H.5.c. Plant Parameters Equipment and instrumentation to monitor plant parameters such as reactor coolantpressure, temperature, levels, containment

pressure, temperature,

humidity, sumplevels, hydrogen concentrations, system flow rates, status, line-ups, are included inoperating and emergency procedures.

Examples of specific instruments used foraccident evaluation are given in Section I.H.5.d Fire Detection Fire detection devices of the ionization-chamber and thermal type are locatedthroughout the site.H.6 Data, Monitoring Equipment and Analysis Facilities Provisions have been made and exist to obtain data from off-site agencies or monitoring equipment and analysis facilities.

The provisions are described below:a. Meteorological information is available from the National Weather Service as described in Section H.5.a. Monitoring of the Catawba River for hydrologic data is conducted within the Duke System of dams and hydro-electric facilities.

Seismic data is available from the U.S. Geological Survey Office as provided for in the McGuire Procedure RP/O/A/5700/007 (Earthquake).

b. Radiological monitors for emergency environmental monitoring are provided inemergency kits. The established environmental monitoring network and samplingequipment in the surrounding area are also available to provide emergency assessment data. Environmental Radiological Monitoring equipment includes radioiodine andparticulate continuous air samplers and thermoluminescent dosimeters.

Thethermoluminescent dosimeters are posted and collected in accordance with Table 1,Branch Technical

Position, Rev. 1 of November, 1979. Emergency PlanningImplementing Procedure, HP/O/B/1009/023 (Environmental Monitoring for Emergency Conditions) lists locations of posted thermoluminescent dosimeters and air samplers.

c. See Section C.3.Rev. 14-5H-6 December, 2014 H.7 Offsite Radiological Monitoring As described in H.6.b above.H.8 Meteorology Instrumentation and Procedures See Section H.5.a.H.9 Operations Support CenterSee Section H. 1 .c.H.10 Emergency Equipment/Instrumentation Inspection, Inventory, Operational Check, Calibration McGuire Procedure PT/O/A/4600/088, Functional Check of Emergency Vehicle andEquipment, defines the inspection, inventory and operational checks required of emergency equipment.

Various Radiation Protection procedures define the criteria for calibration of allmonitoring equipment located in the emergency kits.H. 11 Emergency KitsRadiological Emergency kits are described in PT/O/A/4600/088, Functional Check ofEmergency Vehicle and Equipment.

H. 12 Receipt and Analysis of Field Monitoring DataDuke Energy's Emergency Operations Facility (Radiological Assessment Manager) will be thecentral point for the receipt of off-site monitoring data results and sample media analysis resultscollected by Duke personnel.

Resources exist within the organization to evaluate theinformation and make recommendations based upon the evaluations.

The Radiological Assessment Manager's group will perform these evaluations and make recommendations to theEOF Director for protective actions.

The EOF Director is the individual responsible formaking protective action recommendations to off-site agencies after activation of the EOF.Rev. 14-5H-7 December, 2014 FIGURE H-I/ Statim-UBoardPointer CO#W IIsite IEmner. Status Assam./ RP Mgr.EPinr. Coordinators Site Evac. 4959Emergency Coordinat4 4950Reactor Eng4968IAECommunications 4151Ast.Emergency Coordinator ETS Unes NRC Resident256-9004 4519256-9014 401t, 10_System EngMgr4954Selective Signaling 4970RadioOffsite AgencyCommunicator Operations Procedure SupportIOperations Manager InTSC4951Ipplie1DataCoordinators 45174522Emergency Figure H-1Duke EnergyMcGuire Nuclear SiteTechnical Support CenterRev. 14-5December, 2014H-8 FIGURE H-2BriefingRoomI~IMech, LAE, Chem, RP Techs &OPS-10PIZN1 -Engineering x-49712- OPS Liaison x-21263- OPS SRO x-44754- Asst. OSC Coord. x-4952, 45185- OSC Coord. x-49526- IAE Mgr. x-49577- Mach. Mgr. x-49589- RP Tech10- RP Tech11 -RP Tech12- RP Supv. x-497813 -Status Coord. x-429214- Status Coord. #2 x Security x-495616- Supply Chain x496317 -Chemistry Mgr. x-4960CopieroVI13r_ LUINES980-875-1952 980-875-1957 980-875-1 9580Staffing BoardCL P§C FAX5.4423 RP Phone$ Supplies Procedures Supplies Radios & FormscCcCFigure H-2Duke EnergyMcGuire Nuclear SiteOperations Support CenterRev. 14-5December 2014H-9 FIGURE H-3DUKE ENERGYEMERGENCY RESPONSEMNS/CNS/ONS EOFGENERAL LOCATIONMen ImNuedame91=10a0I..9-..- -.N"s51-85u s..[it1;V4)3%.////// 1A.EL-/1r7. ~* CutflibmNUiOSd 6W164tto I,N- 49.S-,t Pt dcaI-'NN..S.Rev. 14-5December, 2014H-10 Figure H-4DUKE ENERGYGENERAL OFFICE RESPONSEFACILITYMcGuire I Catawba I Oconee EOFGENERAL OFFICE BUILDING LAYOUT -CHARLOTTE, NCMINT STDUKEENERGYCENTER-CHURCH ST zWACHOVIACENTERTRYON STThe EOF, Media Center and Joint Information Center are in the Energy Center on the 1 st floor.Rev. 14-5H-1I December, 2014 FIGURE H-5Emergency Operations FacilityEOF GENERAL ARRANGEMENT Figure H-5Duke EnergyMcGuire Nuclear SiteRev. 14-5December, 2014H-12 Figure H-6Duke EnergyMedia CenterI StageChartsi DukelNRC/State/FEMAICounties iI IPodium0 0-----------------------------------

(Rope)(Media Seats) (Media Seats)mm.... masus@Video CamerasI Media Coordinator's Table M State Tables i...... .......(...........).......................................................................

(Partition) a 6 8 8 8 9 a 8 6Media Phones//IKitchenRev. 14-5December, 2014H-13 Figure H-7Duke EnergyJoint Information CenterRumor Control.30UJ0DPCLeadStatesCounties/IMultm-use AreaFax & CopyRev. 14-5December, 2014H-14 FIGURE H-8McGuire and Catawba Nuclear SitesGeneralized Met SystemSensor (Met) andInstrumentation ComputerRoomTSCOutputs to TSC, EOF, Control RoomOSC display areasRead only -mode for NRC and StateState remote interrogation.

Rev. 14-5December, 2014H-15 FIGURE H-9MCGUIRE NUCLEAR SITEALTERNATE TECHNICAL SUPPORT CENTER(EXECUTIVE BOARD ROOM, ROOM 111, ADMIN. BUILDING)

OPSNRC OPS Procedure NRC Resident Mgr. SupportCommunicator Enginer 4 49h Systems 8Engineer 4954 87Reactor PCEngineer 496862 4519 PC 4951 45205-1955 875-4789(PMCL) 875-1953'5-4778 (ENS) 875-4770(HPN) 75-4788 (RSCL) 49504959 PCAssistant Emergency Coordinator Emergency Coordinator RP Site Evacuation Status Emergency Manager Coordinator Coordinator Planner*2211Other TSC Position Locations

• Site Evacuation Coordinator (EP Room 114) -*4458, *4977, *875-1951.

• Offsite Communicator (EP Room 115B -- *4970, DEMNET, *Radio, *875-1951.

" IAE Communicator (CBX Equipment Room 112) -- *4248.* Data Coordinator (CBX Equipment Room 112) -- *4999." Dose Assessor (SCR Room IOOD) -- *4405." Public Affairs (Rooms 118 and 141) -- *4400, *4419, *4233." NRC (NRC Office, Room 126) -- *875-1681.

" Other, use Jaguar Room as needed (Room 144) -- *4826.Office Equipment

" FAX (Mail Room, Room 116) -- *875-4506.

" FAX (EP Room 114) -- *875-4382.

" Copier (Mail Room, Room 116)." Copier (SA Room 170).* CBX (CBX Office in Admin. Building Lobby).* Indicates existing phones. All others are to be plugged in when the Alternate TSC is activated.

Rev. 14-5December, 2014H-16 FIGURE H-10MCGUIRE NUCLEAR SITEALTERNATE OPERATIONS SUPPORT CENTER(TRAINING ROOM TR155, ADMIN. BUILDING)

Mechanical 4958NLO4974RP4965Chem4966NLO4975Mech4973lAE4972ChairStorageBriefingAreaSRO Security Chemistry StatusCoord.Office Equipment 0S00SFAX, Mail Room, Room 116 -- *875-4506.

FAX, EP, Room 114 -- *875-4382.

Copier, Mail Room, Room 116.Copier, SA, Room 170.CBX, CBX Office in Lobby.* Indicates existing phone. All others are to be plugged in when the Alternate OSC is activated.

Rev. 14-5December, 2014H-17 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 1 OCFR 50.54(q)

Evaluations

§50.54(q)

Screening Evaluation Form Activity Description and

References:

MNSEmergency Plan Section H (Emergency Facilities and Equipment)

Rev14-5 December 2014Page H-16 Changed from "SSN-315" to "DEMNET".

BL*CK 1To support a Duke Energy fleetwide initiative, replacing references and instructions associated with Selective Signaling toDuke Emergency Management Network (DEMNET) which is used for notifications to state/county agencies.

The Selective Signaling to DEMNET replacement work is being performed under Engineering Change(EC)# 112636.Fleet procedure, AD-EP-ALL-0406, Duke Emergency Management Network (DEMNET),

Revision 0, includesinformation on how to operate DEMNET.DEMNET was incorporated to remove the Selective Signaling System and on the use of the new communication network,for making emergency notifications to off-site agencies by initiating group calls to the government agencies usingDEMNET "MS'N Notify".Planning Standards 50.47(b)(5) and 50.47(b)(6),

are impacted by the new DEMNET process therefore a IOCFR50.54(q)

Effectiveness Evaluation must be performed.

Activity Scope:[ The activity is a change to the emergency plan[] The activity is not a change to the emergency planBLOCK 2Revision 12 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 10CFR 50.54(q)

Evaluations Change Type: I OC Change Type: D 4-El The change is editorial or typographical El The change does conform to an activity that hasZ The change is not editorial or typographical prior approvalThe change does not conform to an activity that hasprior approvalPlanning Standard Impact Determination:

El §50.47(b)(1)

-Assignment of Responsibility (Organization Control)F- §50.47(b)(2)

-Onsite Emergency Organization El §50.47(b)(3)

-Emergency Response Support and Resources El §50.47(b)(4)

-Emergency Classification System*[ §50.47(b)(5)

-Notification Methods and Procedures*

[ §50.47(b)(6)

-Emergency Communications El §50.47(b)(7)

-Public Education and Information El §50.47(b)(8)

-Emergency Facility and Equipment El §50.47(b)(9)

-Accident Assessment*

EL §50.47(b)(10)

-Protective Response*

El §50.47(b)(1

1) -Radiological Exposure ControlEl §50.47(b)(12)

-Medical and Public Health SupportEl §50.47(b)(13)

-Recovery Planning and Post-accident Operations El §50.47(b)(14)

-Drills and Exercises El §50.47(b)(1

5) -Emergency Responder TrainingEl §50.47(b)(16)

-Emergency Plan Maintenance

• Risk Significant Planning Standards El The proposed activity does not impact a Planning StandardCommitment Impact Determination:

[ CKEl The activity does involve a site specific EP commitment Record the commitment or commitment reference:

[ The activity does not involve a site specific EP commitment I ~Screening Evaluation Results:

J CK 7El The activity can be implemented without performing a §50.54(q) effectiveness evaluation Z The activity cannot be implemented without performing a §50.54(q) effectiveness evaluation PReiwr Name: Prep re Date*,m e: I ~ ~ w S g a u y / ZD a te -

Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.3§50.54(q)

Effectiveness Evaluation FormActivity Description and

References:

MNS Emergency Plan Section H BLOCK I(Emergency Facilities and Equipment)

Rev 14-5 December 2014Page H-16 Changed from "SSN-315" to "DEMNET".

To support a Duke Energy fleetwide initiative, replacing references and instructions associated with Selective Signaling to Duke Emergency Management Network (DEMNET) which is used for notifications to state/county agencies.

The Selective Signaling to DEMNET replacement work is being performed under Engineering Change(EC)# 112636.ew Fleet procedure, AD-EP-ALL-0406, Duke Emergency Management Network (DEMNET),

Revision 0, willalso be issued. The new Fleet procedure includes information on how to operate DEMNET.DEMNET changes were incorporated to remove the Selective Signaling System and add instructions on theuse of the new communication

network, DEMNET. Step details for using the old Selective Signaling systemwere deleted or replaced with instructions for using DEMNET. Step details for using DEMNET include thefollowing:

Initiating group calls to the government agencies with the DEMNET 'V1 Notify" button, use of theAlternate DEMNET buttons, and notes containing supplemental information.

MO,7Additional information regarding this change: d The Selective Signaling emergency communications system has been the primary method of promptcommunication to State and local Offsite Response Organizations (OROs) from the McGuire NuclearStation (MNS) for many years. Within the confines of MNS, Selective Signaling operates as part of thenormal plant communications system (i.e. internal extensions, commercial phones, etc.). Beyond theboundaries of MNS, Selective Signaling transmits over analog lines that are leased from localtelephone providers.

In the past, these lines have been subject to damage by natural and man-madecauses or other failures such that all or part of communication ability of MNS to or from some or all ofthe OROs via Selective Signaling has been lost for various periods of time.Since Selective Signaling is an unmonitored system, it is typically not known that problems exist untilthe system is used (i.e., during periodic

testing, communication checks, drills, etc.). When problemsare identified and reported, it is up to the local telephone provider to determine when the repair(s) canbe made. In addition to the less than reliable service for the Selective Signaling system, Duke Energyhas been notified by local telephone providers that due to the frequency of failures and the everincreasing difficulty in obtaining repair parts / materials, they will no longer be able to provide repair /maintenance support of the antiquated system beyond 2014.As a solution for this, Duke Energy has selected Emergency Management Network (EMnet) asprovided by the vendor, Communications Laboratories (Comlabs).

EMnet is currently in use by anumber of Federal, State, and local government

agencies, and is being implemented by an increasing number of nuclear stations

/ utilities.

EMnet will be referenced as DEMNET for the remainder of thisevaluation.

Comlabs provides

hardware, software,

training, installation and other services necessary for DEMNET to operate.

DEMNET is being implemented across the Duke Energy Fleet as areplacement for Selective Signaling.

DEMNET allows the Control Room, Technical Support Center (TSC), Emergency Operations Center(EOF), and alternative response facilities to communicate with Offsite Response Organizations and/orwith each other using VoIP (voice-over-internet protocol) as the primary method. In the event ofinternet related problems (i.e., slow data transfer rate, unavailability, etc.), the system automatically transfers to satellite communication as a backup. Like Selective Signaling, DEMNET allows internaland external point-to-point contact between individual stations as well as simultaneous conferencing with multiple stations.

This ability is a valuable backup to existing telephone circuits.

The point-to-point Revision 12 Emergency Planning Functional Area Manual3.10 1 OCFR 50.54(q)

Evaluations Attachment 3.10.7.3capability also allows DEMNET to continue to provide Decision Line capability, which enables OROdecision makers to use the system to discuss public protective actions over dedicated

/ controlled access communication links.Via the dedicated DEMNET computer, historical and real-time system status can be readilydetermined.

DEMNET is also monitored by the vendor, Comlabs.

This allows for a more proactive approach in identification and resolution of problems associated with the system should they occur. Inthe event of failure, the application of suitable compensatory measures (i.e., use of back upcommunications) can be made in a more efficient and effective manner.No changes are made to the communications systems that currently serve as a backup to Selective Signaling or the associated implementation process(es) for employing them.DEMNET equipment installed and operated at Duke Energy nuclear plants and support facilities isinstalled and maintained to meet cyber security requirements in accordance with 10 CFR 73.54 andother related guidance.

As part of the installation

process, DEMNET has been extensively tested to ensure connectivity

/operability before being placed in service.

Duke Energy Emergency Response Organization andEmergency Preparedness, along with personnel from Offsite Response Organizations have receivedtraining on the new system as well.As configured, the network that DEMNET resides within MNS causes the system to be powered fromvarious sources based upon the physical location of the individual components within the network.

Inthe event normal and/or backup power supplies become unavailable, and as a result, DEMNET and allother backup communications system become non-functional, MNS and the OROs have a number ofbattery powered portable satellite phones available that can be placed into service in an effort tomaintain the capability of providing prompt communications between MNS and the OROs.Upon implementation across the Duke Energy Fleet and its State and local Offsite ResponseOrganizations, the product name "EMNet" is replaced with the new system name "Duke Emergency Management Network (DEMNET)".

The name "Selective Signaling" will no longer be used, while thename "Decision Line" will continue to be used.Activity Type: BLOCK[ The activity is a change to the emergency planEl The activity affects implementation of the emergency plan, but is not a change to the emergency planImpact and Licensing Basis Determination:

BLOCK 3,* 10 CFR 50.47(b)(5)

-Notification Methods and Procedures (Risk Significant Planning Standard) states:"Procedures have been established for notification, by the licensee, of State and local responseorganizations and for notification of emergency personnel by all organizations; the content of initial andfollow up messages to response organizations and the public has been established; and means toprovide early notification and clear instruction to the populace within the plume exposure pathwayEmergency Planning Zone have been established."

The applicable emergency planning function associated with 10 CFR 50.47(b)(5) states:"Procedures for notification of State and local governmental agencies are capable of alerting them ofthe declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications."

• 10 CFR 50.47(b)(6)

-Emergency Communications states: "Provisions exist for promptcommunications among principal response organizations to emergency personnel and to the public."

Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.3The applicable emergency planning functions associated with 10 CFR 50.47(b)(6) state:" Systems are established for prompt communication among principal emergency responseorganizations.

" Systems are established for prompt communication to emergency response personnel Licensing Basis:This evaluation included a search of McGuire Nuclear Station (MNS) licensing basis documents forreferences to the Selective Signaling system. The search concluded that a review of the Duke EnergyMcGuire Nuclear Station (MNS) Emergency Plan was warranted.

While the MNS Emergency Plan contains several references to Selective Signaling, there are no detailswithin the Emergency Plan regarding usage of the system, other than to indicate that it is the primarysystem used for prompt communications to the offsite response organizations.

DEMNET is replacing Selective Signaling as the primary system used for prompt communications to the offsite responseorganizations.

Other references within the MNS Emergency Plan include facility diagrams which indicate the location ofSelective Signaling telephones.

DEMNET equipment is replacing Selective Signaling in each locationwhere Selective Signaling was present.The MNS Emergency Plan also references periodic testing of Selective Signaling.

DEMNET will be testedin a similar manner and frequency as was Selective Signaling.

Consequently, the replacement of the Selective Signaling system with DEMNET within the MNSEmergency Plan will constitute a name change only.This review concludes that changes to this document relative to the replacement of Selective Signaling withDEMNET do not affect the licensing basis of the MNS Emergency Plan. The changes in this revisionsupport replacement of the Selective Signaling telephone system, which is used for notifications tostate/county

agencies, with a new dedicated telephone system called the Duke Emergency Management Network (DEMNET).

These changes support a Duke Energy fleet-wide initiative to upgrade the dedicated telephone system for notifying state/county agencies of a declared emergency as an overall enhancement to emergency preparedness.

These changes meet or exceed all emergency preparedness requirements based on NRC regulations and requirements.

1. Evaluation:

10 CFR Part 50, Appendix E, Section IV.D.1 states the following:

Administrative and physical means for notifying local, State, and Federal officials and agencies andagreements reached with these officials and agencies for the prompt notification of the public and for publicevacuation or other protective

measures, should they become necessary, shall be described.

Thisdescription shall include identification of the appropriate officials, by title and agency, of the State and localgovernment agencies within the EPZs.10 CFR Part 50, Appendix E, Section IV.D.3 states the following, in part:A licensee shall have the capability to notify responsible State and local governmental agencies within 15minutes after declaring an emergency.

The licensee shall demonstrate

...10 CFR Part 50, Appendix E, Section IV.E.8.d states the following, in part:For nuclear power reactor licensees, an alternative facility (or facilities) that would be accessible even if thesite is under threat of or experiencing hostile action, to function as a staging area for augmentation ofemergency response staff and collectively having the following characteristics:

... the capability to performoffsite notifications;

....NUREG-0696 (Functional Criteria for Emergency Response Facilities),

Section 2.7, states, in part:The TSC voice communication equipment shall include:* Hotline telephone

...* Dedicated telephone

...* Dial telephones

...

Emergency Planning Functional Area Manual3.10 1 0CFR 50.54(q)

Evaluations Attachment 3.10.7.3* Intercommunications systems ...* Communications

... to State and local operations center prior to EOF activation.

NUREG-0696 (Functional Criteria for Emergency Response Facilities),

Section 4.6, states, in part:The EOF shall have reliable voice communications facilities to the TSC, the control room, NRC, and Stateand local emergency operations centers.

The normal communication path between the EOF and thecontrol room will be through the TSC. The primary functions of the EOF voice communications facilities willbe:* EOF management

...* Communications

...* Communications

...* Communications to coordinate offsite emergency response activities, and* Communications

....NUREG-0654 (Criteria for Preparation and Evaluation of Radiological Emergency Response Plans andPreparedness in Support of Nuclear Power Plants),

Section II.F, states, in part:1. The communications plans for emergencies shall include organizational titles and alternates for bothends of the communication links. Each organization shall establish reliable primary and backup meansof communication for licensees, local, and State response organizations.

Such systems should beselected to be compatible with one another.

Each plan shall include:a. provision for 24-hour per day notification to and activation of the State/local emergency responsenetwork; and at a minimum, a telephone link and alternate, including 24-hour per day manning ofcommunications links that initiate emergency response actions.b. provision for communications with contiguous State/local governments within the Emergency Planning Zones;c. provision for communications

...d. provision for communications

...e. provision for alerting or activating emergency personnel in each response organization; andprovision for communication

...The replacement of Selective Signaling and Decision Line (SS/DL) with DEMNET continues to comply withapplicable regulations and commitments by providing a dedicated method of contacting State and localauthorities in a timely manner during an emergency.

Compliance is maintained in the following manner:1. DEMNET is a dedicated system for communication with OROs that is capable of establishing contactwithin 15 minutes of emergency declaration.

This is consistent with the capability of the SS/DLsystem.2. DEMNET stations are present in the Control Room, TSC, EOF, and alternative facilities which arecapableof initiating or receiving point-to-point or conference calls with any ORO site similarly equipped.

Thisis consistent with the capability of the SS/DL system.3. Compatible DEMNET stations are installed in all ORO locations that were serviced by the SS/DLsystem.4. The TSC has an DEMNET station to allow communication with State and local OROs prior to EOFactivation.

This capability existed with the existing SS/DL system.5. DEMNET is a voice communications system with dedicated stations located in the Control Room, TSC,EOF, alternative facilities, and State/local emergency operations centers and is capable of coordinating Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.3offsite response activities via point-to-point or conference calling.

Communications with NRC isconducted using a separate system unrelated to DEMNET. This is consistent with the SS/DL system.NOTE: In addition to voice communications, DEMNET is also capable of transmitting data. The voicecommunications feature of DEMNET is the replacement for SS/DL voice communications capability.

6. DEMNET has redundant features to maintain communication capability in the event of system failure ordegradation.

During normal operation, DEMNET employs voice-over-internet protocol (VolP)technology to establish contact between stations.

Should internet problems (unavailability, slow transfer rate, etc.)occur, the system will automatically shift to satellite communication as a backup. This backup featureis an enhancement that SS/DL did not have. Failure of the SS/DL system required the use of thecommercial telephone system to re-establish communications.

7. By locating an DEMNET station in the continuously staffed Control Room, the licensee provides 24-hour per day capability to establish links to initiate emergency response actions.8. DEMNET stations are established at each contiguous State/local emergency response agency withinthe EPZ. This is consistent with the usage of the SS/DL system.* 10 CFR 50.47(b)(5) states the following:

"Procedures have been established for notification, by the licensee, of State and local responseorganizations and for notification of emergency personnel by all organizations; the content of initial andfollow-up messages to response organizations and the public has been established; and means to provideearly notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established."

The function of this planning standard pertinent to this change is the establishment of procedures for Stateand local governmental agencies that are capable of initiating notification of the declared emergency within15 minutes after declaration of an emergency and providing follow-up notification.

• 10 CFR 50.47(b)(6) states the following:

"Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public."The function of this planning standard pertinent to the change is that systems be established for promptcommunications among principal response organizations.

==

Conclusion:==

The proposed activity Z does / El does not continue to comply with the requirements.

Reduction in Effectiveness (RIE) Evaluation and

Conclusion:

BLOCK, 51. Evaluation:

The screening of this change has identified two (2) affected planning standard functions described above:1. Procedures for notification of State and local government agencies are capable of initiating notification of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notification.

Additional procedures are currently in effect for notification of State and local agencies following adeclared emergency.

These procedures explicitly require that such notification occur within 15 minutesof emergency declaration.

Station procedures were originally intended to address notifications using the Selective Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.3Signaling/Decision Line (SS/DL) system and have likewise been revised to address the change toDEMNET. The functionality and utility of the procedures remain unaffected by the proposed change.Consequently, this evaluation concludes that the change presents no undesirable impact on thisplanning function.

2. Systems are established for prompt communication to emergency response personnel.

The SS/DL system suffered from obsolescence and eroding vendor support.

The communications carriers currently providing service for the system informed the licensee that all support will terminate atthe end of 2014. This prompted the change to DEMNET, a communications system widely used in theemergency response community.

As described above, DEMNET possesses all of the capabilities of SS/DL with additional enhancements not found in the former system. Significant among these is the use of robust VoIP technology andautomatic "failover" to satellite communications in the event of a failure or degradation of the primaryinternet flowpath.

Consequently, this evaluation concludes that the change presents no undesirable impact on this planning function.

The evaluation concludes that the change does not impact either applicable planning function negatively and therefore does not constitute a reduction in effectiveness.

==

Conclusion:==

The proposed activity El does / Z does not constitute a RIE.Effectiveness Evaluation Results Z The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E and theactivity does not constitute a reduction in effectiveness.

Therefore, the activity can be implemented withoutprior approval.

E: The activity does not continue to comply with the requirements of §50.47(b) and §50 Appendix E or theactivity does constitute a reduction in effectiveness.

Therefore, the activity cannot be implemented withoutprior approval.

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....... .a e : .. ........Y .......Reviewer Nae Rev1ie gn r DateApprover Name: (Approver ignate Date-Kevin L Murray /-

I. ACCIDENT ASSESSMENT To assure the adequacy of methods, systems and equipment for assessing and monitoring actualor potential offsite consequences of a radiological emergency condition.

1.1 Emergency Action Level Procedures Emergency Action Level procedures have been established in accordance withNUMARC/NESP-007 (Rev. 2) that was approved by the NRC in Revision 3 of Regulatory Guide 1.101, and subsequent guidance provided in NRC Bulletin 2005-02, the guidanceendorsed in RIS 2006-12 and to support implementation of NEI 03-12. See Bases Documentin Section D.Emergency Response Procedure, RP/0/A/5700/000, Classification of Emergency, will identifythe system parameter and effluent parameter values which can be used to determine theemergency condition.

1.2 Onsite Capability and Resources to Provide Initial Values and Continuing Assessment 1.2.a. Post Accident SamplingThe requirement to have reactor coolant and containment atmosphere post accident samplepanels (PASS) has been deleted per NRC License Amendment 199/180 by letter datedSeptember 17, 2001. As a result, Emergency Plan Implementing Procedures HP/l/B/1009/015, Unit 1 Nuclear Post-Accident Containment Air Sampling System Operating Procedure and HP/2/B/1009/015, Unit 2 Nuclear Post-Accident Containment Air SamplingSystem Operating Procedure have been deleted.

These EPIPs were replaced by Radiation Protection group procedure HP/0/B/1009/032, Sampling Containment Atmosphere UnderAccident Conditions.

HP/O/B/1009/032 is not an EPIP or a part of the EPLAN. It is listedin this paragraph for reference Rurposes only. HP/0/B/1009/032 provides contingency methods for containment atmosphere sampling under accident conditions.

Also as a result of NRC License Amendment 199/180, OP/0/B/6200/090, PALSS Operation for Accident Sampling has been deleted from the EPLAN as an Emergency Plan Implementing Procedure.

However, OP/0/B/6200/090 will be retained as a Chemistry group procedure toprovide contingency methods for reactor coolant and containment sump sampling underaccident conditions.

OP/O/B/6200/090 is not an EPIP or a part of the EPLAN. It is listedin this paragraph for reference ourposes only.1.2.b. Radiation and Effluent MonitorsRadiological monitoring capabilities include process and effluent monitoring systems (FSAR11.4); area monitoring system (FSAR 12.1.4);

plus station portable monitoring instruments, laboratory counters and analyzers (FSAR 12.3.2.4),

including emergency high-range instruments and air samplers.

Rev. 14-5I-i December, 2014 In addition, there are two (2) high range containment

monitors, two (2) high range unit ventmonitors, four (4) steam line monitors per unit and four (4) N-16 steam line monitors per unit.1.2.c In-plant Iodine Instrumentation Radioiodine sampling cartridges are used for sampling containments and unit vents. Radiation Protection personnel are knowledgeable in the appropriate site procedures required and aretrained in the equipment required to determine airborne iodine concentrations in the plant underall conditions.

Procedures to detemn-ine airborne iodine concentrations will cover analyses tobe done if counting room capabilities are not available.

1.3.a/ Method For Determining Release Source Term1.3.bProcedures HP/O/B/1009/006, HP/0/B/1009/010 and AD-EP-ALL-0202 are used on shift, inthe TSC and/or EOF for the calculation of potential off-site doses based on a Design BasisAccident, release of primary coolant, or release of GAP activity situation scaled to actualcontainment monitor readings.

Provisions for use of actual source terms exist in theprocedures.

The magnitude of the release is based on actual effluent monitoring

readings, plant systemparameters (containment pressure),

area meteorology and the duration of the release.1.4 Effluent Monitor Readings Vs Onsite/Offsite ExposureThe procedures referenced in 1.3.a/I.3.b establish the relationship between effluent monitorreadings and on-site/off-site exposures and contamination for various meteorological conditions.

1.5 Meteorological Information Availability Meteorological information will be available to the Emergency Operations

Facility, theTechnical Support Center, the Control Room through use of the Station Operator AidComputer (OAC) and by direct telephone communication.

Meteorological information will beavailable to the NRC through the Emergency Response Data System (ERDS), Health PhysicsNetwork (HPN) or by direct telephone communications with the individual responsible formaking off-site dose assessments either at the Technical Support Center or the Emergency Operations Facility.

Meteorological information will also be given to both the county Emergency Operations Centers and the State of North Carolina during initial and follow-up information via themessage format in Figure E-1.1.6 Release Rates/Projected Dose For Offscale Instrumentation If instrumentation used for dose assessment is offscale or inoperable, dose rates within theReactor Building will be determined using procedure HP/0/B/1009/002, Alternative MethodRev. 14-51-2 December, 2014 for Determining Dose Rate Within the Reactor Building, or HP/0/B/1009/006, Procedure forQuantifying High Level Radioactivity Release During Accident Conditions.

1.7/ Field Monitoring Within E.P.Z.1.8Field monitoring within the McGuire Emergency Planning Zone will be performed inaccordance with HP/0/B/1009/023, Environmental Monitoring for Emergency Conditions.

Four off-site field monitoring teams are comprised from site personnel and are under thedirection of the Field Monitoring Coordinator.

On-site monitoring is performed by Radiation Protection personnel under the direction of the OSC Radiation Protection Supervisor.

HP/0/B/1009/023 describes how to obtain the vehicles to be used, routes to be used, samplingand monitoring equipment to be used, locations of TLD's and directions for taking KI tablets.An emergency radio system is available for the field monitoring teams to use to relayinforlnation to the TSC/EOF.

The state will be able to monitor the results of the fieldmonitoring teams and relay results to the counties.

1.9 Detect and Measure Radioiodine Concentration in the EPZAir sampling results will be obtained through the use of a Portable Single Channel Analyzerand appropriate garmna sensitive detector.

The air sample will be taken with a Portable AirSampler equipped with a CP-100 or an acceptable charcoal cartridge and particulate filter.Interference from the presence of noble gas and background radiation shall not decrease theminimum detectable activity of 1E-7 pCi/cc (microcuries per cubic centimeter) under fieldconditions.

These samples taken by the offsite monitoring teams will be evaluated further by one of theavailable laboratory facilities described in Section C.3. A multi-channel analyzer will be usedto perform this evaluation.

1.10 Relationship Between Contamination Levels and Integrated Dose/Dose RatesProvisions for relating contamination levels, water, and air to dose rates for key isotopes isfound in HP/0/B/1009/021.

1.11 Plume TrackingThe state of North Carolina has arrangements to locate and track an airborne plume ofradioactive materials.

Duke Power Company will have monitoring teams in the field, fixedTLD sites and the capability for airborne monitoring to assist in plume tracking.

Rev. 14-51-3 December, 2014 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 1OCFR 50.54(q)

Evaluations

§50.54(q)

Screening Evaluation Form Activity Description and

References:

BLOKMNS Emergency Plan Section I (Accident Assessment)

Rev 14-5December 2014Click here to enter text.Page 1-2 -Deleted any reference to HP/0/B/1009/029 and SH/0/B2005/001 and replaced with AD-EP-ALL-0202 (Emergency Response Offsite Dose Assessment).

This change supports a fleetwide initiative to replace the dose assessment tools that are currently in place at the DukeEnergy Carolinas sites (using RADDOSE-V) and the Duke Energy Progress sites (using RASCAL) with UnifiedRASCAL Interface (URI) in order to align dose assessment tools at all Duke Energy nuclear plant sites. A new fleetprocedure AD-EP-ALL-0202, Emergency Response Dose Assessment, has been developed which provides instructions forperforming dose projections using Unified RASCAL Interface (URI) at MNS and the other nuclear plant sites.Planning Standards 50.47(b)(8) and 50.47(b)(9),

are impacted by the new URI process therefore a 1OCFR50.54(q)

Effectiveness Evaluation must be performed.

Activity Scope: ' BLOCKI[ The activity is a change to the emergency planED The activity is not a change to the emergency planChange Type: BLOCK 3 .Change Type: K BLOCK4El The change is editorial or typographical

[] The change does conform to an activity that has[ The change is not editorial or typographical prior approval[ The change does not conform to an activity that hasprior approvalPlanning Standard Impact Determination:

El §50.47(b)(1)

-Assignment of Responsibility (Organization Control)[1 §50.47(b)(2)

-Onsite Emergency Organization El §50.47(b)(3)

-Emergency Response Support and Resources

[] §50.47(b)(4)

-Emergency Classification System*El §50.47(b)(5)

-Notification Methods and Procedures*

El §50.47(b)(6)

-Emergency Communications LI §50.47(b)(7)

-Public Education and Information

[ §50.47(b)(8)

-Emergency Facility and Equipment

[ §50.47(b)(9)

-Accident Assessment*

El §50.47(b)(10)

-Protective Response*

El §50.47(b)(1

1) -Radiological Exposure Control[] §50.47(b)(12)

-Medical and Public Health SupportEl §50.47(b)(1

3) -Recovery Planning and Post-accident Operations El §50.47(b)(14)

-Drills and Exercises El §50.47(b)(1

5) -Emergency Responder TrainingEl §50.47(b)(16)

-Emergency Plan Maintenance

• Risk Significant Planning Standards El The proposed activity does not impact a Planning StandardRevision 12 3.10 1OCFR 50.54(q)

Evaluations Emergency Planning Functional Area ManualAttachment 3.10.7.2Commitment Impact Determination:

D The activity does involve a site specific EP commitment Record the commitment or commitment reference:

[ The activity does not involve a site specific EP commitment BLOCK 6Screening Evaluation Results:

i BLOCK7[] The activity can be implemented without performing a §50.54(q) effectiveness evaluation Z The activity cannot be implemented without performing a §50.54(q) effectiveness evaluation e "e eName:.R S e ae Date .Revewe amL e ....... .i ....ew Iintue / ...... .................

I...... ae Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachunent 3.10.7.350.54(q)

Effectiveness Evaluation FormActivity Description and

References:

M NS Emergency Plan Section I BLOCK.I(Accident Assessment)

Rev 14-5 December 2014Page 1-2 for 1.3.b -Deleted procedures HP/0/B/1009/029 and SH/0/B/2005/001 and replaced withAD-EP-ALL-0202.

To support a Duke Energy fleetwide initiative, replacing instructions associated with the RADDOSE doseassessment tool with Unified RASCAL Interface (URI).This change supports a fleetwide initiative to replace the dose assessment tools that are currently in place atthe Duke Energy Carolinas sites (using RADDOSE-V) and the Duke Energy Progress sites (using RASCAL)with Unified RASCAL Interface (URI) in order to align dose assessment tools at all Duke Energy nuclear plantsites. A new fleet procedure AD-EP-ALL-0202, Emergency Response Dose Assessment, has been developed which provides instructions for performing dose projections using Unified RASCAL Interface (URI) at MNS andthe other nuclear plant sites. As a result, specific site procedures for performing dose projections aresuperseded by AD-EP-ALL-0202.

Additional information supporting this changqe:RADDOSE is the current application used for dose assessment and projection of radiological releases duringan emergency.

The proposed change will replace RADDOSE with the Unified RASCAL Interface (URI) as thestandard fleet-wide dose assessment tool.RADDOSE is designed to estimate dose rates and deposition rates at 15-minute time intervals.

From theseestimates, integrated doses (using EPA 400-R-92-001 (EPA-400)[14]

dose factors and methodologies) andtotal deposition are calculated for the length of time covering the release of radioisotopes.

Doses are determined at radial grid and special receptor locations in the Plume Exposure Pathway Emergency Planning Zone while deposition is calculated to fifty miles surrounding the facility, based on radiological andmeteorological data collected at the plant.The RADDOSE model is designed to provide real-time (as the release is occurring) and projected site specificpredictions of atmospheric transport and diffusion as required by NUREG-0654, Revision 1, Appendix.

Atmospheric transport and diffusion are performed using a variable trajectory plume simulation model alongwith realtime meteorological data entered either directly from the PI server or manually.

Likewise, the sourceterm component of RADDOSE uses plant specific radiological data, for a number of accident types, entered viathe PI server or manually.

Using this information along with EPA-400 dose conversion

factors, the modeldetermines dose rates, doses, deposition rates and total deposition.

URI is a computer code intended for use at nuclear generating stations and other emergency response facilities in the event of an actual or potential release of airborne radioactivity to the environment at levels warranting declaration of an Emergency specified in the Radiological Emergency Plan. URI is a replacement for the userinterface normally delivered with the computer code Radiological Assessment System for Consequence AnaLysis

("RASCAL")

maintained and distributed by the by the Nuclear Regulatory Commission (NRC).The URI program:* Provides a user interface specifically designed for users for nuclear power station events." Allows input of all required dose assessment model parameters including meteorological data, planteffluent monitor data, and plant condition and status.* Develops source terms based on user input.Revision 12 Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.3* Creates RASCAL data files based on the specific user input0 Invokes the RASCAL met data processor, plume model processor, and puff model processors.

0 Reads and interprets RASCAL results files and provide reports to the user of doses, affected areas,and other information relevant to emergency plan implementation.

The code has three modes: Rapid Assessment, Detailed Assessment, and Sum Assessment.

RapidAssessment enables on-shift staff to meet regulatory requirements for quick, simplified dose assessments inthe initial phases of an event. Detailed Assessment enables the Emergency Response Organization staff tomake more detailed dose assessments.

Sum Assessment adds multiple concurrent assessment results.Because certain aspects of the interface must be site or unit specific, particularly the release pathways, separate programs are used for each unit, or when possible, multi-unit site if the units are identical.

Themajority of the code forms and modules are common to all these separate

programs, with the pathways andsite specific setup parameters different for each site / unit.The program utilizes two types of data:" User inputs* Constants stored in external encrypted xml format files unique to each site.User inputs are values needed to run dose assessments that vary from assessment to assessment.

Thesewould consist of items such as meteorological data and effluent monitor readings.

Constants are values set internally by the system administrators.

These would consist of items such as siteboundary distances and monitor response factors that define the site and do not change for each assessment.

A separate computer program called "Interface Maintenance" is used to control and generate these constants and maintain the SQL data table files that these constants are stored in. The URI computer programs cannotchange constant values or their related encrypted xml files.The dose assessment computer programs will only be run when a user needs to perform a dose assessment.

The code does not generate any data that needs to be retained by the program after an assessment iscompleted, though reports can be printed or saved to individual files for later retrieval if required.

There are no interfaces with plant safety systems.The URI programs are specifically designed to interface with versions 4.0 to 4.2 of the NRC computer programRASCAL. It is expected that future revisions will remain compatible but would need to be verified for each newRASCAL release.

RASCAL is designed to produce emergency release dose assessments.

RASCALcommunicates between its own separate modules (.exe and .dll modules) using ASCII text data files. The URIprograms interface with RASCAL by creating the same data files in the same format based on the information stored in the xml data tables and the user input. These RASCAL data files are modified or retrieved

'on-the-fly' for each assessment performed.

Activity Type: J .CK2The activity is a change to the emergency planThe activity affects implementation of the emergency plan, but is not a change to the emergency planImpact and Licensing Basis Determination:

ý Mý310 CFR 50.47(b)(8) states: "Adequate emergency facilities and equipment to support the emergency response are provided and maintained."

The emergency planning functions associated with 10 CFR 50.47(b)(8) state:* Adequate facilities are maintained to support emergency response.

Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.30 Adequate equipment is maintained to support emergency response.

The applicable supporting requirement which is described in 10 CFR 50, Appendix E.IV.E states (inpart): Adequate provisions shall be made and described for emergency facilities and equipment, including:

2. Equipment for determining the magnitude of and for continuously assessing the impact of the release ofradioactive materials to the environment; The applicable informing criteria described in NUREG-0654,Section II.H.8 states:Each licensee shall provide meteorological instrumentation and procedures which satisfy the criteria inAppendix 2, and provisions to obtain representative current meteorological information from other sources.10 CFR 50.47(b)(9) states: "Adequate

methods, systems and equipment for assessing and monitoring actualor potential offsite consequences of a radiological emergency condition are in use."The emergency planning function associated with 10 CFR 50.47(b)(9) states:0 Methods, systems and equipment for assessment of radioactive releases are in use.The applicable supporting requirements which are described in 10 CFR 50, Appendix E state:Section IV.B (in part):1. The means to be used for determining the magnitude of, and for continually assessing the impact of, therelease of radioactive materials shall be described,Section IV.E (in part):Adequate provisions shall be made and described for emergency facilities and equipment, including:

2. Equipment for determining the magnitude of and for continuously assessing the impact of the release ofradioactive materials to the environment; The applicable informing criteria described in NUREG-0654, Section 11.1 states (in part):8. Each organization, where appropriate, shall provide methods, equipment and expertise to make rapidassessments of the actual or potential magnitude and locations of any radiological hazards through liquid orgaseous release pathways.

This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.9. Each organization shall have a capability to detect and measure radioiodine concentrations in air in theplume exposure EPZ as low as 10-7 uCi/cc (microcuries per cubic centimeter) under field conditions.

Interference from the presence of noble gas and background radiation shall not decrease the stated minimumdetected activity.

The applicable informing criteria described in NUREG-0696, Section 4.8 states (in part):The EOF technical data system will receive, store, process and display information sufficient to performassessments of the actual and potential onsite and offsite environmental consequences of an emergency condition.

Data providing information...

The EOF data set shall include radiological, meteorological, and other environmental data needed to:" Assess environmental conditions,

" Coordinate radiological monitoring activities, and" Recommend implementation of offsite emergency plans.Licensing Basis:This evaluation included a search of MNS licensing basis documents for references to Dose Assessment, andspecifically for references to RADDOSE-V.

The search concluded that while the dose assessment function is Emergency Planning Functional Area Manual3.10 l0CFR 50.54(q)

Evaluations Attachment 3.10.7.3discussed, specific references to the dose assessment tool and how to perform dose assessments are notdiscussed.

As a result, the MNS licensing basis is not impacted by the change to replace RADDOSE-V withURI as the dose assessment tool. The change is which supports replacement of RADDOSE V with URI and isstrictly administrative and does not affect the licensing basis.Compliance Evaluation and

Conclusion:

BLOCK 41. Evaluation:

The replacement of RADDOSE with URI will continue to comply with applicable regulations and commitments by providing a means of assessing offsite radiation dose during an emergency.

Compliance with the requirements identified above is maintained in the following manner:Item 1URI uses plant effluent monitor values and meteorological instrumentation input for the calculation of doseassessment results.

These results are then used to determine the environmental impact of radioactive materialreleases and to direct the activities of field monitoring teams in plume tracking.

Licensee emergency responsepersonnel also use the assessment results to make protective action recommendations to state and localauthorities.

These features of URI are consistent with the current capabilities of RADDOSE.RADDOSE employs an automatic data download from selected meteorological and radiation monitoring instrumentation to make dose projections.

Typically, these downloads occur at 15-minute intervals.

The userperforming the assessment is responsible for validating the downloaded information against current plantconditions.

While URI has no provision for automatic data downloading, it does allow the user to "drag anddrop" meteorological and radiation parameters into the fields used by the application.

This does not result in asignificant delay since most of the time spent for data input in both RADDOSE and URI is for data validation.

Field syntax restrictions reject out-of-range data to prevent erroneous information from being used in projection calculations.

This feature, coupled with continual validation by the user, minimizes the risk of incorrect dataentry.Item 2The portion of this requirement pertinent to the proposed change is that the licensee provide the method toperform rapid radiological assessments.

RADDOSE uses a Gaussian dispersion model and employs dose conversion factors taken from EPA 400,Manual of Protective Action Guides and Protective Actions for Nuclear Incidents.

URI uses a similar modelwith the same dose conversion factors.

Empirical comparisons of both applications yield similar doseprojection results when subjected to the same radiological and meteorological conditions.

Calculation time ofboth applications is approximately the same. In addition, RASCAL (the underlying calculational base of URI) issanctioned by the NRC and accepted as an industry standard application for dose projection.

Item 3The portion of this requirement pertinent to the proposed change is that the emergency plan will contain adescription of how offsite dose projections are made. This description appears in Section I of the McGuireNuclear Station (MNS) Emergency Plan.Item 4The portion of this requirement pertinent to the proposed change is that the emergency plan will contain adescription of the equipment used for assessing the impact of the release of radioactive materials to theenvironment.

This description appears in Section I of the McGuire Nuclear Station (MNS) Emergency Plan.The replacement of the Raddose-V dose assessment tool with URI involved rigorous testing and walkdowns toensure the tool was ready for implementation.

Duke Energy and the URI vendor performed a Validation and Emergency Planning Functional Area Manual3.10 1 OCFR 50.54(q)

Evaluations Attachment 3.10.7.3Verification of the program to support implementation of the change. In addition, MNS ERO members qualified in dose projections received training on the changes and differences in dose projection methodology betweenRADDOSE-V and URI. This change to replace Raddose-V with URI does not change intent. This changesupports the Duke Energy fleetwide initiative to replace the dose projection tool used for dose assessment andfor protective action decision-making at all nuclear sites with an enhanced and improved methodology.

Thefleet procedure AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment" will now provide MNS doseassessment personnel with instructions for performing dose projections at the MNS site. The implementation of AD-EP-ALL-0202 ensures the correct software program for performing dose projections is used. Thischange continues to comply with planning standards, as described in 10 CFR 50.47(b) and 10 CFR 50,Appendix E requirements.

The change which supports the replacement of Raddose-V with URI is strictly:administrative and continues tocomply with planning standards, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E requirements.

==

Conclusion:==

The proposed activity 0 does / E] does not continue to comply with the requirements.

Reduction in Effectiveness (RIE) Evaluation and

Conclusion:

BLOCK 51. Evaluation:

The screening of the change from Raddose-V to URI identified two affected emergency planning functions associated with 10 CFR 50.47(b)(8) and 10 CFR 50.47(b)(9),

as described above in the Impact and Licensing Basis Determination.

The change replaces RADDOSE with URI as the principal dose assessment tool. While the user interface forURI differs from that of RADDOSE, the assessment methodologies of both applications are essentially thesame. Both employ the same dose conversion factors for determining source term dose. Both applications also use similar meteorological models of Gaussian plume dispersion.

URI provides a site specific overlay on the existing RASCAL meteorological, dispersion, and dose assessment models for all required input for emergency dose assessment as well as reports and plume graphics.

Using theURI interface, the user does not interact with any part of the original RASCAL input or output screens.Three of the primary purposes of URI are to make an interface that includes significant additional site specificprocesses (e.g. site specific effluent monitors),

to simplify the input process for the user, and to use an industrycommon dose assessment model.URI operates by providing a single input / result display form with non-serial input, and uses a 'pathway' release condition process rather than requiring the user to answer repetitive questions about the release.

Byselecting a 'pathway',

options are set including default meteorological towers, release heights, applicable effluent

monitors, etc. to limit the number of sequential questions the user must answer and to preventselections that do not match. While all emergency effluent dose assessment systems require similarinformation (met data, isotopic mix, release magnitude),

URI minimizes the effort required and significantly limits the opportunity for inappropriate selections.

Options selections are defined for each specific pathway,which both prevent inappropriate selections and highlight to the user the available options for defining theengineered active and passive particulate and iodine removal processes that affect the mix appropriate for theselected pathway.Numerous additional

reports, data displays, etc. are provided for details when needed. Plume plots areprovided, and a graphical display of areas exceeding the protective action guideline (PAG) limit is available.

The PAG graphic can be based on either the standard 16 sectors and 3 distances or on geo-political emergency response areas.One distinction between RADDOSE and URI deals with the identification of protective action recommendations (PARs). A feature of RADDOSE automatically flags the user when a dose projection determines that a PAR Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.3threshold has been met. The user is then expected to refer to approved procedures to confirm the validity ofthis indication.

Experience has shown that the automatic feature can be misleading under certain conditions and has led to incorrect PAR recommendations, particularly when the dose projection was performed by a lessexperienced user.URI does not have this automatic flagging feature.

PAR determination is made solely on approved procedural guidance without reliance on a potentially misleading indication.

Multiple options for source term basis are provided including monitored with single channel effluent

monitors, monitored with multi-channel group monitors, or release point samples, and numerous unmonitored optionsincluding containment high radiation

monitors, containment leakrate without monitors, RCS leakrate, or fieldteam back calculation.

Three assessment methods are provided; a "Detailed" option for more experienced users, a "Rapid" option thatmakes more fundamental assumptions that is intended for immediate on-shift

response, and a "Summation" option that allows for adding multiple concurrent releases.

While the "Detailed" and "Rapid" options areconsistent with current RASCAL assessment modes, the "Summation" option is an enhancement resulting fromFukushima experience.

The URI application, using site-specific inputs, has been evaluated against the software quality assurance criteria of NSD-800.

Comparison of test cases for RADDOSE and URI show consistently satisfactory results.The two applications showed no significant difference in the timeliness or accuracy of dose assessment information.

In summary, URI is characterized by:* a user-friendly input interface,

• graphical overlays displaying projected plume paths and dose values,* the ability to perform dose projections using multiple simultaneous

releases, and* wide acceptance by both the industry and the NRC as an effective dose assessment application.

The change does not result in a reduction in effectiveness of facilities, response organizations, or responseequipment.

This change is strictly administrative and does not change intent. This change supports thereplacement of the RADDOSE dose assessment tool with Unified RASCAL Interface (URI). This change doesnot affect the timeliness, accuracy or capability to determine or process dose projections and supports afleetwide initiative to align dose assessment tools at all Duke Energy nuclear plant sites.This change does not affect the emergency planning functions associated with 10 CFR 50.47(b)(8),

becausethis change continues to ensure that adequate facilities and equipment are maintained at MNS to supportemergency

response, including equipment used for performing dose projections.

This change does not affectthe applicable supporting requirement which is described in 10 CFR 50, Appendix E.IV.E, because this changecontinues to ensure that adequate provisions shall be made and described for emergency facilities andequipment.

In addition, this change continues to meet informing criteria described in NUREG-0654, SectionII.H.8.This change does not affect the emergency planning function associated with 10 CFR 50.47(b)(9),

because thechange continues to ensure that methods,

systems, and equipment for assessment of radioactive releases arein use at MNS. This change does not affect the applicable supporting requirement described in 10 CFR 50,Appendix E.IV.B and E, because this change continues to ensure that equipment is available for determining magnitude and assessment of releases to the environment.

In addition, this change continues to meetinforming criteria described in NUREG-0654, Section 11.1 (8-9) and NUREG-0696, Section 4.8.As stated above, this change does not reduce the effectiveness of the MNS Emergency Plan. Instead, thechange described in this revision continues to provide additional assurance that the ERO has the ability andcapability to:9 respond to an emergency;

@ perform functions in a timely manner; Emergency Planning Functional Area ManualAttachment 3.10.7.33.10 10CFR 50.54(q)

Evaluations

" effectively identify and take measures to ensure protection of the public health and safety; and* effectively use response equipment and emergency response procedures.

This change enhances ERO readiness to support a classified emergency, resulting in an improved capability toensure health and safety of plant personnel and the general public. This change continues to meet NRCrequirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.This change is an overall improvement to the MNS Emergency Preparedness Program.Conclusion:

The proposed activity El does / E does not constitute a RIE.Effectiveness Evaluation Results BLOCK6Z The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E and theactivity does not constitute a reduction in effectiveness.

Therefore, the activity can be implemented withoutprior approval.

LI The activity does not continue to comply with the requirements of §50.47(b) and §50 Appendix E or theactivity does constitute a reduction in effectiveness.

Therefore, the activity cannot be implemented withoutprior approval.

Pr Nanme, &ilf.....'& 0 ..V ... ...........

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Reviewer Nme l,R * -...........

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.......Approver Name:Kevin L. MurrayPr are nat eSi nature................

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J. PROTECTIVE RESPONSETo assure that a range of protective actions is available for the plume exposure pathway foremergency workers and the public. Guidelines for protective actions during an emergency, consistent with Federal guidance, are developed and in place and protective actions for theingestion exposure pathway appropriate to the locale have been developed.

To protect onsite personnel during hostile action and ensure the continued ability to safelyshutdown the reactor and perform the functions of the emergency plan a range of protective actions are in place.J. 1. Onsite Alerting and Notification The means and time required to warn, alert and/or notify employees not having emergency assignments (non-essential),

visitors, contractor and construction personnel and otherindividuals who may be on or passing through the owner-controlled area are described inRP/O/A/5700/01 1, Conducting a Site Assembly, Site Evacuation or Containment Evacuation.

Methods to notify and alert onsite personnel (essential and non-essential) during hostile actionactivities are describe in AP/O/A/5500/047, Security Events and RP/O/A/5700/01 1, Conducting A Site Assembly, Site Evacuation or Containment Evacuation.

J.2 Evacuation Routes and Transportation The Operations Shift Manager/Emergency Coordinator or designee uses site and local areamaps, information available from meteorological tower instrument readouts and currentradiological data for determining the evacuation route. Evacuation routes for onsite individuals to suitable offsite locations, including alternatives for weather or radiological conditions isprovided in RP/O/A/5700/01 1, Conducting a Site Assembly, Site Evacuation or Containment Evacuation.

J.3 Personnel Monitoring Radiation Protection emergency personnel survey teams equipped with portable monitoring instruments will monitor employees,

visitors, contract workers and vehicles for contamination at the Relocation Sites. Monitoring will be performed in accordance with Radiation Protection procedure HP/O/B/1009/024, Personnel Monitoring for Emergency Conditions.

Rev. 14-5J-1 December, 2014 J.4 Site Evacuation Procedures

-Decontamination/Non-Essential Personnel CriteriaNon-essential personnel may be evacuated from the plant site in the event of a Site AreaEmergency and will be evacuated in the event of a General Emergency.

Provisions are madefor the decontamination of vehicles and personnel at an off-site location if the situation shouldwarrant.All members of the general public who are on-site must be evacuated if there is a possibility they may be exposed to dose rates in excess of any of the following:

External Radiation Level = 2 mrems/hrAirborne Radioactivity

= 1 times DAC for an unrestricted areaDuring hostile threat conditions that do not require Site Sheltering, Site Relocation of non-essential personnel to locations outside of the protected area are performed in accordance withAP/O/A/5500/047, Security Events and RP/O/A/5700/01 1, Conducting A Site Assembly, SiteEvacuation or Containment Evacuation.

J.5 Personnel Accountability Within thirty minutes of a Site Assembly, all persons within the Protected Area at the McGuireNuclear Site can be accounted for and any person(s) determined to be missing, will beidentified by name. RP/O/A/5700/1 1, Conducting a Site Assembly, Site Evacuation orContainment Evacuation, provides for the accounting of personnel (on site) continuously thereafter.

When hostile threat conditions permit, personnel accountability is performed in accordance with RP/O/A/5700/01 1, Conducting A Site Assembly, Site Evacuation or Containment Evacuation.

J.6 Protective Equipment

-Breathing Apparatus, Protective

Clothes, KIProtective equipment and supplies will be distributed to respiratory qualified personnel remaining on site or arriving on site during the emergency to minimize the effects ofradiological exposures or contamination.

Protective measures will be utilized as follows:Individual Respiratory Protection

-Respiratory protective equipment will be used whenairborne radioactivity levels exceed the appropriate limits specified in 1OCFR20, Appendix B.Self-contained breathing apparatus will also be used in areas that are deficient in oxygen orwhen fighting fires. Respiratory protective equipment will be issued by Radiation Protection orSafety and Health Services.

Self-contained breathing apparatus are available with other firefighting equipment for use by the site fire brigade.Individual Thyroid Protection

-All efforts should be made to utilize respiratory protective equipment to minimize ingestion and/or inhalation of radionuclides and to maintain internalRev. 14-5J-2 December, 2014 exposure below the limits specified in 10CFR20, Appendix B. However, if an unplanned incident involves the accidental or potential ingestion or inhalation of radioactive iodine,Potassium Iodide Tablets (KI) are available to distribution by SH/0/B/2005/003, Distribution ofPotassium Iodide Tablets in the Event of a Radioiodine Release.Use of Protective Clothing

-Protective clothing will be issued when contamination levelsexceed 1000 dpm/100 cm2 beta-gamma and 20 dpm/100 cm2 alpha of smearable contamination.

Protective clothing items are located in the Change Rooms inside the Radiation Control Area, available for emergency use. Special fire-fighting protective clothing andequipment is available in designated site supply storage areas for use by fire brigade personnel.

J.7 Protective Actions Recommendations The Emergency Coordinator (Operations Shift Manager or Station Manager) or the EOFDirector shall be responsible for contacting the state and/or local governments to give promptnotification for implementing protective measures within the plume exposure

pathway, andbeyond it if necessary.

Protective Action Guides are adopted from EPA 400-R-92-001 and in the State Plan guidanceon the use of KI and are shown in Figure J-1. A flowchart to aid the Emergency Coordinator/EOF Director in making Protective Action Recommendations is also shown inFigure J-1. {PIP-G-03-606}

As described in section B.4, the Emergency Coordinator and the EOF Director are responsible for making protective action recommendations.

Prior to activation of the EOF, the Emergency Coordinator will be responsible for making these recommendations.

After activation of theEOF, the EOF Director assumes this responsibility.

Protective action recommendations will beprovided to the off-site authorities (states and counties) who are responsible for implementing public protective actions.

The pre-established warning message format (Figure E-1) will beused in transmitting the recommendations.

The mechanism for making dose projections upon EOF activation is as follows:The Radiological Assessment Manager is responsible for making dose projections on a periodicbasis. Calculations are made using a computer based dose projection model to calculate projected dose to the population-at-risk for either potential or actual release conditions.

Forconditions in which a release has not occurred but fuel damage has taken place and radiation levels in the containment building atmosphere are significant, a scoping analysis will beperformed to determine what recommendations would be made if containment integrity werelost at that time. The analysis will be based upon a design leak rate and upon a projected penetration failure indicated by a hole size of certain diameter.

This analysis will include theuse of actual containment

pressure, realistic meteorology, and actual source term. A TotalEffective Dose Equivalent and Committed Dose Equivalent thyroid dose will be calculated atvarious distances from the plant (site boundary, 2 miles, 5 miles, 10 miles and beyond ifneeded).

These dose projections are compared to the Protective Action Guides in Figure J-l,which are derived from the "Manual of Protective Action Guides and Protective Actions forRev. 14-5J-3 December, 2014 Nuclear Incidents" (EPA-400-R-92-001) and in the State Plan guidance on use of KI. Based onthese comparisons, protective action recommendations are developed by the Radiological Assessment Manager.

The Radiological Assessment Manager informs the EOF Director of thesituation and recommendations for protective actions.

{P[P-G-03-606}

If dose projections show that PAGs have been exceeded at 10 miles, the dose assessment codeand in-field measurements, when available, shall be used to calculate doses at various distances down wind to determine how far from the site PAG levels are exceeded.

The Radiological Assessment Manager shall forward the results to the EOF Director who will communicate thisinformation to the offsite authorities.

J.8 Evacuation Time Estimates An Analysis of Evacuation Time Estimates is available at the site and a summary of the TimeEstimates is included in Figure J-3 and Appendix 4.Under normal weather and for the critical time period (weekday during school hours), themaximum evacuation time for the McGuire EPZ is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 35 minutes.

The critical component in the evacuation is the permanent resident population, all other segments of the population canbe evacuated in less than the maximum time.Under adverse weather conditions (winter storm), the evacuation time for the McGuire EPZ is5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 40 minutes.

This evacuation time assumes evacuation of the entire EPZ. Figure J-3provides more detailed information including evacuation times for individual zones. Appendix4 discusses the ETE used by the site, state and local planners.

A description of the methods and assumptions used in developing the analysis of evacuation time estimates is included in the current Evacuation Time Estimate study for McGuire NuclearSite. (MNS-ETE-12132012, Rev. 000; MNS EVACUATION TIME ESTIMATES (ETE)DATED December 2012). The Evacuation Time Estimates will be considered in evaluating protective action recommendations from the Technical Support Center or the Emergency Operations Facility.

A copy of the most recent study is available in the MNS Master File underMNS-ETE-12132012.000 or EP Office area.An updated ETE analysis will be submitted to the NRC under §50.4 no later than 365 daysafter MNS determination that the criteria for updating the ETE have been met and at least 180days before using it to form protective action recommendations and providing it to State andlocal governmental authorities for use in developing offsite protective action strategies.

Rev. 14-5J-4 December, 2014 The criteria for determination that an updated ETE analysis have been met:a) The availability of the most recent decennial census data from the U.S. Census Bureau:ORb) If at any time during the decennial period, the EPZ permanent resident population increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone,including all affected Emergency Response Planning Areas, or for the entire 10-mileEPZ to increase by 25 percent or 30 minutes, whichever is less, from the currently NRCapproved or updated ETE.During the years between decennial period censuses MNS will estimate EPZ permanent resident population changes once a year, but no later than 365 days from the date of theprevious

estimate, using the most recent U.S. Census Bureau annual resident population estimate and State/local government population data, if available.

MNS will maintain theseestimates so that they are available for NRC inspection during the period between decennial censuses and shall submit these estimates to the NRC with any updated ETE analysis.

MNS ETE analysis, using the 2010 decennial census data from the U.S. Census Bureau, wassubmitted to the NRC via §50.4 on December 13, 2012.J.9 Implementing Protective MeasuresIf protective actions for any off-site location are deemed necessary, the emergency management agency of the affected County, in conjunction with the appropriate State agency(NC-Department of Public Safety) has the legal authority and responsibility for initiating protective measures for the general public in the plume exposure pathway EPZ including evacuation of these areas. Use of sheltering as an alternative to evacuation for impediments toevacuation and special populations is a decision that will be made by the offsite officials.

Sheltering in lieu of evacuation should also be considered during a short term release.

A shortterm release is any release that can be accurately projected to be less than the affectedprotective action zone's evacuation time. An example would be a "puff release".

In addition, sheltering may be appropriate (when available) for areas not designated for immediate evacuation because:

1) it positions the public to receive additional instructions; and 2) it mayprovide protection equal to or greater than evacuation.

{PIP G-04-337}

Public notification ofthe emergency, the resources used to determine if an evacuation is necessary, the evacuation routes, and the methods used for evacuating persons in the plume exposure pathway EPZ areoutlined in the appropriate County and State emergency plans.See County and State Plans for more detailed information.

For hostile action events, a range of protective actions for onsite workers including siterelocation of essential personnel from potential target buildings, timely evacuation of non-essential site personnel, dispersal of critical personnel to safe locations, on site sheltering ofRev. 14-5J-5 December, 2014 personnel and accountability of personnel after the attack are provided in emergency planimplementing procedures AP/O/A15500/047, Security Events and RP/0/A/5700/01 1,Conducting A Site Assembly, Site Evacuation or Containment Evacuation.

J. 10 Implementation of Protective Measures for Plume Exposure PathwayJ. 10.a EPZ MapsFigures i-I and 2 describe the EPZ's, government jurisdictions and evacuation zones forMcGuire Nuclear Site. Evacuation routes are displayed in Figure J-5.J. 1 O.b EPZ -Population Distribution MapFigure J-6 describes the population distribution by Emergency Planning subzone.

TheFSAR describes the population distribution by sector.J.10.c EPZ -Population Alerting and Notification As described in Appendix 3 of this plan, a system exists for alerting and notifying thepopulation (resident and transient) within the EPZ areas. This system is activated bythe county and state organization and includes the use of large fixed-site sirens and theEmergency Alert System (EAS). A back-up means of alerting and notification isdescribed in the State and County Emergency Plans.J. 10.d EPZ -Protecting Immobile PersonsSee County and State Plans.J.10.e Use of Radioprotective Drugs For Persons in EPZSee County and State Plans.J. 10.f Conditions For Use of Radioprotective DrugsSee County and State Plans.J. 10.g State/County Relocation PlansSee County and State Plans.J. 1 O.h Reception Center Locations See County and State Plans.J. 1 O.i Evacuation Route -Traffic Capacities Rev. 14-5J-6 December, 2014 See County and State Plans.J. 10.j Evacuated Area Access ControlSee County and State Plans.J. 1 O.k Planning For Contingencies in Evacuation See County and State Plans.J. 10.1 State/County Evacuation Time Estimates The estimates shown in Appendix 4 are references in the County and State Plans.J. 1 O.m Bases For Protective Action Recommendations Figure J-1 describes the considerations used by Duke management in developing protective action recommendations.

J. 11 Ingestion Pathway PlanningSee County and State Plans.J. 12 Reception Center -Registering

& Monitoring See County and State PlansRev. 14-5J-7 December, 2014 Figure J-11 of 3Guidance for Offsite Protective ActionsGE Has BeenDeclaredIs this a Rapidly NoProgressing SevereAccident (RPSA)(See Note 3)YesINITIAL PAR Determination Note 1: Protective Action Zones (PAZs) are defined in Table I on page 3. SIP is Shelter in Place.Note 2: Offsite Agencies have provided prior knowledge of offsite impediments to evacuation (such as flooding, bridge/road

closures, adverse weather, traffic control not in place, etc.) AND specifically requested that siteNOT issue an evacuation PAR.Note 3: RPSA criteria:

Only Applicable to First PAR after GE Declaration AND two of the following exist fromRP/O/A/5700/000:

(IF RPSA conditions can NOT be confirmed, THEN answer NO)1. LOSS of Containment Barrier per Enclosure 4.1.AND2. POTENTIAL LOSS of Containment Barrier per Containment Radiation Monitor EMF51A or 51B perEnclosure 4.1.ORThere is a significant radiological release projected to exceed 4.3.G. 1 EAL at the site boundary within anhour.(See Note 1) p" Evacuate 2-mile Radius A* Evacuate 2-5 miles Downwind R* SIP 5-10 miles DownwindAre offsite dosee erm s tsprojections or fields-eeasurements 5m C T vroi ?OJ ct0 so<rem CDE Thyroid?m u m140(See Note 1) P" Evacuate 2-mile Radius A* Evacuate 2-5 miles Downwind R,I,1I1,(See Note 1) P* SIP 2-mile Radius A* SIP 2-5 miles Downwind YesRecommend the consideration ofKI use by the public.ARlRecommend theconsideration of KIuse by the publicFToPge2 forrIV y-I.Rev. 14-5December, 2014J-8 Figure J-12 of 3EXPANDED PAR Determination Note 1: Protective Action Zones (PAZs) are defined in Table 1 on page 3. SIP is Shelter in Place.(IF a PAZ has been accurately selected for evacuation, it shall remain selected.)

Note 2: Offsite Agencies have provided prior knowledge of offsite impediments to evacuation (such asflooding, bridge/road

closures, adverse weather, traffic control not in place, etc.) ANDspecifically requested that site NOT issue an evacuation PAR.Note 3: A short-term release is one that can be accurately projected to be < three hours and controlled by the licensee.

This consideration would typically apply to controlled venting of containment.

Note 4: Plant conditions exist which would require the classification of a General Emergency per theEALs. This does NOT include consideration of offsite dose-based EALs.From INITIALPAREvaluate PA]" Increase* Increase" Shift inaadition* Offsite Aimpedim* Hostile aIs thre aHostie NoIs there a known No I RSNo ,,No IF RPSIIscther Based ee nt offisite impediment to SIP PAZAcion Bagrsedevn evacuation?

discussic Isthere a hr-tr [oYsrlaein progress?

(e oe2YsYes (Se Noto3YessYes (See Note 4)Yes.Continuous Assessment R based on changes in any of the following:

in dose assessment projected values.in field team measured values.15-minute average wind direction resulting inal sectors being affected.

(Table 3 on page 3) provides information that offsiteents no longer exist.Lction based event has been terminated.

k, when safer to do so consider evacuation ofs based upon radiological assessment andrns with Offsite Agencies.

jKMite Projecte Doseprojections or field >Nomeasurements exceedPAGs?Table 27*YesI ""11(See Note 1)" SIP 2-mile Radius" SIP 2-5 miles Downwind" SIP additional PAZ(s) that exceed PAGsPARtoeeuiott 1)" Evacuate 2-mile Radius" Evacuate 2-5 miles DownwindPAREvacuate PAZ(s) that exceed P[PAGs. If projected dose exceeds 'A'5-Rem Thyroid CDE then Rrecommend the consideration ofKI use by the public.Rev. 14-5December, 2014J-9 FIGURE J-13 OF 3GUIDANCE FOR OFFSITE PROTECTIVE ACTIONSTable 1Protective Action ZonesWind Direction 2 Mile 2-5 Miles 5-10 MilesRadius Downwind Downwind0.1 -22.5 B,C,L,M D,O,R E,F,S22.6 -45.0 B,C,L,M D,O,R E,Q,S45.1 -67.5 B,C,L,M D,N,O,R E,P,Q,S67.6 -90.0 B,C,L,M D,N,O,R P,Q,S90.1 -112.5 B,C,L,M N,O,R K,P,Q,S112.6 -135.0 B,C,L,M A,N,O,R I,K,P,Q,S 135.1 -157.5 B,C,L,M A,N,O I,K,P,Q157.6 -180.0 B,C,L,M A,N H,I,J,K,P 180.1 -202.5 B,C,L,M A,N G,H,I,J,K,P 202.6 -225.0 B,C,L,M A,D,N G,H,I,J,K,P 225.1 -247.5 B,C,L,M A,D F,G,H,I,J 247.6 -270.0 B,C,L,M A,D F,G,H,I,J 270.1 -292.5 B,C,L,M A,D E,F,G,H,J 292.6 -315.0 B,C,L,M A,D,R E,F,G315.1 -337.5 B,C,L,M D,R E,F,G,S337.6 -360.0 B,C,L,M D,R,O E,F,STable 2PROTECTIVE ACTION GUIDES (PAGs)(Projected Dose or Field Measurements)

Total Effective Dose Committed DoseEquivalent (TEDE) Equivalent (CDE)Thyroid> I Rem > 5 RemTable 3WIND SPEED/DIRECTION ENF Line 9Radiation Protection ManagerMcGuire SDS Group Display ERORD5DPC Meteorological Lab 704-382-0139 704-373-7896 National Weather Service 864-879-1085 Greer, S.C 800-268-7785 Rev. 14-5December, 2014J-10 Figure J-2Description of Evacuation RegionsDegrees From Sub-ZoneRegion Description North: A B C D E F G H I J K L M N 0 P Q R SRO 2-Mile Ring N/A X X X XR02 5-Mile Ring N/A X X X X X X X X XR03 Full EPZ N/A X X X X X X X X X X X X X X X X X X XR04 Catawba County N/A XR05 Gaston County N/A X XR06 Iredell County N/A X X XR07 Lincoln County N/A _ X X X X X XR08 Mecklenburg N/A x x x x x xCountyWind Direction Degrees From Sub-ZoneRegion From: North: A B C D E F G H I J K L M N 0 P Q R SR09 N, NNE 0.1-45.0 X X X X X XRIO NE, ENE 45.1 -90.0 X X X X X XR11 E,ESE, SE 90.1 -157.6 X X X X X XR12 SSE 157.5- 180.0 X X X X XR13 S 180.1 -202.5 X X X X X XR14 SSW, SW 202.6 -247.5 X X X X XR15 WSW, W 247.6 -292.5 X X X X X XR16 WNW, NW, NNW 292.6 -360.0 X X X X X-vactia M i il mto the EPZ ,lliiiWind Direction Degrees From Sub-ZoneRegion From: North: A B C D E F G H I J K L M N 0 P Q R SR17 N 0.1-22.5 X X X X X X X X X X X XR18 NNE 22.6-45.0 X X X X X X X X X X XR19 NE 45.1 -67.5 X X X X X X X X X X X XR20 ENE 67.6-90.0 X X X X X X X X X X XR21 E 90.1-112.5 X X X X X X X X X X X XR22 ESE 112.6 -135.0 X X X X X X X X X X XR23 SE 135.1-157.6 X X X X X X X X X X X XR24 SSE 157.5 -180.0 X X X X X X X X X X X XR25 S 180.1 -202.5 X X X X X X X X X X X X XR26 SSW 202.6 -225.0 X X X X X X X X X X X X X XR27 SW 225.1 -247.5 X X X X X X X X X X X X XR28 WSW 247.6 -270.0 X X X X X X X X X X X X XR29 W 270.1 -292.5 X X X X X X X X X X X XJ-11Rev. 14-5December, 2014 Figure J-2Degrees From Sub-ZoneRegion Description North: A B C D E F G H I J K L M N 0 P Q R SR30 WNW 292.6 -315.5 X X X X X X X X X X XR31 NW 315.1 -337.5 X X X X X X X X X X X XR32 NNW 337.6 -360.0 X X X X X X X X X X XStaged Evacuation

--Ille R ius Evacates then 15kitiail ind to 5 MilesWind Direction Degrees From Sub-ZoneRegion From: North: A B C D E F G H I J K L M N 0 P Q R SR33 N, NNE 0.1-45.0 X X X X X XR134 NE, ENE 45.1 -90.0 X X X X X XR35 E,ESE, SE 90.1-157.6 X X X X X XR36 SSE 157.5- 180.0 X X X X X1137 S 180.1 -202.5 X X X X X X1138 SSW, SW 202.6 -247.5 X X X X XR39 WSW, W 247.6 -292.5 X X X X X XR40 WNW, NW, NNW 292.6 -360.0 X X X X XR141 5-Mile Ring N/A X X I X _ X X X X XSub-Zone(s)

Shelter-in-Place J-12Rev. 14-5December, 2014 Figure J-3MNS ETE Based on 2010 CensusTime to Clear the Indicated Area of 90 Percent of the Affected Population Summer Summer Summer Winter Winter Winter Winter SummerMidweek Weekend Midweek Midweek Weekend Midweek Weekend MidweekWeekend Weekend-cenario:

(1) -2) -3) ---(14)Midday Midday Evening Midday Midday Evening Midday MiddayGood1 Ra Good Rain Good Good ] I Good Good Special RoadwayWeather Weather J Weather Weather j Weather Weather Event ImpactEntire 2-Mile Region, 5-Mile Region, EPZ and each CountyR01 2:35 2:50 1:50 1:50 1:50 2:45 2:55 3:10 1:50 1:50 1:55 1:50 1:50 2:40(B,C,L,M)

R02R02 2:50 3:10 2:25 2:45 2:20 2:45 3:10 3:35 2:25 2:40 3:00 2:20 2:25 3:30(A,B,CD,L,MNOR)

R03(Al 4:35 5:00 3:30 3:55 3:10 4:35 5:00 5:40 3:30 3:50 4:10 3:10 3:40 4:50(All Sub-Zones)I R04 2:25 2:25 2:00 2:00 2:00 2:25 2:25 2:25 2:00 2:00 2:00 2:00 2:00 2:25(K)R05R05 2:20 2:30 2:10 2:15 2:10 2:20 2:30 2:35 2:05 2:15 2:25 2:05 2:10 2:20(R,S)IIR06R06 2:40 2:50 2:25 2:35 2:20 2:40 2:55 3:15 2:25 2:35 2:55 2:20 2:25 3:25(A,1,4)R07R07 3:30 3:40 3:05 3:20 2:50 3:20 3:30 3:55 2:50 3:05 3:25 2:40 3:05 3:30(L,M,N,O,P,Q)

R08 4:35 5:00 3:30 3:55 3:10 4:40 5:05 5:45 3:30 3:50 4:10 3:10 3:35 4:50(A,B,C,D,E,FGH) 2-Mile Region and Keyhole to 5 MilesR09 2:35 2:50 2:20 2:35 2:30 2:35 2:50 3:10 2:20 2:30 2:55 2:30 2:25 3:35(B,C,D,L,M,R)

RI0R10 2:30 2:40 1:55 1:55 1:55 2:35 2:45 2:55 1:55 1:55 2:00 1:55 1:55 2:30(BCLM,O)RI1R11 2:30 2:35 1:55 1:55 1:55 2:30 2:35 2:50 1:55 1:55 2:00 1:55 1:55 2:30(BCL,MNO)IIII R12R12 2:30 2:40 1:55 1:55 1:55 2:35 2:40 2:55 1:55 1:55 1:55 1:55 1:55 2:30(B,C,L,M,N)

R13R13 2:20 2:40 2:10 2:20 2:00 2:20 2:40 3:00 2:10 2:20 2:40 2:00 2:10 3:45(A,B,C,LM,N)I I -IIR14R1M 2:25 2:40 2:10 2:20 2:00 2:25 2:45 3:00 2:10 2:20 2:35 2:00 2:10 3:40(A,BCL,M)IIIII J-13Rev. 14-5December, 2014 Figure J-3MNS ETE Based on 2010 CensusSummer Summer Summer Winter Winter Winter Winter SummerMidweek Weekend Midweek Midweek Weekend Midweek Weekend MidweekWeekend WeekendScenario:

(e) (2 (3 (4 (5 (6 (7) il (9 n10 (111Midday Midday Evening Midday Midday Evening Midday MiddayGood Rain Good Rain Good Good 1 in le Good Rain Ice Good Special RoadwayWeather Weather Weather Weather Ra Weather Weather Event Impact2-Mile Re ion, and Keyhole to 5 MilesR15 2:50 3:15 2:30 2:45 2:25 2:50 3:10 3:35 2:25 2:40 3:05 2:20 2:30 3:35(A,B,C,D,L,M)

R16 2:35 2:50 2:25 2:35 2:30 2:35 2:50 3:10 2:20 2:30 2:55 2:30 2:25 3:40(B,C,D,L,M) 5-Mile Region and Keyhole to EPZ BoundaryR17(A,B,C,D,E,F,L,M,N, 4:10 4:40 3:15 3:35 3:00 4:20 4:40 5:15 3:10 3:30 3:50 2:55 3:10 4:25ORS)R18(A,B,C,D,E,L,M,N, 2:45 3:05 2:30 2:45 2:30 2:50 3:05 3:25 2:30 2:40 3:00 2:25 2:30 3:15O,R,S)" R19(A,B,C,D,E,L,M,N, 2:55 3:15 2:35 2:50 2:35 2:55 3:15 3:35 2:35 2:45 3:05 2:35 2:35 3:20O,Q,R,S)R20(A,B,C,D,L,M,N, 2:45 3:10 2:25 2:40 2:20 2:45 3:00 3:30 2:20 2:35 2:55 2:20 2:25 3:25OQRS)R21(A,B,C,D,L,M,N, 3:00 3:15 2:35 2:55 2:30 2:55 3:15 3:40 2:30 2:45 3:10 2:30 2:35 3:30O,P,Q,R,S)

R22(A,B,C,D,L,M,N, 3:00 3:20 2:35 2:55 2:35 3:00 3:15 3:40 2:30 2:45 3:10 2:30 2:40 3:30OPQRS)R23(A,B,C,D,K,L,M,N, 3:05 3:20 2:40 2:55 2:35 3:00 3:15 3:45 2:30 2:45 3:10 2:30 2:40 3:35O,P,Q,R)R24(A,B,C,D,I,K,LM,N, 3:05 3:25 2:45 3:00 2:45 3:05 3:20 3:45 2:35 2:50 3:15 2:40 2:45 3:30O,P,R)J- 14Rev. 14-5December, 2014 Figure J-3MNS ETE Based on 2010 CensusSummer Summer Summer Winter Winter Winter Winter SummerMidweek MidweekMidweek Weekend Weekend Midweek Weekend Weekend Weekend MidweekWeekend Weekend--Ill-lio (-" ( (3) ( .-(7) (8) (9)- -(- .)3(Midday Midday Evening Midday Midday Evening Midday MiddayGood Rain Good Rain Good Good [ Ice Good Rain Ice Good Special RoadwayWeather Weather I Weather Weather Rain Weather Weather Event Impact5-Mile Region and Keyhole to EPZ Boundary1125(A,B,C,D,I,J,K,L,M, 3:00 3:20 2:45 3:00 2:40 3:05 3:20 3:45 2:40 2:55 3:15 2:35 2:45 3:30N,O,PR)1126(A,B,C,D,H,I,J,K,L, 3:15 3:35 2:50 3:05 2:40 3:15 3:30 4:00 2:45 3:00 3:25 2:35 2:50 3:45MN,OPR)R27(A,B,C,D,G,H,I,J, 3:45 4:05 3:10 3:30 2:55 3:40 4:05 4:35 3:10 3:25 3:50 2:50 3:15 4:35LM,N,O,R) 1R28(A,B,C,D,F,G,H,J, 4:30 5:00 3:30 3:50 3:05 4:35 5:05 5:35 3:25 3:45 4:10 3:00 3:35 4:50LM,N,O,R) 1129(A,B,C,D,F,G,H,L, 4:30 4:55 3:25 3:45 3:00 4:30 4:55 5:35 3:20 3:35 4:05 3:00 3:25 4:40MNOR)1130(A,B,C,D,F,G,L,M, 4:25 4:45 3:15 3:40 3:00 4:25 4:50 5:20 3:15 3:35 4:00 3:00 3:25 4:35N,O,R)1131(A,B,C,D,E,F,G,L, 4:35 4:55 3:35 3:45 3:05 4:30 5:05 5:30 3:25 3:45 4:05 3:05 3:35 4:40MNO,R)1132(A,B,C,D,E,F,L,M, 4:10 4:35 3:10 3:30 2:55 4:20 4:40 5:10 3:15 3:30 3:50 2:55 3:15 4:20N,O,R) IJ-15Rev. 14-5December, 2014 Figure J-3J-16Rev. 14-5December, 2014 Figure J-4MNS ETE Based on 2010 CensusTime to Clear the Indicated Area of 100 Percent of the Affected Population Summer Summer Summer Winter Winter Winter Winter SummerMidweek MidweekMidweek Weekend Weekend Midweek Weekend Weekend Weekend MidweekWeekend Weekend-ce--ri-(-- -] (6(10) (11) Ill (13) (14)Midday Midday Evening Midday Midday Evening Midday MiddayGood Go Good Good Special RoadwayGood Rain Wo od Rain Go d G od Rain Ice Weather Rain Ice W ah r E et I p cWeather Weather Weather Weather IWeather Event ImpactEntire 2-Mile Region, 5-Mile Region, EPZ and each CountyROl 4:30 4:30 4:30 4:30 4:30 4:30 4:35 4:35 4:30 4:30 4:30 4:30 4:30 4:30(B,C,L,M)

R02R02 4:35 4:35 4:35 4:35 4:35 4:35 4:35 5:00 4:35 4:35 4:35 4:35 4:35 4:45(A,B,C,D,L,M,N,O,R)

R03(Al 6:10 6:50 5:00 5:25 5:05 6:20 7:15 7:55 5:05 5:15 5:40 5:05 5:00 7:10(All Sub-Zones)

R04 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35(K)R05 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35(R,S) IR06R06 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 5:20(A,I,J)R07R07 4:35 4:50 4:35 4:35 4:35 4:35 4:35 5:05 4:35 4:35 4:35 4:35 4:35 4:35(L,M,N,O,PQ)

R08 6:05 6:50 4:45 5:10 4:40 6:20 7:00 7:45 4:40 5:15 5:40 4:40 4:50 7:05(A,B,C,D,E,F,G,H) 2-Mile Region and Keyhole to 5 MilesR09R09 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 5:15(B,C,D,LM,,R)

RI0,C 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35(B,C,LM,O)

RllR11 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35(B,C,L,M,N,O)I R12R12 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35(B,C,L,M,N)II J-17Rev. 14-5December, 2014 Figure J-4Summer Summer Summer Winter Winter Winter Winter SummerMidweek Weekend Midweek Weekend Weekend MidweekWeekend Weekend-cenario (3 ( ( (- ( -. ( (10) (1- (i31Midday Midday Evening Midday Midday Evening Midday MiddayGood Rain Good Rain Good Good RainlIce Good Rain Ice Good Special RoadwayWeather Weather Weather Weather Weather Weather Event ImpactEntire 2-Mile Region, and Keyhole to 5 milesR13 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 5:30(A,B,C,L,M,N)

R14(ABCLM) 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 5:30R15(ABCDLM) 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 5:45R16R16 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:40 4:35 4:35 4:35 4:35 4:35 5:20(B,C,D,L,M)

III III5-Mile Region and Keyhole to EPZ BoundaryR17(A,B,C,D,E,F,L,M,N, 5:55 6:10 5:00 5:10 5:00 6:15 6:30 7:20 5:05 5:10 5:35 5:00 5:05 6:40O,R,S)R18(A,B,C,D,E,L,M,N, 4:40 4:40 4:40 4:40 4:40 4:40 4:40 5:10 4:40 4:40 4:40 4:40 4:40 5:40O,R,S)R19(A,B,C,D,E,L,M,N, 5:15 6:00 4:55 5:10 4:55 5:35 6:05 6:20 4:55 5:05 5:30 4:55 5:00 5:40O,Q,R,S)R20(A,B,C,D,L,M,N, 4:40 4:40 4:40 4:40 4:40 4:40 4:40 5:05 4:40 4:40 4:40 4:40 4:40 5:45O,Q,R,S)R21(A,B,C,D,L,M,N, 4:40 5:05 4:40 4:40 4:40 4:40 5:05 5:15 4:40 4:40 4:40 4:40 4:40 5:45O,P,Q,R,S)

R22(A,B,C,D,LM,N, 4:40 4:45 4:40 4:40 4:40 4:40 4:40 5:10 4:40 4:40 4:40 4:40 4:40 5:40O,P,Q,R)

I IJ-18Rev. 14-5December, 2014 Figure J-4Summer Summer Summer Winter Winter Winter Winter SummerMidweek MidweekMidweek Weekend Weekend Midweek Weekend Weekend Weekend MidweekWeekend tWeekendMidday Midday Evening Midday Midday Evening Midday MiddayGood Rain Good Rain Good Good Rain Ice Good Ra Good Special RoadwayWeather Weather I Weather Weather Weather Weather Event Impact5-Mile Region and Keyhole to EPZ BoundaryR23(A,B,C,D,K,L,M,N, 4:40 5:10 4:40 4:40 4:40 4:40 4:50 5:25 4:40 4:40 4:45 4:40 4:40 5:45O,P,QR)R24(A,B,C,D,I,K,L,M,N, 4:40 5:05 4:40 4:40 4:40 4:40 4:50 5:20 4:40 4:40 4:40 4:40 4:40 5:40O,P,R)R25(A,B,C,D,I,J,K,L,M, 4:40 5:05 4:40 4:40 4:40 4:40 4:45 5:20 4:40 4:40 4:40 4:40 4:40 5:40N,O,P,R)R26(A,B,C,D,H,I,J,K,L, 4:40 5:05 4:40 4:40 4:40 4:40 4:45 5:20 4:40 4:40 4:40 4:40 4:40 6:05M,N,O,PR) 1R27(A,B,C,D,G,H,I,J, 5:05 5:25 4:40 4:40 4:40 4:55 5:30 6:05 4:40 4:40 4:40 4:40 4:40 6:40LM,N,O,R)

R28(A,B,C,D,F,G,H,J, 6:00 6:30 4:40 4:55 4:40 6:15 7:05 7:30 4:40 4:45 5:30 4:40 4:55 7:10L,M,N,O,R) 1129(A,B,C,D,F,G,H,L, 6:10 6:25 4:40 5:00 4:40 6:20 7:00 7:30 4:40 4:45 5:25 4:40 4:40 7:05MNOR)R30(A,B,C,DF,G,L,M, 6:10 6:35 4:40 4:45 4:40 6:15 6:55 7:20 4:40 4:45 5:20 4:40 4:40 7:00N,O,R)R31(A,B,C,D,E,F,G,L, 6:05 6:45 4:45 5:10 4:40 6:15 7:15 7:50 4:50 5:05 5:35 4:40 4:50 6:55M,NO,R)R32 6:00 6:30 4:40 4:50 4:40 6:05 6:35 7:00 4:55 5:00 5:20 4:40 4:55 6:30(A,B,C,D,E,F,L,M, N,O,R)J-19Rev. 14-5December, 2014 Figure J-4Midweek MidweekSummerSummerSummerWinterWinterWinterWinter WinterMidweek Weekend Weekend Midweek Weekend Weekend Weekend MidweekI- IWeekend W VeekendScen rio:I (1) ((12 (I13 l(14)Midday Midday Evening Midday Midday Evening Midday MiddayGood Rain Good I Rain Good Good Rain lee Good [ Good Special RoadwayWeather Weather I Weather Weather Ri Weather Rain lce Weather Event ImpactStaged Evacuation

-2 mile Region and Keyhole to 5 Miles4:35 4:55 4:35 4:40 4:35 4:35 4:50 5:10 4:35 4:45 5:10 4:35 4:35 5:25(BC,D,LM,R)

R34R34 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35(BCL,MO)R35R35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35(BC,L,M,N,O)

R36R3M 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35(B,C,L,M,N)II 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 5:30(A,B,C,LM,N)

R38R38 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 4:35 5:30(A,B,C,L,M)

R39R39 4:40 4:55 4:35 4:45 4:35 4:40 5:05 5:15 4:35 4:45 5:10 4:35 4:35 5:55(A,B,C,DLM)III R40R4M 4:35 4:55 4:35 4:45 4:35 4:50 4:50 5:10 4:35 4:45 5:10 4:35 4:35 5:25(BCDLM)R41(A,B,C,D,L,M, 4:55 5:00 4:35 4:45 4:35 5:00 5:10 5:20 4:35 4:50 5:10 4:35 4:35 5:55N,O,R) I I I I I IIJ-20Rev. 14-5December, 2014 Figure J-5Evacuation Route map for MNSMjiesJ-21Rev. 14-5December, 2014 Figure J-6Summary of Population and DemandA 18433 335 1478 3632 0 338 24,216B 931 17 0 2231 0 896 4,075C 1484 27 0 0 0 0 1,511D 22994 418 2065 1163 102 4900 31,642E 37228 674 472 2354 0 4134 44,862F 30364 552 7850 14154 740 6591 60,251G 25408 462 1150 3311 149 5356 35,836H 9665 176 694 2604 0 4826 17,965I 8053 146 19 121 0 0 8,339J 7447 135 128 1398 107 1471 10,686K 2272 41 111 0 0 0 2,424L 1247 23 13 0 0 0 1,283M 238 4 0 0 0 0 242N 5381 98 134 1079 0 509 7,2010 3705 67 0 501 0 0 4,273P 10377 189 5232 1048 112 3408 20,366Q 3394 62 13 56 0 0 3,525R 1667 30 0 43 0 0 1,740S 14970 272 0 756 236 1652 17,886Shadow 9085 61906 70,991RegionTotal 205,258 3,728 19,359 34,451 1,446 43,166 61,906 369,314NOTE:NOTE:Shadow population has been reduced to 20%.Shadow Facilities include both medical facilities and correctional facilities.

J-22Rev. 14-5December, 2014

-I MEmergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.2§50.54(q)

Screening Evaluation Form Activity Description and

References:

B 1, OCKMNS Emergency Plan Section J -Figure J-1, Offsite Protective Actionsrev 14-5 December 2014This is a document change to provide Protective Action Recommendations (PAR) based upon three new scenarios (Rapidly Progressing Severe Accident (RPSA), Hostile Action and Impediments to Evacuation) during a General Emergency (GE). A new recommendation isto Shelter in Place (SIP) instead of immediate evacuation for given times and type of events.RPSA only applies to first PAR for initial General Emergency.

RPSA is based upon the following criterion:

Loss of Containment Barrierper EALs with a potential loss of containment barrier per containment radiation monitors per EALs OR projected radiological release atsite boundary to exceed EAL 4.3.G.1 within one hour.The document change includes using a flowchart and contains the following PAR:* If event is a Rapidly Progressing Severe Accident (RPSA), then the PAR is Evacuate 2 mile radius, Evacuate 2 -5 milesdownwind and SIP 5 -10 miles downwind.

• If event is a Hostile Action or Impediments to Evacuation, then the PAR is SIP 2 mile radius and SIP 2 -5 miles downwind.

• If event is a short term release, then the PAR is SIP 2 mile radius and SIP 2 -5 miles downwind.

• If any other event has generated a General Emergency, then the PAR is evacuate 2 mile radius and evacuate 2 -5 milesDownwind.

The document change DELETED the following PAR as compared to the previous revision;

• If containment radiation level exceeds limits in table, evacuate 5 mile radius. This is replaced per the RPSA PAR.* If wind speed less than 5mph, evacuate 5 mile radius. New PAR has a decision point where OROs can provide input perdecision line for an expansion of PAR for various reasons in their zones such adverse weather.* 100% gap activity release.

This is now based on EALs for containment EMF readings which use 20% gap activity release.* Steps for PAR beyond 10 mile EPZ. These steps are within the Radiation Managers procedure.

This document change is in response to 75772 Federal Register

/ Vol. 76, No. 233 / Monday, December 5, 2011 / Rules and Regulations where the U.S. Nuclear Regulatory Commission (NRC) is issuing Supplement 3, "Guidance for Protective Action Strategies,"

to NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants".

This document provides guidance for addressing new EP requirements for nuclear power plantsbased on changes to EP regulations in 10 CFR 50.47 and Appendix E to Part 50 in the November 23, 2011, final rule. Newly addedprovision of Part 50, Appendix E,Section IV, paragraph 3.Planning Standards 50.47(b)(7) and 50.47(b)(10),

are impacted by the new PAR process therefore a IOCFR50.54(q)

Effectiveness Evaluation must be performed.

Activity Scope: ...Z The activity is a change to the emergency plan[] The activity is not a change to the emergency planChange Type: I L RLCK3 Change Type:F- The change is editorial or typographical El The change does conform to an activity that hasZ The change is not editorial or typographical prior approval[ The change does not conform to an activity that hasprior approvalRevision 12 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 1 0CFR 50.54(q)

Evaluations Planning Standard Impact Determination:

El §50.47(b)(1)

-Assignment of Responsibility (Organization Control)El §50.47(b)(2)

-Onsite Emergency Organization El §50.47(b)(3)

-Emergency Response Support and Resources El §50.47(b)(4)

-Emergency Classification System*El §50.47(b)(5)

-Notification Methods and Procedures*

El §50.47(b)(6)

-Emergency Communications Z §50.47(b)(7)

-Public Education and Information

[E §50.47(b)(8)

-Emergency Facility and Equipment El §50.47(b)(9)

-Accident Assessment*

Z §50.47(b)(10)

-Protective Response*

[] §50.47(b)(1

1) -Radiological Exposure ControlEl §50.47(b)(12)

-Medical and Public Health Support[] §50.47(b)(13)

-Recovery Planning and Post-accident Operations El §50.47(b)(14)

-Drills and Exercises El §50.47(b)(1

5) -Emergency Responder Training[E §50.47(b)(16)

-Emergency Plan Maintenance

• Risk Significant Planning Standards BLOCK 5El The proposed activity does not impact a Planning StandardCommitment Impact Determination:

BLOCKEl The activity does involve a site specific EP commitment Record the conunitment or commitment reference:

[ The activity does not involve a site specific EP commitment Screening Evaluation Results:

L BLOCK 71El The activity can be implemented without performing a §50.54(q) effectiveness evaluation 0 The activity cannot be implemented without performing a §50.54(q) effectiveness evaluation

... ........... _ _ .........

........ .............

.... ... ...... .. .. ..._ ! ..........

.. .... .NrM~rame:

Pre 1gntmre Date: 2 /~Reviewer Nae: Reviewer ignature

-7 _ Date:4e -7f C___ Lý_

§50.54(q)

Effectiveness Evaluation FormActivity Description and

References:

MNS Emergency Plan Section J- Figure J-1, B1 0CKIOffsite Protective Actions rev 14-5 December 2014This is a document change to provide Protective Action Recommendations (PAR) based upon three new scenarios (Rapidly Progressing Severe Accident (RPSA), Hostile Action and Impediments to Evacuation) during a General Emergency (GE). A new recommendation is toShelter in Place (SIP) instead of immediate evacuation for given times and type of events.RPSA only applies to first PAR for initial General Emergency.

RPSA is based upon the following criterion:

Loss of Containment Barrier perEALs with a potential loss of containment barrier per containment radiation monitors per EALs OR projected radiological release at siteboundary to exceed EAL 4.3.G.1 within one hour.The document change includes using a flowchart and contains the following PAR:* If event is a Rapidly Progressing Severe Accident (RPSA), then the PAR is Evacuate 2 mile radius, Evacuate 2 -5 milesdownwind and SIP 5 -10 miles downwind.

• If event is a Hostile Action or Impediments to Evacuation, then the PAR is SIP 2 mile radius and SIP 2 -5 miles downwind.

• If event is a short term release, then the PAR is SIP 2 mile radius and SIP 2 -5 miles downwind.

• If any other event has generated a General Emergency, then the PAR is evacuate 2 mile radius and evacuate 2 -5 milesDownwind.

The document change DELETED the following PAR as compared to the previous revision;

• If containment radiation level exceeds limits in table, evacuate 5 mile radius. This is replaced per the RPSA PAR.* If wind speed less than 5mph, evacuate 5 mile radius. New PAR has a decision point where OROs can provide input perdecision line for an expansion of PAR for various reasons in their zones such adverse weather.* 100% gap activity release.

This is now based on EALs for containment EMF readings which use 20% gap activity release.* Steps for PAR beyond 10 mile EPZ. These steps are within the Radiation Managers procedure.

This document change is in response to 75772 Federal Register

/ Vol. 76, No. 233 / Monday, December 5, 2011 / Rules and Regulations where the U.S. Nuclear Regulatory Commission (NRC) is issuing Supplement 3, "Guidance for Protective Action Strategies,"

to NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness inSupport of Nuclear Power Plants".

This document provides guidance for addressing new EP requirements for nuclear power plantsbased on changes to EP regulations in 10 CFR 50.47 and Appendix E to Part 50 in the November 23, 2011, final rule. Newly addedprovision of Part 50, Appendix E,Section IV, paragraph 3.Activity Type: B_ OCK_2gThe activity is a change to the emergency planDl The activity affects implementation of the emergency plan, but is not a change to the emergency plan Impact and Licensing Basis Determination:

Licensing Basis:75772 Federal Register

/ Vol. 76, No. 233 / Monday, December 5, 2011 / Rules and Regulations states "wherethe U.S. Nuclear Regulatory Commission (NRC) is issuing Supplement 3, "Guidance for Protective ActionStrategies,"

to NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants".

This document providesguidance for addressing new EP requirements for nuclear power plants based on changes to EP regulations in 10CFR 50.47 and Appendix E to Part 50 in the November 23, 2011, final rule. Newly added provision of Part 50,Appendix E,Section IV, paragraph 3."NUREG-0654 FEMA-REP-1, Rev. 1 Criteria for Preparation and Evaluation of Radiological Emergency ResponsePlans and Preparedness in Support of Nuclear Power Plants, Supplement 3, Guidance for Protective ActionStrategies" states"Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support ofNuclear Power Plants,"

updates the previous version of Supplement 3, "Criteria for Protective ActionRecommendations for Severe Accidents,"

issued July 1996. Supplement 3 provides a protective action strategydevelopment tool based on recent technical information and is intended for use by nuclear power reactorlicensees to develop site-specific protective action recommendation procedures.

Offsite response organizations should use Supplement 3 to develop protective action strategy guidance for decision makers. The guidance ofSupplement 3 provides an acceptable method to comply with Appendix E to Part 50, Title 10 of the Code of FederalRegulations (10 CFR)Section IV, paragraph 3 in the use of evacuation time estimates in the formulation ofprotective action recommendations (PAR) for the plume exposure emergency planning zone, and providesguidance for the provisions of 10 CFR 50.47(b)(10) in the development of a range of PAR. Supplement 3 alsoprovides guidance to support the information in NUREG-0654/FEMA-REP-1 that the U.S. Nuclear Regulatory Commission finds to be an acceptable method of meeting the requirements in 10 CFR 50.47(b)(7) for thedevelopment of a public information program.

However, licensees may identify alternative methods of compliance with these requirements."

Appendix E to Part 50, Title 10 of the Code of Federal Regulations (10 CFR)Section IV, paragraph 3 states"Nuclear power reactor licensees shall use NRC approved evacuation time estimates (ETEs) and updates to theETEs in the formulation of protective action recommendations and shall provide the ETEs and ETE updates to Stateand local governmental authorities for use in developing offsite protective action strategies."

10 CFR 50.47(b)(7) states "Information is made available to the public on a periodic basis on how they will benotified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station andremaining indoors),

the principal points of contact with the news media for dissemination of information during anemergency (including the physical location or locations) are established in advance, and procedures forcoordinated dissemination of information to the public are established."

10 CFR 50.47(b)(10)

"A range of protective actions has been developed for the plume exposure pathway EPZ foremergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI), as appropriate.

Evacuation time estimates have been developed by applicants and licensees.

Licensees shall update the evacuation timeestimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent withFederal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZappropriate to the locale have been developed."

MNS Emergency Plan J.7 Protective Actions Recommendations states "Protective Action Guides are adopted from EPA400-R-92-001" EPA 400-R-92-001 states "Public officials are charged with the responsibility to protect the health of the publicduring hazardous incidents.

The purpose of this manual is to assist these officials in establishing emergency response plans and in making decisions during a nuclear incident.

It provides radiological protection guidance thatmay be used for responding to any type of nuclear incident or radiological emergency, except nuclear war.Under regulations governing radiological emergency planning and preparedness issued by the Federal Emergency Management Agency (47 FR 10758, March 11, 1982), the Environmental Protection Agency's responsibilities

include, among others, (1) establishing Protective Action Guides (PAGs), (2) preparing guidance on implementing PAGs, including recommendations on protective

actions, (3) developing and promulgating guidance to State andlocal governments on the preparation of emergency response plans, and (4) developing, implementing, andpresenting training programs for State and local officials on PAGs and protective

actions, radiation doseassessment, and decision making."

MNS Emergency Plan Section D (Emergency Notification System) ENCLOSURE 4.1,BASIS INFORMATION FOR FISSIONPRODUCT BARRIER REFERENCE TABLE states "CONTAINMENT BARRIER EALs: The Containment Barrier includes thecontainment

building, its connections up to and including the outermost containment isolation valves. This barrier alsoincludes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including theoutermost secondary side isolation valve.4.1.C.2 Containment Conditions states "Rapid unexplained loss of pressure (i.e., not attributable to containment spray orcondensation effects) following an initial pressure increase indicates a loss of containment integrity" or "Containment pressure and sump levels should increase as a result of the mass and energy release into containment from a Loss ofCoolant Accident (LOCA). Thus, sump level or containment pressure not increasing indicates an interfacing systems LOCAwhich is a containment bypass and a loss of containment integrity, or some other containment pressure boundary failure".

4.1.C.3 Containment Isolation Valve Status After Containment Isolation Actuation states "Failure to isolate those containment pathways which would allow containment atmosphere to be released from containment is a loss of the containment barrier".

4.1.C.4 Steam Generator (SG) Secondary Side Release With Primary To Secondary Leakage states "Secondary side releases tothe environment include those from the condenser air ejectors, CA turbine exhaust, SG Power Operated Relief Valves(PORVs),

atmospheric dump valves, faulted steam lines, and main steam safety valves. Steam releases, in combination with primary to secondary

leakage, constitute a bypass of the containment and, therefore, a loss of the containment barrier".

4.1.C.SSignificant Radioactive Inventory in Containment states "These values indicate significant fuel damage well in excess ofthe EALs associated with both loss of Fuel Clad and loss of NCS Barriers.

NUREG-1228, Source Estimations During IncidentResponse to Severe Nuclear Power Plant Accidents, indicates that such conditions do not exist when the amount of claddamage is less than 20%. This amount of activity in containment, if released, could have such severe consequences that itis prudent to treat this as a potential loss of containment."

MNS EPLAN J.8 Evacuation Time Estimates states " An Analysis of Evacuation Time Estimates is available at the site and a summaryof the Time Estimates is included in Figure J-3 and Appendix 4.Under normal weather and for the critical time period (weekday during school hours), the maximum evacuation time for theMcGuire EPZ is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 35 minutes.

The critical component in the evacuation is the permanent resident population, all othersegments of the population can be evacuated in less than the maximum time.Under adverse weather conditions (winter storm), the evacuation time for the McGuire EPZ is 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 40 minutes.

This evacuation time assumes evacuation of the entire EPZ. Figure J-3 provides more detailed information including evacuation times for individual zones. Appendix 4 discusses the ETE used by the site, state and local planners.

A description of the methods and assumptions used in developing the analysis of evacuation time estimates is included in the currentEvacuation Time Estimate study for McGuire Nuclear Site. (MNS-ETE-12132012, Rev. 000; MNS EVACUATION TIME ESTIMATES (ETE)DATED December 2012). The Evacuation Time Estimates will be considered in evaluating protective action recommendations fromthe Technical Support Center or the Emergency Operations Facility.

A copy of the most recent study is available in the MNS MasterFile under MNS-ETE-12132012.000 or EP Office area.MNS-ETE-12132012.O00 7.6 Staged Evacuation Results states Table 7-3 and Table 7-4 present a comparison of the ETE compiledfor the concurrent (unstaged) and staged evacuation studies.

Note that Regions R09 through R16 and R02 are the samegeographic areas as Regions R33 through R41, respectively.

To determine whether the staged evacuation strategy is worthy ofconsideration, one must show that the ETE for the 2 Mile region can be reduced without significantly affecting the regionbetween 2 miles and 5 miles. In all cases, as shown in Table 7-3 and Table 7-4, the ETE for the 2 mile region is unchanged whena staged evacuation is implemented.

As shown in Figure 7-4, there is traffic congestion between 2 and 5 miles to the east of theplant. However, this congestion does not propagate upstream into the 2 mile region. Thus, those evacuating from the 2 mileregion are not delayed.

While failing to provide assistance to evacuees from within 2 miles of the MNS, staging produces anegative impact on the ETE for those evacuating from within the S-mile region. A comparison of ETE between Regions, R02 andR09 through R16 and R33 through R41; reveals that staging retards the 90th percentile evacuation time for those in the 2 to5-mile area by up to 65 minutes (see Table 7-1). This extending of ETE is due to the delay in beginning the evacuation trip,experienced by those who shelter, plus the effect of the trip-generation "spike" (significant volume of traffic beginning theevacuation trip at the same time) that follows their eventual ATE, in creating congestion within the EPZ area beyond 2 miles. Insummary, the staged evacuation option provides no benefits to evacuees from within 2 miles and adversely impacts manyevacuees located beyond 2 miles from the MNS.NRC ML 14007A652, EPFAQ 2013-004 Question 3Question concerns Attachment Note 9: Should the most limiting Evacuation Time Estimate (ETE) for the 0-2 mile zone and 2-5mile zones downwind be the deciding factor for PAR determination for a Rapidly Progressing Severe Accident?

NRC ResponseClearly one ETE value for the 0-2 mile zone exists and should be used, regardless of wind direction.

However, ETE values for 2-5mile downwind sectors and associated emergency response planning areas could vary substantially.

In that case the decisionshould be based upon wind direction.

Use of the longest ETE could potentially prevent evacuation when it is more beneficial than SIP. Licensees could reasonably consider this effect where the relevant ETEs vary by more than about 25%. However, thiswould only be applicable when some of the 2-5 mile ETEs exceed the guidance in Supplement 3 (i.e., 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />); otherwise, evacuation would be recommended regardless of wind direction.

Licensees could justify some other value based on a technical evaluation.

NRC ML 14007A652, EPFAQ 2013-004 Question 4Attachment block "Evacuate 2 mile radius and SIP 5 miles downwind, all others monitor and prepare" (staged evacuation):

Arethere circumstances where it is appropriate to not implement staged evacuation.

What type of justification is required?

NRC ResponseStaged evacuation is the preferred protective action strategy and is shown to be effective according to NRC studies.

Stagedevacuation emphasizes protection of those members of the public most at risk and limits impact upon the public in the eventthe General Emergency is mitigated.

Staged evacuation is used in emergency response nationwide.

FINAL 6Licensees can appropriately provide the best technical PAR acknowledging that Offsite Response Organizations' protective action decisions may differ. However, the studies conducted by the NRC to support Supplement 3 used national levelparameters for analyses (Ref.: NUREG/CR-6953, Vol. 1, "Review of NUREG-0654, Supplement 3, 'Criteria for Protective ActionRecommendations for Severe Accidents,"'

(NRC's Agencywide Documents Access and Management System (ADAMS) Accession No. ML080360602)).

Licensees may compare the ETE results for a keyhole evacuation verses a staged evacuation and in somecases perform a site-specific dose-based analysis to show the efficacy of alternate protective action strategies.

The techniques in an example document (ADAMS Accession No. ML13269A370) or those in NUREG/CR-6953 may be instructive in the conductof such analyses.

Results must be made available for NRC staff for review.NRC ML 13269A370 Markup of NRC Draft Response Question 4The following text was excerpted from NRC EPFAQ 2013-004

Response, Rev 1, dated 8.14.2013 (ML13226A313),

Question 4,NRC Response, starting with paragraph four. NEI provides additional underlined text it would like added to the NRC response.

Abasis for the change is explained below.However, the studies conducted by the NRC (NUREG/CR-6953, Vol. 1, "Review of NUREG- 0654, Supplement 3, 'Criteria forProtective Action Recommendations for Severe Accidents,"'

ADAMS Accession No. ML080360602) to support Supplement 3used national level parameters for analyses.

Licensees may compare the evacuation time estimate results for a keyholeevacuation verses a staged evacuation and in some cases perform a site-specific dose-based analysis to show the efficacy ofalternate protective action strategies.

The techniques in the NUREG/CR-6953 may be instructive in the conduct of such analysesand the results should be provided to NRC staff for review. Basis for the Proposed Change to NRC Response 4 NEI requests NRCadd the comparison statement to the NRC response.

Based on assumptions from NUREG/CR-6953, a comparison of Evacuation Time Estimate (ETE) results can be used to determine the efficacy of alternate protective action strategies.

NEI provides anexample methodology in Attachment

2. This methodology integrates principles conveyed at the Advisory Committee onReactor Safeguards (ACRS) -544th Meeting conducted on Thursday, July 12, 2007 (ACRSR-2263),

including a need for strategies that are simple and that consider unique site characteristics.

As background, participants at the July 12, 2007 ACRS meetingheard arguments from the NRC staff on the need to revise NUREG-0654 Supplement 3 based on the efficacy of protective action strategies identified in NUREG/CR 6953, "Review of NUREG-0654, Supplement 3, 'Criteria for Protective ActionRecommendations for Severe Accidents".

ACRS recommended that updates to Supplement 3 to NUREG-0654/FEMA-REP-1, Revision I should take into consideration NUREG/CR 6953 model uncertainties, complexity of decision-making and relatedindustry work. ACRS letter ACDRSR-2263, states "For more slowly progressing source terms, radial evacuation generally performed well, and therefore should remain a major element of protective strategies as recommended in Supplement 3." Theletter further states, "The results show that the effectiveness of a strategy is sensitive to the value of ETE..., but do agree withthe staff that credible ETEs are important to sound decision-making on PARs. The staff should consider uncertainties in ETEsand other uncertainties such as uniformity of population density (as assumed in the study) may affect the ranking of PARstrategies."

NEI's methodology is sensitive to the value of the ETEs and allows licensees the flexibility to select appropriate protective actions based on their unique site characteristics.

This includes the option to refrain from staged evacuations incases where such a strategy would not substantively benefit Page 6 of 18 evacuation times for populations closer to the plantsite and would complicate the decision-making process.

Because they reflect the non-uniformity of populations in and aroundnuclear sites, ETE's should be used in ranking the effectiveness of SIP (as used for determining appropriateness of SIP for aRapidly Progressing Severe Accident),

keyhole evacuation, staged evacuation and other PAR strategies at a particular site. Theexample methodology in Attachment 2 is in line with the principles discussed in the ACRS meeting and the goal of ensuring thatPAR strategies resulting from the implementation of Supplement 3 do not overly complicate the decision making process.

NUREG-0654 FEMA-REP-1, Rev. 1 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support ofNuclear Power Plants, Supplement 3, Guidance for Protective Action Strategies" states within PROTECTIVE ACTION STRATEGY DEVELOPMENT TOOLNOTESImpediments to evacuation include the following:

-Evacuation support (e.g., traffic control) is not yet in place. In this situation, the GE is the initial notification, or if a previous notification was made, theGE notification occurs before preparations to support an evacuation are complete.

Many sites have a low population density within 2 miles, and lack oftraffic control may not be considered an impediment.

The licensee and OROs should discuss this element and reach an agreement.

The licensee andOROs should agree, in advance, on an expected time for evacuation support to be put in place after notification of an emergency classification.

The site-specific protective action recommendation (PAR) procedure for those sites at which a delay of an initial staged evacuation is necessary, pendingsupport setup, should include this time. The licensee would base procedures on the agreement and would not confer with OROs before making theinitial PAR notification.

• In a hostile-action-based GE (armed attack),

OROs may determine that an initial recommendation to shelter in place (SIP) rather than evacuation is thepreferred path. The licensee would discuss this element with OROs and reach an agreement during the development process.

The licensee would baseprocedures on the agreement and would not confer with OROs before making the initial PAR notification.

-In the event of adverse weather, licensees are not responsible for soliciting information or for making a determination that weather or otherimpediments (eg., an earthquake or wildfire) for safe public evacuation exist at the time of the emergency.

However, the licensee will consider animpediment to exist if OROs have previously notified it of such an impediment (e.g., roadways are closed because of deep snow). During the planningprocess, OROs may determine that the licensee does not need to consider adverse weather in its plant PAR procedures.

Compliance Evaluation and

Conclusion:

Evaluation:

RPSA only applies to first PAR for initial General Emergency.

RPSA is based upon the following criterion:

Loss of Containment Barrier per EALs with 0a potential loss of containment barrier per containment radiation monitors per EALs OR projected radiological release at site boundary to exceedEAL 4.3.G.1 within one hour.RP/O/A/5700/000 (Classification of Emergency) provides the EAL criterion and the basis is found in the MNS Emergency Plan Section D.NUREG-0654 FEMA-REP-1, Rev. I Supplement 3 has the following guidance

" Where evacuation cannot be accomplished in the time specified, arecommendation for SIP until the plume has passed is more beneficial.

Concerning the 0 -2 mile radius -If the 90-percent ETE for this area is 2hours or less, immediately evacuate.

IF greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, SIP. Concerning the 2 -5 mile downwind

-If the 90-percent ETE for this area is 3hours or less, immediately evacuate.

Concerning the 5 -10 mile downwind

-SIP, then when safe to do so, evacuate."

NUREG-0654 provides guidance for Sheltering in Place (SIP) based upon Rapidly Progressing Severe Accident (RPSA) if evacuation exceeds twohours for the two mile radius. SIP is based upon Evacuation Time Estimates for 90% population.

The ETE for two hours was exceeded for the 2 mileradius during Midweek Midday for rain/ice.

NUREG-0654 provides guidance for Sheltering in Place (SIP) based upon Rapidly Progressing Severe Accident (RPSA) if evacuation exceeds threehours for 2 -5 miles downwind.

SIP is based upon Evacuation Time Estimates for 90% population.

The greater than 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> requirement for 2 -5miles downwind for SIP per ETE 90% had one time that exceeded 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> due to ice. This time was 3:10 for the 2 mile radius region and keyhole to5 miles. There were several other ETEs that exceeded 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for Midday and Roadway Impact for the 2 mile radius region and keyhole to 5 miles.OROs have option to request the site not to issue an evacuation PAR based upon impediments.

These ETEs are based upon 2 mile radius regionand keyhole to 5 miles.NUREG-0654 provides guidance for Sheltering in Place (SIP) based upon Rapidly Progressing Severe Accident (RPSA) per Supplement 3 guidance thePAR for 5 -10 miles downwind is SIP at all times.NRC ML 14007A652, EPFAQ 2013-004 Question 3 had NRC Response" Licensees could justify some other value based on a technical evaluation."

NRC ML 14007A652, EPFAQ 2013-004 Question 4 had NRC Response "Licensees may compare the ETE results for a keyhole evacuation verses astaged evacuation and in some cases perform a site-specific dose-based analysis to show the efficacy of alternate protective action strategies."

NRC ML 13269A370 was published as the NEI response to EPFAQ 2013-004 where NEI provided methodology for allowing licenses to performevacuations in lieu of SIP. The final of ML 13269A370 allowed NEI to place this methodology into NEI 12-10.KLD TR -682 14140jAs per these regulations and guidance documents, Duke EnergyhM contracted KLD to complete Appendix D (Worksheets I and 2) of NEI 12-10 forthe development of the MNS PAR procedure.

This report utilizes the MNS 2012 ETE to determine the PAR for a Rapidly Progressing Severe Accident(RPSA) and to determine if a staged evacuation is beneficial for the MNS site. Block G of Appendix A of NEI 12-10, Steps 1 through 4 are alsoanalyzed for completeness.

Rapidly Progressing Severe AccidentThe results for the 5 step process are outlined below for MNS: Step 1. The average 90th percentile ETE (excluding the special event and theroadway impact scenarios) for the full EPZ (Region R03) is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 10 minutes.

This is greater than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />so the radial regions are to be evaluated individually using Steps 2 through 4. Step 2. The average 90th percentile ETE value for the 2 mile Region(V) for midday is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 21 minutes, which is longer than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. As discussed in the methodology above, a 25% variance factor can beapplied (in accordance with NRC EPFAQ 2013-004) as the ETE is close to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This 25% variance factor makes the criterion 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 30minutes.

Thus, V equal to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 21 minutes is less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 30 minutes, and the midday PAR for the 2 mile Region is to evacuate.

Theaverage 90th percentile ETE value for the 2 mile Region for evening is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 50 minutes, which is less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. As such, the evening PARfor the 2 mile Region is to evacuate.

Thus, during the midday and evening, the 2 mile Region will evacuate for an RPSA. Step 3. Table 2 presents theRPSA PARs for each 2-5 mile Region for Scenario 6, where V equals 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 11 minutes.

Table 3 presents the RPSA PARs for each 2-5 mileRegion for Scenario 12, where V equals 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 40 minutes.

Table 2 and Table 3 are adapted from Worksheet 1, Table 1 of NEI 12-10. Asshown, the 2-5 mile Region evacuates for all wind directions for both of the bounding scenarios considered.

Step 4. Based on the Step 1 analysis the 5-10 Mile Region should SIP during an RPSA. Step 5. Duke Energy and the OROs should work together toensure the protective action strategy properly accounts for impediments.

UREG-0654 FEMA-REP-1, Rev. 1 Supplement 3 states "In a hostile-action-based GE (armed attack),

OROs may determine that an initialrecommendation to shelter in place (SIP) rather than evacuation is the preferred path."If event is a Hostile Action or Impediments to Evacuation, then the PAR is SIP 2 mile radius and SIP 2 -5 miles downwind.

NUREG-0654 FEMA-REP-1, Rev. 1 Supplement 3 states "The site-specific protective action recommendation (PAR) procedure for those sites atwhich a delay of an initial staged evacuation is necessary, pending support setup, should include this time." Any impediments to allow anevacuation within the ETE is considered as exceeding the ETE. If event is a Hostile Action or Impediments to Evacuation, then the PAR is SIP 2 mileradius and SIP 2 -5 miles downwind.

RP/O/A/5700/012 Enclosure 19 and RP/O/B/5700/029 current revisions have a Caution which implies that Sheltering in lieu of evacuation shouldbe considered during short term release.

PIP M-05-3611.

If event is a short term release during expanded PAR, then the PARs are SIP 2 mile radiusand SIP 2 -5 miles downwind.

This caution is now an action step and will not be discussed any further.

EPA 400-R-92-001 states "The primary objective of evacuation is to avoid exposure to airborne or deposited radioactive material by moving individuals away from the path of the plume. Evacuation, if completed before plume arrival, can be 100 percent effective in avoiding future exposure.

Even ifevacuation coincides with or follows plume passage, a large reduction of exposure may be possible."

MNS EPlan Figure J-3 provides data to evacuate a 5 mile radius verses 2 mile radius and Keyhole to 5 miles. The greatest time for ETE for a five mileradius is 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 45 minutes.

The greatest time for ETE for a 2 mile radius and Keyhole to 5 miles is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 10 minutes excluding a roadimpediment.

EPA 400-R-92-001 states" Sheltering may be an appropriate protective action because:

1. It positions the public to receive additional instructions whenthe possibility of high enough doses to justify evacuation exists, but is small. 2. It may provide protection equal to or greater than evacuation.

3. It isless expensive and disruptive than evacuation.

4. Since it may be implemented

rapidly, sheltering may be the protective action of choice if. rapidevacuation is impeded by, a) severe environmental conditions--e.g.

severe weather or floods; b) health constraints--e.g.

patients and workers inhospitals and nursing homes; or c) long mobilization times--certain industrial and farm workers, or prisoners and guards; d) physical constraints toevacuation--e.g.

inadequate roads. 5. Sheltering may be more effective against inhalation of radioactive particulates than against external gammaexposure, especially for short term plumes."MNS Emergency Plan J.7 Protective Actions Recommendations states "Protective Action Guides are adopted from EPA 400-R-92-001".

NUREG-0654 FEMA-REP-1, Rev. 1 Supplement 3 states "This guidance should not affect the use of the protective action guidelines developed andissued by the U.S. Environmental Protection Agency (EPA). The EPA protective action guides (EPA, 1992) remain the appropriate Federal guidance onradiological criteria for consideration of protective actions."

MNS EPLAN J.8 Evacuation Time Estimates references the MNS-ETE-12132012.000 for the data used for the ETEs.MNS-ETE-12132012.000 7.6 Staged Evacuation Results states "In summary, the staged evacuation option provides no benefits to evacuees from within 2miles and adversely impacts many evacuees located beyond 2 miles from the MNS."NUREG-0654 FEMA-REP-1, Rev. 1 Supplement 3 states "Extreme weather conditions, such as inversion, significant precipitation, or no wind, can changethe efficacy of SIP and make evacuation the preferred protective action."Conclusion:

Rapidly Progressing Severe Accident (RPSA) only applies to first PAR after initial General Emergency via criterion for Loss of Containment Barrier perEALs with a potential loss of containment barrier per containment radiation monitors per EALs OR projected radiological release at site boundary toexceed EALs within one hour. A loss of containment barrier alone does not have enough points to generate a General Emergency per the EALs therefore two other fission product barriers are lost or one other fission product barrier is lost with a potential loss of the other. Once a GE is declared thencontainment must be evaluated for a Loss of Containment Barrier then containment radiation monitors and dose at site boundary must be evaluated todetermine if a RPSA applies.

The potential loss of containment barrier per the EALs using the containment radiation monitors EMF51A and EMF51B isbased on 20% fuel failure is more conservative for taking expedite actions for protecting the health and safety of the public as compared to 100% fuelfailure in the previous revision of this procedure.

The projected radiological release at site boundary to exceed EALs within one hour is a conservative measure for the protection of the health and safety of the public. MNS Emergency Plan Section D (Emergency Notification System) is not challenged.

IF RPSA criteria is met, then affective actions are taken to ensure the health and safety of the public therefore the actions to determine PAR for a RPSAcontinues to comply with the requirements.

NUREG-0654 also provides guidance for SIP in place based upon Hostile Action or Impediments to Evacuation.

EPA 400-R-92-001 supports SIP and states that Since it may be implemented

rapidly, sheltering may be the protective action of choice.EPA 400-R-92-001 is also the basis for the MNS EPlan Section J -PAR.NUREG-0654 states that staged evacuation may be the preferred evacuation but MNS-ETE-12132012.000 provides a summary that a staged evacuation adversely impacts many evacuees therefore staged evacuation is not a recommendation KLD TR -682 supports evacuating and not using staged evacuation using the methodology per NEI 12-10.NRC ML 13269A370 endorsed the NEI methodology that is used in Appendix D of NEI 12-10.NRC ML 14007A652, EPFAQ 2013-004 Question 3 and 4, NRC response allowed license to perform a technical evaluation.

KLD TR-682 is the evaluation.

Based upon Supplement 3 guidance and KLD TR-682; These PAR for RPSA changes take into consideration the health and safety of the pubic whereevacuation can actually reduce dose where members of the general public evacuate the two mile radius and 2-5 miles downwind and SIP 5 -10 milesdownwind.

Based upon Supplement 3 guidance; These PAR changes take into consideration the health and safety of the pubic where SIP can actually reduce dose wheremembers of the general public could be overtaken by the radioactive plume taking into account that sheltering inside their homes would be more protective than trying to make a quick evacuation where traffic or other impediments could slow down the evacuation.

Based upon Supplement 3 guidance; These PAR changes take into consideration the health and safety of the pubic where SIP can actually reduce dose wheremembers of the general public could be overtaken by the radioactive plume taking into account that sheltering inside their homes would be more protective than trying to make a quick evacuation where a security event could slow down the evacuation.

Based upon Supplement 3 guidance; Actions are taken for expanded PAR for the OROs and licensee to make decisions to evacuate areas that are SIP basedupon removal of impediments, adverse weather or other factors.

SIP provides affective actions to ensure the health and safety of the public therefore these changes continue to comply with the requirements.

If any other event has generated a General Emergency, then the PAR is evacuate 2 mile radius and evacuate 2 -5 miles Downwind.

These changes comply with 10 CFR 50.47(b)(7),

10 CFR 50.47(b)(10) and Appendix E to Part 50, Title 10 of the Code of Federal Regulations (10 CFR)Section IV, paragraph 3.The proposed activity)(Noes

/ D does not continue to comply with the requirements.

Reduction in Effectiveness (RIE) Evaluation and

Conclusion:

BLOCK 5Evaluation:

This document change is in response to 75772 Federal Register

/ Vol. 76, No. 233 / Monday, December 5, 2011 / Rules and Regulations where the U.S.Nuclear Regulatory Commission (NRC) is issuing Supplement 3, "Guidance for Protective Action Strategies,"

to NUREG-0654/FEMA-REP-1, Revision 1,"Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants".

Thisdocument provides guidance for addressing new EP requirements for nuclear power plants based on changes to EP regulations in 10 CFR 50.47 andAppendix E to Part 50 in the November 23, 2011, final rule. Newly added provision of Part 50, Appendix E,Section IV, paragraph 3.Protective Action Recommendations (PAR) based upon three new scenarios (Rapidly Progressing Severe Accident (RPSA), Hostile Action andImpediments to Evacuation) during a General Emergency (GE) provides the recommendation to Shelter in Place (SIP) instead of immediate evacuation for a given event under various circumstances.

MNS Emergency Plan J.7 Protective Actions Recommendations states "Protective Action Guides are adopted from EPA 400-R-92-001".

NUREG-0654 FEMA-REP-1, Rev. 1 Supplement 3 states "This guidance should not affect the use of the protective action guidelines developed andissued by the U.S. Environmental Protection Agency (EPA). The EPA protective action guides (EPA, 1992) remain the appropriate Federal guidance onradiological criteria for consideration of protective actions."

NUREG-0654 FEMA-REP-1, Rev. 1 Supplement 3 has the following statement concerning the health and safety of the publicThe regulation at 44 CFR 350.5(10) states, in part, "Guidelines for the choice of protective actions during an emergency, consistent with Federalguidance, are developed and in place.....

Offsite response organizations (OROs) should consider using this guidance to develop appropriate protective action strategies.

Nothing in this guide should be interpreted as interfering with State, Tribal, and local ORO authority to determine the appropriate protective action strategies and decision making protocols for the protection of public health and safety during a radiological emergency."

Appendix E to Part 50, Title 10 of the Code of Federal Regulations (10 CFR)Section IV, paragraph 3 states "Nuclear power reactor licensees shall useNRC approved evacuation time estimates (ETEs) and updates to the ETEs in the formulation of protective action recommendations and shall provide theETEs and ETE updates to State and local governmental authorities for use in developing offsite protective action strategies."

NUREG-0654 FEMA-REP-1, Rev. I Supplement 3, Guidance for Protective Action Strategies" states within PROTECTIVE ACTION STRATEGYDEVELOPMENT TOOL NOTES the impediments to evacuation.

10 CFR 50.47(b)(7) states "Information is made available to the public on a periodic basis on how they will be notified and what their initial actionsshould be in an emergency (e.g., listening to a local broadcast station and remaining indoors),

the principal points of contact with the news media fordissemination of information during an emergency (including the physical location or locations) are established in advance, and procedures forcoordinated dissemination of information to the public are established."

10 CFR 50.47(b)(10)

"A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. Indeveloping this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use ofpotassium iodide (KI), as appropriate.

Evacuation time estimates have been developed by applicants and licensees.

Licensees shall update theevacuation time estimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed."

KLD TR -682 supports evacuating and not using staged evacuation using the methodology per NEI 12-10.NRC ML 13269A370 endorsed the NEI methodology that is used in Appendix D of NEI 12-10.NRC ML 14007A652, EPFAQ 2013-004 Question 3 and 4,NRC response allowed license to perform a technical evaluation.

KLD TR-682 is the evaluation

==

Conclusion:==

It is a requirement that MNS adheres to NUREG-0654 FEMA-REP-1, Rev. 1 Supplement 3 as a direction by the NRC per 75772 Federal Register

/ Vol. 76,No. 233 / Monday, December 5, 2011 / Rules and Regulations.

Since MNS EPlan Protective Action Guides are adopted from EPA 400-R-92-001 and NUREG-0654 FEMA-REP-1, Rev. 1 Supplement 3 does not affect the EPA guidelines therefore there is no impact on the MNS EPlan or the Protected ActionGuides (PAGs).KLD Engineering performed the ETEs for MNS as described in MNS Emergency Plan Section J. KLD Engineering generated KLD TR-682 (Development ofProtective Action Strategy) using methodology from Appendix D of NEI 12-10. KLD TR-682 only applies to RPSA. The methodology was endorsed by theNRC per ML 13269A370 per the NEI letter to the NRC per EPFAQ 2013 and then NEI added the methodology to Appendix D of NEI 12-10.These PAR changes take into consideration the health and safety of the pubic where evacuation can actually reduce dose where members of the generalpublic evacuate the two mile radius and 2-5 miles downwind.

Duke Energy Fleet and MNS has placed into procedures PAR for impediments to evacuation per recommendations of NUREG-0654 FEMA-REP-1, Rev. 1,Supplement 3, using PROTECTIVE ACTION STRATEGY DEVELOPMENT TOOL NOTES. MNS continues training and discussions with offsite agencies for PAR.These PAR changes take into consideration the health and safety of the pubic where SIP can actually reduce dose where members of the general public couldbe overtaken by the radioactive plume taking into account that sheltering inside their homes would be more protective than trying to make a quick evacuation where traffic, other impediments or security event could slow down the evacuation.

Actions are taken for expanded PAR for the OROs and licensee to make decisions to evacuate areas that are SIP based upon removal of impediments, adverseweather or other factors.

SIP provides affective actions to ensure the health and safety of the publicMNS continues to provide information to residents within the 10 mile EPZ as described in 10 CFR S0.47(b)(7).

MNS continues to provide PAR to ensure the health and safety of the public as described in 10 CFR 50.47(b)(10).

These PAR changes adhere to providing PAR using the ETEs as described in Appendix E to Part 50, (10 CFR)Section IV, paragraph 3.This activity does not constitute a reduction in effectiveness.

The proposed activity 1-1 does not constitute a RiE.

Effectiveness Evaluation Results I BLOCK 6The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E and the activity does notconstitute a reduction in effectiveness.

Therefore, the activity can be implemented without prior approval.

[ The activity does not continue to comply with the requirements of §50.47(b) and §50 Appendix E or the activity doesconstitute a reduction in effectiveness.

Therefore, the activity cannot be implemented without prior approval.

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N. EXERCISES AND DRILLSN.l.a Exercises McGuire Nuclear Site will conduct emergency exercises in accordance with therequirements of 10CFR50 Appendix E.The Emergency Operations Facility will participate in each exercise involving fullparticipation by the affected state or local governmients.

N. 1 .b Exercise Scenario/Response The exercises will be designed to test the integrated capability of those involved and amajor portion of the basic elements existing within the plans and organizations.

Thescenario for these exercises will be varied from exercise to exercise such that all majorelements of the plans and organizations will be tested within a six year period. Theexercise will be initiated at various times of the day, but in every six year period, oneexercise will begin between 6:00 P.M. and 4:00 A.M.N.2 DrillsMcGuire Nuclear Station will conduct drills in accordance with 10CFR50, Appendix E toensure that adequate emergency response capabilities are maintained between exercises.

Atleast one drill will be conducted between exercises involving a combination of the principal functional areas of McGuire's on-site emergency response capabilities.

{PIP 0-G98-0023}

Drills shall be conducted to test, develop and maintain skills in a particular operation.

Drillsmay be a component of an exercise.

Drills will be conducted and evaluated by a designated drill director.

Drills will be held in accordance with PT/0/A/4600/097, Procedure forPreparing and Conducting Emergency Exercises/Drills, and FAM 3.19, Drills and Exercises.

N.2.a Communications

1. Monthly checks are conducted with the state of North Carolina and withMecklenburg, Gaston, Catawba,

Cabarrus, Lincoln, and Iredell Counties.

2. Monthly checks are also conducted with the NRC Headquarters from theControl Room and EOF. The ENS phone located in the TSC is checked inconjunction with the monthly call from the Control Room. Also a monthlycall to the National Weather Service will be made to ensure accessibility.

Rev. 14-5N-1 December, 2014

3. Quarterly checks with Federal emergency response organizations areconsidered complete with the monthly call to the NRC. The state of NorthCarolina in the ingestion pathway is called monthly.

The state of SouthCarolina is called quarterly.

4. Annual communications checks are performed between the Control Room,TSC, and EOF; and between the McGuire facility and the North CarolinaEOC, Mecklenburg, Gaston, Catawba,

Cabarrus, Lincoln and IredellCounties' EOCs and the field monitoring teams.5. Annual checks are conducted with Federal emergency response organizations, Dept. of Energy's Savannah River Plant and REAC/TS in Oak Ridge, Tenn.See PT/O/A/4600/089, Periodic Test of Control Room and TSC DEMNET,ENS and Duke ETS.6. Periodic drills conducted with the ERO teams throughout each calendar yearinclude the aspect of understanding the content of messages.

N.2.b Fire drills shall be conducted in accordance with Nuclear System Directive (NSD)112, Fire Brigade Organization Training and Responsibilities.

N.2.c Medical emergency drills involving a simulated contaminated and injured individual which contains provisions for participation by the local ambulance service shall beconducted annually.

The offsite portion of the medical drill may be performed as partof the required biennial exercise.

N.2.d Station environs and radiological monitoring drills (onsite and offsite) shall beconducted annually.

These drills shall include collection and analysis of all samplemedia (e.g. water, vegetation, soil and air).N.2.e Radiation Protection drills shall be conducted semi-annually which involve responseto and analysis of, simulated elevated airborne and liquid samples and direct radiation measurements in the environment.

Analysis of samples may be simulated inRadiation Protection drills.NOTES: 1. Due to ALARA considerations actual elevated samples willnot be used in drills.2. Radiation Protection and Chemistry personnel performanalyses of similar nature routinely and therefore are notrequired to perform the analysis for drills.Rev. 14-5N-2 December, 2014 N.3 Exercise and Drill Execution The Emergency Planning Group is responsible for the overall development and direction ofthe biennial exercise.

An Exercise Director and a key group of controllers will develop theexercise

scenario, exercise

messages, and simulated data for the site and off-site areas. TheExercise Director will, for each exercise, develop an exercise plan. This plan will includeobjectives of the exercise and evaluation

criteria, the date, time, place, and participating organizations, the exercise

scenario, a narrative summary of the event including such thingsas emergency classification at various times in the simulated

accident, off-site assistance, some detail on plant conditions, and a description of the arrangements for official observers.

N.4 Exercise CritiqueA critique will be held following each exercise.

The critique will be a closed session betweenDuke and the Nuclear Regulatory Commission.

During the critique, the Emergency PlanningManager, the Exercise

Director, the NRC and other official observers from state, federal orlocal governments will make preliminary evaluations of the emergency response.

N.5 Critique Action ItemsThe verbal evaluations made during the critique and any follow-up written evaluation will becompiled into a Critique Sulnmary.

Items from the Critique Summary will be entered into theProblem Investigation Process (PIP). Through this process, items will be tracked untilcompleted.

Completion dates will be established during development of the critiquesummary.

The Emergency Planning Manager acting under the authority of the Site VicePresident will ensure resolution of each item.Rev. 14-5N-3 December, 2014 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 1OCFR 50.54(q)

Evaluations

§50.54(q)

Screening Evaluation Form Activity Description and

References:

MNSEmergency Plan Section N (Exercises and Drills) Rev 14-5 December2014Page N-2 Changed from "Selective Signaling" to "DEMNET".

BLOCK ITo support a Duke Energy fleetwide initiative, replacing references and instructions associated with Selective Signaling toDuke Emergency Management Network (DEMNET) which is used for notifications to state/county agencies.

The Selective Signaling to DEMNET replacement work is being performed under Engineering Change(EC)# 112636.Fleet procedure, AD-EP-ALL-0406, Duke Emergency Management Network (DEMNET),

Revision 0, includesinformation on how to operiate DEMNET.DEMNET was incorporated to remove the Selective Signaling System and on the use of the new communication network,for making emergency notifications to off-site agencies by initiating group calls to the government agencies usingDEMNET "lS'N Notify".7.S 7< Ih 4 ( :Plamning Standards 50.47(b)(5) and 50.47(b)(6),

are impacted by the new DEMNET process therefore a 1OCFR50.54(q)

Effectiveness Evaluation must be performed.

Activity Scope: BLOCK2The activity is a change to the emergencyOplan ED The activity isnot a change to the emergency planRevision 12 Emergency Planning Functional Area ManualAttacluhment 3.10.7.23.10 1OCFR 50.54(q)

Evaluations Change Type: BLOCK 3,FD The change is editorial or typographical Z The change is not editorial or typographical Change Type: BLOCK 4FD The change does conform to an activity that hasprior approvalZ The change does not conform to an activity that hasprior approvalPlanning Standard Impact Determination:

El §50.47(b)(1)

-Assignment of Responsibility (Organization Control)D] §50.47(b)(2)

-Onsite Emergency Organization ED §50.47(b)(3)

-Emergency Response Support and Resources ED §50.47(b)(4)

-Emergency Classification System*Z §50.47(b)(5)

-Notification Methods and Procedures*

Z §50.47(b)(6)

-Emergency Conmmunications ED §50.47(b)(7)

-Public Education and Information E: §50.47(b)(8)

-Emergency Facility and Equipment El §50.47(b)(9)

-Accident Assessment*

II §50.47(b)(10)

-Protective Response*

LI §50.47(b)(1

1) -Radiological Exposure ControlEl §50.47(b)(12)

-Medical and Public Health SupportLi §50.47(b)(13)

-Recovery Planning and Post-accident Operations LI §50.47(b)(14)

-Drills and Exercises EI §50.47(b)(1

5) -Emergency Responder TrainingLI §50.47(b)(1

6) -Emergency Plan Maintenance

• Risk Significant Planning Standards EL The proposed activity does not impact a Planning StandardBLOCK 5Commitment Impact Determination:

BLOCK6LI The activity does involve a site specific EP conmmitment Record the conmiitment or commitment reference:

Z The activity does not involve a site specific EP commitment Screening Evaluation Results:

BLOCK 7Sr The activity can be implemented without performing a §50.54(q) effectiveness evaluation Z The activity cannot be implemented without performing a §50.54(q) effectiveness evaluation Pppvapr Name: Prep er atu Date:mD 2.........

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Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.3§50.54(q)

Effectiveness Evaluation FormActivity Description and

References:

Emergency Plan Section N BLOCK 1(Exercises and Drills) Rev 14-5 December 2014Page N-2 Changed "Selective Signaling to "DEMNET"To support a Duke Energy fleetwide initiative, replacing references and instructions associated with Selective Signaling to Duke Emergency Management Network (DEMNET) which is used for notifications to state/county agencies.

The Selective Signaling to DEMNET replacement work is being performed under Engineering Change(EC)# 112636.ew Fleet procedure, AD-EP-ALL-0406, Duke Emergency Management Network (DEMNET),

Revision 0, willalso be issued. The new Fleet procedure includes information on how to operate DEMNET.DEMNET changes were incorporated to remove the Selective Signaling System and add instructions on theuse of the new communication

network, DEMNET. Step details for using the old Selective Signaling systemwere deleted or replaced with instructions for using DEMNET. Step details for using DEMNET include thefollowing:

Initiating group calls to the government agencies with the DEMNET "MEN Notify" button, use of theAlternate DEMNET buttons, and notes containing supplemental information.

M.5"Additional information regarding this change: ,- " -'!The Selective Signaling emergency communications system has been the primary method of promptcommunication to State and local Offsite Response Organizations (OROs) from the McGuire NuclearStation (MNS) for many years. Within the confines of MNS, Selective Signaling operates as part of thenormal plant communications system (i.e. internal extensions, commercial phones, etc.). Beyond theboundaries of MNS, Selective Signaling transmits over analog lines that are leased from localtelephone providers.

In the past, these lines have been subject to damage by natural and man-madecauses or other failures such that all or part of communication ability of MNS to or from some or all ofthe OROs via Selective Signaling has been lost for various periods of time.Since Selective Signaling is an unmonitored system, it is typically not known that problems exist untilthe system is used (i.e., during periodic

testing, communication checks, drills, etc.). When problemsare identified and reported, it is up to the local telephone provider to determine when the repair(s) canbe made. In addition to the less than reliable service for the Selective Signaling system, Duke Energyhas been notified by local telephone providers that due to the frequency of failures and the everincreasing difficulty in obtaining repair parts / materials, they will no longer be able to provide repair /maintenance support of the antiquated system beyond 2014.As a solution for this, Duke Energy has selected Emergency Management Network (EMnet) asprovided by the vendor, Communications Laboratories (Comlabs).

EMnet is currently in use by anumber of Federal, State, and local government

agencies, and is being implemented by an increasing number of nuclear stations

/ utilities.

EMnet will be referenced as DEMNET for the remainder of thisevaluation.

Comlabs provides

hardware, software,

training, installation and other services necessary for DEMNET to operate.

DEMNET is being implemented across the Duke Energy Fleet as areplacement for Selective Signaling.

DEMNET allows the Control Room, Technical Support Center (TSC), Emergency Operations Center(EOF), and alternative response facilities to communicate with Offsite Response Organizations and/orwith each other using VoIP (voice-over-internet protocol) as the primary method. In the event ofinternet related problems (i.e., slow data transfer rate, unavailability, etc.), the system automatically transfers to satellite communication as a backup. Like Selective Signaling, DEMNET allows internaland external point-to-point contact between individual stations as well as simultaneous conferencing with multiple stations.

This ability is a valuable backup to existing telephone circuits.

The point-to-point Revision 12 Emergency Planning Functional Area ManualAttachment 3.10.7.33.10 1OCFR 50.54(q)

Evaluations capability also allows DEMNET to continue to provide Decision Line capability, which enables OROdecision makers to use the system to discuss public protective actions over dedicated

/ controlled access communication links.Via the dedicated DEMNET computer, historical and real-time system status can be readilydetermined.

DEMNET is also monitored by the vendor, Comlabs.

This allows for a more proactive approach in identification and resolution of problems associated with the system should they occur.the event of failure, the application of suitable compensatory measures (i.e., use of back upcommunications) can be made in a more efficient and effective manner.No changes are made to the communications systems that currently serve as a backup to Selective Signaling or the associated implementation process(es) for employing them.DEMNET equipment installed and operated at Duke Energy nuclear plants and support facilities isinstalled and maintained to meet cyber security requirements in accordance with 10 CFR 73.54 andother related guidance.

InAs part of the installation

process, DEMNET has been extensively tested to ensure connectivity

/operability before being placed in service.

Duke Energy Emergency Response Organization andEmergency Preparedness, along with personnel from Offsite Response Organizations have receivedtraining on the new system as well.As configured, the network that DEMNET resides within MNS causes the system to be powered fromvarious sources based upon the physical location of the individual components within the network.

Inthe event normal and/or backup power supplies become unavailable, and as a result, DEMNET and allother backup communications system become non-functional, MNS and the OROs have a number ofbattery powered portable satellite phones available that can be placed into service in an effort tomaintain the capability of providing prompt communications between MNS and the OROs.Upon implementation across the Duke Energy Fleet and its State and local Offsite ResponseOrganizations, the product name "EMNet" is replaced with the new system name "Duke Emergency Management Network (DEMNET)".

The name "Selective Signaling" will no longer be used, while thename "Decision Line" will continue to be used.Activity Type: BLOCK 2Z The activity is a change to the emergency planF1 The activity affects implementation of the emergency plan, but is not a change to the emergency planImpact and Licensing Basis Determination:

BLOCmK3* 10 CFR 50.47(b)(5)

-Notification Methods and Procedures (Risk Significant Planning Standard) states:"Procedures have been established for notification, by the licensee, of State and local responseorganizations and for notification of emergency personnel by all organizations; the content of initial andfollow up messages to response organizations and the public has been established; and means toprovide early notification and clear instruction to the populace within the plume exposure pathwayEmergency Planning Zone have been established."

The applicable emergency planning function associated with 10 CFR 50.47(b)(5) states:"Procedures for notification of State and local governmental agencies are capable of alerting them ofthe declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications."

• 10 CFR 50.47(b)(6)

-Emergency Communications states: "Provisions exist for promptcommunications among principal response organizations to emergency personnel and to the public."

Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.3The applicable emergency planning functions associated with 10 CFR 50.47(b)(6) state:" Systems are established for prompt communication among principal emergency responseorganizations.

" Systems are established for prompt communication to emergency response personnel Licensing Basis:This evaluation included a search of McGuire Nuclear Station (MNS) licensing basis documents forreferences to the Selective Signaling system. The search concluded that a review of the Duke EnergyMcGuire Nuclear Station (MNS) Emergency Plan was warranted.

While the MNS Emergency Plan contains several references to Selective Signaling, there are no detailswithin the Emergency Plan regarding usage of the system, other than to indicate that it is the primarysystem used for prompt communications to the offsite response organizations.

DEMNET is replacing Selective Signaling as the primary system used for prompt communications to the offsite responseorganizations.

Other references within the MNS Emergency Plan include facility diagrams which indicate the location ofSelective Signaling telephones.

DEMNET equipment is replacing Selective Signaling in each locationwhere Selective Signaling was present.The MNS Emergency Plan also references periodic testing of Selective Signaling.

DEMNET will be testedin a similar manner and frequency as was Selective Signaling.

Consequently, the replacement of the Selective Signaling system with DEMNET within the MNSEmergency Plan will constitute a name change only.This review concludes that changes to this document relative to the replacement of Selective Signaling withDEMNET do not affect the licensing basis of the MNS Emergency Plan. The changes in this revisionsupport replacement of the Selective Signaling telephone system, which is used for notifications tostate/county

agencies, with a new dedicated telephone system called the Duke Emergency Management Network (DEMNET).

These changes support a Duke Energy fleet-wide initiative to upgrade the dedicated telephone system for notifying state/county agencies of a declared emergency as an overall enhancement to emergency preparedness.

These changes meet or exceed all emergency preparedness requirements based on NRC regulations and requirements.

Compliance Evaluation and

Conclusion:

BLOCK 41. Evaluation:

10 CFR Part 50, Appendix E, Section IV.D.1 states the following:

Administrative and physical means for notifying local, State, and Federal officials and agencies andagreements reached with these officials and agencies for the prompt notification of the public and for publicevacuation or other protective

measures, should they become necessary, shall be described.

Thisdescription shall include identification of the appropriate officials, by title and agency, of the State and localgovernment agencies within the EPZs.10 CFR Part 50, Appendix E, Section IV.D.3 states the following, in part:A licensee shall have the capability to notify responsible State and local governmental agencies within 15minutes after declaring an emergency.

The licensee shall demonstrate

...10 CFR Part 50, Appendix E, Section IV.E.8.d states the following, in part:For nuclear power reactor licensees, an alternative facility (or facilities) that would be accessible even if thesite is under threat of or experiencing hostile action, to function as a staging area for augmentation ofemergency response staff and collectively having the following characteristics:

... the capability to performoffsite notifications;

....NUREG-0696 (Functional Criteria for Emergency Response Facilities),

Section 2.7, states, in part:The TSC voice communication equipment shall include:* Hotline telephone

...* Dedicated telephone

...Dial telephones

...

Emergency Planning Functional Area Manual3.10 1 OCFR 50.54(q)

Evaluations Attaclunent 3.10.7.3* Intercommunications systems ...* Communications

... to State and local operations center prior to EOF activation.

NUREG-0696 (Functional Criteria for Emergency Response Facilities),

Section 4.6, states, in part:The EOF shall have reliable voice communications facilities to the TSC, the control room, NRC, and Stateand local emergency operations centers.

The normal communication path between the EOF and thecontrol room will be through the TSC. The primary functions of the EOF voice communications facilities willbe:* EOF management

...* Communications

...* Communications

...* Communications to coordinate offsite emergency response activities, and* Communications

....NUREG-0654 (Criteria for Preparation and Evaluation of Radiological Emergency Response Plans andPreparedness in Support of Nuclear Power Plants),

Section 1l.F, states, in part:1. The communications plans for emergencies shall include organizational titles and alternates for bothends of the communication links. Each organization shall establish reliable primary and backup meansof communication for licensees, local, and State response organizations.

Such systems should beselected to be compatible with one another.

Each plan shall include:a. provision for 24-hour per day notification to and activation of the State/local emergency responsenetwork; and at a minimum, a telephone link and alternate, including 24-hour per day manning ofcommunications links that initiate emergency response actions.b. provision for communications with contiguous State/local governments within the Emergency Planning Zones;c. provision for communications

...d. provision for communications

...e. provision for alerting or activating emergency personnel in each response organization; andprovision for communication

...The replacement of Selective Signaling and Decision Line (SS/DL) with DEMNET continues to comply withapplicable regulations and commitments by providing a dedicated method of contacting State and localauthorities in a timely manner during an emergency.

Compliance is maintained in the following manner:1. DEMNET is a dedicated system for communication with OROs that is capable of establishing contactwithin 15 minutes of emergency declaration.

This is consistent with the capability of the SS/DLsystem.2. DEMNET stations are present in the Control Room, TSC, EOF, and alternative facilities which arecapableof initiating or receiving point-to-point or conference calls with any ORO site similarly equipped.

Thisis consistent with the capability of the SS/DL system.3. Compatible DEMNET stations are installed in all ORO locations that were serviced by the SS/DLsystem.4. The TSC has an DEMNET station to allow communication with State and local OROs prior to EOFactivation.

This capability existed with the existing SS/DL system.5. DEMNET is a voice communications system with dedicated stations located in the Control Room, TSC,EOF, alternative facilities, and State/local emergency operations centers and is capable of coordinating Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attaclunent 3.10.7.3offsite response activities via point-to-point or conference calling.

Communications with NRC isconducted using a separate system unrelated to DEMNET. This is consistent with the SS/DL system.NOTE: In addition to voice communications, DEMNET is also capable of transmitting data. The voicecommunications feature of DEMNET is the replacement for SS/DL voice communications capability.

6. DEMNET has redundant features to maintain communication capability in the event of system failure ordegradation.

During normal operation, DEMNET employs voice-over-internet protocol (VoIP)technology to establish contact between stations.

Should internet problems (unavailability, slow transfer rate, etc.)occur, the system will automatically shift to satellite communication as a backup. This backup featureis an enhancement that SSIDL did not have. Failure of the SS/DL system required the use of thecommercial telephone system to re-establish communications.

7. By locating an DEMNET station in the continuously staffed Control Room, the licensee provides 24-hour per day capability to establish links to initiate emergency response actions.8. DEMNET stations are established at each contiguous State/local emergency response agency withinthe EPZ. This is consistent with the usage of the SS/DL system.* 10 CFR 50.47(b)(5) states the following:

"Procedures have been established for notification, by the licensee, of State and local responseorganizations and for notification of emergency personnel by all organizations; the content of initial andfollow-up messages to response organizations and the public has been established; and means to provideearly notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established."

The function of this planning standard pertinent to this change is the establishment of procedures for Stateand local governmental agencies that are capable of initiating notification of the declared emergency within15 minutes after declaration of an emergency and providing follow-up notification.

0 10 CFR 50.47(b)(6) states the following:

"Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public."The function of this planning standard pertinent to the change is that systems be established for promptcommunications among principal response organizations.

==

Conclusion:==

The proposed activity 2 does / El does not continue to comply with the requirements.

Reduction in Effectiveness (RIE) Evaluation and

Conclusion:

aBLOC M,£1. Evaluation:

The screening of this change has identified two (2) affected planning standard functions described above:1. Procedures for notification of State and local government agencies are capable of initiating notification of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notification.

Additional procedures are currently in effect for notification of State and local agencies following adeclared emergency.

These procedures explicitly require that such notification occur within 15 minutesof emergency declaration.

Station procedures were originally intended to address notifications using the Selective Emergency Planning Functional Area ManualAttachment 3.10.7.33.10 l OCFR 50.54(q)

Evaluations Signaling/Decision Line (SS/DL) system and have likewise been revised to address the change toDEMNET. The functionality and utility of the procedures remain unaffected by the proposed change.Consequently, this evaluation concludes that the change presents no undesirable impact on thisplanning function.

2. Systems are established for prompt communication to emergency response personnel.

The SS/DL system suffered from obsolescence and eroding vendor support.

The communications carriers currently providing service for the system informed the licensee that all support will terminate atthe end of 2014. This prompted the change to DEMNET, a communications system widely used in theemergency response community.

As described above, DEMNET possesses all of the capabilities of SS/DL with additional enhancements not found in the former system. Significant among these is the use of robust VolP technology andautomatic "failover" to satellite communications in the event of a failure or degradation of the primaryinternet flowpath.

Consequently, this evaluation concludes that the change presents no undesirable impact on this planning function.

The evaluation concludes that the change does not impact either applicable planning function negatively and therefore does not constitute a reduction in effectiveness.

==

Conclusion:==

The proposed activity

[II does / Z does not constitute a RIE.Effectiveness Evaluation Results BLOCK 6[ The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E and theactivity does not constitute a reduction in effectiveness.

Therefore, the activity can be implemented withoutprior approval.

LI The activity does not continue to comply with the requirements of §50.47(b) and §50 Appendix E or theactivity does constitute a reduction in effectiveness.

Therefore, the activity cannot be implemented withoutprior approval.

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D ae2 /.e , -r Ic/k P. RESPONSIBILITY FOR THE PLANNING EFFORTTo assure that responsibilities for plan development, review and distribution of emergency plans are established and that the Emergency Planning staff are properly trained.P. 1 Emergency Planning Staff TrairingEmergency Planning Group personnel will attend training/workshops, information exchangemeetings with other licensees, and conferences held by industry and government

agencies, asavailable, to maintain current knowledge of the overall planning effort. The Emergency Planning Manager is required to attend offsite training on an annual basis. This training will bedocumented in site Emergency Planning files or the Training group database (i.e. People Soft,etc.).P.2 Emergency Response PlanningThe Site Vice President has the overall authority and responsibility for the Site Emergency Plan. This planning effort is delegated to the Emergency Planning Manager.P.3 Site Emergency Planning ManagerThe Emergency Planning Manager has the overall authority and responsibility for siteemergency response planning as well as the responsibility for the development and updating ofthe site Emergency Plan and coordination of this plan with other response organizations.

P.4 Review of Emergency PlanReview and updating of the site Emergency Plan and Emergency Plan Implementing Procedures shall be certified to be current on an annual basis. Any changes identified by drillsand exercises shall be incorporated into the Site Emergency Plan.On an annual basis, the Emergency Planning Manager will provide each state and localorganization responsible for off-site activation and protective action decision-making, a copy ofthe nuclear site procedures appropriate for their area on emergency classification andnotification.

A response will be requested by letter within 30 days that a review has beencompleted with concurrence with the EAL's used for event classification and for protective action recommendations.

If problem areas are identified, the Emergency Planning Managerwill ensure resolution.

P.5 Distribution of Revised PlansThe Emergency Plan and approved changes shall be forwarded to individuals and organizations listed in App. 6. Revised pages shall be dated and marked to show where changes have beenmade.Rev. 14-5P-1 December, 2014 P.6 Supporting PlansFigure P-I gives a detailed listing of supporting plans to the McGuire Nuclear Site Emergency Plan.P.7 Implementing Procedures Written procedures will be established, implemented, and maintained covering the activities associated with emergency plan implementation.

Each procedure, and changes thereto, shall bereviewed and approved by the responsible implementing manager prior to implementation andshall be reviewed periodically as set forth in administrative procedures.

McGuire Emergency Plan lInplementing Procedures are listed in Figure P-2 with a reference tothe section of Emergency Plan implemented by each procedure.

Figure P-3 contains thedistribution list for McGuire Emergency Plan Inplementing Procedures.

P.8 Table of ContentsThe McGuire Nuclear Site Emergency Plan contains a specific table of contents.

The McGuireNuclear Site Emergency Plan has been cross referenced to the applicable sections of NUREG-0654 Rev. 1.P.9 Audit of Emergency PlanThe Nuclear Safety Review Board Chairman will arrange for an independent review ofMcGuire Nuclear Station's Emergency Preparedness Program as necessary, based on anassessment against performance indicators, and as soon as reasonably practicable after achange occurs in personnel, procedures, equipment, or facilities that potentially couldadversely affect emergency preparedness, but no longer than 12 months after the change. Inany case, all elements of the emergency preparedness program will be reviewed at least onceevery 24 months. Guidance for performing the assessment against the performance indicators is provided in the Emergency Preparedness Administrative Procedure AD-EP-ALL-0001.

The independent review will be conducted by the Nuclear Oversight

-Auditsand will include the following plans, procedures, training

programs, drills/exercises, equipment, and State/local government interfaces:

1. McGuire Nuclear Site Emergency Plan and Implementing Procedures

2. State/Local Support Agency Training Program3. Site Training Program4. Public and Media Training/Awareness

5. Equipment

-Communications, Monitoring, Meteorological, Public Alerting6. State/Local Plan Interface Rev. 14-5P-2 December, 2014 The review findings will be submitted to the appropriate corporate and nuclear sitemanagement.

Appropriate portions of the review findings will be reported to the involvedfederal, state, and local organizations.

The corporate or nuclear site management, asappropriate, will evaluate the findings affecting their area of responsibility and ensure effective corrective actions are taken. The result of the review, along with recormmendations forimprovements, will be documented and retained for a period of five years.P.10 Telephone Number UpdatesTelephone numbers reflected in the online organization charts will be updated quarterly inaccordance with PT/O/A/4600/09 1, Periodic Test of Technical Support Center Commnunications and Supplies.

Rev. 14-5P-3 December, 2014 DUKE ENERGYMCGUIRE NUCLEAR SITEFIGURE P- ISUPPORTING PLANSI. North Carolina Emergency Response Plan in support of McGuire Nuclear Site2. South Carolina Operational Radiological Emergency Response Plan in support of FixedNuclear Facilities (McGuire Nuclear Site)3. Iredell County, N.C., Radiological Emergency Response Plan in Support of the McGuireNuclear Site4. Mecklenburg County, N.C., Radiological Emergency Response Plan in Support of the McGuireNuclear Site5. Gaston County, N.C., Radiological Emergency Response Plan in Support of the McGuireNuclear Site6. Lincoln County, N.C., Radiological Emergency Response Plan in Support of the McGuireNuclear Site7. Catawba County, N.C., Radiological Emergency Response Plan in Support of the McGuireNuclear Site8. Cabarrus County, N.C., Radiological Emergency Response Plan in Support of the McGuireNuclear Site9. Emergency Response Plan, Water Reactors

Division, Westinghouse Electric Corporation

10. N.R.C. Region II Incident Response Plan11. Interagency Radiological Assistance Plan -Region 3 -U.S. Department of Energy12. INPO Emergency Response PlanRev. 14-5P-4 December, 2014 MCGUIREFIGURE P-2PAGE 1 OF 4EMERGENCY PLAN IMPLEMENTING PROCEDURES Procedure

1. Title Emergency Plan SectionImplemented AP/O/A/5500/047 Security Events (Proprietary Info) Section JRP/O/A/5700/000 Classification of Emergency Section D, E, IRP/O/A/5700/001 Notification of Unusual Event Section D, E, 1. 1, J.7RP/O/A/5700/002 Alert Section D, E, 1. 1, J.7RP/O/A/5700/003 Site Area Emergency Section D, E, 1. 1, J.7, M. IRP/O/A/5700/004 General Emergency Section D, E, 1. 1, J.7, M. 1RP/O/A/5700/006 Natural Disasters Section DRP/O/A/5700/007 Earthquake Section D, H.6RP/O/A/5700/008 Release of Toxic or Flammable Gases Section DRP/O/A/5700/09 Collisions/Explosions Section DRP/O/A/5700/010 NRC Immediate Notification Section DRP/O/A/5700/011 Conducting a Site Assembly, Site Evacuation or Section E.2, J, K.7Containment Evacuation RP/O/A/5700/012 Activation of the Technical Support Center (TSC) Section B, H, M.1Rev. 14-5December, 2014P-5 MCGUIREFIGURE P-2PAGE 2 OF 4EMERGENCY PLAN IMPLEMENTING PROCEDURES Procedure

1. Title Emergency Plan SectionImplemented RP/O/A/5700/018 Notifications to the State and Section ECounties from the TSCRP/0/A/5700/019 Core Damage Assessment RP/O/A/5700/020 Activation of the Operations Support Center (OSC) Section HRP/0/A/5700/022 Spill/Incident Response Procedure Appendices 7, 8, 9RP/O/A/5700/024 Recovery and Reentry Section MRP/0/A/5700/026 Operations/Engineering Required Actions in theTechnical Support Center (TSC)RP/0/B/5700/023 Nuclear Communications Emergency Response Section GPlanRP/0/B/5700/029 Notifications to Offsite Agencies from the Control Section ERoomHP/0/B/1009/002 Alternative Methods for Determining Dose Rate Section D, 1.6within the Reactor BuildingHP/0/B/1009/003 Recovery Plan Section MHP/0/B/1009/006 Procedure for Quantifying High Level Gaseous Section D, 1.3Radioactivity Release During Accident Conditions Rev. 14-5December, 2014P-6 MCGUIREFIGURE P-2PAGE 3 OF 4EMERGENCY PLAN IMPLEMENTING PROCEDURES Procedure

1. Title Emergency Plan SectionImplemented HP/0/B/1009/010 Releases of Liquid Radioactive Materials Section D, 1.3Exceeding Selected Licensee Commitments HP/O/B/1009/021 Estimating Food Chain Doses Under Post-Accident 1.10Conditions HP/0/B/1009/022 Accident and Emergency Response Section I, Section EHP/0/B1/1009/023 Environmental Monitoring for Emergency Section E, 1.7, 1.8, 1.9Conditions HP/0/B 1009/024 Personnel Monitoring for Emergency Conditions J.3, K.7Rev. 14-5December, 2014P-7 MCGUIREFIGURE P-2PAGE 4 OF 4EMERGENCY PLAN IMPLEMENTING PROCEDURES Procedure

1. Title Emergency Plan SectionImplemented AD-EP-ALL-0202 Emergency Response Offsite Dose Assessment Section ISH/O/B/2005/002 Protocol for the Field Monitoring Coordinator Section 1.8SH/O/B/2005/003 Distribution of Potassium Iodide Tablets in the J.6Event of a Radioiodine ReleaseSR/O/A/2000/001 Standard Procedure for Corporate Communications Section GResponse to the Emergency Operations FacilitySR/O/A/2000/003 Activation of the Emergency Operations Facility Section B, H, M. 1SR/O/A/2000/004 Notifications to States and Counties from the EOF Section EEP Manual Section 1.1 Emergency Organization Sections B, E, HPT/O/A/4600/088 Functional Check of Emergency Vehicle and Section H. 1IEquipment Rev. 14-5December, 2014P-8 FIGURE P-3McGUIRE NUCLEAR SITEEMERGENCY PLAN IMPLEMENTING PROCEDURES DISTRIBUTION Control No.2. Radiation Protection Manager3. Emergency Planming

Manager, Oconee4. McGuire Nuclear Training5. Operations Staff Manager6. Site Emergency

Planner, MGO 1 EP7. NRC Site Representative, McGuire Nuclear Site (forwarded by McGuire Emergency Planning)

8. Operator Training Director13. Emergency Planning

Manager, CNS14. Director, Division of Radiation Protection

16. NCEM REP Program Manager17. Tina Kuhr, Emergency Planning Consultant/NSRB Staff19. Emergency Operations

Facility, EOF Director's Area (MNS Emergency

Planning, custodians)

20. McGuire Nuclear Site, Document Control21. NCEM Western Branch Office Manager22. NRC Document Control Desk, Washington D.C. (forwarded 1 copy by McGuire Emergency Planning)

Rev. 14-5P-9 December, 2014 FIGURE P-3McGUIRE NUCLEAR SITEEMERGENCY PLAN IMPLEMENTING PROCEDURES DISTRIBUTION Control No.23. NRC, Regional Administrator,

Atlanta, GA (forwarded 1 copy by McGuire Emergency Planning)

24. NRC, Regional Administrator,

Atlanta, GA (forwarded 1 copy by McGuire Emergency Planning)

25. NRC Office of Nuclear Materials Safety and Safeguards Rev. 14-5December, 2014P-10 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 1OCFR 50.54(q)

Evaluations

§50.54(q)

Screening Evaluation Form Activity Description and

References:

BLOCK IMNS Emergency Plan Section P (Accident Assessment)

Rev 14-5December 2014Click here to enter text.Page P-8 for Figure P-2 -Deleted any reference to HP/0/B/1009/029 and SH/0/B2005/001 andreplaced with AD-EP-ALL-0202.

This change supports a fleetwide initiative to replace the dose assessment tools that are currently in place at the DukeEnergy Carolinas sites (using RADDOSE-V) and the Duke Energy Progress sites (using RASCAL) with UnifiedRASCAL Interface (URI) in order to align dose assessment tools at all Duke Energy nuclear plant sites. A new fleetprocedure AD-EP-ALL-0202, Emergency Response Dose Assessment, has been developed which provides instructions forperforming dose projections using Unified RASCAL Interface (URI) at MNS and the other nuclear plant sites.Planning Standards 50.47(b)(8) and 50.47(b)(9),

are impacted by the new URI process therefore a IOCFR50.54(q)

Effectiveness Evaluation must be performed.

Activity Scope: BLOCK2[] The activity is a change to the emergency planL1 The activity is not a change to the emergency planChange Type: BLOCK 3 Change Type: BLOCK4El The change is editorial or typographical E] The change does conform to an activity that has[ The change is not editorial or typographical prior approval[ The change does not conform to an activity that hasprior approvalPlanning Standard Impact Determination:

BLOCK5El §50.47(b)(1)

-Assignment of Responsibility (Organization Control)[I §50.47(b)(2)

-Onsite Emergency Organization El §50.47(b)(3)

-Emergency Response Support and Resources EL §50.47(b)(4)

-Emergency Classification System*El §50.47(b)(5)

-Notification Methods and Procedures*

El §50.47(b)(6)

-Emergency Comumnunications EL §50.47(b)(7)

-Public Education and Information Z §50.47(b)(8)

-Emergency Facility and Equipment 2 §50.47(b)(9)

-Accident Assessment*

El §50.47(b)(10)

-Protective Response*

[L §50.47(b)(1

1) -Radiological Exposure ControlL1 §50.47(b)(12)

-Medical and Public Health SupportEL §50.47(b)(13)

-Recovery Planning and Post-accident Operations EI §50.47(b)(14)

-Drills and Exercises El §50.47(b)(1

5) -Emergency Responder Training[] §50.47(b)(16)

-Emergency Plan Maintenance

• Risk Significant Planning Standards E] The proposed activity does not impact a Planning StandardRevision 12 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 10COR 50.54(q)

Evaluations Commitment Impact Determination:

BLOCK 6,LI The activity does involve a site specific EP conmfitment Record the comnitment or colmnitmnent reference:

[ The activity does not involve a site specific EP conmmitment Screening Evaluation Results:L1 The activity can be implemented without performing a §50.54(q) effectiveness evaluation Z The activity cannot be implemented without performing a §50.54(q) effectiveness evaluation Prepaier Namne: 'G, LPrep S natreDat..........

K a y ...........................

......................................................................................

.................

.. ..... .... ........

.............

..........

Revie r N e: d i Review Signa DateZ :44ý ýo:44X 0/BLOCK 7/

Emergency Planning Functional Area Manual3.10 1 OCFR 50.54(q)

Evaluations Attachment 3.10.7.350.54(q)

Effectiveness Evaluation FormActivity Description and

References:

MNS Emergency Plan Section P BLOCK 1I(Responsibility for the Planning Effort) Rev 14-5 December I2014Page P-8 for Figure P-2 -Deleted procedures HP/0/B/1009/029 and SH/0/B/2005/001 and replacedwith AD-EP-ALL-0202.

To support a Duke Energy fleetwide initiative, replacing instructions associated with the RADDOSE doseassessment tool with Unified RASCAL Interface (URI).This change supports a fleetwide initiative to replace the dose assessment tools that are currently in place atthe Duke Energy Carolinas sites (using RADDOSE-V) and the Duke Energy Progress sites (using RASCAL)with Unified RASCAL Interface (URI) in order to align dose assessment tools at all Duke Energy nuclear plantsites. A new fleet procedure AD-EP-ALL-0202, Emergency Response Dose Assessment, has been developed which provides instructions for performing dose projections using Unified RASCAL Interface (URI) at MNS andthe other nuclear plant sites. As a result, specific site procedures for performing dose projections aresuperseded by AD-EP-ALL-0202.

Additional information supportinq this changqe:RADDOSE is the current application used for dose assessment and projection of radiological releases duringan emergency.

The proposed change will replace RADDOSE with the Unified RASCAL Interface (URI) as thestandard fleet-wide dose assessment tool.RADDOSE is designed to estimate dose rates and deposition rates at 15-minute time intervals.

From theseestimates, integrated doses (using EPA 400-R-92-001 (EPA-400)[14]

dose factors and methodologies) andtotal deposition are calculated for the length of time covering the release of radioisotopes.

Doses are determined at radial grid and special receptor locations in the Plume Exposure Pathway Emergency Planning Zone while deposition is calculated to fifty miles surrounding the facility, based on radiological andmeteorological data collected at the plant.The RADDOSE model is designed to provide real-time (as the release is occurring) and projected site specificpredictions of atmospheric transport and diffusion as required by NUREG-0654, Revision 1, Appendix.

Atmospheric transport and diffusion are performed using a variable trajectory plume simulation model alongwith realtime meteorological data entered either directly from the PI server or manually.

Likewise, the sourceterm component of RADDOSE uses plant specific radiological data, for a number of accident types, entered viathe PI server or manually.

Using this information along with EPA-400 dose conversion

factors, the modeldetermines dose rates, doses, deposition rates and total deposition.

URI is a computer code intended for use at nuclear generating stations and other emergency response facilities in the event of an actual or potential release of airborne radioactivity to the environment at levels warranting declaration of an Emergency specified in the Radiological Emergency Plan. URI is a replacement for the userinterface normally delivered with the computer code Radiological Assessment System for Consequence AnaLysis

("RASCAL")

maintained and distributed by the by the Nuclear Regulatory Commission (NRC).The URI program:* Provides a user interface specifically designed for users for nuclear power station events.* Allows input of all required dose assessment model parameters including meteorological data, planteffluent monitor data, and plant condition and status.Revision 12 Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.30 Develops source terms based on user input.* Creates RASCAL data files based on the specific user input* Invokes the RASCAL met data processor, plume model processor, and puff model processors.

• Reads and interprets RASCAL results files and provide reports to the user of doses, affected areas,and other information relevant to emergency plan implementation.

The code has three modes: Rapid Assessment, Detailed Assessment, and Sum Assessment.

RapidAssessment enables on-shift staff to meet regulatory requirements for quick, simplified dose assessments inthe initial phases of an event. Detailed Assessment enables the Emergency Response Organization staff tomake more detailed dose assessments.

Sum Assessment adds multiple concurrent assessment results.Because certain aspects of the interface must be site or unit specific, particularly the release pathways, separate programs are used for each unit, or when possible, multi-unit site if the units are identical.

Themajority of the code forms and modules are common to all these separate

programs, with the pathways andsite specific setup parameters different for each site / unit.The program utilizes two types of data:* User inputs* Constants stored in external encrypted xml format files unique to each site.User inputs are values needed to run dose assessments that vary from assessment to assessment.

Thesewould consist of items such as meteorological data and effluent monitor readings.

Constants are values set internally by the system administrators.

These would consist of items such as siteboundary distances and monitor response factors that define the site and do not change for each assessment.

A separate computer program called "Interface Maintenance" is used to control and generate these constants and maintain the SQL data table files that these constants are stored in. The URI computer programs cannotchange constant values or their related encrypted xml files.The dose assessment computer programs will only be run when a user needs to perform a dose assessment.

The code does not generate any data that needs to be retained by the program after an assessment iscompleted, though reports can be printed or saved to individual files for later retrieval if required.

There are no interfaces with plant safety systems.The URI programs are specifically designed to interface with versions 4.0 to 4.2 of the NRC computer programRASCAL. It is expected that future revisions will remain compatible but would need to be verified for each newRASCAL release.

RASCAL is designed to produce emergency release dose assessments.

RASCALcommunicates between its own separate modules (.exe and .dll modules) using ASCII text data files. The URIprograms interface with RASCAL by creating the same data files in the same format based on the information stored in the xml data tables and the user input. These RASCAL data files are modified or retrieved

'on-the-fly' for each assessment performed.

Activity Type: [1 The activity is a change to the emergency planThe activity affects implementation of the emergency plan, but is not a change to the emergency planImpact and Licensing Basis Determination:

[ LOCK3-10 CFR 50.47(b)(8) states: "Adequate emergency facilities and equipment to support the emergency response are provided and maintained."

The emergency planning functions associated with 10 CFR 50.47(b)(8) state:

Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.3" Adequate facilities are maintained to support emergency response.

• Adequate equipment is maintained to support emergency response.

The applicable supporting requirement which is described in 10 CFR 50, Appendix E.IV.E states (inpart): Adequate provisions shall be made and described for emergency facilities and equipment, including:

2. Equipment for determining the magnitude of and for continuously assessing the impact of the release ofradioactive materials to the environment; The applicable informing criteria described in NUREG-0654,Section II.H.8 states:Each licensee shall provide meteorological instrumentation and procedures which satisfy the criteria inAppendix 2, and provisions to obtain representative current meteorological information from other sources.10 CFR 50.47(b)(9) states: "Adequate

methods, systems and equipment for assessing and monitoring actualor potential offsite consequences of a radiological emergency condition are in use."The emergency planning function associated with 10 CFR 50.47(b)(9) states:0 Methods, systems and equipment for assessment of radioactive releases are in use.The applicable supporting requirements which are described in 10 CFR 50, Appendix E state:Section IV.B (in part):1. The means to be used for determining the magnitude of, and for continually assessing the impact of, therelease of radioactive materials shall be described,Section IV.E (in part):Adequate provisions shall be made and described for emergency facilities and equipment, including:

2. Equipment for determining the magnitude of and for continuously assessing the impact of the release ofradioactive materials to the environment; The applicable informing criteria described in NUREG-0654, Section 11.1 states (in part):8. Each organization, where appropriate, shall provide methods, equipment and expertise to make rapidassessments of the actual or potential magnitude and locations of any radiological hazards through liquid orgaseous release pathways.

This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.9. Each organization shall have a capability to detect and measure radioiodine concentrations in air in theplume exposure EPZ as low as 10-7 uCi/cc (microcuries per cubic centimeter) under field conditions.

Interference from the presence of noble gas and background radiation shall not decrease the stated minimumdetected activity.

The applicable informing criteria described in NUREG-0696, Section 4.8 states (in part):The EOF technical data system will receive, store, process and display information sufficient to performassessments of the actual and potential onsite and offsite environmental consequences of an emergency condition.

Data providing information...

The EOF data set shall include radiological, meteorological, and other environmental data needed to:" Assess environmental conditions,

" Coordinate radiological monitoring activities, and" Recommend implementation of offsite emergency plans.Licensing Basis:This evaluation included a search of MNS licensing basis documents for references to Dose Assessment, and Emergency Planning Functional Area Manual3. 10 1OCFR 50.54(q)

Evaluations Attaclmnent 3.10.7.3specifically for references to RADDOSE-V.

The search concluded that while the dose assessment function isdiscussed, specific references to the dose assessment tool and how to perform dose assessments are notdiscussed.

As a result, the MNS licensing basis is not impacted by the change to replace RADDOSE-V withURI as the dose assessment tool. The change is which supports replacement of RADDOSE V with URI and isstrictly administrative and does not affect the licensing basis.Compliance Evaluation and

Conclusion:

BLOCK 4.1. Evaluation:

The replacement of RADDOSE with URI will continue to comply with applicable regulations and commitments by providing a means of assessing offsite radiation dose during an emergency.

Compliance with the requirements identified above is maintained in the following manner:Item 1URI uses plant effluent monitor values and meteorological instrumentation input for the calculation of doseassessment results.

These results are then used to determine the environmental impact of radioactive materialreleases and to direct the activities of field monitoring teams in plume tracking.

Licensee emergency responsepersonnel also use the assessment results to make protective action recommendations to state and localauthorities.

These features of URI are consistent with the current capabilities of RADDOSE.RADDOSE employs an automatic data download from selected meteorological and radiation monitoring instrumentation to make dose projections.

Typically, these downloads occur at 15-minute intervals.

The userperforming the assessment is responsible for validating the downloaded information against current plantconditions.

While URI has no provision for automatic data downloading, it does allow the user to "drag anddrop" meteorological and radiation parameters into the fields used by the application.

This does not result in asignificant delay since most of the time spent for data input in both RADDOSE and URI is for data validation.

Field syntax restrictions reject out-of-range data to prevent erroneous information from being used in projection calculations.

This feature, coupled with continual validation by the user, minimizes the risk of incorrect dataentry.Item 2The portion of this requirement pertinent to the proposed change is that the licensee provide the method toperform rapid radiological assessments.

RADDOSE uses a Gaussian dispersion model and employs dose conversion factors taken from EPA 400,Manual of Protective Action Guides and Protective Actions for Nuclear Incidents.

URI uses a similar modelwith the same dose conversion factors.

Empirical comparisons of both applications yield similar doseprojection results when subjected to the same radiological and meteorological conditions.

Calculation time ofboth applications is approximately the same. In addition, RASCAL (the underlying calculational base of URI) issanctioned by the NRC and accepted as an industry standard application for dose projection.

Item 3The portion of this requirement pertinent to the proposed change is that the emergency plan will contain adescription of how offsite dose projections are made. This description appears in Section I of the McGuireNuclear Station (MNS) Emergency Plan.Item 4The portion of this requirement pertinent to the proposed change is that the emergency plan will contain adescription of the equipment used for assessing the impact of the release of radioactive materials to theenvironment.

This description appears in Section I of the McGuire Nuclear Station (MNS) Emergency Plan.The replacement of the Raddose-V dose assessment tool with URI involved rigorous testing and walkdowns toensure the tool was ready for implementation.

Duke Energy and the URI vendor performed a Validation and Emergency Planning Functional Area Manual3.10 1 OCFR 50.54(q)

Evaluations Attachment 3.10.7.3Verification of the program to support implementation of the change. In addition, MNS ERe members qualified in dose projections received training on the changes and differences in dose projection methodology betweenRADDOSE-V and URI. This change to replace Raddose-V with URI does not change intent. This changesupports the Duke Energy fleetwide initiative to replace the dose projection tool used for dose assessment andfor protective action decision-making at all nuclear sites with an enhanced and improved methodology.

Thefleet procedure AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment" will now provide MNS doseassessment personnel with instructions for performing dose projections at the MNS site. The implementation of AD-EP-ALL-0202 ensures the correct software program for performing dose projections is used. Thischange continues to comply with planning standards, as described in 10 CFR 50.47(b) and 10 CFR 50,Appendix E requirements.

The change which supports the replacement of Raddose-V with URI is strictly administrative and continues tocomply with planning standards, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E requirements.

==

Conclusion:==

The proposed activity Z does / E] does not continue to comply with the requirements.

Reduction in Effectiveness (RIE) Evaluation and

Conclusion:

BLOCK 51. Evaluation:

The screening of the change from Raddose-V to URI identified two affected emergency planning functions associated with 10 CFR 50.47(b)(8) and 10 CFR 50.47(b)(9),

as described above in the Impact and Licensing Basis Determination.

The change replaces RADDOSE with URI as the principal dose assessment tool. While the user interface forURI differs from that of RADDOSE, the assessment methodologies of both applications are essentially thesame. Both employ the same dose conversion factors for determining source term dose. Both applications also use similar meteorological models of Gaussian plume dispersion.

URI provides a site specific overlay on the existing RASCAL meteorological, dispersion, and dose assessment models for all required input for emergency dose assessment as well as reports and plume graphics.

Using theURI interface, the user does not interact with any part of the original RASCAL input or output screens.Three of the primary purposes of URI are to make an interface that includes significant additional site specificprocesses (e.g. site specific effluent monitors),

to simplify the input process for the user, and to use an industrycommon dose assessment model.URI operates by providing a single input / result display form with non-serial input, and uses a 'pathway' release condition process rather than requiring the user to answer repetitive questions about the release.

Byselecting a 'pathway',

options are set including default meteorological towers, release heights, applicable effluent

monitors, etc. to limit the number of sequential questions the user must answer and to preventselections that do not match. While all emergency effluent dose assessment systems require similarinformation (met data, isotopic mix, release magnitude),

URI minimizes the effort required and significantly limits the opportunity for inappropriate selections.

Options selections are defined for each specific pathway,which both prevent inappropriate selections and highlight to the user the available options for defining theengineered active and passive particulate and iodine removal processes that affect the mix appropriate for theselected pathway.Numerous additional

reports, data displays, etc. are provided for details when needed. Plume plots areprovided, and a graphical display of areas exceeding the protective action guideline (PAG) limit is available.

The PAG graphic can be based on either the standard 16 sectors and 3 distances or on geo-political emergency response areas.One distinction between RADDOSE and URI deals with the identification of protective action recommendations (PARs). A feature of RADDOSE automatically flags the user when a dose projection determines that a PAR Emergency Planning Functional Area Manual3.10 1 OCFR 50.54(q)

Evaluations Attaclunient 3.10.7.3threshold has been met. The user is then expected to refer to approved procedures to confirm the validity ofthis indication.

Experience has shown that the automatic feature can be misleading under certain conditions and has led to incorrect PAR recommendations, particularly when the dose projection was performed by a lessexperienced user.URI does not have this automatic flagging feature.

PAR determination is made solely on approved procedural guidance without reliance on a potentially misleading indication.

Multiple options for source term basis are provided including monitored with single channel effluent

monitors, monitored with multi-channel group monitors, or release point samples, and numerous unmonitored optionsincluding containment high radiation

monitors, containment leakrate without monitors, RCS leakrate, or fieldteam back calculation.

Three assessment methods are provided; a "Detailed" option for more experienced users, a "Rapid" option thatmakes more fundamental assumptions that is intended for immediate on-shift

response, and a "Summation" option that allows for adding multiple concurrent releases.

While the "Detailed" and "Rapid" options areconsistent with current RASCAL assessment modes, the "Summation" option is an enhancement resulting fromFukushima experience.

The URI application, using site-specific inputs, has been evaluated against the software quality assurance criteria of NSD-800.

Comparison of test cases for RADDOSE and URI show consistently satisfactory results.The two applications showed no significant difference in the timeliness or accuracy of dose assessment information.

In summary, URI is characterized by:* a user-friendly input interface,

• graphical overlays displaying projected plume paths and dose values,* the ability to perform dose projections using multiple simultaneous

releases, and* wide acceptance by both the industry and the NRC as an effective dose assessment application.

The change does not result in a reduction in effectiveness of facilities, response organizations, or responseequipment.

This change is strictly administrative and does not change intent. This change supports thereplacement of the RADDOSE dose assessment tool with Unified RASCAL Interface (URI). This change doesnot affect the timeliness, accuracy or capability to determine or process dose projections and supports afleetwide initiative to align dose assessment tools at all Duke Energy nuclear plant sites.This change does not affect the emergency planning functions associated with 10 CFR 50.47(b)(8),

becausethis change continues to ensure that adequate facilities and equipment are maintained at MNS to supportemergency

response, including equipment used for performing dose projections.

This change does not affectthe applicable supporting requirement which is described in 10 CFR 50, Appendix E.IV.E, because this changecontinues to ensure that adequate provisions shall be made and described for emergency facilities andequipment.

In addition, this change continues to meet informing criteria described in NUREG-0654, SectionII.H.8.This change does not affect the emergency planning function associated with 10 CFR 50.47(b)(9),

because thechange continues to ensure that methods,

systems, and equipment for assessment of radioactive releases arein use at MNS. This change does not affect the applicable supporting requirement described in 10 CFR 50,Appendix E.IV.B and E, because this change continues to ensure that equipment is available for determining magnitude and assessment of releases to the environment.

In addition, this change continues to meetinforming criteria described in NUREG-0654, Section 11.1 (8-9) and NUREG-0696, Section 4.8.As stated above, this change does not reduce the effectiveness of the MNS Emergency Plan. Instead, thechange described in this revision continues to provide additional assurance that the ERO has the ability andcapability to:* respond to an emergency; e perform functions in a timely manner; Emergency Plarming Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.3" effectively identify and take measures to ensure protection of the public health and safety; and" effectively use response equipment and emergency response procedures.

This change enhances ERO readiness to support a classified emergency, resulting in an improved capability toensure health and safety of plant personnel and the general public. This change continues to meet NRCrequirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.This change is an overall improvement to the MNS Emergency Preparedness Program.Conclusion:

The proposed activity ED does / Z does not constitute a RIE.Effectiveness Evaluation Results BLOCK 6Z The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E and theactivity does not constitute a reduction in effectiveness.

Therefore, the activity can be implemented withoutprior approval.

LI The activity does not continue to comply with the requirements of §50.47(b) and §50 Appendix E or theactivity does constitute a reduction in effectiveness.

Therefore, the activity cannot be implemented withoutprior approval.

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DUKE ENERGYMCGUIRE NUCLEAR SITEAPPENDIX INDEXAppendix 1Appendix 2Appendix 3Appendix 4Appendix 5Appendix 6Appendix 7Appendix 8Appendix 9Definitions Meteorological System Description Alert and Notification System Description Summary of Evacuation Time Estimates Agreement LettersDistribution List for McGuire Emergency PlanSpill Prevention Control and Countermeasure PlanMcGuire Hazardous Waste Contingency PlanHazardous Materials Response PlanQ-1Rev. 14-5December, 2014 APPENDIX 11.0 DEFINITIONS AFFECTED PERSONSPersons who have received radiation exposure or have been physically injured as a result of anaccident to a degree requiring special attention as individuals, e.g., decontamination, first aid ormedical services.

ANNUALFor periodic emergency planning requirements, annual is defined as twelve months, with amaximum interval of 456 days.ASSESSMENT ACTIONThose actions taken during or after an accident to obtain and process information that isnecessary to make decisions to implement specific emergency measures.

BIENNIALFor periodic emergency planning requirements, biennial is defined as at least once every twoyears, with a maximum interval of 912 days. (Note that this does not apply to the scheduling ofbiennial exercises.

An exercise can occur at any time during the second calendar year after theprevious exercise.)

CORRECTIVE ACTIONSEmergency measures taken to ameliorate or terminate an emergency situation at or near thesource of the problem to prevent an uncontrolled release of radioactive material or to reduce themagnitude of the release, e.g., shutting down equipment, fire-fighting, repair and damagecontrol.DEGRADING

" Plant parameters (ex. temperature,

pressure, level, voltage, frequency) are trendingunfavorably away from expected or desired values AND plant conditions could resultin a higher classification or Protective Action Recommendation (PAR) before the nextfollow-up notification.

" Site conditions (ex. wind, ice/snow, ground tremors, hazardous/toxic/radioactive material leak, fire, security event) impacting plant operations or personnel safety areworsening AND plant conditions could result in a higher classification or Protective Action Recommendation (PAR) before the next follow-up notification.

DRILLA drill is a supervised instruction period aimed at testing, developing, and maintaining skills ina particular operation.

Q-2Rev. 14-5December, 2014 EMERGENCY ACTION LEVELS (EAL's)A pre-determined, site-specific, observable threshold for a plant Initiating Condition that placesthe plant in a given emergency class. An EAL can be: an instrument reading; an equipment status indicator; a measurable parameter (onsite or offsite);

a discrete, or another phenomenon which, if it occurs, indicates entry into a particular emergency class.EMERGENCY OPERATIONS FACILITY (EOF)The Emergency Operations Facility is the facility utilized for direction and control of allemergency and recovery activities with emphasis on the coordination of off-site activities suchas dispatching mobile emergency monitoring teams, communications with local, state andfederal agencies, and coordination of corporate and other outside support.EMERGENCY PLANNING ZONE (EPZ)The area for which planning is needed to assure that prompt and effective actions can be takento protect the public in the event of an accident.

The plume exposure EPZ is about 10 miles inradius and the ingestion exposure EPZ is about 50 miles in radius.EXCLUSION AREAThe nuclear site property out to a radius of 2500 feet, that meets the 10CFR100 definition.

EXERCISEAn exercise is an event that tests the integrated capability and a major portion of the basicelements existing within emergency preparedness plans and organizations.

IMPROVING

" Plant parameters (ex. temperature,

pressure, level, voltage, frequency) are trendingfavorably toward expected or desired values AND plant conditions could result in alower classification or emergency termination before the next follow-up notification.

" Site conditions (ex. wind, ice/snow, ground tremors, hazardous/toxic/radioactive material leak, fire, security event) have become less of a threat to plant operations orpersonnel safety AND plant conditions could result in a lower classification oremergency termination before the next follow-up notification.

INGESTION EXPOSURE PATHWAYThe principle exposure from this pathway would be from ingestion of contaminated water orfoods such as milk or fresh vegetables.

The time of potential exposure could range in lengthfrom hours to months.MONTHLYFor periodic emergency planning requirements, monthly is defined as once each month, with amaximum interval of 38 days.Q-3Rev. 14-5December, 2014 OPERATIONAL SUPPORT CENTER (OS)In the event of an emergency, shift support personnel (e.g., auxiliary operators and technicians) other than those required and allowed in the control room shall report to this center for furtherorders and assignment.

PLUME EXPOSURE PATHWAYThe principle exposure sources from this pathway are (a) external exposure to gamma radiation from the plume and from deposited material and (b) inhalation exposure from the passingradioactive plume. The time of potential exposure could range from hours to days.POPULATION-AT-RISK Those persons for whom protective actions are being or would be taken.PROTECTED AREAAn area encompassed by physical barriers and to which access is controlled.

PROTECTIVE ACTIONSThose emergency measures taken after an uncontrolled release of radioactive materials hasoccurred, for the purpose of preventing or minimizing radiological exposures to persons thatwould be likely to occur if the actions were not taken.PROTECTIVE ACTION GUIDES (PAG)Projected radiological dose or dose-commitment values to individuals in the general population that warrant protective action following a release of radioactive material.

Protective actionswould be warranted provided the reduction in individual dose expected to be achieved bycarrying out the preventive action is not offset by excessive risks to individual safety in takingthe protective action. The PAG does not include the dose that has unavoidably occurred priorto the assessment.

QUARTERLY For periodic emergency planning requirements, quarterly is defined as once every threemonths, with a maximum interval of 112 days.RECOVERY ACTIONSThose actions taken after the emergency to restore affected property as nearly as practicable toits pre-emergency condition.

SEMI-ANNUAL For periodic emergency planning requirements, semi-annual is defined as once every 6 months,with a maximum interval of 228 days.SITEThat part of the nuclear site property consisting of the Reactor, Auxiliary,

Turbine, ServiceBuildings and grounds, contained within the outer security area fence.Q-4Rev. 14-5December, 2014 STABLEPlant conditions are neither degrading nor improving.

TECHNICAL SUPPORT CENTER (TSC)This on-site center is for use by plant management, technical and engineering supportpersonnel.

In an emergency, this center shall be used for assessment of plant status andpotential off-site impact in support of the control room command and control function.

TRIENNIAL For periodic emergency planning requirements, triennial is defined as at least once every threeyears, with maximum interval of 1369 days.VITAL AREAAreas within the Protected Area that house equipment important for nuclear safety. Access to aVital Area is allowed only if an individual has been authorized to be in that area per theSecurity plan, therefore Vital Area is a Security term.WEEKLYFor periodic emergency planning requirements, weekly is defined as once every 7 days, with amaximum interval of 9 days.Q-5Rev. 14-5December, 2014 APPENDIX 2MCGUIRE NUCLEAR SITEMETEOROLOGICAL PROGRAMINTRODUCTION The meteorological program described in this appendix was developed using guidance provided byNUREG-0654, Revision 1, Regulatory Guide 1.23, Proposed Revision 1, Regulatory Guide 1.111, Revision1, and Regulatory Guide 1.109.EFFLUENT DISPERSION MODELA computer model which simulates the transport and diffusion of released effluents is a puff-advection model which incorporates a horizontal wind field that can vary in time but is consistent in space. It isassumed in the puff-type model that the spread within a puff along the direction of flow is equal to thespread in the lateral direction (i.e., horizontal Gaussian Symmetry).

In the model, concentration averagesare obtained by summing concentrations of individual elements for the grid points over which the puffspass. Features incorporated into the model include the use of primary, backup and predicted data, buildingwake effects and an assumed ground release mode. Appropriate persistence would be used for initialreleases until a meteorologist is notified to provide predictive data.INSTRUMENTATION Figure 2-1 shows the type and number of parameters measured at McGuire Nuclear Site. Themeteorological conditions present at McGuire Nuclear Site warrant the use of the basic described meteorological variables.

These include wind speed and wind direction measured at high and low levels,delta-temperature and sigma theta for stability classification, ambient air and dew point temperature andprecipitation.

DATA HANDLINGMeteorological data for dose calculation consists of a primary digital recording/storage system and asecondary analog chart recording system both of which meet system accuracies and other specifications assuggested in Regulatory Guide 1.23, Proposed Revision

1. In the digital system meteorological variables are sampled at varying time (1-60 seconds) intervals from which 15 minute total, average and/or standarddeviation quantities are computed.

Digital data is placed on an external PI server accessible to computers that are used for emergency effluent dispersion modeling and dose calculation.

The chart recording systemis maintained as a backup to the digital system.DOSE ASSESSMENT METHODOLOGY Dose assessment is calculated through a dose projection computer model Unified RASCAL Interface (URI). The model provides for the assessment of off-site radiological doses and accommodates both realtime and forecast modes in the calculation of exposures to the general public. The model provides results ofthe sum of the effective dose equivalent from external radiation (both plume and ground deposition) andthe committed effective dose equivalent from the inhalation of radioisotopes (the sum of both factorsequaling the total effective dose equivalent of TEDE), and the committed dose equivalent to the thyroid(CDE thyroid).

Dose conversion factors are derived from Regulatory Guide 1.109.Q-6Rev. 14-5December, 2014 The model uses source term (amount of radioactivity in the unit vent, containment and containment leakage or steam release valves),

flow rates and real time meteorology to calculate doses. Unit ventgrab sample analyses or unit vent radiation monitor readings are used to determine concentrations ofradioactivity within the unit vent source term. Containment atmosphere

samples, containment processradiation monitors or containment high range radiation monitors are used to determine concentrations within the containment source term. The containment design leak rate is used unless factors, such ascontainment

pressure, indicate that another value is more realistic.

Equivalent concentrations from asteam release are calculated by using known or assumed steam mass release rates and the specificsteam line radiation monitor reading.PHYSICAL SYSTEM DESCRIPTION Continuous parallel signals enter each Operator Aid Computer (OAC) and the analog recorders.

TheOAC calculates end to end 15 minute quantities, starting on the hour, for all meteorological variables (except sigma theta) with a sampling interval of 60 seconds.

It calculates a 15 minute average for highand low level wind direction and speed; 15 minute averages are also calculated for delta-temperature, ambient temperature and dew point temperature.

Total water equivalence is computed forprecipitation.

Sigma theta is calculated by a field unit with a sampling interval of one second again forend to end 15 minute periods starting on the hour, and then is fed to each OAC. All quantities arestored on the OAC with a minimum recall of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This data is transferred to the MNS PI Server.Data stored on the PI server is accessible to computers which are used for emergency effluentdispersion modeling and dose calculation DETAILED DESCRIPTION OF SUBSYSTEMS Sensors to Operator Aid ComputerLightning protection is provided for all sensors and signal conditioning equipment; wind sensors areoutfitted with heating jackets, when necessary, for protection against icing conditions.

Signalconditioners and the sigma theta field unit are housed in an environmentally controlled building at thebase of the high level tower. Signal cables to the OACs and analog recorders are shielded to minimizeelectrical interference.

Q-7Rev. 14-5December, 2014 Operator Aid Computer (OAC) to MNS PI ServerThe process computer OAC system which is utilized for data storage consists of SAIC, HP and RTPequipment.

Each unit OAC is a backup for the other, capable of supplying the same requiredmeteorological values. The data is transferred to the MNS PI server which is the server used for long-term data storage and retrieval.

Plant data on the PI server is accessible to computers that are used foremergency effluent dispersion modeling and dose calculation.

OUALITY ASSURANCE Meteorological components have been designed, procured and installed as a non-safety related system.Equipment has been purchased from suppliers which have provided high quality, reliable products inthe past. Surveillance during construction was provided as for any other non-safety system.Q-8Rev. 14-5December, 2014 FIGURE 2-1MCGUIRE NUCLEAR SITEMETEOROLOGICAL PARAMETERS OF THE UPGRADED SYSTEMMeasurement SystemExisting high level and10 meter towerHigh level wind speedand direction Low level wind speedand direction Delta-temperature Low level sigma thetaDry bulb temperature Dew pointPrecipitation Q-9Rev. 14-5December, 2014 APPENDIX 3DUKE ENERGYMCGUIRE NUCLEAR SITEALERT AND NOTIFICATION SYSTEM DESCRIPTION GENERAL DESCRIPTION The Alert and Notification System for McGuire Nuclear Site consists of an acoustic alerting signal andnotification of the public by commercial broadcast (EAS). The system is designed to meet theacceptance criteria of Section B of Appendix 3, NUREG-0654, FEMA-REP-1, Rev. 1.The Emergency plans of Duke Energy, the State of North Carolina, and the counties of Mecklenburg, Gaston, Catawba,

Lincoln, and Iredell include the organizations and individuals, by title, who will beresponsible for decision-making as regards the alert and notification system. The county locations fromwhich the sirens would be activated and, potentially, the request for an EAS message would come aremanned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Each organization's plan describes provisions for use of publiccommunications media or other emergency instructions to members of the public. The plans of the stateof North Carolina include a description of the information that would be communicated to the publicunder given circumstances.

A. Concept of Operations A system of 67 fixed sirens is installed and operational in the 10-mile EPZ around McGuireNuclear Site. A backup means of alerting and notification is described in the State and CountyPlans. This backup method includes area-wide emergency service vehicles traversing the areaand giving both an alerting signal and notification message.Each county will control the activation of the sirens within its boundaries (except for CatawbaCounty -their one siren will be activated by Lincoln County).

However, Mecklenburg, as thelead county, has the ability to activate all EPZ sirens from its control point.B. Criteria for Acceptance The alert and notification system for the McGuire Nuclear Site provides an alerting signal and aninformational or instructional message to the population (via the EAS) on an area-wide basisthroughout the 10-mile EPZ within 15 minutes from the time the cognizant off-site agencies havedetermined the need for such alerting exists. The emergency plans for the state of North Carolina(Annex E) include evidence of EAS preparation for emergency situations and the means foractivating the system.Q-10Rev. 14-5December, 2014 C. Physical Implementation

1. The activation of this alert and notification system requires procedures and relationships between both Duke Energy and the off-site agencies that support Duke and McGuireNuclear Site. When an incident is determined to have reached the level requiring publicprotective

actions, Duke contacts the cognizant off-site agency via DEMNET andprovides its recommendations.

This system is available for use 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day andlinks the Control Room, TSC, EOF, SERT headquarters, the county warning points, andthe county EOC's.2. The expected performance of the sirens used in this system is described in Figure Q-1.These sirens complement existing alerting systems.

The ambient background sound levelin the McGuire area is taken to be 50 db for areas of "less than 2000 persons/per squaremile" and 60 db for areas above this density.

On this basis, the siren coverages aredesigned to provide a signal 10db above the average daytime ambient background.

Furthermore, the sirens have been located to assure that the maximum sound levelsreceived by any member of the public should be lower than 126 db.The basis for selection of the 60 db(c) and 70 db(c) criteria is documented as follows:Location of heavy industry

-There is no "heavy industry" in the McGuire 10 mile EPZ.Attenuation factors with distance

-10 db loss per distance doubled (See Figure Q-1)Siren output db(c) at 100 ft. vs. assumed range and acoustic frequency spectra -2001-AC:

126+ 1.0 db at 100 feetAssumed ranges per Figure Q-l, 10 db loss columnFrequency Spectra:2001-AC:

top frequency 750 HzMap showing siren location

-See Figure Q-2Mounting height of sirens -50 feet (approximate)

Special weather condition considerations (such as expected heavy snow) -NoneThe siren system will produce a 3 minute steady signal and is capable of repetition.

Q-11Rev. 14-5December, 2014 Test ProgramPeriodic testing of the sirens is performed as follows:Test Req'd By Min. Req'd Freq. Norm. Freq. Perf. ByDukeSilent Test FEMA-REP-Every two weeks. Normally performed weekly1 0,NUREG-0654 Rev. on Thursdays.

1, App. 3Full Cycle Test (called FEMA-REP-10, Annually.

Normally performed on thefull-scale test by NUREG-0654 second Wednesday of eachFEMA) Rev. 1, App. 3 quarter, or during thebiennial exercise.

See Note1 below.Growl Test FEMA-REP-10, Quarterly and after See NOTE 1 below forNUREG-0654 PM is performed.

quarterly test.Rev. 1, App. 3, See NOTE 3 below forFEMA CPG 1-17 growl test following PM.March 1, 1980{PIP-G-00-0135}

NOTE: 1. Quarterly full cycle tests fulfill/exceed the requirements for quarterly growl tests.2. Each site may elect to perform some method of feedback system verification during thefull cycle siren test.3. For the FEMA CPG 1-17 growl test following PM, the siren chopper is sounded for ashort period of time so that it never produces full sound output. {PIP G-00-0135}

Refer to FAM Section 3.3 for a detailed narrative of the siren test program.Q-12Rev. 14-5December, 2014 FIGURE Q-1SIREN RANGE IN FEET12 AND 10 dB LOSS PER DISTANCE DOUBLEDMINIMUMLEVELCOVERAGEIN dB85807573706865602001AC126dB(c)SIREN 12 101125 18301500 26002000 36802260 42102700 52003000 60003600 74004800 10400Q-13Rev. 14-5December, 2014 FIGURE Q-2SIREN LOCATIONS C -- Ary*l-p ~I~iI.0 G)0(0C=3 ~hh~v0 S. >I ~C trQ-14Rev. 14-5December, 2014 APPENDIX 4DUKE ENERGYMCGUIRE NUCLEAR SITEEVACUATION TIME ESTIMATES DECEMBER 2012The evacuation time estimates described in part J of this plan were prepared for McGuire by KLDEngineering, P.C. Report KLDTR-501, MNS, development of Evacuation Time Estimates, revision 1.See M[NS-ETE-12132012-000, MNS Evacuation time Estimates (ETE) dated December 2012.The purpose of the study was to update the permanent resident population count for the EPZ aroundMcGuire Nuclear Site due to population growth.The ETE Report has been made available to site, state, and local planners for their use.Six scenarios were chosen to be studied and ETE listed is for entire EPZ:1. Winter weekday, fair weather conditions.

Estimated evacuation time is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 35 minutes.2. Winter weeknight, fair weather conditions.

Estimated evacuation time is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 10 minutes.3. Summer weekend, fair weather conditions.

Estimated evacuation time is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 30 minutes.4. Winter weekday, adverse weather conditions.

Estimated evacuation time is 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 40minutes.5. Winter weekend, adverse weather conditions.

Estimated evacuation time is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 10minutes.6. Summer weekend, adverse weather conditions.

Estimated evacuation time is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 55minutes.The evacuation study is available in the MNS Emergency Planning office for study and review.Q-15Rev. 14-5December, 2014 APPENDIX 5AGREEMENT LETTERSThe following agreement letters support the McGuire Nuclear Site Emergency Plan and are attached:

1. Carolinas Medical Center2. Huntersville Fire Department

3. Cornelius Volunteer Fire Department

4. Mecklenburg County Fire Marshall5. North Mecklenburg Rescue Squad (DELETED)

6. Mecklenburg Emergency Medical Services Agency (MEDIC)7. Charlotte-Mecklenburg Emergency Management Office8. Iredell County Civil Preparedness Agency9. Lincoln County Department of Emergency Management

10. Gaston County Department of Emergency Management

11. Catawba County Department of Emergency Management

12. Cabarrus County Department of Emergency Management

13. REACTS14. DOE -Savannah River15. INPO16. North Carolina17. Letter Documenting Duke Energy Assumptions for Offsite Dose Calculation Methodology

18. Duke Energy Back-Up TLD Reader19. Joint Information Center20. Alternate Site Agreement

21. G & G Metal Fabrication (Hale pump repair vendor)22. Duke's Lincoln Combustion Turbine Facility operating agreement with MNS/CNS/ONS onemergency supply of diesel fuel.23. Charlotte Mecklenburg Police Department (CMPD)These Letters of Agreement are updated as necessary and at least every (3) years to ensure adequateawareness on the part of all concerned of the existence and commitment to provide agreed services orassistance.

Q-16Rev. 14-5December, 2014 APPENDIX 6MCGUIRE NUCLEAR SITEEMERGENCY PLAN DISTRIBUTION NAMEMcGuire Nuclear SiteDocument

Control, MG05DMSite Emergency

Planner, MGO1EPSite Emergency Planner (TSC), MGO1EPControl Room, MGO1OPOperator Training

Director, MG03OTOperations Staff Manager, MGO1OPOperations Shift Manager, MGOIOPRadiation Protection

Manager, MGO1RPSatellite File, MGO IS1Environmental Management, MGO1EMRegulatory Compliance, MGO1RCEOF Director's AreaMcGuire Emergency

Planning, MGO1EPNRCMcGuire NRC Resident Inspector, MG01ANRC Regional Administrator (copy forwarded by Emer. Plan)NRC Regional Administrator (copy forwarded by Emer. Plan)NRC Document Control (copy forwarded by Emer. Plan)NRC Office Of Nuclear Material Safety and Safeguards Emergency Planning Consultant/NSRB StaffE. M. Kuhr, EC05PNews GroupEmergency Planning Consultant, EC 12XCatawba Nuclear SiteCNS Emergency Planning

Manager, CNO1EPNorth CarolinaDirector, Division of Environmental Health, Radiation Protection

Section, Raleigh, NCNCEM REP Program Manager,

Raleigh, NCNCEM Western Branch Office Manager,

Conover, NCCabarrus CountyCoordinator, Cabarrus County Dept. of Emergency Mgmt., Concord, NCQ-17Rev. 14-5December, 2014 APPENDIX 6MCGUIRE NUCLEAR SITEEMERGENCY PLAN DISTRIBUTION Catawba CountyCatawba County Emergency Management Coordinator, Newton, NCGaston CountyCoordinator, Gaston County Dept. of Emergency Mgmt., Gastonia, NCIredell CountyCoordinator, Iredell County Civil Preparedness Agency, Statesville, NCLincoln CountyDirector, Lincoln County Emergency

Services, Lincointon, NCMecklenburg CountyDirector, Charlotte-Mecklenburg Emergency Mgmt. Office, Charlotte, NCOconee Nuclear SiteONS Emergency Planning

Manager, ON03EPQ-18Rev. 14-5December, 2014 APPENDIX 6MCGUIRE NUCLEAR SITEEMERGENCY PLAN DISTRIBUTION (ADDRESSES)

DirectorDivision of Environmental HealthRadiation Protection Section1645 Mail Service CenterRaleigh, NC 27699-1645 REP Program ManagerNC Division of Emergency Management 4713 Mail Service CenterRaleigh, NC 27699-4713 Western Branch Office ManagerNC Division of Emergency Management 3305-15 16th Ave. S.E.Suite 305Conover, NC 28613-9213 Coordinator Cabamrs County Department of Emergency Management P.O. Box 707Concord, NC 28026-0707 Michael F Weber, DirectorOffice of Nuclear Material Safety and Safeguards Mail Stop T-8A23Washington DC, 20555-0001 Q-19Rev. 14-5December, 2014 APPENDIX 6MCGUIRE NUCLEAR SITEEMERGENCY PLAN DISTRIBUTION (ADDRESSES Continued)

Emergency Management Coordinator Catawba County Administration Building100-A South West Boulevard Post Office Box 389Newton, NC 28658-0389 Coordinator Gaston County Department of Emergency Management Post Office Box 15781615 North Highland StreetGastonia, NC 28052Coordinator Iredell County Civil Preparedness AgencyPost Office Box 788Statesville, NC 28677DirectorLincoln County Emergency Services115 W. Main StreetLincolnton, NC 28092DirectorMecklenburg Emergency Management 228 East 9th StreetCharlotte, NC 28202-2852 Q-20Rev. 14-5December, 2014 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 10CFR 50.54(q)

Evaluations.

§50.54(q)

Screening Evaluation Form Activity Description and

References:

BLOCK 1IMNS Emergency Plan Section Q (Appendix 2, Meteorological SystemDescription)

Rev 14-5 December 2014 Click here to enter text.Page Q-6 -Changed "RADDOSE" to "Unified RASCAL Interface (URI)".This change supports a fleetwide initiative to replace the dose assessment tools that are currently in place at the DukeEnergy Carolinas sites (using RADDOSE-V) and the Duke Energy Progress sites (using RASCAL) with UnifiedRASCAL Interface (URI) in order to align dose assessment tools at all Duke Energy nuclear plant sites. A new fleetprocedure AD-EP-ALL-0202, Emergency Response Dose Assessment, has been developed which provides instructions forperforming dose projections using Unified RASCAL Interface (URI) at MNS and the other nuclear plant sites.Planning Standards 50.47(b)(8) and 50.47(b)(9),

are impacted by the new URI process therefore a IOCFR50.54(q)

Effectiveness Evaluation must be performed.

Activity Scope: BLOCK 2E The activity is a change to the emergency planEl The activity is not a change to the emergency planChange Type: I BLOCK3 Change Type: BLOCK 4E] The change is editorial or typographical E] The change does conform to an activity that hasZ The change is not editorial or typographical prior approvalZ The change does not conform to an activity that hasprior approvalPlanning Standard Impact Determination:

BLOCK5El §50.47(b)(1)

-Assignment of Responsibility (Organization Control)EL §50.47(b)(2)

-Onsite Emergency Organization LI §50.47(b)(3)

-Emergency Response Support and Resources El §50.47(b)(4)

-Emergency Classification System*LI §50.47(b)(5)

-Notification Methods and Procedures*

LI §50.47(b)(6)

-Emergency Communications El §50.47(b)(7)

-Public Education and Information

[ §50.47(b)(8)

-Emergency Facility and Equipment

[ §50.47(b)(9)

-Accident Assessment*

El §50.47(b)(10)

-Protective Response*

[: §50.47(b)(1

1) -Radiological Exposure ControlEj §50.47(b)(12)

-Medical and Public Health SupportEj §50.47(b)(1

3) -Recovery Planning and Post-accident Operations

[: §50.47(b)(14)

-Drills and Exercises El §50.47(b)(1

5) -Emergency Responder TrainingEl §50.47(b)(1

6) -Emergency Plan Maintenance

• Risk Significant Planning Standards El The proposed activity does not impact a Planning StandardRevision 12 Emergency Planming Functional Area ManualAttachment 3.10.7.23.10 1 OCFR 50.54(q)

Evaluations Commitment Impact Determination:

BLOCK 6,[ The activity does involve a site specific EP conmmitment Record the conmuitment or commitment reference:

[ The activity does not involve a site specific EP comnnitment Screening Evaluation Results:

BLOCK 7F] The activity can be implemnented without performing a §50.54(q) effectiveness evaluation Z.The activity cannot be implemented without perfornp ng a §50.54(q) effectiveness evaluation Pr1a -r Name ' Prepa atu Ee Date-/? / ~ ~ ~ ~ ~~. ... ... .. .. .. .....................................................................

.. ..... ....... ...... .. .. ........

................................................................................

........... ..............

R i we Na e: Review Signature Date:11+04 ./10/22 7-1/I Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attaclunent 3.10.7.350.54(q)

Effectiveness Evaluation FormActivity Description and

References:

M NS Emergency Plan Section Q BLOC.:K(Appendix 2 (Meteorological System Description))

Rev 14-5December 2014Page Q-6 for Appendix 2 (Meteorological System Description) for "Dose Assessment Methodology"-

replaced RADDOSE with the Unified RASCAL Interface (URI).To support a Duke Energy fleetwide initiative, replacing instructions associated with the RADDOSE doseassessment tool with Unified RASCAL Interface (URI).This change supports a fleetwide initiative to replace the dose assessment tools that are currently in place atthe Duke Energy Carolinas sites (using RADDOSE-V) and the Duke Energy Progress sites (using RASCAL)with Unified RASCAL Interface (URI) in order to align dose assessment tools at all Duke Energy nuclear plantsites. A new fleet procedure AD-EP-ALL-0202, Emergency Response Dose Assessment, has been developed which provides instructions for performing dose projections using Unified RASCAL Interface (URI) at MNS andthe other nuclear plant sites. As a result, specific site procedures for performing dose projections aresuperseded by AD-EP-ALL-0202.

Additional information supportinq this changqe:RADDOSE is the current application used for dose assessment and projection of radiological releases duringan emergency.

The proposed change will replace RADDOSE with the Unified RASCAL Interface (URI) as thestandard fleet-wide dose assessment tool.RADDOSE is designed to estimate dose rates and deposition rates at 15-minute time intervals.

From theseestimates, integrated doses (using EPA 400-R-92-001 (EPA-400)[14]

dose factors and methodologies) andtotal deposition are calculated for the length of time covering the release of radioisotopes.

Doses are determined at radial grid and special receptor locations in the Plume Exposure Pathway Emergency Planning Zone while deposition is calculated to fifty miles surrounding the facility, based on radiological andmeteorological data collected at the plant.The RADDOSE model is designed to provide real-time (as the release is occurring) and projected site specificpredictions of atmospheric transport and diffusion as required by NUREG-0654, Revision 1, Appendix.

Atmospheric transport and diffusion are performed using a variable trajectory plume simulation model alongwith realtime meteorological data entered either directly from the PI server or manually.

Likewise, the sourceterm component of RADDOSE uses plant specific radiological data, for a number of accident types, entered viathe PI server or manually.

Using this information along with EPA-400 dose conversion

factors, the modeldetermines dose rates, doses, deposition rates and total deposition.

URI is a computer code intended for use at nuclear generating stations and other emergency response facilities in the event of an actual or potential release of airborne radioactivity to the environment at levels warranting declaration of an Emergency specified in the Radiological Emergency Plan. URI is a replacement for the userinterface normally delivered with the computer code Radiological Assessment System for Consequence Ana!ysis

("RASCAL")

maintained and distributed by the by the Nuclear Regulatory Commission (NRC).The URI program:* Provides a user interface specifically designed for users for nuclear power station events.* Allows input of all required dose assessment model parameters including meteorological data, planteffluent monitor data, and plant condition and status.Revision 12 Emergency Planning Functional Area Manual3.10 l OCFR 50.54(q)

Evaluations Attachment 3.10.7.30 Develops source terms based on user input.* Creates RASCAL data files based on the specific user input* Invokes the RASCAL met data processor, plume model processor, and puff model processors.

e Reads and interprets RASCAL results files and provide reports to the user of doses, affected areas,and other information relevant to emergency plan implementation.

The code has three modes: Rapid Assessment, Detailed Assessment, and Sum Assessment.

RapidAssessment enables on-shift staff to meet regulatory requirements for quick, simplified dose assessments inthe initial phases of an event. Detailed Assessment enables the Emergency Response Organization staff tomake more detailed dose assessments.

Sum Assessment adds multiple concurrent assessment results.Because certain aspects of the interface must be site or unit specific, particularly the release pathways, separate programs are used for each unit, or when possible, multi-unit site if the units are identical.

Themajority of the code forms and modules are common to all these separate

programs, with the pathways andsite specific setup parameters different for each site / unit.The program utilizes two types of data:* User inputs* Constants stored in external encrypted xml format files unique to each site.User inputs are values needed to run dose assessments that vary from assessment to assessment.

Thesewould consist of items such as meteorological data and effluent monitor readings.

Constants are values set internally by the system administrators.

These would consist of items such as siteboundary distances and monitor response factors that define the site and do not change for each assessment.

A separate computer program called "Interface Maintenance" is used to control and generate these constants and maintain the SQL data table files that these constants are stored in. The URI computer programs cannotchange constant values or their related encrypted xml files.The dose assessment computer programs will only be run when a user needs to perform a dose assessment.

The code does not generate any data that needs to be retained by the program after an assessment iscompleted, though reports can be printed or saved to individual files for later retrieval if required.

There are no interfaces with plant safety systems.The URI programs are specifically designed to interface with versions 4.0 to 4.2 of the NRC computer programRASCAL. It is expected that future revisions will remain compatible but would need to be verified for each newRASCAL release.

RASCAL is designed to produce emergency release dose assessments.

RASCALcommunicates between its own separate modules (.exe and .dll modules) using ASCII text data files. The URIprograms interface with RASCAL by creating the same data files in the same format based on the information stored in the xml data tables and the user input. These RASCAL data files are modified or retrieved

'on-the-fly' for each assessment performed.

Activity Type: BLO .2 :The activity is a change to the emergency plan=-The activity affects implementation of the emergency plan, but is not a change to the emergency planImpact and Licensing Basis Determination:

Mo I::10 CFR 50.47(b)(8) states: "Adequate emergency facilities and equipment to support the emergency response are provided and maintained."

The emergency planning functions associated with 10 CFR 50.47(b)(8) state:

Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.3* Adequate facilities are maintained to support emergency response.

" Adequate equipment is maintained to support emergency response.

The applicable supporting requirement which is described in 10 CFR 50, Appendix E.IV.E states (inpart): Adequate provisions shall be made and described for emergency facilities and equipment, including:

2. Equipment for determining the magnitude of and for continuously assessing the impact of the release ofradioactive materials to the environment; The applicable informing criteria described in NUREG-0654,Section II.H.8 states:Each licensee shall provide meteorological instrumentation and procedures which satisfy the criteria inAppendix 2, and provisions to obtain representative current meteorological information from other sources.10 CFR 50.47(b)(9) states: "Adequate

methods, systems and equipment for assessing and monitoring actualor potential offsite consequences of a radiological emergency condition are in use."The emergency planning function associated with 10 CFR 50.47(b)(9) states:* Methods, systems and equipment for assessment of radioactive releases are in use.The applicable supporting requirements which are described in 10 CFR 50, Appendix E state:Section IV.B (in part):1. The means to be used for determining the magnitude of, and for continually assessing the impact of, therelease of radioactive materials shall be described,Section IV.E (in part):Adequate provisions shall be made and described for emergency facilities and equipment, including:

2. Equipment for determining the magnitude of and for continuously assessing the impact of the release ofradioactive materials to the environment; The applicable informing criteria described in NUREG-0654, Section 11.1 states (in part):8. Each organization, where appropriate, shall provide methods, equipment and expertise to make rapidassessments of the actual or potential magnitude and locations of any radiological hazards through liquid orgaseous release pathways.

This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.9. Each organization shall have a capability to detect and measure radioiodine concentrations in air in theplume exposure EPZ as low as 10-7 uCi/cc (microcuries per cubic centimeter) under field conditions.

Interference from the presence of noble gas and background radiation shall not decrease the stated minimumdetected activity.

The applicable informing criteria described in NUREG-0696, Section 4.8 states (in part):The EOF technical data system will receive, store, process and display information sufficient to performassessments of the actual and potential onsite and offsite environmental consequences of an emergency condition.

Data providing information...

The EOF data set shall include radiological, meteorological, and other environmental data needed to:* Assess environmental conditions,

" Coordinate radiological monitoring activities, and" Recommend implementation of offsite emergency plans.Licensing Basis:This evaluation included a search of MNS licensing basis documents for references to Dose Assessment, and Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.3specifically for references to RADDOSE-V.

The search concluded that while the dose assessment function isdiscussed, specific references to the dose assessment tool and how to perform dose assessments are notdiscussed.

As a result, the MNS licensing basis is not impacted by the change to replace RADDOSE-V withURI as the dose assessment tool. The change is which supports replacement of RADDOSE V with URI and isstrictly administrative and does not affect the licensing basis.Compliance Evaluation and

Conclusion:

BtLOCK 41. Evaluation:

The replacement of RADDOSE with URI will continue to comply with applicable regulations and commitments by providing a means of assessing offsite radiation dose during an emergency.

Compliance with the requirements identified above is maintained in the following manner:Item 1URI uses plant effluent monitor values and meteorological instrumentation input for the calculation of doseassessment results.

These results are then used to determine the environmental impact of radioactive materialreleases and to direct the activities of field monitoring teams in plume tracking.

Licensee emergency responsepersonnel also use the assessment results to make protective action recommendations to state and localauthorities.

These features of URI are consistent with the current capabilities of RADDOSE.RADDOSE employs an automatic data download from selected meteorological and radiation monitoring instrumentation to make dose projections.

Typically, these downloads occur at 15-minute intervals.

The userperforming the assessment is responsible for validating the downloaded information against current plantconditions.

While URI has no provision for automatic data downloading, it does allow the user to "drag anddrop" meteorological and radiation parameters into the fields used by the application.

This does not result in asignificant delay since most of the time spent for data input in both RADDOSE and URI is for data validation.

Field syntax restrictions reject out-of-range data to prevent erroneous information from being used in projection calculations.

This feature, coupled with continual validation by the user, minimizes the risk of incorrect dataentry.Item 2The portion of this requirement pertinent to the proposed change is that the licensee provide the method toperform rapid radiological assessments.

RADDOSE uses a Gaussian dispersion model and employs dose conversion factors taken from EPA 400,Manual of Protective Action Guides and Protective Actions for Nuclear Incidents.

URI uses a similar modelwith the same dose conversion factors.

Empirical comparisons of both applications yield similar doseprojection results when subjected to the same radiological and meteorological conditions.

Calculation time ofboth applications is approximately the same. In addition, RASCAL (the underlying calculational base of URI) issanctioned by the NRC and accepted as an industry standard application for dose projection.

Item 3The portion of this requirement pertinent to the proposed change is that the emergency plan will contain adescription of how offsite dose projections are made. This description appears in Section I of the McGuireNuclear Station (MNS) Emergency Plan.Item 4The portion of this requirement pertinent to the proposed change is that the emergency plan will contain adescription of the equipment used for assessing the impact of the release of radioactive materials to theenvironment.

This description appears in Section I of the McGuire Nuclear Station (MNS) Emergency Plan.The replacement of the Raddose-V dose assessment tool with URI involved rigorous testing and walkdowns toensure the tool was ready for implementation.

Duke Energy and the URI vendor performed a Validation and Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.3Verification of the program to support implementation of the change. In addition, MNS ERO members qualified in dose projections received training on the changes and differences in dose projection methodology betweenRADDOSE-V and URI. This change to replace Raddose-V with URI does not change intent. This changesupports the Duke Energy fleetwide initiative to replace the dose projection tool used for dose assessment andfor protective action decision-making at all nuclear sites with an enhanced and improved methodology.

Thefleet procedure AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment" will now provide MNS doseassessment personnel with instructions for performing dose projections at the MNS site. The implementation of AD-EP-ALL-0202 ensures the correct software program for performing dose projections is used. Thischange continues to comply with planning standards, as described in 10 CFR 50.47(b) and 10 CFR 50,Appendix E requirements.

The change which supports the replacement of Raddose-V with URI is strictly administrative and continues tocomply with planning standards, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E requirements.

==

Conclusion:==

The proposed activity Z does / E] does not continue to comply with the requirements.

Reduction in Effectiveness (RIE) Evaluation and

Conclusion:

BLOCK 51. Evaluation:

The screening of the change from Raddose-V to URI identified two affected emergency planning functions associated with 10 CFR 50.47(b)(8) and 10 CFR 50.47(b)(9),

as described above in the Impact and Licensing Basis Determination.

The change replaces RADDOSE with URI as the principal dose assessment tool. While the user interface forURI differs from that of RADDOSE, the assessment methodologies of both applications are essentially thesame. Both employ the same dose conversion factors for determining source term dose. Both applications also use similar meteorological models of Gaussian plume dispersion.

URI provides a site specific overlay on the existing RASCAL meteorological, dispersion, and dose assessment models for all required input for emergency dose assessment as well as reports and plume graphics.

Using theURI interface, the user does not interact with any part of the original RASCAL input or output screens.Three of the primary purposes of URI are to make an interface that includes significant additional site specificprocesses (e.g. site specific effluent monitors),

to simplify the input process for the user, and to use an industrycommon dose assessment model.URI operates by providing a single input / result display form with non-serial input, and uses a 'pathway' release condition process rather than requiring the user to answer repetitive questions about the release.

Byselecting a 'pathway',

options are set including default meteorological towers, release heights, applicable effluent

monitors, etc. to limit the number of sequential questions the user must answer and to preventselections that do not match. While all emergency effluent dose assessment systems require similarinformation (met data, isotopic mix, release magnitude),

URI minimizes the effort required and significantly limits the opportunity for inappropriate selections.

Options selections are defined for each specific pathway,which both prevent inappropriate selections and highlight to the user the available options for defining theengineered active and passive particulate and iodine removal processes that affect the mix appropriate for theselected pathway.Numerous additional

reports, data displays, etc. are provided for details when needed. Plume plots areprovided, and a graphical display of areas exceeding the protective action guideline (PAG) limit is available.

The PAG graphic can be based on either the standard 16 sectors and 3 distances or on geo-political emergency response areas.One distinction between RADDOSE and URI deals with the identification of protective action recommendations (PARs). A feature of RADDOSE automatically flags the user when a dose projection determines that a PAR Emergency Planning Functional Area Manual3.10 1 OCFR 50.54(q)

Evaluations Attachment 3.10.7.3threshold has been met. The user is then expected to refer to approved procedures to confirm the validity ofthis indication.

Experience has shown that the automatic feature can be misleading under certain conditions and has led to incorrect PAR recommendations, particularly when the dose projection was performed by a lessexperienced user.URI does not have this automatic flagging feature.

PAR determination is made solely on approved procedural guidance without reliance on a potentially misleading indication.

Multiple options for source term basis are provided including monitored with single channel effluent

monitors, monitored with multi-channel group monitors, or release point samples, and numerous unmonitored optionsincluding containment high radiation

monitors, containment leakrate without monitors, RCS leakrate, or fieldteam back calculation.

Three assessment methods are provided; a "Detailed" option for more experienced users, a "Rapid" option thatmakes more fundamental assumptions that is intended for immediate on-shift

response, and a "Summation" option that allows for adding multiple concurrent releases.

While the "Detailed" and "Rapid" options areconsistent with current RASCAL assessment modes, the "Summation" option is an enhancement resulting fromFukushima experience.

The URI application, using site-specific inputs, has been evaluated against the software quality assurance criteria of NSD-800.

Comparison of test cases for RADDOSE and URI show consistently satisfactory results.The two applications showed no significant difference in the timeliness or accuracy of dose assessment information.

In summary, URI is characterized by:* a user-friendly input interface,

" graphical overlays displaying projected plume paths and dose values," the ability to perform dose projections using multiple simultaneous

releases, and* wide acceptance by both the industry and the NRC as an effective dose assessment application.

The change does not result in a reduction in effectiveness of facilities, response organizations, or responseequipment.

This change is strictly administrative and does not change intent. This change supports thereplacement of the RADDOSE dose assessment tool with Unified RASCAL Interface (URI). This change doesnot affect the timeliness, accuracy or capability to determine or process dose projections and supports afleetwide initiative to align dose assessment tools at all Duke Energy nuclear plant sites.This change does not affect the emergency planning functions associated with 10 CFR 50.47(b)(8),

becausethis change continues to ensure that adequate facilities and equipment are maintained at MNS to supportemergency

response, including equipment used for performing dose projections.

This change does not affectthe applicable supporting requirement which is described in 10 CFR 50, Appendix E.IV.E, because this changecontinues to ensure that adequate provisions shall be made and described for emergency facilities andequipment.

In addition, this change continues to meet informing criteria described in NUREG-0654, SectionII.H.8.This change does not affect the emergency planning function associated with 10 CFR 50.47(b)(9),

because thechange continues to ensure that methods,

systems, and equipment for assessment of radioactive releases arein use at MNS. This change does not affect the applicable supporting requirement described in 10 CFR 50,Appendix E.IV.B and E, because this change continues to ensure that equipment is available for determining magnitude and assessment of releases to the environment.

In addition, this change continues to meetinforming criteria described in NUREG-0654, Section 11.1 (8-9) and NUREG-0696, Section 4.8.As stated above, this change does not reduce the effectiveness of the MNS Emergency Plan. Instead, thechange described in this revision continues to provide additional assurance that the ERO has the ability andcapability to:* respond to an emergency;

• perform functions in a timely manner; Emergency Planning Functional Area ManualAttachmnent 3.10.7.33.10 1OCFR 50.54(q)

Evaluations

" effectively identify and take measures to ensure protection of the public health and safety; and" effectively use response equipment and emergency response procedures.

This change enhances ERO readiness to support a classified emergency, resulting in an improved capability toensure health and safety of plant personnel and the general public. This change continues to meet NRCrequirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.This change is an overall improvement to the MNS Emergency Preparedness Program.Conclusion:

The proposed activity El does / 0 does not constitute a RIE.Effectiveness Evaluation Results BLOCK 6Z The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E and theactivity does not constitute a reduction in effectiveness.

Therefore, the activity can be implemented withoutprior approval.

L1 The activity does not continue to comply with the requirements of §50.47(b) and §50 Appendix E or theactivity does constitute a reduction in effectiveness.

Therefore, the activity canmot be implemented withoutprior approval.

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Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachmnent 3.10.7.2Activity Description and

References:

MNS EPLAN Change 14X-, Section Q, Appendix BLOCK 13, Alert and Notification System Description 1ot1KActivity Scope: BLOCK 2The activity is a change to the emergency planD-The activity is not a change to the emergency planChange Type: BLOCK 3 Change Type: BLOCK4The change is editorial or typographical

-The change does conform to an activity that hasE\ The change is not editorial or typographical prior approval--]The change does not conform to an activity that hasprior approvalPlanning Standard Impact Determination:

E]I §50.47(b)(1)

-Assignment of Responsibility (Organization Control)-- §50.47(b)(2)

-Onsite Emergency Organization El §50.47(b)(3)

-Emergency Response Support and Resources L-- §50.47(b)(4)

-Emergency Classification System*[-] §50.47(b)(5)

-Notification Methods and Procedures*

El §50.47(b)(6)

-Emergency Communications El §50.47(b)(7)

-Public Education and Information

[I §50.47(b)(8)

-Emergency Facility and Equipment El §50.47(b)(9)

-Accident Assessment*

E] §50.47(b)(10)

-Protective Response*

E-l§50.47(b)(1

1) -Radiological Exposure ControlL] §50.47(b)(12)

-Medical and Public Health SupportEl §50.47(b)(1

3) -Recovery Planning and Post-accident Operations L-- §50.47(b)(14)

-Drills and Exercises L] §50.47(b)(15)

-Emergency Responder Training[1] §50.47(b)(16)

-Emergency Plan Maintenance

• Risk Significant Planning Standardsproposed activity does not impact a Planning StandardBLOCK 5This change corrects a reference to a note. The note is located on Page Q-12, in the table that describes periodic testing of sirens. The correction changes a reference in the Growl Test section of the chart on Q-1 2from "Note 4" to "Note 3". The note became Note 3 as a result of a previous plan change to this section(EPLAN Change 14-3, which delete a note. The notes were subsequently renumbered but the note reference was not changed.

This change does not alter the frequency nor content of siren tests.Commitment Impact Determination:

BLOCK 6Revision 12I Emergency Planning Functional Area Manual3.10 1 OCFR 50.54(q)

Evaluations Attachment 3.10.7.2[-]The activity does involve a site specific EP commitment Record the commitment or conmnitment reference:

Z The activity does not involve a site specific EP conrniitment Zesults:

BLOCK 7The activity can be implemented without performing a §50.54(q) effectiveness evaluation D-\ The activity cannot be implemented without performing a §50.54(q) effectiveness evaluation Preparer Name:a ntr Date:Renard Burris ! 10/9/14Revieyxejr Name: i /, Revie~e/ignature Date:Al "" Ib2ý2 /Revision 122 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 1OCFR 50.54(q)

Evaluations

§50.54(q)

Screening Evaluation Form Activity Description and

References:

MNSEmergency Plan Section Q (Appendix 3, Alert and Notification System)Rev 14-5 December 2014Page Q-1 I Changed from "Selective Signaling" to "DEMNET".

BLOCK 1'To support a Duke Energy fleetwide initiative, replacing references and instructions associated with Selective Signaling toDuke Emergency Management Network (DEMNET) which is used for notifications to state/county agencies.

The Selective Signaling to DEMNET replacement work is being performed under Engineering Change(EC)# 112636.Fleet procedure, AD-EP-ALL-0406, Duke Emergency Management Network (DEMNET),

Revision 0, includesinformation on how to operate DEMNET.DEMNET was incorporated to remove the Selective Signaling System and on the use of the new conmmunication network,for making emergency notifications to off-site agencies by initiating group calls to the government agencies usingDEMNET "MSN Notify".Planning Standards 50.47(b)(5) and 50.47(b)(6),

are impacted by the new DEMNET process therefore a 1OCFR50.54(q)

Effectiveness Evaluation must be performed.

Activity Scope:0 The activity is a change to the emergency planEl The activity is not a change to the emergency planI BLOCK 2Revision 12 Emergency Planning Functional Area ManualAttachment 3.10.7.23.10 10CFR 50.54(q)

Evaluations Change Type: BLOCK 3ED The change is editorial or typographical Z The change is not editorial or typographical Change Type: ,BLOCK4FD The change does conform to an activity that hasprior approval[ The change does not conform to an activity that hasprior approvalPlanning Standard Impact Determination:

ED §50.47(b)(1)

-Assignment of Responsibility (Organization Control)D §50.47(b)(2)

-Onsite Emergency Organization ED §50.47(b)(3)

-Emergency Response Support and Resources Dj §50.47(b)(4)

-Emergency Classification System*Z §50.47(b)(5)

-Notification Methods and Procedures*

[ §50.47(b)(6)

-Emergency Communications E- §50.47(b)(7)

-Public Education and Infornation D §50.47(b)(8)

-Emergency Facility and Equipment El §50.47(b)(9)

-Accident Assessment*

LI §50.47(b)(10)

-Protective Response*

LI §50.47(b)(1

1) -Radiological Exposure ControlLI §50.47(b)(12)

-Medical and Public Health SupportEL §50.47(b)(13)

-Recovery Planning and Post-accident Operations LI §50.47(b)(14)

-Drills and Exercises E] §50.47(b)(15)

-Emergency Responder TrainingLI §50.47(b)(16)

-Emergency Plan Maintenance

• Risk Significant Planning Standards BLOCK 5El The proposed activity does not impact a Planning StandardCommitment Impact Determination:

BLOCK 6LI The activity does involve a site specific EP coirunitment Record the cormnitment or commitment reference:

[ The activity does not involve a site specific EP commitment Screening Evaluation Results:

BLOCK 7FI The activity can be implemented without performing a §50.54(q) effectiveness evaluation

[] The activity carno___t be implemented without performir g a §50.54(q) effectiveness evaluation P~e arr Namie: Prep~ fu Date: y/Rev iewer Na e: 1 , ..R.-

--i...Date:...............................

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R ev e we N ~ e:. * , / R ~evievK r Signature

, D ate:/7 Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attachment 3.10.7.3§50.54(q)

Effectiveness Evaluation FormActivity Description and

References:

MNS Emergency Plan, Section Q (Appendix BLOCK 13, Alert and Notification System Description) rev 14-5 December 2014Page Q-1 1 Changed "Selective Signaling to "DEMNET"To support a Duke Energy fleetwide initiative, replacing references and instructions associated with Selective Signaling to Duke Emergency Management Network (DEMNET) which is used for notifications to state/county agencies.

The Selective Signaling to DEMNET replacement work is being performed under Engineering Change(EC)# 112636.F ew Fleet procedure, AD-EP-ALL-0406, Duke Emergency Management Network (DEMNET),

Revision 0, willalso be issued. The new Fleet procedure includes information on how to operate DEMNET.DEMNET changes were incorporated to remove the Selective Signaling System and add instructions on theuse of the new communication

network, DEMNET. Step details for using the old Selective Signaling systemwere deleted or replaced with instructions for using DEMNET. Step details for using DEMNET include thefollowing:

Initiating group calls to the government agencies with the DEMNET "'AN Notify" button, use of theAlternate DEMNET buttons, and notes containing supplemental information.

,yl1'L,$kA hiAdditional information regarding this change: /I-2.-4-/

tThe Selective Signaling emergency communications system has been the primary method of promptcommunication to State and local Offsite Response Organizations (OROs) from the McGuire NuclearStation (MNS) for many years. Within the confines of MNS, Selective Signaling operates as part of thenormal plant communications system (i.e. internal extensions, commercial phones, etc.). Beyond theboundaries of MNS, Selective Signaling transmits over analog lines that are leased from localtelephone providers.

In the past, these lines have been subject to damage by natural and man-madecauses or other failures such that all or part of communication ability of MNS to or from some or all ofthe OROs via Selective Signaling has been lost for various periods of time.Since Selective Signaling is an unmonitored system, it is typically not known that problems exist untilthe system is used (i.e., during periodic

testing, communication checks, drills, etc.). When problemsare identified and reported, it is up to the local telephone provider to determine when the repair(s) canbe made. In addition to the less than reliable service for the Selective Signaling system, Duke Energyhas been notified by local telephone providers that due to the frequency of failures and the everincreasing difficulty in obtaining repair parts / materials, they will no longer be able to provide repairmaintenance support of the antiquated system beyond 2014.As a solution for this, Duke Energy has selected Emergency Management Network (EMnet) asprovided by the vendor, Communications Laboratories (Comlabs).

EMnet is currently in use by anumber of Federal, State, and local government

agencies, and is being implemented by an increasing number of nuclear stations

/ utilities.

EMnet will be referenced as DEMNET for the remainder of thisevaluation.

Comlabs provides

hardware, software,

training, installation and other services necessary for DEMNET to operate.

DEMNET is being implemented across the Duke Energy Fleet as areplacement for Selective Signaling.

DEMNET allows the Control Room, Technical Support Center (TSC), Emergency Operations Center(EOF), and alternative response facilities to communicate with Offsite Response Organizations and/orwith each other using VoIP (voice-over-internet protocol) as the primary method. In the event ofinternet related problems (i.e., slow data transfer rate, unavailability, etc.), the system automatically transfers to satellite communication as a backup. Like Selective Signaling, DEMNET allows internaland external point-to-point contact between individual stations as well as simultaneous conferencing with multiple stations.

This ability is a valuable backup to existing telephone circuits.

The point-to-point capability also allows DEMNET to continue to provide Decision Line capability, which enables ORORevision 12 Emergency Planning Functional Area ManualAttachmnent 3.10.7.33.10 1OCFR 50.54(q)

Evaluations decision makers to use the system to discuss public protective actions over dedicated

/ controlled access communication links.Via the dedicated DEMNET computer, historical and real-time system status can be readilydetermined.

DEMNET is also monitored by the vendor, Comlabs.

This allows for a more proactive approach in identification and resolution of problems associated with the system should they occur. Inthe event of failure, the application of suitable compensatory measures (i.e., use of back upcommunications) can be made in a more efficient and effective manner.No changes are made to the communications systems that currently serve as a backup to Selective Signaling or the associated implementation process(es) for employing them.DEMNET equipment installed and operated at Duke Energy nuclear plants and support facilities isinstalled and maintained to meet cyber security requirements in accordance with 10 CFR 73.54 andother related guidance.

As part of the installation

process, DEMNET has been extensively tested to ensure connectivity Ioperability before being placed in service.

Duke Energy Emergency Response Organization andEmergency Preparedness, along with personnel from Offsite Response Organizations have receivedtraining on the new system as well.As configured, the network that DEMNET resides within MNS causes the system to be powered fromvarious sources based upon the physical location of the individual components within the network.

Inthe event normal and/or backup power supplies become unavailable, and as a result, DEMNET and allother backup communications system become non-functional, MNS and the OROs have a number ofbattery powered portable satellite phones available that can be placed into service in an effort tomaintain the capability of providing prompt communications between MNS and the OROs.Upon implementation across the Duke Energy Fleet and its State and local Offsite ResponseOrganizations, the product name "EMNet" is replaced with the new system name "Duke Emergency Management Network (DEMNET)".

The name "Selective Signaling" will no longer be used, while thename "Decision Line" will continue to be used.Activity Type: BLOCK 20 The activity is a change to the emergency planM] The activity affects implementation of the emergency plan, but is not a change to the emergency planImpact and Licensing Basis Determination:

I BLOCK 30 10 CFR 50.47(b)(5)

-Notification Methods and Procedures (Risk Significant Planning Standard) states:"Procedures have been established for notification, by the licensee, of State and local responseorganizations and for notification of emergency personnel by all organizations; the content of initial andfollow up messages to response organizations and the public has been established; and means toprovide early notification and clear instruction to the populace within the plume exposure pathwayEmergency Planning Zone have been established."

The applicable emergency planning function associated with 10 CFR 50.47(b)(5) states:"Procedures for notification of State and local governmental agencies are capable of alerting them ofthe declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications."

• 10 CFR 50.47(b)(6)

-Emergency Communications states: "Provisions exist for promptcommunications among principal response organizations to emergency personnel and to the public."The applicable emergency planning functions associated with 10 CFR 50.47(b)(6) state:

Emergency Planning Functional Area Manual3.10 1 0CFR 50.54(q)

Evaluations Attachment 3.10.7.3" Systems are established for prompt communication among principal emergency responseorganizations.

" Systems are established for prompt communication to emergency response personnel Licensing Basis:This evaluation included a search of McGuire Nuclear Station (MNS) licensing basis documents forreferences to the Selective Signaling system. The search concluded that a review of the Duke EnergyMcGuire Nuclear Station (MNS) Emergency Plan was warranted.

While the MNS Emergency Plan contains several references to Selective Signaling, there are no detailswithin the Emergency Plan regarding usage of the system, other than to indicate that it is the primarysystem used for prompt communications to the offsite response organizations.

DEMNET is replacing Selective Signaling as the primary system used for prompt communications to the offsite responseorganizations.

Other references within the MNS Emergency Plan include facility diagrams which indicate the location ofSelective Signaling telephones.

DEMNET equipment is replacing Selective Signaling in each locationwhere Selective Signaling was present.The MNS Emergency Plan also references periodic testing of Selective Signaling.

DEMNET will be testedin a similar manner and frequency as was Selective Signaling.

Consequently, the replacement of the Selective Signaling system with DEMNET within the MNSEmergency Plan will constitute a name change only.This review concludes that changes to this document relative to the replacement of Selective Signaling withDEMNET do not affect the licensing basis of the MNS Emergency Plan. The changes in this revisionsupport replacement of the Selective Signaling telephone system, which is used for notifications tostate/county

agencies, with a new dedicated telephone system called the Duke Emergency Management Network (DEMNET).

These changes support a Duke Energy fleet-wide initiative to upgrade the dedicated telephone system for notifying state/county agencies of a declared emergency as an overall enhancement to emergency preparedness.

These changes meet or exceed all emergency preparedness requirements based on NRC regulations and requirements.

Compliance Evaluation and

Conclusion:

BLOCK41. Evaluation:

10 CFR Part 50, Appendix E, Section IV.D.1 states the following:

Administrative and physical means for notifying local, State, and Federal officials and agencies andagreements reached with these officials and agencies for the prompt notification of the public and for publicevacuation or other protective

measures, should they become necessary, shall be described.

Thisdescription shall include identification of the appropriate officials, by title and agency, of the State and localgovernment agencies within the EPZs.10 CFR Part 50, Appendix E, Section IV.D.3 states the following, in part:A licensee shall have the capability to notify responsible State and local governmental agencies within 15minutes after declaring an emergency.

The licensee shall demonstrate

...10 CFR Part 50, Appendix E, Section IV.E.8.d states the following, in part:For nuclear power reactor licensees, an alternative facility (or facilities) that would be accessible even if thesite is under threat of or experiencing hostile action, to function as a staging area for augmentation ofemergency response staff and collectively having the following characteristics:

... the capability to performoffsite notifications;

....NUREG-0696 (Functional Criteria for Emergency Response Facilities),

Section 2.7, states, in part:The TSC voice communication equipment shall include:* Hotline telephone

...* Dedicated telephone

...* Dial telephones

...Intercommunications systems ...

Emergency Planning Functional Area Manual3.10 10CFR 50.54(q)

Evaluations Attaclhnent 3.10.7.3Communications

... to State and local operations center prior to EOF activation.

NUREG-0696 (Functional Criteria for Emergency Response Facilities),

Section 4.6, states, in part:The EOF shall have reliable voice communications facilities to the TSC, the control room, NRC, and Stateand local emergency operations centers.

The normal communication path between the EOF and thecontrol room will be through the TSC. The primary functions of the EOF voice communications facilities willbe:* EOF management

...* Communications

...* Communications

...* Communications to coordinate offsite emergency response activities, and* Communications

....NUREG-0654 (Criteria for Preparation and Evaluation of Radiological Emergency Response Plans andPreparedness in Support of Nuclear Power Plants),

Section II.F, states, in part:1. The communications plans for emergencies shall include organizational titles and alternates for bothends of the communication links. Each organization shall establish reliable primary and backup meansof communication for licensees, local, and State response organizations.

Such systems should beselected to be compatible with one another.

Each plan shall include:a. provision for 24-hour per day notification to and activation of the State/local emergency responsenetwork; and at a minimum, a telephone link and alternate, including 24-hour per day manning ofcommunications links that initiate emergency response actions.b. provision for communications with contiguous State/local governments within the Emergency Planning Zones;c. provision for communications

...d. provision for communications

...e. provision for alerting or activating emergency personnel in each response organization; andprovision for communication

...The replacement of Selective Signaling and Decision Line (SS/DL) with DEMNET continues to comply withapplicable regulations and commitments by providing a dedicated method of contacting State and localauthorities in a timely manner during an emergency.

Compliance is maintained in the following manner:1. DEMNET is a dedicated system for communication with OROs that is capable of establishing contactwithin 15 minutes of emergency declaration.

This is consistent with the capability of the SS/DLsystem.2. DEMNET stations are present in the Control Room, TSC, EOF, and alternative facilities which arecapableof initiating or receiving point-to-point or conference calls with any ORO site similarly equipped.

Thisis consistent with the capability of the SS/DL system.3. Compatible DEMNET stations are installed in all ORO locations that were serviced by the SS/DLsystem.4. The TSC has an DEMNET station to allow communication with State and local OROs prior to EOFactivation.

This capability existed with the existing SS/DL system.5. DEMNET is a voice communications system with dedicated stations located in the Control Room, TSC,EOF, alternative facilities, and State/local emergency operations centers and is capable of coordinating offsite response activities via point-to-point or conference calling.

Communications with NRC is Emergency Planning Functional Area Manual3. 10 OCFR 50.54(q)

Evaluations Attachment 3.10.7.3conducted using a separate system unrelated to DEMNET. This is consistent with the SS/DL system.NOTE: In addition to voice communications, DEMNET is also capable of transmitting data. The voicecommunications feature of DEMNET is the replacement for SS/DL voice communications capability.

6. DEMNET has redundant features to maintain communication capability in the event of system failure ordegradation.

During normal operation, DEMNET employs voice-over-internet protocol (VoIP)technology to establish contact between stations.

Should internet problems (unavailability, slow transfer rate, etc.)occur, the system will automatically shift to satellite communication as a backup. This backup featureis an enhancement that SS/DL did not have. Failure of the SS/DL system required the use of thecommercial telephone system to re-establish communications.

7. By locating an DEMNET station in the continuously staffed Control Room, the licensee provides 24-hour per day capability to establish links to initiate emergency response actions.8. DEMNET stations are established at each contiguous State/local emergency response agency withinthe EPZ. This is consistent with the usage of the SS/DL system.* 10 CFR 50.47(b)(5) states the following:

"Procedures have been established for notification, by the licensee, of State and local responseorganizations and for notification of emergency personnel by all organizations; the content of initial andfollow-up messages to response organizations and the public has been established; and means to provideearly notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established."

The function of this planning standard pertinent to this change is the establishment of procedures for Stateand local governmental agencies that are capable of initiating notification of the declared emergency within15 minutes after declaration of an emergency and providing follow-up notification.

• 10 CFR 50.47(b)(6) states the following:

"Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public."The function of this planning standard pertinent to the change is that systems be established for promptcommunications among principal response organizations.

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Conclusion:==

The proposed activity 2 does / []I does not continue to comply with the requirements.

Reduction in Effectiveness (RIE) Evaluation and

Conclusion:

BLOCKS51. Evaluation:

The screening of this change has identified two (2) affected planning standard functions described above:1. Procedures for notification of State and local government agencies are capable of initiating notification of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notification.

Additional procedures are currently in effect for notification of State and local agencies following adeclared emergency.

These procedures explicitly require that such notification occur within 15 minutesof emergency declaration.

Station procedures were originally intended to address notifications using the Selective Siqnalinq/Decision Line (SS/DL) system and have likewise been revised to address the chanqe to Emergency Planning Functional Area Manual3.10 1OCFR 50.54(q)

Evaluations Attachment 3.10.7.3DEMNET. The functionality and utility of the procedures remain unaffected by the proposed change.Consequently, this evaluation concludes that the change presents no undesirable impact on thisplanning function.

2. Systems are established for prompt communication to emergency response personnel.

The SS/DL system suffered from obsolescence and eroding vendor support.

The communications carriers currently providing service for the system informed the licensee that all support will terminate atthe end of 2014. This prompted the change to DEMNET, a communications system widely used in theemergency response community.

As described above, DEMNET possesses all of the capabilities of SS/DL with additional enhancements not found in the former system. Significant among these is the use of robust VolP technology andautomatic "failover" to satellite communications in the event of a failure or degradation of the primaryinternet flowpath.

Consequently, this evaluation concludes that the change presents no undesirable impact on this planning function.

The evaluation concludes that the change does not impact either applicable planning function negatively and therefore does not constitute a reduction in effectiveness.

==

Conclusion:==

The proposed activity LI does / M does not constitute a RIE.Effectiveness Evaluation Results BLOCK 6[ The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E and theactivity does not constitute a reduction in effectiveness.

Therefore, the activity can be implemented withoutprior approval.

LI The activity does not continue to comply with the requirements of §50.47(b) and §50 Appendix E or theactivity does constitute a reduction in effectiveness.

Therefore, the activity cannot be implemented withoutprior approval.

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.......Approver Name: L , ro ignaue D