Text

ERO Position Comparison and Evaluation
	ML17311A540
Person / Time
Site:	Catawba
Issue date:	11/01/2017
From:	; Duke Energy Carolinas
To:	; Office of Nuclear Reactor Regulation
References
	CNS-17-056
	Download: ML17311A540 (222)
	v • d • e

DUKE ENERGY Catawba Nuclear Station (CNS) Duke Energy ERO Standardization TSC/OSC ERO Position Comparison and Evaluation Revision 0 CNS ERO Position Comparison and Evaluation Table of Contents 1 PURPOSE ...........................................................................................................................

3 2 DISCUSSION

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3 3

SUMMARY

OF CHANGES .................................

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....... 4 3.1 Comparison of ERO Positions, Responders and Response Times ...........................

....... 4 3.1.1 Numeric Change Impact to the Augmented ERO ................................................

.4 3.1.2 Response Time Impact to the Augmented ERO ..................................................

.4 3.2 Comparison of the ERO Hierarchy/

Reporting Relationships

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6 3.3 Comparison of ERO Responsibilities by Position ............................................................

6 Attachments Attachment 1, CNS ERO Staffing Depth Comparison

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7 Attachment 2, CNS Organizational Comparison of the ERO Hierarchy .....................................

13 Attachment 3, CNS TSC ERO Position Comparison and Evaluation

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17 Attachment 4, CNS OSC ERO Position Comparison and Evaluation

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....... 86 Attachment 5, Change Evaluation Process ..............

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125 Page 2 of 128 Revision 0 CNS ERO Position Comparison and Evaluation 1 PURPOSE Identify differences and deviations between the current CNS ERO and the Duke standard ERO from the TSC and OSC. Evaluate all deviations to determine whether they create a reduction in effectiveness (RIE) within the Emergency Preparedness Program. 2 DISCUSSION A program initiative has been undertaken by Duke Energy personnel to standardize the ERO positions, functions and responsibilities (tasks) across the fleet. This involves changes to the current ERO, which for' this evaluation is based upon those responder titles and numbers identified in emergency plan and the implementing procedures.

It is recognized that any changes to the ERO structure and the implementing procedures require a detailed §50.54(q) effectiveness evaluation.

Regulatory Guide 1.219 provides the following information related specifically to this type of change: [C.1.1.b]

Some changes that a licensee may make to its approved emergency plan warrant prior NRG approval to ensure that the changes would not adversely affect the NRG's reasonable assurance determination.

However, other general types of changes may have such a minimal effect on this determination that they would not warrant prior NRG approval.

For example, changes that reduce the number of personnel available to respond to emergencies or lengthen the time it takes to staff and activate emergency response facilities (ERFs) could affect the NRG's reasonable assurance determination and would require prior NRG staff approval.

Minor administrative changes, such as correcting position titles and spelling errors and updating document numbers, would not warrant prior NRG staff review." Between these extremes is a range of possible changes for which the licensee is required to perform and document a detailed, objective evaluation.

[G.1.4.a]

.... Proposed changes that could delay emergency declarations, notifications, or PARs may reduce the effectiveness of the emergency plan in that subsequent emergency response actions may not be timely and emergency response personnel, facilities, and equipment may not be in position if it becomes necessary to carry out measures to protect the public health and safety. Generally, the licensee should view any change that could delay an activity or relax a timeliness criterion for the activity as a potential reduction in effectiveness and should evaluate it accordingly.

Due to the scope of changes being made, this position to position and task to task comparison evaluation has been developed to document the effectiveness review. Attachment 5 documents the methods used to conduct this evaluation.

Page 3 of 128 Revision 0 CNS ERO Position Comparison and Evaluation 3

SUMMARY

OF CHANGES 3.1 Comparison of ERO Positions, Responders and Response Times The total number of responders filling augmented ERO positions in the current CNS ERO is 46 and the total number of responders filling augmented ERO positions in the standard ERO is 46 (no change to ERO responders).

45 Minute ERO Responders:

The standard ERO imposes no changes to 45 minute responders.

All 45 minute response positions are staffed in accordance with existing site specific Emergency Plan commitments.

CNS has two (2) 45 minute response positions.

75 Minute ERO Responders:

The standard ERO imposes no changes to 75 minute responders.

The current augmented ERO has twenty-four (24) 75 minute responders and the standard augmented ERO has twenty-four (24) 75 minute responders (no change).

Full Staffing ERO Responders:

The standard ERO imposes no changes to full staff responders

.. The current augmented ERO has twenty (20) full staff responders and the standard augmented ERO has twenty (20) full staff responders (no change). Current CNS Duke Standard 45 Minute 2 2 75 Minute 24 24 Full Staffing 20 20 Total 46 46 3.1.1 Numeric Change Impact to the Augmented ERO There is no change to the numeric ERO responders. Difference 0 0 0 0

Three (3) responders are added as a result of three new positions.

Three (3) responders are removed as a result of the elimination of three positions.

3.1.2 Response

Time Impact to the Augmented ERO The changes result in no change to the 75 minute responders.

Two (2) 75 minute responders are added as a result of two full staffing positions being changed to 75 minute positions.

Two (2) 75 minute responders are removed as a result of the elimination of two 75 minute positions being changed into full staff positions.

The changes result in no change to the full staffing responders.

Two (2) full staff responders are added as a result of two 75 minute positions being changed into full staff positions.

Two (2) full staff responders are removed as a result of two full staff positions being changed into 75 minute positions.

Page 4 of 128 Revision 0 CNS ERO Position Comparison and Evaluation In practice, all ERO members are called out at the same time and respond as soon as possible.

This provides for the quickest response and offers the ability to adjust ERO personnel resources as the specific conditions of the event warrant. The numeric and response time changes resulting from the adoption of the standard ERO establish a closer relationship between risk significant

/ key functions and the positions assigned those functions.

The objective of the changes is to ensure those functions and their processes are linked directly to the augmented minimum staffing positions to allow for optimum relief of on shift personnel and less complicated response execution following facility activation.

Removal of the TSC Assistant Operations Engineering position:

This position was a support position and the duties have been assumed by various members of the standard ERO. Given that all required functions within the TSC have been accommodated in the new procedure, and timeliness is unaffected, this change is found to be acceptable.

Removal of the TSC Emergency Planner position:

This position was a support position and the duties have been assumed by various members of the standard ERO. Given that all required functions within the TSC have been accommodated in the new procedure, and timeliness is unaffected, this change is found to be acceptable.

The DRC Supervisor did not exist in the CNS Emergency Plan, but had actions in the OSC Activation Procedure.

All actions contained within the DRC Supervisor procedure are implemented elsewhere in the standard OSC organization.

Given that all required functions within the OSC have been accommodated in the new procedure, and timeliness is unaffected, this change is found to be acceptable.

One of two Offsite communicators was moved from 75 min response to full response. The EOF assumes offsite communications when activated.

Moved the OSC Manager position from a full staffing position to a 75 minute response.

This is considered an enhancement.

The basis for this change is to specify the OSC facility management ERO position as a requirement for activation and thus relieve the Control Room SM of the direction of repair and corrective action functions as soon as possible.

Moved the TSC NRC Communicator position from a full staffing position to a 75 minute response.

This is considered an enhancement.

The basis for this change is to ensure communications with the NRC is established and thus relieve the Control Room of this function as soon as possible.

Collectively and individually these changes do not decrease the capability or the timeliness of the ERO to perform their assigned tasks. No site specific commitments regarding particular ERO positions, tasks or their response time were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Refer to Attachment 1 for a position-by-position comparison of the CNS and standard ERO responders in the TSC and OSC, sorted by facility and by function.

Page 5 of 128 Revision 0 CNS ERO Position Comparison and Evaluation

3.2 Comparison

of the ERO Hierarchy/

Reporting Relationships In the adoption of the standard ERO, CNS facility staffing continues to be grouped by major functions.

In general, each of the directors, managers and supervisors

/ coordinators in the standard ERO maintain a similar span of control to that of the current ERO. Summary descriptions of the changes to the ERO reporting hierarchy are as follows:

All risk significant functions ( classification, notification, protective actions and assessment) are assigned to minimum staffing positions aligned within the hierarchy.

The Assistant Emergency Coordinator position in the TSC and the Assistant OSC Manager position in the OSC have been formalized.

This allows each facility lead to maintain an oversight and coordination role while the assistant's focus can be on facility operations.

Engineering leadership and functions have been aggregated in the TSC which provides improvements in engineering team communications and management.

The organizational/hierarchical changes improve the reporting relationships and management levels of the ERO and streamline the process path for risk significant functions.

The organizational/hierarchical changes do not overload the next level supervisor/manager positions.

The organizational/hierarchical changes do not decrease the capability or the timeliness of the ERO to perform their assigned tasks. No site specific commitments regarding a particular ERO hierarchy were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Refer to Attachment 2 for a comparison of the organization charts illustrating the current augmented ERO and the standard augmented ERO. 3.3 Comparison of ERO Responsibilities by Position Deviations created by the addition, removal or modification of a task to a particular ERO position did not degraded the capability or timeliness to perform that associated function.

No site specific commitments regarding a particular ERO task assignment were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Refer to Attachments 3 and 4 for comparisons and evaluations of added, removed and modified tasks between the current augmented ERO and the standard augmented ERO. Page 6 of 128 Revision 0 Attachment 1 CNS ERO Staffing Depth Comparison Augmented ERO Comparison by Facility ( Current ERO Position Title 45 I 75 I Full I Standard ERO Position Title 45 I 75 Technical Support Cent 0 6 13 EmerQency Coordinator 1 EmerQencv Coordinator 1 Assistant Emergency Coordinator 1 Assistant Emergency Coordinator 1 Offsite AQency Communicator 2 Offsite Communicator 1 1 NRC Communicator 1 NRC Communicator 1 CR/TSC Communicator 1 CR Operations Bridge 1 Assisitant Ops EnQineer 1 Offsite Dose Assessor 1 Dose Assessor 1 RP Manager 1 RP ManaQer 1 Ops Superintenent 1 Operations Manager 1 Operations Engineer 1 Assistant Ops Manager 1 Engineering Manager 1 Engineering Manager 1 Reactor Engineer 1 Reactor Engineer 1 Electrical Engineer (moved from OSC) 1 Systems Support Engineer 1 Mechanical Engineer 1 Emergency Planner 1 Security ManaQer 1 Security Coordinator 1 Evacuation Coordinator 1 Site Evacuation Coordinator 1 Log/Status Keeper 1 Log Keeper 1 Data Coordinator 1 OAC Support 1 IT Support 1 Page 7 of 128 Revision 0 Attachment 1 I Current ERO Position Title Operations Support Center OSC Coordinator Nuclear Supply Chain Maintenance Manager Equipment (Electrical)

Engineer (moved to TSC) Operations Supervisor RP Supervisor On-Site Survey RC Technician In-Plant Survey RC Technician Protective Actions RC Technician FMT Members Chemistry Manager Log Keeper DRC Supervisor IAE Technician (OSC) Mech Maint Technician (OSC) Radwaste Operator (OSC) Total Augmenting ERO: CNS ERO Staffing Depth Comparison 45 I 75 I Full I Standard ERO Position Title 2 18 7 1 OSC Manager Assistant OSC Manager OSC Operations Liaison 1 Generation Supply Chain Liaison 1 Maintenance Supervisor 1 1 Operations Supervisor 1 RP Supervisor 1 1 On-Site Survey RP Qualified Personnel 1 1 In-Plant Survey RP Qualified Personnel 6 Protective Actions RP Qualified Personnel 4 FMT Members 1 Chemistry Supervisor 1 Log Keeper 1 2 IAE Technician (OSC) 1 Mechanical Technician (OSC) 1 Radwaste Operator (OSC) 2 24 20 Page 8 of 128 45 I 75 2 17 8 1 1 1 1 1 1 1 1 1 1 1 6 4 1 1 2 1 1 2 24 20 Revision 0 Attachment 1 CNS ERO Staffing Depth Comparison I Aug'!'e_'.1ted E_~O ~omparison by Function C: C: -:a: C: C: _:a: -ca -ca Functional Area Major Tasks CNS ERO Emergency Positions It) *-It) *-::s .... Standard ERO Emergency Positions It) *-It) *-::s .... ..... ,... LL rn v~ LL rn 2. Direction and Command and Emergency Coordinator

{TSC) 1 Emergency Coordinator(EC) (TSC) 1 Control Control ---.. -*-.. --.--.. *------*-Assistant EC (TS9) *----*-----------

Facility Control 1 Assistant EC (TSC) 1 --**-----------_OSC Coordinator

_(OSC) 1 OSC Manager (OSC) 1 -*-----*---Assis.talilt Q.SC MaliJag~r (PS'~,) 1, Function 2 Totals: 0 1 2 0 2 2 3. Notification

& Emergency Offsite Agency Comm (TSC) ______ 2 Offsite Communicator (TSC) 1 1 --*--* Comm. Communications NRC Communicator (TSC) 1 NRC Communicator (TSC) 1 *---*--** ---------Plant Status & Assistant Ops EngJneerjTSC)

___________ 1 *-----*-Technical

_Q§C ~Q~~atipns Liais_01il (Q_SC) _ 1 ----------*------*--*---*-1 Activities CR/TSC Communicator (TSC) 1 CR Operations Bridge (TSC) Function 3 Totals: 0 2 3 0 2 3 4. Radiological Offsite Dose Offsite Dose Assessor (TSC) 1 Dose Assessor (TSC) 1 Assessment Assmt *-*-*--*-. ------------

--*-***-----* Offsite Surveys £:M..I._[Y.!~_!Tlbers-2 teams (OSC)___ __________

4 FMT Members -2 teams (OSC~ __ 4 Onsite~y~

_ _ 13p_g~~l~J~d Personnel (OSC) ------* 1 1 RP Qualified Personnel (OSC) 1 1 *-----_ In-plant Surveyy RP Qualified_Personne~(OSC)

______ 1 1 _RP Qualified Personnel (9_§f) ______ 1 1 RP Supervisory

_RP Manager (TSC) ___ 1 RP Manager (TSC) 1 -------RP Supervisor (OSC) 1 RP Supervisor (OSC) 1 Function 4 Totals: 2 7 2 2 7 2 5. Plant System Technical OPs Superintendent (TSC) 1 _Qperations Manager (TSC) 1 --*--* Engineering, Support/ Operations_EngineerjTSg_)

1 Assistant Ops Manag..e!:_(TSC) 1 -------Repair, and Accident Analysis Engineering Manager (TSC) 1 Engineering Manager (TSC) 1 Corrective

--Reactor Engineer {TSC) 1 Reactor Engineer (TSC) 1 Actions *--* ---~9_l:!!Pi':lent (Electrical)

Engin~_r:_JOSC) 1 . Electrical Engine~.!:_(I_~C) 1 ----------Systems ~ue_e_ort Eng (TSCL_ ____ 1 _IYlechanical Engine_~(TS~)

1 -----Emerg~y]'lanner(I§g_)

1 *--------Maintenance Manager (OSC 1 Maintenance Supervisor (OSC) ___ 1 ----Qperations Supervisor (OSC) 1 Operations Supervisor (OSC~-----

1 ---*----_ChemistrLManager (OSC) _______ 1 Chemistry Supervisor(OSg 1 ------*--_ ....... .........

______ .. --*-*--Repair and DRC SupervismjOSC) 1 ------Corrective Nuclear Supply Chain (OSC) ____ 1 Generation Supply Chain Liaison (OSC 1 Actions IAE Technician (OSC) 2 IAE Technician (OSC) 2 Mech Maint Technician (OSC) 1 Mechanical Technician (OSC) 1 ----Radwaste Operator (OSC) 1 Radwaste Operator (OSC) 1 Function 5 Totals: 0 8 8 0 7 7 Page 9 of 128 Revision 0 Attachment 1 CNS ERO Staffing Depth Comparison C: C: -:s: C: C: -:s: -ca -ca Functional Area Major Tasks CNS ERO Emergency Positions u, *-u, *-::::,-Standard ERO Emergency Positions u, *-u, *-::::, _ "d'~ ...... LL en "d' ...... LL en 6. In-Plant PAs Radiation RP Qualified Personnel (OSC) 6 RP Qualified Personnel (OSC) 6 Protection Function 6 Totals: 0 6 0 0 6 0 7. Access Control Sec& Security Manager (TSC)_ ______ 1 Security Coordinator (TSCL _________ 1 ----*-*-----* Accountability Evacuation Coordinator

{TSC) 1 Site Evacuation Coard (TSC) 1 Function 7 Totals: 0 0 2 0 0 2 8. Resource Administration Log_!5eeper (TSC) 1 _Log Keeper (TSC) 1 --Allocation and LogJStatus Keeper (OSC) 1 _Log Keeper (OSC) __________

1 *-*-----Admin Facility Data Coordinator (TSC). _____________ 1 OAC Support (TSC) 1 Operations IT Support (TSC) 1 Function 8 Totals: 0 0 3 0 0 4 TOTAL: 2 24 20 2 24 20 Page 10 of 128 Revision 0 Attachment 1 CNS ERO Staffing Depth Comparison

1. Addition and Removal of Positions and Responders 1.1. The total number of responders filling augmented ERO positions in the current CNS ERO is 46 and the total number of responders filling augmented ERO positions in the standard ERO is 46 (no difference).

1.1.1. Three

(3) responders are added to the CNS ERO. 1) TSC IT Support (full staff) 2) Assistant OSC Manager (full staff) 3) OSC Operations Liaison (full staff) 1.1.2. Three (3) responders are removed from the CNS ERO. 1) TSC Assistant Operations Engineer (full staff) 2) TSC Emergency Planner (full staff) 3) OSC DRC Supervisor (full staff) 1.2. Specific comparison between the ERO staffing numbers in each facility are as follows: 1.2.1. TSC -The. TSC ERO staffing numbers remain at 19: 1) TSC IT Support was added ( +1) 2) Electrical Engineer (moved from OSC) (+1) 3) Emergency Planner was removed (-1) 4) Assistant Operations Engineer was removed (-1) 1.2.2. OSC -The OSC ERO staffing numbers remain at 27: 1) Assistant OSC Manager was added ( + 1) 2) OSC Operations Liaison was added ( +1) 3) DRC Supervisor was removed (-1) 4) Equipment (Electrical)

Engineer (moved to the TSC) (-1) Page 11 of 128 Revision 0 Attachment 1 CNS ERO Staffing Depth Comparison

2. Alteration of ERO Response Times 2.1. 45 Minute Response:

The standard ERO imposes no changes to 45 minute responders.

All 45 minute response positions are staffed in accordance with existing site specific Emergency Plan commitments.

CNS has two (2) 45 minute response positions.

2.2. 75 Minute Response:

The current augmented ERO has twenty-four (24) 75 minute responders and the standard augmented ERO has twenty-four (24) 75 minute responders (no change). 2.2.1. Two (2) responders are moved from full staff to 75 minute response ( +2):

TSC NRC Communicator (CNS NRC Communicator)

OSC Manager (CNS OSC Coordinator) 2.2.2. Two (2) responders are moved from 75 minute to full staff response (-2):

One (1) TSC Offsite Communicator (CNS Offsite Agency Communicator)

OSC Maintenance Supervisor (CNS Maintenance Manager) 2.3. Full Staffing:

The current augmented ERO has twenty (20) full staff responders and the standard augmented ERO has twenty (20) full staff responders (no change). 2.3.1. Three (3) responders are added by new full staff response positions

(+3):

TSC IT Support

OSC Assistant OSC Manager

OSC Operations Liaison 2.3.2. Two (2) responders are moved from 75 minute to full staff response (+2):

One (1) TSC Offsite Communicator (CNS Offsite Agency Communicator)

OSC Maintenance Supervisor (CNS Maintenance Manager) 2.3.3. Three (3) responders are removed by the elimination of 3 full staff response positions

(-3 ):

TSC Assistant Operations Engineer

TSC Emergency Planner

OSC DRC Supervisor 2.3.4. Two (2) responders are moved from full staff to 75 minute response (-2):

TSC NRC Communicator (CNS NRC Communicator)

OSC Manager (CNS OSC Coordinator)

Page 12 of 128 Revision 0 Attachment 2 Current Station TSC Organization I *-2 Offsite Agency TSC Data Comm Coordinator

,-~. 7i'.5~min. . I CNS Organizational Comparison of the ERO Hierarchy Emergency Coordinator

-75min .. TSCLo~ Keeper I I I I I TSC 1 security Radiation Evacuation Protection Coordinator Emergency I Manager Planner I Offsite Dose -Assessor-75 min Page 13 of 128 I I Operations I Superintdt

-Ops Engineer -Asst Ops Engineer NRC Comm -* I I Engineering Manager Systems Support -Engineer 75min Reactor -Engineer-75 min Revision 0 Attachment 2 Standard TSC Organization Assistant Emergency Coordinator Security Coordinator Site Evacuation Coordinator OAC Support IT Support CNS Organizational Comparison of the ERO Hierarchy Emergency Coordinator 75min Offsite Communicator 75 Min Offsite Commuinicator

---~~--------, Log Keeper Engineering Manager Operations Manager RP Manager Reactor Engineer 75 Min Electrical Engineer 75 Min Mechanical Engineer 75 Min Assistant Operations Manger Page 14 of 128 NRC Communicator 75 Min CR Ops Bridge Dose Assessor 75 Min Revision 0 Attachment 2 Current Station OSC Organization Operations Supervisor

{a~O" Waste Operator 75 3AO (from shift) '*aintenanoe Manager 75min arnca Technician 75 2 IAE Technicians 75min Mechanical (from shift) 2 IAE Technicians (from shift) CNS Organizational Comparison of the ERO Hierarchy Emergency Coordinator

-75min osc Coordinator osc Log/Status Keee_er Equipment (Electrical)

Engineer 75 min RP Supervisor members 75_mio 6 RP Techs 75min 3 RP Techs (from shift) Page 15 of 128 Chemistry Manager Chem Tech (from shift) Nuclear Supply Chain Revision 0 Attachment 2 Standard OSC Organization Maintenance Supervisor IAE Techs (2) 75min Mechanical Technician 75min Mechanical (from shift) IAE Tech (2) (from shift) CNS Organizational Comparison of the ERO Hierarchy OSC Manager 75 min Assistant OSC Manager Log keeper Operations Supervisor Radwaste Operator 75 min Operations Liaison AO (3) (from Shift) RP Supervisor RP Techs (6) Rad Support 75min FMT Members ( 4) 75min RP Tech (3) (from shift) Page 16 of 128 Chemistry Supervisor Chem Tech (from shift) Generation Supply Chain Liaison Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Emergency Coordinator (E-Plan 8.2; CNS/RP/O/A/5000/020 Enclosure 4.1) Emergency Coordinator (E-Plan 8.2; AD-EP-ALL-0105 Attachment

1) Overall Change Impact to the Position The span of control for this position has been reduced to 7 people. The Emergency Coordinator and the Assistant Emergency Coordinator are equally qualified and are interchangeable.

The Assistant Emergency Coordinator typically acts as a TSC manager more in line with industry practices, which allows the Emergency Coordinator greater attention on site response activities in all facilities (TSC, OSC and CR) and less attention on TSC operation and administration.

Deviations created by the addition, removal and modification of tasks to the. Emergency Coordinator position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position. These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 23 tasks were added, 23 were modified and O were removed. Emergency Coordinator

m*,JM+i.P Establish 24-hour staffing Coordinate response activities with offsite response agencies (EM , ICP , Field Mon , etc.) AD-EP-ALL-0105 Att 1 Step 3.6 Verify that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing li st has been completed AD-EP-ALL-0105 Att 1 Step 1.5 Page 17 of 128 This task has been added and is categorized as a deviation. CNS implementing procedures do not specifically include this task although the EC does control coordination with the ICP as a task for overall control of site response. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 Emergency Coordinator

m 1#M*i*1& Perform position turnover when a shift change occurs. Assume and establish command and control Transfer command and control Set priorities for staff and work actions. Respond as directed when notified of an event (sign in, get materials, etc.). CNS TSC ERO Position Comparison and Evaluation Emergency Coordinator 1 tMdM*Met Coordinate ERO/facility shift turnover AD-EP-ALL-0105 Att 1 Step 1.5 Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 1 Step 2.3 Assume/maintain command and control AD-EP-ALL-0105 Att 1 Step 1.4 Transfer command and control AD-EP-ALL-0105 Att 1 Step 1.4 Manage all onsite emergency response activities AD-EP-ALL-0105 Att 1 Step 2.1 Manage facility emergency response activities AD-EP-ALL-0105 Att 1 Step 2.1 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 1 Step 1.1 Page 18 of 128 This task has been added and is categorized as a deviation.

Previous CNS procedures has each facility manager responsible for their groups shift turnover and do not specifically include this task for the EC. Although the EC, as the individual responsible for the site response , does control shift turnover. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as no reduction. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Coordinate integration of the NRG site team AD-EP-ALL-0105 Att 1 Step 3.8 Prioritize and authorize requests for external assistance (technical, craft, admin, etc.) AD-EP-ALL-0105 Att 1 Step 2.1.5 Approve equipment, supply, and logistics expenditures for response to the event AD-EP-ALL-0105 Att 1 Step 2.1.5 Page 19 of 128 This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

This task has been added and is categorized as a deviation.

Previous CNS procedures do not specifically include this task although the EC, as the individual responsible for the site response, does control prioritization and authorization of requests for external assistance.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Previous CNS procedures do not specifically include this task although the EC, as the individual responsible for the site response, does approve equipment, supply, and logistics expenditures.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

Revision 0 Attachment 3 Classify and declare emergencies CNS TSC ERO Position Comparison and Evaluation Arrange for equipment and supply resources AD-EP-ALL-0105 Att 1 Step 2.1.5 Arrange for logistics support AD-EP-ALL-0105 Att 1 Step 2.1.5 Request Federal support and resources AD-EP-ALL-0105 Att 1 Step 2.1.5 Classify and declare emergencies AD-EP-ALL-0105 Att 1 Step 2.1.2 Page 20 of 128 This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation. Previous CNS procedures do not specifically include this task although the EC, as the individual responsible for the site response, does request Federal support and resources.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 Emergency Coordinator *1 HriM+i& Ensure the performance of offsite notifications Approve NRC Notifications CNS TSC ERO Position Comparison and Evaluation Assist with emergency classification AD-EP-ALL-0105 Att 1 Step 2.1.2 Approve and direct offsite emergency notifications to state and local authorities AD-EP-ALL-0105 Att 1 Step 2.1.a.2.b Direct notifications and ENS communications with the NRC AD-EP-ALL-0105 Att 1 Step 2.1.10 Ensure flow of information within and between the emergency response facilities AD-EP-ALL-0105 Att 1 Step 2.1.9 Perform or direct emergency PA announcements AD-EP-ALL-0105 Att 1 Step 2.1.2.a.4 Page 21 of 128 This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

Previous CNS procedures do not specifically include this task although the EC, as the individual responsible for the site response , is responsible for the flow of information.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

Revision 0 Attachment 3 Emergency Coordinator

)O*riM+i& Activate TSC and OSC CNS TSC ERO Position Comparison and Evaluation Ensure minimum staff is available (facility staffed) AD-EP-ALL-0105 Att 1 Step 1.3.5 Determine current/projected staff needs AD-EP-ALL-0105 Att 1 Step 1.3.10 , 11 Ensure facility staff is prepared to perform their activities (facility ready) AD-EP-ALL-0105 Att 1 Step 1.3 Activate the facility (facility activated)

AD-EP-ALL-0105 Att 1 Step 1.3.9 Page 22 of 128 This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 Implement Contingency Actions as required Identify critical tasks and direct OSC to execute CNS TSC ERO Position Comparison and Evaluation Direct/coordinate facility relocation AD-EP-ALL-0105 Att 1 Step 3.4 Determine and direct site response priorities AD-EP-ALL-0105 Att 1 Step 2.2 Support determination of site response priorities AD-EP-ALL-0105 Att 1 Step 2.2 Determine and direct the actions for mitigation strategies and contingency plans AD-EP-ALL-0105 Att 1 Step 2.2 Coordinate between CR, OSC and TSC to set OSC Team task priorities AD-EP-ALL-0105 Att 1 Step 2.2 Page 23 of 128 This task has been added and is categorized as a deviation. Previous CNS procedures do not specifically include this task although the EC, as the individual responsible for the site response, does diect and coordinate facility relocation.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. Previous CNS procedures do not specifically include this task although the EC, as the individual responsible for the site response, does determine and direct site response prioritization.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 Emergency Coordinator

1 H#4+M& Authorize site evacuation Approve Protective Action Recommendations CNS TSC ERO Position Comparison and Evaluation Emergency Coordinator t@l;JM+1 1* Direct/support site assembly, accountability and search & rescue activities AD-EP-ALL-0105 Att 1 Step 3.1 Establish and maintain facility accountability AD-EP-ALL-0105 Att 1 Step 3.1 Coordinate site evacuation AD-EP-ALL-0105 Att 1 Step 3.2 Approve use of Kl AD-EP-ALL-0105 Att 1 Step 3.3 Approve offsite Protective Action Recommendations AD-EP-ALL-0105 Att 1 Step 2.1.2.a.2 Page 24 of 128 This task has been added and is categorized as a deviation.

Previous CNS procedures do not specifically include this task although the EC, as the i ndividual responsible for the site response, does direct assembly, accountability and search & rescue activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

Previous CNS procedures do not specifically include this task although the EC, as the individual responsible for authorizing Kl. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement The steps for this task have been modified for checklist use , which is categorized as a difference.

Revision 0 Attachment 3 Approve emergency radiation exposures Downgrade or terminate emergencies Implement Recovery actions Ensure appropriate actions are taken of 54(x) is invoked Conduct TSC staff briefings to update ERF staffs (EOF , OSC, TSC) on a periodic and as-needed basis Maintain event logs, forms and records. CNS TSC ERO Position Comparison and Evaluation Approve emergency exposures AD-EP-ALL-0105 Att 1 Step 3.3 Ensure habitability is established and maintained for occupied areas AD-EP-ALL-0105 Att 1 Step 1.2.2 Terminate the emergency event AD-EP-ALL-0105 Att 1 Step 3.5 Develop recovery plans AD-EP-ALL-0105 Att 1 Step 3.5 Authorize and direct extreme measures (FLEX , EDMG , SAMG, §50.54(x) or security controls)

AD-EP-ALL-0105 Att 1 Step 3. 7 Conduct facility briefs and updates AD-EP-ALL-0105 Att 1 Step 2.1.7 Provide input for facility briefs and updates AD-EP-ALL-0105 Att 1 Step 2.1. 7 Maintain event logs, forms and records AD-EP-ALL-0105 Att 1 Step 1.1.2 Page 25 of 128 The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation. CNS implementing procedures do not specifically include this task although the EC is responsible for habitability actions. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Emergency Coordinator

m*;JM+i&

Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination. AD-EP-ALL-0105 Att 1 Step 4.0 The steps for this task have been modified for checklist use, which is categorized as a difference. Page 26 of 128 Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Assistant Emergency Coordinator (CNS/RP/O/A/5000/020 Enclosure 4.16) Assistant Emergency Coordinator (AD-EP-ALL-0105 Attachment

1) Overall Change Impact to the Position The span of control for the Assistant Emergency Coordinator has been established at 4 ERO positions.

The Emergency Coordinator and the Assistant Emergency Coordinator are equally qualified and are interchangeable.

The standard ERO develops the Assistant Emergency Coordinator position as a TSC manager more typical of industry practices.

The facility administrative supervisory duties of the old Assistant Emergency Coordinator align with the standard Assistant Emergency Coordinator, although the standard ERO position has additional tasks that expand the role of the position.

Tasks added the Assistant Emergency Coordinator position relieve the Emergency Coordinator of TSC facility management duties and allow them to concentrate on overall site emergency response activities.

Removed tasks continue to be performed by other more appropriate ERO positions.

Deviations created by the addition, removal or modification of tasks to the Assistant Emergency Coordinator position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 36 tasks were added, 8 were modified and O were removed. Assistant Emergency Coordinator Old Responsibility (tas Assistant Emergency Coordinator l~t¥i;iM+1 MlffiHNJiffiH Coordinate response activities with offsite response agencies (EM, ICP, Field Mon, etc.) AD-EP-ALL-0105 Att 1 Step 3.6 Page 27 of 128 This task has been added and is categorized as a deviation.

CNS implementing procedures do not specifically include this task although the EC does control coordination with the ICP as a task for overall control of site response.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

Revision 0 Attachment 3 Assistant Emergency Coordinator Old Responsibility (task) Perform position turnover when a shift change occurs. Assist with the transfer of command and control CNS TSC ERO Position Comparison and Evaluation Assistant Emergency Coordinator

@W;JM+i1Mlfflffffiffi Verify that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list has been completed AD-EP-ALL-0105 Att 1 Step 1.5 Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 1 Step 2.3 Coordinate ERO/facility shift turnover AD-EP-ALL-0105 Att 1 Step 1.5 Assume/maintain command and control AD-EP-ALL-0105 Att 1 Step 1.4 Transfer command and control AD-EP-ALL-0105 Att 1 Step 1.4 Page 28 of 128 This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use , which is categorized as a difference.

This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 Assistant Emergency Coordinator Old Responsi Respond as directed when notified of an event (sign in, get materials, etc.). CNS TSC ERO Position Comparison and Evaluation Assistant Emergency Coordinator New Responsibility (task Manage all onsite emergency response activities AD-EP-ALL-0105 Att 1 Step 2.1 Manage facility emergency response activities AD-EP-ALL-0105 Att 1 Step 2.1 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 1 Step 1.1 Coordinate integration of the NRC site team AD-EP-ALL-0105 Att 1 Step 3.8 Prioritize and authorize requests for external assistance (technical, craft, admin, etc.) AD-EP-ALL-0105 Att 1 Step 2.1.5 Page 29 of 128 This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

Revision 0 Attachment 3 Assistant Emergency Coordinator Old Responsibility (task) CNS TSC ERO Position Comparison and Evaluation Assistant Emergency Coordinator ISS.Ull~J.ts.0.1.:SIMRMJMij Approve equipment, supply, and logistics expenditures for response to the event AD-EP-ALL-0105 Att 1 Step 2.1.5 Arrange for equipment and supply resources AD-EP-ALL-0105 Att 1 Step 2.1.5 Arrange for logistics support AD-EP-ALL-0105 Att 1 Step 2."1.5 Request Federal support and resources AD-EP-ALL-0105 Att 1 Step 2.1.5 Page 30 of 128 This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation. CNS implementing procedures do not include this task for the Assistant EC as the scope of that position did not warrant this activity.

This change formally documents the task as a specific activity as the position is elevated to an assistant EC role. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

This change is evaluated as no reduction Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Assistant Emergency Coordinator Old Responsi Assistant Emergency Coordinator IS *. till ~lts .I.I .i& 1!41 ftW Classify and declare emergencies AD-EP-ALL-0105 Att 1 Step 2.1.2 Assist with emergency classification AD-EP-ALL-0105 Att 1 Step 2.1.2 Assist with the development of offsite notifications I Approve and direct offsite emergency notificat i ons to state and local authorities AD-EP-ALL-0105 Att 1 Step 2.1.a.2.b Direct notifications and ENS communications w i th the NRC AD-EP-ALL-0105 Att 1 Step 2.1.10 Page 31 of 128 This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation. CNS implementing procedures do not include this task for the Assistant EC as the scope of that position did not warrant this activity. This change formally documents the task as a specific activity as the position is elevated to an assistant EC role. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. This change is evaluated as no reduction. The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. Revision 0 Attachment 3 Assistant Emergency Coordinator Old Responsibility (task) CNS TSC ERO Position Comparison and Evaluation Assistant Emergency Coordinator ISl.tul~lts.O.C.tsl!41RMJMl5 Ensure flow of information within and between the This task has been added and is categorized as emergency response facilities a deviation.

AD-EP-ALL-0105 Att 1 Step 2 .. 1.9 Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. Perform or direct emergency PA announcements AD-EP-ALL-0105 Att 1 Step 2.1.2.a.4 Ensure minimum staff is available (facility staffed) AD-EP-ALL-0105 Att 1 Step 1.3.5 Determine current/projected staff needs AD-EP-ALL-0105 Att 1 Step 1.3.10, 11 Page 32 of 128 This change is evaluated as no reduction.

This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation. CNS implementing procedures do not include this task for the Assistant EC as the scope of that position did not warrant this activity.

The assistant EC is the TSC manager, who ensures min staffing.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. CNS implementing procedures do not include this task for the Assistant EC as the scope of that position did not warrant this activity.

The assistant EC is the TSC manager, who manages the preparation for facility activation.

This change is evaluated as an improvement.

Revision 0 Attachment 3 Assistant Emergency Coordinator Old Responsi Assist with activation of the TSC CNS TSC ERO Position Comparison and Evaluation Assistant Emergency Coordinator ISLUL~J.4&.J.t.lSIMWM2M.J Ensure facility staff is prepared to perform their activities (facility ready) AD-EP-ALL-0105 Att 1 Step 1.3 Activate the facility (facility activated)

AD-EP-ALL-0105 Att 1 Step 1.3.9 Direct/coordinate facility relocation AD-EP-ALL-0105 Att 1 Step 3.4 Determine and direct site response priorities AD-EP-ALL-0105 Att 1 Step 2.2 Page 33 of 128 This task has been added and is categorized as a deviation. CNS implementing procedures do not include this task for the Assistant EC as the scope of that position did not warrant this activity.

The assistant EC is the TSC manager, who manages the preparation for facility activation.

This change is evaluated as an improvement.

Responsibility has been modified and is categorized as a deviation. CNS implementing procedures do not include this task for the Assistant EC as the scope of that position did not warrant this activity.

The assistant EC is the TSC manager, who can activate the facility, which relieves the EC of the task. This change is evaluated as no reduction This task has been added and is categorized as a deviation.

CNS implementing procedures do not include this task for the Assistant EC as the scope of that position did not warrant this activity. The assistant EC is the TSC manager, who manages the preparation for facility activation. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. Revision 0 Attachment 3 Assistant Emergency Coordinator Old Responsibility (tas CNS TSC ERO Position Comparison and Evaluation Support determination of site response priorities AD-EP-ALL-0105 Att 1 Step 2.2 Determine and d i rect the actions for mit i gation strategies and contingency plans AD-EP-ALL-0105 Att 1 Step 2.2 Coordinate between CR , OSC and TSC to set OSC T earn task priorities AD-EP-ALL-0105 Att 1 Step 2.2 DirecUsupport site assembly , accountability and search & rescue activities AD-EP-ALL-0105 Att 1 Step 3.1 Page 34 of 128 This task has been added and is categorized as a deviation.

CNS implementing procedures do not include this task for the Asssitant EC as the scope of that position did not warrant this activity. This change formally documents the task as a specific activity as the position is elevated to an assistant EC role. This change i s evaluated as no reduction. This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation. CNS implementing procedures do not specifically reference event prioritization tasks for positions other than the EC. The assistant EC is the TSC manager , who now is involved in establishing and coordinating TSC priorities , allowing the EC to focus attention on directing the overall priorities for the site. This change is evaluated as no reduction. This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. Revision 0 Attachment 3 Assistant Emergency Coordinator Old Responsibility (tas CNS TSC ERO Position Comparison and Evaluation Assistant Emergency Coordinator New Responsibility (task Establish and maintain facility accountability AD-EP-ALL-0105 Att 1 Step 3.1 Coordinate site evacuation AD-EP-ALL-0105 Att 1 Step 3.2 Approve use of Kl AD-EP-ALL-0105 Att 1 Step 3.3 Approve offsite Protective Action Recommendations AD-EP-ALL-0105 Att 1 Step 2.1.2.a.2 Page 35 of 128 This task has been added and is categorized as a deviation.

CNS implementing procedures do not include this task for the Assistant EC as the scope of that position did not warrant this activity.

This change formally documents the task as a specific activity as the position is elevated to an assistant EC role. This change is evaluated as no reduction This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction. Revision 0 Attachment 3 Assistant Emergency Coordinator Old Responsibility (task) CNS TSC ERO Position Comparison and Evaluation Assistant Emergency Coordinator

@Mi;J*1+1 Mlfflhdiffl5 Approve emergency exposures AD-EP-ALL-0105 Att 1 Step 3.3 Ensure habitability is established and maintained for occupied areas AD-EP-ALL-0105 Att 1 Step 1.2.2 Terminate the emergency event AD-EP-ALL-0105 Att 1 Step 3._5 Develop recovery plans AD-EP-ALL-0105 Att 1 Step 3.5 Page 36 of 128 This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

This task has been added and is categorized as a deviation.

Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification.

One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Assistant Emergency Coordinator Old Responsibility (task) Prepare routine updates Maintain event logs, forms and records. Assistant Emergency Coordinator l~tMl3M+iehlffl6dHM@

Authorize and direct extreme measures (FLEX , EDMG , SAMG , §50.54(x) or security controls)

AD-EP-ALL-0105 Att 1 Step 3. 7 Conduct facility briefs and updates AD-EP-ALL-0105 Att 1 Step 2.1. 7 Provide input for facility briefs and updates AD-EP-ALL-0105 Att 1 Step 2.1. 7 Maintain event logs , forms and records AD-EP-ALL-0105 Att 1 Step 1.1.2 Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination.

AD-EP-ALL-0105 Att 1 Step 4.0 Page 37 of 128 This task has been added and is categorized as a deviation. CNS implementing procedures do not include this task for the Assistant EC as the scope of that position did not warrant this activity. This change formally documents the task as a specific activity as the position is elevated to an assistant EC role. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. This change is evaluated as no reduction. This task has been added and is categorized as a deviation. Standard ERO established the EC and Assistant EC as equivalent positions having a single qualification. One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Off-Site Agency Communicator (CNS/RP/O/A/5000/020 Enclosure 4.3) Offsite Communicator (AD-EP-ALL-0105 Attachment

2) Overall Change Impact to the Position Changes to the Offsite Communicator tasks were minor and primarily differences.

Deviations created by the modification of tasks to the Offsite Communicator position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 0 tasks were added, 6 were modified and 1 was removed. Off-Site Agency Communicator Old Responsibility Perform position turnover when a shift change occurs. Ensure off-site agency communicators in the EOF are aware of information affecting offsite agencies even after turnover has occurred Respond as directed when notified of an event (sign i n, get materials, etc.). Offsite Communicator New Responsibility (t Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 2 Step 2.4 Respond as directed when notified of an event (sign in , get materials , etc.) AD-EP-ALL-0105 Att 2 Step 1.1 Perform off-site notifications using ENF and comm I Perform offsite emergency notifications to state equipment and local author i ties AD-EP-ALL-0105 Att 2 Step 2.3 Page 38 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been removed and is categorized as a deviation.

The TSC Offsite Communicator performs offsite notifications when the EOF is not performing the task. Upon EOF activiation the EOF performs offsite notifications. The change is evaluated as no reduction. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision O Attachment 3 Off-Site Agency Communicator

[*itt*ilM+

11 Mlffldfliffi Provide the status of off-site agency notifications to the Emergency Coordinator and staff during TSC update briefings. Maintain event logs, forms and records. Offsite Communicator Distribute forms, reports, etc. as needed AD-EP-ALL-0105 Att 2 Step 2.1.6 Maintain event logs, forms and records AD-EP-ALL-0105 Att 2 Step 1.1 CNS TSC ERO Position Comparison and Evaluation This task has been modified for checklist use and is categorized as a deviation.

This task related to activities associated with both roles of the TSC Offsite Communicator.

First, to distribute completed notification forms to appropriate personnel when the EOF is not performing the task. Second, to distribute other materials as directed by the EC when the EOF is performing offsite notifications. The change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination.

AD-EP-ALL-0105 Att 2 Step 4.0 The steps for this task have been modified for checklist use , which is categorized as a difference.

Page 39 of 128 Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Logkeeper (CNS/RP/O/A/5000/020 Enclosure 4.12) Log Keeper (AD-EP-ALL-0105 Attachment

3) Overall Change Impact to the Position Changes to the Log Keeper tasks were minor and primarily differences.

Deviations created by the modification of tasks to the Log Keeper position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 1 task was added, 6 were modified and O were removed. Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Activate data displays in TSC Operate WebEOC Maintain event logs, forms and records. Log Keeper Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 3 Step 2.2 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 3 Step 1.1 Prepare for facility activation (rooms , work area, equipment, etc.) AD-EP-ALL-0105 Att 3 Step 1.2 Maintain status and information boards/displays AD-EP-ALL-0105 Att 3 Step 2.1 Maintain event logs, forms and records AD-EP-ALL-0105 Att 3 Step 1.1 Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination.

AD-EP-ALL-0105 Att 3 Step 4.0 Page 40 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: ICP Liaison (CNS/RP/O/B/5000/034&035 Enclosure 4.1) ICP Liaison (AD-EP-ALL-0105 Attachments 18, 19 and 20) Overall Change Impact to the Position Changes to the ICP Liaison tasks were minor and primarily differences.

No deviations were created by the addition or modification of tasks to the ICP Liaison position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison O tasks were added, 5 were modified and O were removed. ICP Liaison ICP Liaison Establish an ICP position log of activities sufficient Perform position turnover when a shift change enough to conduct a turnover for the on-coming occurs shift in an event AD-EP-ALL-0105 Att 18 19 & 20 Step 2.2 Respond as directed when notified of an event (sign in , get materials , etc.) Contact the ICP Commander and introduce yourself as the Catawba ICP Liaison. Establish an ICP position log of activities Restore work area equipment and materials Respond as directed when notified of an event (sign in , get materials , etc.) AD-EP-ALL-0105 Att 18 19 & 20 Step 1.1 Communicate with ICP to provide information and coordination AD-EP-ALL-0105 Att 18 19 & 20 Step 2.1 Maintain event logs , forms and records AD-EP-ALL-0105 Att 18 19 & 20 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0105 Att 18 19 & 20 Step 4.0 Page 41 of 128 The steps for this task have been modified for checklist use , which is categorized as a difference The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 Old Title: New Title: Emergency Planner (CNS/RP/O/A/5000/020 Enclosure 4.11) No Equivalent Position in Standard ERO Overall Change Impact to the Position Position not part of the standard ERO. CNS TSC ERO Position Comparison and Evaluation All tasks previously assigned to the Emergency Planner position are performed by various other standard ERO staff. Deviations created by the removal of the Emergency Planner position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 7 tasks are performed by other ERO positions.

Interface with NRC, state and county Establish secure comms during security-related events Establish and monitor communications on the EP bridge line. Assist with the development of offsite notifications Page 42 of 128 This task has been removed and is categorized as a deviation.

This task is performed by Assistant Emergency Coordinator position with regard to the NRC site team interface.

State and County personnel do not respond to the TSC. If they respond, they o to the EOF. This task has been removed and is categorized as a deviation. This task is performed by Security Coordinator Q_osition.

This task has been removed and is categorized as a deviation.

This change is result of the removal of the Emergency Planner position from the TSC hence no longer needing a bridge line. This chanQe is evaluated as no reduction.

This task has been removed and is categorized as a deviation. This task is performed by other positions within the TSC ERO (Ops Mgr and Asst Ops Mgr). Revision 0 Attachment 3 Support operation of the TSC Facilitate site evacuation Page 43 of 128 CNS TSC ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation.

This task is performed by other positions within the TSC ERO. This task has been removed and is categorized as a deviation. This task is performed by other positions within the TSC ERO. This task has been removed and is categorized as a deviation. This change maintains the capability to conduct a site evacuation because that capability is the responsibility of the Site Evacuation Coordinator. This chanQe is evaluated as no reduction. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: Engineering Manager (CNS/RP/O/A/5000/020 Enclosure 4.8) New Title: Engineering Manager (AD-EP-ALL-0105 Attachment

8) Overall Change Impact to the Position The span of control for this position has increased from 2 people to 3 people. The Engineering Manager responsibilities have been aligned to maintain oversight of emergency-related engineering tasks, and its staff increased to accommodate all the Engineering disciplines and the re-alignment of responsibilities.

Deviations created by the addition, removal or modification of tasks to the Engineering Manager position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 6 tasks were added, 9 were modified and O were removed. Perform position turnover when a shift change occurs. Complete the "Engineering 24 Hour TSC Essential Staffing List." Manage overall site engineering effort and ensure adequate levels of engineering resources are available to support the TSC and OSC. Respond as directed when notified of an event (sign in, get materials, etc.). Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 8 Step 2.2 Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list AD-EP-ALL-0105 Att 8 Step 2.1.3 Manage assigned group emergency response activities AD-EP-ALL-0105 Att 8 Step 2._1 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 8 Step 1.1 Page 44 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 Complete actions for facility activation CNS TSC ERO Position Comparison and Evaluation Develop requests and coordinate external assistance (technical, craft, admin, etc.) AD-EP-ALL-0105 Att 8 Step 2.1.3 Arrange for equipment and supply resources AD-EP-ALL-0105 Att 8 Step 2.1.3 Monitor status and information boards/displays/systems AD-EP-ALL-0105 Att 8 Step 2.1.6 Prepare for facility activation (rooms, work area, equipment, etc.) AD-EP-ALL-0105 Att 8 Step 1.2 Page 45 of 128 This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Engineering Manager does evaluate and coordinate external resources for their area. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Engineering Manager does evaluate and obtain additional resources for their area. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Engineering Manager does monitor plant status in the execution of assessment related functions.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 Engineering Manager Id Responsibility (t Assess plant conditions and advise TSC EC of potential challenges Provide the status of the following items to the Emergency Coordinator staff during update briefings.

CNS TSC ERO Position Comparison and Evaluation Engineering Manager i~@idM+i,MlfflHdD Perform event detection and assessment activities AD-EP-ALL-0105 Att 8 Step 2.1 Support determination of site response priorities AD-EP-ALL-0105 Att 8 Step 2 .. 1 Support development of mitigation strategies and contingency plans AD-EP-ALL-0105 Att 8 Step 2.1. 7 Analyze and develop extreme measures actions (FLEX, EDMG , SAMG , §50.54(x))

AD-EP-ALL-0105 Att 8 Step 2.1 Provide input for facility briefs and updates AD-EP-ALL-0105 Att 8 Step 2.2.12 Page 46 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Engineering Manager does assist with establishing site priorities in the execution of development of mitigation strategies and contingency plans. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Engineering Manager does support development of mitigation strategies and contingency plans. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Previous procedures did not specifically reference extreme measures. This change documents the responsibilities for this position to provide better clarity and instruction.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 Engineering Manager [*,O*GM+ieMlfflddm Maintain event logs, forms and records. Engineering Manager New Responsibility (t Maintain event logs, forms and records AD-EP-ALL-0105 Att 8 Step 1.1 CNS TSC ERO Position Comparison and Evaluation The steps for this task have been modified for checklist use, which is categorized as a difference.

Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination.

AD-EP-ALL-0105 Att 8 Step 4.0 The steps for this task have been modified for checklist use, which is categorized as a difference. Page 47 of 128 Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: Reactor Engineer (CNS/RP/O/A/5000/020 Enclosure 4.9) New Title: Reactor Engineer (AD-EP-ALL-0105 Attachment

9) Overall Change Impact to the Position Changes to the Reactor Engineer tasks were minor and primarily differences.

Tasks added to the Reactor Engineer position involves current common undirected actions. Task removed was a non-RERP activity. Deviations created by the addition or modification of tasks to the Reactor Engineer position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 2 tasks were added, 8 were modified and 1 was removed. Reactor Engineer Id Responsibilit Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Complete actions for facility activation Reactor Engineer Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 9 Step 2.3 Respond as directed when notified of an event (sign i n , get materials , etc.) AD-EP-ALL-0105 Att 9 Step 1.1 Communicate on assigned communication line and provide i nformation to facility staff AD-EP-ALL-0105 Att 9 Step 2.1.1 Prepare for facility activation (rooms , work area , equipment , etc.) AD-EP-ALL-0105 Att 9 Step 1.2 Page 48 of 128 The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly include this task although the Reactor Engineer does maintain communications for core damage and effluent related information.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Reactor Engineer Ensure parameters that support core/spent fuel cooling are monitored , controlled, maintained, Communicate rx status to TSC staff Evaluate status of reactor and containment (core damage, ECCS status , margins , RPV status) Ensure control and accountability of Special Nuclear Materials. Maintain event logs, forms and records. Reactor Engineer @¥Jl;JM+ieMiffi6d 1 ttaa: Perform event detection and assessment activities AD-EP-ALL-0105 Att 9 Step 2.1 Monitor status and information boards/displays/systems AD-EP-ALL-0105 Att 9 Step 2.1.1 Support development of mitigation strategies and contingency plans AD-EP-ALL-0105 Att 9 Step 2.1.3 Provide analysis of core damage and fission product release potential AD-EP-ALL-0105 Att 9 Step 2.2 Maintain event logs , forms and records AD-EP-ALL-0105 Att 9 Step 1.1 Turn in logs/forms and restore area/materials upon/ Restore work area equipment and materials event termination.

AD-EP-ALL-0105 Att 9 Step 4.0 Page 49 of 128 This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly include this task although the Reactor Engineer does perform event detection and assessment activities. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been removed and is categorized as a deviation. This is a non-RERP task and therefore not included as a Standard ERO responibility.

However , the management of EHS related activities will remain. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Equipment

{Electrical)

Engineer {CNS/RP/O/A/5000/024 Enclosure 4.5) Electrical Engineer {AD-EP-ALL-0105 Attachment

10) Overall Change Impact to the Position This position was moved from the OSC to the TSC to consolidate the engineering function.

Tasks added to the Electrical Engineer position involves current common undirected actions. Tasks removed are performed by other standard ERO positions.

Deviations created by the addition of tasks to the Electrical Engineer position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 3 tasks were added, 5 were modified and 5 were removed. Coordinate Equipment Engineer shift rotation Coordinate augmentation of personnel and equipment.

Prepare for facility activation (rooms, work area , equipment, etc.) Perform position turnover when a shift change occurs. Electrical Engineer Prepare for facility activation (rooms , work area, equipment, etc.) AD-EP-ALL-0105 Att 10 Step 1.1 Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 10 Step 2.2 Page 50 of 128 This task has been removed and is categorized as a deviation.

The capability to coordinate the shift rotation of the Engineer staff is maintained by the Engineering Manager. It is that positions responsibility to centrally manage the shift rotation of the Engineering staff in the TSC, which sustains the capability. This change is evaluated as no reduction. This task has been removed and is categorized as a deviation. The capability to augment personnel and equipment is maintained by the Engineering Manager. It is that positions responsibility to centrally manage that function in the TSC, which sustains the capability.

This change is evaluated as no reduction. The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference.

Revision 0 Attachment 3 Equipment (Electrical)

Engineer Old Responsi Respond as directed when notified of an event (sign in, get materials, etc.). CNS TSC ERO Position Comparison and Evaluation Electrical Engineer Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 10 Step 1.1 Monitor status and information boards/displays/systems AD-EP-ALL-0105 Att 10 Step 2.1 Perform event detection and assessment activities AD-EP-ALL-0105 Att 10 Step 2.1 Support development of mitigation strategies and contingency plans AD-EP-ALL-0105 Att 10 Step 2.1 Page 51 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Electrical Engineer does monitor information systems. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Electrical Engineer does perform event detection and assessment activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Electrical Engineer does support development of mitigation strategies and contingency plans. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

Revision O Attachment 3 CNS TSC ERO Position Comparison and Evaluation Brief and debrief engineering teams and maintain updates of plant conditions Implement accountability requirements Inform the OSC RP Manager of any locations outside the OSC or TSC where Engineering personnel are located following a site evacuation Maintain event logs, forms and records. Electrical Engineer Maintain event logs, forms and records AD-EP-ALL-0105 Att 10 Step 1.1 Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination.

AD-EP-ALL-0105 Att 10 Step 4.0 Page 52 of 128 This task has been removed and is categorized as a deviation.

The capability to brief engineering teams and update them on plant conditions is maintained by the Engineering Manager. It is that positions responsibility to centrally manage these functions for the Engineering staff in the TSC, which sustains the capability. This change is evaluated as no reduction. This task has been removed and is categorized as a deviation.

The capability to implement accountability for the TSC is maintained by the Assistant Emergency Coordinator.

It is that positions responsibility to establish and maintain accountability for staff in the TSC, which sustains the capability. This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation.

The capability to track engineering personnel is maintained by the Assistant Emergency Coordinator and Engineering Manager. It is those positions responsibility to track Engineering staff in the TSC, which sustains the capability.

This change is evaluated as no reduction. The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Systems Support Engineer (CNS/RP/O/A/5000/020 Enclosure 4.10) Mechanical Engineer (AD-EP-ALL-0105 Attachment

11) Overall Change Impact to the Position Changes to the Mechanical Engineer tasks were minor and primarily differences.

Task added to the Mechanical Engineer position involves current common undirected actions. Task removed is performed by other standard ERO positions.

Deviations created by the addition or modification of tasks to the Mechanical Engineer position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 1 task was added, 7 were modified and 1 was removed. Communicate information to TSC staff Complete actions for facility activation Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Mechanical Engineer WMidM*MeMlfflHdJffi@

Prepare for facility activation (rooms, work area, equipment, etc.) AD-EP-ALL-0105 Att 11 Step 1.1 Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 11 Step 2.2 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 11 Step 1.1 Page 53 of 128 This task has been removed and is categorized as a deviation. The capability to communicate various information to the TSC staff rests with the Engineering Manager. It is that positions responsibility to centrally manage the flow of information to and from the TSC engineering group, which sustains the capability.

This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Mechanical Engineer New Responsib Monitor status and information boards/displays/systems AD-EP-ALL-0105 Att 11 Step 2.1 Provide status of primary and secondary systems, I Perform event detection and assessment electrical systems and containment status activities Advise TSC Engineering Manager on current systems status and accident mitigation strategies. Maintain event logs, forms and records. AD-EP-ALL-0105 Att 11 Step 2.1 Support development of mitigation strategies and contingency plans AD-EP-ALL-0105 Att 11 Step 2.1 Maintain event logs , forms and records AD-EP-ALL-0105 Att 11 Step 1.1 Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination.

AD-EP-ALL-0105 Att 11 Step 4.0 Page 54 of 128 This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Mechanical Engineer does monitor information systems. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Operations Superintendent

{CNS/RP/O/A/5000/020 Enclosure 4.5) Operations Manager {AD-EP-ALL-0105 Attachment

12) Overall Change Impact to the Position There are no changes to the span of control to this position however there is a realignment of the subordinate ops related communicators.

Deviations created by the addition, removal or modification of tasks to the Operations Manager position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 4 tasks were added, 14 were modified and O were removed. Operations Superintendent Old Responsi Perform position turnover when a shift change occurs. Provide technical expertise regarding solutions to operational problems to the TSC, Control Room, OSC and other members of the ERO as required. Advise Emergency Coordinator on the anticipated course of the event. Respond as directed when notified of an event (sign in, get materials, etc.). Ensure each operating shift is staffed with adequate personnel to support all emergency situations, augmenting with additional resources as necessary.

Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 12 Step 2.4 Monitor status of the Emergency Operations Procedures AD-EP-ALL-0105 Att 12 Step 2.1.1 & 2.1.3 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 12 Step 1.1 Develop requests and coordinate external assistance (technical, craft, admin, etc.) AD-EP-ALL-0105 Att 12 Step 1.2.3 Arrange for equipment and supply resources AD-EP-ALL-0105 Att 12 Step 1.2.3 Page 55 of 128 The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

The role of the Operations Manager is expanded in the standard ERO to include assisting the EC in identifying and obtaining and ops related equipment and supply resources.

This change is evaluated as an improvement.

Revision 0 Attachment 3 Operations Superintendent Old Responsibility (task Assist in making decisions on emergency classifications , mitigation strategies, and contingency plans. Assist the TSC Off-Site Agency Communicators in completion of the Emergency Notification Forms Assist in making decisions on emergency classifications, mitigation strategies, and contingency plans. Evaluate and prioritize requests for information from the TSC staff, EOF staff, NRC and others. Provide technical expertise regarding solutions to operational problems to the TSC, Control Room, OSC and other members of the ERO as required.

CNS TSC ERO Position Comparison and Evaluation Assist with emergency classifiQation AD-EP-ALL-0105 Att 12 Step 2.2 Support completion of the ENF to state and local authorities AD-EP-ALL-0105 Att 12 Step 2.1.1 Monitor status and information boards/displays/systems AD-EP-ALL-0105 Att 12 Step 2.1.3 Manage assigned group emergency response activities AD-EP-ALL-0105 Att 12 Step 1.2 & 2.1 Support determination of site response priorities AD-EP-ALL-0105 Att 12 Step 2.1.5 Support development of mitigation strategies and contingency plans AD-EP-ALL-0105 Att 12 Step 2.1.5 Perform event detection and assessment activities AD-EP-ALL-0105 Att 12 Step 2.1.3 Page 56 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation. Previous procedures did not specifically define the process for monitoring facility displays.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task for the Operations Manager, although that position was responsible for supervision of subordinates. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Operations Superintendent Old Responsi Establish communications with the Control Room, Coordinate between CR, OSC and TSC to set OSC and EOF with the wireless phone/headset OSC Team task priorities via the OPS bridge line. AD-EP-ALL-0105 Att 12 Step 2.1.5 Establish direct communications with SM for the following conditions

A. During all 1 OCFR50.54x discussions. Provide the status of the following items as applicable to the Emergency Coordinator staff duringupdate briefings. Maintain event logs , forms and records Analyze and develop extreme measures actions (FLEX , EDMG , SAMG , §50.54(x)) AD-EP-ALL-0105 Att 12 Step 3.2 Evaluate conditions and develop offsite Protective Action Recommendations AD-EP-ALL-0105 Att 12 Step 2.2 Provide input for facility briefs and updates AD-EP-ALL-0105 Att 12 Step 2.1.9 Maintain event logs , forms and records AD-EP-ALL-0105 Att 1 2 Step 1.1 Turn i n logs/forms and restore area/materials upon I Restore work area equipment and materials event termination. AD-EP-ALL-0105 Att 12 Step 4.0 Page 57 of 128 This task has been modified and is categorized as a deviation. This task wording is modified to explicitly include this task for the Operations Manager. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. This change is evaluated as no reduction The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation.

The role of the Operations Manager is expanded i n the standard ERO to include assisting the EC with the identification of appropriate plant based PARs when the EOF is not available.

This change is evaluated as no reduction. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Operations Engineer (CNS/RP/O/A/5000/020 Enclosure 4.6) Assistant Operations Manager (AD-EP-ALL-0105 Attachment

13) Overall Change Impact to the Position Changes to the Assistant Operations Manager tasks were minor and mostly associated with providing clearer definition of the position in an operations communications role and support of the Operations Manager. Tasks were altered to minimize potential overburden and overlap of actions. Deviations created by the addition, removal or modification of tasks to the Assistant Operations Manager position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 6 tasks were added, 7 were modified and 4 were removed. Perform position turnover when a shift change occurs. Consult the EOF for possible solutions if procedural adequacy becomes a concern. Follow Response Procedures (RPs) and ensure completion of appropriate steps. Respond as directed when notified of an event (sign in, get materials , etc.). Verify that the TSC ventilation system is operable (capable of operating in filter mode). Perform recommendations to TSC Ops Superintendent on emergency classifications Assistant Operations Manager New Responsibility (task Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 13 Step 2.3 Monitor status of the Emergency Operations Procedures AD-EP-ALL-0105 Att 13 Step 2.1.1 Respond as directed when notified of an event (sign in, get materials , etc.) AD-EP-ALL-0105 Att 13 Step 21.1 Assist with emergency classification AD-EP-ALL-0105 Att 13 Step 2.2 Page 58 of 128 The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference.

This task has been removed and is categorized as a deviation. This task is performed by TSC Dose Assessor in the standard ERO. This change is evaluated as no reduction. The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 Provide information to Off-site Agency Communicator and the NRC Communicator as requested regarding changes in plant conditions and protective action recommendations Establish communications with the Control Room , OSC and EOF with the wireless phone/headset via the OPS bridge line. CNS TSC ERO Position Comparison and Evaluation Assistant Operations Manager iN¥'13M+iMlfflffdiffi~

Communicate on assigned communication li ne and provide information to facility staff AD-EP-ALL-0105 Att 13 Step 1.2.2 Monitor status and information boards/displays/systems AD-EP-ALL-0105 Att 13 Step 2.1.2 & 2.2.1 Maintain status and information boards/displays AD-EP-ALL-0105 Att 13 Step 2.1.2 Page 59 of 128 This task has been removed and is categorized as a deviation. This task is performed by Ops Manager in the standard ERO. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly i nclude this task although the Assistant Operations Manager does monitor plant status in the execution of assessment related functions. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly include this task although the Assistant Operations Manager does maintain status boards and displays in the execution of assessment related functions.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement Revision 0 Attachment 3 Serve as Lead Evaluators for Severe Accident Management guidelines CNS TSC ERO Position Comparison and Evaluation Assistant Operations Manager I.till ,.J.IQ .0.: .IS I !4i fti, Support development of mitigation strategies and contingency plans AD-EP-ALL-0105 Att 13 Step 2.1.3 Perform event detection and assessment activities AD-EP-ALL-0105 Att 13 Step 2.1.2 Coordinate between CR, OSC and TSC to set OSC Team task priorities AD-EP-ALL-0105 Att 13 Step 2.1.3 Page 60 of 128 This task has been added and is categorized as a deviation.

The Assistant Ops Manager will support development of mitigation strategies and contingency plans by support of the Ops Manager. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

The Assistant Ops Manager will support event detection and assessment by support of the Ops Manager. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

The Assistant Ops Manager will support setting OSC Team prioirites by support of the Ops Manager. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been removed and is categorized as a deviation.

This task is overseen by Ops Manager in the standard ERO. This change is evaluated as no reduction.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Perform recommendations to TSC Ops Superintendent on protective actions Maintain event logs, forms and records. Assistant Operations Manager New Responsibility (task Provide input for facility briefs and updates AD-EP-ALL-0105 Att 13 Step 2.2.2 Maintain event logs, forms and records AD-EP-ALL-0105 Att 13 Step 1.1 Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination.

AD-EP-ALL-0105 Att 13 Step 4.0 Page 61 of 128 This task has been removed and is categorized as a deviation.

This task is performed by Ops Manager in the standard ERO. This change is evaluated as no reduction.

This task has been added and is categorized as a deviation. CNS implementing procedures do not include this task for the Assistant Operations Manager as all positions could be called upon to provide input during a briefing.

Positions that have this task specifically called out are expected to contribute during all or most briefings. This change is evaluated as no reduction The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: NRC Communicator (CNS/RP/O/A/5000/020 Enclosure 4.4) NRC Communicator (AD-EP-ALL-0105 Attachment

14) Overall Change Impact to the Position Changes to the NRC Communicator tasks were minor and primarily differences.

Deviations created by the addition of tasks to the NRC Communicator position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 2 tasks were added, 5 was modified and O were removed. NRC Communicator Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Perform NRC notifications and communications NRC Communicator Perform position turnover when a shift change occurs AO-EP-ALL-0105 Att 14 Step 2.3 Respond as directed when notified of an event (sign in, get materials, etc.) AO-EP-ALL-0105 Att 14 Step 1.1 Provide event data and plant information to the NRC via the ENS AO-EP-ALL-0105 Att 14 Step 2.1 Activate EROS or confirm EROS operation AO-EP-ALL-0105 Att 14 Step 1.2.1 Page 62 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation. This task was previously performed by IT Support. The IT Support position is not under a response time requirement and has a job focus of addressing computer issues. This task has been moved to a minimum staffing response position to ensure EROS is operating properly.

This change is evaluated as no reduction. Revision 0 Attachment 3 NRC Communicator Maintain event logs, forms and records NRC Communicator Monitor status and information boards/displays/systems AD-EP-ALL-0105 Att 14 Step 2.1 Mainta i n event logs , forms and records AD-EP-ALL-0105 Att 14 Step 1.1 CNS TSC ERO Position Comparison and Evaluation This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly include this task, although it was performed to facilitate NRC communications.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change i s evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference. Turn i n logs/forms and restore area/materials upon/ Restore work area equipment and materials event termination. AD-EP-ALL-0105 Att 14 Step 4.0 The steps for this task have been modified for checklist use, which is categorized as a difference. Page 63 of 128 Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: CR/TSC Communicator

{CNE406) New Title: Control Room OPs Bridge {AD-EP-ALL-0105 Attachment

15) Overall Change Impact to the Position Changes to the Control Room OPs Bridge tasks were minor and primarily differences.

Tasks added to the Control Room OPs Bridge position involve current common undirected actions. Deviations created by the addition of tasks to the Control Room OPs Bridge position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 3 tasks were added, 5 was modified and O were removed. CR/TSC Communicator Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 15 Step 2.2 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 15 Step 1.1 Establish communications with the TSC , OSC and Communicate on assigned communication lin e EOF with the wireless and provide information to facility staff phone/headset via the OPS bridge line. AD-EP-ALL-0105 Att 15 Step 1.2 Communicate the activities of Ops personnel dispatched out of the CR to the OSC AD-EP-ALL-0105 Att 15 Step 2.1 Page 64 of 128 The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly include this task although the CR Ops Bridge does communicate with the OSC. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation CR/TSC Communicator Maintain event logs, forms and records. Control Room OPs Bridge New Respons Support development of mitigation strategies and contingency plans AD-EP-ALL-0105 Att 15 Step 2.1 Perform event detection and assessment activities AD-EP-ALL-0105 Att 15 Step 2.1 Maintain event logs, forms and records AD-EP-ALL-0105 Att 15 Step 1.1 Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination.

AD-EP-ALL-0105 Att 15 Step 4.0 Page 65 of 128 This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly include this task although the CR Ops Bridge does support the development of mitigation strategies and contingency plans. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly include this task although the CR Ops Bridge does perform event detection and assessment activities. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Radiation Protection Manager (CNS/RP/O/A/5000/020, Enclosure 4.14) Radiation Protection Manager (AD-EP-ALL-0105 Attachment

16) Overall Change Impact to the Position There is no change to the span of control for this position.

The Radiation Protection Manager position now has direct responsibility for TSC dose assessment when the EOF is unavailable.

Changes to the Radiation Protection Manager tasks were minor and primarily differences.

Deviations created by the addition, removal and modification of tasks to the Radiation Protection Manager position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 6 tasks were added, 18 were modified and 2 were removed. Radiation Protection Manager Old Responsibility (task Coordinate RP shift rotation Perform position turnover when a shift change occurs. Radiation Protection Manager ISl.thl~J.i&.0.1.:SIMRM,M.Y Perform pos i tion turnover when a shift change occurs AD-EP-ALL-0105 Att 16 Step 2.3 Page 66 of 128 This task has been removed and is categorized as a deviation.

The capability to coordinate the shift rotation of RP technicians is maintained by the RP Supervisor in the OSC. It is that positions responsibility to centrally manage the shift rotation of the RP Technicians to support all RP operations, which sustains the capability.

This change is evaluated as no reduction. The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 Radiation Protection Manager Id Responsibility (tas Verify that RP Supervisor has provided forms activities in progress in the field Respond as directed when notified of an event (sign in, get materials, etc.). CNS TSC ERO Position Comparison and Evaluation Radiation Protection Manager New Responsibility (task Manage assigned group emergency response activities AD-EP-ALL-0105 Att 16 Step 2.2 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 16 Step 1.1 Develop requests and coordinate external assistance (technical, craft, admin, etc.) AD-EP-ALL-0105 Att 16 Step 2.1 Arrange for equipment and supply resources AD-EP-ALL-0105 Att 16 Step 2.1 Page 67 of 128 This task have been modified and is categorized as a deviation.

The steps for this task has been modified since CNS implementing procedures do not explicitly include this step for the RP Manager, although it was performed under the broader task of managing the RP activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the RP Manager does develop requests for and coordinate external assistance.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the RP Manager does evaluate and obtain additional resources for their area. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

Revision 0 Attachment 3 Radiation Protection Manager Old Responsi Review RP/O/A/5000/001 (Classification of Emergency) criteria (EMFs, offsite dose, etc.) for emergency classification changes and discuss with OPS Procedure Support position. Prepare for participating in the ENF review Establish communications with RP personnel in the OSC , Shift Lab , and EOF using cell phone , Evaluate specific plant conditions , offsite dose projections , field monitoring team data , IF AT ANY TIME conditions degrade where contamination CANNOT be contained within the RCA , establish contamination control in the TSC , OSC , and Control Room CNS TSC ERO Position Comparison and Evaluation Radiation Protection Manager 1~tMid+1+ieMlffl6diffiN Assist with emergency classification AD-EP-ALL-0105 Att 16 Step 3.4 Support completion of the ENF to state and local authoritie s AD-EP-ALL-0105 Att 16 Step 2.1.10 & 3.4 Maintain status and information boards/displays AD-EP-ALL-0105 Att 16 Step 2.1.1 Perform event detection and assessment activities AD-EP-ALL-0105 Att 16 Step 2.1.1 Monitor , evaluate and communicate conditions involving any release of radioactivity AD-EP-ALL-0105 Att 16 Step 2.1.1 Direct/perform dose assessment AD-EP-ALL-0105 Att 16 Step 2.1.5 Page 68 of 128 The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a dev i at i on. CNS implementing procedures do not explicitly i nclude this task for the RP Manager, although it was performed under the broader task of managing the RP activities. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

This task has been removed and is categorized as a deviation. The bridge line Is assigned to the Dose Assessor i n the standard TSC ERO. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference.

This task has been added and is categorized as a deviation.

The dose assessment process has been explicitly included in the TSC in the event that the corporate EOF is unavailable. This change is evaluated as no reduction. Revision 0 Attachment 3 Radiation Protection Manager Id Responsibility (task Coordinate communications with TSC Dose Assessor or EOF Field Monitoring Coordinator regarding onsite survey teams IF a release is occurring, evaluate the need to:

Move any assembly points in the release path IF a release is occurring, evaluate the need to:

Conduct site relocation or evacuation. Evaluate the need to administer Potassium Iodide to emergency workers on site and to Field Monitoring teams Review dose projections to determine if Protective Action Recommendations for Kl are required for the General Public. Evaluate specific plant conditions, offsite dose projections, field monitoring team data, and assess need to update Protective Action Recommendations Track exposure and authorize emergency doses above normal occupational exposure or exceed dose extension limits Ensure that personnel monitoring is performed in OSC, TSC and Control Room Initiate contamination control requirements CNS TSC ERO Position Comparison and Evaluation Radiation Protection Manager New Responsi Brief and dispatch the onsite/offsite radiation monitoring teams AD-EP-ALL-0105 Att 16 Step 2.2.1 Provide support and logistics for site assembly activities AD-EP-ALL-0105 Att 16 Step 3.3 Provide support and logistics for site evacuation activities AD-EP-ALL-0105 Att 16 Step 3.3 Evaluate the need for and ensure proper use of Kl AD-EP-ALL-0105 Att 16 Step 3.1 This task has been removed and is categorized as a deviation. The capability to coordinate Field Monitoring Team communications is maintained by the RP Supervisor in the OSC or the Dose Assessor in the TSC. This sustains the capability to direct field monitoring teams. This change is evaluated as no reduction. This task has been added and is categorized as a deviation. The TSC will now perform the initial briefing and then turn the FMT over to the EOF. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. Evaluate conditions and develop offsite Protective The steps for this task have been modified for Action Recommendations checklist use, which is categorized as a AD-EP-ALL-0105 Att 16 Step 3.4 difference.

Ensure approved emergency exposure controls are issued AD-EP-ALL-0105 Att 16 Step 3.1 Direct personnel monitoring and decontamination activities AD-EP-ALL-0105 Att 16 Step 3.2 Establish contamination controls for occupied areas AD-EP-ALL-0105 Att 16 Step 3.2 Page 69 of 128 The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Radiation Protection Manager Old Responsibility (task Radiation Protection Manager 1~t4i;J4-1+

1 Mlffl6dittffi IF a release occurs after the TSC and OSC Ensure habitability is established and maintained personnel were previously permitted to eat and for occupied areas drink in their facilities.suspend eating and drinking AD-EP-ALL-0105 Att 16 Step 3.2 Maintain event logs, forms and records. Support MERT activities AD-EP-ALL-0105 Att 16 Step 2.2 Provide input for facility briefs and updates AD-EP-ALL-0105 Att 16 Step 2.1.12 Maintain event logs, forms and records AD-EP-ALL-0105 Att 16 Step 1.1 Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination.

AD-EP-ALL-0105 Att 16 Step 4.0 Page 70 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task for the RP Manager, although it was performed under the broader task of managing the RP activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not include this task for the RP Manager as all positions could be called upon to provide input during a briefing.

Positions that have this task specifically called out are expected to contribute during all or most briefings.

This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Off-Site Dose Assessor (CNS/RP/O/A/5000/020, Enclosure 4.2) Dose Assessor (AD-EP-ALL-0105 Attachment

18) Overall Change Impact to the Position Changes to the Dose Assessor tasks were minor and primarily differences.

Tasks added to the Dose Assessor position involve current common undirected administrative actions, communications and monitoring activities as well as tasks to be performd in the event the EOF unavailable.

Deviations created by the addition of tasks to the Dose Assessor position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 3 tasks were added, 12 were modified and 1 was removed. Off-Site Dose Assessor Perform position turnover when a shift change occurs. Manage Dose Assessment staff in the TSC Respond as directed when notified of an event (sign in, get materials, etc.). Evaluate the Emergency Action Levels (EALs) based on radiological conditions using Dose Assessment Dose Assessor Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 17 Step 2.4 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 17 Step 1.1 Assist with emergency classification AD-EP-ALL-0105 Att 17 Step 2.1 and AD-EP-ALL-0202 Communicate on assigned communication line and provide information to facility staff AD-EP-ALL-0105 Att 17 Step 1.2 Page 71 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been removed and is categorized as a deviation.

This task is performed by the RP Manager in the TSC. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

Under the standard ERO the Dose Assessor also monitors the RP bridge to obtain RP related information directly from the site. This change is evaluated as an improvement.

Revision 0 Attachment 3 Off-Site Dose Assessor Inform the NRC of rad conditions and recommended protective actions Complete actions for facility activation Inform the emergency facilities of rad conditions Calculate, assess and review off-site dose inputs and projections Establish communications with EOF Dose Assessment Team and, if applicable, the EOF Field Monitoring Coordinator (FMC). CNS TSC ERO Position Comparison and Evaluation Dose Assessor Provide event data and plant information to the NRC via the HPN AD-EP-ALL-0105 Att 17 Step 3.1 Prepare for facility activation (rooms, work area, equipment , etc.) AD-EP-ALL-0105 Att 17 Step 1.2 Monitor status and information boards/displays/systems AD-EP-ALL-0105 Att 17 Step 2.1.2 Maintain status and information boards/displays AD-EP-ALL-0105 Att 17 Step 2.1 Monitor , evaluate and communicate conditions involving any release of radioactivity AD-EP-ALL-0105 Att 17 Step 2.1.4 Direct/perform dose assessment AD-EP-ALL-0105 Att 17 Step 2.2 Direct field monitoring team activities AD-EP-ALL-0105 Att 17 Step 3.2 Page 72 of 128 The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Dose Assessor does monitor indications in order to perform dose assessment.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly include this task although the Dose Assessor does maintain status boards and displays in the execution of assessment related functions.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Off-Site Dose Assessor Assess, develop and recommend protective actions Maintain oversight of TSC habitability systems, controls and conditions Maintain event logs , forms and records. Dose Assessor Evaluate conditions and develop offsite Protective Action Recommendations AD-EP-ALL-0105 Att 17 Step 2.2.4 Establish facility ventilation and monitoring for habitability controls AD-EP-ALL-0105 Att 17 Step 1.2.4 & 5 Maintain event logs, forms and records AD-EP-ALL-0105 Att 17 Step 1.1 Turn in logs/forms and restore area/materials upon j Restore work area equipment and materials event termination. AD-EP-ALL-0105 Att 17 Step 4.0 Page 73 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Security/HR Manager (CNS/RP/O/A/5000/020, Enclosure 4.15) Security Coordinator (AD-EP-ALL-0105 Attachment

4) Overall Change Impact to the Position The span of control for this position does not change. Tasks added to the Security Coordinator position involve current common undirected actions, specifying tasks previously implied under more generalized task wording, and participation in OSC dispatch as it applies to security personnel.

Deviations created by the addition of tasks to the Security Coordinator position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 10 tasks were added, 10 were modified and O were removed. Security/HR Manager Old Responsibility (t Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Security Coordinator New Responsibility ( Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 4 Step 2.2 Manage assigned group emergency response activities AD-EP-ALL-0105 Att 4 Step 2.1 Respond as directed when notified of an event (sign in , get materials, etc.) AD-EP-ALL-0105 Att 4 Step 1.1 Page 74 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation. Previous procedures did not explicitly state the task to manage and coordinate with the site security force. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Security Coordinator New Responsi Request and coordinate emergency activities with law enforcement agencies AD-EP-ALL-0105 Att 4 Step 2.1.2 Develop requests and coordinate external assistance (technical, craft, admin , etc.) AD-EP-ALL-0105 Att 4 Step 1.2.2 Arrange for equipment and supply resources AD-EP-ALL-0105 Att 4 Step 1.2.2 Page 75 of 128 This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly state the task to request and coordinate with the LLEAs. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly include this task although the Security Coordinator does evaluate and obtain additional resources for their area -including LLEA. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Security Coordinator does evaluate and obtain additional resources for their area. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

Revision 0 Attachment 3 Complete actions for facility activation CNS TSC ERO Position Comparison and Evaluation Security Coordinator New Responsibility ( Communicate with ICP to provide information and This task has been added and is categorized as coordination a deviation.

AD-EP-ALL-0105 Att 4 Step 2.1.2 Previous CNS procedures included this task for the EC to communicate directly with the IC. Although the EC, as the individual responsible for the site response, will ensure the necessary resources and support will be provided to the ICP, direct communications was transferred to the Security Coordinator.

This change assigns this task to the appropriate individual and alleviates the EC from direct communications.

Provide security related information to the NRG AD-EP-ALL-0105 Att 4 Step 1.2.2 Prepare for facility activation (rooms, work area, equipment, etc.) AD-EP-ALL-0105 Att 4 Step 1.2 Participate with OSC Team dispatch and control AD-EP-ALL-0105 Att 4 Step 2.1.1, 2.1.4 & 2.1.9 Page 76 of 128 This change is evaluated as an improvement.

This task has been added to the Security Manager procedure.

This task was previously performed by the Emeregncy Planner position.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

For Security events or search and rescue missions Security personnel will be dispatched with OSC Teams. This change ensures that the Security Coordinator position will be made aware of process to control OSC teams. This change is evaluated as an improvement.

Revision 0 Attachment 3 Provide the TSC Emergency Planner with the names of essential personnel associated with your position that would not leave the site should a site evacuation be necessary. Perform actions associated with accountability Perform actions associated with evacuation Coordinate with the OSC Radiation Protection Manager to control security officer dose in the field. CNS TSC ERO Position Comparison and Evaluation Security Coordinator New Responsi Coordinate security activities AD-EP-ALL-0105 Att 4 Step 2.*1 Establish and maintain accountability for security personnel AD-EP-ALL-0105 Att 4 Step 2.1.3 & 3.1 Direct/support site assembly, accountability and search & rescue activities AD-EP-ALL-0105 Att 4 Step 3.1 Provide support and logistics for site evacuation activities

AD-EP-ALL-0105 Att 4 Step 3.2 Direct site access controls activities AD-EP-ALL-0105 Att 4 Step 2.1.7 Ensure radiological conditions are known for occupied areas AD-EP-ALL-0105 Att 4 Step 2.1. Page 77 of 128 This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Security Coordinator does coordinate security activies as part of his responsibilities. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

This task has been modified and is categorized as a deviation. The procedure did contain some actions to execute this task. The new task builds on those actions by including additional actions coordinated with the overall Security Coordinator responsibilities.

This change is evaluated as no reduction The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation.

The procedure did contain some actions to execute this task. The new task builds on those actions by including additional actions coordinated with the overall Security Coordinator responsibilities. This change is evaluated as an improvement The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Perform actions associated with MERT support Maintain event logs, forms and records. Security Coordinator ISl.ll.ll~J.M.f.l.Ui!41RMf Support MERT activities AD-EP-ALL-0105 Att 4 Step 2.1. 7 Provide input for facility briefs and updates AD-EP-ALL-0105 Att 4 Step 2.1.10 Maintain event logs, forms and records AD-EP-ALL-0105 Att 4 Step 1.1 Turn in logs/forms and restore area/materials upon J Restore work area equipment and materials event termination. AD-EP-ALL-0105 Att 4 Step 4.0 Page 78 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation. CNS implementing procedures do not include this task for the Security Coordinator as all positions could be called upon to provide input during a briefing.

Positions that have this task specifically called out are expected to contribute during all or most briefings.

This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Evacuation Coordinator (CNS/RP/0/

A/5000/020, Enclosure 4.17) Site Evacuation Coordinator (AD-EP-ALL-0105 Attachment

5) Overall Change Impact to the Position Changes to the Site Evacuation Coordinator tasks were minor and primarily differences.

Task added to the Site Evacuation Coordinator position involve current common undirected administrative actions. Deviations created by the addition of tasks to the Site Evacuation Coordinator position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 1 task was added, 7 were modified and O were removed. Evacuation Coordinator Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Prepare for facility activation (rooms, work area, equipment, etc.). Establish TSC Accountability Log for persons leaving the TSC and their intended destination. Site Evacuation Coordinator Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 5 Step 2.3 Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list AD-EP-ALL-0105 Att 5 Step 1.3 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 5 Step 1.1 Prepare for facility activation (rooms , work area, equipment, etc.) AD-EP-ALL-0105 Att 5 Step 1.2 Establish and maintain facility accountability AD-EP-ALL-0105 Att 5 Step 1.2 Page 79 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation. The Site Evacuation Coordinator assists the EC Manager and Assistant ECG Manager with facility staffing as part of tracking personnel.

This process has been specifically defined in the standard ERO to include development of the list, which is not performed by the EC Manager This change is evaluated as no reduction. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 Evacuation Coordinator Perform logistical actions at evacuation site Maintain event logs, forms and records. Site Evacuation Coordinator Coordinate site evacuation AD-EP-ALL-0105 Att 5 Step 2.2 Maintain event logs, forms and records AD-EP-ALL-0105 Att 5 Step 1.1 CNS TSC ERO Position Comparison and Evaluation The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination.

AD-EP-ALL-0105 Att 5 Step 4.0 The steps for this task have been modified for checklist use, which is categorized as a difference.

Page 80 of 128 Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: No equivalent position in CNS ERO New Title: OAC Support (AD-EP-ALL-0105 Attachment

6) Overall Change Impact to the Position This standard position is new to the CNS ERO. Deviations created by the addition of the OAC Support position and its associated tasks did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 6 tasks added. OAC Support Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 6 Step 2.2 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 6 Step 1.1 Activate ERDS or confirm EROS operation AD-EP-ALL-0105 Att 6 Step 2.1.4 Page 81 of 128 This task has been added and is categorized as a deviation. It was previously an undirected administrative action now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

It was previously an undirected administrative action now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

OAC Support is expected to be able to troubleshoot ERDS equipment in conjunction with ERFIS. This change is evaluated as an improvement.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Monitor facility equipment (computer, communications , etc.) for proper operation AD-EP-ALL-0105 Att 6 Step 2.1.1 Maintain event logs, forms and records AD-EP-ALL-0105 Att 6 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0105 Att 6 Step 4.0 Page 82 of 128 This task has been added and is categorized as a deviation.

The addition of this task/position will assist in assuring efficient reponse actions. The change is evaluated as an improvement.

This task has been added and is categorized as a deviation. It was previously an undirected administrative action now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 3 CNS TSC ERO Position Comparison and Evaluation Old Title: New Title: Data Coordinator (CNS/RP/O/A/5000/020, Enclosure 4.13) IT Support (AD-EP-ALL-0105 Attachment

7) Overall Change Impact to the Position Changes to the IT Support tasks were differences.

Task added to the IT Support position involves current common undirected administrative actions. Deviations created by the addition of tasks to the IT Support position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 1 task was added, 5 was modified and 1 was removed. Data Coordinator Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Verify that TSC and OSC electronic equipment is operating properly Perform position turnover when a shift change occurs AD-EP-ALL-0105 Att 7 Step 1.1 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0105 Att 7 Step 1.1 Prepare for facility activation (rooms, work area, equipment, etc.) AD-EP-ALL-0105 Att 7 Step 1.2 Monitor facility equipment (computer, communications, etc.) for proper operation AD-EP-ALL-0105 Att 7 Step 2.1 Page 83 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

It was previously an undirected administrative action now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 Data Coordinator Verify proper operation of EROS Maintain event logs , forms and records. Maintain event logs , forms and records AO-EP-ALL-0105 Att 7 Step 1.1 CNS TSC ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation The IT Support position is not under a response time requirement and has a job focus of addressing computer issues. This task has been moved to a minimum staffing response position to ensure EROS is operating properly.

This change is evaluated as no reduction The steps for this task have been modified for checklist use, which is categorized as a difference. Turn in logs/forms and restore area/materials upon I Restore work area equipment and materials event termination. AO-EP-ALL-0105 Att 7 Step 4.0 The steps for this task have been modified for checklist use , which is categorized as a difference. Page 84 of 128 Revision 0 Attachment 3 Old Title: New Title: Assistant Operations Engineer (CNS/RP/O/A/5000/020 Enclosure 4.7) No equivalent position in standard ERO Overall Change Impact to the Position Position not part of the standard ERO. CNS TSC ERO Position Comparison and Evaluation All tasks previously assigned to the Assistant Operations Engineer position are performed by various other standard ERO positions.

Deviations created by the removal of the Assistant Operations Engineer position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 2 tasks are performed by other ERO positions.

Assistant Operations Engineer Old Responsibility (task Support CR and TSC with EOP and RP procedure execution Establish communications with the Control Room, OSC and EOF with the wireless phone/headset via the OPS bridge line. Page 85 of 128 This task has been removed and is categorized as a deviation.

The capability to support EOP and RP procedure execution is maintained by the Operations Manager, Assitant Operations Manager, Reactor Engineer, RP Manager and Dose Assessors, which sustains the capability.

This task has been removed and is categorized as a deviation.

The capability to support EOP and RP procedure execution is maintained by the Operations Manager, Assitant Operations Manager, Reactor Engineer, RP Manager and Dose Assessors, which sustains the capability. Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Old Title: New Title: OSC Coordinator (CNS/RP/0/5000/024 Enclosure 4.1) OSC Manager (AD-EP-ALL-0106 Attachment

1) Overall Change Impact to the Position The span of control for this position has been reduced from 8 to 7 positions, however the OSC Manager now has a dedicated assistant rather than it being staffed as needed. The OSC Manager and the Assistant OSC Manager are equally qualified and are interchangeable.

The Assistant OSC Manager typically acts as a OSC manager more in line with industry practices, which allows the OSC Manager greater attention on site response activities in all facilities (TSC, OSC and CR) and less attention on OSC operation and administration.Tasks added to the OSC Manager position involve common undirected administrative actions, specifying tasks previously implied under more generalized task wording, and control of OSC assembly and search & rescue actions. Deviations created by the addition and removal of tasks to the OSC Manager position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 8 tasks were added, 19 were modified and 2 were remov$d. OSC Coordinator Verify that the OSC Log/Status Keeper has obtained a completed 24-hour staffing/essential personnel form from each OSC Manager. During a Beyond Design Basis External Event (BDBEE) or an Extended Loss of AC Power (ELAP) event, work with the Emergency Coordinator and the Emergency Planner in the TSC to establish 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months coverage for an extended period (up to 10 days) using a combination of qualified CNS ERO personnel.

Verify that the OSC Log/Status Keeper has obtained a completed 24-hour staffing/essential personnel form from each OSC Manager OSC Manager New Respons Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list AD-EP-ALL-0106 Att 1 Step 1.2.10 Verify that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list has been completed AD-EP-ALL-0106 Att 1 Step 1.2.10 Page 86 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 4 OSC Coordinator Contact OSC Operations Supervisor and request turnover of command and control for the OSC Respond as directed when notified of an event (sign i n , get materials, etc.). Call out additional OSC support personnel as needed Call out additional OSC support personnel as needed Inform the TSC Emergency Coordinator of encountered plant conditions and status of emergency actions in progress.

Require positions submit completed minimum staffing level forms CNS OSC ERO Position Comparison and Evaluation OSC Manager Coordinate ERO/facility shift turnover AD-EP-ALL-0106 Att 1 Step 2.3 Perform pos i tion turnover when a shift change occurs AD-EP-ALL-0106 Att 1 Step 2.3 Manage facility emergency response activities AD-EP-ALL-0106 Att 1 Step 2.1 Respond as directed when notified of an event (sign in, get mater i als , etc.) AD-EP-ALL-0106 Att 1 Step 1.1 Develop requests and coordinate external assistance (technical , craft , admin , etc.) AD-EP-ALL-0106 Att 1 Step 2.1.6 Arrange for equipment and supply resources AD-EP-ALL-0106 Att 1 Step 2.1.6 Ensure flow of information within and between the emergency response facilities AD-EP-ALL-0106 Att 1 Step 2.1.2 Prepare for facility activation (rooms , work area , equipment , etc.)\ AD-EP-ALL-0106 Att 1 Step 1.2 Page 87 of 128 This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the OSC Manager does control when the facility conducts a shift turnover. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification. One individual assumes the station command and control functions and the other assumes the facility manager and assistant role. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use , which i s categorized as a difference. Revision 0 Attachment 4 OSC Coordinator Declare operational upon completion of all minimum staffing level forms Declare operational upon completion of all minimum staffing level forms Relocate to the Alternate OSC if OSC uninhabitable CNS OSC ERO Position Comparison and Evaluation OSC Manager Ensure minimum staff is available (facility staffed) /The steps for this task have been modified for AD-EP-ALL-0106 Att 1 Step 1.2 checklist use, which is categorized as a difference.

Determine current/projected staff needs AD-EP-ALL-0106 Att 1 Step 1.2 Ensure facility staff is prepared to perform their activities (facility ready) AD-EP-ALL-0106 Att 1 Step 1.2 Activate the facility (facility activated)

AD-EP-ALL-0106 Att 1 Step 1.2 Direct/coordinate facility relocation AD-EP-ALL-0106 Att 1 Step 3.3 Support facility relocation AD-EP-ALL-0106 Att 1 Step 3.3 Page 88 of 128 This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the OSC Manager has responsibility for the overall facility response activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the OSC Manager has responsibility for the overall facility response activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

Revision 0 Attachment 4 OSC Coordinator Ensure team activities are prioritized and in agreement with TSC established priorities.

Ensure team activities are prioritized and in agreement with TSC Coordinate Assessment and Repair Team dispatch and control. Evaluate the completed OSC Task Work Sheets collected by the OSC Log/Status Keeper to determine if any in-progress work should be discontinued.

Implement accountability requirements Announce when non-essential personnel are to be evacuated from the site CNS OSC ERO Position Comparison and Evaluation OSC Manager New Respon Support determination of site response priorities AD-EP-ALL-0106 Att 1 Step 2.1.5 Coordinate between CR, OSC and TSC to set OSC T earn task priorities AD-EP-ALL-0106 Att 1 Step 2.2. 7 Coordinate OSC Team dispatch and control AD-EP-ALL-0106 Att 1 Step 2.2 Participate with OSC Team dispatch and control AD-EP-ALL-0106 Att 1 Step 2.2 DirecUsupport site assembly , accountability and search & rescue activities AD-EP-ALL-0106 Att 1 Step 3.1 Establish and maintain facility accountability AD-EP-ALL-0106 Att 1 Step 3.1 Page 89 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

The procedure did contain some actions to execute this task. The new task builds on those actions by including additional actions coordinated with the overall OSC Manager's responsibilities. This change is evaluated as an improvement.

his task has been added and is categorized as a deviation.

The procedure did contain some actions to execute this task. The new task builds on those actions by including additional actions coordinated with the overall OSC Manager's responsibilities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been removed and is categorized as a deviation.

This change maintains the capability to conduct a site evacuation because that capability is the responsibility of the Site Evacuation Coordinator. Hence the capability is sustained.

This change is evaluated as no reduction. Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation OSC Coordinator Inform the TSC Emergency Coordinator if the RP Manager issues a Blanket Dose Extension for the event Ensure OSC habitability OSC Manager Ensure habitability is established and maintained for occupied areas AD-EP-ALL-0106 Att 1 Step 1.2.1.b, 2.1.4 Conduct a briefing and updates every 30-minutes J Conduct facility briefs and updates AD-EP-ALL-0106 Att 1 Step 2.1.1 Maintain event logs, forms and record Turn i n logs/forms and restore area/materials upon event termination. Provide input for facility briefs and updates AD-EP-ALL-0106 Att 1 Step 2.1.1 Maintain event logs, forms and records AD-EP-ALL-0106 Att 1 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0106 Att 1 Step 4.0 Page 90 of 128 This task has been removed and is categorized as a deviation.

The capability to authorize and utilize emergency dose limits is proceduralized in the Radiation Protection Managers procedure, and the specific emergency dose extension procedure.

This maintains the capability. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation. CNS implementing procedures do not include this task for the OSC Manager as all positions could be called upon to provide input during a briefing.

Positions that have this task specifically called out are expected to contribute during all or most briefings.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Old Title: No Equivalent Position in CNS ERO New Title: Assistant OSC Manager (AD-EP-ALL-0106 Attachment

1) Overall Change Impact to the Position This standard position is new to the CNS ERO. This positon does not have an organizational span of control. The OSC Manager and the Assistant OSC Manager are equally qualified and are interchangeable.

The Assistant OSC Manager typically acts as a OSC manager more in line with industry practices, which allows the OSC Manager greater attention on site response activities in all facilities (TSC, OSC and CR) and less attention on OSC operation and administration.

Deviations created by the addition of the Assistant OSC Manager position and its associated tasks did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 27 tasks added. Assistant OSC Manager ISi.ii.ii

~>.M .0.: .i& IM ftMti!+.!

Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list AD-EP-ALL-0106 Att 1 Step 1.2.10 Verify that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list has been completed AD-EP-ALL-0106 Att 1 Step 1.2.10 Page 91 of 128 This task has been added and is categorized as a deviation. Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement..

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Assistant OSC Manager * ~t4§1 ;JM +1 eh I ffl HdOffi Perform position turnover when a shift change occurs AD-EP-ALL-0106 Att 1 Step 2.3 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0106 Att 1 Step 1.1 Coordinate ERO/facility shift turnover AD-EP-ALL-0106 Att 1 Step 2.3 Manage facility emergency response activities AD-EP-ALL-0106 Att 1 Step 2.1 Page 92 of 128 This task has been added and is categorized as a deviation.

It was previously an undirected administrative action now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

It was previously an undirected administrative action now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Assistant OSC Manager ISl.ll.ll~J.M.1.4.MIMRM,M!!

Develop requests and coordinate external assistance (technical, craft, admin, etc.) AD-EP-ALL-0106 Att 1 Step 2.1.6 Arrange for equipment and supply resources AD-EP-ALL-0106 Att 1 Step 2.1.6 Ensure flow of information within and between the emergency response facilities AD-EP-ALL-0106 Att 1 Step 2.1.2 Prepare for facility activation (rooms, work area , equipment, etc.)\ AD-EP-ALL-0106 Att 1 Step 1.2 Page 93 of 128 This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. It was previously an undirected administrative action now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Assistant OSC Manager New Responsibility Ensure minimum staff is available (facility staffed) I This task has been added and is categorized as AD-EP-ALL-0106 Att 1 Step 1.2 a deviation.

Determine current/projected staff needs AD-EP-ALL-0106 Att 1 Step 1.2 Ensure facility staff is prepared to perform their activities (facility ready) AD-EP-ALL-0106 Att 1 Step 1.2 Activate the facility (facility activated)

AD-EP-ALL-0106 Att 1 Step 1.2 Page 94 of 128 Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement..

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Assistant OSC Manager New Responsibility (tas Direct/coordinate facility relocation AD-EP-ALL-0106 Att 1 Step 3.3 Support facility relocation AD-EP-ALL-0106 Att 1 Step 3.3 Support determination of site response priorities AD-EP-ALL-0106 Att 1 Step 2.1.5 Coordinate between CR, OSC and TSC to set OSC Team task priorities AD-EP-ALL-0106 Att 1 Step 2.2.7 Page 95 of 128 This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement..

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification. One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement..

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Assistant OSC Manager New Responsibility (tas Coordinate OSC Team dispatch and control AD-EP-ALL-0106 Att 1 Step 2.2 Participate with OSC Team dispatch and control AD-EP-ALL-0106 Att 1 Step 2.2 Direct/support site assembly, accountability and search & rescue activities AD-EP-ALL-0106 Att 1 Step 3.1 Establish and maintain facility accountability AD-EP-ALL-0106 Att 1 Step 3.1 Page 96 of 128 This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Assistant OSC Manager New Responsibility (tas Ensure habitability is established and maintained for occupied areas AD-EP-ALL-0106 Att 1 Step 1.2.1.b, 2.1.4 Conduct facility briefs and updates AD-EP-ALL-0106 Att 1 Step 2.1.1 Provide input for facility briefs and updates AD-EP-ALL-0106 Att 1 Step 2.1.1 Maintain event logs, forms and records AD-EP-ALL-0106 Att 1 Step 1.1 Page 97 of 128 This task has been added and is categorized as a deviation. Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification. One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated an improvement.

This task has been added and is categorized as a deviation. Standard ERO established the OSC Manager and Assistant OSC Manager as equivalent positions having a single qualification.

One individual assumes the facility manager and the other assumes an assistant role. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

It was previously an undirected administrative action now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Assistant OSC Manager ISS.tl.li!'J.M.S.i.Ml:41ffM,M Restore work area equipment and materials AD-EP-ALL-0106 Att 1 Step 4.0 Page 98 of 128 This task has been added and is categorized as a deviation.

It was previously an undirected administrative action now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Old Title: New Title: Log/Status Keeper (CNS/RP/O/A/5000/024 Enclosure 4.8) Log Keeper (AD-EP-ALL-0106 Attachment

2) Overall Change Impact to the Position Changes to the OSC Log Keeper tasks were minor and primarily differences.

Removed task involves facility access controls which are now individual position actions and the team dispatch process. Deviations created by the addition, modification and removal of tasks to the Log Keeper position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 0 tasks were added, 9 were modified and 1 was removed. Log/Status Keeper Old Responsibi Coordinate OSC Log/Status Keeper shift rotation and augmentation of personnel and equipment Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Prepare for facility activation (rooms , work area , equipment , etc.). Determine OSC minimum staffing levels from collect group staffing forms Establish an OSC log (WebEOC or manual) and maintain event classification posting Maintain status tracking of OSC teams Log Keeper Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list AD-EP-ALL-0106 Att 2 Step 1.2.3 Perform posit i on turnover when a shift change occurs AD-EP-ALL-0106 Att 2 Step 2.2 Respond as directed when notified of an event (sign in , get materials , etc.) AD-EP-ALL-0106 Att 2 Step 1.1 Prepare for facility activation (rooms , work area , equipment , etc.) AD-EP-ALL-0106 Att 2 Step 1.2 Ensure minimum staff is available (facility staffed) AD-EP-ALL-0106 Att 2 Step 1.2.3 Maintain status and i nformation boards/displays AD-EP-ALL-0106 Att 2 Step 2.1.6 Participate with OSC Team dispatch and control AD-EP-ALL-0106 Att 2 Step 2.1.4 & 7 Page 99 of 128 The steps for this task have been modified for checklist use, which is categorized as a d i fference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 4 Implement accountability requirements Maintain event logs, forms and record Log Keeper IM4i;J4-1¥i Maintain event logs, forms and records AD-EP-ALL-0106 Att 2 Step 1.1 CNS OSC ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation.

The standard ERO uses a continuous accountability log in each facility and the OSC team dispatch process for accountability of teams sent outside the OSC. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Provide all logs and records to Emergency I Restore work area equipment and materials Preparedness upon termination of the emergency.

AD-EP-ALL-0106 Att 2 Step 4.0 The steps for this task have been modified for checklist use, which is categorized as a difference.

Page 100 of 128 Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Old Title: New Title: OSC Maintenance Manager (CNS/RP/O/A/5000/024 Enclosure 4.6) Maintenance Supervisor (AD-EP-ALL-0106 Attachment

3) Overall Change Impact to the Position Changes to the Maintenance Supervisor tasks were minor and primarily differences.

The tasks added to the Maintenance Supervisor position involve common undirected administrative actions. The removed tasks involve facility access controls which are now performed within the OSC team dispatch process and 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing maintained by the OSC Manager and Assistant OSC Manager. Deviations created by the addition and removal of tasks to the Maintenance Supervisor position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 3 responsibility were added, 7 were modified and 3 were removed. OSC Maintenance Manager [*1 d*#M+1 Mlffl61Jffl~

Perform position turnover when a shift change occurs. Complete a "Maintenance 24 Hour Staffing/Site Essential Personnel" form Maintenance Supervisor New Responsibilit Perform position turnover when a shift change occurs AD-EP-ALL-0106 Att 3 Step 2.2 Manage assigned group emergency response activities AD-EP-ALL-0106 Att 3 Step 2.1 Page 101 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been removed and is categorized as a deviation. The task for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing is maintained by the OSC Manager/Assistant OSC Manager which sustains the capability. This change is evaluated as no reduction. This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Maintenance Supervisor has the responsibility for the overall maintenance activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

Revision 0 Attachment 4 OSC Maintenance Manager Old Responsi Respond as directed when notified of an event (sign in, get materials, etc.). Coordinate Maintenance augmentation of personnel and equipment Prepare for facility activation (rooms, work area, equipment, etc.). Brief and debrief maintenance teams for dispatched activities Implement accountability requirements Inform the OSC RP Manager of any locations outside the OSC where Maintenance personnel are located following a site evacuation CNS OSC ERO Position Comparison and Evaluation Maintenance Supervisor New Responsibility (tas Respond as directed when notified of an event (sign in, get materials , etc.) AD-EP-ALL-0106 Att 3 Step 1.1 Develop requests and coordinate external assistance (technical , craft, admin, etc.) AD-EP-ALL-0106 Att 3 Step 2.1 Arrange for equipment and supply resources AD-EP-ALL-0106 Att 3 Step 2.1 Prepare for facility activation (rooms, work area, equipment, etc.) AD-EP-ALL-0106 Att 3 Step 1.2 Participate with OSC Team dispatch and control AD-EP-ALL-0106 Att 3 Step 2.1 Page 102 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

The Maintenance Supervisor has the responsibility for the overall maintenance activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been removed and is categorized as a deviation. With regard to this position, accountability is related to the OSC teams sent out of the facility and is inherent to the 'Participate with OSC Team dispatch and control' task. This change is evaluated as no reduction.

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation OSC Maintenance Manager Old Responsibility (task Maintain event logs, forms and record Maintenance Supervisor New Responsibility (tas Provide input for facility briefs and updates AD-EP-ALL-0106 Att 3 Step 2.1 Maintain event logs , forms and records AD-EP-ALL-0106 Att 3 Step 1.1 Provide all logs and records to Emergency I Restore work area equipment and materials Preparedness upon termination of the emergency. AD-EP-ALL-0106 Att 3 Step 4.0 Page 103 of 128 This task has been added and is categorized as a deviation. CNS implementing procedures do not include this task for the Maintenance Supervisor as all positions could be called upon to provide input during a briefing.

Positions that have this task specifically called out are expected to contribute during all or most briefings. This change is evaluated as no reduction. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 4 Old Title: New Title: Operations Supervisor (CNS/RP/O/A/5000/024 Enclosure 4.4) Operations Supervisor (AD-EP-ALL-0106 Attachment

4) Overall Change Impact to the Position Changes to the Operations Supervisor tasks were minor and primarily differences.

CNS OSC ERO Position Comparison and Evaluation The tasks added to the Operations Supervisor position involve common undirected administrative actions. The removed tasks involve facility access controls which are now performed within the OSC team dispatch process, 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing maintained by the OSC Manager and Assistant OSC Manager and communications which is now assigned to the Operations Liaison. The need for the Operations Supervisor to assume the role of OSC Manager no longer exists. Deviations created by the addition and removal of tasks to the Operations Supervisor position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 5 tasks were added, 6 were modified and 4 were removed. Complete "Operations 24 Hour Staffing/Site Essential Personnel" form Page 104 of 128 This task has been removed and is categorized as a deviation.

The task for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing is maintained by the OSC Manager/Assistant OSC Manager which sustains the capability.

This change is evaluated as no reduction.

Revision 0 Attachment 4 Assume the OSC Coordinator position until properly relieved by a qualified OSC Coordinator Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). CNS OSC ERO Position Comparison and Evaluation Perform position turnover when a shift change occurs AD-EP-ALL-0106 Att 4 Step 2.2 Manage assigned group emergency response activities AD-EP-ALL-0106 Att 4 Step 2.1 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0106 Att 4 Step 1.1 Develop requests and coordinate external assistance (technical, craft, admin, etc.) AD-EP-ALL-0106 Att 4 Step 2.1 Page 105 of 128 This task has been removed and is categorized as a deviation.

The capability to provide command and control to the OSC resides with the OSC Manager and Assistant OSC Manager. These two positions are required to be staffed within 75 minutes, while the Ops Supervisor position is required for full staffing, possibly taking greater than 75 minutes to respond. Since the OSC and Assistant OSC Mangers can reasonably be expected to arrive within 75 minutes, the capability of OSC command and control is maintained with the required timeframe.

This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

The Operations Supervisor has the responsibility for the overall operations repair activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

The Operations Supervisor has the responsibility for the overall operations repair activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

Revision 0 Attachment 4 Operations Supervisor Id Responsibility (tas Establish communications with Control Room , TSC and EOF with the phone/headset via the Operations Bridge Line Prepare for facility activation (rooms , work area , equipment , etc.). Establish communications with Operations personnel deployed from the OSC including fire brigade CNS OSC ERO Position Comparison and Evaluation Arrange for equipment and supply resources AD-EP-ALL-0106 Att 4 Step 2.1 Prepare for facility activation (rooms , work area , equipment , etc.) AD-EP-ALL-0106 Att 4 Step 1.2 Monitor status and information boards/displays/systems AD-EP-ALL-0106 Att 4 Step 2.1.8 Participate with OSC Team dispatch and control AD-EP-ALL-0106 Att 4 Step 2.1.4-6 Page 106 of 128 This task has been added and is categorized as a deviation.

The Operations Supervisor has the responsibility for the overall operations repair activities. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been removed and is categorized as a deviation. This task is now assigned to the Ops Liaison which is a new position to the CNS OSC ERO which improves the ability to monitor operations communications and provide updates and support OSC response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference.

This task has been added and is categorized as a deviation. The Operations Supervisor monitors plant status in the execution of event mitigation activities. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 4 Inform the OSC RP Manager of any locations outside the OSC where Operations personnel are located following a site evacuation Maintain event logs, forms and record Ensure all "OSC Team Work Sheets" initiated by Ops are completed, closed out and submitted.

Provide all logs and records to Emergency Preparedness upon termination of the emergency.

Ensure all "OSC Team Work Sheets" initiated by Ops are completed, closed out and submitted. CNS OSC ERO Position Comparison and Evaluation Provide input for facility briefs and updates AD-EP-ALL-0106 Att 4 Step 2.1.2 Maintain event logs, forms and records AD-EP-ALL-0106 Att 4 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0106 Att 4 Step 4.0 Page 107 of 128 This task has been removed and is categorized as a deviation.

With regard to this position, accountability is related to the OSC teams sent out of the facility and is inherent to the 'Participate with OSC Team dispatch and control' task. This change is evaluated as no reduction. This task has been added and is categorized as a deviation. CNS implementing procedures did not include this task for the OpS Supervisor as all positions could be called upon to provide input during a briefing.

Positions that have this task specifically called out are expected to contribute during all or most briefings.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Old Title: No equivalent position in CNS ERO New Title: Operations Liaison (AD-EP-ALL-0106 Attachment

5) Overall Change Impact to the Position This standard position is new to the CNS ERO. Deviations created by the addition of the Operations Liaison position and its associated tasks did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 7 tasks were added. Operations Liaison l~t4iidM+iMlffl6diffi Perform position turnover when a shift change occurs AD-EP-ALL-0106 Att 5 Step 2.2 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0106 Att 5 Step 1.1 Communicate on assigned communication line and provide information to facility staff AD-EP-ALL-0106 Att 5 Step 1.2.3 & 2.1.2 Page 108 of 128 This task has been added and is categorized as a deviation.

This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

The Operations Liaison cummunicates plant status in the execution of event mitigation activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Operations Liaison Monitor status and information boards/displays/systems AD-EP-ALL-0106 Att 5 Step 2.1.8 Participate with OSC Team dispatch and control AD-EP-ALL-0106 Att 5 Step 2.1.5 & 6 Maintain event logs, forms and records AD-EP-ALL-0106 Att 5 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0106 Att 5 Step 4.0 Page 109 of 128 This task has been added and is categorized as a deviation.

The Operations Liaison monitors plant status in the execution of event mitigation activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. This task is added to the Ops Liaison role to ensure Ops personnel dispatched from the CR or OSC are coordinated I communicated with the shift. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Old Title: New Title: RP Supervisor (CNS/RP/0/5000/024, Enclosure 4.2) RP Supervisor (AD-EP-ALL-0106 Attachment

6) Overall Change Impact to the Position The span of control for this position is the pool of RP Technicians in the OSC, which does not change. Tasks added to the RP Supervisor position involve current common undirected administrative actions and survey/monitoring actions. The removed tasks involves 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing maintained by the OSC Manager and Assistant OSC Manager, recovery activities which will be assigned the EC, if needed and dispatch of FMT team members which is now the responsibility of the FMT Coordinator in the EOF. Deviations created by the addition and removal of tasks to the RP Supervisor position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 7 tasks were added, 12 were modified and 4 were removed. RP Supervisor Old Responsi Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Provide information for Radiation Protection 24 Hour Staffing/Site Essential Personnel RP Supervisor Perform position turnover when a shift change occurs AD-EP-ALL-0106 Att 6 Step 2.3 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0106 Att 6 Step 1.1 Page 110 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been removed and is categorized as a deviation.

The task for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing is maintained by the OSC Manager/Assistant OSC Manager which sustains the capability.

This change is evaluated as no reduction.

Revision 0 Attachment 4 RP Supervisor Id Responsi Establish communications with TSC RP Manager and/or TSC Dose Assessors.

Continuously monitor plant radiological status. Prepare for facility activation (rooms , work area , equipment, etc.) CNS OSC ERO Position Comparison and Evaluation RP Supervisor Manage assigned group emergency response activities AD-EP-ALL-0106 Att 6 Step 2.1 Develop requests and coordinate external assistance (technical, craft, admin, etc.) AD-EP-ALL-0106 Att 6 Step listed in tasks Arrange for equipment and supply resources AD-EP-ALL-0106 Att 6 listed in tasks Communicate on assigned communication line and provide information to facility staff AD-EP-ALL-0106 Att 6 Step 2.1.3 Monitor status and information boards/displays/systems AD-EP-ALL-0106 Att 6 Step 2.1.10 Prepare for facility activation (rooms , work area , equipment , etc.) AD-EP-ALL-0106 Att 6 Step 2.1.4 Page 111 of 128 This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the RP Supervisor has the responsibility for the overall RP activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

The RP Supervisor has the responsibility for the overall RP activities. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. The RP Supervisor has the responsibility for the overall RP activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference.

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation RP Supervisor

[*in*mH Activate, prepare and dispatch Field Monitoring Teams (FMTs) Provide immediate support and RP job coverage Provide RP personnel support of assembly and accountability Implement personnel vehicle contamination monitoring RP Supervisor Participate with OSC Team dispatch and contro l AD-EP-ALL-0106 Att 6 Step 2.1.6 & 7 Establish and maintain facility accountabi li ty AD-EP-ALL-0106 Att 6 Step 2.1.8 Track emergency worker exposure and eva l uate the need for dose extensions AD-EP-ALL-0106 Att 6 Step 2.1.10 Coordinate the monitoring of site evacuees AD-EP-ALL-0106 Att 6 Step 3.1 Monitor radiation conditions for OSC habitability to I Ensure habitability is established and ma i ntained determine if relocation is necessary for occupied areas AD-EP-ALL-0106 Att 6 Step 2.1.1 Page 112 of 128 This task has been removed and is categorized as a deviation.

Previous procedures directed the OSC RP Supervisor to brief the FMT members prior to dispatch. This task can be done by the FMT Coordinator from the EOF now to expedite dispatch and allow OSC personnel to focus on on-site and in plant teams in the revised procedures. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly include this task although the RP Supervisor does track emergency worker exposure and evaluate the need for dose extensions. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as no reduction. The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 4 RP Supervisor Monitor OSC contamination levels Participate in OSC critique following the event CNS OSC ERO Position Comparison and Evaluation RP Supervisor New Responsi Perform radiological sampling and surveys AD-EP-ALL-0106 Att 6 Step 2.1.1 Record/review radiological sampling and survey data AD-EP-ALL-0106 Att 6 Step 2.1 Establish and maintain facility accountability AD-EP-ALL-0106 Att 6 Step 2.1.8 Provide input for facility briefs and updates AD-EP-ALL-0106 Att 6 Step 2.1.4 Page 11 3 of 128 This task has been added and is categorized as a deviation.

OSC RP Supervisors are capable of performing survey and sample tasks in the standard ERO in order to support habitability tasks and for supervision of RP personnel.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the RP Supervisor does record/review radiological sampling and survey data. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not include this task for the RP Supervisor as all positions could be called upon to provide input during a briefing.

Positions that have this task specifically called out are expected to contribute during all or most briefings.

This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation.

The capability to conduct a critique does not require this action step. It is the responsibility of the OSC Manager to lead post-event critiques, which sustains the capability.

This change is evaluated as no reduction.

Revision 0 Attachment 4 RP Supervisor Assist OSC Coordinator in forming re-entry and recovery plans Maintain event logs, forms and record RP Supervisor New Responsi Maintain event logs , forms and records AD-EP-ALL-0106 Att 6 Step 1.1 CNS OSC ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation.:. The recovery process requires the EC to determine the appropriate ERO positions used to develop recovery plans as dictated by the extent of the particular event. Thus , this task may or may not be assigned to the RP Supervisor position and does not need to be specified in their checklist.

Th i s change has no impact on the recovery process. This change is evaluated as no reduction. The steps for this task have been modified for checklist use, which is categorized as a difference. Turn i n logs/forms and restore area/materials upon/ Restore work area equipment and materials event termination. AD-EP-ALL-0106 Att 6 Step 4.0 The steps for this task have been modified for checklist use , which i s categorized as a difference. Page 114 of 128 Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Old Title: Field Monitoring Team (E-Plan 1.7/1.8; CNS/HP/0/8/1009/003)

New Title: Field Monitoring Team (E-Plan 1.7/1.8; AD-EP-ALL-0203 Attachment

6) Overall Change Impact to the Position Changes to the Field Monitoring Team tasks were minor and primarily differences.

Task added to the Field Monitoring Team position involve explicit assignment of actions that were performed but absent or implied in previous procedures.

Deviations created by the addition of tasks to the Field Monitoring Team position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 1 tasks was added, 6 were modified and O were removed. Field Monitoring Team ,_,.,_ Respond as directed when notified of an event (sign in, get materials, etc.) CNS/HP/0/B/1009/003, Encl. 5.1 Use 800 MHz radio system for FMT communications CNS/HP/0/B/1009/003, Step 4.1.2 Offsite Surveys CNS/HP/0/B/1009/003, Step 4.3 Field Air Samples CNS/HP/0/B/1009/003, Step 4.4 Field Sampling CNS/HP/0/B/1009/003, Step 4.5 IF requested by FMC, analyze air samples for Iodine

Report air sample analysis results to FMC. CNS/HP/0/B/1009/003, Step 4.4.2.D Field Monitoring Team New Responsibility (ta Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0203 Att 6 Step 1.0 AD-EP-BNP-0203 Communicate on assigned communication line and provide information to facility staff AD-EP-ALL-0203 Att 6 Step 1.3 Perform radiological sampling and surveys AD-EP-ALL-0203 Att 6 Step 2.0-9.0 Record/review radiological sampling and survey data AD-EP-ALL-0203 Att 6 Step 2.0-9.0 Page 115 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 4 Field Monitoring Team Id Responsibilit Document survey results CNS/HP/0/B/1009/003, Step 4.3.8 WHEN event is over, inventory Emergency Kits. Restock items and return all emergency equipment to appropriate storage location after event is terminated.

CNS/HP/0/B/1009/003, Encl. 5.1 CNS OSC ERO Position Comparison and Evaluation Field Monitoring Team New Responsibility (ta Participate with OSC Team dispatch and control AD-EP-ALL-0203 Att 6 Step 1.1 Maintain event logs, forms and records AD-EP-ALL-0203 Att 6 Step 2.0-9.0 Restore work area equipment and materials AD-EP-ALL-0203 Att 6 Step 11 Page 116 of 128 This task has been added and is categorized as a deviation.

Previous procedures do not explicitly include this task although FMT personnel received briefings under the OSC dispatch process. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference.

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Old Title: New Title: Chemistry Manager (CNS/RP/0/5000/024, Enclosure 4.3) Chemistry Supervisor (AD-EP-ALL-0106 Attachment

7) Overall Change Impact to the Position The span of control for this position is the pool of Chemistry Technicians in the OSC, which does not change. Tasks added to the Chemistry Supervisor position involve current common undirected administrative actions and sampling actions. The removed tasks involve facility access controls which are now performed within the OSC team dispatch process and 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing maintained by the OSC Manager and Assistant OSC Manager. Deviations created by the addition of tasks to the Chemistry Supervisor position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 7 tasks were added, 6 were modified and 2 were removed. Coordinate 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing of the chemistry function Perform position turnover when a shift change occurs. Chemistry Supervisor l~tW;JM+1 eMlffl6dlt Perform position turnover when a shift change occurs AD-EP-ALL-0106 Att 7 Step 2.2 Manage assigned group emergency response activities AD-EP-ALL-0106 Att 7 Step 2.1 Page 117 of 128 This task has been removed and is categorized as a deviation.

The task for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing is maintained by the OSC Manager/Assistant OSC Manager which sustains the capability.

This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

CNS implementing procedures do not explicitly include this task although the Chem Supervisor has the responsibility for the overall chemistry activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

Revision 0 Attachment 4 Respond as directed when notified of an event (sign in, get materials, etc.). Prepare for facility activation (rooms, work area, equipment, etc.) CNS OSC ERO Position Comparison and Evaluation Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0106 Att 7 Step 1.1 Develop requests and coordinate external assistance (technical, craft, admin , etc.) AD-EP-ALL-0106 Att 7 Step 2.1 Arrange for equipment and supply resources AD-EP-ALL-0106 Att 7 Step 2.1 Prepare for facility activation (rooms, work area, equipment, etc.) AD-EP-ALL-0106 Att 7 Step 1.2 Perform event detection and assessment activities AD-EP-ALL-0106 Att 7 Step 2.1.3 Page 118 of 128 The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

The Chem Supervisor has the responsibility for the overall chemistry activities. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

The Chem Supervisor has the responsibility for the overall chemistry activities.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

OSC Chemistry Supervisors are capable of performing event detection and assessment tasks in the standard ERO in order to support EOP and technical specification actions. This change is evaluated as an improvement.

Revision 0 Attachment 4 Brief and debrief chemistry teams for sampling activities Implement accountability requirements CNS OSC ERO Position Comparison and Evaluation Chemistry Supervisor New Responsibility (t Perform chemical sampling and analysis AD-EP-ALL-0106 Att 7, Section 2.1 Record/review chemical sampling and analysis AD-EP-ALL-0106 Att 7 Step 2.1.8 Participate with OSC Team dispatch and control AD-EP-ALL-0106 Att 7 Step 2.1.3 & 4 Provide input for facility briefs and updates AD-EP-ALL-0106 Att 7 Step 2.1.5 Page 119 of 128 This task has been added and is categorized as a deviation. OSC Chemistry Supervisors are capable of performing sample tasks in the standard ERO in order to support EOP and technical specification actions. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. CNS implementing procedures do not explicitly include this task although the Chemistry Supervisor does review sample analyses.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as no reduction. The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been removed and is categorized as a deviation.

With regard to this position, accountability is related to the OSC teams sent out of the facility and is inherent to the 'Participate with OSC Team dispatch and control' task. This change is evaluated as no reduction.

This task has been added and is categorized as a deviation. CNS implementing procedures do not include this task for the Chemistry Supervisor as all positions could be called upon to provide input during a briefing.

Positions that have this task specifically called out are expected to contribute during all or most briefings.

This change is evaluated as no reduction.

Revision 0 Attachment 4 Maintain event logs, forms and record Chemistry Supervisor New Responsibility (t Maintain event logs , forms and records AD-EP-ALL-0106 Att 7 Step 1.1 CNS OSC ERO Position Comparison and Evaluation The steps for this task have been modified for checklist use, which is categorized as a difference.

Provide all logs and records to Emergency I Restore work area equipment and mater i als Preparedness upon termination of the emergency. AD-EP-ALL-0106 Att 7 Step 4.0 The steps for this task have been modified for checklist use , which is categorized as a difference. Page 120 of 128 Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Old Title: Nuclear Supply Chain Manager (CNS/RP/O/A/5000/024 Enclosure 4.7) New Title: Generation Supply Chain Liaison (AD-EP-ALL-0106 Attachment

8) Overall Change Impact to the Position Changes to the Generation Supply Chain Liaison tasks were minor and primarily differences.

The tasks removed from the Generation Supply Chain Liaison position involve facility accountabilty controls,24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing maintained by the OSC Manager and Assistant OSC Manager and communications with the EOF which would occur in the coordination of logistics and resource support. The task additions involve current common undirected actions including being the point of contact for SAFER and FLEX. Deviations created by the addition and removal of tasks to the Generation Supply Chain Liaison position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 0 tasks were added, 10 were modified and 3 were removed. Coordinate Nuclear Supply Chain shift rotation and augmentation of personnel and equipment.

Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Coordinate acquisition of materials, parts, equipment and services both from warehouse and by procurement Coordinate acquisition of materials, parts, equipment and services both from warehouse and by procurement Perform position turnover when a shift change occurs AD-EP-ALL-0106 Att 8 Step 2.2 Respond as directed when notified of an event (sign in , get materials, etc.) AD-EP-ALL-0106 Att 8 Step 1.1 Develop requests and coordinate external assistance (technical, craft, admin, etc.) AD-EP-ALL-0106 Att 8 Step 2.1 Arrange for equipment and supply resources AD-EP-ALL-0106 Att 8 Step 2.1 Page 121 of 128 This task has been removed from the Nuclear Supply Chain Manager procedure.

The capability to sufficiently staff the OSC with Nuclear Supply Chain staff resides with the OSC Manager and Assistant OSC Manager. It is the responsibility of these positions to take or assign action for Nuclear Supply Chain staffing, which sustains the capability. The change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 4 Communicate with EOF Services Manager Prepare for facility activation (rooms , work area , equipment , etc Inventory OSC equipment and supplies following OSC activation Assist OSC responders in repair of OSC communications or other equipment Ensure all "OSC Team Work Sheets" initiated by supply chain work group are completed , closed out and submitted. Maintain event logs, forms and records CNS OSC ERO Position Comparison and Evaluation Prepare for facility activation (rooms , work area , equipment , etc.) AD-EP-ALL-0106 Att 8 Step 1.1 Arrange for logistics support AD-EP-ALL-0106 Att 8 Step 2 .. 1 Participate with OSC Team dispatch and control AD-EP-ALL-0106 Att 8 Step 2.1 Serve as primary po i nt of contact for SAFER and FLEX support AD-EP-ALL-0106 Att 8 Step 2.1. 7 Maintain event logs , forms and records AD-EP-ALL-0106 Att 8 Step 1.1 Page 122 of 128 This task has been removed and is categorized as a deviation. The capability to support the OSC with resources and logistics continues to reside with Nuclear Supply Chain. Communications with the EOF describes an action that is subsumed into the core task of this position, thus maintaining the capability. The change is evaluated as no reduction. The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference.

This task has been removed and is categorized as a deviation. The capability to assist in the repair of OSC equipment continues to reside with Nuclear Supply Chain. The old responsibility describes an action that is subsumed into the core task of this position , thus maintaining the capability. The change is evaluated as no reduction.

The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation. Task not previously assigned within the CNS ERO. This change provides a dedicated common fleet ERO position for SAFER and FLEX activities. The change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference.

Revision 0 Attachment 4 CNS OSC ERO Position Comparison and Evaluation Turn i n logs/forms and restore area/materials upon I Restore work area equipment and materials event termination. AD-EP-ALL-0106 Att 8 Step 4.0 Implement accountability requirements Page 123 of 128 The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been removed and is categorized as a deviation. The task to implement accountability i s maintained by the OSC Manager/Assistant OSC Manager which sustains the capability. This change i s evaluated as no reduction. Revision 0 Attachment 4 Old Title: DRC Supervisor (CNS RP/O/A/5000/024)

New Title: No equivalent position in the Standard ERO Overall Change Impact to the Position Position not part of the standard ERO. CNS OSC ERO Position Comparison and Evaluation All tasks previously assigned to the DRC Supervisor position are performed by various other standard ERO staff. Deviations created by the removal of the DRC Supervisor position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 2 tasks are performed by other ERO positions.

DRC Supervisor Complete actions for facility activation, turnover , dosimetry, log keeping and emergency staffing Ensure proper emergency exposure controls are taken for personnel.

Page 124 of 128 This task has been removed and is categorized as a deviation.

The capability to activate the OSC is maintained by the OSC Manager. This task has been removed and is categorized as a deviation.

The capability to ensure adequate exposure controls is maintained by the RP Supervisor.

Revision 0 Attachment 5 Change Evaluation Process The changes to the ERO were evaluated from three distinct perspectives.

First, changes to the physical number and response time requirements of the ERO positions were evaluated.

Second, changes to the ERO chain of command and reporting relationships were evaluated.

Lastly, the changes to the addition, alteration or removal of responsibilities (tasks) for each ERO position were evaluated.

1. Changes to the ERO Staffing Numbers This evaluation was performed to assess whether any changes to the number of ERO positions were made (total and by response time) and to determine whether those changes impacted the licensing bases, capability or timeliness of the ERO response and performance of functions.

The addition of an ERO position is considered a deviation.

The addition of an ERO position is considered an improvement due to having additional staff to perform the work, provided it does not overload the next level supervisor/manager position.

The alteration of a position from a specific time requirement into another time requirement is considered a deviation.

The acceptability of the deviation is assessed by evaluation of the assigned tasks in Step 3 below. The deletion of a position is considered a deviation.

The acceptability of the deviation is assessed by evaluation of the assigned tasks in Step 3 below. 2. Changes to the ERO Hierarchy/

Reporting Relationships This evaluation was performed to assess whether any changes to the structural hierarchy or reporting relationships were made and to determine whether those changes impacted capability or timeliness of the ERO response and performance of functions.

3. Changes to an ERO Position's Responsibilities (tasks) Tasks for each ERO position in the current Emergency Plan and implementing procedures are matched to a standard ERO task list based on planning standard, function and element terminology (or identified as station specific tasks and given a unique task ID). Tasks that may have been stated in the E-Plan or procedures in general terms such as provide engineering support or manage radiological personnel may be associated with more specific task descriptions.

Tasks for each ERO position in the new organization are identified and assigned from the same task list used for the current ERO as described above. The tasks for each ERO position are organized in a table for individual comparison.

Changes to an ERO position can involve adding, removing or modifying a task. Added task -involves moving an existing task from a different ERO position, assigning a task previously performed as an undirected action (such as an inherent administrative expectation), or assigning a task that is entirely new (typically limited to when process or equipment changes are being implemented in conjunction).

Removed task -involves moving an existing task to a different ERO position or eliminating it entirely (typically limited to when process or equipment changes are being implemented in conjunction).

Modified task -involves changes in wording or sequencing that potentially affect the capability or timeliness of the task. Page 125 of 128 Revision 0 Attachment 5 Change Evaluation Process Since all ERO procedures are being converted to a checklist format for improved human factors design, all task wording has been modified to some extent. Task modifications limited to checklist format changes where step wording and sequence remains essentially unchanged are defined as differences.

Following table alignment of the added, removed and altered tasks, each comparison is categorized as a no change, difference or deviation.

Added and removed tasks are automatically categorized as deviations with regard to their impact on the ERO position in order to force further evaluation and conclusion documentation.

Modified tasks may be categorized as a difference or a deviation.

Difference A difference only applies to modified tasks where the change to the wording (of either the task or its steps) does not alter the capability and/or timeliness of the function for which the task was performed.

Any change that is determined to be a difference requires no further evaluation.

Deviation A deviation is defined as a change to the wording of a task or its steps that does alter the capability and/or timeliness of the function for which the task was performed.

All added tasks and those removed tasks that are fully eliminated (no longer performed by any position) must be further evaluated in the change evaluation column to establish whether the change improved, maintained, reduced or lost the ability to perform the function.

Removed tasks that are transferred to another ERO position are evaluated as an added task. Thus, only the ERO position that the task is being moved to needs to be documented in the change evaluation column. Modified tasks categorized as deviations must be further evaluated in the change evaluation column to establish whether the change improved, maintained, reduced or lost the ability to perform the function.

For all task changes categorized as deviations, further evaluation is performed to determine the impact on the qualities (attributes) of capability and timeliness.

Capability is defined as the quality (attribute) of being able or capable to perform the task. In order to determine an impact to capability the actions accomplished by the task must be known (what the task does). For example; assume the Steps in an existing procedure for the task to classify an event establish the actions for initial event declaration, upgrade and downgrade.

The Steps in the standard procedures for the classification task include the actions for initial event declaration and upgrade. Therefore, a deviation is created by the removal of an action (downgrading) of the task in the original procedure.

Timeliness is defined as the quality (attribute) of task duration.

The impact to timeliness can sometimes be determined by evaluating the changes to the steps, such as when one or more steps are added or removed. In other cases it may be necessary to perform the task, such as in a drill or exercise, and observe whether the change impacted the timeliness of the task. Page 126 of 128 Revision 0 Attachment 5 Change Evaluation Process 4. Completing a Comparison Table for Each ERO Position A. Identify and list the current tasks performed by the ERO position (sources can include the E-Plan, positional procedures, functional procedures, forms, etc.). B. Identify, list and align the new tasks performed by the ERO position to each of the current tasks. 1) If a new task can be correlated to a current task, list it in the same row in the comparison table. 2) If a new task cannot be correlated to a current task, list it in a separate row in the comparison table. C. Where a current task does not align with a new task identify whether the task was added or removed and document as a deviation in the Change Evaluation column. 1) For added tasks and those removed tasks that are fully eliminated (no longer performed by any position), document an explanation and evaluation of the addition or removal that justifies the change and explicitly states whether it improves, maintains, degrades or loses the ability to perform the function.

2) For removed tasks that are transferred to another ERO position, document which position the task has been transferred to. D. Where a current task does align with a new task identify whether the task was not changed or modified in the Change Evaluation column. E. For each modified tasks identify whether the change is a difference or a deviation.

1) Review the Steps and identifying the actions that the current task does. 2) Review the Steps and identifying the actions that the new task does. NOTE: Changes to informational wording in current tasks that don't "do" anything ( content that is not actionable) do not affect the actions of the task. 3) Compare the list of actions to determine whether the new task does more or less than the current task. A. If the new task does more or less (has more or fewer actions) as compared to the current task, then categorize the change as a deviation (due to an alteration in the capability).

B. If the new task does the same actions as compared to the current task, then categorize the change as a difference.

Page 127 of 128 Revision 0 Attachment 5 Change Evaluation Process NOTE: In the case where the current procedure simply states the task and the new task has added performance steps, and in consideration that there has been no change in how the actual task is performed, it is acceptable to conclude that the timeliness has not been altered. 4) Compare the steps to determine whether the new task takes more or less time to accomplish than the current task. a. If the new task takes more or less time to accomplish as compared to the current task, then categorize the change as a deviation (due to an alteration in the timeliness).

b. If the new task takes the same amount of time to accomplish as compared to the standard task, then categorize the change as a difference.

c. If it is not possible to determine whether the standard task can be accomplished in more or less time than the current task, note that further evaluation is necessary.

F. For each modified task identified as a difference, provide a brief statement for why it is considered such. G. For each modified task identified as a deviation, document an explanation and evaluation of the addition or removal that justifies the change and explicitly states whether it improves, maintains, degrades or loses the ability to perform the function.

5. Overall Change to a Position A summary of the overall impact of the task changes is documented above the comparison table for each position.

Information included in the summary is as follows: A. Span of control change description for positions that manage or supervise other positions (as applicable).

B. Description of overall change impact to position.

C. Summary of task deviations.

D. Evaluation statement explicitly documenting:

1) That the deviation did not degrade the capability or timeliness to perform an associated function.

2) That no site specific commitments are adversely altered by changes to tasks assigned to this position (this statement is able to be made in the comparison document based on the results of the commitment search recorded on the §50.54(q) evaluation form). 3) That the changes do not reduce the effectiveness of the emergency plan. Page 128 of 128 Revision 0 Enclosure 2 CNS ERO Position Comparison and Evaluation

-JIG

DUKE '-' ENERGY

Catawba ~~~~~~Nuclear Station {CNS) Duke Energy ERO Standardization JIC ERO Position Comparison and Evaluation Revision 0 CNS JIC ERO Position Comparison and Evaluation Table of Contents 1. PURPOSE ...........................................................................................................................

3 2. DISCUSSION

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

3 3.

SUMMARY

OF CHANGES ..................................................................................................

4 3.1 Comparison of ERO Positions, Responders and Response Times ..................................

4 3.1.1 Numeric Change to the Augmented ERO ...........................................................

.4 3.1.2 Response Time Impact to the Augmented ER0 ...................................................

4 3.2 Comparison of the ERO Hierarchy/

Reporting Relationships

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

4 3.3 Comparison of the ERO Responsibilities by Position .......................................................

4 Attachments Attachment 1, CNS JIC ERO Staffing Depth Comparison

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

5 Attachment 2, CNS Organizational Comparison of the ERO Hierarchy

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

6 Attachment 3, CNS JIC ERO Position Comparison and Evaluation

..........

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

8 Attachment 4, Change Evaluation Process ...............................................................................

26 Page 2 of 29 Revision 0 CNS JIC ERO Position Comparison and Evaluation

1. PURPOSE Identify differences and deviations between the current CNS ERO and the Duke standard ERO for the Joint Information Center (JIC). Evaluate all deviations to determine whether they create a reduction in effectiveness (RIE) in the current station Emergency Preparedness Program. 2. DISCUSSION A program initiative has been undertaken by Duke Energy personnel to standardize the ERO positions, functions and responsibilities (tasks) across the fleet. This involves changes to the current ERO, which for this evaluation is based upon those responder titles and numbers identified in emergency plan and the implementing procedures.

It is recognized that any changes to the ERO structure and the implementing procedures require a detailed §50.54(q) effectiveness evaluation.

Regulatory Guide 1.219 provides the following information related specifically to this type of change: [G.1.1.b]

Some changes that a licensee may make to its approved emergency plan warrant prior NRG approval to ensure that the changes would not adversely affect the NRG's reasonable assurance determination.

However, other general types of changes may have such a minimal effect on this determination that they would not warrant prior NRG approval.

For example, changes that reduce the number of personnel available to respond to emergencies or lengthen the time it takes to staff and activate emergency response facilities (ERFs) could affect the NRG's reasonable assurance determination and would require prior NRG staff approval.

Minor administrative changes, such as correcting position titles and spelling errors and updating document numbers, would not warrant prior NRG staff review." Between these extremes is a range of possible changes for which the licensee is required to perform and document a detailed, objective evaluation.

[G.1.4.a]

.... Proposed changes that could delay emergency declarations, notifications, or PARs may reduce the effectiveness of the emergency plan in that subsequent emergency response actions may not be timely and emergency response personnel, facilities, and equipment may not be in position if it becomes necessary to carry out measures to protect the public health and safety. Generally, the licensee should view any change that could delay an activity or relax a timeliness criterion for the activity as a potential reduction in effectiveness and should evaluate it accordingly.

Due to the scope of changes being made, this position to position and task to task comparison evaluation has been developed to document the effectiveness review. Attachment 4 documents the methods used to conduct this evaluation.

Page 3 of 29 Revision 0 CNS JIC ERO Position Comparison and Evaluation

3.

SUMMARY

OF CHANGES 3.1 Comparison of ERO Positions, Responders and Response Times The total number of responders filling JIC ERO positions in the current CNS ERO is 5 and the total number of responders filling positions in the standard JIC ERO is 5 (no change to ERO responders).

3.1.1 Current

CNS Duke Difference Standard 5 5 0 Numeric Change to the Augmented ERO One position -Media Center Coordinator

-was added to the CNS Media Center ERO in adopting the Duke Standard ERO. The addition of this position improves overall performance.

The Nuclear Communications Staff Person (an "as-needed" position staffed by an extra Media Liaison or other individual) position was removed from the CNS JIC ERO in adopting the Duke Standard ERO. The reduction of this "as-needed" position does not reduce the overall performance.

The tasks for the Nuclear Communications Staff Person tasks are performed by other JIC personnel.

3.1.2 Response

Time Impact to the Augmented ERO No changes in response time of JIC ERO responders occurred when adopting the Duke Standard ERO. 3.2 Comparison of the ERO Hierarchy/

Reporting Relationships There are no changes to the reporting hierarchy or reporting relationships as a result in adopting the Duke Standard ERO. 3.3 Comparison of the ERO Responsibilities by Position No tasks were removed from JIC response.

Changes to task assignments do not overburden any position.

Refer to Attachment 3 for specific disposition of each task for each position.

Page 4 of 29 Revision 0 Attachment 1 CNS JIC ERO Staffing Depth Comparison Augmented ERO Comparison by Function t:: t:: 0 0 -:s: Q. -:s: Q. -RI Q. -RI Q. Functional Area Major Tasks CNS ERO Emergency Positions

i-:::I Standard ERO Emergency Positions

i-:::I LL U, u, LL U, u, 9. Public Information Public Information Lead PIO 1 -----*---*---*-*-*--

-**-------------------**----

Public Spokesperson

(!IC) 1 Company Spokesperson (JIC/MC) 1 Nu~_lear Comm Staff Person (MC) _____ 1 --Media Center Coordinator (MC} 1 Technical Liaison (EOF/JIC) 1 EOF Technical Liaison (EOF) 1 --,-. News Manager (JIC/MC) 1 Info GatheringJ-ead JJIC/MC) 1 *-**-*-----

*--* Public Information Coordinator (JIC) 1 News Writer (EOF) 1 TOTAL: 5 0 TOTAL: 5 1 Page 5 of 29 Revision 0 Attachment 2 Current Station JIC Organization CNS Organizational Comparison of the ERO Hierarchy FIGURE G-2 Corporate Communications Emergency Response Organization Strategic

/\dvisor Pu bile Informat i on Manager *-*-*-*~ ECOC Public Information Coordinator Media Coordinator Regional Commumcat1ons Coordinator Government

/\gency Liaison Ad min & Logistics Manager Technical L1a1son News Manager Public Spokesperson Located in EOF/EOC/gas control or field location The above positions plus one individual to assist with setup are staffed at the site's Near-Site Media Center Media L1a1son Media Monitor /\dv ertisi ng Manager Customer Service (CS) L1a1son Message Integrator Teleproductions Support G--l Social Media Support Page 6 of 29 Web Communication Coordinator Internal Communications Coordinator Emergency Planner 1-ax!Copy!Distribut,on Support Regmtmt,on Support Media Center Assistant t'-..DUKE ~,;ENERGY .. Rev. 16-2 April. 2016 Revision 0 Attachment 2 Standard Near-Site Media Center Organization Media Center I Coordinator Company Spokesperson Lead PIO News Writer Info Gathering Lead Page 7 of 29 CNS Organizational Comparison of the ERO Hierarchy EOF Tech Liaison Green -Corporate Support Positions Blue -Site Emergency Plan Positions Revision 0 Attachment 3 CNS JIC ERO Position Comparison and Evaluation Old Title: Public Spokesperson (E-Plan G.4.a) New Title: Company Spokesperson (E-Plan G.4.a; AD-EP-ALL-0108 Attachment

3) Overall Change Impact to the Position There is no change to the span of control to this position.

Deviations created by the addition, removal and modification of tasks to the. Company Spokesperson position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 3 tasks were added, 7 were modified and 4 were removed. Perform position turnover when a shift change occurs. SRO A 2000 001 Encl. 6.2, Step 1.12 Respond as directed when notified of an event (sign in, get materials, etc.). SRO A 2000 001 Encl. 6.2, Steps 1.1-1.3 Maintain contact with Public Spokesperson at visitor's center or CNS Joint Information Center (JIG) SRO A 2000 001 Encl. 6.2, Steps 1.7 Coordinate with Public Spokespersons at other locations SR O A 2000 001 Encl. 6.2, Step 1.8 Perform position turnover when a shift change occurs. AD-EP-ALL-0108 Att 3 Step 17 Respond as directed when notified of an event (sign in, get materials, etc.). AD-EP-ALL-0108 Att 3 Steps 1-4 Page 8 of 29 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been removed and is categorized as a deviation. The Lead PIO has the overall responsibility for the coordinating of information between the Company Spokespersons. This change is evaluated as no reduction This task has been removed and is categorized as a deviation. The Lead PIO has the overall responsibility for the coordinating of information between the Company Spokespersons. This change is evaluated as no reduction Revision O Attachment 3 Prepare for news conference SR O A 2000 001 Encl. 6.2 , Step 1.8 Provide brief update to state and county PIOs at pre-news conference briefing. SR O A 2000 001 Encl. 6.2, Step 1.9.6 Company Spokesperson New Responsibility (tas Provide input for facility briefs and updates AD-EP-ALL-0108 Att 3 Step 14 Perform media briefings and interviews AD-EP-ALL-0108 Att 3 Step 13 Coordinate information to the Incident Response Team AD-EP-ALL-0108 Att 3 Step 15 Page 9 of 29 CNS JIC ERO Position Comparison and Evaluation This task has been added and is categorized as a deviation. The change is considered a deviation however it does not reduce the ability of the Company Spokesperson perform assigned functions during declared event. This change is evaluated as an improvement.

This task has been removed and is categorized as a deviation. This task is considered a part of the performance of media conferences and interviews and coordinate information with government officials/agencies tasks. This change is evaluated as no reduction. This task has been removed and is categorized as a deviation. This task is assigned to the Government Liaison. In the standard ERO the Government Liaison.is responsible for providing updates to the state and county PIOs. Assigning this task to Government Liaison allows the spokesperson to better perform their functions.

This change is evaluated as no reduction. Task has been added and is categorized as a deviation. Position would have always supported this as part of serving as the Company Spokesperson.

Adding this step clarifies the task. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. This change ensures Duke Enterprise is kept informed on public information activities.

This change is evaluated as an improvement.

Revision 0 Attachment 3 Consult with Public Information Manager in JIC to obtain most current information for rumors, status of news releases, etc. SRO A 2000 001 Encl. 6.2, Step 1.9.5 ADDRESS significant rumors about plant status and/or any misinformation revealed by media questions.

RP O B 5000 028 Encl. 4.2 Review and approve news releases/bulleted updates. SR O A 2000 001 Encl. 6.2, Step 1.6 Coordinate information with government officials/agencies , owner's Groups, and ECOC SRO A 2000 001 Encl. 6.2 , Step 1.10 Maintain event logs , forms and records SR O A 2000 001 Encl. 6.2, Step 1.11 Restore work area equipment and materials SR 0 A 2000 001 Encl. 6.2, Step 1.13 CNS JIC ERO Position Comparison and Evaluation Corrects rumors in media briefings and interviews AD-EP-ALL-0108 Att 3 Step 10 Approve/review all news releases , statements and messages. AD-EP-ALL-0108 Att 3 Step 8 Coordinate information with government officials/agencies.

AD-EP-ALL-0108 Att 3 Step 15 Maintain event logs, forms and records. AD-EP-ALL-0108 Step 5.3 and Att 3 Step 17 Restore work area equipment and materials AD-EP-ALL-0108 Att 3 Step 18 Page 10 of 29 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 Old Title: New Title: Nuclear Communications Staff Person (RP O B 5000 028) No Equivalent Position in Standard ERO Overall Change Impact to the Position Position not part of the standard ERO. CNS JIC ERO Position Comparison and Evaluation The position of Nuclear Communications Staff Person is eliminated in the Standard ERO. This position was an "as-needed" position if there was a need to open a Near-Site media center. In that occurrence, an extra Media Liaison (or other individual) would open the media center to manage any media that arrive. This position is not referenced in the CNS Emergency Plan or JIC Organization Chart because it is a communications process to be use as needed -depending on the event and staffing availability.

Deviations created by the removal of tasks from the Nuclear Communications Staff Person position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 0 tasks were added, 0 were modified and 10 were removed. Nuclear Communications Respond as directed when notified of an event (sign i n, get materials, etc.). RP O B 5000 028 Encl. 4.3 ASSIGN activation activities to available staff. ENSURE Onsite Media Center Staff area is setup for staff use. RP O B 5000 028 Encl. 4.3 ENSURE media are logged in , properly identified , and given assistance , as needed. RP O B 5000 028 Encl. 4.3 Page 11 of 29 This task has been removed and is categorized as a deviation. This task is performed by all JIC staff members for their position.

This change is evaluated as no reduction. This task has been removed and is categorized as a deviation. The Information Gathering Lead has the overall responsibility to assign to Media Center staff upon their arrival. This change is evaluated as no reduction. This task has been removed and is categorized as a deviation. The Information Gathering Lead has the overall responsibility to assign to Media Center staff upon their arrival. This change is evaluated as no reduction.

Revision 0 Attachment 3 Nuclear Communications ENSURE Security understands where to route media. RP O B 5000 028 Encl. 4.3 ENSURE information is available for the media. ENSURE event status board is updated as needed. RP O B 5000 028 Encl. 4.3 SERVE as News Manager until Nuclear Communications Manager arrives, or if the Nuclear Communications Manager is not available. RP O B 5000 028 Encl. 4.3 ESTABLISH communications with the TSC AND EOF RP O B 5000 028 Encl. 4.3 ENSURE all visitor center phones are forwarded to the Customer Contact Center (CCC) at the News Manager's discretion RP O B 5000 028 Encl. 4.3 ENSURE auditorium is setup for onsite media interactions if directed by News Manager. RP O B 5000 028 Encl. 4.3 Page 12 of 29 CNS JIC ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation.

The Information Gathering Lead has the overall responsibility for this task and will assign to Media Center staff upon their arrival. This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation.

The Information Gathering Lead has the overall responsibility to perform this task and assign to Media Center staff upon their arrival. This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation.

The Information Gathering Lead has the overall responsibility to perform this task and assign to Media Center staff upon their arrival. This change is evaluated as no reduction. This task has been removed and is categorized as a deviation.

The Information Gathering Lead has the overall responsibility to perform this task and assign to Media Center staff upon their arrival. This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation. The Information Gathering Lead has the overall responsibility to perform this task and assign to Media Center staff upon their arrival. This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation.

The Information Gathering Lead has the overall responsibility to perform this task and assign to Media Center staff upon their arrival. This change is evaluated as no reduction.

Revision 0 Attachment 3 Nuclear Communications Maintain event logs, forms and records. RP O B 5000 028 Encl. 4.3 Page 13 of 29 CNS JIC ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation.

This task is performed by all JIG staff members for their position. This change is evaluated as no reduction Revision 0 Attachment 3 CNS JIC ERO Position Comparison and Evaluation Old Title: No Equivalent Position in Previous CNS ERO New Title: Media Center Coordinator (AD-EP-ALL 0108 Attachment

10) Overall Change Impact to the Position This standard position is new to the CNS ERO. The Media Center Coordinator is responsible for assigning and performing work to ensure the Media Center operates efficiently.

Deviations created by the addition of the Media Center Coordinator position and its associated tasks did not degrade the capability or timeliness to perform an associated function.

No site-specific commitments were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 11 tasks were added, O were modified and O were removed. Media Center Coordinator Perform position turnover when a shift change occurs. AD-EP-ALL-0108 Att 10 Step 13 Respond as directed when notified of an event (sign in, get materials, etc.). AD-EP-ALL-0108 Att 10 Steps 1-4 Prepare for facility activation (rooms , work area, equipment , etc.) AD-EP-ALL-0108 Att 10 Steps 9 & 10 Page 14 of 29 This task has been added and is categorized as a deviation. This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 3 Media Center Coordinator Register personnel at the assigned location AD-EP-ALL-0108 Att 10 Step 5 Monitor facility entrance areas. AD-EP-ALL-0108 Att 10 Steps 6-8 Arrange for equipment and supply resources. AD-EP-ALL-0108 Att 10 Step 12 Arrange for logistical support. AD-EP-ALL-0108 Att 10 Step 12 Coordinate d i stribution of news releases , statements and messages. AD-EP-ALL-0108 Att 10 Step 10 Page 15 of 29 CNS JIC ERO Position Comparison and Evaluation This task has been added and is categorized as a deviation. This task was previously performed by the Registration Support position.

This change moves the task to the Media Center Coordinator and Registration Liaison. The change is evaluated as an improvement.

This task has been added and is categorized as a deviation. This task was previously performed by the Registration Support position.

This change moves the task to the Media Center Coordinator and Registration Liaison. The change is evaluated as an improvement.

This task has been added and is categorized as a deviation. The Media Center Coordinator is a new position i n the Standard ERO and is responsible for assigning and performing work to ensure the Media Center operates efficiently. The change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

The Media Center Coordinator is a new position in the Standard ERO and is responsible for assigning and performing work to ensure the Media Center operates efficiently.

The change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

The Media Center Coordinator is a new position in the Standard ERO and is responsible for assigning and performing work to ensure the Media Center operates efficiently. The change is evaluated as an improvement.

Revision 0 Attachment 3 Media Center Coordinator New Responsibility (task Coordinate accommodation of news media personnel AD-EP-ALL-0108 Att 10 Step 12 Maintain event logs , forms and records. AD-EP-ALL-0108 Step 5.3 Restore work area equipment and materials AD-EP-ALL-0108 Att 10 Step 14 Page 16 of 29 CNS JIC ERO Position Comparison and Evaluation This task has been added and is categorized as a deviation.

This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 3 CNS JIC ERO Position Comparison and Evaluation Old Title: EOF Technical Liaison (SRO A 2000 001) New Title: EOF Technical Liaison (AD-EP-ALL-0108 Attachment

4) Overall Change Impact to the Position This EOF Technical Liaison reports to the EOF. There are no changes to the span of control to this position.

The primary tasks of the EOF Technical Liaison remain the same. Deviations created by the addition, removal and modification of tasks to the EOF Technical Liaison position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 0 tasks were added, 8 were modified and 6 were removed. EOF Technical Liaison Perform position turnover when a shift change occurs. SR O A 2000 001 Encl. 6.4, Step 1.28 Respond as directed when notified of an event (sign i n, get materials , etc.). SRO A 2000 001 Encl. 6.4 , Steps 1.1-1.2 Support either Pl Coord , Public Spokesperson , or man JIC/EOF conference bridge SR O A 2000 001 Encl. 6.4 , Step 1.3 Access JIC/EOF conference bridge. SRO A 2000 001 Encl. 6.4 , Step 1.5 Support the Public Spokesperson. SR O A 2000 001 Encl. 6.4 , Step 1.13 Update regional communications coordinator on JIC bridge as conditions change , SRO A 2000 001 Encl. 6.4 , Step 1.16 Assist public information coordinator to understand information on Emergency Notification Forms (ENF) and logs. SR O A 2000 001 Encl. 6.4, Step 1.14 Notify Public Spokesperson immediately of any significant changes , such as changes in emergency classifications. SR O A 2000 001 Encl. 6.4, Step 1.25 EOF Technical Liaison Perform position turnover when a shift change occurs. AD-EP-ALL-0108 Att 4 Step 34 Respond as directed when notified of an event (s i gn in , get mater i als , etc.). AD-EP-ALL-0108 Att 4 Steps 1-4 Communicate on assigned communication li ne and provide information to facility staff AD-EP-ALL-0108 Att 4 Steps 9-12 Provide site event and response information for public information staff. AD-EP-ALL-0108 Att 4 Step 21 Page 17 of 29 The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which i s categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 EOF Technical Liaison Provide dose comparison information to Public Information Coordinator.

SRO A 2000 001 Encl. 6.4, Step 1.21 Request assistance from EOF Rad Assessment Manager or designee in obtaining Site Boundary dose information and use for proper dose comparisons for news releases/bulleted updates SRO A 2000 001 Encl. 6.4, Step 1.18 Monitor and update radiological release information SRO A 2000 001 Encl. 6.4, Step 1.22 Coordinate with State and County Liaisons SRO A 2000 001 Encl. 6.4, Step 1.8 Assist Regional Communications Coordinator and State/County EOC Liaisons by obtaining information to dispel rumors: SRO A 2000 001 Encl. 6.4, Step 1.24 Verify sounding of sirens with State Liaison in EOF or with State/County EOC Liaison and share this information with JIC Regional Communicator Coordinator.

SRO A 2000 001 Encl. 6.4, Step 1.17 Review document "Questions Corporate Communications May Ask." SRO A 2000 001 Encl. 6.4, Step 1.11 Maintain "rumor/question/issue log" to keep all technical liaisons apprised of issues. SRO A 2000 001 Encl. 6.4, Step 1.12 CNS JIC ERO Position Comparison and Evaluation EOF Technical Liaison Provide technical assistance for the development of news releases and statements AD-EP-ALL-0108 Att 4 Steps 8 & 27 Page 18 of 29 The steps for this task have been modified for checklist use, which is categorized as a difference.

Task has been removed and is categorized as a deviation.

This task is performed by the EOF Emergency Planner at the EOF. This change is evaluated as no reduction This task has been removed and is categorized as a deviation.

The status of the sirens is monitored continuously by both station and offsite agency personnel.

The need for an individual to monitor the siren system from the JIC during an event is not viewed as necessary.

There is no longer a JIC Regional Communicator Coordinator in the standard ERO. This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation.

This task is the responsibility of the Data Coordinator and Information Gathering Lead in the Corporate JIC. This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation.

This task is the responsibility of the Data Coordinator in the Corporate JIC. This change is evaluated as no reduction.

Revision 0 Attachment 3 EOF Technical Liaison Id Responsi Provide information in EOF Briefings concerning rumors being addressed.

SR O A 2000 001 Encl. 6.4, Step 1.2 7 Provide input for facility briefs and updates SRO A 2000 001 Encl. 6.4, Step 1.26 Gather technical information on event and document on EOF log sheets. SRO A 2000 001 Encl. 6.4, Step 1.10 Restore work area equipment and materials. SRO A 2000 001 Encl. 6.4, Step 1.10 EOF Technical Liaison Maintain event logs, forms and records. AD-EP-ALL-0108 Step 5.3 and Att 4 Step 14 Restore work area equipment and materials AD-EP-ALL-0108 Att 4 Step 35 Page 19 of 29 CNS JIC ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation.

This task is the responsibility of the Data Coordinator in the Corporate JIC. This change is evaluated as no reduction. This task has been removed and is categorized as a deviation.

Task is the responsibility of the JIC Technical Liaison. This change is evaluated as no reduction. The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 Old Title: New Title: News Manager {SR O A 2000 001, RP O B 5000 028) Information Gathering Lead {AD-EP-ALL-0108 Attachment

2) Overall Change Impact to the Position CNS JIC ERO Position Comparison and Evaluation There are changes to the span of control to this position as the Company Spokesperson, Data Coordinator, Media Monitor, News Writer and Technical Liaison now report to the Information Gathering Lead in the new Standard JIC ERO. Deviations created by the addition, removal and modification of tasks to the Information Gathering Lead position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 3 tasks were added, 8 were modified and 4 were removed News Manager Perform position turnover when a shift change occurs. SR O A 2000 001 Encl. 6.1, Step 1.15 Respond as directed when notified of an event {sign i n, get materials, etc.). SRO A 2000 001 Encl. 6.1, Steps 1.1-1.3 Prepare Public Spokesperson for news conference SRO A 2000 001 Encl. 6.1, Step 1.4 Information Gathering Lead @¥iiUi-1+i1Mlfflurt 1 ffi Perform position turnover when a shift change occurs. AD-EP-ALL-0108 Att 2 Step 25 Respond as directed when notified of an event (sign in, get materials, etc.). AD-EP-ALL-0108 Att 2 Steps 1-3 Assist the Company Spokesperson in gathering information for media briefings and interviews AD-EP-ALL-0108 Att 2 Step 18 Coordinate development of a communications strategy AD-EP-ALL-0108 Att 2 Step 4 Page 20 of 29 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation. The Lead PIO at the Corporate JIC has the overall responsibility for coordinating the development of a communications strategy and will coordinate with appropriate public information personnel.

This change is evaluated as an improvement.

Revision 0 Attachment 3 News Manager Old Responsib Provide Spokesperson's talking points/message block to Public Information Coordinator and the Public Information Manager or Media SRO A 2000 001 Encl. 6.1, Step 1.5 Prepare for news conferences with state and county Public Information Officers (PIOs): SRO A 2000 001 Encl. 6.1, Step 1.8 & 1.9 Escort and assist Public Spokesperson during all news briefings , news conferences and interviews.

SRO A 2000 001 Encl. 6.1 , Step 1.7 Perform news conference moderator/facilitator function SRO A 2000 001 Encl. 6.1 , Step 1.10 Contact NRC representatives in EOF to update them on communication activities. SR O A 2000 001 Encl. 6.1, Step 1 .12 Information Gathering Lead ew Responsibility (task Coordinate information flow to the media and public between the utility , Corporate JIC and Federal, State & local PIOs AD-EP-ALL-0108 Att 2 Steps 21 & 22 Coordinate the distribution of news releases , statements and messages AD-EP-ALL-0108 Att 2 Step 21 Manage assigned group emergency response activities AD-EP-ALL-0108 Att 2 Step 6 Coordinate the conduct of media briefings and interviews AD-EP-ALL-0108 Att 2 Step 21 Page 21 of 29 CNS JIC ERO Position Comparison and Evaluation The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

The Information Gathering Lead is responsible for managing the Information Gathering Team and coordinates with Company Spokesperson , EOF Technical Liaisons , and News Writer to coordinate distribution of messages and news releases. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. The Information Gathering Lead has the overall responsibility for the information gathering team. Adding this task specifies that responsibility. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been removed and is categorized as a deviation. This task is assigned to the Government Liaison. This change is evaluated as no reduction Revision 0 Attachment 3 News Manager 1 .... 1.sus Provide information in EOF Briefings SRO A 2000 001 Encl. 6.1, Step 1.13 Determine 24 hr staffing requirements RPO B 5000 028 Encl. 4.1 SERVE as Company Spokesperson for media exchanges until relieved by the Onsite Public Spokesperson/alternate.

RP O B 5000 028 Encl. 4.1 ESTABLISH communication with technical liaison Bridge Line to resolve rumors identified during media briefings and interviews.

RP O B 5000 028 Encl. 4.1 Maintain personal event logs, forms and records. SRO A 2000 001 Encl. 6.1, Step 1.14 Restore work area equipment and materials. SRO A 2000 001 Encl. 6.1, Step 1.16 Information Gathering Lead ew Responsibility (task Perform rumor control activities AD-EP-ALL-0108 Att 2 Step 6 Maintain personal event logs, forms and records. AD-EP-ALL-0108 Step 5.3 and Att 2 Step 24 Restore work area equipment and materials AD-EP-ALL-0108 Att 2 Step 26 Page 22 of 29 CNS JIC ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation.

The Corporate JIC personnel as well as the EOF Technical Liaison will provide information regarding JIC activities to the EOF. This change is evaluated as no reduction This task has been removed and is categorized as a deviation.

This task is the responsibility of the Logistics Lead. This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation.

A qualified Company Spokesperson will speak on behalf of Duke Energy. This change is evaluated as no reduction The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 Old Title: New Title: Public Information Coordinator (SRO A 2000 001) News Writer (AD-EP-ALL-0108 Attachment

12) Overall Change Impact to the Position CNS JIC ERO Position Comparison and Evaluation There are no changes to the span of control to this position.

The primary tasks of the News Writer remain the same. Deviations created by the addition, removal and modification of tasks to the News Writer position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS emergency plan. Specific (one-for-one)

Responsibility (task) Comparison 0 tasks were added, 6 were modified and 11 were removed Public Information Coordinator Perform position turnover when a shift change occurs. SRO A 2000 001 Encl. 6.3, Step 1.26 Respond as directed when notified of an event (sign in, get materials, etc.). SRO A 2000 001 Encl. 6.3, Step 1.1-1.3 Access JIC media bridge line SR O A 2000 001 Encl. 6.3, Step 1.5 IF additional computers are needed to support public affairs EOF response, THEN contact JIC Admin & Logistics Manager SR O A 2000 001 Encl. 6.3, Step 1.6 News Writer Perform position turnover when a shift change occurs. AD-EP-ALL-0108 Att 12 Step 18 Respond as directed when notified of an event (sign in, get materials, etc.). AD-EP-ALL-0108 Att 12 Steps 1-3 Page 23 of 29 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been removed and is categorized as a deviation.

This task is the responsibility of the Information Dissemination Lead. This change is evaluated as no reduction. This task has been removed and is categorized as a deviation.

This task is the responsibility of the Logistics Lead at the Corporate JIC. This change is evaluated as no reduction. Revision 0 Attachment 3 Public Information Coordinator Print initial news release SR O A 2000 001 Encl. 6.3, Step 1.11 Request EOF Services Admin/Commissary make copies of initial news release and distribute copies to EOF SRO A 2000 001 Encl. 6.3, Step 1.12 Access e-mail and maintain open path for emails to NRC and Charlotte JIC. SRO A 2000 001 Encl. 6.3, Step 1.13 Prepare news releases and bulleted updates by working with News Manager, Technical Liaison, and Public Spokesperson, SRO A 2000 001 Encl. 6.3, Step 1.14 Have Technical Liaison verify technical information provided in news releases.

SRO A 2000 001 Encl. 6.3, Step 1.16 Coordinate with Spokesperson or EOF Director to ensure on-site incident command center or security reviews news release/updates.

SRO A 2000 001 Encl. 6.3, Step 1.17 News Writer @4§1;J41¥J Develop news releases, statements and messages AD-EP-ALL-0108 Att 12 Step 12-14 Page 24 of 29 CNS JIC ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation.

The task of printing the initial news release is considered a part of the develop news releases, statements and messages task below. Removing it as a separate task does not change the overall responsibilities of position.

This change is evaluated as an improvement This task has been removed and is categorized as a deviation.

This task is the responsibility of the Information Dissemination Lead and Products Lead at the Corporate JIC. This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation.

This task is the responsibility of the Information Dissemination Lead at the Corporate JIC. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been removed and is categorized as a deviation.

This task is considered a part of the develop news releases, statements and messages task above. Removing it as a separate task does not change the overall responsibilities of position.

This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation.:.

This task is the responsibility of the Lead and Deputy PIOs at the Corporate JIC. This change is evaluated as no reduction.

Revision 0 Attachment 3 Public Information Coordinator Provide news release/bulleted updates to Public Spokesperson (or EOF Director, if Spokesperson not available) for review and approval SRO A 2000 001 Encl. 6.3, Step 1.18 Distribute news release/bulleted update to Pl Manager and NRC SRO A 2000 001 Encl. 6.3, Step 1.19 Coordinate with EOF Services Admin/Commissary to ensure all news releases and bulleted updates are copied and distributed within EOF: SRO A 2000 001 Encl. 6.3, Step 1.22 Ensure Media Coordinator knows name and location of file. SR O A 2000 001 Encl. 6.3, Step 1.21 Prepare Charlotte Public Spokesperson for news conference.

SR O A 2000 001 Encl. 6.3, Step 1.24 Maintain personal event logs, forms and records. SR O A 2000 001 Encl. 6.3, Step 1.25 Restore work area equipment and materials SRO A 2000 001 Encl. 6.3, Step 1.29 News Writer Coordinate distribution of news releases, statements and messages AD-EP-ALL-0108 Att 12 Step 15 Maintain event logs, forms and records. AD-EP-ALL-0108 Step 5.3 Restore work area equipment and materials AD-EP-ALL-0108 Att 12 Step 19 Page 25 of 29 CNS JIC ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation. This task is the responsibility of the Information Gathering Lead at the Corporate JIC. This change is evaluated as no reduction.

This task has been removed and is categorized as a deviation.

This task is the responsibility of the Information Dissemination Lead and Products Lead at the Corporate JIC. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been removed and is categorized as a deviation.:.

This task is the responsibility of the Information Dissemination Lead at the Corporate JIC. This change is evaluated as no reduction. This task has been removed and is categorized as a deviation.:.

This task is the responsibility of the Information Gathering Lead at the Corporate JIC. This change is evaluated as no reduction.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 4 Change Evaluation Process The changes to the ERO were evaluated from three distinct perspectives.

First, changes to the physical number and response time requirements of the ERO positions were evaluated.

Second, changes to the ERO chain of command and reporting relationships were evaluated.

Lastly, the changes to the addition, alteration or removal of responsibilities (tasks) for each ERO position were evaluated.

1. Changes to the ERO Staffing Numbers This evaluation was performed to assess whether any changes to the number of ERO positions were made (total and by response time) and to determine whether those changes impacted the licensing bases, capability or timeliness of the ERO response and performance of functions.

The addition of an ERO position is considered a deviation.

The addition of an ERO position is considered an improvement due to having additional staff to perform the work, provided it does not overload the next level supervisor/manager position.

The alteration of a position from a specific time requirement into another time requirement is considered a deviation.

The acceptability of the deviation is assessed by evaluation of the assigned tasks in Step 3 below. The deletion of a position is considered a deviation.

The acceptability of the deviation is assessed by evaluation of the assigned tasks in Step 3 below. 2. Changes to the ERO Hierarchy/

Reporting Relationships This evalu_ation was performed to assess whether any changes to the structural hierarchy or reporting relationships were made and to determine whether those changes impacted capability or timeliness of the ERO response and performance of functions.

3. Changes to an ERO Position's Responsibilities (tasks} Tasks for each ERO position in the current Emergency Plan and implementing procedures are matched to a standard ERO task list based on planning standard, function and element terminology (or identified as station specific tasks and given a unique task ID). Tasks that may have been stated in the E-Plan or procedures in general terms such as provide engineering support or manage radiological personnel may be associated with more specific task descriptions.

Tasks for each ERO position in the new organization are identified and assigned from the same task list used for the current ERO as described above. The tasks for each ERO position are organized in a table for individual comparison.

Changes to an ERO position can involve adding, removing or modifying a task. Added task -involves moving an existing task from a different ERO position, assigning a task previously performed as an undirected action (such as an inherent administrative expectation), or assigning a task that is entirely new (typically limited to when process or equipment changes are being implemented in conjunction).

Removed task -involves moving an existing task to a different ERO position or eliminating it entirely (typically limited to when process or equipment changes are being implemented in conjunction).

Modified task -involves changes in wording or sequencing that potentially affect the capability or timeliness of the task. Page 26 of 29 Revision 0 Attachment 4 Change Evaluation Process Since all ERO procedures are being converted to a checklist format for improved human factors design, all task wording has been modified to some extent. Task modifications limited to checklist format changes where step wording and sequence remains essentially unchanged are defined as differences.

Following table alignment of the added, removed and altered tasks, each comparison is categorized as a no change, difference or deviation.

Added and removed tasks are automatically categorized as deviations with regard to their impact on the ERO position in order to force further evaluation and conclusion documentation. Modified tasks may be categorized as a difference or a deviation.

Difference A difference only applies to modified tasks where the change to the wording (of either the task or its steps) does not alter the capability and/or timeliness of the function for which the task was performed.

Any change that is determined to be a difference requires no further evaluation.

Deviation A deviation is defined as a change to the wording of a task or its steps that does alter the capability and/or timeliness of the function for which the task was performed.

All added tasks and those removed tasks that are fully eliminated (no longer performed by any position) must be further evaluated in the change evaluation column to establish whether the change improved, maintained, reduced or lost the ability to perform the function.

Removed tasks that are transferred to another ERO position are evaluated as an added task. Thus, only the ERO position that the task is being moved to needs to be documented in the change evaluation column. Modified tasks categorized as deviations must be further evaluated in the change evaluation column to establish whether the change improved, maintained, reduced or lost the ability to perform the function.

For all task changes categorized as deviations, further evaluated further evaluation is performed to determine the impact on the qualities (attributes) of capability and timeliness.

Capability is defined as the quality (attribute) of being able or capable to perform the task. In order to determine an impact to capability the actions accomplished by the task must be known (what the task does). For example; assume the Steps in an existing procedure for the task to classify an event establish the actions for initial event declaration, upgrade and downgrade.

The Steps in the standard procedures for the classification task include the actions for initial event declaration and upgrade. Therefore, a deviation is created by the removal of an action (downgrading) of the task in the original procedure.

Timeliness is defined as the quality (attribute) of task duration.

The impact to timeliness can sometimes be determined by evaluating the changes to the steps, such as when one or more steps are added or removed. In other cases it may be necessary to perform the task, such as in a drill or exercise, and observe whether the change impacted the timeliness of the task. Page 27 of 29 Revision 0 Attachment 4 Change Evaluation Process 4. Completing a Comparison Table for Each ERO Position A. Identify and list the current tasks performed by the ERO position (sources can include the E-Plan, positional procedures, functional procedures, forms, etc.). 8. Identify, list and align the new tasks performed by the ERO position to each of the current tasks. 1) If a new task can be correlated to a current task, list it in the same row in the comparison table. 2) If a new task cannot be correlated to a current task, list it in a separate row in the comparison table. C. Where a current task does not align with a new task identify whether the task was added or removed and document as a deviation in the Change Evaluation column. 1) For added tasks and those removed tasks that are fully eliminated (no longer performed by any position), document an explanation and evaluation of the addition or removal that justifies the change and explicitly states whether it improves , maintains, degrades or loses the ability to perform the function.

2) For removed tasks that are transferred to another ERO position, document which position the task has been transferred to. D. Where a current task does align with a new task identify whether the task was not changed or modified in the Change Evaluation column. E. For each modified tasks identify whether the change is a difference or a deviation. 1) Review the Steps and identifying the actions that the current task does. 2) Review the Steps and identifying the actions that the new task does. NOTE: Changes to informational wording in current tasks that don't "do" anything ( content that is not actionable) do not affect the actions of the task. 3) Compare the list of actions to determine whether the new task does more or less than the current task. A. If the new task does more or less (has more or fewer actions) as compared to the current task, then categorize the change as a deviation (due to an alteration in the capability).

B. If the new task does the same actions as compared to the current task, then categorize the change as a difference. Page 28 of 29 Revision 0 Attachment 4 Change Evaluation Process NOTE: In the case where the current procedure simply states the task and the new task has added performance steps, and in consideration that there has been no change in how the actual task is performed, it is acceptable to conclude that the timeliness has not been altered. 4) Compare the steps to determine whether the new task takes more or less time to accomplish than the current task. a. If the new task takes more or less time to accomplish as compared to the current task, then categorize the change as a deviation (due to an alteration in the timeliness).

b. If the new task takes the same amount of time to accomplish as compared to the standard task, then categorize the change as a difference.

c. If it is not possible to determine whether the standard task can be accomplished in more or less time than the current task, note that further evaluation is necessary.

F. For each modified task identified as a difference, provide a brief statement for why it is considered such. G. For each modified task identified as a deviation, document an explanation and evaluation of the addition or removal that justifies the change and explicitly states whether it improves, maintains, degrades or loses the ability to perform the function.

5. Overall Change to a Position A summary of the overall impact of the task changes is documented above the comparison table for each position. Information included in the summary is as follows: A. Span of control change description for positions that manage or supervise other positions (as applicable).

8. Description of overall change impact to position.

C. Summary of task deviations.

D. Evaluation statement explicitly documenting:

1) That the deviation did not degrade the capability or timeliness to perform an associated function.

2) That no site specific commitments are adversely altered by changes to tasks assigned to this position (this statement is able to be made in the comparison document based on the results of the commitment search recorded on the §50.54(q) evaluation form). 3) That the changes do not reduce the effectiveness of the emergency plan. Page 29 of 29 Revision O

Enclosure 3 EOF ERO Position Comparison and Evaluation

DUKE '-' ENERGY Corporate Emergency Operations Facility ~==----------=-

~ (CEO F) Duke Energy ERO Standardization EOF ERO Position Comparison and Evaluation Revision 0 CEOF ERO Position Comparison and Evaluation Table of Contents 1 PURPOSE ......................................................

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

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

3 2 DISCUSSION

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

3 3

SUMMARY

OF CHANGES .............................................................................................

4 3.1 Comparison of ERO Positions, Responders and Response Times .................................

.4 3.1.1 Numeric Change Impact to the Augmented ERO ................................................

.4 3.1.2 Response Time Impact to the Augmented ERO ..................................................

.4 3.2 Comparison of the ERO Hierarchy/

Reporting Relationships

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

5 3.3 Comparison of ERO Responsibilities by Position ............................................................

5 Attachments Attachment 1, CEOF ERO Staffing Depth Comparison

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

.......... 6 Attachment 2, CEOF Organizational Comparison of the ERO Hierarchy

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

9 Attachment 3, CEOF ERO Position Comparison and Ev~luation

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

11 Attachment 4, Change Evaluation Process ...............................................................................

47 Page 2 of 50 Revision 0 CEOF ERO Position Comparison and Evaluation 1 PURPOSE Identify differences and deviations between the current EOF ERO and the Duke standard ERO from the EOF. Evaluate all deviations to determine whether they create a reduction in effectiveness (RIE) in the current station Emergency Preparedness Program. 2 DISCUSSION A program initiative has been undertaken by Duke Energy personnel to standardize the ERO positions, functions and responsibilities (tasks) across the fleet. This involves changes to the current ERO, which for this evaluation is based upon those responder titles and numbers identified in emergency plan and the implementing procedures.

It is recognized that any changes to the ERO structure and the implementing procedures require a detailed §50.54(q) effectiveness evaluation.

Regulatory Guide 1.219 provides the following information related specifically to this type of change: [G.1.1.b]

Some changes that a licensee may make to its approved emergency plan warrant prior NRG approval to ensure that the changes would not adversely affect the NRG's reasonable assurance determination.

However, other general types of changes may have such a minimal effect on this determination that they would not warrant prior NRG approval.

For example, changes that reduce the number of personnel available to respond to emergencies or lengthen the time it takes to staff and activate emergency response facilities (ERFs) could affect the NRG's reasonable assurance determination and would require prior NRG staff approval.

Minor administrative changes, such as correcting position titles and spelling errors and updating document numbers, would not warrant prior NRG staff review." Between these extremes is a range of possible changes for which the licensee is required to perform and document a detailed, objective evaluation.

[G.1.4.a]

.... Proposed changes that could delay emergency declarations, notifications, or PARs may reduce the effectiveness of the emergency plan in that subsequent emergency response actions may not be timely and emergency response personnel, facilities, and equipment may not be in position if it becomes necessary to carry out measures to protect the public health and safety. Generally, the licensee should view any change that could delay an activity or relax a timeliness criterion for the activity as a potential reduction in effectiveness and should evaluate it accordingly.

Due to the scope of changes being made, this position to position and task to task comparison evaluation has been developed to document the effectiveness review. Attachment 4 documents the methods used to conduct this evaluation.

Page 3 of 50 Revision 0 CEOF ERO Position Comparison and Evaluation 3

SUMMARY

OF CHANGES 3.1 Comparison of ERO Positions, Responders and Response Times The total number of responders filling augmented ERO positions in the current EOF ERO is 16 and the total number of responders filling augmented ERO positions in the standard ERO is 16 (no difference).

75 Minute ERO Responders:

The current augmented EOF ERO has five (5) 75 minute responders and the standard augmented EOF ERO has five (5) 75 minute responders (no difference).

Full Staffing ERO Responders:

The current augmented EOF ERO has eleven (11) fixed full staff responders and the standard augmented EOF ERO has eleven (11) fixed full staff responders (no difference).

The number of EOC Liaisons is dependent upon the site (personnel are sent to each risk county and state EOC). Current EOF Duke Difference Standard 75 Minute 5 5 0 Full Staffing 11 11 0 Total 16 16 0 3.1.1 Numeric Change Impact to the Augmented ERO There is no change to the numeric EOF ERO responders.

The Ops Interface, a full staff position, is removed.

An additional Dose Assessor is added as a full staff position.

3.1.2 Response

Time Impact to the Augmented ERO The change results in same number of 75 minute responder.

The Accident Assessment Manager position is changed from a full staffing to a 75 minute position.

The Dose Assessor position is changed from a 75 minute to a full staffing position.

The change results in same number of full staffing responders.

In practice, all ERO members are called out at the same time and respond as soon as possible.

This provides for the quickest response and offers the ability to adjust ERO personnel resources as the specific conditions of the event warrant. The numeric and response time changes resulting from the adoption of the standard ERO establish a closer relationship between risk significant/

key functions and the positions assigned those responsibilities.

The objective of these changes is to ensure those functions and their processes are linked directly to the augmented minimum staffing positions to allow for optimum relief of on shift personnel and less complicated response execution following facility activation.

Page 4 of 50 Revision 0 CEOF ERO Position Comparison and Evaluation Collectively and individually the changes to the EOF ERO in the adoption of the Duke standard ERO do not decrease the capability or the timeliness of the ERO to perform their assigned tasks. No site specific commitments regarding particular ERO positions, tasks or their response time were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Refer to Attachment 1 for a position-by-position comparison of the current and standard EOF ERO responders sorted by title and by function.

3.2 Comparison

of the ERO Hierarchy/

Reporting Relationships In the adoption of the standard ERO, EOF facility staffing continues to be grouped by major functions.

In general, each of the directors, managers and supervisors/coordinators in the standard ERO maintain their span of control. Summary descriptions of the changes to the EOF ERO reporting hierarchy are as follows:

All risk significant functions (classification, notification, protective actions and assessment) are assigned to minimum staffing positions aligned within the hierarchy.

The Assistant EOF Director position has been formalized.

This allows the facility lead to maintain an oversight and coordination role while the assistant's focus can be on facility operations.

The organizational/hierarchical changes improve the reporting relationships and management levels of the ERO and streamline the process path for risk significant functions.

The organizational/hierarchical changes do not overload the next level supervisor/manager positions. The organizational/hierarchical changes do not decrease the capability or the timeliness of the ERO to perform their assigned tasks. No site specific commitments regarding a particular ERO hierarchy were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Refer to Attachment 2 for a comparison of the organization charts illustrating the current augmented EOF ERO and the standard augmented EOF ERO. 3.3 Comparison of ERO Responsibilities by Position Deviations created by the addition, removal or modification of a task to a particular ERO position did not degraded the capability or timeliness to perform that associated function.

No site specific commitments regarding a particular ERO task assignment were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Refer to Attachment 3 for comparisons and evaluations of added, removed and modified tasks between the current augmented EOF ERO and the Duke standard augmented EOF ERO. Page 5 of 50 Revision 0 Attachment 1 CEOF ERO Staffing Depth Comparison Augmented EOF ERO Comparison by Facility Current EOF ERO Position Title 75 Full Standard EOF ERO Position Title 75 Full EOF Director 1 EOF Director 1 Assistant EOF Director 1 Assistant EOF Director 1 Offsite Agency Communicator 2 Offsite Communicator 2 LoQ Recorder 1 Log Keeper 1 Data Coordinator 1 Data Coordinator 1 EmerQencv Planner 1 EmerQencv Planner 1 State & County EOC Liaisons (a) State & County EOC Liaisons (a) Accident Assessment Manaqer 1 Accident Assessment Manager 1 Accident Assessment Interface 1 Accident Assessment Interface 1 Ops Interface 1 Rad Assessment Manager 1 Rad Assessment Manager 1 Dose Assessor 1 Dose Assessor 2 EOF Director 1 FMT Goordinator 2 Radio Operator 1 Services Manager 1 Services Manager 1 Services Admin/Commissary 1 Services Admin/Commissary 1 Total Augmenting EOF ERO 5 11 5 11 (a) Number of EOC Liaisons is dependent on the site (personnel are sent to each of the at risk county and state EOCs) Page 6 of 50 Revision 0 Attachment 1 CEOF ERO Staffing Depth Comparison Augmented EOF ERO Comparison by Function C: -~ C: -~ -111 -111 Functional Area Major Tasks Current ERO Emergency Positions It) *-::::, ... Standard ERO Emergency Positions It) *-::::, ... ..... :ii!: LL en ..... :!!: LL en 2. Direction and Control Command and Control . _EOF _Director (EOF) 1 --*--EOF Director (EOF) 1 Facility Control Assistant EOF Director (EOF) 1 Assistant EOF Director (EOF) 1 Function 2 Totals: 1 1 1 1 3. Notification

& Comm. Emergency Offsite Agency Communicator (EOF) 2 Offsite Communicator (EOF) 2 Communications

---*----------*

-----*-*---*-

Plant Status & State & County EOC Liaisons (EOF) (a) State & County EOC Liaisons (EOF) (a) Technical Activities Function 3 Totals: 2 2 4. Radiological Offsite Dose Dose Assessor (EOF) 1 Dose Assessor (EOF) 2 Assessment Assessment

------*------**-***--*------*---**----

.. --**------

Offsite Surveys £MT Coordinator (EOF) 1 FMT Coordinator (EOF) 2 --------*

_ Radio Oeerator (EOF). 1 -------RP Supervisory Rad Assessment Manager (EOF) 1 Rad Assessment Manager (EOF) 1 Function 4 Totals: 2 2 1 4 5. Plant System Eng, Technical Support/ Accident Assessment Manager (EOF)_ 1 _Accident Assessment M_~nag_er (EOF) 1 Repair, and Accident Analysis *--* --~~cident Assessment lnterf~.ce (EOF)_ 1 .Accident Assessment Interface (EOF) __ 1 Corrective Actions ------* Operations Interface (EOF) 1 Function 5 Totals: 0 3 1 1 8. Resource Allocation Administration Log Recorder (~9F). 1 Log Keeeer (EOF) 1 and Admin . ---* Services Manager (EOF) 1 Services Manager (EOF) ________ 1 **--***-**------**-***---**--*---

--Facility Operations Emergmy Planner(~

_,, ___ . 1 Emil_!:gency Planner (EOF). 1 --* *-*-Data Coordinator (EOF). 1 Data Coordinator (EOF). 1 Services Adm in/Commissary (EOF) 1 Services Admin/Commissary (EOF) 1 Function 8 Totals: 0 5 0 5 TOTAL: 5 11 5 11 (a) Number of EOC Liaisons is dependent on the site (personnel are sent to each of the at risk county and state EOCs) Page 7 of 50 Revision 0 Attachment 1 CEOF ERO Staffing Depth Comparison

1. Addition and Removal of Positions and Responders 1.1. The total number of responders filling augmented ERO positions in the current EOF ERO is 16 and the total number of responders filling augmented ERO positions in the standard ERO is 16 ( no difference).

1.1.1. One (1) responder is added to the EOF ERO. 1) Dose Assessor (full staff) 1.1.2. One (1) responder is removed from the EOF ERO. 1) Ops Interface (full staff) 2. Alteration of ERO Response Times 2.1. 75 Minute Response: The current augmented EOF ERO has five (5) 75 minute responders and the standard augmented EOF ERO has five (5) 75 minute responders (no difference).

2.1.1. One (1) responder is moved from full staff to 75 minute response (+1 ):

Accident Assessment Manager 2.1.2. One ( 1) responder is moved from 75 mihute to full staff response (-1 ):

Dose Assessor 2.2. Full Staffing:

The current augmented EOF ERO has eleven (11) full staff responders and the standard augmented ERO has eleven (11) full staff responders (no difference).

2.2.1. One (1) responder is moved from 75 minute to full staff response (+1 ):

Dose Assessor 2.2.2. One (1) responder is removed by the elimination of one full staff position (-1 ):

Ops Interface Page 8 of 50 Revision 0 Attachment 2 CEOF Organizational Comparison of the ERO Hierarchy Current Corporate EOF Organization I Accident Assmt Manager i---Accident Assmt Interface OPs Interface EOF Director 75min Assistant EOF Director ,-.+---Log Recorder Data Coordinator 1-1--Emergency Planner ----I 1 I State & County EOC Liaison (# site specific}

I Rad Assessment Manager 75 min wrrs1te A'gency Communicator (2) Services Manager i--Dose Assessor 75min LJ ~T Coordinator I --FMT Radio Operator Page 9 of 50 75min -Services Administration/

Commissary Revision 0 Attachment 2 Standard EOF Organization I -Accident Assmt M;~;ger** 75 min -Accident Assmt Interface I I I EOF Director 75 min Assistant EOF Director CEOF Organizational Comparison of the ERO Hierarchy Log Keeper Data Coordinator Emergency Planner I Rad Assessment Manager 75 min Dose Assessor (2) i......-.

FMT Coordinator (2) r--State & County EOC ---Liaison (# site specific)

T Offsite Communicator (2) l 75min _L Services Manager Services Administration/

-Commissary Page 10 of 50 Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: EOF Director (SR/O/A/2000/003 R14 Enclosure 6.1) New Title: EOF Director (AD-EP-ALL-0103 Attachment

1) Overall Change Impact to the Position The span of control for this position did not change. The EOF Director and the Assistant EOF Director are equally qualified and are interchangeable.

The Assistant EOF Director typically acts as an EOF manager more typical of industry practices, which allows the EOF Director greater attention on overall response activities in all facilities (site, JIC and EOF) and less attention on EOF operation and administration.

Deviations created by the addition, removal or modification of tasks to the EOF Director position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 4 tasks were added, 25 were modified and 2 were removed. EOF Director Old Respons Coordinate response activities with offsite response agencies (EM, ICP, Field Mon, etc.) Verify that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list has been completed Coordinate ERO/facility shift turnover Perform position turnover when a shift change occurs Assume/maintain command and control Transfer command and control Manage facility emergency response activities EOF Director New Respon Coordinate response activities with offsite response agencies (EM, ICP, Field Mon, etc.) AD-EP-ALL-0103 Att 1 Step 3.1 Verify that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list has been completed AD-EP-ALL-0103 Att 1 Step 2.1.12 Coordinate ERO/facility shift turnover AD-EP-ALL-0103 Att 1 Step 2.5 Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 1 Step 2.5 Assume/maintain command and control AD-EP-ALL-0103 Att 1 Step 1.4 Transfer command and control AD-EP-ALL-0103 Att 1 Step 1.4 Manage facility emergency response activities AD-EP-ALL-0103 Att 1 Step 1.3, 2.1 Page 11 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 EOF Director Respond as directed when notified of an event (sign in, get materials, etc.) Coordinate integration of the NRG site team Request Federal support and resources Assist with emergency classification CEOF ERO Position Comparison and Evaluation EOF Director Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0103 Att 1 Step 1.1 Coordinate integration of the NRG site team AD-EP-ALL-0103 Att 1 Step 2.1.15 Prioritize and authorize requests for external assistance (technical, craft, admin, etc.) AD-EP-ALL-0103 Att 1 Step 2.1.18 Approve equipment, supply, and logistics expenditures for response to the event AD-EP-ALL-0103 Att 1 Step 2.1.4 Request Federal support and resources AD-EP-ALL-0103 Att 1 Step 2.1.18 Assist with emergency classification AD-EP-ALL-0103 Att 1 Step 2.1.8 Page 12 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

Current implementing procedures do not explicitly include this task although the EOF Director, as the individual responsible for the overall response, does control prioritization and authorization of requests for external assistance. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation. Current implementing procedures do not explicitly include this task although the EOF Director, as the individual responsible for the overall response, does control prioritization and authorization of requests for external assistance.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation EOF Director EOF Director Approve and direct offsite emergency notifications I Approve and direct offsite emergency notifications to state and local authorities to state and local authorities AD-EP-ALL-0103 Att 1 Step 2.2 Establish communications with Emergency Coordinator or Assistant Emergency Coordinator in the TSC Communicate plant status to County Directors of Emergency Management , State Liaisons or State Directors Perform or direct emergency PA announcements Provide technical assistance for the development of news releases and statements Verify EOF minimum staffing positions are prepared to assume their EOF duties. Determine current/projected staff needs Ensure facility staff is prepared to perform their activities (facility ready) Activate the facility (facility activated)

Ensure flow of i nformation within and between the emergency response facilities AD-EP-ALL-0103 Att 1 Step 2.1.8 Perform or direct emergency PA announcements AD-EP-ALL-0103 Att 1 Step 2.1.3 Provide technical assistance for the development of news releases and statements AD-EP-ALL-0103 Att 1 Step 2.1.10 Ensure minimum staff is available (facility staffed) AD-EP-ALL-0103 Att 1 Step 1.3 Determine current/projected staff needs AD-EP-ALL-0103 Att 1 Step 1.3 Ensure facility staff is prepared to perform the i r activities (facility ready) AD-EP-ALL-0103 Att 1 Step 1.3 Activate the facility (facility activated)

AD-EP-ALL-0 1 03 Att 1 Step 1.3 Page 13 of 50 The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a d i fference. The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 EOF Director Determine and direct the actions for mitigation strategies and contingency plans Approve offsite Protective Action Recommendations Terminate the emergency event Develop recovery plans Conduct facility briefs and updates Maintain event logs , forms and records SR/0/ A/2000/003 Step 3.1 .1 CEOF ERO Position Comparison and Evaluation EOF Director Direct/coordinate facility relocation AD-EP-ALL-0103 Att 1 Step 3.3 Determine and direct the actions for m i tigation strategies and contingency plans AD-EP-ALL-0103 Att 1 Step 2.1.8 Approve offsite Protective Action Recommendations AD-EP-ALL-0103 Att 1 Step 2.3 Terminate the emergency event OPEP-02.6.27 , Step 2.4 Develop recovery plans OPEP-02.6.27 , Step 2.4 AD-EP-ALL-0110 Conduct facility briefs and updates OPEP-02.6.27 , Step 2.1.9 Maintain event logs , forms and records AD-EP-ALL-0103 Att 1 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0103 Att 1 Step 4.0 Page 14 of 50 This task has been added and is categorized as a deviation.

Current implementing procedures do not explicitly include this task although the EOF Director , as the individual responsible for the overall response, they would make decision of facility relocat i on. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which i s categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation. This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 3 EOF Director [*)P*dME Maintain status and information boards/displays Authorize emergency worker extensions if the radiation exposure doses are expected to exceed the blanket dose extension limits EOF Director Page 15 of 50 CEOF ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation.

Maintaining status boards is an administrative task assigned to several subordinates. This change is evaluated as an improvement.

This task has been removed and is categorized as a deviation.

Approval of emergency exposures remains with the site Emergency Coordinator.

Personnel performing FMT activities are assigned by the site. This change is evaluated as an improvement.

Revision 0 Attachment 3 Old Title: New Title: Assistant EOF Director (SR/O/A/2000/003 R14 Enclosure 6.1) Assistant EOF Director (AD-EP-ALL-0103 Attachment

1) Overall Change Impact to the Position This positon does not have an organizational span of control. CEOF ERO Position Comparison and Evaluation The EOF Director and the Assistant EOF Director are equally qualified and *are interchangeable.

The standard ERO develops the Assistant EOF Director position as an EOF manager more typical of industry practices.

Tasks added to the Assistant EOF Director position involve specifying tasks previously implied under more generalized task wording and EOF Director equivalent tasks. Deviations created by the addition, removal and modification of tasks to the Assistant EOF Director position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 4 tasks were added, 25 were modified and 2 were removed. EOF Director Coordinate response activities with offsite response agencies (EM , ICP , Field Mon , etc.) Verify that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list has been completed Coordinate ERO/facility shift turnover Perform position turnover when a shift change occurs Assume/maintain command and control Transfer command and control Assistant EOF Director Coordinate response activities with offsite response agencies (EM , ICP , Field Mon , etc.) AD-EP-ALL-0103 Att 1 Step 3.1 Verify that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list has been completed AD-EP-ALL-0103 Att 1 Step 2.1.12 Coordinate ERO/facility shift turnover AD-EP-ALL-0103 Att 1 Step 2.5 Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 1 Step 2.5 Assume/maintain command and control AD-EP-ALL-0103 Att 1 Step 1.4 Transfer command and control AD-EP-ALL-0103 Att 1 Step 1.4 Page 16 of 50 The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 EOF Director Manage facility emergency response activities Respond as directed when notified of an event (sign in, get materials, etc.) Coordinate integration of the NRC site team Request Federal support and resources CEOF ERO Position Comparison and Evaluation Assistant EOF Director Manage facility emergency response activities AD-EP-ALL-0103 Att 1 Step 1.3, 2.1 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0103 Att 1 Step 1.1 Coordinate integration of the NRC site team AD-EP-ALL-0103 Att 1 Step 2.1.15 Prioritize and authorize requests for external assistance (technical, craft, admin , etc.) AD-EP-ALL-0103 Att 1 Step 2.1 .18 Approve equipment, supply, and logistics expenditures for response to the event AD-EP-ALL-0103 Att 1 Step 2.1.4 Request Federal support and resources AD-EP-ALL-0103 Att 1 Step 2.1.18 Page 17 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation. Current implementing procedures do not explicitly include this task although the EOF Director, as the individual responsible for the overall response, does control prioritization and authorization of requests for external assistance. This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Current implementing procedures do not explicitly include this task although the EOF Director, as the individual responsible for the overall response, does control prioritization and authorization of requests for external assistance.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. ft does not change the execution of response activities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation EOF Director Assist with emergency classification Assistant EOF Director Assist with emergency classification AD-EP-ALL-0103 Att 1 Step 2.1 .8 Approve and direct offsite emergency notifications I Approve and direct offsite emergency notifications to state and local authorities to state and local authorities AD-EP-ALL-0103 Att 1 Step 2.2 Establish communications with Emergency Coordinator or Assistant Emergency Coordinator in the TSCF Perform or direct emergency PA announcements Provide technical assistance for the development of news releases and statements Verify EOF minimum staffing positions are prepared to assume their EOF duties. Determine current/projected staff needs Ensure facility staff is prepared to perform their activities (facility ready) Activate the facility (facility activated)

Ensure flow of information within and between the emergency response facilities AD-EP-ALL-0103 Att 1 Step 2.1.8 Perform or direct emergency PA announcements AD-EP-ALL-0103 Att 1 Step 2.1.3 Provide technical assistance for the development of news releases and statements AD-EP-ALL-0103 Att 1 Step 2.1.10 Ensure minimum staff is available (facility staffed) AD-EP-ALL-0103 Att 1 Step 1.3 Determine current/projected staff needs AD-EP-ALL-0103 Att 1 Step 1.3 Ensure facility staff is prepared to perform their activities (facility ready) AD-EP-ALL-0103 Att 1 Step 1.3 Activate the facility (facility activated)

AD-EP-ALL-0103 Att 1 Step 1.3 Page 18 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 EOF Director Determine and direct the actions for mitigation strategies and contingency plans Approve offsite Protective Action Recommendations Term i nate the emergency event Develop recovery plans Conduct facility briefs and updates Maintain event logs , forms and records SR/O/A/2000/003 Step 3.1.1 CEOF ERO Position Comparison and Evaluation Assistant EOF Director New Responsibility (ta DirecUcoordinate facility relocation AD-EP-ALL-0103 Att 1 Step 3.3 Determine and direct the actions for mit i gation strategies and contingency plans AD-EP-ALL-0103 Att 1 Step 2.1.8 Approve offsite Protective Action Recommendations AD-EP-ALL-0103 Att 1 Step 2.3 Terminate the emergency even t OPEP-02.6.27 , Step 2.4 Develop recovery plans OPEP-02.6.27 , Step 2.4 AD-EP-ALL-0110 Conduct facility briefs and updates OPEP-02.6.27 , Step 2.1.9 Maintain event logs , forms and records AD-EP-ALL-0103 Att 1 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0103 Att 1 Step 4.0 Page 19 of 50 This task has been added and is categorized as a deviation. Current implementing procedures do not explicitly include this task although the EOF Director , as the individual responsible for the overall response , they would make decision of facility relocation.

This change formally documents the task as a specific activity to improve checklist detail and task training clarity. It does not change the execution of response activities. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation. This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 3 EOF Director Maintain status and information boards/displays Authorize emergency worker extensions if the radiation exposure doses are expected to exceed the blanket dose extension limits Assistant EOF Director Page 20 of 50 CEOF ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation.

Maintaining status boards is an administrative task now assigned to several subordinates.

This change is evaluated as an improvement.

This task has been removed and is categorized as a deviation.

Approval of emergency exposures remains with the site Emergency Coordinator.

Personnel performing FMT activities are assigned by the site. This change is evaluated as an improvement.

Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: Log Recorder (SR/O/A/2000/003 R14 Enclosure 6.16) New Title: Log Keeper (AD-EP-ALL-0103 Attachment

10) Overall Change Impact to the Position Changes to the Log Keeper tasks were minor and primarily differences.

Deviations created by the modification of tasks to the Log Keeper position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 1 tasks were added, 6 were modified and O were removed. Perform position turnover when a shift change occurs Respond as directed when notified of an event (sign in, get materials, etc.) Prepare for facility activation (rooms, work area, equipment, etc.) Maintain status and information boards/displays Maintain event logs, forms and records Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 10 Step 2.2 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0103 Att 10 Step 1.1 Prepare for facility activation (rooms, work area, equipment, etc.) AD-EP-ALL-0103 Att 10 Step 1.2 Distribute forms, reports, etc. as needed AD-EP-ALL-0103 Att 10 Step 2.1 Maintain status and information boards/displays AD-EP-ALL-0103 Att 10 Step 2.1 Maintain event logs, forms and records AD-EP-ALL-0103 Att 10 Step 1.1 Page 21 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

This administrative action is now specified.

Log Keeper provides information electronically and may be called on to distribute information through alternate media. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 Restore work area equipment and materials Restore work area equipment and materials AD-EP-ALL-0103 Att 10 Step 4.0 Page 22 of 50 CEOF ERO Position Comparison and Evaluation The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: New Title: Data Coordinator (SR/O/A/2000/003 R14 Enclosure 6.17) Data Coordinator (AD-EP-ALL-0103 Attachment

11) Overall Change Impact to the Position Changes to the Data Coordinator tasks were differences.

No deviations were created by the modification of tasks to the Data Coordinator position.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 0 tasks were added, 5 were modified and O were removed. Data Coordinator Perform position turnover when a shift change occurs Respond as directed when notified of an event (sign in, get materials, etc.) Monitor facility equipment (computer , communications, etc.) for proper operation Maintain event logs, forms and records SR/O/A/2000/003 Step 3.1.1 Restore work area equipment and materials Data Coordinator Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 11 Step 2.2 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0103 Att 11 Step 1.1 Monitor facility equipment (computer, communications, etc.) for proper operation AD-EP-ALL-0103 Att 11 Step 1.2 and 2.1 Maintain event logs, forms and records AD-EP-ALL-0103 Att 11 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0103 Att 11 Step 4.0 Page 23 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: Emergency Planner (SR/O/A/2000/003 R14 Enclosure 6.15) New Title: Emergency Planner (AD-EP-ALL-0103 Attachment

9) Overall Change Impact to the Position Changes to the Emergency Planner tasks were minor and primarily differences.

Previous procedures had very general actions for the Emergency Preparedness Representative in the EOF to provide support and ensure procedure compliance in the facility.

The new task list is more specific, but the position performs the same functions in assisting the EOF Director with key EP functions.

Tasks added to the Emergency Planner position involve current common undirected administrative actions, specifying tasks previously implied under more generalized task wording, and NRC site team interface.

Deviations created by the addition of tasks to the Emergency Planner position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 2 tasks were added, 8 were modified and 1 were removed. Emergency Planner Perform position turnover when a shift change occurs Respond as directed when notified of an event (sign i n , get materials , etc.) Interface with federal , state and local agencies Emergency Planner New Responsibility Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 9 Step 2.2 Respond as directed when notified of an event (sign in , get materials, etc.) AD-EP-ALL-0103 Att 9 Step 1.1 Coordinate information and act i vities with offsite agency personnel i n the facility AD-EP-ALL-0103 Att 9 Step 2.1.4 Coordinate integration of the NRC s i te team AD-EP-ALL-0103 Att 9 Step 3.1 Page 24 of 50 The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference.

This task has been added and is categorized as a deviation. Emergency Planner now assist the EOF Director and Assistant EOF Director with this task This change is evaluated as an improvement.

Revision 0 Attachment 3 Support completion of the ENF to state and local authorities Prepare for facility activation (rooms , work area , equipment , etc.) Provide input for facility briefs and updates Maintain event logs , forms and records SR/O/A/2000/003 Step 3.1.1 Restore work area equipment and materials Complete 24 Hour Position Staffing Log CEOF ERO Position Comparison and Evaluation Support State/County EOG Liaisons AD-EP-ALL-0103 Att 9 Step 2.1.4 Support completion of the ENF to state and local authorities AD-EP-ALL-0103 Att 9 Step 2.1.4 Prepare for facility activation (rooms , work area, equipment , etc.) AD-EP-ALL-0103 Att 9 Step 1.2 Provide input for facility br i efs and updates AD-EP-ALL-0103 Att 9 Step 2.1.8 Maintain event logs , forms and records AD-EP-ALL-0103 Att 9 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0103 Att 9 Step 4.0 Page 25 of 50 This task has been added and is categorized as a deviation. Emergency Planner now primary point of contact for EOG Liaisons. Previous procedures did not specify who communicated with liaisons. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been removed and is categorized as a deviation. Task has been transferred to the Services Admin I Commissary position. Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: State & County EOC Liaisons New Title: State & County EOC Liaisons (AD-EP-ALL-0103 Attachment

17) Overall Change Impact to the Position No task changes were made to the CNS, MNS and ONS State & County EOC Liaisons as part of the adoption of Standard ERO. Page 26 of ~o Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: New Title: Accident Assessment Manager (SR/O/A/2000/003 R14 Enclosure 6.12) Accident Assessment Manager (AD-EP-ALL-0103 Attachment

7) Overall Change Impact to the Position Changes to the Accident Assessment Manager tasks were minor and primarily differences.

Deviations created by the addition of tasks to the Accident Assessment Manager position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 3 tasks were added, 7 were modified and O were removed. Accident Assessment Manager Old Responsibility (ta Perform position turnover when a shift change occurs Respond as directed when notified of an event (sign in, get materials, etc.) Assist with emergency classification Accident Assessment Manager l~tfidM*t*

1 Mlffl6d 1 ffi Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 7 Step 2.2 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0103 Att 7 Step 1.1 Develop requests and coordinate external assistance (technical, craft , admin , etc.) AD-EP-ALL-0103 Att 7 Step 2.1.6 Arrange for equipment and supply resources AD-EP-ALL-0103 Att 7 Step 2.1.6 Assist with emergency classification AD-EP-ALL-0103 Att 7 Step 1.2.3 Perform event detection and assessment activities I Perform event detection and assessment activities AD-EP-ALL-0103 Att 7 Step 2._1.5 Page 27 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation. This administrative action to assist in obtaining needed assistance from outside sources. This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

This administrative action is to obtain any needed supplies to perform assigned tasks. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Accident Assessment Manager Accident Assessment Manager Pair!l~J.i&.0.4.i&IMHMIM

@¥i;JM+i1Mlfflffdtffii Evaluate conditions and develop offsite Protective I Evaluate conditions and develop offsite Protective Action Recommendations Action Recommendations AD-EP-ALL-0103 Att 7 Step 2 .. 1.3 The steps for this task have been modified for checklist use, which is categorized as a difference. Provide input for facility briefs and updates Maintain event logs, forms and records SR/O/A/2000/003 Step 3.1.1 Provide input for facility briefs and updates AD-EP-ALL-0103 Att 7 Step 2.1. 7 Maintain event logs, forms and records AD-EP-ALL-0103 Att 7 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0103 Att 7 Step 4.0 Page 28 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: New Title: Accident Assessment Interface (SR/O/A/2000/003 R14 Enclosure 6.13) Accident Assessment Interface (AD-EP-ALL-0103 Attachment

8) Overall Change Impact to the Position Changes to the Accident Assessment Interface tasks were minor and mostly associated with providing clearer definition of the position in an operations related communications role. Tasks added to the Accident Assessment Interface position involve current common undirected administrative actions and BOB support actions. Deviations created by the addition of tasks to the Accident Assessment Interface position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 2 tasks were added, 11 were modified and O were removed. Accident Assessment Interface Perform position turnover when a shift change occurs Monitor status of the Emergency Operations Procedures Respond as directed when notified of an event (sign in, get materials , etc.) Assist with emergency classification Communicate on assigned communication line and provide information to facility staff Monitor status and information boards/displays/systems Maintain status and information boards/displays Accident Assessment Interface Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 8 Step 2.2 Monitor status of the Emergency Operations Procedures AD-EP-ALL-0103 Att 8 Step 2.1.4 Respond as directed when notified of an event (sign in , get materials, etc.) AD-EP-ALL-0103 Att 8 Step 1.1 Assist with emergency classification AD-EP-ALL-0103 Att 8 Step 2.1 Communicate on assigned communication line and provide information to facility staff AD-EP-ALL-0103 Att 8 Step 1.2.3 Monitor status and information boards/displays/systems AD-EP-ALL-0103 Att 8 Step 2.1 Maintain status and information boards/displays AD-EP-ALL-0103 Att 8 Step 2.1 Page 29 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Accident Assessment Interface Accident Assessment Interface New Responsibility (task Perform event detection and assessment activities I Perform event detection and assessment activities AD-EP-ALL-0103 Att 8 Step 2.1 Perform event detection and assessment activities I Provide analysis of core damage and fission product release potential Analyze and develop extreme measures actions (FLEX , EDMG , SAMG, §50.54(x))

Maintain event logs, forms and records SR/O/A/2000/003 Step 3.1.1 AD-EP-ALL-0103 Att 8 Step 2.1.2 Evaluate cond i tions and develop offsite Protective Action Recommendations AD-EP-ALL-0103 Att 8 Step 2.1. 7 Analyze and develop extreme measures actions (FLEX , EDMG , SAMG, §50.54(x)) AD-EP-ALL-0103 Att 8 Step 2.1.6 Maintain event logs , forms and records AD-EP-ALL-0103 Att 8 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0103 Att 8 Step 4.0 Page 30 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

Accident Assessment Interface works with Accident Assessment Manager to assist EOF Director in determining PAR. This task was not previously identified in procedure.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation.

This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 3 Old Title: New Title: Ops Interface (SR/O/A/2000/003 R14, Enclosure 6.14) No equivalent position in the standard ERO Overall Change Impact to the Position Position not part of the standard ERO. CEOF ERO Position Comparison and Evaluation All tasks previously assigned to the Ops Interface position are performed by other positions.

Deviations created by the removal of the Ops Interface position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS and MNS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 0 tasks was transferred, 5 are performed by other ERO positions, and 4 were common task eliminated with the position.

Ops Interface Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials, etc.). Establish and monitor communications on the Ops bridge line and provide updates. Monitor status of the Emergency Operations Procedures.

Assist with emergency classification.

Provide support for accident detection and assessment.

Page 31 of 50 Common Task for all ERO Members Common Task for all ERO Members This task has been removed and is categorized as a deviation.

Task performed by Accident Assessment Interface. This task has been removed and is categorized as a deviation. Task performed by Accident Assessment Interface.

This task has been removed and is categorized as a deviation. Task performed by Accident Assessment Manager and Accident Assessment Interface This task has been removed and is categorized as a deviation.

Task performed by Accident Assessment Manager and Accident Assessment Interface Revision 0 Attachment 3 Ops Interface Assist in the development of mitigative strategies based on assessment of the event. Maintain personal event logs, forms and records. Turn in logs/forms and restore area/materials upon event termination. Page 32 of 50 CEOF ERO Position Comparison and Evaluation This task has been removed and is categorized as a deviation.

Task performed by Accident Assessment Manager and Accident Assessment Interface Common Task for all ERO Members Common Task for all ERO Members Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: New Title: Radiological Assessment Manager (SR/O/A/2000/003 R14 Enclosure 6.6) Radiological Assessment Manager (AD-EP-ALL-0103 Attachment

2) Overall Change Impact to the Position The span of control for this position changes from 3 to 4 ERO positions.

The task added to the Radiological Assessment Manager position involves post plume environmental survey and sample activities.

The tasks removed involved radiological actions not applicable to the corporate EOF. Deviations created by the addition, removal and modification of tasks to the Radiological Assessment Manager position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 4 tasks were added, 11 were modified and O were removed. Radiological Controls Manager ,_,,,. -Perform position turnover when a shift change occurs Manage assigned group emergency response activities Respond as directed when notified of an event (sign in, get materials, etc.) Assist with emergency classification Support completion of the ENF to state and local authorities Radiological Assessment Manager New Responsibility (task) Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 2 Step 2.4 Manage assigned group emergency response activities AD-EP-ALL-0103 Att 2 Step 2.1 Respond as directed when notified of an event (sign in, get materials , etc.) AD-EP-ALL-0103 Att 2 Step 1.1 Develop requests and coordinate external assistance (technical, craft, admin, etc.) AD-EP-ALL-0103 Att 2 Step 2.1.8 Assist with emergency classification AD-EP-ALL-0103 Att 2 Step 2.1.3 Support completion of the ENF to state and local authorities AD-EP-ALL-0103 Att 2 Step 2.3 Page 33 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation. This administrative action to obtain needed assistance from outside sources to perform radiological assessment activities. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference.

Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Radiological Controls Manager Old Responsi Communicate on assigned communication line and provide information to facility staff Monitor status and information boards/displays/systems Radiological Assessment Manager t~tM13ii*t*

1 Mlffl6Miffi Communicate on assigned communication line and provide information to facil_ity staff AD-EP-ALL-0103 Att 2 Step 2.1.4 Monitor status and information boards/displays/systems AD-EP-ALL-0103 Att 2 Step 2.1.3 Perform event detection and assessment activities I Perform event detection and assessment activities AD-EP-ALL-0103 Att 2 Step 2.1.3 Monitor , evaluate and communicate conditions involving any release of radioactivity Direct and review dose assessment activities Brief and dispatch the onsite/offsite radiation monitoring teams Monitor, evaluate and communicate conditions involving any release of radioactivity AD-EP-ALL-0103 Att 2 Step 2.3 Direct/perform dose assessment AD-EP-ALL-0103 Att 2 Step 2.1.6 Brief and dispatch the onsite/offsite radiation monitoring teams AD-EP-ALL-0103 Att 2 Step 1.2.2 & 3 Provide support and logistics for site evacuation activities AD-EP-ALL-0103 Att 2 Step 2.1.9 Evaluate conditions and develop offsite Protective

/ Evaluate conditions and develop offsite Protective Action Recommendations Action Recommendations AD-EP-ALL-0103 Att 2 Step 2.1.6.c Page 34 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified, position is now specifically task with performing dose assessment if Dose Assessors are not present. This change is categorized as a deviation.

The Rad Assessment Manager is a minimum staff position. Having them trained and tasks with performing dose assessments assures that capability is available as soon as possible. This is considered and improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference. This task has been added and is categorized as a deviation. The purpose of adding this task if the Rad Assessment Manager is working with offsite radiological personnel and assisting with any needed logistics for site evacuation would have been and still is performed by this position.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference.

Revision 0 Attachment 3 Radiological Controls Manager r.1r:1~1.tS .. J.t.lJIMM Provide input for facility briefs and updates Maintain event logs , forms and records SR/O/N2000/003 Step 3.1.1 CEOF ERO Position Comparison and Evaluation Radiological Assessment Manager New Responsibility (task Direct post-accident environmental sampling and exposure activities AD-EP-ALL-0103 Att 2 Section 4.0 Provide input for facility briefs and updates AD-EP-ALL-0103 Att 2 Step 2.1. 7 Maintain event logs , forms and records AD-EP-ALL-0103 Att 2 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0103 Att 2 Step 4.0 Page 35 of 50 This task has been added and is categorized as a deviation. Previous procedure did not address post event actions. Adding task ensures position is aware this may be a required action. This change is evaluated as an improvement.

The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation. This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: New Title: EOF Dose Assessor (SR/O/A/2000/003 R14 Enclosure 6.7) EOF Dose Assessor (AD-EP-ALL-0103 Attachment

3) Overall Change Impact to the Position Changes to the Dose Assessor tasks were minor and primarily differences.

Tasks added to the Dose Assessor position involve current common undirected administrative actions, communications and monitoring activities.

An additional Dose Assessor (total of 2) will also be called out in procedures as part of overall EOF staff ensuring listed responsibilities can be performed in a timely manner. Deviations created by the addition of tasks to the Dose Assessor position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by *changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 2 tasks were added, 11 were modified and O were removed. Dose Projection Coordinator

[*1 H sJ M*HMlfflH@ffii Perform position turnover when a shift change occurs Respond as directed when notified of an event (sign in, get materials, etc.) Provide event data and plant information to the NRC via the HPN EOF Dose Assessor Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 3 Step 2.2 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0103 Att 3 Step 1.1 Assist with emergency classification AD-EP-ALL-0103 Att 3 Step 2.1.4 AD-EP-ALL-0202 Support completion of the ENF to state and local authorities AD-EP-ALL-0103 Att 3 Step 2.1.4 AD-EP-ALL-0202 Provide event data and plant information to the NRC via the HPN AD-EP-ALL-0103 Att 3 Step 3.1 Page 36 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been added and is categorized as a deviation.

Task added to ensure Dose Assessor is aware of EALs based on dose projections.

This change is evaluated as an improvement.

This task has been added and is categorized as a deviation.

Task added to ensure Dose Assessor is aware of how dose projection information is used in notifications to offsite authorities.

This change is evaluated as an improvement.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Dose Projection Coordinator

,_,.,. Communicate on assigned communication line and p r ovide information to facility staff Monitor status and information boards/displays/systems Prepare for facility activation (rooms , work area , equipment, etc.) Monitor , evaluate and communicate conditions i nvolving any release of radioactivity Direct/perform dose assessment EOF Dose Assessor Communicate on assigned communication line and prov i de information to facility staff AD-EP-ALL-0103 Att 3 Step 1.2.3 Monitor status and information boards/displays

/systems AD-EP-ALL-0103 Att 3 Step 2.1.3 Prepare for facility activation (rooms , work area , equipment , etc.) AD-EP-ALL-0103 Att 3 Step 1.2 Monitor , evaluate and communicate condit i ons involving any release of radioactivity AD-EP-ALL-0103 Att 3 Step 2.1.1 & 4 AD-EP-ALL-0202 Direct/perform dose assessment AD-EP-ALL-0103 Att 3 Step 2.1.4 AD-EP-ALL-0202 Evaluate conditions and develop offsite Protect i ve I Evaluate conditions and deve l op offsite Protective Action Recommendations Action Recommendations AD-EP-ALL-0103 Att 3 Step 2.1.6 Maintain event logs , forms and records SR/O/A/2000/003 Step 3.1.1 Restore work area equipment and materials Maintain event logs , forms and records AD-EP-ALL-0103 Att 3 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0103 Att 3 Step 4.0 Page 37 of 50 The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: New Title: Field Monitoring Coordinator (SR/O/A/2000/003 R14 Enclosure 6.8) Field Monitoring Coordinator (AD-EP-ALL-0103 Attachment

4) Overall Change Impact to the Position Changes to the Field Monitoring Team Coordinator tasks were minor and primarily differences.

Tasks added to the Field Monitoring Team Coordinator position involve current common undirected administrative actions and FMT briefing.

Deviations created by the addition of tasks to the Field Monitoring Team Coordinator position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 0 tasks were added, 10 were modified and O were removed. Field Monitoring Coordinator Old Responsibility (task) Perform position turnover when a shift change occurs Respond as directed when notified of an event (sign in, get materials, etc.) Maintain status and information boards/displays Brief and dispatch the onsite/offsite radiation monitoring teams Direct field monitoring team activities Field Monitoring Coordinator New Responsibility (task Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 4 Step 2.2 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0103 Att 4 Step 1.1 Maintain status and information boards/displays AD-EP-ALL-0103 Att 4 Section 2.1 AD-EP-ALL-0203 Brief and dispatch the onsite/offsite radiation monitoring teams AD-EP-ALL-0103 Att 4 Section 2.1 AD-EP-ALL-0203 Direct field monitoring team activities AD-EP-ALL-0103 Att 4 Section 2.1 AD-EP-ALL-0203 Page 38 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

This task has been modified and is categorized as a deviation.

The Radio Operator position is being eliminated.

A FMT Coordinator now communicates with the FMTs directly.

An Additional FMT Coordinator is now staffed. This is considered an improvement.

Revision 0 Attachment 3 Field Monitoring Coordinator Old Responsibility (tas Coordinate activities with the external agency field monitoring teams. Coordinate the receipt, analysis, storage and transfer of field monitoring samples Record/review radiological sampling and survey data Maintain event logs, forms and records SR/O/A/2000/003 Step 3.1.1 Restore work area equipment and materials CEOF ERO Position Comparison and Evaluation Field Monitoring Coordinator l~tMdM+1 eMl:flU@ffi3 Coordinate activities with the external agency field monitoring teams. AD-EP-ALL-0103 Att 4 Section 2.1 AD-EP-ALL-0203 Coordinate the receipt, analysis, storage and transfer of field monitoring samples AD-EP-ALL-0103 Att 4 Section 2.1 AD-EP-ALL-0203 Record/review radiological sampling and survey data AD-EP-ALL-0103 Att 4 Section 2.1 AD-EP-ALL-0203 Maintain event logs, forms and records AD-EP-ALL-0103 Att 4 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0103 Att 4 Step 4.0 Page 39 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use , which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 Old Title: New Title: FMT Radio Operator (SR/O/A/2000/003 R14 Enclosure 6.9) No equivalent position in the standard ERO Overall Change Impact to the Position Position not part of the standard ERO. CEOF ERO Position Comparison and Evaluation All tasks previously assigned to the FMT Radio Operator position are performed by one to of the two Field Monitoring Coordinators.

Deviations created by the removal of the FMT Radio Operator position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS and MNS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 1 tasks was transferred, 1 is now performed by other ERO positions, and 4 was eliminated with the position.

FMT Radio Operator Id Responsibility ( Perform position turnover when a shift change occurs. Respond as directed when notified of an event (sign in, get materials , etc.). Establish and maintain OMT communications. Maintain personal event logs , forms and records. Turn i n logs/forms and restore area/materials upon event termination. Page 40 of 50 Common Task for all ERO Members Common Task for all ERO Members Task transferred to FMT Coordinator. There are now 2 FMT Coordinators trained to perform all required tasks. Common Task for all ERO Members Common Task for all ERO Members Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: Offsite Agency Communicator (SR/O/A/2000/003 R14 Enclosure 6.10) New Title: Offsite Communicator (AD-EP-ALL-0103 Attachment

5) Overall Change Impact to the Position Changes to the Offsite Communicator tasks were minor and primarily differences.

The deviation created by the addition of a task to the Offsite Communicator position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 1 tasks were added, 7 were modified and O were removed. Offsite Communicator Perform position turnover when a shift change occurs Respond as directed when notified of an event (sign in, get materials, etc.) Notify INPO for an Alert, Site Area Emergency, General Emergency, or any event expected to require significant industry support. Perform offsite emergency notifications to state and local authorities Support completion of the ENF to state and local authorities Distribute forms, reports, etc. as needed Maintain event logs, forms and records SR/O/A/2000/003 Step 3.1.1 Offsite Communicator Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 5 Step 2.5 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0103 Att 5 Step 1.1 Provide event notification/information to industry groups (INPO, ANI, etc.) AD-EP-ALL-0103 Att 5 Step 2.4 Perform offsite emergency notifications to state and local authorities AD-EP-ALL-0103 Att 5 Step 2.3 AD-EP-ALL-0304 Support completion of the ENF to state and local authorities AD-EP-ALL-0103 Att 5 Step 2.2 AD-EP-ALL-0304 Distribute forms, reports, etc. as needed AD-EP-ALL-0103 Att 5 Step 2.2 AD-EP-ALL-0304 Maintain event logs, forms and records AD-EP-ALL-0103 Att 5 Step 1.1 Page 41 of 50 The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference. The steps for this task have been modified for checklist use, which is categorized as a difference. Revision 0 Attachment 3 Offsite Communicator Offsite Communicator

"""' Restore work area equipment and mater i als AD-EP-ALL-0103 Att 5 Step 4.0 Page 42 of 50 CEOF ERO Position Comparison and Evaluation This task has been added and is categorized as a deviation. This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: New Title: EOF Services Manager (SR/O/A/2000/003 R14 Enclosure 6.18} EOF Services Manager (AD-EP-ALL-0103 Attachment

12) Overall Change Impact to the Position The span of control for this position remains unchanged.

The tasks removed from the Services Manager position involve shift relief coordination actions performed by the EOF Director position in the standard ERO, admin and logistics actions performed by the EOF Services Administration

/ Commissary position.

Deviations created by the addition of tasks to the EOF Services Manager position did not degraded the capability or timeliness to perform an associated function.

No site specific commitments are adversely altered by changes to tasks assigned this position.

These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 1 tasks were added, 6 were modified and O were removed. EOF Services Manager Old Responsibilit Perform position turnover when a shift change occurs Respond as directed when notified of an event (sign in , get materials, etc.) Develop requests and coordinate external assistance (technical, craft, admin, etc.) Arrange for equipment and supply resources EOF Services Manager l~tW4M+iMlffl6dmt Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 12 Step 2.3 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0103 Att 12 Step 1.1 Develop requests and coordinate external assistance (technical, craft, admin, etc.) AD-EP-ALL-0103 Att 12 Step 1.2 and Section 2.1 Arrange for equipment and supply resources AD-EP-ALL-0103 Att 12 Step 1.2 and Section 2.1 Notify ANI at 9-1-877-680-2644 within 120 minutes I Provide event notification/information to industry of an Alert or higher event declaration groups (INPO, ANI, etc.) AD-EP-ALL-0103 Att 12 Step 2.2 Maintain event logs, forms and records SR/O/A/2000/003 Step 3.1.1 Maintain event logs, forms and records AD-EP-ALL-0103 Att 12 Step 1.1 Page 43 of 50 The steps for this task have been modified for checklist use , which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 EOF Services Manager Old Responsibil EOF Services Manager New Responsibility (ta Restore work area equipment and materials AD-EP-ALL-0103 Att 12 Step 4.0 Page 44 of 50 CEOF ERO Position Comparison and Evaluation This task has been added and is categorized as a deviation.

This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 3 CEOF ERO Position Comparison and Evaluation Old Title: New Title: Services Admin/Commissary (SR/O/A/2000/003 R14 Enclosure 6.11} Services Administration

/ Commissary (AD-EP-ALL-0103 Attachment

6) Overall Change Impact to the Position Deviations created by the addition of the Services Administration

/ Commissary position and its associated tasks did not degraded the capability or timeliness to perform an associated function.

No site specific commitments regarding tasks assigned to the Services Administration

/ Commissary were adversely altered by the adoption of the standard ERO. These changes do not reduce the effectiveness of the CNS, MNS and ONS emergency plans. Specific (one-for-one)

Responsibility (task) Comparison 2 tasks were added, 7 were modified and O were removed. Services Administration

/ Commissary t*)N*dM+IMlfflUNiftia Perform position turnover when a shift change occurs Manage assigned group emergency response activities Respond as directed when notified of an event (sign in, get materials, etc.) Arrange for logistics support Services Administration

/ Commissary New Responsibility (task Develop facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list AD-EP-ALL-0103 Att 6 Step 2.1.1 Perform position turnover when a shift change occurs AD-EP-ALL-0103 Att 6 Step 2.2 Manage assigned group emergency response activities AD-EP-ALL-0103 Att 6 Step 2.1 Respond as directed when notified of an event (sign in, get materials, etc.) AD-EP-ALL-0103 Att 6 Step 1.1 Arrange for logistics support AD-EP-ALL-0103 Att 6 Step 2.1 Provide administrative support for facility operation I Provide administrative support for facility operation AD-EP-ALL-0103 Att 6 Step 2.1.2 Distribute forms, reports, etc. as needed Distribute forms, reports, etc. as needed AD-EP-ALL-0103 Att 6 Step 2.1.2 Page 45 of 50 This task has been added and is categorized as a deviation.

Task has been transferred from the Emergency Planner position.

Transfer of task does no reduce effectiveness of planning effort. The steps for this task have been modified for checklist use, which is categorized as a difference.

The steps for this task have been modified for checklist use, which is categorized as a difference.

Revision 0 Attachment 3 Services Administration

/ Commissary Old Responsi Maintain event logs , forms and records SR/O/A/2000/003 Step 3.1.1 Services Administration

/ Commissary IM.thl~J.M.O.i.1&1!41RM2M4i Maintain event logs , forms and records AD-EP-ALL-0103 Att 6 Step 1.1 Restore work area equipment and materials AD-EP-ALL-0103 Att 6 Step 4.0 Page 46 of 50 CEOF ERO Position Comparison and Evaluation The steps for this task have been modified for checklist use , which is categorized as a difference. This task has been added and is categorized as a deviation. This administrative action is now specified in all appropriate ERO checklists to bring formality and consistency to the task. This change is evaluated as an improvement.

Revision 0 Attachment 6 Change Evaluation Process The changes to the ERO were evaluated from three distinct perspectives.

First, changes to the physical number and response time requirements of the ERO positions were evaluated.

Second, changes to the ERO chain of command and reporting relationships were evaluated.

Lastly, the changes to the addition, alteration or removal of responsibilities (tasks) for each ERO position were evaluated.

1. Changes to the ERO Staffing Numbers This evaluation was performed to assess whether any changes to the number of ERO positions were made (total and by response time) and to determine whether those changes impacted the licensing bases, capability or timeliness of the ERO response and performance of functions.

The addition of an ERO position is considered a deviation.

The addition of an ERO position is considered an improvement due to having additional staff to perform the work, provided it does not overload the next level supervisor/manager position.

The alteration of a position from a specific time requirement into another time requirement is considered a deviation.

The acceptability of the deviation is assessed by evaluation of the assigned tasks in Step 3 below. The deletion of a position is considered a deviation.

The acceptability of the deviation is assessed by evaluation of the assigned tasks in Step 3 below. 2. Changes to the ERO Hierarchy/

Reporting Relationships This evaluation was performed to assess whether any changes to the structural hierarchy or reporting relationships were made and to determine whether those changes impacted capability or timeliness of the ERO response and performance of functions.

3. Changes to an ERO Position's Responsibilities (tasks) Tasks for each ERO position in the current Emergency Plan and implementing procedures are matched to a standard ERO task list based on planning standard, function and element terminology (or identified as station specific tasks and given a unique task ID). Tasks that may have been stated in the E-Plan or procedures in general terms such as provide engineering support or manage radiological personnel may be associated with more specific task descriptions.

Tasks for each ERO position in the new organization are identified and assigned from the same task list used for the current ERO as described above. The tasks for each ERO position are organized in a table for individual comparison.

Changes to an ERO position can involve adding, removing or modifying a task. Added task -involves moving an existing task from a different ERO position, assigning a task previously performed as an undirected action ( such as an inherent administrative expectation), or assigning a task that is entirely new (typically limited to when process or equipment changes are being implemented in conjunction).

Removed task -involves moving an existing task to a different ERO position or eliminating it entirely (typically limited to when process or equipment changes are being implemented in conjunction).

Page 47 of 50 Revision O Attachment 6 Change Evaluation Process Modified task -involves changes in wording or sequencing that potentially affect the capability or timeliness of the task. Since all ERO procedures are being converted to a checklist format for improved human factors design, all task wording has been modified to some extent. Task modifications limited to checklist format changes where step wording and sequence remains essentially unchanged are defined as differences.

Following table alignment of the added, removed and altered tasks, each comparison is categorized as a no change, difference or deviation.

Added and removed tasks are automatically categorized as deviations with regard to their impact on the ERO position in order to force further evaluation and conclusion documentation. Modified tasks may be categorized as a difference or a deviation.

Difference A difference only applies to modified tasks where the change to the wording (of either the task or its steps) does not alter the capability and/or timeliness of the function for which the task was performed. Any change that is determined to be a difference requires no further evaluation.

Deviation A deviation is defined as a change to the wording of a task or its steps that does alter the capability and/or timeliness of the function for which the task was performed.

All added tasks and those removed tasks that are fully eliminated (no longer performed by any position) must be further evaluated in the change evaluation column to establish whether the change improved, maintained, reduced or lost the ability to perform the function.

Removed tasks that are transferred to another ERO position are evaluated as an added task. Thus, only the ERO position that the task is being moved to needs to be documented in the change evaluation column. Modified tasks categorized as deviations must be further evaluated in the change evaluation column to establish whether the change improved, maintained, reduced or lost the ability to perform the function.

For all task changes categorized as deviations, further evaluated further evaluation is performed to determine the impact on the qualities (attributes) of capability and timeliness.

Capability is defined as the quality (attribute) of being able or capable to perform the task. In order to determine an impact to capability the actions accomplished by the task must be known (what the task does). For example; assume the Steps in an existing procedure for the task to classify an event establish the actions for initial event declaration, upgrade and downgrade.

The Steps in the standard procedures for the classification task include the actions for initial event declaration and upgrade. Therefore, a deviation is created by the removal of an action (downgrading) of the task in the original procedure.

Page 48 of 50 Revision 0 Attachment 6 Change Evaluation Process

Timeliness is defined as the quality (attribute) of task duration.

The impact to timeliness can sometimes be determined by evaluating the changes to the steps, such as when one or more steps are added or removed. In other cases it may be necessary to perform the task, such as in a drill or exercise, and observe whether the change impacted the timeliness of the task. 4. Completing a Comparison Table for Each ERO Position A. Identify and list the current tasks performed by the ERO position (sources can include the E-Plan, positional procedures, functional procedures, forms, etc.). B. Identify, list and align the new tasks performed by the ERO position to each of the current tasks. 1) If a new task can be correlated to a current task, list it in the same row in the comparison table. 2) If a new task cannot be correlated to a current task, list it in a separate row in the comparison table. C. Where a current task does not align with a new task identify whether the task was added or removed and document as a deviation in the Change Evaluation column. 1) For added tasks and those removed tasks that are fully eliminated (no longer performed by any position), document an explanation and evaluation of the addition or removal that justifies the change and explicitly states whether it improves, maintains, degrades or loses the ability to perform the function.

2) For removed tasks that are transferred to another ERO position, document which position the task has been transferred to. D. Where a current task does align with a new task identify whether the task was not changed or modified in the Change Evaluation column. E. For each modified tasks identify whether the change is a difference or a deviation.

1) Review the Steps and identifying the actions that the current task does. 2) Review the Steps and identifying the actions that the new task does. NOTE: Changes to informational wording in current tasks that don't "do" anything ( content that is not actionable) do not affect the actions of the task. 3) Compare the list of actions to determine whether the new task does more or less than the current task. A. If the new task does more or less (has more or fewer actions) as compared to the current task, then categorize the change as a deviation (due to an alteration in the capability).

B. If the new task does the same actions as compared to the current task, then categorize the change as a difference.

Page 49 of 50 Revision 0 Attachment 6 Change Evaluation Process NOTE: In the case where the current procedure simply states the task and the new task has added performance steps, and in consideration that there has been no change in how the actual task is performed, it is acceptable to conclude that the timeliness has not been altered. 4) Compare the steps to determine whether the new task takes more or less time to accomplish than the current task. a. If the new task takes more or less time to accomplish as compared to the current task, then categorize the change as a deviation (due to an alteration in the timeliness).

b. If the new task takes the same amount of time to accomplish as compared to the standard task, then categorize the change as a difference.

c. If it is not possible to determine whether the standard task can be accomplished in more or less time than the current task, note that further evaluation is necessary.

F. For each modified task identified as a difference, provide a brief statement for why it is considered such. G. For each modified task identified as a deviation, document an explanation and evaluation of the addition or removal that justifies the change and explicitly states whether it improves, maintains, degrades or loses the ability to perform the function.

5. Overall Change to a Position A summary of the overall impact of the task changes is documented above the comparison table for each position.

Information included in the summary is as follows: A. Span of control change description for positions that manage or supervise other positions (as applicable).

B. Description of overall change impact to position.

C. Summary of task deviations.

D. Evaluation statement explicitly documenting:

1) That the deviation did not degrade the capability or timeliness to perform an associated function.

2) That no site specific commitments are adversely altered by changes to tasks assigned to this position (this statement is able to be made in the comparison document based on the results of the commitment search recorded on the §50.54(q) evaluation form). 3) That the changes do not reduce the effectiveness of the emergency plan. Page 50 of 50 Revision 0 Enclosure 4 Summary of the Emergency Plan changes

Activity Description for EPA A {CNS Emergency Plan Section A-Assignment of Responsibility ) Rev 150 Changed rev number from 149 to 150; changed date from March 2017 to September 2017 Section A.1.c

Updated as follows to reflect revised tables/figures from EPA B. o "See Table B-la and B-lb and Figures B-1, B-2, B-3, B-4, B-Sa and B-Sb" Activity Description for EPA B (CNS Emergency Plan Section B-Site Emergency Organization)

Rev 163 Changed rev number from 162 to 163; changed date from September 2016 to September 2017 Section B.2

Changed "Operations Shift Manager" to "Shift Manager" in first and second sentences. (new title) Section B.4

Changed "Operations Shift Manager" to "Shift Manager" in second sentence. (new title) Section B.6

Changed references to Figure Sa and Sb. Section B-8

Page B-3 (State of South Carolina) added Robinson to Oconee and Catawba. Table B-lb

Changed title to "Augmented ERO Staffing for Emergencies"

Figure revised to reflect new staffing assignments and titles

Page 2 of 2 (Notes) o Deleted first paragraph related to 75 minute clock o Deleted third paragraph related to augmentation by local support o Deleted last sentence in fourth paragraph related to FMT qualifications o Numbered remaining paragraphs (1-3) Figure B-1

Added (TSC) to the title

Revised the entire figure to reflect new (TSC) titles and assignments with response times as applicable Figure B-2

Change title to Site Emergency Organization (OSC)

Revised the entire figure to reflect new (OSC) titles and assignments with response times as applicable Figure B-3

Changed Title to Emergency Operations Facility (EOF)

Figure B-4

New figure with Media Center Organization Figure B-Sa

New revised figure with inter-relationships Figure B-Sb

New revised figure with inter-relationships Activity Description for EPA E (CNS Emergency Plan Section E -Notification Methodology)

Rev 148 Changes to section E are editorial as defined in AD-EP-ALL-0602 because they are changes to update references that are being implemented to support the Standard ERO Project. Changed rev number from 147 to 148; changed date from September 2016 to September 2017 Section E2

Deleted references to procedures RP/O/A/5000/006 Band SR/O/A/2000/004

Added new procedure reference AD-EP-ALL-0304, State and County Notifications Section E.2.a

Note changed to add procedure AD-EP-ALL-0101, Emergency Classification Section E.2.b

Note changed to add procedure AD-EP-ALL-0101, Emergency Classification

Page E-3, added "or AD-EP-ALL-0301, Activation of the Emergency Response Organization Notification System (ERO NS)" added after "RP/0/ A/5000/003, Alert" Section E.2.c

Note changed to add procedure AD-EP-ALL-0101, Emergency Classification

Page E-5, added "or AD-EP-ALL-0301, Activation of the Emergency Response Organization Notification System (ERONS)" after "RP/O/A/5000/004, Site Area Emergency"

Page E-5, added "or AD-EP-ALL-0101, Emergency Classification" after "RP/0/ A/5000/004, Site Area Emergency" at the bottom of the page. Section E.2.d

Note changed to add procedure AD-EP-ALL-0101, Emergency Classification

Page E-6, added "or AD-EP-ALL-0301, Activation of the Emergency Response Organization Notification System (ERONS)" after "RP/O/A/5000/005, General Emergency"

Page E-7, added "or AD-EP-ALL-0109, Offsite Protective Actions Recommendations" after "RP/0/ A/5000/005, General Emergency" at the bottom of the page. Activity Description for EPA G (CNS Emergency Plan Section G -Public Education and Information)

Rev 161 Changed rev number from 14-3 to 161; change date from June 2014 to September 2017 Section G.2

Changed emergency "planning" to emergency "preparedness" Section G.3

Capitalized "Media Center" and "News Releases"

In the last sentence, first paragraph

-changed "news manager and public spokesperson" to "A company spokesperson"

In the last sentence, second paragraph

-deleted references to SR/0/ A/2000/001 and RP/O/B/5000/028.

Replaced with "the Joint information Center (JIC} implements media procedures" Section G.4

Changed "Pubic Spokesperson" to "Company Spokesperson";

deleted capitalization for "site" VPs. Section G.4.c

Reordered county, state, and federal in logical order

Added "or via JIS"

Deleted capitalization of "portal"

Corrected spelling of government Activity Description for EPA H (CNS Emergency Plan Section H -Emergency Facilities and Equipment)

Rev 149 Changes to section Hare editorial as defined in AD-EP-ALL-0602 because they are changes to update references that are being implemented to support the Standard ERO Project. Changed Rev number from 16-1 to 149; changed date from March 2016 to September 2017 Section H.1.b

Replaced RP/O/B/5000/020 with new procedure reference AD-EP-ALL-0105 Activation and Operation of the Technical Support Center (TSC} Activity Description for EPA I (CNS Emergency Plan Section I -Accident Assessment ) Rev 147 Changes to section 1.3, 1.7, and 1.8 are editorial as defined in AD-EP-ALL-0602 because they are changes to update references that are being implemented to support the Standard ERO Project. Change rev number from 146 to 147. Changed date from May 2015 to September 2017 Section 1.1

Added basis information from EPA D discussion section on the CNS NEI 99-01 Rev 6 EAL upgrade.

Added AD-EP-ALL-0101 and NEI 99-01 Revision 6 EAL Wallboard as references for determining emergency condition.

Section l.3.a/1.3.b

Deleted references to HP/O/B/1009/004 and HP/O/B/1009/026, which have been superseded.

Added new procedures AD-EP-ALL-0203 and AD-EP-CNS-0203 Section 1.7 /1.8

Deleted HP/O/B/1009/004, which was superseded

Added AD-EP-ALL-0203, Field Monitoring During an Emergency, and AD-EP-CNS-0203, CNS Site Specific Field Monitoring Information Section 1.9 Detect and Measure Radioiodine Concentration in EPZ

Added the following to the end of the paragraph "OR a count rate meter utilizing direct corrected count rate (ccpm) of the Silver Zeolite or equivalent cartridge cross-referenced against an estimated lodine-131 microCi/cc concentration attachment." Activity Description for EPA J (CNS Emergency Plan Section J -Protective Response)

Rev 147 Changes to section J are editorial as defined in AD-EP-ALL-0602 because they are changes to update references and position titles that are being implemented to support the Standard ERO Project and a correction to a referenced procedure title. Change rev number from 146 to 147. Changed date from May 2015 to September 2017. Section J.6

For TSC positions:

o Changed "Operations Superintendent, Operations Engineer" to "Operations Manager" o Changed "Assistant Operations Engineer" to "Assistant Operations Manager" o Changed "Systems Engineer" to "Mechanical Engineer, Electrical Engineer"

For OSC positions:

o Changed "OSC Log/Status Keeper" to "OSC Log Keeper" Section J.7

Added "General Emergency" to RP/O/A/5000/005

Deleted SR/O/A/2000/003 and replaced with AD-EP-ALL-0109, Off Site Protective Actions Recommendations.

Activity Description for EPA K (CNS Emergency Plan Section K -Radiological Exposure Control) Rev 144 Changes to section Kare editorial as defined in AD-EP-ALL-0602 because they are changes to update position titles that are being implemented to support the Standard ERO Project and one typographical correction that does not change intent of the Emergency Plan. Change rev number from 14-3 to 144. Changed date from June 2014 to September 2017 2017. Section K.2

Last sentence:

Changed "Procedures" to "Site procedures" Section K.6.b

Changed "OSC Nuclear Supply Chain Manager/designee" to "OSC Generation Supply Chain Liaison/designee" Activity Description for EPA M (CNS Emergency Plan Section M -Recovery and Re-entry Planning and Post -Accident Operations)

Rev 161 Changed rev number from 13-1 to 161; Changed date from August 2013 to September 2017. Section M.1

Replaced RP/O/B/5000/025, Recovery and Reentry procedure with AD-EP-ALL-0110, Recovery Section M.2

Replaced "EOF Director" with "Recovery Manager"

Replace "Coordination" with "High level coordination"

Deleted Work Control Manager and description

Added Onsite Recovery Director -Directs the recovery activities onsite to restore the plant to pre-incident conditions.

Added Offsite Recovery Director-Directs interface with Federal, State, and local agencies during the recovery process.

Add condition (if needed) for Radiological Assessment Manager

Deleted Engineering Support Manger, Public Information Manager, and EOF Services Manager

Added Company Spokesperson-Directs the Public Information Program during the recovery process.

Added Other Support-Other individuals or groups assigned specific tasks to support activities during the Recovery Phase Section M.3 * #2 Replaced Public Information Manager with "either JIC Director or Company Spokesperson"

Figure M-1 Replaced with chart with the revised positions and descriptions.

Activity Description for EPA O (CNS Emergency Plan Section 0-Radiological Emergency Response Training)

Rev 144 Changes to section O are editorial as defined in AD-EP-ALL-0602 because they are changes to update references that are being implemented to support the Standard ERO Project and correcting a reference title. Changed rev number from 143 to 144; changed date from June 2014 to September 2017 Section 0.1.a

Replace CNS Addendum 7111.0 with new procedure AD-EP-ALL-0500, Emergency Response Training.

Section 0.2.a

Replace EP Group Manual Guideline 5.4.1 with AD-EP-ALL-0500 (first sentence)

Replace EP Group Manual Guideline 5.4.1, ETQS 7111.00 and CNS Addendum 7111.0 with EP-ALL-0500 (last sentence)

Section 0.2.c

Replaced Nuclear System Directive 112 and CNS Training Addendum 7111.0 with AD-TQ-ALL-0086, Fire Brigade and HAZMAT Training Section 0.2.d

Corrected title for PT/O/B/4600/006 by adding "Exercises and". Section 0.3

Replaced Nuclear System Directive 119 with AD-SY-ALL-0280, Medical Emergency Response Team (MERT) and Technical Rescue Training.

Activity Description for EPA P (CNS Emergency Plan Section P -Responsibility for the Planning Effort) Rev 147 Changes to section Pare editorial as defined in AD-EP-ALL-0602 because they are changes to update references that are being implemented to support the Standard ERO Project and correcting telephone numbers. Changed Rev number from 146 to 147; changed date from May 2015 to September 2017 Section P.10

Telephone Number Updates (PRR#02073026/02147671)

Deleted reference to procedure ST /0/ A/4600/086 and replaced with TE-EP-ALL-0407 (Periodic Verification of EOF Communication Equipment Operation and Equipment/

Supply Inventory).

Figure P-2 (PRR# 02019725/02147671)

Revised table to delete and add procedures as a result of the Fleet Standard ERO Project and JIC procedures.

Reordered table in alpha-numeric order. Procedures added/Revised Procedure Title Emergency Plan Section Implemented AD-EP-ALL-0101 Emergency Classifications D, E, 1.1 AD-EP-ALL-0103 Activation and Operation of the B,C,H Emergency Operations Facility (EOF) AD-EP-ALL-0104 ERO Common Guidelines and B, E, F, G, I, Forms K,M AD-EP-ALL-0105 Activation and Operations of the B, H, E Technical Support Center (TSC) AD-EP-CNS-0105 CNS Site Specific TSC Support B, H AD-EP-ALL-0106 Activation and Operations of the B,H Operations Support Center (OSC) AD-EP-ALL-0108 Joint Information System G Support AD-EP-ALL-0109 Protective Action J.7 AD-EP-ALL-0110 AD-EP-ALL-0203 AD-EP-CNS-0203 AD-EP-ALL-0205 AD-EP-ALL-0304

Title changed Procedures marked as deleted: RP/O/A/5000/006 B RP/0/ A/5000/018 RP /0/ A/5000/020 RP /0/ A/5000/024 RP/0/ A/5000/025 HP /O/B/1009/004 SR/0/ A/2000/001 SR/0/ A/2000/003 SR/O/A/2000/004 Recommendations

Recovery M Field Monitoring During an D, I, H.6.b Emergency*

CNS Site Specific Field I Monitoring Information Emergency Exposure Controls K.2 State and County Notifications E, J.7

ML17311A540

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SUMMARY

SUMMARY

3.1.2 Response

3.2 Comparison

1.1.1. Three

SUMMARY

SUMMARY

3.1.1 Current

3.1.2 Response

SUMMARY

SUMMARY

3.1.2 Response

3.2 Comparison

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