ML12352A125

Submittal of Emergency Plan, Volume a, Revision 2012-04

ML12352A125
Person / Time
Site:	Oconee
Issue date:	12/13/2012
From:	Gillespie T Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
FOIA/PA-2016-0071
Download: ML12352A125 (46)

Text

i.%T. PRESTON GILLESPIE, JR.Vice President* Energye Oconee Nuclear Station Duke Energy ON01 VP / 7800 Rochester Hwy.Seneca, SC 29672 864-873-4478 864-873-4208 fax T. Gillespie@duke-energy.

corn December 13, 2012 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, -287 Emergency Plan, Volume A, Revision 2012-04 Please find attached for your use and review copies of the revision to the Oconee Nuclear Station Emergency Plan.This revision is being submitted in accordance with 10 CFR 50.54(q) and does not reduce the effectiveness of the Emergency Plan or the Emergency Plan Implementing Procedures.

By copy of this letter, two copies of this revision are being provided to the NRC, Region II, Atlanta, Georgia.If there are any questions or concems pertaining to this submittal, please call Patrick M. Street, Emergency Planning Manager, at 864-873-3124.

Sincerely,.reston Gillespie, Jr.Vice President Oconee Nuclear Station Attachments:

Revision Instructions Emergency Plan Revision 2012-04 50.54(q) Evaluation(s) 4y6f t'%j^x www. duke-energy, com U. S. Nuclear Regulatory Commission December 13, 2012 Page 2 xc: (w/2 copies of attachments)

Mr. V. M. McCree U.S. Nuclear Regulatory Commission

-Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 w/copy of attachments Mr. John Boska, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike -Mail Stop 8G9A Rockville, MD 20852 (Send via E-mail)w/o attachments NRC Senior Resident Inspector Oconee Nuclear Station December 13, 2012 OCONEE NUCLEAR STATION

SUBJECT:

Oconee Nuclear Site Emergency Plan Volume A, Revision 2012-04 Please make changes to the Emergency Plan, Volume A by following the below directions.

REMOVE INSERT Cover Sheet 2012-03 List of Effective Pages -Revision 2012-03 Record of Changes-Revision 2012-03 Section B -Rev. 2011-02 Cover Sheet 2012-04 List of Effective Pages -Revision 2012-04 Record of Changes-Revision 2012-04 Section B -Rev. 2012-04 Emergency Planning Manager Oconee Nuclear Station PDuke ftEnergyOCONEE NUCLEAR STATION EMERGENCY PLAN APPROVED: T. Freston Gillespie, Jr.VP, Oconee Nuclear Station DatDEC A2 Date Approved EfeI1ti Date Effective Date VOLUME A REVISION 2012-04 DECEMBER 2012 December 13, 2012 OCONEE NUCLEAR STATION

SUBJECT:

Oconee Nuclear Site Emergency Plan Volume A, Revision 2012-04 Please make changes to the Emergency Plan, Volume A by following the below directions.

REMOVE INSERT Cover Sheet 2012-03 List of Effective Pages -Revision 2012-03 Record of Changes-Revision 2012-03 Section B -Rev. 2011-02 Cover Sheet 2012-04 List of Effective Pages -Revision 2012-04 Record of Changes-Revision 2012-04 Section B -Rev. 2012-04 Pat Street Emergency Planning Manager Oconee Nuclear Station

• &Duke~EnergyOCONEE NUCLEAR STATION EMERGENCY PLAN APPROVED: T. Preston Gillespie, Jr.VP, Oconee Nuclear Station bDtEC 12 Date Approved Effective Date VOLUME A REVISION 2012-04 DECEMBER 2012 0 Oconee Emergency Plan List Of Effective Pages SECTION PAGE NUMBER REVISION NO.Emergency Plan Approval Cover Sheet Coversheet Rev 2012-04 List of Effective Pages Page 1 -4 Rev. 2012-04 List Of Figures Page 1 -6 Rev. 2008-02 Record Of Changes Page 1 -9 Rev. 2012-04 Table of Contents Page 1 Rev. 2008-02 I. Introduction Page i-I -i-6a Rev. 2008-02 I1. Planning Standards

& Evaluation Criteria A. Assignment of Responsibility Page A-I -A-8 Rev. 2010-01 B. Onsite Emergency Organization Page B-1 -B-21 Rev. 2012-04 C. Emergency Response Support And Resources Page C-I & C-2 Rev. 2012-02 D. Emergency Classification System Page D-1 -D-100 Rev. 2012-02 E. Notification Page E-I & E-2 Rev. 2008-02 F. Emergency Communications Page F-I -F-8 Rev. 2012-01 G. Public Information and Education Page G-I -G-5 Rev 2011-01 2011 Emergency Planning Rev. 2011-01 Calendar H. Emergency Facilities And Equipment Page H-I -H-39 Rev. 2012-02 I. Accident Assessment Page I-I 37 Rev. 2012-02 J. Protective Response Page J-1 -J-24 Rev. 2012-02 DATE December 2012 December 2012 October 2008 December 2012 October 2008 October 2008 February 2010 December 2012 June 2012 June 2012 October 2008 June 2012 May 2011 May 2011 June 2012 June 2012 June 2012 Revision 2012-04 December 2012 I A Oconee Emergency Plan List Of Effective Pages SECTION PAGE NUMBER REVISION NO.K. Radiological Exposure Control Page K-1 -K-12 Rev. 2008-02 L. Medical And Public Health Support Page L-1 -L-5 Rev. 2009-01 M. Recovery And Reentry Planning And Post-Accident Operations Page M-I -M-5 Rev. 2008-02 N. Exercises and Drills Page N-1 -N-5 Rev. 2011-01 0. Emergency Response Training Page 0-1 3 Rev. 2008-02 P. Responsibility For The Planning Effort: Development, Periodic Review and Distribution Of The Emergency Plans Page P-I -P-8 Rev. 2012-02 DATE October 2008 February 2009 October 2008 May 2011 October 2008 June 2012 June 2012 October 2008 October 2008 October 2008 III. APPENDICIES APPENDIX 1 Definitions Page 1 -5 APPENDIX 2 Meteorology And Offsite Dose Assessment Program Page 1 -4 APPENDIX 3 Alert And Notification

System Description

Page 1 -4 APPENDIX 4 Evacuation Time Estimates Page 1 Rev. 2012-02 Rev. 2008-02 Rev. 2008-02 Rev. 2008-02 2 Revision 2012-04 December 2012 Oconee Emergency Plan List Of Effective Pages APPENDIX 5 Letters of Agreement Page 1 Page 2 Agreement Letter I Agreement Letter 2 Agreement Letter 3 Agreement Letter 4 Agreement Letter 5 Page 1, 2, & 3 Agreement Letter 6 Page 1 & 2 Agreement Letter 7 Agreement Letter 8 Agreement Letter 9 Agreement Letter 10 Agreement Letter 11 Page 1 & 2 Agreement Letter 12 Page 1 & 2 Agreement Letter 13 Page 1 & 2 Agreement Letter 14 Page 1, 2, & 3 Agreement Letter 15 Page 1, 2 & 3 Agreement Letter 16 Agreement Letter 17 DELETED Agreement Letter 18 Rev. 2011-01 Rev. 2011-01 Rev. 2008-02 Rev. 2008-02 Rev. 2008-02 Rev. 2008-02 Rev. 2008-02 Rev. 2010-01 Rev. 2008-02 Rev. 2010-01 Rev. 2008-02 Rev. 2008-02 Rev. 2008-02 Rev. 2004-01 Rev. 2010-01 Rev. 2010-01 Rev. 2010-01 Rev. 2011-01 Rev. 2004-01 Rev. 2010-01 May 2011 May 2011 February 19, 2008 February 15, 2008 February 19, 2008 February 25, 2008 April 25, 2008 February 23, 2010 July 28, 2008 April 16, 2009 February 22, 2008 February 19, 2008 April 28, 2008 November 29, 2001 September 21, 2009 June 02, 2009 June 5, 2009 September 30, 2010 DELETED -08/26/03 September 04, 2009 3 Revision 2012-04 December 2012

ý 0 Oconee Emergency Plan List Of Effective Pages Agreement Letter 19 Agreement Letter 20 Page 1 thru 5 Agreement Letter 21 Page 1 thru 6 Agreement Letter 22 Page 1 thru 5 Agreement Letter 23 Agreement Letter 24 Agreement Letter 25 Agreement Letter 26 Rev. 2008-02 Rev. 20 10-01 Rev. 2008-02 Rev. 2010-01 Rev. 2010-01 Rev. 2008-02 Rev. 2012-03 Rev. 2012-03 June 27, 2008 January 05, 2010 August 6, 2008 June 22, 2009 April 16, 2009 June 27, 2007 May 23, 2012 June 06, 2012 APPENDIX 6 Distribution List Page 1 -6 Rev. 2008-02 October 2008 APPENDIX 7 Emergency Data Transmittal System Page 1 Rev. 2012-01 June 2012 APPENDIX 8 Spill Prevention Control Spill Prevention Control Page 1 -36 Rev. 2004-02 And Countermeasure Plan Site Drawing Drawing Revision 2001-03 APPENDIX 9 Ground Water Monitoring Sampling And Analysis Plan Page 1 -17 Rev. 2008-02 December 2004 October 2001 December 2007 February 2010 APPENDIX 10 Hazardous Materials Response Plan Page 1 -12 Rev. 2010-01 4 Revision 2012-04 December 2012 RECORD OF CHANGES REVISION NUMBER Revision I Revision 2 Revision 3 Revision 4 Revision 5 Revision 6 Revision 7 83-1 EFFECTIVE DATE April 1, 1981 December 31, 1981 March, 1982 April, 1982 September 1, 1982 November 1, 1982 December 14, 1982 June 10, 1983 November 17, 1983 March 26, 1984 November 15, 1984 June 7, 1985 March 8, 1986 November 13, 1986 December 9, 1986 February 4, 1987 REASON FOR REVISIONS 83-2 84-1 84-2 85-1 85-2 86-1 86-2 86-3 87-1 Meteorological Update Rewrite Emergency Plan in Nureg 0654 Format Update Emergency Plan Revisions

& Changes to update Emergency Plan Revision to coincide with Crisis Management Plan Revision update Review and update Changes required by action items due to annual exercise and review and general update Changes required by review and general update Revisions as determined by QA audit and minor editing Revisions as determined by annual review Revisions/changes/editing Revisions/changes/editing-annual review New Oconee Brochure Revisions/changes/editing-annual review Correct changes identified as deficiencies by the NRC in Rev.85-2.Revision update, minor editing changes, included failed fuel accident assessment information.

I Revision 2012-04 RECORD OF CHANGES (Continued)

EFFECTIVE DATE REASON FOR REVISIONS REVISION NUMBER 87-2 87-4 88-1 88-2-89-1 89-2 89-3 90-1 90-2 90-3 90-4 91-1 91-2 91-3 91-5 91-6 92-1 92-2 92-3 December 10, 1987 June 7, 1988 October 14, 1988 February 28, 1989 August 14, 1989 January 5, 1990 March 1, 1990 June 1, 1990 July 2, 1990 October 31, 1990 January 21, 1991 February 20, 1991 March 22, 1991 September 19, 1991 December 16, 1991 March 1, 1992 June 30, 1992 October 29, 1992 Revision update, minor editing changes Review Section D.Agreement letters updated.Incorporate alternate TSC and OSC into Emergency Plan Revised EALS in Section D.Annual review. Minor editorial revisions.

Major revision to Section D. Added Appendix 7. Minor editorial changes.Change to Section D. Minor editorial revisions.

Annual Review.Changes to Section D as required by NRC commitment.

Changes reflect upgrade of radiation monitor system and minor editing.Change to Section D, Emergency Classification.

Annual Review Section D revision. (RIA upgrade)Section D revision. (TS to SLC)Section D revision. (RIA upgrade)Section D revision. (SLB revision)Section D revision. (RIA upgrade)Annual review.Section D (RIA upgrade).

Minor editorial changes.Major Revision Annual review 2 Revision 20 12-04 RECORD OF CHANGES (Continued)

REVISION EFFECTIVE DATE REASON FOR REVISIONS NUMBER 92-4 12/31/92 Section B, D, H, J, Appendix 4, 5 & 6 changes.93-1 03/01/93 Sections D, G, H, N, P, and Appendix 6 93-2 05/07/93 Sections A, B, D, Appendix 5 and 6 93-3 07/23/93 Sections A, B, G, H, 1, J, L, M, N, & Appendix 6 93-4 08/11/93 Sections B, D, and Appendix 5 93-05 01/01/94 Annual Review, Incorporation of EPA-400 guidelines.

94-01 03/15/94 Additions of Appendix 8 and 9. -(Minor revisions) 94-02 05/09/94 Changes to Appendix 5, Pages 1 and 2;Changes to Appendix 6, Pages 2 and 4;State of South Carolina Agreement Letter 94-03 05/25/94 Changes to Appendix 5, Page 2;Changes to Appendix 6, Pages 4 and 5;INPO Agreement Letter 94-04 06/06/94 Changes to Appendix 5, Page 2;Change Teledyne Isotopes Badge Service Service Company 94-05 08/08/94 Changes to Section D 94-06 12/29/94 Annual review. Editorial changes, minor revisions.

95-01 02/23/95 Changes to Sections B, G, Appendix 5.95-02 10/23/95 Annual review and changes 95-03 11/01/95 Section D. Change, Incorporated new EAL'S.95-04 12/31/95 Calendar 1996, HAZMAT Changes, RP/14 deleted 96-01 02/13/96 Changes to Sections B, D, and N.96-02 06/25/96 Changes to Section D 96-03 07/96 Changes to Section D 96-04 12/96 Annual review, editorial changes, minor changes with major change to Appendix 10.3 Revision 20 12-04 RECORD OF CHANGES REVISION EFFECTIVE REASON FOR CHANGE NUMBER DATE 97-01 07-97 Section B, I, Appendix 5 & 7, with editorial/minor changes to Section H & P 97-02 12-97 Annual review and editorial/minor changes 98-01 02-98 Section D, page 35. Correction of title on Enclosure 4.3 98-02 03-98 Section N, page 1 & 2, Added part a (General) to Section N.2 to ensure drills conducted between NRC evaluated exercises are performed in accordance with IOCFR50, Appendix E,Section IV.F.2.b 98-03 04-98 List of Figures page number corrections, Added Emergency Operation Facility to Figure H-I 5, Figure H-20 reformatted.

Added Agreement Letter with Keowee-Key Volunteer Fire Department, Appendix 5, #24.Appendix 10 -Hazardous Materials Response Plan, corrections on Table of Contents with minor revisions.

Headings on Appendix 10, Figure 2 with minor revisions.

98-04 12-98 Annual review and editorial/minor changes.99-01 03-99 The ONS Technical Specifications have been converted to a set of Technical Specifications based on NUREG 1430. "Standard Technical Specifications Babcock and Wilcox Plants." Replaced the description phrases (titles) in Section D for Operating Modes with the Mode number from Improved Technical Specifications.

In Section I the portion describing leak rate volume percent per day was changed to percent of the containment air weight per day. The reference to Tech Spec 4.4.1.1 was changed to reference Improved Technical Specification 5.5.2.NOTE: The implementation date of Improved Tech Specs was moved from March 4, 1999 to March 27, 1999, therefore the revision date for revision 99-01 will depict February when the actual administrative changes were completed.

99-02 12-99 Annual review and editorial/minor changes 2000-01 04-2000 Addition of List of Effective Pages 2000-02 05/2000 Editorial

/minor changes 2000-03 12/2000 Annual review and editorial/minor changes 2001-01 02/07/2001 Additions and corrections as result of 50.54(t) audit.4 Revision 20 12-04 RECORD OF CHANGES REVISION EFFECTIVE REASON FOR CHANGE NUMBER DATE Additional information added to Basis Document and additional EAL's resulting from EP drill critiques.

2001-02 08/2001 Changes in areas of responsibility.

Added note concerning RVLS to Fission Product Barrier Matrix; 2001 calendar; information added to EP Functional Area Manual; added/updated information on annual average meteorology; Appendix 5; Appendix 6; editorial/minor changes.2001-03 12/2001 Added information in Basis Document concerning a reactor building containment break. Replaced the 2001 calendar with the 2002 calendar.Editorial/minor changes 2002-01 01/02 The present Oconee Nuclear Station Emergency Operating Procedure is written in a different format and with some different terms than the earlier version. The term PTS (Pressurized Thermal Shock) has replaced TSOR (Thermal Shock Operating Range). This is only a change in terminology.

The additional EAL is to ensure a site specific credible threat results in a declaration of a notification of Unusual Event (NOUE). This change is also intended to achieve an appropriate level and consistent response Nationwide.

2002-02 06/02 Section B -minor changes; Section D -Added information requested by Emergency Coordinators to Enclosure 4.1; Section G -Rewrite of entire section; Section H -Updated information on Figure H-4 relating to Met Data; Appendix 5 -Updated Letters of Agreement; and miscellaneous spelling/grammar errors.2002-03 09/02 Section A -Compliance with the NRC Security Interim Compensatory Measure (ICM) issued 02/25/02; Section P -Audit frequencies per revised 10 CFR 50.54 (t) as stated in Federal Register Vol 64, 03/29/99.Appendix I -Added definition of monthly and Semi-Annual; Appendix 5, Agreement Letters, updated #17, Appendix 6 -Changed name on 78A.Miscellaneous corrections.

2003-01 02/03 Section D -RIA setpoints change, Section G -2003 Calendar, Appendix 3 -Siren upgrade, new map (i-5) ; Appendix 5 -Agreement Letters, Appendix 6 -Issued To change, Section B, E, F editorial/minor changes 2003-02 08/03 Section D -incorporates additional guidance for the Emergency Coordinator/EOF Director related to classification of a high energy line break, such as a Main Steam Line Break. In addition, Section D has been retyped using a consistent font style -no changes in content resulted from the retype.2004-01 02/04 Incorporates a retype of the majority of the sections as an editorial change to adopt a consistent format: Section G -Added information concerning One Mile Exclusion Area Signs; Section H -Strip Chart Recorders were removed under an NSM; Section J -Incorporated guidance on the use of KI as a protective action recommendation; Section K -changed KI dose to 5 REM CDE from 25 REM; Appendix 4 -Incorporate results of Evacuation Time Estimate; Appendix 5 -Revised Agreement Letters 5 Revision 20 12-04 RECORD OF CHANGES REVISION EFFECTIVE REASON FOR CHANGE NUMBER DATE 2004-02 12/21/04 Editorial changes to correct typos, drawings, and title/organizational names. This revision also incorporates clarifying information from the latest Evacuation Time Estimate (ETE); clarification of offsite agency responsibilities for protective actions for impediments and special populations; revised EAL #2 for Enclosure 4.3, Unusual Event IC #2; clarification of ERO activation after normal working hours; and revisions to the site's SPCC Plan included in Appendix 8. In addition to these changes, applicable references have replaced generic references in Figure P-1. This revision also incorporates the 2005 Calendar distributed to the 10 mile EPZ population.

2005-01 02/01/05 Section D, Enclosure 4.7, Page 66 -Duke Power Hydro-Electric Group has revised the Lake Keowee water level from 807 to 815.5 feet for initiating a Condition B. This elevation is used in Enclosure 4.7 for classifying the event as an Unusual Event. The Hydro -Electric Group notifies the Control Room when Condition B has been declared.

No protective actions by the plant are changed.2005-02 05/17/05 Section I & Letters of Agreement

-Incorporates an editorial revision that describes the makeup of Field Monitoring Teams and updated Agreement Letters.1.7&8 replaced .personnel from Radiation Protection and Chemistry." with "..a RP Technician and a Driver." Editorial Change -Chemistry personnel no longer perform the function of FMT Driver. FMT Drivers are now provided by other groups.2005-03 08/24/05 Revision 2005-03 incorporates an addendum for the Fire Department/Volunteer Fire Department Agreement Letters. This addendum was added as a result of NRC guidance provided to utilities.

The addendum to these letters provides guidance on the. use of the Incident Command System at ONS and identifies the ONS Fire Brigade Leader as the on-scene commander and site-interface for responding offsite fire departments.

2005-04 09/15/05 Revision 2005-04 is a change to Page 66, Enclosure 4.7, Emergency Action Levels #1 -Reservoir elevation greater than or equal to 807.0 feet with all spillway gates open and the lake elevation continues to rise. This change undoes Revision 2005-01 which changed Keowee Lake level from 807 feet elevation to 815.5 feet elevation.

This revision was determined to be a non conservative change in that it delayed the Unusual Event emergency classification.

Appendix 5, Agreement Letter #21 has been updated.2005-05 01/09/06 Revision 2005-05 incorporates editorial changes that clarify organizational charts/responsibilities, revise procedure references, replaces public information calendar, and replaces obsolete survey instruments.

Agreement Letters #16 and# 19 were updated.2006-03 06/8/06 Section D -Change #1 Revised initiating condition

1. 2 for the Alert classification for Enclosure 4.6 (Fire/Explosions and Security Events). This change is based on a correction to the NEI White Paper, Enhancements to Emergency Preparedness Programs For Hostile Actions which was endorsed in a letter from the NRC on December 8, 2005. Change #2 -Renumbered Emergency Action Levels through out Section D to match the numbering scheme found in RP/0/B/1000/001 6 Revision 2012-04 RECORD OF CHANGES REVISION EFFECTIVE REASON FOR CHANGE NUMBER DATE (Emergency Classification) procedure

-Renumbering makes it easier for procedure users to locate the correct emergency action level in the Basis Document.

-Appendix 5 -Agreement Letters #8, 14,15 & 23 were updated.2006-04 11/06 Reference changes to the deletion of the Clemson EOF and incorporates reference to the Charlotte EOF. In addition, miscellaneous editorial changes are included in this revision.2007-01 03/07 Appendix 5 Agreement Letters that have been updated/revised.

2007-02 12/07 Editorial changes including a revised 50 mile radius map (Figure B), a revision to the Emergency Classification Basis Section D , the 2008 Emergency Planning Calendar, a revised layout drawing for the JIC, a revised listing of portable survey instruments, the latest renewal of existing agreement letters and a revised Ground Water Monitoring Plan 2008-01 09/08 The original order of the EALs created a human performance trap. The first fission barrier column that the procedure user reviews is the RCS Barrier column which is on the left side of the page. The second fission barrier column that is reviewed is the Fuel Clad Barrier which is in the center of the page. This order gives the procedure user the mind set that the EALs are listed in the same order: RCS EAL followed by the Fuel Clad EAL. Changing the order of the EALs is not a deviation from the approved EAL scheme but is a difference.

This change does not constitute a decrease in the effectiveness of the EPLAN since the EALs are exactly the same.2008-02 10/08 As of this change 2008-02, the Emergency Plan is now available on NEDL/SCRIBE and has been completely re-issued.

All changes in the future to the Emergency Plan will be completed thru NEDL/SCRIBE.

The following Agreement Letters were also updated: 1, 2, 3, 4, 5, 6, 7, 9, 10, 11, 19 and 21.2009-01 02/09 Revised existing information relating to organization names that have changed, removed specific names and replaced with a title to mitigate the need for future revisions due to personnel changes, and changed staging location names based on changes made to area designation names; however staging will still occur in same area. Changes made only reflect actual organization names, functional position names, and current location names being used to make the E-Plan more accurately reflect current information.

No changes are being made to the process or conduct of the how the E-Plan is to be implemented 2010-10 02/10 Revised existing information relating to changes made to the callback system, who performs the dose assessments, the basis information for the Containment Barrier EAL based on NEI 99-01 Rev 5 FAQ lessons learned. Made name change for Oconee Medical Center, corrected information relating to testing frequency for major elements referenced in the E-Plan, the new neutron instrument used by radiation protection, and street name change for figure H-3A.Changes made are the result of the Annual Review process and no changes are being made to the process or conduct of how the E-Plan is to be implemented.

The following Agreement Letters were also updated: Number -6, 8, 13, 14, 15, 16, 18, 20, 22, & 23.7 Revision 2012-04 REVISION NUMBER 2011-01 EFFECTIVE DATE 05/11 2011-02 10/11 2012-01 06/12 RECORD OF CHANGES REASON FOR CHANGE Figure B-10 -Redistribution of support for Field Monitoring Teams from Chemistry to Business Management and Work Control. Section D -Basis corrected to delete reference to USFAR Table 15-114 which has been deleted, revised ICs 4.3.A.3 and 4.4.A.3, EAL A to align with RP/0/B/1000/001, revised ICs and EALs to add levels of operating modes that represent the operating levels of hot shutdown, cold shutdown and hot standby were listed, added "AC" back to IC 4.5.A. 1 where it had been inadvertently deleted, add SSF to IC 4.6.U. 1, correct IC 4.5.G. 1, EAL 1 to reflect SSF maintaining Mode 3 (hot standby) rather than hot shutdown, add new ICs for Jocassee Dam condition A and B declarations, correct misprint in IC 4.7.A.2, EAL B, correct formatting errors, and add Security EALs. Section F -deleted onsite areas requiring phone notifications for site assembly due to new wireless system being installed in those areas. Section G -replace 2010 calendar with 2011 calendar.

Figure H-I -revised room layout to reflect current arrangement.

Section N -Revised the testing cycle for the EPLAN from a 5 year cycle to a 6 year cycle. Appendix 5 -update letters of agreement.

This evaluation supports a request to revise the Oconee (ONS), McGuire (MNS), and Catawba (CNS) Emergency Plans to allow for an alternate approach for compliance with 10 CFR 50.47(b)(2) relative to meeting the minimum staffing requirement during emergencies for site Radiation Protection (RP) personnel and the Emergency Operations Facility (EOF)position staffing to that in Table B-1 in NUREG-0654, endorsed by Regulatory Guide 1.101.Section F -A change to the process for answering the 4911 emergency phone calls. The new process will have both Operations and Security(SAS) answering the phone.Appendix 7 -Will clarify the ERDS related system description verbiage from the modem based data transfer system to the new VPN System.The NRC published Federal Register notice [RIN 3150-Al 101,"Enhancements to Emergency Preparedness Regulations" on November 23, 2011. The amendments contained in the rule are summarized as twelve (XII) topics with varying implementation due dates. Emergency Plan changes to the following sections (C, D, H, I, J, P, and Appendix 1) are made in accordance with the rule and the appropriate guidance documents pertaining to Topic V -Emergency Action Level for Hostile Action, Topic V1 -Emergency Declaration Timeliness, Topic VII1 -Emergency Operation Facility (Performance Based), Topic IX -Emergency Response Organization Augmentation at Alternate Facility, and Topic XI -Protective Actions for On-site Personnel.

Added Agreement Letter 25 -G&G Metal Fabrication to provide Hale pump technical support and Agreement Letter 26 Operating Agreement between Duke Energy's Lincoln Combustion Turbine Facility & MNS, CNS and ONS Nuclear Supply Chain concerning an Emergency Supply of Diesel Fuel.8 Revision 2012-041 2012-02 06/12 2012-03 06/13 I RECORD OF CHANGES REVISION EFFECTIVE DATE NUMBER REASON FOR REVISIONS 2012-04 12/12 Section B -This change is to incorporate the new staffing analysis for the new EP rule and editorial changes.9 Revision 2012-04 B. ONSITE EMERGENCY ORGANIZATION Adequate staffing to provide for initial emergency response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the interfaces among various onsite response activities and offsite support and response activities are specified.

B. 1. Emergency Response Organization Figures B-I through B-6 shows the Oconee Nuclear Site Emergency Response Organization that would be established during an incident along with the duties the different groups would assume. Designation of personnel to the Emergency Response organization is determined by the particular job expertise of an individual.

This assures that these personnel are qualified to carry out their responsibilities during an emergency.

The normal staffing assignments at the Oconee Nuclear Site include emergency response responsibilities.

See Figures B-10 for emergency responsibilities for designated groups.The Emergency Response Organization is outlined in Division/Section Directives.

These directives establish the duties, responsibilities and alternates for each required emergency response position.

Response procedures have been established for each section through these Directives.

B.2. Emergency Coordinator

-(24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />)As a result of training and day-to-day experiences in the normal operating mode at the Oconee Nuclear Site, the Operations Shift Manager will assume authority and responsibility for any emergency that may arise at the site. He will assume control of the situation, alert and warn personnel and others, take necessary onsite remedial action, obtain necessary outside aid and notify management and appro-priate offsite agencies.

The authority vested in this position by Duke Energy management enables the Operations Shift Manager to declare an emergency as necessary to protect the plant, site personnel, and the general public. He is vested with the authority to provide protective action recommendations to state and local agencies for implementing offsite emergency measures.The Operations Shift Manager will continue with these responsibilities until relieved by the Station Manager (alternate).

B-i Rev. 12-04 December 2012 B.3. Alternates for Emergency Coordinator In an emergency situation where the Station Manager/Emergency Coordinator is unavailable, for whatever reason, and an acting Station Manager has not been designated in writing, an alternate will be contacted.

Alternates are personnel with intimate knowledge of plant operations and will fulfill the position as TSC Emergency Coordinator when assigned duty. Alternates are designees appointed by the Station Manager.Note: Emergency Telephone Directory, provides names, home addresses and phone numbers for the Emergency Coordinators listed above.B.4 Functional Responsibilities of the Emergency Coordinator Figure B-5 defines the duties and responsibilities of the Emergency Coordinator within the emergency response organization.

The Emergency Coordinator and the EOF Director are the individuals responsible for making protective action recommendations to the state and county agencies.Once the Emergency Operations Facility is activated, only the EOF Director has this responsibility.

Prior to the activation of the EOF, the Emergency Coordinator is responsible for making protective action recommendations, classifying/

downgrading/

escalating/terminating events, and approving notification forms to offsite agencies.

These responsibilities may not be delegated.

B.5 Minimum Staffing Requirements for Nuclear Power Plant Emergencies Figure B-8(a/b) identifies the positions by title and major tasks to be performed by the persons assigned to the functional areas of emergency activity within 45 to 75 minutes. The TSC and OSC will be activated within 75 minutes of event classification.

The EOF (Figure B-9) will also be staffed and operational by a minimum staff within 75 minutes of event classification.

A detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in Figure B-8a is located in ONS-OSSA-12212012 Rev: 0.B.6 Interface

-Onsite, Offsite Organizations (Figure A-1) shows the interfaces between and among the onsite functional areas of emergency activity, site support, local services support, and State and Local government response organizations.

The onsite Technical Support Center, Operational Support Center, and the Emergency Operations Facility is shown.B-2 Rev. 12-04 December 2012 B.7 Minimum Staffing Reauirements

-Corporate Level Personnel from the corporate location will provide assistance to the Oconee Nuclear Station in the areas of dose assessment, coordination of news media and severe accident analysis.

These people will respond on an as needed basis.The Emergency Response Facility Organization is shown on Figures B-4A through B-4D. Division/Section Directives detail the emergency response organization and are included as implementing procedures.

Should an event occur at another Duke Energy nuclear facility concurrent with an event at Oconee Nuclear Site, additional resources would be required to support the EOF Organization.

Figure B- II shows the supplemental EOF organization that would be required to manage a multi-site event. An additional Assistant EOF Director would function as the lead manager to support the second site. The EOF Director would have overall emergency management responsibility for both events.B.8 Contractor/Private Organizations

-Technical Assistance Private Contractors and/or companies that would be available to augment and support the emergency organization:

Waste Management Chem Nuclear Bartlett Nuclear Emergency Equipment Supplier SEG (e.g. Safe Industries, Inc.)Alaron AREVA Additional groups that could respond to emergencies would be contacted by the Site Services Group who are represented at the Emergency Operations Facility.B.9 Local Agency Support Agreements with local agency support groups have been made to assist the Oconee Nuclear Site during emergency situations.

POLICE -Oconee Sheriffs Department Pickens Sheriffs Department S. C. Highway Patrol S. C. Law Enforcement Division B-3 Rev. 12-04 December 2012 AMBULANCE

-Oconee Medical Center -Emergency Medical Services MEDICAL -Blue Ridge Emergency Physicians Oconee Medical Center FIRE-FIGHTING

-Oconee Rural Fire Association Keowee-Ebenezer Fire Department Corinth-Shiloh Fire Department Six-Mile Fire Department Keowee Fire Department RADIOLOGICAL MONITORING

-Pickens County Emergency Management Agency Oconee County Emergency Management Agency EVACUATION OF POPULATION

-Oconee County Emergency Management Agency Pickens County Emergency Management Agency HOSPITAL -Oconee Medical Center USE OF BUILDINGS

-Oconee County School District Pickens County School District BA Rev. 12-04 December 2012 FIGURE B-1 OCONEE NUCLEAR STATION EMERGENCY RESPONSE ORGANIZATION FUNCTIONAL AREAS OF EMERGENCY RESPONSE Emergency Response Coordination Operations Shift Manager Station Manager Division Managers Section Managers 2. Plant Systems Operations Superintendent of Operations Operations Shift Managers Operations Engineers On Shift Staff (Operations)

Engineering

3. Accident Assessment Emergency Coordinators Operations Shift Managers Operations Engineers Shift Managers Site Engineering Severe Accident Analysis Group (GO)4. Radiological Environmental Survey and Monitoring Contract service Radiation Protection Section 5. First Aid/Rescue, Firefighting Medical Emergency Response Team Members Fire Brigade 6. Personnel Monitoring Radiation Protection Section 7. Decontamination Radiation Protection Section B-5 Rev. 12-04 December 2012 FIGURE B-1 OCONEE NUCLEAR STATION EMERGENCY RESPONSE ORGANIZATION

8. Security of Plant and Access Control Duke Security (ONS and Oconee JIC)Building Security/Access

& Control (Charlotte EOF)9. Repair/Corrective Actions Nuclear Supply Chain Site Services Group 10. Personnel Accountability Division Managers Section Managers Supervisors Duke Security 11. Radiological Accident Assessment Radiation Protection Section (ONS/GO/CNS/MNS)

Site Engineering Operations Group Chemistry Group Severe Accident Analysis Group (GO)12. Communications Operations Safety Assurance Training Nuclear Assurance 13. Radiation Protection Section Radiation Protection Section 14. Plant ChemistKy Chemistry Group B-6 Rev. 12-04 December 2012 FIGURE B-i OCONEE NUCLEAR STATION EMERGENCY RESPONSE ORGANIZATION

15. Radwaste Operations Chemistry Group 16. Technical Support Site Engineering

17. Manpower Planning and Logistical Support Work Control Group Nuclear Supply Chain Site Services Group 18. Public Information Corporate Communications

-Joint Information Center 19. Licensee Representative to State County EOC Site Engineering B-7 Rev. 12-04 December 2012 FIGURE B-2 DUKE ENERGY COMPANY OCONEE NUCLEAR STATION TECHNICAL SUPPORT CENTER ORGANIZATION CHART B-8 Rev. 12-04 December 2012 FIGURE B-3 DUKE ENERGY COMPANY OCONEE NUCLEAR STATION OPERATIONAL SUPPORT CENTER ORGANIZATION CHART OPERATIONAL SUPPORT CENTER OSC B COORDINATOR Technical Assistant I Work Control Technical Assistant 11 F Nuclear Supply Chain Work Control Se urt Oprations Mitn ceEngineering ManGerou Liaison Maitnanera

~RP Shift 1-SRO Shift SPOC Team_sige with Radiological Asso Corporate GO (as B-9 Rev. 12-04 December 2012 FIGURE B-4A OCONEE NUCLEAR STATION Emergency Operations Facility Assistant EOF Director I Accident Assessment Manager Radiological Assessment Manager I EOF Dose Assessors B-10 Rev. 12-04 December 2012 FIGURE B-4B DUKE ENERGY COMPANY OCONEE NUCLEAR STATION EMERGENCY OPERATIONS FACILITY EOF Services Manager Food &Communications Logistics Transportation Lodging Rev. 12-04 December 2012 FIGURE B-4C OCONEE NUCLEAR STATION EMERGENCY OPERATIONS FACILITY Radiological Assessment Manager[Assessors HPN RP Status Communicator Boards B-12 Meteorological (GO Support)Rev. 12-04 December 2012 FIGURE B-5 OCONEE NUCLEAR STATION EMERGENCY COORDINATOR DUTIES Duties and Responsibilities:

1. Activate the Emergency Response Organization (Technical Support Center, Operational Support Center and the Emergency Operations Facility).

2. Coordinate technical assistance for remedial actions to mitigate circumstances surrounding plant operations.

3. Designate individual to communicate with offsite agencies promptly.

Approve all information released via the emergency notification form. Approval (signature) of contents of message form may not be delegated to others in the emergency organization.

4. Initiate emergency actions within the provisions of the Oconee Nuclear Site Emergency Plan.5. Classify emergency events. Escalate/de-escalate or ternlinate from an emergency status if the Emergency Operations Facility is not operational.

Responsibility may not be delegated.

6. Make senior technical and management staff available onsite for consultation with NRC and State on periodic basis if EOF has not been activated.

7. Coordinate all emergency actions concerning the technical aspects of the corrective actions taken within the Technical Support Center.8. Evacuate all non-essential personnel on site if a radiological emergency exists. Be aware of exposure guidelines of personnel.

9. Recommend protective action guides for the safety and welfare of the public to the appropriate offsite agency if the Emergency Operations Facility/EOF Director is not in a position to do so. This authority may not be delegated.

10. Authorize exposures in excess of routine yearly exposure limits for lifesaving and equipment repair missions in accordance with RP/0/B/1000/11.

This responsibility can be delegated to the RP Manager in the OSC.B-13 Rev. 12-04 December 2012 FIGURE B-6 OCONEE NUCLEAR STATION EMERGENCY OPERATIONS FACILITY DIRECTOR Duties and Responsibilities:

I. Overall Management of the offsite emergency response activities of Duke Energy (Oconee Nuclear Site).2. Recommend protective action guides for the safety and welfare of the public to the appropriate offsite agency. This authority may not be delegated.

3. Classify emergency events. Escalate, de-escalate, terminate emergency classification.

This responsibility may not be delegated.

4. Approve all information released via the emergency notification form.Approval (signature) of contents of message form may not be delegated to others in the emergency organization.

5. Coordination with federal, state and local government agencies.6. Provide approval of news releases if Public Spokesperson is unavailable.

B-14 Rev. 12-04 December 2012 FIGURE B-8a OCONEE NUCLEAR STATION MINIMUM ON-SHIFT STAFFING LEVELS 0)(-Functional Area Major Tasks Emergency Positions 1. Plant Operations and CR Supervisor (SRO) 3 Assessment of Control Room Operator (RO) 6 Operational Aspects (a) Non-Licensed Operator (NLO) 3 2. Emergency Direction Command and Control Ops Shift Manager 1 and Control Licensee Operator (SRO/RO/NLO) 3 .N o tific a tio n & ---c. e -n. ..... s.. .. e. ............

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

..........

.. .........

.--- -e -a ° -S R --! F N L O --............

.... -- ....Local/State SRO 1 C o m m u n ic a tio n ..... .. ..... ...............

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

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

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

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

...Fe..ra l ... .r ..........

R.o/ .o.-l ..... .. ..................

.. .........] ]....Commnictioral Operator (SRO/RO/NLO) 1 Dose Assessment RP Qualified Individual 1 4. Radiological In-plant Surveys -- RP Qualified Individual

-1 4 ...........

I -.a.n ._ _ .J .r e y .... .... ......._ _...... ........................

---

-.--- ------.d ... ---i _._u a .! ... ....... .... .... .........

... .....1 ...........

Assessment Onsite Surveys ... ..RP Qualified Individual 1 Chemistry Chemistry Technician I Tech Support -OPs Shift Technical Advisor 1 Engieerig, R pair... ... .... ..... .. -_5. P lngi e ri g Sys em a r -........................

C or-e-D a-m a~ge S h .. if .t -T -c.hni .c..a.I A.d. .i s -.-. or-iiiiiiiii .i ................

.. .... .. .i.....j..15 and Corrective Actions Repair and Corrective Mechanical Maintenance 2 Actions IAE Maintenance 2 Radiation Protection

6. In-Plant PAs (such as access control, job RP Qualified Individual 2 (b)coverage and personnel monitoring)

Fire Brigade Lead (SRO/NLO) 1 7. Fire Fighting (c) -- Fire Brigade Member (NLO) 4 Fire Brigade Member 5 (bc)8. Ist Aid and Rescue -- MERT (d) 2 9. Site Access Control S SAS Operator 1 and Accountability Security & Accountability Security Personnel Minimum # of Persohnne:

1 (a) The Control Room staff complement is reflective of 3 Units in operation.(b) May be performed by an individual filling another position provided they are qualified to do the collateral function.(c) The Fire Brigade requirement of ten members is met by using five personnel from Operations (including the Fire Brigade Leader) and five personnel from either SPOC, Radiation Protection, Chemistry or Security (SLC 16.13.1).(d) The Medical Emergency Response Team (MERT) can be filled by any qualified technician.(e) Per Duke Energy ONS Security Plan.B-15 Rev. 12-04 December 2012 FIGURE B-8b OCONEE NUCLEAR STATION MINIMUM AUGMENTED ERO STAFFING LEVELS MAJOR FUNCTIONAL AREA MAJOR TASKS POSITION TITLE OR CAPABILITY EXPERTISE FOR ADDITIONS*

WITHIN 45 WITHIN 75 MINUTES MINUTES Emergency Director and Control Station Manager I (Emergency.

Coordinator)

• • • Notification/Communication Notify Company Personnel, State, State Communicators 2 County, Federal Agencies and maintain communication EOF/Radiological Accident Assessment EOF Director (Emergency DPC Senior Manager I and Offsite Agency Support Classification, Protective Action Recommendation, Offsite Agency Interface, ENF approval)Emergency Classification EOF Plant Assessment Accident Assessment Manager I Dose Assessment and EOF Offsite Dose Assessment]

Radiological Assessment Protective Action Protective Action Manager I Recommendations Recommendations Offsite Notifications Offsite Agency Notifications Offsite Agency Communicator I II EOF Access Control Electronic Card Reader #TSC Dose Assessment/Protective Radiological Assessment I Action Recommendations Offsite Surveys Field Monitoring Teams (2) 4 Onsite Surveys (Out-of-Plant)

I I In-Plant Surveys RP Qualified Individuals I I Chemistry/Radio Chemistry Rad/Chem Technician I Plant System Engineering, Repair and Technical Support Core/Thermal Hydraulics I Corrective Actions Electrical I Mechanical I Repair and Corrective Actions Mechanical Maintenance I Rad/Waste Operator I I&E Technician 2 Protective Actions Radiation Protection RP Qualified Individuals

', (In-Plant)

A. Access Control B. RP Coverage for Repair Corrective Actions, Search and Rescue, First Aid & Firefighting C. Personnel Monitoring D. Dosimetry E. On-Shift Dose Assessment Firefighting Fire Brigade Local Support Rescue Operations

& First-Aid MERT Team Local Support B-16 Rev. 12-04 December 2012 FIGURE B-8b OCONEE NUCLEAR STATION MINIMUM STAFFING LEVELS Consideration is given to the fact that many of the Oconee Nuclear Site Emergency Response Organization personnel do not live within a radius of the station which will allow a response time of 30 minutes or less under ideal conditions.

Factors such as weather conditions, road capacity and traffic density, and the distance to travel from residence to the emergency response facility, indicate a realistic response time from a few minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes for most employees.

Consideration is also given to personnel on shift who are qualified and sufficient in number to handle any emergency condition until response personnel begin to arrive on site.**

• Management of the Offsite Emergency Response will be assumed by the EOF Director when the Emergency Operations Facility is activated.

Management of the Onsite Emergency Response is assumed by the Station Manager/alternate acting as the Emergency Coordinator when the Technical Support Center and Operational Support Centers are activated.

• • • • The Field Monitoring Teams will initially report to the Body Burden Analysis (BBA)Room. If needed, the Field Monitoring Teams will dispatch from the Body Burden Analysis (BBA) Room. Once the Emergency Operations Facility (EOF) Field Monitoring Coordinator is ready he/she will assume control of the Field Monitoring Teams. A FMT consists of one RP qualified individual and one vehicle driver.#4 An electronic card reader in conjunction with a posted building security officer fulfills the function for controlling access to the EOF during emergencies.

B-17 Rev. 12-04 December 2012 FIGURE B-9 OCONEE NUCLEAR STATION MINIMUM STAFFING REQUIREMENTS EOF DIRECTOR AcietRadiological Offsite Agency Assessment Assessment Manager Communicator (2)Manager B-18 Rev. 12-04 December 2012 0 0 FIGURE B-10 OCONEE NUCLEAR STATION ONSITE EMERGENCY RESPONSE DUTIES RADIATION CHEMISTRY MAINTENANCE OPERATIONS WORK CONTROL BUSINESS GROUP PROTECTION Onsite Monitoring Post-accident liquid Repair/calibration of Plant Operations OSC Coordination Provide personnel for field sampling electrical and monitoring teams mechanical equipment Initial dose assessment Chemistry analysis Staff OSC with onshift Accident assessment Recovery implementation personnel Decontamination Tank farm operation Augment OSC with Safe shut-down of Provide personnel for field additional personnel reactor monitoring teams Post-accident gaseous Radwaste operation Liaison with OSC sampling Dose Control Fire brigade response Provide personnel for Initial Emergency field monitoring teams Management Evacuation coordination NRC Communications RP support for work tasks Fire Support in the field B-19 Rev. 12-04 December 2012 0 FIGURE B-10 OCONEE NUCLEAR STATION ONSITE EMERGENCY RESPONSE DUTIES 0 SAFETY ASSURANCE ENGINEERING SECURITY SAFETY NUCLEAR SUPPLY CHAIN I SITE SERVICES GROUP TSC LOG ACCESS & CONTROL COMMUNICATIONS EQUIPMENT OFF SITE TSC/OSC LIAISON EVACUATION SUPPLY/PARTS COMMUNICATIONS TECHNICAL ASSISTANT COORDINATION ASSIST WITH ENGINEERING SUPPORT MEDICAL (MERT) PERSONNEL HEAVY EQUIPMENT ACCOUNTABILITY SAFETY OPERATORS REPORTING ASSIST WITH EVACUATION LIAISON WITH CORPORATE COMMISSARY ACCIDENT ASSESSMENT GROUP EMERGENCY PLANNING TSC STATUS BOARDS B-20 Rev. 12-04 December 2012 0 FIG& B-11 OCONEE NUCLEAR STATION Common EOF -Multi-Site Event Staffing EOF Offsite Aqency EOF Services Communicators (6) Manager (1)I. Pagers activated for second unit -all call response 2. Assistant EOF Director assumes responsibility as lead manager for designated Site 3. Additional Log Keeper retained to support 2"d Site 4. Additional Accident Assessment Manager retained to support 2 nd Site 5. Additional Dose Assessor retained to support 2 nd Site 6 Additional FMT Coordinator retained to support 2 nd Site 7. Additional FMT Radio Operator retained to support 2"d Site 8. Four additional Offsite Communicators as needed to support both Sites 9. Additional Emergency Planner as needed to support 2 nd Site 10. Additional Radiological Assessment Manager as needed to support 2'nd Site I1. Additional Assistant EOF Director as needed to support 2 d Site 12. Oconee Ops Interface position is staffed in the ONS TSC 13. Additional Accident Assessment Interface as needed to support 2"d Site B-21 Rev. 12-04 December 2012 Emergency Planning Functional Area Manual 3.10 1OCFR 50.54(q) Evaluations Attachment 3.10.7.2§50.54(q)

Screening Evaluation Form Activity Description and

References:

See Attached mark-up of Oconee Nuclear Station, BlOCK.I.Emergency Plan, Section B -Site Emergency Organization The following changes are to be evaluated from Oconee Nuclear Station, Emergency Plan, Section B -Site Emergency Organization: (Screening 1 of 2 -Conforming Changes)I Section B.5: Added paragraph for the required detailed analysis of on-shift staffing fulfilled in the Oconee Nuclear Station (ONS) Emergency Response Organization (ERO) On-shift Staffing Analysis Report, Revision 0.2. Figure B-8a: Added Figure B-8a that corresponds to Section 2.2 of the ONS ERO On-shift Staffing Analysis Report, Revision 0.3. Figure B-8a: Title created for Figure B-8a for "MINIMUM ON-SHIFT STAFFING LEVELS." 4. Figure B18b: Added "AUGMENTED ERO" to title to differentiate from Figure B-8a.5. Figure B-8b: Deleted the second paragraph under "*," as this information is now explicitly stated in Figure B-8a.6. Figure B-Sb: Deleted "**" and the associated description, as this information is now contained in Figure B-8a.Discussion:

10 CFR 50 Appendix E.IV specifies the requirements for the content of emergency plans. Subsection A.9 states the following:

By December 24, 2012,for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.As part of the overall Emergency Preparedness rulemaking published in November of 2011, the Commission amended §50, Appendix E,Section IV.A, Organization, to address concerns regarding the assignment of tasks or responsibilities to on-shift emergency response organization (ERO) personnel that would potentially overburden them and prevent the timely performance of their emergency plan functions.

In conjunction with the new rule, the NRC issued Interim Staff Guidance (ISG) NSIR/DPR-ISG-01.

ISG Section IV.C provides specific detail on the criteria and acceptable methods for the conduct of the staffing analysis and includes the endorsement of NEI 10-05. The Oconee Nuclear Station (ONS) on-shift staffing analysis was performed in accordance with NEI 10-05.The ISG considers the staffing analysis to be the technical basis for the on-shift ERO and also requires that it be part of emergency plan. The ISG specifies that §50.54(o) is the process by which staffing analyses are to be incorporated into licensee emergency plans. §50.54(q) uses the characteristic"reduction in effectiveness" to exclude those changes that would not reduce the effectiveness from the requirement to seek prior NRC approval, and therefore maintain the NRC staff's reasonable assurance determination, of the "original" approved emergency plan.Adding the staffing analysis to the emergency plan per the new requirement of §50, Appendix E,Section IV.A.9 does not, by itself, reduce the effectiveness of the emergency plan, and as such does not require prior NRC approval.

Regulatory Guide 1.219 requires consideration of"the basis for the staffs Revision 12 Emergency Planning Functional Area Manual 3.10 10CFR 50.54(q) Evaluations Attachment 3.10.7.2 approval of the original plan" when performing a §50.54(q) evaluation for changes being made to the emergency plan. Since the on-shift ERO is part of the emergency plan, there is a licensing basis for that specific staffing level. At ONS, there was no prior on-shift staffing analysis mentioned in the emergency plan. Adding the staffing analysis to the ONS emergency plan, as the technical bases for that shift staff'ig, does not change the licensing basis because the report simply documents the methods and process used to formally establish the adequacy of the NRC approved on-shift staffing complement.

The results of the ONS analysis validate the adequacy of the current on-shift staffing ERO licensing basis and conclude that the emergency plan fulfills the §50.47(b)(2) planning standard requirement to have an adequate on-shift staffing level. As such, the inclusion of the staffing analysis as part of the ONS emergency plan does not result in a reduction in effectiveness and can performed without prior NRC approval.References consulted:

• Oconee Emergency Plan Revision 12-3, Section N 9 FederalRegister Notice (76FR 72560), "Enhancements to Emergency Preparedness Regulations", November 23, 2011 [RIN 3150-AI10]

• Interim Staff Guidance, Rev. 0 (November 2011). NSIR/DPR-ISG-01

• NEI 10-05 [Revision 0], "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," June 2011.PIP Corrective Actions addressed through Emergency Plan revision:* G-12-0205 CA#5 Activity Scope: 0 The activity is a change to the emergency plan El The activity jinot a change to the emergency plan Change Type: BLJOCK3? Change Type: W El The:change is editorial:or:typographical 0 The change does conform to an activity that has 0 The change isnot editorial or typographical prior approval Ill The change does not conform to an activity that has prior approval Emergency Planning Functional Area Manual Attachment 3.10.7.2 3.10 10CFR 50.54(q) Evaluations Planning Standard Impact Determination:

C1 §50.47(b)(1)

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

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

-Emergency Response Support and Resources[I §50.47(b)(4)

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

-Notification Methods and Procedures*

El §50.47(b)(6)

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

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

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

-Accident Assessment*

El §50.47(b)(10)

-Protective Response*El §50.47(b)(1

1) -Radiological Exposure Control 0l §50.47(b)(12)

-Medical and Public Health Support El §50.47(b)(13)

-Recovery Planning and Post-accident Operations El §50.47(bX14)

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

-Emergency Responder Training El §50.47(b)(16)

-Emergency Plan Maintenance

• Risk :Significant Planning Standards El The proposed activity does not impact a Planning Standard*Per the procedure Block 5 is skipped. -DMB, 11.20.12*BLOC K5 Commitment Impact Determination:

BLOCK 6 El The activity does involve a site specific EP commitment Record the commitment or commitment reference:

E The activity does not involve a site specific EP commitment

• Per the procedure Block 6 is skipped. -DMB, 11.20.12*Screening Evaluation Results: B 7[ The activity can be implemented without performing a §50.54(q) effectiveness evaluation E The activity cannot be implemented without performing a §50.54(q) effectiveness evaluation Preparer Name: Douglas M. Brunson Prep Sgn re Date: November 20,.2012.1 Reviewer Name: Reyer.Signature Date::IA4, 6Vqf~?2'n_

_/

Emergency Planning Functional Area Manual 3.10 1OCFR 50.54(q) Evaluations Attachment 3.10.7.2§50.54(q)

Screening Evaluation Form Activity Description and

References:

See Attached mark-up of Oconee Nuclear Station, I"BLOCK I Emergency Plan, Section B -Site Emergency Organization The following changes are to be evaluated from Oconee Nuclear Station, Emergency Plan, Section B -Site Emergency Organization: (Screening 2 of 2 -Editorial Changes)1. Section B.5: Revised Figure B-8 references as appropriate to differentiate between Figure B-8a and Figure B-8b.2. Section B.9: Added a "-" behind "MEDICAL" to maintain internal consistency.

3. Figure B-i: Removed "DUKE ENERGY COMPANY" from title to maintain consistency.

4. Figure B-4A: Removed "DUKE ENERGY COMPANY" from title to maintain consistency.

5. Figure B-4C: Removed "DUKE ENERGY COMPANY" from title to maintain consistency.

6. Figure B-5: Removed "DUKE ENERGY COMPANY" from title to maintain consistency.

7. Figure B-6: Removed "DUKE ENERGY COMPANY" from title to maintain consistency.

8. Figure B-8: Removed "DUKE ENERGY COMPANY" from title to maintain consistency.

9. Figure B-8b: Renamed original Figure B-8 to Figure B-8b.10. Figure B-8b: Relocated "Plant Operations and Assessment of Operational Aspects" to Figure B-8a.11. Figure B-8b: Relocated "Operations Shift Manager" to Figure B-8a.12. Figure B-8b: Relocated "Control Room Senior Reactor Operator (SRO)" equivalent to Figure B-8a.13. Figure B-8b: Relocated "Control Room Reactor Operators (RO)" equivalent to Figure B-8a.14. Figure B-8b: Relocated "Nuclear Equipment Operators" equivalent to Figure B-8a.15: Figure B-8b: Relocated "Operations Designee" equivalent for communications to Figure B-8a.16. Figure B-Sb: Relocated "Shift Technical Advisor (STA)" to Figure B-Sa.17. Figure B-8b: Relocated "Site Access Control and Personnel Accountability" to Figure B-8a.18. Figure B-8b: Relocated "Security, Firefighting Communications, Personnel Accountability" equivalent to Figure B-8a.19. Figure B-Sb: Relocated "Security Personnel" to Figure B-8a.20. Figure B-8b: Reformatted Figure B-Sb by removing empty rows/columns due to relocated information to Figure B-Sa.21. Figure B-9: Removed "DUKE ENERGY COMPANY" from title to maintain consistency.

22. Figure B- 10: Removed "DUKE ENERGY COMPANY" from title to maintain consistency.

23. Figure B-I 1: Removed "DUKE ENERGY COMPANY" from title to maintain consistency.

24. Footer: Renamed to Rev. 12-04, December 2012 as to accurately reflect the current ONS Emergency Plan Revision.25. Various editorial changes to the document for internal consistency. (ex. Font size, Bold/Not Bold, Tabs, Underline, etc)Discussion:

These changes are considered to be editorial because they are* Reference or annotation changes," Procedure title changes,* Grammar, and* Formatting changes that do not change intent,:purpose, or order of procedural steps and do not change the intent or value of a program element and do not impact the capability or timeliness of the Emergency Notification Function and will not be evaluated further.References consulted:

• Oconee Emergency Plan Revision 12-2, Section N Revision 12 Emergency Planning Functional Area Manual Attachment 3.10.7.2 3.10 1OCFR 50.54(q) Evaluations

• Federal Register Notice (76FR 72560), "Enhancements to Emergency Preparedness Regulations", November 23, 2011 [RIN 3150-AIl10]

• Interim Staff Guidance, Rev. 0 (November 2011). NSIR/DPR-ISG-01

• NEI 10-05 [Revision 0], "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," June 2011.ergency Plan revision addressed the following PIP Corrective Actions:* G-12-0205 CA#5 Em Activity Scope: BLOCK 2 Z The activity is a change to the emergency plan El The activity isno a change to the emergency plan Change Type: Change Type: _K 4 0 The change is editorial or typographical Cl The changedoes conform to an activity that has El The changeis not editorial or typographical prior approval 0" The change does not conform to an activity that has prior approval*Per the procedure Block 4 is skipped.~DMB, 11.20.12" Planning Standard Impact Determination:

[I §50.47(b)(1)

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

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

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

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

-Notification Methods and Procedures*

El §50.47(bX6)

-Emergency Communications El §50.47(bX7)

-Public Education and Information E §50.47(bX8)

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

-Accident Assessment*

El §50.47(b)(10)

-Protective Response*El §50.47(b)(l

1) -Radiological Exposure Control l §50.47(b)(12)

-Medical and Public Health Support El §50.47(bX 1 3) -Recovery Planning and Post-accident Operations El §50.47(bX14)

-Drills and Exercises El §50.47(bX15)

-Emergency Responder Training El §50.47(b)(16).-

Emergency Plan Maintenance

• Risk Significant Planning Standards El The proposed activity does not impact a Planning Standard*Per the procedure Block 5 is skipped. -DMB, 11.20.12P Commitment Impact Determination:

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

_ ___ ....___E] The activity does not involve a site specific EP commitment

• Per the procedureBlock 6 is skipped. -DMB, 11.20.12*

1:

Emergency Planning Functional Area Manual 3.10 1 OCFR 50.54(q) Evaluations Attachment 3.10.7.2 Screening Evaluation Results: Il tOCK7,[ The activity can be implemented without performing a §50.54(q) effectiveness evaluation L] The activity cannot be implemented without performing a §50.54(q) effectiveness evaluation Preparer Name: Douglas M. Brunson re ature Date: November 20,2012 Reviewer Name: Rev' e ina Date: