RA-19-0427, Emergency Plan PLP-007, Rev. 92
| ML19325E303 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/21/2019 |
| From: | Catherine Nolan Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RA-19-0427 | |
| Download: ML19325E303 (15) | |
Text
M. CHRISTOPHER NOLAN Vice President
(_~ DUKE
~ ENERGY Nuclear Regulatory Affairs, Policy &
Emergency Preparedness 526 South Church Street, EC-07C Charlotte, NC 28202 980-382-7426 Chris. Nolan@duke-energy.com Serial: RA-19-0427 10 CFR 50.54(q)
November 21, 2019 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 I RENEWED LICENSE NO. DPR-23
SUBJECT:
Emergency Plan PLP-007, Revision 92 Ladies and Gentlemen:
In accordance with 10 CFR 50.54(q), Duke Energy Progress, LLC is submitting a revision summary for H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, Emergency Plan PLP-007, Revision 92, which is effective November 04, 2019.
In accordance with 10 CFR 50.54(q)(5), Attachments I and II include a summary of analyses associated with the emergency plan changes.
This document contains no new Regulatory Commitments.
Should you have any questions concerning this letter, or require additional information, please contact Art Zaremba, Director- Nuclear Fleet Licensing, at 980-373-2062.
S i n e ~~
M. Christopher Nolan Vice President, Nuclear Regulatory Affairs, Policy & Emergency Preparedness Attachment I: 10 CFR 50.54(q) Screening Evaluation Form Attachment II: 10 CFR 50.54(q) Effectiveness Evaluation Form cc: L. Dudes, NRC Regional Administrator, NRC, Region II M. Fannon, NRC Senior Resident Inspector, HBRSEP, Unit No. 2 M. Barillas, NRC Project Manager, NRR
U.S. Nuclear Regulatory Commission Attachment I, Page 1 Serial: RA-19-0427 Attachment I: 10 CFR 50.54(q) Screening Evaluation Form
U.S. Nuclear Regulatory Commission Attachment I, Page 2 Serial: RA-19-0427
<< 10 CFR 50.54(q) Screening Evaluation Form >>
Screening and Evaluation Number Applicable Sites BNP EREG #: 2289207 CNS CR3 HNP MNS 5AD #: 2289016 ONS RNP GO Document and Revision PLP-007 Robinson Emergency Plan Revision 92 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):
- E-Plan or Current (Existing) Text Proposed (Change) Text Supporting Rationale Procedure (Justification) for Section Reference Change 1 Old: Step 5.3.2.1. g OAC Support Deleted The following The OAC Support position responsibility is duplicated reports to the Assistant under Step 5.3.2.1.g IT Emergency Coordinator. support:
Key responsibilities include:
- Monitor facility
- Monitor facility equipment equipment (computer, (computer, communications, communications, etc.) for etc.) for proper operation proper operation
- Activate ERDS or confirm The following ERDS operation responsibility is transferred under Step 5.3.2.1.g IT Support:
2 New Step 5.3.2.1.g IT Support The second bullet was The IT Support position reports transferred from Old to the Assistant Emergency step 5.3.2.1.g OAC Coordinator. Key Support to IT Support.
responsibilities include: Step renumbered
- Monitor facility equipment (computer, communications, etc.) for proper operation
3 Page 86 Figure OAC Support position None Removed position
U.S. Nuclear Regulatory Commission Attachment I, Page 3 Serial: RA-19-0427 5.3.2-1 Technical block Removed from table Support Center ERO 4 Page 92 Table OAC Support (TSC) 1 None Removed position 5.3.2-2 Augmented Removed from table Staffing For Emergencies 5 Step 5.3.2.4. i Logistics Lead (Near Site Logistics Lead (Near Site JIC) The following JIC) responsibilities were The Logistics Lead reports to transferred from deleted The Logistics Lead reports the Near Site JIC Manager. Key Step 5.3.2.4.j Admin to the Near Site JIC responsibilities include: Support (Near JIC):
Manager. Key
- Coordinate ERO/facility shift
- Coordinate distribution of responsibilities include: turnover news releases, statements
- Coordinate ERO/facility and messages
- Manage assigned group shift turnover
- Distribute forms, reports, emergency response activities etc. as needed
- Manage assigned group
- Arrange for logistics support emergency response activities
- Make staffing notifications
- Arrange for logistics
- Coordinate JIC security and support media badging
- Make staffing notifications
- Prepare for facility
- Coordinate JIC security activation (rooms, work area, and media badging equipment, etc.)
- Determine
- Prepare for facility current/projected staff needs activation (rooms, work area, equipment, etc.)
- Provide administrative support for facility operation
- Determine current/projected staff
- Coordinate distribution of needs news releases, statements and messages
- Provide administrative support for facility
- Distribute forms, reports, operation etc. as needed 6 Old Step 5.3.2.4. j Admin Support (Near Site Deleted The following JIC) responsibilities are The Admin Support position duplicated under Step reports to the Logistics 5.3.2.4.i Logistics Lead:
Lead. Key responsibilities
- Prepare for facility include: activation (rooms, work
- Coordinate distribution of area, equipment, etc.)
news releases, statements
- Provide administrative and messages support for facility operation
- Prepare for facility activation (rooms, work
U.S. Nuclear Regulatory Commission Attachment I, Page 4 Serial: RA-19-0427 area, equipment, etc.) The following responsibilities were
- Provide administrative transferred under Step support for facility 5.3.2.4.i Logistics Lead:
operation
- Coordinate distribution of
- Distribute forms, reports, news releases, statements etc. as needed and messages
- Distribute forms, reports, etc. as needed 7 Old Step 5.3.2.4. l Registration Liaison (Near Deleted Deleted Registration Site JIC) Liaison Position &
The Registration Liaison functions. The same reports to the Logistics responsibilities are Lead. Key responsibilities duplicated under the Media include: Center Coordinator in Step
- Register personnel at the 5.3.2.4.g.
assigned location
- Monitor facility entrance areas
- Prepare for facility activation (rooms, work area, equipment, etc.)
8 Page 87 Figure Admin Support and None Removed position 5.3.2-4, Joint Registration Liaison Removed from table Information Center block ERO 9 Step 5.6.1 Organizational Preparedness Organizational Preparedness This change is to align with AD-EP-ALL-0500 Organizational Organizational and the fleet use of preparedness is preparedness is LMS to track maintained through an maintained through an requalification and not integrated training integrated training program the use of an annual program that includes that includes general paper requalification general orientation of all orientation of all persons at checklist.
persons at the site and the site and detailed detailed training of training of individuals and individuals and groups groups required to perform required to perform specific functions and specific functions and actions during an actions during an emergency condition. The emergency condition. training program provides The training program initial training and annual provides initial training continuing training as and annual continuing outlined in AD-EP-ALL-training by completion 0500 Emergency of Annual Response Training.
Requalification Classroom training may be Checklist for designated provided as necessary.
positions to include drill or exercise participation. Initial and
U.S. Nuclear Regulatory Commission Attachment I, Page 5 Serial: RA-19-0427 Requalification Checklists include a review of applicable procedures and job responsibilities.
Classroom training may be provided as necessary.
10 Page 87 Figure Information Gathering Information Gathering No change to the 5.3.2-4, Joint Lead and News Writer Lead and News Writer content of these Information Center (EOF) position box (EOF) position box boxes, the color of the ERO boxes was changed from Blue to Pink to align with other boxes that contain Note 2.
Editorial Part II. Activity Previously Reviewed? Yes No Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or 10 CFR 50.54(q) Continue to Alert and Notification System Design Report? Effectiveness Attachment 4, Evaluation is not 10 CFR If yes, identify bounding source document number or approval reference and required. Enter 50.54(q) ensure the basis for concluding the source document fully bounds the proposed justification Screening change is documented below: below and Evaluation complete Form, Part III Justification: Attachment 4, Part V.
Bounding document attached (optional)
Part III. Editorial Change No or Yes Is this activity an editorial or typographical change only, such as formatting, Partially paragraph numbering, spelling, or punctuation that does not change intent? 10 CFR 50.54(q) Continue to Effectiveness Attachment 4, Evaluation is not Part IV and Justification:
required. Enter address non justification and editorial The proposed change10 is editorial as defined by AD-EP-ALL-0602, complete changes EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS Attachment 4, EVALUATIONS 10 CFR 50.54(Q) and do not cause a reduction in effectiveness of the Robinson Emergency Plan. Part V.
U.S. Nuclear Regulatory Commission Attachment I, Page 6 Serial: RA-19-0427 Part IV. Emergency Planning Element and Function Screen (Reference Attachment 1, Considerations for Addressing Screening Criteria)
Does this activity involve any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If answer is yes, then check box.
1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.
1b The response organization has the staff to respond and to augment staff on a continuing basis (24-7 staffing) in accordance with the emergency plan.
2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned 2b The process for timely augmentation of on shift staff is established and maintained.
3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.
3b State and local staff can be accommodated at the EOF in accordance with the emergency plan. (NA for CR3) 4 10 CFR 50.47(b)(4) Emergency Classification System 4a A standard scheme of emergency classification and action levels is in use. (Requires final approval of Screen and Evaluation by EP CFAM.)
5 10 CFR 50.47(b)(5) Notification Methods and Procedures 5a Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.
5b Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway. (NA for CR3) 5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. (NA for CR3) 6 10 CFR 50.47(b)(6) Emergency Communications 6a Systems are established for prompt communication among principal emergency response organizations.
6b Systems are established for prompt communication to emergency response personnel.
7 10 CFR 50.47(b)(7) Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established.
8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response.
8b Adequate equipment is maintained to support emergency response.
9 10 CFR 50.47(b)(9) Accident Assessment 9a Methods, systems, and equipment for assessment of radioactive releases are in use.
10 10 CFR 50.47(b) (10) Protective Response 10a A range of public PARs is available for implementation during emergencies. (NA for CR3)
U.S. Nuclear Regulatory Commission Attachment I, Page 7 Serial: RA-19-0427 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities. (NA for CR3) 10c A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.
10d KI is available for implementation as a protective action recommendation in those jurisdictions that chose to provide KI to the public.
11 10 CFR 50.47(b) (11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.
12 10 CFR 50.47(b) (12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.
13 10 CFR 50.47(b) (13) Recovery Planning and Post-Accident Operations 13a Plans for recovery and reentry are developed.
14 10 CFR 50.47(b) (14) Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program areas) is established.
14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.
14c Identified weaknesses are corrected.
15 10 CFR 50.47(b) (15) Emergency Response Training 15a Training is provided to emergency responders.
16 10 CFR 50.47(b) (16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.
16b Planners responsible for emergency plan development and maintenance are properly trained.
PART IV. Conclusion If no Part IV criteria are checked, then provide Justification and complete Part V below.
Justification:
Change 9 provides specific guidance on how annual requalification documentation will be maintained. It does not change the requalification process or the training process. There is no change to the intent and there is no impact to the planning standards, therefore, there is no reduction in effectiveness.
If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete , 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q)
Effectiveness Evaluation. Program Element 4a requires final approval of Screen and Evaluation by EP CFAM.
U.S. Nuclear Regulatory Commission Attachment II, Page 1 Serial: RA-19-0427 Attachment II: 10 CFR 50.54(q) Effectiveness Evaluation Form
U.S. Nuclear Regulatory Commission Attachment II, Page 2 Serial: RA-19-0427
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
Screening and Evaluation Number Applicable Sites BNP EREG #: 2289207 CNS CR3 HNP MNS 5AD #: 2289016 ONS RNP GO Document and Revision PLP-007 Robinson Emergency Plan Revision 92 Part I. Description of Proposed Change:
- E-Plan or Procedure Current (Existing) Proposed (Change) Text Supporting Rationale Section Reference Text (Justification) for Change 1 Old: Step 5.3.2.1. g OAC Support Deleted The following The OAC Support responsibility is duplicated position reports to the under Step 5.3.2.1.g IT Assistant Emergency support:
Coordinator. Key
- Monitor facility responsibilities include: equipment (computer,
- Monitor facility communications, etc.) for equipment (computer, proper operation communications, etc.) for proper operation The following responsibility is transferred
2 New Step 5.3.2.1.g IT Support The second bullet was The IT Support position reports transferred from Old to the Assistant Emergency step 5.3.2.1.g OAC Coordinator. Key Support to IT Support.
responsibilities include: Step renumbered
- Monitor facility equipment (computer, communications, etc.) for proper operation
U.S. Nuclear Regulatory Commission Attachment II, Page 3 Serial: RA-19-0427 3 Page 86 Figure OAC Support position None Removed position 5.3.2-1 Technical block Removed from table Support Center ERO 4 Page 92 Table OAC Support (TSC) 1 None Removed position 5.3.2-2 Augmented Removed from table Staffing For Emergencies 5 Step 5.3.2.4. i Logistics Lead (Near Site Logistics Lead (Near Site JIC) The following JIC) responsibilities were The Logistics Lead reports to transferred from deleted The Logistics Lead reports the Near Site JIC Manager. Key Step 5.3.2.4.j Admin to the Near Site JIC responsibilities include: Support (Near JIC):
Manager. Key
- Coordinate ERO/facility shift
- Coordinate distribution of responsibilities include: turnover news releases, statements
- Coordinate ERO/facility and messages
- Manage assigned group shift turnover
- Distribute forms, reports, emergency response activities etc. as needed
- Manage assigned group
- Arrange for logistics support emergency response activities
- Make staffing notifications
- Arrange for logistics
- Coordinate JIC security and support media badging
- Make staffing
- Prepare for facility notifications activation (rooms, work area,
- Coordinate JIC security equipment, etc.)
and media badging
- Determine current/projected staff needs
- Prepare for facility activation (rooms, work
- Provide administrative area, equipment, etc.) support for facility operation
- Determine
- Coordinate distribution of current/projected staff news releases, statements needs and messages
- Provide administrative
- Distribute forms, reports, support for facility etc. as needed operation 6 Old Step 5.3.2.4. j Admin Support (Near Site Deleted The following JIC) responsibilities are duplicated under Step The Admin Support 5.3.2.4.i Logistics Lead:
position reports to the
- Prepare for facility Logistics Lead. Key activation (rooms, work responsibilities include: area, equipment, etc.)
- Coordinate distribution
- Provide administrative of news releases, support for facility statements and messages operation
- Prepare for facility The following
U.S. Nuclear Regulatory Commission Attachment II, Page 4 Serial: RA-19-0427 activation (rooms, work responsibilities were area, equipment, etc.) transferred under Step 5.3.2.4.i Logistics Lead:
- Provide administrative
- Coordinate distribution of support for facility news releases, statements operation and messages
- Distribute forms, reports,
- Distribute forms, reports, etc. as needed etc. as needed 7 Old Step 5.3.2.4. l Registration Liaison (Near Deleted Deleted Registration Site JIC) Liaison Position &
The Registration Liaison functions. The same reports to the Logistics responsibilities are Lead. Key responsibilities duplicated under the Media include: Center Coordinator in Step
- Register personnel at the 5.3.2.4.g.
assigned location
- Monitor facility entrance areas
- Prepare for facility activation (rooms, work area, equipment, etc.)
8 Page 87 Figure Admin Support and None Removed position 5.3.2-4, Joint Registration Liaison Removed from table Information Center block ERO Attachment 6, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes Bases Validation and Verification (V&V) Form, is attached (required for IC or EAL change) No Part II. Description and Review of Licensing Basis Affected by the Proposed Change:
- PLP-007, Robinson Emergency Plan (Revision 0, dated 1982)
- PLP-007, Robinson Emergency Plan, Revision 91
- NRC Correspondence - May 11, 1983:
Subject:
NUREG-0737 Item III.A.2.1 - Emergency Plan Upgrade to Meet Rule (H.B. Robinson Unit 2)
- H.B. Robinson Steam Electric Plant, Unit No. 2, Updated Final Safety Analysis Report Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments.
If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q):
Changes 1-4 move the OAC Support responsibilities and procedure steps to IT Support in the TSC. This change is an efficiency gain. The OAC Support only defined responsibility was to turn on or verify ERDS was operating. That responsibility has been added to the IT Support Checklist. The IT Support will contact the on-call OAC Subject Matter Expert for any other OAC related issues. Responsibilities continue to be defined and timely augmentation of an OAC SME is available. The ERO continues to be staffed to augment initial response on a continuous basis. Thus, the Robinson Emergency Plans will continue to comply with 10 CFR 50.47(b)(1) Assignment of Responsibility/Organizational Control, 10 CFR 50.47(b)(2), Onsite Emergency Organization, and 10 CFR Part 50
U.S. Nuclear Regulatory Commission Attachment II, Page 5 Serial: RA-19-0427 Appendix E,Section IV.A Organization.
Changes 5-8 delete the Administrative Support position and the Registration Liaison position from the Joint Information Center (JIC) operations. The deletion of these positions requires some tasks from the deleted positions to move to other positions in the JIC. This change is due to personnel changes and efficiency gains. The tasks that were moved were only administrative in nature and not associated with ERO Key roles or Key Functions. The tasks that were moved to other positions in the JIC will not prevent activation of the facility or hinder operations to provide the public information on a periodic basis on how they will be notified and what their initial actions should be in an emergency. The ERO continues to be staffed and the responsibility for emergency response is assigned, and able to augment initial response on a continuous basis. Thus, the Robinson Nuclear Plant Emergency Plans will continue to comply with 10 CFR 50.47(b)(1) Assignment of Responsibility/Organizational Control, 10 CFR 50.47(b)(2), Onsite Emergency Organization, and 10 CFR Part 50 Appendix E, Section IV.A Organization.
The changes evaluated above continue to meet NRC requirements as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.
Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen):
10CFR50.47(b)(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
10CFR50 Appendix E.IV.A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:
- 2. A description of the onsite emergency response organization (ERO) with a detailed discussion of:
- a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;
- b. Plant staff emergency assignments;
- c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.
- 3. A description, by position and function to be performed, of the licensee's headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.
The associated EP Function is Function 1b, "The response organization has the staff to respond and to augment staff on a continuing basis (i.e., 24/7 support) in accordance with the emergency plan."
Program Element NUREG-0654 Section II.A A.1.e. Each organization shall provide for 24-hour emergency response, including 24-hour per day manning of communication links.
A.4 Each principal organization shall be capable of continuous (24-hour) operations for a protracted period. The individual in the principal organization who will be responsible for assuring continuity of resources (technical, administrative, and material) shall be specified by title.
U.S. Nuclear Regulatory Commission Attachment II, Page 6 Serial: RA-19-0427 10CFR50.47(b)(2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident 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.
The associated EP Function is Function 2b, "The process for timely augmentation of on shift staff is established and maintained."
Program Elements NUREG-0654 Section II.B B.1 Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement.
B.5 Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies."
The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1. The implementation schedule for licensed operators, auxiliary operators and the shift technical advisor on shift shall be as specified in the July 31, 1980 letter to all power reactor licensees. Any deficiencies in the other staffing requirements of Table B-1 must be capable of augmentation within 30 minutes by September 1, 1981, and such deficiencies must be fully removed by July 1, 1982.
Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:
Proposed changes 1-4 move the OAC Support responsibilities and procedure steps to IT Support in the TSC. This change is an efficiency gain. The OAC Support positions only defined responsibility was to turn on or verify ERDS was operating. That responsibility has been added to the IT Support Checklist. The IT Support position will contact the on-call OAC Subject Matter Expert for any other OAC related issues. Responsibilities continue to be defined and timely augmentation of an OAC SME is available. The ERO continues to be staffed to augment initial response on a continuous basis and maintain the process for timely augmentation of on shift staff in accordance with the emergency plan.
Proposed changes 5-8 RNP originally approved Emergency plan do not speak to the specific positions that are being eliminated with this change. These positions were introduced to the Emergency Plan during the standard ERO implementation across the fleet in 2018. These positions were to support administrative tasks that were not associated with the Key functions of providing the public with information on a periodic basis on how they will be notified and what their initial actions should be in an emergency. These 2 specific positions were located at the near site JIC. Some tasks associated with these positions were redundant across multiple positions in the JIC. The other tasks that were not duplicated across other positions in the JIC have been moved to other positions in the JIC.
These additional tasks for these other positions do not add additional burden nor do these tasks hinder other JIC position responsibilities.
Responsibilities for dissemination of public information during emergencies continue to be defined and timely. The ERO continues to be staffed to augment initial response on a continuous basis. Thus, there is no reduction in effectiveness of the Emergency Planning Functions of Assignment of Responsibility and Onsite Emergency Organization.
The changes described provide assurance that the normal plant operating organization and ERO have the ability and capability to:
- respond to an emergency;
- perform functions in a timely manner;
U.S. Nuclear Regulatory Commission Attachment II, Page 7 Serial: RA-19-0427
- effectively identify and take measures to ensure protection of the public health and safety; and
- effectively use response equipment and emergency response procedures.
Thus, there is no reduction in effectiveness of the Robinson Emergency Plan.
Part VI. Evaluation Conclusion.
Answer the following questions about the proposed change.
1 Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? Yes No 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes No reduction in effectiveness)?
3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes No 4 Choose one of the following conclusions:
a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current Emergency Action Level (EAL) scheme. Therefore, the activity can be implemented without prior NRC approval.
b The activity does not continue to comply with the requirements of 10 CFR 50.47(b) or 10 CFR 50 Appendix E or the activity does constitute a reduction in effectiveness or EAL scheme change.
Therefore, the activity cannot be implemented without prior NRC approval.