RA-20-0067, Emergency Plan PLP-007, Revision 94

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Emergency Plan PLP-007, Revision 94
ML20072N601
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 03/12/2020
From: Ellis K
Duke Energy Progress
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0067
Download: ML20072N601 (10)
v • d • e


Text

Kevin Ellis Manager- Nuclear Support Services

( ~ DUKE H. 8. Robinson Steam Electric Plant, Unit 2 ENERGYa Duke Energy 3581 West Entrance Road Hartsville, SC 28550 843.951.1329 Kevin.Ellis@duke-energy.com Serial: RA-20-0067 10 CFR 50.54(q)

March 12, 2020 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 / RENEWED LICENSE NO. DPR-23

SUBJECT:

Emergency Plan PLP-007, Revision 94 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 94, which is effective February 13, 2020.

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, Manager - Nuclear Fleet Licensing, at 980-373-2062.

Kevin Ellis - Manager- Nuclear Support Services, H.B. Robinson Steam Electric Plant 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 A. Hon, NRC Project Manager, NRR

U.S. Nuclear Regulatory Commission Attachment I, Page 1 Serial: RA-20-0067 Attachment I: 10 CFR 50.54(q) Screening Evaluation Form

U.S. Nuclear Regulatory Commission Attachment I, Page 2 Serial: RA-20-0067

<< 10 CFR 50.54(q) Screening Evaluation Form>>

Screening and Evaluation Number Applicable Sites BNP

  • EREG #: 2316116 2320299 CNS
  • This is a revised EREG. Deletions to this EREG are identified by bold CR3
  • and strike through text. Additions made to this EREG are identified by HNP
  • Bold and Italicized Text MNS
  • 5AD#: 2316105 ONS
  • I GO Document and Revision PLP-007 Robinson Emergency Plan Rev 94 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):
  1. E-Plan/ Current (Existing) Proposed(Change)Te~ Supporting Rationale Procedure Text (Justification) for Change Section Reference 1 Section 5.3 New The Emergency Added information to clearly 6th Coordinator, or EOF identify the Emergency paragraph Director after the EOF is Coordinators non-delegable activated, may not delegate duties.

the responsibilities for notification of and making This information was recommendations to previously removed in error authorities responsible for from Rev 89 of the RNP E-off-site measures. The Plan.

Emergency Coordinator may consult with others, but may not delegate the responsibility to determine the appropriate emergency action level for the conditions. Further, while he/she may consult with others, he/she may not delegate the responsibility to declare that the emergency has been terminated.

U.S. Nuclear Regulatory Commission Attachment I, Page 3 Serial: RA-20-0067 I I Part II. Activity Previously Reviewed? Yes ,* No I

  • 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 Ill Justification: Attachment 4, Part V.

Bounding document attached (optional) 1

  • Part Ill. Editorial Change Yes 1
  • No or Partially I
  • Is this activity an editorial or typographical change only, such as formatting ,

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 complete changes Attachment 4, Part V.

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

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

U.S. Nuclear Regulatory Commission Attachment I, Page 4 Serial: RA-20-0067 Sa 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 .

Sb Administrative and physical means have been established for alerting and providing prompt

  • instructions to the public within the plume exposure pathway. (NA for CR3)

Sc 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.

  • 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 Ba 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)
  • 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 Kl is available for implementation as a protective action recommendation in those jurisdictions

  • that chose to provide Kl 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.

U.S. Nuclear Regulatory Commission Attachment I, Page 5 Serial: RA-20-0067 14c Identified weaknesses are corrected .

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

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-20-0067 Attachment II: 10 CFR 50.54(q) Effectiveness Evaluation Form

U.S . Nuclear Regulatory Commission Attachment II, Page 2 Serial: RA-20-0067

<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>

Screening and Evaluation Number Applicable Sites BNP

  • EREG #: 2316116 2320299 CNS
  • CR3 D lfhis is a revised EREG. Deletions to this EREG are identified by bold and stFike

,~~-::...:;'::text. Additions made to this EREG are identified by Bold and Italicized HNP

  • Ifext.

MNS

  • 5AD #: 2316105 ONS
  • GO
  • Document and Revision PLP-007 Robinson Emergency Plan Revision 94 Part I. Description of Proposed Change:
  1. E-Plan or Procedure Current (Existing) Proposed (Change) Text Supporting Rationale Section Reference Text (Justification) for Chanoe 1 Section 5.3 6th New The Emergency Added information to paragraph Coordinator, or EOF clearly identify the Director after the EOF is Emergency Coordinators activated, may not non-delegable duties.

delegate the responsibilities for notification of and making recommendations to This information was authorities responsible for previously removed in off-site measures. The error from Rev 89 of Emergency Coordinator the RNP E-Plan .

may consult with others, but may not delegate the responsibility to determine the appropriate emergency action level for the conditions. Further, while he/she may consult with others, he/she may not delegate the responsibility to declare that the emergency has been terminated.

U.S. Nuclear Regulatory Commission Attachment II, Page 3 Serial: RA-20-0067 , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is attached (required for IC or EAL change) I Yes No Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

  • NRC Correspondence - May 11, 1983:

Subject:

NUREG-0737 Item 111.A.2.1 - Emergency Plan Upgrade to Meet Rule (H.B. Robinson Unit 2)

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):

This change provides clear guidance and identification of the duties that the Emergency Coordinator (EC) cannot delegate to others. This guidance ensures the EC fully understands his emergency response responsibilities. 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, 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.

U.S. Nuclear Regulatory Commission Attachment II, Page 4 Serial: RA-20-0067

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 1a, "Responsibility for emergency response is assigned."

Program Elements NUREG-0654 Section 11.8 8 .2 Each licensee shall designate an individual as emergency coordinator who shall be on shift at all times and who shall have the authority and responsibility to immediately and unilaterally initiate any emergency actions, including providing protective action recommendations to authorities responsible for implementing offsite emergency measures.

8 .4. Each licensee shall establish the functional responsibilities assigned to the emergency coordinator and shall clearly specify which responsibilities may not be delegated to other elements of the emergency organization .

Among the responsibilities which may not be delegated shall be the decision to notify and to recommend protective actions to authorities responsible for offsite emergency measures.

Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

This change provides clear guidance and identification of the duties that the Emergency Coordinator (EC) cannot delegate to others. This guidance ensures the EC fully understands his emergency response responsibilities . The ERO continues to be staffed to augment initial response on a continuous basis. Thus, the Robinson Emergency Plans will continue to ensure responsibility for emergency response assigned .

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;
  • 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 EmerQencv 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 D 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes
  • No D reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes

  • No D 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. D Therefore, the activity cannot be implemented without prior NRC approval.

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