View source for RA-22-0037, Emergency Plan Annex, Revision 1 and Emergency Plan Annex, Revision 1, Emergency Action Level (EAL) Wallchart, Revision 2, and EAL Technical Basis Document

{{Adams
| number = ML22039A189
| issue date = 02/08/2022
| title = Emergency Plan Annex, Revision 1 and Emergency Plan Annex, Revision 1, Emergency Action Level (EAL) Wallchart, Revision 2, and EAL Technical Basis Document
| author name = Nolan M
| author affiliation = Duke Energy Progress, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000261, 05000400
| license number = DPR-023, NPF-063
| contact person = 
| case reference number = RA-22-0037
| document type = Emergency Preparedness-Emergency Plan, Letter type:RA
| page count = 60
}}

=Text=
{{#Wiki_filter:M. CHRISTOPHER NOLAN Vice President Nuclear Regulatory Affairs, Policy &
Emergency Preparedness 13225 Hagers Ferry Rd., MG011E Huntersville, NC 28078 704-382-7426 Chris.Nolan@duke-energy.com Serial: RA-22-0037                                                              10 CFR 50.54(q)
February 8, 2022 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23

==SUBJECT:==
Shearon Harris Emergency Plan Annex, Revision 1 and H.B. Robinson Emergency Plan Annex, Revision 1, Emergency Action Level (EAL)
Wallchart, Revision 2, and EAL Technical Basis Document, Revision 2 Ladies and Gentlemen:
In accordance with 10 CFR 50.54(q), Duke Energy Progress, LLC (Duke Energy) is submitting revision summaries for the Shearon Harris Nuclear Plant (HNP) Emergency Plan Annex (EP-HNP-EPLAN-ANNEX, Revision 1) and the H.B. Robinson Steam Electric Plant (RNP)
Emergency Plan Annex (EP-RNP-EPLAN-ANNEX, Revision 1) and the Emergency Action Level (EAL) Technical Basis Document and EAL Wallchart (CSD-EP-RNP-0101-01, Revision 2 and CSD-EP-RNP-0101-02, Revision 2, respectively).
EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, is the HNP specific compliment to the Duke Energy Common Emergency Plan. The Annex has been revised from Revison 0 to update format, correct procedure references, and incorporate changes to the Operations Support Center (OSC) location and Technical Support Center (TSC) backup location.
EP-RNP-EPLAN-ANNEX, Duke Energy Robinson Emergency Plan Annex is the RNP specific compliment to the Duke Energy Common Emergency Plan. The Annex has been revised from Revision 0 to update the format and correct procedure references.
CSD-EP-RNP-0101-01 is the RNP EAL Technical Basis Document, and CSD-EP-RNP-0101-02 is the EAL Wallchart (both Hot and Cold) for RNP. These documents have been revised from revision 2 to include editorial changes such as updating revision number, table of contents, page numbers, and reference corrections. Communication methods have been updated to align with Common Emergency Plan communcation methods. Clarifications were made to the technical basis document for EALs CA6.1 and SA9.1. Additionally, basis discussions were updated for HU4.1 and HU4.2 based on implementation of NFPA-805.
In accordance with 10 CFR 50.54(q)(5), Attachment 1 includes a summary of analyses associated with the issuance of EP-HNP-EPLAN-ANNEX, Revision 1. Attachment 2 includes a summary of analyses associated with the issuance of EP-RNP-EPLAN-ANNEX, Revision 1.

U.S. Nuclear Regulatory Commission                                                Page 2 Serial: RA-22-0037  includes a summary of analyses associated with issuance of CSD-EP-RNP-0101-01, Revision 2, and CSD-EP-RNP-0101-02, Revision 2.
This document contains no new regulatory commitments.
Should you have any questions concerning this letter, or require additional information, please contact Lee Grzeck, Fleet Licensing Manager (Acting), at (980) 373-1530.
Sincerely,
      /4-1/4-M. Christopher Nolan Vice President, Nuclear Regulatory Affairs, Policy & Emergency Preoaredness Attachments:
: 1. EP-HNP-EPLAN-ANNEX, Revision 1 10 CFR 50.54(q) Summary of Analyses
: 2. EP-RNP-EPLAN-ANNEX, Revision 1 10 CFR 50.54(q) Summary of Analyses
: 3. CSD-EP-RNP-0101-01, Revision 2 and CSD-EP-RNP-0101-02, Revision 2 10 CFR 50.54(q) Summary of Analyses cc:     L. Dudes, NRC Regional Administrator, NRC, Region II J. Zeiler, NRC Sr. Resident Inspector, HNP A. Hon, NRC Project Manager, HNP M. Fannon, NRC Sr. Resident Inspector, RNP T. Hood, NRC Project Manager, RNP

U.S. Nuclear Regulatory Commission                     Attachment 1, Page 1 Serial: RA-22-0037 Attachment 1: EP-HNP-EPLAN-ANNEX, Revision 1 10 CFR 50.54(q) Summary of Analyses

U.S. Nuclear Regulatory Commission                                          Attachment 1, Page 2 Serial: RA-22-0037
                                       << 10 CFR 50.54(q) Review Form >>
Section I: 10 CFR 50.54(q) Review Number: (EREG #):                                      02401692 Applicable Sites and Applicability Determination # (5AD)
BNP                                      CNS                                     HNP      2397663 MNS                                      ONS                                    RNP Document #, EC #,             Revision # or or N/A                       N/A                            Document or Activity Title EP-HNP-EPLAN-ANNEX            1                     Duke Energy Harris Emergency Plan Annex Section II: Identify/Describe All Proposed Activities/Changes 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 (Use attachments, or continue additional pages as necessary): Continue to Section III.
EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, is the Harris specific compliment to the Duke Energy Common Emergency Plan. The Annex is being revised to update format, correct various references, and incorporate changes to the Operations Support Center (OSC) location and Technical Support Center (TSC) backup location. A summary of changes is provided in the table below.
Change      Section or Step                   Change From                                  Change to 1           Throughout           Old revision number, document cover       New revision number, document cover page, document title, table of contents,  page, document title, updated table of header and footer, page numbers.          contents, added revision summary, added section numbers, and page numbers as a result of the changes to the document. Document format was updated to align with Procedure Automation System (PAS). PAS formatting includes updating documents referenced in body of annex to include hyperlinks and are designated with blue text.
2           Throughout           Revision 0 grammar issues found in        Revision 1 Updated grammar issues review.                                   found in review (added or removed spaces and hyphens where needed).
3           Section B            The HNP on-shift staffing analysis        The HNP on-shift staffing analysis has report has been developed in              been developed in accordance with 10 accordance with 10 CFR 50 Appendix        CFR 50 Appendix E.IV.A.9 and NEI 10-E.IV.A.9 and NEI 10-05.                   05.
4           Sections A and       Rex Healthcare                            UNC Rex Healthcare L
5           Section B            CSD-EP-HNP-0603-02, Harris Plant          EP-HNP-OSSA, Harris On-Shift Staffing On-Shift Staffing Analysis                Analysis 6           Section B            AECOM (the architect-engineer for         AECOM, Inc (the architect-engineer for HNP): AECOM (formerly URS Energy          HNP): AECOM (formerly URS Energy and Construction) will form a Technical   and Construction, Inc) will form a Support Team upon request.                Technical Support Team upon request.

U.S. Nuclear Regulatory Commission                                        Attachment 1, Page 3 Serial: RA-22-0037 7         Section B        Under Contractor Support, A and B are         Under Contractor Support, A and B are shown in front of contractor descriptions     not shown in front of contractor descriptions 8         Section E        CSD-EP-HNP-0603-01, Harris Plant              EP-HNP-ANS, Harris Alert and Alert and Notification System Design          Notification System Design Report Report 9         Section H        In the event the TSC must be                  In the event the TSC must be evacuated, evacuated, the backup location is the         a backup location has been designated 305 Shift Manager, Shift Technical           in the Control Room.
Advisor, and the Auxiliary Operator office area.
10        Section H        The OSC located in the Waste                  The OSC located in the Service Building Processing Building inside the                inside the Protected Area. The total area Protected Area. The total area is             is approximately 1200 square feet in the approximately 1500 square feet in the         Service Building. This area includes a Waste Processing Building HP Tech             Command and Control area, co-located Work Area. This area includes a               with the Outage Command Center separate Command and Control area             (OCC), for coordinating and planning of for coordinating and planning of OSC          OSC activities, as well as sufficient area activities in addition to sufficient area for in adjacent conference rooms for team team members to standby for activities.       members to standby for activities.
Additional space in excess of 8500            Additional space in excess of 2000 square feet is available in adjacent          square feet is available in adjacent offices and locker rooms to                   offices to accommodate additional accommodate additional personnel as           personnel as may be required.
may be required.
11        Section H        Duke Energy EOF                               Duke Energy Common EOF 12        Section H        Monitoring equipment described under          Monitoring equipment described under H.8 has numbers in front of each              H.8 does not have numbers in front of description                                   each description 13        Section J        CSD-EP-HNP-0603-03, Harris Plant              EP-HNP-ETE, Harris Evacuation Time Evacuation Time Estimate Study                Estimate 14        Section L        Regulatory Reference                          Regulatory References 15        Section P, Table AD-EP-HNP-0105 HNP Specific TSC               AD-EP-HNP-0105 HNP Site Specific P.7-1            Support                                       TSC Support AD-EP-HNP-0106 HNP Specific OSC               AD-EP-HNP-0106 HNP Site Specific Support                                       OSC Support 16        Section P, Table (1) after Plan Sections Implemented on        Removed from document P.7-1            header of column 3 and (1) All letters refer to Sub-Sections of Plan Section II, Planning Standards and Elements 17        Section P, Table PEP-342 Core Damage Assessment;               PEP-342 and EPM-601 removed from P.7-1            implements Plan Sections D, I                 document, since they have been EPM-601 Core Damage Assessment                superseded by AD-EP-PWR-0206, Core Technical Basis; implements Plan              Damage Assessment During an Section I                                     Emergency 18        Section P, Table EPL-001 Emergency Phone List                  Removed from document P.7-1 19        Section P, Table n/a                                           Added PEP-350, First Aid and Medical P.7-1                                                          Care of Contaminated Injured Persons, which implements Plan Section L 20        Section L        The Wake County EMS                           Wake County

U.S. Nuclear Regulatory Commission                                         Attachment 1, Page 4 Serial: RA-22-0037 Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:
List all emergency plan sections that were reviewed for this activity by number and title.
IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.
Licensing Basis EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 0 EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex Revision 0

U.S. Nuclear Regulatory Commission                                              Attachment 1, Page 5 Serial: RA-22-0037 Section IV: Ability to Maintain the Emergency Plan.
Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.
: 1. Do any of the elements of the proposed activity change information or intent contained in the Emergency        Yes Plan?                                                                                                           No
: 2. Do any elements of the proposed activity change an Initiating Condition (IC), Emergency Action Level           Yes (EAL), associated EAL note or basis, including underlying calculation or basis?                                 No  , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is required to be completed as part of this review if "Yes" is selected above in question 2.
: 3. Do any elements of the proposed activity change the process or capability for alerting or notifying the public Yes as described in the FEMA-approved Alert and Notification System Design Report?                                  No
: 4. Do any elements of the proposed activity change the Evacuation Time Estimate results?                          Yes No
: 5. Do any elements of the proposed activity change the On-Shift Staffing Analysis results?                        Yes No
: 6. Does the Proposed activity require a change to the Emergency Plan Programmatic Description?                    Yes No If Question 6 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.
Section IV conclusion:
If questions 1-6 in Section IV marked NO, then complete Section V.
If any question 1-6 of Section IV marked yes, then continue at Section VI.

U.S. Nuclear Regulatory Commission                                             Attachment 1, Page 6 Serial: RA-22-0037 Section V: Maintaining the Emergency Plan Conclusion.
The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.
: 1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.
: 2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.
I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).

== Conclusion:==

Section VI: Activity Previously Reviewed?
Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?
10 CFR 50.54(q) Evaluation is not required.
Yes Identify bounding source document below and continue to Section XIV.
No            Continue to Section VII.
If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.
Partially Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.

U.S. Nuclear Regulatory Commission                                              Attachment 1, Page 7 Serial: RA-22-0037 Section VII: Editorial Changes All Activities/Changes identified in Section II are editorial/typographical changes such as Yes            formatting, paragraph numbering, spelling, or punctuation that does not change intent.
None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to No Section VIII.
Partially      Some Activities/Changes are editorial/typographical.
If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XIV.
If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.
Justification:
The proposed changes below are defined as editorial in accordance with AD-EP-ALL-0602, and do not change the intent of the Emergency Plan as written.
Proposed change 1, updates procedure format to align with the Procedure Automated System (PAS) formatting. This Duke Energy Standard formatting includes updates on the document cover page, document number, table of contents, adds a revision summary, replaces lists separated by semicolon with bulleted lists, revises section spacing and page alignment, removes the previous revisions header and footer and replaces those with a PAS standard header to each page, updates the revision number throughout the document, adds hyperlinks to procedures referenced in body of annex. These format changes do not change the intent of the Emergency Plan.
Proposed change 2 revises grammar mistakes found in the review of revision 0. Extra spaces, and hyphens were placed or removed between words when needed.
Change 14 corrects the use of a noun, from singular to plural. These changes do not change the intent of the Emergency Plan.
Proposed change 3 changes the description of the on-shift staffing analysis report to on-shift staffing analysis to align with the title of the EP-HNP-OSSA referenced in the Emergency Plan. This change does not change intent of the Emergency Plan.
Proposed changes 4, 6, 11, and 20 correct titles and do not impact any support or functions provided in support of the Emergency Plan.
Proposed changes 7 and 12 change how information is divided in sections of the document (removed sub-letters and sub-numbers) and do not change intent of the Emergency Plan.
Proposed reference changes 5, 8, 13, and 15 update document references to correct document number and title as needed. These changes do not change the intent of the Emergency Plan.
Proposed reference change 17 removes procedures that have been superseded by fleet procedures. This change does not change the intent of the Emergency Plan.
These editorial changes do not change the intent of the Emergency Plan and does not reduce the effectiveness of the Harris Nuclear Plant Emergency Plan.

U.S. Nuclear Regulatory Commission                                        Attachment 1, Page 8 Serial: RA-22-0037 Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)
Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate box.
1       10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a     Responsibility for emergency response is assigned.
The response organization has the staff to respond and to augment staff on a continuing basis (24-7 1b 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 onshift 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.
4       10 CFR 50.47(b)(4) Emergency Classification System                                                   RS A standard scheme of emergency classification and action levels is in use. (Requires V/V 4a (Attachment 5) and final approval of Screen and Evaluation by EP CFAM) 5       10 CFR 50.47(b)(5) Notification Methods and Procedures                                               RS Procedures for notification of State and local governmental agencies are capable of alerting them of 5a      the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.
Administrative and physical means have been established for alerting and providing prompt 5b instructions to public within the plume exposure pathway.
The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 5c      Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter 6       10 CFR 50.47(b)(6) Emergency Communications Systems are established for prompt communication among principal emergency response 6a organizations.
6b      Systems are established for prompt communication to emergency response personnel.
7       10 CFR 50.47(b)(7) Public Education and Information Emergency preparedness information is made available to the public on a periodic basis within the 7a plume exposure pathway emergency planning zone (EPZ).
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                                                               RS 9a      Methods, systems, and equipment for assessment of radioactive releases are in use.
10      10 CFR 50.47(b) (10) Protective Response                                                             RS 10a     A range of public PARs is available for implementation during emergencies.
Evacuation time estimates for the population located in the plume exposure pathway EPZ are 10b     available to support the formulation of PARs and have been provided to State and local governmental authorities.

U.S. Nuclear Regulatory Commission                                          Attachment 1, Page 9 Serial: RA-22-0037 A range of protective actions is available for plant emergency workers during emergencies, including 10c those for hostile action events.
KI is available for implementation as a protective action recommendation in those jurisdictions that 10d 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 A drill and exercise program (including radiological, medical, health physics and other program areas) 14a is established.
Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, 14b 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.
Planners responsible for emergency plan development and maintenance are properly trained.
16b Section VIII: Conclusion If any Section VIII criteria are checked, continue the 50.54(q) Review Section IX.
If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document the basis for conclusion below and continue to Section XIV.
Proposed change 16 is more than editorial, however does not impact any emergency planning function identified in Reg Guide 1.219.
Proposed change 16 removes a note that is not needed. Updating procedure format to align with PAS formatting added Section to each of the plan sections thus eliminating need to have a note stating letters refer to sub sections of plan. This change does not change intent of the Emergency Plan.
Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.
Change 9 is related to the Backup TSC location change:
Planning Standard 10 CFR 50.47(b)(8) - Adequate emergency facilities and equipment to support the emergency response are provided and maintained.
Functions: Emergency Plan Planning Function 8a - Adequate facilities are maintained to support emergency response.
Emergency Plan Planning Function 8b - Adequate equipment is maintained to support emergency response.

U.S. Nuclear Regulatory Commission                                           Attachment 1, Page 10 Serial: RA-22-0037 Supporting requirements of Appendix E to 10 CFR Part 50:
Adequate provisions shall be made and described for emergency facilities and equipment, including:
8.a. (i) A licensee onsite technical support center and an emergency operations facility from which effective direction can be given and effective control can be exercised during an emergency; Informing Criteria from NUREG-0654, Section II Planning Element H.1. A TSC is established, using current Federal guidance, from which NPP conditions are evaluated and mitigative actions are developed.
Informing Criteria from NUREG-0696 1.3.1 Technical Support Center: The technical support center (TSC) is an onsite facility located close to the control room that shall provide plant management and technical support to the reactor operating personnel located in the control room during emergency conditions. It shall have technical data displays and plant records available to assist in the detailed analysis and diagnosis of abnormal plant conditions and any significant release of radioactivity to the environment. The TSC shall be the primary communications center for the plant during an emergency. A senior official, designated by the licensee, shall use the resources of the TSC to assist the control room operators by handling the administrative items, technical evaluations, and contact with offsite activities, relieving them of these functions.
The TSC facilities may also be used for performing normal functions, such as shift technical supervisor and plant operations/maintenance analysis functions, as well as for emergencies.
2.1       Function. The onsite technical support center (TSC) will provide the following functions:
* Provide plant management and technical support to plant operations personnel during emergency conditions.
* Relieve the reactor operators of peripheral duties and communications not directly related to reactor system manipulations.
* Prevent congestion in the control room.
* Perform EOF functions for the Alert Emergency class and for the Site Area Emergency class and General Emergency class until the EOF is functional.
Change 10 is related to the OSC relocation:
Planning Standard: 10 CFR 50.47(b)(8) - Adequate emergency facilities and equipment to support the emergency response are provided and maintained.
Functions: Emergency Plan Planning Function 8a - Adequate facilities are maintained to support emergency response.
Emergency Plan Planning Function 8b - Adequate equipment is maintained to support emergency response.
Supporting requirements of Appendix E to 10 CFR Part 50:
Adequate provisions shall be made and described for emergency facilities and equipment, including:
8.a. (i) A licensee onsite technical support center and an emergency operations facility from which effective direction can be given and effective control can be exercised during an emergency;

U.S. Nuclear Regulatory Commission                                        Attachment 1, Page 11 Serial: RA-22-0037 (ii) For nuclear power reactor licensees, a licensee onsite operational support center.
Informing Criteria from NUREG-0654 Planning Element H. 2. An OSC is established, using current Federal guidance, from which repair team activities are planned and teams are dispatched to implement actions.
Changes 18-19 are related to implementing procedure reference changes:
Planning Standard (16) Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.
Functions: Emergency Plan Planning Function 16a - Responsibility for emergency plan development and review is established.
Supporting requirements of Appendix E to 10 CFR Part 50:
G. Maintaining Emergency Preparedness: Provisions to be employed to ensure that the emergency plan, its implementing procedures, and emergency equipment and supplies are maintained up to date shall be described.
Informing Criteria from NUREG-0654, Section II Planning Element P.7 - An appendix containing a listing by title of the procedures required to maintain and implement the emergency plan is included. The listing includes the section(s) of the emergency plan to be implemented by each procedure.

U.S. Nuclear Regulatory Commission                                         Attachment 1, Page 12 Serial: RA-22-0037 Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC 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). Address each Planning Standard identified in Section IX. Continue to Section XI.
Change 9: NUREG-0696, Functional Criteria for Emergency response Facilities, was used to ensure HNP Main Control Room, used as Backup TSC, would be an adequate emergency facility to support emergency response and from which effective direction can be given and effective control can be exercised during an emergency. Ten TSC criteria are listed in NUREG-0696:
Function: The Backup TSC using approved TSC procedures will provide the following functions:
* Provide plant management and technical support to plant operations personnel during emergency conditions.
* Relieve the reactor operators of peripheral duties and communications not directly related to reactor system manipulations.
* Prevent congestion in the Main Control Room crew operating area. Backup TSC will be located along the exterior perimeter of the Main Control Room away from the control board.
* Perform EOF functions for the Alert, Site Area Emergency, and General Emergency classifications until the EOF is functional.
Location: The Backup TSC will provide a facility near the Main Control Room (MCR) operating area for detailed analyses of plant conditions during abnormal conditions or emergencies by trained and competent technical staff. This will allow for adequate telephone communications and face-to-face communications if needed. Since the Backup TSC is inside the MCR complex this will allow for face to face communications, as well as live alarm response for key decision making by the Emergency Coordinator-TSC.
Staffing and Training: The Backup TSC will be staffed and activated by same individuals trained to staff and activate the Primary TSC. Activation of the Backup TSC away from the Main Control Room operating area (Control Board) shall ensure that only designated operating personnel are in the Main Control Room operating area during the emergency and that needed technical support will be provided without obstructing actual plant manipulations or overcrowding the Main Control Room.
Size: Per NUREG-0696, TSC working space should be sized to accommodate for ERO personnel assigned to the TSC and NRC personnel. The Backup TSC has sufficient space for minimum staff personnel and NRC personnel. It is large enough to provide:
* Working space, without crowding, for the personnel.
* Space for the TSC data system equipment (laptop computers) needed to acquire, process, and display data used in the TSC. Since the Back Up TSC is located inside the MCR complex, alarms, data, and plant conditions will be provided directly to the Emergency Coordinator -TSC, from MCR staff. When the Backup TSC is in use, these updates will be conducted face to face, as well as telephone bridge lines with the OSC/EOF.
* Sufficient space to perform repair, maintenance, and service of equipment, displays, and instrumentation.
* Space for data transmission equipment needed to transmit data originating in the TSC to other locations. Printers, computers, and facsimile capability exists in the MCR. The TSC will have assigned laptops for use in addition to installed MCR IT infrastructure.
* Space for personnel access to functional displays (laptop computers) of TSC data. Since the Back Up TSC is located inside the MCR complex, alarms, data, and plant conditions will be provided directly to the Emergency Coordinator-TSC from MCR staff. When the Backup TSC is in use, these updates will be conducted face to face, as well as telephone bridge lines with the OSC/EOF.

U.S. Nuclear Regulatory Commission                                          Attachment 1, Page 13 Serial: RA-22-0037
* Space for unhindered access to communications equipment by all TSC personnel who need communications capabilities to perform their functions. Existing IT infrastructure is able to be utilized by Back Up TSC personnel. In addition, there are pre-staged ASCOM devices (one for each minimum staff position) for external/internal telephone communications.
* Space for storage of and/or access to plant records and historical data. The MCR has a library and has hard copy procedures, as well as access to the electronic data and plant records system.
* A separate area adequate for at least three persons to be used for private NRC consultations.
Structure: The Backup TSC can withstand the most adverse conditions reasonably expected during the design life of the plant including adequate capabilities for (1) earthquakes, (2) high winds (other than tornadoes), and (3) floods.
Habitability: The Backup TSC is located in the MCR so it has equivalent radiological habitability and environmental conditions as the MCR during an accident.
Communications: The Backup TSC will be the primary onsite communications center for HNP when in use during an emergency. It has reliable voice communications to the Main Control Room, OSC, EOF, and the NRC. Provisions for communications with State and local operations centers are provided. Communication methods include Duke Emergency Management Network (DEMNET),
cellular phones, business lines, and onsite radios.
Instrumentation, Data System Equipment, and Power Supplies: Computers are available to gather, store, and display data needed in the Backup TSC to analyze plant conditions. Data will be accessed with qualified OSI -PI displays and Control Board indications via MCR staff. Data can be accessed independent of actions in the Main Control Room and without degrading or interfering with Main Control Room and plant functions. Backup power sources (Emergency Diesel Generators) are available for the Control Room complex that contains the Backup TSC. In areas where there is a loss of lighting, pre -staged flashlights, and portable desks are available to deploy and relocate to a lighted area inside the MCR complex.
Technical Data and Data System: The Backup TSC will utilize the qualified OSI-PI displays and the Main Control Board for TSC function. This data enables the plant management, engineering, and technical personnel assigned in TSC to aid the control room operators in handling emergency conditions. A sufficient number of computers will be available for ERO personnel to perform their assigned tasks with unhindered access to data.
Records Availability and Management: Backup TSC personnel will have access to plant records and procedures to aid in their technical analysis and evaluation of emergency conditions. These records include drawings of plant systems needed to diagnose sensor data, evaluate data inconsistencies, and identify and counteract faulty plant system elements.
Since all 10 NUREG-0696 criteria can be met, as described above, using the Backup TSC, emergency assessment capability would not be impaired if the primary TSC is not available and the Backup TSC had to be utilized. This proposed change does not impact 10 CFR 50.47(b)(8) because this change continues to ensure adequate emergency facilities and equipment to support the emergency response are provided and maintained.
This proposed change does not impact Appendix E to 10 CFR 50 because adequate provisions are made and described including an onsite technical support center from which effective direction can be given and effective control can be exercised during an emergency.

U.S. Nuclear Regulatory Commission                                           Attachment 1, Page 14 Serial: RA-22-0037 Change 10: As part of a planned remodel/upgrade to the OCC, there was an opportunity to add elements to the remodel to create an enhanced OSC, with newer technology. The legacy OSC met the needs of the OSC team, however a larger, modern space allows the OSC to utilize technology more effectively. The design needs of the new OSC were developed by the ERO stakeholders.
Briefing rooms upgraded audio visual technology, and the proximity to the maintenance shop areas provided many efficiencies. The overall mission of an OCC and OSC are similar in nature. Combining the facilities improved the visibility and material condition of the complex. The new complex is identified as an OSC first, OCC second. If the OCC is in use and an emergency is declared the transition to an OSC would be seamless. The OCC manages all field work and activities which would transfer into the OSC processes.
NUREG-0696, section 1.3.2, requires that the OSC is an onsite assembly area separate from the control room and the TSC where licensee operations support personnel shall report in an emergency.
There shall be direct communications between the OSC and the control room and between the OSC and the TSC so that the personnel reporting to the OSC can be assigned to duties in support of emergency operations. NUREG-0696 criteria can be met using the proposed OSC location, therefore emergency assessment capability would not be impaired. This proposed change does not impact 10 CFR 50.47(b)(8) because this change continues to ensure adequate emergency facilities and equipment to support the emergency response are provided and maintained.
Changes 18 and 19 make changes to references in Table P.7-1, HNP Emergency Plan Response and Administrative Procedures, to reflect procedures that implement the Harris Emergency Plan.
Change 18 removes the reference to EPL-001, Emergency Phone List. EPL-001 contains contact information for ERO members and instructions for use of the telephone system. EPL-001 is considered a functional area document (FAD) and is not a procedure. Therefore, EPL-001 is not a procedure that implements the Harris Emergency Plan. CSD-EP-ALL-0111-01, ERONS [Emergency Response Organization Notification System] Backup Job Aid, will continue to provide a reference to EPL-001 for ERO contact information as needed. Change 19 adds a reference to PEP-350, First Aid and Medical Care of Contaminated Injured Persons, which implements Section L of the Duke Energy Harris Emergency Plan Annex. PEP-350, Revision 13, is a procedure that provides instructions for implementing first aid and medical care of contaminated injured persons.
The proposed changes do not affect any planning standards because, responsibilities for plan development and review and for distribution of emergency plans continue to be established, and planners continue to be properly trained. These changes continue to meet NRC requirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.

U.S. Nuclear Regulatory Commission                                          Attachment 1, Page 15 Serial: RA-22-0037 Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.
Change 9: In the event the TSC becomes uninhabitable or inaccessible, a Backup TSC will be established in the Main Control Room complex. This proposed change establishes a Backup TSC around the exterior area of the Main Control Room away from the control room operating area. This change is being made to ensure emergency assessment capability is not impaired if the primary TSC is not available. The primary TSC will continue to be maintained to the same level of readiness.
Adequate equipment to support emergency response will be maintained in primary TSC and Backup TSC. The Backup TSCs space, structure, habitability requirements, communication capabilities, data system equipment, and records availability for ERO personnel establish the same function as the primary TSC. Therefore, the Backup TSC continues to ensure adequate facilities and equipment are maintained to support emergency response. Since NUREG-0696 criteria can be met using the Backup TSC, emergency assessment capability would not be impaired if the primary TSC is not available and the Backup TSC had to be utilized.
Change 10: The proposed OSC location change dedicates a new space (that also serves as the OCC) to supporting operations, tracking field work, and command/control of craft workers. This is the same mission of the OSC and OCC respectively. The readiness of the OSC is enhanced by this change since more frequent use of the facility as an OCC will ensure the technology and tools are at a state of readiness, and familiar with the end user. The new OSC location is close to the maintenance shop locations where all tools, equipment, and facilities are housed. This will facilitate the decrease in dispatch time of damage control missions to the field. The change to the emergency plan as a result of the OSC relocation is not a reduction in effectiveness because adequate facilities continue to be maintained to support emergency response.
Changes 18 and 19 make changes to references in Table P.7-1, HNP Emergency Plan Response and Administrative Procedures, to reflect procedures that implement the Harris Emergency Plan.
Change 18 removes the reference to EPL-001, Emergency Phone List. EPL-001 contains contact information for ERO members and instructions for use of the telephone system. EPL-001 is considered a functional area document (FAD) and is not a procedure. Therefore, EPL-001 is not a procedure that implements the Harris Emergency Plan. CSD-EP-ALL-0111-01, ERONS [Emergency Response Organization Notification System] Backup Job Aid, will continue to provide a reference to EPL-001 for ERO contact information as needed. Change 19 adds a reference to PEP-350, First Aid and Medical Care of Contaminated Injured Persons, which implements Section L of the Duke Energy Harris Emergency Plan Annex. PEP-350, Revision 13, is a procedure that provides instructions for implementing first aid and medical care of contaminated injured persons. The proposed changes do not affect the emergency plan function of Emergency Plan maintenance because, responsibility for emergency plan development and review continues to be established. The proposed changes maintain the effectiveness of the Emergency Plan because responsibility for emergency plan development and review is established.
These changes continue to provide assurance that the Emergency Response Organization has 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.
These changes continue to meet NRC requirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E as well as the requirements of the Harris Nuclear Plant Emergency Plan as written and approved.

U.S. Nuclear Regulatory Commission                                   Attachment 1, Page 16 Serial: RA-22-0037 Section XII: 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 reduction in Yes effectiveness)?                                                                                 No
: 3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme?               Yes No Section XII: Conclusion Questions 1, 2 and 3 are answered YES, complete step below to create CAS assignment EP03, and then continue on to Section XIV and implement change(s).
Complete CAS assignment EP03 - Licensing submit changes in accordance with 10 CFR 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XIII and Section XIV.                       

U.S. Nuclear Regulatory Commission                      Attachment 2, Page 1 Serial: RA-22-0037 Attachment 2: EP-RNP-EPLAN-ANNEX, Revision 1 10 CFR 50.54(q) Summary of Analyses

U.S. Nuclear Regulatory Commission                                           Attachment 2, Page 2 Serial: RA-22-0037
                                      << 10 CFR 50.54(q) Review Form >>
Section I: 10 CFR 50.54(q) Review Number: (EREG #):                                        2398627 Applicable Sites and Applicability Determination # (5AD)
BNP                                     CNS                                      HNP MNS                                     ONS                                      RNP      2398636 Document #, EC #,             Revision # or or N/A                      N/A                            Document or Activity Title EP-RNP-EPLAN-ANNEX            1                   Duke Energy Robinson Emergency Plan Annex Section II: Identify/Describe All Proposed Activities/Changes 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 (Use attachments, or continue additional pages as necessary): Continue to Section III.
EP-RNP-EPLAN-ANNEX, Duke Energy Robinson Emergency Plan Annex, this is Robinson specific compliment to the Duke Energy Common Emergency Plan. The Annex is being revised to update format and correct procedure references.
 #      E-Plan           Current (Existing) Text                         Proposed (Change) Text Section Reference 1      Throughout       Old revision number, table of contents          New revision number, document cover updates due to changes in the                   page, document title, updated table of procedure, old revision summary, page           contents, added revision summary, added number                                          section numbers, and page numbers as a result of the changes to the document.
Document format was updated to align with Procedure Automation System (PAS). PAS formatting includes updating documents referenced in body of annex to include hyperlinks and are designated with blue text.
2      B.1.a            CSD-EP-RNP-0603-02, Robinson Plant              EP-RNP-OSSA, Robinson On-Shift Staffing On-Shift Staffing Analysis Report               Analysis 3      E.2              CSD-EP-RNP-0603-01, Robinson Plant              EP-RNP-ANS, Robinson Alert and Notification Alert and Notification System Design            System Design Report Report 4      J.2              CSD-EP-RNP-0603-03, Robinson Plant              EP-RNP-ETE, Robinson Evacuation Time Evacuation Time Estimate Study                  Estimate 5      J.8.a            CSD-EP-RNP-0603-03, Robinson Plant              EP-RNP-ETE, Robinson Evacuation Time Evacuation Time Estimate Study                  Estimate 6      Table P.7-1      EPNOT-01, CR Emergency                          Removed from document.
Communicator Procedure has been superseded by AD-EP-ALL-0111, Control Room Activation of the ERO and AD-EP-ALL-0304, State and County Notifications 7      Table P.7-1      EPPRO-02, Maintenance and Testing               AD-EP-RNP-0407, Maintenance and Testing 8      Table P.7-1      EPPRO-07, Operation and Maintenance             Removed from document.

U.S. Nuclear Regulatory Commission                                            Attachment 2, Page 3 Serial: RA-22-0037 of the Alert and Notification System Procedure has been superseded by AD-EP-ALL-0305, Fleet Emergency Preparedness (EP) Alert and Notification System (ANS)
Siren Program 9        Table P.7-1   EPSPA-01, Evacuation and                         Removed from document.
Accountability Procedure superseded by AD-EP-ALL-0112, Site Assembly and Accountability 10       Table P.7-1   [Note 1]                                         Removed from document.
[Note1] All letters refer to Sub Sections of     Reference to note also removed from Plan Plan Section II, Planning Standards and          Section Implemented column.
Elements 11       Section       The Duke Energy EOF is located greater           The Duke Energy Common EOF is located H.3.a         than 25 miles from the site. The Remote          greater than 25 miles from the site. The Emergency Response Facility in                   Remote Emergency Response Facility in Hartsville, SC is used as a near site            Hartsville, SC is used as a near site location location for the NRC and other off-site          for the NRC and other off-site agency staff.
agency staff.
Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:
List all emergency plan sections that were reviewed for this activity by number and title.
IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.
Licensing Basis EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 0 EP-RNP-EPLAN-ANNEX, Duke Energy Robinson Emergency Plan Annex Revision 0 Current Emergency Plan EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 1 The differences in approved revisions and the current revisions of the Emergency Plans have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions.

U.S. Nuclear Regulatory Commission                                               Attachment 2, Page 4 Serial: RA-22-0037 Section IV: Ability to Maintain the Emergency Plan.
Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.
: 1. Do any of the elements of the proposed activity change information or intent contained in the Emergency        Yes Plan?                                                                                                           No
: 2. Do any elements of the proposed activity change an Initiating Condition (IC), Emergency Action Level           Yes (EAL), associated EAL note or basis, including underlying calculation or basis?                                 No  , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is required to be completed as part of this review if "Yes" is selected above in question 2.
: 3. Do any elements of the proposed activity change the process or capability for alerting or notifying the public Yes as described in the FEMA-approved Alert and Notification System Design Report?                                  No
: 4. Do any elements of the proposed activity change the Evacuation Time Estimate results?                          Yes No
: 5. Do any elements of the proposed activity change the On-Shift Staffing Analysis results?                        Yes No
: 6. Does the Proposed activity require a change to the Emergency Plan Programmatic Description?                    Yes No If Question 6 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.
Section IV conclusion:
If questions 1-6 in Section IV marked NO, then complete Section V.
If any question 1-6 of Section IV marked yes, then continue at Section VI.
Section V: Maintaining the Emergency Plan Conclusion.
The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.
: 1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.
: 2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.
I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).

== Conclusion:==

U.S. Nuclear Regulatory Commission                                               Attachment 2, Page 5 Serial: RA-22-0037 Section VI: Activity Previously Reviewed?
Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?
10 CFR 50.54(q) Evaluation is not required.
Yes Identify bounding source document below and continue to Section XIV.
No              Continue to Section VII.
If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.
Partially Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.
Section VII: Editorial Changes All Activities/Changes identified in Section II are editorial/typographical changes such as Yes            formatting, paragraph numbering, spelling, or punctuation that does not change intent.
None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to No Section VIII.
Partially      Some Activities/Changes are editorial/typographical.
If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XIV.
If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.
Justification:
The changes below are defined as editorial in accordance with AD-EP-ALL-0602, and do not change the intent of the emergency plan as written.
Proposed change 1 updates procedure format to align with the standard Duke Energy Procedure Automated System formatting. This includes updates on the cover page, document number, table of contents, and standard header to each page and updates the revision number, layout of document and the addition of some hyperlinks.
Proposed changes 2-5 updates the procedures to the correct number and title. These changes do not change the intent, purpose or procedural steps.
Reference changes 6-9, remove procedures that have been superseded by fleet and site procedures.
Fleet procedures are referenced in the Common Emergency Plan. Site procedure AD-EP-RNP-0407, Maintenance and Testing, superseded EPPRO-02, Maintenance and Testing and was added to Section P. Fleet procedure AD-EP-AL-0112, Site Assembly and Accountability superseded EPSPA-01, Evacuation and Accountability, EPNOT-01, CR Emergency Communicator, superseded by Fleet Procedures AD-EP-ALL-0111, Control Room Activation of the ERO and AD-EP-ALL-0304, State and County Notifications, and EPPRO-07, Operation and Maintenance of the Alert and Notification System superseded by AD-EP-ALL-0305, Fleet Emergency Preparedness (EP) Alert and Notification System (ANS) Siren Program.
Proposed change 11 updates the title of the EOF, to be consistent with approved documents and procedures. This change do not change intent or purpose.

U.S. Nuclear Regulatory Commission                                     Attachment 2, Page 6 Serial: RA-22-0037 Removing these procedures from the reference section, and updating referenced documents as needed, does not reduce the effectiveness of the Robinson Emergency Plan and does not change the intent of the Plan.

U.S. Nuclear Regulatory Commission                                        Attachment 2, Page 7 Serial: RA-22-0037 Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)
Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate box.
1       10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a     Responsibility for emergency response is assigned.
The response organization has the staff to respond and to augment staff on a continuing basis (24-7 1b 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 The response organization has the staff to respond and to augment staff on a continuing basis (24-7 2b staffing) in accordance with the emergency plan.
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.
4       10 CFR 50.47(b)(4) Emergency Classification System                                                   RS A standard scheme of emergency classification and action levels is in use. (Requires V/V 4a (Attachment 5) and final approval of Screen and Evaluation by EP CFAM) 5       10 CFR 50.47(b)(5) Notification Methods and Procedures                                               RS Procedures for notification of State and local governmental agencies are capable of alerting them of 5a      the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.
Administrative and physical means have been established for alerting and providing prompt 5b instructions to public within the plume exposure pathway.
The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 5c      Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter 6       10 CFR 50.47(b)(6) Emergency Communications Systems are established for prompt communication among principal emergency response 6a organizations.
6b      Systems are established for prompt communication to emergency response personnel.
7       10 CFR 50.47(b)(7) Public Education and Information Emergency preparedness information is made available to the public on a periodic basis within the 7a plume exposure pathway emergency planning zone (EPZ).
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                                                               RS 9a      Methods, systems, and equipment for assessment of radioactive releases are in use.
10      10 CFR 50.47(b) (10) Protective Response                                                             RS 10a     A range of public PARs is available for implementation during emergencies.
Evacuation time estimates for the population located in the plume exposure pathway EPZ are 10b     available to support the formulation of PARs and have been provided to State and local governmental authorities.

U.S. Nuclear Regulatory Commission                                          Attachment 2, Page 8 Serial: RA-22-0037 A range of protective actions is available for plant emergency workers during emergencies, including 10c those for hostile action events.
KI is available for implementation as a protective action recommendation in those jurisdictions that 10d 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 A drill and exercise program (including radiological, medical, health physics and other program areas) 14a is established.
Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, 14b 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.
Planners responsible for emergency plan development and maintenance are properly trained.
16b Section VIII: Conclusion If any Section VIII criteria are checked, continue the 50.54(q) Review Section IX.
If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document the basis for conclusion below and continue to Section XIV.
Proposed change 10 is more than editorial, however does not impact any emergency planning function identified in Appendix E to Part 50-Emergency Planning and Preparedness for Production and Utilization Facilities.
Proposed change 10 removes a note that is not needed. Updating procedure format to align with PAS formatting added Section to each of the plan sections thus eliminating need to have a note stating letters refer to sub sections of plan. This change does not change intent of the Emergency Plan.

U.S. Nuclear Regulatory Commission                                     Attachment 2, Page 9 Serial: RA-22-0037 Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.
Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC 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). Address each Planning Standard identified in Section IX. Continue to Section XI.
Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.
Section XII: 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 reduction in    Yes effectiveness)?                                                                                     No
: 3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme?                  Yes No 

U.S. Nuclear Regulatory Commission                          Attachment 3, Page 1 Serial: RA-22-0037 Attachment 3: CSD-EP-RNP-0101-01, Revision 2 and CSD-EP-RNP-0101-02, Revision 2 10 CFR 50.54(q) Summary of Analyses

U.S. Nuclear Regulatory Commission                                           Attachment 3, Page 2 Serial: RA-22-0037
                                   << 10 CFR 50.54(q) Review Form >>
Section I: 10 CFR 50.54(q) Review Number: (EREG #):                                     02403847 Applicable Sites and Applicability Determination # (5AD)
BNP                                     CNS                        HNP MNS                                     ONS                        RNP        CSD-EP-RNP-0101 02403832 CSD-EP-RNP-0101 02403842 Document #, EC #,             Revision # or or N/A                      N/A                            Document or Activity Title CSD-EP-RNP-0101-01            2                    EAL Technical Basis Document CSD-EP-RNP-0101-02            002                  EAL Wallchart (Both Hot and Cold)
Section II: Identify/Describe All Proposed Activities/Changes 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 (Use attachments or continue additional pages as necessary): Continue to Section III.
CSD-EP-RNP-0101-01 is the EAL Technical Basis Document and CSD-EP-RNP-0101-02 is the EAL Wallcharts for RNP.
Changes include:
Editorial changes such as updating revision number, table of contents, revision summary, page numbers, and correcting references.
Update CU5.1 and SU7.1 communication methods to align with Common Emergency Plan communication methods. No physical changes to the communications equipment were made.
Added clarification to the technical basis document for EALs CA6.1, and SA9.1.
Updated basis discussions for HU4.1 & HU4.2 based on implementation of NFPA 805.
Changes for CSD-EP-RNP-0101-01 unless noted otherwise (bolded) in Section or Step # column:
Change      Section or                       Change From                                     Change to
  #            Step #
1       Throughout         Table of contents updates due to changes in     Updated table of contents as a result of the procedure, old revision summary, page       procedure changes, updated revision numbers.                                        summary identifying the changes made from the procedure revision request, and page numbers as a result of the changes to the procedure.
2       Throughout         Old revision number                             New revision number Change applicable to BOTH documents

U.S. Nuclear Regulatory Commission                                   Attachment 3, Page 3 Serial: RA-22-0037 3      2.6                                                               4     Hot Shutdown Basis Changes 3              Hot Shutdown Keff < 0.99 and average coolant Keff < 0.99 and average coolant             temperature 350F > Tavg > 200F (excluding decay heat) temperature 350F > Tavg >
200F (excluding decay heat) 5     Cold Shutdown 4              Cold Shutdown Keff < 0.99 and average coolant Keff < 0.99 and average coolant temperature Tavg  200&#xba;F temperature Tavg  200&#xba;F 5              Refueling                         6     Refueling Keff < 0.95 and average coolant Keff < 0.95 and average coolant temperature Tavg  140F; fuel              temperature Tavg  140F; fuel in the in the reactor vessel with the              reactor vessel with the vessel head vessel head closure bolts less              closure bolts less than fully than fully tensioned or with the            tensioned or with the head removed head removed 4      4.2.5 Basis    PLP-007 Robinson Emergency Plan               Reference deleted Change 5      4.3.6 Basis    Reference added                               EP-ALL-EPLAN, Duke Energy Common Change                                                       Emergency Plan 6      Att. 1 page 1  Error! Reference source not found. Index      Index 7      Att. 1 EAL     4. OMM-014, Radiation Monitor Setpoints       4. OP-920, Radiation Monitoring System RA2.2 Change Basis Change 8      Att. 1 EAL     1. OMM-014, Radiation Monitor Setpoints       1. OP-920, Radiation Monitoring System RA3.1 Basis Change 9      Att. 1 EAL     1. The Emergency Coordinator should           1. The Emergency Coordinator should CA3.1 Basis    declare the event promptly upon determining   declare the event promptly upon Change Note 1  that the applicable time has been exceeded,   determining that time limit has been or will likely be exceeded.                   exceeded, or will likely be exceeded.

U.S. Nuclear Regulatory Commission                                     Attachment 3, Page 4 Serial: RA-22-0037 10     Att. 1 EAL CU5.1 Basis Change and Wallboard 11     Att. 1 EAL Onsite, offsite and NRC communications         Onsite, offsite and NRC communications CU5.1 Basis include one or more of the systems listed in   include one or more of the systems listed in Change         Table C-4 (ref. 1, 2).                         Table C-4 (ref. 1, 2).
The NRC ETS Phone and the NRC HPN              Public Address (PA) System Phone are part of the PBX and will be The Robinson (PA) Public Address System unavailable if the PBX is unavailable.
can broadcast a message via speakers This EAL is the cold condition equivalent of   located throughout the site. It is used to the hot condition EAL SU7.1.                   notify site personnel of emergency declarations, provide additional means to This IC addresses a significant loss of on-notify the ERO, and facilitate on-site site or offsite communications capabilities.
protective actions for personnel.
While not a direct challenge to plant or personnel safety, this event warrants prompt   Radios (on-site) notifications to Offsite Response Standard fixed and mobile transceivers that Organizations (OROs) and the NRC.
allow point-to-point communications onsite.
This IC should be assessed only when Radios are the primary means of extraordinary means are being utilized to communication for the MCR, TSC, and EOF make communications when contacting FMTs.
possible (e.g., use of non-plant, privately Radios are an alternate means of owned equipment, relaying of on-site communication between the MCR, TSC, information via individuals or multiple radio and OSC.
transmission points, individuals being sent to offsite locations, etc.).                      Duke Energy Emergency Management Network (DEMNET)
The first EAL condition addresses a total loss of the communications methods used in     The DEMNET consists of equipment and support of routine plant operations.           circuits linking Duke Energy nuclear sites with the offsite agencies involved in initial The second EAL condition addresses a total emergency notifications. This system can loss of the communications methods used to quickly conference the offsite agencies for notify all OROs of an emergency notifications. RNP MCR, TSC, and the EOF declaration. The OROs referred to here are have this system. It is also located in RNP the State, Darlington, Lee and Chesterfield Alternate TSC and EOF.
County EOCs DEMNET is the primary means of The third EAL addresses a total loss of the communication for the MCR, TSC, and EOF communications methods used to notify the when contacting OROs.
NRC of an emergency declaration.
Private Branch Exchange (PBX)
A PBX is a full featured telephone system

U.S. Nuclear Regulatory Commission    Attachment 3, Page 5 Serial: RA-22-0037 that provides internal calling services for one or more locations. The PBX terminates commercial phone lines from a carrier (AT&T, Verizon, CenturyLink, etc.) to provide inbound and outbound calling capabilities between Duke Energy and external parties. PBX systems have a number of mechanisms which make them resistant to failure including, redundant power connections, redundant network connections, and server hardware installed in geographically diverse locations.
PBX is the primary means of communication between the MCR, TSC, OSC, and EOF.
PBX is the alternate means of communication for the MCR, TSC, and EOF when contacting OROs.
NRC Communications Links PBX is the primary means of communication with the NRC. Extensions designated for NRC communications are located in the MCRs, TSCs, and EOF.
Telephones have been designated for the following NRC communications:
: a. NRC Emergency Notification System (ENS) - This communications line provides a communications link to the NRC Operations Center in Rockville, Maryland, and is used for initial notifications and continuous communications in a classified emergency.
: b. NRC Health Physics Network (HPN) - This communications line provides a communications link with the NRC to provide radiological information. Normally available from the TSC and the EOF.
: c. NRC Reactor Safety Counterpart Link (RSCL) - This communications line provides a communications link for the NRC to conduct internal NRC discussions on plant equipment conditions separate from the licensee.
: d. Protective Measures Counterpart

U.S. Nuclear Regulatory Commission    Attachment 3, Page 6 Serial: RA-22-0037 Link (PMCL) - This communications line provides a communications link for the NRC to conduct internal NRC discussions on radiological releases, meteorological conditions, and the need for protective actions.
: e. Management Counterpart Link (MCPL) (Executive Bridge Line) -
This communications line provides a communications link for any NRC internal discussions between the NRC Executive Team Director or Executive Team members and the NRC response team leader or top-level licensee management at the site.
Business Line A direct single telephone line (i.e. copper) from a carrier (AT&T, Verizon, CenturyLink, etc.) directly to an end point within the plant.
These lines do not pass through any other phone systems (i.e. PBX).
The Business line is an alternate means of communication for the MCR when contacting OROs or NRC.
Cellular Telephones Any mobile telephone (non-Duke Energy or Duke Energy provided) capable of sending and receiving phone calls through ground based cell sites.
Cellular phones are an alternate means of communication between the MCR, TSC, and EOF.
Cellular phones are an alternate means of communication for the MCR, TSC, and EOF when contacting OROs.
Cellular phones are an alternate means of communication for the MCR and TSC when contacting NRC.
Cellular phones are an alternate means of communication for the MCR, TSC, and EOF when contacting FMTs.
Satellite Telephones Any mobile telephone capable of sending and receiving phone calls through orbiting

U.S. Nuclear Regulatory Commission                                    Attachment 3, Page 7 Serial: RA-22-0037 satellites.
Satellite phones are an alternate means of communication between the MCR, TSC, and EOF.
Satellite phones are an alternate means of communication for the MCR, TSC, and EOF when contacting OROs.
Satellite phones are an alternate means of communication for the MCR and TSC when contacting NRC.
Satellite phones are an alternate means of communication for the MCR, TSC, and EOF when contacting FMTs.
12     Att. 1 EAL     1. PLP-007, Emergency Plan, Attachment        1. EP-ALL-EPLAN, Section F, Emergency CU5.1 Basis    6.1                                           Communications References Change 13     Att. 1 EAL     Added to document                             This EAL is based on a single event that is CA6.1 Basis                                                  significant enough to cause damage to two Change                                                       trains of the same safety system. The examples below can assist in determining the threshold meeting the two train criteria.
14     Att. 1 EAL     Added to document CA6.1 Basis Change 15     Att. 1 EAL     This IC addresses a hazardous event that      This IC addresses a hazardous event that CA6.1 Basis    causes damage to SAFETY SYSTEMS               causes damage to SAFETY SYSTEMS Change         needed for the current operating mode. In     needed for the current operating mode. In order to provide the appropriate context for  order to provide the appropriate context for consideration of an ALERT classification,     consideration of an ALERT classification, the hazardous event must have caused          the hazardous event must have caused indications of degraded SAFETY SYSTEM         indications of degraded SAFETY performance in one train, and there must be   SYSTEM performance in one train, and either indications of performance issues with there must be either indications of

U.S. Nuclear Regulatory Commission                                        Attachment 3, Page 8 Serial: RA-22-0037 the second SAFETY SYSTEM train or                 performance issues with the second VISIBLE DAMAGE to the second train such           SAFETY SYSTEM train or VISIBLE that the potential exists for this second         DAMAGE to the second train such that SAFETY SYSTEM train to have                       the potential exists for this second performance issues. In other words, in order      SAFETY SYSTEM train to have for this EAL to be classified, the hazardous      performance issues. In other words, in event must occur, at least one SAFETY             order for this EAL to be classified, the SYSTEM train must have indications of             hazardous event must occur, at least one degraded performance, and the second              SAFETY SYSTEM train must have SAFETY SYSTEM train must have                     indications of degraded performance, and indications of degraded performance or            the second SAFETY SYSTEM train must VISIBLE DAMAGE such that the potential            have indications of degraded performance exists for performance issues. Note that this     or VISIBLE DAMAGE such that the second SAFETY SYSTEM train is from the            potential exists for performance issues.
same SAFETY SYSTEM that has                       Note that this second SAFETY SYSTEM indications of degraded performance for           train is from the same SAFETY SYSTEM criteria in the first condition of this EAL;      that has indications of degraded commercial nuclear power plants are               performance for criteria in the first condition designed to be able to support single system      of this EAL. Commercial nuclear power failures without compromising public health       plants are designed to be able to support and safety from radiological events.              single system issues without compromising Indications of degraded performance               public health and safety from radiological address damage to a SAFETY SYSTEM                 events.
train that is in service/operation since          Indications of degraded performance indications for it will be readily available. The address damage to a SAFETY SYSTEM indications of degraded performance should        train that is in service/operation since be significant enough to cause concern            indications for it will be readily available.
regarding the operability or reliability of the   The indications of degraded performance SAFETY SYSTEM train.                              should be significant enough to cause Operators will make a determination of            concern regarding the operability or VISIBLE DAMAGE based on the totality of           reliability of the SAFETY SYSTEM train.
available event and damage report                 Operators will make a determination of information. This is intended to be a brief       VISIBLE DAMAGE based on the totality of assessment not requiring lengthy analysis or      available event and damage report quantification of the damage. The VISIBLE         information. This is intended to be a brief DAMAGE should be significant enough to            assessment not requiring lengthy analysis cause concern regarding the operability or        or quantification of the damage. This reliability of the SAFETY SYSTEM train.           VISIBLE DAMAGE should be significant An event affecting equipment common to            enough to cause concern regarding the two or more safety systems or safety system       operability or reliability of the SAFETY trains (i.e., there are indications of degraded   SYSTEM train.
performance and/or VISIBLE DAMAGE                 An event affecting equipment common affecting the common equipment) should be         to two or more safety systems or safety classified as an Alert under CA6, as              system trains (i.e., there are indications appropriate to the plant mode. By affecting       of degraded performance and/or VISIBLE the operability or reliability of multiple        DAMAGE affecting the common system trains, the loss of the common             equipment) should be classified as an equipment effectively meets the two-train         Alert under CA6, as appropriate to the impact criteria that underlie the EALs and        plant mode. By affecting the operability or Bases.                                            reliability of multiple system trains, the loss An event affecting a single-train safety          of the common equipment effectively meets system (i.e., there are indications of            the two-train impact criteria that underlie the degraded performance and/or VISIBLE               EALs and Bases.
DAMAGE affecting the one train) would not         An event affecting a single-train safety

U.S. Nuclear Regulatory Commission                                         Attachment 3, Page 9 Serial: RA-22-0037 be classified under CA6 because the two-           system (i.e., there are indications of train impact criteria that underlie the EALs       degraded performance and/or VISIBLE and Bases would not be met. If an event            DAMAGE affecting the one train) would not affects a single-train safety system, then the     be classified under CA6 because the two-emergency classification should be made            train impact criteria that underlie the EALs based on plant parameters/symptoms                 and Bases would not be met. If an event meeting the EALs for another IC. Depending         affects a single-train safety system, then the upon the circumstances,                            emergency classification should be made based on plant parameters/symptoms meeting the EALs for another IC.
Depending upon the circumstances, 16     Att. 1 EAL     classification may also occur based on Shift       classification may also occur based on Shift CA6.1 Basis    Manager/Emergency Director                         Manager/Emergency Coordinator Change         judgement.                                         judgement.
17     Att. 1 EAL     The 15 minute requirement begins with a            The 15 minute requirement begins with a HU4.1 Basis    credible notification that a fire is occurring,    credible notification that a fire is occurring, Change         or receipt of multiple valid fire detection        or receipt of multiple valid fire detection system alarms or field validation of a single      system alarms or field validation of a single fire alarm. The alarm is to be validated using     fire alarm. The alarm is to be validated available Control Room indications or              using available Control Room indications or alarms to prove that it is not spurious, or by     alarms to prove that it is not spurious, or by reports from the field.                            reports from the field.
Table H-1 Fire Areas include those                 Table H-1 Fire Areas include those structures containing functions and systems        structures containing functions and systems required for safe shutdown of the plant            required for safe shutdown of the plant (SAFETY SYSTEMS) (ref. 1, 2).                      (SAFETY SYSTEMS) (ref. 1, 2).
This IC addresses the magnitude and extent         This IC addresses the magnitude and of FIRES that may be indicative of a               extent of FIRES that may be indicative of a potential degradation of the level of safety of    potential degradation of the level of safety the plant.                                         of the plant.
For EAL HU4.1 the intent of the 15-minute          For EAL HU4.1 the intent of the 15-minute duration is to size the FIRE and to                duration is to size the FIRE and to discriminate against small FIRES that are          discriminate against small FIRES that are readily extinguished (e.g., smoldering waste       readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other        paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire      indications of a FIRE could be a drop in fire main pressure, automatic activation of a           main pressure, automatic activation of a suppression system, etc.                           suppression system, etc.
Upon receipt, operators will take prompt           Upon receipt, operators will take prompt actions to confirm the validity of an initial fire actions to confirm the validity of an initial fire alarm, indication, or report. For EAL              alarm, indication, or report. For EAL assessment purposes, the emergency                 assessment purposes, the emergency declaration clock starts at the time that the      declaration clock starts at the time that the initial alarm, indication, or report was           initial alarm, indication, or report was received, and not the time that a subsequent       received, and not the time that a verification action was performed. Similarly,      subsequent verification action was the fire duration clock also starts at the time    performed. Similarly, the fire duration clock of receipt of the initial alarm, indication or     also starts at the time of receipt of the initial report.                                            alarm, indication or report.
Basis-Related Requirements from Appendix           Depending upon the plant mode at the time R Appendix R to 10 CFR 50, states in part:         of the event, escalation of the emergency Criterion 3 of Appendix A to this part             classification level would be via IC CA6 or specifies that "Structures, systems, and           SA9.

U.S. Nuclear Regulatory Commission                                     Attachment 3, Page 10 Serial: RA-22-0037 components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."
When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.
Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.
In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c).
As used in this EAL, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or SA9.
18     Att. 1 EAL     The 30 minute requirement begins upon           The 30 minute requirement begins upon HU4.2 Basis    receipt of a single valid fire detection system receipt of a single valid fire detection Change         alarm. The alarm is to be validated using       system alarm. The alarm is to be validated available Control Room indications or           using available Control Room indications or alarms to prove that it is not spurious, or by  alarms to prove that it is not spurious, or by reports from the field. Actual field reports    reports from the field. Actual field reports must be made within the 30 minute time limit    must be made within the 30 minute time or a classification must be made. If a fire is  limit or a classification must be made. If a verified to be occurring by field report,       fire is verified to be occurring by field report, classification shall be made based on EAL       classification shall be made based on EAL HU4.1.                                          HU4.1.
Table H-1 Fire Areas include those              Table H-1 Fire Areas include those structures containing functions and systems     structures containing functions and systems required for safe shutdown of the plant         required for safe shutdown of the plant (SAFETY SYSTEMS) (ref. 1, 2).                   (SAFETY SYSTEMS) (ref. 1, 2).
This IC addresses the magnitude and extent      This IC addresses the magnitude and of FIRES that may be indicative of a            extent of FIRES that may be indicative of a potential degradation of the level of safety of potential degradation of the level of safety

U.S. Nuclear Regulatory Commission                                     Attachment 3, Page 11 Serial: RA-22-0037 the plant.                                      of the plant.
This EAL addresses receipt of a single fire     This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not       alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30- verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt,             minutes of the alarm. Upon receipt, operators will take prompt actions to confirm   operators will take prompt actions to confirm the validity of a single fire alarm. For EAL    the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock        assessment purposes, the 30-minute clock starts at the time that the initial alarm was   starts at the time that the initial alarm was received, and not the time that a subsequent    received, and not the time that a verification action was performed.              subsequent verification action was A single fire alarm, absent other indication(s) performed.
of a FIRE, may be indicative of equipment       A single fire alarm, absent other failure or a spurious activation, and not an    indication(s) of a FIRE, may be indicative of actual FIRE. For this reason, additional time   equipment failure or a spurious activation, is allowed to verify the validity of the alarm. and not an actual FIRE. For this reason, The 30-minute period is a reasonable            additional time is allowed to verify the amount of time to determine if an actual        validity of the alarm. The 30-minute period FIRE exists; however, after that time, and      is a reasonable amount of time to determine absent information to the contrary, it is       if an actual FIRE exists; however, after that assumed that an actual FIRE is in progress. time, and absent information to the contrary, If an actual FIRE is verified by a report from  it is assumed that an actual FIRE is in the field, then HU4.1 is immediately            progress.
applicable, and the emergency must be           If an actual FIRE is verified by a report from declared if the FIRE is not extinguished        the field, then HU4.1 is immediately within 15-minutes of the report. If the alarm   applicable, and the emergency must be is verified to be due to an equipment failure   declared if the FIRE is not extinguished or a spurious activation, and this verification within 15-minutes of the report. If the alarm occurs within 30-minutes of the receipt of      is verified to be due to an equipment failure the alarm, then this EAL is not applicable      or a spurious activation, and this verification and no emergency declaration is warranted.      occurs within 30-minutes of the receipt of Basis-Related Requirements from Appendix        the alarm, then this EAL is not applicable R Appendix R to 10 CFR 50, states in part:      and no emergency declaration is warranted.
Criterion 3 of Appendix A to this part          Depending upon the plant mode at the time specifies that "Structures, systems, and        of the event, escalation of the emergency components important to safety shall be         classification level would be via IC CA6 or designed and located to minimize,               SA9.
consistent with other safety requirements, the probability and effect of fires and explosions."
When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.
Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to

U.S. Nuclear Regulatory Commission                                    Attachment 3, Page 12 Serial: RA-22-0037 systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.
In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c).
As used in this EAL, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or SA9.
19     Att. 1 EAL     A list of hazardous gases (ref. 2, 3):          A list of hazardous gases (ref. 2, 3, 4):
HA5.1 Basis Change 20     Att. 1 EAL     1. Attachment 3, Safe Operation &               1. Attachment 3, Safe Operation &
HA5.1 Basis    Shutdown Rooms/Areas Table R-2/H-2              Shutdown Rooms/Areas Table R-2/H-2 Reference      Bases                                           Bases Change         2. PLP-021, Chemical Storage, Inventory,        2. AD-EN-ALL-0045, Nuclear Chemical Spill And Hazard Communication Program          Control
: 3. PLP-022, Environmental Regulatory            3. AD-EN-ALL-0200, Spill Response Compliance Guidelines For Disposal Of           4. AD-EN-ALL-0140, Management of Hazardous                                       Chlorofluorocarbons, Refrigerants, and Waste/Surplus Chemicals                         Halons
: 4. NEI 99-01 HA5                                5. NEI 99-01 HA5 21     Att. 1 EAL     1. PLP-007, Robinson Emergency Plan             1. EP-ALL-EPLAN, Duke Energy Common HU7.1 Basis                                                    Emergency Plan Reference Change 22     Att. 1 EAL     1. PLP-007, Robinson Emergency Plan             1. EP-ALL-EPLAN, Duke Energy Common HA7.1 Basis                                                    Emergency Plan Reference Change 23     Att. 1 EAL     1. PLP-007, Robinson Emergency Plan             1. EP-ALL-EPLAN, Duke Energy Common HS7.1 Basis                                                    Emergency Plan Reference Change 24     Att. 1 EAL     1. PLP-007, Robinson Emergency Plan             1. EP-ALL-EPLAN, Duke Energy Common HG7.1 Basis                                                    Emergency Plan Reference Change 25     Att. 1 EAL     2. OMM-014, Radiation Monitor Setpoints         2. OP-920, Radiation Monitoring System SU4.2 Basis Reference Change

U.S. Nuclear Regulatory Commission                                    Attachment 3, Page 13 Serial: RA-22-0037 26     Att. 1 EAL SU7.1 Basis Change and Wallboard 27     Att. 1 EAL     Onsite, offsite and NRC communications Onsite, offsite and NRC communications SU7.1 Basis    include one or more of the systems listed in include one or more of the systems listed in Change         Table S-3 (ref. 1, 2).
Table S-3 (ref. 1, 2).
The NRC ETS Phone and the NRC HPN Phone are part of the PBX and will be           Public Address (PA) System unavailable if the PBX is unavailable.          The Robinson (PA) Public Address System This EAL is the hot condition equivalent of     can broadcast a message via speakers the cold condition EAL CU5.1.                   located throughout the site. It is used to This IC addresses a significant loss of on-     notify site personnel of emergency site or offsite communications capabilities. declarations, provide additional means to While not a direct challenge to plant or        notify the ERO, and facilitate on-site personnel safety, this event warrants prompt    protective actions for personnel.
notifications to Offsite Response Organizations (OROs) and the NRC.               Radios (on-site)
This IC should be assessed only when            Standard fixed and mobile transceivers that extraordinary means are being utilized to       allow point-to-point communications onsite.
make communications possible (e.g., use of non-plant, privately owned equipment,           Radios are the primary means of relaying of on-site information via individuals communication for the MCR, TSC, and EOF or multiple radio transmission points,          when contacting FMTs.
individuals being sent to offsite locations,    Radios are an alternate means of etc.).                                          communication between the MCR, TSC, The first EAL condition addresses a total       and OSC.
loss of the communications methods used in support of routine plant operations.            Duke Energy Emergency Management Network (DEMNET)
The second EAL condition addresses a total loss of the communications methods used to      The DEMNET consists of equipment and notify all OROs of an emergency                 circuits linking Duke Energy nuclear sites declaration. The OROs referred to here are      with the offsite agencies involved in initial the State, Darlington, Lee and Chesterfield     emergency notifications. This system can County EOCs                                     quickly conference the offsite agencies for The third EAL condition addresses a total       notifications. RNP MCR, TSC, and the EOF loss of the communications methods used to      have this system. It is also located in RNP notify the NRC of an emergency declaration. Alternate TSC and EOF.
DEMNET is the primary means of communication for the MCR, TSC, and EOF when contacting OROs.
Private Branch Exchange (PBX)
A PBX is a full featured telephone system

U.S. Nuclear Regulatory Commission  Attachment 3, Page 14 Serial: RA-22-0037 that provides internal calling services for one or more locations. The PBX terminates commercial phone lines from a carrier (AT&T, Verizon, CenturyLink, etc.) to provide inbound and outbound calling capabilities between Duke Energy and external parties. PBX systems have a number of mechanisms which make them resistant to failure including, redundant power connections, redundant network connections, and server hardware installed in geographically diverse locations.
PBX is the primary means of communication between the MCR, TSC, OSC, and EOF.
PBX is the alternate means of communication for the MCR, TSC, and EOF when contacting OROs.
NRC Communications Links PBX is the primary means of communication with the NRC. Extensions designated for NRC communications are located in the MCRs, TSCs, and EOF.
Telephones have been designated for the following NRC communications:
: a. NRC Emergency Notification System (ENS) - This communications line provides a communications link to the NRC Operations Center in Rockville, Maryland, and is used for initial notifications and continuous communications in a classified emergency.
: b. NRC Health Physics Network (HPN) - This communications line provides a communications link with the NRC to provide radiological information. Normally available from the TSC and the EOF.
: c. NRC Reactor Safety Counterpart Link (RSCL) - This communications line provides a communications link for the NRC to conduct internal NRC discussions on plant equipment conditions separate from the licensee.
: d. Protective Measures Counterpart Link (PMCL) - This

U.S. Nuclear Regulatory Commission  Attachment 3, Page 15 Serial: RA-22-0037 communications line provides a communications link for the NRC to conduct internal NRC discussions on radiological releases, meteorological conditions, and the need for protective actions.
: e. Management Counterpart Link (MCPL) (Executive Bridge Line) -
This communications line provides a communications link for any NRC internal discussions between the NRC Executive Team Director or Executive Team members and the NRC response team leader or top-level licensee management at the site.
Business Line A direct single telephone line (i.e. copper) from a carrier (AT&T, Verizon, CenturyLink, etc.) directly to an end point within the plant.
These lines do not pass through any other phone systems (i.e. PBX).
The Business line is an alternate means of communication for the MCR when contacting OROs or NRC.
Cellular Telephones Any mobile telephone (non-Duke Energy or Duke Energy provided) capable of sending and receiving phone calls through ground based cell sites.
Cellular phones are an alternate means of communication between the MCR, TSC, and EOF.
Cellular phones are an alternate means of communication for the MCR, TSC, and EOF when contacting OROs.
Cellular phones are an alternate means of communication for the MCR and TSC when contacting NRC.
Cellular phones are an alternate means of communication for the MCR, TSC, and EOF when contacting FMTs.
Satellite Telephones Any mobile telephone capable of sending and receiving phone calls through orbiting satellites.

U.S. Nuclear Regulatory Commission                                  Attachment 3, Page 16 Serial: RA-22-0037 Satellite phones are an alternate means of communication between the MCR, TSC, and EOF.
Satellite phones are an alternate means of communication for the MCR, TSC, and EOF when contacting OROs.
Satellite phones are an alternate means of communication for the MCR and TSC when contacting NRC.
Satellite phones are an alternate means of communication for the MCR, TSC, and EOF when contacting FMTs.
28     Att. 1 EAL     1. PLP-007, Emergency Plan, Attachment        1. EP-ALL-EPLAN, Section F, Emergency SU7.1 Basis    6.1                                           Communications References Change 29     Att. 1 EAL     Added to document                             This EAL is based on a single event that is SA9.1 Basis                                                  significant enough to cause damage to two Change                                                       trains of the same safety system. The examples below can assist in determining the threshold meeting the two train criteria.
30     Att. 1 EAL     Added to document SA9.1 Basis Change 31     Att. 1 EAL     This IC addresses a hazardous event that      This IC addresses a hazardous event SA9.1 Basis    causes damage to SAFETY SYSTEMS               that causes damage to SAFETY Change         needed for the current operating mode. In     SYSTEMS needed for the current order to provide the appropriate context for  operating mode. In order to provide the consideration of an ALERT classification,     appropriate context for consideration of the hazardous event must have caused          an ALERT classification, the hazardous indications of degraded SAFETY SYSTEM         event must have caused indications performance in one train, and there must be   of degraded SAFETY SYSTEM either indications of performance issues with performance in one train, and there the second SAFETY SYSTEM train or             must be either indications of VISIBLE DAMAGE to the second train such       performance issues with the second

U.S. Nuclear Regulatory Commission                                      Attachment 3, Page 17 Serial: RA-22-0037 that the potential exists for this second         SAFETY SYSTEM train or VISIBLE SAFETY SYSTEM train to have                       DAMAGE to the second train such performance issues. In other words, in order      that the potential exists for this for this EAL to be classified, the hazardous      second SAFETY SYSTEM train to event must occur, at least one SAFETY             have performance issues. In other SYSTEM train must have indications of             words, in order for this EAL to be degraded performance, and the second              classified, the hazardous event must SAFETY SYSTEM train must have                     occur, at least one SAFETY SYSTEM indications of degraded performance or            train must have indications of degraded VISIBLE DAMAGE such that the potential            performance, and the second SAFETY exists for performance issues. Note that this     SYSTEM train must have indications of second SAFETY SYSTEM train is from the            degraded performance or VISIBLE same SAFETY SYSTEM that has                       DAMAGE such that the potential exists indications of degraded performance for           for performance issues. Note that this criteria in the first condition of this EAL;      second SAFETY SYSTEM train is from commercial nuclear power plants are               the same SAFETY SYSTEM that has designed to be able to support single system      indications of degraded performance for failures without compromising public health       criteria in the first condition of this EAL.
and safety from radiological events.              Commercial nuclear power plants are Indications of degraded performance               designed to be able to support single address damage to a SAFETY SYSTEM                 system issues without compromising train that is in service/operation since          public health and safety from indications for it will be readily available. The radiological events.
indications of degraded performance should        Indications of degraded performance be significant enough to cause concern            address damage to a SAFETY SYSTEM regarding the operability or reliability of the   train that is in service/operation since SAFETY SYSTEM train.                              indications for it will be readily available.
Operators will make a determination of            The indications of degraded performance VISIBLE DAMAGE based on the totality of           should be significant enough to cause available event and damage report                 concern regarding the operability or information. This is intended to be a brief       reliability of the SAFETY SYSTEM train.
assessment not requiring lengthy analysis or      Operators will make a determination of quantification of the damage. The VISIBLE         VISIBLE DAMAGE based on the totality of DAMAGE should be significant enough to            available event and damage report cause concern regarding the operability or        information. This is intended to be a brief reliability of the SAFETY SYSTEM train.           assessment not requiring lengthy analysis An event affecting equipment common to            or quantification of the damage. This two or more safety systems or safety system       VISIBLE DAMAGE should be significant trains (i.e., there are indications of degraded   enough to cause concern regarding the performance and/or VISIBLE DAMAGE                 operability or reliability of the SAFETY affecting the common equipment) should be         SYSTEM train.
classified as an Alert under SA9 (SA8 for         An event affecting equipment common BNP), as appropriate to the plant mode. By        to two or more safety systems or safety affecting the operability or reliability of       system trains (i.e., there are indications multiple system trains, the loss of the           of degraded performance and/or VISIBLE common equipment effectively meets the            DAMAGE affecting the common two-train impact criteria that underlie the       equipment) should be classified as an EALs and Bases.                                   Alert under SA9 (SA8 for BNP), as An event affecting a single-train safety          appropriate to the plant mode. By system (i.e., there are indications of            affecting the operability or reliability of degraded performance and/or VISIBLE               multiple system trains, the loss of the DAMAGE affecting the one train) would not         common equipment effectively meets the be classified under SA9 because the two-          two-train impact criteria that underlie the train impact criteria that underlie the EALs      EALs and Bases.

U.S. Nuclear Regulatory Commission                                   Attachment 3, Page 18 Serial: RA-22-0037 and Bases would not be met. If an event        An event affecting a single-train safety affects a single-train safety system, then the system (i.e., there are indications of emergency classification should be made        degraded performance and/or VISIBLE based on plant parameters/symptoms             DAMAGE affecting the one train) would not meeting the EALs for another IC. Depending     be classified under SA9 (SA8 for BNP) upon the circumstances,                        because the two-train impact criteria that underlie the EALs and Bases would not be met. If an event affects a single-train safety system, then the emergency classification should be made based on plant parameters/symptoms meeting the EALs for another IC. Depending upon the circumstances, 32     Att. 1 EAL     classification may also occur based on Shift   classification may also occur based on Shift SA9.1 Basis    Manager/Emergency Director                     Manager/Emergency Coordinator Change                                                        judgement.
33     Att. 2 CSFST   2. OMM-022, EOP Users Guide                    2. AD-OP-RNP-1001, RNP Conduct of Core Cooling-                                                 Abnormal Operations RED Path entry conditions met References Change 34     Att. 2 CSFST   2. OMM-022, EOP Users Guide                    2. AD-OP-RNP-1001, RNP Conduct of Core Cooling-                                                 Abnormal Operations ORANGE Path entry conditions met References Change 35     Att. 2 CSFST   3. OMM-022, EOP User's Guide                   3. AD-OP-RNP-1001, RNP Conduct of Heat Sink-                                                    Abnormal Operations RED Path entry conditions met AND Heat sink is required References Change

U.S. Nuclear Regulatory Commission                                       Attachment 3, Page 19 Serial: RA-22-0037 36      Att. 2            5. OMM-014, Radiation Monitor Setpoints         5. OP-920, Radiation Monitoring System Containment High Range Radiation Monitor R-32A or R-32B >100 R/hr References Change 37      Att. 2 CSFST      3. OMM-022, EOP User's Guide                    3. AD-OP-RNP-1001, RNP Conduct of Heat Sink-                                                        Abnormal Operations RED path entry conditions met AND Heat sink is required References Change 38      Att. 2            4. OMM-014, Radiation Monitor Setpoints         4. OP-920, Radiation Monitoring System Containment High Range Radiation Monitor R-32A or R-32B > 5 R/hr.
References Change 39      Att. 2            4. OMM-014, Radiation Monitor Setpoints         4. OP-920, Radiation Monitoring System Containment High Range Radiation Monitor R-32A or R-32B
           >2000 R/hr References Change Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:
List all emergency plan sections that were reviewed for this activity by number and title.
IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.

U.S. Nuclear Regulatory Commission                                             Attachment 3, Page 20 Serial: RA-22-0037 Licensing Basis EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 0 EP-RNP-EPLAN-ANNEX, Duke Energy Robinson Emergency Plan Annex Revision 0 Licensing Basis for NEI 99-01 Rev 6 EALS RNP: ML16061A472 Letter Dated April 28, 2016. 

==Subject:==
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - ISSUANCE OF AMENDMENT TO ADOPT EMERGENCY ACTION LEVEL SCHEME PURSUANT TO NEI 99-01, REVISION 6, "DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS" (CAC NO. MF6222)
Amendment No. 245 to Renewed Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant Unit No. 2.
Current Emergency Plan EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 1 EP-RNP-EPLAN-ANNEX, Duke Energy Robinson Emergency Plan Annex Revision 1 The differences in the approved and the current revision of the Emergency Plan have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions.
Section IV: Ability to Maintain the Emergency Plan.
Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.
: 1. Do any of the elements of the proposed activity change information or intent contained in the Emergency        Yes Plan?                                                                                                           No
: 2. Do any elements of the proposed activity change an Initiating Condition (IC), Emergency Action Level           Yes (EAL), associated EAL note or basis, including underlying calculation or basis?                                 No  , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is required to be completed as part of this review if "Yes" is selected above in question 2.
: 3. Do any elements of the proposed activity change the process or capability for alerting or notifying the public Yes as described in the FEMA-approved Alert and Notification System Design Report?                                  No
: 4. Do any elements of the proposed activity change the Evacuation Time Estimate results?                          Yes No
: 5. Do any elements of the proposed activity change the On-Shift Staffing Analysis results?                        Yes No
: 6. Does the Proposed activity require a change to the Emergency Plan Programmatic Description?                    Yes No If Question 6 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.
Section IV conclusion:
If questions 1-6 in Section IV marked NO, then complete Section V.
If any question 1-6 of Section IV marked yes, then continue at Section VI.

U.S. Nuclear Regulatory Commission                                                  Attachment 3, Page 21 Serial: RA-22-0037 Section V: Maintaining the Emergency Plan Conclusion.
The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.
: 1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.
: 2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.
I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).

== Conclusion:==

Section VI: Activity Previously Reviewed?
Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?
10 CFR 50.54(q) Evaluation is not required.
Yes Identify bounding source document below and continue to Section XIV.
No              Continue to Section VII.
If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.
Partially Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.
Section VII: Editorial Changes All Activities/Changes identified in Section II are editorial/typographical changes such as formatting, Yes                 paragraph numbering, spelling, or punctuation that does not change intent.
None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to Section No VIII.
Partially           Some Activities/Changes are editorial/typographical.
If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XIV.
If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.
Justification:
The changes below are defined as editorial in accordance with AD-EP-ALL-0602, and do not change the intent of the steps as written:
Changes 1 and 2 - Editorial because the changes update revision number, page numbers, table of contents, and revision summary.

U.S. Nuclear Regulatory Commission                                               Attachment 3, Page 22 Serial: RA-22-0037 Changes 4, 5, 12, 21 - 24, and 28 - Editorial because it updates the reference from the superseded document PLP-007 to the new Common Emergency Plan, EP-ALL-EPLAN. Change 4 and 5 also moved the reference from Procedures section 4.2 to Miscellaneous Documents section 4.3.
Change 6 - Editorial because is corrects formatting and typographical changes that do not change intent, purpose, or order of procedural steps.
Changes 7 - 8, 25, 36, 38 Editorial because it updates the reference from the superseded document OMM-014 to the new document OP-920.
Changes 16 and 32 - Editorial because it corrects the ERO Position title from "Emergency Director" to "Emergency Coordinator". Correct titles of plant organizations, position titles or department/section/unit names where no change in the authority, responsibility, or reporting relationships.
Changes 19 and 20 - Editorial because it updates the references from the superseded documents. PLP-021 is being superseded by two procedures: AD-EN-ALL-0045, Nuclear Chemical Control and AD-EN-ALL-0200, Spill Response. PLP-022 is being superseded to AD-EN-ALL-0140, Management of Chlorofluorocarbons, Refrigerants, and Halons.
Changes 33 - 35, and 37 - Editorial because it updates the references from the superseded document OMM-022 to the new document AD-OP-RNP-1001.

U.S. Nuclear Regulatory Commission                                               Attachment 3, Page 23 Serial: RA-22-0037 Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)
Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate box.
1       10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a    Responsibility for emergency response is assigned.
The response organization has the staff to respond and to augment staff on a continuing basis (24-7 staffing) in 1b 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 The response organization has the staff to respond and to augment staff on a continuing basis (24-7 staffing) in 2b accordance with the emergency plan.
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.
4       10 CFR 50.47(b)(4) Emergency Classification System                                                                RS A standard scheme of emergency classification and action levels is in use. (Requires V/V (Attachment 5) and 4a final approval of Screen and Evaluation by EP CFAM) 5       10 CFR 50.47(b)(5) Notification Methods and Procedures                                                            RS Procedures for notification of State and local governmental agencies are capable of alerting them of the declared 5a      emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.
Administrative and physical means have been established for alerting and providing prompt instructions to 5b public within the plume exposure pathway.
The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 5c      Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter 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 Emergency preparedness information is made available to the public on a periodic basis within the plume 7a exposure pathway emergency planning zone (EPZ).
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                                                                            RS 9a      Methods, systems, and equipment for assessment of radioactive releases are in use.
10      10 CFR 50.47(b) (10) Protective Response                                                                          RS 10a     A range of public PARs is available for implementation during emergencies.
Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to 10b support the formulation of PARs and have been provided to State and local governmental authorities.
A range of protective actions is available for plant emergency workers during emergencies, including those for 10c hostile action events.

U.S. Nuclear Regulatory Commission                                                 Attachment 3, Page 24 Serial: RA-22-0037 KI is available for implementation as a protective action recommendation in those jurisdictions that chose to 10d 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 A drill and exercise program (including radiological, medical, health physics and other program areas) is 14a established.
Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and 14b 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.
Planners responsible for emergency plan development and maintenance are properly trained.
16b Section VIII: Conclusion If any Section VIII criteria are checked, continue the 50.54(q) Review Section IX.
If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document the basis for conclusion below and continue to Section XIV.
Change 9 - More than editorial as it removes "the applicable time" in note 1 to align with all other instances of note 1 terminology "time limit" used in the basis document and wallcharts. The changing of the terminology does not change the intent of the note or cause the EAL to be declared more or less often.
Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.
Planning Standard 10 CFR 50.47(b)(4) states: A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

U.S. Nuclear Regulatory Commission                                          Attachment 3, Page 25 Serial: RA-22-0037 Function The emergency planning function associated with 10 CFR 50.47(b)(4) states:
* A standard scheme of emergency classification and action levels is in use.
Appendix E Supporting requirements which are described in 10 CFR 50, Appendix E states:
IV.B:
: 1. The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities and approved by the NRC.
Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis.
IV.C:
: 1. The entire spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described. The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described.
Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described. The existence, but not the details, of a message authentication scheme shall be noted for such agencies. The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG-0654/FEMA-REP-1.
: 2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.
Informing Criteria from NUREG-0654 Revision 2 The applicable program elements described in NUREG-0654 revision 2, Section II.D state:
D.1: A standard emergency classification and action level scheme is established and maintained. The scheme provides detailed EALs for each of the four ECLs in Section IV.C.1 of Appendix E to 10 CFR Part 50.
D.1.a: The EALs are developed using guidance provided or endorsed by the NRC that is applicable to the reactor design.

U.S. Nuclear Regulatory Commission                                                Attachment 3, Page 26 Serial: RA-22-0037 D.1.b: The initial emergency classification and action level scheme is discussed and agreed to by the licensee and OROs, and approved by the NRC. Thereafter, the scheme is reviewed with OROs on an annual basis.
D.2: The capability to assess, classify, and declare the emergency condition within 15 minutes after the availability of indications to NPP operators that an EAL has been met or exceeded is described.
Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC 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). Address each Planning Standard identified in Section IX. Continue to Section XI.
Proposed change 3 updates the Operating Mode Applicability:
Hot Shutdown, Cold Shutdown, and Refueling where inadvertently given the wrong numerical equivalent in section 2.6 of the EAL basis. This change aligns those modes with the accepted definitions of the modes of applicability as found the RNP Technical Specifications and the UFSAR. All individual ICs have correct modes listed with the correct numerical values for each mode. This change does not cause a change to mode applicability of the EAL that excludes an operating mode in which the EAL should be applicable.
Proposed changes 10 - 11 and 26 - 27 update CU5.1 and SU7.1 communication methods:
This updates EAL wallchart and bases document Communication Methods table and bases definitions to match Common Emergency Plan. The following changes were made:
Added acronym (PA) to Public Address System. This aligns with terminology used at the site with no change to intent or how the EAL determined.
Radios (on-site) added to table. This is a renaming of the previous Radio Transceivers for RNP and Vicinity and which are the designated ERO radios and radio transceivers used onsite. There is no change to the equipment or how the equipment is being utilized. Radios are an alternate means of communication between the MCR, TSC, and OSC. This communication type is included in the Duke Energy Emergency Plan as a means to communicate between emergency facilities onsite. This change does not change the intent or how the EAL determined.
Spelled out acronym for DEMNET. Enhancement to understand meaning of DEMNET, this change does not change the intent or how the EAL is determined.
BellSouth removed from communication table and combined with ESSX into the new title Business Line.
BellSouth(AT&T) is the dedicated copper line coming into the plant that ties in with the ESSX system which is separate from PBX to provide communication with on-site, offsite and NRC. The removal of the title Bellsouth does not change any systems or functions of the communication system. Bellsouth was a duplicate naming of ESSX. This does not change the intent of the EAL as the removal of this title does not alter any functions or capabilities of the telephone system. RNP still maintains the ability to effectively maintain onsite, offsite and NRC communications.
Back-up Telephone System (ESSX) removed from communications table and replaced by title Business Line. ESSX utilizes dedicated AT&T lines and bypasses the PBX extensions in the emergency facilities.
This system is independent of the operation of the plant PBX and with the dedicated copper line (AT&T line) can be used for onsite, offsite and NRC notifications. The removal of the title ESSX does not change any systems or functions of the communication system. ESSX was a duplicate naming of Bellsouth. This does not change the intent of the EAL as the removal of this title does not alter any functions or capabilities

U.S. Nuclear Regulatory Commission                                                 Attachment 3, Page 27 Serial: RA-22-0037 of the telephone system. RNP still maintains the ability to effectively maintain onsite, offsite and NRC communications.
NRC Emergency Telecommunications System (ETS) removed from communication methods table for communicating with OROs and NRC and combined with PBX. NRC ETS is supplied through site PBX.
PBX is the primary means of communicating with the NRC. Extensions designated for NRC communications are in the emergency response facilities. This change aligns with terminology used at the site and fleet with no change to intent or how the EAL is determined.
Plant Security Radio Transceivers removed from communication methods table. These transceiver portables are used by the dedicated plant security force for communications in and around the plant through two UHF radio repeaters. The ERO does not use these radios for communications in the MCR, TSC, or OSC. The primary method of onsite communication is PBX with alternate means being onsite radios, PA system, and Business Line. This system is remaining in service to by used by Security personnel as their primary means of communication. Alternate forms of communication for Security is PA system or PBX System.
Plant Security Radio Control Station removed from communication methods table. This system is utilized for communicating with offsite Law Enforcement and is not used for notification to the OROs. Based on not meeting the intent of offsite communication, this method of communication is being removed. The primary means of notification with OROs is DEMNET with alternate means being PBX, Business Line, Cellular Telephone, and Satellite Telephones. This change aligns with the common E-Plan and does not change the intent or how the EAL determined. Offsite Law Enforcement can still be contacted using this system, PBX, Cellular Phone, Satellite Phone, Business Line or Palmetto 800.
o From UFSAR 9.5.2: plant security radio link station are used by the dedicated plant security force for communications in and around the plant through two UHF radio repeaters. A fixed radio link is available from the Plant Security to the Darlington County Sheriff's Dispatch Center.
Corporate Telephone Communications Systems (Voicenet) was removed from communication methods table for communicating with OROs and NRC. Corporate Telephone Communications Systems (Voicenet) was an internal telephone network system used to call intrafacility with a 5 digit extension, and was not capable for use outside of the company. Corporate Telephone Communications Systems (Voicenet) was removed with the new AVAYA telephone system and is no longer applicable. The primary means of notification with OROs is DEMNET and backup communication methods are PBX, Business Line, Cellular Telephone, and Satellite Telephones. The primary means of communication with the NRC is PBX and backup communications methods are Business Line, Cellular Phone, and Satellite Phone This change aligns with the common E-Plan and does not change the intent or how the EAL determined.
Palmetto 800 Transceivers removed from communication methods table. The Palmetto 800 system was added for use during a B.5.B type event and was not intended for use to contact the OROs but rather for contacting Law Enforcement and other emergency services. Based on not meeting the intent of offsite communication, this method of communication is being removed. The primary means of notification with OROs is DEMNET and backup communication methods are PBX, Business Line, Cellular Telephone, and Satellite Telephones. Offsite Law Enforcement and other emergency services can still be contacted using this system, PBX, Cellular Phone, Satellite Phone, Business Line or Plant Security Radio Control Station.
This change aligns with the common E-Plan and does not change the intent or how the EAL determined.
o From UFSAR chapter 9.5.2: Palmetto 800 Statewide radio network, enables Robinson personnel to communicate with various Law Enforcement and Emergency agencies via the Palmetto 800 Statewide radio network. Palmetto 800 is a statewide shared public safety communication network that includes common operability between state, local, and federal

U.S. Nuclear Regulatory Commission                                                    Attachment 3, Page 28 Serial: RA-22-0037 safety agencies as well as with major utility companies and healthcare providers in the state.
The proposed changes add clarifying information and align terminology so that communications methods are not duplicated or called upon that could not be used to contact state, local or federal partners. The proposed changes are intended to minimize the potential for an under or overclassification of equipment failure Proposed changes 13 - 15 and 29 - 31 add clarification for EALs CA6.1 and SA9.1:
Changes 13 and 29 add a sentence to the beginning of the basis section to clarify that the EAL is based off the significance of the event that caused damage. This adds clarification to the reader that the event needs to be of significant size to cause damage to 2 trains of the same safety system or damage to a common component affecting 2 trains of the same safety system the common component supports.
Changes 14 and 30 add a table of nonspecific equipment scenarios. This table is designed to provide a reference of different examples of event significance to aid in classification. The table adds clarifying examples of what does and what does not meet Alert classifications to ensure predictable accurate classification.
Changes 15 and 31 added bolding to existing text. The proposed changes aid in clarifying information that is intended to minimize the potential for an under or overclassification of equipment failure. The proposed clarifications will reduce the potential of declaring an Alert when events are in progress that do not involve an actual or potential substantial degradation of the level of safety of the plant, i.e., does not cause significant concern with shutting down or cooling down the plant.
Adding additional clarification for these EALs is consistent with the NEI submitted FAQ 2016-002 for Visible Damage approved in Duke Energy EALs as referenced in Part II, and NEI Submitted FAQ 2018 -04 that adds additional clarification to FAQ 2016-002. As required by 10 CFR 50.47(b)(4), the proposed change complies with the regulations because a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee.
Proposed changes 17 - 18 updates basis discussions based on implementation of NFPA 805:
The proposed changes update information based on RNPs transition from 10 CFR part 50.48 Appendix R to NFPA 805, as a standard for its fire protection program, and the elimination of Self-induced Station Blackout (SISBO) strategy for a fire event (Engineering Change 400530) per Amendment Request RNP-RA/13-0090. The proposed changes address the adoption of NFPA 805 at Robinson Nuclear Plant.
Adoption of NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition in accordance with 10 CFR 50.48(c) serves as the method of satisfying 10 CFR 50.48(a) and General Design Criterion 3. Prior to adoption of NFPA 805, General Design Criterion 3, "Fire Protection" of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Licensing of Production and Utilization Facilities," was followed in the design of safety and non-safety related structures, systems, and components, as required by 10 CFR 50.48(a).
NFPA 805 does not supersede the requirements of GDC 3, 10 CFR 50.48(a), or 10 CFR 50.48(t). Those regulatory requirements continue to apply. However, under NFPA 805, the means by which GDC 3 or 10 CFR 50.48(a) requirements are met may be different than under 10 CFR 50.48(b). Specifically, whereas GDC 3 refers to SSCs important to safety, NFPA 805 identifies fire protection systems and features required to meet the Chapter I performance criteria through the methodology in Chapter 4 of NFPA 805. Also, under NFPA 805, the 10 CFR 50.48(a)(2)(iii) requirement to limit fire damage to SSCs important to safety so that the capability to safely shut down the plant is satisfied by meeting the performance criteria in Section 1.5.1 of NFPA 805.
The proposed changes assure the current Fire Protection Program is considered for EALs HU4.1 and HU4.2.

U.S. Nuclear Regulatory Commission                                                 Attachment 3, Page 29 Serial: RA-22-0037 The proposed changes do not change the logic of an EAL that would result in a particular event not being declared when the declaration would have occurred before the change. Additionally, the proposed changes do not change the language of a particular EAL that would render the classification logic unclear and could potentially result in an inaccurate classification.
The proposed changes improve the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application reference in Part II. Implementation of the clarifications will maintain the accuracy and timeliness of a classification following a hazardous event affecting a safety system.
The meaning or intent of the basis of the approved EALs are unchanged.
The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the events would NOT be different from that approved by the NRC. Implementation of the clarifications will maintain the accuracy and timeliness of a classification following a hazardous event affecting a safety system. The meaning or intent of the basis of the approved EAL is unchanged. The proposed changes will not result in the EALs being classified at a greater or less frequency. As required by 10 CFR 50.47(b)(4), the proposed change complies with the regulations because a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee.
Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.
Proposed change 3 updates the Operating Mode Applicability:
Hot Shutdown, Cold Shutdown, and Refueling where inadvertently given the wrong numerical equivalent in section 2.6 of the EAL basis. This change aligns those modes with the accepted definitions of the modes of applicability as found the RNP Technical Specifications and the UFSAR. All individual ICs have correct modes listed with the correct numerical values for each mode. This change does not cause a change to mode applicability of the EAL that excludes an operating mode in which the EAL should be applicable.
Proposed changes 10 - 11 and 26 - 27 update CU5.1 and SU7.1 communication methods:
The communications methods updated for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6 and lists communications methods as described in Common Emergency Plan. The proposed changes sustain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application reference in Part II. Implementation of the clarifications will maintain the accuracy and timeliness of a classification following a loss of all communications methods used to communicate on-site or with OROs or NRC. The meaning or intent of the basis of the approved EAL is unchanged.
Added acronym (PA) to Public Address System. This aligns with terminology used at the site with no change to intent or how the EAL determined.
Radios (on-site) added to table. This is a renaming of the previous Radio Transceivers for RNP and Vicinity and which are the designated ERO radios and radio transceivers used on-site. There is no change to the equipment or how the equipment is being utilized. Radios are an alternate means of communication between the MCR, TSC, and OSC. This communication type is included in the Duke Energy Emergency Plan as a means to communicate between emergency facilities onsite. This change does not change the intent or how the EAL determined.

U.S. Nuclear Regulatory Commission                                                 Attachment 3, Page 30 Serial: RA-22-0037 Spelled out acronym for DEMNET. Enhancement to understand meaning of DEMNET, this change does not change the intent or how the EAL is determined.
BellSouth removed from communication table and combined with ESSX into the new title Business Line. BellSouth(AT&T) is the dedicated copper line coming into the plant that ties in with the ESSX system which is separate from PBX to provide communication with on-site, offsite and NRC. The removal of the title Bellsouth does not change any systems or functions of the communication system.
Bellsouth was a duplicate naming of ESSX. This does not change the intent of the EAL as the removal of this title does not alter any functions or capabilities of the telephone system. RNP still maintains the ability to effectively maintain onsite, offsite and NRC communications.
Back-up Telephone System (ESSX) removed from communications table and replaced by title Business Line. ESSX utilizes dedicated AT&T lines and bypasses the PBX extensions in the emergency facilities. This system is independent of the operation of the plant PBX and with the dedicated copper line (AT&T line) can be used for onsite, offsite and NRC notifications. The removal of the title ESSX does not change any systems or functions of the communication system. ESSX was a duplicate naming of Bellsouth. This does not change the intent of the EAL as the removal of this title does not alter any functions or capabilities of the telephone system. RNP still maintains the ability to effectively maintain onsite, offsite and NRC communications.
NRC Emergency Telecommunications System (ETS) removed from communication methods table for communicating with OROs and NRC and combined with PBX. NRC ETS is supplied through site PBX. PBX is the primary means of communicating with the NRC. Extensions designated for NRC communications are in the emergency response facilities. This change aligns with terminology used at the site and fleet with no change to intent or how the EAL is determined.
Plant Security Radio Transceivers removed from communication methods table. These transceiver portables are used by the dedicated plant security force for communications in and around the plant through two UHF radio repeaters. The ERO does not use these radios for communications in the MCR, TSC, or OSC. The primary method of onsite communication is PBX with alternate means being onsite radios, PA system, and Business Line. This system is remaining in service to by used by Security personnel as their primary means of communication. Alternate forms of communication for Security is PA system or PBX System.
Plant Security Radio Control Station removed from communication methods table. This system is utilized for communicating with offsite Law Enforcement and is not used for notification to the OROs.
Based on not meeting the intent of offsite communication, this method of communication is being removed. The primary means of notification with OROs is DEMNET with alternate means being PBX, Business Line, Cellular Telephone, and Satellite Telephones. This change aligns with the common E-Plan and does not change the intent or how the EAL determined. Offsite Law Enforcement can still be contacted using this system, PBX, Cellular Phone, Satellite Phone, Business Line or Palmetto 800.
From UFSAR 9.5.2: plant security radio link station are used by the dedicated plant security force for communications in and around the plant through two UHF radio repeaters. A fixed radio link is available from the Plant Security to the Darlington County Sheriff's Dispatch Center.
Corporate Telephone Communications Systems (Voicenet) was removed from communication methods table for communicating with OROs and NRC. Corporate Telephone Communications Systems (Voicenet) was an internal telephone network system used to call intrafacility with a 5 digit extension, and was not capable for use outside of the company. Corporate Telephone Communications Systems (Voicenet) was removed with the new AVAYA telephone system and is no longer applicable.
The primary means of notification with OROs is DEMNET and backup communication methods are PBX, Business Line, Cellular Telephone, and Satellite Telephones. The primary means of communication with the NRC is PBX and backup communications methods are Business Line, Cellular Phone, and Satellite Phone This change aligns with the common E-Plan and does not change the intent or how the EAL determined.

U.S. Nuclear Regulatory Commission                                                    Attachment 3, Page 31 Serial: RA-22-0037 Palmetto 800 Transceivers removed from communication methods table. The Palmetto 800 system was added for use during a B.5.B type event and was not intended for use to contact the OROs but rather for contacting Law Enforcement and other emergency services. Based on not meeting the intent of offsite communication, this method of communication is being removed. The primary means of notification with OROs is DEMNET and backup communication methods are PBX, Business Line, Cellular Telephone, and Satellite Telephones. Offsite Law Enforcement and other emergency services can still be contacted using this system, PBX, Cellular Phone, Satellite Phone, Business Line or Plant Security Radio Control Station. This change aligns with the common E-Plan and does not change the intent or how the EAL determined.
o From UFSAR chapter 9.5.2: Palmetto 800 Statewide radio network, enables Robinson personnel to communicate with various Law Enforcement and Emergency agencies via the Palmetto 800 Statewide radio network. Palmetto 800 is a statewide shared public safety communication network that includes common operability between state, local, and federal safety agencies as well as with major utility companies and healthcare providers in the state.
The proposed changes add clarifying information that is intended to minimize the potential for an under or overclassification of equipment failure. The proposed clarifications will reduce the potential of declaring or not declaring an Unusual Event when events are in progress that do not involve an actual or potential substantial degradation of the level of safety of the plant, i.e., does not cause significant concern with shutting down or cooling down the plant.
Proposed changes 13 - 15 and 29 - 31 add clarification for EALs CA6.1 and SA9.1:
Changes 13 and 29 add a sentence to the beginning of the basis section to clarify that the EAL is based off the significance of the event that caused damage. This adds clarification to the reader that the event needs to be of significant size to cause damage to 2 trains of the same safety system or damage to a common component affecting 2 trains of the same safety system the common component supports.
Changes 14 and 30 add a table of nonspecific equipment scenarios. This table is designed to provide a reference of different examples of event significance to aid in classification. The table adds clarifying examples of what does and what does not meet Alert classifications to ensure predictable accurate classification.
Changes 15 and 31 added bolding to existing text. The proposed changes aid in clarifying information that is intended to minimize the potential for an under or overclassification of equipment failure. The proposed clarifications will reduce the potential of declaring an Alert when events are in progress that do not involve an actual or potential substantial degradation of the level of safety of the plant, i.e., does not cause significant concern with shutting down or cooling down the plant.
Adding additional clarification for these EALs is consistent with the NEI submitted FAQ 2016-002 for Visible Damage approved in Duke Energy EALs as referenced in Part II, and NEI Submitted FAQ 2018 -04 that adds additional clarification to FAQ 2016-002. As required by 10 CFR 50.47(b)(4), the proposed change complies with the regulations because a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee.
Proposed changes 17 - 18 updates basis discussions based on implementation of NFPA 805:
The proposed changes update information based on RNPs transition from 10 CFR part 50.48 Appendix R to NFPA 805, as a standard for its fire protection program, and the elimination of Self-induced Station Blackout (SISBO)

U.S. Nuclear Regulatory Commission                                                Attachment 3, Page 32 Serial: RA-22-0037 strategy for a fire event (Engineering Change 400530) per Amendment Request RNP-RA/13-0090. The proposed changes address the adoption of NFPA 805 at Robinson Nuclear Plant.
Adoption of NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants", 2001 Edition in accordance with 10 CFR 50.48(c) serves as the method of satisfying 10 CFR 50.48(a) and General Design Criterion 3. Prior to adoption of NFPA 805, General Design Criterion 3, "Fire Protection" of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Licensing of Production and Utilization Facilities," was followed in the design of safety and non-safety related structures, systems, and components, as required by 10 CFR 50.48(a).
NFPA 805 does not supersede the requirements of GDC 3, 10 CFR 50.48(a), or 10 CFR 50.48(t). Those regulatory requirements continue to apply. However, under NFPA 805, the means by which GDC 3 or 10 CFR 50.48(a) requirements are met may be different than under 10 CFR 50.48(b). Specifically, whereas GDC 3 refers to SSCs important to safety, NFPA 805 identifies fire protection systems and features required to meet the Chapter I performance criteria through the methodology in Chapter 4 of NFPA 805. Also, under NFPA 805, the 10 CFR 50.48(a)(2)(iii) requirement to limit fire damage to SSCs important to safety so that the capability to safely shut down the plant is satisfied by meeting the performance criteria in Section 1.5.1 of NFPA 805.
The proposed changes assure the current Fire Protection Program is considered for EALs HU4.1 and HU4.2.
The proposed changes do not change the logic of an EAL that would result in a particular event not being declared when the declaration would have occurred before the change. Additionally, the proposed changes do not change the language of a particular EAL that would render the classification logic unclear and could potentially result in an inaccurate classification.
The proposed changes improve the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application reference in Part II. Implementation of the clarifications will maintain the accuracy and timeliness of a classification following a hazardous event affecting a safety system.
The meaning or intent of the basis of the approved EALs are unchanged.
The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the events would NOT be different from that approved by the NRC. Implementation of the clarifications will maintain the accuracy and timeliness of a classification following a hazardous event affecting a safety system. The meaning or intent of the basis of the approved EAL is unchanged. The proposed changes will not result in the EALs being classified at a greater or less frequency. As required by 10 CFR 50.47(b)(4), the proposed change complies with the regulations because a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee.
The emergency plan function of Emergency Classification System is sustained because a standard scheme of emergency classification and action levels remains in use. The proposed changes do not reduce the effectiveness of the Duke Energy Common Emergency Plan or Site Annex because a standard scheme of emergency classification and action levels are in use. Emergencies will continue to be appropriately classified as warranted based on the proposed changes.
These changes continue to provide assurance that the Emergency Response Organization has 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.

U.S. Nuclear Regulatory Commission                                         Attachment 3, Page 33 Serial: RA-22-0037 These changes continue to meet NRC requirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E as well as the requirements of the Duke Energy Common Emergency Plan and Site Annex as written and approved.
Section XII: 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 reduction in            Yes effectiveness)?                                                                                             No
: 3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme?                          Yes No}}