ML16040A331

H.B. Robinson, Unit 2 - Transmittal of Emergency Procedure Revisions and 10CFR50.54(q) Summary of Analysis, Including Revision 26 to EPOSC-01, Revision 15 to EPOSC-02, Revision 16 to EPEOF-01, and Revision 19 to EPTSC-01

ML16040A331
Person / Time
Site:	Robinson
Issue date:	02/09/2016
From:	Hoffman D S Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/16-0007
Download: ML16040A331 (65)

Text

(-, DUKE ENERGY QD Serial: RNP-RA/16-0007 FEB 0 9 2016 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 TRANSMITTAL OF EMERGENCY PROCEDURE REVISIONS AND 10 CFR 50.54(g)

SUMMARY

OF ANALYSIS Ladies and Gentlemen:

David S. Hoffman H. B. Robinson Steam Electric Plant Unit 2 Director -Nuc Org Effectiveness Duke Energy Progress 3581 West Entrance Road Hartsville, SC 29550 0: 843 857 5239 F: 843 8571319 David.Hoffman@duke-energy.com 10 CFR 50, Appendix E In accordance with 1 O CFR 50.4(b)(5) and Appendix E to 1 O CFR 50, Duke Energy Progress, Inc. is transmitting revisions to the H.B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, Emergency Implementing Procedures.

A description of the procedure changes are provided on the "Summary of Changes" page included within each emergency procedure.

Please replace the superseded procedures with the enclosed revisions.

The procedure revisions and effective dates are listed in Attachment I to this letter. In accordance with 1 O CFR 50.54(q)(5), Attachments II and Ill include a summary of the analysis associated with the procedure changes provided in Attachment I. This document contains no new Regulatory Commitments.

If you have any questions concerning this matter, please contact Scott Connelly, Acting Nuclear Regulatory Affairs at (843) 857-1569.

Sinc&vt lf--David S. Hoffman Director -Nuc Org Effectiveness DSH/cac United States Nuclear Regulatory Commission Serial: RNP-RA/16-0007 Page 2 of 2 Attachments:

I. Procedure Revisions and Effective Dates II. 50.54(q)(3)

Screen Ill. 50.54(q)(3)

Evaluation Enclosure c: NRC Regional Administrator, NRC, Region II NRC Resident Inspector, HBRSEP Ms. Martha Barillas, NRC Project Manager, NRR (w/o Enclosure)

United States Nuclear Regulatory Commission Attachment I to Serial: RNP-RA/16-0007 Page 1 of 1 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 Procedure Revisions and Effective Dates Procedure Revision No. EPOSC-01, "Operational Support Center Leader" 26 EPOSC-02, "Damage Control Team Leader 15 EPEOF-01, "Emergency Response Manager

16 EPTSC-01, "Site Emergency Coordinator

19 Effective Date 1/27/16 1/27/16 1/27/16 1/27/16 United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/16-0007 5 Pages (including cover page) H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 50.54(g}(3)

Screen

.. EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) 10 CFR 50.54(q) Screening Evaluation Form AD-EP-ALL-0602 Rev. O ATTACHMENT 4 Page 1of4 Screening and Evaluation Number Applicable Sites BNP D EREG #: 1991300 CNS D CR3 D HNP D MNS D SAD #: 1991294 ONS D RNP

• GO D Document and Revision EPEOF-01 Rev. 16 EPTSC-01 Rev. 19 EPOSC-01 Rev. 26 EPOSC-02 Rev. 15 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan): EPEOF-01 Rev. 16, Resgonse Manager

• Section 2.1, 2.2, 8.1 O: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: 0 Added step stating "Approve deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." 0 Added reference to AD-OP-ALL-1000, Conduct of Operations, and EPCLA-01, Emergency Control EPTSC-01 Rev. 19, Site Coordinator

• Section 8.8, Attachment 10.1 Step 11, 2.1: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: 0 Added step stating "Approve deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." 0 Added reference to AD-OP-ALL-1000 EPOSC-01 Rev. 26, Ogerational Suggort Center Leader

• Section 3.1.4, 8.3.13, Attachment 10.1 under Operation, 2.1, 2.2: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: 0 Added "Obtaining approval for deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." 0 Added "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation Attachment or EPCLA-01, Emergency Control." 0 Added "Obtain approval for deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." 0 Added reference to AD-OP-ALL-1000

& EPCLA-01

• * ' EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) Rev. 0 ATTACHMENT 4 Page 2 of 4 10 CFR 50.54(q) Screening Evaluation Form EPOSC-02 Rev. 15, Damage Control Team Leader

• Section 8.9, 2.1, 2.2: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: 0 Revised "unless deviations are authorized" to "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD-OP-ALL-1000 , Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment or EPCLA-01 , Emergency Control." 0 Added reference to AD-OP-ALL-1000

& EPCLA-01 Part II. Activity Previously Reviewed?

Yes 10 No I* Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or 10 CFR 50.54(q) Continue to Alert and Notification System Design Report? Effectiveness Attachment 4, Evaluation is not 10CFR If yes , identify bounding source document number or approval reference and required.

Enter 50.54(q) ensure the basis for concluding the source document fully bounds the proposed justification Screening change is documented below: below and Evaluation complete Form, Part Ill Justification

Attachment 4, N/A Part V. Bounding document attached (optional) lo Part Ill. Editorial Change Yes ID No I* Is this activity an editorial or typographical change only, such as formatting, 10 CFR 50.54(q) Continue to paragraph numbering, spelling, or punctuation that does not change intent? Effect i veness Attachment 4 , Evaluation is not Part IV and Justification:

required. Enter address non justification and editorial complete changes Attachment 4, Part V & VI. Part IV. Emergency Planning Element and Function Screen (Reference Attachment 1, Considerations for Addressing Screening Criteria)

Does this activity involve any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If answer is yes, then check box. 1 10 CFR 50.47(b)(1)

Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.

• 1b The response organization has the staff to respond and to augment staff on a continuing basis D (24-7 staffing) in accordance with the emergency plan. 2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that onshift emergency response responsibilities are staffed and assigned D 2b The process for timely augmentation of onshift staff is established and maintained. D 3 10 CFR 50.47(b)(3)

Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made. D 3b State and local staff can be accommodated at the EOF in accordance with the emergency plan. D (NA for CR3)

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) 10 CFR 50.54(q) Screening Evaluation Form AD-EP-ALL-0602 Rev. 0 ATTACHMENT 4 Page 3 of 4 Part IV. Emergency Planning Element and Function Screen (cont.) 4 10 CFR 50.47(b)(4)

Emergency Classification System 4a A standard scheme of emergency classification and action levels is in use. D (Requires final approval of Screen and Evaluation by EP CFAM.) 5 10 CFR 50.47(b)(5)

Notification Methods and Procedures 5a Procedures for notification of State and local governmental agencies are capable of initiating D notification of the declared emergency within 15 minutes (30 minutes for CR3) after declaration of an emergency and providing follow-up notification.

5b Administrative and physical means have been established for alerting and providing prompt instructions D to the public within the plume exposure pathway. (NA for CR3) Sc The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. (NA for CR3) 6 10 CFR 50.47(b)(6)

Emergency Communications 6a Systems are established for prompt communication among principal emergency response D organizations.

6b Systems are established for prompt communication to emergency response personnel.

D 7 10 CFR 50.47(b)(7)

Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within the D plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established.

D 8 10 CFR 50.47(b)(8)

Emergency Facilities and Equipment Ba Adequate facilities are maintained to support emergency response.

D 8b Adequate equipment is maintained to support emergency response.

D 9 10 CFR 50.4 7(b )(9) Accident Assessment 9a Methods, systems, and equipment for assessment of radioactive releases are in use. D 10 10 CFR 50.47(b)(10)

Protective Response 10a A range of public PARs is available for implementation during emergencies. (NA for CR3) D 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available D to support the formulation of PARs and have been provided to State and local governmental authorities. (NA for CR3) 10c A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events. 10d Kl is available for implementation as a protective action recommendation in those jurisdictions that D chose to provide Kl to the public. 11 10 CFR 50.47(b)(11)

Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.

D 12 10 CFR 50.47(b)(12)

Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.

D 13 10 CFR 50.47(b)(13)

Recovery Planning and Post-accident Operations 13a Plans for recovery and reentry are developed.

D EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. O ATTACHMENT 4 Page 4 of 4 10 CFR 50.54(q) Screening Evaluation Form Part IV. Emergency Planning Element and Function Screen (cont.) 14 10 CFR 50.47(b)(14)

Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program areas) D is established. 14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain , D and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.

14c Identified weaknesses are corrected.

D 15 10 CFR 50.47(b)(15)

Emergency Response Training 1 Sa Training is provided to emergency responders. D 16 10 CFR 50.47(b)(16)

Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established. D 16b Planners responsible for emergency plan development and maintenance are properly trained. D PART IV. Conclusion If no Part IV criteria are checked, a 10 CFR 50.54(q) Effectiveness Evaluation is not required, then complete Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part V. Go to Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part VI for instructions describing the NRC required 30 day submittal.

D If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete

• Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q) Effectiveness Evaluation.

Shaded block requires final approval of Screen and Evaluation by EP CFAM. Part V. Signatures:

Prepare Name (Print): Reviewer Name ( t):

S'. bowl', n Approver Part VI. NRC Emergency Plan and Implementing Procedure Submittal Actions Create two EREG General Assig n ments. One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q), to Licensing.

One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect. QA RECORD *

• United States Nuclear Regulatory Commission Attachment Ill to Serial: RNP-RA/16-0007 6 Pages (including cover page) H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 50.54(g)(3)

Evaluation

.J EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) 10 CFR 50.54(q) Effectiveness Evaluation Form Screening and Evaluation Number EREG #: 1991300 5AD #: 1991294 AD-EP-ALL-0602 Rev. 0 ATTACHMENT 5 Page 1 of 5 Applicable Sites BNP D CNS D CR3 D HNP D MNS D ONS D RNP

• GO D Document and Revision EPEOF-01 Rev. 16 EPTSC-01 Rev. 19 EPOSC-01 Rev. 26 EPOSC-02 Rev. 15 Part I. Description of Proposed Change: EPEOF-01 Rev. 16, Emergency Response Manager

• Section 2.1, 2.2 , 8.10: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: o Added step stating "Approve deviations from normal work processes as appropriate per ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." o Added reference to AD-OP-ALL-1000, Conduct of Operations, and EPCLA-01, Emergency Control EPTSC-01 Rev. 19, Site Emergency Coordinator

• Section 8.8, Attachment 10.1 Step 11, 2.1: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: o Added step stating "Approve deviations from normal work processes as appropriate per ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." o Added reference to AD-OP-ALL-1000 EPOSC-01 Rev. 26. Operational Support Center Leader

• Section 3.1.4, 8.3.13, Attachment 10.1 under Operation, 2.1, 2.2: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: o Added "Obtaining approval for deviations from normal work processes as appropriate per ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." o Added "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation Attachment or EPCLA-01, Emergency Control." a Added "Obtain approval for deviations from normal work processes as appropriate per ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." o Added reference to AD-OP-ALL-1000

& EPCLA-01

_, EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) 10 CFR 50.54(q) Effectiveness Evaluation Form AD-EP-ALL-0602 Rev.a ATTACHMENT 5 Page 2 of 5 EPOSC-02 Rev. 15. Damage Control Team Leader

• Section 8.9, 2.1, 2.2:

Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: a Revised "unless deviations are authorized" to "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment or EPCLA-01, Emergency Control." o Added reference to AD-OP-ALL-1000

& EPCLA-01 Attachment 6, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is attached (required for IC or EAL change) Part II. Description and Review of Licensing Basis Affected by the Proposed Change: Yes D No

• The proposed changes listed in EPEOF-01 Rev. 16, Emergency Response Manager; EPTSC-01 Rev. 19, Site Emergency Coordinator; EPOSC-01 Rev. 26, Operational Support Center Leader; EPOSC-02 Rev. 15 and Damage Control Team Leader included a review of the following RNP emergency plan licensing basis documents:

• PLP-007, Robinson Emergency Response Plan (Revision 0, dated 1982)

• PLP-007, Robinson Emergency Plan (Revision

85)

• NRG Correspondence

-May 11, 1983:

Subject:

NUREG-0737 Item 111.A.2.1

-Emergency Plan Upgrade To Meet Rule (H.B. Robinson Unit 2)

• H.B. Robinson Steam Electric Plant, Unit No. 2, Updated Final Safety Analysis Report, Chapter 13.3 This review concludes that the proposed changes in the procedures listed above continue to meet the intent and requirements of the documents listed above. Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments. If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50. 54( q): The proposed changes to the procedures listed in Part I of this evaluation are associated with enhancing the guidance to Emergency Response Organization leaders to respond quickly and efficiently to events that may occur during an emergency. AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment and EPCLA-01, Emergency Control currently provide guidance on when deviation from normal work processes may occur. These Emergency Preparedness procedures incorporate that guidance by establishing clear directions to facility leaders to refer to AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment or EPCLA-01, Emergency Control if deviations from the work process become necessary in an emergency event. By using a process that is currently in place at RNP and familiar to site personnel, the responsibility for emergency response is assigned and familiar to site personnel.

Planning Standard 10 CFR 50.47(b)(1) continues to be met with these proposed changes. The definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization is strengthened by including the standard process for deviations from the normal work process into emergency procedures.

10 CFR 50 Appendix E, Section IV.A.2 continues to be met as these proposed changes incorporate procedural guidance for deviations from the normal work process into emergency response procedures.

' EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) 10 CFR 50.54(q) Effectiveness Evaluation Form AD-EP-ALL-0602 Rev. 0 ATTACHMENT 5 Page 3 of 5 Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen): 50.47(b)(1), Emergency Response Responsibility PLANNING STANDARD:

Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis. PS FUNCTIONS:

1. Responsibility for emergency response is assigned.

2. The response organization has the staff to respond and augment on a continuing basis (24/7 staffing) in accordance with the E-plan. Supporting Requirements:

10 CFR Part 50, Appendix E, Sections IV.A.2 A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency.

Specifically, the following shall be included:

2. A description of the onsite emergency response organization with a detailed discussion of: a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

b. Plant staff emergency assignments;

c. Authorities, responsibilities, and duties on an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

Elements

• Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organizations within the Emergency Planning Zones have been assigned.

• The emergency responsibilities of the various supporting organizations have been specifically established.

• Each organization and sub-organization having an operational role shall specify its concept of operations, and its relationship to the total effort.

• Each organization shall identify a specific individual by title who shall be in charge of the emergency response Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

The proposed changes to the procedures listed in Part I of this evaluation are associated with enhancing the guidance to Emergency Response Organization leaders to respond quickly and efficiently to events that may occur during an emergency. AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment and EPCLA-01, Emergency Control currently provide guidance on when deviation from normal work processes may occur during emergency activities.

The use of the procedures ensures a smooth transition when the Emergency Plan is activated and actions must be taken quickly to mitii:iate the event. Individuals that will need to use the process to support deviations from the normal work

. EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) Rev. 0 A TT AC HM ENT 5 Page 4 of 5 10 CFR 50.54(q) Effectiveness Evaluation Form process now have the associated guidance referenced in their emergency procedures.

This ensures RNP is able to carry out critical actions (emergency response functions) in a timely manner. This proposed change integrates procedures used in normal modes of operation into the emergency response procedures.

This continues to meet the guidance provided in PLP-007, Robinson Emergency Plan Section 5.3, Emergency Response Organization. In addition, the guidance in Section 5.4, Emergency Measures is also maintained by ensuring personnel will be directed to take actions to mitigate plant/equipment damage and minimize impact to the general public by utilizing established work processes. As stated above, the proposed changes to the procedures listed in Part I do not reduce the effectiveness of PLP-007. Instead, the proposed changes described in this revision continue to provide additional assurance that the ERO 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 . Effective use of this procedure helps ensure emergency response capabilities described in PLP-007 are adequately maintained and demonstrated.

The proposed changes in EPEOF-01 Rev. 16, Emergency Response Manager; EPTSC-01 Rev. 19, Site Emergency Coordinator; EPOSC-01 Rev. 26, Operational Support Center Leader and EPOSC-02 Rev. 15, Damage Control Team Leader, enhance ERO readiness to support a classified emergency, resulting in an improved capability to ensure health and safety of plant personnel and the general public. PLP-007 Section 5.3, Emergency Response Organization and Section 5.4, Emergency Measures, provide guidance to emergency response personnel on the actions to take when deviations from normal work processes are needed. These procedures incorporate the guidance of PLP-007 into RNP implementing procedures. These proposed changes continue to meet the guidance provided in PLP-007 with no reduction in effectiveness.

Part VI. Evaluation Conclusion.

Answer the following questions about the proposed change. 1 Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? Yes* NoD 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes* NoD reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes* NoD 4 Choose one of the following conclusions:

a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current

• Emergency Action Level (EAL) scheme. Therefore, the activity can be implemented without prior NRC approval.

b The activity does not continue to comply with the requirements of 10 CFR 50.47(b) or 10 CFR 50 Appendix E or the activity does constitute a reduction in effectiveness or EAL scheme change. D Therefore, the activity cannot be implemented without prior NRC approval.

.. . : EMERGENCY PLAN CHANGE SCREENING AND *EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) 10 CFR 50.54(q) Effectiveness Evaluation Form Part VII. Disposition of Proposed Change Requiring Prior NRC Approval AD-EP-ALL-0602 Rev. 0 ATTACHMENT 5 Page 5 of 5 Will the proposed change determined to require prior NRC approval be either revised or Yes D No D rejected?

If No, then initiate a License Amendment Request in accordance 10 CFR 50.90 and AD-LS-ALL-0002, Regulatory Correspondence, and include the tracking number: Part VIII. Signatures

EP CFAM Final Approval is required for changes affecting risk significant planning standard 10 CFR 50.47(b)(4).

Approver (CFAM, as re uired) Name (Print): t0 If the proposed activity is a change to the E-Plan or implementing procedures, then create two EREG General Assignments. Date: l)2-b/Jb Date:

• One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR

• 50.54(q), to Licensing.

• One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the

• change is put in effect. QA RECORD EPOSC-01 Rev. 26 Page 1 of 18 I Information Use H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PLANT OPERATING MANUAL VOLUME 2 PART 5 EPOSC-01 OPERATIONAL SUPPORT CENTER LEADER REVISION 26

EPOSC-01 Rev. 26 Page 2 of 18

SUMMARY

OF CHANGES PRR 1990343 , NCR 1988798 EPOSC-01 Revision 2 6 SECTI ON REVISION COMMENTS 3.1.4 , 8.3.13, Attachment 10.1 under Operation ,

2.1, 2.2 Clarified approval of deviation from normal work processes by referring to deviation process described in AD

-OP-ALL-1000 and EPCLA-01 as follows: Added "Obtaining approval for deviations from normal work processes as appropriate per AD

-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes /

Requirements Documentation attachment or EPCLA

-01, Emergency Control." Added "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD

-OP-ALL-1000 , Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation Attachment or EPCLA-01, Emergency Control

." Added "Obtain approval for deviations from normal work processes as appropriate per AD

-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes /

Requirements Documentation attachment or EPCLA

-01, Emergency Control." Added reference to AD

-OP-ALL-1000 & EPCLA-01 Justification: NCR 1988798 identified INPO gap focus area related to deviations from normal work processes.

EPOSC-01 Rev. 26 Page 3 of 18 TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE ............................................................................................................

4

2.0 REFERENCES

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

4 3.0 RESPONSIBILITIES

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

4 4.0 PREREQUISITES ................................................................................................

5 5.0 PRECAUTIONS AND LIMITATIONS

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

5 6.0 SPECIAL TOOLS AND EQUIPMENT

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

5 7.0 ACCEPTANCE CRITERIA

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

5 8.0 INSTRUCTIONS

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

6 9.0 RECORDS..........................................................................................................

10 10.0 ATTACHMENTS

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

10 10.1 OSC LEADER CHECKLIST

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

11 10.2 OSC LEADER INITIAL BRIEFING CHECKLIST

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

14 10.3 OSC LEADER SUBSEQUENT BRIEFING CHECKLIST

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

16 10.4 BACKUP OSC SETUP

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

17 EPOSC-01 Rev. 26 Page 4 of 18 1.0 PURPOSE 1.1 The purpose of this procedure is to describe the duties and responsibilities of the Operational Support Center (OSC) Leader. Attachments to this procedure describe the organization, activation, and operation of the OSC.

2.0 REFERENCES

2.1 AD-OP-ALL-1000, Conduct of Operations 2.2 EPCLA-01, Emergency Control 2.3 EPOSC-00, Activation and Operation of the Operational Support Center 2.4 EPNOT-01, CR/EOF Emergency Communicator 2.5 EPEOF-03, Administrative and Logistics Manager 2.6 EPOSC-03, Environmental and Radiation Control Team 2.7 IER L2 11-39, Rec. 3.c., Develop a process for filling vacant ERO positions with other plant staff members 2.8 EPSPA-03, Administration of Potassium Iodine

3.0 RESPONSIBILITIES

NOTE: In order to augment the staff of the Control Room as soon as practical, activation of the OSC is permitted with partial staffing. 3.1 The OSC Leader is responsible to the Emergency Repair Director (ERD) when the Technical Support Center (TSC) is activated. The OSC Leader is responsible to the Control Room Site Emergency Coordinator (CR-SEC) prior to the activation of the TSC. General responsibilities include:

3.1.1 Activation of the OSC at an Alert OR higher emergency classification OR at a lower level, if directed by the SEC.

3.1.2 Coordinating the activities of the OSC AND supporting its assigned personnel.

3.1.3 Coordinating the distribution of Potassium Iodide (KI) to onsite personnel within the Protected Area in accordance with EPSPA

-03, Administration of Potassium Iodide.

EPOSC-01 Rev. 26 Page 5 of 18 3.1.4 Obtaining approval for deviations from normal work processes from the Shift Manager, SEC or ERM per AD

-OP-ALL-1000, Deviation from Normal Work Processes/Requirements Documentation Attachment or EPCLA-01, Emergency Control.

4.0 PREREQUISITES

4.1 Activation of the OSC will be done at all Alert or higher emergency classifications OR at the discretion of the Site Emergency Coordinator (SEC), as needed to support site emergencies or events.

4.2 All off-duty responders called in to support the facility activation shall make a Fitness-For-Duty affirmation prior to entering the Protected Area.

4.3 If electronic logging is unavailable, then paper logs and paper/whiteboard status board(s) shall be maintained.

5.0 PRECAUTIONS AND LIMITATIONS 5.1 None 6.0 SPECIAL TOOLS AND EQUIPMENT 6.1 Equipment used to support OSC activities is listed in the body of the procedure, as applicable.

7.0 ACCEPTANCE CRITERIA 7.1 None EPOSC-01 Rev. 26 Page 6 of 18 8.0 INSTRUCTIONS NOTE: Activation of emergency facilities may be delayed due to adverse site conditions (e.g., hostile action). If delayed, activation must be completed as promptly as is practical once the site is secure as directed by site Security. 8.1 Refer to Attachment 10.1, OSC Leader Checklist, for a summary of responsibilities/tasks associated with ERO position (attachment information does not replace the procedure steps).

NOTE: Initial actions of this procedure can be implemented by the Damage Control Team Leader (DCTL) in the absence of the OSC Team Leader.

8.2 The OSC staff will be called out, IF required, at an Alert OR higher emergency classification , OR at a lower level, if directed by the SEC. NOTE: The actions in Step 8.2 may be performed at any time.

8.3 Upon reporting to the OSC, the OSC Leader shall:

8.3.1 ESTABLISH communications with the Control Room OR the Emergency Repair Director (ERD), IF the TSC is activated, AND GIVE the status of OSC augmentation.

1. USE the OSC Tag Board AND OSC Personnel Roster in EP O SC-00, Activation and Operation of the Operational Suppor t Center, for tracking OSC positions being filled.

2. REQUEST plant status AND discuss any repair missions underway OR needed. 8.3.2 PERFORM initial OSC briefing, using Attachment 10.2, OSC Leader Initial Briefing Checklist.

EPOSC-01 Rev. 26 Page 7 of 18 8.3.3 ORDER all non-emergency response personnel to leave the staffing areas of the OSC.

8.3.4 ENSURE accountability is initiated AND CALL Emergency Security Team Leader (ESTL) WHEN complete. 1. ASSIGN the Security Watchperson to establish AND maintain OSC access control. 2. A radiological control point may be set up at the OSC Entrance/Exit point, IF the OSC leader deems it appropriate.

3. Admin supplies AND equipment (including phone s) for this purpose are located in the OSC supply cabinet. NOTE: The Tag Board describes the recommended OSC staff. Other personnel may be assigned to the facility, as needed. Not all personnel assigned to the OSC are required to have a tag.

IF the emergency can be handled with less than the recommended staff, the OSC can be activated.

8.3.5 USE the Tag Board located at the OSC entrance AND t he OSC Personnel Roster from EPOSC

-00 , Activation and Operation of the Operational Support Center, to ensure that the OSC organization is adequately staffed. 1. EPOSC-00 describes the OSC organization structure AND staffing information. 8.3.6 ENSURE facility is set-up, in accordance with EPOSC

-00. 1. Communication lines should be checked with the TSC AND the Control Room.

2. Communications system information is contained in EPNOT

-01 , CR/EOF Emergency Communicator, OR the ERO Phone Book.

8.3.7 DETERMINE the need for additional equipment, supplies, AND manpower. 1. Requests should be made through the ERD to the A&LM. 8.3.8 ENSURE the appropriate attachment in EPEOF-03, Administrative and Logistics Manager, is completed for OSC Extended Schedules AND provided to the A&LM within two hour s after facility activation.

EPOSC-01 Rev. 26 Page 8 of 18 8.3.9 Upon reaching the activation staffing level established in EPOSC

-00, the OSC Leader (OR in his absence, the DCTL) SHALL DECLARE the facility activated.

1. This SHALL be done by an announcement in the facility AND by a call to the E RD. 2. A final personnel accountability check will be made AND the ESTL SHALL be informed of the result.

8.3.10 OBTAIN an initial briefing on plant status and emergency operations from the Control Room or ERD, if the TSC has been activated.

8.3.11 ADVISE OSC staff regardin g: 1. Eating AND drinking requirements.

2. Use of 3-way communications

3. No talking over team members and restricted use of phones during briefs.

4. Ensure logs contain all details of key decisions and supporting information such that the current event and responses could be recreated from the ir logs. 5. Timely activation is required to support 75 minute limit.

8.3.12 The OSC Leader will control, direct, AND support assigned personnel as follows: 1. Upon notification of a mission from the ERD, ENSURE that the personnel AND resources necessary for the mission are available.

2. Whenever it is determined that an OSC mission is not practical OR feasible during the course of a declared emergency, ADVISE the ERD for appropriate action.

EPOSC-01 Rev. 26 Page 9 of 18 8.3.13 ENSURE radiological briefings are conducted for activities dispatched from the OS C, unless an approved deviation exists from the Shift Manager, SEC or ERM per AD

-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment or EPCLA-01, Emergency Control. REFER TO EPOSC-03, Environmental and Radiation Control Team, for guidance

. (AR #47564, AR #43529)

1. IF a medical emergency exists, verbal authorization may be given for team dispatch as long as the information is documented in the OSC Leader log.

8.3.14 ENSURE both security AND radiological updates are available for all briefings and activities. This information should be provided by the R C lead person AND IF available, to the Damage Control Team Leader s , E&C lead person, AND the Work Control SRO.

8.3.15 CONDUCT frequent status update briefings with OSC staff personnel using Attachment 10.3, OSC Leader Subsequent Briefing Checklist.

8.3.16 INFORM the ERD of the status of missions/teams, emphasizing time of dispatch and mission status at a frequency consistent with the timing of CR/TSC/EOF joint briefings. 8.3.17 DIRECT the RC personnel to establish AND monitor habitability in the OSC. 8.3.18 CONSULT the Site Industrial Safety Representative, Chemistry personnel , OR other industry/emergency response personnel to assist with determining the appropriate protective actions in the event of a chemical/toxic hazard.

1. IF deemed necessary, take steps to secure ventilation. (AR #28241) 8.4 IF adverse environmental conditions dictate, THEN move the OSC, in accordance with Attachment 10.

4, Backup OSC Setup.

8.4.1 Operations personnel will report to the Control Room, IF conditions permit. 8.4.2 Consider evacuation, IF the actual OR anticipated total accumulated dose exceeds 1000 mR em. 8.4.3 The recommendation to evacuate the OSC will be made in conjunction with the ERD AND the Radiological Control Director (RCD) in the TSC, OR with the SEC. 1. The SEC will approve OSC evacuations AND relocation of the OSC.

EPOSC-01 Rev. 26 Page 10 of 18 8.5 IF directed by Radiation Control Director (RCD), THEN COORDINATE the distribution of Potassium Iodide (KI) to onsite personnel within the Protected Area in accordance with EPSPA

-03, Administration of Potassium Iodide.

8.6 ENSURE proper use of communications equipment. IDENTIFY yourself by name AND the position you hold at the beginning of each transmission.

8.7 SUPPORT the requests from the Administrative and Logistics Manager (A&LM) AND ASSIGN individuals as needed, and if available, to support the response effort. 8.8 Upon instructions from the ERD or SEC, the OSC Leader SHALL deactivate the facility by: 8.8.1 Appropriately notifying all OSC personnel; AND 8.8.2 Assuring that all equipment AND supplies are returned to the appropriate storage location.

8.8.3 Reviewing OSC Leader Log for completeness AND accuracy. 8.9 Records generated during a declared emergency should be forwarded to the Emergency Preparedness Unit. 9.0 RECORDS 9.1 No records generated by this procedure.

10.0 ATTACHMENTS 10.1 OSC Leader Checklist 10.2 OSC Leader Initial Briefing Checklist 10.3 OSC Leader Subsequent Briefing Checklist 10.4 Backup OSC Setup

ATTACHMENT 10.1 Page 1 of 3 EPOSC-01 Rev. 26 Page 11 of 18 OSC LEADER CHECKLIST NOTE: Activation of emergency facilities may be delayed due to adverse site conditions (e.g., hostile action). If delayed, activation must be completed as promptly as is practical once the site is secure as directed by site Security. ACTIVATION

______ Upon your arrival, announce your presence in the OSC and establish communications with the Control Room, or the ERD if the TSC has been activated, giving status of augmentation and requesting mission information.

______ The OSC Leader, or in his absence, the Damage Control Leader shall declare the facility activated upon reaching the activation staffing level established in EPOSC

-00. ______ Ensure the site and OSC PA system volumes are at an appropriate leve l

to be heard in all areas of the OSC.

______ Order all non

-emergency response personnel to leave the OSC staffing areas and provide additional instructions, as warranted by emergency conditions.

______ Ensure set up of the OSC. The OSC boundaries may be modified to better facilitate OSC operations, at the discretion of the OSC Leader.

______ Ensure set up of telephones (phones are located in the OSC Briefing Room supply cabinet), placing them according to the marked numbers on the OSC Layout Diagram (phone jacks on walls are also marked).

______ Request OSC personnel to retrieve their TLD from the storage location.

______ Request OSC personnel to retrieve personal safety equipment including respirator glasses and shaving equipment.

______ Ensure status lights are appropriately illuminated.

______ Ensure accountability is initiated; call the Emergency Security Team Leader when complete.

______ Ensure that the Security Watchperson maintains access control and the OSC Personnel Roster.

______ Ensure that the facility is adequately staffed for the emergency at hand, (refer to the Tag Board AND OSC Personnel Roster in EPOSC-00). ______ Ensure that the facility is being monitored for radiological habitability.

ATTACHMENT 10.1 Page 2 of 3 EPOSC-01 Rev. 26 Page 12 of 18 OSC LEADER CHECKLIST

______ Make requests for additional personnel and equipment, as the situation dictates. ______ Conduct briefing for OSC personnel. Obtain initial plant status briefing from Control Room or ERD, if the TSC has been activated.

______ Instruct personnel to obtain their equipment and to prepare for missions (pre-stage a limited number of Maintenance and RC personnel with Protective Clothing on, to facilitate expediting public health and safety missions).

______ Verify clocks are synchronized to ERFIS/EDS/LAN and the TSC/EOF.

NOTE: When a position required for activation is not filled, a supervisory position may fulfill the responsibilities provided they are trained to perform the assigned activities of the position. [IER L2 11-39, Rec. 3.c.]

______ Declare the OSC activated. Announce activation and time activated using the OSC public address system. Report the same to the Emergency Repair Director or SEC.

(Time sensitive - 60 minutes after declaration of Alert or higher)

______ Provide OSC personnel with an update of plant conditions and any expectations for the facility or its personnel.

______ Announce to all personnel to place phone s on vibrate.

______ Announce to all personnel to ensure logs contain all details of key decisions and supporting information such that the current event and

responses could be recreated from their logs.

______ Ensure OSC Extended Schedules are completed and provided to the A&LM within two hour s of activation, in accordance with EPEOF

-03 , Administrative and Logistics Manager

. (Time sensitive)

OPERATION ______ Support overall emergency response efforts. ______ Obtain approval for deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachment or EPCLA-01, Emergency Control.

______ Ensure the OSC Leader Log, Tag, and OSC Status Board s are being maintained.

ATTACHMENT 10.1 Page 3 of 3 EPOSC-01 Rev. 26 Page 13 of 18 OSC LEADER CHECKLIST

______ Ensure Damage Control Teams are preparing for missions.

______ Ensure plant monitoring activities are conducted by RC and Chemistry personnel.

______ Conduct frequent briefings of OSC command personnel.

______ Participate in inter

-facility briefings with the EOF/TSC, as time permits.

______ Conduct facility briefing for all personnel and include:

Current emergency classification and the conditions for it Plant status Mission status Habitability status (condition of eating, smoking, or drinking)

Team specific briefings/debriefings will be given by the work group leaders/coordinators.

EVACUATION

______ Should it become necessary, evacuate the facility according to 0.

4, Backup OSC Setup.

DEACTIVATION

______ Notify OSC personnel that the OSC has been deactivated. This notification should also be communicated to individuals in the field.

______ Review OSC Log for completeness and accuracy.

______ Ensure all logs and Attachments are given to the Emergency Preparedness Staff.

______ Ensure proper decontamination is performed, if required.

______ Ensure all equipment and supplies are returned to the appropriate storage location. ______ Leave the area in a clean condition.

______ Give a final deactivation status report to the ERD or the SEC.

ATTACHMENT 10.2 Page 1 of 2 EPOSC-01 Rev. 26 Page 14 of 18 OSC LEADER INITIAL BRIEFING CHECKLIST

______ Attention all personnel in the OSC. My name is

____________________

and I am the OSC leader.

______ The Damage Control Team Electrical Leader is _____________________

______ The RC Coordinator is

________________________________________

______ The Damage Control Team Mechanical Leader is ___________________

______ Discuss the status of the plant and conditions leading to event.

______ Direct all personnel that are not involved in the event to exit the building and provide additional instructions, as warranted by emergency conditions.

______ Ensure you update the OSC Access Log to maintain accountability. (i.e., tag board, OSC Personnel Roster)

______ Personnel entering the OSC must use the East Entrance of the O&M building.

______ Observe all OSC boundaries.

______ Three-way communications is an absolute must.

______ Communication and coordination between workgroups is important to ensure personnel and plant safety.

______ Let me remind you that the public health and safety missions will be our first priority. We must prepare and be in the field in less than 30 minutes. Assist all teams, as they are preparing for a mission.

Team work is the key for successful missions.

______ It is important and required that each of you listen to any and all PA announcements. This will ensure all of us are receiving the latest information.

Continue to set up the OSC, per the applicable procedures.

______ Retrieve your TLD from the storage location.

______ Retrieve personal safety equipment, including respirator glasses and shaving equipment.

ATTACHMENT 10.2 Page 2 of 2 EPOSC-01 Rev. 26 Page 15 of 18 OSC LEADER INITIAL BRIEFING CHECKLIST

______ Place phones on vibrate.

______ Remember to use human factor tools such as STAR and the two

-minute rule.

ATTACHMENT 10.3 Page 1 of 1 EPOSC-01 Rev. 26 Page 16 of 18 OSC LEADER SUBSEQUENT BRIEFING CHECKLIST OSC Status Update Briefing Time _________________

______ Emergency classification level

__________________________________________

______ Plant conditions

__________________________________________

__________________________________________

__________________________________________

______ Special radiological __________________________________________

conditions / dose rate information

__________________________________________

__________________________________________

______ Major equipment out of service __________________________________________

__________________________________________

______ Damage Control missions in progress

_____________________________________

__________________________________________

______ OSC habitability

__________________________________________

______ Other Information

__________________________________________

__________________________________________

__________________________________________

ATTACHMENT 10.4 Page 1 of 2 EPOSC-01 Rev. 26 Page 17 of 18 BACKUP OSC SETUP The backup OSC is located in Building 410, EOF/TSC/Training Bldg.

Should adverse environmental conditions dictate, the primary OSC may be evacuated and relocated. The recommendation to evacuate the OSC will be made in conjunction with the ERD and RCD, or with the SEC, who will approve OSC evacuation and relocation.

The attached diagram provides the recommended layout for the Backup OSC.

Operations personnel will report to the Control Room or the Simulator Control Room (for drills/exercise).

Telephones for OSC personnel sent to the Back

-up OSC are stored in the closet in the Training Building Library.

The following equipment should be moved from the primary OSC to the Backup OSC:

OSC Personnel Roster Any Manual Logs Generated Radiation Work Permits Radios (Maintenance and RC)

Survey Instruments and supplies Other equipment, as deemed necessary for continued operation

ATTACHMENT 10.4 Page 2 of 2 EPOSC-01 Rev. 26 Page 18 of 18 BACKUP OSC SETUP

EPOSC-02 Rev. 15 Page 1 of 13 R Reference Use H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PLANT OPERATING MANUAL VOLUME 2 PART 5 EPOSC-02 DAMAGE CONTROL TEAM LEADER REVISION 15

EPOSC-02 Rev. 15 Page 2 of 13

SUMMARY

OF CHANGES PRR 1990346, NCR 1988798 EPOSC-02 Rev. 15 SECTION REVISION COMMENTS 8.9, 2.1, 2.2 Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: Revised "unless deviations are authorized" to "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD-OP-ALL-1000 , Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation

attachment or EPCLA-01, Emergency Control

." Added reference to AD

-OP-ALL-1000 & EPCLA-01 Justification: NCR 1988798 identified INPO gap focus area related to deviations from normal work processes.

EPOSC-02 Rev. 15 Page 3 of 13 TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE

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

4

2.0 REFERENCES

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

4 3.0 RESPONSIBILITIES

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

4 4.0 PREREQUISITES ....................................................................................................

4 5.0 PRECAUTIONS AND LIMITATIONS

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

4 6.0 SPECIAL TOOLS AND EQUIPMENT

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

4 7.0 ACCEPTANCE CRITERIA

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

4 8.0 INSTRUCTIONS

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

5 9.0 RECORDS

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

7 10.0 ATTACHMENTS

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

7 10.1 EMERGENCY DAMAGE CONTROL

SUMMARY

SHEET

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

8 10.2 EMERGENCY DAMAGE CONTROL PROCEDURE CHECKLIST

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

11 10.3 EQUIPMENT DAMAGE AND REPAIR LOG

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

12 10.4 DAMAGE CONTROL TEAM LEADER QUICK START GUIDE

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

13 EPOSC-02 Rev. 15 Page 4 of 13 1.0 PURPOSE The purpose of this procedure is to outline the duties and responsibilities of the Damage Control Team Leader (DCTL).

2.0 REFERENCES

2.1 EPCLA-01, Emergency Control 2.2 AD-OP-ALL-1000, Conduct of Operations 2.3 See EPOSC-00, Activation and Operation of the Operational Support Center

3.0 RESPONSIBILITIES

3.1 The DCTL, as requested/directed by the OSC Leader, shall be responsible for expediting and monitoring the planning, direction and execution of the efforts of the Damage Control Team to:

3.1.1 Assess the nature and extent of damage incurred.

3.1.2 Perform emergency repairs, if possible.

3.1.3 Perform other actions to reduce the effect of the emergency or to slow down a release when repair is not possible. 3.1.4 Install necessary emergency structures, systems, or components.

3.1.5 Use Attachment 10.4, Damage Control Team Leader Quick Start Guide, as needed, to meet position responsibilities. 3.1.6 Update WebEOC for damage control missions.

3.2 On an interim basis, assume the duties of the Operational Support Center Leader. 4.0 PREREQUISITES 4.1 See EPOSC-00 5.0 PRECAUTIONS AND LIMITATIONS 5.1 See EPOSC-00 6.0 SPECIAL TOOLS AND EQUIPMENT 6.1 See EPOSC-00 7.0 ACCEPTANCE CRITERIA 7.1 See EPOSC-00 EPOSC-02 Rev. 15 Page 5 of 13 8.0 INSTRUCTIONS NOTE: Attachment information does not replace the procedure steps. 8.1 Refer to Attachment 10.4, Damage Control Team Leader Quick Start Guide, for a summary of responsibilities/tasks associated with ERO position.

8.2 Prior to performing any mission, obtain the information specified on the WebEOC Damage Control Mission Status Board or Attachment 10.1, Emergency Damage Control Summary Sheet , i f WebEOC is unavailable.

8.2.1 Ensure that the work functions involved in the mission (i.e., Security, Mechanical/Electrical Planners, Operations, Radiation Control and Supervisor) are involved in the planning stage of the mission.

1. When selecting personnel for a mission, consider training, qualifications, skills, and number needed.

8.3 Review the mission information with the OSC Leader for authorization to proceed. 8.3.1 Document authorization using the WebEOC Damage Control Missio n Status board or Attachment 10.1, Emergen cy Damage Control Summary Sheet, i f WebEOC is unavailable.

8.4 Prior to the mission, perform the following actions:

8.4.1 Determine need for additional equipment, supplies, and manpower, and request same from the OSC Leader.

8.4.2 Acquire procedures, drawings, schematics, tools, Radiation Work Permits, and other documentation necessary for the team's specific mission. NOTE: A crash cart that can be fitted with SCBA bottles is available in the OSC Equipment Room. 8.4.3 Assure that all Damage Control Team members are properly outfitted with equipment necessary for their missions (e.g., dosimeters, hard hats, tools, respirators, etc.).

EPOSC-02 Rev. 15 Page 6 of 13 8.5 When approval to dispatch the team is received from the OSC Leader, execute the mission, in accordance with Attachment 10.2, Emergency Damage Control Procedure Checklist.

8.6 Select appropriate locations for side conversations and radio communications, e.g., outside the OSC Command Room, away from locations with a brief/debrief in progress.

8.7 Request status updates from the appropriate personnel on missions and inform the OSC Leader.

8.8 Use Attachment 10.3, Equipment Damage and Repair Log, if electronic means via WebEOC are not available to log activities associated with missions.

8.9 Follow the requirements outlined in the WebEOC Damage Control Mission Status Board or Attachment 10.1, Emergency Damage Control Summary Sheet , (including ingress and egress routes), unless an approved deviation exists from the Shift Manager, SEC or ERM per AD

-OP-ALL-1000 , Conduct of Operations , Deviation from Normal Work Processes/Requirements Documentation

attachment or EPCLA-01, Emergency Control. Authorizations for repair, maintenance, installation, and clean

-up deviations shall be received from the OSC Leader with the following exceptions, which are authorized by the Site Emergency Coordinator (SEC) and normally received from the ERD: 8.9.1 Life-saving actions (which are highest priority);

8.9.2 Immediate personnel health and safety precautions (e.g., fire, steam leak, etc.). 8.10 During or upon completion of the mission, as appropriate, complete WebEOC Damage Control Mission Status Board or Attachment 10.

1 , Emergency Damage Control Summary Sheet.

8.11 Conduct team debrief in OSC staffing/briefing location.

8.12 Inform the OSCL of the Damage Control Team debrief summary.

EPOSC-02 Rev. 15 Page 7 of 13 9.0 RECORDS 9.1 Records generated during a declared emergency should be forwarded to the Emergency Preparedness Unit.

10.0 ATTACHMENTS 10.1 Emergency Damage Control Summary Sheet 10.2 Emergency Damage Control Procedure Checklist 10.3 Equipment Damage and Repair Log 10.4 Damage Control Team Leader Quick Start Guide

ATTACHMENT 10.1 Page 1 of 3 EPOSC-02 Rev. 15 Page 8 of 13 EMERGENCY DAMAGE CONTROL

SUMMARY

SHEET Missio n # _________________________

Dispatch Time Out _________________________

Dispatch Time In ___________________________

(1) Mission (Condition/Problem): Public Health & Safety Missions must receive top priority to get mission in field within the target goal of 30 minutes.

(2) Is this a Public Health &

[ ] Yes [ ] No Safety Mission (Priority 1)? If yes, Notification Time

_________________________________________

(3) Mission Priority: _________________________________________

(4) Location: (5) Repairs: Highlight critical tasks and risks involved.

(6) Tools and Equipment Required (include communication methods and work coordination)

(7) Procedures:

(8) Field Team Leader:

ATTACHMENT 10.1 Page 2 of 3 EPOSC-02 Rev. 15 Page 9 of 13 EMERGENCY DAMAGE CONTROL

SUMMARY

SHEET (9) Other Team Members:

(Assign roles/responsibilities) (10) Radiation Control Team Member:

(11) Attachments Ingress/Egress Route & Alternate(s)

Maps: (12) Protective Gear/Dosimetry Required: (13) General: Emphasize safety, work quality, STAR and the importance of a questioning attitude.

Approved: RC Coordinator Damage Control (if available)

Team Leader OSC Leader

/

/

/

Initial Time Initial Time Initial Time ATTACHMENT 10.1 Page 3 of 3 EPOSC-02 Rev. 15 Page 10 of 13 EMERGENCY DAMAGE CONTROL

SUMMARY

SHEET Status Update:

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

ATTACHMENT 10.2 Page 1 of 1 EPOSC-02 Rev. 15 Page 11 of 13 EMERGENCY DAMAGE CONTROL PROCEDURE CHECKLIST

1. Verify all personnel have appropriate qualifications (respirator, security clearance, etc.). 2. Conduct mission - specific briefing.

3. Ensure that the following are completed by the appropriate team members: a. Check out equipment and establish communications.

b. Don appropriate gear.

c. Proceed to location in accordance with approved routes.

d. Perform task. Keep the OSC Leader advised of the status of the mission, as necessary, and if any difficulties encountered during the course of the mission. e. Return. 4. Debrief team and report results to the OSC Leader.

5. Document activities

.

ATTACHMENT 10.3 Page 1 of 1 EPOSC-02 Rev. 15 Page 12 of 13 EQUIPMENT DAMAGE AND REPAIR LOG NAME OF STRUCTURE, SYSTEM, OR COMPONENT LOCATION DAMAGE ASSESSMENT/REPAIRS DAMAGE CONTROL TEAM LEADER:

/

Initials Time ATTACHMENT 10.4 Page 1 of 1 EPOSC-02 Rev. 15 Page 13 of 13 DAMAGE CONTROL TEAM LEADER QUICK START GUIDE NOTE: Blanks are provided for place keeping only; logs are the official record. This is a summary level guide and does not replace the procedure steps.

1. Announce your presence and position in the Operational Support Center (OSC).

_____ 2. Notify the OSC Leader of readiness to activate the OSC.

_____ 3. Comple te the WebEOC Damage Control Mission Status Board or Attachment 10.1, Emergency Damage Control Summary Sheet, if WebEOC is unavailable, for outstanding missions.

_____ 4. Obtain authorization to proceed with mission.

_____ 5. Acquire necessary procedures, tools, and permits.

_____ 6. Ensure Damage Control Team is briefed and that they understand the mission.

_____ 7. Maintain awareness of mission status and report to the OSC Leader.

_____ 8. Upon completion of mission, debrief the team and complete necessary paper work. _____ 9. Refer to procedure steps.

_____

EPEOF-01 Rev. 16 Page 1 of 9 R Reference Use H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PLANT OPERATING MANUAL VOLUME 2 PART 5 EPEOF-01 EMERGENCY RESPONSE MANAGER REVISION 16

EPEOF-01 Rev. 16 Page 2 of 9

SUMMARY

OF CHANGES PRR 1990335 N CR 1988798 EPEOF-01 Revision 16 SECTION REVISION COMMENTS 2.1, 2.2 , 8.10 Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows:

Added step stating "Approve deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachment or EPCLA-01, Emergency Control

." Added reference to AD

-OP-ALL-1000, Conduct of Operations, and EPCLA-01, Emergency Control Justification: N CR 1988798 identified INPO gap focus area related to deviations from normal work processes.

EPEOF-01 Rev. 16 Page 3 of 9 TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE ............................................................................................................

4

2.0 REFERENCES

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

4 3.0 RESPONSIBILITIES

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

4 4.0 PREREQUISITES

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

4 5.0 PRECAUTIONS AND LIMITATIONS

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

4 6.0 SPECIAL TOOLS AND EQUIPMENT

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

4 7.0 ACCEPTANCE CRITERIA

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

4 8.0 INSTRUCTIONS

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

5 9.0 RECORDS............................................................................................................

8 10.0 ATTACHMENTS

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

8 10.1 EMERGENCY RESPONSE MANAGER (ERM) QUICK START GUIDE

........ 9 EPEOF-01 Rev. 16 Page 4 of 9 1.0 PURPOSE 1.1 This procedure describes the functional responsibilities and procedure steps for the Emergency Response Manager (ERM).

2.0 REFERENCES

2.1 AD-OP-ALL-1000, Conduct of Operations 2.2 EPCLA-01, Emergency Control 2.3 EPEOF-10, Recovery Manager and Recovery Operations 2.4 INPO Event Report L1 10, Nuclear Accident at the Fukushima Daiichi Nuclear Power Station, Recommendation 11b

3.0 RESPONSIBILITIES

3.1 Maintain overall command and control of the company

's response to the emergency, the Emergency Operations Facility (EOF), and the Remote Emergency Response Facility (RERF), when activated /utilized. 3.2 Maintain unilateral authority to commit company resources to the emergency response. 3.3 Maintain communications regarding the emergency with internal and external contacts. 3.4 Approve Emergency Notification Forms and press releases.

3.5 Recommend Protective Actions to the offsite agencies.

3.6 Manage the company

's offsite radiological monitoring and dose projection.

4.0 PREREQUISITES

4.1 As per EPEOF

-00, Activation and Operation of the Emergency Operations Facility 5.0 PRECAUTIONS AND LIMITATIONS 5.1 N/A 6.0 SPECIAL TOOLS AND EQUIPMENT 6.1 N/A 7.0 ACCEPTANCE CRITERIA 7.1 N/A EPEOF-01 Rev. 16 Page 5 of 9 8.0 INSTRUCTIONS NOTE: The non-delegable duties for notifying the off

-site authorities and formulating Protective Action Recommendations (PAR) transfer to the ERM upon activation of the EOF OR the Remote Emergency Response Facility. Refer to Attachment 10.1, Emergency Response Manager (ERM) Quick Start Guide, for a summary of responsibilities/tasks associated with ERO position (attachment information does not replace the procedure steps).

Activation of emergency facilities may be delayed due to adverse site conditions (e.g., hostile action). If delayed, activation must be completed as promptly as is practical once the site is secure as directed by site Security.

8.1 Upon notification of the declaration of an Unusual Event, the ERM shall INTERFACE with the Site Emergency Coordinator - CR (SEC-CR) to determine if the EOF shall be activated.

8.1.1 EOF activation is required at an Alert or higher emergency classification level, but will normally activate simultaneously with the Technical Support Center (TSC). 8.2 DETERMINE if conditions exist which would prevent immediate occupancy of the EOF. CONSULT the S tate/County Emergency Management Agencies for appropriate protective actions in the event of an off

-site chemical/toxic hazard. (NCR 00146425) 8.2.1 For sheltering or evacuation, refer to EPSPA

-01, "Evacuation and Accountability". (NCR 00146425) 8.3 DETERMINE if the Remote Emergency Response Facility (RERF) should be utilized to support the Control Room actions during the emergency , when the EOF is inaccessible. 8.3.1 Provide direction to all responders at the RERF.

EPEOF-01 Rev. 16 Page 6 of 9 8.4 DELEGATE TSC command and control as well as plant support / mitigation activities to the SEC, when the TSC minimum staffing positions are available.

8.5 The EOF shall relieve the Control Room (CR) of offsite communications, as soon as possible.

8.6 CONTACT the SEC- TSC and the SEC- CR and conduct a briefing for turnover. 8.6.1 UTILIZE EPCLA-01, Attachment 10.4, Turnover Checklist.

8.7 ACTIVATE the EOF when minimum staffing positions have been acquired, as established by EPEOF

-00, Attachment 10.3. 8.8 BRIEF the EOF staff regarding the information from the turnover, if not completed as a group.

8.9 PRIORITIZE

actions and strategies for the emergency response activities to ensure the health and safety of the general public. 8.10 APPROVE deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachme nt or EPCLA-01, Emergency Control. 8.11 ADVISE EOF staff regarding:

8.11.1 Eating AND drinking requirements 8.11.2 Use of 3-way communications 8.11.3 No talking over team members and restricted use of phones during briefs 8.11.4 Time activation is required to support 75 minute limit 8.12 SCHEDULE AND PROVIDE facility briefings. (30

-60 minute time frame) 8.13 APPROVE Emergency Notification Forms.

8.13.1 Notification is required within 15 minutes for initial classification and/or change in Protective Action Recommendations (PARs).

8.13.2 Follow-up notifications are required every 30

-60 minutes, or for any event which significantly impacts the health and safety of the public, such as the initiation or termination of a release or a significant change in plant conditions (either positive or negative), and when an emergency classification has not changed.

EPEOF-01 Rev. 16 Page 7 of 9 8.14 APPROVE press releases.

NOTE: During a Security Event, divulging information regarding the event may provide information to the adversaries and is undesirable to responding Law Enforcement Agencies.

8.14.1 Following the activation of the EOF, press releases should be available for issue to the news media after any of the following conditions, unless it is a Security related event: 1. A change of an emergency classification, OR 2. The initiation OR termination of a radiological release as a result of the emergency, OR 3. Other significant events provided to the offsite agencies via an Emergency Notification Form.

8.14.2 IF it is a security related event, THEN ENSURE that the lead responding law enforcement agency reviews and concurs with the press release.

8.15 CONFER with Joint Information Center (JIC) personnel upon their arrival at the JIC. Prior to JIC activation, the EOF Public Information Emergency Communicator (PI

-EC) will communicate with Corporate Communications concerning status of news releases and inquiries from the news media/general public. 8.16 REVIEW AND MAINTAIN awareness of dose projection and environmental field monitoring activities.

8.16.1 This includes administration of Potassium Iodide (KI) and expanded environmental monitoring.

8.17 FORMULATE AND COMMUNICATE protective action recommendations (PARs) to the state and counties. 8.18 ENSURE the Assistant to the Emergency Response Manager (AERM) is maintaining contact with Unit 1 AND the Darlington County Plant. Habitability screening may be necessary, if personnel remain in the area.

8.19 NOTIFY state AND counties to provide "heads

-up" information, as necessary. PROVIDE assistance, as requested. REFER to the Emergency Response Organization (ERO) Telephone Book for telephone numbers.

EPEOF-01 Rev. 16 Page 8 of 9 8.20 NOTIFY Corporate Senior Management periodically regarding plant status. Refer to the ERO Telephone Book for telephone numbers.

8.21 DETERMINE the need for AND request assistance from neighboring utilities.

NOTE: The INPO Duty Manager's contact information is located in the ERO Phone Book. The INPO Emergency Resources Manual provides a list of contacts at each US Commercial Nuclear Power Site, and an emergency equipment list. The INPO Emergency Resources Manual can be found on the INPO website.

8.22 DETERMINE the need for and request assistance from INPO (Human Resources, Emergency Equipment, Technical Expertise).

9.0 RECORDS 9.1 Records generated during a declared emergency should be forwarded to the Emergency Preparedness Unit."

10.0 ATTACHMENTS 10.1 Emergency Response Manager (ERM) Quick Start Guide

ATTACHMENT 10.1 Page 1 of 1 EPEOF-01 Rev. 16 Page 9 of 9 EMERGENCY RESPONSE MANAGER (ERM) QUICK START GUIDE NOTE: Blanks are provided for place keeping only; logs are the official record. This is a summary level guide and does not replace the procedure steps.

1. Sign in on the Facility Sign

-In Board and EOF Staffing Requirements/Overflow Roster. Announce your name and title. Log on to the electronic logging. _____ NOTE: Activation of emergency facilities may be delayed due to adverse site conditions (e.g., hostile action). If delayed, activation must be completed as promptly as is practical once the site is secure as directed by site Security. 2. Verify EOF minimum staffing and resources available for facility activation per EPEOF-00, Attachment 10.3. _____ NOTE: During a Security Event, divulging information regarding the event may provide information to the adversaries and is undesirable to responding Law Enforcement Agencies. 3. Review Emergency Notification Forms and press releases issued.

_____ 4. Direct the EOF staff to prepare for initial plant status briefing.

_____ 5. Obtain initial plant status briefing from the CR and the TSC.

_____ Use EPCLA-01, Attachment 10.4, for guidance.

6. Activate EOF as soon as possible.

_____ 7. Refer to procedure steps.

_____ 8. Approve Emergency Notification Forms within 15 minutes of a change in emergency classification or Protective Action Recommendation (PAR)

_____ 9. Approve press releases, as needed.

_____

EPTSC-01 Rev. 19 Page 1 of 11 R Reference Use H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PLANT OPERATING MANUAL VOLUME 2 PART 5 EPTSC-01 SITE EMERGENCY COORDINATOR REVISION 19

EPTSC-01 Rev. 19 Page 2 of 11

SUMMARY

OF CHANGES PRR 1990340, NCR 1988798 SECTION REVISION COMMENTS 8.8, Attachment 10.1 Step 11, 2.1 Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: Added step stating "Approve deviations from normal work processes as appropriate per AD

-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachment or EPCLA-01, Emergency Control." Added reference to AD

-OP-ALL-1000 Justification: NCR 1988798 identified INPO gap focus area related to deviations from normal work processes.

EPTSC-01 Rev. 19 Page 3 of 11 TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE

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

4

2.0 REFERENCES

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

4 3.0 RESPONSIBILITIES

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

4 4.0 PREREQUISITES

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

5 5.0 PRECAUTIONS AND LIMITATIONS

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

5 6.0 SPECIAL TOOLS AND EQUIPMENT

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

5 7.0 ACCEPTANCE CRITERIA

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

5 8.0 INSTRUCTIONS

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

5 9.0 RECORDS

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

8 10.0 ATTACHMENTS

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

8 10.1 SITE EMERGENCY COORDINATOR (SEC) QUICK

-START GUIDE

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

9 10.2 SITE EMERGENCY COORDINATOR (SEC) INCIDENT COMMAND POST INTERFACE QUICK

-START GUIDE

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

11 EPTSC-01 Rev. 19 Page 4 of 11 1.0 PURPOSE 1.1 This procedure describes the functional responsibilities and procedure steps for the Site Emergency Coordinator (SEC) in the Technical Support Center (TSC).

2.0 REFERENCES

2.1 AD-OP-ALL-1000, Conduct of Operations 2.2 IER L2 11-39, Lack of Timely Emergency Response Organization and Emergency Response Facility Activation

2.2.1 Recommendation

3, Clearly define emergency response facility activation criteria 2.2.2 Recommendation 3.c., Develop a process for filling vacant ERO positions with other plant staff members 2.3 EPTSC-00, Activation and Operation of the Technical Support Center 2.4 EPCLA-01, Emergency Control 2.5 EPTSC-03, Emergency Repair Director 2.6 EPOSC-04, Emergency Work Control 2.7 EPSPA-01, Evacuation and Accountability 2.8 EPSPA-03, Administration of Potassium Iodide 2.9 EPSPA-05, Unified Incident Command

3.0 RESPONSIBILITIES

3.1 Maintain command AND control of the Technical Support Center (TSC), the onsite activities, AND response to the emergency.

3.2 Classify, terminate, OR downgrade the emergency using the Emergency Action Level (EALs) Matrices and EPCLA-01, Emergency Control.

3.3 Provide guidance for AND approve communications regarding the emergency with the Nuclear Regulatory Commission (NRC).

3.4 Authorize planned radiation exposures in excess of routine yearly exposure limits for lifesaving OR equipment repair missions.

3.5 Coordinate with the Emergency Repair Director (ER D) in assigning priorities for missions. Ensure any potential repair issues are documented, using electronic or handwritten logs. Potential missions, even if deferred, should be listed on the logs.

EPTSC-01 Rev. 19 Page 5 of 11 4.0 PREREQUISITES N/A 5.0 PRECAUTIONS AND LIMITATIONS 5.1 If electronic logging is unavailable, then paper logs and paper/whiteboard status board(s) shall be maintained. 6.0 SPECIAL TOOLS AND EQUIPMENT N/A 7.0 ACCEPTANCE CRITERIA N/A 8.0 IN STRUCTIONS NOTE: Attachment 10.1, Site Emergency Coordinator (SEC) Quick Start Guide, contains a summary of responsibilities/tasks associated with ERO position (attachment information does not replace the procedure steps).

NOTE: The TSC is responsible for emergency classification AND NRC communications after activation. NOTE: PA announcements and initiation of ERDS will remain the responsibility of the Control Room SEC/Shift Manager even after turnover. 8.1 DIRECT the TSC staff to prepare for activation.

Activation staffing and functional staffing requirements are shown on the TSC Staffing Requirements/Overflow Roster in EPTSC-00, Activation and Operation of the Technical Support Center.

8.2 In order to relieve the Control Room of NRC communication activities, the SEC AND the NRC Emergency Communicator can assume and conduct communication activities from the TSC prior to full facility activation, after receiving turnover from the SEC

-Control Room and Emergency Communicator

-Control Room, if staffing is available. [IER L2 11-39, Rec. 3]

EPTSC-01 Rev. 19 Page 6 of 11 8.3 CONTACT the SEC/ Shift Manager and get a briefing for turnover. 8.3.1 UTILIZE EPCLA-01, Attachment 10.

3 , and Turnover Checklist for this briefing. 8.4 BRIEF the TSC staff regarding turnover, if not performed on speaker phone OR video. NOTE: Activation of the TSC is implemented following turnover from the Control Room SEC.

8.5 WHEN a position required for activation is not filled, a supervisory position may fulfill the responsibilities provided they are trained to perform the assigned activities of the position. [IER L2 11-39, Rec. 3.c.]

8.6 WHEN required staffing is in place, ACTIVATE the TSC. 8.7 PRIORITIZE/ESTABLISH strategies to prevent/limit core damage AND prevent OR terminate any unintended environmental release associated with the emergency. 8.8 APPROVE deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachment or EPCLA

-01, Emergency Control. 8.9 Continuously MONITOR AND REVIEW the Emergency Action Level (EAL) Matrices to determine changes in the emergency classification.

8.10 ADVISE TSC staff regarding: 8.10.1 Eating AND drinking requirements 8.10.2 Use of 3-way communications 8.10.3 No talking over team members and restricted use of phones during briefs. 8.10.4 Time activation is required to support 75 minute limit.

8.10.5 Ensure logs contain all details of key decisions and supporting information such that the current event and responses could be recreated from their logs. 8.11 ANNOU N CE, in the TSC

, any significant changes in plant or emergency conditions, as soon as possible.

8.11.1 ENSURE that the Emergency Operations Facility (EOF), Control Room, and Operational Support Center (OSC) are made aware of the significant changes in plant or emergency conditions.

EPTSC-01 Rev. 19 Page 7 of 11 8.12 INITIATE subsequent facility briefings. (30

-60 minute time frame) 8.12.1 COORDINATE briefings with EOF, CR, AND OSC staff to preclude unnecessary interruptions.

8.13 REQUEST personnel accountability for personnel reporting to the EOF from the Administration & Logistics Manager (A

&LM). 8.14 IF an Alert has been declared AND an emergency assembly has been requested or initiated, THEN DIRECT the Emergency Security Team Leader (ESTL) to initiate a preliminary personnel accountability check. This will expedite the accountability process in the event of a site evacuation, if not already required.

8.15 APPROVE administration of potassium iodide (KI) to onsite emergency response personnel, as appropriate.

8.15.1 Radiation Control staff will make recommendations based on guidance in EPSPA-03, Administration of Potassium Iodide.

8.16 APPROVE planned personnel radiation exposures > 5 REM whole body OR entries into areas > 100 Rem/hr when needed for equipment repair / reentry OR li fe saving efforts. 8.17 REFER to EPOSC-04, Emergency Work Control, for guidance on emergency worker dose limits and exposure guidelines. 8.18 APPROVE , when requested, relocation/evacuation of the OSC to the Training Building. 8.18.1 ANNOUNCE to the TSC and EOF that the OSC is relocating to the Training Building. 8.19 IF TSC relocation is required from the TSC to the Remote Emergency Response Facility (RERF) THEN ensure that critical functions of emergency classification and NRC communications continue during transition from the TSC to RERF.

8.19.1 Individuals supporting these functions may remain at the TSC until relieved by personnel in the RERF or the functions may be performed by the Main Control Room.

8.20 CONFER with the ERM frequently to ensure continuity of operations, response, AND information.

8.21 ENSURE plant entries are tracked, if the OSC is relocated and during the Recovery Phase of an event. 8.22 For sheltering or evacuation, REFER to EPSPA-01, "Evacuation and Accountability."

EPTSC-01 Rev. 19 Page 8 of 11 8.23 IF the need arises for a plant announcement to be made, THEN CONTACT the Unit 2 Control Room.

8.24 IDENTIFY additional equipment and manpower resources needed to support emergency response.

8.24.1 REQUEST resources through the Admin and Logistics Manager in the EOF. (Electronic Resource Request may be used.)

8.25 IF an Incident Command Post has been activated, REFER to Attachment 10.2 , "Site Emergency Coordinator (SEC) Incident Command Post Interface Quick Start Guide."

9.0 RECORDS 9.1 Records generated during a declared emergency should be forwarded to the Emergency Preparedness Unit.

10.0 ATTACHMENTS 10.1 Site Emergency Coordinator (SEC) Quick

-Start Guide 10.2 Site Emergency Coordinator (SEC) Incident Command Post Interface Quick Start Guide ATTACHMENT 10.1 Page 1 of 2 EPTSC-01 Rev. 19 Page 9 of 11 SITE EMERGENCY COORDINATOR (SEC) QUICK-START GUIDE NOTE: Blanks are provided for place keeping only; logs are the official record. This is a summary level guide and does not replace the procedure steps.

1. SIGN IN on Facility Sign

-In Board and the TSC Staffing Requirements/Overflow Roster. Announce your name and title.

LOG into electronic logging for access to status board and logs.

_____ NOTE: The Site Emergency Coordinator and the NRC Emergency Communicator (EC) can assume AND conduct NRC communication activities from the Technical Support Center to relieve the Control Room prior to facility activation after receiving turnover from the Control Room SEC.

NOTE: Full Activation of the TSC can occur when minimum TSC staffing is met AND turnover from the Control Room SEC is complete. NOTE: When a position required for activation is not filled, a supervisory position may fulfill the responsibilities provided they are trained to perform the assigned activities of the position. [IER L2 11-39, Rec. 3.c.]

2. VERIFY TSC staffing AND resources available to prepare for facility activation. _____ 3. REVIEW Emergency Notification Forms AND press releases issued.

_____ 4. ACTIVATE the TSC within 75 minutes of ERO notification.

_____ 5. REVIEW Nuclear Regulatory Commission (NRC) Event Notification Worksheets issued.

_____ 6. DIRECT staff to prepare for initial plant status briefing.

_____ 7. COORDINATE with CR, OSC and EOF to receive initial Plant Status briefing.

_____ 8. OBTAIN initial plant status briefing from the Control Room (CR) using the turnover attachment in EPCLA-01, Emergency Control. _____

ATTACHMENT 10.1 Page 2 of 2 EPTSC-01 Rev. 19 Page 10 of 11 SITE EMERGENCY COORDINATOR (SEC) QUICK

-START GUIDE

9. ACTIVATE the TSC as soon as minimum staffing is reached

minimum required staffing personnel declare that they are ready to activate; and turnover from the Control Room has been completed. _____ Time activated

_______

10. DIRECT radiation control activities, until the arrival of the Radiological Control Director (RCD).

_____ 11. APPROVE deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachment or EPCLA-01, Emergency Control. _____ 12. REFER to EPCLA-01, Emergency Control, for specific instructions to upgrade OR downgrade the emergency.

_____ 13. ESTABLISH a briefing schedule with facility staff AND the EOF. _____ 14. ENSURE TSC extended schedules are completed and provided to the A&LM within two hours of activation. (Time sensitive)

_____ 15. EVALUATE needed resources.

16. REFER to Attachment 10.2 if ICP is activated. _____ 17. REFER to procedure steps.

_____

ATTACHMENT 10.2 Page 1 of 1 EPTSC-01 Rev. 19 Page 11 of 11 SITE EMERGENCY COORDINATOR (SEC) INCIDENT COMMAND POST INTERFACE QUICK-START GUIDE NOTE: This is a summary level guide and will only apply when confirmation that the Incident Command Post (ICP) has been activated.

IF the Incident Command Post (ICP) is activated:

1. DISPATCH Security, Operations and Radiation Protection liaison to ICP, if not already completed.

_____ 2. MAINTAIN communications with the RNP Liaisons at the ICP.

_____ Consider bridging the ICP Operations liaison into the Intra

-facility briefs.

3. MAINTAIN awareness of both RNP and offsite agency resources available from the ICP. _____ 4. ENSURE RNP Liaisons at the ICP are informed of communications systems to be used, changes in plant status (including security status), site protective measures, damage control and casualty care priorities, and resource needs. _____ 5. IF assistance from the ICP is required, THEN INFORM RNP Liaisons of required resources, mission objectives and location, time constraints, hazards, and required site access controls and safety measures. _____ 6. ENSURE ESTL is informed of any requests for personnel to report to, leave, or move about the site. _____ 7. MAINTAIN accountability of offsite teams dispatched to locations inside the owner controlled area (OCA). _____ 8. REQUEST updates from RNP Liaisons regarding law enforcement requirements for on

-site crime scene preservation. _____

(-, DUKE ENERGY QD Serial: RNP-RA/16-0007 FEB 0 9 2016 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 TRANSMITTAL OF EMERGENCY PROCEDURE REVISIONS AND 10 CFR 50.54(g)

SUMMARY

OF ANALYSIS Ladies and Gentlemen:

David S. Hoffman H. B. Robinson Steam Electric Plant Unit 2 Director -Nuc Org Effectiveness Duke Energy Progress 3581 West Entrance Road Hartsville, SC 29550 0: 843 857 5239 F: 843 8571319 David.Hoffman@duke-energy.com 10 CFR 50, Appendix E In accordance with 1 O CFR 50.4(b)(5) and Appendix E to 1 O CFR 50, Duke Energy Progress, Inc. is transmitting revisions to the H.B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, Emergency Implementing Procedures.

A description of the procedure changes are provided on the "Summary of Changes" page included within each emergency procedure.

Please replace the superseded procedures with the enclosed revisions.

The procedure revisions and effective dates are listed in Attachment I to this letter. In accordance with 1 O CFR 50.54(q)(5), Attachments II and Ill include a summary of the analysis associated with the procedure changes provided in Attachment I. This document contains no new Regulatory Commitments.

If you have any questions concerning this matter, please contact Scott Connelly, Acting Nuclear Regulatory Affairs at (843) 857-1569.

Sinc&vt lf--David S. Hoffman Director -Nuc Org Effectiveness DSH/cac United States Nuclear Regulatory Commission Serial: RNP-RA/16-0007 Page 2 of 2 Attachments:

I. Procedure Revisions and Effective Dates II. 50.54(q)(3)

Screen Ill. 50.54(q)(3)

Evaluation Enclosure c: NRC Regional Administrator, NRC, Region II NRC Resident Inspector, HBRSEP Ms. Martha Barillas, NRC Project Manager, NRR (w/o Enclosure)

United States Nuclear Regulatory Commission Attachment I to Serial: RNP-RA/16-0007 Page 1 of 1 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 Procedure Revisions and Effective Dates Procedure Revision No. EPOSC-01, "Operational Support Center Leader" 26 EPOSC-02, "Damage Control Team Leader 15 EPEOF-01, "Emergency Response Manager

16 EPTSC-01, "Site Emergency Coordinator

19 Effective Date 1/27/16 1/27/16 1/27/16 1/27/16 United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/16-0007 5 Pages (including cover page) H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 50.54(g}(3)

Screen

.. EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) 10 CFR 50.54(q) Screening Evaluation Form AD-EP-ALL-0602 Rev. O ATTACHMENT 4 Page 1of4 Screening and Evaluation Number Applicable Sites BNP D EREG #: 1991300 CNS D CR3 D HNP D MNS D SAD #: 1991294 ONS D RNP

• GO D Document and Revision EPEOF-01 Rev. 16 EPTSC-01 Rev. 19 EPOSC-01 Rev. 26 EPOSC-02 Rev. 15 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan): EPEOF-01 Rev. 16, Resgonse Manager

• Section 2.1, 2.2, 8.1 O: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: 0 Added step stating "Approve deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." 0 Added reference to AD-OP-ALL-1000, Conduct of Operations, and EPCLA-01, Emergency Control EPTSC-01 Rev. 19, Site Coordinator

• Section 8.8, Attachment 10.1 Step 11, 2.1: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: 0 Added step stating "Approve deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." 0 Added reference to AD-OP-ALL-1000 EPOSC-01 Rev. 26, Ogerational Suggort Center Leader

• Section 3.1.4, 8.3.13, Attachment 10.1 under Operation, 2.1, 2.2: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: 0 Added "Obtaining approval for deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." 0 Added "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation Attachment or EPCLA-01, Emergency Control." 0 Added "Obtain approval for deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." 0 Added reference to AD-OP-ALL-1000

& EPCLA-01

• * ' EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) Rev. 0 ATTACHMENT 4 Page 2 of 4 10 CFR 50.54(q) Screening Evaluation Form EPOSC-02 Rev. 15, Damage Control Team Leader

• Section 8.9, 2.1, 2.2: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: 0 Revised "unless deviations are authorized" to "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD-OP-ALL-1000 , Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment or EPCLA-01 , Emergency Control." 0 Added reference to AD-OP-ALL-1000

& EPCLA-01 Part II. Activity Previously Reviewed?

Yes 10 No I* Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or 10 CFR 50.54(q) Continue to Alert and Notification System Design Report? Effectiveness Attachment 4, Evaluation is not 10CFR If yes , identify bounding source document number or approval reference and required.

Enter 50.54(q) ensure the basis for concluding the source document fully bounds the proposed justification Screening change is documented below: below and Evaluation complete Form, Part Ill Justification

Attachment 4, N/A Part V. Bounding document attached (optional) lo Part Ill. Editorial Change Yes ID No I* Is this activity an editorial or typographical change only, such as formatting, 10 CFR 50.54(q) Continue to paragraph numbering, spelling, or punctuation that does not change intent? Effect i veness Attachment 4 , Evaluation is not Part IV and Justification:

required. Enter address non justification and editorial complete changes Attachment 4, Part V & VI. Part IV. Emergency Planning Element and Function Screen (Reference Attachment 1, Considerations for Addressing Screening Criteria)

Does this activity involve any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If answer is yes, then check box. 1 10 CFR 50.47(b)(1)

Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.

• 1b The response organization has the staff to respond and to augment staff on a continuing basis D (24-7 staffing) in accordance with the emergency plan. 2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that onshift emergency response responsibilities are staffed and assigned D 2b The process for timely augmentation of onshift staff is established and maintained. D 3 10 CFR 50.47(b)(3)

Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made. D 3b State and local staff can be accommodated at the EOF in accordance with the emergency plan. D (NA for CR3)

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) 10 CFR 50.54(q) Screening Evaluation Form AD-EP-ALL-0602 Rev. 0 ATTACHMENT 4 Page 3 of 4 Part IV. Emergency Planning Element and Function Screen (cont.) 4 10 CFR 50.47(b)(4)

Emergency Classification System 4a A standard scheme of emergency classification and action levels is in use. D (Requires final approval of Screen and Evaluation by EP CFAM.) 5 10 CFR 50.47(b)(5)

Notification Methods and Procedures 5a Procedures for notification of State and local governmental agencies are capable of initiating D notification of the declared emergency within 15 minutes (30 minutes for CR3) after declaration of an emergency and providing follow-up notification.

5b Administrative and physical means have been established for alerting and providing prompt instructions D to the public within the plume exposure pathway. (NA for CR3) Sc The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. (NA for CR3) 6 10 CFR 50.47(b)(6)

Emergency Communications 6a Systems are established for prompt communication among principal emergency response D organizations.

6b Systems are established for prompt communication to emergency response personnel.

D 7 10 CFR 50.47(b)(7)

Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within the D plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established.

D 8 10 CFR 50.47(b)(8)

Emergency Facilities and Equipment Ba Adequate facilities are maintained to support emergency response.

D 8b Adequate equipment is maintained to support emergency response.

D 9 10 CFR 50.4 7(b )(9) Accident Assessment 9a Methods, systems, and equipment for assessment of radioactive releases are in use. D 10 10 CFR 50.47(b)(10)

Protective Response 10a A range of public PARs is available for implementation during emergencies. (NA for CR3) D 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available D to support the formulation of PARs and have been provided to State and local governmental authorities. (NA for CR3) 10c A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events. 10d Kl is available for implementation as a protective action recommendation in those jurisdictions that D chose to provide Kl to the public. 11 10 CFR 50.47(b)(11)

Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.

D 12 10 CFR 50.47(b)(12)

Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.

D 13 10 CFR 50.47(b)(13)

Recovery Planning and Post-accident Operations 13a Plans for recovery and reentry are developed.

D EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) Rev. O ATTACHMENT 4 Page 4 of 4 10 CFR 50.54(q) Screening Evaluation Form Part IV. Emergency Planning Element and Function Screen (cont.) 14 10 CFR 50.47(b)(14)

Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program areas) D is established. 14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain , D and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.

14c Identified weaknesses are corrected.

D 15 10 CFR 50.47(b)(15)

Emergency Response Training 1 Sa Training is provided to emergency responders. D 16 10 CFR 50.47(b)(16)

Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established. D 16b Planners responsible for emergency plan development and maintenance are properly trained. D PART IV. Conclusion If no Part IV criteria are checked, a 10 CFR 50.54(q) Effectiveness Evaluation is not required, then complete Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part V. Go to Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part VI for instructions describing the NRC required 30 day submittal.

D If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete

• Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q) Effectiveness Evaluation.

Shaded block requires final approval of Screen and Evaluation by EP CFAM. Part V. Signatures:

Prepare Name (Print): Reviewer Name ( t):

S'. bowl', n Approver Part VI. NRC Emergency Plan and Implementing Procedure Submittal Actions Create two EREG General Assig n ments. One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q), to Licensing.

One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect. QA RECORD *

• United States Nuclear Regulatory Commission Attachment Ill to Serial: RNP-RA/16-0007 6 Pages (including cover page) H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 50.54(g)(3)

Evaluation

.J EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) 10 CFR 50.54(q) Effectiveness Evaluation Form Screening and Evaluation Number EREG #: 1991300 5AD #: 1991294 AD-EP-ALL-0602 Rev. 0 ATTACHMENT 5 Page 1 of 5 Applicable Sites BNP D CNS D CR3 D HNP D MNS D ONS D RNP

• GO D Document and Revision EPEOF-01 Rev. 16 EPTSC-01 Rev. 19 EPOSC-01 Rev. 26 EPOSC-02 Rev. 15 Part I. Description of Proposed Change: EPEOF-01 Rev. 16, Emergency Response Manager

• Section 2.1, 2.2 , 8.10: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: o Added step stating "Approve deviations from normal work processes as appropriate per ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." o Added reference to AD-OP-ALL-1000, Conduct of Operations, and EPCLA-01, Emergency Control EPTSC-01 Rev. 19, Site Emergency Coordinator

• Section 8.8, Attachment 10.1 Step 11, 2.1: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: o Added step stating "Approve deviations from normal work processes as appropriate per ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." o Added reference to AD-OP-ALL-1000 EPOSC-01 Rev. 26. Operational Support Center Leader

• Section 3.1.4, 8.3.13, Attachment 10.1 under Operation, 2.1, 2.2: Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: o Added "Obtaining approval for deviations from normal work processes as appropriate per ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." o Added "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation Attachment or EPCLA-01, Emergency Control." a Added "Obtain approval for deviations from normal work processes as appropriate per ALL-1000, Conduct of Operations, Deviation from Normal Work Processes I Requirements Documentation attachment or EPCLA-01, Emergency Control." o Added reference to AD-OP-ALL-1000

& EPCLA-01

_, EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) 10 CFR 50.54(q) Effectiveness Evaluation Form AD-EP-ALL-0602 Rev.a ATTACHMENT 5 Page 2 of 5 EPOSC-02 Rev. 15. Damage Control Team Leader

• Section 8.9, 2.1, 2.2:

Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: a Revised "unless deviations are authorized" to "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment or EPCLA-01, Emergency Control." o Added reference to AD-OP-ALL-1000

& EPCLA-01 Attachment 6, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is attached (required for IC or EAL change) Part II. Description and Review of Licensing Basis Affected by the Proposed Change: Yes D No

• The proposed changes listed in EPEOF-01 Rev. 16, Emergency Response Manager; EPTSC-01 Rev. 19, Site Emergency Coordinator; EPOSC-01 Rev. 26, Operational Support Center Leader; EPOSC-02 Rev. 15 and Damage Control Team Leader included a review of the following RNP emergency plan licensing basis documents:

• PLP-007, Robinson Emergency Response Plan (Revision 0, dated 1982)

• PLP-007, Robinson Emergency Plan (Revision

85)

• NRG Correspondence

-May 11, 1983:

Subject:

NUREG-0737 Item 111.A.2.1

-Emergency Plan Upgrade To Meet Rule (H.B. Robinson Unit 2)

• H.B. Robinson Steam Electric Plant, Unit No. 2, Updated Final Safety Analysis Report, Chapter 13.3 This review concludes that the proposed changes in the procedures listed above continue to meet the intent and requirements of the documents listed above. Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments. If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50. 54( q): The proposed changes to the procedures listed in Part I of this evaluation are associated with enhancing the guidance to Emergency Response Organization leaders to respond quickly and efficiently to events that may occur during an emergency. AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment and EPCLA-01, Emergency Control currently provide guidance on when deviation from normal work processes may occur. These Emergency Preparedness procedures incorporate that guidance by establishing clear directions to facility leaders to refer to AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment or EPCLA-01, Emergency Control if deviations from the work process become necessary in an emergency event. By using a process that is currently in place at RNP and familiar to site personnel, the responsibility for emergency response is assigned and familiar to site personnel.

Planning Standard 10 CFR 50.47(b)(1) continues to be met with these proposed changes. The definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization is strengthened by including the standard process for deviations from the normal work process into emergency procedures.

10 CFR 50 Appendix E, Section IV.A.2 continues to be met as these proposed changes incorporate procedural guidance for deviations from the normal work process into emergency response procedures.

' EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q) 10 CFR 50.54(q) Effectiveness Evaluation Form AD-EP-ALL-0602 Rev. 0 ATTACHMENT 5 Page 3 of 5 Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen): 50.47(b)(1), Emergency Response Responsibility PLANNING STANDARD:

Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis. PS FUNCTIONS:

1. Responsibility for emergency response is assigned.

2. The response organization has the staff to respond and augment on a continuing basis (24/7 staffing) in accordance with the E-plan. Supporting Requirements:

10 CFR Part 50, Appendix E, Sections IV.A.2 A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency.

Specifically, the following shall be included:

2. A description of the onsite emergency response organization with a detailed discussion of: a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

b. Plant staff emergency assignments;

c. Authorities, responsibilities, and duties on an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

Elements

• Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organizations within the Emergency Planning Zones have been assigned.

• The emergency responsibilities of the various supporting organizations have been specifically established.

• Each organization and sub-organization having an operational role shall specify its concept of operations, and its relationship to the total effort.

• Each organization shall identify a specific individual by title who shall be in charge of the emergency response Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

The proposed changes to the procedures listed in Part I of this evaluation are associated with enhancing the guidance to Emergency Response Organization leaders to respond quickly and efficiently to events that may occur during an emergency. AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment and EPCLA-01, Emergency Control currently provide guidance on when deviation from normal work processes may occur during emergency activities.

The use of the procedures ensures a smooth transition when the Emergency Plan is activated and actions must be taken quickly to mitii:iate the event. Individuals that will need to use the process to support deviations from the normal work

. EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) Rev. 0 A TT AC HM ENT 5 Page 4 of 5 10 CFR 50.54(q) Effectiveness Evaluation Form process now have the associated guidance referenced in their emergency procedures.

This ensures RNP is able to carry out critical actions (emergency response functions) in a timely manner. This proposed change integrates procedures used in normal modes of operation into the emergency response procedures.

This continues to meet the guidance provided in PLP-007, Robinson Emergency Plan Section 5.3, Emergency Response Organization. In addition, the guidance in Section 5.4, Emergency Measures is also maintained by ensuring personnel will be directed to take actions to mitigate plant/equipment damage and minimize impact to the general public by utilizing established work processes. As stated above, the proposed changes to the procedures listed in Part I do not reduce the effectiveness of PLP-007. Instead, the proposed changes described in this revision continue to provide additional assurance that the ERO 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 . Effective use of this procedure helps ensure emergency response capabilities described in PLP-007 are adequately maintained and demonstrated.

The proposed changes in EPEOF-01 Rev. 16, Emergency Response Manager; EPTSC-01 Rev. 19, Site Emergency Coordinator; EPOSC-01 Rev. 26, Operational Support Center Leader and EPOSC-02 Rev. 15, Damage Control Team Leader, enhance ERO readiness to support a classified emergency, resulting in an improved capability to ensure health and safety of plant personnel and the general public. PLP-007 Section 5.3, Emergency Response Organization and Section 5.4, Emergency Measures, provide guidance to emergency response personnel on the actions to take when deviations from normal work processes are needed. These procedures incorporate the guidance of PLP-007 into RNP implementing procedures. These proposed changes continue to meet the guidance provided in PLP-007 with no reduction in effectiveness.

Part VI. Evaluation Conclusion.

Answer the following questions about the proposed change. 1 Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? Yes* NoD 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes* NoD reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes* NoD 4 Choose one of the following conclusions:

a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current

• Emergency Action Level (EAL) scheme. Therefore, the activity can be implemented without prior NRC approval.

b The activity does not continue to comply with the requirements of 10 CFR 50.47(b) or 10 CFR 50 Appendix E or the activity does constitute a reduction in effectiveness or EAL scheme change. D Therefore, the activity cannot be implemented without prior NRC approval.

.. . : EMERGENCY PLAN CHANGE SCREENING AND *EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0) 10 CFR 50.54(q) Effectiveness Evaluation Form Part VII. Disposition of Proposed Change Requiring Prior NRC Approval AD-EP-ALL-0602 Rev. 0 ATTACHMENT 5 Page 5 of 5 Will the proposed change determined to require prior NRC approval be either revised or Yes D No D rejected?

If No, then initiate a License Amendment Request in accordance 10 CFR 50.90 and AD-LS-ALL-0002, Regulatory Correspondence, and include the tracking number: Part VIII. Signatures

EP CFAM Final Approval is required for changes affecting risk significant planning standard 10 CFR 50.47(b)(4).

Approver (CFAM, as re uired) Name (Print): t0 If the proposed activity is a change to the E-Plan or implementing procedures, then create two EREG General Assignments. Date: l)2-b/Jb Date:

• One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR

• 50.54(q), to Licensing.

• One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the

• change is put in effect. QA RECORD EPOSC-01 Rev. 26 Page 1 of 18 I Information Use H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PLANT OPERATING MANUAL VOLUME 2 PART 5 EPOSC-01 OPERATIONAL SUPPORT CENTER LEADER REVISION 26

EPOSC-01 Rev. 26 Page 2 of 18

SUMMARY

OF CHANGES PRR 1990343 , NCR 1988798 EPOSC-01 Revision 2 6 SECTI ON REVISION COMMENTS 3.1.4 , 8.3.13, Attachment 10.1 under Operation ,

2.1, 2.2 Clarified approval of deviation from normal work processes by referring to deviation process described in AD

-OP-ALL-1000 and EPCLA-01 as follows: Added "Obtaining approval for deviations from normal work processes as appropriate per AD

-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes /

Requirements Documentation attachment or EPCLA

-01, Emergency Control." Added "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD

-OP-ALL-1000 , Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation Attachment or EPCLA-01, Emergency Control

." Added "Obtain approval for deviations from normal work processes as appropriate per AD

-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes /

Requirements Documentation attachment or EPCLA

-01, Emergency Control." Added reference to AD

-OP-ALL-1000 & EPCLA-01 Justification: NCR 1988798 identified INPO gap focus area related to deviations from normal work processes.

EPOSC-01 Rev. 26 Page 3 of 18 TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE ............................................................................................................

4

2.0 REFERENCES

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

4 3.0 RESPONSIBILITIES

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

4 4.0 PREREQUISITES ................................................................................................

5 5.0 PRECAUTIONS AND LIMITATIONS

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

5 6.0 SPECIAL TOOLS AND EQUIPMENT

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

5 7.0 ACCEPTANCE CRITERIA

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

5 8.0 INSTRUCTIONS

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

6 9.0 RECORDS..........................................................................................................

10 10.0 ATTACHMENTS

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

10 10.1 OSC LEADER CHECKLIST

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

11 10.2 OSC LEADER INITIAL BRIEFING CHECKLIST

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

14 10.3 OSC LEADER SUBSEQUENT BRIEFING CHECKLIST

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

16 10.4 BACKUP OSC SETUP

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

17 EPOSC-01 Rev. 26 Page 4 of 18 1.0 PURPOSE 1.1 The purpose of this procedure is to describe the duties and responsibilities of the Operational Support Center (OSC) Leader. Attachments to this procedure describe the organization, activation, and operation of the OSC.

2.0 REFERENCES

2.1 AD-OP-ALL-1000, Conduct of Operations 2.2 EPCLA-01, Emergency Control 2.3 EPOSC-00, Activation and Operation of the Operational Support Center 2.4 EPNOT-01, CR/EOF Emergency Communicator 2.5 EPEOF-03, Administrative and Logistics Manager 2.6 EPOSC-03, Environmental and Radiation Control Team 2.7 IER L2 11-39, Rec. 3.c., Develop a process for filling vacant ERO positions with other plant staff members 2.8 EPSPA-03, Administration of Potassium Iodine

3.0 RESPONSIBILITIES

NOTE: In order to augment the staff of the Control Room as soon as practical, activation of the OSC is permitted with partial staffing. 3.1 The OSC Leader is responsible to the Emergency Repair Director (ERD) when the Technical Support Center (TSC) is activated. The OSC Leader is responsible to the Control Room Site Emergency Coordinator (CR-SEC) prior to the activation of the TSC. General responsibilities include:

3.1.1 Activation of the OSC at an Alert OR higher emergency classification OR at a lower level, if directed by the SEC.

3.1.2 Coordinating the activities of the OSC AND supporting its assigned personnel.

3.1.3 Coordinating the distribution of Potassium Iodide (KI) to onsite personnel within the Protected Area in accordance with EPSPA

-03, Administration of Potassium Iodide.

EPOSC-01 Rev. 26 Page 5 of 18 3.1.4 Obtaining approval for deviations from normal work processes from the Shift Manager, SEC or ERM per AD

-OP-ALL-1000, Deviation from Normal Work Processes/Requirements Documentation Attachment or EPCLA-01, Emergency Control.

4.0 PREREQUISITES

4.1 Activation of the OSC will be done at all Alert or higher emergency classifications OR at the discretion of the Site Emergency Coordinator (SEC), as needed to support site emergencies or events.

4.2 All off-duty responders called in to support the facility activation shall make a Fitness-For-Duty affirmation prior to entering the Protected Area.

4.3 If electronic logging is unavailable, then paper logs and paper/whiteboard status board(s) shall be maintained.

5.0 PRECAUTIONS AND LIMITATIONS 5.1 None 6.0 SPECIAL TOOLS AND EQUIPMENT 6.1 Equipment used to support OSC activities is listed in the body of the procedure, as applicable.

7.0 ACCEPTANCE CRITERIA 7.1 None EPOSC-01 Rev. 26 Page 6 of 18 8.0 INSTRUCTIONS NOTE: Activation of emergency facilities may be delayed due to adverse site conditions (e.g., hostile action). If delayed, activation must be completed as promptly as is practical once the site is secure as directed by site Security. 8.1 Refer to Attachment 10.1, OSC Leader Checklist, for a summary of responsibilities/tasks associated with ERO position (attachment information does not replace the procedure steps).

NOTE: Initial actions of this procedure can be implemented by the Damage Control Team Leader (DCTL) in the absence of the OSC Team Leader.

8.2 The OSC staff will be called out, IF required, at an Alert OR higher emergency classification , OR at a lower level, if directed by the SEC. NOTE: The actions in Step 8.2 may be performed at any time.

8.3 Upon reporting to the OSC, the OSC Leader shall:

8.3.1 ESTABLISH communications with the Control Room OR the Emergency Repair Director (ERD), IF the TSC is activated, AND GIVE the status of OSC augmentation.

1. USE the OSC Tag Board AND OSC Personnel Roster in EP O SC-00, Activation and Operation of the Operational Suppor t Center, for tracking OSC positions being filled.

2. REQUEST plant status AND discuss any repair missions underway OR needed. 8.3.2 PERFORM initial OSC briefing, using Attachment 10.2, OSC Leader Initial Briefing Checklist.

EPOSC-01 Rev. 26 Page 7 of 18 8.3.3 ORDER all non-emergency response personnel to leave the staffing areas of the OSC.

8.3.4 ENSURE accountability is initiated AND CALL Emergency Security Team Leader (ESTL) WHEN complete. 1. ASSIGN the Security Watchperson to establish AND maintain OSC access control. 2. A radiological control point may be set up at the OSC Entrance/Exit point, IF the OSC leader deems it appropriate.

3. Admin supplies AND equipment (including phone s) for this purpose are located in the OSC supply cabinet. NOTE: The Tag Board describes the recommended OSC staff. Other personnel may be assigned to the facility, as needed. Not all personnel assigned to the OSC are required to have a tag.

IF the emergency can be handled with less than the recommended staff, the OSC can be activated.

8.3.5 USE the Tag Board located at the OSC entrance AND t he OSC Personnel Roster from EPOSC

-00 , Activation and Operation of the Operational Support Center, to ensure that the OSC organization is adequately staffed. 1. EPOSC-00 describes the OSC organization structure AND staffing information. 8.3.6 ENSURE facility is set-up, in accordance with EPOSC

-00. 1. Communication lines should be checked with the TSC AND the Control Room.

2. Communications system information is contained in EPNOT

-01 , CR/EOF Emergency Communicator, OR the ERO Phone Book.

8.3.7 DETERMINE the need for additional equipment, supplies, AND manpower. 1. Requests should be made through the ERD to the A&LM. 8.3.8 ENSURE the appropriate attachment in EPEOF-03, Administrative and Logistics Manager, is completed for OSC Extended Schedules AND provided to the A&LM within two hour s after facility activation.

EPOSC-01 Rev. 26 Page 8 of 18 8.3.9 Upon reaching the activation staffing level established in EPOSC

-00, the OSC Leader (OR in his absence, the DCTL) SHALL DECLARE the facility activated.

1. This SHALL be done by an announcement in the facility AND by a call to the E RD. 2. A final personnel accountability check will be made AND the ESTL SHALL be informed of the result.

8.3.10 OBTAIN an initial briefing on plant status and emergency operations from the Control Room or ERD, if the TSC has been activated.

8.3.11 ADVISE OSC staff regardin g: 1. Eating AND drinking requirements.

2. Use of 3-way communications

3. No talking over team members and restricted use of phones during briefs.

4. Ensure logs contain all details of key decisions and supporting information such that the current event and responses could be recreated from the ir logs. 5. Timely activation is required to support 75 minute limit.

8.3.12 The OSC Leader will control, direct, AND support assigned personnel as follows: 1. Upon notification of a mission from the ERD, ENSURE that the personnel AND resources necessary for the mission are available.

2. Whenever it is determined that an OSC mission is not practical OR feasible during the course of a declared emergency, ADVISE the ERD for appropriate action.

EPOSC-01 Rev. 26 Page 9 of 18 8.3.13 ENSURE radiological briefings are conducted for activities dispatched from the OS C, unless an approved deviation exists from the Shift Manager, SEC or ERM per AD

-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation attachment or EPCLA-01, Emergency Control. REFER TO EPOSC-03, Environmental and Radiation Control Team, for guidance

. (AR #47564, AR #43529)

1. IF a medical emergency exists, verbal authorization may be given for team dispatch as long as the information is documented in the OSC Leader log.

8.3.14 ENSURE both security AND radiological updates are available for all briefings and activities. This information should be provided by the R C lead person AND IF available, to the Damage Control Team Leader s , E&C lead person, AND the Work Control SRO.

8.3.15 CONDUCT frequent status update briefings with OSC staff personnel using Attachment 10.3, OSC Leader Subsequent Briefing Checklist.

8.3.16 INFORM the ERD of the status of missions/teams, emphasizing time of dispatch and mission status at a frequency consistent with the timing of CR/TSC/EOF joint briefings. 8.3.17 DIRECT the RC personnel to establish AND monitor habitability in the OSC. 8.3.18 CONSULT the Site Industrial Safety Representative, Chemistry personnel , OR other industry/emergency response personnel to assist with determining the appropriate protective actions in the event of a chemical/toxic hazard.

1. IF deemed necessary, take steps to secure ventilation. (AR #28241) 8.4 IF adverse environmental conditions dictate, THEN move the OSC, in accordance with Attachment 10.

4, Backup OSC Setup.

8.4.1 Operations personnel will report to the Control Room, IF conditions permit. 8.4.2 Consider evacuation, IF the actual OR anticipated total accumulated dose exceeds 1000 mR em. 8.4.3 The recommendation to evacuate the OSC will be made in conjunction with the ERD AND the Radiological Control Director (RCD) in the TSC, OR with the SEC. 1. The SEC will approve OSC evacuations AND relocation of the OSC.

EPOSC-01 Rev. 26 Page 10 of 18 8.5 IF directed by Radiation Control Director (RCD), THEN COORDINATE the distribution of Potassium Iodide (KI) to onsite personnel within the Protected Area in accordance with EPSPA

-03, Administration of Potassium Iodide.

8.6 ENSURE proper use of communications equipment. IDENTIFY yourself by name AND the position you hold at the beginning of each transmission.

8.7 SUPPORT the requests from the Administrative and Logistics Manager (A&LM) AND ASSIGN individuals as needed, and if available, to support the response effort. 8.8 Upon instructions from the ERD or SEC, the OSC Leader SHALL deactivate the facility by: 8.8.1 Appropriately notifying all OSC personnel; AND 8.8.2 Assuring that all equipment AND supplies are returned to the appropriate storage location.

8.8.3 Reviewing OSC Leader Log for completeness AND accuracy. 8.9 Records generated during a declared emergency should be forwarded to the Emergency Preparedness Unit. 9.0 RECORDS 9.1 No records generated by this procedure.

10.0 ATTACHMENTS 10.1 OSC Leader Checklist 10.2 OSC Leader Initial Briefing Checklist 10.3 OSC Leader Subsequent Briefing Checklist 10.4 Backup OSC Setup

ATTACHMENT 10.1 Page 1 of 3 EPOSC-01 Rev. 26 Page 11 of 18 OSC LEADER CHECKLIST NOTE: Activation of emergency facilities may be delayed due to adverse site conditions (e.g., hostile action). If delayed, activation must be completed as promptly as is practical once the site is secure as directed by site Security. ACTIVATION

______ Upon your arrival, announce your presence in the OSC and establish communications with the Control Room, or the ERD if the TSC has been activated, giving status of augmentation and requesting mission information.

______ The OSC Leader, or in his absence, the Damage Control Leader shall declare the facility activated upon reaching the activation staffing level established in EPOSC

-00. ______ Ensure the site and OSC PA system volumes are at an appropriate leve l

to be heard in all areas of the OSC.

______ Order all non

-emergency response personnel to leave the OSC staffing areas and provide additional instructions, as warranted by emergency conditions.

______ Ensure set up of the OSC. The OSC boundaries may be modified to better facilitate OSC operations, at the discretion of the OSC Leader.

______ Ensure set up of telephones (phones are located in the OSC Briefing Room supply cabinet), placing them according to the marked numbers on the OSC Layout Diagram (phone jacks on walls are also marked).

______ Request OSC personnel to retrieve their TLD from the storage location.

______ Request OSC personnel to retrieve personal safety equipment including respirator glasses and shaving equipment.

______ Ensure status lights are appropriately illuminated.

______ Ensure accountability is initiated; call the Emergency Security Team Leader when complete.

______ Ensure that the Security Watchperson maintains access control and the OSC Personnel Roster.

______ Ensure that the facility is adequately staffed for the emergency at hand, (refer to the Tag Board AND OSC Personnel Roster in EPOSC-00). ______ Ensure that the facility is being monitored for radiological habitability.

ATTACHMENT 10.1 Page 2 of 3 EPOSC-01 Rev. 26 Page 12 of 18 OSC LEADER CHECKLIST

______ Make requests for additional personnel and equipment, as the situation dictates. ______ Conduct briefing for OSC personnel. Obtain initial plant status briefing from Control Room or ERD, if the TSC has been activated.

______ Instruct personnel to obtain their equipment and to prepare for missions (pre-stage a limited number of Maintenance and RC personnel with Protective Clothing on, to facilitate expediting public health and safety missions).

______ Verify clocks are synchronized to ERFIS/EDS/LAN and the TSC/EOF.

NOTE: When a position required for activation is not filled, a supervisory position may fulfill the responsibilities provided they are trained to perform the assigned activities of the position. [IER L2 11-39, Rec. 3.c.]

______ Declare the OSC activated. Announce activation and time activated using the OSC public address system. Report the same to the Emergency Repair Director or SEC.

(Time sensitive - 60 minutes after declaration of Alert or higher)

______ Provide OSC personnel with an update of plant conditions and any expectations for the facility or its personnel.

______ Announce to all personnel to place phone s on vibrate.

______ Announce to all personnel to ensure logs contain all details of key decisions and supporting information such that the current event and

responses could be recreated from their logs.

______ Ensure OSC Extended Schedules are completed and provided to the A&LM within two hour s of activation, in accordance with EPEOF

-03 , Administrative and Logistics Manager

. (Time sensitive)

OPERATION ______ Support overall emergency response efforts. ______ Obtain approval for deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachment or EPCLA-01, Emergency Control.

______ Ensure the OSC Leader Log, Tag, and OSC Status Board s are being maintained.

ATTACHMENT 10.1 Page 3 of 3 EPOSC-01 Rev. 26 Page 13 of 18 OSC LEADER CHECKLIST

______ Ensure Damage Control Teams are preparing for missions.

______ Ensure plant monitoring activities are conducted by RC and Chemistry personnel.

______ Conduct frequent briefings of OSC command personnel.

______ Participate in inter

-facility briefings with the EOF/TSC, as time permits.

______ Conduct facility briefing for all personnel and include:

Current emergency classification and the conditions for it Plant status Mission status Habitability status (condition of eating, smoking, or drinking)

Team specific briefings/debriefings will be given by the work group leaders/coordinators.

EVACUATION

______ Should it become necessary, evacuate the facility according to 0.

4, Backup OSC Setup.

DEACTIVATION

______ Notify OSC personnel that the OSC has been deactivated. This notification should also be communicated to individuals in the field.

______ Review OSC Log for completeness and accuracy.

______ Ensure all logs and Attachments are given to the Emergency Preparedness Staff.

______ Ensure proper decontamination is performed, if required.

______ Ensure all equipment and supplies are returned to the appropriate storage location. ______ Leave the area in a clean condition.

______ Give a final deactivation status report to the ERD or the SEC.

ATTACHMENT 10.2 Page 1 of 2 EPOSC-01 Rev. 26 Page 14 of 18 OSC LEADER INITIAL BRIEFING CHECKLIST

______ Attention all personnel in the OSC. My name is

____________________

and I am the OSC leader.

______ The Damage Control Team Electrical Leader is _____________________

______ The RC Coordinator is

________________________________________

______ The Damage Control Team Mechanical Leader is ___________________

______ Discuss the status of the plant and conditions leading to event.

______ Direct all personnel that are not involved in the event to exit the building and provide additional instructions, as warranted by emergency conditions.

______ Ensure you update the OSC Access Log to maintain accountability. (i.e., tag board, OSC Personnel Roster)

______ Personnel entering the OSC must use the East Entrance of the O&M building.

______ Observe all OSC boundaries.

______ Three-way communications is an absolute must.

______ Communication and coordination between workgroups is important to ensure personnel and plant safety.

______ Let me remind you that the public health and safety missions will be our first priority. We must prepare and be in the field in less than 30 minutes. Assist all teams, as they are preparing for a mission.

Team work is the key for successful missions.

______ It is important and required that each of you listen to any and all PA announcements. This will ensure all of us are receiving the latest information.

Continue to set up the OSC, per the applicable procedures.

______ Retrieve your TLD from the storage location.

______ Retrieve personal safety equipment, including respirator glasses and shaving equipment.

ATTACHMENT 10.2 Page 2 of 2 EPOSC-01 Rev. 26 Page 15 of 18 OSC LEADER INITIAL BRIEFING CHECKLIST

______ Place phones on vibrate.

______ Remember to use human factor tools such as STAR and the two

-minute rule.

ATTACHMENT 10.3 Page 1 of 1 EPOSC-01 Rev. 26 Page 16 of 18 OSC LEADER SUBSEQUENT BRIEFING CHECKLIST OSC Status Update Briefing Time _________________

______ Emergency classification level

__________________________________________

______ Plant conditions

__________________________________________

__________________________________________

__________________________________________

______ Special radiological __________________________________________

conditions / dose rate information

__________________________________________

__________________________________________

______ Major equipment out of service __________________________________________

__________________________________________

______ Damage Control missions in progress

_____________________________________

__________________________________________

______ OSC habitability

__________________________________________

______ Other Information

__________________________________________

__________________________________________

__________________________________________

ATTACHMENT 10.4 Page 1 of 2 EPOSC-01 Rev. 26 Page 17 of 18 BACKUP OSC SETUP The backup OSC is located in Building 410, EOF/TSC/Training Bldg.

Should adverse environmental conditions dictate, the primary OSC may be evacuated and relocated. The recommendation to evacuate the OSC will be made in conjunction with the ERD and RCD, or with the SEC, who will approve OSC evacuation and relocation.

The attached diagram provides the recommended layout for the Backup OSC.

Operations personnel will report to the Control Room or the Simulator Control Room (for drills/exercise).

Telephones for OSC personnel sent to the Back

-up OSC are stored in the closet in the Training Building Library.

The following equipment should be moved from the primary OSC to the Backup OSC:

OSC Personnel Roster Any Manual Logs Generated Radiation Work Permits Radios (Maintenance and RC)

Survey Instruments and supplies Other equipment, as deemed necessary for continued operation

ATTACHMENT 10.4 Page 2 of 2 EPOSC-01 Rev. 26 Page 18 of 18 BACKUP OSC SETUP

EPOSC-02 Rev. 15 Page 1 of 13 R Reference Use H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PLANT OPERATING MANUAL VOLUME 2 PART 5 EPOSC-02 DAMAGE CONTROL TEAM LEADER REVISION 15

EPOSC-02 Rev. 15 Page 2 of 13

SUMMARY

OF CHANGES PRR 1990346, NCR 1988798 EPOSC-02 Rev. 15 SECTION REVISION COMMENTS 8.9, 2.1, 2.2 Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: Revised "unless deviations are authorized" to "unless an approved deviation exists from the Shift Manager, SEC or ERM per AD-OP-ALL-1000 , Conduct of Operations, Deviation from Normal Work Processes/Requirements Documentation

attachment or EPCLA-01, Emergency Control

." Added reference to AD

-OP-ALL-1000 & EPCLA-01 Justification: NCR 1988798 identified INPO gap focus area related to deviations from normal work processes.

EPOSC-02 Rev. 15 Page 3 of 13 TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE

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

4

2.0 REFERENCES

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

4 3.0 RESPONSIBILITIES

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

4 4.0 PREREQUISITES ....................................................................................................

4 5.0 PRECAUTIONS AND LIMITATIONS

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

4 6.0 SPECIAL TOOLS AND EQUIPMENT

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

4 7.0 ACCEPTANCE CRITERIA

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

4 8.0 INSTRUCTIONS

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

5 9.0 RECORDS

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

7 10.0 ATTACHMENTS

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

7 10.1 EMERGENCY DAMAGE CONTROL

SUMMARY

SHEET

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

8 10.2 EMERGENCY DAMAGE CONTROL PROCEDURE CHECKLIST

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

11 10.3 EQUIPMENT DAMAGE AND REPAIR LOG

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

12 10.4 DAMAGE CONTROL TEAM LEADER QUICK START GUIDE

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

13 EPOSC-02 Rev. 15 Page 4 of 13 1.0 PURPOSE The purpose of this procedure is to outline the duties and responsibilities of the Damage Control Team Leader (DCTL).

2.0 REFERENCES

2.1 EPCLA-01, Emergency Control 2.2 AD-OP-ALL-1000, Conduct of Operations 2.3 See EPOSC-00, Activation and Operation of the Operational Support Center

3.0 RESPONSIBILITIES

3.1 The DCTL, as requested/directed by the OSC Leader, shall be responsible for expediting and monitoring the planning, direction and execution of the efforts of the Damage Control Team to:

3.1.1 Assess the nature and extent of damage incurred.

3.1.2 Perform emergency repairs, if possible.

3.1.3 Perform other actions to reduce the effect of the emergency or to slow down a release when repair is not possible. 3.1.4 Install necessary emergency structures, systems, or components.

3.1.5 Use Attachment 10.4, Damage Control Team Leader Quick Start Guide, as needed, to meet position responsibilities. 3.1.6 Update WebEOC for damage control missions.

3.2 On an interim basis, assume the duties of the Operational Support Center Leader. 4.0 PREREQUISITES 4.1 See EPOSC-00 5.0 PRECAUTIONS AND LIMITATIONS 5.1 See EPOSC-00 6.0 SPECIAL TOOLS AND EQUIPMENT 6.1 See EPOSC-00 7.0 ACCEPTANCE CRITERIA 7.1 See EPOSC-00 EPOSC-02 Rev. 15 Page 5 of 13 8.0 INSTRUCTIONS NOTE: Attachment information does not replace the procedure steps. 8.1 Refer to Attachment 10.4, Damage Control Team Leader Quick Start Guide, for a summary of responsibilities/tasks associated with ERO position.

8.2 Prior to performing any mission, obtain the information specified on the WebEOC Damage Control Mission Status Board or Attachment 10.1, Emergency Damage Control Summary Sheet , i f WebEOC is unavailable.

8.2.1 Ensure that the work functions involved in the mission (i.e., Security, Mechanical/Electrical Planners, Operations, Radiation Control and Supervisor) are involved in the planning stage of the mission.

1. When selecting personnel for a mission, consider training, qualifications, skills, and number needed.

8.3 Review the mission information with the OSC Leader for authorization to proceed. 8.3.1 Document authorization using the WebEOC Damage Control Missio n Status board or Attachment 10.1, Emergen cy Damage Control Summary Sheet, i f WebEOC is unavailable.

8.4 Prior to the mission, perform the following actions:

8.4.1 Determine need for additional equipment, supplies, and manpower, and request same from the OSC Leader.

8.4.2 Acquire procedures, drawings, schematics, tools, Radiation Work Permits, and other documentation necessary for the team's specific mission. NOTE: A crash cart that can be fitted with SCBA bottles is available in the OSC Equipment Room. 8.4.3 Assure that all Damage Control Team members are properly outfitted with equipment necessary for their missions (e.g., dosimeters, hard hats, tools, respirators, etc.).

EPOSC-02 Rev. 15 Page 6 of 13 8.5 When approval to dispatch the team is received from the OSC Leader, execute the mission, in accordance with Attachment 10.2, Emergency Damage Control Procedure Checklist.

8.6 Select appropriate locations for side conversations and radio communications, e.g., outside the OSC Command Room, away from locations with a brief/debrief in progress.

8.7 Request status updates from the appropriate personnel on missions and inform the OSC Leader.

8.8 Use Attachment 10.3, Equipment Damage and Repair Log, if electronic means via WebEOC are not available to log activities associated with missions.

8.9 Follow the requirements outlined in the WebEOC Damage Control Mission Status Board or Attachment 10.1, Emergency Damage Control Summary Sheet , (including ingress and egress routes), unless an approved deviation exists from the Shift Manager, SEC or ERM per AD

-OP-ALL-1000 , Conduct of Operations , Deviation from Normal Work Processes/Requirements Documentation

attachment or EPCLA-01, Emergency Control. Authorizations for repair, maintenance, installation, and clean

-up deviations shall be received from the OSC Leader with the following exceptions, which are authorized by the Site Emergency Coordinator (SEC) and normally received from the ERD: 8.9.1 Life-saving actions (which are highest priority);

8.9.2 Immediate personnel health and safety precautions (e.g., fire, steam leak, etc.). 8.10 During or upon completion of the mission, as appropriate, complete WebEOC Damage Control Mission Status Board or Attachment 10.

1 , Emergency Damage Control Summary Sheet.

8.11 Conduct team debrief in OSC staffing/briefing location.

8.12 Inform the OSCL of the Damage Control Team debrief summary.

EPOSC-02 Rev. 15 Page 7 of 13 9.0 RECORDS 9.1 Records generated during a declared emergency should be forwarded to the Emergency Preparedness Unit.

10.0 ATTACHMENTS 10.1 Emergency Damage Control Summary Sheet 10.2 Emergency Damage Control Procedure Checklist 10.3 Equipment Damage and Repair Log 10.4 Damage Control Team Leader Quick Start Guide

ATTACHMENT 10.1 Page 1 of 3 EPOSC-02 Rev. 15 Page 8 of 13 EMERGENCY DAMAGE CONTROL

SUMMARY

SHEET Missio n # _________________________

Dispatch Time Out _________________________

Dispatch Time In ___________________________

(1) Mission (Condition/Problem): Public Health & Safety Missions must receive top priority to get mission in field within the target goal of 30 minutes.

(2) Is this a Public Health &

[ ] Yes [ ] No Safety Mission (Priority 1)? If yes, Notification Time

_________________________________________

(3) Mission Priority: _________________________________________

(4) Location: (5) Repairs: Highlight critical tasks and risks involved.

(6) Tools and Equipment Required (include communication methods and work coordination)

(7) Procedures:

(8) Field Team Leader:

ATTACHMENT 10.1 Page 2 of 3 EPOSC-02 Rev. 15 Page 9 of 13 EMERGENCY DAMAGE CONTROL

SUMMARY

SHEET (9) Other Team Members:

(Assign roles/responsibilities) (10) Radiation Control Team Member:

(11) Attachments Ingress/Egress Route & Alternate(s)

Maps: (12) Protective Gear/Dosimetry Required: (13) General: Emphasize safety, work quality, STAR and the importance of a questioning attitude.

Approved: RC Coordinator Damage Control (if available)

Team Leader OSC Leader

/

/

/

Initial Time Initial Time Initial Time ATTACHMENT 10.1 Page 3 of 3 EPOSC-02 Rev. 15 Page 10 of 13 EMERGENCY DAMAGE CONTROL

SUMMARY

SHEET Status Update:

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

__________

_________________________________________

ATTACHMENT 10.2 Page 1 of 1 EPOSC-02 Rev. 15 Page 11 of 13 EMERGENCY DAMAGE CONTROL PROCEDURE CHECKLIST

1. Verify all personnel have appropriate qualifications (respirator, security clearance, etc.). 2. Conduct mission - specific briefing.

3. Ensure that the following are completed by the appropriate team members: a. Check out equipment and establish communications.

b. Don appropriate gear.

c. Proceed to location in accordance with approved routes.

d. Perform task. Keep the OSC Leader advised of the status of the mission, as necessary, and if any difficulties encountered during the course of the mission. e. Return. 4. Debrief team and report results to the OSC Leader.

5. Document activities

.

ATTACHMENT 10.3 Page 1 of 1 EPOSC-02 Rev. 15 Page 12 of 13 EQUIPMENT DAMAGE AND REPAIR LOG NAME OF STRUCTURE, SYSTEM, OR COMPONENT LOCATION DAMAGE ASSESSMENT/REPAIRS DAMAGE CONTROL TEAM LEADER:

/

Initials Time ATTACHMENT 10.4 Page 1 of 1 EPOSC-02 Rev. 15 Page 13 of 13 DAMAGE CONTROL TEAM LEADER QUICK START GUIDE NOTE: Blanks are provided for place keeping only; logs are the official record. This is a summary level guide and does not replace the procedure steps.

1. Announce your presence and position in the Operational Support Center (OSC).

_____ 2. Notify the OSC Leader of readiness to activate the OSC.

_____ 3. Comple te the WebEOC Damage Control Mission Status Board or Attachment 10.1, Emergency Damage Control Summary Sheet, if WebEOC is unavailable, for outstanding missions.

_____ 4. Obtain authorization to proceed with mission.

_____ 5. Acquire necessary procedures, tools, and permits.

_____ 6. Ensure Damage Control Team is briefed and that they understand the mission.

_____ 7. Maintain awareness of mission status and report to the OSC Leader.

_____ 8. Upon completion of mission, debrief the team and complete necessary paper work. _____ 9. Refer to procedure steps.

_____

EPEOF-01 Rev. 16 Page 1 of 9 R Reference Use H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PLANT OPERATING MANUAL VOLUME 2 PART 5 EPEOF-01 EMERGENCY RESPONSE MANAGER REVISION 16

EPEOF-01 Rev. 16 Page 2 of 9

SUMMARY

OF CHANGES PRR 1990335 N CR 1988798 EPEOF-01 Revision 16 SECTION REVISION COMMENTS 2.1, 2.2 , 8.10 Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows:

Added step stating "Approve deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachment or EPCLA-01, Emergency Control

." Added reference to AD

-OP-ALL-1000, Conduct of Operations, and EPCLA-01, Emergency Control Justification: N CR 1988798 identified INPO gap focus area related to deviations from normal work processes.

EPEOF-01 Rev. 16 Page 3 of 9 TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE ............................................................................................................

4

2.0 REFERENCES

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

4 3.0 RESPONSIBILITIES

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

4 4.0 PREREQUISITES

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

4 5.0 PRECAUTIONS AND LIMITATIONS

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

4 6.0 SPECIAL TOOLS AND EQUIPMENT

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

4 7.0 ACCEPTANCE CRITERIA

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

4 8.0 INSTRUCTIONS

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

5 9.0 RECORDS............................................................................................................

8 10.0 ATTACHMENTS

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

8 10.1 EMERGENCY RESPONSE MANAGER (ERM) QUICK START GUIDE

........ 9 EPEOF-01 Rev. 16 Page 4 of 9 1.0 PURPOSE 1.1 This procedure describes the functional responsibilities and procedure steps for the Emergency Response Manager (ERM).

2.0 REFERENCES

2.1 AD-OP-ALL-1000, Conduct of Operations 2.2 EPCLA-01, Emergency Control 2.3 EPEOF-10, Recovery Manager and Recovery Operations 2.4 INPO Event Report L1 10, Nuclear Accident at the Fukushima Daiichi Nuclear Power Station, Recommendation 11b

3.0 RESPONSIBILITIES

3.1 Maintain overall command and control of the company

's response to the emergency, the Emergency Operations Facility (EOF), and the Remote Emergency Response Facility (RERF), when activated /utilized. 3.2 Maintain unilateral authority to commit company resources to the emergency response. 3.3 Maintain communications regarding the emergency with internal and external contacts. 3.4 Approve Emergency Notification Forms and press releases.

3.5 Recommend Protective Actions to the offsite agencies.

3.6 Manage the company

's offsite radiological monitoring and dose projection.

4.0 PREREQUISITES

4.1 As per EPEOF

-00, Activation and Operation of the Emergency Operations Facility 5.0 PRECAUTIONS AND LIMITATIONS 5.1 N/A 6.0 SPECIAL TOOLS AND EQUIPMENT 6.1 N/A 7.0 ACCEPTANCE CRITERIA 7.1 N/A EPEOF-01 Rev. 16 Page 5 of 9 8.0 INSTRUCTIONS NOTE: The non-delegable duties for notifying the off

-site authorities and formulating Protective Action Recommendations (PAR) transfer to the ERM upon activation of the EOF OR the Remote Emergency Response Facility. Refer to Attachment 10.1, Emergency Response Manager (ERM) Quick Start Guide, for a summary of responsibilities/tasks associated with ERO position (attachment information does not replace the procedure steps).

Activation of emergency facilities may be delayed due to adverse site conditions (e.g., hostile action). If delayed, activation must be completed as promptly as is practical once the site is secure as directed by site Security.

8.1 Upon notification of the declaration of an Unusual Event, the ERM shall INTERFACE with the Site Emergency Coordinator - CR (SEC-CR) to determine if the EOF shall be activated.

8.1.1 EOF activation is required at an Alert or higher emergency classification level, but will normally activate simultaneously with the Technical Support Center (TSC). 8.2 DETERMINE if conditions exist which would prevent immediate occupancy of the EOF. CONSULT the S tate/County Emergency Management Agencies for appropriate protective actions in the event of an off

-site chemical/toxic hazard. (NCR 00146425) 8.2.1 For sheltering or evacuation, refer to EPSPA

-01, "Evacuation and Accountability". (NCR 00146425) 8.3 DETERMINE if the Remote Emergency Response Facility (RERF) should be utilized to support the Control Room actions during the emergency , when the EOF is inaccessible. 8.3.1 Provide direction to all responders at the RERF.

EPEOF-01 Rev. 16 Page 6 of 9 8.4 DELEGATE TSC command and control as well as plant support / mitigation activities to the SEC, when the TSC minimum staffing positions are available.

8.5 The EOF shall relieve the Control Room (CR) of offsite communications, as soon as possible.

8.6 CONTACT the SEC- TSC and the SEC- CR and conduct a briefing for turnover. 8.6.1 UTILIZE EPCLA-01, Attachment 10.4, Turnover Checklist.

8.7 ACTIVATE the EOF when minimum staffing positions have been acquired, as established by EPEOF

-00, Attachment 10.3. 8.8 BRIEF the EOF staff regarding the information from the turnover, if not completed as a group.

8.9 PRIORITIZE

actions and strategies for the emergency response activities to ensure the health and safety of the general public. 8.10 APPROVE deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachme nt or EPCLA-01, Emergency Control. 8.11 ADVISE EOF staff regarding:

8.11.1 Eating AND drinking requirements 8.11.2 Use of 3-way communications 8.11.3 No talking over team members and restricted use of phones during briefs 8.11.4 Time activation is required to support 75 minute limit 8.12 SCHEDULE AND PROVIDE facility briefings. (30

-60 minute time frame) 8.13 APPROVE Emergency Notification Forms.

8.13.1 Notification is required within 15 minutes for initial classification and/or change in Protective Action Recommendations (PARs).

8.13.2 Follow-up notifications are required every 30

-60 minutes, or for any event which significantly impacts the health and safety of the public, such as the initiation or termination of a release or a significant change in plant conditions (either positive or negative), and when an emergency classification has not changed.

EPEOF-01 Rev. 16 Page 7 of 9 8.14 APPROVE press releases.

NOTE: During a Security Event, divulging information regarding the event may provide information to the adversaries and is undesirable to responding Law Enforcement Agencies.

8.14.1 Following the activation of the EOF, press releases should be available for issue to the news media after any of the following conditions, unless it is a Security related event: 1. A change of an emergency classification, OR 2. The initiation OR termination of a radiological release as a result of the emergency, OR 3. Other significant events provided to the offsite agencies via an Emergency Notification Form.

8.14.2 IF it is a security related event, THEN ENSURE that the lead responding law enforcement agency reviews and concurs with the press release.

8.15 CONFER with Joint Information Center (JIC) personnel upon their arrival at the JIC. Prior to JIC activation, the EOF Public Information Emergency Communicator (PI

-EC) will communicate with Corporate Communications concerning status of news releases and inquiries from the news media/general public. 8.16 REVIEW AND MAINTAIN awareness of dose projection and environmental field monitoring activities.

8.16.1 This includes administration of Potassium Iodide (KI) and expanded environmental monitoring.

8.17 FORMULATE AND COMMUNICATE protective action recommendations (PARs) to the state and counties. 8.18 ENSURE the Assistant to the Emergency Response Manager (AERM) is maintaining contact with Unit 1 AND the Darlington County Plant. Habitability screening may be necessary, if personnel remain in the area.

8.19 NOTIFY state AND counties to provide "heads

-up" information, as necessary. PROVIDE assistance, as requested. REFER to the Emergency Response Organization (ERO) Telephone Book for telephone numbers.

EPEOF-01 Rev. 16 Page 8 of 9 8.20 NOTIFY Corporate Senior Management periodically regarding plant status. Refer to the ERO Telephone Book for telephone numbers.

8.21 DETERMINE the need for AND request assistance from neighboring utilities.

NOTE: The INPO Duty Manager's contact information is located in the ERO Phone Book. The INPO Emergency Resources Manual provides a list of contacts at each US Commercial Nuclear Power Site, and an emergency equipment list. The INPO Emergency Resources Manual can be found on the INPO website.

8.22 DETERMINE the need for and request assistance from INPO (Human Resources, Emergency Equipment, Technical Expertise).

9.0 RECORDS 9.1 Records generated during a declared emergency should be forwarded to the Emergency Preparedness Unit."

10.0 ATTACHMENTS 10.1 Emergency Response Manager (ERM) Quick Start Guide

ATTACHMENT 10.1 Page 1 of 1 EPEOF-01 Rev. 16 Page 9 of 9 EMERGENCY RESPONSE MANAGER (ERM) QUICK START GUIDE NOTE: Blanks are provided for place keeping only; logs are the official record. This is a summary level guide and does not replace the procedure steps.

1. Sign in on the Facility Sign

-In Board and EOF Staffing Requirements/Overflow Roster. Announce your name and title. Log on to the electronic logging. _____ NOTE: Activation of emergency facilities may be delayed due to adverse site conditions (e.g., hostile action). If delayed, activation must be completed as promptly as is practical once the site is secure as directed by site Security. 2. Verify EOF minimum staffing and resources available for facility activation per EPEOF-00, Attachment 10.3. _____ NOTE: During a Security Event, divulging information regarding the event may provide information to the adversaries and is undesirable to responding Law Enforcement Agencies. 3. Review Emergency Notification Forms and press releases issued.

_____ 4. Direct the EOF staff to prepare for initial plant status briefing.

_____ 5. Obtain initial plant status briefing from the CR and the TSC.

_____ Use EPCLA-01, Attachment 10.4, for guidance.

6. Activate EOF as soon as possible.

_____ 7. Refer to procedure steps.

_____ 8. Approve Emergency Notification Forms within 15 minutes of a change in emergency classification or Protective Action Recommendation (PAR)

_____ 9. Approve press releases, as needed.

_____

EPTSC-01 Rev. 19 Page 1 of 11 R Reference Use H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PLANT OPERATING MANUAL VOLUME 2 PART 5 EPTSC-01 SITE EMERGENCY COORDINATOR REVISION 19

EPTSC-01 Rev. 19 Page 2 of 11

SUMMARY

OF CHANGES PRR 1990340, NCR 1988798 SECTION REVISION COMMENTS 8.8, Attachment 10.1 Step 11, 2.1 Clarified approval of deviation from normal work processes by referring to deviation process described in AD-OP-ALL-1000 and EPCLA-01 as follows: Added step stating "Approve deviations from normal work processes as appropriate per AD

-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachment or EPCLA-01, Emergency Control." Added reference to AD

-OP-ALL-1000 Justification: NCR 1988798 identified INPO gap focus area related to deviations from normal work processes.

EPTSC-01 Rev. 19 Page 3 of 11 TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE

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

4

2.0 REFERENCES

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

4 3.0 RESPONSIBILITIES

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

4 4.0 PREREQUISITES

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

5 5.0 PRECAUTIONS AND LIMITATIONS

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

5 6.0 SPECIAL TOOLS AND EQUIPMENT

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

5 7.0 ACCEPTANCE CRITERIA

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

5 8.0 INSTRUCTIONS

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

5 9.0 RECORDS

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

8 10.0 ATTACHMENTS

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

8 10.1 SITE EMERGENCY COORDINATOR (SEC) QUICK

-START GUIDE

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

9 10.2 SITE EMERGENCY COORDINATOR (SEC) INCIDENT COMMAND POST INTERFACE QUICK

-START GUIDE

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

11 EPTSC-01 Rev. 19 Page 4 of 11 1.0 PURPOSE 1.1 This procedure describes the functional responsibilities and procedure steps for the Site Emergency Coordinator (SEC) in the Technical Support Center (TSC).

2.0 REFERENCES

2.1 AD-OP-ALL-1000, Conduct of Operations 2.2 IER L2 11-39, Lack of Timely Emergency Response Organization and Emergency Response Facility Activation

2.2.1 Recommendation

3, Clearly define emergency response facility activation criteria 2.2.2 Recommendation 3.c., Develop a process for filling vacant ERO positions with other plant staff members 2.3 EPTSC-00, Activation and Operation of the Technical Support Center 2.4 EPCLA-01, Emergency Control 2.5 EPTSC-03, Emergency Repair Director 2.6 EPOSC-04, Emergency Work Control 2.7 EPSPA-01, Evacuation and Accountability 2.8 EPSPA-03, Administration of Potassium Iodide 2.9 EPSPA-05, Unified Incident Command

3.0 RESPONSIBILITIES

3.1 Maintain command AND control of the Technical Support Center (TSC), the onsite activities, AND response to the emergency.

3.2 Classify, terminate, OR downgrade the emergency using the Emergency Action Level (EALs) Matrices and EPCLA-01, Emergency Control.

3.3 Provide guidance for AND approve communications regarding the emergency with the Nuclear Regulatory Commission (NRC).

3.4 Authorize planned radiation exposures in excess of routine yearly exposure limits for lifesaving OR equipment repair missions.

3.5 Coordinate with the Emergency Repair Director (ER D) in assigning priorities for missions. Ensure any potential repair issues are documented, using electronic or handwritten logs. Potential missions, even if deferred, should be listed on the logs.

EPTSC-01 Rev. 19 Page 5 of 11 4.0 PREREQUISITES N/A 5.0 PRECAUTIONS AND LIMITATIONS 5.1 If electronic logging is unavailable, then paper logs and paper/whiteboard status board(s) shall be maintained. 6.0 SPECIAL TOOLS AND EQUIPMENT N/A 7.0 ACCEPTANCE CRITERIA N/A 8.0 IN STRUCTIONS NOTE: Attachment 10.1, Site Emergency Coordinator (SEC) Quick Start Guide, contains a summary of responsibilities/tasks associated with ERO position (attachment information does not replace the procedure steps).

NOTE: The TSC is responsible for emergency classification AND NRC communications after activation. NOTE: PA announcements and initiation of ERDS will remain the responsibility of the Control Room SEC/Shift Manager even after turnover. 8.1 DIRECT the TSC staff to prepare for activation.

Activation staffing and functional staffing requirements are shown on the TSC Staffing Requirements/Overflow Roster in EPTSC-00, Activation and Operation of the Technical Support Center.

8.2 In order to relieve the Control Room of NRC communication activities, the SEC AND the NRC Emergency Communicator can assume and conduct communication activities from the TSC prior to full facility activation, after receiving turnover from the SEC

-Control Room and Emergency Communicator

-Control Room, if staffing is available. [IER L2 11-39, Rec. 3]

EPTSC-01 Rev. 19 Page 6 of 11 8.3 CONTACT the SEC/ Shift Manager and get a briefing for turnover. 8.3.1 UTILIZE EPCLA-01, Attachment 10.

3 , and Turnover Checklist for this briefing. 8.4 BRIEF the TSC staff regarding turnover, if not performed on speaker phone OR video. NOTE: Activation of the TSC is implemented following turnover from the Control Room SEC.

8.5 WHEN a position required for activation is not filled, a supervisory position may fulfill the responsibilities provided they are trained to perform the assigned activities of the position. [IER L2 11-39, Rec. 3.c.]

8.6 WHEN required staffing is in place, ACTIVATE the TSC. 8.7 PRIORITIZE/ESTABLISH strategies to prevent/limit core damage AND prevent OR terminate any unintended environmental release associated with the emergency. 8.8 APPROVE deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachment or EPCLA

-01, Emergency Control. 8.9 Continuously MONITOR AND REVIEW the Emergency Action Level (EAL) Matrices to determine changes in the emergency classification.

8.10 ADVISE TSC staff regarding: 8.10.1 Eating AND drinking requirements 8.10.2 Use of 3-way communications 8.10.3 No talking over team members and restricted use of phones during briefs. 8.10.4 Time activation is required to support 75 minute limit.

8.10.5 Ensure logs contain all details of key decisions and supporting information such that the current event and responses could be recreated from their logs. 8.11 ANNOU N CE, in the TSC

, any significant changes in plant or emergency conditions, as soon as possible.

8.11.1 ENSURE that the Emergency Operations Facility (EOF), Control Room, and Operational Support Center (OSC) are made aware of the significant changes in plant or emergency conditions.

EPTSC-01 Rev. 19 Page 7 of 11 8.12 INITIATE subsequent facility briefings. (30

-60 minute time frame) 8.12.1 COORDINATE briefings with EOF, CR, AND OSC staff to preclude unnecessary interruptions.

8.13 REQUEST personnel accountability for personnel reporting to the EOF from the Administration & Logistics Manager (A

&LM). 8.14 IF an Alert has been declared AND an emergency assembly has been requested or initiated, THEN DIRECT the Emergency Security Team Leader (ESTL) to initiate a preliminary personnel accountability check. This will expedite the accountability process in the event of a site evacuation, if not already required.

8.15 APPROVE administration of potassium iodide (KI) to onsite emergency response personnel, as appropriate.

8.15.1 Radiation Control staff will make recommendations based on guidance in EPSPA-03, Administration of Potassium Iodide.

8.16 APPROVE planned personnel radiation exposures > 5 REM whole body OR entries into areas > 100 Rem/hr when needed for equipment repair / reentry OR li fe saving efforts. 8.17 REFER to EPOSC-04, Emergency Work Control, for guidance on emergency worker dose limits and exposure guidelines. 8.18 APPROVE , when requested, relocation/evacuation of the OSC to the Training Building. 8.18.1 ANNOUNCE to the TSC and EOF that the OSC is relocating to the Training Building. 8.19 IF TSC relocation is required from the TSC to the Remote Emergency Response Facility (RERF) THEN ensure that critical functions of emergency classification and NRC communications continue during transition from the TSC to RERF.

8.19.1 Individuals supporting these functions may remain at the TSC until relieved by personnel in the RERF or the functions may be performed by the Main Control Room.

8.20 CONFER with the ERM frequently to ensure continuity of operations, response, AND information.

8.21 ENSURE plant entries are tracked, if the OSC is relocated and during the Recovery Phase of an event. 8.22 For sheltering or evacuation, REFER to EPSPA-01, "Evacuation and Accountability."

EPTSC-01 Rev. 19 Page 8 of 11 8.23 IF the need arises for a plant announcement to be made, THEN CONTACT the Unit 2 Control Room.

8.24 IDENTIFY additional equipment and manpower resources needed to support emergency response.

8.24.1 REQUEST resources through the Admin and Logistics Manager in the EOF. (Electronic Resource Request may be used.)

8.25 IF an Incident Command Post has been activated, REFER to Attachment 10.2 , "Site Emergency Coordinator (SEC) Incident Command Post Interface Quick Start Guide."

9.0 RECORDS 9.1 Records generated during a declared emergency should be forwarded to the Emergency Preparedness Unit.

10.0 ATTACHMENTS 10.1 Site Emergency Coordinator (SEC) Quick

-Start Guide 10.2 Site Emergency Coordinator (SEC) Incident Command Post Interface Quick Start Guide ATTACHMENT 10.1 Page 1 of 2 EPTSC-01 Rev. 19 Page 9 of 11 SITE EMERGENCY COORDINATOR (SEC) QUICK-START GUIDE NOTE: Blanks are provided for place keeping only; logs are the official record. This is a summary level guide and does not replace the procedure steps.

1. SIGN IN on Facility Sign

-In Board and the TSC Staffing Requirements/Overflow Roster. Announce your name and title.

LOG into electronic logging for access to status board and logs.

_____ NOTE: The Site Emergency Coordinator and the NRC Emergency Communicator (EC) can assume AND conduct NRC communication activities from the Technical Support Center to relieve the Control Room prior to facility activation after receiving turnover from the Control Room SEC.

NOTE: Full Activation of the TSC can occur when minimum TSC staffing is met AND turnover from the Control Room SEC is complete. NOTE: When a position required for activation is not filled, a supervisory position may fulfill the responsibilities provided they are trained to perform the assigned activities of the position. [IER L2 11-39, Rec. 3.c.]

2. VERIFY TSC staffing AND resources available to prepare for facility activation. _____ 3. REVIEW Emergency Notification Forms AND press releases issued.

_____ 4. ACTIVATE the TSC within 75 minutes of ERO notification.

_____ 5. REVIEW Nuclear Regulatory Commission (NRC) Event Notification Worksheets issued.

_____ 6. DIRECT staff to prepare for initial plant status briefing.

_____ 7. COORDINATE with CR, OSC and EOF to receive initial Plant Status briefing.

_____ 8. OBTAIN initial plant status briefing from the Control Room (CR) using the turnover attachment in EPCLA-01, Emergency Control. _____

ATTACHMENT 10.1 Page 2 of 2 EPTSC-01 Rev. 19 Page 10 of 11 SITE EMERGENCY COORDINATOR (SEC) QUICK

-START GUIDE

9. ACTIVATE the TSC as soon as minimum staffing is reached

minimum required staffing personnel declare that they are ready to activate; and turnover from the Control Room has been completed. _____ Time activated

_______

10. DIRECT radiation control activities, until the arrival of the Radiological Control Director (RCD).

_____ 11. APPROVE deviations from normal work processes as appropriate per AD-OP-ALL-1000, Conduct of Operations, Deviation from Normal Work Processes / Requirements Documentation attachment or EPCLA-01, Emergency Control. _____ 12. REFER to EPCLA-01, Emergency Control, for specific instructions to upgrade OR downgrade the emergency.

_____ 13. ESTABLISH a briefing schedule with facility staff AND the EOF. _____ 14. ENSURE TSC extended schedules are completed and provided to the A&LM within two hours of activation. (Time sensitive)

_____ 15. EVALUATE needed resources.

16. REFER to Attachment 10.2 if ICP is activated. _____ 17. REFER to procedure steps.

_____

ATTACHMENT 10.2 Page 1 of 1 EPTSC-01 Rev. 19 Page 11 of 11 SITE EMERGENCY COORDINATOR (SEC) INCIDENT COMMAND POST INTERFACE QUICK-START GUIDE NOTE: This is a summary level guide and will only apply when confirmation that the Incident Command Post (ICP) has been activated.

IF the Incident Command Post (ICP) is activated:

1. DISPATCH Security, Operations and Radiation Protection liaison to ICP, if not already completed.

_____ 2. MAINTAIN communications with the RNP Liaisons at the ICP.

_____ Consider bridging the ICP Operations liaison into the Intra

-facility briefs.

3. MAINTAIN awareness of both RNP and offsite agency resources available from the ICP. _____ 4. ENSURE RNP Liaisons at the ICP are informed of communications systems to be used, changes in plant status (including security status), site protective measures, damage control and casualty care priorities, and resource needs. _____ 5. IF assistance from the ICP is required, THEN INFORM RNP Liaisons of required resources, mission objectives and location, time constraints, hazards, and required site access controls and safety measures. _____ 6. ENSURE ESTL is informed of any requests for personnel to report to, leave, or move about the site. _____ 7. MAINTAIN accountability of offsite teams dispatched to locations inside the owner controlled area (OCA). _____ 8. REQUEST updates from RNP Liaisons regarding law enforcement requirements for on

-site crime scene preservation. _____