The inspectors identified a Green
NCV of Title 10 of the Code of Federal Regulations (CFR), Part 50.47(b)(16), for the licensees failure to maintain the effectiveness of its
emergency plan by ensuring procedures for use by the emergency response organization are maintained and up-to-date. Specifically, responsibilities for
emergency plan implementing procedure distribution were not adequately maintained in multiple emergency response facilities because the procedures were not of the correct revision and may have been used had an emergency been declared. After the NRC inspectors informed the licensee of the discrepancy, the licensee entered the issue into their
CAP as action request (
AR) 01959550. The licensees immediate corrective actions were to perform an extent of condition review of all site
EP procedures, including the corporate office and the other legacy Duke sites, and replace the procedures with the correct revision. The licensees failure to adequately maintain controlled procedures in the emergency response facilities was a performance deficiency. The inspectors determined that the performance deficiency was more than minor because the performance deficiency was associated with the procedure quality attribute of the
emergency preparedness (
EP) cornerstone and adversely affected the associated cornerstone objective. The finding was evaluated using the
EP significance determination process and was identified as having very low safety significance because it was a failure to comply with NRC requirements and was not a loss of the planning standard function. The finding was associated with a cross-cutting aspect in the documentation component of the human performance area because the licensee failed to maintain complete, accurate, and up-to-date documentation.
