CNS-18-022, Submittal of Emergency Plan Implementing Procedure

From kanterella
Jump to navigation Jump to search
Submittal of Emergency Plan Implementing Procedure
ML18107A029
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 04/12/2018
From: Simril T
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CNS-18-022
Download: ML18107A029 (25)
v • d • e


Text

Tom Simril

(_~ DUKE Vice President ENERGY. Catawba Nuclear Station Duke Energy CN01VP 14800 Concord Road York, SC 29745 o: 803.701.3340

t. 803.701 .3221 tom .simril@duke-energy.com CNS-18-022 10CFR 50.54(q)

April 12, 2018 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC Catawba Nuclear Station Units 1 and 2 Docket Nos. 50-413 and 50-414 Emergency Plan Implementing Procedure Please find enclosed for NRC Staff use the following 10CFR 50.54(q) Evaluation for Catawba Nuclear Station, Emergency Plan Implementing Procedure (EPIP) Revision:

RP/0/A/5000/002 Notification of Unusual Event Revision 048 RP/O/A/5000/003 Alert Revision 053 RP/0/A/5000/004 Site Area Emergency Revision 056 RP/0/A/5000/005 General Emergency Revision 059 This revision evaluation is being submitted in accordance with 10CFR 50.54(q) and does not cause a reduction in the effectiveness of the Emergency Plan Implementing Procedures or the Emergency Plan.

There are no new regulatory commitments in this document. By copy of this letter, two copies of this document are being provided to the NRC, Region II.

If there are any questions, please contact Tom Arlow at 803-701 -4027.

Sincerely,

r~ ~

Tom Simril Vice President, Catawba Nuclear Station Attachment www .duke-energy .com

Catawba Nuclear Station CNS-18-022 April 12, 2018 Page 2 xc (w/attachment):

Catherine Haney, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 (w/o attachment):

Michael Mahoney NRG Project Manager (CNS)

U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 0881A 11555 Rockville Pike Rockville, MD 20852-2738 Joseph D. Austin NRG Senior Resident Inspector (CNS)

Catawba Nuclear Station CNS-18-022 April 12, 2018 Page 3 bxc (w/o attachment):

North Carolina Municipal Power Agency Number 1 P. 0. Box 29513 Raleigh, NC 27626-0513 North Carolina Electric Membership Corporation Power Supply Division P. 0 . Box 27306 Raleigh, NC 27611-7306 Piedmont Municipal Power Agency 121 Village Drive Greer, SC 29651 T. A. Arlow, CN01EP C. A. Fletcher, CN01 RC C. A. Moore, EC04C RGC Licensing File, CN01 RC Electronic Licensing Library, EC2ZF CN-750.25, CN04DM

ATTACHMENT Catawba Nuclear Station 10CFR 50.54(q) Evaluation For RP/O/A/5000/002 Notification of Unusual Event Revision 048 RP/O/A/5000/003 Alert Revision 053 RP/0/A/5000/004 Site Area Emergency Revision 056 RP/O/A/5000/005 General Emergency Revision 059

f DUKE Duke Energy

" ENERGY. ACTION REQUEST- 02182185 ASSIGNMENT NBR - 02 IAction Request Assignment Details ARNUMBER :02182185 ASSIGNMENTNUMBER :02 Type  : EP02 Due Date  : 02/08/2018 Pri Resp Fae Status  : COMPLETE Reschedule :0 Pri Resp Group Assigned To  : ERNESTINE M KUHR Sec Resp Fae Subject  : CNS 50.54(Q) EVALUATION RP-001 Enabler (OSDA to OPS) Sec Resp Group Aff Facility  : CN Unit System UCR Schedule Ref Organization Department  : 44279 Discipline Est Manhrs :O Est Comp Date Description COMPLETE 50.54(0) EVALUATION IN ACCORDANCE WITH AD-EP-ALL- 0602.

Action Request Assignment Completion Notes IAction Request Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 02/05/2018 EMK7353 INPROG 02/05/2018 144004 02/08/2018 02/05/2018 144004 NTFY/ASG 02/05/2018 EMK7353 ACC/ASG 02/07/2018 EMK7353 AWAIT/C 02/08/2018 E39701 ACC/ASG 02/08/2018 EMK7353 AWAIT/C 02/12/2018 TAA7322 COMPLETE Action Request Assignment Routing/Return Comments Routing Comments from the X601 Panel Updated On Updated By Update the change description 20180208 EMK7353 Routing Comments from the X602 Panel Updated On Updated By

      • No Return Comments Found ***

\Printed 03/28/2018 Page :1

,( DUKE Duke Energy

"' ENERGY. ACTION REQUEST - 02182185 ASSIGNMENT NBR - 02 Action Request Assignment Completion Approval Route List  : 001 Route List Initiator :EMK7353 Send Send Action Action Passport Fae Group I Type Date Time Taken Date I Time Last Name TAA7322 A 02/08/2018 1340 APPROVED 02/12/2018 1257 ARLOW E39701 A 02/07/2018 1654 RETURNED 02/08/2018 1109 WHITE E39701 A 02/08/2018 1137 APPROVED 02/08/2018 1340 WHITE IAction Request Assignment Cause/Action Action Request Assignment Reference Documents Doc Sub Minor Facility Type Type Document Sheet Rev Rev Title Action Request Assignment Reference Equipment Equip Equip Equip Equip Rev Facility Unit System Type Number Tag Status Rev Status I Action Request Assignment Cross References Ref Ref Ref RefNbr Limit Type Nbr Sub Type Status AS Cls Description IAction Request Assignment Appendices APPENDIX 1 p rinted 03/28/2018 Page :2

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev.4 ATTACHMENT 5 Page 1 of 15

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

Screening and Evaluation Number Applicable Sites BNP D EREG #: 02182185 CNS 18:l CR3 D HNP D MNS D 5AD # 02179103 ONS D RNP D GO D Document and Revision Transfer On-Shift Dose Assessment to Operations DNA Organization Optimization Enabler RP-001 (NTM 02094399-33)

CNS Emergency Plan Section B (ORR 02160999)

Part I. Description of Proposed Change:

Transfer responsibility for on-shift dose assessment from an RP Qualified Individual to a Dose Assessment Qualified Individual having no collateral emergency plan duties prior to augmentation of onshift staff.

Change CNS Emergency Plan Section 8 .5, last sentence from "See CNS-OSSA-12212012, Rev. O." to "See CNS-OSSA-12212012, Rev. 0 and AR 02182185-02."

Change CNS Emergency Plan Section B, Figure B-1a (Page B-7), Item 4 - Functional Area of Radiological Assessment, Major Task of Dose Assessment. Change from "RP Qualified Individual" to "Dose Assessment Qualified Individual." , 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes D Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change) No 18:l Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

Four Emergency Planning Standards have been identified for this change:

  • 10 CFR 50.47(b)(15) Emergency Responder Training The licensing bases for each of these Planning Standards, as stated in the original NRC approved Emergency Plan, (Revision 2, January 1983) and the current Emergency Plan (revisions vary), are identified below. Additional licensing basis documents reviewed include the Safety Evaluation Report (SER), July 29, 2011 , and the On-Shift Staffing Analysis, CNS-OSSA-12212012 performed in accordance with Emergency Planning Rulemaking in 2011 .

p rinted 03/28/2018 Page 3

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 4 ATTACHMENT 5 Page 2 of 15

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

Assignment of Responsibility Approved Emergency Plan Catawba Nuclear Station Emergency Plan (Revision 2, January 1983)

Section A.1 .c Block Diagram of Organization Interrelationships (See CMP}

Current Emergency Plan Catawba Nuclear Station Emergency Plan, Section A (Revision 150, September 2017)

Section A.1.c Block Diagram of Organization Interrelationships "See Table B-1a and B1b and Figures B- 1, B-2, B-3, B-4, B-5a and B-5b."

Onsite Emergency Organization Approved Emergency Plan Catawba Nuclear Station Emergency Plan (Revision 2, January 1983) 8.5 Minimum Staffing Requirements "The positions, title and major tasks to be performed by the persons assigned to the functional areas of emergency activity at the station are described below. These assignments shall cover the emergency functions in Figure B-1 . The minimum on-shift staffing are as indicated in Figure B-1 ...

.. . The Station Health Physicist shall provide for the calculation and distribution of off-site dose determinations for releases of radioactive materials to the atmosphere."

Figure B-1, Catawba Nuclear Station Minimum Staffing Requirements for Emergencies f>rinted 03/28/2018 Page 4

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 4 ATTACHMENT 5 Page 3 of 15

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

{'AIAWl\A !htC L[A.H &fAl H)N t!lt~H1HM: SlAH IWL!!fqtJIBfNHHS FOR f1,tfft.t'";fM , ,  :-s to,;.itinn. 1~tlc Of lxp<:tt.i~t:

tm S! ~!°ft l :ap a h , 1 i t. Y for* Add~ t i ons l1!J 11,tJI

/.i, IOIP Pl ~ nt {Jp t!rAti rm~ ~ml /\!."i('"i!-i ...  !~l* 1t.. !:i1 1pe t v1 ~rn,* (~HO }

i:Jnwt or Op <.:- r tit i ~na I ,*hpcc:t !> At.t.t. Sl - 1 f t S%. *ptH'Vl ':>& I' t S!H), I contnH Ho1y 1 {)J;i~r.'.I tors ( rw) 2 AH ** i t ~f!if'Y Op-H-! ~tors <'

fmnrgen cy 01 rcc, to11 2ir td Off .. !:,ltl.1 COl:Ll~mi- 'Shift Tut.tlll'CJI AtJ:v,iup 1{ l J Cn11t.ruf (fm1*!9cm ;y (?) c<1t iu1 , t> 'ihllt Su;, ~nnr,tH nr Cor.>r:d:1:.1tor't D1~~ , ,;1mt...iH! Fvci Ii LY ~t1n.t<, *H 1 Untj1"1 ('i'Jtir,n/ tht I ' )' f if~Ullhl:l:~ Or,:i~1 t1t1tm:-i ~01 ~.>n Cor.1r,,u1r;:..',1 t i o 11 ( l) 'S ~.*1 L~, ~ c){:t\ I ;)IHI rv~:~r;1! p~.rs:m n-1/ t It fl:<} i fl tt, J H (;011 ~!'I.hi I -

cat10n n,H110!0.*1 , ~;1 1 A~*cr~en t A5;jt! .S. 'S - C !' ~-:, 1 5 f-l<i, l!iJgl i J>lC:~rl !. l{l t l r WH. an-d Si,ppH l or Cp L' ~ .:Jt it~ P4 I Cc~!t..:-1 ~ Cl,tCJ

,\cc , tlcn t A:."!:O'id'.i 1Hlt1t Off~ i UJ i}(a6C ~fl'liHH" tlf! {I) Ul Pti y s i c~

,i.\r.!h~"\f,f"f*Hl (i!i'J fxpert i$e I urr ... ite Survuys 2 Ori~J tf' l .C1 , t - flf - l p I rmt)

IU .. fllilrtf,  :.;:U{V\1.,1~ HI ' T1te h -~! 1; 1,1n ~;

ChC!r f ~t i"y/f~.1 1.$~ 0 - C.. h ?>mislt:)' JP:c tlr1 , ~1~n~

._;lte.
<1, i *-l 1 ~,

P i .lnl !:>y r;te: m {;13 nP~ r in9* ltt["hn it' -1' I Sl~ppo, t S!.ift H* ChrliCOI AU....- , sc r R~},a l r and Ct>rnH.:tlvt! ,'\t.*t i 011 !:i co, c /!hes ,n-al t i vO,~tAf i.G-!:<

l.1.f!CH tr itl -  !

1kc}1,1n11:a1 1 R1~1>~1 i r u rn.l t,1 uuh,1nical Mc1i11tur1.ancC"JR,.*d l( l l 1

{:oru*rt i ve ~u, ..,ti"' np~1nu-~r I ACLJJJfl~ t i.,.,:t1 i icaf H~i r tem1m.n/ 1 [1 J 1(5) ft1strnr.:tmt Oi<d Guntn, I

( l&E.t ft<Cl)1,q:; i JO f !GUHf A- I fCotl l. !

iiev . ;>

il - lll Jau , 19,83 Current Emergency Plan Section 8 - Site Emergency Organization (Revision 163, September 2017) 8.5 Minimum Staffing Requirements "The positions, title and major tasks to be performed by the persons assigned to the functional areas of emergency activity at the station are described in Emergency Plan Implementing Procedures. These assignments shall cover the emergency functions in Figure 8-1 (a and b ).

The minimum on-shift staffing reflective of two units in operation is as indicated in Figure 8-1a ...

...A detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in Figure 8-1a. See CNS-OSSA-12212012 Rev: O."

Figure 8-1a, Catawba Nuclear Station Minimum On-Shift ERO Staffing Requirements for Emergencies p rinted 03/28/2018 Page 5

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev.4 ATTACHMENT 5 Page 4 of 15

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

T.-\BLE B-la CATA\\13*.\ :\"UCLEAR <;TATIOK

\JI:\"ThlDI o:,;.smn ERO ST..\FFD;G REQt1REl\,IE~T5 FOR El\IERGE);CIES Functional Area ll:1jor Tasks E mergency Positions Unit Supen~,or (SRO) l
1. Plant Operation; and CR Supermor (5RO) l As~s'illltn1 of Ope1:at1011.1l Aspec~ la)

Control Roo,n Opttotor (RO) 3 Auxihary Operator (AO) 3 2 &uerge-uq Du ect1011 and Co1lllll3ud and ( outtol Op~rauons 5hifi: ~fauager Control Licoi!See Operator ($RO RO/:\"I.O) l '* '

3 !'iot1ficat1on &

Couunurucat1on L ocal '>tat< ~ ~(SRO R0-~'1.0) *- - - ~ 11b' Fed<ral Opor.itor (5RO RO ~'LO) Itbl Do-:.e Assf'~Yn~ut ln-plant Survey, Onsitf' ~ttrYe)'~

C'heU11strv Tech Support - OP, RP Quahf1e-d Individual RP Quahfied lnd1vidu.,l

~ Qu.'Uifted Ind1v1du.1l _ ___

Chenustrv TeclwicL'\11 Sluft T eduucol Adv1Sor

  • -=
  • - - - - 1 1
5. Plant S:n,t~m

- Core Damage ~hift I e-ci;uucal Ad":!!2!..-~= 1~b Engmee-iwg. Repatr. and Rq,air and C'orrectn:e ~1echanical :M:ainteu.ance 1 Con*C'ctn:~ Ac:noru Achoo.~ IAE ~{aintenao.ce 2 Radrntaon Ptotecbon (c;nch ai acce;; control. job

6. In-Plant PA, RP Qualified lndin<l,~,l coverage- and ~r~onud m ouitonog)

Fue Br igade Lead (RO SR0 -~ 0)

7. Fire- F1ghtmg (c) Fire B,'i8ade :-.tember (NLO)

Fire Brigade !\,lember (SPOC) 8 . l '1 A1d and Resa1e '.\1£RT (d) 9 . Site Acct-5>> Control and i>ecucuy & Accouutabihty $AS OperatoJ° Accmu1tab1hty SecmityPerc;ound (e)

~linimum # of Per~ounel : 23 (a) The Control R oow !>t.1ff cowplemt.nt .1; rdlectn*e of.:! Cwts m oper:mon w accordance with §50 54tm)

(bJ Ma\' be performed by nn wdtndual ftlluig another po; mon prov1dt-d they are quahfied to do the collaternl function.

tc) The Fu-e-Brigack 1*eqmremeut of fiv e membet"o:. n tnet by u,;,uig: three ~rsolllld from Operation-. (wdud111g the Fire Brigade Leader) and two pmounel from SPOC (',LC 1613-1).

/d) The '.\.fed,cal Emergency Response Team t'.\.IERT) can be filled by any quohfi<d techniaan

(<) Per D 11k < Euergy 01:i Security Plan CNS On Shift Staffing Analysis, CNS-OSSA-12212012 CNS On Shift Staffing Analysis, CNS-OSSA-12212012, was performed using the standard on-shift staffing of three RP Qualified Individuals, performing the functions of In-Plant Surveys, Out of Plant Surveys and Dose Assessment.

Emergency Assessment Capability Approved Plan Catawba Nuclear Station Emergency Plan (Revision 2, January 1983) l.3.a/1.3.b Method For Determining Release Source Term Catawba Nuclear Station procedures HP/0/8/1009/04/06/07/12/13/14/15 are used in the TSC and/or CMC for the calculation of potential offsite doses based on a Design Basis Accident, release of primary coolant, or release of GAP activity situation scaled to actual containment monitor readings. Provisions for use of actual source terms exist in the procedures. The magnitude of the release is based on actual effluent monitoring readings, plant system parameters (containment pressure), area meteorology and the duration of the release.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.4 ATTACHMENT 5 Page 5 of 15

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

The procedures referenced in l.3.a/1.3.b establish the relationship between effluent monitor readings and on site/off site exposures and contamination for various meteorological conditions.

Current Plan Catawba Nuclear Station Emergency Plan (Revision 147, September 2017) l.3.a/1.3.b Method For Determining Release Source Term Procedures AD-EP-ALL-0203, AD-EP-CNS-0202 [sic] , HP/0/8 /1009/006, HP/0/8/1009/007, HP/0/8/1009/014, and AD-EP-ALL-0202 are used on-shift, in the TSC and/or EOF for the calculation of potential off-site doses based on a Design Basis Accident, release of primary coolant, or release of GAP activity situation scaled to actual containment monitor readings. Provisions for use of actual source terms exist in the procedures. The magnitude of the release is based on actual effluent monitoring readings, plant system parameters (containment pressure), area meteorology and the duration of the release.

1.4 Effluent Monitor Readings Vs On-site/Off-site Exposure The procedures referenced in l.3.a/1.3.b establish the relationship between effluent monitor readings and on-site/off-site exposures and contamination for various meteorological conditions.

Emergency Responder Training Approved Emergency Plan Catawba Nuclear Station Emergency Plan (Revision 2, January 1983) 0 .2 Onsite Organization Training The training program for members of the onsite emergency organization is outlined in Figure 0-2. A practice drill session will be held for each group within the organization to allow the individuals to perform their assigned functions. The drill instructor will make on the spot corrections and/or demonstration of the proper performance.

0.4 Training For Radiological Emergency Response Personnel Training of the following groups will be necessary to insure that all organizations and responding agencies are kept current on Catawba Nuclear Station's Emergency Plan. The Emergency Preparedness Coordinator, Health Physics Section and the Training and Safety Section will provide training to the following groups:

...b. Personnel Responsible for Accident Assessment...

Current Emergency Plan Catawba Emergency Plan (Rev 144, dated September 2017) 0 .2 Emergency Organization Training 0 .2.a. The training program for members of the Emergency Organization is outlined in AD-EP-ALL-0500.

Training objectives and lesson plans are maintained in the site training files. Prior to inclusion in the Emergency Organization, all individuals must satisfy training requirements for his/her position as outlined in AD-EP-ALL-0500.

0.2.d. A practice drill session may be held to allow the individuals to perform their assigned functions (See PT/0/8 /4600/006 Emergency Exercises and Drills). The drill instructor may make on the spot corrections and/or Pdntednstrati0!3/CUlfMt8uper performance. Pa11e : 7 I

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev.4 ATTACHMENT 5 Page 6 of 15

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

0.4 Training For Radiological Emergency Response Personnel Training requirements for the following groups are described in EP Group Manual 5.4.1 and AD-EP-ALL-0500.

Training objectives and lesson plans are maintained in training files .

...b. Personnel Responsible for Radiological Assessment...

US NRC Letter, Catawba Nuclear Station, Units 1 and 2, McGuire Nuclear Station, Units 1 and 2, And Oconee Nuclear Station, Units 1, 2, and 3, Issuance Of Amendments Regarding Changes to the Emergency Plans (TAC NOS. ME4446, ME4447, ME4448, ME4449, ME4450, ME4451 , and ME4452), dated July 29, 2011, - Safety Evaluation Excerpts from the Safety Evaluation

3.0 TECHNICAL EVALUATION

3.1 Increase the response time requirement for the TSC Dose Assessor from 45 minutes to 75 minutes Each site has three RP qualified individuals minimum per shift. One RP qualified individual is assigned to on-shift dose assessment and two RP qualified individuals are currently available to support other emergency response actions as described in the emergency plans for each site, which is in excess of on-shift RP staffing identified in Table B-1 of NUREG-0654 .

... In automatic mode, the RADDOSE program will automatically populate current meteorological data into the program and produce reports as described above. The manual mode does require the data to be entered manually and the process repeated each time an assessment is run, but due to the increased staffing of RP personnel on-shift, one RP qualified personnel is dedicated to this one task. The other two RP qualified personnel are available for other RP tasks which allows for the increase in augmentation time of the TSC Dose Assessor.

3.4 Change RP staffing during emergency response events from RP Technicians to RP qualified individuals.

. . . RP qualified individuals can include RP supervisors and RP staff who routinely administer RP programs, policies and procedures. Based on their training and experience, these individuals maintain the level of knowledge required to perform the tasks described on Figure B-8 (Oconee) and Figure B-1 (Catawba and McGuire).

The licensee stated in the March 3, 2011 , supplemental letter that the Catawba, McGuire and Oconee, RP supervisors and staff personnel participate in the same training as the RP qualified individuals. RP supervisors and staff personnel who have task qualification must maintain the same training qualifications and requalification as the RP qualified individuals. ERO task requalification is covered in RP continuing training at least every 2 years.

The on-shift minimum staffing levels referenced in Figure B-8 (Oconee) and Figure B-1 (Catawba and McGuire),

specify whether other personnel on-shift would be able to perform the RP functions in the "Major Functional Area of Protective Actions (In-plant)" (Oconee) and "Major Functional Area of Radiological Support and Protective Actions" (Catawba and McGuire). The licensee stated in the March 3, 2011 , letter that no other personnel on-shift will be assigned those ERO duties - only RP qualified individuals.

The differences in NRG approved revisions and the current revisions of the Emergency Plans have been reviewed and they have been determined to meet the regulatory requirements required during the course of revisions. Each revision has been evaluated in the inspection process by the NRG.

p rinted  : 03/28/2018 Page  : 8

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 4 ATTACHMENT 5 Page 7 of 15

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

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):

10 CFR 50.47(b)(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

10 CFR Part 50 Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section IV.A Organization states:

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:

1. A description of the normal plant operating organization.
2. A description of the onsite emergency response organization (ERO) with a detailed discussion of:
a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;
b. Plant staff emergency assignments;
c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.
4. Identification, by position and function to be performed, of persons within the licensee organization who will be responsible for making offsite dose projections, and a description of how these projections will be made and the results transmitted to State and local authorities, NRC, and other appropriate governmental entities.

10 CFR 50.47(b)(2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the interfaces among various onsite response activities and offsite support and response activities are specified.

10 CFR Part 50 Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section IV.A Organization states:

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:

1. A description of the normal plant operating organization.
2. A description of the onsite emergency response organization (ERO) with a detailed discussion of:
a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;
b. Plant staff emergency assiqnments; r nntea : U::.S/.!tl/LU 11:S t"8Q8 9 I

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 4 ATTACHMENT 5 Page 8 of 15

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

c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.
4. Identification, by position and function to be performed, of persons within the licensee organization who will be responsible for making offsite dose projections, and a description of how these projections will be made and the results transmitted to State and local authorities, NRC, and other appropriate governmental entities.
9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

10 CFR Part 50 Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section IV.C, Activation of Emergency Organization states:

1. The entire spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described. The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described. Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on read ings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described.

The existence, but not the details, of a message authentication scheme shall be noted for such agencies.

The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG- 0654/FEMA-REP- 1.

2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.

Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.

10 CFR 50.47(b)(9) Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

10 CFR Part 50 Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section IV.B, Assessment Actions and E.2 Emergency Facilities and Equipment state:

Appendix E to 10 CFR Part 50, Section IV.Band IV.E.2 B. 1. The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power acmr ,ese acuon 1eve1s musl mc,uae nosme acuon mal may aaverse1v a, m1c11o

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 4 ATTACHMENT 5 Page 9 of 15

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

power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC. Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis.

E.2 Equipment for determining the magnitude of and for continuously assessing the impact of the release of radioactive materials to the environment; 10 CFR 50.47(b)(15) Radiological emergency response training is provided to those who may be called on to assist in an emergency.

10 CFR Part 50 Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section IV.F Training states:

1. The program to provide for: (a) The training of employees and exercising, by periodic drills, of emergency plans to ensure that employees of the licensee are familiar with their specific emergency response duties, and (b) The participation in the training and drills by other persons whose assistance may be needed in the event of a radiological emergency shall be described. This shall include a description of specialized initial training and periodic retraining programs to be provided to each of the following categories of emergency personnel:

... ii. Personnel responsible for accident assessment, including control room shift personnel; Regulatory Compliance Assessment On-shift dose assessment responsibilities will continue to be defined. The CNS Emergency Plan, as revised, will require one Dose Assessment Qualified Individual be assigned on-shift to perform dose assessments, providing input to the PAR decision-maker, until relieved by a Dose Assessor in the TSC or EOF. On-shift dose assessment results will continue to be transmitted by Control Room personnel to the State and local authorities using the Emergency Notification Form (ENF) and to the NRC using the Event Notification Report. The Dose Assessment Qualified Individual will have no collateral ERO duties, which ensures that this EP function can be performed when needed without any additional competing priorities.

The CNS On-Shift Staffing Analysis (OSSA) was evaluated for the transfer of responsibility for on-shift dose assessment from an RP Qualified Individual to a Dose Assessment Qualified Individual having no collateral Emergency Plan duties prior to augmentation of on-shift staff. Of the events listed in the CNS OSSA, the following two events were noted to be impacted due to a change in a position performing functions/tasks:

  • Event 6 - Steam Generator Tube Rupture These two events (Event 4 - Reactor Coolant Pump Shaft Break, and Event 6 - Steam Generator Tube Rupture) were evaluated for an overlap or delay in performing functions/tasks. Results of the evaluation concluded that the remaining two RP Qualified Individuals could perform the necessary functions/tasks for the events without overlap of tasks, and any activity that would be delayed would not impact the response to the emergency or cause the emergency to escalate to a higher Emergency Classification Level (ECL). See Attachment 2 for detailed analysis of the OSSA. Thus, the CNS Emergency Plan will continue to comply with 10 CFR 50.47(b)(1) Assignment of Responsibility/Organizational Control, 10 CFR 50.47(b)(2), Onsite Emergency Organization, and 10 CFR Part 50 Appendix E, Section IV.A Organization.

The on-shift Dose Assessment Qualified Individuals will require training and qualifications to perform Dose A en ~- er er11

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 4 ATTACHMENT 5 Page 10 of 15

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

will continue to comply with 10 CFR 50.47(b)(9), Emergency Assessment Capability; 10 CFR Part 50 Appendix E, Section IV.B, Assessment Actions; 10 CFR Part 50 Appendix E Section IV.E.2 Emergency Facilities and Equipment; 10 CFR 50.47(b)(15) Emergency Responder Training; and 10 CFR Part 50 Appendix E, Section IV.F Training.

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):

Assignment of Responsibility Emergency Plan Planning Standard 10 CFR 50.47(b)(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Functions Two emergency planning functions have been defined for this planning standard:

(1) Responsibility for emergency response is assigned.

(2) The response organization has the staff to respond and to augment staff on a continuing basis (i.e., 24/7 support) in accordance with the emergency plan.

Element NUREG- 0654,Section II. A, Assignment of Responsibility (Organization Control) 1.b. Each organization and sub-organization having an operational role shall specify its concept of operations, and its relationship to the total effort.

1.c Each plan shall illustrate these interrelationships in a block diagram.

1.e Each organization shall provide for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day emergency response, including 24-hour per day manning of communications links.

Onsite Emergency Organization Emergency Planning Standard 10 CFR 50.47(b)(2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the interfaces among various onsite response activities and offsite support and response activities are specified.

Functions Two emergency planning functions have been defined for this planning standard:

(1) The process ensures that onshift emergency response responsibilities are staffed and assigned.

(2) The process for timely augmentation of onshift staff is established and maintained.

Program Element NUREG-0654,Section II. B, Onsite Emergency Organization 12

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 4 ATTACHMENT 5 Page 11 of 15

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

to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1 .

Table B-1 , Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies, Major Functional Area of Radiological Accident Assessment and Support of Operational Accident Assessment lists the following

  • Major Task of Offsite Dose Assessment, Positon Title or Expertise of Senior Health Physics Expertise, capable of being added in 30 minutes.

Emergency Assessment Capability Emergency Planning Standard 10 CFR 50.47(b)(9) Emergency Assessment Capability Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Function The following emergency planning function has been defined for this planning standard:

Methods, systems, and equipment for assessment of radioactive releases are in use.

Elements NUREG-0654,Section II.I , Accident Assessment

1. Each licensee shall identify plant system and effluent parameter values characteristic of a spectrum of off-normal conditions and accidents, and shall identify the plant parameter values or other information which correspond to the example initiating conditions of Appendix 1. Such parameter values and the corresponding emergency class shall be included in the appropriate facility emergency procedures. Facility emergency procedures shall specify the kinds of instruments being used and their capabilities.
2. Each licensee shall identify plant system and effluent parameter values characteristic of a spectrum of off-normal conditions and accidents, and shall identify the plant parameter values or other information which correspond to the example initiating conditions of Appendix 1. Such parameter values and the corresponding emergency class shall be included in the appropriate facility emergency procedures. Facility emergency procedures shall specify the kinds of instruments being used and their capabilities.
3. Each licensee shall establish methods and techniques to be used for determining:

3.a. the source term of releases of radioactive material within plant systems. An example is the relationship between the containment radiation monitor(s) reading(s) and radioactive material available for release from containment 3.b. the magnitude of the release of radioactive materials based on plant system parameters and effluent monitors.

4. Each licensee shall establish the relationship between effluent Monitor readings and onsite and offsite exposures and contamination for various meteorological conditions.
5. Each licensee shall have the capability of acquiring and evaluating meteorological information sufficient to meet the criteria of Appendix 2. There shall be provisions for access to meteorological information by at least the near-site Emergency Operations Facility, the Technical Support Center, the Control Room and an offsite NRC center.

The licensee shall make available to the State suitable meteorological data processing interconnections which will

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev.4 ATTACHMENT 5 Page 12 of 15

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

use this information.

6. Each licensee shall establish the methodology for determining the release rate/projected doses if the instrumentation used for assessment are offscale or inoperable.
7. Each organization shall describe the capability and resources for field monitoring within the plume exposure Emergency Planning Zone which are an intrinsic part of the concept of operations for the facility.
8. Each organization, where appropriate, shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways. This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.
10. Each organization shall establish means for relating the various measured parameters (e.g., contamination levels, water and air activity levels) to dose rates for key isotopes (i.e., those given in Table 3, page 18) and gross radioactivity measurements. Provisions shall be made for estimating integrated dose from the projected and actual dose rates and for comparing these estimates with the protective action guides. The detailed provisions shall be described in separate procedures.

Emergency Responder Training Emergency Planning Standard 10 CFR 50.47(b)(15) Radiological emergency response training is provided to those who may be called on to assist in an emergency.

Emergency Plan Function The following emergency planning function has been defined for this planning standard:

Training is provided to emergency responders.

Program Elements NUREG-0654, 11.0. Radiological Emergency Response Training

1. Each organization shall assure the training of appropriate individuals.
2. The training program for members of the onsite emergency organization shall, besides classroom training, include practical drills in which each individual demonstrates ability to perform his assigned emergency function.

During the practical drills, on-the-spot correction of erroneous performance shall be made and a demonstration of the proper performance offered by the instructor.

4. Each organization shall establish a training program for instructing and qualifying personnel who will implement radiological emergency response plans. The specialized initial training and periodic retraining programs (including the scope, nature and frequency) shall be provided in the following categories:
b. Personnel responsible for accident assessment and radiological analysis personnel;
5. Each organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities.

,nn n

IU

...-~- . 14 I

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev.4 ATTACHMENT 5 Page 13 of 15

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

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

The CNS Emergency Plan will continue to ensure that the Emergency Response Organization has the on-shift staff to respond and to augment staff on a continuing basis (24-7 staffing). The process for augmentation of onshift staff is not changing. On-shift dose assessment responsibilities will continue to be unambiguously defined . The Dose Assessment Qualified Individual assigned to perform dose assessments on-shift will have no collateral ERO duties to ensure that this EP function can be performed when needed without additional competing priorities, until relieved by the TSC or EOF Dose Assessor. On-shift dose assessment results will continue to be provided to the applicable PAR decision-maker. On-shift dose assessment results will continue to be transmitted by Control Room personnel to the State and local authorities using the Emergency Notification Form (ENF) and to the NRC using the Event Notification Report.

Two RP qualified individuals will continue to be available to support other RP emergency response tasks as described in the CNS Emergency Plan (i.e., In-Plant Surveys, Onsite Surveys, and In-Plant Protective Actions).

The CNS On-Shift Staffing Analysis (OSSA) was evaluated for the transfer of responsibility for on-shift dose assessment from a RP Qualified Individual to a Dose Assessment Qualified Individual having no collateral Emergency Plan duties prior to augmentation of on-shift staff. Of the events listed in the CNS OSSA, the following two events were noted to be impacted due to a change in a position performing functions/tasks:

  • Event 6 - Steam Generator Tube Rupture These two events (Event 4 - Reactor Coolant Pump Shaft Break, and Event 6 - Steam Generator Tube Rupture) were evaluated for a potential reduction in effectiveness due to overlap or delay in performing functions/tasks.

Results of the evaluation concluded that the remaining two RP Qualified Individuals could perform the necessary functions/tasks for the events without overlap of tasks, and any activity that would be delayed would not impact the response to the emergency or cause the emergency to escalate to a higher Emergency Classification Level (ECL).

See Attachment 2 for changes to the CNS OSSA.

Thus, there is no reduction in effectiveness of the Emergency Planning Functions of Assignment of Responsibility and Onsite Emergency Organization.

The Dose Assessment Qualified Individual will be trained using lesson plan CN-OP-Dose Assessment and qualified to RP Task CN-RP-2705 Initial Response On-Shift Dose Assessment. Attachment 1 provides a Comparison of Training Objectives between RP Task CN-RP-2705 Initial Response On-Shift Dose Assessment and CN-OP-Dose Assessment. Since the CNS Emergency Plan and ERO training program, as revised , will continue to have an on-shift Dose Assessment Qualified Individual, there is no reduction in the effectiveness of the Emergency Planning Functions of Emergency Assessment Capability and Emergency Responder Training.

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 l2Sl NoD 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes l2Sl NoD reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes l2Sl NoD 4 Choose one of the following conclusions:

p rinted 03/28/2018 Page 15

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev.4 ATIACHMENTS Page 14 of 15

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

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 IB]

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

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

Therefore, the activity cannot be implemented without prior NRC approval.

D Part VII. Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change determined to require prior NRC approval be either revised or rejected?

I DI D Yes No 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:

f rinted 03/28/2018 Page 16

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 4 ATTACHMENT 5 Page 15 of 15

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

Part VIII. Signatures: EP CFAM Final Approval is required for changes affecting risk significant planning standard 10 CFR 50.47(b)(4). If CFAM approval is NOT required , then mark the CFAM signature block as not applicable (N/A) to indicate that signature is not required.

Preparer Name (Print): Preparer Signature: Date:

Ernestine M Kuhr See CAS 02/08/18 Reviewer Name (Print): Reviewer Signature: Date:

Eric White See CAS SeeCAS Approver (EP Manager) Name (Print): Approver Signature: Date:

See CAS See CAS SeeCAS Approver (CFAM, as required) Name (Print): Approver Signature: Date:

N/A N/A N/A If the proposed activity is a change to the E-Plan or implementing procedures, then create two EREG General Assignments.

If required by Section 5.6, Submitting Reports of Changes to the NRC, then create two EREG General Assignments.

  • One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change 00 is put in effect.

QA RECORD f>rinted 03/28/2018 Page 17

Attachment 1 Comparison of Training Objectives between RP Task CN-RP-2705 Initial Response On-Shift Dose Assessment and CN-OP-Dose Assessment RP Task CN-RP-2705 CN-OP-Dose Assessment Explain the initiating conditions that would require Explain the initiating conditions that would require implementation of procedure AD-EP-ALL-0202. implementation of procedure AD-EP-ALL-0202.

Explain when URI Rapid Dose Assessment for an Explain when URI Rapid Dose Assessment for an off site off site release of radioactive materials must be release of radioactive materials must be performed .

performed.

State potential release paths that are monitored by on-shift State potential release paths that are monitored by dose assessors to identify any abnormal releases that may on-shift dose assessors to identify any abnormal occur as the result of an emergency. releases that may occur as the result of an emergency.

Explain how certain accidents could result in multiple Explain how certain accidents could result in release paths. multiple release paths.

Explain the significance of multiple release paths when Explain the significance of multiple release paths calculating off site dose. when calculating off site dose.

State the locations of the computers that are to be used to State the locations of the computers that are to be access the Operator Aid Computer (OAC) and URI. used to access the Operator Aid Computer (OAC) and URI.

Describe the two "Source Term" options used by Describe the two "Source Term" options used by URI to URI to perform Rapid Dose Assessment.

perform Rapid Dose Assessment.

Explain when conditions for coolant spiking have Explain when conditions for coolant spiking have been met.

been met.

Explain how to obtain meteorological information if Explain how to obtain meteorological information if data data from the CNS meteorological tower is from the CNS meteorological tower is unavailable.

unavailable.

Describe the plant conditions indicative of the four (4) Describe the plant conditions indicative of the four

'Release Point Pathways' that are used for Rapid Dose (4) 'Release Point Pathways' that are used for Rapid Assessment. Dose Assessment.

Given real or simulated data, perform a Rapid Dose Given real or simulated data, perform a Rapid Dose Assessment. Assessment.

Given real or simulated data from multiple release points, Given real or simulated data from multiple release perform an Assessment Summation points, perform an Assessment Summation.

printed 03/28/20 18 Page 18

Attachment 2 On-Shift Staffing Analysis Review The CNS On-Shift Staffing Analysis (OSSA) was evaluated for the transfer of responsibility for on-shift dose assessment from a RP Qualified Individual to a Dose Assessment Qualified Individual having no collateral Emergency Plan duties prior to augmentation of on-shift staff.

Of the events listed in the CNS OSSA, the following two events were noted to be impacted due to a change in a position performing functions/tasks:

==

Conclusion:==

These two events (Event 4 - Reactor Coolant Pump Shaft Break, and Event 6 - Steam Generator Tube Rupture) were evaluated for a potential reduction in effectiveness due to overlap or delay in performing functions/tasks. Results of the evaluation concluded that the remaining two RP Qualified Individuals could perform the necessary functions/tasks for the events without overlap of tasks, and any activity that would be delayed would not impact the response to the emergency or cause the emergency to escalate to a higher Emergency Classification Level (ECL).

Scenario Details:

Event 1 - Main Steam Line Break Current OSSA Study Basis:

  • RP1 performs Dose Assessment (Offsite Radiological Assessment);
  • RP2 performs in-plant surveys;
  • RP3 performs equipment setup (for LOOP).

o Equipment setup position was designated to restore Count Room equipment

==

Conclusion:==

There are no overlaps in the listed duties. There are no changes for this event.

Event 4 - Reactor Coolant Pump Shaft Break Current OSSA Study Basis:

  • RP1 performs In-plant surveys;
  • RP2 performs equipment setup; o RP2 equipment setup: due to LOOP, restoring Count Room equipment
  • RP3 performs In-plant surveys and provides Job Coverage.

o RP3 starts to do In-plant surveys, (sample setup for Unit Vent grab samples),then goes with Operations to do recovery in the field for minutes 30 - 60.

o There is a 30 minute overlap where the Dose Assessor (RP1) was designated to fill in for RP3.

To support reducing Staffing to 2 RP Qualified Individuals:

- RP3 is doing the sample cart; at T +30 takes a break to go with OPS to U1 SFPT

- RP2 is restoring power to Count Room; at T+30 takes a break to go survey 1VQ-10 Note: A battery powered sample pump (not credited in OSSA) is now used to expedite Unit Vent samples.

Conclusion:

Two RP Qualified Individuals could perform the necessary functions I tasks for Event 4. This CAS assignment documents the acceptable overlap on RP2 to survey 1VQ-10 while delaying Count Room power restoration activities.

Event 6 - Steam Generator Tube Rupture Current OSSA Study Basis: See both Time Motion Study and Tabletop Exercise Data

  • RP1 makes management notification and performs Dose Assessment;
  • RP2 pulls Unit Vent sample(s), performs Job Coverage for Operations (T+33), and then reports to OSC;
  • RP3 checks cation columns (T+14) and reports to OSC f rinted  : 03/28/2018 Page 19

Attachment 2 On-Shift Staffing Analysis Review (Continued)

Suggested Change (Combination of Time Motion Study and Tabletop Exercise):

RP2 makes management notifications (T +Oto T +5); starts HP/O/B/1009/003 (T+11 ); collects shutdown sample (T+12 to T +32); provides Operations Fuel Pool job coverage (T+33 to T +50).

RP3 at T +14 will survey the cation columns then goes to the OSC at T +34.

==

Conclusion:==

Two RP Qualified Individuals could perform the necessary functions I tasks for Event 6. This CAS assignment documents that RP2 (or RP3) is to perform management notification (T+O to T+5) prior to other actions.

Event 7 - Large Break LOCA Current OSSA Study Basis:

  • RP1 performs Dose Assessment;
  • RP2 performs In-Plant Surveys (sampling Unit Vent and surveying Cation Columns) ;
  • RP3 performs Equipment Set-Up (restores power to the Count Room)

==

Conclusion:==

There are no overlaps in the listed duties. There are no changes for this event.

Event 8 - Fuel Handling Accident Current OSSA Study Basis:

  • RP1 performs Personnel Monitoring (job coverage, evacuates crew, notifies management);
  • RP2 performs In-Plant Surveys (sampling Unit Vent, receives notification to perform surveys in affected areas);
  • RP3 performs Dose Assessment

Conclusion:

There are no overlaps in the listed duties. There are no changes for this event.

Event 9 - Design Basis Threat (DBT),

Event 10 - Probable Aircraft Threat (PAT), and Event 11 - Control Room Evacuation Due to Fire Current OSSA Study Basis:

  • RP1 NIA for Radiation Protection functions
  • RP2 NIA for Radiation Protection functions
  • RP3 NIA for Radiation Protection functions

Conclusion:

There are no duties listed to evaluate for overlap. There are no changes for these events.

Event 12 - Station Blackout Current OSSA Study Basis:

  • RP1 checks EMF panels in Control Room, performs Dose Assessment as needed (never performed);
  • RP2 restores power to the Unit Vent sample pump and samples the Unit Vent;
  • RP3 performs Equipment Set-Up (restores Count Room equipment)

Note: A battery powered sample pump (not credited in OSSA) is now used to expedite Unit Vent samples.

Conclusion:

There are no overlaps in the listed duties. There are no changes for this event.

p rinted 03/28/2018 Page 20

      • END OF REPORT***
Retrieved from "https://kanterella.com/w/index.php?title=CNS-18-022,_Submittal_of_Emergency_Plan_Implementing_Procedure&oldid=2407211"