HNP-18-049, Submittal of 1 0 CFR 50.54(q) Evaluation Form of Changes to Procedure EMP-420, Emergency Program Maintenance, Revision 19

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Submittal of 1 0 CFR 50.54(q) Evaluation Form of Changes to Procedure EMP-420, Emergency Program Maintenance, Revision 19
ML18124A244
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 05/03/2018
From: Bradley Jones
Duke Energy Progress
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-18-049 AD-EP-ALL-0602, Rev 4
Download: ML18124A244 (18)
v • d • e


Text

el_~ DUKE

~ ENERGY MAY O 3 2018 Serial: HNP-18-049 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63

Subject:

1 0 CFR 50.54(q) Evaluation Ladies and Gentlemen:

Bentley K. Jones Director, Organizational Effectiveness Harris Nuclear Plant 5413 Shearon Harris Rd New Hill, NC 27562-9300 919.362.2305 10 CFR 50.54(q)(5)

As required by 1 0 CFR 50.54(q)(5), Duke Energy Progress, LLC, is providing the 1 0 CFR 50.54(q) evaluation and the associated 1 0 CFR 50.54(q) Screening Evaluation Form of changes to procedure EMP-420, Emergency Program Maintenance, Revision 19.

This submittal contains no regulatory commitments. Please refer any questions regarding this submittal to Jeffrey Robertson, Manager - Regulatory Affairs, at (919) 362-3137.

Sincerely, Bentley K. Jones :

Copy of 1 0 CFR 50.54(q) Screening Evaluation Form and 1 0 CFR 50.54(q)

Effectiveness Evaluation Form for EMP-420 Revision 19 cc:

J. Zeiler, NRC Senior Resident Inspector, HNP M. Barillas, NRC Project Manager, HNP NRC Regional Administrator, Region II

Document Control Desk Serial: HNP-18-049 Copy of 1 O CFR 50.54(q) Screening Evaluation Form and 1 O CFR 50.54(q) Effectiveness Evaluation Form for EMP-420 Revision 19 (16 pages plus cover)

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

Rev.4 ATTACHMENT 4 Page 1 of 5

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

Screening and Evaluation Number Applicable Sites BNP EREG #:

2183336 CNS CR3 HNP

~

MNS SAD#:

2188922 ONS RNP GO Document and Revision Emergency Equipment Inventory EPM-420 Revision 19 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):

EPM-420 Emergency Equipment Inventory is being revised.

Throughout the procedure, references to "Emergency Action Level Board" were replaced with "EP-EAL Matrix Board"

  • , TSC Accident Assessment Room Inventory Checklist, the quantity of satellite phones in Item 29 was changed to "7"; new item 18 was added, moving "Laptop Computer with Unified RASCAL Interface (URI) back-up media" from Attachment 24 to Attachment 3.

Deleted Attachment 24, TSC Dose Projection Cabinet Checklist.

  • 4, Emergency Equipment - HEEG Boat Shed Field Monitoring Supplies Inventory Checklist, removed "vehicle platforms" and "ramp"
  • , line items 33 and 34: replaced "Manger - Nuclear Chemistry" with "Manager - Nuclear Radiation Protection" Attachments 33 and 34: replaced "Chemistry Supv. Review" with "RP Supv Review"
  • 5: removed signoff for "RP Supv Review" (editorial correction only)

Part II. Activity Previously Reviewed?

Yes 1

Continue to Alert and Notification System Design Report?

Effectiveness,

Evaluation is not 10 CFR If yes, identify bounding source document number or approval reference and required. Enter 50.54(q) ensure the basis for concluding the source document fully bounds the proposed justification Screening change is documented below:

below and Evaluation complete Form, Part Ill Justification:,

Part V.

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

Rev.4 ATTACHMENT 4 Page 2 of 5

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

Bounding document attached (optional)

Part Ill. Editorial Change Yes No I X 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?

Effectiveness,

Evaluation is not Part IV and Justification:

required. Enter address non The following are editorial changes as defined in AD-EP-ALL-0602, Emergency justification and editorial complete changes Plan Change Screening and Effectiveness Evaluations 10 CFR 50.54(0) step,

3.0.6.

Part V.

Throughout the pro.cedure, references to "Emergency Action Level Board" were replaced with "EP-EAL Matrix Board" The change only changes the descriptive title of the Emergency Action Level board to reflect the current title. No other changes are being made to the boards.

  • 5: removed signoff for "RP Supv Review" This change only removes a redundant review line that is not needed.

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 1 O 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 (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 2b The process for timely augmentation of onshift staff is established and maintained.

3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.

3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.

(NA for CR3) 4 10 CFR 50.47(b)(4) Emergency Classification System 4a A standard scheme of emergency classification and action levels is in use.

(Requires final approval of Screen and Evaluation by EP CFAM.)

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

Rev. 4 ATTACHMENT 4 Page 3 of 5

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

10 CFR 50.47(b)(5) Notification Methods and Procedures Procedures for notification of State and local governmental agencies are capable of alerting them of the

  • declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.

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

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

The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. (NA for CR3)

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

Rev.4

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

ATTACHMENT 4 Page 4 of 5 Part IV. Emergency Planning Element and Function Screen (cont.)

6 10 CFR 50.47(b)(6) Emergency Communications 6a Systems are established for prompt communication among principal emergency response organizations.

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

7 10 CFR 50.47(b)(7) Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established.

8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment Ba Adequate facilities are maintained to support emergency response.

8b Adequate equipment is maintained to support emergency response.

X 9

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

10 10 CFR 50.47(b)(10) Protective Response 10a A range of public PARs is available for implementation during emergencies. (NA for CR3) 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available

  • to support the formulation of PARs and have been provided to State and local governmental authorities. (NA for CR3) 10c A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.

10d Kl is available for implementation as a protective action recommendation in those jurisdictions that chose to provide Kl to the public.

11 1 O CFR 50.47(b)(11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.

12 10 CFR 50.47(b)(12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.

13 10 CFR 50.47(b)(13) Recovery Planning and Post-accident Operations 13a Plans for recovery and reentry are developed.

14 1 O CFR 50.47(b)(14) Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program areas) is established..

14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.

14c Identified weaknesses are corrected.

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

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

Rev. 4 ATTACHMENT 4 Page 5 of 5

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

Part IV. Emergency Planning Element and Function Screen (cont.)

16 10 CFR 50.47(b)(16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.

16b Planners responsible for emergency plan development and maintenance are properly trained.

PART IV. Conclusion If no Part IV criteria are checked, a 10 CFR 50.54(q) Effectiveness Evaluation is not required, then complete

Justification:

If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete X, 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q)

Effectiveness Evaluation. Program Element 4a requires final approval of Screen and Evaluation by EP CFAM.

Part V. Signatures:

EP CFAM Final Approval is required for changes affecting Program Element 4a. If CFAM approval is NOT required, then mark the EP CFAM signature block as not applicable (N/A) to indicate that signature is not required.

Approver (EP Manager Name (Print):

Co~~,Y'V\\

NS,.

Approver (EP CFAM, as required) Name (Print)

N/A QA RECORD Date:

3/6/18 Date:

3h Date:

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

Rev. 4 ATTACHMENT 5 Page 1 of 11

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

Screening and Evaluation Number Applicable Sites BNP EREG #:

2183336 CNS CR3 HNP X

MNS SAD#: __

2188922 ONS RNP GO Document and Revision:

I Emergency Equipment Inventory EPM-420 Revision 19 Part I. Description of Proposed Change:

EPM-420 Emergency Equipment Inventory is being revised.

  • , TSC Accident Assessment Room Inventory Checklist, the quantity of satellite phones in Item 29 was changed to "7"; new item 18 was added, moving "Laptop Computer with Unified RASCAL Interface (URI) back-up media" from Attachment 24 to Attachment 3.

Deleted Attachment 24, TSC Dose Projection Cabinet Checklist.

  • 4, Emergency Equipment - HEEC Boat Shed Field Monitoring Supplies Inventory Checklist, removed "vehicle platforms" and "ramp"
  • , line items 33 and 34: replaced "Manger - Nuclear Chemistry" with "Manager - Nuclear Radiation Protection" Attachments 33 and 34: replaced "Chemistry Supv. Review" with "RP Supv Review", 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL} and EAL I Yes
  • Bases Validation and Verification (V&V) Form, is attached (required for IC or EAL chanqe)

No X

Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

NUREG-1038, Safety Evaluation Report Related to the Operation of Shearon Harris Nuclear Power Plant, Units 1 and 2 Section 13.3.2.8 Emergency Facility and Equipment Standard Adequate emergency facilities and equipment to support the emergency response provided and maintained.

Evaluation Emergency facilities to support an emergency response have been established as follows:

(1) The control room (CR) contains those controls, instruments, and communications facilities necessary for operation of the plant under both normal and emergency conditions. The ventilation system, shielding, and the structure's Integrity are designed to permit continuous occupancy during postulated accidents. Storage is provided for food and water sufficient for 7 davs.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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

AD-EP-ALL-0602 Rev.4 ATTACHMENT 5 Page 2 of 11 (2) The TSC is located within the plant's protected area in the fuel-handling building, approximately 400 feet (walking distance) from the CR. Traffic between the TSC and CR is entirely within buildings that are equipped with HEPA and charcoal filters and are built to seismic Category I, tornado, and missile safety-related criteria, with radiation protection equivalent to the CR. The TSC will have all the necessary equipment and supplies when fully functional to operate as the command center for the SEC and his staff.

(3) The OSC is located in the service building inside the protected area and functions as an assembly and dispatch area for all emergency teams.

PLP-201, Emergency Plan Revision 3 3.0 EMERGENCY FACILITIES, COMMUNICATIONS, EQUIPMENT 3.1 General The purpose of emergency response facilities is to provide centralized locations for organized command and control of on-site activities, and off-site activities performed by the Company such as environmental monitoring.

Each emergency response organization is provided with a location from where they may direct or perform the activities for which they are responsible while providing for coordination of activities with other organizations.

Adequate emergency facilities, communications, and equipment to support emergency response are provided and maintained. Carolina Power & Light Company (CP&L) Emergency Plans include provision for emergency response facilities as follows:

Control Room Technical Support Center (TSC)

Operational Support Center (OSC)

Emergency Operations Facility (EOF)

Plant Media Center (PMC)

Corporate Emergency Operations Center (CEOC)

The Control Room is an emergency response facility that is operational on a day-to-day basis. The other facilities are unmanned or used for other purposes on a day-to-day basis. In the event of an emergency, the TSC, OSC, EOF, and PMC would be activated in accordance with Section 4 of this Plan, "Emergency Measures and Operations".

In addition to the emergency response facilities, provision is made for onsite and offsite geophysical phenomena monitors (meteorological and seismic); radiological monitors; process monitors; and fire and combustion products detectors for use in initiating emergency measures and assessing the emergency, each are described in subsequent paragraphs of this Chapter. Typical emergency supplies available for emergency facilities are indicated in Table 3.1-1.

3.2 Control Room 3.2.3 Emergency Equipment and Supplies

a.

Main Control Board

b.

Emergency Response Facility Information System (ERFIS)

c.

Safety Parameter Display System (SPDS) (Part of ERFIS)

d.

Measurement and Indication of Regulatory Guide 1.97 (Rev. 2) variables (ERFIS)

e.

Radiation Monitoring System (RMS)

f.

Fire Detection System (adjacent room)

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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

g.

Seismic Monitoring Cabinet

h.

Gross Failed Fuel Detector Console

i.

Food and Water Storage for seven days

j.

Basic medical supplies, kitchen and sanitary facilities AD-EP-ALL-0602 Rev. 4 ATTACHMENT 5 Page 3 of 11

k.

Reliable voice communications with the TSC, OSC, EOF, NRC Operations Centers and State and local government 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> warning points.

I.

Respirators and anti-Cs

m. SeeTable3.1-1 3.3 Technical Support Center (TSC)
3. 3. 3 Emergency Equipment and Supplies
a.

Reliable voice communications with the Control Room, EOF, OSC, NRC Operations Center and State and local government 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> warning points as described in Section 3.8 which follows

b.

Four ERFIS consoles capable of displaying plant data, SPDS, RMS and dose projections as discussed in Section 3.9.1

c.

Mechanical systems, electrical systems drawings; Plant Operating Manual; FSAR; Corporate, plant, state &

local emergency plans; photocopier, telecopier (also Document Control Library nearby)

d.

Decontamination and monitoring area

e.

Survey meter, area radiation monitor and constant air monitors

f.

Maps showing evacuation routes, evacuation areas, preselected radiological sampling and monitoring points, relocation centers in host areas, and shelter areas

g.

Maps showing population distribution around the nuclear facility by evacuation areas (See Annex H)

h.

SeeTable3.1-1 3.4 Operational Support Center (OSC) 3.4.3 Emergency Equipment and Supplies

a.

Reliable voice communications with the Control Room, EOF and TSC

b.

Supplies and equipment as shown in Table 3.1-1 PLP-201 Emergency Plan Revision 69 3.0 Emergency Facilities, Communications and Equipment 3.1 General The purpose of emergency response facilities is to provide centralized locations for organized command and control of on-site activities and off-site activities performed by the Company such as environmental monitoring.

Different groups within the Emergency Response Organization are provided with a location from where they may direct or perform the activities for which they are responsible while providing for coordination of activities with other organizations.

Adequate emergency facilities, communications, and equipment to support emergency response are provided and maintained. Duke Energy Emergency Plans include provision for emergency response facilities as follows:

Main Control Room (MCR)

Technical Support Center (TSC)

Operations Support Center (OSC)

Emergency Operations Facility (EOF)

Joint Information Center (JIC)

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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

AD-EP-ALL-0602 Rev. 4 ATTACHMENT 5 Page 4 of 11 The Main Control Room is an emergency response facility that is operational on a day-to-day basis. Initially the emergency actions and in plant response would be directed by the Emergency Coordinator from the Main Control Room. Operations personnel would be dispatched from their work area located immediately north of the Main Control Room with assistance from on-shift health physics, maintenance, and security personnel as needed.

The facilities, other than the Main Control Room, are unstaffed or used for other purposes on a day-to-day basis. In the event of an emergency, the TSC, OSC, EOF, and JIC would be activated in accordance with Section 4 of this Plan, "Emergency Measures and Operations."

In addition to the emergency response facilities, provision is made for on-site and off-site geophysical phenomena monitors (meteorological and seismic); radiological monitors; process monitors; and fire and combustion products detectors for use in initiating emergency measures and assessing the emergency. Each of these is described in subsequent paragraphs of this Chapter. Typical emergency supplies available for emergency facilities are indicated in Table 3.1-1.

3.2 Main Control Room 3.2.3 Emergency Equipment and Supplies A.

Main Control Board B. Emergency Response Facility Information System (ERFIS)

C. Safety Parameter Display System (SPDS is part of ERFIS)

D. Measurement and Indication of Regulatory Guide 1.97 (Rev. 2) variables (ERFIS)

E. Radiation Monitoring System (RMS)

F.

Fire Detection System (adjacent room)

G. Seismic Monitoring Cabinet H. Gross Failed Fuel Detector Console I.

Kitchen and sanitary facilities J.

Reliable voice communications with the TSC, OSC, EOF, NRC Operations Centers, and State and local government 24-hour warning points and State EOC K. See Table 3.1-1 3.3 Technical Support Center (TSC) 3.3.3 Emergency Equipment and Supplies A.

Reliable voice communications with the Main Control Room, EOF, OSC, NRC Operations Center and State and local government 24-hour warning points and State EOC as described in Section 3.8 which follows.

B. Video System capable of displaying ERFIS information (such as, plant data, SPDS, and RMS) as discussed in Section 3.9.1.

C. All reference materials, including Mechanical and Electrical Systems Drawings; Controlled Procedure Manual; FSAR; Corporate, Plant, State, and Local Emergency Plans, are available.

D. Decontamination and monitoring area.

E. Survey meter and area radiation monitor.

F.

Photocopier equipment and reliable facsimile transmission capability to the EOF and NRC Operations Center.

G. SeeTable3.1-1.

3.4 Operations Support Center (OSC) 3.4.3 Emergency Equipment and Supplies A.

Reliable voice communications with the Main Control Room, EOF, and TSC.

B. Supplies and equipment as shown in Table 3.1-1.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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

Review:

AD-EP-ALL-0602 Rev. 4 ATTACHMENT 5 Page 5 of 11

  • , TSC Accident Assessment Room Inventory Checklist, the quantity of satellite phones in Item 29 was changed to "7"; new item 18 was added, moving "Laptop Computer with Unified RASCAL Interface (URI) back-up media" from Attachment 24 to Attachment 3.

Deleted Attachment 24, TSC Dose Projection Cabinet Checklist.

These changes were made to align the number of satellite phones to that needed to support emergency response and to add a URI laptop computer to the TSC inventory. The URI computer was relocated from Attachment 24 to. Attachment 24 was deleted because it duplicated materials already contained in another kit in the TSC (Attachment 3). The only item in the deleted Attachment 24 that was not in another kit was the URI laptop, which was move to Attachment 3.

  • 4, Emergency Equipment - HEEC Boat Shed Field Monitoring Supplies Inventory Checklist, removed "vehicle platforms" and "ramp" This change was made because the vehicle platforms and ramps are no longer needed. These items were previously required for large portable generators that were carried in vehicle mounted racks. The large generators have been replaced with small generators that can be loaded by hand.
  • , line items 33 and 34: replaced "Manger - Nuclear Chemistry" with "Manager - Nuclear Radiation Protection" Attachments 33 and 34: replaced "Chemistry Supv. Review" with "RP Supv Review" These changes were made to re-align the responsibility for performing these inventories. After the new ERO structure was implemented, the responsibility for these inventories was re-assigned to RP.

RIS 2005-02, Clarifying the Process for Making Emergency Plan Changes, Revision 1 states,

2) Emergency plan a) The document prepared and maintained by the licensee that identifies and describes the licensee's methods for maintaining emergency preparedness, and responding to emergencies. An emergency plan includes the plan as originally approved by the NRC, and all subsequent changes made by the licensee with, and without, prior NRC review and approval under 10 CFR 50.54(q).

i) The licensee's emergency plan consists of:

(1) The emergency plan as approved by the NRC via a Safety Evaluation Report (SE), or license amendment (LA} from the Office of Nuclear Reactor Regulation (NRR) or the Office of Federal and State Materials and Environmental Management Programs (FSME).

(2) Any subsequent changes to the emergency plan explicitly reviewed by the NRC through an SE, or LA from NRR or FSME, and found to meet the applicable regulations.

(3) Any subsequent changes made by the licensee without NRC review and approval after the licensee concluded that the change(s) do not constitute a decrease in effectiveness under 10 CFR 50.54(q).

The differences in PLP-201, Revision 3, and PLP-201, Revision 65 have been determined to meet the regulatory requirements of the course of revisions. Each revision has been evaluated in the regulatory process has met the approval of the NRC during the inspection process.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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

AD-EP-ALL-0602 Rev.4 ATTACHMENT 5 Page 6 of 11 The changes being made remove un-needed items, re-align inventory responsibilities and relocate a URI laptop from the near site EOF to the TSC to ensure that the EOF function of performing dose assessment continues to be performed.

These changes continue to align with the licensing basis.

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)(8) Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

10 CFR 50 Appendix E, Emergency Planning and Preparedness for Production an Utilization Facilities IV.E. Emergency Facilities and Equipment Adequate provisions shall be made and described for emergency facilities and equipment, including:

1.

Equipment at the site for personnel monitoring;

2.

Equipment for determining the magnitude of and for continuously assessing the impact of the release of radioactive materials to the environment; The changes being made:

  • , TSC Accident Assessment Room Inventory Checklist, the quantity of satellite phones in Item 29 was changed to "7"; new item 18 was added, moving "Laptop Computer with Unified RASCAL Interface (URI) back-up media" from Attachment 24 to Attachment 3.

Deleted Attachment 24, TSC Dose Projection Cabinet Checklist.

These changes were made to align the number of satellite phones to that needed to support emergency response and to add a URI laptop computer to the TSC inventory. The URI computer was relocated from Attachment 24 to. Attachment 24 was deleted because it duplicated materials already contained in another kit in the TSC (Attachment 3). The only item in the deleted Attachment 24 that was not in another kit was the URI laptop, which was move to Attachment 3.

  • 4, Emergency Equipment - HEEC Boat Shed Field Monitoring Supplies Inventory Checklist, removed "vehicle platforms" and "ramp" This change was made because the vehicle platforms and ramps are no longer needed. These items were previously required for large portable generators that were carried in vehicle mounted racks. The large generators have been replaced with small generators that can be loaded by hand.
  • , line items 33 and 34: replaced "Manger - Nuclear Chemistry" with "Manager - Nuclear Radiation Protection" Attachments 33 and 34: replaced "Chemistry Supv. Review" with "RP Supv Review"

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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

AD-E P-ALL-0602 Rev.4 ATTACHMENT 5 Page 7 of 11 These changes were made to re-align the responsibility tor performing these inventories. After the new ERO structure was implemented, the responsibility tor these inventories was re-assigned to RP.

The equipment that was removed (ramp and vehicle platform) are equipment is no longer needed. The equipment removed was necessary tor large generators which have been replaced by smaller portable generators. The portable generators remain as part of the inventory.

The deletion of Attachment 24 was necessary to remove redundant materials already located in the TSC. The only item not duplicated was the URI laptop, which was moved to another TSC kit. The TSC will continue to be able to perform the required dose assessments.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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

AD-EP-ALL-0602 Rev. 4 ATTACHMENT 5 Page 8 of 11 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):

Standard 10 CFR 50.47(b)(8) Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Function Regulatory Guide 1.219 function - Adequate equipment is maintained to support emergency response.

Element NUREG-0654 element - 11.H

5. Each licensee shall identify and establish onsite monitoring systems that are to be used to initiate emergency measures in accordance with Appendix 1, as well as those to be used for conducting assessment.

The equipment shall include:

5.b. radiological monitors, (e.g., process, area, emergency, effluent, wound and portable monitors and sampling equipment);

9. Each licensee shall provide for an onsite operations support center (assembly area) which shall have adequate capacity, and supplies, including, for example, respiratory protection, protective clothing, portable lighting, portable radiation monitoring equipment, cameras and communications equipment for personnel present in the assembly area.

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.4 ATTACHMENT 5 Page 9 of 11 Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

The changes being made:

  • , TSC Accident Assessment Room Inventory Checklist, the quantity of satellite phones in Item 29 was changed to "7"; new item 18 was added, moving "Laptop Computer with Unified RASCAL Interface (URI) back-up media" from Attachment 24 to Attachment 3.

Deleted Attachment 24, TSC Dose Projection Cabinet Checklist.

These changes were made to align the number of satellite phones to that needed to support emergency response and to add a URI laptop computer to the TSC inventory. The URI computer was relocated from Attachment 24 to. Attachment 24 was deleted because it duplicated materials already contained in another kit in the TSC (Attachment 3). The only item in the deleted Attachment 24 that was not in another kit was the URI laptop, which was move to Attachment 3. The adjusted satellite phone inventory still provides the back-up means of communication. The URI laptop was only moved from one cabinet to another in the TSC and continues to be available for performing dose assessments.

  • 4, Emergency Equipment - HEEG Boat Shed Field Monitoring Supplies Inventory Checklist, removed "vehicle platforms" and "ramp" This change was made because the vehicle platforms and ramps are no longer needed. These items were previously required for large portable generators that were carried in vehicle mounted racks. The large generators have been replaced with small generators that can be loaded by hand. Portable generators continue to be a required item in the emergency kits
  • , line items 33 and 34: replaced "Manger - Nuclear Chemistry" with "Manager - Nuclear Radiation Protection" Attachments 33 and 34: replaced "Chemistry Supv. Review" with "RP Supv Review" These changes were made to re-align the responsibility for performing these inventories. After the new ERO structure was implemented, the responsibility for these inventories was re-assigned to RP. These changes only re-assign the responsibility for performing the inventories to ensure that the equipment remains available and ready to support emergency response.

The changes as described above continue to meet the required emergency plan functions and do not result in a reduction in effectiveness of emergency plan functions.

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?

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

Yes X No D Yes X No D

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

Rev. 4 ATTACHMENT 5 Page 10 of 11

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

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

I YesX No

  • 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 X

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.

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

  • I No
  • 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:

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

Rev. 4 ATTACHMENT 5 Page 11 of 11

<< 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):

David Stih Reviewer Name (Print):

Jamey Sharlow Date:

3/6/18 Date:

3/141 Approver (EP Manager) Name (Print):

Gregg Simmons Date:

~-,-x,i Approver (CFAM, as required) Name (Print):

Date:

NIA 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 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 X

X

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