Text

Transmittal of Emergency Plan Updates
	ML16060A097
Person / Time
Site:	FitzPatrick
Issue date:	02/23/2016
From:	Jackie Jones; Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	JAFP-16-0025
	Download: ML16060A097 (27)
	v • d • e

---Entergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 James D. Jones Manager Emergency Planning JAFP-1 6-0025 February 23, 2016 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

Transmittal of Emergency Plan Updates James A. FitzPatrick Nuclear Power Plant Docket No.50-333 License No. DPR-059

Dear Sir or Madam:

The documents enclosed with this letter are changes to the James A. FitzPatrick Nuclear Power Plant's (JAF) Emergency Plan made pursuant to 10 CFR 50.54(q). This transmittal fulfills the requirements of 10 CFR 50.54(q), 10 CFR 50 Appendix E Section V, 10 CFR 70.32(i), and 10 CFR 72.44(f) to inform the commission of changes that have been made which do not decrease the effectiveness of the Emergency Plan.

The following documents (including change documentation, evaluation and screening) are attached:

EAP-4C, Rev. 1 This letter contains no new regulatory commitments.

If you should have any questions, please contact Mr. James D. Jones at (315) 349-6030.

Sincerely, Manager Emergency Planning J DJ :cfv Enclosure(s):

Including change documentation, evaluation and screening:

EAP-4C, Rev. 1

~4L~

JAFP-1 6-0025 Page 2 of 2 cc w/o procedure documentation, evaluation and screening:

USNRC (l&E) Regional Administrator, Region I - Controlled - 2 Copies NRC Resident Inspector - Controlled - 1 Copy NRC Director NMSS - Uncontrolled - 1 Copy NRC Director Division of Spent Fuel Storage and Transportation - Uncontrolled - 1 Copy NRC Director, Division of Security Policy - Uncontrolled - 1 Copy NYSEMO - Controlled - 1 Copy OCEMO - Controlled - 1 Copy

JAFP-1 6-0025 Enclosures Including change documentation, evaluation and screening:

EAP-4C, Rev. 1

ATTACHMENT 9.4 NRC SUBMITTAL REVIEW Sheet I of 2 S-U bject..::.Transmittal iof Em.ergency Pian Updates>*

,.:. :.Date ssued. dfor Review*: :i/i.7/16-"...:

C:orres-p~ondence P*reprerl " Phone #:! Cathee Vickery 31-349-639 77-7"..----

i

.: ::i:-.i Section I Letter Concurrence and Agreement to Perform Actions

-" PO.SITION I NAME.-:

.I:":_

Actio~n",

Signature..

-::-., ! --.. *:-" -..,I:(c~oncurrence, "cert'ification, letc.)

'.(sign.; int~eroffi~e m~emo,e-email, or.-:>..:

Emergency Planning Dept.

Preparer/Reviewer Cathee Vickery/**,

1 Licensing Department Concurrence Mark Hawes /

-*E.m erig e* n.c.y* *Pr~e.P-ari e-d. n-.!ess M ia-n-a g~er *:..A.Pi-P.ro:v.e.r.COMNS..

James Jones /

-EAP-4C, Revision 1 Section II Correspondence Screening Does this letter contain commitments? If "yes," identify the commitments with due dates Yes LI in the submittal and in Section III. When fleet letters contain commitments, a PCRS 10 No

[

(e.g., LO-LAR, LO-WT) should be initiated with a CA assigned to each applicable site to enter the commitments into the site's commitment management system.

Does this letter contain any information or analyses of new safety issues performed at NRC Yes El request or to satisfy a regulatory requirement? If "yes," reflect requirement to update the No

[

UFSAR in Section II1.

Does this letter require any document changes (e.g., procedures, DBDs, FSAR, TS Bases, Yes LI etc.), if approved? If "yes," indicate in Section III an action for the responsible No

[

department to determine the affected documents. (The Correspondence Preparer may indicate the specific documents requiring revision, if known or may initiate an action for review.)

Does this letter contain information certified accurate? If "yes," identify the information Yes LI and document certification in an attachment. (Attachment 9.5 must be used.)

No

ATTACHMENT 9.4 NRC SUBMITTAL REVIEW Sheet 2 of 2 Section III Actions and Commitments Required Actions Due Date Responsible Dept.

Note: Actions needed upon approval should be captured in the appropriate action tracking system NIA Commitments Due Date Responsible Dept.

Note: When fleet letters contain commitments, a PCRS LO should be initiated with a CA assigned to each applicable site to enter the commitments into the site's commitment management system.*

NIA Section IV Final Document Signoff for Submittal Correspondence Preparer Ca thee Vickery /I

/

/.*

Final Submittal Review (optional)

N/A/

Responsible Department Head James Jones / I

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A~JD R~IP1>ACKNuWLEpG~MENTFQfIM TO:

DEPT.:

LOCATION:

DC/RockvillelvD EP Admin Emergency Planning USNRC Document Control Center, Washington SPECIAL NOTES:

JAFP Memo & EN-LI-106 form required.

Include 10CFR50.54(q)

Screen and Evaluation (EN-EP-305 Attach 9.1 & 9.2)

CONTROL MANUAL NUMBER 34 FROM:

DEPT.:

LOCATION:

DATE:

KELLY SAWYER ADMINISTRATIVE SERVICES JAF February 16, 2016 APPLICABLE MANUAL:

E-PLAN PROCEDURES UPDATE LITUPDATE LIST VOLUME 2 N/A 2/2312016 EAP-4C PROTECTIVE ACTION RECOMMENDATIONS 1

2/23/2016 INSTRUCTIONS:

1.

Insert the attached revised documents, and withdraw any noted WITHDRAWN documents from your controlled copy.

2.

DISCARD ALL SUPERCEDED DOCUMENTS, as applicable. DISCARD THIS TRANSMITTAL.

NOTE Failure to incorporate these documents into your controlled manual will result in cancellation of the subject controlled documents.

EMERGENCY PLAN IMPLEMENTING PROCEDURES/VOLUME 2 UPDATE LIST Date of Issue:

2/23/20 16 Procedure Procedure Revision Date of Last Use of Number Title Number Review Procedure NIA TABLE OF CONTENTS REV. 22 07/15 Informational lAP-I EMERGENCY PLAN IMPLEMENTATIONRE.4095 Inoatnl CHECKLIST CLASIFICTIO OF MERGNCYREV.

34 IAP-2 CONDSIFATIONS OFEEGNFLOWCHART 07/15 Informational CONDIIONSREV.

10 EAP-1.1 OFFSITE NOTIFICATIONS REV. 72 10/15 Informational EAP-2 PERSONNEL INJURY REV. 33 05/15 Informational EAP-3 FIRE REV. 26 0 1 /13 Informational EAP-4 WITHDRAWN (12/14)

EAP-4A ONSHIFT DOSE ASSESSMENT REV. 0 12/14 Informational EAP-4B DETAILED DOSE ASSESSMENT

.REV.

1 12/14 Informational EAP-4C PROTECTIVE ACTION RECOMMENDATIONS REV. 1 12/14 Informational

. EAP-4.1 RELEASE RATE DETERMINATIONRE.21/4 Inomtna EAP-5.1 DELETED (02/94)

EAP-5.2 DELETED (04/9 1)

EAP-5.3 ONSITE/OFES1TE DOWNWIND SURVEYS AND REV. 21 06/12 Informational ENVIRONMENTAL MONITORING___________

EAP-6

[N-PLANT EMERGENCY SURVEY/ENTRY REV. 19 02/ 14 Informational EAP-7. i DELETED (02/94)

EAP-7.2 DELETED (02/94)

EAP-8 PERSONNEL ACCOUNTABILITY REV. 74 09/13 Informational EAP-9 SEARCH AND RESCUE OPERATIONS REV. 13 08/13 Informational EAP-l10 PROTECTED AREA EVACUATION REV. 22 10/ 13 Informational EAP-1I 1 SITE EVACUATION REV. 23 1 0/13 Informational DOSE ESTIMATED FROM AN ACC*IDE*NTAL t.....

EAP-12 RELEASE OF RADIOACTIVE MATERIAL TO REV. 13 02/14 Informational LAKE ONTARIO_____

S EAP-13 DAMAGE CONTROL REV. 22 07/11 Informational Pag °~ONTR LL

EMERGENCY PLAN IMPLEMENTING PROCEDURES/VOLUME 2 UPDATE LIST Date of Issue:

2/23/2016 Procedure Procedure Revision Date of Last Use of

,,i.Number

,Title Number Review

.. Procedure EAP-14.1 WITHDRAWN (02/23/05)

EAP-14.2 WITHDRAWN (02/23/15)

EAP-14.5 WITHDRAWN (02/23/15)

EAP-14.6 HBTBLTOFTEERGNYREV.

18 04/14 Informational FACILITIES EAP-14.7 REMOTE ASSEMBLY AREA ACTIVATION REV. 3 12/14 Reference EAP-4.8 ALTERNATE TSC/SC ACTIVATION AND RV 21 eeec OPERATION EAP-15 EMREC AITO XOUEREV.

13 07/15 Informational

________CRITERIA AND CONTROL_____

EAP-16 PUBLIC INFORMATION PROCEDURE REV. 9 03/14 Informational EAP-16.2 JOINT INFORMATION CENTER OPERATION REV. 16 12/15 Informational EAP-1i7 EMERGENCY ORGANIZATION STAFFING REV. 124 09/15 Informational EAP-I18 DELETED (12/93)

EAP-19 EMERGENCY USE OF POTASSIUM IODINE (KI)

REV. 29 10/11 Informational EAP-20 POST ACCIDENT SAMPLE, OFFSITE SHIPMENT REV. 11 04/14 Informational

________AND ANALYSIS___________

EAP-21 DELETED (12/85),,

EAP-22 DELETED (02/98)

EAP-23 EMERGENCY ACCESS CONTROL REV. 15 04/14 Informational EAP-24 EFVHCEADPRONLREV.

11 12/14 Informational DECONTAMINATION EAP-25 DELETED (02/94)

Page 2 of 2

O ENTERGY NUCLEAR OPERATIONS, INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURE PROTECTIVE ACTION RECOMMENDATIONS EAP-4 4C REVISION 1 EFFECTIVE DATE:

~2~AAadi'Ži~~ £92: ~2~1/22 I.

I

/

INFOMITIONRATUSE QUALITY RELATED PERIODIC REVIEW DUE DATE:

PROTECTIVE ACTION RECOMMENDATIONS EAP -4 C REVISION

SUMMARY

SHEET REV.

NO.

1 Procedure change to section 6.1.3 to address Columbia Station CE on not requiring field team data prior to making PARs beyond 10 mile EPZ.

(CR-HQN-2015-850 CA#2 )

Revise note 2 at beginning of Section 6.1.3 to include the words "When available,"

Delete Section 6.1.3.A, renumber sections accordingly.

Revise previous section 6.1.3.B to delete "IF field surveys verify the calculated dose assessment exposure rates, then"

Deleted word "the" for grammatical correctness.

Added section 6.1.3.A.I: "IF not already performed, THEN direct DISPATCH of Field Monitoring Teams to downwind areas outside the 10 mile EPZ to validate expanded PARs adequately bound the areas with PAGs exceeded."

Rev. No.

01 Rev No 01Page 2 of 11

PROTECTIVE ACTION RECOMMENDATIONS EAP -4 C TABLE OF CONTENTS SE CT ION PAGE 1.0 PURPOSE.......................................................

4

2.0 REFERENCES

4 3.0 IN'ITIATIN1G EVENTS............................................

4 4.0 RESPONSIBILITIES.............................................

4 5.0 DEFINITIONS AND TERMS.......................................

5 6.0 PROCEDURE.....................................................

6 7.0 RECORDS.......................................................

7 8.0 ATTACHM~ENTS.................................................. 7

i.

FITZPATRICK PAR FLOWCHART (POSTED ATTACHMENT)....... 8 Rev. No.

01 Rev N.

2.Page 3 of 12.

PROTECTIVE ACTION RECOMMENDATIONS EP-EAP-4C 1.0*

PURPOSE This procedure provides guidelines for determining Protective Action Recommendations (PARs) to be made to offsite authorities during a General Emergency.

2.0 REFERENCES

2.1 Performance References 2.1.1 EAP-4A, Onshift Dose Assessment 2.1.2 EAP-4B, Detailed Dose Assessment 2.1.3 EAP-1.1, Offsite Notifications 2.1.4 EAP-5.3, Onsite/Offsite Downwind Surveys and Environmental Monitoring 2.1.5 EAP-42, Obtaining Meteorological Data 2.1.6 IAP-2, Classifications of Emergency Conditions 2.2 Developmental References 2.2.1 NEI 12-10 Guidelines for Developing a Licensee Protective Action Recommendation Procedure Using NUREG-0654 Supplement 3, Revision 0, April 2014 2.2.2 NUREG 0654/FEMA-REP-l, Supplements 3 3.0 INITIATING EVENTS0 3.1 A General Emergency has been declared.

4.0 RESPONSIBILITIES 4.1 Shift Manager/Emergency Director (SM/ED)

When in Command and Control the SM/ED is responsible for ensuring that Protective Action Recommendations (PARs) are developed in accordance with this procedure and approves PARs prior to communicating the PARs to offsite agencies.

4.2 TSC Radiological Coordinator The TSC Radiological Coordinator is responsible to the Emergency Director for managing the radiological monitoring and assessment aspects onsite and in plant during an emergency and of those functions specified in Step 4.3 until relieved of those functions by the EOF.

4.3 EOF Radiological Assessment Coordinator The EOF Radiological Assessment Coordinator (RAC) is responsible to the Emergency Director for managing the Rev. No.

01 Re.

o.

01Page 4 of 11

PROTECTIVE ACTION RECOMMENDATIONS EP-EAP-4C radiological monitoring and assessment aspects of fsite during an emergency, in order to assess the radiological consequences to the public including providing PARs to the ED for timely review and approval.

4.4 Onshift Chemistry Technician When Command and Control is in the Control Room the Onshift Chemistry Technician is responsible to the Shift Manager for developing Protective Action Recommendations (PARs) in accordance with this procedure.

5.0 DEFINITIONS AND TERMS 5.1 EPA Protective Action Guideline (PAG); Guidance developed by the Environmental Protection Agency regarding projected radiological dose or dose commitment values to individuals in the general population that warrant protective action following a release of radioactive materials.

These levels have been established at 1 Rem TEDE or 5 Rem CDE Thyroid.

5.2 Emergency Planning Zones (EPZ): That area surrounding the plant in which emergency planning is conducted for the protection of the public.

With respect to protecting the public from the plume exposure resulting from an incident, the EPZ is an area with a radius of about 10 miles surrounding the plant.

With respect to the ingestion exposure pathway, the EPZ is an area with a radius of 50 miles.

5.3 Emergency Response Planning Area (ERPA): Pre-designated sub-area within the 10 mile Emergency Planning Zone used to more specifically target the recommendation of offsite protective actions.

The FitzPatrick/Nine Mile Point Site utilizes 27 ERPAs based on geopolitical boundaries.

5.4 Initiating Condition (IC): one of a predetermined subset of*

plant conditions where either the potential exists for a radiological emergency, or such an emergency has occurred.

5.5 Potential

mitigation actions are not effective and trended information indicates that the parameters are outside desirable bands and not stable or improving.

5.6 Controlled Containment Vent (Puff Release): A venting of the containment that is anticipated to be terminated prior to exceeding 60 minutes in duration (short term release).

5.7 Protective Action Recommendations (PARs): In the context of this procedure, PARs are protective actions recommended to Rev.

No.

01 Page 5

of 11

PROTECTIVE ACTION RECOMMENDATIONS EP-EAP-4C government officials for the purpose of protecting the public from the effects of the release of radioactive materials from JAF.

PARs are recommended based on EPA 400 Protective Action Guidelines and plant conditions.

5.8 Rapidly Progressing Severe Accident (RPSA):

a General Emergency with a rapid loss of containment integrity and loss of the ability to cool the core.

6.0 PROCEDURE 6.1 Protective Action Recommendations NOTE INITIAL Protective Action Recommendations (PARs) can be made from any Emergency Facility where the Shift Manager (SM)

OR the Emergency Director (ED) are in command and control.

6.1.1 DETERMINE PARs USING Attachment 1, FitzPatrick PAR Flowchart.

6.1.2 IF an evacuation recommendation for an ERPA has been given, Then DO NOT reduce it to shelter.

NOTES

1. Does Assessment performed in the Control Room (EAP-4A) can only be used for projections out to 10 miles.

Therefore, step 6.1.3 will only apply to the EOF.

2. Beyond 10 miles the uncertainties in dose projection methods may result in significant inaccuracies in dose projection results.

When available, field surveys results should be used in conjunction with dose projections to estimate doses beyond 10 miles.

6.1.3 IF dose assessment results indicate the need to recommend actions beyond 10 miles, then PERFORM the following steps:

A.

EXPAND the PAR to include areas outside the EPZ where PAGs have been exceeded using convenient geographic boundaries (i.e.,

townships).

1.

IF not already performed, THEN direct DISPATCH of Field Monitoring Teams to downwind areas outside the 10 mile EPZ to Rev. No.

01 Re.

o.

01Page 6 of 11

PROTECTIVE ACTION RECOMMENDATIONS EAP -4 C validate expanded PARs adequately bou~nd the areas with PAGs exceeded.

2.

Continue monitoring beyond the current PAR areas to determine the need for further PAR expansion beyond 10 miles.

6.1.4 ENTER the PAR information on the Part 1 Formn (EAP-1.1, ).

6.1.5 The PAR MUST be provided to Oswego County and New York State via step 6.1.7 within 15 minutes of:

A. The classification of the General Emergency OR B. Any change in recommended actions 6.1.6 ALL PARs SHALL include the recommendation to implement the KI plan.

6.1.7 COMPLETE the PAR notification in accordance with EAP-1.I1.

6.1.8 CONTINUE to evaluate applicable Flowchart entry points for PAR upgrades.

7.0 RECORDlS 7.1 There are no records generated by this procedure that are subject to the requirements of EN-AD-103 Document Control and Records Management Programs.

8.0 ATTACHMENTS

1.

ATTACHMENT 1, FITZPATRICK PAR FLOWCHART (POSTED ATTACHMENT)

Rev. No.

01 Re.

o.

01Page 7 of 11

ATTACHMENT 9.1 SHEET I OF 3 I 0CFR5O.54(q) SCREENING ProcedurelDocument Number: EAP-4C Revision: 01 Equlpment/Facllity/Other: N/A

Title:

Protective Action Recommendations.

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):

The change removes a requirement to complete offsite monitoring prior to issuing PARs beyond 10 miles. The supporting details of the text changes to section 6.1.3 are as follows:

Revise note 2 at beginning of Section 6.1.3 to include the words "When available,.... "

Delete Section 6.1.3.A, renumber sections accordingly.

Revise previous section 6,1.3.B to deiete "IF field surveys verify the calculated dose assessment exposure rates, then" Deleted word "the" for grammatical correctness.

Added section 6.1.3.A.1: "IF not already performed, THEN direct DISPATCH of Field Monitoring Teams to downwind areas outside the 10 mile EPZ to validate expanded PARs adequately bound the areas with PAGs exceeded."

Part II. Activity Previously Reviewed?

L-]YES

[]NO Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3)

Continue to Alet ad NtiicaionSysemDesgn epotEvaluation is next part Aler an NotfictionSysem Dsig ReprtNOT required.

Enter If YES, identify bounding source document number/approval reference and justification enuethe basis for concluding the source document fully bounds the below and proposed change is documented below:

vI.complete Part Justification:

El Bounding document attached (optional)

Part III. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity,(Refer to EN-LI-I100)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

Screening...

APPLICABILITY CONCLUSION

[] If there are no controlling change processes, continue the 50.54(q)(3) Screening.

El One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

El One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT required. Identify controlling change processes below and complete Part VI.

CONTROLLING CHANGE PROCESSES 10OCFR50.54(cj)(3)

Part IV. Editorial Change Is this activity an editorial or typographical change such as formatting, paragraph numbering, spelling, or punctuation that does not change intent?

Justification:

Deleted word "the" for grammatical correctness is an editorial change and will not be screened further.

[-]YES 50.S4(q)(3)

Evaluation is NOT required.

Enter justification and comnplete Part Vl.

[]NO Continue to next part EN-EP-305 REV 3

ATTACHMENT 9.1 SHEET 2 OF 3 10CFR50.54(q) SCREENING ProcedurelDocument Number: EAP-4C Revision: 01 EquipmentlFacility/Other: NIA

Title:

Protective Action Recommendations Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-I Section II?

1. Responsibility for emergency response is assigned. [1]

[

2.

The response organization has the staff to respond and to augment staff on a continuing basis (24/7 U]

staffing) in accordance with the emergency plan. L1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2]

[]

4. The process for timely augmentation of onshift staff is established and maintained. [2]

[

5. Arrangements for requesting and using off site assistance have been made. [3]

[

6.

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

LI

7.

A standard scheme of emergency classification and action levels is in use. [4]

[]

8.

Procedures for notification of State and local governmental agencies are capabl'e Of alerting them of

[]

the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt

[]

instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-1 0, Guide for Evaluation of Alert and U]

Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response LI organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6]

U]

13. Emergency preparedness information is made available to the public on a periodic basis within the

[]

plume exposure pathway emergency planning zone (EPZ). [7]____

14. Coordinated dissemination of public information during emergencies is established. [7]

U]

15. Adequate facilities are maintained to support emergency response. [8]

[]

16. Adequate equipment is maintained to support emergency response. [8]

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9]

U]

18. A range of public PARs is available for implementation during emergencies. L[10]

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are U]

available to support the formulation of PARs and have been provided to State and local governmental authorities. [10]

20. A range of protective actions is available for plant emergency workers during emergencies, including U]

those for hostile action events.[1 0]

EN-EP-305 REV 3

P ATTACHMENT 9.1 SHEET 3OF 3 t0CFRS0.54(q) SCREENING ProcedurelDocument Number: EAP-4C Revision: 01 EquipmentlFaclltylOther: N/A

Title:

Protective Action Recommendations

21. The resources for controlling radiological exposures for emergency workers are established. [11][

22. Arrangements are made for medical services for contaminated, Injured individuals. [12]

r-

23. Plans for recovery and reentry are developed. [13]

[

24. A dril'l and exercise program (including radiological, medical, health physics and'other program

[

areas) is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, LI1 maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]

26. Identified weaknesses are corrected. [14]

III

27. Training is provided to emergency responders. [15]

[

28. Responsibility for emergency plan development and review is established, [16]

29. Planners responsible for emergency plan development and maintenance are properly trained [16)

III APPLICABILITY CONCLUSION o If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI.

l[1 If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION Emergency planning element 10 in Part V of this form is affected by the change to remove a requirement to complete offsite monitoring prior to issuing PARs beyond 10 miles. A 10CFR50.54 (q) evaluation will be performed to determine whether or not the effectiveness of the emergency plan is reduced and prior NRC acoroval is reauired.

Part VI, Signatures:________

Preparer Name (Print)

Prepp eaj*

Date:

/

Pete Cullinan*

2'***

(Optional) Reviewer Name (Print)

Reviewer Signature Date:

N/A N1 P Nuclear EP Project Manager Approver Name (Print)

Approver Signature Date:

James 0. Jones

\\ft()~t j

v/

,- I*- *.t*

EP manager or designee

(

EN-EP-305 REV 3

ATTACHMENT 9.2 I OCFR5O.54(q) EVALUATION ATTACHMENT 9.2 10CFRS0.54(q) EVALUATION ProcedurelDocument Number: EAP-4C Revision: 01 EquipmenitlFacilitylOther: NIA

Title:

Protective Action Recommendations Part h. Description of Proposed Change:

The change removes a requirement to complete offsite monitoring prior to issuing PARs beyond 10 miles.

The supporting details of the text changes to section 6.1.3 are as follows:

Revise note 2 at beginning of Section 6.1.3 to include the words "When available,..

Delete Section 6.1.3.A, renumber sections accordingly.

Revise previous section 6.1.3.B to delete "IF field surveys verify the calculated dose assessment exposure rates, then" Added section 6.1.3.A.1: 'IF not already performed, THEN direct DISPATCH of Field Monitoring Teams to downwind areas outside the 10 mile EPZ to validate expanded PARs adequately bound the areas with PAGs exceeded."

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

1. The FSAR, Tech Spec Amendments, TRM and Emergency Plan Section 6 were reviewed electronically with the following results:

a.

FSAR - Protective Action, Emergency P Tech Specs - Protective Action, Emergency P TRM - Protective Action, Emergency P Emergency Plan Section 6 Rev 35 (Current revision) - PAR, Protective Action Emergency Plan Section 6 Rev 36 (Pending revision) - PAR, Protective Action Licensing Research System (commitments) - Protective Action

b.

List relevant sections of controlled electronic documents reviewed:

FSAR:

Chapter 13.8.5 Emergency Plans and Procedures - no relevant hits Protective Action - no relevant hits throughout document Tech Specs - No relevant hits throughout the document.

TRM - No relevant hits throughout the document.

Emergency Plan Section 6 Rev 35 (Current revision):

6.2.3 Dose Assessment Methods and Techniques - a general discussion of the dose assessment methods utilized to develop PARs, there is no requirement contained in this section to perform field surveys prior to issuing PARs beyond 10 miles.

6.4.20Offsite Protective Actions - the section states that dose projections will be compared to Protective Action Guidelines with no indication that field surveys are required to be performed prior to issuing PARs beyond 10 miles.

Emergency Plan Section 6 Rev 36 (Pending revision):

6.2.3 Dose Assessment Methods and Techniques - a general discussion of the dose assessment methods utilized to develop PARs, there is no requirement contained in this section to perform field surveys prior to issuing PARs beyond 10 miles.

6.4.20Offsite Protective Actions - the section states that dose projections will be compared to Protective Action Guidelines with no indication that field surveys are required to be performed prior to issuing PARs beyond 10 miles.

Page 1 of 5

Part Ill. Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:

10 CFR 50.47(b)(10).

A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI), as appropriate.

Evacuation time estimates have been developed by applicants and licensees. Licensees shall update the evacuation time estimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.

site Compliance The proposed change and subsequent adjustments to EAP--C section 6.1.3 remove the need to verify dlose projections with field readings prior to making a Protective Action Recommendation to the offsite authorities.

The proposed changes remain compliant with the rule because it does not affect; 1) the licensees ability to recommend a range of Protective Action Recommendations to offsite officials including evacuation, sheltering and prophylactic use of KI as appropriate, 2) the evacuation time estimates or the ability to update evacuation time estimates on a periodic basis, or 3) the ability to modify or revise the choice of protective actions available during an emergency or the ingestion exposure pathway EPZ. Specifically:

Revise note 2 at beginning of Section 6.1.3 to include the words 'When available,....':

o This change directs the use of field survey data when it is available when developing PARs.

Adding the words "when available" does not remove or inhibit the ability to recommend PARs, and under certain circumstances ensures that PARs can be provided to offsite agencies without undue wait for field survey results.

Delete Section 6.1.3.A, renumber sections accordingly.

o This change removes the requirement to obtain survey readings prior to issuing PARs beyond 10 miles. Removing this section combined with the other clarifying changes ensures that PARs can be issued in a timely manner without undue delay awaiting field survey information.

Revise previous section 6.1.3.B to delete "IF field surveys verify the calculated dose assessment exposure rates, then":

o Removing this wording combined with the other clarifying changes ensures that PARs can be issued in a timely manner without undue delay awaiting field survey information.

Added section 6.1.3.A.1: "IF not already performed, THEN direct DISPATCH of Field Monitoring Teams to downwind areas outside the 10 mile EPZ to validate expanded PARs adequately bound the areas with PAGs exceeded.":

o Addition of this section ensures field teams are dispatched to areas previously identified for PARs to validate the PARs recommended are adequate, or if necessary can be modified in a timely manner based on field survey assessment.

Previous NRC Commitments -

The Licensing Research System (commitments) and Section 6 of the Emergency Plan were reviewed for potential NRC commitment changes as a result of the procedure revision. There were no identified conflicts with this procedure revision and the current listing of NRC commitments associated with Protective Action Recommendations. All current NRC commitments that relate to dose assessment and protective actions continue to be maintained with the proposed procedure revision.

Page 2 of 5

Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change:

10 CFR 50.47(b)(.1_)

- Emergency Protective Actions A range of public PARs is available for implementation during emergencies.

Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities.

A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.

Page 3 of 5

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

The change removes a procedure requirement to complete offsite monitoring prior to issuing PARs beyond 10 miles. The change enhances the timeliness of PAR issuance to the offsite agencies based on removing a delay in situations where downwind survey teams are not in the field or in the area projected to be affected by the plume based on the URI dose assessment software. Removal of the requirement to await survey results removes unnecessary delay for PAR issuance based on the use of the URI model. The impact of the supporting text changes to section 6.1.3 are as follows:

Revise note 2 at beginning of Section 6.1.3 to include the words "When available,..."

o This statement makes the use of field survey data permissive rather than required, thus allowing the field data to be used if available but not delaying the ability to issue PARs when field data is not available. This change does not affect the Emergency Plan as the ability to issue PARs in a timely manner is maintained and no longer dependent on survey team transit to the indicated areas.

Delete Section 6.1.3.A, renumber sections accordingly:

o The change removes a procedure requirement to complete offsite monitoring prior to issuing PARs beyond 10 miles. The change enhances the timeliness of PAR issuance to the offsite agencies based on removing a delay in situations where downwind survey teams are not in the field or in the area projected to be affected by the plume based on the URI dose assessment software. Removal of the requirement to await survey results removes unnecessary delay for PAR issuance based on the use of the URI model. This change does not affect the Emergency Plan as the ability to issue PARs in a timely manner is maintained.

Revise previous Section 6.1.3.B to delete "IF field surveys verify the calculated dose assessment exposure rates, then":

o This change directs that PARs are to be issued based on dose assessment results and no longer require the field survey information as a confirmatory, thus providing for a timely PAR issuance. Removal of the requirement to await survey results removes unnecessary delay for PAR issuance based on the use of the URI model. This change does not affect the Emergency Plan as the ability to issue PARs in a timely manner is maintained.

Added section 6.1.3.A.1: "IF not already performed, THEN direct DISPATCH of Field Monitoring Teams to downwind areas outside the 10 mile EPZ to validate expanded PARs adequately bound the areas with PAGs exceeded.":

oThis change maintains the ability to verify PARs are adequate and revised if necessary by directing field survey verification of previously recommended PAR areas. Addition of this section ensures the Emergency Plan continues to be able to revise PARs as necessary based on field data when warranted.

This change does not affect the Emergency Plan as the ability to issue PARs in a timely manner is maintained.

The proposed changes to EAP-4C, Protective Action Recommendations, continue to meet the planning standards outlined in 10 CFR 50.47(10). This revision does not require a change to the emergency plan or represent a reduction in the effectiveness to the emergency plan and can be incorporated without prior NRC approval.

Page 4 of 5

ATTACHMENT 9.2 I OCFRSO.54(q) EVALUATION ATFACHMENT 9,2 10CFR50.54{q) EVALUATION Pro--cedr/oument Nu----

ber:E---AP-4c....

Revision: 01' EquipmentlFacilttylOther: N/A

Title:

Protective Action Recommendations Part VI. Evaluation Conclusion Answer the following questions about the proposed change.

I. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E'9 O*YV.. [ NO

2. Does the proposed change maintain the effectiveness of the emergency plan (i e., no YS N

reduction in effectiveness)?

3. Does the proposed change constitute an emergency action level scheme change?

O-YES 0] NO If questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRC approval under provisions of 10 CFR 50.90. If questions 1 and 2 are answered YES, and question 3 answered NO, implement applicable change process(es). Refer to step 5.618].

Part VII, Signatures Preparer Name (Print)

Dale:

Pete Cullinan+"

(Optional) Reviewer Name (Print)

Reviewer Signature Date" Reviewer Name (Print)

,,Re~viewer Signature Date:

Nuc.lear EP Project Manager EP Manager or designee______________________________

Page 5 of 5

---Entergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 James D. Jones Manager Emergency Planning JAFP-1 6-0025 February 23, 2016 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

Transmittal of Emergency Plan Updates James A. FitzPatrick Nuclear Power Plant Docket No.50-333 License No. DPR-059

Dear Sir or Madam:

The documents enclosed with this letter are changes to the James A. FitzPatrick Nuclear Power Plant's (JAF) Emergency Plan made pursuant to 10 CFR 50.54(q). This transmittal fulfills the requirements of 10 CFR 50.54(q), 10 CFR 50 Appendix E Section V, 10 CFR 70.32(i), and 10 CFR 72.44(f) to inform the commission of changes that have been made which do not decrease the effectiveness of the Emergency Plan.

The following documents (including change documentation, evaluation and screening) are attached:

EAP-4C, Rev. 1 This letter contains no new regulatory commitments.

If you should have any questions, please contact Mr. James D. Jones at (315) 349-6030.

Sincerely, Manager Emergency Planning J DJ :cfv Enclosure(s):

Including change documentation, evaluation and screening:

EAP-4C, Rev. 1

~4L~

JAFP-1 6-0025 Page 2 of 2 cc w/o procedure documentation, evaluation and screening:

USNRC (l&E) Regional Administrator, Region I - Controlled - 2 Copies NRC Resident Inspector - Controlled - 1 Copy NRC Director NMSS - Uncontrolled - 1 Copy NRC Director Division of Spent Fuel Storage and Transportation - Uncontrolled - 1 Copy NRC Director, Division of Security Policy - Uncontrolled - 1 Copy NYSEMO - Controlled - 1 Copy OCEMO - Controlled - 1 Copy

JAFP-1 6-0025 Enclosures Including change documentation, evaluation and screening:

EAP-4C, Rev. 1

ATTACHMENT 9.4 NRC SUBMITTAL REVIEW Sheet I of 2 S-U bject..::.Transmittal iof Em.ergency Pian Updates>*

,.:. :.Date ssued. dfor Review*: :i/i.7/16-"...:

C:orres-p~ondence P*reprerl " Phone #:! Cathee Vickery 31-349-639 77-7"..----

i

.: ::i:-.i Section I Letter Concurrence and Agreement to Perform Actions

-" PO.SITION I NAME.-:

.I:":_

Actio~n",

Signature..

-::-., ! --.. *:-" -..,I:(c~oncurrence, "cert'ification, letc.)

'.(sign.; int~eroffi~e m~emo,e-email, or.-:>..:

Emergency Planning Dept.

Preparer/Reviewer Cathee Vickery/**,

1 Licensing Department Concurrence Mark Hawes /

-*E.m erig e* n.c.y* *Pr~e.P-ari e-d. n-.!ess M ia-n-a g~er *:..A.Pi-P.ro:v.e.r.COMNS..

James Jones /

-EAP-4C, Revision 1 Section II Correspondence Screening Does this letter contain commitments? If "yes," identify the commitments with due dates Yes LI in the submittal and in Section III. When fleet letters contain commitments, a PCRS 10 No

[

(e.g., LO-LAR, LO-WT) should be initiated with a CA assigned to each applicable site to enter the commitments into the site's commitment management system.

Does this letter contain any information or analyses of new safety issues performed at NRC Yes El request or to satisfy a regulatory requirement? If "yes," reflect requirement to update the No

[

UFSAR in Section II1.

Does this letter require any document changes (e.g., procedures, DBDs, FSAR, TS Bases, Yes LI etc.), if approved? If "yes," indicate in Section III an action for the responsible No

[

department to determine the affected documents. (The Correspondence Preparer may indicate the specific documents requiring revision, if known or may initiate an action for review.)

Does this letter contain information certified accurate? If "yes," identify the information Yes LI and document certification in an attachment. (Attachment 9.5 must be used.)

No

ATTACHMENT 9.4 NRC SUBMITTAL REVIEW Sheet 2 of 2 Section III Actions and Commitments Required Actions Due Date Responsible Dept.

Note: Actions needed upon approval should be captured in the appropriate action tracking system NIA Commitments Due Date Responsible Dept.

Note: When fleet letters contain commitments, a PCRS LO should be initiated with a CA assigned to each applicable site to enter the commitments into the site's commitment management system.*

NIA Section IV Final Document Signoff for Submittal Correspondence Preparer Ca thee Vickery /I

/

/.*

Final Submittal Review (optional)

N/A/

Responsible Department Head James Jones / I

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A~JD R~IP1>ACKNuWLEpG~MENTFQfIM TO:

DEPT.:

LOCATION:

DC/RockvillelvD EP Admin Emergency Planning USNRC Document Control Center, Washington SPECIAL NOTES:

JAFP Memo & EN-LI-106 form required.

Include 10CFR50.54(q)

Screen and Evaluation (EN-EP-305 Attach 9.1 & 9.2)

CONTROL MANUAL NUMBER 34 FROM:

DEPT.:

LOCATION:

DATE:

KELLY SAWYER ADMINISTRATIVE SERVICES JAF February 16, 2016 APPLICABLE MANUAL:

E-PLAN PROCEDURES UPDATE LITUPDATE LIST VOLUME 2 N/A 2/2312016 EAP-4C PROTECTIVE ACTION RECOMMENDATIONS 1

2/23/2016 INSTRUCTIONS:

1.

Insert the attached revised documents, and withdraw any noted WITHDRAWN documents from your controlled copy.

2.

DISCARD ALL SUPERCEDED DOCUMENTS, as applicable. DISCARD THIS TRANSMITTAL.

NOTE Failure to incorporate these documents into your controlled manual will result in cancellation of the subject controlled documents.

EMERGENCY PLAN IMPLEMENTING PROCEDURES/VOLUME 2 UPDATE LIST Date of Issue:

2/23/20 16 Procedure Procedure Revision Date of Last Use of Number Title Number Review Procedure NIA TABLE OF CONTENTS REV. 22 07/15 Informational lAP-I EMERGENCY PLAN IMPLEMENTATIONRE.4095 Inoatnl CHECKLIST CLASIFICTIO OF MERGNCYREV.

34 IAP-2 CONDSIFATIONS OFEEGNFLOWCHART 07/15 Informational CONDIIONSREV.

10 EAP-1.1 OFFSITE NOTIFICATIONS REV. 72 10/15 Informational EAP-2 PERSONNEL INJURY REV. 33 05/15 Informational EAP-3 FIRE REV. 26 0 1 /13 Informational EAP-4 WITHDRAWN (12/14)

EAP-4A ONSHIFT DOSE ASSESSMENT REV. 0 12/14 Informational EAP-4B DETAILED DOSE ASSESSMENT

.REV.

1 12/14 Informational EAP-4C PROTECTIVE ACTION RECOMMENDATIONS REV. 1 12/14 Informational

. EAP-4.1 RELEASE RATE DETERMINATIONRE.21/4 Inomtna EAP-5.1 DELETED (02/94)

EAP-5.2 DELETED (04/9 1)

EAP-5.3 ONSITE/OFES1TE DOWNWIND SURVEYS AND REV. 21 06/12 Informational ENVIRONMENTAL MONITORING___________

EAP-6

[N-PLANT EMERGENCY SURVEY/ENTRY REV. 19 02/ 14 Informational EAP-7. i DELETED (02/94)

EAP-7.2 DELETED (02/94)

EAP-8 PERSONNEL ACCOUNTABILITY REV. 74 09/13 Informational EAP-9 SEARCH AND RESCUE OPERATIONS REV. 13 08/13 Informational EAP-l10 PROTECTED AREA EVACUATION REV. 22 10/ 13 Informational EAP-1I 1 SITE EVACUATION REV. 23 1 0/13 Informational DOSE ESTIMATED FROM AN ACC*IDE*NTAL t.....

EAP-12 RELEASE OF RADIOACTIVE MATERIAL TO REV. 13 02/14 Informational LAKE ONTARIO_____

S EAP-13 DAMAGE CONTROL REV. 22 07/11 Informational Pag °~ONTR LL

EMERGENCY PLAN IMPLEMENTING PROCEDURES/VOLUME 2 UPDATE LIST Date of Issue:

2/23/2016 Procedure Procedure Revision Date of Last Use of

,,i.Number

,Title Number Review

.. Procedure EAP-14.1 WITHDRAWN (02/23/05)

EAP-14.2 WITHDRAWN (02/23/15)

EAP-14.5 WITHDRAWN (02/23/15)

EAP-14.6 HBTBLTOFTEERGNYREV.

18 04/14 Informational FACILITIES EAP-14.7 REMOTE ASSEMBLY AREA ACTIVATION REV. 3 12/14 Reference EAP-4.8 ALTERNATE TSC/SC ACTIVATION AND RV 21 eeec OPERATION EAP-15 EMREC AITO XOUEREV.

13 07/15 Informational

________CRITERIA AND CONTROL_____

EAP-16 PUBLIC INFORMATION PROCEDURE REV. 9 03/14 Informational EAP-16.2 JOINT INFORMATION CENTER OPERATION REV. 16 12/15 Informational EAP-1i7 EMERGENCY ORGANIZATION STAFFING REV. 124 09/15 Informational EAP-I18 DELETED (12/93)

EAP-19 EMERGENCY USE OF POTASSIUM IODINE (KI)

REV. 29 10/11 Informational EAP-20 POST ACCIDENT SAMPLE, OFFSITE SHIPMENT REV. 11 04/14 Informational

________AND ANALYSIS___________

EAP-21 DELETED (12/85),,

EAP-22 DELETED (02/98)

EAP-23 EMERGENCY ACCESS CONTROL REV. 15 04/14 Informational EAP-24 EFVHCEADPRONLREV.

11 12/14 Informational DECONTAMINATION EAP-25 DELETED (02/94)

Page 2 of 2

O ENTERGY NUCLEAR OPERATIONS, INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURE PROTECTIVE ACTION RECOMMENDATIONS EAP-4 4C REVISION 1 EFFECTIVE DATE:

~2~AAadi'Ži~~ £92: ~2~1/22 I.

I

/

INFOMITIONRATUSE QUALITY RELATED PERIODIC REVIEW DUE DATE:

PROTECTIVE ACTION RECOMMENDATIONS EAP -4 C REVISION

SUMMARY

SHEET REV.

NO.

1 Procedure change to section 6.1.3 to address Columbia Station CE on not requiring field team data prior to making PARs beyond 10 mile EPZ.

(CR-HQN-2015-850 CA#2 )

Revise note 2 at beginning of Section 6.1.3 to include the words "When available,"

Delete Section 6.1.3.A, renumber sections accordingly.

Revise previous section 6.1.3.B to delete "IF field surveys verify the calculated dose assessment exposure rates, then"

Deleted word "the" for grammatical correctness.

Added section 6.1.3.A.I: "IF not already performed, THEN direct DISPATCH of Field Monitoring Teams to downwind areas outside the 10 mile EPZ to validate expanded PARs adequately bound the areas with PAGs exceeded."