ML17286A023

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Description of Changes/Summary of Analysis Evaluation for Emergency Plan Implementing Procedure Change and Revision 18 to EPIP 0PGP05-ZV-0010
ML17286A023
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 10/03/2017
From:
South Texas
To:
Office of Nuclear Reactor Regulation
Shared Package
ML17286A015 List:
References
NOC-AE-17003521
Download: ML17286A023 (48)
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Text

Attachment 1 NOC-AE-17003521 Attachment 1 Description of Changes I Summary of Analysis Evaluation

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Attachment 1 NOC-AE-17003521 Page 1 of 3 OPGPOS-ZV-0010, Emergency Plan Changes, Revision 18 (Effective 9/26/17)

No. Change Reason Definition Section (for "Change", 4th bullet Editorial clarification.

1. under step 3.4 modified from:

"Refer to Regulatory Guide 1.219 Section 3.6 for a complete discussion on what is considered a change."

to:

"Refer to §50.54(q)(1)(i) and (ii), respectively, as expanded on in Regulatory Guide 1.219 Sections 3.6 and 3.5 for a complete discussion on what is considered a change" Addendum 1, Screening Evaluation Editorial clarification.

2. Instructions, Addendum 2, Effectiveness Evaluation Instructions, and Addendum 3, EAL Evaluation Instructions were re-formatted to include automatic step numbering. Bulleted items were relocated into note boxes, duplicated information was removed, and steps re-worded without changing intent.

Screen Evaluation (Form 1) and Addendum Procedure was lacking guidance for

3. 1, Screening Evaluation Instructions modified activities that are not actually to include consideration for items that are not changes to the emergency plan but a change to the emergency but may could potentially impact potentially affect implementation of the implementation of the emergency emergency plan. plan.

Addendum 1, Screening Evaluation Procedure guidance did not allow Instructions modified to add verbiage on how screening out items that are a the use of the term "affects" is used related to change to the Emergency Plan, but the screening process. do not affect implementation of a planning standard or element.

Addendum 1, Screening Evaluation lnstruetions modified to add verbiage on how items that are a change to the Emergency Plan, but do not affect implementation of a planning standard or element may be screened out.

A new question was added to Screen Evaluation (Form 1) Block 5 to clearly delineate if a planning standard is affected.

Attachment 1 NOC-AE-17003521 Page 2 of 3 OPGPOS-ZV-0010, Emeraency Plan Changes, Revision 18 {Effective 9/26/17)

No. Change Reason Addendum 1, Screening Evaluation Step was misleading. Any potential

4. Instructions, bulleted step prior to step 5.0 re- impact must be identified to ensure worded from: proper screening.

"The screening evaluation need not identify all planning standard functions or program elements that are associated with the proposed activity. Identification of one function br element is sufficient to complete the screening evaluation."

to:

"The screening evaluation includes all planning standard functions or program elements that are potentially affected by the proposed activity."

Addendum 1, Screening Evaluation Steps are not applicable for

5. Instructions, deleted step 7.3 and sub step screening form.

7.3.1 that read:

"Check the box that indicates that the activity cannot be implemented. An NRC license amendment is required, under §50.90. An Effectiveness Evaluation is not required, for the following condition:

Based upon the screening, the activity is a change that will require NRC approval prior to implementation. For an example: an emergency action level scheme change."

1.

Attachment 1 NOC-AE-17003521 Page 3 of 3 The procedure change does not negatively alter the current methodology for review of and retention of proposed changes to emergency plan or other changes that may impact implementation of the emergency plan. The change to the screening process continues to ensure proposed changes are reviewed, and an effective methodology is in place to identify changes that must be evaluated prior to implementation. The process continues to maintain provisions for demonstrating that proposed changes do not reduce the effectiveness of the plan. The process continues to maintain a method to demonstrate such changes continue to meet the requirements in appendix E, prior to implementation. The procedure follows guidance contained in Regulatory Guide 1.219.

10 CFR 50.54(a) Summary of Analysis Evaluation for change:

The changes have been evaluated and the determination made that:

  • The changes do not affect the licensing basis.
  • The changes do not affect any function or element of a Planning Standard and does not affect an Emergency Preparedness commitment.
  • The changes do not affect the meaning or intent of the procedure, facilities or equipment, or any processes.
  • This procedure continues to comply with regulations.

Based upon the evaluation, the changes do not represent a Reduction in Effectiveness of the Emergency Plan.

Attachment 2 NOC-AE-17003521 Attachment 2 South Texas Project Electric Generating Station Emergency Plan Implementing Procedure, OPGPOS-ZV-0010, Emergency Plan Change, Revision 18

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION D0527 STI: 34543202 Rev. 18 OPGP05-ZV-0010 Page 1of43 Emergency Plan Change Quality I Non Safety-Related I Usage: Available Effective Date: 09/26/17 S. Korenek G. Williams NIA Emergency Response Division PREPARER TECHNICAL USER COGNIZANT ORGANIZATION Table of Contents

1.0 Purpose and Scope

............................................................................................................................. 2 2.0 Responsibilities .................................................................................................................................. 2 3.0 Definitions .......................................................................................................................................... 4 4.0 Procedure ............................................................................................................................................ 6 5.0 References ........................................................................................................................................ 11 6.0 Support Documents .......................................................................................................................... 12 Addendum 1, Screening Evaluation Instructions ............................................................................. 13 Addendum 2, Effectiveness Evaluation Instructions ....................................................................... 22 Addendum 3, EAL Change Evaluation Instructions ........................................................................ 31 Addendum 4, Emergency Plan Maintenance Guidance ................................................................... 34 Addendum 5, Examples of Changes That do not Require Prior NRC Approval.. ........................... 3 5 Addendum 6, Examples of Changes Requiring Prior NRC Approval.. ........................................... 36 Form 1, Screen Evaluation Form ..................................................................................................... 37 Form 2, Effectiveness Evaluation Form ........................................................................................... 39 Form 3, EAL Change Evaluation Form ........................................................................................... 40 Form.4, Emergency Plan*Approval Form ........................................................................................ 43

I OPGP05-ZV-0010 I Rev.18 I Page 2 of43 Emergency Plan Change

1.0 Purpose and Scope

1.1 This procedure provides guidance for the revision and approval of the South Texas Project (STP) Emergency Plan and implementing procedures.

1.2 This procedure defines the requirements of Title 10, Code of Federal Regulations, Part 50.54(q), for maintaining the Emergency Plan.

1.3 This procedure provides for the method to evaluate proposed plant and procedures changes to determine if they affect the Emergency Plan or emergency response.

1.4 This procedure implements appropriate portions of the STP Emergency Plan.

2.0 Responsibilities 2.1 The Approval Authority (Reference step 3.2) is responsible for:

2.1.1 Approving Emergency Plan changes.

2.2 The Plant General Manager is responsible for:

2.2.1 Recommending for approval Revisions and ICNs to the Emergency Plan.

2.2.2 Approving Revisions to select implementing procedures.

2.3 The Emergency Response Manager is responsible for:

2.3 .1 Approval of select implementing procedures.

2.4 The Emergency Response Staff is responsible for:

2.4.l Completing Screen Evaluation (Form 1) or Effectiveness Evaluation (Form 2) for changes identified by other processes (i.e. License Compliance Review, Plant Design Changes, etc.) that may have a potential affect on the Emergency Preparedness Program.

I OPGPOS-ZV-0010 I Rev.18 I Page 3 of43 Emergency Plan Change 2.5 The Supervisor, Emergency Response, or designee, is responsible for:

2.5.l Maintaining the Emergency Plan and implementing procedures in accordance with appropriate regulations.

2.5.2 Performing and documenting an annual review of the Emergency Plan and implementing procedures, in accordance with procedure OPGP05-ZV-0014, Emergency Response Activities, to include:

  • . Written critiques and evaluations of drills/exercises;
  • Changes in key personnel that are part of the Emergency Response Organization;
  • Changes in the organizational structure;
  • Changes in applicable Federal and State regulations;
  • Changes in functional capability of support organizations;
  • Modifications to the Station facilities, procedures, emergency response facilities, site or operating status that could affect emergency response;
  • Recommendations received from other organizations, such as Federal, State, or County agencies or private support groups;
  • Independent audit findings;
  • Comments from the State and County;
  • Documented Condition Report or NRC Inspection Report identified items and;
  • Changes to implementing procedures; and
  • Changes to Letters of Agreement .

2.5.3 Approving Screen Evaluation (Form 1), Effectiveness Evaluation (Form

2) and EAL Change Evaluation (Form 3).

2.6 Appropriate Department Managers, or designees, are responsible for:

2.6.l Reviewing and commenting on proposed Revisions and ICNs to the Emergency Plan.

I OPGPOS-ZV-0010 I Rev. 18 I Page 4 of43 Emergency Plan Change 3 .0 Definitions

3.1 ACTIVITY

A series of events or actions that may result in a change to the emergency plan or affect the implementation of the emergency plan.

  • An activity sets in motion the need to determine impact on certain licensing bases documents using regulatory review criteria such as §50.54(q).
  • Activities may range from a simple editorial change or an organizational change, to complicated facility modifications.
  • For the purposes of §50.54(q), activities may also originate outside of the licensee's responsibility such as permanent road closings or substantive population increases.

3.2 APPROVAL AUTHORITY for Emergency Plan Changes: The Management position one level above the Department Manager that has responsibility for the Emergency Preparedness Program.

3.3 CAPABILITY

The capacity to implement the response actions or fulfill the administrative provisions identified in the emergency plan. Capability can be evaluated and described by the following:

  • Methods: The procedural means or manner of implementing the response actions or fulfill the administrative provisions identified in the emergency plan.
  • Resources: The personnel, procedures, equipment, communications, instrumentation, analytical equipment, transportation, supplies, and other items needed to implement the response actions or fulfill the administrative provisions identified in the emergency plan.
  • State or Condition:
  • The material means of implementing the response actions or fulfill the administrative provisions identified in the emergency plan; such as operative, physical or spatial.

3.4 CHANGE

An action that results in modification or addition to, or removal from, the licensee's emergency plan.

  • Editorial and typographical changes are formatting, paragraph numbering, spelling, or punctuation that do not change intent.
  • Conforming changes are those changes that been submitted to and approved by the NRC or FEMA through other formal change processes (for example, FSAR/TS equipment changes, EAL scheme changes, ANS design certification changes, etc.).
  • Interdependent changes involve two or more activities that collectively impact a function (these are typically where one change compensates for another change).
  • Refer to §50.54(q)(l)(i) and (ii), respectively, as expanded on in Regulatory Guide 1.219 Sections 3.5 and 3.6 for a complete discussion on what is considered a change.

I OPGPOS-ZV-0010 I Rev. 18 I Page 5 of43 Emergency Plan Change 3.5 EMERGENCY PLAN: The document(s) prepared and maintained by the licensee that identify and describe the methods for maintaining emergency preparedness and responding to emergencies.

  • An emergency plan includes the plan the NRC originally approved and all subsequent changes made by the licensee with, and without, prior NRC review and approval under 10 CFR 50.54(q).

. G 3.6 EMERGENCY PLANNING FUNCTION: A capability necessary to prepare for and respond to a radiological emergency, as set forth in 10 CFR Part 50 Appendix E Section IV and in 10 CFR 50.47(b).

3.7 IMPACT

Change or alter the methods that verify compliance with the planning standards in 10 CFR 50.47(b) or the requirements in Appendix E to 10 CFR Part 50; or reduces the capability or resources necessary to prepare for, and respond to, a radiological emergency.

3.8 PLANNING STANDARDS: The 16 standards delineated in 10 CFR 50.47(b) that onsite and offsite emergency plans must meet in order for the NRC to find reasonable assurance that adequate protective measures can and will be taken.

3.9 PROGRAM ELEMENTS: The items that comprise the implementation aspects of an emergency planning function. These items correspond to the evaluation criteria in NUREG-0654 (or other alternative methods for which the licensee obtained approval) that identify specific acceptable methods for complying with an emergency planning function.

3.10 REDUCTION IN EFFECTIVENESS: A change to an emergency plan that results in reducing the licensee's capability to perform an emergency planning function in the event of an emergency.

3.11 REGULATORY REQUIREMENT: Any emergency preparedness-related requirement, including the 10CFR50.47 planning standards, Appendix E to 10 CFR Part 50, 10 CFR 50.54(q), 10 CFR 50.54(t), commitments made in the emergency plan, Commission orders, and commitments made with regard to compensatory actions under 10 CFR 50.47(c) or 10 CFR 50.54(s)(2)(ii). "Regulatory requirement" includes a licensee's self-imposed requirements necessary for demonstrating compliance with the planning standards and Appendix E to 10 CFR Part 50.

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I OPGP05-ZV-0010 I Rev. 18 I Page 6 of43 Emergency Plan Change i 4.0 Procedure I .

I NOTE In instances where a revision to a page or multiple pages of the Emergency Plan is necessary, without performing a full revision, the change may be processed as an Interim Change Notice (ICN).

4.1 Emergency Plan Change Process 4.1.1 Revisions to the Emergency Plan shall be accomplished, as needed, and shall include items identified during annual review.

4.1.2 Changes shall be prepared as follows:

  • Every affected page of the Emergency Plan shall be marked to reflect the proposed change number. A full revision includes all pages.
  • The proposed change shall be reviewed in accordance with procedure OPAPOl-ZA-0103, License Compliance Review, Form 1. Revisions are exempt from 10 CFR 50.59 Screening so skip questions 1 through 4 and go to question 5.
  • The proposed change shall be reviewed in accordance with procedure OPAPOl-ZA-7358, Security Compliance Review, Form 1.
  • The proposed change shall be reviewed using a 50.54(q) screening evaluation to determine whether an effectiveness evaluation is required. The screen will be performed in accordance with Addendum 1 of this procedure and documented on Form 1, Screen Evaluation Form.

NOTE Addendum 5 provides examples of changes that do not require prior NRC approval.

Addendum 6 provides examples of changes requiring prior NRC approval.

  • If the screen evaluation concludes a 50.54(q) effectiveness evaluation is required to determine whether the revision can be made without prior NRC approval, then perform the effectiveness evaluation in accordance with Addendum 2 of this procedure and document using Form 2, Effectiveness Evaluation Form.

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I OPGPOS-ZV-0010 I Rev. 18 I Page 7 of43 Emergency Plan Change

  • IF the change affects an Emergency Action Level, conduct a review of the EAL in accordance with Addendum 3 and document the evaluation on Form 3, EAL Change Evaluation Form.
  • An independent technical review shall be performed utilizing OPAPOl-ZA-0102, Form 4, Technical Review Checklist.

4.1.3 If Form 2, Effectiveness Evaluation Form, concludes that the change will result in a Reduction in Effectiveness, then NRC approval is required prior to implementation.

4.1.3.1 Process the change as a license amendment request in accordance with OPGP05-ZN-0004, Changes to Licensing Basis Documents and Amendments to the Operating License. (Ref 5.14) 4.1.4 If Form 3, EAL Change Evaluation, concludes that the activity is not consistent with the license basis for the EAL or the change is considered a Reduction in Effectiveness, then NRC approval is required prior to implementation.

4.1.4.l Process the change as a license amendment request in accordance with OPGP05-ZN-0004, Changes to Licensing Basis Documents and Amendments to the Operating License. (Ref 5.14) 4.1.5 IF the change is determined to require prior NRC approval, then PORC approval is required prior to submitting to the NRC in accordance with OPGP05-ZN-0004 (Ref. 5.14).

4.1.5.l Any changes made during the NRC approval process require PORC submittal and approval by the Plant General Manager prior to effective date.

4.1.5.2 Document NRC approval date on Form 4.

4.2 Review & Comment Requirements:

4.2.1 Forward the proposed change and applicable forms in accordance with procedure OPAPOl-ZA-0102, Plant Procedures, to Quality and all departments that could be affected by the revision.

a. For ICN's, include as a minimum, the Director, Manager, or Coordinator from each emergency response facility affected.
b. For a full revision, include the Director, Manager, or Coordinator from all emergency response facilities.

I OPGP05-ZV-0010 I Rev.18 I Page 8 of43 Emergency Plan Change 4.2.2 Approval 4.2.2.1 Once the proposed change has completed the review and comment cycle, all comments have been resolved, and NRC prior approval has been obtained if applicable, forward to the Plant Operations Review Committee (PORC) for review.

  • If change was submitted for, and received NRC prior approval, record the NRC Safety Evaluation Correspondence Number, and date of approval on Form 4.

4.2.2.2 If the proposed change is recommended for approval by PORC, forward to the Plant General Manager for approval.

Document the PORC Meeting No. and date and Plant Manager approval on Form 4, Emergency Plan Approval Form.

4.2.2.3 Submit to the Approval Authority defined in step 3 .2 for final approval. Document on Form 4.

4.2.3 Distribution 4.2.3.1 Place the effective date on the bottom of all affected pages of the Emergency Plan. A full revision includes all pages.

4.2.3.2 Forwarded to Document Control for distribution.

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I OPGP05-ZV-0010 I Rev. 18 I Page 9 of43 Emergency Plan Change NOTE IF an Emergency Plan requirement is removed from the plan and transferred to an implementing procedure, THEN future changes to the implementing procedure must be reviewed in accordance with this procedure to ensure the requirement is maintained consistent with 10 CFR 50.54(q).

4.3 Emergency Plan Implementing Procedure Revisions:

4.3.1 Emergency Plan Implementing Procedures are listed in the Emergency Plan, Attachment 2, Implementing Procedures.

4.3.2 Changes to implementing procedures shall be processed in accordance with OPAPOl-ZA-0102, Plant Procedures.

4.3.3 The proposed change shall be reviewed using a 50.54(q) screen evaluation to determine whether an effectiveness evaluation is required. The screening will be performed in accordance with Addendum 1 of this procedure and documented on Form 1, Screen Evaluation Form.

4.3.4 If the screen evaluation concludes a 50.54(q) effectiveness evaluation is required to determine whether the revision can be made without prior NRC approval, then perform the effectiveness evaluation in accordance with Addendum 2 of this procedure and document using Form 2, Effectiveness Evaluation Form.

4.3.5 If the change affects an Emergency Action Level, conduct a review of the EAL in accordance with Addendum 3 and document the evaluation on Form 3, EAL Change Evaluation Form.

4.3.6 Administrative controls governing usage of the Emergency Plan implementing procedures shall be designated in accordance with procedure OPGPOS-ZV-0004, Emergency Plan Implementing Procedure Users Guide.

4.3.7 Revisions to Emergency Classification Initiating Conditions should be discussed with the state and county government authorities (this list may not be all inclusive):

  • (Texas) Division of Emergency Management (DEM),
  • Department of State Health Services (DSHS),
  • Matagorda County.

I OPGPOS-ZV-0010 Emergency Plan Change Rev.18 Page 10 of43 4.4 NRC Prior Approval Process 4.4.1 Revisions requiring NRC approval prior to implementation shall be processed as a license amendment request in accordance with OPGP05-ZN-0004, Changes to Licensing Basis Documents and Amendments to the Operating License. (Ref 5.14) 4.4.2 Changes made during the NRC approval process require PORC submittal and approval by the Plant General Manager prior to effective date.

4.5 30 Day NRC Transmittal (10 CFR 50.54(q))

4.5.1 All Emergency Plan Revisions and Interim Change Notices (ICN) shall be sent to the NRC Within thirty (30) days after effective date:

4.5.1.1 Make a copy ofrevised Emergency Plan or ICN.

4.5.1.2 Draft a cover letter including the changed pages and Summary of Changes.

4.5.1.3 The summary of changes will include the following information for each change:

  • A description of why the change is editorial (if not editorial, skip this requirement and proceed below)
  • A description of the licensing basis affected by the change to the Emergency Plan (if not affected, omit this item)
  • A description of how the change to the Emergency Plan still complies with regulation. *
  • A description of why the proposed change was not a reduction in the effectiveness of the Emergency Plan.

4.5.2 Submit the package to a classification officer in accordance with OPGP03-ZA-0138, Security Sensitive Information Program ifthe package: (Ref 5.8)

  • May contain Restricted Data, e.g., For Official Use Only, Security Sensitive Information-Withhold from Public.

Disclosure Under 2.390, Sensitive Security-Related Information, Sensitive Unclassified Non-'Safeguards Information.

4.5.3 Submit the package to the Licensing Department for transmittal to the NRC.

I OPGPOS-ZV-0010 I Rev. 18 I Page 11 of43 Emergency Plan Change 5.0 References 5.1 , STP Emergency Plan I

5.2 10 CFR 50, Appendix E 5.3 10 CFR 50.47 5.4 10 CFR 50.54(q) 5.5 10 CFR50.4 5.6 NRC Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, November 2011.

5.7 NRC Regulatory Issue Summary 2005-02, Clarifying the Process for Making Emergency Plan Changes 5.8 NRC Regulatory Issue Summary 2015-17, Review and Submission of Updates to Final Safety Analysis Reports, Emergency Preparedness Documents, and Fire Protection Documents 5.9 . NUREG 0654, FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in support of Nuclear Power Plants, Rev. 1 5.10 NEI 11-03, Guidelines for Evaluating Emergency Plan Changes Under 10 CFR 50.54(q),

Revision 0, January 2012.

  • 5.11 NUMARC/NESP-007, Rev 2 5.12 OPAPOl-ZA-0102, Plant Procedures 5.13 OPAPOl-ZA-0103, License Compliance Review 5.14 OPGP03-ZA-0138, Security Sensitive Information Program 5.15 OPGP05-ZN-0004, Changes to Licensing Basis Documents and Amendments to the Operating License 5.16 OPGP05-ZV-0014, Emergency Response Activities 5.17 OPGP05-ZV-0004, Emergency Plan Implementing Procedure Users Guide 5.18 OPAPOl-ZA-7358, Security Compliance Review 5.19 OERPOl-ZV-lNOl, Emergency Classification 5.20 CR 08-3114 (Proposed revision to the Emergency Plan that bypassed the normal review process, including Plant Operation Review Committee)

I OPGPOS-ZV-0010 j Rev. 18 I Page 12 of 43 Emergency Plan Change 6.0 Support Documents 6.1 Addendum 1, Screening Evaluation Instructions 6.2 Addendum 2, Effectiveness Evaluation Instructions 6.3 Addendum 3, EAL Evaluation Instructions 6.4 Addendum 4, Emergency Plan Maintenance Guidance 6.5 Addendum 5, Examples of Changes Not Requiring Prior NRC Approval 6.6 Addendum 6, Examples of Changes Requiring Prior NRC Approval 6.7 Form 1, Screen Evaluation Form 6.8 Form 2, Effectiveness Evaluation Form 6.9 Form 3, EAL Evaluation Form 6.10 Form 4, Emergency Plan Approval Form

I OPGPOS-ZV-0010 I Rev. 18 I Page 13 of 43 Emergency Plan Change Addendum 1 I Screening Evaluation Instructions I Page 1 of9 NOTES All proposed activities that potentially affect the EP Program shall undergo a screening evaluation to determine and document whether a §50.54(q) effectiveness evaluation is necessary.

This screening applies to activities associated with the emergency plan, including Interim Change Notices or implementing procedures.

The proposed activity may be subject to one or more change processes outside of §50.54(q). If so, compliance with the other applicable change processes is required (such as §50.59, §50.90, §50.54(a) §50.54(p) and 44 CFR 350.14).

The purpose of the screening evaluation is to determine whether a §50.54(q) effectiveness evaluation is required, not to determine if the proposed activity(ies) reduces the effectiveness of the EP Program.

Each proposed change should be evaluated separately. The treatment of changes collectively in the screening evaluation should be reserved for:

  • Repetitive identical changes.
  • Editorial or typographical changes such as formatting, paragraph numbering, spelling, or punctuation that does not change intent.
  • Conforming changes (e.g. changes that implement a change in regulation or NRC approved license amendments)

1 OPGPOS-ZV-0010 I Rev. 18 I Page 14 of 43 Emergency Plan Change Addendum 1 l Screening Evaluation Instructions I Page 2 of9 Screening Flowchart Proposed activity may impact EP Document screening evaluation results indicating the activity can be implemented without performing an Evaluation Implement the activity Submit Emergency Plan change and summary within 30 days Document screening evaluation results indicating the activity cannot be implemented without performing an Evaluation Perform a §50.54(q)

Effectiveness Evaluation using Addendum 2.

Implement the activity Document screening evaluation.

results indicating the activity can be implemented without performing an Evaluation Submit Emergency Plan change and summary within 30 days

OPGPOS-ZV-0010 Rev.18 Page 15 of 43 Emergency Plan Change Addendum 1 Screening Evaluation Instructions Page 3 of9 Proposed activity Block 1 may impact EP 1.0 Use the Screening Evaluation Flowchart as a process aid and document the evaluation on Form 1, Screen Evaluation Form.

1.1 Enter the CR number on Form 1, Screen Evaluation Form.

1.2 Enter a description of the activity. An actual line-in/strike-out mark-up of the change may be attached.

1.3 Enter the references related to the activity that are applicable to the evaluation (e.g.,

CR#, Design Change Package, Procedure Change Request, calculation #, prior approval ADAMS accession#, etc.)

Block2 NOTE An activity may require a corresponding change to the emergency plan which at this point has not yet been determined. This step is simply to establish whether the activity itself is a change to the emergency plan or potentially affects implementation of the emergency plan.

2.0 Determine whether the proposed activity meets the definition of change to the emergency plan (Ref 3.4 and 3.5) OR ifthe proposed activity potentially affects implementation of the emergency plan.

2.1 Check the applicable box.

I OPGPOS-ZV-0010 I Rev.18 I Page 16 of 43 Emergency Plan Change Addendum 1 I Screening Evaluation Instructions I Page 4 of9 I

2.1.1 IF the activity is a change to the emergency continue with step 3.0 of this addendum.

2.1.1.l IF the activity is a change to the emergency plan AND the actual revision is not fully provided in the activity description section OR in an attached change sysposis, THEN a mark-up of the complete change may be attached to the screening evaluation form.

2.1.2 IF the activity is not a change to the emergency plan but may affect implementation of the emergency plan, THEN go to step 5.0 of this addendum.

2.1.3 IF the activity is not a change to the emergency plan, AND does not affect implementation of the emergency plan, THEN go to step 6.0 of this addendum.

Block3 NOTE Editorial and typographical changes include formatting, paragraph numbering, spelling, grammar, or punctuation that do not change intent or value of a program element, or affect the capability or timeliness of the function.

3.0 Determine whether the change is editorial or typographical.

3 .1 Check the applicable box.

3.1.1 IF the change is editorial or typographical, THEN, go to step 7.0 of this addendum.

3.1.2 IF the change is not editorial or typographical,, THEN, continue with step 4.0 of this addendum.

OPGPOS-ZV-0010 Rev.18 Page 17of43 I I I Emergency Plan Change Addendum 1 I Screening Evaluation Instructions I Page 5 of9 Block 4 NOTE Activities that have been submitted to and approved by the NRC or FEMA through other formal change processes do not require a §50.54(q) effectiveness evaluation provided the related change to the emergency plan is specifically and fully addressed in the docketed approval transmittal (such as plant design, equipment, EALs, ANS, etc.).

For orders and submittals that do not specifically or fully address the change or changes to the emergency plan, a §50.54(q) effectiveness evaluation must be completed for the areas not specifically addressed to determine whether implementing the activity would result in a Reduction in Effectiveness.

4.0 Determine whether the change conforms to an activity that has prior regulatory approval.

4.1 Check the applicable box.

4.1.1 IF the activity is a conforming change, THEN go to step 7.0 of this addendum.

4.1.2 IF the activity is not a conforming change, THEN continue with step 5.0 of this addendum.

OPGPOS-ZV-0010 Rev.18 Page 18 of 43 Emergency Plan Change Addendum 1 Screening Evaluation Instructions Page 6 of9 Block 5 NOTE The screening evaluation includes all planning standard functions or program elements that are potentially affected by the proposed activity.

The activity affects an emergency planning function or a program element IF it changes any of the following:

  • The meaning or the intent of a description
  • Facilities or equipment
  • A process 5.0 Determine whether the proposed activity affects a planning standard function or program element.

5.1 Identify any functions and/or program elements associated with the activity. Use the following references as needed.

  • NUREG-0654 5.2 Check the applicable box or boxes for the planning standard(s) related to the function or program element associated with the activity.

5.3 IF the activity affects a planning standard function or program element, THEN check the yes box. Go to step 7.0 of this addendum.

5.4 IF the activity does not affect a planning standard function or program element, THEN check the no box. Go to step 6.0 of this addendum.

I OPGPOS-ZV-0010 I Rev.18 I Page 19 of 43 Emergency Plan Change Addendum 1 I- Screening Evaluation Instructions I Page 7 of9 Block 6 NOTE Most EP Program commitments are associated with a planning standard and would be identified with a function or program element above. The emergency plan may contain licensing basis content associated with other regulations, orders, Atomic Safety and Licensing Board (ASLB), NRC I FEMA correspondence such as RAI response and submittal approval items, or other source material that has been defined as an EP Program commitment.

If the activity is a change to the emergency plan this evaluation item will be obvious.

If the activity is not a change to the emergency plan this evaluation item may be more complicated. For example, a station's telecommunications group is responsible for maintenance of tone alert radios. To save money they propose an activity to reduce the independently performed user survey from animal to biennial and perform it with corporate group. The annual independent survey requirement was an ASLB commitment not written in the emergency plan.

6.0 Determine whether the proposed activity affects an_EP Program commitment (licensing basis item) not associated with a planning standard function or program element.

6.1 Compare the proposed activity with the emergency plan.

6.1.1 Check the appropriate box.

6.2 IF the activity affects an EP Program commitment, THEN:

6.2.1 Record the applicable EP Program commitment or commitment reference.

6.2.2 Go to step 7.0. of this addendum.

6.3 IF the activity does not affect an EP Program commitment, THEN, go to step 7.0 of this addendum.

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Page 20of43 I OPGPOS-ZV-0010 I Rev.18 I Emergency Plan Change Addendum 1 I Screening Evaluation Instructions l Page 8 of9 Document screening evaluation Block 7 results 7.0 Record the screening evaluation results.

7.1 Check the box that indicates the activity can be implemented without performing a

§50.54(q) effectiveness evaluation IF any of the following conditions are met:

7.1;1 The change is editorial or typographical.

7.1.2 The change is fully addressed in and conformed to an activity that has been given prior approval by the NRC or FEMA.

7.1.3 The change does not:

  • Affect a planning standard function or program element
  • Affect a site-specific EP commitment 7.2 Check the box that indicates that the activity cannot be implemented without performing a §50.54(q) effectiveness evaluation IF either of the following conditions are met:

7.2.1 The activity does affect a planning standard function or program element.

7.2.2 The activity does affect a site-specific EP commitment.

7.3 Record name, signature and date for the Preparer.

7.4 Record name, signature and date for the Approver.

Rev.18 Page 21of43 I OPGP05-ZV-0010 I I Emergency Plan Change Addendum 1 I Screening Evaluation Instructions I Page 9 of9 Submit Emergency Plan change Block8 and summary within 30 days NOTE It is not the intent to generate lengthy descriptions, supported by detailed analyses, but rather to capture the essence of the basis for changing the Emergency Plan 8.0 Process the 30 Day NRC Transmittal in accordance with Section 4.5 of this procedure.

8.1 Submit changes to the emergency plan, including a summary of the change analysis, within 30 days after the change is put in effect.

Page 22of43 I OPGP05-ZV-0010 I Rev.18 I Emergency Plan Change Addendum2 I Effectiveness Evaluation Instructions I Page 1 of9 NOTE The NRC expects §50.54(q) evaluations to be of a level of rigor and thoroughness consistent with the scope of the proposed changes with particular emphasis placed on the risk-significant planning standards (§50.47(b)(4), (5), (9), and (10)). The NRC I.

would consider any §50.54(q) evaluation that is of inadequate scope and extent to reasonably assess the impact of the proposed change on the effectiveness of the emergency plan to be a violation of the rule.

Each proposed change should be evaluated separately. The treatment of changes collectively in the effectiveness evaluation should be reserved for:

o Repetitive identical changes.

o Two or more program elements that are interdependent (e.g., a change to one program element compensates for a change to another program element).

Addendums 5 and 6 provide examples of changes that do/do not require prior NRC approval from RIS 2005-02. See also Regulatory Guide 1.219, Section C.4 for additional guidance and examples

Page 23 of 43 I OPGP05-ZV-0010 I Rev.18 I Emergency Plan Change Addendum2 I Effectiveness Evaluation Instructions I Page 2 of9

§50.54(q) Effectiveness Evaluation Determine the type of activity to be evaluated.

Determine functions, elements, commitments and licensing basis associated with the activity.

Revise the Activity Reject the Activity Submit for exemption or prior Document effectiveness approval in accordance with evaluation results the licensing LAR process 0 Document effectiveness evaluation results y Implement the activity Submit Emergency Plan change and summary within G

30 davs

OPGPOS-ZV-0010 Rev.18 Page 24of43 I I I Emergency Plan Change Addendum2 I Effectiveness Evaluation Instructions I Page 3 of9

§50.54(q) Effectiveness Block 1

- Evaluation 1.0 Use the Screening Evaluation Flowchart as a process aid and document the evaluation on Form 2, Effectiveness Evaluation Form.

1.1 Enter the CR number on Form 2, Effectiveness Evaluation Form. Use the same CR action number assigned for screening evaluation.

1.2 Enter a description of the activity or include an actual line-in/strike-out mark-up of the change on Form 2, Effectiveness Evaluation Form.

1.3 Enter and document other references related to the activity that are applicable to the evaluation (e.g., CR#, Design Change Package, Procedure Change Request, calculation #,

prior approval ADAMS accession#, etc.) on Form 2, Effectiveness Evaluation Form.

Determine the type of Block2 activity to be evaluated.

2.0 Determine whether the proposed activity is or requires a change to the emergency plan (Ref 3.4 and 3.5) OR affects implementation of the emergency plan.

2.1 Check the applicable box.

2.2 IF the activity is a change to the emergency plan AND the actual revision is not fully provided in the activity description section OR in an attached change sysposis, THEN a mark-up of the complete change may be attached.

OPGPOS-ZV-0010 Rev.18 Page 25of43 I I I Emergency Plan Change Addendum2 I Effectiveness Evaluation Instructions I Page 4 of9 Determine functions, elements, Block3 commitments and licensing basis associated with the activity.

3.0 Impact and Licensing Basis Determination

  • 3.1 Determine and list all the functions, program elements and EP commitments affected by the proposed activity.

3.1.1 Use the following references to identify any functions and/or program elements associated with the activity.

  • NUREG-0654 NOTE The greatest number of inspection findings has pertained to inappropriate Emergency Action Level changes. An additional review specifically for EAL changes is required to prevent making inappropriate changes and violation of 10 CFR 50.54(q) requirements 3 .2 Identify and record each EP related commitment affected by the proposed activity (organized by planning standard, if applicable).

3.3 IF the change affects an EmergencyAction Level, THEN in addition to the effectiveness evaluation, conduct a review of the EAL change in accordance with Addendum* 3.

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I OPGP05~ZV-0010 I Rev.18 I Page 26 of 43 Emergency Plan Change Addendum2 I Effectiveness Evaluation Instructions I Page 5 of9 NOTE The approved means to meet a particular planning standard function, program element or site specific commitment is documented by and in the Emergency Plan. Subsequent changes may have been implemented that alter the original means for several reasons (e.g., regulatory, administrative, special circumstances, physical and technological upgrades, etc.). The basis for approval of the original means and any subsequent change to it must all be considered to properly establish the actual "licensing basis" in order to evaluate whether a proposed change is non-compliant or a reduction in effectiveness. The licensing basis may be provided in other documents leading to the approval of the emergency plan and subsequent revisions. Documents can include items such as the SERs, Supplemental SERs, licensing hearing transcripts and docketed inspection finding commitments.

3.4 Using Section 1.6 ofRG 1.219 for reference, determine and document the licensing basis for the functions, program elements and commitments affected by the proposed activity.

3.5 IF the licensing basis is different from the basis for the subsequent change, THEN document the reason for the difference.

3.6 List the source of the licensing basis information.

Page 27of43 I OPGP05-ZV-0010 I Rev.18 I Emergency Plan Change Addendum2 I Effectiveness Evaluation Instructions I Page 6 of9 Block 4 4.0 For each affected function, program element or commitment listed in the impact determination, evaluate and document whether the proposed activity continues to provide compliance with the requirements of §50.47(b) and §50, Appendix E.

4.1 Ensure the specific requirement associated with the proposed activity is included or referenced in the evaluation.

4.2 Check the appropriate box in the conclusion.

NOTE Proposed activities that do not continue to provide compliance with the regulatory requirements must be; (1) rejected, (2) revised to achieve compliance, or (3) formally submitted for an exemption to the regulatory requirement per §50.12.

4.3 IF the evaluation concludes that the proposed activity does not continue to provide compliance with the regulatory requirements, THEN go to step 6.2 of this addendum.

OPGPOS-ZV-0010 Rev.18 Page 28of43 Emergency Plan Change Addendum2 Effectiveness Evaluation Instructions Page 7 of9 Block5 NOTE A reduction in effectiveness is usually based on the change to a planning standard function. A change to one or more program elements may not always reduce the effectiveness of the associated planning standard function.

A reduction in effectiveness will occur if there is a decrease in the capabilities or timeliness for performing or fulfilling a function or commitment without activities to compensate for the reduction.

An activity can affect rhore than one program element or function under different planning standards. Each affected program element and function must be evaluated separately as a reduction in effectiveness may occur in one planning standard but not in the other Unless an activity results in repetitive identical changes or multiple activities result in interdependent changes, document the reduction in effectiveness evaluation for each change separately.

5.0 For each affected function, program element or commitment listed in the impact determination, evaluate and document whether the activity constitutes a reduction in effectiveness.

5.1 If the proposed activity affects multiple functions, program elements or commitments, then evaluate and document the overall impact on the effectiveness of the emergency plan or its implementation in a summary section at the end of the block.

5.2 Document a comparison of how the affected function, program element or commitment is currently fulfilled and how it will be fulfilled as a result of the proposed activity,'with specific evaluation of the following attributes:

5.2.1 Continued capability to meet or perform the function, program element or commitment.

5.2.2 Continued timeliness of the function, program element or commitment.

5.3 Review Addendums 5 and 6 and Regulatory Guide 1.219, Section 4 for examples of changes that may or niay not require prior NRC approval.

OPGPOS-ZV-0010 Rev.18 Page 29of43 I - I I Emergency Plan Change Addendum2 I Effectiveness Evaluation Instructions I Page 8 of9 5.4 IF there are any differences in how an affected function, program element or commitment is fulfilled, THEN:

5.4.1 Document a clear basis for the difference (e.g., special circumstances that require the difference in order to effectively perform the function or as a matter of convenience or operating philosophy).

5.4.2 Qualify the difference as improving, sustaining or reducing the effectiveness of the planning standard function or commitment.

5.5 Check the appropriate box in the conclusion.

Document effectiveness Block 6 evaluation results NOTE Proposed activities that reduce the effectiveness of the emergency plan, either through a direct change or by adversely affecting its implementation, must be; (1) rejected, (2) revised to maintain effectiveness, or (3) formally submitted for prior approval per

§50.90.

In the case where it is uncertain whether the proposed change constitutes a reduction in effectiveness, the NRC suggests that a pre-application conference call be arranged with the NRC Headquarters staff to discuss the proposed change and to ask the staff to clarify the regulatory positions in Regulatory Guide 1.219.

6.0 Record the effectiveness evaluation results.

6.1 Check the appropriate box that indicates that the activity can be implemented without prior NRC approval provided both of the following conditions are met:

6.1.l The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E.

6.1.2 The activity does not constitute a reduction in effectiveness.

Page 30 of 43 I OPGP05-ZV-0010 I Rev. 18 I Emergency Plan Change Addendum2 I Effectiven~ss Evaluation Instructions I Page 9 of9 6.2 Check the appropriate box that indicates that the activity cannot be implemented without prior NRC approval provided either of the following conditions are met:

6.2.1 The activity does not continue to comply with the requirements of

§50.47(b) and §50 Appendix E.

6.2.2 The activity does constitute a reduction in effectiveness.

6.3 Record name, signature and date for the Preparer.

6.4 Record name, signature and date for the Approver.

6.5 IF the proposed change(s) do require prior NRC approval, THEN process the proposed change in accordance with OPGP05-ZN-0004, Changes to Licensing Basis Documents and Amendments to the Operating License for approval prior to implementing the change.

Submit Emergency Plan Block 7 change and summary within 30 davs NO:fE Changes to the emergency plan shall be submitted, including a summary of the change analysis, within 30 days after the change is put in effect in accordance with §50.4.

It is not the intent to generate lengthy descriptions, supported by detailed analyses, but rather to capture the essence of the basis for changing the Emergency Plan 7.0 Process the 30 Day NRC Transmittal in accordance with Section 4.5 of this procedure.

Page 31of43 I OPGP05-ZV-0010 I Rev.18 I Emergency Plan Change Addendum 3 I EAL Change Evaluation Instructions I Page 1 of3 NOTE The Emergency Action Levels and the EAL technical bases manual are a part of the emergency plan. This section is applicable to all changes to the EALs that include changes to the technical bases manual, initiating conditions, fission product barriers, mode applicability, bases, definitions, and other subjects necessary to establish the criteria for entering an emergency plan event.

An emergency action level scheme change shall be submitted as an application for an amendment in accordance with OPGP05-ZN-0004 (Ref 5.14) and receive NRC approval before implementation.

Follow the change process in§ 50.54(q) for all other emergency action level changes.

[10 CFR 50, Appendix E.IV.B.(2)]

IF the change did not require an effectiveness evaluation (editorial, typographical or conforming), THEN the change may be implemented without further evaluation.

Block 1 1.0 Use the EAL Change Review Form to document the evaluation:

1.1 Record the Condition Report number on the form.

1.2 Record a description of the change or an actual line-in/strike-out mark-up of the change.

1.3 Record the references related to the change.

Block2 2.0 Perform a verification review of the change. I 2.1 Record the verification check (yes, no or NIA) as appropriate for the change.

2.2 Document any comments for and the resolution of any items that were checked no.

I OPGPOS-ZV-0010 I Rev.18 I Page 32of43 Emergency Plan Change Addendum 3 I EAL Change Evaluation Instructions I Page 2 of3 Block3 3.0 Perform a validation review of the change.

3 .1 Check the method used to perform the validation review.

3.2 Discuss any deletions, additions or modifications to Initiating Conditions with state and county government authorities.

3.3 Record the validation check (yes, no or NIA) as appropriate for the change.

3 .4 Document any comments and the resolution of any items that were checked no.

-Block4 NOTE Whether an EAL change warrants NRC prior approval or can be implemented per

§50.54(q), it is recommended that detailed documentation be compiled to discuss the evaluation of the proposed change. EAL evaluation packages which "stand-alone" will assist in an efficient review and/or inspection process. Supporting information (such as engineering studies, calculations, referenced procedures, diagrams, maps, etc.) is important to include with the supporting document.

4.0 Document the detailed evaluation and technical basis for the change.

Block 5 5.0 Record the EAL change review results.

5 .1 'Check the box indicating the change can be implemented without prior NRC approval IF both of the following conditions are met:

5 .1.1 The change is consistent with the license basis for the EAL and applicable part of the EAL technical basis manual.

5 .1.2 The change does not constitute a reduction in effectiveness.

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I OPGPOS-ZV-0010 I Rev.18 l Page 33 of 43 Emergency Plan Change Addendum3 I EAL Change Evaluation Instructions I Page 3 of3 5.2 Check the box that indicates that the activity cannot be implemented without prior NRC approval IF either of the following conditions are met:

5.2.l The change is considered not consistent with the license basis for the EAL and applicable part of the EAL technical basis manual.

5 .2.2 The change does constitute a reduCtion in effectiveness.

5.3 Record name, signature and date for the Preparer.

5.4 Record name, signature and date for the Approver.

I OPGP05-ZV-0010 I Rev.18 I Page 34of43 Emergency Plan Change Addendum4 I Emergency Plan Maintenance Guidance I Page 1of1 1.0 All proposed changes to the Emergency Plan must be screened and I or evaluated following guidance in Addendums 1 and I or 2 of this procedure.

2.0 Determine the next revision number for the Emergency Plan. For Interim Change Notice (ICN),

use the current Emergency Plan revision number and the next sequential number. For example, Revision 16 becomes ICN 16-1. For major changes use the next sequential number. For example, Revision ICN 16-1 becomes Revision 17. For major revisions all pages of the Emergency Plan shall b~ updated with the new revision number.

3.0 Revise the appropriate steps within the Emergency Plan, documenting step changes and the basis the changes continue to meet the regulation (Block 4) and that the change does not reduce the effectiveness of the Emergency Plan (Block 5) on Form 2, Effectiveness Evaluation Form.

4.0 Obtain an independent technical and editorial review of the changes verifying the proposed change:

4.1 Can be implemented as written.

4.2 Complies with existing regulations and commitments.

4.3 Does not exceed the bounds of an approved 10 CFR 50.54(q) evaluation.

4.4 Does not introduce a 10 CFR 50.54(q) bypass mechanism.

4.5 Process the change following guidance in section 4.1 of this procedure.

I 5.0 Develop an implementation plan that describes the actions necessary for the effective implementation of the proposed changes.

5.1 Make a copy of the newly revised Emergency Plan and provide a summary of changes including the following information for each change:

5 .1.1 A description of the change made to the Emergency Plan.

5.1.2 A description of why the change is editorial (if not editorial, skip this step).

5.1.3 A description of the licensing basis affected by the change to the Emergency Plan (if not affected, skip this step).

5.1.4 A description of how the change to the Emergency Plan still complies with regulation. Reference Form 2, Effectiveness Evaluation Form, Block4.

5.1.5 A description of why the proposed change was not a reduction in the effectiveness of the Emergency Plan. Reference Form 2, Effectiveness Evaluation Form, Block 5.

OPGP05-ZV-0010 Rev.18 Page 35of43 I

Emergency Plan Change Addendum 5 Examples of Changes That do not Require Prior NRC Page 1of1 Approval 1.0 Management, organization and/or responsibility changes are acceptable ifthe function for command and control and the line of succession is clearly defined and assigned tasks do not overload the on-shift organization.

2.0 Organizational changes are acceptable ifthe ability to maintain an on-shift staff without an overload of assignments, and to augment it in accordance with the emergency plan is maintained.

3.0 Changes to ERO augmentation processes are acceptable if they remain capable of ensuring augmentation of the initial response staff in accordance with facility activation commitments.

4.0 Changes to ERO are acceptable if the staffing levels of NUREG 0654, Table B-1 or an approved alternative method are maintained.

5.0 Changes are acceptable if the level of offsi!e assistance is maintained.

6.0 Changes to the Emergency Operations Facility (EOF) are acceptable if accommodations for offsite authorities are adequate.

7.0 Changes to processes to provide follow-up messages and/or the content of the follow-up messages to offsite authorities are acceptable ifthe offsite authorities agree that the process and information content is adequate to support their emergency response needs.

8.0 Changes to communications systems and processes are acceptable if they maintain the capability to implement offsite notifications with 15 minutes.

9.0 A.n increase in communications technology that decreases the need for backup systems is acceptable.

10.0 Changes that provide an alternate means of notifying the public consistent with FEMA guidance are acceptable.

11.0 The use of digital recorders versus paper recorders is acceptable.

12.0 Emergency Action Level and other changes based on NRC approved Technical Specification or Offsite Dose Calculation Manual changes are acceptable.

I OPGPOS-ZV-0010 I Rev. 18 I Page 36 of 43 Emergency Plan Change Addendum 6 I Examples of Changes Requiring Prior NRC Approval I Page 1 ofl 1.0 The licensee installed seismic monitoring equipment that required local readout by a trained l&C Technician using a computer like device: however, the l&C Tech was a 30-minute responder, rather than an on-shift ERO member, thereby, delaying the classification of certain EALs.

2.0 Following an Alert declaration for a carbon dioxide discharge into one of the emergency diesel generator rooms, the licensee implemented a series of corrective actions which included the revision of EALs pertaining to toxic gas events at two stations. These changes were primarily based upon the licensee's assessment that the conditions did not meet the definition of an Alert.

The licensee's change to the EAL would reduce the number of declarable events because not only was the presence of gas required but also an effect on plant operations needs to be considered.

(With the revised EALs, no emergency classification would have been made.) The emphasis of the EAL shifted from personnel safety to the impact on plant conditions or operations.

3.0 A significant deviation in the EAL scheme from the NRC approved version. The deviation involved changes to eight EALs that reduced the effectiveness of the Emergency Plan in that emergency conditions that would have resulted in classification at the General Emergency, Alert, and Notification of Unusual Event levels under the prior NRC approved plan would now result in a lesser classification or no classification.

4.0 Changes that reduce the coverage of or increase the activation time of Alert and Notification Systems without review and approval by offsite agencies and FEMA.

5.0 Equipment is removed from the Emergency Response Facility (ERF) and the plan such that the capability to communicate among the ERFs or offsite agencies that does not exist.

6.0 Changes are made such that the capability to notify ERO responders no longer exists.

7 .0 Procedures are revised such that a range of offsite protective actions or adequate protective actions for onsite personnel who are not members of the ERO would not be recommended or impl~mented.

8.0 Procedures are revised such that follow-up notifications do not take into account previous PARs.

9.0 Changes are made such that personnel in the owner controlled area are not informed of the need to evacuate or shelter.

10.0 A change is made that increases an EP commitment followed by a change that reduces the new EP commitment.

I OPGP05-ZV-0010 I Rev.18 I Page 37of43 Emergency Plan Change Form 1 I Screen Evaluation Form I Page I of2 CR Number:

Activity Description and

References:

I BLOCKl Activity Scope: I BLOCK2 D The activity lli a change to the emergency plan. Proceed to Block 3 D The activity is not a change to the emergency plan, AND does not affect implementation of the emergency plan. Proceed to Block 6 D The activity is not a change to the emergency plan but may affect implementation of the emergency plan Proceed to Block 5.

Change Type: I BLOCK 3 Change Type: I BLOCK 4 D The change lli_ editorial or typographical. D The change does conform to an activity that has prior Proceed to Block 7 approval. Proceed to Block 7 D The change is not editorial.or typographical. D The change does not conform to an activity that has Proceed to Block 4 prior approval. Proceed to Block 5 Planning Standard Impact Determination: I .* BLOCKS' D §50.4 7(b)(1) - Assignment of Responsibility (Organization Control)

D §50.47(b)(2)- Onsite Emergency Organization D §50.47(b)(3)-Emergency Response Support and Resources D §50.47(b)(4)-Emergency Classification System D §50.47(b)(5)- Notification Methods and Procedures D §50.47(b)(6)- Emergency Communications D §50.47(b)(7) - Public Education and Information D §50.47(b)(8)- Emergency Facility and Equipment D §50.47(b)(9)-Accident Assessment D §50.47(b)(10)- Protective Response D §50.47(b)(l 1)- Radiological Exposure Control D §50.47(b)(12) -Medical and Public Health Support D §50.47(b)(13)-Recovery Planning and Post-accident Operations D §50.47(b)(14) - Drills and Exercises D §50 .47(b)(15) - Emergency Responder Trainiijg D §50 .47(b)(16) - Emergency Plan Maintenance Does the proposed activity affect a planning standard function or program element?

D Yes. The activity cannot be implemented without performing a §50.54(q) effectiveness evaluation. Proceed to Block 7.

D No. Proceed to Block 6..

Commitment Impact Determination: I' BLOCK6 D The activity does affect a site specific EP commitment.

Record the commitment or commitment reference: ~~~~~~~~~~~~~

Proceed to Block 7.

D The activity does not affect a site specific EP commitment. Proceed to Block 7 This page when completed, shall be retained as per the Document Type List (DTL).

I OPGPOS-ZV-0010 I Rev. 18 I Page 38 of 43 Emergency Plan Change Form 1 I Screen Evaluation Form I Page2 of2 Screening Evaluation Results: I *BLOCK 7 D The activity can be implemented without performing a §50.54(q) effectiveness evaluation.

D The activity cannot be implemented without performing a §50.54(q) effectiveness evaluation .

Preparer Name: Preparer Signature Date:

Approver Name: Approver Signature Date:

This page when completed, shall be retained as per the Document Type List (DTL).

I OPGPOS-ZV-0010 I Rev. 18 I Page 39of43 Emergency Plan Change Form2 I Effectiveness Evaluation Form I Page 1 ofl CR Number:

Activity Description and

References:

I, , BLOCK1 Activity Type: I, BLOCK2 D The activity lli a change to the emergency plan.

D The activity affects implementation of the emergency plan, but is not a change to the emergency plan.

Impact and Licensing Basis Determination: I ,. BLOCK3

[list offunctions, program elements and/or commitments affected by the activity (organized by planning standard as applicable)]

Licensinl! Basis:

Compliance Evaluation and

Conclusion:

I , :BLOCK4 ' -

Evaluation:

Conclusion:

The proposed activity D does I D does not continue to comply with the requirements.

Reduction in Effectiveness (RIE) Evaluation and

Conclusion:

I BLOCKS Evaluation:

Conclusion:

The proposed activity D does I D does not constitute a RIE.

Effectiveness Evaluation Results I' BLOCK6' D The activity does continue to comply with the requirements of §50.47(b) and §50 Appendix E and the activity does not constitute a reduction in effectiveness. Therefore, the activity can be implemented without prior approval.

D The activity does not continue to comply with the requirements of §50.4 7(b) and §50 Appendix E or the activity does constitute a reduction in effectiveness. Therefore, the activity cannot be implemented without prior approval.

Preparer Name: Preparer Signature Date:

Approver Name:

  • Approver Signature Date:

This page when completed, shall be retained as per the Document Type List (DTL).

I OPGPOS-ZV-0010 I *Rev. 18 I Page 40of43 Emergency Plan Change Form3 I EAL Change Evaluation Form I Page 1 of3 CR Number:

Change Description and

References:

I BLOCKl Change Verification: I BLOCK2 Item J Yes J No JN/A JResolution/Comments Initiating C6ndition (IC) *.

IC identification number is correct.

Wording is consistent with the NRC approved IC.

Emergency Action Level (EAL) I Fission Product Barrier (FPB)

EAL/FPB identification number is correct.

Wording is consistent with the NRC approved EAL/FPB.

Threshold values or conditions remain specific to ensure generic criteria are not substituted reducing clarity and accuracy of the EAL.

Sequencing/nesting logic format is correct.

Site specific content wording/tables/values are correct and specific:

  • Operations procedures are consistent with the change ,
  • Instrument/display number and noun name are provided
  • Alarm setpoints/indications are equal to EAL/FPB values
  • Radiation monitor values account for background
  • Procedure references are correct.

The EAL/FPB Matrix is legible and intuitively organized.

Mode Applicability *. .

Operational modes align is consistent with the EAL license basis (i.e. basis the NRC approved the EAL being changed).

E.Ai;, Technical Bases*:

The change is consistent with the EAL technical bases approved by the NRC.

This page when completed, shall be retained as per the Document Type List (DTL).

I OPGPOS-ZV-0010 I Rev.18 I Page 41 of 43r Emergency Plan Change Form3 I EAL Change Evaluation Form I Page 2 of3 Item Yes No NIA Resolution/Comments EAL Technical Bases (continued)

Bases for calculations and threshold values are

consistent with the technical bases for the EAL I FPB as approved by the NRC.

Source document inputs used for calculations and in thresholds are correct.

Site specific content remains accurate and consistent with NRC approved technical bases.

Site specific content has appropriate level of detail and is unambiguous.

The change does not cause a change to the logic of the EAL scheme (i.e. gaps in classification thresholds).

Conflicts with the EAL/FPB wording have not been introduced.

~

References Source document references are correct.

Source document references are current.

Definitions Wording is consistent with the license basis definitions approved by the NRC for the EALs and EAL technical bases.

Other Manual Content Wording is consistent with the license basis definitions approved by the NRC for the EALs and EAL technical bases.

Change Validation: I BLOCK3 Method. ...

Use the appropriate technique(s) to ensure the change is accurate and cari be effe~tively Used for .

emergency classification.

D In-Plant Walk-down D Simulator D Other (Spe~ify)

D Training D State and County Government concurrence D \abletop ON/A This page when completed, shall be retained as per the Document Type List (DTL).

I OPGPOS-ZV-0010 I Rev.18 I Page 42of43 Emergency Plan Change Form3 I EAL Change Evaluation Form I Page 3 of3 Item ,

Yes No NIA Resolution/Comments EAL/FPB ,

Information and/or values are available in all facilities where classifications are required to be made.

Instrumentation and computer points are compatible:

  • Instrument/display designation matches
  • Instrument/display units are correct and readable
  • Proper significant digits a~e indicated
  • The instrument/display range is on scale and within the accuracy capabilities for the threshold values of the EAL I FPB. '

Conditions are easily recognizable and able to support declaration within 15 minutes.

Information and/or values are easily obtained and able to support declaration within 15 minutes.

The change does not introduce a time delay to classification when compared to the former EAL I FPB.

Change Justification: I BLO(:K4

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EAL Change Review Results: I.. BLOCKS D The EAL change can be implemented without prior NRC approval.

D The EAL change cannot be implemented without prior NRC approval.

Preparer Name: Preparer Signature Date:

J Approver Name: Approver Signature Date:

This page when completed, shall be retained as per the Document Type List (DTL).

I OPGP05-ZV-0010 I Rev.18 I Page 43 of43 Emergency Plan Change Form4 I Emergency Plan Approval Form I Page 1of1 D Revision D Interim Change Notice _ __ Is attached for your review and approval of the STP Emergency Plan.

NRC Safety Evaluation Correspondence Number (if applicable)------------

NRC approval received (if applicable)

Date PORC Meeting No. I Date Approved: I Plant General Manager Date Approved: I Approval Authority (As defined in step 3.2) Date Effective Date:

When completed, this form shall serve as certification and accompany the STP Emergency Plan change package.

When completed, a copy of this form shall become the cover page of the revision for controlled distribution.

I This page when completed, shall be retained as per the Document Type List (DTL).

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