ML17311A542
| ML17311A542 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/20/2017 |
| From: | Duke Energy Carolinas |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| CNS-17-056 | |
| Download: ML17311A542 (40) | |
Text
[ DUKE
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Duke Energy ACTION REQUEST -02152281 I
Action Request Details Type Subject Description
- EREG Orig Date :
09/20/2017 14:43
- CNS EPlan change for Standard ERO Discovery Date CONTACT SITE EP SUPERVISOR FOR ASSISTANCE IN PREPARING EP01, EP02, AND EP03. ENSURE EREG IS CROSS-REFERENCED TO THE REG AR WHICH INITIATED IT. Complete 50.54q per AD-EP-ALL-0602.
Notes Priority Report To Status :
APPROVED 09/20/2017 Severity Due Date
- 10/26/2017 Event Date Originator
- 118938 Originator Group Facility
- NCP Department
- 44278 Organization Owed To Owed To Group
- QUALREVW Owed To Fae :CN Department Discipline I
Action Request Status History Updated Date Updated By AR Status AR Due Date 09/20/2017 118938 INPROG 10/26/2017 09/20/2017 118938 APPROVED I
Action Request Attributes Request Attribute Values Reqd Date BOUNDED EREG AR N
y 09/20/2017 Name : MATTHEW L NELSON Request Attribute Values Reqd Date EREG AR CROSS XREF y
y 09/20/2017 Name : MATTHEW L NELSON Request Attribute Values Reqd Date REG AR CROSS XREF y
y 09/20/2017 Name : MATTHEW L NELSON I
Printed : 10/10/2017 Page : 1
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' ENERGY" Duke Energy ACTION REQUEST -02152281 I
Action Request Notes Action Request Routing/Return Comments Routing Comments from the X601 Pane l
- No Routing Comments Found ***
Routing Comments from the X602 Pane l
- No Return Comments Found ***
I Action Request Approval Review Route List :
001 Send Passport Fae Group I
Type Date I
Action Request Trend/Cause I
Action Request Keywords Keyword Keyword Description I
Action Request Reference Documents Doc Sub Facility Type Type Document I
Action Request Reference Equipment Equip Equip Facility Unit System Type Number I
Printed :
10/10/2017 Send Action Time Taken Minor Sheet Rev Rev Title Equip Tag Updated On Updated By Updated On Updated By Route List Initiator :
Action Date I Time Last Name Equip Status Rev Rev Status Page : 2
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Duke Energy ACTION REQUEST -02152281 I
Action Request Cross References Ref Ref Ref Ref Nbr Limit Type Nbr Sub Type Status AR Cls Description AR 021476SO ORR COMPLETE N
EPA B rev 163 AR 021476S2 ORR COMPLETE N
EPA E Rev 148 AR 021476S4 ORR COMPLETE N
EPA Grev 161 AR 021476SS ORR COMPLETE N
EPA H Rev 149 AR 021476S7 ORR COMPLETE N
EPA I Rev 147 AR 021476S9 ORR COMPLETE N
EPA J rev 147 AR 02147664 ORR COMPLETE N
EPA K rev 144 AR 02147666 ORR COMPLETE N
EPA M rev 161 AR 02147671 ORR COMPLETE N
EPA P rev 147 AR 02147943 SAD COMP-NA N
EPA E -002100S214 CNS EMERGENCY PLAN SECTION E -
AR 02148298 SAD COMP-NA N
EPA B -0021011193 CNS EMERGENCY PLAN SECTION B-SITE AR 02148394 SAD COMP-NA N
EPA G -002101119S CNS EMERGENCY PLAN SECTION G -PUBLIC AR 02148481 SAD COMP-NA N
EPA I -002100S777 CNS EMERGENCY PLAN SECTION I -ACCIDENT AR 02148663 SAD COMP-NA N
EPA J
-0021 OOS306 CNS EMERGENCY PLAN SECTION J
-PROTECTIVE AR 02148690 SAD COMP-NA N
EPA K -0021011196 CNS EMERGENCY PLAN SECTION K -
AR 02148769 SAD COMP-NA N
EPA M - 0021011198 CNS EMERGENCY PLAN SECTION M - RECOVERY AR 02148791 SAD COMP-NA N
EPA P -002100S28S CNS EMERGENCY PLAN SECTION P -
AR 021S1S62 ORR COMPLETE N
EPA A rev 1SO AR 021S1S84 ORR COMPLETE N
EPA 0 rev 144 AR 021S2021 SAD COMP-NA N
EPA A -0021011172 CNS EMERGENCY PLAN SECTION A-ASSIGNMENT AR 021S20S8 SAD COMP-NA N
EPA 0 -0021011199 CNS EMERGENCY PLAN SECTION 0 -
AR 021S2146 SAD COMP-NA N
EPA H -002100S362 CNS EMERGENCY PLAN SECTION H -EMERGENCY I
Action Request Assignment Details ASSIGNMENT NUMBER :01 SUB I
Printed : 10/10/2017 Page :3
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Duke Energy ACTION REQUEST -02152281 Type Status Assigned To Subject
- EP01
- COMPLETE
- MATTHEW L NELSON
- 50.54(0) SCREEN
- CN Due Date Reschedule Unit Schedule Ref
- 09/20/2017 Aff Facility UCR Organization Est Manhrs Department 44278 Ext Comp Date Description COMPLETE 50.54(0) SCREEN IN ACCORDANCE WITH AD-EP-ALL-0602.
Act ion Request Ass ignment Comp let ion Notes Enclosures in E-folder for main AR. This action is complete.
Act ion Request Ass ignment Status H istory Updated Date Updated By Assgn Status Assgn Due Date 09/20/2017 118938 INPROG 09/20/2017 118938 09/20/2017 09/20/2017 118938 ACC/ASG 09/20/2017 118938 AWAIT/C 09/21/2017 TAA7322 COMPLETE 09/21/2017 118938 INPROG 09/21/2017 118938 ACC/ASG 09/21/2017 118938 AWAIT/C 09/21/2017 144004 ACC/ASG 09/21/2017 118938 AWAIT/C 09/21/2017 TAA7322 COMPLETE I
Act ion Request Assignment Attr ibutes Act ion Request Assignment Rout ing/Return Comments Routing Comments from the X601 Panel requested from preparer I
Printed : 10/10/2017 Pri Resp Fae Pri Resp Group Sec Resp Fae Sec Resp Group System Discipline Updated On 20170921 Updated By 144004 Page :4
( DUKE
' ENERGY-Duke Energy ACTION REQUEST -02152281 Routing Comments from the X602 Panel
- No Return Comments Found ***
Action Request Assignment Completion Approval Route List :
001 Send Send Passport Fae Group I
Type Date Time EMK7353 A
09/20/2017 17:39 TM7322 CN EPSUPV A
09/20/2017 17:44 Route List :002 Send Send Passport Fae Group I
Type Date Time 144004 A
09/21/2017 10:11 TM7322 CN EPSUPV A
09/21/2017 10:19 144004 A
09/21/2017 10:16 Action Request Assignment Cause/Action Action Request Assignment Reference Documents Doc Sub Action Taken APPROVED A"PPROVED Action Taken RETURNED APPROVED APPROVED Minor Updated On Updated By Route List Initiator : 118938 Action Date I Time Last Name 09/20/2017 17:44 KUHR 09/21/2017 08:22 ARLOW Route List Initiator : 118938 Action Date I Time Last Name 09/21/2017 10:13 FISCHER 09/21/2017 10:48 AR LOW 09/21/2017 10:19 FISCHER Facility Type Type Document Sheet Rev Rev Title Action Request Assignment Reference Equipment Equip Equip Facility Unit System Type Number Equip Tag Action Request Assignment Cross References Ref Ref Type Nbr I
Printed : 10/10/2017 Ref Ref Nbr Sub Type Status Limit Equip Status AS Cls Description Rev Rev Status Page
- 5
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Act ion Request Assignment Append ices APPENDIX 1 I
Printed : 10/10/2017 Page
- 6
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q) Screening Evaluation Form>>
Screening and Evaluation Number EREG #: 2152281 SAD#:
EPAA 2151562 EPAJ 2148663 EPAB 2148298 EPAK 2148690 EPAE 2147943 EPAM 2148769 EPAG 2148394 EPAO 2152058 EPAH 2152146 EPAP 2148791 EPAI 2148481 Document and Revision Catawba Emergency Plan CN-ADMN-EPLAN-MANUAL, for section revision numbers see summary of changes.
AD-EP-ALL-0602 Rev. 3 ATTACHMENT 4 Page 1 of 6 Applicable Sites BNP D
CNS CR3 D
HNP D
MNS D
ONS D
RNP D
GO D
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):
In conjunction with the common EOF for BNP, HNP, and RNP, an initiative was undertaken by Duke Energy to standardize the augmenting ERO positions, functions and responsibilities (tasks) across the fleet. This involves changes to the current CNS augmenting ERO, based on the number of responders and their titles identified in the site emergency plan and implementing procedures. Included in the standard ERO initiative is the development of fleet standard ERO checklists, procedures and forms. Note -this initiative makes no changes to the on-shift ERO or 45 minute augmenting response positions. is the CNS ERO Position Comparison and Evaluation -TSC/OSC is the CNS ERO Position Comparison and Evaluation -JIC is the EOF ERO Position Comparison and Evaluation is the detailed summary of the Emergency Plan changes Enclosures are located in the CAS E-Folder.
The following changes are outside the Fleet Standard ERO project and will be evaluated separately within this evalaution.
- EPA G Section G.2 -changed emergency "planning" to emergency "preparedness"
- EPA G Section G.4.c:
0 reordered county, state, and federal in logical order 0
deleted capitalization of "portal" 0
corrected spelling of "government" n---.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
AD-EP-ALL-0602 Rev.3
<< 10 CFR 50.54(q) Screening Evaluation Form>>
ATTACHMENT 4 Page 2 of 6
- EPA I Section 1.1 -added bases information from EPA section D discussion on the CNS NEI 99-01 Rev. 6 EAL upgrade.
- EPA I Section 1.9 -added the following at the end of the paragraph; "OR a count rate meter utilizing direct corrected count rate (
ccpm) of the Silver Zeolite or equivalent cartridge cross-referenced against an estimated lodine-131 microCi/cc concentration attachment."
- EPA J Section J.7 -added "General Emergency" to RP/O/A/5000/005
- EPA K Section K.2 -changed "Procedures" to "Site procedures" in the last sentence
- Section 0.1.a -Replaced CNS Addendum 7111.0 with new procedure AD-EP-ALL-0500, Emergency Response Training.
- Section 0.2.a -Replaced EP Group Manual Guideline 5.4.1 with AD-EP-ALL-0500 (first sentence)
- Section 0.2.a -Replaced EP Group Manual Guideline 5.4.1, ETQS 7111.00 and CNS Addendum 7111.0 with AD-EP-ALL-0500 (last sentence)
- Section 0.2.c -Replaced Nuclear System Directive 112 and CNS Training Addendum 7111.0 with AD-TQ-ALL-0086, Fire Brigade and Hazmat Training
- Section 0.2.d -Corrected title for PT/O/B/4600/006 "Exercises and"
- Section 0.3 Replaced Nuclear System Directive 119 with AD-SY-ALL-0280, Medical Emergency Response Team (MERT) and Technical Rescue Training.
Part II. Activity Previously Reviewed?
Yes I
D No I
- Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design Report?
If yes, identify bounding source document number or approval reference and ensure the basis for concluding the source document fully bounds the proposed change is documented below:
Justification:
EPA I Section 1.1 -added bases information from EPA section D discussion on the CNS NEI 99-01 Rev. 6 EAL upgrade.
The CNS Technical Basis for the development of Initiating Conditions and Emergency Action Levels changed FROM TO NUMARC/NESP-007, Revision 2, Methodology for Development of Emergency Action Levels, endorsed by the NRC in Regulatory Guide 1.101, Rev. 3, August 1992, as an alternative methodology for the development of Emergency Action Levels Nuclear Energy Institute (NEI) 99-01, Revision 6 (Development of Emergency Action Levels for Non-Passive Reactors),
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... "'7 10 CFR 50.54(q)
Effectiveness Evaluation is not required. Enter justification below and complete,
Part V Continue to,
Screening Evaluation Form, Part Ill n---
.a
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
AD-E P-ALL-0602 Rev. 3 ATTACHMENT 4 Page 3 of 6
<< 10 CFR 50.54(q) Screening Evaluation Form>>
which was endorsed by the NRG in a letter dated March 28, 2013 from Mark Thaggard (U.S. Nuclear Regulatory Commission) to Susan Perkins-Grew (Nuclear Energy Institute), titled "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, November 2012(ML12346A463)."
The NRG approved the license amendments for CNS to adopt an emergency action level scheme based on the Nuclear Energy Institute (NEI) 99-01, Revision 6 (Development of Emergency Action Levels for Non-Passive Reactors).
Date of Issuance, on April 18, 2016. (ML16082A038)
DUKE ENERGY CAROLINAS. LLC DOCKET NO. 50-413 CATAWBA NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 279 to RFOL No. NPF-35 DUKE ENERGY CAROLINAS. LLC DOCKET NO. 50-414 CATAWBA NUCLEAR STATION. UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 275 to RFOL No. NPF-52 Bounding document attached (optional)
Part Ill. Editorial Change Is this activity an editorial or typographical change only, such as formatting, paragraph numbering, spelling, or punctuation that does not change intent?
Justification:
See Enclosure 4 that lists changes that are editorial as described in AD-EP-ALL-0602 Emergency Plan Change Screening and Effectiveness Evaluations 10 CFR 50.54(Q). These editorial changes require no further evaluation.
Yes lo 10 CFR 50.54(q)
Effectiveness Evaluation is not required. Enter justification and complete,
Part V.
lo No I
- Continue to,
Part IV and address non editorial changes
-.n
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
AD-EP-ALL-0602 Rev. 3 ATIACHMENTS Page 1 of 8
<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>
Screening and Evaluation Number Applicable Sites BNP D
EREG #: 2152281 CNS CR3 D
HNP D
SAD#:
MNS D
EPAA 2151562 EPAJ 2148663 ONS D
EPAB 2148298 EPAK 2148690 RNP D
EPAE 2147943 EPAM 2148769 D
EPAG 2148394 EPAO 2152058 EPAH 2152146 EPAP 2148791 GO EPAI 2148481 Document and Revision Catawba Emergency Plan CN-ADMN-EPLAN-MANUAL, for section revision numbers see summary of changes.
Part I. Description of Proposed Change:
In conjunction with the common EOF for BNP, HNP, and RNP, an initiative was undertaken by Duke Energy to standardize the augmenting ERO positions, functions and responsibilities (tasks) across the fleet. This involves changes to the current CNS augmenting ERO, based on the number of responders and their titles identified in the site emergency plan and implementing procedures. Included in the standard ERO initiative is the development of fleet standard ERO checklists, procedures and forms. Note -this initiative makes no changes to the on-shift ERO or 45 minute augmenting response positions. is the CNS ERO Position Comparison and Evaluation -TSC/OSC is the CNS ERO Position Comparison and Evaluation -JIC is the EOF ERO Position Comparison and Evaluation is the detailed summary of the Emergency Plan changes Enclosures are located in the CAS E-Folder.
The following changes are outside the Fleet Standard ERO project and will be evaluated separately within this evaluation.
- EPA I Section 1.9 -added the following at the end of the paragraph: "OR a count rate meter utilizing direct corrected count rate (ccpm) of the Silver Zeolite or equivalent cartridge cross-referenced against an estimated lodine-131 microCi/cc concentration attachment.", 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes D Bases Validation and Verification (V&V) Form, is attached (required for IC or EAL change)
No
- EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>
Part II. Description and Review of Licensing Basis Affected by the Proposed Change:
Licensing Basis of the ERO AD-EP-ALL-0602 Rev. 3 ATTACHMENT 5 Page 2 of 8 CNS Emergency Plan Revision 2 (dated January 1983), revision 97-1 (dated January 1997), and revision 11-2 (dated September 2011) reflect the NRC approved versions related to the augmenting ERO. The augmenting ERO documented in the current CNS E-Plan, Revision 162, bounds the NRC approved E-Plan augmenting ERO and is used as the basis for the detailed comparison and evaluation provided in Enclosures 2, 3, and 4.
List Commitments Associated with the Change A search to identify site specific commitments related to the ERO positions and their assigned responsibilities was performed. No site specific commitments were identified aside from those in the Emergency Plan.
The differences in approved revisions and the current revisions of the Emergency Plans have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions. Each revision has been reviewed by the NRC during the inspection process.
Part I l
- l. Description of How the Proposed Change Complies with Regulation and Commitments.
If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q):
The changes resulting from the adoption of the standard ERO establish a closer relationship between risk significant I key functions and the positions assigned those functions. The objective of the changes is to ensure that those functions and their processes are linked directly to the augmented minimum staffing positions to allow for optimum relief of on shift personnel and less complicated response execution following facility activation.
Refer to Enclosures 1, 2, and 3 for a detailed review of the differences between the current CNS augmenting ERO and the standard augmenting ERO, and the evaluation of those changes from the organizational hierarchy, position and response, and task-by-task levels.
The adoption of the standard augmenting ERO into the CNS Emergency Plan: (1) provides a response organization defined by specific structure and responsibilities, which is consistent with regulations and industry guidance, and (2) maintains an efficient augmentation capability for both minimum staffing and full staffing positions.
The adoption of the standard augmenting ERO into the CNS Emergency Plan does not alter the licensing basis and continues to meet the regulatory requirements of 10CFR50.47(b)(1 ), (b)(2),
(b)(7), and 10CFR50 Appendix E, Section IV.A. This change does not alter, add or remove previous site specific commitments with regards to the augmenting ERO.
The Section I revision includes a description on the use of a frisker to measure radioiodine concentrations in addition to the method in the current Emergency Plan. There will continue to be adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition as required by 10 CFR 50.47(b)(9) and Appendix E to 10 CFR Part 50, IV.E.2.
The adoption of a fleet standard recovery organization and plan into the CNS Emergency Plan provides a flexible recovery organization based on the complexity of the event or recovery plan. This new recovery organization and plan is based on the current recovery orqanization and plan in place at HNP, which has been evaluated in drills and
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>
AD-EP-ALL-0602 Rev. 3 ATTACHMENT 5 Page 3 of 8 exercises. The adoption of a fleet standard recovery organization into the CNS Emergency Plan does not alter the licensing basis and continues to meet the regulatory requirements of 10CFR50.47(b)(13). This change does not alter, add or remove previous site specific commitments with regards to the recovery organization and plan.
Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen):
- 1. The following portion of planning standard §50.47(b)(1) is related to the change in adopting the standard augmenting ERO.
Primary responsibilities for emergency response by the nuclear facility licensee have been assigned, and each principal response organization has staff to augment its initial response on a continuous basis.
The functions for §50.47(b)(1) related to this change are:
- a. Responsibility for emergency response is assigned.
- b. The response organization has the s.taff to respond and augment on a continuing basis (2417 staffing) in accordance with the E-plan.
The NUREG-0654 Part II.A elements for §50.47(b)(1) related to this change are:
A. 1.d. Each organization shall identify a specific individual by title who shall be in charge of the emergency response.
A.2.
Each principal organization shall be capable of continuous (24-hour) operations for a protracted period.
The individual in the principal organization who will be responsible for assuring continuity of resources (technical, administrative, and material) shall be specified by title.
- 2. The following portion of planning standard §50.47(b)(2) is related to the change in adopting the standard augmenting ERO.
, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.
The function for §50.47(b)(2) related to this change is:
- b. The process for timely augmentation of on shift staff is established and maintained.
The NUREG-0654 Part 11.B elements for §50.47(b)(2) related to this change are:
B.3. Each licensee shall identify a line of succession for the emergency coordinator position and identify the specific conditions for higher level utility officials assuming this function.
B.4. Each licensee shall establish the functional responsibilities assigned to the emergency coordinator and shall clearly specify which responsibilities may not be delegated to other elements of the emergency organization. Among the responsibilities which may not be delegated shall be the decision to notify and to recommend protective actions to authorities responsible for offsite emergency measures.
B.5. Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The licensee must be able to augment on-shift capabilities within a short period after declaration of an emeraencv. This capability shall be as indicated in Tab le B-1.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>
AD-EP-ALL-0602 Rev. 3 ATTACHMENT 5 Page 4 of 8
- 8. 7. Each licensee shall specify the corporate management, administrative, and technical support personnel who will augment the plant staff as specified in the table entitled "Minimum Staffing Requirements for Nuclear Power Plant Emergencies," (Table 8-1)
- 3. The following portions of §50 Appendix E,Section IV.A are related to the change in adopting the standard augmenting ERO.
The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:
- 2. A description of the onsite emergency response organization (ERO) with a detailed discussion of:
- a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;
- b. Plant staff emergency assignments;
- c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.
- 3. A description, by position and function to be performed, of the licensee's headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.
- 4. Identification, by position and function to be performed, of persons within the licensee organization who will be responsible for making offsite dose projections,...
- 4. The following portion of planning standard §50.47(b)(7) is related to the change in adopting the standard augmenting ERO.
Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dissemination of information during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of information to the public are established.
The function for §50.47(b)(7) related to this change are:
- a. Coordinated dissemination of public information during emergencies is established.
The NUREG-0654 Part 11.G elements for §50.47(b)(5) related to this change are:
G.4.a Each principal organization shall designate a spokesperson who should have access to all necessary information.
- 5. The following portion of planning standard §50.47(b)(9) is associated with the addition of a frisker for measuring radioiodine concentrations.
Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
The function for §50.47(b)(9) related to this change are:
- a. Methods, systems, and equipment for assessment of radioactive releases are in use.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54{q) Effectiveness Evaluation Form>>
The NUREG-0654 Part II.I elements for §50.47(b)(9) related to this change are:
AD-EP-ALL-0602 Rev. 3 ATTACHMENT 5 Page 5 of 8 I. 7 Each organization shall describe the capability and resources for field monitoring within the plume exposure Emergency Planning Zone which are an intrinsic part of the concept of operations for the facility.
1.8 Each organization, where appropriate, shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways. This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.
1.9 Each organization shall have a capability to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low as 10-7 ucilcc (microcuries per cubic centimeter) under field conditions.
Interference from the presence of noble gas and background radiation shall not decrease the stated minimum detectable activity.
- 6. The following portion of planning standard §50.47(b)(13) is associated with the change in adopting the standard recovery organization and plan.
General plans for recovery and reentry are developed.
The function for §50.47(b)(13) related to this change are:
- a. Plans for recovery and reentry are developed.
The NUREG-0654 Part 11.M elements for §50.47(b)(13) related to this change are:
M. 1 Each organization, as appropriate, shall develop general plans and procedures for reentry and recovery and describe the means by which decisions to relax protective measures (e.g., allow reentry into an evacuated area) are reached. This process should consider both existing and potential conditions.
M.2 Each licensee plan shall contain the position/title, authority and responsibilities of individuals who will fill key positions in the facility recovery organization. This organization shall include technical personnel with responsibilities to develop, evaluate and direct recovery and reentry operations.
M.3 Each licensee and State plan shall specify means for informing members of the response organizations that a recovery operation is to be initiated, and of any changes in the organizational structure that may occur.
M.4 Each plan shall establish a method for periodically estimating total population exposure.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>
AD-EP-ALL-0602 Rev.3 ATTACHMENT 5 Page 6 of 8 Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:
There is no numeric change to the CNS augmenting ERO. Refer to Enclosures 1, 2, and 3 for a detailed review of the differences between the current CNS augmenting ERO and the standard augmenting ERO, and the evaluation of those changes.
- 1. Capability Assessment All emergency response related functions and tasks performed by the current CNS augmenting ERO have been dispositioned against the standard ERO positions as documented in Enclosures 1, 2 and 3. Changes to ERO task assignments categorized as deviations were evaluated and determined not to degrade the capability to perform their particular function.
Additionally, a l
l ERO tasks for each position have been formally defined, indexed to their corresponding planning standard, and listed in the Emergency Plan Implementing Procedures for Emergency Response Facility activation. These tasks can now be readily adopted into the ERO systematic approach to training based qualification process and easily associated with the drill and exercise evaluation performance objectives and demonstration criteria. Thus, the capability to determine performance vs. process issues and feedback to training of task level items is significantly improved.
- 2. Timeliness Assessment The standard augmenting ERO, with minor modification, is based on the current augmenting ERO in place at CNS, MNS and ONS which has been evaluated in numerous drills and exercises. There are no changes to the on-shift ERO or 45 minute response positions as part of the standard augmenting ERO initiative.
The aspect of timeliness with regard to the ability of any position to perform their assigned responsibilities was further evaluated by a review of the impact of any new tasks assigned to a position by a process similar to that used in the on-shift staffing study task analysis. It was assumed there was no timeliness impact for positions that were not assigned new tasks or were only assigned new tasks which were determined to be undocumented and were actually performed by the position. New tasks are categorized as deviations. The aspects of overburden and overlap were considered in the determination of whether there was a potential adverse impact on timeliness to any assigned task. No position was identified with task overburden or overlap with regard to the addition of any responsibilities.
Based on the above, the adoption of the standard augmenting ERO will continue to maintain or improve the capability and timeliness of the CNS augmenting ERO to respond to an event and effectively perform their assigned tasks.
The Section I change to use a frisker to measure radioiodine concentrations in addition to the method in the current Emergency Plan is an enhancement. The change provides additional assurance that methods, systems, and equipment for assessment of radioactive releases are in use.
The adoption of a fleet standard recovery organization and plan ensures the Corporate EOF can be a part of the site recovery organization if needed. The standard recovery organization and plan continues to ensure plans for recovery and reentry are developed.
The changes described do not affect the emergency planning functions because the changes continue to ensure:
- Responsibilities for emergency response are assigned
- The response organization has the staff to respond and augment on a continuing basis (24/7 staffing) in accordance with the E-plan
- The process for timely augmentation of on shift staff is established and maintained
- Coordinated dissemination of public information during emergencies is established
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
AD-EP-ALL-0602 Rev. 3 ATIACHMENT 5 Page 7 of 8
<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>
- Methods, systems, and equipment for assessment of radioactive releases are in use
- Plans for recovery and reentry are developed.
The changes described provide additional assurance that the normal plant operating organization and ERO has the ability and capability to:
- respond to an emergency;
- perform functions in a timely manner;
- effectively identify and take measures to ensure protection of the public health and safety; and
- effectively use response equipment and emergency response procedures.
Part VI. Evaluation Conclusion.
Answer the following questions about the proposed change.
1 Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E?
Yes* No D 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes* NoD reduction in effectiveness)?
3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme?
Yes* NoD 4 Choose one of the following conclusions:
a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current Emergency Action Level (EAL) scheme. Therefore, the activity can be implemented without prior NRC approval.
b The activity does not continue to comply with the requirements of 10 CFR 50.47(b) or 10 CFR 50 Appendix E or the activity does constitute a reduction in effectiveness or EAL scheme change.
D Therefore, the activity cannot be implemented without prior NRC approval.
Part VII. Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change determined to require prior NRC approval be either revised or I
Yes D I No D rejected?
If No, then initiate a License Amendment Request in accordance 10 CFR 50.90 and AD-LS-ALL-0002, Regulatory Correspondence, and include the tracking number:
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>
AD-EP-ALL-0602 Rev. 3 ATIACHMENT5 Page 8 of 8 Part VIII. Signatures: EP CFAM Final Approval is required for changes affecting risk significant planning standard 10 CFR 50.47(b)(4).
Preparer Name (Print):
Preparer Signature:
Date:
Matthew Nelson See CAS See CAS Reviewer Name (Print):
Reviewer Signature:
Date:
See CAS See CAS See CAS Approver (EP Manager) Name (Print):
Approver Signature:
Date:
See CAS See CAS See CAS Approver (CFAM, as required) Name (Print): Approver Signature:
Date:
N/A N/A N/A If the proposed activity is a change to the E-Plan or implementing procedures, then create two EREG General Assignments.
If required by Section 5.5, Submitting Reports of Changes to the NRC, then create two EREG General Assignments.
- One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q),
to Licensing.
One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect.
QA RECORD
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
AD-EP-ALL-0602 Rev. 3
<< 10 CFR 50.54(q) Screening Evaluation Form>>
ATTACHMENT 4 Page 4 of 6 Part IV. Emergency Planning Element and Function Screen (Reference Attachment 1, Considerations for Addressing Screening Criteria)
Does this activity involve any of the following, including program elements from NUREG-06S4/FEMA REP-1 Section II? If answer is yes, then check box.
1 10 CFR S0.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.
1b The response organization has the staff to respond and to augment staff on a continuing basis (24-7 staffing) in accordance with the emergency plan.
2 10 CFR S0.47(b)(2) Onsite Emergency Organization 2a Process ensures that onshift emergency response responsibilities are staffed and assigned D
2b The process for timely augmentation of onshift staff is established and maintained.
3 10 CFR S0.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.
D 3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.
D (NA for CR3) 4 10 CFR S0.47(b)(4) Emergency Classification System 4a A standard scheme of emergency classification and action levels is in use.
D (Requires final approval of Screen and Evaluation by EP CFAM.)
s 10 CFR S0.47(b)(S) Notification Methods and Procedures Sa Procedures for notification of State and local governmental agencies are capable of alerting them of the D declared emergency within 1 S minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.
Sb Administrative and physical means have been established for alerting and providing prompt instructions D to the public within the plume exposure pathway. (NA for CR3)
Sc The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D
Notification Systems for Nuclear Power Plants, or complies with the licensee
's FEMA-approved ANS design report and supporting FEMA approval letter. (NA for CR3) n---
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EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
AD-EP-ALL-0602 Rev.3
<< 10 CFR 50.54(q) Screening Evaluation Form>>
ATTACHMENT 4 Page 5 of 6 Part IV. Emergency Planning Element and Function Screen (cont.)
6 10 CFR 50.47(b)(6) Emergency Communications 6a Systems are established for prompt communication among principal emergency response D
organizations.
6b Systems are established for prompt communication to emergency response personnel.
D 7
10 CFR 50.4 7(b )(7) Public Education and Information
?a Emergency preparedness information is made available to the public on a periodic basis within the D
plume exposure pathway emergency planning zone (EPZ). (NA for CR3)
?b Coordinated dissemination of public information during emergencies is established.
8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment Ba Adequate facilities are maintained to support emergency response.
D 8b Adequate equipment is maintained to support emergency response.
D 9
10 CFR 50.47(b)(9) Accident Assessment 9a Methods, systems, and equipment for assessment of radioactive releases are in use.
10 10 CFR 50.47(b)(10) Protective Response 10a A range of public PARs is available for implementation during emergencies. (NA for CR3)
D 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available D to support the formulation of PARs and have been provided to State and local governmental authorities. (NA for CR3) 10c A range of protective actions is available for plant emergency workers during emergencies, including D
those for hostile action events.
10d Kl is available for implementation as a protective action recommendation in those jurisdictions that D
chose to provide Kl to the public.
11 10 CFR 50.47(b)(11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.
D 12 10 CFR 50.47(b)(12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.
D 13 10 CFR 50.47(b)(13) Recovery Planning and Post-accident Operations 13a Plans for recovery and reentry are developed.
14 10 CFR 50.47(b)(14) Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program areas)
D is established.
14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, D
and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.
14c Identified weaknesses are corrected.
D 15 10 CFR 50.47(b)(15) Emergency Response Training 15a Training is provided to emergency responders.
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EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q} Screening Evaluation Form >>
Part IV. Emergency Planning Element and Function Screen (cont.)
16 10 CFR 50.47(b)(16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.
AD-EP-ALL-0602 Rev. 3 ATTACHMENT 4 Page 6 of 6 D
16b Planners responsible for emergency plan development and maintenance are properly trained.
D PART IV. Conclusion If no Part IV criteria are checked, a 10 CFR 50.54(q) Effectiveness Evaluation is not required, then complete D, 10 CFR 50.54(q) Screening Evaluation Form, Part V. ATTACHMENT 4 Justification:
If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete *, 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q)
Effectiveness Evaluation. Program Element 4a requires final approval of Screen and Evaluation by EP CFAM.
Part V. Signatures:
Preparer Name (Print):
Preparer Signature:
Date:
Matthew Nelson See CAS See CAS Reviewer Name (Print):
Reviewer Signature:
Date:
See CAS See CAS See CAS Approver (EP Manager Name (Print):
Approver Signature:
Date:
See CAS See CAS See CAS Approver (CFAM, as required) Name (Print)
Approver Signature:
Date:
N/A N/A N/A QA RECORD n..:-a.-....1 M---
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' ENERGY~
Duke Energy ACTION REQUEST -02152281 I
Act ion Request Ass ignment Deta i
ls ASSIGNMENT NUMBER
- 02 SUB :
Type Status Assigned To Subject
- EP02
- COMPLETE
- MATTHEW L NELSON
- 50.54(0) EVALUATION
- CN Due Date Reschedule Unit Schedule Ref
- 09/20/2017 Aff Facility UCR Organization Est Manhrs Department 44278 Ext Comp Date Description COMPLETE 50.54(0) EVALUATION IN ACCORDANCE WITH AD-EP-ALL-0602.
Act ion Request Ass ignment Comp let ion Notes Enclosures in E-folder for main AR. This action is complete.
Act ion Request Ass ignment Status History Updated Date Updated By Assgn Status Assgn Due Date 09/20/2017 118938 INPROG 09/20/2017 118938 09/20/2017 09/20/2017 118938 ACC/ASG 09/20/2017 118938 AWAIT/C 09/21/2017 TAA7322 COMPLETE 09/21/2017 118938 INPROG 09/21/2017 118938 ACC/ASG 09/21/2017 118938 AWAIT/C 09/21/2017 TAA7322 COMPLETE I
Act ion Request Assignment Attr ibutes I
Printed : 10/10/2017 Pri Resp Fae Pri Resp Group Sec Resp Fae Sec Resp Group System Discipline Page
- 13
f DUKE
~ ENERGY, Duke Energy ACTION REQUEST -02152281 Action Request Assignment Routing/Return Comments Routing Comments from the X601 Panel
- No Routing Comments Found ***
Routing Comments from the X602 Panel
- No Return Comments Found ***
Action Request Assignment Completion Approval Route List :
001 Send Send Passport Fae Group I
Type Date Time EMK7353 A
09/20/2017 17:51 TAA7322 CN EPSUPV A
09/20/2017 17:54 Route List :002 Send Send Passport Fae Group I
Type Date Time 144004 A
09/21/2017 10:16 TAA7322 CN EPSUPV A
09/21/2017 10:22 Action Request Assignment Cause/Action Action Request Assignment Reference Documents Doc Sub Action Taken APPROVED APPROVED Action Taken APPROVED APPROVED Minor Facility Type Type Document Sheet Rev Rev Title Action Request Assignment Reference Equipment Equip Equip Facility Unit System Type Number I
Printed : 10/10/2017 Equip Tag Updated On Updated By Updated On Updated By Route List Initiator : 118938 Action Date I Time Last Name 09/20/2017 17:54 KUHR 09/21/2017 08:27 ARLOW Route List Initiator : 118938 Action Date I Time Last Name 09/21/2017 10:22 FISCHER 09/21/2017 10:48 ARLOW Equip Rev Status Rev Status Page : 14
( DUKE
' ENERGY~
Duke Energy ACTION REQUEST -02152281 Act ion Request Assignment Cross References Ref Ref Type Nbr Ref Ref Nbr Sub Type I
Act ion Request Assignment Append ices APPENDIX 1 I
Printed : 10/10/2017 Limit Status AS Cls Description Page : 15
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
AD-EP-ALL-0602 Rev. 3 ATTACHMENT 5 Page 1 of 8
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
Screening and Evaluation Number Applicable Sites BNP D
EREG #: 2152281 CNS CR3 D
HNP D
SAD#:
MNS D
EPAA 2151562 EPAJ 2148663 ONS D
EPAB 2148298 EPAK 2148690 RNP D
EPAE 2147943 EPAM 2148769 D
EPAG 2148394 EPAO 2152058 EPAH 2152146 EPAP 2148791 GO EPAI 2148481 Document and Revision Catawba Emergency Plan CN-ADMN-EPLAN-MANUAL, for section revision numbers see summary of changes.
Part I. Description of Proposed Change:
In conjunction with the common EOF for BNP, HNP, and RNP, an initiative was undertaken by Duke Energy to standardize the augmenting ERO positions, functions and responsibilities (tasks) across the fleet. This involves changes to the current CNS augmenting ERO, based on the number of responders and their titles identified in the site emergency plan and implementing procedures. Included in the standard ERO initiative is the development of fleet standard ERO checklists, procedures and forms. Note -this initiative makes no changes to the on-shift ERO or 45 minute augmenting response positions. is the CNS ERO Position Comparison and Evaluation -TSC/OSC is the CNS ERO Position Comparison and Evaluation -JIC is the EOF ERO Position Comparison and Evaluation is the detailed summary of the Emergency Plan changes Enclosures are located in the CAS E-Folder.
The following changes are outside the Fleet Standard ERO project and will be evaluated separately within this evaluation.
- EPA I Section 1.9 -added the following at the end of the paragraph: "OR a count rate meter utilizing direct corrected count rate (ccpm) of the Silver Zeolite or equivalent cartridge cross-referenced against an estimated lodine-131 microCi/cc concentration attachment.", 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Yes D Bases Validation and Verification (V&V) Form, is attached (required for IC or EAL change)
No
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EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>
Part II. Description and Review of Licensing Basis Affected by the Proposed Change:
Licensing Basis of the ERO AD-EP-ALL-0602 Rev.3 ATTACHMENT 5 Page 2 of 8 CNS Emergency Plan Revision 2 (dated January 1983), revision 97-1 (dated January 1997), and revision 11-2 (dated September 2011) reflect the NRC approved versions related to the augmenting ERO. The augmenting ERO documented in the current CNS E-Plan, Revision 162, bounds the NRC approved E-Plan augmenting ERO and is used as the basis for the detailed comparison and evaluation provided in Enclosures 2, 3, and 4.
List Commitments Associated with the Change A search to identify site specific commitments related to the ERO positions and their assigned responsibilities was performed. No site specific commitments were identified aside from those in the Emergency Plan.
The differences in approved revisions and the current revisions of the Emergency Plans have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions. Each revision has been reviewed by the NRC during the inspection process.
Part I l
- l. Description of How the Proposed Change Complies with Regulation and Commitments.
If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.4 7(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54( q):
The changes resulting from the adoption of the standard ERO establish a closer relationship between risk significant I key functions and the positions assigned those functions. The objective of the changes is to ensure that those functions and their processes are linked directly to the augmented minimum staffing positions to allow for optimum relief of on shift personnel and less complicated response execution following facility activation.
Refer to Enclosures 1, 2, and 3 for a detailed review of the differences between the current CNS augmenting ERO and the standard augmenting ERO, and the evaluation of those changes from the organizational hierarchy, position and response, and task-by-task levels.
The adoption of the standard augmenting ERO into the CNS Emergency Plan: (1) provides a response organization defined by specific structure and responsibilities, which is consistent with regulations and industry guidance, and (2) maintains an efficient augmentation capability for both minimum staffing and full staffing positions.
The adoption of the standard augmenting ERO into the CNS Emergency Plan does not alter the licensing basis and continues to meet the regulatory requirements of 10CFR50.47(b)(1), (b)(2), (b)(7), and 10CFR50 Appendix E, Section IV.A. This change does not alter, add or remove previous site specific commitments with regards to the augmenting ERO.
The Section I revision includes a description on the use of a frisker to measure radioiodine concentrations in addition to the method in the current Emergency Plan. There will continue to be adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition as required by 10 CFR 50.47(b)(9) and Appendix E to 10 CFR Part 50, IV.E.2.
The adoption of a fleet standard recovery organization and plan into the CNS Emergency Plan provides a flexible recovery organization based on the complexity of the event or recovery plan. This new recovery organization and plan is based on the current recovery organization and plan in place at HNP, which has been evaluated in drills and
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EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
AD-E P-ALL-0602 Rev.3
<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>
ATTACHMENT 5 Page 3 of 8 exercises. The adoption of a fleet standard recovery organization into the CNS Emergency Plan does not alter the licensing basis and continues to meet the regulatory requirements of 10CFR50.47(b)(13). This change does not alter, add or remove previous site specific commitments with regards to the recovery organization and plan.
Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen):
- 1. The following portion of planning standard §50.47(b)(1) is related to the change in adopting the standard augmenting ERO.
Primary responsibilities for emergency response by the nuclear facility licensee have been assigned, and each principal response organization has staff to augment its initial response on a continuous basis.
The functions for §50.47(b)(1) related to this change are:
- a. Responsibility for emergency response is assigned.
- b. The response organization has the staff to respond and augment on a continuing basis (24!7 staffing) in accordance with the E-plan.
The NUREG-0654 Part II.A elements for §50.47(b)(1) related to this change are:
A. 1.d. Each organization shall identify a specific individual by title who shall be in charge of the emergency response.
A.2. Each principal organization shall be capable of continuous (24-hour) operations for a protracted period.
The individual in the principal organization who will be responsible for assuring continuity of resources (technical, administrative, and material) shall be specified by title.
- 2. The following portion of planning standard §50.47(b)(2) is related to the change in adopting the standard augmenting ERO.
n..:_.. _ _.
, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.
The function for §50.47(b)(2) related to this change is:
- b. The process for timely augmentation of on shift staff is established and maintained.
The NUREG-0654 Part 11.B elements for §50.47(b)(2) related to this change are:
8.3. Each licensee shall identify a line of succession for the emergency coordinator position and identify the specific conditions for higher level utility officials assuming this function.
8.4. Each licensee shall establish the functional responsibilities assigned to the emergency coordinator and shall clearly specify which responsibilities may not be delegated to other elements of the emergency organization. Among the responsibilities which may not be delegated shall be the decision to notify and to recommend protective actions to authorities responsible for offsite emergency measures.
8
.5. Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table 8-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Tab le 8-1.
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EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>
AD-EP-ALL-0602 Rev. 3 ATTACHMENT 5 Page 4 of 8 B. 7. Each licensee shall specify the corporate management, administrative, and technical support personnel who will augment the plant staff as specified in the table entitled "Minimum Staffing Requirements for Nuclear Power Plant Emergencies," (Table B-1)
- 3. The following portions of §50 Appendix E,Section IV.A are related to the change in adopting the standard augmenting ERO.
The organization for coping w ith radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:
- 2. A description of the onsite emergency response organization (ERO) w ith a detailed discussion of:
- a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;
- b. Plant staff emergency assignments;
- c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.
- 3. A description, by position and function to be performed, of the licensee's headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.
- 4. Identification, by position and function to be performed, of persons within the licensee organization who will be responsible for making offsite dose projections,...
- 4. The following portion of planning standard §50.47(b)(7) is related to the change in adopting the standard augmenting ERO.
Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact w ith the news media for dissemination of information during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of information to the public are established.
The function for §50.47(b)(7) related to this change are:
- a. Coordinated dissemination of public information during emergencies is established.
The NUREG-0654 Part 11.G elements for §50.47(b)(5) related to this change are:
G.4.a Each principal organization shall designate a spokesperson who should have access to all necessary information.
- 5. The following portion of planning standard §50.47(b)(9) is associated with the addition of a frisker for measuring radioiodine concentrations.
Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
The function for §50.47(b)(9) related to this change are:
- a. Methods, systems, and equipment for assessment of radioactive releases are in use.
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EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>
The NUREG-0654 Part II.I elements for §50.47(b)(9) related to this change are:
AD-EP-ALL-0602 Rev. 3 ATTACHMENT 5 Page 5 of 8 I. 7 Each organization shall describe the capability and resources for field monitoring within the plume exposure Emergency Planning Zone which are an intrinsic part of the concept of operations for the facility.
I. 8 Each organization, where appropriate, shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways. This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.
1.9 Each organization shall have a capability to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low as 10-7 uci/cc (microcuries per cubic centimeter) under field conditions.
Interference from the presence of noble gas and background radiation shall not decrease the stated minimum detectable activity.
- 6. The following portion of planning standard §50.47(b)(13) is associated with the change in adopting the standard recovery organization and plan.
General plans for recovery and reentry are developed.
The function for §50.47(b)(13) related to this change are:
- a. Plans for recovery and reentry are developed.
The NUREG-0654 Part 11.M elements for §50.47(b)(13) related to this change are:
M. 1 Each organization, as appropriate, shall develop general plans and procedures for reentry and recovery and describe the means by which decisions to relax protective measures (e.g., allow reentry into an evacuated area) are reached. This process should consider both existing and potential conditions.
M.2 Each licensee plan shall contain the position/title, authority and responsibilities of individuals who will fill key positions in the facility recovery organization. This organization shall include technical personnel with responsibilities to develop, evaluate and direct recovery and reentry operations.
M.3 Each licensee and State plan shall specify means for informing members of the response organizations that a recovery operation is to be initiated, and of any changes in the organizational structure that may occur.
M.4 Each plan shall establish a method for periodically estimating total population exposure.
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EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
AD-E P-ALL-0602 Rev.3 ATTACHMENT 5 Page 6 of 8 Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:
There is no numeric change to the CNS augmenting ERO. Refer to Enclosures 1, 2, and 3 for a detailed review of the differences between the current CNS augmenting ERO and the standard augmenting ERO, and the evaluation of those changes.
- 1. Capability Assessment All emergency response related functions and tasks performed by the current CNS augmenting ERO have been dispositioned against the standard ERO positions as documented in Enclosures 1, 2 and 3. Changes to ERO task assignments categorized as deviations were evaluated and determined not to degrade the capability to perform their particular function.
Additionally, a l
l ERO tasks for each position have been formally defined, indexed to their corresponding planning standard, and listed in the Emergency Plan Implementing Procedures for Emergency Response Facility activation. These tasks can now be readily adopted into the ERO systematic approach to training based qualification process and easily associated with the drill and exercise evaluation performance objectives and demonstration criteria. Thus, the capability to determine performance vs. process issues and feedback to training of task level items is significantly improved.
- 2. Timeliness Assessment The standard augmenting ERO, with minor modification, is based on the current augmenting ERO in place at CNS, MNS and ONS which has been evaluated in numerous drills and exercises. There are no changes to the on-shift ERO or 45 minute response positions as part of the standard augmenting ERO initiative.
The aspect of timeliness with regard to the ability of any position to perform their assigned responsibilities was further evaluated by a review of the impact of any new tasks assigned to a position by a process similar to that used in the on-shift staffing study task analysis. It was assumed there was no timeliness impact for positions that were not assigned new tasks or were only assigned new tasks which were determined to be undocumented and were actually performed by the position. New tasks are categorized as deviations. The aspects of overburden and overlap were considered in the determination of whether there was a potential adverse impact on timeliness to any assigned task. No position was identified with task overburden or overlap with regard to the addition of any responsibilities.
Based on the above, the adoption of the standard augmenting ERO will continue to maintain or improve the capability and timeliness of the CNS augmenting ERO to respond to an event and effectively perform their assigned tasks.
The Section I change to use a frisker to measure radioiodine concentrations in addition to the method in the current Emergency Plan is an enhancement. The change provides additional assurance that methods, systems, and equipment for assessment of radioactive releases are in use.
The adoption of a fleet standard recovery organization and plan ensures the Corporate EOF can be a part of the site recovery organization if needed. The standard recovery organization and plan continues to ensure plans for recovery and reentry are developed.
The changes described do not affect the emergency planning functions because the changes continue to ensure:
- Responsibilities for emergency response are assigned
- The response organization has the staff to respond and augment on a continuing basis (24/7 staffing) in accordance with the E-plan
- The process for timely augmentation of on shift staff is established and maintained
- Coordinated dissemination of public information during emergencies is established n---
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
AD-EP-ALL-0602 Rev.3 ATTACHMENT 5 Page 7 of 8
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
- Methods, systems, and equipment for assessment of radioactive releases are in use
- Plans for recovery and reentry are developed.
The changes described provide additional assurance that the normal plant operating organization and ERO has the ability and capability to:
- respond to an emergency;
- perform functions in a timely manner;
- effectively identify and take measures to ensure protection of the public health and safety; and
- effectively use response equipment and emergency response procedures.
Part VI. Evaluation Conclusion.
Answer the following questions about the proposed change.
1 Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E?
Yes* No D 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no Yes* NoD reduction in effectiveness)?
3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme?
Yes* NoD 4 Choose one of the following conclusions:
a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current Emergency Action Level (EAL) scheme. Therefore, the activity can be implemented without prior NRC approval.
b The activity does not continue to comply with the requirements of 10 CFR 50.47(b) or 10 CFR 50 Appendix E or the activity does constitute a reduction in effectiveness or EAL scheme change.
D Therefore, the activity cannot be implemented without prior NRC approval.
Part VII. Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change determined to require prior NRC approval be either revised or I
Yes D I No D rejected?
If No, then initiate a License Amendment Request in accordance 10 CFR 50.90 and AD-LS-ALL-0002, Regulatory Correspondence, and include the tracking number:
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EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
AD-E P-ALL-0602 Rev.3 ATTACHMENT 5 Page 8 of 8 Part VIII. Signatures: EP CFAM Final Approval is required for changes affecting risk significant planning standard 10 CFR 50.47(b)(4).
Preparer Name (Print):
Preparer Signature:
Date:
Matthew Nelson See CAS See CAS Reviewer Name (Print):
Reviewer Signature:
Date:
See CAS See CAS See CAS Approver (EP Manager) Name (Print):
Approver Signature:
Date:
See CAS See CAS See CAS Approver (CFAM, as required) Name (Print): Approver Signature:
Date:
N/A N/A N/A If the proposed activity is a change to the E-Plan or implementing procedures, then create two EREG General Assignments.
If required by Section 5.5, Submitting Reports of Changes to the NRC, then create two EREG General Assignments.
- One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q),
to Licensing.
One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect.
QA RECORD n---
l l
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Duke Energy ACTION REQUEST -02152281 I
Act ion Request Ass ignment Deta i
ls ASSIGNMENT NUMBER
- 04 SUB :
Type Status Assigned To Subject Aff Facility UCR Organization Est Manhrs Description
- GNRL
- ACC/ASG
- STACI N FISCHER Due Date Reschedule
- 10/12/2017
- PROVIDE 50.54(0) INFO TO LICENSING FOR NRG 30 DAY SUBMITTAL
- CN Unit Schedule Ref Department
- 13650 Ext Comp Date Pri Resp Fae Pri Resp Group Sec Resp Fae Sec Resp Group System Discipline THE REGULATION AT 10 CFR 50.54(0)(5) REQUIRES THE LICENSEE TO SUBMIT, AS SPECIFIED IN 10 CFR 50.4(B)(5)(11), A REPORT OF EACH CHANGE TO THE EMERGENCY PLAN MADE WITHOUT PRIOR NRG APPROVAL, INCLUDING A
SUMMARY
OF ITS ANALYSIS, WITHIN 30 DAYS AFTER THE CHANGE IS PUT IN EFFECT. THE NRG HAS STATED THAT THE
SUMMARY
REPORT OR A FULL COPY OF THE COMPLETED 50.54(0) MAY BE SUBMITTED TO SATISFY THIS REQUIREMENT. SUBMIT TO LICENSING, A
SUMMARY
, AS DESCRIBED IN AD-EP-ALL-0602, OR THE FULL 50.54(0) REVIEWING ALL CHANGES TO THE EMERGENCY PLAN MADE WITHOUT PRIOR NRG APPROVAL FOR SUBMITTAL TO THE NRC
'S DOCUMENT CONTROL DESK, WITH A COPY TO THE APPROPRIATE REGIONAL OFFICE, AND A COPY TO THE APPROPRIATE NRG RESIDENT INSPECTOR. IF THE COMMUNICATION IS ON PAPER, THE SUBMISSION TO THE DOCUMENT CONTROL DESK MUST BE THE SIGNED ORIGINAL.
Act ion Request Ass ignment Comp let ion Notes Act ion Request Assignment Status H istory Updated Date 09/20/2017 0912012017 09/20/2017 09/20/2017 Updated By 118938 118938 118938 144004 I
Printed : 10/10/2017 Assgn Status I
NP ROG NTFY/ASG ACC/ASG Assgn Due Date 10/12/2017 Page :
24
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Duke Energy ACTION REQUEST -02152281 I
Action Request Assignment Attr ibutes Request Attribute 1A COMMITTED Name :
Request Attribute 1 B CHANGE BASIS Name :
Request Attribute 2A COMMENTS Name :
Request Attribute BENEFIT REALIZED Name :
Request Attribute FINAL ISSUE Name :
Request Attribute IMPORTANT TO NRC Name :
Request Attribute IT LABOR ESTIMATE Name :
Request Attribute LTAM ISSUE ID Name :
I Printed : 10/10/2017 Values Values Values Values Values Values Values Values Reqd N
Reqd N
Reqd N
Reqd N
Reqd N
Reqd N
Reqd N
Reqd N
Date Date Date Date Date Date Date Date Page :
25
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Duke Energy ACTION REQUEST -02152281 Request Attribute PHC DUE DATE Name :
Request Attribute PLANT HEAL TH ISSUE ?
Name :
Request Attribute T +1 CRITIQUE Name :
Request Attribute WBS Name :
Values Values Values Values Act ion Request Assignment Rout ing/Return Comments Routing Comments from the X601 Panel
- No Routing Comments Found ***
Routing Comments from the X602 Panel
- No Return Comments Found ***
Act ion Request Assignment Comp let ion Approva l
Act ion Request Assignment Cause/Act ion Action Request Assignment Reference Documents Doc Sub Reqd N
Reqd N
Reqd N
Reqd N
Minor Date Date Date Date Facility Type Type Document Sheet Rev Rev Title I
Printed : 10/10/2017 Updated On Updated By Updated On Updated By Page :26
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Duke Energy ACTION REQUEST -02152281 Act ion Request Assignment Reference Equ ipment Equip Equip Facility Unit System Type Number Equip Tag Act ion Request Assignment Cross References Limit Equip Status Rev Rev Status Ref Ref Type Nbr Ref Ref Nbr Sub Type Status AS Cls Description I
Act ion Request Assignment Append ices I
Act ion Request Assignment Deta i
ls ASSIGNMENT NUMBER
- 05 SUB :
Type
- GNRL NTFY/ASG TONYA L LOWERY Due Date Reschedule
- 10/26/2017 Status Assigned To Subject
- LICENSING SUBMIT 50.54(Q) TO NRC WITHIN 30 DAYS OF CHANGE Aff Facility UCR Organization Est Manhrs Description
- CN Unit Schedule Ref Department
- 1041 o Ext Comp Date Pr i Resp Fae CN Pri Resp Group REGSUPV Sec Resp Fae Sec Resp Group System Discipline THE REGULATION AT 10 CFR 50.54(Q)(5) REQUIRES THE LICENSEE TO SUBMIT, AS SPECIFIED IN 10 CFR 50.4(B)(5}{11), A REPORT OF EACH CHANGE TO THE EMERGENCY PLAN MADE WITHOUT PRIOR NRC APPROVAL, INCLUDING A
SUMMARY
OF ITS ANALYSIS, WITHIN 30 DAYS AFTER THE CHANGE IS PUT IN EFFECT. THE NRC HAS STATED THAT THE
SUMMARY
REPORT OR A FULL COPY OF THE COMPLETED 50.54(Q) MAY BE SUBMITTED TO SATISFY THIS REQUIREMENT. SUBMIT, WITHIN 30 DAYS OF IMPLEMENTING THE CHANGE, THE FULL 50.54(Q) OR
SUMMARY
(AS DESCRIBED IN AD-EP-ALL-0602) FOR ALL CHANGES TO THE EMERGENCY PLAN MADE WITHOUT PRIOR NRC APPROVAL TO THE NRC
'S DOCUMENT CONTROL DESK, WITH A COPY TO THE APPROPRIATE REGIONAL OFFICE, AND A COPY TO THE APPROPRIATE NRC RESIDENT INSPECTOR. IF THE COMMUNICATION IS ON PAPER, THE SUBMISSION TO THE DOCUMENT CONTROL DESK MUST BE THE SIGNED ORIGINAL.
I Printed : 10/10/2017 Page :27
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Duke Energy ACTION REQUEST -02152281 Action Request Assignment Completion Notes Action Request Assignment Status History Updated Date 09/20/2017 09/20/2017 09/20/2017 09/21/2017 09/21/2017 Updated By 118938 118938 118938 CAFLETC CAFLETC Assgn Status INPROG Assgn Due Date NTFY/PRI ACC/PRI NTFY/ASG I
Action Request Assignment Attributes Request Attribute 1A COMMITTED Name :
Request Attribute 1 B CHANGE BASIS Name :
Request Attribute 2ACOMMENTS Name :
Request Attribute BENEFIT REALIZED Name :
Request Attribute FINAL ISSUE Name :
I Printed : 10/10/2017 Values Values Values Values Values 10/26/2017 Reqd N
Reqd N
Reqd N
Reqd N
Reqd N
Date Date Date Date Date Page : 28
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ACTION REQUEST -02152281 Request Attribute IMPORTANT TO NRC Name :
Request Attribute IT LABOR ESTIMATE Name :
Request Attribute LTAM ISSUE ID Name :
Request Attribute PHC DUE DATE Name :
Request Attribute PLANT HEAL TH ISSUE?
Name :
Request Attribute T +1 CRITIQUE Name :
Request Attribute WBS Name :
Values Values Values Values Values Values Values Action Request Assignment Routing/Return Comments Routing Comments from the X601 Panel
- No Routing Comments Found ***
Routing Comments from the X602 Panel
- No Return Comments Found***
I Printed : 10/10/2017 Reqd N
Reqd N
Reqd N
Reqd N
Reqd N
Reqd N
Reqd N
Date Date Date Date Date Date Date Updated On Updated By Updated On Updated By Page :
29
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Duke Energy ACTION REQUEST -02152281 Act ion Request Ass ignment Comp let ion Approva l
Act ion Request Ass ignment Cause/Act ion Act ion Request Ass ignment Reference Documents Doc Sub M
inor Facility Type Type Document Sheet Rev Rev T
it le Act ion Request Ass ignment Reference Equ ipment Equ ip Equ ip Facility Un it System Type Number Equ ip Tag Act ion Request Ass ignment Cross References L
im it Equ ip Rev Status Rev Status Ref Ref Type Nbr Ref Ref Nbr Sub Type Status AS C ls Descr ipt ion I
Act ion Request Ass ignment Append ices I
Pr inted : 10/10/2017 Page :
30
- END OF REPORT***