ML18199A165
| ML18199A165 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 07/18/2018 |
| From: | Public Service Enterprise Group |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18199A162 | List: |
| References | |
| LR-N18-0074 | |
| Download: ML18199A165 (5) | |
Text
LR-N 18-007 4 ENCLOSURE 1 10 CFR 50.54(Q)
SUMMARY
ANALYSIS REPORTS 2018-52, 2018-24, 2018-01
LR -N 18-007 4 10 CFR 50.54(g)
SUMMARY
ANALYSIS REPORT 50.54Q I.D. Number:.:;20=-1:...::8'-'-5=2=------------------------
50.54Q
Title:
NC.EP-EP.ZZ-0102 Rev 23. Emergency Coordinator Response Description of the change made to the Emergency Plan/Procedures:
Procedure change to:
Add communications systems available to EC during ELAP/Biackout event (70196577)
Revise Sections 5.2.a, 5.3.a, Attachment 6 and Attachment 7 to assess capability of the TSC and EOF to staff and activate and to activate at an Alert or higher Page 9 step 5.2.a, 3rd step revised from "EDO" to "EC" to be consistent with ERM and to ensure EC notifies SM (80120807/001 0)
Section 5.2.b & Section 5.3.b-added PAG values for PAR upgrade and scientific notation (70198198/0030)
Revise Attachment 4 to provide instructions for optional activation of the ERO at a UE classification (70195488 0020 & 80120807/0030)
Revised Step 2. 7 of Attachment 10 to provide continuing direction during a security event Description of why the change is editorial (if not editorial, N/A this block): N/A Description of the licensing basis affected by the change to the Emergency Plan/Procedure (if not affected, omit this element):
Emergency Plan Section 5.0 discusses facility activation for all classifications. Emergency Plan Section 9.0 discusses the TSC and EOF capability to be staffed and activated or ready to activate within 90 minutes of an Alert or higher emergency classification (not required at a UE). The change adds steps for the EDO and ERM to assess the TSC and EOF readiness as well as instructions for activation of the ERO at a UE (optional).
Emergency Plan Section 10.0 discusses PAG values as stated in EPA-400 and the need to report exceedance of these values to the states at a GE. The change adds these values to the procedure as another means of verification.
Section 7.0 of the Emergency Plan discusses emergency communications systems available in an emergency however the availability of communications systems during an ELAP/Biackout event are not discussed in the emergency plan.
A description of how the change to the Emergency Plan/Procedures still complies with regulation:
1 OCFR50 Appendix E Sections C discusses Activation of Emergency Organization and the requirement to describe the communication steps to be taken to alert or activate emergency personnel under each class of emergency. Appendix E does not discuss communications systems required to be available during ELAP/Biackout event and does not discuss a time requirement to staff and activate emergency response facilities.
With respect to Appendix E, there is no reduction in effectiveness of the emergency plan resulting from the proposed change.
A description of why the proposed change was not a reduction in the effectiveness of the Emergency Plan/Procedure:
Based on the review, the proposed change does not result in a decrease in effectiveness of PSEG emergency plan functions.
LR-N 18-007 4 10 CFR 50.54(g)
SUMMARY
ANALYSIS REPORT 50.54Q 1.0. Number: =-20=-1:...::8:.....:-2=-4,__ ___________________ _
50.54Q
Title:
NC.EP-EP.ZZ-0309(0) Rev. 16. Dose Assessment (MIDAS) Instructions Description of the change made to the Emergency Plan/Procedures:
Procedure revision to:
Convert to new procedure format.
Section 2.1, Deleted Original Step 3.1.5 as individuals that would be in the emergency facilities during an event would be qualified.
Step 2.1.4, Added clarification to indicate that NC.EP-EP.ZZ-0313(0) is used at the EOF.
Step 2.2.2, Added information to reference EP-Aid-025 for obtaining meteorological data when automatic meteorological data acquisition is not operational. (SAP #70196625/001 0)
Step 4.4.18, Added new step concerning Time of Trip and renumbered remaining steps.
Section 4.5.1, Revised to remove recommendation of Radiological Protective Action Recommendations (RAD PARs). PAR determination is performed by the RAC (SAP
- 70196625/0020)
Step 4.6.1, Updated diagram of the Teletector/Telepole Rad Monitor Location.
Step 4.6.1 and Attachment 1, Added reference to telepole instrumentation for performing dose assessment calculations using Main Steam Line Teletector Readings and deleted information for Hope Creek Containment Leakage "What If' calculations which was printed twice. (SAP
- 80120090/0180)
The proposed revision makes no change to the MIDAS dose assessment software Description of why the change is editorial (if not editorial, N/A this block): N/A Description of the licensing basis affected by the change to the Emergency Plan/Procedure (if not affected, omit this element):
Emergency Plan Section 1 0.0, Accident Assessment discusses the use of MIDAS for dose assessment.
The proposed change clarifies various aspects of performing dose assessment using MIDAS and remains consistent with the requirements of Eplan Section 10.0 A description of how the change to the Emergency Plan/Procedures still complies with regulation:
1 OCFR50 Appendix E states:
A. 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 and a description of how these projections will be made and the results transmitted to State and local authorities, NRC, and other appropriate governmental entities.
B. Assessment Actions:
- 1) The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety.
The proposed change is consistent with the requirements of 1 OCFR50 Appendix E A description of why the proposed change was not a reduction in the effectiveness of the Emergency Plan/Procedure:
Based on the review above, the proposed change does not result in a decrease in effectiveness of PSEG emergency plan functions
LR-N 18-007 4 10 CFR 50.54(g)
SUMMARY
ANALYSIS REPORT 50.54Q 1.0. Number: =20::...1:....:8:......:-0::....:1'----------------------
50.54Q
Title:
NC.EP-EP.ZZ-0601(0) Rev. 13-Radiological Support Manager and Radiological Assessment Staff Response Description of the change made to the Emergency Plan/Procedures:
Procedure revision to include:
Procedure converted to new template.
Entire Procedure-Corrected title of NC.EP-EP.ZZ-0602(0). (SAP #70161063/0010)
Corrected formatting of procedure numbers NC.EP-EP.ZZ-0308, NC.EP-EP.ZZ-0305. (SAP
- 70161 063/0030)
Section 4.0- Moved initiation of RSM log to Section 4.0 from Attachment 1 Old Step 3.1 - Deleted step that provided guidance to initial steps as this is part of the procedure process and does not need to be included in this procedure.
Deleted step that stated only qualified individuals are to implement procedure. This step is not required as the only individuals contacted to implement procedure would be qualified.
Old Step 4.0- Step deleted. Not part of new template and all equipment is maintained within the EOF.
Step 7.2-Cross references were updated and reordered.
- - Deleted bullet to contact RAC. This is performed in Section 4. 0
- - Revise Note prior to Step A to remove that steps can be performed in any order.
This instruction is already in Precautions Step 2.1. 1, second bullet.
Revised Step A.1.d to reflect RSM issuance of Kl to offsite PSEG radiation workers and corrected title of procedure NC.EP EP.ZZ 0305(0), Potassium Iodide (KI) Administration.
(SAP #70161 063/001 0)
Revised Step A.1.g to add reference to guidance for initial PAR and PAR upgrades. (SAP
- 70161 063/001 0)
Revised Step A.1.g to correct title for NC.EP-EP.ZZ-0404(0). (SAP #70161 063/0020)
Added new Step A. 1.j to provide direction for EOF relocation if needed due to Radiological or External Event concerns. (SAP #70198023)
Revised Section i for RSM actions when a release is in progress.
Moved bullet for Coast Guard Helicopter approval to end of Section i
- - Step A.2.c added (at 5 miles or 10 miles) to clarify the range that the projected doses are applicable.
Step 3.c,last bullet, removed "... that could indicate exceeding a PAG", this criteria is not
- required,
- -Reordered steps and corrected numbering/bullets.
Added step to verify and/or issue dosimetry for EOF personnel. (SAP #70161063/0040)
Form-2 Formatted and added signature line for entry of data into Sentinel.
Form-3 Added line for second instrument and deleted Calibration Due Date field as not required.
Form-4 Page 1, changed "TRIP" to "SCRAM".
Updated HTV NG values to match NC.EP-EP.ZZ-0313, Attachment 5 values.
Form-5, Page 1, changed "ATWS" to "ATWT".
Description of why the change is editorial (if not editorial, N/A this block): N/A
LR-N18-0074 50.54Q I.D. Number: 2018-01 (continued)
Description of the licensing basis affected by the change to the Emergency Plan/Procedure (if not affected, omit this element):
The proposed revisions do not adversely affect the PSEG emergency plan. Roles and responsibilities for the Radiological Support Manager and Radiological Assessment Staff are unaffected (Eplan Section 3).
The EOF facility is also unaffected (Eplan Section 9). The addition of mustering/relocation information in the event of radiological or external events would only be implemented in extreme conditions and does not affect existing EOF capabilities. The remainder of changes is formatting and editorial in nature and have no effect on the emergency plan.
A description of how the change to the Emergency Plan/Procedures still complies with regulation:
10 CFR 50.47(b)(2), Onsite Emergency Organization and 10 CFR 50.47(b)(8) Emergency Facilities and Equipment were reviewed. The change as described does not adversely affect the onsite emergency organizations duties as previously described and provides clarification on EOF relocation in the event of a catastrophic event, therefore the requirements of these planning standards remain satisfied.
A description of why the proposed change was not a reduction in the effectiveness of the Emergency Plan/Procedure:
Based on the changes and reviews as described above, there is no reduction in the effectiveness of the emergency plan functions.