ML19248C297
| ML19248C297 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  (NPF-009, NPF-017) |
| Issue date: | 08/20/2019 |
| From: | Duke Energy Carolinas |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19248C291 | List:
|
| References | |
| RA-18-0325 | |
| Download: ML19248C297 (6) | |
Text
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 1 of 6
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
Screening and Evaluation Number Applicable Sites EREG #: _02279039____________________
BNP CNS CR3 HNP 5AD #: __02278967_________________
MNS ONS RNP GO Document and Revision Emergency Plan Appendix 3 19-01 Part I. Description of Proposed Change:
Change #
Plan Section Current Revision Proposed Revision Reason 2
Section Q, Appendix 3, ALERT AND NOTIFICATION SYSTEM DESCRIPTION, Table of Periodic Testing on page 3, fourth column Norm. Freq. Perf. By Duke Normally performed weekly on Thursdays.
Normally performed on the second Wednesday of each quarter, or during the biennial exercise. See Note 1 below.
See NOTE 1 below for quarterly test.
See NOTE 3 below for growl test following PM.
NA Deleted Duke Energy Normal Test Frequencies.
Duke Energy will now use the regulatory minimum required testing frequency as listed in column 3 of the table.
3 Section Q, Appendix 3, ALERT AND NOTIFICATION SYSTEM DESCRIPTION, Notes box on page 3 NOTE: 1. Quarterly full cycle tests fulfill/exceed the requirements for quarterly growl tests.
NOTE: 1. Quarterly full cycle tests fulfill/exceed the requirements for quarterly growl tests.
Full cycle test can be performed in lieu of the quarterly growl test.
Added second sentence for clarity.
4 Section Q, Appendix 3, ALERT AND NOTIFICATION SYSTEM DESCRIPTION, Sentence below Refer to FAM Section 3.3 for a detailed narrative of the siren test program NA Statement deleted per DRR 02197609.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 2 of 6
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
Notes box on page 3
, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is attached (required for IC or EAL change)
Yes No Part II. Description and Review of Licensing Basis Affected by the Proposed Change:
Licensing Basis McGuire Emergency Plan Change 2 (dated February 13, 1981)
Current Emergency Plan Emergency Plan, Revision 18-3 FEMA Alert and Notification System (ANS) Design Report Date - September 12, 1986 Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments.
If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q):
Changes are grouped as follows for evaluation purposes:
Change 2 - Deleted Duke Energy Normal Test Frequencies. This change aligns McGuires siren testing frequencies with regulatory requirements while reducing wear on the equipment. McGuires siren performance has been >99%.
Change 3 - Added second sentence to Note 1 for Test Program table to add clarity. Added Full cycle test can be performed in lieu of the quarterly growl test. as allowed per FEMA CPG 1-17.
Change 4 - Deleted statement at the bottom of Test Program table - Refer to FAM Section 3.3 for a detailed narrative of the siren test program. Statement was informational in nature and provided no specific actions or commitments. Siren test program documentation (procedures) and regulatory guidance documents are readily available.
List Commitments Associated with the Change No site specific commitments were identified aside from those in the Emergency Plan.
These changes do not affect alerting the public in a timely fashion after a declared event requiring notification.
Procedures continue to be maintained to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone. Thus, the McGuire Emergency Plan will continue to comply with 10 CFR 50.47(b)(5), Emergency Notifications and 10 CFR Part 50 Appendix E,Section IV.D, Notification Procedures.
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,
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 3 of 6
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
Part IV of associated Screen):
10CFR50.47(b)(5) - Emergency Notifications Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.
10CFR50 Appendix E.IV.D. Notification Procedures (in part)
- 1. Administrative and physical means for notifying local, State, and Federal officials and agencies and agreements reached with these officials and agencies for the prompt notification of the public and for public evacuation or other protective measures, should they become necessary, shall be described. This description shall include identification of the appropriate officials, by title and agency, of the State and local government agencies within the EPZs.
- 3. A licensee shall have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency. The licensee shall demonstrate that the appropriate governmental authorities have the capability to make a public alerting and notification decision promptly on being informed by the licensee of an emergency condition. Prior to initial operation greater than 5 percent of rated thermal power of the first reactor at a site, each nuclear power reactor licensee shall demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ. The design objective of the prompt public alert and notification system shall be to have the capability to essentially complete the initial alerting and initiate notification of the public within the plume exposure pathway EPZ within about 15 minutes. The use of this alerting and notification capability will range from immediate alerting and notification of the public (within 15 minutes of the time that State and local officials are notified that a situation exists requiring urgent action) to the more likely events where there is substantial time available for the appropriate governmental authorities to make a judgment whether or not to activate the public alert and notification system. The alerting and notification capability shall additionally include administrative and physical means for a backup method of public alerting and notification capable of being used in the event the primary method of alerting and notification is unavailable during an emergency to alert or notify all or portions of the plume exposure pathway EPZ population. The backup method shall have the capability to alert and notify the public within the plume exposure pathway EPZ, but does not need to meet the 15-minute design objective for the primary prompt public alert and notification system. When there is a decision to activate the alert and notification system, the appropriate governmental authorities will determine whether to activate the entire alert and notification system simultaneously or in a graduated or staged manner. The responsibility for activating such a public alert and notification system shall remain with the appropriate governmental authorities.
The associated EP Function is Function 5c - The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 4 of 6
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
FEMA-approved ANS design report and supporting FEMA approval letter.
Program Element NUREG-0654 Section II.E.
Notification Methods and Procedures
- 6. Each organization shall establish administrative and physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone. (See Appendix 3.) It shall be the licensee's responsibility to demonstrate that such means exist, regardless of who implements this requirement. It shall be the responsibility of the State and local governments to activate such a system.
Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:
Changes are grouped as follows for evaluation purposes:
Change 2 - Deleted Duke Energy Normal Test Frequencies. Duke Energy will now use the regulatory minimum required testing frequency as listed in column 3 (Min. Req'd Freq.) of the table. This change aligns McGuires siren testing frequencies with regulatory requirements while reducing wear on the equipment. McGuires siren performance has been >99%.
Change 3 - Added second sentence to Note 1 for Test Program table to add clarity. Added Full cycle test can be performed in lieu of the quarterly growl test. as allowed per FEMA CPG 1-17. This change also reduces wear on the equipment by more clearly identifying that full cycle test can be used for growl tests.
Change 4 - Deleted statement at the bottom of Test Program table - Refer to FAM Section 3.3 for a detailed narrative of the siren test program. Statement was informational in nature and provided no specific actions or commitments. Siren test program documentation (procedures) and regulatory guidance documents are readily available.
The change in testing frequency does not change the administrative and physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone. Duke Energy maintains the responsibility to demonstrate that such means exist. The State and Counties maintain the responsibility to activate the Duke Energy Siren system.
There is no reduction in effectiveness of the Emergency Plan based on:
McGuires siren performance being >99%.
Sirens continuing to be tested per regulatory requirements.
The Duke Energy ANS continues to meet the design requirements and FEMA approved design report as now specified in the FEMA REP Manual.
The changes described provide 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.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 5 of 6
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
The changes described do not reduce the effectiveness of the McGuire Nuclear Station Emergency Plan, as written and approved; and continue to meet NRC requirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.
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 2
Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in effectiveness)?
Yes No 3
Does the proposed change maintain the current Emergency Action Level (EAL) scheme?
Yes No 4
Choose one of the following conclusions:
a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current Emergency Action Level (EAL) scheme. Therefore, the activity can be implemented without prior NRC approval.
b The activity does not continue to comply with the requirements of 10 CFR 50.47(b) or 10 CFR 50 Appendix E or the activity does constitute a reduction in effectiveness or EAL scheme change.
Therefore, the activity cannot be implemented without prior NRC approval.
Part VII. Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change determined to require prior NRC approval be either revised or rejected?
Yes No If No, then initiate a License Amendment Request in accordance 10 CFR 50.90, AD-LS-ALL-0002, Regulatory Correspondence, and AD-LS-ALL-0015, License Amendment Request and Changes to SLC, TRM, and TS Bases, and include the tracking number:__________________________________________________.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 6 of 6
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
Part VIII. Signatures: EP CFAM Final Approval is required for changes affecting risk significant planning standard 10 CFR 50.47(b)(4) (i.e., Emergency Action Levels and Emergency Action Level Bases). If CFAM approval is NOT required, then mark the CFAM signature block as not applicable (N/A) to indicate that signature is not required.
Preparer Name (Print): Barry Kimray Preparer Signature: See CAS Date:
See CAS Reviewer Name (Print): See CAS Reviewer Signature: See CAS Date:
See CAS Approver (Manager, Nuclear Support Services) Name (Print): See CAS Approver Signature: See CAS Date:
See CAS Approver (EP CFAM, as required) Name (Print):
See CAS Approver Signature: See CAS Date:
See CAS If the proposed activity is a change to the E-Plan, then initiate PRRs.
If the proposed activity is a change to the E-Plan, then create two EREG General Assignments.
If required by Section 5.6, Submitting Reports of Changes to the NRC, then create two EREG General Assignments.
One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q),
to Licensing.
One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect.
QA RECORD