ML19248C311
| ML19248C311 | |
| 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: ML19248C311 (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 #: _02279017____________________
BNP CNS CR3 HNP 5AD #: __02278949_________________
MNS ONS RNP GO Document and Revision Emergency Plan Section B 19-01 Part I. Description of Proposed Change:
Change #
Plan Section Current Revision Proposed Revision Reason 3
Figure B-2 OAC Support Position Deleted OAC Support Position removed from AD-EP-ALL-0105 with Revision 3 (EREG 02274584) 4 Figure B-3 NA Added
- to OSC Manager and
- OSC Manager is NOT required per Figure B-1b and is an administrative minimum staff position per AD-EP-ALL-106. as a footnote.
Clarifying that OSC Manager is NOT required per Figure B-1b and is an administrative minimum staff position per AD-EP-ALL-106.
5 Figure B-3 Chemistry Supervisor Deleted.
Chemistry Supervisor Position removed from AD-EP-ALL-0106 with Revision 3 (EREG 02253328).
6 Figure B-3 Chemistry Tech (shift) under Chemistry Supervisor Chemistry Tech (shift) under Operations Supervisor Chemistry Tech (shift) position moved per AD-EP-ALL-0106 with Revision 3 (EREG 02253328).
, 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
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
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 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):
Change 3 moves the OAC Support responsibilities and procedure steps to IT Support in the TSC. This change is an efficiency gain. The OAC Support only defined responsibility was to turn on or verify ERDS was operating. That responsibility has been added to the IT Support Checklist. The IT Support will contact the on-call OAC Subject Matter Expert for any other OAC related issues. Responsibilities continue to be defined and timely augmentation of an OAC SME is available. The ERO continues to be staffed to augment initial response on a continuous basis.
Thus, the Duke Energy Emergency Plans will continue to comply with 10 CFR 50.47(b)(1) Assignment of Responsibility/Organizational Control, 10 CFR 50.47(b)(2), Onsite Emergency Organization, and 10 CFR Part 50 Appendix E,Section IV.A Organization. This change was previously evaluated with AD-EP-ALL-0105 with Revision 3 via EREG 02274584.
Change 4 clarifies that OSC Manager is NOT required per Figure B-1b and is an administrative minimum staff position per AD-EP-ALL-106. Thus, the Duke Energy Emergency Plans will continue to comply with 10 CFR 50.47(b)(1) Assignment of Responsibility/Organizational Control, 10 CFR 50.47(b)(2), Onsite Emergency Organization, and 10 CFR Part 50 Appendix E,Section IV.A Organization.
Changes 5 and 6 move Chemistry Supervisor responsibilities and procedure steps to Operations Supervisor in the OSC. This change is due to staffing analysis and efficiency gains. During normal and emergency operations, operations procedures direct when to take chemistry samples. When procedures direct to take a chemistry sample, operations contacts chemistry to perform samples and report results to control room. This process will only modify by location when OSC is activated. The OSC Operations Supervisor will be in contact with control room during declared emergencies and as samples are required by procedure, the OSC Operations Supervisor will direct chemistry to perform samples and report results to OSC. The OSC Operations Supervisor is trained to direct and control in-plant operations as directed by procedure. The OSC Operations Supervisor is aware of plant conditions and will continue to dispatch missions including requesting chemistry samples using OSC resources ensuring radiological and personnel safety. Chemistry samples will continue to be assessed in TSC for upgrades in classification and core damage assessments. Responsibilities for chemistry sampling continue to be defined and timely augmentation of chemistry sampling supervision is available. The ERO continues to be staffed to augment initial response on a continuous basis. Thus, the Duke Energy Emergency Plans will continue to comply with 10 CFR 50.47(b)(1) Assignment of Responsibility/Organizational Control, 10 CFR 50.47(b)(2), Onsite Emergency Organization, and 10 CFR Part 50 Appendix E,Section IV.A Organization. This change was previously evaluated with AD-EP-ALL-0106 with Revision 3 via EREG 02253328.
The differences in approved revisions and the current revisions of the Emergency Plans have been reviewed, and they have been determined to continue to meet NRC requirements as described in 10 CFR 50.47(b) and 10 CFR
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 >>
50, Appendix E during the course of revisions.
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):
10CFR50.47(b)(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
10CFR50 Appendix E.IV.A. Organization 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.
The associated EP Function is Function 1b, "The response organization has the staff to respond and to augment staff on a continuing basis (i.e., 24/7 support) in accordance with the emergency plan."
Program Elements NUREG-0654 Section II.B B.1 Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement.
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 minimum on-shift staffing levels shall be as indicated in Table B-1. 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 Table B-1. The implementation schedule for licensed operators, auxiliary operators and the shift technical advisor on shift shall be as specified in the July 31, 1980 letter to all power reactor licensees. Any deficiencies in the other staffing requirements of Table B-1 must be capable of augmentation within 30 minutes by September 1, 1981, and such deficiencies must be fully removed by July 1, 1982.
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 >>
Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:
Change 3 moves the OAC Support responsibilities and procedure steps to IT Support in the TSC. This change is an efficiency gain. The OAC Support only defined responsibility was to turn on or verify ERDS was operating. That responsibility has been added to the IT Support Checklist. The IT Support will contact the on-call OAC Subject Matter Expert for any other OAC related issues. Responsibilities continue to be defined and timely augmentation of an OAC SME is available. The ERO continues to be staffed to augment initial response on a continuous basis.
Thus, the Duke Energy Emergency Plans will continue to comply with 10 CFR 50.47(b)(1) Assignment of Responsibility/Organizational Control, 10 CFR 50.47(b)(2), Onsite Emergency Organization, and 10 CFR Part 50 Appendix E,Section IV.A Organization. This change was previously evaluated with AD-EP-ALL-0105 with Revision 3 via EREG 02274584.
Change 4 clarifies that OSC Manager is NOT required per Figure B-1b and is an administrative minimum staff position per AD-EP-ALL-106. Thus, the Duke Energy Emergency Plans will continue to comply with 10 CFR 50.47(b)(1) Assignment of Responsibility/Organizational Control, 10 CFR 50.47(b)(2), Onsite Emergency Organization, and 10 CFR Part 50 Appendix E,Section IV.A Organization.
Changes 5 and 6 move Chemistry Supervisor responsibilities and procedure steps to Operations Supervisor in the OSC. This change is due to staffing analysis and efficiency gains. During normal and emergency operations, operations procedures direct when to take chemistry samples. When procedures direct to take a chemistry sample, operations contacts chemistry to perform samples and report results to control room. This process will only modify by location when OSC is activated. The OSC Operations Supervisor will be in contact with control room during declared emergencies and as samples are required by procedure, the OSC Operations Supervisor will direct chemistry to perform samples and report results to OSC. The OSC Operations Supervisor is trained to direct and control in-plant operations as directed by procedure. The OSC Operations Supervisor is aware of plant conditions and will continue to dispatch missions including requesting chemistry samples using OSC resources ensuring radiological and personnel safety. Chemistry samples will continue to be assessed in TSC for upgrades in classification and core damage assessments. Responsibilities for chemistry sampling continue to be defined and timely augmentation of chemistry sampling supervision is available. The ERO continues to be staffed to augment initial response on a continuous basis. Thus, there is no reduction in effectiveness of the Emergency Planning Functions of Assignment of Responsibility and Onsite Emergency Organization. This change was previously evaluated with AD-EP-ALL-0106 with Revision 3 via EREG 02253328.
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.
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
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 >>
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)
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<< 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