ML19248C315
| ML19248C315 | |
| 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: ML19248C315 (20) | |
Text
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 1 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
Screening and Evaluation Number Applicable Sites EREG #: _02279019____________________
BNP CNS CR3 HNP 5AD #: __02278951_________________
MNS ONS RNP GO Document and Revision Emergency Plan Section D 19-01 Part I. Description of Proposed Change:
Change Plan Section Current Revision Proposed Revision Reason 2
Section D Section 1.0 This information may assist the Emergency Coordinator/EOF Director in making classifications, particularly those involving judgment or multiple events.
This information may assist the Emergency Coordinator in making classifications, particularly those involving judgment or multiple events.
Removed EOF Director as he/she no longer has responsibility for classification.
9 Section D Section 3.3.1 When making an emergency classification, the Emergency Coordinator/EOF Director must consider all information having a bearing on the proper assessment of an Initiating Condition (IC).
When making an emergency classification, the Emergency Coordinator must consider all information having a bearing on the proper assessment of an Initiating Condition (IC).
Removed EOF Director as he/she no longer has responsibility for classification.
10 Section D Section 3.3.1.3 For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Coordinator/EOF Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.
For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.
Removed EOF Director as he/she no longer has responsibility for classification.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 2 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
11 Section D Section 3.3.1.6 The NEI 99-01 EAL scheme provides the Emergency Coordinator/EOF Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The Emergency Coordinator/EOF Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.
The NEI 99-01 EAL scheme provides the Emergency Coordinator with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The Emergency Coordinator will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.
Removed EOF Director as he/she no longer has responsibility for classification.
12 Section D Section 3.2.3 Although EALs provide specific thresholds, the Emergency Coordinator/EOF Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Coordinator/EOF Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met.
Although EALs provide specific thresholds, the Emergency Coordinator must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Coordinator, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met.
Removed EOF Director as he/she no longer has responsibility for classification.
13 Section D Section 3.2.6 The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the Removed EOF Director as he/she no longer has responsibility for classification.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 3 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
Emergency Coordinator/EOF Director completing the review and steps necessary to make the emergency declaration.
Emergency Coordinator completing the review and steps necessary to make the emergency declaration.
17 Section D EAL Bases:
RU1.1, RU1.2, RA1.1, RA1.3, RA1.4, RS1.1, RS1.3, RG1.1, RG1.3, RG2.1, CU1.1, CA1.2, CS1.1, CG1.1, CU2.1, CA2.1, CU3.2, CA3.1, CU4.1, HU4.1, HU4.2, HU4.3, HS6.1, SU1.1, SA1.1, SS1.1, SG1.1, SG1.2, SS2.1, SU3.1, SA3.1, SU5.1, SU8.1; Barrier: Containment, Category: D. CMT Integrity or Bypass, Degradation Threat:
Potential Loss, Threshold: 3 Note 1: The Emergency Coordinator/EOF Director should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.
Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.
Removed EOF Director as he/she no longer has responsibility for classification.
23 Section D Attachment 1, EAL Bases, SU5.1 NA Failure to isolate the leak within 15 minutes, or if known that the leak cannot be isolated within 15 minutes from the start of the leak, requires immediate classification.
Added paragraph per NTM 02187203 based on Operating Experience from Catawba. This will assure classification within 15 minutes of indication that an EAL was or will be exceeded.
35 Section D Attachment 1 EAL Bases, Category H, 7. Emergency Coordinator Judgment The EALs of this category provide the Emergency Coordinator/EOF Director the latitude to classify emergency conditions consistent with the established classification criteria based upon Emergency Coordinator/EOF Director judgment.
The EALs of this category provide the Emergency Coordinator the latitude to classify emergency conditions consistent with the established classification criteria based upon Emergency Coordinator judgment.
Removed EOF Director as he/she no longer has responsibility for classification.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 4 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
37 Section D Attachment 1 EAL Bases, Category H, HU7.1 Initiating Condition Other conditions exist that in the judgment of the Emergency Coordinator/EOF Director warrant declaration of an Alert Other conditions existing that in the judgment of the Emergency Coordinator warrant declaration of a UE Removed EOF Director as he/she no longer has responsibility for classification 38 Section D Attachment 1 EAL Bases, Category H, HU7.1 EAL Other conditions exist which in the judgment of the Emergency Coordinator/EOF Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of SAFETY SYSTEMS occurs.
Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of SAFETY SYSTEMS occurs.
Removed EOF Director as he/she no longer has responsibility for classification 39 Section D Attachment 1 EAL Bases, Category H, HU7.1 Basis The Emergency Coordinator/EOF Director are the designated onsite individuals having the responsibility and authority for implementing the MNS Emergency Response Plan. The Operations Shift Manager (SM) initially acts in the capacity of the Emergency Coordinator/EOF Director and takes actions as outlined in the Emergency Plan implementing procedures. If required by the emergency classification or if deemed appropriate by the Emergency The Emergency Coordinators are the designated onsite individuals having the responsibility and authority for implementing the MNS Emergency Response Plan. The Operations Shift Manager (SM) initially acts in the capacity of the Emergency Coordinator and takes actions as outlined in the Emergency Plan implementing procedures. If required by the emergency classification or if deemed appropriate by the Emergency Coordinator, emergency response Changed The Emergency Coordinator/EOF Director are the designated to The Emergency Coordinators are the designated.
Pluralized Emergency Coordinator for grammatical correctness.
Removed EOF Director as he/she no longer has responsibility for classification.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 5 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
Coordinator/EOF Director, emergency response personnel are notified and instructed to report to their emergency response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (ref. 1).
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator/EOF Director to fall under the emergency classification level description for an Unusual Event.
personnel are notified and instructed to report to their emergency response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (ref. 1).
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the emergency classification level description for an Unusual Event.
40 Section D Attachment 1 EAL Bases, Category H, HA7.1 Initiating Condition Other conditions exist that in the judgment of the Emergency Coordinator/EOF Director warrant declaration of an Alert Other conditions exist that in the judgment of the Emergency Coordinator warrant declaration of an Alert Removed EOF Director as he/she no longer has responsibility for classification.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 6 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
41 Section D Attachment 1 EAL Bases, Category H, HA7.1 EAL Other conditions exist which, in the judgment of the Emergency Coordinator/EOF
- Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.
Other conditions exist which, in the judgment of the Emergency Coordinator, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION.
Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.
Removed EOF Director as he/she no longer has responsibility for classification.
42 Section D Attachment 1 EAL Bases, Category H, HA7.1 Basis The Emergency Coordinator/EOF Director are the designated onsite individuals having the responsibility and authority for implementing the MNS Emergency Response Plan. The Operations Shift Manager (SM) initially acts in the capacity of the Emergency Coordinator and takes actions as outlined in the Emergency Plan implementing procedures. If required by the emergency classification or if deemed appropriate by the Emergency Coordinator, emergency response personnel are notified and instructed to report The Emergency Coordinators are the designated onsite individuals having the responsibility and authority for implementing the MNS Emergency Response Plan. The Operations Shift Manager (SM) initially acts in the capacity of the Emergency Coordinator and takes actions as outlined in the Emergency Plan implementing procedures. If required by the emergency classification or if deemed appropriate by the Emergency Coordinator, emergency response personnel are notified and instructed to report to their emergency Changed The Emergency Coordinator/EOF Director are the designated to The Emergency Coordinators are the designated.
Pluralized Emergency Coordinator for grammatical correctness.
Removed EOF Director as he/she no longer has responsibility for classification.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 7 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
to their emergency response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (ref.1).
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator/EOF Director to fall under the emergency classification level description for an Alert.
response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (ref.1).
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the emergency classification level description for an Alert.
43 Section D Attachment 1 EAL Bases, Category H, HS7.1 Initiating Condition Other conditions existing that in the judgment of the Emergency Coordinator/EOF Director warrant declaration of a Site Area Emergency Other conditions existing that in the judgment of the Emergency Coordinator warrant declaration of a Site Area Emergency Removed EOF Director as he/she no longer has responsibility for classification
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 8 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
44 Section D Attachment 1 EAL Bases, Category H, HS7.1 EAL Other conditions exist which in the judgment of the Emergency Coordinator/EOF Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the SITE BOUNDARY.
Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the SITE BOUNDARY.
Removed EOF Director as he/she no longer has responsibility for classification 45 Section D Attachment 1 EAL Bases, Category H, HS7.1 Basis The Emergency Coordinator/EOF Director are the designated onsite individuals having the responsibility and authority for implementing the MNS Emergency Response Plan. The Operations Shift Manager (SM) initially acts in the capacity of the Emergency Coordinator and takes actions as outlined in the Emergency Plan implementing The Emergency Coordinators are the designated onsite individuals having the responsibility and authority for implementing the MNS Emergency Response Plan. The Operations Shift Manager (SM) initially acts in the capacity of the Emergency Coordinator and takes actions as outlined in the Emergency Plan implementing procedures. If required Changed The Emergency Coordinator/EOF Director are the designated to The Emergency Coordinators are the designated.
Pluralized Emergency Coordinator for grammatical correctness.
Removed EOF Director as he/she no longer has responsibility for classification.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 9 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
procedures. If required by the emergency classification or if deemed appropriate by the Emergency Coordinator, emergency response personnel are notified and instructed to report to their emergency response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (ref. 1).
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator/EOF Director to fall under the emergency classification level description for a Site Area Emergency.
by the emergency classification or if deemed appropriate by the Emergency Coordinator, emergency response personnel are notified and instructed to report to their emergency response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (ref. 1).
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the emergency classification level description for a Site Area Emergency.
46 Section D Attachment 1 EAL Bases, Category H, HG7.1 Initiating Condition Other conditions exist which in the judgment of the Emergency Coordinator/EOF Director warrant declaration of a Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of a General Emergency Removed EOF Director as he/she no longer has responsibility for classification
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 10 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
General Emergency 47 Section D Attachment 1 EAL Bases, Category H, HG7.1 EAL Other conditions exist which in the judgment of the Emergency Coordinator/EOF Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.
Removed EOF Director as he/she no longer has responsibility for classification. Added period at end of EAL
- editorial.
48 Section D Attachment 1 EAL Bases, Category H, HG7.1 Basis The Emergency Coordinator/EOF Director are the designated onsite individuals having the responsibility and authority for implementing the MNS Emergency Response Plan. The Operations Shift Manager(SM) initially acts in the capacity of the Emergency Coordinator and takes actions as outlined in the Emergency Plan implementing procedures. If required by the emergency classification or if deemed appropriate by the Emergency Coordinator, emergency response personnel are notified and instructed to report The Emergency Coordinator are the designated onsite individuals having the responsibility and authority for implementing the MNS Emergency Response Plan. The Operations Shift Manager(SM) initially acts in the capacity of the Emergency Coordinator and takes actions as outlined in the Emergency Plan implementing procedures. If required by the emergency classification or if deemed appropriate by the Emergency Coordinator, emergency response personnel are notified and instructed to report to their emergency Removed EOF Director as he/she no longer has responsibility for classification
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 11 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
to their emergency response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (ref. 1).
Releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the Site Boundary.
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator/EOF Director to fall under the emergency classification level description for a General Emergency.
response locations. In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency response, but Plant Management is expected to manage the emergency response as soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (ref. 1).
Releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the Site Boundary.
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the emergency classification level description for a General Emergency.
49 Section D Attachment 1 EAL Bases, Category F-Fission Product Barrier Degradation, last paragraph/bullet Alternatively, if both the Fuel Clad and NCS fission product barriers were potentially lost, the Emergency Coordinator/EOF Alternatively, if both the Fuel Clad and NCS fission product barriers were potentially lost, the Emergency Coordinator would have Removed EOF Director as he/she no longer has responsibility for classification
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 12 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
Director would have more assurance that there was no immediate need to escalate to a General Emergency.
more assurance that there was no immediate need to escalate to a General Emergency.
50 Section D Attachment 1 EAL Bases, FS1.1 Basis Alternatively, if both Fuel Clad and NCS potential loss thresholds existed, the Emergency Coordinator/EOF Director would have greater assurance that escalation to a General Emergency is less imminent.
Alternatively, if both Fuel Clad and NCS potential loss thresholds existed, the Emergency Coordinator would have greater assurance that escalation to a General Emergency is less imminent.
Removed EOF Director as he/she no longer has responsibility for classification 52 Section D Attachment 1,
, Fission Product Barrier Loss/Potential Loss Matrix and Bases:
Barrier: Fuel Clad, Category: E.
Emergency Coordinator Judgment, Degradation Threat:
Loss, Threshold: 1; Barrier: Fuel Clad, Category: E.
Emergency Coordinator Judgment, Degradation Threat:
Potential Loss, Threshold: 1; Barrier: Reactor Coolant System, Category: E.
Emergency Coordinator Judgment, Degradation Threat:
- Loss, Threshold: 1; Barrier: Reactor Coolant System, Category: E.
Emergency Coordinator Judgment, Degradation Threat:
Potential Loss, Threshold: 1; Emergency Coordinator/EOF Director Emergency Coordinator Removed EOF Director as he/she no longer has responsibility for classification
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 6 ATTACHMENT 5 Page 13 of 20
<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
Barrier: Containment, Category: F.
Emergency Coordinator Judgment, Degradation Threat:
Loss, Threshold: 1; Barrier: Containment, Category: F.
Emergency Coordinator Judgment, Degradation Threat:
Potential Loss, Threshold: 1; 53 Section D Attachment 2 Fission Product Barrier Loss/Potential Loss Matrix and Bases Table Emergency Coordinator/EOF Director Emergency Coordinator Removed EOF Director as he/she no longer has responsibility for classification 55 Section D Attachment 2 Fission Product Barrier Loss/Potential Loss Matrix and Bases, Barrier: Fuel Clad, Category: E.
Emergency Coordinator Judgment, Degradation Threat:
Loss, Basis, 3rd bullet Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator/EOF Director should be mindful of the Loss of AC power (Station Blackout) and ATWS EALs to assure timely emergency classification declarations.
Dominant accident sequences lead to degradation of all fission product barriers and likely entry to the EOPs. The Emergency Coordinator should be mindful of the Loss of AC power (Station Blackout) and ATWS EALs to assure timely emergency classification declarations.
Removed EOF Director as he/she no longer has responsibility for classification 56 Section D Attachment 2 Fission Product Barrier Loss/Potential Loss Matrix and Bases Table, Barrier: Fuel Clad, Category: B.
Inadequate Heat Removal, 1st paragraph of Basis Critical Safety Function Status Tree (CSFST)
Core Cooling-ORANGE path indicates indicates subcooling has been lost and that some fuel clad damage may potentially occur.
Critical Safety Function Status Tree (CSFST)
Core Cooling-ORANGE path indicates subcooling has been lost and that some fuel clad damage may potentially occur.
Removed second indicates. Editorial
, 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 RP/0/A/5700/000 - CLASSIFICATION OF EMERGENCY AD-EP-ALL-0105 - ACTIVATION AND OPERATION OF THE TECHNICAL SUPPORT CENTER
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 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:
Removing EOF Director from classify - Changes 2, 9 through 13, 17, 35, 37 through 46, 47 (non-editorial),
48 through 50, 52, 53 and 55. Changes 39, 42 and 45 also pluralized Emergency Coordinator for grammatical correctness.
Added clarifying statement to SU5.1 Bases - Change 23 Removing EOF Director from classify - Changes 2, 9 through 13, 17, 35, 37 through 46, 47 (non-editorial), 48 through 50, 52, 53 and 55. Changes 39, 42 and 45 also pluralized Emergency Coordinator for grammatical correctness The changes reflect that the EOF Director no longer maintains the function of Emergency Classification. Procedure SR/0/A/2000/003 (Activation of the Emergency Operations Facility Revision 010 implemented this change in the EOF for McGuire and was evaluated as meeting licensing and regulatory bases per EREG 02056256. Emergency Classification functions continue to be maintained by the Control Room Emergency Coordinator and the TSC Emergency Coordinator. Thus, the Emergency Plans will continue to comply with 10 CFR 50.47(b)(2) Onsite Emergency Organization and 10 CFR Part 50 Appendix E,Section IV.A. Organization.
Added clarifying statement to SU5.1 Bases - Change 23 This change added Failure to isolate the leak, within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification. as part of the Bases for EAL SU5.1. This addition provides additional clarifying guidance to assure that classifications are made within 15 minutes of indication that an EAL was or will be exceeded. This change is an enhancement to the EAL SU5.1 Bases. Thus, the Emergency Plans will continue to comply with 10 CFR 50.47(b)(4) Emergency Classification System and 10 CFR Part 50 Appendix E,Section IV.B. Assessment Actions.
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 continue to meet NRC requirements as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E during the course of revisions.
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 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)(2)
On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.
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 2b, The process for timely augmentation of onshift staff is established and maintained.
Program Element NUREG-0654 Section II.B B. Onsite Emergency Organization
- 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.
- 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.
10CFR50.47(b)(4)
A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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<< 10 CFR 50.54(q) Effectiveness Evaluation Form >>
10CFR50 Appendix E.IV.C. Activation of Emergency Organization
- 2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.
The associated EP Function is Function 4a, A standard scheme of emergency classification and action levels is in use.
Program Element NUREG-0654 Section II.D.
Emergency Classification System
- 1. An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee. The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, in the in-plant emergency procedures. The plan shall identify the parameter values and equipment status for each emergency class.
- 2. The initiating conditions shall include the example conditions found in Appendix I and all postulated accidents in the Final Safety Analysis Report (FSAR) for the nuclear facility.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:
Changes are grouped as follows for evaluation purposes:
Removing EOF Director from classify - Changes 2, 9 through 13, 17, 35, 37 through 46, 47 (non-editorial),
48 through 50, 52, 53 and 55. Changes 39, 42 and 45 also pluralized Emergency Coordinator for grammatical correctness.
Added clarifying statement to SU5.1 Bases - Change 23 Removing EOF Director from classify - Changes 2, 9 through 13, 17, 35, 37 through 46, 47 (non-editorial), 48 through 50, 52, 53 and 55. Changes 39, 42 and 45 also pluralized Emergency Coordinator for grammatical correctness The changes reflect that the EOF Director no longer maintains the function of Emergency Classification. Procedure SR/0/A/2000/003 (Activation of the Emergency Operations Facility Revision 010 implemented this change in the EOF for McGuire and was evaluated as meeting licensing and regulatory bases per EREG 02056256. Emergency Classification functions continue to be maintained by the Control Room Emergency Coordinator and the TSC Emergency Coordinator.
Added clarifying statement to SU5.1 Bases - Change 23 This change added Failure to isolate the leak, within 15 minutes or if known that the leak cannot be isolated within 15 minutes, from the start of the leak requires immediate classification. as part of the Bases for EAL SU5.1. This addition provides additional clarifying guidance to assure that classifications are made within 15 minutes of indication that an EAL was or will be exceeded. This change is an enhancement to the EAL SU5.1 Bases.
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.
There is no reduction in effectiveness of the Emergency Plan based on:
Emergency Classification functions continue to be maintained by the Control Room Emergency Coordinator and the TSC Emergency Coordinator.
The EAL scheme, based on NEI 99-01 rev. 6, is not changing.
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.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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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)
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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