ML19248C316
| ML19248C316 | |
| 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: ML19248C316 (21) | |
Text
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 5 ATTACHMENT 6 Page 1 of 21
<< 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form >>
Screening or Evaluation Number: MNS Emergency Plan Section D - EAL Bases - Revision 19-1 Part I. Identification of ICs and EALs Affected by Proposed Change and the applicable NEI Generic ICs and EALs:
Document and Revision - Emergency Plan Section D 19-01 (EREG 02279019.
Change bases are -
Change s1, 3 through 8, 14 through 16, 18, 20 through 22, 24 through 34, 36, 47 (period added at end of EAL), 54, and 56 through 58 -
o Editorial changes correcting typos and formatting throughout.
Change 51 -
o Deleted Operations before Shift Manager to reflect correct position title in Section D Attachment 1, EAL Bases, EAL: HU7.1, HA7.1, HS7.1, HG7.1 - Basis second sentence. Editorial.
Changes 2, 9 through 13, 17, 35, 37 through 46, 47 (non-editorial), 48 through 50, 52, 53 and 55 -
o 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. Changes 39, 42 and 45 also pluralized Emergency Coordinator for grammatical correctness.
Change 23 -
o 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.
Change Plan Section Current Revision Proposed Revision Reason 1
Section D Table of Contents Rev 18-3 Table of Contents Rev 19-1 Update page numbers for Rev 19-
- 1. Editorial 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.
3 Section D Section 2.3 Alert:
Any loss or any potential loss of either Fuel Clad or NCS barrier Site Alert:
Any loss or any potential loss of either Fuel Clad or NCS barrier Added carriage return between barrier and Site. Editorial
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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<< 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form >>
Area Emergency:
Site Area Emergency:
4 Section D Section 2.4 EALs applicable under all_ plant operating modes -
EALs applicable under all plant operating modes -
Removed underline after all and before plant. Editorial 5
Section D Section 2.4 EALs applicable only under hot operating modes -
EALs applicable only under hot operating modes -
Removed underline after hot and before operating. Editorial 6
Section D Section 2.4 EALs applicable only under cold operating modes -
EALs applicable only under cold operating modes -
Removed underline after cold and before operating. Editorial 7
Section D Section 2.4 The MNS EAL categories are aligned to and represent the NEI 99- 01Recognition Categories.
The MNS EAL categories are aligned to and represent the NEI 99- 01 Recognition Categories.
Added space between 99- 01 and Recognition.
Editorial 8
Section D Section 3.2.7, 1st paragraph, 2nd sentence This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event orcondition no longer exists at the time of discovery This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery Added space between or and condition. Editorial 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 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 Removed EOF Director as he/she no longer has responsibility for classification.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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<< 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form >>
exceed, the applicable time.
exceed, the applicable time.
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 The provision discussed above addresses only those Removed EOF Director as he/she no longer has
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 5 ATTACHMENT 6 Page 4 of 21
<< 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form >>
rapidly evolving situations when an operator is able to take a successful corrective action prior to the Emergency Coordinator/EOF Director completing the review and steps necessary to make the emergency declaration.
rapidly evolving situations when an operator is able to take a successful corrective action prior to the Emergency Coordinator completing the review and steps necessary to make the emergency declaration.
responsibility for classification.
14 Section D Section 5.2 Abbreviations
/Acronyms NA NA Removed and added spaces/periods for alignment. Editorial 15 Section D Section 6.0 Table NA NA Centered text in columns. Editorial 16 Section D -
5.1 Definitions, Explosion, 1st sentence; CA6.1, Definitions, Explosion, 1st sentence; SA9.1, Definitions, Explosion, 1st sentence; Overpressurization Over pressurization Added space between over and pressurization.
Editorial 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.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 5 ATTACHMENT 6 Page 5 of 21
<< 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form >>
18 Section D Attachment 1, EAL Bases, CA1.1, 1st paragraph of Basis, 5.1 in. above hotleg centerline (reounded to 5 in.) NCS level indication is the lowest level to assure adequate net positive suction head and prevent ND pump cavitation and air entrainment for all flow rates (ref. 1).
5.1 in. above hotleg centerline (rounded to 5 in.) NCS level indication is the lowest level to assure adequate net positive suction head and prevent ND pump cavitation and air entrainment for all flow rates (ref. 1).
Corrected spelling of rounded. Editorial 19 Section D Attachment 1, EAL Bases, CA2.1 NA Definition(s):
None Added text to be consistent with other EALs.
20 Section D Attachment 1, EAL Bases, CG1.1, 14th paragraph of Basis, last sentence Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from theNCS.
Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the NCS.
Added space between the and NCS. Editorial 21 Section D Attachment 1, EAL Bases, CU3.1, 3rd paragraph of Basis This IC addresses an UNPLANNED increase in NCS temperature above the Technical Specification cold shutdown temperature limitand represents a potential degradation of the level of safety of the plant.
This IC addresses an UNPLANNED increase in NCS temperature above the Technical Specification cold shutdown temperature limit and represents a potential degradation of the level of safety of the plant.
Added space between limit and and. Editorial 22 Section D Attachment 1, EAL Bases, SU1.1 Definition(s):
None Basis:
Basis:
Definition(s):
None Basis:
Removed extra Basis: Editorial 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.
24 Section D Attachment 1, EAL Bases, SU6.1 Mode Applicability: 1 1-Power Operations Mode Applicability:
1-Power Operations Removed extra 1 Editorial 25 Section D Attachment 1, EAL Bases, SU6.1, 8th paragraph of Bases Following the failure on an automatic reactor trip, operators will Following the failure on an automatic reactor trip, operators will Added space between shut and down and removed
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor trip ).
promptly initiate manual actions at the reactor control consoles to shut down the reactor (e.g.,
initiate a manual reactor trip).
space between trip and ). Editorial 26 Section D Attachment 1, EAL Bases, SU6.1, 9th paragraph of Bases If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor trip using a different switch).
If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shut down the reactor (e.g., initiate a manual reactor trip using a different switch).
Added space between shut and down. Editorial 27 Section D Attachment 1, EAL Bases, SU6.1, Last paragraph of Bases, 2nd bullet and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.
and the RPS fails to automatically shut down the reactor, then this IC and the EALs are applicable, and should be evaluated.
Added space between shut and down. Editorial 28 Section D Attachment 1, EAL Bases, SU6.2, 6th paragraph of Bases Following the failure on an automatic reactor trip, operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor trip).
Following the failure on an automatic reactor trip, operators will promptly initiate manual actions at the reactor control consoles to shut down the reactor (e.g.,
initiate a manual reactor trip).
Added space between shut and down. Editorial 29 Section D Attachment 1, EAL Bases, SU6.2, 6th paragraph of Bases If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor trip using a different switch).
If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shut down the reactor (e.g., initiate a manual reactor trip using a different switch).
Added space between shut and down. Editorial 30 Section D Attachment 1, EAL Bases, SU6.1, Last paragraph of Bases, 1st bullet If the signal causes a plant transient that should have included an automatic reactor If the signal causes a plant transient that should have included an automatic reactor Added space between shut and down. Editorial
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<< 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form >>
trip and the RTS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.
trip and the RTS fails to automatically shut down the reactor, then this IC and the EALs are applicable, and should be evaluated.
31 Section D Attachment 1, EAL Bases, SA6.1, 5th paragraph of Bases This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor control consoles to shutdown the reactor are also unsuccessful.
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor control consoles to shut down the reactor are also unsuccessful.
Added space between shut and down. Editorial 32 Section D Attachment 1, EAL Bases, SA6.1, 6th paragraph of Bases, last sentience Actions taken at backpanels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control console.
Actions taken at back panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control console.
Added space between back and panels. Editorial 33 Section D Attachment 1, EAL Bases, SS6.1, 7th paragraph of Bases 5% rated power is a minimum reading on the power range scale that indicates continued power production. It also approximates the decay heat which the shutdown systems were designed to remove and is indicative of a condition requiring immediate response to prevent subsequent core damage. Below 5%,
plant response will be similar to that observed during a normal shutdown. Nuclear instrumentation can be used to determine if 5% rated power is a minimum reading on the power range scale that indicates continued power production. It also approximates the decay heat which the shutdown systems were designed to remove and is indicative of a condition requiring immediate response to prevent subsequent core damage. Below 5%,
plant response will be similar to that observed during a normal shutdown. Nuclear instrumentation can be used to determine if Removed extra spaces between designed and to and a and normal.
Editorial
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reactor power is greater than 5% power (ref. 1, 4).
reactor power is greater than 5% power (ref. 1, 4).
34 Section D Attachment 1, EAL Bases, SS6.1, 10th paragraph of Bases The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.
The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shut down the reactor.
Added space between shut and down. Editorial 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.
36 Section D Attachment 1 EAL Bases, HU1.1, 5th paragraph of Basis This threshold references the Security Shift Supervison because these are the individuals trained to confirm that a security event is occurring or has occurred.
This threshold references the Security Shift Supervision because these are the individuals trained to confirm that a security event is occurring or has occurred.
Corrected spelling of Supervision.
Editorial 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 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 Removed EOF Director as he/she no longer has responsibility for classification
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<< 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form >>
protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of SAFETY SYSTEMS occurs.
initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of SAFETY SYSTEMS occurs.
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 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 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 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 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.
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<< 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form >>
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.
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.
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 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 Removed EOF Director as he/she no longer has responsibility for classification.
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<< 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form >>
to be limited to small fractions of the EPA Protective Action Guideline exposure levels.
to small fractions of the EPA Protective Action Guideline exposure levels.
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 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 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 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 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.
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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.
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 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 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 Removed EOF Director as he/she no longer has responsibility for classification
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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.
public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the SITE BOUNDARY.
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 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 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 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 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.
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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.
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 General Emergency 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 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 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 Removed EOF Director as he/she no longer has responsibility for classification. Added period at end of EAL
- editorial.
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EPA Protective Action Guideline exposure levels offsite for more than the immediate site area Guideline exposure levels offsite for more than the immediate site area.
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 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 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 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 Removed EOF Director as he/she no longer has responsibility for classification
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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.
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 Director would have more assurance that there was no immediate need to escalate to a General Emergency.
Alternatively, if both the Fuel Clad and NCS fission product barriers were potentially lost, the Emergency Coordinator would have more assurance that there was no immediate need to escalate to a General Emergency.
Removed EOF Director as he/she no longer has responsibility for classification 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 51 Section D Attachment The Operations Shift The Shift Manager(SM)
Deleted Operations
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1, EAL Bases, EAL:
HU7.1, HA7.1, HS7.1, HG7.1 - Basis second sentence Manager (SM) initially acts in the capacity of the Emergency Coordinator and takes actions as outlined in the Emergency Plan implementing procedures initially acts in the capacity of the Emergency Coordinator and takes actions as outlined in the Emergency Plan implementing procedures before Shift Manager to reflect correct position title.
Editorial 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; Barrier: Containment, Category: F.
Emergency Coordinator Judgment, Degradation Threat:
Loss, Threshold: 1; Emergency Coordinator/EOF Director Emergency Coordinator Removed EOF Director as he/she no longer has responsibility for classification
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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 54 Section D Attachment 2 Fission Product Barrier Loss/Potential Loss Matrix and Bases Table NA NA Added bottom border to table. Editorial 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 57 Section D Throughout NA NA Added/removed spaces and carriage returns and corrected capitalization and indentions. Editorial 58 Section D Footer - Rev. 18-1 January, 2018 Footer - Rev. 19-1 July, 2019 Editorial
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Part II. Determination of Validation Method by Site EP Manager:
In-Plant Walkdown Tabletop Training Other (Specify) __Read and Review____________
Simulator NA EP Manager Name (Print):
David Thompson EP Manager Signature: See CAS Date: See CAS Part Ill. Validation. (Answers marked No require resolution)
Validation Question Yes No NA Resolution and Comments Readouts, alarms, indications. etc., available in the Control Room?
Monitor, gauge, etc., designations are correct?
Are correct units of measure displayed on the monitor, gauge, etc.?
All values are within instrumentation display range?
Is instrument display finite enough to distinguish between values?
No miscellaneous issues were identified during walkdown correct?
Part IV. Verification (Answers marked No require resolution)
Validation Question Yes No NA Resolution and Comments Is the IC/EAL change easy to use and does it flow well? Is sequencing logical and correct?
Is it written to appropriate level of detail and unambiguous?
Is the IC/EAL Matrix legible and easy to use?
Are correct units of measure displayed on the monitor, gauge, etc.?
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Part IV. Verification (cont.) (No answers require resolution))
Validation Question Yes No NA Resolution and Comments Instrumentation; Plant Computer System (PCS); and/or Plant Process Computer System (PPCS) points specified?
Correct instrument?
Correct units Adequate instrument range?
Display unit readable?
Proper significant digits?
Instrument number and noun name provided?
Consistent with operations procedures?
References specified in EAL Technical Basis current and updated and source documents for inputs have been identified and verified to be appropriate for use?
Does the change avoid human performance challenges, latent weaknesses, and human performance traps?
No vague or missing critical detail(s).
Decisions are not over-reliant on knowledge for successful performance Modifications, Emergency Plan, EAL Technical Basis, reference manual and procedure revisions, setpoint changes, software changes, training, etc. are appropriately scheduled to correspond to the EAL revision?
Are alarm setpoints equal to or below EAL thresholds?
Do radiation monitor setpoints account for background?
Part V. Comments:
If an EAL change requires a License Amendment Request, then document the gap analysis review of the site specific EAL versus NEI generic guidance in this section.
Not required.
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Part VI. Completion Review and Approval Signatures Validation and Verification (Print Names) [Note1]:
Scott Fortin (Fleet Ops CFAM Organization and previous MNS Senior License Holder)
Validation and Verification Signatures: See CAS Date: See CAS Site EP Manager Review (Print Name):
David Thompson EP Manager Signature: See CAS Date: See CAS Senior Operations License Holder (Print Name):
Ryan Severns Senior Operations License Holder Signature:
See CAS Date: See CAS Qualified Emergency Coordinator (Print Name):
Pete Schuerger Qualified Emergency Coordinator Signature:
See CAS Date: See CAS Engineering Review (Print Name) [Note2]:
Not required per David Thompson as no EAL initiating conditions changing Engineering Signature: N/A Date: N/A PSA Review (Print Name) [Note3]:
Not required per David Thompson as no EAL initiating conditions changing PSA Signature: N/A Date: N/A Radiation Protection Review [Note 4]:
Not required per David Thompson as no EAL initiating conditions changing Radiation Protection Signature: N/A Date: N/A EP CFAM Review (Print Name):
David Thompson EP CFAM Signature: See CAS Date: See CAS Notes:
- 1. Validation and Verification can be performed by the same individual but must be:
Qualified in the subject matter Separate from the author of change A cross-discipline reviewer
- 2. System specific Engineering Review is required for EAL changes related to process equipment such as radiological instruments and environmental monitoring.
- 3. PSA review is required for EAL changes to ensure any potential or actual impact to PSA calculations or assumptions are adequately addressed (not applicable to CR3).
- 4. Radiation Protection is required for radiological EAL changes.
QA RECORD