ML19248C319

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Screening Evaluation Form for Emergency Plan 19-1 Section D, 50.54 Screen
ML19248C319
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 08/20/2019
From:
Duke Energy Carolinas
To:
Office of Nuclear Reactor Regulation
Shared Package
ML19248C291 List:
References
RA-18-0325
Download: ML19248C319 (22)


Text

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

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<< 10 CFR 50.54(q) Screening 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 Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

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 Area Emergency:

Alert:

Any loss or any potential loss of either Fuel Clad or NCS barrier Site Area Emergency:

Added carriage return between barrier and Site. Editorial 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 The MNS EAL categories are aligned Added space between 99- 01 and

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to and represent the NEI 99- 01Recognition Categories.

to and represent the NEI 99- 01 Recognition Categories.

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 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.

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 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 Removed EOF Director as he/she no longer has responsibility for classification.

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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.

will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.

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 Emergency Coordinator/EOF Director completing the review and steps necessary to make the emergency declaration.

The provision discussed above addresses only those 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.

Removed EOF Director as he/she no longer has 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, Overpressurization Over pressurization Added space between over and

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Explosion, 1st sentence; CA6.1, Definitions, Explosion, 1st sentence; SA9.1, Definitions, Explosion, 1st sentence; 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.

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

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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 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 and removed 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

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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 trip and the RTS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.

If the signal causes a plant transient that should have included an automatic reactor trip and the RTS 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 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 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 Added space between back and panels. Editorial

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console.

console.

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 reactor power is greater than 5% power (ref. 1, 4).

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 reactor power is greater than 5% power (ref. 1, 4).

Removed extra spaces between designed and to and a and normal.

Editorial 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

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

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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.

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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.

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, Other conditions exist which, in the judgment of the Emergency Coordinator, indicate that events are Removed EOF Director as he/she no longer has responsibility for classification.

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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.

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.

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 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 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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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.

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 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 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 Removed EOF Director as he/she no longer has responsibility for classification

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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.

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.

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 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 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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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.

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 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 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 Removed EOF Director as he/she no longer has responsibility for classification. Added period at end of EAL

- editorial.

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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 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.

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 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 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).

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.

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 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 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

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imminent.

51 Section D Attachment 1, EAL Bases, EAL:

HU7.1, HA7.1, HS7.1, HG7.1 - Basis second sentence 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 The Shift Manager(SM) initially acts in the capacity of the Emergency Coordinator and takes actions as outlined in the Emergency Plan implementing procedures Deleted Operations 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. Activity Previously Reviewed?

Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design Report?

If yes, identify bounding source document number or approval reference and ensure the basis for concluding the source document fully bounds the proposed change is documented below:

Justification:

Yes No 10 CFR 50.54(q)

Effectiveness Evaluation is not required. Enter justification below and complete,

Part V.

Continue to,

10 CFR 50.54(q)

Screening Evaluation Form, Part III Bounding document attached (optional)

Part III. Editorial Change Is this activity an editorial or typographical change only, such as formatting, paragraph numbering, spelling, or punctuation that does not change intent?

Justification:

The following changes are Editorial Changes per AD-EP-ALL-0602 and will NOT be evaluated further:

1, 3 through 8, 14 through 16, 18, 20 through 22, 24 through 34, 36, 47 (period added at end of EAL), 51, 54, and 56 through 58.

Yes No or Partially 10 CFR 50.54(q)

Effectiveness Evaluation is not required. Enter justification and complete,

Part V.

Continue to,

Part IV and address non editorial changes Part IV. Emergency Planning Element and Function Screen (Reference Attachment 1, Considerations for Addressing Screening Criteria)

Does this activity involve any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If answer is yes, then check box.

1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.

1b The response organization has the staff to respond and to augment staff on a continuing basis (24-7 staffing) in accordance with the emergency plan.

2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that onshift emergency response responsibilities are staffed and assigned 2b The process for timely augmentation of onshift staff is established and maintained.

3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.

3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.

(NA for CR3)

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4 10 CFR 50.47(b)(4) Emergency Classification System 4a A standard scheme of emergency classification and action levels is in use.

(Requires final approval of Screen and Evaluation by EP CFAM.)

5 10 CFR 50.47(b)(5) Notification Methods and Procedures 5a Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.

5b Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway. (NA for CR3) 5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. (NA for CR3)

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Part IV. Emergency Planning Element and Function Screen (cont.)

6 10 CFR 50.47(b)(6) Emergency Communications 6a Systems are established for prompt communication among principal emergency response organizations.

6b Systems are established for prompt communication to emergency response personnel.

7 10 CFR 50.47(b)(7) Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established.

8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response.

8b Adequate equipment is maintained to support emergency response.

9 10 CFR 50.47(b)(9) Accident Assessment 9a Methods, systems, and equipment for assessment of radioactive releases are in use.

10 10 CFR 50.47(b)(10) Protective Response 10a A range of public PARs is available for implementation during emergencies. (NA for CR3) 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities. (NA for CR3) 10c A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.

10d KI is available for implementation as a protective action recommendation in those jurisdictions that chose to provide KI to the public.

11 10 CFR 50.47(b)(11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.

12 10 CFR 50.47(b)(12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.

13 10 CFR 50.47(b)(13) Recovery Planning and Post-accident Operations 13a Plans for recovery and reentry are developed.

14 10 CFR 50.47(b)(14) Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program areas) is established.

14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.

14c Identified weaknesses are corrected.

15 10 CFR 50.47(b)(15) Emergency Response Training 15a Training is provided to emergency responders.

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Part IV. Emergency Planning Element and Function Screen (cont.)

16 10 CFR 50.47(b)(16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.

16b Planners responsible for emergency plan development and maintenance are properly trained.

PART IV. Conclusion If no Part IV criteria are checked, then provide Justification and complete Part V below.

Justification:

The proposed changes below are considered changes that are more than editorial but do NOT impact an Emergency Planning Standard and need NOT be evaluated further:

Change 19 - Added Definition(s): None. Added text to be consistent with other EALs.

The following Changes are to be evaluated:

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 Added clarifying statement to SU5.1 Bases - Change 23 If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete, 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q)

Effectiveness Evaluation. Program Element 4a requires final approval of Screen and Evaluation by EP CFAM.

Part V. Signatures:

EP CFAM Final Approval is required for changes affecting Program Element 4a. If CFAM approval is NOT required, then mark the EP 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

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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