ML23164A026

Procedure Review Form - Emergency Coordinator (EC) Checklist

ML23164A026
Person / Time
Site:	Callaway
Issue date:	05/18/2023
From:	Fortman J Ameren Missouri
To:	Office of Nuclear Reactor Regulation
Shared Package
ML23164A024	List: ML23164A025 ML23164A026
References
EIP-ZZ-00240 Add A, Rev. 0008
Download: ML23164A026 (1)

Text

PROCEDURE REVIEW FORM (PRF) 1.0 Initiation Initiator: Joseph Fortman Date: 05/1 8/2023 Procedure Dept:

EP Document #: EIP-ZZ-00240 Addendum A New Rev. #

008

ügt requued}

Title:

Emergency Coordinator (EC) Checklist Level of Use:

UContinuous IlReference Information MultipIe EN/A 2.0 Reason for Change/Description of Change (List commitments, CRs, eB Change Requests, OliRs, P/ant Afods etc and record numbers here.)

CR 202302005 Added set in procedure to review plant events that led to prior EAL call and added reminder that if a declaration is missed or misclassified then there is a potential I hour report the NRC.

====

==

Continuefl 3.0.

Document Disposition Temp Change EJNew Document LiMajor Revision Minor Revision

üCancellation Administrative Correction Dept. Head or Designated jpovcr required for Administrative Corrections(Sinature/PTN/Date) no other signatures required 4.0 Interim Approval (Temp. Change Only)

Temp. Change #:

Expiration Date:

Cognizant Supervisor (Signature/PIN/Date)

SRO (Signature/PIN/Date)

5.0 Comments

Continued: i:

6.0 Reviews and Signatures (NOT required/or Athninit?Lrtive Corrections)

RLwL%t?qt1zred thpi I

PIN mu;e Date CAOI39Attached Preparer EP 14588 05/18/2023 N/A 1 &chnical Review EP I 4588 05/1 8/2023 D Yes No Tcthrncal Review f 7C&

O/3,tQ2 E Yes No Addl Review Yes L1 No Ald1 Review E1 Yes No ElAdditionaiReviews (See Attached CAQI39forms).

Number ofadditional CAO139s:

_pe Coordttitttor PIN Signature Date CA0139 4ttached EjValidation LI Yes No 5O59 Review CA25 10 ECA25 1 1 LCA25 12 / uN/A (peiAPA-/Z-00143)

Screener Inittal, PIN Reviewer Initial / PIN (Dept. Head or Designated Approver) Is a Change Management Plan required?

EYes No (If YES, attach CA2773 or CA2774)

Is a Cross-Disciplinary review required?

LlYes No 7.0 Approval (Either aJ)provat must be qualified as PAT44PVR or PA JYGAPR in QualAiaste;)

Senior Director Nuclear Operations Approval (per APA-ZZ-OOlt)t)

ORC is required in accordance with APA-ZZ-00091 DLII tttfllLflt I [C 1(1 Final Review and Approval ORt Meeting j -

p I

q

(

I q L Dept 1k id or Designated Apo u Sernoi Dtiector Nulcit t)pLritlons (Signature/PIN/I)ate)

(Signature/PIN/Date)

Note: Page 2 jioviiJes iflStflICtiC)flS to com;/ete thiSJOIflI and may be disanIecI A19t)OOt)1 2

5 35 A2100062 65 69 M1900001 Page 1 ot2 CA0033 APA-ZZ-t)t)lt)I Rev. 002

APPLICABILITY DETERMINATION Address the questions below for all aspects of the activity. If the answer is YES for any portion of the activity, apply the identified procedures to that portion of the activity. Note that it is not unusual to have more than one process apply to a given activity. Refer to Section 4 of the 10 CFR 50.59 Resource Manual (RM) and the instructions on pages 5-6 for additional guidance.

Activity/Document Number: EIP-ZZ-00240 Addendum A Revision Number:_Q8

Title:

EmerencyCoordinator(EC) Checklist Brief Description of activity (what is being changed and why):

h3 Initiation section, added new step 1) under SM Briefing to Discuss plant conditions that led to current EAL dccbtations.

,ln Operations section, added new step 6 to inform the EC Ifreview ofEALs identifies an EAL declaration was mssed or was miss-classified, a potential 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> report to the NRC may exist. Review EIP-ZZ-OO1O1 Note prior to scctkn 5.5 for details.

IfYES, no further 50.59 (or 72.48) review beyond this Applicability Determination (AD) is required, but

Response

complete the remainder of this form.

, Identify the applicable 5059172.48 NO J YES Evaluation Log No., License Amendment No., or applicable document number.

Document #

NO YES IfYES, process per APA-ZZ-OO 108 and fDP-ZZ-001 03.

IfYES, process per APA-ZZ-00 108 rc NO YES and GDP-ZZ-00600 and related y

facility or procedure change programs.

If YES, process per APA-ZZ-O0 108 El YES and SDP-ZZ-00030 for Security

)

Plan and related facility or procedure change programs.

IfYES process per APA-ZZ-00 108 Note: If your proposed change alters a RERP implementing procedure [any EIP-ZZ-XXXX equipment fl NO YES and KDP-ZZ-00400 for RERP and related facility or procedure change identified as important to emergency response [refer to programs.

KDP-ZZ-00013], or could alter response time, staffing, or other items covered in the I 6 Planning Standards or in Appendix E to Part 50.47(b) [refer to KDP-ZZ-00400],

answer this qttestion YES.

APA-ZZ-OO 143 A170.OO1O 11.

Does the proposed activity fall within the scope ofan activity that has been previously approved by the NRC or for which a 50.59/72.48 Screen or evaluation has already been performed?

(See Section 4.2 ofthe RM.)

III.

Does the proposed activity involve a change to the:

Response

I.

Technical Specifications or the Renewed Operating License?

Sce 10 CFR 50.90.)

2.

Quality Assurance Plan? (See 10 CFR 50.54(a).)

See Scction4.2.l ofthe RM.

3.

Security Plan which also includes the Cyber Security Plan?

NO (See 10 CFR 50.54(p).

4.

Radiological EmergencyResponse Plan (RERP) or Emergency Action Levels tEALS)? (See 10 CFR 50.54(q).)

Page 1 CA2510 Rev. 005

APPUCABLLIfl DETERMENATION (Continued)

IfYBS, process APA-ZZ-00356 for ASh code compliance and related facility or procedure change pmgrama.

5. 1ST Program Plan? (See 10 CFR 50.55a(O.)

7. Fire Protection Pmgram? (See Operating License Condition 2.C(5).)

ØN0 QYEs 8.

Storage Cask Certificate ofCompliance (CoC), including appendices? (See 10 CFR 72.244.)

0 No 9.

Does the proposed activity impact other programs (e.g.,

the ODCM) that are conniled by reguIalions the Openthg License (including Orders and License Conditions) or thc Technical Specifications? (See ectio IáI NO 42.1 ofthe RM.)

w. Does the proposed activity involve:

1. Maintenance which restores SSCs to their original (as designed) condition? (See 10 CW 50.65(a)(4).)

Note: lfthe maintenance is on ISFSI or cask-related items, NO the Maintenance Rule does NOT apply, and the activity is subject to a 10 CFR 72.48 Screen on a CM 145.

2. A temponq alteration (to procedures or the facility) supporting maintenance (FASM) that will be in effect during at-power operations for 90 days or less?

1See 1? Screening questions in EDP ZZ-04044. Ifany ofthe screening ci ns queslions are answered YES, a Fire 3Pmtecdon review is needed in jsccce iwithjP-ZZ-O4O44.

.11 YES, then contact Regidatciy ci YES Affairs/Licensing to determine nut i-ct IfYBS, indicate the applicable D YS program in BdefDescdpfion Section.

IfYBS, process per APA-ZZ-OO1O1 for procedure changes or APA-ZZ-00605 for facility changes 0 NO Q ns or PO12Lluflh13P Controlled Temporaiy Modifications or MDP-ZZ-FSOOl for Freeze Seals.

Evaluate fisk using APA-ZZ-00315, Appendix A.

APA-ZZ-00143 A170.OO1O CA2510 Rev. 005

6. 151 Program Plan? (See 10 CFR 50.55a&J.)

1 -n IfYES, process perEDP-ZZA1003 for ASME code compliance and related facility or procedure change programs.

ØN0 DYES

Response

Sea Section 4.22 ofthe KM IfYES, process change per D YES AP4ZZ4O1O1 frprocedure changes or APA-ZZ-00320/330/340 for Maintenance activities.

Page 2

APPLICABILITY DETERMINATION (Continued)

V.

Does the propt)setI activHy involve a change to the:

1.

fSAR NO DYES Ifthe above response is NO, check N/A in the Response colunrn at right.

Note: in lieu ofthe exclusion criteria ofRM Section 4.2.3, a YES response may also be provided ifthe fSAR change requires no further 50.59 review based on a YES response to the question in Section II ofthis Applicability Determination form.)

2.

Technical Specification Bases?

NO YES Ifthe above response is NO, check N/A in the Response column at right.

Ifthe above response is YES, does the proposed activity involve a TS Bases change comparable to that which may be excluded from the requirement to perform a 5059 Screen/Evaluation by NEI 9607 or NEI 9803 (as described for an fSAR change)? (Provide a YES or NO rcsponse to this question in the Response column at right.)

Note: In lieu ofthe exclusion criteria oCRM Section 4.2.3. a YES response may also be provided lfthe TS Bases change requires no further 50.59 review based on a YES response to the question in Section II ofthis Applicability Detennination form.)

VI.

Does the pwposed activity involve a change to:

I Managerial or administrative procedures, controls, or activities (including software used only for the implementation of administrative procedures, controls, or activities) governing the conduct of facility operations (sublect to the control of YOCFR5O, Appendix B)?

2.

Regulatory commitment not covered by another regulation based change process? (Sec NEI 99-04.)

APA-ZZ-OO 143 A170.OO1O

Response

See Section 4.2.3 ofthe RM Process the FSAR change per APA-ZZ-00108 and FDP-ZZ-00103 for revising License Documents.

Note:

A NO response in the Response column at left means that the FSARJTS Bases change is one that requires ftirther 50.59 review (i.e., is not excludable from further review).

A YES response means that the FSAR does NOT require further 50.59 review.

Process the TS Bases change per APA-ZZ-00108 and FDP-ZZ-00 103 for revising License Documents.

Note:

A NO response in the Response column at left means that the TS El NO El YES Bases change is one that requires further 50.59 review (i.e., is not N/A excludable from further review).

A YES response means that the TS Bases Change does NOT require further 50.59 review.

NO El YES IfYES, process per APA-ZZ-00 101 or APA-ZZ-00 109.

M NO 0 YES IfYES, process per v-APA-ZZ-00540.

IfYES, perform a 72.4$ Screen per APA-ZZ-00143 unless the change is completely covered by the response to Section II.

Note:

Editorial or administrative changes are excluded from the requirement to petloim a 72.48 Review.

Ifthe above response is YES, does the proposed activity involve an fSAR change that may be excluded from the D NO D YES requirement to perform a 50.59 Screen/Evaluation by NEI 9607 or NEI 9803? (Provide a YES or NO response to N/A this question in the Response column at right.)

Response

See Section 4.2.4 / 4.2.6 ofthe RM.

VII Does the proposed activity potentially affect the design,

. operation, or maintenance ofthe ISFSI facility as described in the dry cask storage fSAR or the 72.212 Report? (See FDP ZZ-00105 and Attachment 1 ofAPA-ZZ-00l43.)

NO DYES Page 3 CA2510 Rev. 005

APPLICABILITY DETERMINATION (Continued)

VIII. Justification/explanation for Response(s) (as needed):

The revision to EIP-ZZ-00240 ADD A includes changes that oniy improve the EC checklist to support EC implementation oftheir ERO position. This activity has no impact toüsystems, structures or component functions. Therefore, this activity is controlled under 1 OCFR5O.54(q) in its entirety as a Change to the RERP or Implementing Procedure and

, therefore 10CFR5O.59 does not apply.

Ix.

Conclusion:

iIpc: ofthc activity controlled by one or more ofthe procedures above, therefore a 50.59 Screen reqtiired.

D A portion of the activity isnot controlled by one or more ofthe procedures above, therefore a 50.59 Screen is required.

x. Signoffs:

Qtiililred PrLprLi Jtcph Fortman

/>1?

I) it.

Y / )3 I Pu name)

I n1?E1 PIN Qu flitid Rc ft Ei (Print nan 6 (Sign/PIN),,Q7tç/

Ensure that once signed, this record is loaded into EB with the Activity/Document Number listed above or submit this form to either the Regulatory Affairs clerk or another member of Administration in accordance with APA-ZZ-00220.

APA-ZZ-00143 Page 4 CA2510 A170.OO1O Rev. 005

50.54(q) Screening Form Document #, Rev #, &

Title:

EIP-ZZ-00240 Addendum A Revision 008, Emergency_Coordinator (EC) Checklist EP Tracking #:

2023021 Activity Description and

References:

CR202302005 Page 5 - Initiation, Step 4.b.1 Added new Step 1 to 4.b

1) Discuss plant conditions that led to current EAL dectarations a

Reason for change to ensure EC fully understand issue and has opportunity to provide additional chec on validity for prior EALs.

Page 7

- Operations, Step 6 Added new Step 6

- If review of EALs identifies an EAL declaration was missed or was miss-classified, a potential I hour report to the NRC may exist. Review EIP-ZZ-00101 Note prior to section 5.5 for details.

0 Provides reminder for EC that potential NRC notifications could occur if errors are identified.

Activity Scope:

YES NO Does this atity revise the Rtdio1oi. ii Plan (RI RP) or lmp1uminting Proedures7 11 LI ChangeType:

YES NO Is this iul\\ t\\ editorial or tpoj ii LI Xl Previously Approved Change:

YES NO is this activity being processed to conform to a previously approved activity LI Xl if YtiS, what is the previously approved activity?

Planning Standard Determination:

Does this activity impact any ofthc 50.47(5) Planning Standards or Part 50 Appendix E:

YLX NO 50.47(b)(1)

- Assignment ofResponsibility (Organization Control)7 LI 50.47(b)(2)

- Onsite Emergency Organization7 H

50.47(b)(3) - Emergency Response Support and Resources?

LI 50.47(b)(4)

- Emergency Classification System7 U

50.47(b)(5) - Notification Methods and Procedures?

U FXl 50.47(b)(6) - Emergency Communications?

U 50.47(b)(7)

- Public Education and Information?

U 50.47(b)(8) - Emergency Facility and Equipment?

U XJ 50.47(b)(9)

- Accident Assessment?

C]

1Xl 50.47(b)(1O)

- Protective Response9

.,.,., H 50.47(b)(ll)

- Radiological Exposure Control?

.,.,, U 50.47(b)(12) - Medical and Public Health Support?

Li 50.47(b)(13)

- Recovery Planning and Post Accident Operations?

,., LI 1

50.47(b)(14)

- Drills and Exercises?

H Xl 50.47(b)(15) - Emergency Responder Training?

LI tXl 50.47(b)(16)

- Emergency Plan Maintenance9 Li IX]

- - Part 50 /PPCdiX F?

=

L

[Xl Commitment Impact Determination:

YES NO Does this activity impact a Site Specific EP Commitment not associated with a Planning Standard or Element7 LI IfYes. record the Commitment number:

Explanation of Determination: (Enter an explanation to each determination-answer that needs clar(ficcttion.)

This change is associated with Planning Standards 50.47(b)(4) Emergency Classification and 50.47(b)f6) Emergency Communication. However, the clarification around the Shift Manager briefing on plant events and the reminder of a potential I hour notification to the NRC has no impact on the EROs ability to implement the regulatory requirements of those planning standards. A 50.54(q) evaluation is not required.

File#A210.0038 Page 1 of2 CA1523 KDP-ZZ-00400 Rev. 002

50.54(q) Screening Form Screening Evaluation Results:

Based on the results of the information above, can the activity be implemented without performing a YES NO

_L5o.54(&) Effectiveness Evaluation?,,

• .. J LI Review/Approval:

Preparer (Sign/PIN)......

Reviewer (Sign/PIN):

Emergency Preparedness File # A210.0038 KDP-ZZ-00400 Page 2 of 2 CA1523 Rev. 002