ML23227A139

EIP-ZZ-A0001, Rev 23, Emergency Response Organization

ML23227A139
Person / Time
Site:	Callaway
Issue date:	06/09/2023
From:	Bassford J - No Known Affiliation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EIP-ZZ-A0001, Rev 23
Download: ML23227A139 (1)

Text

PROCEDURE REVIEW FORM (PRF) 1.0 Initiation Initiator: JpPnpassfprd 06-09-23 Procedure Dept EP Document #: EIP-ZZ-A0001 New Rev. #

023 (3diitsrequüd)

Title:

Emergency Response Organization Level ofUse:

Continuous Reference Information EMultiple flN/A 2.0 Reason for ChangelDescription of Change (List commitments, CRs, eB Change Requests, OERs, Plant Mods etc. and record numbers here.)

See Summary of Changes document for EIP-ZZ-A0001, Rev. 023 CR 202303801-003 3.0.

Document Disposition flTemp Change New Document LlMajor Revision Minor Revision IEjCance1lation UAdminisfrative Correction

.-,p.c.fl Heador Pgnated Aprover required for Administrative Corrections (Sinamre1Nate)no other signaturesrequired 4.0 Interim Approval (Temp. Chatige Only)

Temp. Change #:

Expiration Date:

N/A N/A Cogrnzarit Supervisor (Signature/PIN/Date)

SRO (Signature/PIN/Date)

5.0 Comments

Continued:fl 6.0 Reviews and Signatures (NOT requiredfor Administrative Corrections)

- Reviews Required L

Dept PIN Date CAOl39Attached 1P iC. /a-3 N/A

,J%!%aI Review 7638Q

2-Technical Review J

/s/5#t?

- 1,z F2b3 Add! Review L1 Yes No Addl Review

El Yes fl No EjAdditional Reviews (See Attached CAOl39form)

Number of additional CAO139s j

Type Coordinator - PIN Signature Date CA0139 Attached Evalidation j

Yes 50.59 Review CA251O CA25 1 1 0CA25 12

/ EN/A (perAPA-ZZ-00143)

Screener Initial/PIN Reviever Initial/FIN (Dept. Head or Designated Approver) Is a Change Management Plan required? DYes No (IF YES, attach CA2773 or CA2774)

Is a Cross-Disciplinary review required? UYes No 7.0 Approval (Either approval must be qua4fledas PAT/APVR or FAT/GAPR in QualMaster,)

Senior Director Nuclear Operations Approval (per APA-ZZ-OOlO1)

ORC is required in accordance with APA-ZZ-00091 Department dI,l) iew and Approval ORC Meeting j%

4qL tcz t%t/

L62.,

Dept. head or Designated Approver (Signature/PIN/Date) il t 3 C r i

2L

()enior Director Nuclear Operations (Signature/PIN/Date)

Note: Page 2 provides instructions to complete thisform and may be discarded A190.0001,2, 5, 35 -A210.0062, 65, 69;M190.0001 Page 1 of 2 APA-ZZ-OO 101 Continued: TEl CA0033 Rev. 002

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

Title:

, Rev. 023, Emergency Response Organization EP Tracking #:

2023025 Activity Dcscripfion and

References:

- 5.2 Changed NOTE following 5.2 to read TThe DTI is located on the EP SharePoint alongwith a link to the ERO Position Owners List as new DTI was created for ERO qualification guidance. CR 202303801-003

- 5.2.2 Deleted reference to CA2448 and added FOLLOW guidance from DTI EP Desktop Instructions

ERO Member Additions/Deletions on the EP SharePoint site as DTI has replaced the CA2448. CR 202303801 -003

- 5.2.3 Deleted step 5.2.3 ER Clerk Deleted step 5.2. :

EP Clerk Review CA2448 ERO Member Additions/Deletion& as OTI has replaced the CA2448. CR 202303801-003

- 5.2.4 Deleted 5.2.4 EP Clerk

- WHEN an assigned ERO member ceases employment at the Callaway Energy Center or no longer fills an ERO Position:

. REMOVE ERO code from the ERO database.

. REMOVE member from distribution and phone lists.

This is covered in the DTI. CR 202303801-003 6.1.4 Deleted 6.1.4 reference as CA2448, ERO Position Maintenance Form has been retired and replaced with the DII. CR 202303801-003 Activity Scope:

YES NO Doe, this a.,tiit revist the RdIn1oLil 1 muiicy RpOi1LP1an (RIRP)or tmplLmLnLmg LXI LI Change Type:

YES NO Is this activity editorial or iypographiea1i.

. LI Previously Approved Change:

YES NO Is this activity being processed to conform to a previously approved activity7

. LI I I VI S what is the p tously pp o.d ti Planning Standard Determination:

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

YES NO 50.47(b)(1)

- Assignment ofResponsibility (Organization Control)9 LI 50.47(b)(2)

- Onsite Emergency Organization

, LI 50.47(b)(3)

- Emergency Response Support and Resources?

LI 50.47(b)(4)

- Emergency Classification System7 LI 50.47(b)(5)

- Notification Methods and Procedures?

LI

]

50.47(b)(6)

- Emergency Communications?

LI 5t).47(b)(7)

- Public Education and Information?

LI 1

50.47(b)(8) -Emergency Facility and Equipment7 H

[

50.47(b)(9)

- Accident Assessment7 LI 50.47(b)(lO)

- Protective Response9 LI 50.47(b)(1 1)

- Radiological Exposure Control?

. LI 50.47(b)(12)

- Medical and Public Health Support?

. LI 50.47(b)(13)

- Recovery Planning and Post Accident Operations?

LI 50.47(b)(14) - Drills and Exercises?

LI 50.47(b)(15) - Emergency Responder Training?

L 50.47(b)(16)

- Emergency Plan Maintenance?

. [1 Part 50 Appendix F?

LI Commitment Impact Determination:

YES NO Does this activity impact a Site Specific liP Commitment not associated with a Planning Standard or Element7

. U IfYes, record the Commitment number:

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

50.54(q) Screening Form Explanation of Determination: (Enter an explanation to each determination-answer that needs clcirfication.)

No explanation needed as a full evaluation will be performed.

Screening Evaluation Results:

Based on the results of the information above, can the activity be implemented without performing a YES NO full 5054(q) Effectiveness Evaluation?

LJ Preparer(SignJPIN)*.....

Date:6L3V If )

tepat et (uii qiuthfu d I meg n Re cpnse C wmInu:1i Reviewer (SignIPIN) zj Date kwcr nntst be e ii1fiit (o),tii((}I Emercncy Preparedness Manager (SignJPIN):

J%11 File # A210.0038 Page 2 of2 CA1523 KDP-ZZ-00400 Rev. Ot)2

50.54(q) Effectiveness Evaluation form Document #, Rev #, &

Title:

, Rev 023, Emergency Response Organzafion EP Tracking #:

2023025 Activity Description and

References:

- 5.2 Changed NOTE following 5.2 to read The DTI s located on the EP SharePoint along with a link to the ERO Position Owners List as new DTI was created for ERO qualification guidance. CR 202303801-003

- 5.2.2 Deleted reference to CA2448 and added FOLLOW guidance from DTI EP Desktop Instructions

ERO Member Additions/Deletions on the EP SharePoint site as DTI has replaced the CA2448. CR 202303801 -003

- 52.3 Deleted step 5.2.3 EP Clerk Deleted step 5.2.: EP Clerk Review CA2448 ERO Member Additions/Deletions as DTI has replaced the CA2448. CR 202303801-003

- 5.2.4 Deleted 52.4 EP Clerk

- WHEN an assignedERO member ceases employment at the Callaway Energy Center or no longer fills an ERO Position:

I REMOVE ERO code from the ERO database.

I REMOVE memberfrom distribution and phone lists.

This is covered in the DII. CR 202303801-003 6.1.4 Deleted 6.1.4 reference as CA2448, ERO Position Maintenance Form has been retired and replaced with the DTI CR 202303801-003 Activity Type:

YES NO Does this activity revise the Radiological Emergency Response Plan (RERP) or Implementing Procedures7 1

U ths activity impact implementation of the RERP, but does NOTrevise the RERP or Implementing Procedures?

.. U Impact and Licensing Basis Determination:

(List offitnctions, elements and/or commitments impacted by the activity, organized by planning standard as applicable)

I.tceiisine Basis:

JOCFR5OAZ(b)(f): Primary responsibilities loremergency response by the nuclearfacility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specically established, and each principal response organization has staifto respond and to augment its initial response on a continuous basis.

Part 50, Appendix E,Section IV, A: The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

1

. A description of the normal plant operating organization.

2. A description of the onsite emergency response organization (ERO) with a detailed discussion of:

a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

b. Plant staff emergency assignments; File # A210.0038 Page 1 of3 CA1524 KDP-ZZ-00400 Rev. 001

50.54(q) Effectiveness Evaluation Form Compliance Evalua(ion and

Conclusion:

Evaluation:

IOCFR5O.47(b)(1): This change impacts the process for maintaining ERO personnel and their assigned responsibilities which directly impacts this planning standard, specifically the assignment of the emergency responsibilities of licensee and various supporting organizations. However, the overall actions and approvals required to assign ERO responsibilities is unchanged other than what administrative guidance is used to assist in the process.

Revising Form 2814 to remove references prohibiting the use of CA2814 for ERO purposes and creating a Desk Top Instruction (DTI) that references using From 2814 to replace the current form CA2448 to initiate and track the qualification process for Emergency Response Organization (ERO) members, does not change the fact that primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis Part 50, Appendix E,Section IV, A: This change impacts the process of maintaining ERO personnel and their assigned responsibilities which directly impacts this section, specifically the Plant Staff emergency assignments.

Revising form 28 14 to remove references prohibiting the use of CA2814 for ERO purposes and creating a Desk Top Instruction (DTI) that references using Form 28 14 to replace the current form CA2448 to initiate and track the qualification process for Emergency Response Organization (ERO) members, does not change the fact that the organization for cophig with radiological emergencies is described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the followin shall be included:

I

. A description of the normal plant operating organization.

2. A description of the orisite emergency response organization (ERO) with a detailed discussion of

a. Authorities, responsibilities, and duties ofthe individual(s) who will take charge dtiring an emergency;

b. Plant staff emergency assignments; RERP Revision Review:

Previous revisions of the Emergency Plan were reviewed to determine relevance to Revision 055 with Revision 3 used as a baseline. Revision 3 is the earliest fully intact Emergency Plan revision. Revision 3 of the Callaway RERP was reviewed, and it ias found that the current section 5.0 Organizational Control of Emergencies (Revision 055) was found in Revision 3 (Chapter 5). Revision 4 was also reviewed, and the current section 5.0 was found. A search was performed of revisions 5A through 52 of the RERP using the RERP Database (an excel spreadsheet detailing the various changes made to the RERP on the various revisions of the RERP) on the words ERO, and Qualification. A manual search of Revisions 053 and 054 was also conducted. It is concluded that nothing was found in the historical search that would impact or affect the change being made to create a Desk Top Instruction (DTI) referencing the use offonu 2814 to replace the current form CA2448 to initiate and track the qualification process for Emergency Response Organization (ERO) members. No changes were made to the RERP (since Revision 3, the original approved Callaway RERP) that would indicate a change to this licensing basis determination.

Concltision:

The proposed change, of creating a Desk Top Instruction (DTI) referencing the use ofform 2814 to replace the current form CA2448 to initiate and track the qualification process for Emergency Response Organization (ERO) members, will continue to comply with the requirements of 10CFR5O.47(b)(l) and Part 50 Appendix E,Section IV A.

final Conclusloit:

YES NO Does the proposed activity continue to comply with the Licensing Requirements9.....

U FiIc#A210.0038 Page2of3 CA1524 KDP-ZZ-00400 Rev. 001

50.54(q) Effectiveness Evaluation Form Reduction in Effectiveness (PiE) Evaluation and

Conclusion:

Evaluation:

The CA2448, ERO Position Maintenance Form, is the current method Catlaway Emergency Preparedness uses to initiate, track, an delete Emergency Response Organization (ERD) members. All other Job Duty/Qualification Assignment requests at Callaway exce for ERO/Safeguards use Form 2814, Job Duty/Qualification Assignment Change Request. To provide alignment with the rest of Callaway, corrective action 001 for CR 202303801 is to revise Form 2814 to remove references prohibiting the use of CA281 4 for ERO purposes. This will allow EP to use CA2814 to track ERO changes as the rest ofthe site does. In addition, corrective action 002 for CR 202303801 is for the creation of a Desk Top Instruction (DII) to replace the current form CA2448 to provide guidance for the initiation and tracking of the qualification process for Emergency Response Organization (ERO) members.

Creation of a DTI to add and remove ERO members in conjunction with CA2814, will allow for clearer requirements and additional information to ensure alignment in the EP department on when specific activities are required to add or remove an ERO member. The third corrective action for CR 202303801 is the revision of

, Emergency Response Organization, to replace the reference to Form CA2448 with the reference to the DTI. These corrective actions will enhance the overall process of initiating, tracking, and deleting qualifications for ERO members, therefore this change to use Form 2814 in place of Form CA2448 and adding a DTI is not a reduction in effectiveness as the updated process enhances the ability of the EP Department to ensure ERO members are properly qualified.

==

Conclusion:==

The change remains in compliance with 10 CFR 50.47(b)(f) as Callaway continues to have the means to provide each principal response organization with staifto respond and to augment its initial response on a continuous basis.

The change complies with 10 CFR Part 50, Appendix E, Section IV, A as Callaway continues to maintain a description of the organization for coping with radiological emergencies, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization and the means for notification of such individuals in the event of an emergency.

Specifically, the following are still included:

1. A description ofthe normal plant operating organization.

2. A description of the onsite emergency response organization (ERO) with a detailed discussion of:

a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

b. Plant staff emergency assignments; The change does not impact any of the capabilities or functions described in the emergency plan.

The updated process of using Form 2814 in place of Form CA2448 and adding a DTI to initiate, track, and remove qualifications for ERO members is an enhancement which improves the process and further aligns EP with other Callaway departments. Therefore, this change does not reduce the effectiveness of the Emergency Plan.

final

Conclusion:

YES NO Doesthe proposed activity constitute a Reduction In Effectiveness D

Effectiveness Evaluation Results:

The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E AND the activity does not constitute a Reduction In Effectiveness. Therefore, the activity can be implemented without prior NRC approval.

El The activity does not continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E OR the activity does constitute a Reduction In Effectiveness. Therefore, the activity cannot be implemented without prior NRC approval.

Review/Approval:

Preparer (SigiPIN)

Date:_____________

Reviewer (Sign/PIN)

Date:

Emergency Preparedness Manager (Sign/PIN):

lJtte:

File#A210.0038 CA1524 Page 3 of 3 KDP-ZZ-00400 Rev. 001

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 tinusual to have more than one process appiy to a given activity. Refer to Section 4 of the 10 CFR 50.59 Resource Manual (RIVI) and the instructions on pages 5-6 for additional guidance.

I.

Activity/Document Number: EIP-ZZ-A0001 Revision Number:023

Title:

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

I See attached Summary ofchanges for EIP-ZZ-AOt)O1, Rev. 023 IL 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?

(Sec Section 4.2 of the PM.)

Ill.

Does the proposed activity involve a change to the:

1 Technical Specifications or the Renewed Operating License?

tSee 10 çFR 50.90.)

2.

Quality Assurance Plan? (See 10 CFR 5O.54(a.)

3.

Security Plan which also includes the Cyber Security Plan?

NO (See 10 CFR 50.54(p).)

4.

Radiological Emergency Response Plan (RERP) or Emergency Action Levels (EALS)? (See I 0 CFR 50.54(q).)

Note: Ifyour proposed change alters a RERP implementing procedure {any EIP-ZZ-XXXX], equipment identified as important to emergency response [refer to KDP-ZZ-000 13], or could alter response time, staffing, or other items covered in the 1 6 Planning Standards or In Appendix E to Part 50.47(b) [refer to KDP-ZZ-00400j, answer this YES.

IfYES, no further 50.59 (or 72.4$)

review beyond this Applicability Determination (AD) is required, but

Response

complete the remainder of this form.

Identify the applicable 50.59/72.48 NO LI YES Evaluation Log No., License Amendment No., or applicable document number.

Document #

Response

See Section 4.2.1 ofthe RM.

NO LI YFS If YES, process per APA-ZZ-00 108 and FDP-ZZ-00 103.

IfYES, process per APA-ZZ-0O 108 NO E YES and GI)P-ZZ-00600 and related facility or procedure change APA-ZZ-OO 143 Page 1 CA2510 programs.

IfYES, process per APA-ZZ-00 108 Li YES SDP-ZZ-00030 for Security Plan and related facility or procedure change programs.

IfYES, process per APA-ZZ-00 108 LI NO YES and KDP-ZZ-00400 for RERP and related facility or procedure change programs.

A170.OOlO Rev. 005

APPLICABILITY DETERMiNATION (Continued)

IfYES, process APA-ZZ-00356 for ASME code compliance and related I

facility or procedure change programs.

5.

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

NO El YES IfYES, process per EDP-ZZ-O 1003 for ASME code compliance and related facility or procedure change

)I-t)gr1 6.

1ST Program Plan? (See 10 CFR 5055a(g).)

NO El YES See FP Screening questions in EDP ZZ-04044. Ifany ofthe screening 7.

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

NO YES questions are answered YES, a fire Protection review is needed in accordance with EDP-ZZ-04044.

8.

Storage Cask Certificate of Compliance (CoC), incitiding If YES, then contact Regulatory appendices?

(See 10 CFR 72.244.)

NO YES AfThirs/Licensing to determine next steps 9.

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

the ODCM) that are controlled by regulations, the Operating License (including Orders and License If YES, indicate the applicable Conditions) or the Technical Specifications? (See Section NO El YES 101am in Brief Description 4.2.1 ofthcRM.)

Section.

Iv.

Does the 1rOposed activity involve:

Response

See Section 4.2.2 ofthe RM 1

. Maintenance which restores SSCs to their original (as designed) cndition?

(See 10 CFR 5065(a)(4).)

IfYES, process change per M NO YES APA-ZZ-00l0l for procedure Note: If the maintenance is on ISfSI or cask-related items, changes or APA-ZZ-00320/330/340 the Maintenance Rule does NOT apply, and the activity is for Maintenance activities.

subject to a 10 CFR 72.4$ Screen on a CA3 145.

IfYES, process per APA-ZZ-00101 for procedure changes or APA-ZZ-00605 for facility changes 2.

A temporary alteration (to procedures or the facility)

-2 Of Procedurally Controlled supporting maintenance (TASM) that will be in effect j NO YES Temporary Modifications or during at-power operations for 90 days or less?

MDPZZFSOO1 for Freeze Seals.

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

APA-ZZ-00143 Page2 CA25W A170.OOIO Rev. 005

APPLICABILITY DETERMINATION (Continued)

V.

Does the proposedactivityinvolve a change to the:

1.

FSAR NO LIYEs If the above response is NO, check N/A in the Response column at right.

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

Note: In lieu ofthe exclusion criteria ofRM Section 42.3, 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 11 of this Applicability Determination form.)

2.

Technical Specification Bases?

NO fl YES If the above response is NO, check N/A in the Response cekurin at right.

If the above response is YES, does the proposed activity involve a IS Bases change comparable to that which may be excluded from the requirement to perform a 50.59 Screen/Evaluation by NEI 9607 or NEI 98O3 (as described for an FSAR change)? (Provide a YES or NO response to this question in the Response column at right.)

Note: In lieu ofthe exclusion criteria ofRM Section 4.2.3, a YES response may also be provided if the TS Bases change requires no further 50.59 review based on a YES response to the question in Section II of this Applicability Detenuination form.)

VI.

Does the proposed activity involve a change to:

1.

Managerial or administrative procedures, controls, or activities (including software used only for the implenientation of administrative procedures, controls, or activities) governing the conduct of facility operations (suh1Lt to the control of 1OCER5O Appnd\\ 13)?

2.

Regulatory commitment not covered by another regulation based ch ing ptocss tS NEl 99 04 A NO response in the Response El NO Li YES colunm at left means that the FSARJIS Bases change is one that N/A requires further 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-00103 for revising License Documents.

Note:

IA NO response in the Response column at left means that the TS NO Li 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.

Response

See Section 4.2.4 / 4,2.6 of the RM.

NO El YES If YES, process per APA-ZZOO 101 or APA-ZZ-0O 109.

IfYES, process per APA-ZZ-00540.

IfYES, perform a 72.48 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 prlbrni a 72.48 Review.

APA-ZZ-OO 143 Al 7t).OO1O CA2510 Rev. t)05

Response

ISee Section 4 2 3of the RM I

Process the FSAR change per APA-ZZ-00108 and FDP-ZZ-O0 103 for revising License Documents.

Note:

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 72.2 12 Report? (See FDP zz-00 105 and Attachment 1 of APA-Zi.00 143.)

NO EYES NO EYES Page 3

APPLICABILITY DETERMINATION (Continued)

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

Justification for the above responses is that this activity revises an RERP implementing procedure which is considered a change to the RERP and solely controlled by KDP-ZZOO4OO. Thus 10CFR 50.59 screening is not required..

Ix.

Conclusion:

J1P! ofthe activity are controlled by one or more ofthe procedures above, therefore a 50.59 Screen isnot required.

E A pjJn of the activity isnot controlled by one or more of the procedures above, therefore a 5059 Screen is required.

x

d Preparer JosLph Fortman

1) it 13 2oZ3 (l;it minicl (Sign/PIN) 1)k.

13 O%%

(Print name)

(Sign/PIN)

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 ofAdministration in accordance with APA-ZZ-00220.

APA-ZZ-00143 Page4 CA2510 A170.OO1O Rev. 005