ML24114A052
| ML24114A052 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/13/2024 |
| From: | Kanuckel K Ameren Missouri, Union Electric Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML24114A052 (1) | |
Text
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PROCEDURE REVIEW FORM (PRF) 1.0 Initiation Initiator: KUrt Kanuckel
. Date: 02/13/2024 Procedure Dept:
EP Document #: EIP-ZZ-00102 New Rev. #
071 (3digits/eqltifred)
Title:
EMERGENCY IMPLEMENTING ACTIONS Level ofUse:
ElContinuous EReference Inforrnation flMultiple EJN/A 2.0 Reason for Change/Description of Change (List commitments, Cits, eB Change Requests, OliRs, Plctnt ilIods etc. and record nttnthers here.)
CR 202308638. Added new bullet points on attachment 3 to help with clarfty.
See SOC for more details.
Continued: U 3.0.
Document Disposition ElTemp Change flNew Document EjMajor Revision Minor Revision ECancellation ElAdm inistrative Correction p_t Head or I)csignated Approver required for Administrative Corrections (Signature/PIN/Date) noothersignatures required 4.0 Interim Approval (Temp. Change Only)
Temp. Change #:
Expiration Date:
( ncnri ml SUpLI i(SILI w PP\\ Dite)
SR() (SlgnaturL/PIN/[) ItL)
5.0 Comments
Continued: EJ 6.0 Reviews and Signatures (NOT requiredjor AdminivtrutIve Corrections)
I?i!quired I)Lpi PIN Signature DaIc Preparer 0
15/9d7 tifr7/
L12t1 N/A fethnical Review
(\\.)
- t1 Z J Yes No Addi Review
/
Yes LI No DAdditional Reviews (See Attached C4O1}(Jbrms).
Number of additional CAO 1 39s Type Coordinator PIN Stgtzattcre Dale jCA0139 Allactied LiValidation
I
fjYes j No 50.59 Review CA25 10 DCA25 1 1 ECA2512 I HN/A (perAPA-ZZ-00143)
Screcirer initiat/PIN
/?eeiuei hrttktf PIV (Dept. Bead or Designated Approver) Is a Change Management Plan required?
EJYes No (IF YES. attach CA2773 or (A27?4)
Is a Cross-Disciplinary review required?
LlYes INo 7.0 Approval (Either approval must be qualIec/ as PA T/APVI? or PA T/GAPR in Qita1iiastei.)
LI Senior Director Nuclear Operations Approval (per APA-ZZ-Ot)1OI)
ORC is required in accordance with APA-ZZ-0009 I Ji )LpaIt1rn fi I lyd Fifi t Review and Appioval ORC Meeting J
.. J) 3/i/v Dept. Ilead or Designated Approcr Senior Director Nuclear operations (Signature/PIN/Date)
(Signature/PIN/Date)
A1900001 2 3S A2100062 65 69 M1900001 Page 1 of 2 APA-ZZ-Ot) 101 jiow: PctgL? 2J)!()ltdCS instnic!itms to coo,1ete tIiisThrm and may /)? dlscarcle?c/
CA0033 Rev. t)02
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.
I.
Activity/Document Number: EIP-ZZ-00102 Revision Num her: 071
Title:
Brief Description of activity (what is being changed and why):
III.
Does the proposed ativfty involve a change to the:
1.
Technical Specifications or the Renewed Operating NO License?
(See 10 CFR 5090.)
2.
Quality Assurance Plan? (See 10 CFR 5054(a).)
NO 3.
Security Plan which also includes the Cyber Security Plan?
NO (See 10 CFR 5054(p).)
4.
Radiological Emergency Response Plan (RERP) or Emergency Action Levels (EALS)? (See 10 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-00013J, or could alter response time, staffing, or other items covered In the 16 Planning Standards or in Appendix E to Part 50.47(b) [refer to KDP-ZZ-00400],
answer this question YES.
APA-ZZ-OO143 A170.OO1O IfYE$, no further 50.59 (or 72.48) review beyond this Applicability Determination (AD) is required, but
Response
complete the remainder ofthis form.
Identify the applicable 50.59/72.42 NO i:i YES Evaluation Log No., License Amendment No., or applicable
. document number.
Document#
Response
See Section 4.2.1 ofthe RM.
E: YES IfYE$, process per APA-ZZ-00 1.08 and fDP-ZZ-001 03.
If YES, process per APA-ZZ-00 108 D YES and GDP-ZZ-00600 and related I facility or procedure change programs.
If YES, process per APA-ZZ-00 I 08 LI YES and SDP-ZZ-00030 for Security Plan and related facility or procedure change programs.
Page 16, Attachment 3 step 8-Added 2 new bullets stating, If Alarm Set switch is on the back, turn to adjust and If Alarm Set switch is on the front, UNLOCK the Alarm Set switch by turning the locking ring counterclockwise, then DEPRESS and HOLD the tAlarm button while turning the Alarm Set switch to the value desired on the meter face.
Page 17 Attachment 3 Step 12-Added new bullet point stating, Alarm set at 5 and locking ring locked (clockwiseY II.
Does the proposed activity fall within the scope of an 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.)
. If YES, process per APA-ZZ-00 10$
NO r YES and KDP-ZZ-00400 for RERP and related facility or procedure change programs.
Page 1 CA25 10 Rev. 005
APPLICABILITY DETERMINATION (Continued) 7.
Fire Protection Program? (See Operating License Condition 2.C(5).)
8.
Storage Cask Certificateof Compliance (CoC), including appendices?
(See 10 CFR 72.244.)
9.
Does the proposed activity impact other programs (e.g.,
the ODCM) that are controlled by regulations, the Operating License (including Orders and License Conditions) or the Technical Specifications? (See Section 4.2.1 oftheRM.)
Iv.
Does the proposed activity involve:
1. Maintenance which restores SSCs to their original (as designed) condition?
(See 10 CFR 50.65(a)(4).)
Note: Ifthe maintenance is on ISFSI or cask-related items, the Maintenance Rule does NOT apply, and the activity is subject to a 10 CFR 72.48 Screen on a CA3 145.
2.
A temporary alteration (to procedures or the facility) supporting maintenance (TASM) that will be in effect during at-power operations for 90 days or less?
APA-ZZ-OO143 A170.OO1O IfYES, process APA-ZZ-00356 for ASME code compliance and related facility or procedure change programs.
See FP Screening questions in EDP ZZ-04044. If any ofthe screening questions are answered YES, a Fire Protection review is needed in accordance with EDP-ZZ-04044.
IF YES, then contact Regulatory NO LI YES Affairs/Licensing to determine next stcps.
If YES, indicate the applicable NO YES program in Brief Description Section.
Response
See Section 4 2 2 ofthe RM If YES, process change per APA-ZZ-OO 101 for procedure changes or APA-ZZ-00320/330/340 for Maintenance activities.
IfYES, process per APA-ZZ-OO 101 for procedure changes or
( APA-ZZ-00605 for facility changes or Procedurally Controlled Temporary Modifications or MDP-ZZ-fSOO1 for freeze Seals.
Evaluate risk using APA-ZZ-003 15, Appendix A.
5.
1ST Program Plan? (See 10 CFR 50.55a(O.)
6.
151 Program Plan? (See 10 CFR 50.55a(g).)
NO UYES NO IYE$
IfYES, process per EDP-ZZ-01003 for ASME code compliance and related facility or procedure change programs.
NO LJYES NO LIYES NO flYES Page 2 CA25 10 Rev. 005
APPLICABILITY DETERMINATION (Continued)
Y.
the proposedacüvity involve a changeto the:
1.
F$AR NO EYES If the above response is NO, check N/A in the Response column at right.
Note: In lieu ofthe exclusion criteria ofRM Section 4.2.3, a YES response may also be provided ifthe FSAR change requires no further 50.59 review based on a YES response to the question in Section II ofthis Applicability Determination form.)
2.
Technical Specification Bases?
NO j YES If the above response is NO, check N/A in the Response column at right.
VI.
Does the proposed activity involve a change to:
I Managerial or administrative procedures, controls, or activities (including software used only for the implementation of administrative procedures, controls, or activities) governing the conduct of facility operations (uhJe(t to the control of IOCFRiO APPLflchX B) 2.
Regulatory commitment not covered by another regulation based ching pross tSe NEI 99 04)
APA-ZZ-OO 143 A170.OO1O
Response
SeeSection 4.2.4 I 4.2.6 ofthe RM.
NO fl YES If YES, process per APA-ZZ-OO I 01 or APA-ZZ-00109.
If YES, process per APA-ZZ-00540.
IfYES, perform a 72.48 Screen per APA-ZZ-00143 unless the change is completely covered by the response Ito Section II.
Note:
Editorial or administrative changes are excluded from the requirement
=--.
1to pertbrm a72.48 Review.
Response
1 See Section 4 2 3 ofthe RM Process the FSAR change per APA-ZZ-00108 and FDP-ZZ-00103 I for revising License Documents.
Note:
Ifthe above response is YES, does the proposed activity A NO response in the Response involve an FSAR change that may be excluded from the jj NO YES column at left means that the requirement to perform a 50.59 Screen/Evaluation by
FSAR/TS Bases change is one that NET 9607 or NEI 9803? (Provide a YES or NO response to N/A requires further 50.59 review (i.e., is this question in the Response column at right.)
not excludable from further review).
A YES response means that the
, FSAR does NOT require further 50.59 review Process the TS Bases change per APA-ZZ-0010$ and FDP-ZZ-00 103 for revising License Documents.
Note:
Ifthe above response is YES, does the proposed activity A NO response in the Response involve a TS Bases change comparable to that which may be column at left means that the TS excluded from the requirement to perform a 50.59 j NO j YES Bases change is one that requires Screen/Evaluation by NEI 9607 or NEI 9803 (as described further 50.59 review (i.e., is not for an FSAR change)? (Provide a YES or NO response to this N/A excludable from further review).
question in the Response column at right.)
A YES response means that the TS Note: In lieu ofthe exclusion criteria ofRM Section 4.2.3, a Bases Change does NOT require YES response may also be provided ifthe TS Bases change further 50.59 review.
requires no further 50.59 review based on a YES response to the question in Section II ofthis Applicability Determination form.)
NO EYES VTI Does tle proosed activity PotentiallY affect the desi%n,
. operation, or maintenance otthe ISFSI fticility as described in the dry cask storage FSAR or the 72.2 12 Report? (See FDP zz-00l05 and Attachment 1 of APA-ZZ-00 143.)
NO EYES Page 3 CA2510 Rev. 005
APPLICABILITY DETERMINATION (Continued)
VIII. Justification/explanation for Response(s) (as needed):
Revisionofthe RERP Implementing procedure is covered solely by 10CFR 50.54(q) and controlled by KDP-ZZ-00400.
Therefore, 10CFR5O.59 is not required.
Ix,
Conclusion:
All aspects ofthe activity controlled by one or more ofthe procedures above, therefore a 50.59 Screen jjt required.
A portion ofthe activity jjt controlled by one or more ofthe procedures above, therefore a 50.59 Screen is required.
- x. gnoffs:
Preparer:
Date:
Qualified Reviewer:
Date: 3/j/z (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
50.54(q) Screening Form Document #, Rev #, &
Title:
EIP-ZZ-OO1O2 Rev 071, Emergency Implementing Actions EP Tracking #:
2024006 Activity Description and
References:
All the changes listed below are based off CR#202308638.
Page 16, Attachment 3 step 8-Added 2 new bullets stating.
f Alarm Set switch is on the back, turn to adjus and If Alarm Set switch is on the front, UNLOCK the Alarm Set switch by turning the locking ring counterclockwise, then DEPRESS and HOLD the Alarm button while turning the Alarm Set switch to the value desired on the meter face a
Page 17 Attachment 3 Step 12-Added new bullet point stating, Alarm set at 5 and locking ring locked CclockwiseY Activity Scope:
YES NO Does this activrevise the Radio1oca Plan (RfRP) or LI Change Type:
YES NO Isthis activity editorial or typographical7 LI Previously Approved Change:
YES NO Is this activity being processed to conform to a previously approved activity?
LI I
IfYES, what is the previousiy approved activity?
Planning Standard Determination:
Does this activity impact any ofthe 50.47(b) Planning Standards or Part 50 Appendix F:
YES NO 50.47(b)(1)
- Assignment ofResponsibility (Organization Control)7
,* LI 5047(b)(2)
- Onsite Emergency Organization?
LI 5047(b)(3) - Emergency Response Support and Resources9 LI 50.47(b)(4) - Emergency Classification System9 LI 50.47(b)(5) - Notification Methods and Procedures7 LI 50.47(b)(6) - Emergency Communications?
LI 50.47(b)(7) - Public Education and Information9 LI 50.47(b)(8)
- Emergency Facility and Equipment?
LI 5O.47(b)(9)
- Accident Assessment9 LI 50A7(b)( 10)
- Protective Response?
LI 50A7(b)(1l) - Radiological Exposure Control?
LI 5047(b)(12)
- Medical and Public Health Support9
. LI 50.47(b)(13) - Recovery Planning and Post Accident Operations?
LI 5047(b)(14)
- Drills and Exercises7 LI 50.47(b)(15) - Emergency Responder Training?
LI 50.47(b)(i 6) - Emergency Plan Maintenance?
LI Part 50 Appendix. E LI Commitment Impact Determination:
YES NO Does this activity impact a Site Specific EP Commitment not associated with a Planning Standard or Element7 LI 1
If Yes record the Commitment number:_
Explanation of Determination: (Enter an explanation to each determination-answer that needs clarfIcation.)
This change is associated with planning standard 50.47(b)(l 1) Radiological Exposure Control. However, this change provides guidance on equipment operation. Therefore, there is no impact on the regulatory requirements of the standard. Therefore, a 1O.CFR 50.54(q) evaluation is not required.
File # A210.0038 Page 1 of2 CAl 523 KDP-ZZ-00400 Rev. 002
5054(q) Screening Form Screening Evaluation Results:
Based on the results ofthe information above, can the activity be implemented without performing a YES NO full 50.54(q) Effectiveness Evaluation?
Review/Approval:
Date: 19;1Z Date:
2j Date:4(J?
File # A210.0038 KDP-Zi-00400 Page 2 of 2 CAl 523 Rev, 002 Preparer (Sign/PIN)
Reviewer (Sign/PIN):..