ML24114A053

6 to Emergency Implementing Procedure EIP-ZZ-00201, Revision 56, Notifications

ML24114A053
Person / Time
Site:	Callaway
Issue date:	03/19/2024
From:	Jeffrey Reed Ameren Missouri, Union Electric Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
Download: ML24114A053 (1)

Text

PROCEDURE REVIEW FORM (PRF) 1.0 Initiation Initiator: James Ree Date: 3/1 9/2024 Procedure Dept:

EP_________

Document #: EIP-ZZ-00201 New Rev. #

056 (3 digits required)

Title:

NOTIFICATIONS Level of Use:

JContinuous EReference Information 1Mu1tip1e UN/A 2.0 Reason for Change/Description of Change (List commitments, CRs, eB Change Requests, OERs, Plant Mods etc. and record numbers here.)

CR#- 202401074-QOlSee SOC

J----p-:

3.0.

Document Disposition ETemp Change UNew Document EMajor Revision Minor Revision Ecancellation EAdministrative Correction Dept Head or Designated Approver required for Administrative Corrections (Signature/P1N/Datc)noothersnaturtfred 4.0 Interim Approval (Temp. Change Only)

Temp. Change #;

Expiration Date:

C ognizant Supervisor (Signature/PIN/Date)

SRO (Signature/PIN/Date)

5.0 Comments

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

Rev1e11Y Reqiired Dept PIN Signaturç Date CA0139 Allached Preparer EP 136263 3/19/24 N/A Technical Review

,iyçc Es 3/i/,/

U Yes No Techna1Revw P ji/(

EYes No Addl Review T?1]k fiJZLf U Yes E No Add 1 Review I

U Yes U No EAdditional Reviews (See Attached CAOl39forrns).

Number of additional CAOI39s:

Type Coordinator - PIN Signature Date CA0139 Attached EVahdation U Yes U No (Dept. Head or Designated Approver) Is a Change Management Plan required? Eyes No (IF YES, attach CA2773 or CA2774)

Is a Cross-Disciplinary review reqnired?EjYes No 7.0 Approval (Either approval must be quaflfied as PAT/APVR or PAT/GAPR in QualMaster,)

Senior Director Nuclear Operations Approval (per APA-ZZ-OO1Ol)

ORC is required in accordance with APA-ZZ-00091 Department Head lina Review and Approval ORC Meeting:

1..-cL j3i Dept. Head or Designated Approve (Signature/PIN/Date)

Note: Page 2 provides instructions to complete thisform and may be discarded M90.0001, 2, 5, 35

- A210.0062, 65, 69; M190.000l Page 1 of 2 APA-ZZ-OOlO1 Continiied fl 50.59 Review CA25 10 ECA25 I 1 ECA2512 I EN/AerAPAZZOO143) j?f IE Senior Director Nuclear Operations (Signature/PIN/Date)

CA0033 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.

L Activity/Document Number: EIP-ZZ-00201 Revision Number: 056

Title:

Notifications BriefDescription ofactivity (what is being changed and why):

H.

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 afready been performed?

(See Section 4.2 ofthe RM.)

III.

Does the proposed activity involve a change to the:

1.

Technical Specifications or the Renewed Operating License?

(See 10 CFR 50.90.)

2.

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

3.

Security Plan which also includes the Cyber Security Plan?

NO (See 10 CFR 50.54(p).)

4.

RadiologicalEmergency 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-XXXXJ, equipment identified as important to emergency response [refer to KDP-ZZ-00013], 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-OO 143 Al 70.00 10 IfYE$, 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 50.59/72.48 NO i: YES Evaluation Log No., License Amendment No., or applicable document number.

Docufleflt#

Response

See Section 4.2.1 ofthe RM.

NO El YES If YES, process per APA-ZZ-0O 108 and FDP-ZZ-OO 103.

IfYES, process per APA-ZZ-00 10$

L: YES and GDP-ZZ-00600 and related

. facility or procedure change programs.

If YES, process per APA-ZZ-00 I 08 El YES and SDP-ZZ-00030 for Security Plan and related facility or procedure change programs.

\\Il the change listed below are based off CR#202401 O74001 Page 8 Deleted old step 5.4.4 that stated, Any concurrent EALS that have been identified should be listed in the Additional Notes section to notify the offsite agencies and to aid in Closeout and Recovery.

NO IfYES, process per APA-ZZ-00 108

NO rci YES and KDP-ZZ-00400 for RERP and

.2d related facility or procedure change programs.

Page 1 CA25 10 Rev. 005

7.

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

8.

Storage Cask Certificate of 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-OO 143 A170.OO1O If YES, process per EDP-ZZ-O 1003 for ASME code compliance and related facility or procedure change programs.

See FP Screening questions in EDP ZZ-04044. If any of the screening NO i:i YES questions are answered YES, a Fire Protection review is needed in accordance with EDP-ZZ-04044.

IF YES, then contact Regulatory NO Lj YES Affairs/Licensing to determine next steps.

If YES, indicate the applicable NO D YES program in Brief Description Section.

Response

See Section 4.2.2 ofthe RM If YES, process change per M NO El YES APA-ZZ-00 I 01 for procedure IL.N changes or APA-ZZ-00320/330/340 for Maintenance activities.

If YES, process per APA-ZZ-00 101 for procedure changes or APA-ZZ-00605 for facility changes NO YES or Procedurally Controlled Temporary Modifications or MDP-ZZ-FSOO1 for Freeze Seals.

Evaluate risk using APA-ZZ-003 15, Appendix A.

APPLICABILITY DETERMINATION (Continued)

IfYES, process APA-ZZ-00356 for ASME code compliance and related facility or procedure change programs.

5.

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

6.

ISI Program Plan? (See 1 0 CFR 50.55a(g).)

NO LJYES NO UYES Page 2 CA2510 Rev. 005

v_

Does the proposed actiVity involve a change to the 1.

FSAR NO 1YES 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 NET 9607 or NET 9803? (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 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 fl 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 50.59 Screen/Evaluation by NEI 9607 or NEI 9803 (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 of RM Section 4.2.3, a YES response may also be provided ifthe TS Bases change requires no further 50.59 review based on a YES response to the question in Section IT ofthis Applicability Determination form.)

VI.

Does the proposed activity involve a cha;ige 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 (subjeci to the control of 1t)CFR5O, Appendix 13)?

2.

Regulatory commitment not covered by another regulation based charge process? Se NEI 99-04.)

(Continued)

Response

FSee Section 4.2.3 ofthe RM Process the FSAR change per APA-ZZ-00108 and FDP-ZZ-00 103 for revising License Documents.

Note:

A NO response in the Response

NO 0 YES column at left means that the FSAR/TS 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:

A NO response in the Response column at left means that the TS LI NO i:i 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 1$

Bases Change does NOT require further 50.59 review.

rci NO i: YES If YES, process per APA-ZZ-0O 101

(-:I or APA-ZZ-00 109.

1O LYES IfYES, perform a 72.48 Screen per APA-ZZ-00143 unless the change is completely covered by the response to Section II.

NO LYES Note:

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

APA-ZZ-OO 143 A170.OO1O APPLICABILITY DETERMINATION

Response

Section 4.2.4 / 4.2.6 ofthe RM.

VII l)ocs the proposed activity potentially affect the design,

. oeration or maintenance Oftile ISFSI facility as desctibed in the dry cask storage FSAR or the 72.2 12 Report? (See FDP zz-00105 and Attachment 1 of APA-ZZ-00 143.)

Page 3 CA2510 Rev. 005

APPLICABILITY DETERM1ATION (Continued)

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

Ix

Conclusion:

All aspects ofthe activity ç controlled by one or more ofthe procedures above, therefore a 50.59 Screen isnot required.

ri A portioi ofthe activity jjçt controlled by one or more ofthe procedures above, therefore a 50.59 Screen is required.

x. Signoffs:

Qualified Preparer:

Qualified Reviewer:

APA-ZZ-OO 143 A170.OO1O Date: Jii/1 Date:

/Z-1 Revision ofthe RERP Implementing procedure is covered solely by 10CFR 50.54(q) and controlled by KDP-ZZ-00400.

Therefore, IOCFR5O.59 is not required.

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.

Page 4 CA2510 Rev. 005

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

Title:

EIP-ZZ-00201, Rev. 056, Notifications EP Tracking #:

2024011 Activity Description and

References:

All the change listed below are based oft CR#202401 074-001 Page 8 Deleted old step 5.4.4 that stated, Any concurrent EALS that have been identified should be listed in the Additional Notes section to notify the offsite agencies and to aid in Closeout and Recovery.

Activity Scope:

YES NO DoesthisactivitrevisetheRadio1ogca1 Emergency Response Plan (RERP)or Imj1ementinProcedures?.....

Change Type:

YES NO Is this activity editorial or typographical?.........

.:: P Previously Approved Change:

YES NO Is this activity being processed to conform to a previously approved activity9 IfYES, what is the previously approved activity?

Planning Standard Determination:

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

YES NO 50.47(b)(l) - Assignment of Responsibility (Organization Control)9 LI 50.47(b)(2) - Onsite Emergency Organization?

El 50.47(b)(3) - Emergency Response Support and Resources7 Li 50.47(b)(4) - Emergency Classification System7 1

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

50.47(b)(6) - Emergency Communications7 D

50A7(b)(7) - Public Education and Infom;ation9 LJ 50.47(b)($) - Emergency facility and Equipment?

50.47(b)(9) - Accident Assessment9 J

50.47(b)(l0)

- Protective Response?

J 50.47(b)(ll) - Radiological Exposure Control?

D 50.47(b)(12) - Medical and Public Health Support7 U

50.47(b)(13) - Recovery Planning and Post Accident Operations7 U

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

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

0 50.47(b)(16) - Emergency Plan Maintenance7 U

Part 50 Appendix E i

Commitment Impact Determination:

YES NO Does this activity impact a Site Specific EP Commitment not associated with a Planning Standard or Element?

U If Yes, record the Commitment number:

Explanation of Determination: (Enter an explanation to each deterrnination-answer that needs clarjflcation.)

This change is associated and potentially impacts planning standards 50.47(b)(4) Emergency Classification System, 50.47(b)(5)

Notifications Methods and Procedures and 50.47(b)(6) Emergency Communications. Currently in EIP-ZZ-0020l step 5.4.4 states Any concurrent EALS that have been identified should be listed in the Additional Notes section to notify the offsite agencies and to aid in Closeout and Recovery. Since this change is removing concurrent EALS from the subsequent notifications to the offsite agencies, l0.CFR 50.54(q) evaluation should be performed to determine if this change would result in a reduction of effectiveness.

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

50.54(q) Screening Form Screening Evaluation Results:

Based on the results ofthe information above, can the activity be implemented without performing a YES NO full 50i4(qj Effectiveness Evaluation9

)

C Review/Approval:

Preparer (Sign/PIN)

J Datc

Prj V LI iflUst be cpccrfJfiLltP4er$l;IL ) I?

5fJ(uiIS C ourdinutor Reviewer (Sign/PN)

%J L

Date

!&vhier hilt C Ørcr!ifled Err ogdnLy Response Coordinator.

Emergency Preparedness Ma%aer (Sign/PIN):

/37_

Date:____

File#A210.0038 Page2of2 CA1523 KDP-ZZ-00400 Rev. 002

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

Title:

, Rev. 056, Notifications EP Tracking #:

Activity Description and

References:

The statement of Any concurrent EALS that have been dentified should be tisted in the Additional Notes section to notify the offsite agencies and to aid in Closeout and Recovery is being removed from EIP-ZZ-00201 due to no regulatory requirement to inform the offsite agencies of concurrent EALs.

Activity Type:

YES NO Does this activity revise the Radiological Emergency Response Plan (RERP) or Implementing Procedures9 E

Does this activity impact implementation ofthe RERP, but doesNOT revise the RERP or Implementing Procedures?

Impact and Licensing Basis Determination:

(List offunctions, elements and/or commitments impacted by the activity, organized byplanning standard as applicable) jçeiisiigi3asis:

10CFR5O.47(b)(4) A standard emergency classification and action level scheme, the bases ofwhich include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility ticensees for determinations of minimum initial offsite response measures.

IOCFR5O.47(b)(5) Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

IOCFR5O.47(b)(6) Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.

Compliance Evaluation and

Conclusion:

Evaluation:

10CFR5O.47(b)f4) Removing the concurrent Emergency Action Levels tEALS) from the additional notes section of the notification form does not change the primary responsibilities for EALs classification or declaration during an event. The offsite agencies would still receive notification of the event, which would not impact their ability to initiate their emergency response measures.

IOCFR5O.47(b)(5)- Removing the concurrent Emergency Action Levels (EALS) from the additional notes section of the notification form does not change the primary responsibilities for Notifications during an event. The offsite agencies would still receive notification of the event, which would not impact their ability to initiate their emergency response measures.

IOCFR5O.47(b)(6)- Removing the concurrent Emergency Action Levels (EALS) from the additional notes section of the notification form does not change the primary responsibilities for communications during an event. The offsite agencies would still receive notification of the event, which would not impact their ability to initiate their emergency response measures.

RERP 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 was found that there is no mention of Concurrent EALs in any of the revisions of the RERP. All prior changes to RERP Rev 03 to Rev 55 were reviewed with no impacts identified.

==

Conclusion:==

The proposed change, of removing concurrent EALs from the additional notes section of the notification form will continue to comply with the requirements of IOCFR5O.47(b)(4), IOCFR5O.47(b)(5), 10CFR5O.47(b)(6).

finalCoitciusion:

YES NO Does the p c)posLd lctR it contmue to uompl with the I tisn&a Requirements9 L

File # A210.0038 Page 1 of2 CA1524 KDP-ZZ-00400 Rev. 001

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

Conclusion:

Evaluation:

Removing concurrent EALs from the additional notes section of the notification form does not impact Callaways.

ability to comply with the requirements of IOCFR5O.47(b)(4), IOCFR5O.47(b)(5), IOCFR5O.47(b)(6). This change does not affect event declaration I classification, notification or communication with the offsite agencies. Additionally, this change does not impact the RERP.

==

Conclusion:==

The event declaration I classification notification, or communication with the offsite agencies remains unchanged.

With no changes being made to event declaration I classification, notification, or communication with the offsite agencies there is no impact to their ability to initiate their emergency response measures. This would not be a Reduction in Effectiveness to the RERP.

FiitalConclusion:

YES NO Does the proposed activity constitute a Reduction In Effectiveness?

J 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.

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

jJ+/-/

must be Response Coordinator Reviewer (Sign!P) t Reviewer must be q;alified Iwi:tcn:y Response Coordinator

/

Emergency Preparedness 1agev (Sign/PIN):

I4t3 Date File#A210.0038 Page2of2 CA1524 KDP-ZZ-00400 Rev. 001