ML24115A099
| ML24115A099 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/01/2024 |
| From: | Jeffrey Reed Ameren Corp, Union Electric Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| EIP-ZZ-A0066, Rev 30 | |
| Download: ML24115A099 (1) | |
Text
PROCEDURE REVIEW FORM (PRF) 1.0 Initiation Initiator: James Reed Date: 10/26/2023 Procedure Dept:
EP Document #: EIP-ZZ-A0066 Rev. #
030 (3 diits required)
Title:
RERP Training Program Level ofUse:
LiContinuous LlReference Information LlMultiple QN/A 2.0 Reason for Change/Description of Change (List commitments, CRs, eB Change Recjuests, OERs, Plant Mods etc. and record numbers here.)
CR 202306515. Modified Multiple steps. added new references and formatted to align with Callaway Sb1s ti:
Lo1pfoo 70t.
%zJ rqb A190.000l, 2, 5, 35
- A210.0062, 65, 69; M190.0001 Page 1 of 2 APA-ZZ-OO 101 Continued: D 3.0.
Document Disposition EJTemp Change ONew Document ElMajor Revision Minor Revision flCancellation Administrative Correction I)ept. Head or Designated Ajproverrequired for AdministrativeCorrections tSignature/?IN/Date) no other sinaturcs rcguired_
4.0 Interim Approval (Temp. Change Only)
Temp. Change #:
Expiration Date:
Cognizant Supervisor (Signature/PIN/Date)
SRO (Signature/PIN/Date)
5.0 Comments
6.0 Reviews and Signatures (NOT requiredfor Administrative Corrections)
Re1cws RLqpuIett Dpr I
Y naWre Date
çAoi39Awzched reparerJoTho I
3i1oL N/A1 Technical Revw f) 1Z(,L r
IYes No TechnicaiRevw Addl Review LI Yes LI No dL:9YY flysLJN UAdditional Reviews (See Attached CAOI39forrns).
Number of additional CAOI39s:
I Type Coordinator - PIN Signature Date J
CA0139 Attached EValidation F
5059 Review CA25 10 DCA25 1 1 JCA25 12 / EN/A (per APA-ZZ-00143)
Screener Initial / JTh Reviewer Initial/ PIN (Dept. Head or Designated Approver) Is a Change Management Plan required?
ElYes No (IF YES, attach CA2773 or CA27?4)
Is a Cross-Disciplinary review required?
LJYes No 7O Approval (Either approval must he qual(fIed as
/Aor PAT/GAPR in Quatliaster)
Senior Director Nuclear Operations Approval (per APA-Zi-OO1OI) 1 ORC is required in accordance with APA-ZZ-00091 Depat nt Head Fi(al Review and Approval ORC Meeting:
5 j%
ic L!JlZ_
Dept. Head or Designated Approver Senior Director Nuclear Operations (Signature/PIN/Date)
(Signature/PiN/Date)
Note: Page 2provides instructions to comptete thisform and may be dtscarded 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 activtty 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-A0066 Revision Number: 030
Title:
RERP Trainpgroram Brief Description of activity (what is being changed and why):
Alt the changes Iistedbelow are based off CR#202306515 and CR#202400704-028 3.3.1. Revised Callaway Training Course Catalog to Learning Management System 5.1.1. Removed T68.0030.6/8 5.1.2. a. Removed step a. ERO Positions will have a review completed to determine the validity of the current Position Analysis. Changed step b to a and c to b 5.1.2 a. Add new verbiage.
5.1.2.c. Added bullet Self-guided review of lesson plan and applicable procedures followed by discussion with EP staff or Position Owner.
5.2.3. Revised step to The Recovery Manager (RM), Emergency Coordinator fEC), and Dose Assessment Coordinator (DAC) must complete a CA3340, RERP Leadership Checklist, and Drill Certification as part of initial training. This is also indicated in the Learning Management System (LMS).
- 6. 13 Added new reference, APA-ZZ-00925 Append ix A, Auto-Generated Qualification Lapse Messages.
6.1.4 Added new reference, CTM-EP, Callaway Training Manual-Emergency Preparedness.
6.1.5 Added new reference, CA3340, RERP Leadership Checklist CR# 202400704-028 iiYES, no further 50.59 (or 72.48) review beyond this Applicability Determination (AD) is required, but Does the proposed activity fall within the scope of an activity
Response
complete the remainder of this form.
that has been previously approved by the NRC or for which a Identify the applicable 50.59/72.48 50.59/72.48 Screen or evaluation has already been performed?
(See Section 4.2 ofthe RM.)
NO 1J YES Evaluation Log No., License Amendment No., or applicable document number.
I cument # __
III.
Does the proposed activity involvea change to the:
j
Response
, See Section 4.2JoftheRM.
1.
Technical Specifications or the Renewed Operating NO YES II YES, process per APA-ZZ-00 108 License?
(See 10 CFR 50.90.)
IfYES, process per APA-ZZ-00 108 2.
Quality Assurance Plan? (See 10 CFR 50.54(a).)
NO El YES and GDP-ZZ-00600 and related facility or procedure change programs.
If YES, process per APA-ZZ-O0 108 3,
Security Plan which also includes the Cyber Security Plan?
NO YES and $DP-ZZ-00030 for Security (See 10 CFR 50.54Q).)
Plan and related facility or
i
-X-procedure change programr APA-ZZ-00143 Page 1 CA2510 A170.OO1O Rev. 005
APPLICABILITY DETERMINATION (Continued) 4*
RadiologicalEmergency ResponsePlan (RERP) or Emergency Action Levels (EALS)? (See 10 CFR 50.54(q).)
Note: Ifyour proposed change alters a RERP IfYES, process per APA-ZZ-00 108 and KDP-ZZ-00400 for RERP and implementing procedure [any EIP-ZZ-XXXXJ, equipment L1 NO YES related facility or procedure change 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(5) [refer to KDP-ZZ-00400],
answer this question YES.
- 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(f).)
NO jYES 6.
ISI Program Plan? (See 10 CFR 50.55a(g).)
NO EYES IfYES, process per EDP-ZZ-01003 for ASME code compliance and related facility or procedure change programs.
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).)
APA-ZZ-OO 143 A170.OO1O See fP Screening questions in EDP ZZ-04044. If any ofthe screening NO E YES questions are answered YES, a Fire Protection review is needed in accordance with EDP-ZZ-04044.
IF YES, then contact Regulatory NO E YES Affairs/Licensing to determine next steps.
If YES, indicate the applicable NO Q YES program in Brief Description Section.
If YES, process change per E YES APA-ZZ-OOlOl for procedure changes or APA-ZZ-003201330/340 for Maintenance activities.
Response
- See Section 4.2.2ofthe RM NO 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.
Page 2 CA2510 Rev. 005
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?
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 NEI 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 1J 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 NET 9607 or NE1 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 ofRM 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 II of this Applicability Determination form.)
APA-ZZ-OO 143 A170.OO1O If YES, process per APA-ZZ-OO 101 for procedure changes or APA-ZZ-00605 for facility changes NO El YES or Procedurally Controlled Temporary Modifications or MDP-ZZ-fSOO1 for Freeze Seals.
Evaluate risk using APA-ZZ-003 15, Appendix A.
See Section 4.23ofthe 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 i:: NO YES column at left means that the FSARJTS 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.
Note:
A NO response in the Response column at left means that the TS El NO U 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.
See Section 4.2.4/ 4.2.6 ofthe RM.
APPLICABILITY DETERMINATION (Continued)
V.
Doesthe proposed activity involvea change to the:
Response
1.
FSAR NO UYES Process the TS Bases change per APA-ZZ-0010$ and FDP-ZZ-00 103 for revising License Documents.
VI.Doesthe proposed activity involve a change to:
p 1.
Managerial or administrative procedures, controls, or activities (including software used only for the implementation of administrative procedures, controls, or NO activities) governing the conduct of facility operations X (subject to the control 0fTOCFR5O. Appendix B)?
2.
Regulatory commitment not covered by another regulation NO based change process? (See NEI 99-04.)
U YES IfYES, process per APA-ZZ-00 101 or APA-ZZ-00 109.
O YES If YES, process per APA-ZZ-00540.
Page 3 CA2510 Rev. 005
APPLICABILITY DETERMINATION (Continued)
VII Does the proposed activity potentially affect the design, operation, or maintenance of the ISFSI facility as described in NO YES the dry cask storage FSAR or the 72.212 Report? (See FDP ZZ-00105 and Attachment 1 ofAPA-ZZ-OO 143.)
Page 4 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
.? p!forrn a 72.48 Review.
CA25 10 Rev. 005 APA-ZZ-00143 A170.0010
APPLICABILITY DETERMINATION (Continued)
VEIL Justification/explanation for Response(s) (as needed):
Ix.
Conclusion:
All aspects ofthe activity ç controlled by one or more ofthe procedures above, therefore a 5059 Screen isnot required.
LI A portion of the activity jjjt controlled by one or more ofthe procedures above, therefore a 50.59 Screen j required.
- x. Signoffs:
Qualified Preparer:
Qualified Reviewer:
Date:
Date:
1/
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 Page 5 CA2510 Revision ofthe RERP Implementing procedure is covered solely by 10CFR 50.54(q) and controlled by KDP-ZZ-00400.
Therefore, 10CFR5O59 is not required.
(Print name)
(Sign/PlN)
A170.OO1 0 Rev. 005
50.54(q) Screening Form Document #, Rev #, &
Title:
EIP-ZZ-A0066, Rev. 030, RERP Training Program El? Tracking #:
2023039 Activity Description and
References:
All the changes listed below are based off CR#202306515 and CR#202400704-028 3.3. 1
. Revised Callaway Training Course Catalog to Learning Management System 0
5.1.1. Removed T6800306/8 5.1 2. a. Removed step a. ERO Positions will have a review completed to determine the validity of the current Position Analysis. Changed step b to a and c to b
- 5. 1.2 a. Add new verbiage.
5.J.2.c. Added bullet Self-guided review of lesson plan and applicable procedures followed by discussion with ER staff or Position Owner.
5.2.3. Revised step to The Recovery Manager (RM), Emergency Coordinator (EC), and Dose Assessment Coordinator (DAC) must complete a CA3340, RERP Leadership Checklist, and Drill Certification as part of initial training. This is also indicated in the Learning Management System (LMS).
6.1.3 Added new reference, APA-ZZ-00925 Appendix A, Auto-Generated Qualification Lapse Messages.
6.1.4 Added new reference, CTM-EP, Callaway Training Manual-Emergency Preparedness.
6.1.5 Added new reference, CA3340, RERP Leadership Checklist CR# 202400704-028 Activity Scope:
YES NO Does this activity revise theRadiological Emergency Response Plan (RERP) or Impleinuitm&Procedures9 LI Change Type:
YES NO Is this activity editorial or typographicaI?
LI Previously Approved Change:
YES NO Is this activity being processed to conform to a previously approved activity9 LI If YES, 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)(1) - Assignment ofResponsibility (Organization Control)9 LI I
50.47(b)(2) - Onsite Emergency Organization9
.,.,... LI I
50.47(b)(3) - Emergency Response Support and Resources?
LI 50.47(b)(4) - Emergency Classification System?
. LI 50.47(b)(5) - Notification Methods and Procedures?
LI 50.47(b)(6) - Emergency Communications9 LI 1
50.47(b)(7) - Public Education and Information?
LI 1
50.47(b)(8) - Emergency Facility and Equipment?
LI 50.47(b)(9) - Accident Assessment7 LI 50.47(b)(l 0) - Protective Response?
LI 50.47(b)(1 I) - Radiological Exposure Control?
LI 50.47(b)(12) - Medical and Public Health Support9 LI 50.47(b)(13) - Recovery Planning and Post Accident Operations?
LI l
50.47(b)(14) - Drills and Exercises7 LI 50.47(b)(15) - Emergency Responder Training9 LI 50.47(b)(16) - Emergency Plan Maintenance9 LI Part 50 Appendix E?
LI L
Commitment Impact Determination:
YES NO Does this activity impact a Site Specific EP Commitment not associated with a Planning Standard or Element9 LI If Yes, record the Commitment number:
File#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 clarfication)
None ofthe planning standards in 1O.CFR5O.47(b) nor 10CFRPart 50 Appendix E were impacted by any ofthe above changes.
Therefore a 1O.CFR 50.54(aj screen evauation is not required for the changes.
Screening Evaluation Results:
Based on the results ofthe information above, can the activty be implemented without performing a YES NO full 50 54(q) Effectiveness Evaluation9
- r:;:zz;z.
Date: i l Preparer must be quaflfied Emergency Response Coordinator.
Reviewer (Sign/PIN)
Date O%, -%/
Emergency Preparedness Manager ($ignIN):)
C3i Date:
File # A210.0038 Page 2 of2 CAl 523 KDP-ZZ-00400 Rev. 002
Reference Tracking Parent Document No.:
EIP-ZZ-A0066 Revision No.: 030 Reference Transaction Director Item (Document, Characteristic, Director update complete Code Synopsis, CAR, etc.)
Add Delete Initial YY MM DD LI APA-ZZ-00925 APPENDIX A, AUTO-
,i GENERATED QUALIFICATION LAPSE MESSAGES El CTM-EP, CALLAWAY TRAINING I
I MANUAL - EMERGENCY PREPAREDNESS El CA3340,RERPLEADERSHIP CHECKLIST El U
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I LLJ Il Page 1 of 1 CA0134 Rev. 000