ML24256A076

Review Form - Radiological Emergency Response Plan (RERP)

ML24256A076
Person / Time
Site:	Callaway
Issue date:	07/25/2024
From:	Bassford J Union Electric Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
Download: ML24256A076 (1)

Text

PROCEI)URE REVIEW FORM (PRF)

IA)

Initiation Initiator: John Bassford Date: 07/25/2024 Pmeedure Dept EP Document #: RERP New Rev. #

056 digits tcquiredj

Title:

Radiological Emergency Response Plan (RERP)

Level of Use UContinuous fll{eference flinfonnation MuItiple SN/A 2.0 Rcason for Change/I)escription of Change (List commitrncnts, CRs, eB (hange Requests, OERs, P/tint Alods etc. and neord nitmhe,:s here.)

CR 202404965, see attached Summary of Changes for RERP Revision 056 document.

ton(unted r:i 3.0.

Document Disposition UTemp Change UNew I)ocunwnt Major Revision Minor Revision ElCaneellation flAdministrative Correction N/A

4.0 Interim Approval (Temp. Qiange Only)

Temp. Change #:

Expiration Date:

N/A N/A (ogni ant Supet isu ( S ignature P 1 N t)atc )

S RO ( Sigriatut e Fl N t)i Ic

5.0 Comments

Continued. ID Reviews Required t)cpt PIN

.S%pwturc I

I)ate C40139 4ttacIzed Prepoier EP 76380

/

. 7-2 :

N/A Technical Review I EP 76380 %;

/

- f

. 729 Z,f

, U Yes No Tcdmica1Rti,iev Icf ncFd (jC...:

T

,/-&,zj L\\es tJNo AddI Review

[1 Yes No Addl Review U ye5 EJ No i:iAdditional Reviews (Sec Attached C4OIJ9forms).

Number of additional Co I 39s:

i Coordinator - PIN Sigiwtu;v Date CA0139 Attached

- t----

50.59 Review (A25 I 0

. DCA25 I 1 HCA25 1 2 / UN/A (ocr ALA-I! (10143)

,, I k Ui 1 hutial PtA kti t er bestial / Plv (Dept. Head or Designated Approver) Is a Change Management Plan required? Yes UNo (IF YES, attach CA273 or CA2774 Is a Cross-l)iscipli liar) review_re(Iuired?

UYes EJ o

7.0 S..pproval (Eitbcet approeab must he qzuxb{fIcc! as P.1 T4PJ 7? or P. IT U.4PR be QuabStcLste I)

LI Senior Director Nuclear Operations Approval (per AP%7Z-OOl() I )

ORC is required in accordance with AP%ZZ-0009 I 1 I )epanmeit Head Final Review and Approval CRC Meeting:

cc::#zpbL; 13c7

/t4M4 4ttt 6376 *1-2-r Dept. head or I )esigiiate Approver Senior Director Nuclear Operations (Sigriatuic PIN t)atei I Signature PIN l)ate)

J ye. Pag. 2 i iidcv iastIIetEo;a to this theta aad ran ir dosated Al 9OMt)O I, 2, 5 35 A2 I OMtTh2. 65. 6%; tsl I 9O,00() I Page 1 of 2 C\\.(JO33 APA-ZZ4)O1OI Rev. 002

Summary of Changes for RERP Revision 056

1. Changed Public Alert System to Alert and Notification System to align with industry standards (p. 6 (3), p. 48 (1), p. 72 (4), p. 73 (1),

p. 103 (1), p. 110 (1), p. 111 (1), p. 134 (2), p. 135 (3), p. 137 (1))

CR 202404965

2. Removed various Identifiers for sirens Outdoor Warning Fixed Sirens, Fixed Sirens, Fixed Outdoor Sirens, Warning Sirens, Public Alert Sirens and changed all references to Sirens for consistency (p. 72 Outdoor Warning Fixed Sirens, p. 134 Fixed Sirens (3), p. 135 Fixed Outdoor Sirens/Warning SirensfPubilc Alert SirensfFixed Sirens) CR 202404965

3. Changed DOH and Department of Heaith references to DHSS and Department of Health and Senior Services to align with the current identification (p. 8, p. 17, p. 43, p. 47 (5), p. 48 (12), p. 72, p. 73 (2),

p. 79, p. 105, p. 114, p. 116) CR 202404965

4. Changed Environmental Inc. Midwest Labs to Radiological Sampling Laboratory as Cailaway Energy Center changed laboratory vendors to process radiological samples. Radiologicai Sampling Laboratory is a generic term to be used in the RERP, Appendix C to avoid having to revise the RERP in the event iaboratory vendors change (the current vendor is Teledyne Brown, and a copy of their LOA is on file) CR 202404965

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

Title:

RERP Revision 056, Radiological Emergency Response Plan EP Tracking #:

2024022 Activity Description and

References:

CR 202404965, see attached Summary of Changes for RERP Revision 056 document.

Activity Scope:

YES NO Dts this aci reisc thu R4diolnLlL 11 1 ni i itii Rioii Plan RI RI or lnm3un niwi. FrocLduies Change Type:

YES NO editorial (W tVfWifl)

.hical?.

Previously Approved Change:

YES NO Is this activity being Processed to conform to.t PreviouslY approved activity?

El If 1ES, whaE is the ptvitmsly ajit\\ cd acti ty?

Planning Standard Determination:

Does this activity impact any of the 5047(b) Planning Standards or Part 5() AppendIx E:

IFS Nt) 5t)47(b)(1)

- Assignment of Responsibility (Organization Control)?

D 5047(b)(2)

- Onsite Emergency Organization?

El 5OA7tb)t3)

- Emergency Response Support and Resources?

.. Li Xl 5tL47(b)4)

- ElnelgetiCy Classificalion System?

[El 5047(b)(5 )

- Notification Methods and Procedures?

L 5t).47(h)(6)

- Emergency Communications?

Li 50.47(b)(7)

Public Education and Intormation!

Li Xl 5tL47(h)(8)

- Emergency Paciliiy and Equipment?

LI Xl 5t)47(h)(9)

- Accident Assessment?

,. **,,.. D Xl 5tL47(h)(lt))

- Protective Response?

.... D 5tL47(h)( I 1)

IiI(fiOh)giCai EXpOSUre Control?

5O47(h)( I 2)

- Medical and Public Health Support?

J 5tL47(h)(13)

- Recovery PLanning and POSt Accident operations?

0 5t),47(h)(14) 1)illls and Exercises?

5047(h(15)

Emergency Responder Training?

......., D 50A7(h(16

- Emergency Plan Maintenance?

., U Part 5t) Apndix E?

U Commitment Impact Determination:

YES NO Does this activity inpaet a Site Specific EP Commitment Ili)t associated with a Planning Standard of Element?

If iTes, record the Cotninitinent nunhcr.

Explanation of Determination: (Enter an explanation to each determinatton W1SWCI that needs clatijication.)

All these changes are administratEve in nature except for the incorrect radologicat laboratory vendor listing in Appendix C. Planning Standard 9, Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use is not impacted by this change. In addition, Part 50, Appendix E states Adequate provisions shall be made and described for emergency facilities and equipment, including: Equipment for determining the magnitude of and for continuously assessing the impact of the release of radioactive materials to the environment. This also is not impacted by this change. This specific change to the RERP simply replaces the incorrect vendors name with a generic identification of Radiological Sampling Laboratory so that Appendix C is in alignment with the currently contracted vendor.

File # A2IOOQ38 Page 1 of2 CA1523 KI)P-ZZ-Ot)40t)

Rev. 002

50.54(q) Screening Form Screening Evaluation Results:

Based Ofl the results of the information above, can the activity be implemented without performing a YES NO full 505 101) Effeckeness fivaluation?

[El Review/Approval:

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Ri 1(31 ii flit it tLi!itH Five. çcv I Respi: cc (ThmJi,iutoi Emergency Preparedness Manager (Sign/PIN):

!k17 Date:

File # A210.003%

Page 2 of 2 CA 1523 KDPL-OOTOO Re\\ 002

APPLICABILITY DETERMINATION Address the questions below for all aspects of the activity. If the answer is YES for any portion of the activity, appiy 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.

Activityfflocumciit Number: RERP

Title:

i!1E:al !I1c!:acpcy Response Plan Revision Number: 056 Brief Description of activity (what is being changed and why):

I

( R 20240496%, se attached Summ of Changes for RFRP Revision 056 document IL the proposed activity fall within the scope of an activity that has been previously approved by the NRC or for which a 5t).59!7248 Screen or evaluation has already been perfbrmed?

(See Section4.2 ofthe RM.)

IfYES, no further 50.59 (or 7248) review beyond this Applicability Determination (AD) is required, but

Response

complete the remainder of this form.

Identify the applicable 50.59/72.48 Evaluation Log No., License Amendment No., or applicable document numbef.

Document #

III.

Does the proposed activity involve a change to the:

Response

I.

Technical Specifications or the Renewed Operating License?

(Sec 10 CFR 5O.)U.)

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 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.

CA25It)

Rev. 005 NO EjYES 2.

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

NO El YES See Section 4.2.1 ofthe RM.

No n YES IfYES, process per APA-ZZ-00108 and FDP-ZZ-OO 103.

IfYES, process per APA-ZZ-Q0 108 and GDP-ZZ-00600 and related facility or procedure change programs.

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

IfYES, process per APA-ZZ-00 108 U NO YFS and KDP-ZZ-00400 for RERP and k-:

.. related facility or procedure change programs.

APA-ZZ-001 43 A170.OOlt)

Page 1

APPLICABILITY DETERMINATION (Continued)

IfYES, proce8s APA-ZZ40356 for ASME codc compliance and related

&cilky or procedure change prograM.

5. 1ST Program Plan? (Sec 10 CFR 5O.55aft).)

0 NO Q YES ff1ES, process per EDPZZ-01003 for ASME code compliance and related facility orprocedure change programs.

6.

151 Program Plan? (See 10 CFR 50.55a(g).)

0 NO Q YES See PP Screening questions in EDP ZZ-04044. Ifany ofthe screening

7. Fin Protection Program? (See Operating License NO r] YES questions an answered YES, a Fire Condition 2.C(5).)

Protection review is needed in accordance with EDP-flr04044.

8.

Storage Cask Certificate ofCompliance (CoC), inclading

fl, then contact Regulatory appendices? (See 10 CFR 72.244.)

0 NO Qs Affairs/Licensing to determine nat 9.

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

the ODOM) that are controlled by regulations, the Operating license (including Orders and license E indicate the applicable Conditions) or die Technical Specifications? (See Section 0 NO D YES program in BnefDescdpdon 4.2.1 ofthe RM.)

Section.

I I

w. Does the proposed activity involve:

itesponse See Section 4.22 ofthe RM I

I

1. Maintenance which restores SSCs to their original(as I

designed) condition? (See 10 CFR 50.65(aX4).)

IfYES. process change per APA.ZZ-OOlO1 for procedure Note: Ifthe maintenance is on ISFSI or cask-related items, NO 1] ms ciianges or APA-ZZ-00320/330/340 the Maintenance Rule does NOT apply, and the activity is forMaintenance acdvide&

subject to a 10 CFR 72.48 Screen on a CA3 145.

IfYES, process per APA-ZZ-OO1O1 for procedure changes or APA-ZZ-00605 for facility changes

2. A temporary attention (to procedures or the facility) supporting maintenance (FASM) that will be in effect 0 NO [I YES ° ° during at-power operations for 90 days orless?

Temmwaiv Modifications or MDP-fl-FSOO1 for Freeze Seals.

Evaluate risk using APA-ZZ-00315, Appendix k APA-ZZ-00143 Page 2 CA25 10 A170.0010 Rev. 005

APPLICABILITY DETERMINATION (Continued)

V.

i)oes the propose1 aci-iiy involve a clningc to the:

L FSAR jNo EjYES If the above response is NO, check N/A in the Response c(:)1unn at right.

If the above response is YES, does the proposed activity involve an fSAR change that may be excluded from the requirement to perform a 5t)i9 Screen/Evaluation by NEI 96O7 or NFl 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 niay aso be provided if the FSAR change requires no further 50.59 review based on a YhS response to the question in Section II of this Applicability Determination fomij 2.

Technical Specification Bases?

NO LI YES If the above response is NO, check N/A in the Response colurnii 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 NFl 96 t)7 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 t)fthe exclusion criteria ofRM Section 4.23. a YES response may also be pn)vided if the IS Bases change requires no further 5059 review based on a YES response to the question in Section II of this Applicability i)etemination form.)

vi.

Does the proposed activity iiivolve a chaiige to:

I v1anageriaI or administrative procedures, controls, or activities (including software used oniy for the inpIeinentation of IdmifliStratiVe procedures, controls, or activities) governing the conduct of facility operations (sublect to the control of IOCfR5O. Appendix BY!

2.

Regulatory commitment not covered by another regulation based chamc process? tSec NFl 99-04)

Response

See Section 42.3 of the RM Process the fSAR change per APAZZM0108 and FDP-ZZ-001 03 for revising License Documents.

Note:

A No response in the Response L:J NO El vis column at left means that the fSARiTS 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 5(3.59 review.

Process the 1S Bases change per APA-ZZ-00 I 08 and FDP-ZZ-()0 103 for revisi;;g License Documents.

Note:

A NO response in the Response column at left means that the TS NO ci s Bases change is one that requires further 5059 review (ic., is not NA excludable from further review).

A YES response means that the TS Bases Change does NOl require further 50.59 review.

Response

See Section 42.4 1 426 ofthe RM.

NC) LI YES IfYES, process per APAZZ-00 101 or APA-ZZ00lt)9.

IfYES. process per APAZZ00540.

IfYES, perform a 72.48 Scree;; per APAZZ-0t)143 unless the change is completely covered by the response to Secti:n II.

ote:

Editorial or administrative changes are excluded from the requirement to ie1rm a 72.48 Review.

CA25 it)

Rev. t)05 NO flYES VII I)oes the proposed activity potentially affect the design, operation or mamntenanLe of thc ISFSI fmcility as descrt&d in the dry cask storage FSAR or the 72.2 12 Report? (See FDP-

£ ZZ-t)0105 and Attachment I of APA-ZZ-0t) 143.)

APA-ZZ-O() I 43 I I 7()t)0 I 0 Page 3

APPLICABILITY DETERMINATION (Continued)

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

Changes referenced in the Summary ofChanges apply to the RERP change process and 50.59 does not apply.

Ix.

Conclusion:

All aspects of the activity are controlled by one or more of the procedures above, therefore a 50.59 Screen isnot required.

LI A pgjpj of the activity controlled by one or more of the procedures above, therefore a 50.59 Screen is required.

x Signoffs:

) )

Quahikd Prcpaier f t- ( 7 C :

__) fL3 DatL ) ?

I I

(Print name)

(SignJPIN)

Qualified Reviewer:

cP\\

Date: //%9-(Print name)

(Sig;i/PIW3 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 APAZZ-OO22O.

APA-ZZ-00143 Page4 CA2510 A170.OO1O Rev. Ot)5

PRIMARY LICENSING DOCUMENT CHANGE FORM FOR RERP OR ASSOCIATED EIPS Document & Rev #:

RERP Rev. 056 I

Originator:

Jpi-ni Bassford Date: 07/25/2024 2

Plan Section(s) j Tabe ofContents, Section 1.1, 1.2, 5.2i0.7, 5.3.2.2.1, 5.3.2.2.2, 5.3.2.3, 61.2, 6.72.1, 67.22, 6.7.2.3, Table 6-1, 8.0, 8.12, 861.1, 8.61.2, 92.6, 9.5, 9.6, Appendix C, Appendix H, Figure H-i

References:

ICR 202404965

4. s this change evaluated under an existing License Document Change per APAZZ-OO14O?..

LI Yes ENo If Yes aliach a copy of the change paperwork or provide rcferencc (CMP, RFR, etc.)

If No, an evaLuation Sh()tlld he pClit)rme(1 afl(.1 attached or provide sufficient iflh)rrflatiofl for conipletion ol the evaluation by the responsible department.

fr-Description of Change:

See attached Summary of Changes for RERP Revision 056 document.

6 Justification

A! these changes are administrative in nature except for the incorrect radiological laboratory vendor listing in

!!Appendix C. Planning Standard 9, Adequate methods, systems, and equipment for assessing and monitoring 1actuaI or potential offsite consequences of a radiological emergency condition are in use is not impacted by this change. In addition, Part 50, Appendix E states Adequate provisions shall be made and described for emergency facilities and equipment, including: Equipment for determining the magnitude of and for continuously assessing the impact of the release of radioactive materials to the environment. This also is not impacted by this change.

This specific change to the RERP simply replaces the incorrect vendors name with a generic identification of Aadiological Sampling Laboratory so that Appendix C is in alignment with the currently contracted vendor.

KDP-ZZ-00400 Page 1 tf 3 CA0667C Rev. 003

PRIMARY LICENSING DOCUMENT CHANGE FORM FOR RERP OR ASSOCIATED EIPS

7. Originating Department head Approval I

n S PZ i3 ¶7

8. Concurrence with Need for Change Approved:

Change (oon1iiucir.

%$?

SAMG Coordinator (EAL Change Only)

Manager, Emergency Preparedness:..

Date:

r-- %o;(,

Offsite : (Ifa chutige to EALs or (1/direLt co!;ce17z)

Callaway ( Ount Gasconade County:

Montgomery County:

Osage County:

SEMA:

Others:

KDP-%ZMO400 Page 2 of 3 CA0667C Rev. 003 Rejected: El Review of Proposed Changes Revision No. o5

/!

Date

PRIMARY LICENSING DOCUIENT CHANGE FORM FOR RERP OR ASSOCIATED UPS Did this change modify information displayed on the Sentry Notification System?

[1 YES N()

11 ES piioi to sigarng be1ov bNSLJRE p1dflS ire in place to modify the Senir znfoimnion at the same time this revision is issued.

Change Coordinator:

(Review (-tfFinal Packagefbr Completeness.

ensure RERP Appendix B has been signed by the 3

CNO faimlieable ).

,,(:

Change Coordinator:

(Provide infi)ifll(ltjOtI for UI]JRC letter to Regulatory 4tfiuirs)

KDP-ZZ-00400 Page 3 of 3 CA0667C Rev. 003 Approval of Proposed Changes Al) ?mYcilIkv; Manager, Emergency Prepairdness:

(37 Senior Director Nuclear Operations:

(tiriot Previous&v signed on CAOO33)

RERP Rev. 056 Appendix B Policy Statement Scope of Authority and Responsibility of Emergency Coordinator and the Recovery Manager Sheet 1 of I In the event of an emergency which requires the implementation of the Caflaway Plant Radiological Emergency Response Plan (RERP), the Emergency Coordinator and Recovery Manager are authorized and have the responsibility to:

a.

Evaluate. classify, and declare emergencies.

b.

Activate and direct the Emergency Response Organization.

C.

Direct that off-site authorities be notified.

d.

Make protective action recommendations for the protection of the general public and site personnel; and C,

Request off-site assistance.

Additionally, until such time that the emergency is terminated, or control is assumed by a superior corporate officer, the Emergency Coordinator and Recovery Manager are vested with the authority to commit Ameren resources which may be necessitated by an emergency situation. These resources include personnel, equipment, and funds.

Authoizatiom Date fadi M. Diya Senior Vice-President and Chief Nuclear Officer Page 128 tit 14t)

Appendix B

Abbreviated Change ChecklIst Directions:

Change Owner (or designee)

- COMPLETE items as appropriate during the change process and IF this checklist is determined to be inadequate for the scope of the change. or IF the scope changes. SWITCH to Form CA2774, Comprehensive Change Checklist.

PcLJeckjL!i Name of the Change RERP Revision 056 Change Owner (Name/Title)

John Bassford/EP Coordinator I.

Briefly DESCRIBE the proposed change.

2.

ENSURE the change is defined and understood by all stakeholders.

3.

DETERMINE what needs to be done to accomplish the change.

I.

DETERMINE if this change impacts:

Yes No LI Nuc1ear/industriaI Safety, Dose or Reliability LI Primary Licensing Documents (50.59, 50.54, Technical Specifications, FSAR, RERP, Security Plan, OQAM, etc.) See APA-ZZ-00108 for requirements for timely submittals.

LI i I Training & Qualifications of Personnel Training Request #

El Procedures or Commitments LI I I Business Plans or Budget (Refer Asset Management Board Governance Charter)

LI

[1 Computer programs/Electronic signatures lxi [1 Other Organizations I :i ii Personnel Changes Stakeholders 1

DETERMINE who (groups, departments, individuals) will be affected by this change and where they stand in terms of support f)r the change.

2.

DETERMiNE ifTraining Department support will be required to implement the change (e.g. conduct training for departments/site on new change. revise existing classroom instruction material, participate as a member ofthe Change Management team).

3.

IF change impacts a group, department or individual, CON1ACT affected participant(s) for their input.

i%!!watio.aE1M!

I DEVELOP an implementation Plan (reference Attachment 4 of APA-ZZt)1 400 Appendix J).

2.

ENSUR E. required procedure revisions are identified.

APA-ZZ-01400 Appendix 3 Page 1 of2 CA2773 AlIO.t)315 Rev. 000

Communications Plan 1

C(ThSULT with Communications personnel to develop an effective communication plan (reference of APA-ZZ-O1 400 Appendix J).

(1ornpIctd by

/}

7%

C Date

?

F Change t) ner I PiN Number Approved By: ____ :_

Date:

Dept. Head or Manager I PIN Number APiZZ-t)I4OO Appendix J Page 2 of2 CA2773 A I I (). 03 *i 5 Rev. 000