ML24290A116
| ML24290A116 | |
| Person / Time | |
|---|---|
| Site: | South Texas, 07201041  |
| Issue date: | 10/16/2024 |
| From: | Hill M South Texas |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NOC-AE-24004075, STI: 35654674 | |
| Download: ML24290A116 (1) | |
Text
NOC-AE-24004075 Attachment
Attachment
Summary of Analysis and Description of Changes to the STPEGS Emergency Plan NOC-AE-24004075 Attachment Page 1 of 9
- 1. Emergency Plan (EPlan), EP-0001.002 Change Summary:
The new revision replaces the dedicated automatic ringdown lines as the primary means to notify state and county agencies with a computer-based notification system, referred to as the Electronic Offsite Notification System (EONS).
Change justification:
Through the use of common-place, current technology that replaces dated manual systems, the required state and local event notification process is made more reliable, and implementation procedures are simplified. There is no change to the agreed-upon information content of the required state and local event notification messages. The revised EPlan continues to comply with all applicable regulatory requirements.
- 2. On-Shift Staffing Analysis (OSA), EP-0002.001 Change Summary:
The implementation of an electronic notification system provided the opportunity to consolidate the Emergency Response organization ( ERO) tasks for completion, approval and transmission of the required state and local event notification messages which were divided between the On-shift State & County Communicator and the Shift Manager. The analysis in the revised OSA demonstrated that these tasks could be combined and assigned to the Shift Manager/Emergency Director.
Change justification:
The actions for the notification tasks are simplified by the new EONS system. On-shift Staffing Analysis (OSA) demonstrated that no task overburden was created by this change and all tasks could be performed to meet EPlan timing requirements. The revised OSA continues to comply with all applicable regulatory requirements.
- 3. Emergency Action Level (EAL) Technical Basis Manual (TBM), EP-0003.001 Change Summary:
The implementation of EONS results in the inclusion of the electronic notification system as part of the available means of offsite notification as described in the EAL Technical Basis Manual for Initiating Conditions (IC) CU5, EAL-2 and SU6, EAL-2 (loss of the communications methods used to notify all OROs of an emergency declaration) and the associated bases sections.
Additional editorial changes to align ERO titles and document numbering for EPlan Security positions were made to Table H1, which is used for ICs HU1, HA1, HS1 and HG1.
Change justification:
The new electronic notification system is the primary means of completing the required state and local event notification and it was added to the list of components to be assessed for an event constituting a loss of the communications methods - EAL #2 for Offsite Response Organization ( ORO) emergency declaration notification methods. The availability of any plant telephone line allows the ORO notification to be completed. Therefore, there is no change in capabilities and no change in the ability or timeliness of the ERO to recognize that the threshold conditions have been met for the ICs CU5 and SU6 (EAL-2 for each).
The change to Table H1 aligns the TBM to current EPlan titles and does not result in any changes to approved IC / EAL assessment processes or timing.
The revised TBM continues to comply with all applicable regulatory requirements.
NOC-AE-24004075 Page 2 of 9
Change Synopsis Proc.: EP-0001.002 Rev.: 2
Title:
STPEGS Emergency Plan Description / Reason for Change:
- Modify EPlan to reflect implementation of Electronic Offsite Notification System description (E.1.2) and associated equipment description (F.1.2).
- Etio crtmting issue f Table B -
Item Current Proposed Type / Justification 1 Section E.1 Section E.1 Change
- 2. State and County Event Notification 2. State and County Event Notification EONS replaces the current event Notifications are made Notifications are made notification process and systems, simultaneously via dedicated simultaneously via an electronicwhich involve three separate automatic ringdown lines to State offsite notification system to the immediate activities (form, phone, personnel in the Department of State of Texas and Matagorda fax) with a single electronic system Public Safety Communication County. that performs all three event Center located at the Sub District notification activities (email).
Office and to county personnel Through the use of common current located in the Matagorda County technology to replace dated systems, Sheriff's Office. the event notification process, and thus the procedures to perform that process, are simplified. The use of EONS does not change the agreed upon event information content of the notification messages.
This change continues to meet the requirements of Planning Standard 5.
2 Section F.1 Section F.1 The current system uses a dedicated
- 2. Offsite Communications Systems 2. Offsite Communications Systems automatic ring-down telephone system to verify receipt of the B. Dedicated Automatic B. Electronic Offsite Notification notification. Both EONS and the Ringdown Lines - Dedicated System (EONS) - A system current telephone system contact automatic ringdown lines allow capable of sending emails and state and county warning points that immediate and direct contact with phone calls to provide event are staffed 24/7. The current system the Matagorda County Sheriff's notification to Matagorda County requires a dedicated communicator Office and the Texas Department of and the State of Texas. to verbally transmit and verify receipt Public Safety, Sub District Office. of the notification whereas EONS monitors for receipt acknowledgement as part of system function. EONS messaging is broader than the current system and frees up the user from having to provide full attention to the task.
This change continues to meet the requirements of Planning Standard 6.
NOC-AE-24004075 Page 3 of 9
Change Synopsis Proc.: EP-0001.002 Rev.: 2
Title:
STPEGS Emergency Plan Continued Item Current Proposed Type / Justification 3 Offsite FMT composition listed under Offsite FMT composition listed under This is a Table B-1 formatting TSC/OSC, 90 min. EOF/JIC, 90 min. change. The Offsite Field Monitoring Teams (Technician and Driver) are currently identified and tasked in the EOF as 90 minute required responders. See B.1.a.4.H (Technician) and B.1.a.4.I (Driver) on page 22 of this version above. This Table formatting change does not alter any responsibility or action contained in any current guidance documents.
Current:
Proposed:
NOC-AE-24004075 Page 4 of 9
Change Synopsis Proc.: EP-0002.001 Rev.: 1
Title:
STPEGS On-shift Staffing Analysis Description / Reason for Change:
- Revise the STPEGS on-Shift Staffing Analysis, EP -0002.000 (OSA) to incorporate the results of a new OSA conducted per NEI 10- 05 in November of 2022 and modified with demonstration of the Electronic Offsite Notification System (EONS). The OSA was re-written to be fully compliant with the formatting and content of NEI 10-05. This represents a General Revision to the OSA. Rev bars and a detailed change synopsis were not used.
Item Current Proposed Type / Justification 1 Global changes to body of document. Tables, sections and content were Change - No change of intent.
changed to match the industry-standardStandardize text in all applicable format for an On-Shift Staffing Analysissections and tables in the body of the using NEI 10-05 as guidance. document for standardization with 0EPM04-UA -0001, EPM/EPR Writers NEI 10-05 and updated for new EPlan Guide was also used for formatting document references.
guidance.
2 Changes to Attachment 2, All Event General Revision / Full Re-Write. Changes to all event tables in data tables. Attachment 2 from the results of a full OSA per NEI 10- 05.
Task changes represent the consolidation of the tasks for filling out, approving and transmitting the Offsite Notification Message. These tasks are being moved from the CR State & County Communicator to the Shift Manager. The actions for these tasks are simplified by the new EONS system. There is no task overburden created by this change. The task timing is improved.
NOC-AE-24004075 Page 5 of 9
Change Synopsis Proc.: EP-0003.001 Rev.: 1
Title:
STPEGS Emergency Action Level Technical Basis Manual Description / Reason for Change:
- Incorporate several editorial changes.
- Revise the STPEGS Emergency Action Level Technical Basis Manual to incorporate the results of the change to the STPEGS Emergency Plan to the new Electronic Notification System.
Item Current Proposed Type / Justification 1 Title Page Title Page Editorial STPEGS Emergency Action Level STPEGS Emergency Action Level Correct typographical error. Title is Basis Technical Bases Manual Technical Basis Manual not Bases 2 Page 88, IC HU1, Table H1: Page, HU1, Table : Eti e prio emgency a e S Table H1: Security Supervision Table H1: Security Supervision sed t t Acting curity
- Sitycevis
- Sitycevis Manager. Nth e iivi nor e
- Acting Security Manager
- TSCity Coornat sksosion c upon tivatn
- Sity e EPlan. t new y a there e r t d e r a cnge e new Emy Pl, e Secuty Mang t cuty Coorn.
3 Page, HU1: EAL -1 Secti Page, HU1: EAL -1 Secti Eti Ba Ba e prio emgency a e S For EAL-e positi cuty For EAL-e positi cuty sed t t Acting curity Foe Svis w id n Foe Svis w id n Manager. Nth e iivi nor e a - sition. Normally t a - sition. Normally t sksosion c upon tivatn t would n rt e t would n rt e e EPlan. t new y a Acti cuty Manager cuty T Sity Conat cause there e r t d e r Manager cse e Acng cuty e T Sury Conat positi a cnge Manager siti not normally t normally tiv until after e new Emy Pl, e Secuty tiv til after UAL T has been dled. ver, Mang t cuty T has cled, a e rti e T Secuty Coorn.
cuty M positi t Coorn w cd t ent norm tat until after is pitn m sfd der T has been dled. ver, ual rmstance rti e Acti cuty Manager cuty M s iluded e e these sitions a staffed der unusual rcuman 4 Page, HU1: EAL -1 Rc: Page, HU1: EAL -1 Rc: Eti 01-ZV -SH03, v. 12, ting 0EPR02-PS05, R Sity Uing edure ree. e cuty M Foe Svis ious y an, e sed t t Acting curity Manager.
5 Page, HU1: EAL -1 Rc Page, HU1: EAL -1 Rc Eti 01-ZV -TS, Re 1 Sity 0EPR02- -TSC05, R C Uing edure ree. e new Manager cuty Conat Emy Pl, t Secuty Mger e Sury Conat.
6 Page, 1, Tae : Page 98, IC HA1, Table H1: Editorial In the previous emergency plan, the SFS Table H1: Security Supervision Table H1: Security Supervision assumed the title of Acting Security
- Security Force Supervisor
- Security Force Supervisor Manager. Neither the individual nor the
- Acting Security Manager
- TSC Security Coordinator tasks/position changed upon activation of
- Security Manager the EPlan. In the new emergency plan, there is no title for the SFS and the roles are unchanged.
In the new Emergency Plan, the Security Manger is the TSC Security Coordinator.
NOC-AE-24004075 Page 6 of 9
Change Synopsis Proc.: EP-0003.001 Rev.: 1
Title:
STPEGS Emergency Action Level Technical Basis Manual Continued Item Current Proposed Type / Justification 7 Page 99, HA1: EAL-1 and EAL-2 Page 99, HA1: EAL-1 and EAL-2 Editorial Selection Basis Selection Basis In the previous emergency plan, the SFS The EALs are taken from NEI 99-01, The EALs are taken from NEI 99-01, assumed the title of Acting Security Rev. 6. For EAL-1, the positions of Rev. 6. For EAL-1, the position of Manager. Neither the individual nor the Security Force Supervisor OR Acting Security Force Supervisor was tasks/position changed upon activation of Security Manager were included included since it is a 24-hour position. the EPlan. In the new emergency plan, because either of these positions Normally the event would not be there is no title for the SFS and the roles could be activated prior to meeting reported by the TSC Security are unchanged.
this EAL. The Security Force Coordinator because the TSC In the new Emergency Plan, the Security Supervisor is a 24-hour position and Security Coordinator position is not Manger is the TSC Security the normally the Acting Security normally activated until after an Coordinator.
Manager is activated after an ALERT has been declared. However, UNUSUAL EVENT has been reporting by the TSC Security declared. The Security Manager is Coordinator was included in the event also included although this position is this position may be staffed under normally activated after an ALERT. unusual circumstances.
8 Page 99, HA1: EAL-1
References:
Page 99, HA1: EAL-1
References:
Editorial 0ERP01-ZV -SH03, Rev. 12, Acting 0EPR02-CK -OPS05, Rev 2, Security Updating procedure reference. In the Security Manager Force Supervisor previous emergency plan, the SFS assumed the title of Acting Security Manager.
9 Page 99, HA1: EAL-1 References Page 99, HA1: EAL-1 References Editorial 0ERP01-ZV -TS08, Rev. 16, Security 0EPR02-CK -TSC05, Rev 2, TSC Updating procedure reference. In the new Manager Security Coordinator Emergency Plan, the Security Manger is the TSC Security Coordinator.
10 Page 54, IC CU5, References EAL #2 Page 54, IC CU5, References EAL #2 Editorial Updating procedure reference.
0PGP05-ZV -0011, Rev. 8, 0EPR01-IP -0002, Emergency Emergency Communications Notifications 11 Page 123, IC SU6, References EAL Page 123, IC SU6, References EAL Editorial
- 2 #2 Updating procedure reference.
0PGP05-ZV -0011, Rev. 8, 0EPR01-IP -0002, Emergency Emergency Communications Notifications 12 Page 104, IC HS1, Table H1: Page 104, IC HS1, Table H1: Editorial In the previous emergency plan, the SFS Table H1: Security Supervision Table H1: Security Supervision assumed the title of Acting Security
- Security Force Supervisor
- Security Force Supervisor Manager. Neither the individual nor the
- Acting Security Manager
- TSC Security Coordinator tasks/position changed upon activation of
- Security Manager the EPlan. In the new emergency plan, there is no title for the SFS and the roles are unchanged.
In the new Emergency Plan, the Security Manger is the TSC Security Coordinator.
13 Page 105, HS1: EAL-1 Selection Page 105, HS1: EAL-1 Selection Editorial Basis Basis In the previous emergency plan, the SFS The positions of Security Force The positions of Security Force assumed the title of Acting Security Supervisor, Acting Security Manager, Supervisor and TSC Security Manager. Neither the individual nor the and Security Manager were included Coordinator were included because tasks/position changed upon activation of since any of these positions could be either of these positions could bethe EPlan. In the new emergency plan, activated prior to meeting this EAL. activated prior to meeting this EAL. there is no title for the SFS and the roles The Security Force Supervisor is a The Security Force Supervisor is a are unchanged.
24-hour position, the Acting Security 24-hour position and the TSC In the new Emergency Plan, the Security Manager is activated after an Unusual Security Coordinator is activated after Manger is the TSC Security Event has been declared and the an ALERT has been declared. Coordinator.
Security Manager is activated after an Alert is declared.
NOC-AE-24004075 Page 7 of 9
Change Synopsis Proc.: EP-0003.001 Rev.: 1
Title:
STPEGS Emergency Action Level Technical Basis Manual Continued Item Current Proposed Type / Justification 14 Page 105, HS1: EAL-1
References:
Page 105, HS1: EAL-1
References:
Editorial 0ERP01-ZV -SH03, Rev. 12, Acting 0EPR02-CK -OPS05, Rev 2, Security Updating procedure reference. In the Security Manager Force Supervisor previous emergency plan, the SFS assumed the title of Acting Security Manager.
15 Page 105, HS1: EAL-1 References Page 105, HS1: EAL-1 References Editorial 0ERP01-ZV -TS08, Rev. 16, Security 0EPR02-CK -TSC05, Rev 2, TSC Updating procedure reference. In the new Manager Security Coordinator Emergency Plan, the Security Manger is the TSC Security Coordinator.
16 Page 109, IC HG1, Table H1: Page 109, IC HG1, Table H1: Editorial In the previous emergency plan, the SFS Table H1: Security Supervision Table H1: Security Supervision assumed the title of Acting Security
- Security Force Supervisor
- Security Force Supervisor Manager. Neither the individual nor the
- Acting Security Manager
- TSC Security Coordinator tasks/position changed upon activation of
- Security Manager the EPlan. In the new emergency plan, there is no title for the SFS and the roles are unchanged.
In the new Emergency Plan, the Security Manger is the TSC Security Coordinator.
17 Page 110, HG1: EAL-1
References:
Page 110, HG1: EAL-1
References:
Editorial 0ERP01-ZV -SH03, Rev. 12, Acting 0EPR02-CK -OPS05, Rev 2, Security Updating procedure reference. In the Security Manager Force Supervisor previous emergency plan, the SFS assumed the title of Acting Security Manager.
18 Page 110, HG1: EAL-1
References:
Page 110, HG1: EAL-1
References:
Editorial 0ERP01-ZV -TS08, Rev. 16, Security 0EPR02-CK -TSC05, Rev 2, TSC Updating procedure reference. In the new Manager Security Coordinator Emergency Plan, the Security Manger is the TSC Security Coordinator.
NOC-AE-24004075 Page 8 of 9
Change Synopsis Proc.: EP-0003.001 Rev.: 1
Title:
STPEGS Emergency Action Level Technical Basis Manual Continued Item Current / Proposed Type / Justification 19 Page 53, IC CU5, Table C4: CURRENT Change Table C4: Communications Methods Adding the Electronic notification system to METHOD EAL-1 EAL-2 EAL-3 the list of communication methods represents ONSITE ORO NRC the added functionality of the electronic offsite Plant PA system X notification system. It is being added to the Plant Radios X specified ORO communication systems to Plant telephone system X X X meet the EAL-2 basis intent. The reference to Satellite phones X X Dedicated Ring-down lines is being Direct line from Control Rooms to Bay City X X removed as this capability is included in the Microwave Lines to Houston X X Plant telephone system. The availability of Security radio to Matagorda County X Dedicated Ring-down lines X any plant telephone line in the facility allows ENS line X the ORO notification to be completed.
Page 53, IC CU5, Table C4: PROPOSED Table C4: Communications Methods METHOD EAL-1 EAL-2 EAL-3 ONSITE ORO NRC Plant PA system X Plant Radios X Plant telephone system X X X Satellite phones X X Direct line - Control Rooms to Bay City X X Microwave lines X X Security radio to Matagorda County X Electronic notification system X ENS line X 20 Page 53, IC CU5, Basis: EAL #2 Page 53, IC CU5, Basis: EAL #2 Change.
Texas Department of Public Safety The OROs referred to here are The OROs referred to here are has changed operations - the State Matagorda County Sheriffs Office, Matagorda County Sheriffs Office, Operations Center is the single point and Texas Department of Public and the State of Texas. of contact for STP Emergency Plan Safety Disaster District in Pierce. notifications to the state of Texas.
NOC-AE-24004075 Page 9 of 9
Change Synopsis Proc.: EP-0003.001 Rev.: 1
Title:
STPEGS Emergency Action Level Technical Basis Manual Continued Item Current / Proposed Type / Justification 21 Page 122, IC SU6, Table S2: CURRENT Change Table S2: Communications Methods Adding the Electronic notification system to METHOD EAL-1 EAL-2 EAL-3 the list of communication methods represents ONSITE ORO NRC the added functionality of the electronic offsite Plant PA system X notification system. It is being added to the Plant Radios X specified ORO communication systems to Plant telephone system X X X meet the EAL-2 basis intent. The reference to Satellite phones X X Dedicated Ring-down lines is being Direct line from Control Rooms to Bay City X X removed as this capability is included in the Microwave Lines to Houston X X Plant telephone system. The availability of Security radio to Matagorda County X Dedicated Ring-down lines X any plant telephone line in the facility allows ENS line X the ORO notification to be completed.
Page 122, IC SU6, Table S2: PROPOSED Table S2: Communications Methods METHOD EAL-1 EAL-2 EAL-3 ONSITE ORO NRC Plant PA system X Plant Radios X Plant telephone system X X X Satellite phones X X Direct line - Control Rooms to Bay City X X Microwave lines X X Security radio to Matagorda County X Electronic notification system X ENS line X 22 Page 122, IC SU6, Basis: EAL #2 Page 122, IC SU6, Basis: EAL #2 Change.
The OROs referred to here are The OROs referred to here are Texas Department of Public Safety Matagorda County Sheriffs Office, Matagorda County Sheriffs Office, has changed operations - the State and Texas Department of Public and the State of Texas. Operations Center is the single point Safety Disaster District in Pierce. of contact for STP Emergency Plan notifications to the state of Texas.