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).
Editorial to correct formatting issue for Table B-1.
Item Current Proposed Type / Justification 1
Section E.1
- 2.
State and County Event Notification Notifications are made simultaneously via dedicated automatic ringdown lines to State personnel in the Department of Public Safety Communication Center located at the Sub District Office and to county personnel located in the Matagorda County Sheriff's Office.
Section E.1
- 2.
State and County Event Notification Notifications are made simultaneously via an electronic offsite notification system to the State of Texas and Matagorda County.
Change EONS replaces the current event notification process and systems, which involve three separate immediate activities (form, phone, fax) with a single electronic system that performs all three event notification activities (email).
Through the use of common current technology to replace dated systems, 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
- 2.
Offsite Communications Systems B.
Dedicated Automatic Ringdown Lines - Dedicated automatic ringdown lines allow immediate and direct contact with the Matagorda County Sheriff's Office and the Texas Department of Public Safety, Sub District Office.
Section F.1
- 2.
Offsite Communications Systems B.
Electronic Offsite Notification System (EONS) - A system capable of sending emails and phone calls to provide event notification to Matagorda County and the State of Texas.
The current system uses a dedicated automatic ring-down telephone system to verify receipt of the notification. Both EONS and the current telephone system contact state and county warning points that are staffed 24/7. The current system requires a dedicated communicator to verbally transmit and verify receipt 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 TSC/OSC, 90 min.
Offsite FMT composition listed under EOF/JIC, 90 min.
This is a Table B-1 formatting 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 changed to match the industry-standard format for an On-Shift Staffing Analysis using NEI 10-05 as guidance.
0EPM04-UA-0001, EPM/EPR Writers Guide was also used for formatting guidance.
Change - No change of intent.
Standardize text in all applicable sections and tables in the body of the document for standardization with NEI 10-05 and updated for new EPlan document references.
2 Changes to Attachment 2, All Event data tables.
General Revision / Full Re-Write.
Changes to all event tables in 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 STPEGS Emergency Action Level Technical Bases Manual Title Page STPEGS Emergency Action Level Technical Basis Manual Editorial Correct typographical error. Title is Basis not Bases 2
Page 88, IC HU1, Table H1:
Table H1: Security Supervision Security Force Supervisor Acting Security Manager Security Manager Page 88, IC HU1, Table H1:
Table H1: Security Supervision Security Force Supervisor TSC Security Coordinator Editorial In the previous emergency plan, the SFS assumed the title of Acting Security Manager. Neither the individual nor the tasks/position changed upon activation of 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.
3 Page 89, HU1: EAL-1 Selection Basis:
For EAL-1, the position of Security Force Supervisor was included since it is a 24-hour position. Normally the event would not be reported by the Acting Security Manager or Security Manager because the Acting Security Manager position is not normally activated until after an UNUSUAL EVENT has been declared, and the Security Manager position is not normally activated until after an ALERT has been declared. However, reporting by the Acting Security Manager or Security Manager was included in the event these positions are staffed under unusual circumstances.
Page 89, HU1: EAL-1 Selection Basis:
For EAL-1, the position of Security Force Supervisor was included since it is a 24-hour position. Normally the event would not be reported by the TSC Security Coordinator because the TSC Security Coordinator position is not normally activated until after an ALERT has been declared. However, reporting by the TSC Security Coordinator was included in the event this position may be staffed under unusual circumstances.
Editorial In the previous emergency plan, the SFS assumed the title of Acting Security Manager. Neither the individual nor the tasks/position changed upon activation of 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.
4 Page 89, HU1: EAL-1
References:
0ERP01-ZV-SH03, Rev. 12, Acting Security Manager Page 89, HU1: EAL-1
References:
0EPR02-CK-OPS05, Rev 2, Security Force Supervisor Editorial Updating procedure reference. In the previous emergency plan, the SFS assumed the title of Acting Security Manager.
5 Page 89, HU1: EAL-1 References 0ERP01-ZV-TS08, Rev. 16, Security Manager Page 89, HU1: EAL-1 References 0EPR02-CK-TSC05, Rev 2, TSC Security Coordinator Editorial Updating procedure reference. In the new Emergency Plan, the Security Manger is the TSC Security Coordinator.
6 Page 98, IC HA1, Table H1:
Table H1: Security Supervision Security Force Supervisor Acting Security Manager Security Manager Page 98, IC HA1, Table H1:
Table H1: Security Supervision Security Force Supervisor TSC Security Coordinator Editorial In the previous emergency plan, the SFS assumed the title of Acting Security Manager. Neither the individual nor the tasks/position changed upon activation of 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 Selection Basis The EALs are taken from NEI 99-01, Rev. 6. For EAL-1, the positions of Security Force Supervisor OR Acting Security Manager were included because either of these positions could be activated prior to meeting this EAL. The Security Force Supervisor is a 24-hour position and the normally the Acting Security Manager is activated after an UNUSUAL EVENT has been declared. The Security Manager is also included although this position is normally activated after an ALERT.
Page 99, HA1: EAL-1 and EAL-2 Selection Basis The EALs are taken from NEI 99-01, Rev. 6. For EAL-1, the position of Security Force Supervisor was included since it is a 24-hour position.
Normally the event would not be reported by the TSC Security Coordinator because the TSC Security Coordinator position is not normally activated until after an ALERT has been declared. However, reporting by the TSC Security Coordinator was included in the event this position may be staffed under unusual circumstances.
Editorial In the previous emergency plan, the SFS assumed the title of Acting Security Manager. Neither the individual nor the tasks/position changed upon activation of 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.
8 Page 99, HA1: EAL-1
References:
0ERP01-ZV-SH03, Rev. 12, Acting Security Manager Page 99, HA1: EAL-1
References:
0EPR02-CK-OPS05, Rev 2, Security Force Supervisor Editorial Updating procedure reference. In the previous emergency plan, the SFS assumed the title of Acting Security Manager.
9 Page 99, HA1: EAL-1 References 0ERP01-ZV-TS08, Rev. 16, Security Manager Page 99, HA1: EAL-1 References 0EPR02-CK-TSC05, Rev 2, TSC Security Coordinator Editorial Updating procedure reference. In the new Emergency Plan, the Security Manger is the TSC Security Coordinator.
10 Page 54, IC CU5, References EAL #2 0PGP05-ZV-0011, Rev. 8, Emergency Communications Page 54, IC CU5, References EAL #2 0EPR01-IP-0002, Emergency Notifications Editorial Updating procedure reference.
11 Page 123, IC SU6, References EAL
- 2 0PGP05-ZV-0011, Rev. 8, Emergency Communications Page 123, IC SU6, References EAL
- 2 0EPR01-IP-0002, Emergency Notifications Editorial Updating procedure reference.
12 Page 104, IC HS1, Table H1:
Table H1: Security Supervision Security Force Supervisor Acting Security Manager Security Manager Page 104, IC HS1, Table H1:
Table H1: Security Supervision Security Force Supervisor TSC Security Coordinator Editorial In the previous emergency plan, the SFS assumed the title of Acting Security Manager. Neither the individual nor the tasks/position changed upon activation of 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 Basis The positions of Security Force Supervisor, Acting Security Manager, and Security Manager were included since any of these positions could be activated prior to meeting this EAL.
The Security Force Supervisor is a 24-hour position, the Acting Security Manager is activated after an Unusual Event has been declared and the Security Manager is activated after an Alert is declared.
Page 105, HS1: EAL-1 Selection Basis The positions of Security Force Supervisor and TSC Security Coordinator were included because either of these positions could be activated prior to meeting this EAL.
The Security Force Supervisor is a 24-hour position and the TSC Security Coordinator is activated after an ALERT has been declared.
Editorial In the previous emergency plan, the SFS assumed the title of Acting Security Manager. Neither the individual nor the tasks/position changed upon activation of 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 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:
0ERP01-ZV-SH03, Rev. 12, Acting Security Manager Page 105, HS1: EAL-1
References:
0EPR02-CK-OPS05, Rev 2, Security Force Supervisor Editorial Updating procedure reference. In the previous emergency plan, the SFS assumed the title of Acting Security Manager.
15 Page 105, HS1: EAL-1 References 0ERP01-ZV-TS08, Rev. 16, Security Manager Page 105, HS1: EAL-1 References 0EPR02-CK-TSC05, Rev 2, TSC Security Coordinator Editorial Updating procedure reference. In the new Emergency Plan, the Security Manger is the TSC Security Coordinator.
16 Page 109, IC HG1, Table H1:
Table H1: Security Supervision Security Force Supervisor Acting Security Manager Security Manager Page 109, IC HG1, Table H1:
Table H1: Security Supervision Security Force Supervisor TSC Security Coordinator Editorial In the previous emergency plan, the SFS assumed the title of Acting Security Manager. Neither the individual nor the tasks/position changed upon activation of 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:
0ERP01-ZV-SH03, Rev. 12, Acting Security Manager Page 110, HG1: EAL-1
References:
0EPR02-CK-OPS05, Rev 2, Security Force Supervisor Editorial Updating procedure reference. In the previous emergency plan, the SFS assumed the title of Acting Security Manager.
18 Page 110, HG1: EAL-1
References:
0ERP01-ZV-TS08, Rev. 16, Security Manager Page 110, HG1: EAL-1
References:
0EPR02-CK-TSC05, Rev 2, TSC Security Coordinator Editorial Updating procedure reference. In the new 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 Table C4: Communications Methods METHOD EAL-1 ONSITE EAL-2 ORO EAL-3 NRC Plant PA system X
Plant Radios X
Plant telephone system X
X X
Satellite phones X
X Direct line from Control Rooms to Bay City X
X Microwave Lines to Houston X
X Security radio to Matagorda County X
Dedicated Ring-down lines X
ENS line X
Change Adding the Electronic notification system to the list of communication methods represents the added functionality of the electronic offsite notification system. It is being added to the specified ORO communication systems to meet the EAL-2 basis intent. The reference to Dedicated Ring-down lines is being removed as this capability is included in the Plant telephone system. The availability of any plant telephone line in the facility allows the ORO notification to be completed.
Page 53, IC CU5, Table C4: PROPOSED Table C4: Communications Methods METHOD EAL-1 ONSITE EAL-2 ORO EAL-3 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 The OROs referred to here are Matagorda County Sheriffs Office, and Texas Department of Public Safety Disaster District in Pierce.
Page 53, IC CU5, Basis: EAL #2 The OROs referred to here are Matagorda County Sheriffs Office, and the State of Texas.
Change.
Texas Department of Public Safety has changed operations - the State Operations Center is the single point of contact for STP Emergency Plan 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 Table S2: Communications Methods METHOD EAL-1 ONSITE EAL-2 ORO EAL-3 NRC Plant PA system X
Plant Radios X
Plant telephone system X
X X
Satellite phones X
X Direct line from Control Rooms to Bay City X
X Microwave Lines to Houston X
X Security radio to Matagorda County X
Dedicated Ring-down lines X
ENS line X
Change Adding the Electronic notification system to the list of communication methods represents the added functionality of the electronic offsite notification system. It is being added to the specified ORO communication systems to meet the EAL-2 basis intent. The reference to Dedicated Ring-down lines is being removed as this capability is included in the Plant telephone system. The availability of any plant telephone line in the facility allows the ORO notification to be completed.
Page 122, IC SU6, Table S2: PROPOSED Table S2: Communications Methods METHOD EAL-1 ONSITE EAL-2 ORO EAL-3 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 The OROs referred to here are Matagorda County Sheriffs Office, and Texas Department of Public Safety Disaster District in Pierce.
Page 122, IC SU6, Basis: EAL #2 The OROs referred to here are Matagorda County Sheriffs Office, and the State of Texas.
Change.
Texas Department of Public Safety has changed operations - the State Operations Center is the single point of contact for STP Emergency Plan notifications to the state of Texas.