ML25274A136
| ML25274A136 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/02/2025 |
| From: | Jeffrey Reed - No Known Affiliation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML25274A136 (1) | |
Text
[
PROCEDURE REVIEW FORM (PRF) 1.0. Initiation a
es Initiator: James Reed 7
Date: 09/02/2025
_ Procedure Dept:
Document #: RERP New Rev. # = 058 3 digits required) l
Title:
Radiological Emergency Res se Plan l(RERP) ee Level ofUse:
[JContinuous (JReference
_UInformation DiMultiple DIN/A "2,0 Reason for Change/Description of Change (List cor commitments, CRs, eB Change Requests, OERs, Plant Modsetc. and record numbers here.)
- CR# 202504930
° (Section 1.0 Glossary) Pg.7 -Removed the word "Duty" from the definition of Cellular Paging System (Section 1.0 Glossary) Pg.8 added (when deemed necessary) to definition of Duty (Section 1.0 Glossary) Pg.9 Removed "An Emergency Coordinator (TSC) is on-call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days a week."
(Section 1.0 Glossary) Pg.12-Removed "pre-designated" from the definition of Minimum Staffing (Section 5.0) Pg.33-Removed on-call (not required to be on-site) and predesignated (Section 6.0) Pg. 65-Removed the word "duty" (Section 7.0) Pg.85-Removed predesignated (Appendix B) Change Fadi Diya to Kent Scott Continued: []
3.0.
Document Disposition
~~
[Temp Change
[JNew Document L1Major Revision PdMinor Revision
[Cancellation
[Administrative Correction ee Dept. Head or] Designated Approver required for Administrative Corrections ((Signature/PIN/Date)
- no other signatures required
~
Interim Approval (Temp. Change Only)
Temp. Change #:
Expiration Date:
Cognizant Supervisor (Signature/PIN/Date) a SRO (Signature/PIN/Date)
5.0 Comments
oo.
a a
Continued: o 6.0 Reviews and Signatures (NOTrequiredfor Administrative Corrections)
__ Reviews Required l Dept l PIN. l Signature Date ____l__A0139 Attached Preparer EP 136263l
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nw) ee ponte
_ N/A_
, Technical Review! EP l s4s¢y l
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Dyes [KINo> l Technical Review e
730 VN ee 1812.03 L] YesRl No.
i;Add]Review 7
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_U Yes CLINo
[Addl Review l
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a Dyes [Nol
- LJAdditional R iews (See Attached C40139forms).
Number of additional CA0139s:
Type F Coordinator
- PIN
_ po Signature l
Date
___ l CA0139Attached
[Walidation Oy Yes CINo l
_ 0.59 Review BICA2510
[ICA2511
[ICA2512 / LIN/AGper aP4-z2-00143)
Screener Initial /PIN ReviewerInitial
/ PIN
- PIN_,
Wept. Head or Designated Approver) Is a Change Management Plan required? [Yes [No (IF YES, attach CA2773 or cCA2774)
Is aCross-Disciplinary rev review required? Clyes LXINo "7,0 Approval (Either approval must be qualified as PAT/APVR or PA T/GAPR in QualMaster)
Senior Director Nuclear Operations Approval(per APA-ZZ-00101)
[X] ORCis requiredin accordance with APA-ZZ-00091 epartment Head Final Review and Approval ORC Meeting:
2QAlo oa 6392 _9fivfrer ee se Phils Dept. Head or Designated Approver Senior Director Nuclear Operations (Signature/PIN/Date}
a (Signature/PIN/Date) el Note: Page 2,provides instructions tocomplete thisform ar and may be discarded
~A190.0001,2, 5, 35 A210.0062,65, 69;M190.0001 Page 1 of2 "40033 APA-ZZ-00101 Rev. 002
l PRIMARYLICENSING DOCUMENT CHANGE FORMFOR RERP OR ASSOCIATED EIPS Document
& Rev #: Radiological Emergency Response Plan (RERP) REV.058
~
- 1. Originator; James Reed l
Date: 09/02/2025
- 2. PlanSection(s):
rw Section 1.0 Glossary e
1.1 Definitions Section 5.0 Organizational Control of Emergencies.
Section 6.0 Emergency Measures
6.4 Mobilization Section 7.0 Emergency Response Facilities and Equipment
7.1.3 Emergency Operations Facility (EOF)
References:
l___
None
- 4. Is this change evaluated under an existing License Document Change per APA-ZZ-001407............... Llyes XINo If Yes attach a copy of the change paperwork or provide reference (CMP, RFR, etc.)
ts If No, an evaluation should be performed and attached or provide sufficient information for completion of the evaluation by the responsible department.
is, Description ofChange: l an ae e
(Section 1.0 Glossary) Pg.7 -Removed the word "Duty" from the definition of Cellular Paging System.
(Section 1.0 Glossary) Pg.8 added (when deemed necessary) to definition of Duty (Section 1.0 Glossary) Pg.9 Removed "An Emergency Coordinator (TSC) is on-call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days a week."
(Section 1.0 Glossary) Pg.12-Removed "pre-designated" from the definition of Minimum Staffing (Section 5.0) Pg.33-Removed on-call (not required to be on-site) and predesignated (Section 6.0) Pg. 65-Removed the word "duty" (Section 7.0) Pg.85-Removed predesignated KDP-ZZ-00400_
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Page 1 of3
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CA0667C A210.0038 Rev. 003
Pod a
i=
=
PRIMARY LICENSING DOCUMENT CHANGE FORM FOR RERP OR ASSOCIATEDD EIPS
- 6. Justification:
ae ithe Radiological Emergency Response Plan (RERP)is being revised to remove the duty responder designation j
from Minimum Staff Personnel. Currently, these individuals are required to be on call and fit for duty for a full week:
l at a time. With this change, Minimum Staff positions will be aligned with pool positions, which are not subject to weekly on-call rotations but are still required to report to their Emergency Response Facility (ERF) during Emergency Response Organization (ERO) augmentation.
(attach extrapages as necessa
- 7. Originating Department Head Approval eu) pm {6357 al{>>/Ws
- 8. Concurrence with Need for Change so Rejected: L]
Revision No.
Ae 3q?
4fir/2-Manager, Emergency Preparedness Review of Proposed Changes Reviewed By:
Change Coordinator: 0.00.00... oe ABE wr SAMG Coordinator (EAL Change Only)
Manager, Emergency Preparedness............
Offsite: (Ifa change to EALs or ofdirect concern)
Callaway County: eececseene Gasconade County? cscs l Montgomery County:....
Osage County? cesses NS)OY
Others:
Page 2 of3 l
l CA0667C KDP-ZZ-00400 Rev. 003 A210.0038
PRIMARY LICENSING DOCUMENT CHANGEFORM FORRERP OR ASSOCIATED EIPS Approval of Proposed Changes ian y
Date
\
Manager, Emergency Preparedness............_ Qu te (GBT)
_ afi t [wr Senior Director Nuclear Operations:
(ifnotpreviously signed on CA0033) 7 ~~ Nd 1587K op3/;as Did this change modify information displayed on the Event Notification System?......... DYES LINO If YES, prior to signing below, ENSURE plans are in place to modify the information at the same time this revision is issued.
Change Coordinator:
(Review ofFinal Packagefor Completeness, ensure RERP Appendix B
B has been en signedry th the= ¥ oO CNO ifapplicable.)....
o> \.BOS a vf Ssa
- Change Coordinator:
(Provide informationfort ULNRC letter to Regulatory Affairs.).....
sseenanenees ~ &a.\
\ % &HA. ANSae KDP-ZZ-00400 l
Page30f3
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CA0667C A210.0038 Rev. 003
50.54(q) Screening For orm Document #, Rev #, &
Title:
RERP, Rev.058, Radiological EmergencyResponse Plan EP Tracking #: _2024035 Activity Description and References (pg.9):
CR#202406554-Revise the Radiological Emergency Response Plan (RERP) to remove Duty Responder requirement from Minimum Staff personnel and respond as Pool positions for Augmentation of the ERO.
Activity Scope (pg.9):
YES NO Does this activity revise the Radiological Emergency Response Plan (RERP)or Implementing Procedures?
ws. w C
Change Type:
YES NO Is this activity editorial or typographical?
ecco seaneenenetnnennenneettngcesceseneceestnustennensiesquceticeetersit Ol en me
Previously Approved Change (pg.10):
YES NO, Is this activity being processed to conform to a previously approved activity?
......ccccsccssssssessssssonssssessssesesnstesassssessesenoateee C]
_ If YES, what is the previously approved activity?
Planning Standard Determination (pg.10):
Does this activity impact any of the 50.47(b) Planning Standards or Part 50 Appendix E:
50.47(b)(1) (pg.36)- Assignment of Responsibility (Organization Control)?
50.47(b)(2) (pg.36)- Onsite Emergency Organization?...
secsannteeaeens
$0.47(b)(3) (pg.36)- Emergency Response Support and Resources?.
50.47(b)(4) (pg.36)- Emergency Classification System?
50.47(b)(5) (pg.37)- Notification Methods and Procedures 50.47(b)(6) (pg.37)- Emergency Communications?
50.47(b\(7) (pg.37)
- Public Education and Information 50.47(b)(8) (pg.38)- Emergency Facility and Equipment?
50.47(b)(9) (pg.38)- Accident Assessment?
50.47(b)(10) (pg.39)
- Protective Response?
50.47(b)C1 1) (pg.39)
- Radiological Exposure Control?......
50.47(b)(12) (pg.39)- Medical and Public Health Support?
50.47(b)(13) (pg.39)- Recovery Planning and Post Accident Operations?
50.47(b)(14) (pg.40)- Drills and Exercises?0.0.00...
50.47(b)(15) (pg.40)- Emergency Responder Training?.
50.47(b}(16) (pg.40)- Emergency Plan Maintenance?
Part 50 Appendix E (pg.40)?..............esseeenegecsstetnneneeese rw, Zz mOOZ Xx
[FPS Pa Ba se a
a a
BB Commitment Impact Determination (pg. 11):
YES NO Does this activity impact a Site-Specific EP Commitment not associated with a Planning Standard or Element?
............... O ki IfIfYes, record the Commitment number:l Explanation of Determination (pg.11): (Enter an explanation to eachdeterminatior-answer that needs clarification)
The change of removing Duty Responder from Minimum Staffing positions to Pool positions would require a revision to; the Radiological Emergency Response Pian (RERP). Presently, Duty is defined as Rotating on-call coverage, scheduled around the clock, to ensure response" in the RERP. This change could affect the availability of the onsite Emergency Response Organization. Therefore, the change will impact planning standards 10.CFR.50.47(b)(1),
Assignment of Responsibility (Organization Control), 10.CFR.50.47(b)(2) Onsite Emergency Organization and 10.CFR Part 50 Appendix E. The impacts will require a 10.CFR 50.54(q) Effectiveness Evaluation.
a an i
File#A210.0038 Page 1 of2 a
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CA1523 KDP-ZZ-00400 Rev. 003
7 50.54(q) Screening Form Screening Evaluation Results (pg.12):
Based on the results of the information above, can the activity be implemented without performing a YES NO.
full 50.54(q) Effectiveness Evaluation?.....ccccsseseeesscetiintemnsteveestnstetmesteseriacenanetansetn [)
kK:
Review/Approval (pg.12):
_ Preparer (Sign/PIN)..........
AL) / 136 ¥63 oe Date: 4-2 eparer must be qualified Emergency Response Coordinator.
Reviewer (Sign/PIN)........
i?
743 £O Date: TAS ift reqgency Response Coordinator 1
Emergency Preparedness Manager-(Si ne 16391 Date:
9 j afroas "File # A210.0038 Page2of2.
CA1523__
KDP-ZZ-00400 Rev. 003
50.54(q) Effectiveness Evaluation Form Document #, Rev #, &
Title:
RERP, Rev.058, Radiological Emergency Response Plan EP Tracking #:
2024035 l
Activity Description and References (pg.13):
CR#202406554 Revise the Radiological Emergency Response Plan (RERP) to remove Duty Responder requirement from Minimum Staff personnel and respond as Pool positions for Augmentation of the ERO.
Be Activity Type (pg.13):
YES NO.
Does this activity revise the Radiological Emergency Response Plan (RERP) or Implementing Procedures?
Cl:
Does this activity impact implementation of the RERP, but does NOTrevise the RERP or Implementing Procedures?
... C]
Impact and Licensing Basis Determination (pg.14):
(List offunctions, elements and/or commitments impacted by the activity, organized by planning standard as applicable. See KDP-Z22-00400, section 4.6.5)
Licensing Basis:
10CFR50.47(b)(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities ofthe various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
This change impacts planning standard 10CFR50.47(b)(1) by removing Minimum Staff Duty Responder requirements.
This change could potentially impact the staff response to augmentation.
10CFR 50.47(b)(2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.
e This change impacts the planning standard 10CFR50.47(b)(2) by changing role requirements for Minimum Staff Duty Responders, which potentially impacts timely augmentation of response activities.
Part 50, Appendix E, Section [V, A: The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:
2.
A description of the onsite emergency response organization (ERO) with a detailed discussion of:
- a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency.
e This change impacts 10.CFR Part 50 Appendix E Section IV, A 2a by altering responsibilities ofpersonnel who will augment the onsite emergency organization. (Removing Minimum Staff duty requirements)
File # A210.0038 Page lof4 CA1524 KDP-ZZ-00400 Rev. 003
z
_ 50.54(q) Effectiveness Evaluation Form Compliance Evaluation and Conclusion (pg.15):
Evaluation: (Ensure all sections are evaluated) 10CFRS0.54(b) Planning Standards/I0CFR Part 50 Appendix E evaluation-10CFR50,47(b)(1) Currently, Minimum Staff Personnel are designated duty responders, however during augmentation of the ERO all available ERO personnel are required to report to their ERF which includes minimum staffpersonnel. Removing duty responder requirements from minimum staff positions, does not change the primary responsibilities of the emergency response organization at Callaway. The number of personnel that would be available to respond to the site in the event of an emergency does not change.
Therefore, this change would still comply with this planning standard.
JOCFR 50.47(b)(2):_ Removing Minimum Staff duty requirements does not challenge the timely augmentation ofthe ERO.
As stated above during augmentation of the ERO ail available ERO personnel are required to report to their ERF which includes minimum staff personnel. Eleven (11) previous quarters of augmentation test/drill data confirm minimum staff positions were filled by at least two (2) available responders for each Minimum Staff position within the 75-minute response goal. Therefore, this change to the ERO would comply with this planning standard.
Part 50, Appendix E, Section IV_A: Removing Minimum Staff duty requirements, does not change the authority, responsibilities or duties of personnel that would respond to the site in the event of an Emergency. Minimum StaffPositions are required to respon to declared events, whether designated as Duty Responders or not, Therefore, this change would comply with 10CFR Part 50 Appendix E.
RERP Impact evaluation-All previous revisions of the Emergency Plans were reviewed to determine relevance to Revision 057 with Revision 3 being used as a baseline. Revision 3 is the earliest fully intact Emergency Plan revision. Revision 3 of the Callaway RERP was reviewed, and there is no reference to Duty position responders. Revision 4 was also reviewed and no reference to Duty position responders was found. A search was performed on Rev.5A through 52 of the RERP using the RERP Database (an excel spreadsheet detailing the various changes made to the RERP on each revision of the RERP) for the acronyms "Duty", "Rapid Responders" and "Minimum Staffing.
Revision 22 addeda definition of the term duty
" Rotating On-call coverage, scheduled around the clock to ensure response during off normal working hours, to the RERP and changed the definition of Emergency Response Personnel
" Pre-Designated personnel, in addition to Rapid Responders, who staff the Emergency Response Facilities to make them capable of fulfilling all intended emergency functions". These positions are now defined as the Emergency Response Organization along with Rapid Responders. Also, in Rev.022 the definition of Rapid Responders was added and defined as
" Pre-Designated Emergency Response Personnel designated to staff the Technical Support Center and Emergency Operations Facility sufficiently to relieve the Control Room Personnel of Emergency functions not directly related to the operation of the plant. Rapid Responders are designatec ona rotating basis to be available for mobilization via Cellular Paging System. When designated on duty, personnel must remain fi for duty and within their designated response time of the plant".
Rev. 038 Replaced the title "Rapid Responders" with "Minimum Staffing." This was done to better describe these critical personnel and align with the industry terminology. A manual search of Revisions 053, 054, 055, 56 was also conducted. Revision 057 (current) references "Minimum Staffing Pre-designated Emergency Response Personnel assigned to activate the Technical Support Center and the Emergency Operations Facility sufficiently to relieve Control Room personnel of emergency functions not directly related to operation of the Plant. Minimum Staffing personnel are designated on a rotating basis to be available for mobilization via the Cellular Paging System. When designated on duty, personnel must remain fit for duty and within their designated response time of the Plant."
Other impacted documents-File #A210.0038 Page2 of 4 De CA1524 KDP-ZZ-00400 Rev. 003
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50.54(q) Effectiveness:Evaluation Form
==
Conclusion:==
The proposed change, of Removing Minimum Staff duty requirements will continue to comply with the requirements of 10CFR50.47(b)(1), 10CFR50.47(b)(2) and Part 50 Appendix E,Section IV A 2a.
i 5)tan.
7a. ie Does the proposed activity continue to comply with the Licensing Requirements? oo...
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Reduction in Effectiveness (RIE) Evaluation and Conclusion (pg.16):
Evaluation:
Removing Duty Responder requirements for minimum staffing positions does not impact Callaway's ability to comply with 10CFR50.47(b)(1), 10CFR50.47(b)(2) and Part 50, Appendix E,Section IV, A 2a.
Augmentation drill data was reviewed from the 4" quarter of 2022 through the 2nd quarter of 2025. During the review ofthis data each duty responder position (Minimum Staff} was evaluated against the response goal of 75 minutes to staff the Emergency
+
Response Facilities (EOF/TSC). In each ofthe quarters reviewed, all the Minimum Staff positions response times were met. The following is a breakdown of each Minimum Staff Position and the percentage of available responders to meet the response goal of 75 minutes. 25Q2 Augmentation Drill was conducted during Refuel 27 with many ERO members working all hours of the day andi was completed successfully.
fee le 2204 57; 100 2301 l
66 l 80 (2302
<<66 71 2303 l 57 l 2304 s0f sof 24010 l
7 60,
- 2402, 200, 7 75,
_80l 2403-3 7
30
/
100,83 (2404 l 10 85 l 8075 83 2501
~
100.
<<100, 60 100l 100]
2502 50,66 80, a 83 AVG 65.5 833 723 812 799 84 074.4
==
Conclusion:==
Removing the Duty Responder requirement from Minimum Staff positions will not adversely impact Callaway's ability to staff the Emergency Response Facilities (EOF/TSC) in the response goal of 75 Minutes.
In addition, removing the Duty requirements would potentially improve the ability to staff the ERO by opening an additional pool of individuals to fill Minimum Staffing Positions. The data reviewed during the previous 11 quarters conclude that removing the requirement of duty responder from Minimum Staff personnel
~
would continue to comply with NRC Regulations and the RERP.
Final
Conclusion:
j Does the proposed activity constitute a Reduction In Effectiveness?
Effectiveness Evaluation Results (pg.17):
as 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.
C]
The activity does not continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E OR the
© activity does constitute a Reduction In Effectiveness. Therefore, the activity cannot be implemented without prior NRC l
approval.
File#A210.0038 Page 3 of 4 a
CA1524__
KDP-ZZ-00400 Rev. 003
50,eons EffectivenessEvaluation Form l
Review/Approval:
Preparer (Sign/PIN)....
OA 36 a6 3 ears must be gualified2s ncy: Response Coordinator.
Reviewer (Sign/PIN)........
j S43SZO
- Tied, pbreency Response Coordinator.
Emergency Preparedness ManagerJ Sign/PIN):
~ ie
=
_ 163 q7 File#A210.0038 Page 4 of4 KDP-ZZ-00400 Date:4-2-ad l Date: a7Q4 l
Date: _afig[ per
~GA1524 Rev. 003
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.
I.
ActivityDocument Number: RERP Revision Number:058l
Title:
Radiological Emergency Response Plan l
(RERP)
Brief Description of activity (whatis being changed and why):
ICR#
202504930.
(Section 1.0 Glossary) Pg.7 -Removed the word Duty from the definition of Cellular Paging System.
(Section 1.0 Glossary) Pg.8 added (when deemed necessary) to definition of Duty (Section 1.0 Glossary) Pg.9 Removed "An Emergency Coordinator (TSC) is on-call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days a week.
(Section 1.0 Glossary) Pg.12-Removed "pre-designated" from the definition of Minimum Staffing (Section 5.0) Pg.33-Removed on-call (not required to be on-site) and predesignated (Section 6.0) Pg. 65-Removed the word "duty" (Section 7.0) Pg.85-Removed predesignated (Appendix B) Change Fadi Diya to Kent Scott If YES, nofurther 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 of the RM.)
1.
Technical Specifications o
or the Renewed Operating B
NO oO YES:
XJNO
([] YeEs:Evaluation Log No., License Amendment No., or applicable document number.
Ll.Response IfYES, process perAPA--ZZ-00108 and FDP-2L-00103.
____License? (See 10CFR50.90.)})
eee penne 2.
Quality Assurance Plan? (See 10 CFR 50.54(a).)
DINO [YES If YES, process per APA-ZZ-00108 and GDP-ZZ-00600 and related facility or procedure change programs.
If YES, process per APA-ZZ-3.
Security Plan which also includes the Cyber Security Plan? DNo LI ves and SDP-ZZ-00030 for Security (See 10 CFR 50.54(p).)
Plan and related facility or l
lprocedure change programs.
APA-ZZ-00143.
"Pagel l
~~""" ©A2510 A170.0010 Rev. 006
APPLICABILITY DETERMINATION (Continued)
. Radiological ]Emergency Response Plan (RERP) oor.
i l
Emergency Action Levels (EALS)? (See 10 CFR 50.54(q).)
lt YES, process per APA-ZZ-00108 and KDP-ZZ-00400 for RERP and related facility or procedure change
.programs, Note: Ifyour proposed change alters a RERP implementing procedure [any EIP-ZZ-XXXX], equipment
- ((] NO [J YES 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 AppendixE to Part 50.47(b) [refer to KDP-ZZ-00400],
answer this questionYES._
se ebenee nn tog oe wns tae ce If YES, process APA-ZZ-00356 for ASME code compliance and related facility or procedure change lprograms.
IST Program Plan? (See 10 CFR 50.55a(f).)
IfYES, process per EDP-ZZ-01003 for ASME code compliance and related facility or procedure change programs.
s in EDP-ZZ-04044. If any of the screening Bw NO ((] YES questions are answered YES, a Fire Protection review is neededin
.accordance with EDP-ZZ-04044.
dF YES, then contact Regulatory 9.
Does the proposed activity impact other programs (e.g.,
i the ODCM, PCP, State and local permitting, etc.) that are controlled by regulations, the Operating License l
(including Orders and License Conditions) or the Technical Specifications? (See Section 4.2.1 of the RM.)
If YES, indicate the applicable
_INO [J YES program in Brief Description Section.
IV. Does the proposed act activ involve oo i
Response
_jSee Section4.2.2 ofthe RM I.Maintenance which restores SSCs totheir original (as designed) condition?
(See 10 CFR 50.65(a)(4).)
Note: If the 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.
If YES, process change per APA-ZZ-00101 for procedure changes or APA-ZZ-00320/330/340 for Maintenance activities.
Note: If this Applicability Determination is being NO [] YES performed to satisfy the 60-day requirement of ODP-ZZ-00035 for a Plant Status Control tag(s) (e.g., for a component(s) placed in an out-of-normal position in l
support of maintenance), then the associated activity should no longer be considered a maintenance activity and the response to this AD question should be answered APA-ZZ-00143 Page 2 A170.0010
APPLICABILITY DETERMINATION (Continued)
V.
Does the proposed activity involve a change tothe:
See Section ¢4.2.3 of lthe RM
~
Process the FSAR change per 1.
FSAR [JNO L] YES l
lAPA-ZZ-00108 and FDP-ZZ-00103 If the above response is NO, check N/A in the Response for revising License Documents.
column at right.
Note:
If the above response is YES, does the proposed activity "A NO response in the Response involve an FSAR change that may be excluded from the ClNo CIYES column left means thatthe requirement to perform a 50.59 Screen/Evaluation by FSAR/TS Bases change is one that NEI 96-07 or NEI 98-03? (Provide a YES or NO response to XI N/A requires further 50.59 review (ie.,
is this question in the Response column at right.)
not excludable from farther review).
Note: In lieu of the exclusion criteria of RM Section 4.2.3, a lA YES response means that the YES response may also be provided if the FSAR change
'FSAR does NOT require further requires no further 50.59 review based on a YES response to l
the question in Section II of this Applicability Determination form.)
150.59 review.
a "Process the TS Bases change per
?
1 2.
Technical Specification Bases? QR NO oYES l APA-ZZ-00108 and FDP-ZZ-00103 If the above response is NO, check N/Ain the Response for revising License Documents.
column at right.
Note:
If the above response is YES, does the proposed activity involve a TS Bases change comparable to that which may be l
column at left means that the TS excluded from the requirement to perform a 50.59 LINO [YES Bases change is one that requires Screen/Evaluation by NEI 96-07 or NEI 98-03 (as described further 50.59 review (ie.,
is not for an FSAR change)? (Provide a YES or NO response to this BI N/A a
question in the Response column at right.)
_A NO response in the Response excludable from further review).
oe A YES response means that the TS Note: In lieu of the exclusion criteria of RM Section 4.2.3, a Bases Change does NOT require YES response may also be provided if the TS Bases change fu 50.59 requires no further 50.59 review based on a YES response to rther nevi the question in Section HU of this Applicability Determination form.)
i 1
l "Response_lSee Section4.2.4/ 4.2.6 ofthe RM.
_VI.
Does the proposed activity involvea change to:
a 1.
Managerial or administrative procedures, controls, or activities (including software used only for the implementation of administrative procedures, controls, or >]NO
((] YES If YES, process per APA-2Z-00101 activities) governing the conduct of facility operations oF APA-ZZ-00109.
(subject to the controlof 10CFR50, Appendix B)?
l Regulatory commitment not covered by another regulation l wg NOno 0 YESleYES, process per.
_based change process? (SeeNEI99-04.)
{APA-ZZ-00540.
If YES, perform a 72.48 Screenlper APA-ZZ-00143 unless the changeis l
completely covered by the response Does the proposed activity potentially affect the design, l
to Section IL
- operation, or maintenance of the ISFSI facility as described in l
the dry cask storage FSAR or the 72.212 Report? (See FDP-l No [] YES:
ZZ-00105 and Attachment 1 of APA-ZZ-00143.)
Note:
Editorial or administrative changes are excluded from the requirement
_toperform a 72.48 Review.
APA-ZZ-00143.
(Page 3
So CA2510 A170.0010 Rev. 006
APPLICABILITY DETERMINATION (Continued) ee[
lIf YES, perform a 72.48 Screen per APA-ZZ-00143 unless the change is completely covered by the response Does the proposed activityaan elie the aesien i
Section II.
operation, or maintenance of the ISFSI facility as described in the dry cask storage FSAR or the 72.212 Report? (See FDP-Kino (YES ZZ-00105 and Attachment 1 of APA-ZZ-00143.)
Note:
Editorial or administrative changes are excluded from the requirement
_{to perform a 72.48Review.
APA-ZZ-00143.
a CA2510 A170.0010 Rev. 006
APPLICABILITY DETERMINATION (Continued) l VII. Justification/explanation for Response(s) (as needed):
The changes to Radiological Emergency Response Plan (RERP) Rev.058 Actions can be made under 1 0.CFR 50.54(q),
therefore a 10.CFR50.59 review is not required.
IX.
Conclusion:
KX]
All aspects ofthe activity are controlled by one or more of the procedures above, therefore a 50.59 Screen is not required.
[Ll A portion of the activity is not controlled by one or more of the procedures above, therefore a 50.59 Screen is required.
X. Signoffs:
Qualified Preparer:
James Reed dt.
4
/ca
/ oS (Print name) i aot Ce Qualified Reviewer:l ewok Enckrv 5, TP 11586 Date.
T 1
Hf 125 (Print fame) ae (Sign/PIN)
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.
APA-ZZ-00143 CA2510 A170.0010 Rev. 006
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.
Abbreviated Checklist; Name of the Change:
Radiologica Emergercy Response Pian 1
(RERP) Rev.058 Ichange Owner (Name/Title l James Reed/ Emergency Response Coordinator Recognize 1.
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.
Identify Risk andComplexity 1.
DETERMINE if this change impacts:
Yes No]
0 l Nuclear/industralSafety, Dose or Reliability
= oO Primary L
Licensing Documents (50.59, 50.54, Technical Specifications, FSAR, RERP, Security Pl Plan, OQAM, etc.) See APA-2Z-00108 for requirements ffor timely submittals.
OMTraining & Qualificationsof Personnel, Training Request #
i {_]
Procedures or Commitments 5id[Business Plans or Budget (Refer Asset Management Board Governance Charter)
Pl Computer programs/Electronic signatures Soe Organizations o8 tetpersonnel Changes Stakeholders 1.
DETERMINE who (groups, departments, individuals) will be affected by this change and where they stand in terms of support for the change.
DETERMINE if Training 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 of the Change Management team).
IF change impacts a group, department or individual, CONTACT affected participant(s) for their input.
Implementation Plan 1.
DEVELOP an Implementation Plan (reference Attachment 4 of APA-ZZ-01400 Appendix J).
2.
ENSURE required procedure revisions are identified.
APA-ZZ-01400 Appendix J Page 1 of2 CA2773 A110.0315 Rev. 000
Communications Plan 1.
CONSULT with Communications personnel to develop an effective communication plan (reference of APA-ZZ-01400 Appendix J).
Completed by:-
1 3G) 6%
Date:
Qv-oD_
ange Qwner / PIN Number Approved By:
16397 Date:
a/Tada Dept. Head or Manager / PIN Number APA-ZZ-01400 Appendix J Page 2 of 2 CA2773 A110.0315 Rev. 000