RA-23-0325, Submittal of Procedures CSD-EP-HNP-0101-01, 02, CSD-EP-ONS-0101-01, CSD-EP-RNP-0101-01, and EP-RNP-EPLAN-ANNEX
| ML24009A106 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Harris, Robinson, McGuire  |
| Issue date: | 01/08/2024 |
| From: | Ellis K Duke Energy |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RA-23-0325 | |
| Download: ML24009A106 (1) | |
Text
KEVIN M. ELLIS General Manager Nuclear Regulatory Affairs, Policy &
Emergency Preparedness 13225 Hagers Ferry Rd., MG011E Huntersville, NC 28078 843-951-1329 Kevin.Ellis@duke-energy.com Serial: RA-23-0325 10 CFR 50.54(q)
January 8, 2024 United States Nuclear Regulatory Commission (NRC)
ATTN: Document Control Desk Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400 / Renewed License No. NPF-63 McGuire Nuclear Station, Unit Nos. 1 and 2 Docket Nos. 50-369, 50-370 / Renewed License Nos. NPF-9 and NPF-17 Oconee Nuclear Station, Unit Nos. 1, 2 and 3 Docket Nos. 50-269, 50-270, And 50-287 / Renewed License Nos. DPR-38, DPR-47, and DPR-55 H. B. Robinson Steam Electric Plant, Unit No. 2 Docket No. 50-261 / Renewed License No. DPR-23
SUBJECT:
Procedures; CSD-EP-HNP-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 004 CSD-EP-MNS-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 4 CSD-EP-MNS-0101-02, EAL WALLCHART (BOTH HOT AND COLD), Revision 004 CSD-EP-ONS-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 005 CSD-EP-RNP-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 3 CSD-EP-RNP-0101-02, EAL WALLCHART (BOTH HOT AND COLD), Revision 003 EP-RNP-EPLAN-ANNEX, DUKE ENERGY ROBINSON EMERGENCY PLAN ANNEX, Revision 3, Summary of Changes Ladies and Gentlemen:
In accordance with 10 CFR 50.54(q), Duke Energy Carolinas, LLC, and Duke Energy Progress, LLC (collectively referred to as Duke Energy), are submitting revision summaries for procedures CSD-EP-HNP-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 004, CSD-EP-MNS-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 4, CSD-EP-MNS-0101-02, EAL WALLCHART (BOTH HOT AND COLD), Revision 004, CSD-EP-ONS-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 005, CSD-EP-RNP-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 3, CSD-EP-RNP-0101-02, EAL WALLCHART (BOTH HOT AND COLD), Revision 003 and EP-RNP-EPLAN-ANNEX, DUKE ENERGY ROBINSON EMERGENCY PLAN ANNEX, Revision 3.
The Emergency Action Level (EAL) Technical Basis Document Procedures provide an explanation and rationale for each EAL and provides historical documentation for future reference. Decision-makers responsible for Classification of Emergency may use this document as a technical reference in support of EAL interpretation for implementation of EAL Wallcharts (Both Hot and Cold).
U.S. Nuclear Regulatory Commission Page 3 Serial: RA-23-0325 : Procedure CSD-EP-HNP-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 004, 10 CFR 50.54(q) : Procedure CSD-EP-MNS-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 4 and CSD-EP-MNS-0101-02, EAL WALLCHART (BOTH HOT AND COLD),
Revision 004, 10 CFR 50.54(q) : Procedure CSD-EP-ONS-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 005, 10 CFR 50.54(q) : Procedure CSD-EP-RNP-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 3 and CSD-EP-RNP-0101-02, EAL WALLCHART (BOTH HOT AND COLD),
Revision 003, 10 CFR 50.54(q) : Procedure EP-RNP-EPLAN-ANNEX, DUKE ENERGY ROBINSON EMERGENCY PLAN ANNEX, Revision 3, 10 CFR 50.54(q) cc: L. Dudes, Regional Administrator USNRC Region II P. Boguszewski, USNRC Senior Resident Inspector - HNP C. Safouri, USNRC Senior Resident Inspector - MNS J. Nadel, USNRC Senior Resident Inspector - ONS J. Zeiler, USNRC Senior Resident Inspector - RNP M. Mahoney, NRR Project Manager - HNP J. Klos, NRR Project Manager - MNS S. Williams, NRR Project Manager - ONS L. Haeg, NRR Project Manager - RNP
U.S. Nuclear Regulatory Commission Attachment 1 Serial: RA-23-0325 Attachment 1: Procedure CSD-EP-HNP-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 004, 10 CFR 50.54(q)
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 ATTACHMENT 1 Page 1 of 40
<< 10 CFR 50.54(q) Review Form >>
Section I: 10 CFR 50.54(q) Review Number: (EREG #): 02490584 Applicable Sites and Applicability Determination # (5AD)
BNP CNS HNP 02490554 MNS ONS RNP Document #, EC #, or Revision # or N/A N/A Document or Activity Title CSD-EP-HNP-0101-01 4 EAL Technical Basis Document Section II: Identify/Describe All Proposed Activities/Changes being Reviewed Event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan (Use attachments, or continue additional pages as necessary): Continue to Section III.
CSD-EP-HNP-0101-01 is the Emergency Action Level (EAL) technical basis document for Harris Nuclear Plant (HNP).
Changes include:
Updated revision summary and revision number.
Various reference updates and formatting changes.
Updated EAL SU5.1 basis definitions of Reactor Coolant System (RCS) leakage as a result of revised Technical Specifications (TSs) related to reactor coolant system operational leakage and the definition of the term "LEAKAGE" based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, "Revise Reactor Coolant Leakage Requirements."
Change Section or Step Change From Change to 1 Throughout Old revision summary. Updated revision summary identifying the changes made from the document revision request.
2 Throughout CSD-EP-HNP-0101 Old revision CSD-EP-HNP-0101 New revision number (003) number (004) 3 Throughout Old page numbers and Table of Updated page numbers and Table of Contents Contents 4 Throughout PEP-110, Emergency Classification and AD-EP-ALL-0101, Emergency Protective Action Recommendations Classification, and AD-EP-ALL-0109, Offsite Protective Action Recommendations 5 Throughout Shearon Harris Nuclear Power Plant O/S Dose Calc Manual, Shearon Harris Offsite Dose Calculation Manual Nuclear Power Plant Off-site Dose (ODCM) Calculation Manual (ODCM)
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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Change Section or Step Change From Change to 6 Throughout EP-EALCALC-HNP-1401, HNP CSD-EP-HNP-0101-04, EAL Calculation Radiological Effluent EAL Values - Radiological Effluent EAL Values 7 Throughout AOP-20, Loss of RCS Inventory or AOP-020, Loss of RCS Inventory or Residual Heat Removal While Residual Heat Removal While Shutdown Shutdown 8 Throughout AOP-20, Loss of RCS Inventory or AOP-020-BD, Loss of RCS Inventory or Residual Heat Removal While Residual Heat Removal While Shutdown Shutdown - Basis Document 9 Throughout AOP-21, Seismic Disturbances AOP-021, Seismic Disturbances 10 Throughout PEP-342, Core Damage Assessment AD-EP-PWR-0206, Core Damage Assessment During An Emergency 11 Throughout AOP-16, Excessive Primary Plant AOP-016, Excessive Primary Plant Leakage Leakage 12 Throughout judgement judgment 13 Throughout OP-125, Hydrogen Monitoring System OP-125, Hydrogen Monitoring System (HSM) (HMS) 14 Throughout Old formatting throughout document Updated formatting throughout document in accordance with AD-DC-ALL-0301, Development and Maintenance of Controlled Supporting Documents. Changes include:
Changing outline and substep bullets from "A.", "B", "C", to "1.", "2.", "3."
Placing periods "." after step numbers Bolding step numbers Adding section continuation headers Removing underline from substep numbers Reformatting attachment titles so that they are below the attachment number Reformatting fonts (Formatting changes only. No change to text)
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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Change Section or Step Change From Change to 15 2.6, Operating 1 Power Operations (Reformatted into table format only. No Mode definitions Keff 0.99 and reactor thermal power > change to text.)
5% and average coolant temperature 350ºF 2 Startup Keff 0.99 and reactor thermal power 5% average coolant temperature 350ºF 3 Hot Standby Keff < 0.99 and average coolant temperature 350ºF 4 Hot Shutdown Keff < 0.99 and average coolant temperature 350ºF > Tavg > 200 ºF (excluding decay heat) 5 Cold Shutdown Keff < 0.99 and average coolant temperature Tavg 200ºF 6 Refueling Keff < 0.95 and average coolant temperature Tavg 140°F; fuel in the reactor vessel with the vessel head closure bolts less than fully tensioned or with the head removed D Defueled All reactor fuel removed from reactor pressure vessel (full core off load during refueling or extended outage) 16 4.1.9 4.1.9 PRO-NGGC-0201, NGG 4.1.9 AD-DC-ALL-0202, Writer's Manual Procedure Writer's Guide for Procedures and Work Instructions 17 4.2 4.2.1 PEP-110, Emergency 4.2.1 AD-EP-ALL-0101, Emergency Classification and Protective Action Classification Recommendations 4.2.2 AD-EP-ALL-0109, Offsite 4.2.2 NEI 99-01 Rev. 6 to HNP EAL Protective Action Recommendations Comparison Matrix 4.2.3 NEI 99-01 Rev. 6 to HNP EAL 4.2.3 HNP EAL Matrix Comparison Matrix 4.2.4 HNP EAL Matrix 18 5.1 See Enclosure 1 (Numbered Definitions only. No change to text.)
See Enclosure 2 19 5.2 See Enclosure 3 (Reformatted Abbreviations/Acronyms to table format only. No change to text.)
See Enclosure 4
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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Change Section or Step Change From Change to 20 7.0 7.1 Attachment 1, Emergency Action Attachment 1, EAL Bases Level Technical Bases Attachment 2, Fission Product Barrier 7.2 Attachment 2, Fission Product Loss/Potential Loss Matrix and Bases Barrier Matrix and Basis Attachment 3, Safe Operation &
7.3 Attachment 3, Safe Operation & Shutdown Room/Areas Tables R-3/H-2 Shutdown Areas Tables R-3/H-2 Bases Bases 21 Att. 1, RA1.4 PEP-270, Activation and Operation of AD-EP-ALL-0103, Activation and Basis, the Emergency Operations Facility and Operation of the Emergency Operations Paragraph 1 PEP-330, Radiological Consequences Facility, AD-EP-ALL-0204, Distribution of provide guidance for emergency or Potassium Iodide Tablets in the Event of Att. 1, RS1.3 post-accident radiological a Radioiodine Release, AD-EP-ALL-Basis, environmental monitoring (ref. 1, 2). 0205, Emergency Exposure Controls, Paragraph 1 AD-EP-HNP-0106, HNP Site-Specific OSC Support, AD-EP-HNP-0203, HNP Att. 1, RG1.3 Site-Specific Field Monitoring, AD-RP-Basis, ALL-2000, Preparation and Management Paragraph 1 of Radiation Work Permits (RWP), and AD-RP-ALL-4010, Internal Dose Assessment provides guidance for emergency or post-accident radiological environmental monitoring (ref. 1 - 7).
22 Att. 1, RA1.4 1. PEP-270, Activation and Operation of 1. AD-EP-ALL-0103, Activation and Basis the Emergency Operations Facility Operation of the Emergency Operations Reference(s) 2. PEP-330, Radiological Facility Consequences 2. AD-EP-ALL-0204, Distribution of
- 3. AD-EP-ALL-0205, Emergency Exposure Controls
- 5. AD-EP-HNP-0203, HNP Site-Specific Field Monitoring
- 6. AD-RP-ALL-2000, Preparation and Management of Radiation Work Permits (RWP)
- 7. AD-RP-ALL-4010, Internal Dose Assessment
- 8. NEI 99-01 AA1
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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Change Section or Step Change From Change to 23 Att. 1, RS1.3 1. PEP-270, Activation and Operation of 1. AD-EP-ALL-0103, Activation and Basis the Emergency Operations Facility Operation of the Emergency Operations Reference(s) 2. PEP-330, Radiological Facility Consequences 2. AD-EP-ALL-0204, Distribution of
- 3. AD-EP-ALL-0205, Emergency Exposure Controls
- 5. AD-EP-HNP-0203, HNP Site-Specific Field Monitoring
- 6. AD-RP-ALL-2000, Preparation and Management of Radiation Work Permits (RWP)
- 7. AD-RP-ALL-4010, Internal Dose Assessment
- 8. NEI 99-01 AS1 24 Att. 1, RG1.3 1. PEP-270, Activation and Operation of 1. AD-EP-ALL-0103, Activation and Basis the Emergency Operations Facility Operation of the Emergency Operations Reference(s) 2. PEP-330, Radiological Facility Consequences 2. AD-EP-ALL-0204, Distribution of
- 3. AD-EP-ALL-0205, Emergency Exposure Controls
- 5. AD-EP-HNP-0203, HNP Site-Specific Field Monitoring
- 6. AD-RP-ALL-2000, Preparation and Management of Radiation Work Permits (RWP)
- 7. AD-RP-ALL-4010, Internal Dose Assessment
- 8. NEI 99-01 AG1
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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Change Section or Step Change From Change to 25 Att. 1, SU5.1 Identified Leakage: Identified Leakage:
Basis, a. Leakage (except controlled leakage) a. Leakage, such as that from pump Paragraph 2 into closed systems, such as pump seal seals or valve packing (except controlled or valve packing leaks that are captured leakage), that is captured and conducted and conducted to a sump or collecting to a sump or collecting tank, or tank , or b. Leakage into the containment
- b. Leakage into the containment atmosphere from sources that are both atmosphere from sources that are both specifically located and known to not specifically located or known either not interfere with the operation of leakage to interfere with the operation of detection systems, or leakage detection systems or not to be c. RCS leakage through a steam pressure boundary leakage, or generator to the Secondary Coolant
- c. RCS leakage through a steam System (primary-to-secondary leakage).
generator to the Secondary Coolant Unidentified Leakage:
System (primary-to-secondary leakage). All leakage which is not identified Unidentified Leakage: leakage or controlled leakage.
All leakage which is not identified (Controlled leakage is that seal water Leakage or controlled leakage. flow supplied to the reactor coolant (Controlled leakage is that seal water pump seals.)
flow supplied to the reactor coolant Pressure Boundary Leakage:
pump seals.) Leakage (except primary-to-secondary Pressure Boundary Leakage: leakage) through a fault in a RCS Leakage (except primary-to-secondary component body, pipe wall, or vessel leakage) through a non-isolable fault in wall. Leakage past seals, packing, and a RCS component body, pipe wall, or gaskets is not pressure boundary vessel wall. leakage.
26 Att. 1, SU5.1 The first and second EAL conditions are The first and second EAL conditions are Basis, focused on a loss of mass from the focused on a loss of mass from the RCS Paragraph 6 RCS due to "unidentified leakage", due to "unidentified leakage", "pressure "pressure boundary leakage" or boundary leakage" or "identified "identified leakage" (as these leakage leakage" (as these leakage types are types are defined in the plant Technical defined in the plant Technical Specifications). The third condition Specifications). The third condition addresses an RCS mass loss caused addresses an RCS mass loss caused by by an UNISOLABLE leak through an a leak through an interfacing system.
interfacing system. These conditions These conditions thus apply to leakage thus apply to leakage into the into the containment, a secondary-side containment, a secondary-side system system (e.g., steam generator tube (e.g., steam generator tube leakage) or leakage) or a location outside of a location outside of containment. containment.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:
List all emergency plan sections that were reviewed for this activity by number and title.
IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.
Licensing Basis for NEI 99-01 Rev 6 EALs Letter from U.S. Nuclear Regulatory Commission to Duke Energy, "Shearon Harris Nuclear Power Plant Unit 1 -
Issuance of Amendment [149] to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors," dated April 13, 2016 (ADAMS Accession No. ML16057A838).
License Amendment 149 was implemented in EP-EAL, Emergency Actions Levels, Revision 17.
Letter from U.S. Nuclear Regulatory Commission to Duke Energy, "Catawba Nuclear Station, Units 1 and 2; McGuire Nuclear Station, Units 1 and 2; Oconee Nuclear Station, Units 1, 2, and 3; Brunswick Steam Electric plant, Units 1 and 2; Shearon Harris Nuclear Power Plant, Unit 1; and H.B. Robinson Steam Electric Plant, Unit No. 2 -
Issuance of Amendments [172 for HNP] to Revise Emergency Action Level Schemes to Incorporate Clarifications Provided by Emergency Preparedness Frequently Asked Questions 2015-013, 2015-014, and 2016-002 (EPID L-2018-LLA-0174)," dated July 1, 2019 (ADAMS Accession No. ML19058A632).
Letter from U.S. Nuclear Regulatory Commission to Duke Energy, "Shearon Harris Nuclear Power Plant Unit 1 -
Issuance of Amendment No. 173 Regarding Emergency Plan Emergency Action Level Scheme Change (EPID L-2018-LLA-0216)," dated July 18, 2019 (ADAMS Accession No. ML19108A173).
License Amendments 172 and 173 were implemented in EP-EAL, Emergency Actions Levels, Revision 20.
Current EALs Harris Nuclear Plant EAL Technical Basis Document, CSD-EP-HNP-0101-01, Revision 003 Licensing Basis EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 0 EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, Revision 0 Current Emergency Plan EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Section D - Emergency Classification System EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, Revision 1, Section D - Emergency Classification System The differences in the approved and the current revision of the Emergency Plan and EALs have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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Section IV: Ability to Maintain the Emergency Plan.
Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.
- 1. Do any of the elements of the proposed activity change information or intent contained in the Yes Emergency Plan? No
- 2. Do any elements of the proposed activity change the process or capability for alerting or notifying Yes the public as described in the FEMA-approved Alert and Notification System Design Report? No
- 3. Do any elements of the proposed activity change the Evacuation Time Estimate results? Yes No
- 4. Do any elements of the proposed activity change the On-Shift Staffing Analysis results? Yes No
- 5. Does the Proposed activity require a change to the Emergency Plan Programmatic Description? Yes No If Question 5 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.
Section IV conclusion:
If questions 1-5 in Section IV marked NO, then complete Section V.
If any question 1-5 of Section IV marked yes, then continue at Section VI.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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Section V: Maintaining the Emergency Plan Conclusion.
The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.
- 1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.
- 2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.
I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).
Conclusion:
Section VI: Activity Previously Reviewed?
Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?
10 CFR 50.54(q) Evaluation is not required.
Yes Identify bounding source document below and continue to Section XIV.
No Continue to Section VII.
If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.
Partially Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.
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Section VII: Editorial Changes All Activities/Changes identified in Section II are editorial/typographical changes such as Yes formatting, paragraph numbering, spelling, or punctuation that does not change intent.
None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to No Section VIII.
Partially Some Activities/Changes are editorial/typographical.
If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XII.
If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.
Justification:
The proposed changes below are defined as editorial in accordance with AD-EP-ALL-0602, Emergency Plan Change Screening and Effectiveness Evaluations 10 CFR 50.54(Q), and do not change the intent of the steps as written.
Proposed change 1 updates revision summary. Updating revision summary based on revision is editorial because it makes no changes to intent of the guidance.
Proposed change 2 updates revision number from 3 to 4 for EAL Technical Basis Document. Updating revision number is editorial because it makes no changes to intent of the guidance.
Proposed change 3 updates page numbers and the Table of Contents. Updating page numbers and the Table of Contents is editorial because it makes no changes to intent of the guidance.
Proposed changes 4 - 11, 16, 17, and 21 - 24 update references to procedures and correct references that are no longer applicable. Updating references to procedures and correcting references that are no longer applicable is editorial because it makes no changes to intent of the guidance.
Proposed change 12 corrects a misspelled word. Correcting misspelled words is editorial because it makes no changes to intent of the guidance.
Proposed change 13 corrects a typographical error in the system abbreviation. Correcting typographical errors is editorial because it makes no changes to intent of the guidance.
Proposed changes 14, 15, 18, and 19 are formatting changes only to comply with the guidance of AD-DC-ALL-0301, Development and Maintenance of Controlled Supporting Documents. These changes include:
Changing outline and substep bullets from "A.", "B", "C", to "1.", "2.", "3."
Adding numbering to Definitions Reformatting items into table-style format Placing periods "." after step numbers Bolding step numbers Adding section continuation headers Removing underline from substep numbers Reformatting attachment titles so that they are below the attachment number
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
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Reformatting fonts These changes make no change to intent, purpose, or order of the document steps. These formatting changes are editorial because there is no change to intent, purpose, or order of the document steps.
Proposed change 20 corrects the titles of Attachments 1, 2, and 3 to correspond to the titles used for these items in CSD-EP-ALL-0101-02, EAL Wallchart (Both Hot and Cold). Correcting references to steps, pages, attachments, forms, documents, tables, exhibits, and procedures is editorial because it makes no changes to intent of the guidance.
Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)
Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate box.
1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.
The response organization has the staff to respond and to augment staff on a continuing basis (24-7 1b staffing) in accordance with the emergency plan.
2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned 2b The process for timely augmentation of onshift staff is established and maintained.
3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.
3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.
4 10 CFR 50.47(b)(4) Emergency Classification System RS A standard scheme of emergency classification and action levels is in use. (Requires V/V 4a (Attachment 3) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS Procedures for notification of State and local governmental agencies are capable of alerting them of 5a the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.
Administrative and physical means have been established for alerting and providing prompt 5b instructions to public within the plume exposure pathway.
The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 5c Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter 6 10 CFR 50.47(b)(6) Emergency Communications Systems are established for prompt communication among principal emergency response 6a organizations.
6b Systems are established for prompt communication to emergency response personnel.
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7 10 CFR 50.47(b)(7) Public Education and Information Emergency preparedness information is made available to the public on a periodic basis within the 7a plume exposure pathway emergency planning zone (EPZ).
7b Coordinated dissemination of public information during emergencies is established.
8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response 8b Adequate equipment is maintained to support emergency response.
9 10 CFR 50.47(b)(9) Accident Assessment RS 9a Methods, systems, and equipment for assessment of radioactive releases are in use.
10 10 CFR 50.47(b) (10) Protective Response RS 10a A range of public PARs is available for implementation during emergencies.
Evacuation time estimates for the population located in the plume exposure pathway EPZ are 10b available to support the formulation of PARs and have been provided to State and local governmental authorities.
A range of protective actions is available for plant emergency workers during emergencies, including 10c those for hostile action events.
KI is available for implementation as a protective action recommendation in those jurisdictions that 10d chose to provide KI to the public.
11 10 CFR 50.47(b) (11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.
12 10 CFR 50.47(b) (12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.
13 10 CFR 50.47(b) (13) Recovery Planning and Post-Accident Operations 13a Plans for recovery and reentry are developed.
14 10 CFR 50.47(b) (14) Drills and Exercises A drill and exercise program (including radiological, medical, health physics and other program areas) 14a is established.
Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, 14b and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.
14c Identified weaknesses are corrected.
15 10 CFR 50.47(b) (15) Emergency Response Training 15a Training is provided to emergency responders.
16 10 CFR 50.47(b) (16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.
16b Planners responsible for emergency plan development and maintenance are properly trained.
Section VIII: Conclusion
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If any Section VIII criteria are checked, document the basis for conclusion below for any changes that are more than editorial, however not impacted by any of the identified criteria in Section VIII and continue the 50.54(q) Review in Section IX.
If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document justification below for any changes that are more than editorial and continue to Section XIV.
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Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.
Planning Standard A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Function (1) A standard scheme of emergency classification and action levels is in use.
Supporting requirements from Appendix E, IV to 10 CFR Part 50 B. Assessment Actions
- 1. The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC. Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis.
- 2. A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. Licensees shall follow the change process in § 50.54(q) for all other emergency action level changes.
C. Activation of Emergency Organization
- 1. The entire spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described. The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described. Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described. The existence, but not the details, of a message authentication scheme shall be noted for such agencies. The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG-0654/FEMA-REP-1.
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- 2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.
Informing criteria from Section II.D of NUREG-0654 Rev. 2 D. A standard emergency classification and action level scheme is established and maintained.
The scheme provides detailed EALs for each of the four ECLs in Section IV.C.1 of Appendix E to 10 CFR Part 50.
D.1.a The EALs are developed using guidance provided or endorsed by the NRC that is applicable to the reactor design.
D.1.b The initial emergency classification and action level scheme is discussed and agreed to by the licensee and OROs, and approved by the NRC. Thereafter, the scheme is reviewed with OROs on an annual basis.
D.2 The capability to assess, classify, and declare the emergency condition within 15 minutes after the availability of indications to NPP operators that an EAL has been met or exceeded is described.
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Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q). Address each Planning Standard identified in Section IX. Continue to Section XI.
Proposed change 25:
Proposed change is being made to update EAL SU5.1 basis definitions for identified, unidentified, and pressure boundary leakage. Paragraph 2 was originally written based on Harris Nuclear Plant Technical Specifications (TSs) Definitions section 1.1, as referenced at the end of the EAL basis (ref.1). This reference has been updated in Amendment No. 198 to Renewed Facility Operating License No. DPR-63 for the Harris Nuclear Plant, Unit No. 1. The amendment revises the TSs related to reactor coolant system operational leakage and the definition of the term "LEAKAGE" based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, "Revise Reactor Coolant Leakage Requirements."
Paragraph 2, part 1, changes:
From:
Identified Leakage:
- a. Leakage (except controlled leakage) into closed systems, such as pump seal or valve packing leaks that are captured and conducted to a sump or collecting tank , or
- b. Leakage into the containment atmosphere from sources that are both specifically located or known either not to interfere with the operation of leakage detection systems or not to be pressure boundary leakage, or
- c. RCS leakage through a steam generator to the Secondary Coolant System (primary-to-secondary leakage).
To:
Identified Leakage:
- a. Leakage, such as that from pump seals or valve packing (except controlled leakage), that is captured and conducted to a sump or collecting tank, or
- b. Leakage into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems, or
- c. RCS leakage through a steam generator to the Secondary Coolant System (primary-to-secondary leakage).
Revises the Identified Leakage definition to not exclude Pressure Boundary Leakage. The change to the definition of identified leakage applies to leakage from an RCS component that would be released directly into the containment atmosphere, where the leakage would be detectable by the RCS leakage detection systems. The revised definition of identified leakage removes the existing exclusion of leakage known to be pressure boundary leakage. Therefore, all RCS leakage that is specifically located and known to not interfere with the operation of leakage detection systems would be considered identified leakage, regardless of the source of leakage. Not excluding Pressure Boundary Leakage provides a clearer definition of identified leakage.
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Paragraph 2, part 2: No changes.
Paragraph 2, part 3, changes:
From:
Pressure Boundary Leakage:
Leakage (except primary-to-secondary leakage) through a non-isolable fault in a RCS component body, pipe wall, or vessel wall.
To:
Pressure Boundary Leakage:
Leakage (except primary-to-secondary leakage) through a fault in a RCS component body, pipe wall, or vessel wall. Leakage past seals, packing, and gaskets is not pressure boundary leakage.
Revises the defined term "leakage" to remove the term "non-isolable" from the definition of Pressure Boundary Leakage and added "Leakage past seals, packing, and gaskets is not pressure boundary leakage".
From NRC Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-554, Revision 1, "Revise Reactor Coolant Leakage Requirements," the word "unisolable" [the terms "unisolable" and "non-isolable" are used interchangeably herein] has been interpreted inconsistently in the definition of pressure boundary leakage. In some interpretations, it has been considered a means of emphasizing that the leakage fault is in the base material of the pressure boundary and, therefore, the leakage cannot be stopped by adjusting packing or seals. In such a case, the fault represents degradation of the pressure boundary material that could result in a loss of structural integrity. Another interpretation is that leakage through a fault in portions of the pressure boundary that can be separated from the RCS by an isolation device (typically an installed valve) need not be considered as pressure boundary leakage once the isolation device is performing its isolation function. This would allow certain small sections of the Reactor Coolant Pressure Boundary (RCPB) between the outermost two valves to be removed from consideration as RCPB leakage when the inner valve is closed. Regardless of the interpretation, deletion of the word "unisolable" does not alter the fundamental meaning that pressure boundary leakage represents degradation that could ultimately result in a loss of structural integrity. Therefore, removing the term "unisolable" provides a clearer definition of pressure boundary leakage.
The additional sentence "Leakage past seals, packing, and gaskets is not pressure boundary leakage." is consistent with the definition and was added for emphasis. Definition is clear that pressure boundary leakage is leakage through a fault in an RCS component body, pipe wall, or vessel wall. The additional reminder to exclude leakage from seals, packing, and gaskets which are not RCS component bodies, pipe walls, or vessel walls is an enhancement with no change to the intent of the definition.
The revised second paragraph, part 1, supports the 2nd EAL condition, "RCS identified leakage > 25 gpm for 15 min." and the revised second paragraph, part 3, supports the 1st EAL condition, "RCS unidentified or pressure boundary leakage > 10 gpm for 15 min.". These proposed changes remain consistent with the approved EAL scheme as described in the 6th paragraph of HNP EAL bases:
The first and second EAL conditions are focused on a loss of mass from the RCS due to "unidentified leakage", "pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications).
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These proposed changes remain consistent with NEI 99-01, Rev 6, EAL scheme for this EAL:
EAL #1 and EAL #2 are focused on a loss of mass from the RCS due to "unidentified leakage",
"pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications).
These proposed changes continue to support the first and second EAL conditions, because the definitions continue to be leakage types that are defined in the plant Technical Specifications.
The leakage definitions updated for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01, Rev. 6. The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an RCS leak. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 25 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01, Rev. 6, EAL scheme.
Proposed change 25 continues to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the basis of which include facility system and effluent parameters, is in use by Harris Nuclear Plant (HNP).
Proposed change 25 continues to comply with 10 CFR Part 50, Appendix E, IV.C.2, because HNP has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure HNP will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
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Proposed change 26:
Proposed change is being made to update EAL SU5.1 basis discussion for identified, unidentified, and pressure boundary leakage. Paragraph 6 was originally written based on Harris Nuclear Plant Technical Specifications (TSs) Definitions section 1.1, as referenced at the end of the EAL basis (ref.1). This reference has been updated in Amendment No. 198 to Renewed Facility Operating License No. DPR-63 for the Harris Nuclear Plant, Unit No. 1. The amendment revises the TSs related to reactor coolant system operational leakage and the definition of the term "LEAKAGE" based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, "Revise Reactor Coolant Leakage Requirements."
Paragraph 6 changes:
From:
The first and second EAL conditions are focused on a loss of mass from the RCS due to "unidentified leakage", "pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications). The third condition addresses an RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These conditions thus apply to leakage into the containment, a secondary side system (e.g., steam generator tube leakage) or a location outside of containment.
To:
The first and second EAL conditions are focused on a loss of mass from the RCS due to "unidentified leakage", "pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications). The third condition addresses an RCS mass loss caused by a leak through an interfacing system. These conditions thus apply to leakage into the containment, a secondary side system (e.g., steam generator tube leakage) or a location outside of containment.
Revises the paragraph to remove the term "unisolable" from the discussion of the basis for the third EAL condition.
From NRC Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-554, Revision 1, "Revise Reactor Coolant Leakage Requirements," the word "unisolable" has been interpreted inconsistently in the definition of pressure boundary leakage. In some interpretations, it has been considered a means of emphasizing that the leakage fault is in the base material of the pressure boundary and, therefore, the leakage cannot be stopped by adjusting packing or seals. In such a case, the fault represents degradation of the pressure boundary material that could result in a loss of structural integrity. Another interpretation is that leakage through a fault in portions of the pressure boundary that can be separated from the RCS by an isolation device (typically an installed valve) need not be considered as pressure boundary leakage once the isolation device is performing its isolation function.
This would allow certain small sections of the Reactor Coolant Pressure Boundary (RCPB) between the outermost two valves to be removed from consideration as RCPB leakage when the inner valve is closed.
Regardless of the interpretation, deletion of the word "unisolable" does not alter the fundamental meaning that pressure boundary leakage represents degradation that could ultimately result in a loss of structural integrity. Therefore, removing the term "unisolable" brings the discussion into alignment with the revised definition of "pressure boundary leakage" as noted in Proposed Change 3 above.
Proposed change 26 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01, Rev. 6, EAL scheme.
Proposed change 26 continues to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the basis of which include facility system and effluent parameters, is in use by Harris Nuclear Plant (HNP).
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Proposed change 26 continues to comply with 10 CFR Part 50, Appendix E, IV.C.2, because HNP has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure HNP will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.
Proposed change 25:
Proposed change is being made to update EAL SU5.1 basis definitions for identified, unidentified, and pressure boundary leakage. Paragraph 2 was originally written based on Harris Nuclear Plant Technical Specifications (TSs) Definitions section 1.1, as referenced at the end of the EAL basis (ref.1). This reference has been updated in Amendment No. 198 to Renewed Facility Operating License No. DPR-63 for the Harris Nuclear Plant, Unit No. 1. The amendment revises the TSs related to reactor coolant system operational leakage and the definition of the term "LEAKAGE" based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, "Revise Reactor Coolant Leakage Requirements."
Paragraph 2, part 1, changes:
From:
Identified Leakage:
- a. Leakage (except controlled leakage) into closed systems, such as pump seal or valve packing leaks that are captured and conducted to a sump or collecting tank , or
- b. Leakage into the containment atmosphere from sources that are both specifically located or known either not to interfere with the operation of leakage detection systems or not to be pressure boundary leakage, or
- c. RCS leakage through a steam generator to the Secondary Coolant System (primary-to-secondary leakage).
To:
Identified Leakage:
- a. Leakage, such as that from pump seals or valve packing (except controlled leakage), that is captured and conducted to a sump or collecting tank, or
- b. Leakage into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems, or
- c. RCS leakage through a steam generator to the Secondary Coolant System (primary-to-secondary leakage).
Revises the Identified Leakage definition to not exclude Pressure Boundary Leakage. The change to the definition of identified leakage applies to leakage from an RCS component that would be released directly into the containment atmosphere, where the leakage would be detectable by the RCS leakage detection systems. The revised definition of identified leakage removes the existing exclusion of leakage known to be pressure boundary leakage. Therefore, all RCS leakage that is specifically located and known to not interfere with the operation of leakage detection systems would be considered identified leakage, regardless of the source of leakage. Not excluding Pressure Boundary Leakage provides a clearer definition of identified leakage.
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Paragraph 2, part 2: No changes.
Paragraph 2, part 3, changes:
From:
Pressure Boundary Leakage:
Leakage (except primary-to-secondary leakage) through a non-isolable fault in a RCS component body, pipe wall, or vessel wall.
To:
Pressure Boundary Leakage:
Leakage (except primary-to-secondary leakage) through a fault in a RCS component body, pipe wall, or vessel wall. Leakage past seals, packing, and gaskets is not pressure boundary leakage.
Revises the defined term "leakage" to remove the term "non-isolable" from the definition of Pressure Boundary Leakage and added "Leakage past seals, packing, and gaskets is not pressure boundary leakage".
From NRC Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-554, Revision 1, "Revise Reactor Coolant Leakage Requirements," the word "unisolable" [the terms "unisolable" and "non-isolable" are used interchangeably herein] has been interpreted inconsistently in the definition of pressure boundary leakage. In some interpretations, it has been considered a means of emphasizing that the leakage fault is in the base material of the pressure boundary and, therefore, the leakage cannot be stopped by adjusting packing or seals. In such a case, the fault represents degradation of the pressure boundary material that could result in a loss of structural integrity. Another interpretation is that leakage through a fault in portions of the pressure boundary that can be separated from the RCS by an isolation device (typically an installed valve) need not be considered as pressure boundary leakage once the isolation device is performing its isolation function. This would allow certain small sections of the Reactor Coolant Pressure Boundary (RCPB) between the outermost two valves to be removed from consideration as RCPB leakage when the inner valve is closed. Regardless of the interpretation, deletion of the word "unisolable" does not alter the fundamental meaning that pressure boundary leakage represents degradation that could ultimately result in a loss of structural integrity. Therefore, removing the term "unisolable" provides a clearer definition of pressure boundary leakage.
The additional sentence "Leakage past seals, packing, and gaskets is not pressure boundary leakage." is consistent with the definition and was added for emphasis. Definition is clear that pressure boundary leakage is leakage through a fault in an RCS component body, pipe wall, or vessel wall. The additional reminder to exclude leakage from seals, packing, and gaskets which are not RCS component bodies, pipe walls, or vessel walls is an enhancement with no change to the intent of the definition.
The revised second paragraph, part 1, supports the 2nd EAL condition, "RCS identified leakage > 25 gpm for 15 min." and the revised second paragraph, part 3, supports the 1st EAL condition, "RCS unidentified or pressure boundary leakage > 10 gpm for 15 min.". These proposed changes remain consistent with the approved EAL scheme as described in the 6th paragraph of HNP EAL bases:
The first and second EAL conditions are focused on a loss of mass from the RCS due to "unidentified leakage", "pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications).
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These proposed changes remain consistent with NEI 99-01, Rev 6, EAL scheme for this EAL:
EAL #1 and EAL #2 are focused on a loss of mass from the RCS due to "unidentified leakage",
"pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications).
These proposed changes continue to support the first and second EAL conditions, because the definitions continue to be leakage types that are defined in the plant Technical Specifications.
The leakage definitions updated for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01, Rev. 6. The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an RCS leak. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 25 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01, Rev. 6, EAL scheme.
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Proposed change 26:
Proposed change is being made to update EAL SU5.1 basis discussion for identified, unidentified, and pressure boundary leakage. Paragraph 6 was originally written based on Harris Nuclear Plant Technical Specifications (TSs) Definitions section 1.1, as referenced at the end of the EAL basis (ref.1). This reference has been updated in Amendment No. 198 to Renewed Facility Operating License No. DPR-63 for the Harris Nuclear Plant, Unit No. 1. The amendment revises the TSs related to reactor coolant system operational leakage and the definition of the term "LEAKAGE" based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, "Revise Reactor Coolant Leakage Requirements."
Paragraph 6 changes:
From:
The first and second EAL conditions are focused on a loss of mass from the RCS due to "unidentified leakage", "pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications). The third condition addresses an RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These conditions thus apply to leakage into the containment, a secondary side system (e.g., steam generator tube leakage) or a location outside of containment.
To:
The first and second EAL conditions are focused on a loss of mass from the RCS due to "unidentified leakage", "pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications). The third condition addresses an RCS mass loss caused by a leak through an interfacing system. These conditions thus apply to leakage into the containment, a secondary side system (e.g., steam generator tube leakage) or a location outside of containment.
Revises the paragraph to remove the term "unisolable" from the discussion of the basis for the third EAL condition.
From NRC Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-554, Revision 1, "Revise Reactor Coolant Leakage Requirements," the word "unisolable" has been interpreted inconsistently in the definition of pressure boundary leakage. In some interpretations, it has been considered a means of emphasizing that the leakage fault is in the base material of the pressure boundary and, therefore, the leakage cannot be stopped by adjusting packing or seals. In such a case, the fault represents degradation of the pressure boundary material that could result in a loss of structural integrity. Another interpretation is that leakage through a fault in portions of the pressure boundary that can be separated from the RCS by an isolation device (typically an installed valve) need not be considered as pressure boundary leakage once the isolation device is performing its isolation function.
This would allow certain small sections of the Reactor Coolant Pressure Boundary (RCPB) between the outermost two valves to be removed from consideration as RCPB leakage when the inner valve is closed.
Regardless of the interpretation, deletion of the word "unisolable" does not alter the fundamental meaning that pressure boundary leakage represents degradation that could ultimately result in a loss of structural integrity. Therefore, removing the term "unisolable" brings the discussion into alignment with the revised definition of "pressure boundary leakage" as noted in Proposed Change 3 above.
Proposed change 26 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01, Rev. 6, EAL scheme.
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The proposed changes can be made because the changes continue to ensure a standard scheme of emergency classification and action levels are in use and there is no negative impact to timeliness or accuracy.
The proposed changes do not reduce the effectiveness of the Harris Nuclear Plant Emergency Plan. The change continues to provide assurance that the Emergency Response Organization has the ability and capability to:
- respond to an emergency;
- perform functions in a timely manner;
- effectively identify and take measures to ensure protection of the public health and safety; and
- effectively use response equipment and emergency response procedures.
The change continues to meet NRC requirements, as described in 10 CFR 50.47(b)(4) and 10 CFR 50, Appendix E as well as the requirements of the Harris Nuclear Plant Emergency Plan as written and approved.
Section XII: Evaluation Conclusion Answer the following questions about the proposed change:
- 1. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? Yes No
- 2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in Yes effectiveness)? No
- 3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes No Section XII: Conclusion Questions 1, 2 and 3 are answered YES, complete step below to create a General CAS assignment, and then continue on to Section XIV and implement change(s).
General CAS assignment created- Licensing submit changes in accordance with 10 CFR 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XIII and Section XIV.
Section XIII: Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change be submitted to the NRC for prior approval?
Yes If No, reject the proposed change, or modify the proposed change and perform a new evaluation. No Continue to Section XIV for this evaluation.
If YES, then initiate a License Amendment Request in accordance 10 CFR 50.90, AD-LS-ALL-0002, Regulatory Correspondence, and AD-LS-ALL-0015, License Amendment Request and Changes to SLC, TRM, and TS Bases, and include the tracking number:___________________________________. Complete Section XIV.
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Section XIV: Signatures:
EP CFAM Final Approval is required for changes affecting Program Element 4a of Section VIII. If CFAM approval is NOT required, then mark the EP CFAM signature block as not applicable (N/A) to indicate that signature is not required.Section XIV as applicable.
Preparer Name (Print): Preparer Signature: Date:
David Bell See NAS See NAS Reviewer Name (Print): Reviewer Signature: Date:
Eric White See NAS See NAS Approver Name (Print): Approver Signature: Date:
Jamey Sharlow See NAS See NAS Approver (EP CFAM, as required) Name (Print): Approver Signature: Date:
David Thompson See NAS See NAS QA RECORD
- Old Section 5.1 - Old Section 5.1 - Old Section 5.1 - Old Section 5.1 - Old Section 5.1 - New Section 5.1 - New Section 5.1 - New Section 5.1 - New Section 5.1 - New Section 5.1 - Old Section 5.2 - Old Section 5.2 - New Section 5.2 - New Section 5.2 - New Section 5.2 U.S. Nuclear Regulatory Commission Attachment 2 Serial: RA-23-0325 Attachment 2: Procedure CSD-EP-MNS-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 4 and CSD-EP-MNS-0101-02, EAL WALLCHART (BOTH HOT AND COLD),
Revision 004, 10 CFR 50.54(q)
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ATTACHMENT 2 Page 1 of 33
<< 10 CFR 50.54(q) Review Form >>
Section I: 10 CFR 50.54(q) Review Number: (EREG #): 02487495 Applicable Sites and Applicability Determination # (5AD)
BNP CNS HNP MNS 02487493, 02490790 ONS RNP Document #, EC #, or Revision # or N/A N/A Document or Activity Title CSD-EP-MNS-0101-01 4 EAL Technical Basis Document CSD-EP-MNS-0101-02 004 EAL WALLCHART (BOTH HOT AND COLD)
Section II: Identify/Describe All Proposed Activities/Changes being Reviewed Event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan (Use attachments, or continue additional pages as necessary): Continue to Section III.
CSD-EP-MNS-0101-01 is the Emergency Action Level (EAL) Technical Basis Document and CSD-EP-MNS-0101-02 is the EAL Wallchart for McGuire Nuclear Station (MNS).
This proposed revision includes -
Clarify use of SATA/SATB as a power source for EALs SU1.1, SA1.1, SS1.1, SG1.1, SG1.2, CU2.1 and CA2.1 in EALs and Basis discussion Revise EAL HU2.1 to add additional option for determining an earthquake should the OBE Exceeded alarm be out of service in EAL and Basis discussion Updated EAL SU5.1 basis definitions of Reactor Coolant System (RCS) leakage as a result of revised Technical Specifications (TSs) related to reactor coolant system operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements..
Revise the hyperlink for http://earthquake.usgs.gov to point to the correct website in EAL Basis discussion Correct formatting for EALs on new pages 224, 254, 255 and 257 Correct spelling of Non e on new page 213 Change title of Step Action column to Action on Attachment 3 Change Section or Step Change From Change to CSD-EP-MNS-0101 EAL Technical Basis Document 1 Cover Page Revision 3 Revision 4 Effective Date: 01/31/23 Effective Date: 12/12/23 2 Header CSD-EP-MNS-0101-01 CSD-EP-MNS-0101-01 Throughout Rev 3 Rev 4 Page # of 264 Page # of 266 3 Table of Page number references for Revision 3 Page number references for Revision 4 Contents -
Rev 3 page 3 Rev 4 page 3
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4 EAL CU2.1, Table C Rev 3 page 87 Rev 4 page 87 5 EAL CU2.1 Basis Discussion - The essential buses are normally The essential buses are normally Rev 3 page 88 powered from the 6.9KV offsite power powered from the 6.9KV offsite power Rev 4 page 88 system through their respective system through their respective 6.9KV/4160V Station Auxiliary 6.9KV/4160V Station Auxiliary Transformers (1ATC & 1ATD). Transformers (1ATC & 1ATD).
Additionally, a standby source of power Additionally, a standby source of power to each 4160V essential bus is provided to each 4160V essential bus is provided from the 6.9KV offsite power system via from the 6.9KV offsite power system via two separate and independent two separate and independent 6.9KV/4160V transformers (SATA & 6.9KV/4160V transformers (SATA &
SATB). These transformers are shared SATB). These transformers are shared between the two units (ref. 1, 2). between the two units (ref. 1, 2).
However, alignment of SATA or SATB to an essential bus takes longer than 15 minutes and therefore should only be credited if already aligned.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR Rev. 9 50.54(Q)
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6 EAL CA2.1 Basis Discussion - The essential buses are normally The essential buses are normally Rev 3 page 90 powered from the 6.9KV offsite power powered from the 6.9KV offsite power Rev 4 page 90 system through their respective system through their respective 6.9KV/4160V Station Auxiliary 6.9KV/4160V Station Auxiliary Transformers (1ATC & 1ATD). Transformers (1ATC & 1ATD).
Additionally, a standby source of power Additionally, a standby source of power to each 4160V essential bus is provided to each 4160V essential bus is provided from the 6.9KV offsite power system via from the 6.9KV offsite power system via two separate and independent two separate and independent 6.9KV/4160V transformers (SATA & 6.9KV/4160V transformers (SATA &
SATB). These transformers are shared SATB). These transformers are shared between the two units (ref. 1, 2). between the two units (ref. 1, 2).
However, alignment of SATA or SATB to an essential bus takes longer than 15 minutes and therefore should only be credited if already aligned.
7 EAL HU2.1 - HU2.1 Unusual Event HU2.1 Unusual Event Rev 3 page 125 Rev 4 page 125 Seismic event > OBE as indicated by Seismic event > OBE as indicated by OBE EXCEEDED alarm on 1AD-13, E7 OBE EXCEEDED alarm on 1AD-13, E7 OR Seismic monitoring instrumentation is unavailable to the extent that an OBE cannot be determined (e.g., out-of-service for failed equipment, testing or maintenance).
AND Control Room personnel feel an actual or potential seismic event.
AND The occurrence of a seismic event is confirmed in manner deemed appropriate by the Shift Manager or Emergency Coordinator.
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8 EAL HU2.1 Basis Discussion - Event verification with external sources Event verification with external sources Rev 3 page 126 should not be necessary during or should not be necessary during or Rev 4 page 126 following an OBE. Earthquakes of this following an OBE. Earthquakes of this magnitude should be readily felt by on- magnitude should be readily felt by on-Added new site personnel and recognized as a site personnel and recognized as a paragraph 8 seismic event (e.g., lateral accelerations seismic event (e.g., lateral accelerations in excess of 0.08g). The Shift Manager in excess of 0.08g). The Shift Manager or Emergency Coordinator may seek or Emergency Coordinator may seek external verification if deemed external verification if deemed appropriate (e.g., a call to the USGS, appropriate (e.g., a call to the USGS, check internet news sources, etc.); check internet news sources, etc.);
however, the verification action must however, the verification action must not not preclude a timely emergency preclude a timely emergency declaration. declaration.
Depending upon the plant mode at the The second EAL threshold is used time of the event, escalation of the during periods when the occurrence of emergency classification level would be an OBE cannot be determined because via IC CA6 or SA9. the seismic monitoring instrumentation is out-of-service. The EAL statement The occurrence of a seismic event is confirmed in manner deemed appropriate by the Shift Manager or Emergency Coordinator. is included to ensure that a declaration does not result from felt vibrations caused by a non-seismic source (e.g., a dropped heavy load). The Shift Manager or Emergency Coordinator may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or SA9.
9 EAL HU2.1 http://earthquake.usgs.gov http://earthquake.usgs.gov Basis Discussion -
Rev 3 page 125 Rev 4 page 126
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10 EAL SU1.1, Table S Rev 3 page 156 Rev 4 page 157 11 EAL SU1.1 Basis Discussion - The essential buses are normally The essential buses are normally Rev 3 page 156- powered from the 6.9KV offsite power powered from the 6.9KV offsite power 157 system through their respective system through their respective Rev 4 page 157- 6.9KV/4160V Station Auxiliary 6.9KV/4160V Station Auxiliary 158 Transformers (1ATC & 1ATD). Transformers (1ATC & 1ATD).
Additionally, a standby source of power Additionally, a standby source of power to each 4160V essential bus is provided to each 4160V essential bus is provided from the 6.9KV offsite power system via from the 6.9KV offsite power system via two separate and independent two separate and independent 6.9KV/4160V transformers (SATA & 6.9KV/4160V transformers (SATA &
SATB). These transformers are shared SATB). These transformers are shared between the two units (ref. 1, 2). between the two units (ref. 1, 2).
However, alignment of SATA or SATB to an essential bus takes longer than 15 minutes and therefore should only be credited if already aligned.
12 EAL SA1.1, Table S Rev 3 page 158 Rev 4 page 159
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13 EAL SA1.1 Basis Discussion - The essential buses are normally The essential buses are normally Rev 3 page 159 powered from the 6.9KV offsite power powered from the 6.9KV offsite power Rev 4 page 160 system through their respective system through their respective 6.9KV/4160V Station Auxiliary 6.9KV/4160V Station Auxiliary Transformers (1ATC & 1ATD). Transformers (1ATC & 1ATD).
Additionally, a standby source of power Additionally, a standby source of power to each 4160V essential bus is provided to each 4160V essential bus is provided from the 6.9KV offsite power system via from the 6.9KV offsite power system via two separate and independent two separate and independent 6.9KV/4160V transformers (SATA & 6.9KV/4160V transformers (SATA &
SATB). These transformers are shared SATB). These transformers are shared between the two units (ref. 1, 2). between the two units (ref. 1, 2).
However, alignment of SATA or SATB to an essential bus takes longer than 15 minutes and therefore should only be credited if already aligned.
14 EAL SS1.1 Basis Discussion - The essential buses are normally The essential buses are normally Rev 3 page 161 powered from the 6.9KV offsite power powered from the 6.9KV offsite power Rev 4 page 162 system through their respective system through their respective 6.9KV/4160V Station Auxiliary 6.9KV/4160V Station Auxiliary Transformers (1ATC & 1ATD). Transformers (1ATC & 1ATD).
Additionally, a standby source of power Additionally, a standby source of power to each 4160V essential bus is provided to each 4160V essential bus is provided from the 6.9KV offsite power system via from the 6.9KV offsite power system via two separate and independent two separate and independent 6.9KV/4160V transformers (SATA & 6.9KV/4160V transformers (SATA &
SATB). These transformers are shared SATB). These transformers are shared between the two units (ref. 1, 2). between the two units (ref. 1, 2).
However, alignment of SATA or SATB to an essential bus takes longer than 15 minutes and therefore should only be credited if already aligned.
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15 EAL SG1.1 Basis Discussion - The essential buses are normally The essential buses are normally Rev 3 page 163 powered from the 6.9KV offsite power powered from the 6.9KV offsite power Rev 4 page 164 system through their respective system through their respective 6.9KV/4160V Station Auxiliary 6.9KV/4160V Station Auxiliary Transformers (1ATC & 1ATD). Transformers (1ATC & 1ATD).
Additionally, a standby source of power Additionally, a standby source of power to each 4160V essential bus is provided to each 4160V essential bus is provided from the 6.9KV offsite power system via from the 6.9KV offsite power system via two separate and independent two separate and independent 6.9KV/4160V transformers (SATA & 6.9KV/4160V transformers (SATA &
SATB). These transformers are shared SATB). These transformers are shared between the two units (ref. 1, 2). between the two units (ref. 1, 2).
However, alignment of SATA or SATB to an essential bus takes longer than 15 minutes and therefore should only be credited if already aligned.
16 EAL SG1.2 Basis Discussion - The essential buses are normally The essential buses are normally Rev 3 page 166 powered from the 6.9KV offsite power powered from the 6.9KV offsite power Rev 4 page 167 system through their respective system through their respective 6.9KV/4160V Station Auxiliary 6.9KV/4160V Station Auxiliary Transformers (1ATC & 1ATD). Transformers (1ATC & 1ATD).
Additionally, a standby source of power Additionally, a standby source of power to each 4160V essential bus is provided to each 4160V essential bus is provided from the 6.9KV offsite power system via from the 6.9KV offsite power system via two separate and independent two separate and independent 6.9KV/4160V transformers (SATA & 6.9KV/4160V transformers (SATA &
SATB). These transformers are shared SATB). These transformers are shared between the two units (ref. 1, 2). between the two units (ref. 1, 2).
However, alignment of SATA or SATB to an essential bus takes longer than 15 minutes and therefore should only be credited if already aligned.
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17 EAL SU5.1 ...
Basis Discussion - Identified leakage includes leakage Identified leakage includes leakage such Rev 3 page 176 such as that from pump seals or valve as that from pump seals or valve packing Rev 4 page 177 packing (except reactor coolant pump (except reactor coolant pump (RCP) seal (NCP) seal water injection or leakoff), water injection or leakoff), that is that is captured and conducted to captured and conducted to collection collection systems or a sump or systems or a sump or collecting tank, collecting tank, leakage into the leakage into the containment containment atmosphere from sources atmosphere from sources that are both that are both specifically located and specifically located and known to not known either not to interfere with the interfere with the operation of leakage operation of leakage detection systems detection systems; or Reactor Coolant or not to be pressure boundary leakage; System (NCS) leakage through a steam or NCS leakage through a steam generator to the secondary system generator to the secondary system (primary to secondary leakage) (ref. 1).
(primary to secondary leakage) (ref. 1).
Unidentified leakage is all leakage Unidentified leakage is all leakage (except RCP seal water injection or (except NCP seal water injection or leakoff) that is not identified leakage (ref.
leakoff) that is not identified leakage 1).
(ref. 1).
Pressure Boundary leakage is leakage Pressure Boundary leakage is leakage (except primary to secondary leakage)
(except primary to secondary leakage) through a fault in an NCS component through a nonisolable fault in an NCS body, pipe wall, or vessel wall. Leakage component body, pipe wall, or vessel past seals, packing, and gaskets is not wall (ref. 1) pressure boundary leakage. (ref. 1) 18 Barrier: Threshold: Threshold:
Fuel Clad Category: Non e None
Loss Rev 3 page 212 Rev 4 page 213
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19 Attachment 2, Degradation Threat: Potential Loss Degradation Threat: Potential Loss Added carriage Threshold:
returns - Threshold:
Rev 3 pages 223, 253, 254, and 255 Rev 4 pages 224, 254, 255 and 257 20 Attachment 2, Automatic or manual ECCS If EOPs direct operators to open the If EOPs direct operators to open the (SI) Basis Pressurizer pressure relief valves to Pressurizer pressure relief valves to Discussion - implement a core cooling strategy (i.e., implement a core cooling strategy (i.e., a Rev 3 page 227 a feed and bleed cooldown), then feed and bleed cooldown), then there Rev 4 page 228 there will exist a reactor coolant flow will exist a reactor coolant flow path from path from the RCS, past the the NCS, past the pressurizer safety pressurizer safety and relief valves and relief valves and into the and into the containment that operators containment that operators cannot cannot isolate without compromising the isolate without compromising the effectiveness of the strategy (i.e., for the effectiveness of the strategy (i.e., for the strategy to be effective, the valves must strategy to be effective, the valves must be kept in the open position); therefore, be kept in the open position); therefore, the flow through the pressure relief line the flow through the pressure relief line is UNISOLABLE. In this case, the ability is UNISOLABLE. In this case, the ability of the RCS pressure boundary to serve of the NCS pressure boundary to serve as an effective barrier to a release of as an effective barrier to a release of fission products has been eliminated fission products has been eliminated and and thus this condition constitutes a thus this condition constitutes a loss of loss of the RCS barrier. the NCS barrier.
21 Attachment 3, Step Action Action Second Column Header Title Rev 3 pages 260 to 264 Rev 4 pages 262 to 266
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CSD-EP-MNS-0101 EAL WALLCHART (BOTH HOT AND COLD) 22 Revision McGuire Nuclear Station McGuire Nuclear Station Information CSD-EP-MNS-0101-02 Rev 003 CSD-EP-MNS-0101-02 Rev 004 23 Table S-1 24 Table C-2 25 EAL HU2.1
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Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:
List all emergency plan sections that were reviewed for this activity by number and title.
IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.
Licensing Basis for NEI 99-01 Rev 6 EALs ML16083A208 Letter Dated May 24, 2016.
Subject:
McGuire Nuclear Station, Units 1 and 2 - Issuance of Amendments regarding Emergency Action Level Scheme Change.
Amendment No. 286 to Renewed Facility Operating License (RFOL) No. NPF-9 and Amendment No. 265 to RFOL No. NPF-17 for the McGuire Nuclear Station, Units 1 and 2, respectively.
Additional Licensing basis to implement FAQs ML19058A632 Letter dated July 1, 2019.
Subject:
Catawba Nuclear Station, Units 1 And 2; McGuire Nuclear Station, Units 1 And 2; Oconee Nuclear Station, Units 1, 2, And 3; Brunswick Steam Electric Plant, Units 1 And 2; Shearon Harris Nuclear Power Plant, Unit 1; And H. B. Robinson Steam Electric Plant, Unit No. 2 - Issuance of Amendments To Revise Emergency Action Level Schemes To Incorporate Clarifications Provided By Emergency Preparedness Frequently Asked Questions 2015-013, 2015-014, And 2016-002 (EPID L-2018-LLA-0174)
Amendment Nos. 303 and 299 to Renewed Facility Operating License Nos. NPF-35 and NPF-52 for the Catawba Nuclear Station, Units 1 and 2 (Catawba), respectively; Amendment Nos. 315 and 294 to Renewed Facility Operating License Nos. NPF-9 and NPF-17 for the McGuire Nuclear Station, Units 1 and 2 (McGuire), respectively; Amendment Nos. 412, 414, and 413 to Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55 for the Oconee Nuclear Station, Units 1, 2, and 3 (Oconee), respectively; Amendment Nos. 291 and 319 to Renewed Facility Operating License Nos. DPR-71 and DPR-62 for Brunswick Steam Electric Plant, Units 1 and 2 (Brunswick), respectively; Amendment No. 172 to Renewed Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris); and Amendment No. 264 to Renewed Facility Operating License No.
DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (Robinson).
Current EALs McGuire Nuclear Station Emergency Action Levels, CSD-EP-MNS-0101-01, Revision 003 Licensing Basis EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 0 EP-MNS-EPLAN-ANNEX, Duke Energy McGuire Emergency Plan Annex, Revision 0 Current Emergency Plan EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Section D - Emergency Classification System EP-MNS-EPLAN-ANNEX, Duke Energy McGuire Emergency Plan Annex, Revision 2, Section D -
Emergency Classification System The differences in approved revisions and the current revisions of the Emergency Plans have been reviewed, and they have been determined to meet regulatory requirements during the course of revisions.
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Section IV: Ability to Maintain the Emergency Plan.
Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.
- 1. Do any of the elements of the proposed activity change information or intent contained in the Yes Emergency Plan? No
- 2. Do any elements of the proposed activity change the process or capability for alerting or notifying Yes the public as described in the FEMA-approved Alert and Notification System Design Report? No
- 3. Do any elements of the proposed activity change the Evacuation Time Estimate results? Yes No
- 4. Do any elements of the proposed activity change the On-Shift Staffing Analysis results? Yes No
- 5. Does the Proposed activity require a change to the Emergency Plan Programmatic Description? Yes No If Question 5 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.
Section IV conclusion:
If questions 1-5 in Section IV marked NO, then complete Section V.
If any question 1-5 of Section IV marked yes, then continue at Section VI.
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Section V: Maintaining the Emergency Plan Conclusion.
The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.
- 1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.
- 2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.
I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).
Section VI: Activity Previously Reviewed?
Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?
10 CFR 50.54(q) Evaluation is not required.
Yes Identify bounding source document below and continue to Section XIV.
No Continue to Section VII.
If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.
Partially Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.
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Section VII: Editorial Changes All Activities/Changes identified in Section II are editorial/typographical changes such as Yes formatting, paragraph numbering, spelling, or punctuation that does not change intent.
None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to No Section VIII.
Partially Some Activities/Changes are editorial/typographical.
If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XII.
If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.
Justification:
The proposed changes below are defined as editorial in accordance with AD-EP-ALL-0602, and do not change the intent of the steps as written.
Proposed change 1 - Updates the revision number and effective date on the cover page as a result of the revision process to the document. This proposed change is a result of updating the document during the revision process, and does not change intent of the procedure. Therefore, the proposed change is considered editorial.
Proposed change 2 - Updates the revision number and page numbering in the procedure header as a result of the revision process to the document. These proposed changes are a result of updating the document during the revision process, and do not change intent of the procedure. Therefore, these proposed changes are considered editorial.
Proposed change 3 - Updates the page number references in the Table of Contents as a result of the revision process to the document. This proposed change is a result of updating the document during the revision process, and does not change intent of the procedure. Therefore, the proposed change is considered editorial.
Proposed change 18 - Updates the spelling of Non e to None. This proposed change corrects a spelling/typographical error in the document, and does not change intent of the procedure. Therefore, the proposed change is considered editorial.
Proposed change 19 - Updates a formatting issue to add a carriage return between Degradation Threat:
Potential Loss and Threshold:. This proposed change corrects a formatting issue to align the format for Attachment 2 EAL information, and does not change intent of the procedure. Therefore, the proposed change is considered editorial.
Proposed change 22 - Updates the revision number of the document as a result of the revision process to the document. This proposed change is a result of updating the document during the revision process, and does not change intent of the procedure. Therefore, the proposed change is considered editorial.
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Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)
Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate box.
1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.
The response organization has the staff to respond and to augment staff on a continuing basis (24-7 1b staffing) in accordance with the emergency plan.
2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned 2b The process for timely augmentation of onshift staff is established and maintained.
3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.
3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.
4 10 CFR 50.47(b)(4) Emergency Classification System RS A standard scheme of emergency classification and action levels is in use. (Requires V/V 4a (Attachment 3) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS Procedures for notification of State and local governmental agencies are capable of alerting them of 5a the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.
Administrative and physical means have been established for alerting and providing prompt 5b instructions to public within the plume exposure pathway.
The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 5c Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter 6 10 CFR 50.47(b)(6) Emergency Communications Systems are established for prompt communication among principal emergency response 6a organizations.
6b Systems are established for prompt communication to emergency response personnel.
7 10 CFR 50.47(b)(7) Public Education and Information Emergency preparedness information is made available to the public on a periodic basis within the 7a plume exposure pathway emergency planning zone (EPZ).
7b Coordinated dissemination of public information during emergencies is established.
8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response
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8b Adequate equipment is maintained to support emergency response.
9 10 CFR 50.47(b)(9) Accident Assessment RS 9a Methods, systems, and equipment for assessment of radioactive releases are in use.
10 10 CFR 50.47(b) (10) Protective Response RS 10a A range of public PARs is available for implementation during emergencies.
Evacuation time estimates for the population located in the plume exposure pathway EPZ are 10b available to support the formulation of PARs and have been provided to State and local governmental authorities.
A range of protective actions is available for plant emergency workers during emergencies, including 10c those for hostile action events.
KI is available for implementation as a protective action recommendation in those jurisdictions that 10d chose to provide KI to the public.
11 10 CFR 50.47(b) (11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.
12 10 CFR 50.47(b) (12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.
13 10 CFR 50.47(b) (13) Recovery Planning and Post-Accident Operations 13a Plans for recovery and reentry are developed.
14 10 CFR 50.47(b) (14) Drills and Exercises A drill and exercise program (including radiological, medical, health physics and other program areas) 14a is established.
Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, 14b and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.
14c Identified weaknesses are corrected.
15 10 CFR 50.47(b) (15) Emergency Response Training 15a Training is provided to emergency responders.
16 10 CFR 50.47(b) (16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.
16b Planners responsible for emergency plan development and maintenance are properly trained.
Section VIII: Conclusion If any Section VIII criteria are checked, document the basis for conclusion below for any changes that are more than editorial, however not impacted by any of the identified criteria in Section VIII and continue the 50.54(q) Review in Section IX.
If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document justification below for any changes that are more than editorial and continue to Section XIV.
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<< 10 CFR 50.54(q) Review Form >>
Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.
Planning Standard A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Function (1) A standard scheme of emergency classification and action levels is in use.
Supporting requirements from Appendix E to 10 CFR Part 50 B. Assessment Actions
- 1. The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC. Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis.
- 2. A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. Licensees shall follow the change process in § 50.54(q) for all other emergency action level changes.
C. Activation of Emergency Organization
- 1. The entire spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described. The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described. Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described. The existence, but not the details, of a message authentication scheme shall be noted for such agencies. The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG-0654/FEMA-REP-1.
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<< 10 CFR 50.54(q) Review Form >>
- 2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.
Informing criteria from Section II.D of NUREG-0654 Rev. 2 D. A standard emergency classification and action level scheme is established and maintained.
The scheme provides detailed EALs for each of the four ECLs in Section IV.C.1 of Appendix E to 10 CFR Part 50.
D.1.a The EALs are developed using guidance provided or endorsed by the NRC that is applicable to the reactor design.
D.1.b The initial emergency classification and action level scheme is discussed and agreed to by the licensee and OROs, and approved by the NRC. Thereafter, the scheme is reviewed with OROs on an annual basis.
D.2 The capability to assess, classify, and declare the emergency condition within 15 minutes after the availability of indications to NPP operators that an EAL has been met or exceeded is described.
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Rev. 9 Attachment 2 Page 19 of 33 10 CFR 50.54(q) Review Form Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q). Address each Planning Standard identified in Section IX. Continue to Section XI.
Proposed changes 4, 5, 6, 10, 11, 12, 13, 14, 15, 16, 23 and 24:
Proposed changes are being made to update EAL Tables S-1 and C-2 and associated EALs SU1.1, SA1.1, SS1.1, SG1.1, CU2.1 and CA2.1 basis definitions for crediting SATA and SATB as AC Power Sources. These proposed changes assure that SATA and/or SATB are not credited as an AC Power Source unless the equipment is aligned when an AC power loss event occurs. The previous guidance did not clearly state that SATA/SATB must be aligned to be credited as an AC Power Source. If SATA/SATB are not aligned at the start of an event, it will take longer than the 15-minute classification time window to complete the equipment alignment and, thus, SATA/SATB should not be used.
The AC Power Sources definitions updated for these EALs are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6.
The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the changes will maintain the accuracy and timeliness of a classification following a loss of AC power event. The meaning or intent of the basis of the approved EAL is unchanged.
These proposed changes can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
These proposed changes continue to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by McGuire Nuclear Station (MNS).
These proposed changes continue to comply with 10 CFR Part 50 Appendix E, IV.C.2, because MNS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure MNS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
These proposed changes can be made because the changes differ in wording but agree in meaning and intent of the NRC-approved EALs and its bases such that the classification of an event would remain the same. The language of the EALs and basis does NOT render the classification logic unclear or have a potential for or result in an inaccurate classification.
Proposed changes 7, 8 and 25:
Proposed changes 7, 8 and 25 are being made to add a compensatory EAL for use during periods when the seismic monitoring system is incapable of detecting an Operating Basis Earthquake (OBE) (e.g., the system is out-of-service for maintenance or repair). The proposed addition of a compensatory EAL is consistent with the IC HU2 developer note guidance contained in NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6. NEI 99-01, Revision 6, is the NRC-endorsed guidance used by MNS to develop the site-specific emergency classification scheme.
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Rev. 9 Attachment 2 Page 20 of 33 10 CFR 50.54(q) Review Form From NEI 99-01 developer notes:
For sites that do not have readily assessable OBE indications within the Control Room, developers should use the following alternate EAL (or similar wording).
(1) a. Control Room personnel feel an actual or potential seismic event.
AND
- b. The occurrence of a seismic event is confirmed in manner deemed appropriate by the Shift Manager or Emergency Director.
The EAL 1.b statement is included to ensure that a declaration does not result from felt vibrations caused by a non-seismic source (e.g., a dropped heavy load). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration. It is recognized that this alternate EAL wording may cause a site to declare an Unusual Event while another site, similarly affected but with readily assessable OBE indications in the Control Room, may not.
The above alternate wording may also be used to develop a compensatory EAL for use during periods when a seismic monitoring system capable of detecting an OBE is out-of-service for maintenance or repair.
HU2.1 Unusual Event Seismic event > OBE as indicated by OBE EXCEEDED alarm on 1AD-13, E7 OR Seismic monitoring instrumentation is unavailable to the extent that an OBE cannot be determined (e.g.,
out-of-service for failed equipment, testing or maintenance).
AND Control Room personnel feel an actual or potential seismic event.
AND The occurrence of a seismic event is confirmed in manner deemed appropriate by the Shift Manager or Emergency Coordinator.
As seen above, MNS proposed changes match NEI 99-01 developer notes with the addition of the statement Seismic monitoring instrumentation is unavailable to the extent that an OBE cannot be determined (e.g., out-of-service for failed equipment, testing or maintenance). This statement was added to ensure the compensatory EAL will only be used when seismic monitoring system is out of service which aligns with last sentence of developers notes above.
The changes provide a compensatory means to make an emergency classification assessment following a seismic event when the installed seismic monitoring instrumentation is out-of-service (surveillance, maintenance, etc.). The information being added was not included in the original submittal of the MNS EALs based on NEI 99-01, Revision 6. MNSs experience with the NRC-approved EALs has indicated a need for a compensatory EAL to cover those periods when the seismic monitoring system may be out-of-service for maintenance or surveillances.
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Rev. 9 Attachment 2 Page 21 of 33 10 CFR 50.54(q) Review Form The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the compensatory EAL will maintain the accuracy and timeliness of a classification following a loss of the seismic monitoring system. The meaning or intent of the basis of the approved EAL is unchanged.
These proposed changes continue to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by McGuire Nuclear Station (MNS).
These proposed changes continue to comply with 10 CFR Part 50 Appendix E, IV.C.2, because MNS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure MNS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
The proposed changes can be made because the changes differ in wording but agree in meaning and intent of the NRC-approved EALs and its bases such that the classification of an event would remain the same. The language of the EALs and basis does NOT render the classification logic unclear or have a potential for or result in an inaccurate classification.
Proposed change 9:
Proposed change is being made to change the font from italic and update the hyperlink to http://earthquake.usgs.gov. The change of the font from italic is defined as editorial in accordance with AD-EP-ALL-0602, and does not change the intent of the steps as written. The update of the hyperlink linked to http://earthquake.usgs.gov assures that information on area earthquakes is going to the correct website and provides for evaluation of possible earthquakes within the 15-minute classification window. Previous version of hyperlink did not always function as expected.
The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an earthquake. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 9 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
Proposed change 9 continues to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by McGuire Nuclear Station (MNS).
Proposed change 9 continues to comply with 10 CFR Part 50 Appendix E, IV.C.2, because MNS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure MNS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
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Rev. 9 Attachment 2 Page 22 of 33 10 CFR 50.54(q) Review Form The proposed changes agree in meaning and intent of the NRC-approved EALs and its bases such that the classification of an event would remain the same. The language of the EALs and basis does NOT render the classification logic unclear or have a potential for or result in an inaccurate classification.
Proposed change 17:
Proposed change is being made to update EAL SU5.1 basis definitions for identified, unidentified, and pressure boundary leakage. The first three paragraphs were originally written based on MNS Technical Specifications Definitions Section 1.1 as referenced at the end of each paragraph (ref.1). This reference has been updated in Amendment Nos. 328 and 307 to Renewed Facility Operating License Nos. NPF-9 and NPF-17 for the McGuire Nuclear Station, Unit Nos. 1 and 2, respectively. The amendments revise the TSs related to reactor coolant system operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements.
First paragraph changes:
From:
Identified leakage includes leakage such as that from pump seals or valve packing (except reactor coolant pump (NCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank, leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary leakage; or NCS leakage through a steam generator to the secondary system (primary to secondary leakage)
(ref. 1).
To:
Identified leakage includes leakage such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank, leakage into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or Reactor Coolant System (NCS) leakage through a steam generator to the secondary system (primary to secondary leakage) (ref. 1).
Proposed Change 17 revises the Identified Leakage definition to not exclude Pressure Boundary Leakage and added (primary to secondary leakage) as additional clarification. RCS leakage through a steam generator to the secondary system is also known as primary to secondary leakage so this addition is an enhancement with no change to intent.
The change to the definition of identified leakage applies to leakage from an RCS component that would be released directly into the containment atmosphere where the leakage would be detectable by the RCS leakage detection systems. The revised definition of identified leakage removes the existing exclusion of leakage known to be pressure boundary leakage. Therefore, all RCS leakage that is specifically located and known to not interfere with the operation of leakage detection systems would be considered identified leakage, regardless of the source of leakage. Not excluding Pressure Boundary Leakage provides a clearer definition of identified leakage.
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Rev. 9 Attachment 2 Page 23 of 33 10 CFR 50.54(q) Review Form Second paragraph changes:
From:
Unidentified leakage is all leakage (except NCP seal water injection or leakoff) that is not identified leakage (ref.
1).
To:
Unidentified leakage is all leakage (except RCP seal water injection or leakoff) that is not identified leakage (ref.
1).
Revises NCP seal water injecting or leakoff to RCP seal water injection or leakoff. This aligns use of RCP in the section of the basis discussion.
Third paragraph changes:
From:
Pressure Boundary leakage is leakage (except primary to secondary leakage) through a nonisolable fault in an NCS component body, pipe wall, or vessel wall (ref. 1)
To:
Pressure Boundary leakage is leakage (except primary to secondary leakage) through a fault in an NCS component body, pipe wall, or vessel wall. Leakage past seals, packing, and gaskets is not pressure boundary leakage. (ref. 1)
Revises the defined term leakage to remove the term unisolable from the definition of Pressure Boundary Leakage, changed (except SG leakage) to (except primary to secondary leakage) for clarification, and added Leakage past seals, packing, and gaskets is not pressure boundary leakage.
From NRC Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements, the word unisolable has been interpreted inconsistently in the definition of pressure boundary leakage. In some interpretations, it has been considered a means of emphasizing that the leakage fault is in the base material of the pressure boundary and, therefore, the leakage cannot be stopped by adjusting packing or seals. In such a case, the fault represents degradation of the pressure boundary material that could result in a loss of structural integrity. Another interpretation is that leakage through a fault in portions of the pressure boundary that can be separated from the RCS by an isolation device (typically an installed valve) need not be considered as pressure boundary leakage once the isolation device is performing its isolation function. This would allow certain small sections of the Reactor Coolant Pressure Boundary (RCPB) between the outermost two valves to be removed from consideration as RCPB leakage when the inner valve is closed. Regardless of the interpretation, deletion of the word unisolable does not alter the fundamental meaning that pressure boundary leakage represents degradation that could ultimately result in a loss of structural integrity.
Therefore, removing the term unisolable provides a clearer definition of pressure boundary leakage.
Changing (except SG leakage) to (except primary to secondary leakage) is an enhancement with no change to intent. The words (except SG leakage) could be interpreted as a steam leak from the secondary side of the steam generator. The intent of this EAL is related to RCS leakage into the secondary side of the steam generator and using the words (except primary to secondary leakage) better defines the intent of the EAL.
The additional sentence LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE, is consistent with the definition and was added for emphasis. Definition is clear that pressure boundary leakage is leakage through a fault in an RCS component body, pipe wall, or vessel wall. The additional reminder to exclude leakage from seals, packing, and gaskets which are not RCS component bodies, pipe walls, or vessel walls is an enhancement with no change to intent of the definition.
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Rev. 9 Attachment 2 Page 24 of 33 10 CFR 50.54(q) Review Form The revised first paragraph supports the 2nd EAL condition NCS identified leakage > 25 gpm for 15 min. and the revised third paragraph supports the 1st EAL condition NCS unidentified or pressure boundary leakage > 10 gpm for 15 min.. These proposed changes remain consistent with the approved EAL scheme as described in the 7th paragraph of MNS EAL bases:
The first and second EAL conditions are focused on a loss of mass from the NCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes remain consistent with NEI 99-01 rev 6 EAL scheme for this EAL:
EAL #1 and EAL #2 are focused on a loss of mass from the RCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes continue to support the first and second EAL conditions, because the definitions continue to be leakage types that are defined in the plant Technical Specification.
The leakage definitions updated for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6. The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II.
Implementation of the change will maintain the accuracy and timeliness of a classification following an RCS leak.
The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 17 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
Proposed change 17 continues to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by McGuire Nuclear Station (MNS).
Proposed change 17 continues to comply with 10 CFR Part 50 Appendix E, IV.C.2, because MNS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded.
This change continues to ensure MNS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
The proposed changes agree in meaning and intent of the NRC-approved EALs and its bases such that the classification of an event would remain the same. The language of the EALs and basis does NOT render the classification logic unclear or have a potential for or result in an inaccurate classification.
Proposed change 20:
Proposed change 20 is being made to change the generic RCS acronym to the McGuire specific NCS acronym for the reactor coolant system in this basis discussion section. Changing to the McGuire specific NCS acronym will provide better clarity in the basis discussion to classifiers. The proposed change does not affect the ability to timely classify the event.
The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an earthquake. The meaning or intent of the basis of the approved EAL is unchanged.
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Rev. 9 Attachment 2 Page 25 of 33 10 CFR 50.54(q) Review Form Proposed change 20 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
Proposed change 20 continues to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by McGuire Nuclear Station (MNS).
Proposed change 20 continues to comply with 10 CFR Part 50 Appendix E, IV.C.2, because MNS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure MNS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
The proposed changes agree in meaning and intent of the NRC-approved EALs and its bases such that the classification of an event would remain the same. The language of the EALs and basis does NOT render the classification logic unclear or have a potential for or result in an inaccurate classification.
Proposed change 21:
Proposed change is being made to change the title of Step Action column to Action on Attachment 3 - Safe Operation & Shutdown Areas Tables R-2 & H-2 Basis. Attachment 3 is used to identify areas affected for the EAL Tables R-2 and H-2 and is not used for event classification. No changes are being made to the EAL Tables R-2 and H-2. Attachment 3 Step Action column contained specific procedure step references in revised CSD-EP-MNS-0101-01 but were removed with Revision 3. As the specific procedure steps are no longer referenced, retitle of the column from Step Action to Action more clearly identifies the information in the column.
The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an earthquake. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 21 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
Proposed change 21 continues to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by McGuire Nuclear Station (MNS).
Proposed change 21 continues to comply with 10 CFR Part 50 Appendix E, IV.C.2, because MNS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure MNS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
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Rev. 9 Attachment 2 Page 26 of 33 10 CFR 50.54(q) Review Form The proposed changes agree in meaning and intent of the NRC-approved EALs and its bases such that the classification of an event would remain the same. The language of the EALs and basis does NOT render the classification logic unclear or have a potential for or result in an inaccurate classification.
Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.
Proposed changes 4, 5, 6, 10, 11, 12, 13, 14, 15, 16, 23 and 24:
Proposed changes are being made to update EAL Tables S-1 and C-2 and associated EALs SU1.1, SA1.1, SS1.1, SG1.1, CU2.1 and CA2.1 basis definitions for crediting SATA and SATB as AC Power Sources. These proposed changes assure that SATA and/or SATB are not credited as an AC Power Source unless the equipment is aligned when an AC power loss event occurs. The previous guidance did not clearly state that SATA/SATB must be aligned to be credited as an AC Power Source. If SATA/SATB are not aligned at the start of an event, it will take longer than the 15-minute classification time window to complete the equipment alignment and, thus, SATA/SATB should not be used.
The AC Power Sources definitions updated for these EALs are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6.
The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the changes will maintain the accuracy and timeliness of a classification following a loss of AC power event. The meaning or intent of the basis of the approved EAL is unchanged.
These proposed changes can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
These proposed changes continue to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by McGuire Nuclear Station (MNS).
These proposed changes continue to comply with 10 CFR Part 50 Appendix E, IV.C.2, because MNS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure MNS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
These proposed changes can be made because the changes differ in wording but agree in meaning and intent of the NRC-approved EALs and its bases such that the classification of an event would remain the same. The language of the EALs and basis does NOT render the classification logic unclear or have a potential for or result in an inaccurate classification.
Proposed changes 7, 8 and 25:
Proposed changes 7, 8 and 25 are being made to add a compensatory EAL for use during periods when the seismic monitoring system is incapable of detecting an Operating Basis Earthquake (OBE) (e.g., the system is out-of-service for maintenance or repair). The proposed addition of a compensatory EAL is consistent with the IC HU2 developer note guidance contained in NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6. NEI 99-01, Revision 6, is the NRC-endorsed guidance used by MNS to develop the site-specific emergency classification scheme.
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Rev. 9 Attachment 2 Page 27 of 33 10 CFR 50.54(q) Review Form From NEI 99-01 developer notes:
For sites that do not have readily assessable OBE indications within the Control Room, developers should use the following alternate EAL (or similar wording).
(1) a. Control Room personnel feel an actual or potential seismic event.
AND
- b. The occurrence of a seismic event is confirmed in manner deemed appropriate by the Shift Manager or Emergency Director.
The EAL 1.b statement is included to ensure that a declaration does not result from felt vibrations caused by a non-seismic source (e.g., a dropped heavy load). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration. It is recognized that this alternate EAL wording may cause a site to declare an Unusual Event while another site, similarly affected but with readily assessable OBE indications in the Control Room, may not.
The above alternate wording may also be used to develop a compensatory EAL for use during periods when a seismic monitoring system capable of detecting an OBE is out-of-service for maintenance or repair.
HU2.1 Unusual Event Seismic event > OBE as indicated by OBE EXCEEDED alarm on 1AD-13, E7 OR Seismic monitoring instrumentation is unavailable to the extent that an OBE cannot be determined (e.g.,
out-of-service for failed equipment, testing or maintenance).
AND Control Room personnel feel an actual or potential seismic event.
AND The occurrence of a seismic event is confirmed in manner deemed appropriate by the Shift Manager or Emergency Coordinator.
As seen above, MNS proposed changes match NEI 99-01 developer notes with the addition of the statement Seismic monitoring instrumentation is unavailable to the extent that an OBE cannot be determined (e.g., out-of-service for failed equipment, testing or maintenance). This statement was added to ensure the compensatory EAL will only be used when seismic monitoring system is out of service which aligns with last sentence of developers notes above.
The changes provide a compensatory means to make an emergency classification assessment following a seismic event when the installed seismic monitoring instrumentation is out-of-service (surveillance, maintenance, etc.). The information being added was not included in the original submittal of the MNS EALs based on NEI 99-01, Revision 6. MNSs experience with the NRC-approved EALs has indicated a need for a compensatory EAL to cover those periods when the seismic monitoring system may be out-of-service for maintenance or surveillances.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 2 Page 28 of 33 10 CFR 50.54(q) Review Form The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the compensatory EAL will maintain the accuracy and timeliness of a classification following a loss of the seismic monitoring system. The meaning or intent of the basis of the approved EAL is unchanged.
These proposed changes continue to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by McGuire Nuclear Station (MNS).
These proposed changes continue to comply with 10 CFR Part 50 Appendix E, IV.C.2, because MNS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure MNS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
The proposed changes can be made because the changes differ in wording but agree in meaning and intent of the NRC-approved EALs and its bases such that the classification of an event would remain the same. The language of the EALs and basis does NOT render the classification logic unclear or have a potential for or result in an inaccurate classification.
Proposed change 9:
Proposed change is being made to change the font from italic and update the hyperlink to http://earthquake.usgs.gov. The change of the font from italic is defined as editorial in accordance with AD-EP-ALL-0602, and does not change the intent of the steps as written. The update of the hyperlink linked to http://earthquake.usgs.gov assures that information on area earthquakes is going to the correct website and provides for evaluation of possible earthquakes within the 15-minute classification window. Previous version of hyperlink did not always function as expected.
The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an earthquake. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 9 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
Proposed change 9 continues to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by McGuire Nuclear Station (MNS).
Proposed change 9 continues to comply with 10 CFR Part 50 Appendix E, IV.C.2, because MNS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure MNS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 2 Page 29 of 33 10 CFR 50.54(q) Review Form The proposed changes agree in meaning and intent of the NRC-approved EALs and its bases such that the classification of an event would remain the same. The language of the EALs and basis does NOT render the classification logic unclear or have a potential for or result in an inaccurate classification.
Proposed change 17:
Proposed change is being made to update EAL SU5.1 basis definitions for identified, unidentified, and pressure boundary leakage. The first three paragraphs were originally written based on MNS Technical Specifications Definitions Section 1.1 as referenced at the end of each paragraph (ref.1). This reference has been updated in Amendment Nos. 328 and 307 to Renewed Facility Operating License Nos. NPF-9 and NPF-17 for the McGuire Nuclear Station, Unit Nos. 1 and 2, respectively. The amendments revise the TSs related to reactor coolant system operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements.
First paragraph changes:
From:
Identified leakage includes leakage such as that from pump seals or valve packing (except reactor coolant pump (NCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank, leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary leakage; or NCS leakage through a steam generator to the secondary system (primary to secondary leakage)
(ref. 1).
To:
Identified leakage includes leakage such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank, leakage into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or Reactor Coolant System (NCS) leakage through a steam generator to the secondary system (primary to secondary leakage) (ref. 1).
Proposed Change 17 revises the Identified Leakage definition to not exclude Pressure Boundary Leakage and added (primary to secondary leakage) as additional clarification. RCS leakage through a steam generator to the secondary system is also known as primary to secondary leakage so this addition is an enhancement with no change to intent.
The change to the definition of identified leakage applies to leakage from an RCS component that would be released directly into the containment atmosphere where the leakage would be detectable by the RCS leakage detection systems. The revised definition of identified leakage removes the existing exclusion of leakage known to be pressure boundary leakage. Therefore, all RCS leakage that is specifically located and known to not interfere with the operation of leakage detection systems would be considered identified leakage, regardless of the source of leakage. Not excluding Pressure Boundary Leakage provides a clearer definition of identified leakage.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 2 Page 30 of 33 10 CFR 50.54(q) Review Form Second paragraph changes:
From:
Unidentified leakage is all leakage (except NCP seal water injection or leakoff) that is not identified leakage (ref.
1).
To:
Unidentified leakage is all leakage (except RCP seal water injection or leakoff) that is not identified leakage (ref.
1).
Revises NCP seal water injecting or leakoff to RCP seal water injection or leakoff. This aligns use of RCP in this section of the basis discussion.
Third paragraph changes:
From:
Pressure Boundary leakage is leakage (except primary to secondary leakage) through a nonisolable fault in an NCS component body, pipe wall, or vessel wall (ref. 1)
To:
Pressure Boundary leakage is leakage (except primary to secondary leakage) through a fault in an NSC component body, pipe wall, or vessel wall. Leakage past seals, packing, and gaskets is not pressure boundary leakage. (ref. 1)
Revises the defined term leakage to remove the term unisolable from the definition of Pressure Boundary Leakage, changed (except SG leakage) to (except primary to secondary leakage) for clarification, and added Leakage past seals, packing, and gaskets is not pressure boundary leakage.
From NRC Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements, the word unisolable has been interpreted inconsistently in the definition of pressure boundary leakage. In some interpretations, it has been considered a means of emphasizing that the leakage fault is in the base material of the pressure boundary and, therefore, the leakage cannot be stopped by adjusting packing or seals. In such a case, the fault represents degradation of the pressure boundary material that could result in a loss of structural integrity. Another interpretation is that leakage through a fault in portions of the pressure boundary that can be separated from the RCS by an isolation device (typically an installed valve) need not be considered as pressure boundary leakage once the isolation device is performing its isolation function. This would allow certain small sections of the Reactor Coolant Pressure Boundary (RCPB) between the outermost two valves to be removed from consideration as RCPB leakage when the inner valve is closed. Regardless of the interpretation, deletion of the word unisolable does not alter the fundamental meaning that pressure boundary leakage represents degradation that could ultimately result in a loss of structural integrity.
Therefore, removing the term unisolable provides a clearer definition of pressure boundary leakage.
Changing (except SG leakage) to (except primary to secondary leakage) is an enhancement with no change to intent. The words (except SG leakage) could be interpreted as a steam leak from the secondary side of the steam generator. The intent of this EAL is related to RCS leakage into the secondary side of the steam generator and using the words (except primary to secondary leakage) better defines the intent of the EAL.
The additional sentence LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE, is consistent with the definition and was added for emphasis. Definition is clear that pressure boundary leakage is leakage through a fault in an RCS component body, pipe wall, or vessel wall. The additional reminder to exclude leakage from seals, packing, and gaskets which are not RCS component bodies, pipe walls, or vessel walls is an enhancement with no change to intent of the definition.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 2 Page 31 of 33 10 CFR 50.54(q) Review Form The revised first paragraph supports the 2nd EAL condition NCS identified leakage > 25 gpm for 15 min. and the revised third paragraph supports the 1st EAL condition NCS unidentified or pressure boundary leakage > 10 gpm for 15 min.. These proposed changes remain consistent with the approved EAL scheme as described in the 7th paragraph of MNS EAL bases:
The first and second EAL conditions are focused on a loss of mass from the NCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes remain consistent with NEI 99-01 rev 6 EAL scheme for this EAL:
EAL #1 and EAL #2 are focused on a loss of mass from the RCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes continue to support the first and second EAL conditions, because the definitions continue to be leakage types that are defined in the plant Technical Specification.
The leakage definitions updated for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6. The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II.
Implementation of the change will maintain the accuracy and timeliness of a classification following an RCS leak.
The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 17 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
Proposed change 17 can be made because the change continues to ensure a standard scheme of emergency classification and action levels are in use and there is no negative impact to timeliness or accuracy.
Proposed change 20:
Proposed change 20 is being made to change the generic RCS acronym to the McGuire specific NCS acronym for the reactor coolant system in this basis discussion section. Changing to the McGuire specific NCS acronym will provide better clarity in the basis discussion to classifiers. The proposed change does not affect the ability to timely classify the event.
The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an earthquake. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 20 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
Proposed change 20 continues to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by McGuire Nuclear Station (MNS).
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 2 Page 32 of 33 10 CFR 50.54(q) Review Form Proposed change 20 continues to comply with 10 CFR Part 50 Appendix E, IV.C.2, because MNS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure MNS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
The proposed changes agree in meaning and intent of the NRC-approved EALs and its bases such that the classification of an event would remain the same. The language of the EALs and basis does NOT render the classification logic unclear or have a potential for or result in an inaccurate classification.
Proposed change 21:
Proposed change 21 is being made to change the title of Step Action column to Action on Attachment 3 -
Safe Operation & Shutdown Areas Tables R-2 & H-2 Basis. Attachment 3 is used to identify areas affected for the EAL Tables R-2 and H-2 and is not used for event classification. No changes are being made to the EAL Tables R-2 and H-2. Attachment 3 Step Action column contained specific procedure step references in revised CSD-EP-MNS-0101-01 but were removed with Revision 3. As the specific procedure steps are no longer referenced, retitle of the column from Step Action to Action more clearly identifies the information in the column.
The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an earthquake. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 21 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
Proposed Change 21 can be made because the change continues to ensure a standard scheme of emergency classification and action levels are in use and there is no negative impact to timeliness or accuracy.
The proposed changes do not reduce the effectiveness of the McGuire Nuclear Station Emergency Plan or the McGuire Emergency Plan Annex. The change continues to provide assurance that the Emergency Response Organization has the ability and capability to:
- respond to an emergency;
- perform functions in a timely manner;
- effectively identify and take measures to ensure protection of the public health and safety; and
- effectively use response equipment and emergency response procedures.
The changes continue to meet NRC requirements, as described in 10 CFR 50.47(b)(4) and 10 CFR 50, Appendix E as well as the requirements of the McGuire Nuclear Station Emergency Plan as written and approved.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 2 Page 33 of 33 10 CFR 50.54(q) Review Form Section XII: Evaluation Conclusion Answer the following questions about the proposed change:
- 1. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? Yes No
- 2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in Yes effectiveness)? No
- 3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes No Section XII: Conclusion Questions 1, 2 and 3 are answered YES, complete step below to create a General CAS assignment, and then continue on to Section XIV and implement change(s).
General CAS assignment created - Licensing submit changes in accordance with 10 CFR 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XIII and Section XIV.
Section XIII: Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change be submitted to the NRC for prior approval?
Yes If No, reject the proposed change, or modify the proposed change and perform a new evaluation. No Continue to Section XIV for this evaluation.
If YES, then initiate a License Amendment Request in accordance 10 CFR 50.90, AD-LS-ALL-0002, Regulatory Correspondence, and AD-LS-ALL-0015, License Amendment Request and Changes to SLC, TRM, and TS Bases, and include the tracking number:___________________________________. Complete Section XIV.
Section XIV: Signatures:
EP CFAM Final Approval is required for changes affecting Program Element 4a of Section VIII. If CFAM approval is NOT required, then mark the EP CFAM signature block as not applicable (N/A) to indicate that signature is not required.Section XIV as applicable.
Preparer Name (Print): Preparer Signature: See NAS Date:
Barry Kimray See NAS Reviewer Name (Print): Reviewer Signature: See NAS Date:
Paul Rathbone (T) and Ryan Bobek See NAS Approver Name (Print): Approver Signature: See NAS Date:
Celeste Ceva See NAS Approver (EP CFAM, as required) Name (Print): Approver Signature: See NAS Date:
David Thompson See NAS QA RECORD
U.S. Nuclear Regulatory Commission Attachment 3 Serial: RA-23-0325 Attachment 3: Procedure CSD-EP-ONS-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 005, 10 CFR 50.54(q)
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 1 of 17 10 CFR 50.54(q) Review Form Section I: 10 CFR 50.54(q) Review Number: (EREG #): 02496116 Applicable Sites and Applicability Determination # (5AD)
BNP CNS HNP MNS ONS 02496145 RNP Document #, EC #, or Revision # or N/A N/A Document or Activity Title CSD-EP-ONS-0101-01 005 EAL Technical Basis Document Section II: Identify/Describe All Proposed Activities/Changes being Reviewed Event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan (Use attachments, or continue additional pages as necessary): Continue to Section III.
CSD-EP-ONS-0101-01 is the Emergency Action Level (EAL) technical basis document for Oconee Nuclear Station (ONS).
Changes include:
Updated revision summary and revision number.
Updated EAL SU5.1 basis definitions of Reactor Coolant System (RCS) leakage as a result of revised Technical Specifications (TSs) related to reactor coolant system operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements..
Corrected Attachment 1, EAL Basis SU5.1, ONS Basis Reference(s) section, reference 2. NEI 99-01 SU4 to reference 3. NEI 99-01 SU4.
Change Section or Step Change From Change to 1 Throughout Old revision summary. Updated revision summary identifying the changes made from the document revision request.
2 Throughout CSD-EP-ONS-0101 Old revision CSD-EP-ONS-0101 New revision number (004) number (005) 3 Att. 1, SU5.1 Identified leakage includes (ref. 2): Identified leakage includes (ref. 2):
Basis Leakage such as that from pump Leakage such as that from pump seals or valve packing (except seals or valve packing (except reactor coolant pump (RCP) seal reactor coolant pump (RCP) seal water injection or leakoff), that is water injection or leakoff), that is captured and conducted to captured and conducted to collection collection systems or a sump or systems or a sump or collecting collecting tank, or tank, or Leakage into the containment Leakage into the containment atmosphere from sources that are atmosphere from sources that are both specifically located and known both specifically located and known either not to interfere with the to not interfere with the operation of
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 2 of 17 10 CFR 50.54(q) Review Form operation of leakage detection leakage detection systems, or systems or not to be pressure RCS leakage through a steam boundary leakage, or generator to the secondary system RCS leakage through a steam (primary to secondary leakage).
generator to the secondary system.
Unidentified leakage is all leakage Unidentified leakage is all leakage (except RCP seal water injection or (except RCP seal water injection or leakoff) that is not identified leakage (ref.
leakoff) that is not identified leakage 2).
(ref. 2).
Pressure Boundary leakage is leakage Pressure Boundary leakage is leakage (except primary to secondary leakage)
(except SG leakage) through a through a fault in an RCS component nonisolable fault in an RCS component body, pipe wall, or vessel wall (ref. 2).
body, pipe wall, or vessel wall (ref. 2). Leakage past seals, packing, and gaskets is not pressure boundary leakage.
4 Att. 1, SU5.1, 1. PT/1,2,3/A/0600/010 Reactor 1. PT/1,2,3/A/0600/010 Reactor Reference(s) Coolant Leakage Coolant Leakage
- 2. ONS Technical Specifications 2. ONS Technical Specifications Section 1.1 Definitions Section 1.1 Definitions
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 3 of 17 10 CFR 50.54(q) Review Form Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:
List all emergency plan sections that were reviewed for this activity by number and title.
IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.
Licensing Basis for NEI 99-01 Rev 6 EALs ONS Letter ONS-2016-028 Dated March 18, 2016.
Subject:
Response to Request for Additional Information (RAI)
Regarding the License Amendment Request (LAR) to Change the Oconee Nuclear Station (ONS) Emergency Plan to Upgrade ONS Emergency Action Levels Based on NEI 99-01, Revision 6 License Amendment Request No. 2015-04 Amendment Nos. 399, 401, and 400 to Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55, for the Oconee Nuclear Station, Units 1, 2, and 3, respectively. The amendments in response to application dated June 23, 2015, as supplemented by letters dated February 4, 2016, and March 18, 2016.OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3- ISSUANCE OF LICENSE AMENDMENTS REGARDING EMERGENCY ACTION LEVEL SCHEME CHANGE (CAC NOS. MF6454, MF6455, AND MF6456)
Additional Licensing basis to implement FAQs ML19058A632 Letter dated July 1, 2019.
Subject:
Catawba Nuclear Station, Units 1 And 2; McGuire Nuclear Station, Units 1 And 2; Oconee Nuclear Station, Units 1, 2, And 3; Brunswick Steam Electric Plant, Units 1 And 2; Shearon Harris Nuclear Power Plant, Unit 1; And H. B. Robinson Steam Electric Plant, Unit No. 2 - Issuance of Amendments To Revise Emergency Action Level Schemes To Incorporate Clarifications Provided By Emergency Preparedness Frequently Asked Questions 2015-013, 2015-014, And 2016-002 (EPID L-2018-LLA-0174)
Amendment Nos. 303 and 299 to Renewed Facility Operating License Nos. NPF-35 and NPF-52 for the Catawba Nuclear Station, Units 1 and 2 (Catawba), respectively; Amendment Nos. 315 and 294 to Renewed Facility Operating License Nos. NPF-9 and NPF-17 for the McGuire Nuclear Station, Units 1 and 2 (McGuire), respectively; Amendment Nos. 412, 414, and 413 to Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55 for the Oconee Nuclear Station, Units 1, 2, and 3 (Oconee), respectively; Amendment Nos. 291 and 319 to Renewed Facility Operating License Nos. DPR-71 and DPR-62 for Brunswick Steam Electric Plant, Units 1 and 2 (Brunswick), respectively; Amendment No. 172 to Renewed Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris); and Amendment No. 264 to Renewed Facility Operating License No.
DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (Robinson).
Current EALs Oconee Nuclear Station EAL Technical Basis Document, CSD-EP-ONS-0101-01 Revision 004 The differences in approved revisions and the current revisions of the Emergency Plans have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions.
Licensing Basis EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 0 EP-ONS-EPLAN-ANNEX, Duke Energy Oconee Emergency Plan Annex Revision 0
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 4 of 17 10 CFR 50.54(q) Review Form Current Emergency Plan EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 5 Section D- Emergency Classification System EP-ONS-EPLAN-ANNEX, Duke Energy Oconee Emergency Plan Annex Revision 4 Section IV: Ability to Maintain the Emergency Plan.
Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.
- 1. Do any of the elements of the proposed activity change information or intent contained in the Yes Emergency Plan? No
- 2. Do any elements of the proposed activity change the process or capability for alerting or notifying Yes the public as described in the FEMA-approved Alert and Notification System Design Report? No
- 3. Do any elements of the proposed activity change the Evacuation Time Estimate results? Yes No
- 4. Do any elements of the proposed activity change the On-Shift Staffing Analysis results? Yes No
- 5. Does the Proposed activity require a change to the Emergency Plan Programmatic Description? Yes No If Question 5 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.
Section IV conclusion:
If questions 1-5 in Section IV marked NO, then complete Section V.
If any question 1-5 of Section IV marked yes, then continue at Section VI.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 5 of 17 10 CFR 50.54(q) Review Form Section V: Maintaining the Emergency Plan Conclusion.
The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.
- 1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.
- 2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.
I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).
Section VI: Activity Previously Reviewed?
Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?
10 CFR 50.54(q) Evaluation is not required.
Yes Identify bounding source document below and continue to Section XIV.
No Continue to Section VII.
If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.
Partially Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 6 of 17 10 CFR 50.54(q) Review Form Section VII: Editorial Changes All Activities/Changes identified in Section II are editorial/typographical changes such as Yes formatting, paragraph numbering, spelling, or punctuation that does not change intent.
None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to No Section VIII.
Partially Some Activities/Changes are editorial/typographical.
If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XII.
If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.
Justification:
The proposed changes below are defined as editorial in accordance with AD-EP-ALL-0602, and do not change the intent of the steps as written.
Proposed change 1 updates revision summary. Updating revision summary based on revision is editorial because it makes no changes to intent of the guidance.
Proposed change 2 updates revision number from 4 to 5 for EAL Technical Basis Document. Updating revision number is editorial because it makes no changes to intent of the guidance.
Proposed change 4 corrects reference number from 2 to 3. Correcting the reference number revises the reference section to reference number 1, 2, and 3 from refences 1, 2, and 2.
Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)
Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate box.
1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.
The response organization has the staff to respond and to augment staff on a continuing basis (24-7 1b staffing) in accordance with the emergency plan.
2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned 2b The process for timely augmentation of onshift staff is established and maintained.
3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.
3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.
4 10 CFR 50.47(b)(4) Emergency Classification System RS
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 7 of 17 10 CFR 50.54(q) Review Form A standard scheme of emergency classification and action levels is in use. (Requires V/V 4a (Attachment 3) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS Procedures for notification of State and local governmental agencies are capable of alerting them of 5a the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.
Administrative and physical means have been established for alerting and providing prompt 5b instructions to public within the plume exposure pathway.
The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 5c Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter 6 10 CFR 50.47(b)(6) Emergency Communications Systems are established for prompt communication among principal emergency response 6a organizations.
6b Systems are established for prompt communication to emergency response personnel.
7 10 CFR 50.47(b)(7) Public Education and Information Emergency preparedness information is made available to the public on a periodic basis within the 7a plume exposure pathway emergency planning zone (EPZ).
7b Coordinated dissemination of public information during emergencies is established.
8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response 8b Adequate equipment is maintained to support emergency response.
9 10 CFR 50.47(b)(9) Accident Assessment RS 9a Methods, systems, and equipment for assessment of radioactive releases are in use.
10 10 CFR 50.47(b) (10) Protective Response RS 10a A range of public PARs is available for implementation during emergencies.
Evacuation time estimates for the population located in the plume exposure pathway EPZ are 10b available to support the formulation of PARs and have been provided to State and local governmental authorities.
A range of protective actions is available for plant emergency workers during emergencies, including 10c those for hostile action events.
KI is available for implementation as a protective action recommendation in those jurisdictions that 10d chose to provide KI to the public.
11 10 CFR 50.47(b) (11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.
12 10 CFR 50.47(b) (12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.
13 10 CFR 50.47(b) (13) Recovery Planning and Post-Accident Operations 13a Plans for recovery and reentry are developed.
14 10 CFR 50.47(b) (14) Drills and Exercises
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 8 of 17 10 CFR 50.54(q) Review Form A drill and exercise program (including radiological, medical, health physics and other program areas) 14a is established.
Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, 14b and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.
14c Identified weaknesses are corrected.
15 10 CFR 50.47(b) (15) Emergency Response Training 15a Training is provided to emergency responders.
16 10 CFR 50.47(b) (16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.
16b Planners responsible for emergency plan development and maintenance are properly trained.
Section VIII: Conclusion If any Section VIII criteria are checked, document the basis for conclusion below for any changes that are more than editorial, however not impacted by any of the identified criteria in Section VIII and continue the 50.54(q) Review in Section IX.
If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document justification below for any changes that are more than editorial and continue to Section XIV.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 9 of 17 10 CFR 50.54(q) Review Form Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.
Planning Standard A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Function (1) A standard scheme of emergency classification and action levels is in use.
Supporting requirements from Appendix E to 10 CFR Part 50 B. Assessment Actions
- 1. The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC. Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis.
- 2. A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. Licensees shall follow the change process in § 50.54(q) for all other emergency action level changes.
C. Activation of Emergency Organization
- 1. The entire spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described. The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described. Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described. The existence, but not the details, of a message authentication scheme shall be noted for such agencies. The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG-0654/FEMA-REP-1.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 10 of 17 10 CFR 50.54(q) Review Form
- 2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.
Informing criteria from Section II.D of NUREG-0654 Rev. 2 D. A standard emergency classification and action level scheme is established and maintained.
The scheme provides detailed EALs for each of the four ECLs in Section IV.C.1 of Appendix E to 10 CFR Part 50.
D.1.a The EALs are developed using guidance provided or endorsed by the NRC that is applicable to the reactor design.
D.1.b The initial emergency classification and action level scheme is discussed and agreed to by the licensee and OROs, and approved by the NRC. Thereafter, the scheme is reviewed with OROs on an annual basis.
D.2 The capability to assess, classify, and declare the emergency condition within 15 minutes after the availability of indications to NPP operators that an EAL has been met or exceeded is described.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 11 of 17 10 CFR 50.54(q) Review Form Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q). Address each Planning Standard identified in Section IX. Continue to Section XI.
Proposed change 3:
Proposed change is being made to update EAL SU5.1 basis definitions for identified, unidentified, and pressure boundary leakage. The first three paragraphs were originally written based on ONS Technical Specifications (TS) Definitions section. Amendment Nos. 399, 401, and 400 to Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55, for the Oconee Nuclear Station, Units 1, 2, and 3, respectively. The amendments in response to application dated June 23, 2015, as supplemented by letters dated February 4, 2016, and March 18, 2016.OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3-ISSUANCE OF LICENSE AMENDMENTS REGARDING EMERGENCY ACTION LEVEL SCHEME CHANGE (CAC NOS. MF6454, MF6455, AND MF6456). The amendments revise the TSs related to reactor coolant system operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements..
No changes to first paragraph Paragraph 2 From:
Identified leakage includes (ref. 2):
Leakage such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank, or Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary leakage, or RCS leakage through a steam generator to the secondary system.
Paragraph 2 To:
Identified leakage includes (ref. 2):
Leakage such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank, or Leakage into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems, or RCS leakage through a steam generator to the secondary system (primary to secondary leakage).
Unidentified leakage is all leakage (except RCP seal water injection or leakoff) that is not identified leakage (ref. 2).
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 12 of 17 10 CFR 50.54(q) Review Form The change to the definition of identified leakage applies to leakage from an RCS component that would be released directly into the containment atmosphere where the leakage would be detectable by the RCS leakage detection systems. The revised definition of identified leakage removes the existing exclusion of leakage known to be pressure boundary leakage. Therefore, all RCS leakage that is specifically located and known to not interfere with the operation of leakage detection systems would be considered identified leakage, regardless of the source of leakage. Not excluding Pressure Boundary Leakage provides a clearer definition of identified leakage.
No changes to third paragraph:
Paragraph 4 From:
Pressure Boundary leakage is leakage (except SG leakage) through a nonisolable fault in an RCS component body, pipe wall, or vessel wall (ref. 2).
Paragraph 4 To:
Pressure Boundary leakage is leakage (except primary to secondary leakage) through a fault in an RCS component body, pipe wall, or vessel wall (ref. 2). Leakage past seals, packing, and gaskets is not pressure boundary leakage Revises the defined term leakage to remove the term unisolable from the definition of Pressure Boundary Leakage, changed (except SG leakage) to (except primary to secondary leakage) for clarification, and added Leakage past seals, packing, and gaskets is not pressure boundary leakage.
The Oconee basis uses the similar term nonisolable and is equivalent in definition to unisolable.
From NRC Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements, the word unisolable has been interpreted inconsistently in the definition of pressure boundary leakage. In some interpretations, it has been considered a means of emphasizing that the leakage fault is in the base material of the pressure boundary and, therefore, the leakage cannot be stopped by adjusting packing or seals. In such a case, the fault represents degradation of the pressure boundary material that could result in a loss of structural integrity. Another interpretation is that leakage through a fault in portions of the pressure boundary that can be separated from the RCS by an isolation device (typically an installed valve) need not be considered as pressure boundary leakage once the isolation device is performing its isolation function. This would allow certain small sections of the Reactor Coolant Pressure Boundary (RCPB) between the outermost two valves to be removed from consideration as RCPB leakage when the inner valve is closed. Regardless of the interpretation, deletion of the word unisolable does not alter the fundamental meaning that pressure boundary leakage represents degradation that could ultimately result in a loss of structural integrity. Therefore, removing the term unisolable provides a clearer definition of pressure boundary leakage.
Changing (except SG leakage) to (except primary to secondary leakage) is an enhancement with no change to intent. The words (except SG leakage) could be interpreted as a steam leak from the secondary side of the steam generator. The intent of this EAL is related to RCS leakage into the secondary side of the steam generator and using the words (except primary to secondary leakage) better defines the intent of the EAL.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 13 of 17 10 CFR 50.54(q) Review Form The additional sentence LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE, is consistent with the definition and was added for emphasis. Definition is clear that pressure boundary leakage is leakage through a fault in an RCS component body, pipe wall, or vessel wall. The additional reminder to exclude leakage from seals, packing, and gaskets which are not RCS component bodies, pipe walls, or vessel walls is an enhancement with no change to intent of the definition.
The revised second paragraph supports the 2nd EAL condition RCS identified leakage > 25 gpm for 15 min. and the revised third paragraph supports the 1st EAL condition RCS unidentified or pressure boundary leakage > 10 gpm for 15 min.. These proposed changes remain consistent with the approved EAL scheme as described in the 8th paragraph of ONS EAL bases:
The first and second EAL conditions are focused on a loss of mass from the RCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes remain consistent with NEI 99-01 rev 6 EAL scheme for this EAL:
EAL #1 and EAL #2 are focused on a loss of mass from the RCS due to unidentified leakage",
"pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes continue to support the first and second EAL conditions, because the definitions continue to be leakage types that are defined in the plant Technical Specification.
The leakage definitions updated for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6. The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an RCS leak. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 3 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
Proposed change 3 continues to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by Oconee Nuclear Station (ONS).
Proposed change 3 continues to comply with 10 CFR Part 50 Appendix E, IV.C.2, because ONS has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure ONS will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 14 of 17 10 CFR 50.54(q) Review Form Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.
Proposed change 3:
Proposed change is being made to update EAL SU5.1 basis definitions for identified, unidentified, and pressure boundary leakage. The first three paragraphs were originally written based on ONS Technical Specifications (TS)
Definitions as referenced at the end of each paragraph (ref.1). This reference has been updated in Amendment Nos. 399, 401, and 400 to Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55, for the Oconee Nuclear Station, Units 1, 2, and 3, respectively. The amendments revise the TSs related to reactor coolant system operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements..
No changes to first paragraph.
Paragraph 2 From:
Identified leakage includes (ref. 2):
Leakage such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank, or Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary leakage, or RCS leakage through a steam generator to the secondary system.
Paragraph 2 To:
Identified leakage includes (ref. 2):
Leakage such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank, or Leakage into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems, or RCS leakage through a steam generator to the secondary system (primary to secondary leakage).
Unidentified leakage is all leakage (except RCP seal water injection or leakoff) that is not identified leakage (ref. 2).
Revises the Identified Leakage definition to not exclude Pressure Boundary Leakage and added (primary to secondary leakage) as additional clarification. RCS leakage through a steam generator to the secondary system is also known as primary to secondary leakage so this addition is an enhancement with no change to intent.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 15 of 17 10 CFR 50.54(q) Review Form The change to the definition of identified leakage applies to leakage from an RCS component that would be released directly into the containment atmosphere where the leakage would be detectable by the RCS leakage detection systems. The revised definition of identified leakage removes the existing exclusion of leakage known to be pressure boundary leakage. Therefore, all RCS leakage that is specifically located and known to not interfere with the operation of leakage detection systems would be considered identified leakage, regardless of the source of leakage. Not excluding Pressure Boundary Leakage provides a clearer definition of identified leakage.
No changes to third paragraph.
Fourth paragraph changes:
From:
Pressure Boundary leakage is leakage (except SG leakage) through an unisolable fault in an NCS component body, pipe wall, or vessel wall (ref. 2)
To:
Pressure Boundary leakage is leakage (except primary to secondary leakage) through a fault in an NCS component body, pipe wall, or vessel wall. Leakage past seals, packing, and gaskets is not pressure boundary leakage (ref. 2).
Revises the defined term leakage to remove the term unisolable from the definition of Pressure Boundary Leakage, changed (except SG leakage) to (except primary to secondary leakage) for clarification, and added Leakage past seals, packing, and gaskets is not pressure boundary leakage.
From NRC Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements, the word unisolable has been interpreted inconsistently in the definition of pressure boundary leakage. In some interpretations, it has been considered a means of emphasizing that the leakage fault is in the base material of the pressure boundary and, therefore, the leakage cannot be stopped by adjusting packing or seals. In such a case, the fault represents degradation of the pressure boundary material that could result in a loss of structural integrity. Another interpretation is that leakage through a fault in portions of the pressure boundary that can be separated from the RCS by an isolation device (typically an installed valve) need not be considered as pressure boundary leakage once the isolation device is performing its isolation function. This would allow certain small sections of the Reactor Coolant Pressure Boundary (RCPB) between the outermost two valves to be removed from consideration as RCPB leakage when the inner valve is closed. Regardless of the interpretation, deletion of the word unisolable does not alter the fundamental meaning that pressure boundary leakage represents degradation that could ultimately result in a loss of structural integrity. Therefore, removing the term unisolable provides a clearer definition of pressure boundary leakage.
Changing (except SG leakage) to (except primary to secondary leakage) is an enhancement with no change to intent. The words (except SG leakage) could be interpreted as a steam leak from the secondary side of the steam generator. The intent of this EAL is related to RCS leakage into the secondary side of the steam generator and using the words (except primary to secondary leakage) better defines the intent of the EAL.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 16 of 17 10 CFR 50.54(q) Review Form The additional sentence LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE, is consistent with the definition and was added for emphasis. Definition is clear that pressure boundary leakage is leakage through a fault in an RCS component body, pipe wall, or vessel wall. The additional reminder to exclude leakage from seals, packing, and gaskets which are not RCS component bodies, pipe walls, or vessel walls is an enhancement with no change to intent of the definition.
The revised second paragraph supports the 2nd EAL condition RCS identified leakage > 25 gpm for 15 min. and the revised third paragraph supports the 1st EAL condition NCS unidentified or pressure boundary leakage > 10 gpm for 15 min.. These proposed changes remain consistent with the approved EAL scheme as described in the 8th paragraph of ONS EAL bases:
The first and second EAL conditions are focused on a loss of mass from the NCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes remain consistent with NEI 99-01 rev 6 EAL scheme for this EAL:
EAL #1 and EAL #2 are focused on a loss of mass from the RCS due to unidentified leakage",
"pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes continue to support the first and second EAL conditions, because the definitions continue to be leakage types that are defined in the plant Technical Specification.
The leakage definitions updated for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6. The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an RCS leak. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 3 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme The proposed change can be made because the change continues to ensure a standard scheme of emergency classification and action levels are in use and there is no negative impact to timeliness or accuracy.
The proposed change does not reduce the effectiveness of Oconee Nuclear Station Emergency Plan. The change continues to provide assurance that the Emergency Response Organization has the ability and capability to:
- respond to an emergency;
- perform functions in a timely manner;
- effectively identify and take measures to ensure protection of the public health and safety; and
- effectively use response equipment and emergency response procedures.
The change continues to meet NRC requirements, as described in 10 CFR 50.47(b)(4) and 10 CFR 50, Appendix E as well as the requirements of the Oconee Nuclear Station Emergency Plan as written and approved.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 3 Page 17 of 17 10 CFR 50.54(q) Review Form Section XII: Evaluation Conclusion Answer the following questions about the proposed change:
- 1. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? Yes No
- 2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in Yes effectiveness)? No
- 3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes No Section XII: Conclusion Questions 1, 2 and 3 are answered YES, complete step below to create a General CAS assignment, and then continue on to Section XIV and implement change(s).
General CAS assignment created - Licensing submit changes in accordance with 10 CFR 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XIII and Section XIV.
Section XIII: Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change be submitted to the NRC for prior approval?
Yes If No, reject the proposed change, or modify the proposed change and perform a new evaluation. No Continue to Section XIV for this evaluation.
If YES, then initiate a License Amendment Request in accordance 10 CFR 50.90, AD-LS-ALL-0002, Regulatory Correspondence, and AD-LS-ALL-0015, License Amendment Request and Changes to SLC, TRM, and TS Bases, and include the tracking number:___________________________________. Complete Section XIV.
Section XIV: Signatures:
EP CFAM Final Approval is required for changes affecting Program Element 4a of Section VIII. If CFAM approval is NOT required, then mark the EP CFAM signature block as not applicable (N/A) to indicate that signature is not required.Section XIV as applicable.
Preparer Name (Print): Preparer Signature: See CAS Date:
Eric Lampe See CAS Reviewer Name (Print): Reviewer Signature: See CAS Date:
Eric White See CAS Approver Name (Print): Approver Signature: See CAS Date:
David Wilson See CAS Approver (EP CFAM, as required) Name (Print): Approver Signature: See CAS Date:
David Thompson See CAS QA RECORD
U.S. Nuclear Regulatory Commission Attachment 4 Serial: RA-23-0325 Attachment 4: CSD-EP-RNP-0101-01, EAL TECHNICAL BASIS DOCUMENT, Revision 3 and CSD-EP-RNP-0101-02, EAL WALLCHART (BOTH HOT AND COLD),
Revision 003, 10 CFR 50.54(q)
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 ATTACHMENT 4 Page 1 of 30
<< 10 CFR 50.54(q) Review Form >>
Section I: 10 CFR 50.54(q) Review Number: (EREG #): 02495072 Applicable Sites and Applicability Determination # (5AD)
BNP RNP HNP MNS ONS RNP 02495077 02495081 Document #, EC #, or Revision # or N/A N/A Document or Activity Title CSD-EP-RNP-0101-01 3 EAL Technical Basis Document CSD-EP-RNP-0101-02 003 EAL Wallchart (Both Hot and Cold)
Section II: Identify/Describe All Proposed Activities/Changes being Reviewed Event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan (Use attachments or continue additional pages as necessary): Continue to Section III.
CSD-EP-RNP-0101-01 is the EAL Technical Basis Document and CSD-EP-RNP-0101-02 is the EAL Wallcharts for RNP.
Changes include:
Editorial changes such as updating revision number, table of contents, revision summary, page numbers, and correcting references.
Removed Radios as primary communication method for MCR, TSC, and EOF when contacting FMTs and clarified Cell phones are the primary communication method and Satellite phones are the backup communications method.
Removed TSC as a facility used for contacting OROs Corrected typo when spelling out acronym for DEMNET.
Updated EAL SU5.1 basis definitions of Reactor Coolant System (RCS) leakage as a result of revised Technical Specifications (TSs) related to reactor coolant system operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements..
Proposed Changes listed below are for CSD-EP-RNP-0101-01. Unless noted by bolded font in the Section or Step
- column. Bolded font indicates the proposed changes are for CSD-EP-RNP-0101-01 and CSD-EP-RNP-0101-02.
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 ATTACHMENT 4 Page 2 of 30
<< 10 CFR 50.54(q) Review Form >>
Change Section or Step Change From Change to 1 Throughout Table of contents updates due to Updated table of contents as a result of changes in the procedure, old revision procedure changes, updated revision summary, and page numbers. summary identifying the changes made from the procedure revision request, and page numbers as a result of the changes to the procedure.
2 Throughout Old revision number New revision number Change applicable to BOTH documents 3 2.1 Subsequently, Revision 6 of NEI 99-01 Subsequently, Revision 6 of NEI 99-01 Rev. 2 page 6 has been issued which incorporates has been issued which incorporates Rev. 3 page 5 resolutions to numerous implementation resolutions to numerous implementation issues including the NRC EAL Frequently issues including the NRC EAL Asked Questions (FAQs). Using NEI 99- Frequently Asked Questions (FAQs).
01 Revision 6, "Methodology for the Using NEI 99-01 Revision 6, Development of Emergency Action "Methodology for the Development of Levels for Non-Passive Reactors, Emergency Action Levels for Non-November 2012 (ADAMS Accession Passive Reactors, November 2012 Number ML12326A805), RNP conducted (ADAMS Accession Number an EAL implementation upgrade project ML12326A805), RNP conducted an EAL that produced the EALs discussed implementation upgrade project that herein. [4.3.6] produced the EALs discussed herein.
[4.3.7]
4 2.6 2.6 Operating Mode Applicability 2.6 Operating Mode Applicability Rev. 2 page 11 [4.3.10] [4.3.11]
Rev. 3 page 10
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 ATTACHMENT 4 Page 3 of 30
<< 10 CFR 50.54(q) Review Form >>
5 3.1.1 NRC regulations require the licensee to NRC regulations require the licensee to Rev. 2 page 12 establish and maintain the capability to establish and maintain the capability to Rev. 3 page 11 assess, classify, and declare an assess, classify, and declare an emergency condition within 15 minutes emergency condition within 15 minutes after the availability of indications to plant after the availability of indications to operators that an emergency action level plant operators that an emergency action has been exceeded and to promptly level has been exceeded and to declare the emergency condition as soon promptly declare the emergency as possible following identification of the condition as soon as possible following appropriate emergency classification identification of the appropriate level. The NRC staff has provided emergency classification level. The NRC guidance on implementing this staff has provided guidance on requirement in NSIR/DPR-ISG-01, implementing this requirement in "Interim Staff Guidance, Emergency NSIR/DPR-ISG-01, "Interim Staff Planning for Nuclear Power Plants" Guidance, Emergency Planning for
[4.3.7]. Nuclear Power Plants" [4.3.8].
6 3.2 When assessing an EAL that specifies a When assessing an EAL that specifies a Rev. 2 page 14 time duration for the off-normal condition, time duration for the off-normal Rev. 3 page 13 the clock for the EAL time duration runs condition, the clock for the EAL time concurrently with the emergency duration runs concurrently with the classification process clock. For a full emergency classification process clock.
discussion of this timing requirement, For a full discussion of this timing refer to NSIR/DPR-ISG-01. [4.3.7] requirement, refer to NSIR/DPR-ISG-01.
[4.3.8]
7 3.2.1 Related guidance concerning Related guidance concerning Rev. 2 page 14 classification of rapidly escalating events classification of rapidly escalating events Rev. 3 page 13 or conditions is provided in Regulatory or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, Issue Summary (RIS) 2007-02, Clarification of NRC Guidance for Clarification of NRC Guidance for Emergency Notifications During Quickly Emergency Notifications During Quickly Changing Events. [4.3.9] Changing Events. [4.3.10]
8 3.2.4 As noted above, guidance concerning As noted above, guidance concerning Rev. 2 page 15 classification of rapidly escalating events classification of rapidly escalating events Rev. 3 page 14 or conditions is provided in RIS 2007-02. or conditions is provided in RIS 2007-02.
[4.3.9] [4.3.10]
9 3.2.7 In these cases, no emergency In these cases, no emergency Rev. 2 page 16 declaration is warranted; however, the declaration is warranted; however, the Rev. 3 page 15 guidance contained in NUREG-1022 is guidance contained in NUREG-1022 is applicable. Specifically, the event should applicable. Specifically, the event should be reported to the NRC in accordance be reported to the NRC in accordance with 10 CFR § 50.72 within one hour of with 10 CFR § 50.72 within one hour of the discovery of the undeclared event or the discovery of the undeclared event or condition. The licensee should also notify condition. The licensee should also appropriate State and local agencies in notify appropriate State and local accordance with the agreed upon agencies in accordance with the agreed arrangements. [4.3.8] [4.3.1] upon arrangements. [4.3.9] [4.3.1]
10 3.2.8 Guidance on the retraction of an Guidance on the retraction of an Rev. 2 page 16 emergency declaration reported to the emergency declaration reported to the Rev. 3 page 15 NRC is discussed in NUREG-1022. NRC is discussed in NUREG-1022.
[4.3.8] [4.3.9]
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11 5.1 5.1 Definitions 5.1 Definitions Rev. 2 page 18 [4.3.6] Except as Noted [4.3.7] Except as Noted Rev. 3 page 17 12 5.1.33 Site Boundary: As depicted in UFSAR Site Boundary: As depicted in UFSAR Rev. 2 page 22 Figure 2.1.1-4, Plant Site Boundary and Figure 2.1.1-4, Plant Site Boundary and Rev. 3 page 21 Exclusion Zone. [4.3.11] Exclusion Zone. [4.3.12]
13 CU5.1 attachment 1 Table C-4 Rev. 2 page 124 Rev. 3 page 123 and EAL Wallboard 14 CU5.1 Radios (on-site) Radios (on-site) attachment 1 Standard fixed and mobile transceivers Standard fixed and mobile transceivers Rev. 2 page 125 that allow point-to-point communications that allow point-to-point communications Rev. 3 page 124 onsite. onsite.
Radios are the primary means of Radios are an alternate means of communication for the MCR, TSC, and communication between the MCR, TSC, EOF when contacting FMTs. and OSC.
Radios are an alternate means of communication between the MCR, TSC, and OSC.
15 CU5.1 Duke Energy Emergency Management Duke Emergency Management Network attachment 1 Network (DEMNET) (DEMNET)
Rev. 2 page 125 The DEMNET consists of equipment and The DEMNET consists of equipment and Rev. 3 page 124 circuits linking Duke Energy nuclear sites circuits linking Duke Energy nuclear sites with the offsite agencies involved in initial with the offsite agencies involved in emergency notifications. This system can initial emergency notifications. This quickly conference the offsite agencies system can quickly conference for notifications. RNP MCR, TSC, and the offsite agencies for notifications.
the EOF have this system. It is also RNP MCR, TSC, and the EOF have this located in RNP Alternate TSC and EOF. system. It is also located in RNP DEMNET is the primary means of Alternate TSC and EOF.
communication for the MCR, TSC, and DEMNET is the primary means of EOF when contacting OROs. communication for the MCR and EOF when contacting OROs.
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16 CU5.1 Private Branch Exchange (PBX) Private Branch Exchange (PBX) attachment 1 A PBX is a full featured telephone A PBX is a full featured telephone Rev. 2 page 125 system that provides internal calling system that provides internal calling Rev. 3 page 124 services for one or more locations. The services for one or more locations. The PBX terminates commercial phone lines PBX terminates commercial phone lines from a carrier (AT&T, Verizon, from a carrier (AT&T, Verizon, CenturyLink, etc.) to provide inbound and CenturyLink, etc.) to provide inbound and outbound calling capabilities between outbound calling capabilities between Duke Energy and external parties. PBX Duke Energy and external parties. PBX systems have a number of mechanisms systems have a number of mechanisms which make them resistant to failure which make them resistant to failure including, redundant power connections, including, redundant power connections, redundant network connections, and redundant network connections, and server hardware installed in server hardware installed in geographically diverse locations. geographically diverse locations.
PBX is the primary means of PBX is the primary means of communication between the MCR, TSC, communication between the MCR, TSC, OSC, and EOF. OSC, and EOF.
PBX is the alternate means of PBX is the alternate means of communication for the MCR, TSC, and communication for the MCR and EOF EOF when contacting OROs. when contacting OROs.
17 CU5.1 Cellular Telephones Cellular Telephones attachment 1 Any mobile telephone (non-Duke Energy Any mobile telephone (non-Duke Energy Rev. 2 page 126 or Duke Energy provided) capable of or Duke Energy provided) capable of Rev. 3 page 125 sending and receiving phone calls sending and receiving phone calls through ground based cell sites. through ground based cell sites.
Cellular phones are an alternate means Cellular phones are the primary means of communication between the MCR, of communication for the MCR and EOF TSC, and EOF. when contacting FMTs.
Cellular phones are an alternate means Cellular phones are an alternate means of communication for the MCR, TSC, and of communication between the MCR, EOF when contacting OROs. TSC, and EOF.
Cellular phones are an alternate means Cellular phones are an alternate means of communication for the MCR and EOF of communication for the MCR and TSC when contacting OROs.
when contacting NRC.
Cellular phones are an alternate means Cellular phones are an alternate means of communication for the MCR and TSC of communication for the MCR, TSC, and when contacting NRC.
EOF when contacting FMTs.
18 CU5.1 Satellite Telephones Satellite Telephones attachment 1 Any mobile telephone capable of sending Any mobile telephone capable of sending Rev. 2 page 127 and receiving phone calls through and receiving phone calls through Rev. 3 page 126 orbiting satellites. orbiting satellites.
Satellite phones are an alternate means Satellite phones are an alternate means of communication between the MCR, of communication for the MCR and EOF TSC, and EOF. when contacting FMTs.
Satellite phones are an alternate means Satellite phones are an alternate means of communication for the MCR, TSC, and of communication between the MCR, EOF when contacting OROs. TSC, and EOF.
Satellite phones are an alternate means Satellite phones are an alternate means of communication for the MCR and EOF of communication for the MCR and TSC
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when contacting NRC. when contacting OROs.
Satellite phones are an alternate means Satellite phones are an alternate means of communication for the MCR, TSC, and of communication for the MCR and TSC EOF when contacting FMTs. when contacting NRC.
19 HU2.1 http://earthquake.usgs.gov/eqcenter/ https://earthquake.usgs.gov/earthquakes attachment 1 /maps/
Rev. 2 page 151 Rev. 3 page 150 20 SU5.1 Water balance inventory calculations are Water balance inventory calculations are attachment 1 normally used to determine RCS normally used to determine RCS Rev. 2 page 216 leakage. ERFIS Group Display SP5, leakage. ERFIS Group Display SP5, Rev. 3 page 215 RCS Leakage Paths, is used to evaluate RCS Leakage Paths, is used to evaluate parameters that are indicative of an RCS parameters that are indicative of leakage source (ref. 1). an RCS leakage source (ref. 1).
Technical Specifications (ref. 2, 3) Technical Specifications (ref. 3, 4) defines RCS leakage as follows: defines RCS leakage as follows:
21 SU5.1 Identified Leakage: Identified Leakage:
attachment 1 a. Leakage from pump seals or a. Leakage from pump seals or Rev. 2 page 217 valve packing (except reactor valve packing (except reactor Rev. 3 page 216 coolant pump (RCP) seal water coolant pump (RCP) seal water injection or return) that is injection or return) that is captured and conducted to captured and conducted to collection systems or a sump or collection systems or a sump or collecting tank, or collecting tank, or
- b. Leakage into the containment b. Leakage into the containment atmosphere from sources that atmosphere from sources that are both specifically located and are both specifically located and known either not to interfere with known to not interfere with the the operation of leakage operation of leakage detection detection systems or not to be systems, or pressure boundary leakage, or c. Reactor Coolant System (RCS)
- c. RCS leakage through a steam leakage through a steam generator to the Secondary generator to the Secondary Coolant System (primary-to- Coolant System (primary-to-secondary leakage). secondary leakage).
Unidentified Leakage: Unidentified Leakage:
All leakage (except RCP seal All leakage (except RCP seal water injection or return) that is water injection or return) that is not identified leakage. not identified leakage.
Pressure Boundary Leakage: Pressure Boundary Leakage:
Pressure boundary leakage is Pressure boundary leakage is leakage (except SG leakage) leakage (except SG leakage) through a nonisolable leak in an through a leak in an RCS RCS component body, pipe wall, component body, pipe wall, or or vessel wall. vessel wall. Leakage past seals, packing, and gaskets is not pressure boundary leakage.
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22 SU5.1 RCS leakage outside of the containment RCS leakage outside of the attachment 1 that is not considered identified or containment that is not considered Rev. 2 page 217 unidentified leakage per Technical identified or unidentified leakage per Rev. 3 page 216 Specifications includes leakage via Technical Specifications includes interfacing systems such as RCS to the leakage via interfacing systems such as Component Cooling Water, or systems RCS to the Component Cooling Water, that directly see RCS pressure outside or systems that directly see RCS containment such as Chemical & Volume pressure outside containment such as Control System, Safety Injection, Nuclear Chemical & Volume Control System, Sampling System and Residual Heat Safety Injection, Nuclear Sampling Removal System (when in the shutdown System and Residual Heat Removal cooling mode) (ref. 1, 4). System (when in the shutdown cooling The existence of leakage from the RCS mode) (ref. 1, 5).
to the Containment, regardless of the The existence of leakage from the RCS source of leakage, may be detected by to the Containment, regardless of the one or more of the following conditions source of leakage, may be detected by (ref. 5): one or more of the following conditions (ref. 6):
23 SU5.1 The first and second EAL conditions are The first and second EAL conditions are attachment 1 focused on a loss of mass from the RCS focused on a loss of mass from the RCS Rev. 2 page 218 due to unidentified leakage", "pressure due to unidentified leakage", "pressure Rev. 3 page 217 boundary leakage" or "identified leakage boundary leakage" or "identified leakage (as these leakage types are defined in (as these leakage types are defined in the plant Technical Specifications). The the plant Technical Specifications). The third condition addresses an RCS mass third condition addresses an RCS mass loss caused by an UNISOLABLE leak loss caused by an UNISOLABLE leak through an interfacing system. These through an interfacing system. These conditions thus apply to leakage into the conditions containment, a secondary-side system thus apply to leakage into the (e.g., steam generator tube leakage) or a containment, a secondary-side system location outside of containment. (e.g., steam generator tube leakage) or a location outside of containment. (ref. 2) 24 SU5.1 1. AOP-016, Excessive Primary Plant 1. AOP-016, Excessive Primary Plant attachment 1 Leakage Leakage Rev. 2 page 218 2. Technical Specifications Section 1.1 2. AOP-035, Steam Generator Tube Rev. 3 page 217 Definitions Leak
- 3. Technical Specifications 3.4.13, RCS 3. Technical Specifications Section 1.1 RNP Basis Operational Leakage Definitions Reference(s): 4. OST-051, Reactor Coolant System
- 4. Technical Specifications 3.4.13, RCS Leakage Evaluation
- 5. UFSAR Section 5.2.5 Detection of Operational Leakage Leakage Through Reactor Coolant 5. OST-051, Reactor Coolant System Pressure Boundary Leakage Evaluation
- 6. NEI 99-01 SU4 6. UFSAR Section 5.2.5 Detection of Leakage Through Reactor Coolant Pressure Boundary
- 7. NEI 99-01 SU4
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25 SU7.1 attachment 1 Table S-3 Rev. 2 page 232 Rev. 3 page 231 and EAL Wallboard 26 SU7.1 Radios (on-site) Radios (on-site) attachment 1 Standard fixed and mobile transceivers Standard fixed and mobile transceivers Rev. 2 page 233 that allow point-to-point communications that allow point-to-point communications Rev. 3 page 232 onsite. onsite.
Radios are the primary means of Radios are an alternate means of communication for the MCR, TSC, and communication between the MCR, TSC, EOF when contacting FMTs. and OSC.
Radios are an alternate means of communication between the MCR, TSC, and OSC.
27 SU7.1 Duke Energy Emergency Management Duke Emergency Management Network attachment 1 Network (DEMNET) (DEMNET)
Rev. 2 page 233 The DEMNET consists of equipment and The DEMNET consists of equipment and Rev. 3 page 232 circuits linking Duke Energy nuclear sites circuits linking Duke Energy nuclear sites with the offsite agencies involved in initial with the offsite agencies involved in initial emergency notifications. This system can emergency notifications. This system can quickly conference the offsite agencies quickly conference the offsite agencies for notifications. RNP MCR, TSC, and for notifications. RNP MCR, TSC, and the EOF have this system. It is also the EOF have this system. It is also located in RNP Alternate TSC and EOF. located in RNP Alternate TSC and EOF.
DEMNET is the primary means of DEMNET is the primary means of communication for the MCR, TSC, and communication for the MCR and EOF EOF when contacting OROs. when contacting OROs.
28 SU7.1 Private Branch Exchange (PBX) Private Branch Exchange (PBX) attachment 1 A PBX is a full featured telephone A PBX is a full featured telephone Rev. 2 page 233 system that provides internal calling system that provides internal calling Rev. 3 page 232 services for one or more locations. The services for one or more locations. The PBX terminates commercial phone lines PBX terminates commercial phone lines from a carrier (AT&T, Verizon, from a carrier (AT&T, Verizon, CenturyLink, etc.) to provide inbound and CenturyLink, etc.) to provide inbound and outbound calling capabilities between outbound calling capabilities between Duke Energy and external parties. PBX Duke Energy and external parties. PBX systems have a number of mechanisms systems have a number of mechanisms which make them resistant to failure which make them resistant to failure including, redundant power connections, including, redundant power connections, redundant network connections, and redundant network connections, and server hardware installed in server hardware installed in geographically diverse locations. geographically diverse locations.
PBX is the primary means of PBX is the primary means of communication between the MCR, TSC, communication between the MCR, TSC,
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PBX is the alternate means of PBX is the alternate means of communication for the MCR, TSC, and communication for the MCR and EOF EOF when contacting OROs. when contacting OROs.
29 SU7.1 Cellular Telephones Cellular Telephones attachment 1 Any mobile telephone (non-Duke Energy Any mobile telephone (non-Duke Energy Rev. 2 page 234 or Duke Energy provided) capable of or Duke Energy provided) capable of Rev. 3 page 233 sending and receiving phone calls sending and receiving phone calls through ground based cell sites. through ground based cell sites.
Cellular phones are an alternate means Cellular phones are the primary means of communication between the MCR, of communication for the MCR and EOF TSC, and EOF. when contacting FMTs.
Cellular phones are an alternate means Cellular phones are an alternate means of communication for the MCR, TSC, and of communication between the MCR, EOF when contacting OROs. TSC, and EOF.
Cellular phones are an alternate means Cellular phones are an alternate means of communication for the MCR and EOF of communication for the MCR and TSC when contacting OROs.
when contacting NRC.
Cellular phones are an alternate means Cellular phones are an alternate means of communication for the MCR and TSC of communication for the MCR, TSC, and when contacting NRC.
EOF when contacting FMTs.
30 SU7.1 Satellite Telephones Satellite Telephones attachment 1 Any mobile telephone capable of sending Any mobile telephone capable of sending Rev. 2 page 235 and receiving phone calls through and receiving phone calls through Rev. 3 page 234 orbiting satellites. orbiting satellites.
Satellite phones are an alternate means Satellite phones are an alternate means of communication between the MCR, of communication for the MCR and EOF TSC, and EOF. when contacting FMTs.
Satellite phones are an alternate means Satellite phones are an alternate means of communication for the MCR, TSC, and of communication between the MCR, EOF when contacting OROs. TSC, and EOF.
Satellite phones are an alternate means Satellite phones are an alternate means of communication for the MCR and TSC of communication for the MCR and EOF when contacting NRC.
when contacting OROs.
Satellite phones are an alternate means Satellite phones are an alternate means of communication for the MCR, TSC, and of communication for the MCR and TSC EOF when contacting FMTs.
when contacting NRC.
31 Attachment 2 ECCS (SI) actuation is caused by (ref. ECCS (SI) actuation is caused by (ref.
Rev. 2 page 273 1): 2):
Rev. 3 page 272
- Pressurizer pressure < 1715 psig
- Pressurizer pressure < 1715 psig
- Containment pressure > 4.0 psig
- Containment pressure > 4.0 psig
- Steam Line P > 100 psid
- Steam Line P > 100 psid
- High steam flow w/ low SG pressure or
- High steam flow w/ low SG pressure or low RCS Tavg low RCS Tavg This threshold is based on an This threshold is based on an UNISOLABLE RCS leak of sufficient size UNISOLABLE RCS leak of sufficient size to require an automatic or manual to require an automatic or manual actuation of the Emergency Core Cooling actuation of the Emergency Core Cooling System (ECCS). This condition clearly System (ECCS). This condition clearly
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represents a loss of the RCS Barrier. represents a loss of the RCS Barrier.
This threshold is applicable to This threshold is applicable to unidentified and pressure boundary unidentified and pressure boundary leakage, as well as identified leakage. It leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS is also applicable to UNISOLABLE RCS leakage through an interfacing system. leakage through an interfacing system.
The mass loss may be into any location The mass loss may be into any location
- inside containment, to the secondary- - inside containment, to the secondary-side (i.e., steam generator tube leakage) side (i.e., steam generator tube leakage) or outside of containment. or outside of containment. (ref. 1) 32 Attachment 2 1. EOP-E-0 Reactor Trip or Safety 1. AOP-035, Steam Generator Tube Rev. 2 page 274 Injection Leak Rev. 3 page 273 2. EOP-E-3 Steam Generator Tube 2. EOP-E-0 Reactor Trip or Safety Rupture Injection RNP Basis 3. NEI 99-01 RCS or SG Tube Leakage 3. EOP-E-3 Steam Generator Tube Reference(s): Reactor Coolant System Loss 1.A Rupture
- 4. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Loss 1.A 33 Attachment 2 The Chemical and Volume Control The Chemical and Volume Control Rev. 2 page 275 System (CVCS) includes three positive System (CVCS) includes three positive Rev. 3 page 274 displacement charging pumps each with displacement charging pumps each with a capacity of 77 gpm (54 - 69 gpm in the a capacity of 77 gpm (54 - 69 gpm in the normal charging mode). RCS leakage normal charging mode). RCS leakage greater than the capacity of a charging greater than the capacity of a charging pump is indicative of substantial RCS pump is indicative of substantial RCS leakage. (ref. 1, 2). leakage. (ref. 1, 3).
This threshold is based on an This threshold is based on an UNISOLABLE RCS leak that results in UNISOLABLE RCS leak that results in the inability to maintain pressurizer level the inability to maintain pressurizer level within specified limits by operation of a within specified limits by operation of a normally used charging (makeup) pump, normally used charging (makeup) pump, but an ECCS (SI) actuation has not but an ECCS (SI) actuation has not occurred. The threshold is met an occurred. The threshold is met an operating procedure, or operating crew operating procedure, or operating crew supervision, directs that a standby supervision, directs that a standby charging (makeup) pump be placed in charging (makeup) pump be placed in service to restore and maintain service to restore and maintain pressurizer level. The threshold is also pressurizer level. The threshold is also considered met if a standby charging considered met if a standby charging pump was already in service and is pump was already in service and is required to maintain pressurizer level. required to maintain pressurizer level.
This threshold is applicable to This threshold is applicable to unidentified and pressure boundary unidentified and pressure boundary leakage, as well as identified leakage. It leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS is also applicable to UNISOLABLE RCS leakage through an interfacing system. leakage through an interfacing system.
The mass loss may be into any location The mass loss may be into any location
- inside containment, to the secondary- - inside containment, to the secondary-side (i.e., steam generator tube leakage) side (i.e., steam generator tube leakage) or outside of containment. or outside of containment. (ref. 2)
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34 Attachment 2 1. AOP-016 Excessive Primary Plant 1. AOP-016 Excessive Primary Plant Rev. 2 page 276 Leakage Leakage Rev. 3 page 275 2. UFSAR Section 9.3.4 Chemical and 2. AOP-035, Steam Generator Tube Volume Control Center Leak RNP Basis 3. NEI 99-01 RCS or SG Tube Leakage 3. UFSAR Section 9.3.4 Chemical and Reference(s): Reactor Coolant System Potential Loss Volume Control Center 1.A 4. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.A 35 Attachment 2 The status of the containment barrier The status of the containment barrier Rev. 2 page 300 during an event involving steam during an event involving steam Rev. 3 page 299 generator tube leakage is assessed generator tube leakage is assessed using Loss Threshold A.1. using Loss Threshold A.1. (ref. 1) 36 Attachment 2 1. NEI 99-01 CMT Integrity or Bypass 1. AOP-035, Steam Generator Tube Rev. 2 page 300 Containment Loss 4.A Leak Rev. 3 page 299 2. NEI 99-01 CMT Integrity or Bypass Containment Loss 4.A RNP Basis Reference(s):
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Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:
List all emergency plan sections that were reviewed for this activity by number and title.
IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.
Licensing Basis for NEI 99-01 Rev 6 EALs RNP: ML16061A472 Letter Dated April 28, 2016.
Subject:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.
2 - ISSUANCE OF AMENDMENT TO ADOPT EMERGENCY ACTION LEVEL SCHEME PURSUANT TO NEI 99-01, REVISION 6, "DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS" (CAC NO. MF6222)
Amendment No. 245 to Renewed Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant Unit No. 2.
Additional Licensing basis to implement FAQs ML19058A632 Letter dated July 1, 2019.
Subject:
Catawba Nuclear Station, Units 1 And 2; McGuire Nuclear Station, Units 1 And 2; Oconee Nuclear Station, Units 1, 2, And 3; Brunswick Steam Electric Plant, Units 1 And 2; Shearon Harris Nuclear Power Plant, Unit 1; And H. B. Robinson Steam Electric Plant, Unit No. 2 - Issuance of Amendments To Revise Emergency Action Level Schemes To Incorporate Clarifications Provided By Emergency Preparedness Frequently Asked Questions 2015-013, 2015-014, And 2016-002 (EPID L-2018-LLA-0174)
Amendment Nos. 303 and 299 to Renewed Facility Operating License Nos. NPF-35 and NPF-52 for the Catawba Nuclear Station, Units 1 and 2 (Catawba), respectively; Amendment Nos. 315 and 294 to Renewed Facility Operating License Nos. NPF-9 and NPF-17 for the McGuire Nuclear Station, Units 1 and 2 (McGuire), respectively; Amendment Nos. 412, 414, and 413 to Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55 for the Oconee Nuclear Station, Units 1, 2, and 3 (Oconee), respectively; Amendment Nos. 291 and 319 to Renewed Facility Operating License Nos. DPR-71 and DPR-62 for Brunswick Steam Electric Plant, Units 1 and 2 (Brunswick), respectively; Amendment No. 172 to Renewed Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris); and Amendment No. 264 to Renewed Facility Operating License No.
DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (Robinson).
Current EALs RNP Nuclear Plant EAL Technical Basis Document, CSD-EP-RNP-0101-01 Revision 2 Licensing Basis EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 0 EP-RNP-EPLAN-ANNEX, Duke Energy Robinson Emergency Plan Annex Revision 0 Current Emergency Plan EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 5 Section D- Emergency Classification System EP-RNP-EPLAN-ANNEX, Duke Energy Robinson Emergency Plan Annex Revision 2 Section D-Emergency Classification System The differences in approved revisions and the current revisions of the Emergency Plans have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions.
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Section IV: Ability to Maintain the Emergency Plan.
Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.
- 1. Do any of the elements of the proposed activity change information or intent contained in the Yes Emergency Plan? No
- 2. Do any elements of the proposed activity change the process or capability for alerting or notifying Yes the public as described in the FEMA-approved Alert and Notification System Design Report? No Yes
- 3. Do any elements of the proposed activity change the Evacuation Time Estimate results?
No
- 4. Do any elements of the proposed activity change the On-Shift Staffing Analysis results? Yes No
- 5. Does the Proposed activity require a change to the Emergency Plan Programmatic Description? Yes No If Question 5 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.
Section IV conclusion:
If questions 1-5 in Section IV marked NO, then complete Section V.
If any question 1-5 of Section IV marked yes, then continue at Section VI.
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Section V: Maintaining the Emergency Plan Conclusion.
The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.
- 1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.
- 2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.
I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).
Section VI: Activity Previously Reviewed?
Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?
10 CFR 50.54(q) Evaluation is not required.
Yes Identify bounding source document below and continue to Section XIV.
No Continue to Section VII.
If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.
Partially Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.
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Section VII: Editorial Changes All Activities/Changes identified in Section II are editorial/typographical changes such as Yes formatting, paragraph numbering, spelling, or punctuation that does not change intent.
None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to No Section VIII.
Partially Some Activities/Changes are editorial/typographical.
If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XII.
If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.
Justification:
The proposed changes below are defined as editorial in accordance with AD-EP-ALL-0602, Emergency Plan Change Screening and Effectiveness Evaluations 10 CFR 50.54(Q) and do not change the intent of the steps as written.
Proposed change 1 updates table of contents, revision summary, and page numbers. Each of these changes are defined as editorial IAW AD-EP-ALL-0602 as it corrects references to steps, pages, attachments, forms, documents, tables, exhibits, and procedures.
Proposed change 2 updates revision number from 2 to 3 for CSD-EP-RNP-0101-01, EAL Technical Basis Document and 002 to 003 for CSD-EP-RNP-0101-02, EAL Wallchart (Both Hot and Cold). These changes are defined as editorial IAW AD-EP-ALL-0602 as they correct references to steps, pages, attachments, forms, documents, tables, exhibits, and procedures.
Proposed changes 3-12 correct reference numbers for Section 4.3 references. These changes are defined as editorial IAW AD-EP-ALL-0602 as they correct references to steps, pages, attachments, forms, documents, tables, exhibits, and procedures.
Proposed changes 13 and 25 correct the name of the Duke Emergency Management Network (DEMNET) from Duke Energy Emergency Management Network (DEMNET) Within the tables for EALs CU5.1 (C-4) and SU7.1 (S-
- 3) with no change to intent of document. The word "Energy" was placed in error and is not part of the official title of the system. These changes are defined as editorial IAW AD-EP-ALL-0602 as they correct typographical errors.
Proposed change 19 updates the hyperlink to access the NEIC website for real time seismic data due to USGS updating their webpage. This change is defined as editorial IAW AD-EP-ALL-0602 as it corrects hyperlinks.
Proposed changes 20, 22 - 23, 31, 33, & 35 correct reference numbers in various sections of the procedure. These changes are defined as editorial IAW AD-EP-ALL-0602 as they correct references to steps, pages, attachments, forms, documents, tables, exhibits, and procedures.
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Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)
Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate box.
1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.
The response organization has the staff to respond and to augment staff on a continuing basis (24-7 1b staffing) in accordance with the emergency plan.
2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned 2b The process for timely augmentation of onshift staff is established and maintained.
3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.
3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.
4 10 CFR 50.47(b)(4) Emergency Classification System RS A standard scheme of emergency classification and action levels is in use. (Requires V/V 4a (Attachment 3) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS Procedures for notification of State and local governmental agencies are capable of alerting them of 5a the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.
Administrative and physical means have been established for alerting and providing prompt 5b instructions to public within the plume exposure pathway.
The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 5c Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter 6 10 CFR 50.47(b)(6) Emergency Communications Systems are established for prompt communication among principal emergency response 6a organizations.
6b Systems are established for prompt communication to emergency response personnel.
7 10 CFR 50.47(b)(7) Public Education and Information Emergency preparedness information is made available to the public on a periodic basis within the 7a plume exposure pathway emergency planning zone (EPZ).
7b Coordinated dissemination of public information during emergencies is established.
8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response 8b Adequate equipment is maintained to support emergency response.
9 10 CFR 50.47(b)(9) Accident Assessment RS 9a Methods, systems, and equipment for assessment of radioactive releases are in use.
10 10 CFR 50.47(b) (10) Protective Response RS
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10a A range of public PARs is available for implementation during emergencies.
Evacuation time estimates for the population located in the plume exposure pathway EPZ are 10b available to support the formulation of PARs and have been provided to State and local governmental authorities.
A range of protective actions is available for plant emergency workers during emergencies, including 10c those for hostile action events.
KI is available for implementation as a protective action recommendation in those jurisdictions that 10d chose to provide KI to the public.
11 10 CFR 50.47(b) (11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.
12 10 CFR 50.47(b) (12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.
13 10 CFR 50.47(b) (13) Recovery Planning and Post-Accident Operations 13a Plans for recovery and reentry are developed.
14 10 CFR 50.47(b) (14) Drills and Exercises A drill and exercise program (including radiological, medical, health physics and other program areas) 14a is established.
Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, 14b and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.
14c Identified weaknesses are corrected.
15 10 CFR 50.47(b) (15) Emergency Response Training 15a Training is provided to emergency responders.
16 10 CFR 50.47(b) (16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.
16b Planners responsible for emergency plan development and maintenance are properly trained.
Section VIII: Conclusion If any Section VIII criteria are checked, document the basis for conclusion below for any changes that are more than editorial, however not impacted by any of the identified criteria in Section VIII and continue the 50.54(q) Review in Section IX.
If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document justification below for any changes that are more than editorial and continue to Section XIV.
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Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.
Planning Standard A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Function (1) A standard scheme of emergency classification and action levels is in use.
Supporting requirements from Appendix E to 10 CFR Part 50 B. Assessment Actions
- 1. The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities and approved by the NRC. Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis.
- 2. A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. Licensees shall follow the change process in § 50.54(q) for all other emergency action level changes.
C. Activation of Emergency Organization
- 1. The entire spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described. The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described. Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described. The existence, but not the details, of a message authentication scheme shall be noted for such agencies. The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG-0654/FEMA-REP-1.
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- 2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded. Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.
Informing criteria from Section II.D of NUREG-0654 Rev. 2 D. A standard emergency classification and action level scheme is established and maintained. The scheme provides detailed EALs for each of the four ECLs in Section IV.C.1 of Appendix E to 10 CFR Part 50.
D.1.a The EALs are developed using guidance provided or endorsed by the NRC that is applicable to the reactor design.
D.1.b The initial emergency classification and action level scheme is discussed and agreed to by the licensee and OROs, and approved by the NRC. Thereafter, the scheme is reviewed with OROs on an annual basis.
D.2 The capability to assess, classify, and declare the emergency condition within 15 minutes after the availability of indications to NPP operators that an EAL has been met or exceeded is described.
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Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q). Address each Planning Standard identified in Section IX. Continue to Section XI.
Proposed changes 14-18 and 26-30:
Proposed changes 14-18 and 26-30 are being made to update bases definitions for communication methods to match RNP Emergency Plan. The following changes were made:
Proposed changes 14 and 26 remove radios as the primary means of communication for the MCR, TSC, and EOF when contacting FMTs. Cellular phones are now the primary means when communicating with FMTs with satellite phones as the back-up method. Radios have become obsolete and are less reliable when miles away from the site. Cellular and satellite phones have proven more reliable to communicate in place of radios. This change maintains the effectiveness of the emergency plan because it continues to ensure a reliable primary communication method is available with a back-up. There is no change to the RNP on-site radio system.
Proposed changes 15 and 27 correct the title of DEMNET within the title of the basis of the EALs and removes DEMNET from the TSC as the primary means of communication when contacting OROs. The word "Energy" was placed in error and is not part of the official title of the system. This aligns with RNP Emergency Plan communications methods now that the TSC is no longer responsible for performing ORO emergency notifications since the approval and implementation of the Duke Energy Common Emergency plan. RNP MCR has this responsibility and then turns responsibility to EOF once the EOF is activated. There is no change to the DEMNET system and loss of the DEMNET system will continue to be evaluated for loss of communication methods per EALs.
Proposed changes 16 and 28 remove PBX from the TSC as an alternate means of communication when contacting OROs. This aligns with RNP Emergency Plan communications methods now that the TSC is no longer responsible for performing ORO emergency notifications since the approval and implementation of the Duke Energy Common Emergency plan. RNP MCR has this responsibility and then turns responsibility to EOF once the EOF is activated. There is no change to the PBX system and loss of the PBX system will continue to be evaluated for loss of communication methods per EALs.
Proposed changes 17 and 29 remove Cellular Phones from the TSC as an alternate means of communication when contacting OROs. This aligns with RNP Emergency Plan communications methods now that the TSC is no longer responsible for performing ORO emergency notifications since the approval and implementation of the Duke Energy Common Emergency plan. RNP MCR has this responsibility and then turns responsibility over to EOF once the EOF is activated. There is no change to the Cellular Phone system and loss of the Cellular Phone system will continue to be evaluated for loss of communication methods per EALs.
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Proposed changes 17 and 29 also updates Cellular phones from alternate to primary means of communication for the MCR and EOF when contacting FMTs. This also includes removing TSC from the sentence since FMT control is performed from MCR and then EOF once turnover is completed. Removal of the TSC for communicating with the FMTs is appropriate since the approval and implementation of the Duke Energy Common Emergency plan removing these responsibilities. Cellular phones are now the primary means when communicating with FMTs with satellite phones as the back-up method. This change maintains the effectiveness of the emergency plan because it continues to ensure a reliable primary communication method is available with a back-up. There is no change to the RNP cellular phone system, and a loss of cellular phones will continue to be evaluated for loss of communication methods per EALs.
Proposed changes 18 and 30 remove Satellite Phones from the TSC as an alternate means of communication when contacting FMTs and OROs. This aligns with RNP Emergency Plan communications methods now that the TSC is not responsible for performing ORO emergency notifications or FMT control since the approval and implementation of the Duke Energy Common Emergency plan. RNP MCR has these responsibilities and then turns responsibility over to EOF once the EOF is activated. There is no change to the Satellite Phone system and loss of the Satellite Phone system will continue to be evaluated for loss of communication methods per EALs.
The communications methods updated for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6 and lists communications methods as described in RNP Emergency Plan. The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the changes will maintain the accuracy and timeliness of a classification following a loss of all communications methods used to communicate on-site or with OROs or NRC. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed changes 14-18 and 26-30 can be made because the changes continue to be aligned with Duke Energys approved EAL basis and 10CFR 50.47(b)(4).
Proposed change 21:
Proposed change is being made to update EAL SU5.1 basis definitions for identified, unidentified, and pressure boundary leakage. The first three paragraphs were originally written based on RNP Technical Specifications (TSs) Definitions section 1.1 as referenced at the end of each paragraph (ref.1). This reference has been updated in Amendment No. 264 to Renewed Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (Robinson). for the Robinson Nuclear Plant, Unit 2.
The amendments revise the TSs related to reactor coolant system operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements..
First paragraph changes:
From:
Identified Leakage:
- a. Leakage from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or return) that is captured and conducted to collection systems or a sump or collecting tank, or
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- b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary leakage, or
- c. RCS leakage through a steam generator to the Secondary Coolant System (primary-to-secondary leakage).
To:
Identified Leakage:
- a. Leakage from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or return) that is captured and conducted to collection systems or a sump or collecting tank, or
- b. Leakage into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems, or
- c. Reactor Coolant System (RCS) leakage through a steam generator to the Secondary Coolant System (primary-to-secondary leakage).
Revised the Identified Leakage definition to not exclude Pressure Boundary Leakage and spelled out acronym for Reactor Coolant System (RCS).
The change to the definition of identified leakage applies to leakage from an RCS component that would be released directly into the containment atmosphere where the leakage would be detectable by the RCS leakage detection systems. The revised definition of identified leakage removes the existing exclusion of leakage known to be pressure boundary leakage. Therefore, all RCS leakage that is specifically located and known to not interfere with the operation of leakage detection systems would be considered identified leakage, regardless of the source of leakage. Not excluding Pressure Boundary Leakage provides a clearer definition of identified leakage.
No changes to second paragraph.
Third paragraph changes:
From:
Pressure boundary leakage is leakage (except SG leakage) through a nonisolable leak in an RCS component body, pipe wall, or vessel wall.
To:
Pressure boundary leakage is leakage (except SG leakage) through a leak in an RCS component body, pipe wall, or vessel wall. Leakage past seals, packing, and gaskets is not pressure boundary leakage.
Revised the defined term leakage to remove the term unisolable from the definition of Pressure Boundary Leakage and added Leakage past seals, packing, and gaskets is not pressure boundary leakage.
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From NRC Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements, the word unisolable has been interpreted inconsistently in the definition of pressure boundary leakage. In some interpretations, it has been considered a means of emphasizing that the leakage fault is in the base material of the pressure boundary and, therefore, the leakage cannot be stopped by adjusting packing or seals. In such a case, the fault represents degradation of the pressure boundary material that could result in a loss of structural integrity. Another interpretation is that leakage through a fault in portions of the pressure boundary that can be separated from the RCS by an isolation device (typically an installed valve) need not be considered as pressure boundary leakage once the isolation device is performing its isolation function. This would allow certain small sections of the Reactor Coolant Pressure Boundary (RCPB) between the outermost two valves to be removed from consideration as RCPB leakage when the inner valve is closed. Regardless of the interpretation, deletion of the word unisolable does not alter the fundamental meaning that pressure boundary leakage represents degradation that could ultimately result in a loss of structural integrity. Therefore, removing the term unisolable provides a clearer definition of pressure boundary leakage.
The additional sentence LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE, is consistent with the definition and was added for emphasis. Definition is clear that pressure boundary leakage is leakage through a fault in an RCS component body, pipe wall, or vessel wall. The additional reminder to exclude leakage from seals, packing, and gaskets which are not RCS component bodies, pipe walls, or vessel walls is an enhancement with no change to intent of the definition.
The revised first paragraph supports the 2nd EAL condition RCS identified leakage > 25 gpm for 15 min. and the revised third paragraph supports the 1st EAL condition RCS unidentified or pressure boundary leakage > 10 gpm for 15 min.. These proposed changes remain consistent with the approved EAL scheme as described in the RNP EAL bases:
The first and second EAL conditions are focused on a loss of mass from the RCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes remain consistent with NEI 99-01 rev 6 EAL scheme for this EAL:
EAL #1 and EAL #2 are focused on a loss of mass from the RCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes continue to support the first and second EAL conditions, because the definitions continue to be leakage types that are defined in the plant Technical Specification.
The leakage definitions updated for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6. The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an RCS leak. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 21 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
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Proposed change 21 continues to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by Robinson Nuclear Plant (RNP).
Proposed change 21 continues to comply with 10 CFR Part 50 Appendix E, IV.C.2, because RNP has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure RNP will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
Proposed changes 24, 32, 34, & 36:
Proposed changes 24, 32, 34, & 36 add AOP-035, Steam Generator Tube Leak reference to the RNP Basis Reference(s) for those sections that referred to Steam Generator Tube Leakage. The addition to the reference complies with AD-DC-ALL-0202, Writers Manual for Procedures and Work Instructions for ensuring information contained within the body of the document is properly referenced.
The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the changes will maintain the accuracy and timeliness of a classification following Steam Generator Tube Leakage. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed changes 24, 32, 34, & 36 can be made because the changes continue to be aligned with Duke Energys approved EAL basis and 10CFR 50.47(b)(4).
Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.
Proposed changes 14-18 and 26-30:
Proposed changes 14-18 and 26-30 are being made to update bases definitions for communication methods to match RNP Emergency Plan. The following changes were made:
Proposed changes 14 and 26 remove radios as the primary means of communication for the MCR, TSC, and EOF when contacting FMTs. Cellular phones are now the primary means when communicating with FMTs with satellite phones as the back-up method. Radios have become obsolete and are less reliable when miles away from the site. Cellular and satellite phones have proven more reliable to communicate in place of radios. This change maintains the effectiveness of the emergency plan because it continues to ensure a reliable primary communication method is available with a back-up. There is no change to the RNP on-site radio system.
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Proposed changes 15 and 27 correct the title of DEMNET within the title of the basis of the EALs and removes DEMNET from the TSC as the primary means of communication when contacting OROs. The word "Energy" was placed in error and is not part of the official title of the system. This aligns with RNP Emergency Plan communications methods now that the TSC is no longer responsible for performing ORO emergency notifications since the approval and implementation of the Duke Energy Common Emergency plan. RNP MCR has this responsibility and then turns responsibility to EOF once the EOF is activated. There is no change to the DEMNET system and loss of the DEMNET system will continue to be evaluated for loss of communication methods per EALs.
Proposed changes 16 and 28 remove PBX from the TSC as an alternate means of communication when contacting OROs. This aligns with RNP Emergency Plan communications methods now that the TSC is no longer responsible for performing ORO emergency notifications since the approval and implementation of the Duke Energy Common Emergency plan. RNP MCR has this responsibility and then turns responsibility to EOF once the EOF is activated. There is no change to the PBX system and loss of the PBX system will continue to be evaluated for loss of communication methods per EALs.
Proposed changes 17 and 29 remove Cellular Phones from the TSC as an alternate means of communication when contacting OROs. This aligns with RNP Emergency Plan communications methods now that the TSC is no longer responsible for performing ORO emergency notifications since the approval and implementation of the Duke Energy Common Emergency plan. RNP MCR has this responsibility and then turns responsibility over to EOF once the EOF is activated. There is no change to the Cellular Phone system and loss of the Cellular Phone system will continue to be evaluated for loss of communication methods per EALs.
Proposed changes 17 and 29 also updates Cellular phones from alternate to primary means of communication for the MCR and EOF when contacting FMTs. This also includes removing TSC from the sentence since FMT control is performed from MCR and then EOF once turnover is completed. Removal of the TSC for communicating with the FMTs is appropriate since the approval and implementation of the Duke Energy Common Emergency plan removing these responsibilities. Cellular phones are now the primary means when communicating with FMTs with satellite phones as the back-up method. This change maintains the effectiveness of the emergency plan because it continues to ensure a reliable primary communication method is available with a back-up. There is no change to the RNP cellular phone system, and a loss of cellular phones will continue to be evaluated for loss of communication methods per EALs.
Proposed changes 18 and 30 remove Satellite Phones from the TSC as an alternate means of communication when contacting FMTs and OROs. This aligns with RNP Emergency Plan communications methods now that the TSC is not responsible for performing ORO emergency notifications or FMT control since the approval and implementation of the Duke Energy Common Emergency plan. RNP MCR has these responsibilities and then turns responsibility over to EOF once the EOF is activated. There is no change to the Satellite Phone system and loss of the Satellite Phone system will continue to be evaluated for loss of communication methods per EALs.
The communications methods updated for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6 and lists communications methods as described in RNP Emergency Plan. The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the changes will maintain the accuracy and timeliness of a classification following a loss of all communications methods used to communicate on-site or with OROs or NRC. The meaning or intent of the basis of the approved EAL is unchanged.
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Proposed changes 14-18 and 26-30 can be made because the changes continue to be aligned with Duke Energys approved EAL basis and 10CFR 50.47(b)(4).
Proposed change 21:
Proposed change is being made to update EAL SU5.1 basis definitions for identified, unidentified, and pressure boundary leakage. The first three paragraphs were originally written based on RNP Technical Specifications (TSs) Definitions section 1.1 as referenced at the end of each paragraph (ref.1). This reference has been updated in Amendment No. 264 to Renewed Facility Operating License No. DPR-23 for the H. B.
Robinson Steam Electric Plant, Unit No. 2 (Robinson). for the Robinson Nuclear Plant, Unit 2. The amendments revise the TSs related to reactor coolant system operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements..
First paragraph changes:
From:
Identified Leakage:
- a. Leakage from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or return) that is captured and conducted to collection systems or a sump or collecting tank, or
- b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary leakage, or
- c. RCS leakage through a steam generator to the Secondary Coolant System (primary-to-secondary leakage).
To:
Identified Leakage:
- a. Leakage from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or return) that is captured and conducted to collection systems or a sump or collecting tank, or
- b. Leakage into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems, or
- c. Reactor Coolant System (RCS) leakage through a steam generator to the Secondary Coolant System (primary-to-secondary leakage).
Revised the Identified Leakage definition to not exclude Pressure Boundary Leakage and spelled out acronym for Reactor Coolant System (RCS).
The change to the definition of identified leakage applies to leakage from an RCS component that would be released directly into the containment atmosphere where the leakage would be detectable by the RCS leakage detection systems. The revised definition of identified leakage removes the existing exclusion of leakage known to be pressure boundary leakage. Therefore, all RCS leakage that is specifically located and known to not interfere with the operation of leakage detection systems would be considered identified leakage, regardless of the source of leakage. Not excluding Pressure Boundary Leakage provides a clearer definition of identified leakage.
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No changes to second paragraph.
Third paragraph changes:
From:
Pressure boundary leakage is leakage (except SG leakage) through a nonisolable leak in an RCS component body, pipe wall, or vessel wall.
To:
Pressure boundary leakage is leakage (except SG leakage) through a leak in an RCS component body, pipe wall, or vessel wall. Leakage past seals, packing, and gaskets is not pressure boundary leakage.
Revised the defined term leakage to remove the term unisolable from the definition of Pressure Boundary Leakage and added Leakage past seals, packing, and gaskets is not pressure boundary leakage.
From NRC Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements, the word unisolable has been interpreted inconsistently in the definition of pressure boundary leakage. In some interpretations, it has been considered a means of emphasizing that the leakage fault is in the base material of the pressure boundary and, therefore, the leakage cannot be stopped by adjusting packing or seals. In such a case, the fault represents degradation of the pressure boundary material that could result in a loss of structural integrity. Another interpretation is that leakage through a fault in portions of the pressure boundary that can be separated from the RCS by an isolation device (typically an installed valve) need not be considered as pressure boundary leakage once the isolation device is performing its isolation function. This would allow certain small sections of the Reactor Coolant Pressure Boundary (RCPB) between the outermost two valves to be removed from consideration as RCPB leakage when the inner valve is closed. Regardless of the interpretation, deletion of the word unisolable does not alter the fundamental meaning that pressure boundary leakage represents degradation that could ultimately result in a loss of structural integrity. Therefore, removing the term unisolable provides a clearer definition of pressure boundary leakage.
The additional sentence LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE, is consistent with the definition and was added for emphasis. Definition is clear that pressure boundary leakage is leakage through a fault in an RCS component body, pipe wall, or vessel wall. The additional reminder to exclude leakage from seals, packing, and gaskets which are not RCS component bodies, pipe walls, or vessel walls is an enhancement with no change to intent of the definition.
The revised first paragraph supports the 2nd EAL condition RCS identified leakage > 25 gpm for 15 min. and the revised third paragraph supports the 1st EAL condition RCS unidentified or pressure boundary leakage > 10 gpm for 15 min.. These proposed changes remain consistent with the approved EAL scheme as described in the RNP EAL bases:
The first and second EAL conditions are focused on a loss of mass from the RCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes remain consistent with NEI 99-01 rev 6 EAL scheme for this EAL:
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EAL #1 and EAL #2 are focused on a loss of mass from the RCS due to unidentified leakage", "pressure boundary leakage" or "identified leakage (as these leakage types are defined in the plant Technical Specifications).
These proposed changes continue to support the first and second EAL conditions, because the definitions continue to be leakage types that are defined in the plant Technical Specification.
The leakage definitions updated for this EAL are consistent with the overall EAL scheme development guidance in NEI 99-01 revision 6. The proposed change maintains the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the change will maintain the accuracy and timeliness of a classification following an RCS leak. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed change 21 can be made because the change continues to be aligned with approved EAL basis and NEI 99-01 Rev. 6 EAL scheme.
Proposed change 21 continues to comply with 10 CFR 50.47(b)(4) because the change continues to ensure a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by Robinson Nuclear Plant (RNP).
Proposed change 21 continues to comply with 10 CFR Part 50 Appendix E, IV.C.2, because RNP has established and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded. This change continues to ensure RNP will promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
Proposed changes 24, 32, 34, & 36:
Proposed changes 24, 32, 34, & 36 add AOP-035, Steam Generator Tube Leak reference to the RNP Basis Reference(s) for those sections that referred to Steam Generator Tube Leakage. The addition to the reference complies with AD-DC-ALL-0202, Writers Manual for Procedures and Work Instructions for ensuring information contained within the body of the document is properly referenced.
The proposed changes maintain the licensees capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications. The classification of the event would NOT be different from that approved by the NRC in the site-specific application referenced in Part II. Implementation of the changes will maintain the accuracy and timeliness of a classification following Steam Generator Tube Leakage. The meaning or intent of the basis of the approved EAL is unchanged.
Proposed changes 24, 32, 34, & 36 can be made because the changes continue to be aligned with Duke Energys approved EAL basis and 10CFR 50.47(b)(4).
The proposed change can be made because the change continues to ensure a standard scheme of emergency classification and action levels are in use and there is no negative impact to timeliness or accuracy.
The proposed change does not reduce the effectiveness of Robinson Nuclear Plant Emergency Plan. The change continues to provide assurance that the Emergency Response Organization has the ability and capability to:
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- respond to an emergency;
- perform functions in a timely manner;
- effectively identify and take measures to ensure protection of the public health and safety; and
- effectively use response equipment and emergency response procedures.
The change continues to meet NRC requirements, as described in 10 CFR 50.47(b)(4) and 10 CFR 50, Appendix E as well as the requirements of the Robinson Nuclear Plant Emergency Plan as written and approved.
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Section XII: Evaluation Conclusion Answer the following questions about the proposed change:
- 1. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? Yes No
- 2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in Yes effectiveness)? No
- 3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes No Section XII: Conclusion Questions 1, 2 and 3 are answered YES, complete step below to create a General CAS assignment, and then continue on to Section XIV and implement change(s).
General CAS assignment created - Licensing submit changes in accordance with 10 CFR 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XIII and Section XIV.
Section XIII: Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change be submitted to the NRC for prior approval?
Yes If No, reject the proposed change, or modify the proposed change and perform a new evaluation. No Continue to Section XIV for this evaluation.
If YES, then initiate a License Amendment Request in accordance 10 CFR 50.90, AD-LS-ALL-0002, Regulatory Correspondence, and AD-LS-ALL-0015, License Amendment Request and Changes to SLC, TRM, and TS Bases, and include the tracking number:___________________________________. Complete Section XIV.
Section XIV: Signatures:
EP CFAM Final Approval is required for changes affecting Program Element 4a of Section VIII. If CFAM approval is NOT required, then mark the EP CFAM signature block as not applicable (N/A) to indicate that signature is not required.Section XIV as applicable.
Preparer Name (Print): Preparer Signature: See NAS Date:
Bruce Tunnell See NAS Reviewer Name (Print): Reviewer Signature: See NAS Date:
Nelson Tart See NAS Approver Name (Print): Approver Signature: See NAS Date:
Phil Mason See NAS Approver (EP CFAM, as required) Name (Print): Approver Signature: See NAS Date:
David Thompson See NAS QA RECORD
U.S. Nuclear Regulatory Commission Attachment 5 Serial: RA-23-0325 Attachment 5: Procedure EP-RNP-EPLAN-ANNEX, DUKE ENERGY ROBINSON EMERGENCY PLAN ANNEX, Revision 3, 10 CFR 50.54(q)
EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
Rev. 9 Attachment 5 Page 1 of 8 10 CFR 50.54(q) Review Form Section I: 10 CFR 50.54(q) Review Number: (EREG #): 02497129 Applicable Sites and Applicability Determination # (5AD)
BNP CNS HNP MNS ONS RNP 02497132 Document #, EC #, or Revision # or N/A N/A Document or Activity Title EP-RNP-EPLAN-ANNEX 3 DUKE ENERGY ROBINSON EMERGENCY PLAN ANNEX Section II: Identify/Describe All Proposed Activities/Changes being Reviewed Event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan (Use attachments or continue additional pages as necessary): Continue to Section III.
Activity/Changes:
EP-RNP-EPLAN-ANNEX, Duke Energy Robinson Emergency Plan Annex, is the Robinson specific compliment to the Duke Energy Common Emergency Plan. The Annex is being revised due to Section 6.0, Section H -
Emergency Facilities and Equipment; Under Process Monitors correct "UFSAR Section 7.5" with "UFSAR Section 11.5.2.2".
Change Section or Step Change From Change to 1 Throughout Old revision number and revision New revision number and revision summary. summary.
2 Section H.8 A description of process monitors at A description of process monitors at page 12 RNP is located in the UFSAR Section RNP is located in the UFSAR Section 7.5. 11.5.2.2.
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Rev. 9 Attachment 5 Page 2 of 8 10 CFR 50.54(q) Review Form Section III: Description and Review of Licensing Basis Affected by the Proposed activity or Change:
List all emergency plan sections that were reviewed for this activity by number and title.
IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, Enter Licensing Basis affected by the change and continue to Section VI.
Licensing Basis:
EP-ALL-EPLAN, Duke Energy Common Emergency Plan Revision 0 EP-RNP-EPLAN-ANNEX, Duke Energy Robinson Emergency Plan Annex, Revision 0 Current Emergency Plans:
EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5 EP-RNP-EPLAN-ANNEX, Duke Energy Robinson Emergency Plan Annex, Revision 2 The differences in the approved and the current revision of the Emergency Plans have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions.
Section IV: Ability to Maintain the Emergency Plan.
Answer the following questions related to impact on the ability to maintain the Emergency Plan. Continue to Section V.
- 1. Do any of the elements of the proposed activity change information or intent contained in the Yes Emergency Plan? No
- 2. Do any elements of the proposed activity change the process or capability for alerting or notifying Yes the public as described in the FEMA-approved Alert and Notification System Design Report? No
- 3. Do any elements of the proposed activity change the Evacuation Time Estimate results? Yes No
- 4. Do any elements of the proposed activity change the On-Shift Staffing Analysis results? Yes No
- 5. Does the Proposed activity require a change to the Emergency Plan Programmatic Description? Yes No If Question 5 was answered yes, and the document being reviewed is NOT the Emergency Plan, then exit this review until the Emergency Plan change is complete or the proposed change is modified to not change the Emergency Plan Programmatic Description.
Section IV conclusion:
If questions 1-5 in Section IV marked NO, then complete Section V.
If any question 1-5 of Section IV marked yes, then continue at Section VI.
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Rev. 9 Attachment 5 Page 3 of 8 10 CFR 50.54(q) Review Form Section V: Maintaining the Emergency Plan Conclusion.
The questions in Section IV do not represent the total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Section XIV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.
- 1. Provide a brief conclusion below that describes how the conditions, as described in the emergency plan, are maintained with this activity.
- 2. Select the box below when the review completes all actions for all elements of the activity and no 10CFR50.54 screening or evaluation is required for any element. Continue to Section XIV.
I have completed a review of this activity in accordance with 10CFR50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan. No further actions are required to screen or evaluate this activity in accordance with 10CFR50.54(q)(3).
Conclusion:
Section VI: Activity Previously Reviewed?
Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or Alert and Notification System Design Report?
10 CFR 50.54(q) Evaluation is not required.
Yes Identify bounding source document below and continue to Section XIV.
No Continue to Section VII.
If PARTIALLY, identify bounding source document and list changes bounded by the approved 10 CFR 50.90 or Alert and Notification System Design Report below.
Partially Changes not bound by the approved 10 CFR 50.90 or Alert and Notification System Design Report (i.e., part requiring further review). Continue the review in Section VII.
Bounding source document and list of bounded changes: N/A
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Rev. 9 Attachment 5 Page 4 of 8 10 CFR 50.54(q) Review Form Section VII: Editorial Changes All Activities/Changes identified in Section II are editorial/typographical changes such as Yes formatting, paragraph numbering, spelling, or punctuation that does not change intent.
None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to No Section VIII.
Partially Some Activities/Changes are editorial/typographical.
If Yes is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section XII.
If Partially is checked, Identify the activities/changes listed in Section II that are editorial/typographical changes and provide justification below. Continue to Section VIII for changes not identified as editorial.
Justification:
The change(s) below are defined as editorial in accordance with AD-EP-ALL-0602, and do not change the intent of the steps as written.
Proposed change 1 is an editorial change in accordance with AD-EP-ALL-0602, Emergency Plan Change Screening and Effectiveness Evaluations 10 CFR 50.54(Q) that updated the revision number throughout the document and updated the revision summary identifying the changes made from the procedure revision requests.
Proposed change 2 is an editorial change in accordance with AD-EP-ALL-0602, Emergency Plan Change Screening and Effectiveness Evaluations 10 CFR 50.54(Q) that corrects an obvious step or section number errors where no change in sequence of the task is involved. There is no description of process monitors in the UFSAR Section 7.5 which is Safety-Related Display Instrumentation.
UFSAR 11.5.2.2 Process and Effluent Radiation Monitoring System contains the detailed description of Process Monitor related to equipment important to emergency response. This change is correcting a typographical error that does not change the intent of the steps as written.
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Rev. 9 Attachment 5 Page 5 of 8 10 CFR 50.54(q) Review Form Section VIII: Emergency Planning Element and Function Screen (Utilize Reg Guide 1.219 and Attachment 1, Additional Regulatory Guidance References for additional assistance)
Does any of Proposed Activities/Changes Identified in Section I impact any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If yes check appropriate box.
1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned.
The response organization has the staff to respond and to augment staff on a continuing basis (24-7 1b staffing) in accordance with the emergency plan.
2 10 CFR 50.47(b)(2) Onsite Emergency Organization 2a Process ensures that on shift emergency response responsibilities are staffed and assigned 2b The process for timely augmentation of onshift staff is established and maintained.
3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made.
3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.
4 10 CFR 50.47(b)(4) Emergency Classification System RS A standard scheme of emergency classification and action levels is in use. (Requires V/V 4a (Attachment 3) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS Procedures for notification of State and local governmental agencies are capable of alerting them of 5a the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.
Administrative and physical means have been established for alerting and providing prompt 5b instructions to public within the plume exposure pathway.
The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 5c Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter 6 10 CFR 50.47(b)(6) Emergency Communications Systems are established for prompt communication among principal emergency response 6a organizations.
6b Systems are established for prompt communication to emergency response personnel.
7 10 CFR 50.47(b)(7) Public Education and Information Emergency preparedness information is made available to the public on a periodic basis within the 7a plume exposure pathway emergency planning zone (EPZ).
7b Coordinated dissemination of public information during emergencies is established.
8 10 CFR 50.47(b)(8) Emergency Facilities and Equipment 8a Adequate facilities are maintained to support emergency response 8b Adequate equipment is maintained to support emergency response.
9 10 CFR 50.47(b)(9) Accident Assessment RS 9a Methods, systems, and equipment for assessment of radioactive releases are in use.
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Rev. 9 Attachment 5 Page 6 of 8 10 CFR 50.54(q) Review Form 10 10 CFR 50.47(b) (10) Protective Response RS 10a A range of public PARs is available for implementation during emergencies.
Evacuation time estimates for the population located in the plume exposure pathway EPZ are 10b available to support the formulation of PARs and have been provided to State and local governmental authorities.
A range of protective actions is available for plant emergency workers during emergencies, including 10c those for hostile action events.
KI is available for implementation as a protective action recommendation in those jurisdictions that 10d chose to provide KI to the public.
11 10 CFR 50.47(b) (11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established.
12 10 CFR 50.47(b) (12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals.
13 10 CFR 50.47(b) (13) Recovery Planning and Post-Accident Operations 13a Plans for recovery and reentry are developed.
14 10 CFR 50.47(b) (14) Drills and Exercises A drill and exercise program (including radiological, medical, health physics and other program areas) 14a is established.
Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, 14b and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.
14c Identified weaknesses are corrected.
15 10 CFR 50.47(b) (15) Emergency Response Training 15a Training is provided to emergency responders.
16 10 CFR 50.47(b) (16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established.
16b Planners responsible for emergency plan development and maintenance are properly trained.
Section VIII: Conclusion If any Section VIII criteria are checked, document the basis for conclusion below for any changes that are more than editorial, however not impacted by any of the identified criteria in Section VIII and continue the 50.54(q) Review in Section IX.
If no Section VIII criteria are checked, 10CFR50.54(q)(3) Evaluation is NOT required. Document justification below for any changes that are more than editorial and continue to Section XIV.
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Rev. 9 Attachment 5 Page 7 of 8 10 CFR 50.54(q) Review Form Section IX: Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change Copy each emergency planning standard, function and program element affected by the proposed change that was identified as applicable in Section VIII. Continue to Section X.
Section X: Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q). Address each Planning Standard identified in Section IX. Continue to Section XI.
Section XI: Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions Address each function identified in Section IX. Continue to Section XII.
Justification:
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Rev. 9 Attachment 5 Page 8 of 8 10 CFR 50.54(q) Review Form Section XII: Evaluation Conclusion Answer the following questions about the proposed change:
- 1. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? Yes No
- 2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in Yes effectiveness)? No
- 3. Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes No Section XII: Conclusion Questions 1, 2 and 3 are answered YES, complete step below to create a General CAS assignment, and then continue on to Section XIV and implement change(s).
General CAS assignment created- Licensing submit changes in accordance with 10 CFR 50.4(b)(5)(ii) within 30 days of change implementation Questions 1 or 2 or 3 are answered NO, complete Sections XIII and Section XIV.
Section XIII: Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change be submitted to the NRC for prior approval?
Yes If No, reject the proposed change, or modify the proposed change and perform a new evaluation. No Continue to Section XIV for this evaluation.
If YES, then initiate a License Amendment Request in accordance 10 CFR 50.90, AD-LS-ALL-0002, Regulatory Correspondence, and AD-LS-ALL-0015, License Amendment Request and Changes to SLC, TRM, and TS Bases, and include the tracking number:___________________________________. Complete Section XIV.
Section XIV: Signatures:
EP CFAM Final Approval is required for changes affecting Program Element 4a of Section VIII. If CFAM approval is NOT required, then mark the EP CFAM signature block as not applicable (N/A) to indicate that signature is not required.Section XIV as applicable.
Preparer Name (Print): Preparer Signature: Date:
Bruce Tunnell See NAS See NAS Reviewer Name (Print): Reviewer Signature: Date:
Nelson Tart See NAS See NAS Approver Name (Print): Approver Signature: Date:
Phil Mason See NAS See NAS Approver (EP CFAM, as required) Name (Print): Approver Signature: Date:
N/A N/A N/A QA RECORD