RA-24-0006, 10 CFR 50.54(q) Evaluation
| ML24004A243 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/04/2024 |
| From: | Sharlow J Duke Energy Progress |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RA-24-0006, EP-HNP-OSSA, Rev 1 | |
| Download: ML24004A243 (1) | |
Text
(_~ DUKE
~ ENERGY January 4-, 2024 Serial: RA-24-0006 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63
Subject:
10 CFR 50.54(q) Evaluation Ladies and Gentlemen:
Jamey Sharlow Acting Nuclear Support Services Manager Harris Nuclear Plant 5413 Shearon Harris Road New Hill, NC 27562-9300 10 CFR 50.4(b)(5)(ii) 10 CFR 50.54(q)(5)
In accordance with 10 CFR 50.4(b)(5)(ii) and 10 CFR 50.54(q)(5), Duke Energy Progress, LLC, is submitting the 10 CFR 50.54(q) Review Form for a revision to the Shearon Harris Nuclear Power Plant, Unit 1 (HNP), On-Shift Staffing Analysis. EP-HNP-OSSA, "Harris On-Shift Staffing Analysis," Revision 1, was issued on December 14, 2023.
This submittal contains no regulatory commitments. Please refer any questions regarding this submittal to Sarah McDaniel at (984) 229-2002.
Enclosure:
10 CFR 50.54(q) Review Form for EP-HNP-OSSA, Revision 1 cc:
P. Boguszewski, NRC Senior Resident Inspector, HNP M. Mahoney, NRC Project Manager, HNP NRC Regional Administrator, Region II
Document Control Desk Serial: RA-24-0006 Enclosure ENCLOSURE SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400/RENEWED LICENSE NUMBER NPF-63 10 CFR 50.54(Q) REVIEW FORM FOR EP-HNP-OSSA, REVISION 1 (21 PAGES PLUS COVER)
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 1 of 21 10 CFR 50.54(q) Review Form Section I: 10 CFR 50.54(q) Review Number: (EREG #):
02478380 Applicable Sites and Applicability Determination # (5AD)
BNP CNS HNP 02497822 MNS ONS RNP Document #, EC #,
or N/A Revision # or N/A Document or Activity Title EP-HNP-OSSA 001 Harris On-Shift Staffing Analysis 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.
EP-HNP-OSSA, Harris On-Shift Staffing Analysis, provides the on shift staffing analysis regulatory basis and guidance, the staffing compliment used in the analysis, the events and tasks used during the analysis, applicable time motion studies and the analysis results for Harris Nuclear Plant. Revision 1 of EP-HNP-OSSA incorporates various updates to on-shift personnel requirements and tasks performed by the Chemistry Technician, Mechanic, and I&C Technician.
A description of each proposed change made in Revision 1 is shown in the table below.
Change #
Section or Step #
Changed From Changed To 1
Revision Summary Old revision summary Updated revision summary identifying the changes made in Revision 1 2
Throughout EP-HNP-OSSA: Old revision number (000)
EP-HNP-OSSA: New revision number (001) 3 Section 3.4 Chemistry Technician, Mechanic, and I&C Technician were included in the bulleted list of on-shift personnel and their respective locations Removed Chemistry Technician, Mechanic, and I&C Technician from the bulleted list of on-shift personnel and their respective locations
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 2 of 21 10 CFR 50.54(q) Review Form Change #
Section or Step #
Changed From Changed To 4, Table 1 - On-Shift Positions, Analysis Event # 1 - Main Steam Line Break (MSLB)
Line 15 Chemistry Technician (CT), line 16 Mechanic (MT), and line 17 I&C Technician (ICT) were included in Table 1 with no tasks assigned Removed line 15 Chemistry Technician (CT), line 16 Mechanic (MT), and line 17 I&C Technician (ICT) from Table 1 with no tasks assigned 5, Table 2 - Plant Operations
& Safe Shutdown Analysis Event # 1 -
Main Steam Line Break (MSLB)
Table 2 included a section for Other (non-Operations) Personnel that included the Mechanic (MT) under line 16 and I&C Technician (ICT) under line 17 with no tasks assigned Removed Other (non-Operations) Personnel section of Table 2 that removed the Mechanic (MT) and I&C Technician (ICT) with no tasks assigned 6,
Analysis Event #3-Reactor Coolant Pump Rotor Seizure Tasks and Timing Line 12 contained an action to Dispatch CT to perform samples per step 1 Line 13 action to Sample per AOP-32 step 1 was assigned to the CT.
Line 45 contained an action for the ICT to Check pressure switches for MFP reset/Drain Pumps Line 48 contained an action for the MT to Station at Turbine coastdown/ensure Line 12 contains an action to Dispatch CT or RPT2 to perform samples per step 1 Line 13 action to Sample per AOP-32 step 1 is assigned to the RPT2.
Previous action for the ICT to Check pressure switches for MFP reset/Drain Pumps is removed.
Previous action for the MT to Station at Turbine coastdown/ensure proper turning gear ops is removed.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 3 of 21 10 CFR 50.54(q) Review Form Change #
Section or Step #
Changed From Changed To proper turning gear ops 7, Table 1-On-Shift Positions, Analysis Event #3-Reactor Coolant Pump Rotor Seizure, Table 1 contained lines for the Chemistry Technician (CT) under line 15 with 4/8 role in Table # /
Line # column, Mechanic (MT) under line 16 with 2/16 role in Table # / Line # column, and I&C Technician (ICT) under line 17 with 2/17 role in Table # /
Line # column, Table 1, line 14 for RP Qualified Individual (RPT2) had 4/1 role in Table # /
Line # column, Table 1 does not include lines for the Chemistry Technician (CT), Mechanic (MT),
, Table 1, line 14 for RP Qualified Individual (RPT2) has 4/1 and 4/8 roles in Table # / Line # column 8, Table 2 - Plant Operations
& Safe Shutdown Analysis Event # 3 -
Reactor Coolant Pump Rotor Seizure Table 2 included a section for Other (non-Operations) Personnel that included the Mechanic (MT) that performed the Turbine Coastdown Monitoring task under line 16 and I&C Technician (ICT) that performed the Check Pressure Switches task under line 17 Removed Other (non-Operations) Personnel section of Table 2 that removed the Mechanic (MT) that performed the Turbine Coastdown Monitoring task and I&C Technician (ICT) that performed the Check Pressure Switches task 9, Table 4 - Radiation Task 8 to Sample RCS was performed by the Task 8 to Sample RCS was revised to be
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 4 of 21 10 CFR 50.54(q) Review Form Change #
Section or Step #
Changed From Changed To Protection and Chemistry Analysis Event # 3 - Reactor Coolant Pump Rotor Seizure CT performed by the RPT2 10,
Analysis Event #6-Steam Generator Tube Rupture (SGTR) Tasks and Timing Line 38 contained an action for the RPT1 to Notify CT for sampling CVPET Line 42 contained an action for the CT to Sample CVPET The action for the RPT1 to Notify CT for sampling CVPET is removed The action for the CT to Sample CVPET is removed 11, Table 1 - On-Shift Positions, Analysis Event #6-Steam Generator Tube Rupture (SGTR), Table 1 contained lines for the Chemistry Technician (CT) under line 15 with a role in Table # /Line #
column as 4/8, Mechanic (MT) under line 16 with no tasks, and I&C Technician (ICT) under line 17 with no tasks, Table 1 does not include lines for the Chemistry Technician (CT), Mechanic (MT),
and I&C Technician (ICT). The CT task was removed with this change.
12, Table 2 - Plant Operations
& Safe Shutdown Analysis Event # 6 -
Steam Generator Tube Rupture (SGTR)
Table 2 included a section for Other (non-Operations) Personnel that included the Mechanic (MT) under line 16 and I&C Technician (ICT) under line 17 with no tasks assigned Removed Other (non-Operations) Personnel section of Table 2 that removed the Mechanic (MT) and I&C Technician (ICT) with no tasks assigned
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 5 of 21 10 CFR 50.54(q) Review Form Change #
Section or Step #
Changed From Changed To 13, Table 4 - Radiation Protection and Chemistry Analysis Event # 6 - Steam Generator Tube Rupture (SGTR)
Task 8 to Sample CVPET was performed by the CT Task 8 to Sample CVPET was removed 14, Table 1 - On-Shift Positions, Analysis Event #7-Large Break Loss of Coolant Accident (LB-LOCA)
, Table 1 contained lines for the Chemistry Technician (CT) under line 15 with no tasks, Mechanic (MT) under line 16 with no tasks, and I&C Technician (ICT) under line 17 with no tasks, Table 1 does not include lines for the Chemistry Technician (CT), Mechanic (MT),
and I&C Technician (ICT). No tasks were impacted based upon this change.
15, Table 2 - Plant Operations
& Safe Shutdown Analysis Event # 7-Large Break Loss of Coolant Accident (LB-LOCA)
Table 2 included a section for Other (non-Operations) Personnel that included the Mechanic (MT) under line 16 and I&C Technician (ICT) under line 17 with no tasks assigned Removed Other (non-Operations) Personnel section of Table 2 that removed the Mechanic (MT) and I&C Technician (ICT) with no tasks assigned 16, Table 1 - On-Shift Positions, Analysis Event #9-Design Basis Threat (DBT)
, Table 1 contained lines for the Chemistry Technician (CT) under line 15 with no tasks, Mechanic (MT) under line 16 with no tasks, and I&C Technician (ICT) under, Table 1 does not include lines for the Chemistry Technician (CT), Mechanic (MT),
and I&C Technician (ICT). No tasks were impacted based upon this change.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 6 of 21 10 CFR 50.54(q) Review Form Change #
Section or Step #
Changed From Changed To line 17 with no tasks 17, Table 2 - Plant Operations
& Safe Shutdown Analysis Event # 9-Design Basis Threat (DBT)
Table 2 included a section for Other (non-Operations) Personnel that included the Mechanic (MT) under line 16 and I&C Technician (ICT) under line 17 with no tasks assigned Removed Other (non-Operations) Personnel section of Table 2 that removed the Mechanic (MT) and I&C Technician (ICT) with no tasks assigned 18,
Analysis Event #10-Probable Aircraft Threat Tasks and Timing Line 31 contained an action for CT to Perform surveillances Removed the action for CT to Perform surveillances 19, Table 1 - On-Shift Positions, Analysis Event #10- Probable Aircraft Threat
, Table 1 contained lines for the Chemistry Technician (CT) under line 15 with a role in Table # /Line #
column as 4/8, Mechanic (MT) under line 16 with no tasks, and I&C Technician (ICT) under line 17 with no tasks, Table 1 does not include lines for the Chemistry Technician (CT), Mechanic (MT),
and I&C Technician (ICT). The CT task was removed with this change.
20, Table 2 - Plant Operations
& Safe Shutdown Analysis Event #10-Probable Aircraft Threat Table 2 included a section for Other (non-Operations) Personnel that included the Mechanic (MT) under line 16 and I&C Technician (ICT) under Removed Other (non-Operations) Personnel section of Table 2 that removed the Mechanic (MT) and I&C Technician (ICT) with no tasks
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 7 of 21 10 CFR 50.54(q) Review Form Change #
Section or Step #
Changed From Changed To line 17 with no tasks assigned assigned 21, Table 4 - Radiation Protection and Chemistry Analysis Event # 10 -
Probable Aircraft Threat Task 8 to Perform Surveillances was performed by the CT Task 8 to Perform Surveillances was removed 22, Table 1 - On-Shift Positions, Analysis Event #11-Control Room Evacuation Due to Fire
, Table 1 contained lines for the Chemistry Technician (CT) under line 15 with no tasks, Mechanic (MT) under line 16 with no tasks, and I&C Technician (ICT) under line 17 with no tasks, Table 1 does not include lines for the Chemistry Technician (CT), Mechanic (MT),
and I&C Technician (ICT). No tasks were impacted based upon this change.
23, Table 2 - Plant Operations
& Safe Shutdown Analysis Event #11-Control Room Evacuation Due to Fire Table 2 included a section for Other (non-Operations) Personnel that included the Mechanic (MT) under line 16 and I&C Technician (ICT) under line 17 with no tasks assigned Removed Other (non-Operations) Personnel section of Table 2 that removed the Mechanic (MT) and I&C Technician (ICT) with no tasks assigned 24, -
Table 4-Radiation Protection and Chemistry Analysis for Event #1 -
MSLB, Event# 3-Title of Table 4 was Radiation Protection and Chemistry Analysis Title of Table 4 is Radiation Protection
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 8 of 21 10 CFR 50.54(q) Review Form Change #
Section or Step #
Changed From Changed To RCP Rotor Seizure, Event #6-SGTR, Event#7 - LB-LOCA, Event #9 -
DBT, Event #10 -
PAT, and Event #11
- Control Room Evacuation Due to Fire.
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-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, Revision 0 Current Emergency Plans
- EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Rev 5
- EP-HNP-EPLAN-ANNEX, Duke Energy Harris Emergency Plan Annex, Rev 1 The differences in the approved and the current revision of the Emergency Plan have been reviewed, and they have been determined to meet the regulatory requirements required during the course of revisions.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 9 of 21 10 CFR 50.54(q) Review Form 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 Emergency Plan?
Yes No
- 2. Do any elements of the proposed activity change the process or capability for alerting or notifying the public as described in the FEMA-approved Alert and Notification System Design Report?
Yes 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 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 10 of 21 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?
Yes 10 CFR 50.54(q) Evaluation is not required.
Identify bounding source document below and continue to Section XIV.
No Continue to Section VII.
Partially 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.
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:
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 11 of 21 10 CFR 50.54(q) Review Form Section VII: Editorial Changes Yes All Activities/Changes identified in Section II are editorial/typographical changes such as formatting, paragraph numbering, spelling, or punctuation that does not change intent.
No None of the Activities/Changes listed in Section II are editorial/typographical changes. Continue to 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:
Change 1 updated the revision summary for the EP-HNP-OSSA, Revision 1 scope of changes.
Change 2 updated the revision number of the EP-HNP-OSSA from Revision 0 to Revision 1.
Changes 1 and 2 are defined as editorial in accordance with AD-EP-ALL-0602.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 12 of 21 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.
1b The response organization has the staff to respond and to augment staff on a continuing basis (24-7 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 4a A standard scheme of emergency classification and action levels is in use.
(Requires V/V (Attachment 3) and final approval of Screen and Evaluation by EP CFAM) 5 10 CFR 50.47(b)(5) Notification Methods and Procedures RS 5a Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes (60 minutes for CR3) after declaration of an emergency and providing follow-up notification.
5b Administrative and physical means have been established for alerting and providing prompt instructions to public within the plume exposure pathway.
5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 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 6a Systems are established for prompt communication among principal emergency response organizations.
6b Systems are established for prompt communication to emergency response personnel.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 13 of 21 10 CFR 50.54(q) Review Form 7
10 CFR 50.47(b)(7) Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within the 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.
10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities.
10c A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.
10d KI is available for implementation as a protective action recommendation in those jurisdictions that 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 14a A drill and exercise program (including radiological, medical, health physics and other program areas) is established.
14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, 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.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 14 of 21 10 CFR 50.54(q) Review Form 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.
Justification for changes that are more than editorial, however, not impacted by any of the identified criteria in Section VIII:
Changes 4, 5, 12, 14, 15, 16, 17, 20, 22, and 23 updated various tables to remove the Chemistry Technician (CT), Mechanic (MT), and I&C Technician (ICT) positions that were shown with no tasks assigned. These changes have no impact to the on-shift staffing analysis since the tasks for each event response were not impacted.
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.
List affected Emergency Planning Standards, Functions, and Program Elements:
Planning Standard The regulation at 10 CFR 50.47(b)(2) states the following:
On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.
Function The applicable emergency planning function identified for this planning standard:
The process ensures that onshift emergency response responsibilities are staffed and assigned.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 15 of 21 10 CFR 50.54(q) Review Form Applicable sections of Appendix E to 10 CFR Part 50 IV.A of Appendix E to 10 CFR Part 50 The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency.
IV.A.9 of Appendix E to 10 CFR Part 50 By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.
Informing Criteria from NUREG-0654 The applicable program elements describe in NUREG-0654,Section II.B state:
B.1.a - The site-specific emergency response organization (ERO) is developed. Note that while other site programs, such as operations, fire response, rescue and first aid, and security, may be controlled via other licensing documents, it is only when these personnel are assigned EP functions that they become part of this regulatory standard. Consideration is given to ensure that EP functions are not assigned to individuals who may have difficulties performing their EP function(s) simultaneously with their other assigned (non-EP) duties. Appendix E to 10 CFR Part 50 requires licensees to perform an on-shift staffing analysis to ensure on-shift staff can support the EP functions assigned, as well as other assigned duties.
B.3 - A table is developed depicting the site-specific on-shift staffing plan, as well as the ERO staffing augmentation plan. Table B-1, Emergency Response Organization (ERO) Staffing and Augmentation Plan, provides a model for licensees to consider.
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.
Justification:
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 16 of 21 10 CFR 50.54(q) Review Form Change 6 includes updates to the Reactor Coolant Pump Rotor Seizure event tasks and timing.
The first update adds the RP technician 2 as a position available to perform a sample per AOP-032, High RCS Activity. Plant procedural guidance allows for either a Chemistry technician or RP technician to perform sampling in accordance with AOP-032 and CRC-821, Post Accident Sampling. Therefore, this change aligns personnel responsibilities to responsibilities governed by AOP-032 and CRC-821. The second update removes an action for the I&C technician (ICT) to Check pressure switches for MFP reset/Drain Pumps. The action for the ICT to check pressure switches for MFP reset/Drain Pumps was determined to be unnecessary for the Reactor Coolant Pump Rotor Seizure event immediate response. GP-006, Normal Plant Shutdown From Power Operation to Hot Standby (Mode 1 to Mode 3), contains instructions for the ICT to check pressure switches for MFP reset/Drain Pumps, however this action may be completed after personnel have been called out to support a response to this event. The third change removes an action for the mechanic (MT) to Station at Turbine coastdown/ensure proper turning gear ops. The action for the MT to station at Turbine coastdown/ensure proper turning gear ops was determined to be unnecessary for the Reactor Coolant Pump Rotor Seizure event immediate response. This action may be completed after personnel have been called out to support a response to this event.
Change 7 includes updates to the on-shift positions in Table 1 for the Reactor Coolant Pump Rotor Seizure event, based upon Change 6 described above.
Change 8 includes updates to the Plant Operations & Safe Shutdown Analysis in Table 2 for the Reactor Coolant Pump Rotor Seizure event, based upon Change 6 described above.
Change 9 includes updates to the Radiation Protection and Chemistry Analysis in Table 4 for the Reactor Coolant Pump Rotor Seizure event, based upon Change 6 described above.
Change 10 includes updates to the Steam Generator Tube Rupture (SGTR) event tasks and timing. The first update removes an action for the RP technician 1 to Notify CT for sampling CVPET. The action for the RP technician 1 to notify CT for sampling CVPET was determined to be unnecessary for the SGTR event immediate response. The second update removes an action for the CT to Sample CVPET. The action for CT to sample the CVPET was determined to be unnecessary for the SGTR event immediate response. The CVPET sampling activity may be completed if necessary after personnel have been called out to support a response to this event.
Change 11 includes updates to the on-shift positions in Table 1 for the SGTR event, based upon Change 10 described above.
Change 13 includes updates to the Radiation Protection and Chemistry Analysis in Table 4 for the SGTR event, based upon Change 10 described above.
Change 18 includes an update to the Probable Aircraft Threat event tasks and timing. The action for the CT to Perform surveillances was removed. The action for the CT to perform
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 17 of 21 10 CFR 50.54(q) Review Form surveillances was determined to be unnecessary for the Probable Aircraft Threat event immediate response. AOP-038, Rapid Downpower, contains guidance for an operator to direct Chemistry to initiate surveillances required by RST-204, Reactor Coolant System Chemistry and Radiochemistry Surveillance, and RST-211, Gaseous Effluent Radiochemistry Surveillance.
However, these surveillances may be completed after personnel have been called out to support a response to this event. The shortest timeframe for Chemistry completing these surveillances is six hours following the event (that would involve a thermal power change exceeding 15 percent).
Change 19 includes updates to the on-shift positions in Table 1 for the Probable Aircraft Threat event, based upon Change 18 described above.
Change 21 includes updates to the Radiation Protection and Chemistry Analysis in Table 4 for the Probable Aircraft Threat event, based upon Change 18 described above.
Change 3 removed Chemistry Technician, Mechanic, and I&C Technician from the bulleted list of on-shift personnel and their respective locations in Section 3.4. Change 24 updated the title of Table 4 to remove Chemistry for various analysis events. These updates are based upon other changes to event tasks and responsibilities described under changes 6, 10, and 18 described above. The Chemistry Technician, Mechanic, and I&C Technician do not have tasks in the proposed Revision 1 of the EP-HNP-OSSA and are not required on-shift per the emergency plan, technical specifications, or the UFSAR.
The changes listed above do not change ERO staffing as required by the EP-ALL-EPLAN, Duke Energy Common Emergency Plan and the changes do not reduce on-shift staffing for ERO functions. On shift staffing responsibilities for emergency response remain unambiguously defined, and adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, therefore the changes continue to meet the requirements as identified in 10 CFR 50.47 (b)(2).
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:
Change 6 includes updates to the Reactor Coolant Pump Rotor Seizure event tasks and timing.
The first update adds the RP technician 2 as a position available to perform a sample per AOP-032. Plant procedural guidance allows for either a Chemistry technician or RP technician to perform sampling in accordance with AOP-032 and CRC-821. Therefore, this change aligns personnel responsibilities to responsibilities governed by AOP-032 and CRC-821. The second update removes an action for the I&C technician (ICT) to Check pressure switches for MFP reset/Drain Pumps. The action for the ICT to check pressure switches for MFP reset/Drain Pumps was determined to be unnecessary for the Reactor Coolant Pump Rotor Seizure event
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 18 of 21 10 CFR 50.54(q) Review Form immediate response. GP-006 contains instructions for the ICT to check pressure switches for MFP reset/Drain Pumps, however this action may be completed after personnel have been called out to support a response to this event. The third change removes an action for the mechanic (MT) to Station at Turbine coastdown/ensure proper turning gear ops. The action for the MT to station at Turbine coastdown/ensure proper turning gear ops was determined to be unnecessary for the Reactor Coolant Pump Rotor Seizure event immediate response. This action may be completed after personnel have been called out to support a response to this event.
Change 7 includes updates to the on-shift positions in Table 1 for the Reactor Coolant Pump Rotor Seizure event, based upon Change 6 described above.
Change 8 includes updates to the Plant Operations & Safe Shutdown Analysis in Table 2 for the Reactor Coolant Pump Rotor Seizure event, based upon Change 6 described above.
Change 9 includes updates to the Radiation Protection and Chemistry Analysis in Table 4 for the Reactor Coolant Pump Rotor Seizure event, based upon Change 6 described above.
Change 10 includes updates to the Steam Generator Tube Rupture (SGTR) event tasks and timing. The first update removes an action for the RP technician 1 to Notify CT for sampling CVPET. The action for the RP technician 1 to notify CT for sampling CVPET was determined to be unnecessary for the SGTR event immediate response. The second update removes an action for the CT to Sample CVPET. The action for CT to sample the CVPET was determined to be unnecessary for the SGTR event immediate response. The CVPET sampling activity may be completed if necessary after personnel have been called out to support a response to this event.
Change 11 includes updates to the on-shift positions in Table 1 for the SGTR event, based upon Change 10 described above.
Change 13 includes updates to the Radiation Protection and Chemistry Analysis in Table 4 for the SGTR event, based upon Change 10 described above.
Change 18 includes an update to the Probable Aircraft Threat event tasks and timing. The action for the CT to Perform surveillances was removed. The action for the CT to perform surveillances was determined to be unnecessary for the Probable Aircraft Threat event immediate response. AOP-038 contains guidance for an operator to direct Chemistry to initiate surveillances required by RST-204 and RST-211. However, these surveillances may be completed after personnel have been called out to support a response to this event. The shortest timeframe for Chemistry completing these surveillances is six hours following the event (that would involve a thermal power change exceeding 15 percent).
Change 19 includes updates to the on-shift positions in Table 1 for the Probable Aircraft Threat event, based upon Change 18 described above.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 19 of 21 10 CFR 50.54(q) Review Form Change 21 includes updates to the Radiation Protection and Chemistry Analysis in Table 4 for the Probable Aircraft Threat event, based upon Change 18 described above.
Change 3 removed Chemistry Technician, Mechanic, and I&C Technician from the bulleted list of on-shift personnel and their respective locations in Section 3.4. Change 24 updated the title of Table 4 to remove Chemistry for various analysis events. These updates are based upon other changes to event tasks and responsibilities described under changes 6, 10, and 18 described above. The Chemistry Technician, Mechanic, and I&C Technician do not have tasks in the proposed Revision 1 of the EP-HNP-OSSA and are not required on-shift per the emergency plan, technical specifications, or the UFSAR.
These changes do not cause any of the major functional areas or major tasks identified in the emergency plan to be unassigned. The changes do not eliminate key positions identified in the emergency plan nor reassign the responsibilities of the eliminated positions to other key positions. The changes do not result in an ERO member being assigned duties that could be expected to be performed concurrently rather than sequentially. The changes do not reduce the effectiveness of the emergency plan as the on-shift ERO staffing complement is unaffected by these changes.
The proposed changes to HNPs On Shift Staffing Analysis continue to show the capability of implementing the site's emergency plan to address a spectrum initiating events and consequences. The key emergency response functions and tasks as described in NUREG-0654 include:
- Shutdown the reactor and maintain safe shutdown
- Mitigate event consequences
- Determine Protective Action Recommendations (PARs) for site personnel and the public
- Perform firefighting
- Provide medical assistance if needed The changes listed above do not change ERO staffing as set forth in EP-ALL-EPLAN, Duke Energy Common Emergency Plan as on-shift emergency response responsibilities are staffed and assigned. The changes do not reduce the availability of personnel relied upon in the plan.
Therefore, the changes do not reduce the effectiveness of the Duke Energy Common Emergency Plan. These changes continue 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.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 20 of 21 10 CFR 50.54(q) Review Form These change(s) continue (continues) to meet NRC requirements, as described in 10 CFR 50.47(b) and 10 CFR 50, Appendix E as well as the requirements of the Duke Energy Sites Emergency Plans 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 effectiveness)?
Yes 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?
If No, reject the proposed change, or modify the proposed change and perform a new evaluation. Continue to Section XIV for this evaluation.
Yes No 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.
EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)
AD-EP-ALL-0602 Rev. 9 Page 21 of 21 10 CFR 50.54(q) Review Form 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): Sarah McDaniel Preparer Signature: See NAS Date: See NAS Reviewer Name (Print): Jamey Sharlow Reviewer Signature: See NAS Date: See NAS Approver Name (Print): William Gunter Approver Signature: See NAS Date: See NAS Approver (EP CFAM, as required) Name (Print): N/A Approver Signature: N/A Date: N/A QA RECORD