ML23164A029

Procedure Review Form - Chemistry Coordinator Checklist

ML23164A029
Person / Time
Site:	Callaway
Issue date:	06/13/2023
From:	Fortman J Ameren Missouri
To:	Office of Nuclear Reactor Regulation
Shared Package
ML23164A027	List: ML23164A028 ML23164A029
References
EIP-ZZ-00240, Add. G, Rev. 15
Download: ML23164A029 (1)

Text

PROCEDURE REVIEW FORM (PRF) 1.0 Initiation Initiator: Joseph Fortman Date: 05/1812023 Procedure Dept:

EP Document #: EIP-ZZ-00240 Addendum G New Rev. #

015

Title:

ChemistryCoordinator Checklist Level of Use:

EjContinuous Reference Infonnation UMultiple LN/A 2A)

Reason for Change/Description of Change (List commitments, CRs, eB Change Recjuests, OERs, Plant Mods etc. and record numbers here.)

CR202301425 Page 6 & 7, Operations, Step 6, 8, and 1 1 were reordered to better match the potential event progression 3.0.

Documcnt Disposition LiTemp Change DNew I)ocument LiMajor Revision Minor Revision flCancellation LIAdministrative Correction DepL Head or [)csignatcd Approver required for Adrninisttative Corrections (Signature/PIN/Date) no other signatures regttired 4.0 Interim Approval (Thrnp. Change Only)

Temp. Change #:

Expiration Date:

CbgrnzantSUpc.L visot tSignatui c/P1N/Dat.)

SRO (Sign iturc/PIN/D itc)

5.0 Comments

Continued:

6.0 Reviews and Signatures (NOT Revieies Required Dept PIN Preparer EP j 14588 Technical Review EP I 4588 1 ehrncal Review CfEb\\,

Addl Review f 3O AddI Review DAdditional Reviews (See Attached CAOI39forrns).

Number ofadditional CAOI39s:

Type Coordinator - PIN Sijitature Date CA0139 Attached DVahdation Yes LI No (Dept. Head or Designated Approver) Is a Change Management Plan required?

EYes No (IF YES, attach CA277% or CA2774)

Is a Cross-Disciplinary review required? EYes LINo 7O Approval (Either approvttt must be qicati/led as PA T/APVR or PA T/G4PR in QttnhWaster)

Senior Director Nuclear Operations Approval (per APA-ZZ-OO1O1)

ORC is required in accordance with APA-ZZOOO91 Department iiel Final Review and Approval

()RU Meeting:

J, Q

_p IL3 rJ2Y/ 3 (f1%t&vt I0 I I

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Dept. Head or Designated Approver Senior Director Nuclear Operations (Signature/PIN/Date)

\\

(Signature/PIN/Date)

Date CA0139 Attached 18/2023 N/A 05/1 8/2023 LI Yes No c/:%il;&s Yes No 3/:3/3 DYes jNo LIYes LINo A1900001, 2, 5, 35

- A210.0062, 65, 69; M190.000I Page 1 of 2 APA-ZZ-OO 101 Continued: [1 50.59 Review CA25 1 0 L1CA25 1 1 LICA251 2 I,tii N()1e PUge 2 provides iflsttLfCliOflV to COtflf)/tO this/birn ant may he discarded CA0033 Rev. 002

APPLICABILITY DETERMINATION Address the questions below for all aspects of the activity. If the answer s YES for any portion of the activity, apply (he identified procedures to tha( portion of the activity. Note that it is not unilsual to have more than one process apply to a given activity. Refer to Section 4 of the 10 CFR 50.59 Resource Manual (RM) and the instructions on pages 5-6 for additional guidance.

I.

Activity/Document Number: EIP-ZZ-OO24OAddendum G Revision Number:

015

Title:

ChemistryCoordüiatorChecklist BriefDescription of activity (what is being changed and why):

CR202301425 Page 6 & 7, Operations, Step 6, 8, and 1 1 were reordered to better match the potential event progression.

If YES, no further 50.59 (or 7248) review beyond this Applicability Determination (AD) is required, but

Response

complete the remainder of this form.

Identify the applicable 50.59/72.48 Evaluation Log

, License Amendment No., or applicable document number.

IfYES, process per APA-ZZ-00 108 and GDP-ZZ-00600 and related facility or procedure change programs.

IfYES, process per APA-ZZ-00 108 YES and SDP-ZZ00030 for Security Plan and related facility or procedure change programs.

NO LIYES

Response

II, Does the proposed activity fall within the scope of an activity that has been previously approved by the NRC or for which a 50.59/72.48 Screen or evaluation has already been performed?

(See Section 4.2 of the RM.)

III.

Does the proposed activity involve a change to the:

I Technical Specifications or the Renewed Operating License?

(5cc 10 CFR 50.90.)

2.

Quality Assurance Plan? (See 10 CFR 50.54(a).)

3.

Security Plan which also includes the Cyber Security Plan? 1 (See 10 CFR 50.54(p).)

4.

Radiological Emergency Response Plan (RERP) or Emergency Action Levels (EALS)? (See 10 CFR 50.54(q).)

Document #

See Section 4.2.1 ofthe RM.

NO fl YES IfYES, process per APA-ZZ-00 108 and FDP-ZZ-00 103.

JN() 1YES Note: Ifyour proposed change alters a RERP IfYES, process per APA-ZZ-00 108 implementing procedure [any EIP-ZZ-XXXX], equipment LI NO YES and KDP-ZZ-00400 for RERP and identified as important to emergency response [refer to related facility or procedure change KDP-ZZ-000 13], or could alter response time, staffing, or other items covered in the 1 6 Planning Standards or in Appendix E to Part 50.47(b) [refer to KDPZZ-00400],

answer this question YES.

APA-ZZ-OO 143 A 170.0010 Page 1 CA2510 Rev. 005

APPLICABILITY DETERMINATION (Continued) 7.

Fire Protection Program? (See Operating License Condition 2C(5).)

8.

Storage Cask Certificate of Compliance (CoC), including appendices?

(See 10 CfR 72.244.)

IfYES, process APA-ZZ-00356 for ASME code compliance and related facility or procedure change programs.

IfYES, process per EDP-ZZ-O 1003 for ASME code compliance and j related facility or procedure change programs.

See FP Screening questions in EDP ZZ-04044. If any of the screening NO i:i YES questions are answered YES, a Fire Protection review is needed in accordance with EDP-ZZ-04044.

IF YES, then contact Regulatory NO LI YES Affairs/Licensing to determine next steps.

If YES, indicate the applicable LI YES program in Brief Description Section.

Iv.

Does the proposed activity involve:

1. Maintenance which restores SSCs to their original (as designed) condition?

(See 10 CFR 50.65(a)(4).)

Note: Ifthe maintenance is on ISFSI or cask-related items, the Maintenance Rule does NOT apply, and the activity is subject to a 10 CFR 72.48 Screen on a CA3 145.

Response

NO LIYES See Section 4.2.2 ofthc RlvI IfYES, process change per APA-ZZ-0010l for procedure changes or APA-ZZ-00320/330/340 for Maintenance activities.

2.

A temporary alteration (to procedures or the facility) supporting maintenance (TASM) that will be in effect during at-power operations for 90 days or less?

NO LIYES IfYES, process per APA-ZZ-00101 for procedure changes or APA-ZZ-00605 for facility changes or Procedurally Controlled Temporary Modifications or MDP-ZZ-fSOO1 for Freeze Seals.

Evaluate risk using APA-ZZ-003 15, Appendix A.

APA-ZZ-OO 143 A170.OO1O CA25 10 Rev. 005 NO YES 5.

1ST Program Plan? (See 10 CFR 50.55a(O.)

6.

151 Program Plan? (See 10 CFR 50.55a(g).)

NO LYES 9.

Does the proposed activity impact other programs (e.g.,

the ODCM) that are controlled by regulations, the Operating License (including Orders and License Conditions) or the Technical Specifications? (See Section NO 4.2.1 of the RM.)

Page 2

1.

FSAR NO EJYES If the above response is NO, check N/A in the Response column at right.

If the above response is YES, does the proposed activity involve an FSAR change that may be excluded from the requirement to perform a 50.59 ScrecnlEvaluation by NEI 9607 or NEI 9803? (Provide a YES or NO response to this question in the Response column at right.)

Note: In lieu ofthe exclusion criteria ofRM Section 4.23, a YES response may also be provided if the fSAR change requires no further 5059 review based on a YES response to the question in Section II of this Applicability Determination form.)

2.

Technical Specification Bases?

NO LI YES If the above response is NO, check N/A in the Response column at right.

If the above response is YES, does the proposed activity involve a TS Bases change comparable to that which may be excluded from the requirement to perform a 50.59 Screen/Evaluation by NET 9607 or NEI 9803 (as described for an FSAR change)? (Provide a YES or NO response to this question in the Response column at right.)

Note: In lieu ofthe exclusion criteria ofRM Section 4.2.3, a YES response may also be provided if the 1$ Bases change requires no further 50.59 review based on a YES response to the question in Section TI ofthis Applicability Determination form.)

VI.

Does the iI01)OSed activity involve a chante ttL 1

Managerial or administrative procedures, controls, or activities (including software used only for the implementation of administrative procedures, controls, or activities) governing the conduct of facility operations (subject to the control of TOCFR5O. Appendix B)?

2.

Regulatory conmiitment not covered by another regulation based change pwees? (See NEI 99-04.)

APA-ZZ-OO 143 A170.OOlO

Response

See Section 4 2 3 ofthe R1VI Process the FSAR change per APA-ZZ-00108 arid FDP-ZZ-00 103

. for revising License Documents.

Note:

A NO response in the Response r NO El YES column at left means that the FSARITS Bases change is one that N/A requires further 50.59 review (i.e., is not excludable from further review).

A YES response means that the fSAR does NOT require further 50.59 review.

Process the TS Bases change per APA-ZZ-00108 and FDP-ZZ-00 103 for revising License Documents.

Note:

A NO response in the Response column at left means that the TS E NO Li YES Bases change is one that requires further 50.59 review (i.e., is not N/A excludable from further review).

A YES response means that the TS Bases Change does NOT require further 50.59 review.

Response

See Section 4.2.4 /4.2.6 ofthe RM NO El YES IfYES, process per APA-ZZ-00 101 or APA-ZZ-00 109.

IfYES, process per APA-ZZ-00540.

IfYES, perform a 72.48 Screen per APA-ZZ-00l43 unless the change is completely covered by the response to Section II.

Note:

Editorial or administrative changes are excluded from the requirement to pert()tm a 72.48 Review.

APPLICABILITY DETERMINATION (Continued)

V.

Does the PI0I)SeCl aciivi*ty involve a change to the:

VII Does the proposed activity potentially affect the design,

. operation, or maintenance ofthe ISfSI facility as described in the dry cask storage FSAR or the 72.212 Report? (See fDP zz-00105 and Attachment 1 ofAPA-ZZ-00143.)

1NO DYES NO DYES Page 3 CA2510 Rev. 005

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50.54(q) Screening Form Document #, Rev #, &

Title:

EIP-ZZ-00240 Addendum G, Revision 01 5, Chemistry Coordinator Checklist EP Tracking #:

2023022 Activity Description and

References:

CR202301425 Steps reordered as many post-accident sampling actions would depend on working through Reactor Trip Checklist and current steps do not reference Reactor Trip Checklist until already in the post-accident sampling.

Steps aligned as follows Operations:

Step 6 changed to be Step 9.

Step 7 is unchanged Step 8 changed to be Step 10 Step 9 changed to be Step 8 Step 1 0 changed to be Step II Step I 1 changed to be Step 6 These actions improve the monitoring of evolving plant conditions during major events as seen during the 2023 NRC raded exercise.

Activity Scope:

YES NO revise the Radio1oical Ernergencyçponse PNn (RERP) or Implementing Proceduies7 H

Change Type:

YES NO Is this activityeditorial or typographical?

H I

Previously Approved Change:

YES NO Is this activity being processed to conform to a previously approved activity?

.... H IfYES, what is the previously approved activity?

Planning Standard Determination:

Does this activity impact any ofthe 50.47(b) Planning Staadards or Part 50 Appendix F:

YES NO 50.47(b)(1)

- Assignment ofRcsponsibility (Organization Control)?

.. H 50.47(b)(2)

- Onsite Emergency Organization?

H 50.47(b)(3)

- Emergency Response Support and Resources7 H

50.47(b)(4)

- Emergency Classification System?

H 50.47(b)(5)

- Notification Methods and Procedures9

.*.... H 50.47(b)(6)

- Emergency Cornrnunications LI 50.47(b)(7)

- Public Education and Information7 H

50.47(b)(8)

- Emergency facility and Equipment?

ü 50.47(b)(9)

- Accident Assessment7 H

50.47(b)(10)

- Protective Response7 H

50.47(b)(11)

- Radiological Exposure Control?

H 50.47(b)(12)

- Medical and Public Health Support?

. H 50.47(b)(13)

- Recovery Planning and Post Accident Operations?

. H 50.47(b)(14)

- Drills and Exercises7

.E 50.47(b)(15)

- Emergency Responder Training?

... H 50.47(b)(16)

- Emergency Plan Maintenance?

H Part 50 Appendix E

.... H Commitment Impact Determination:

YES NO Does this activity impact a Site Specific EP Commitment not associated with a Planning Standard or Element?

H If Yes, record the Commitment number:

Explanation of Determination: (Enter an explanation to each determination-answer that needs clarifIcation.)

Revision of EIP-ZZ-00240 Add G, Chemistry Coordinator Checklist is associated with Planning Standards 50.47(b)(8)

Emergency Facility and Equipment and 50.47(b)(9) Accident Assessment. However, the activity only slightly reorders actions in the checklist and the actions themselves were unchanged. This activity has no impact on any of the regulatory required functions of the associated planning standards. Therefore, an evaluation in accordance with 50.54(q) is not required.

File # A210.0038 KDP-ZZ-00400 Page 1 of2 CA1523 Rev. 002

50.54(q) Screening Form Screening Evaluation Results:

Based on the results of the information above, can the activity be implemcntcd without performing a YES NO

full 50.54(q) Effectiveness Evaluation?

• .*)

U Review/Approval Preparer (Sign/PIN)

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Date Z9 Z3 ri: &s, must be qualified nZ)ençv 1?Lcfs:se Coctzltatoi.

Reviewer (Sign/PIN) 2 SZQ 1?

i rit 1 fi IS! F) 4T ci I n

i Response C noidinotot Emergency Prcparedness NI gei (Sign/PIN) itfl1 File#A2l0.0038 Pagc2of2 CA1523 KDP-ZZ-00400 Rev. 002