ML23088A266
| ML23088A266 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/23/2023 |
| From: | Bassford J Ameren Missouri |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML23088A265 | List: |
| References | |
| EIP-ZZ-00201, Rev 054 | |
| Download: ML23088A266 (1) | |
Text
~~
~ Ameren Callaway MISSOURI Energy Center EIP-ZZ-00201 NOTIFICATIONS MINOR Revision 054 Page 1 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 NOTIFICATIONS TABLE OF CONTENTS Section Page Number 1.0 PURPOSE ...................................................................................................................................... 3 2.0 SCOPE ........................................................................................................................................... 3 3.0 RESPONSIBILITIES .................................................................................................................... 3 3.1. Emergency Coordinator (EC)/Recovery Manager (RM) ....................................................... 3 3.2. Off Site Liaison Coordinator (OSL) ..................................................................................... 3 3.3. Control Room Communicator .............................................................................................. 4 3.4. TSC (ENS) Communicator .................................................................................................. 4 3.5. EOF Communicator ............................................................................................................. 4 4.0 PREREQUISITES ......................................................................................................................... 4 5.0 PROCEDURE INSTRUCTIONS ................................................................................................. 5 5.1. Communicators Reporting to Emergency Response Facilities .............................................. 5 5.2. Accelerated NRC Call .......................................................................................................... 6 5.3. Initial Notifications .............................................................................................................. 7 5.4. Follow-Up Notifications ...................................................................................................... 8 5.5. Transferring Notification Responsibility .............................................................................. 9
6.0 REFERENCES
............................................................................................................................ 11 6.1. Implementing ..................................................................................................................... 11 6.2. Developmental ................................................................................................................... 11 7.0 RECORDS ................................................................................................................................... 12 8.0 DEFINITIONS ............................................................................................................................ 12 9.0
SUMMARY
OF CHANGES ....................................................................................................... 13 ATTACHMENT 1, Notifications During Quickly Changing Events ........................................................ 14 EIP-ZZ-00201 Addendum A, Control Room Notification Flowchart EIP-ZZ-00201 Addendum B, TSC (ENS) Communicator Package EIP-ZZ-00201 Addendum C, EOF Notification Package Page 2 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 NOTIFICATIONS 1.0 PURPOSE Provide responsibilities and guidance for notifying off site agencies that an emergency has occurred at the Callaway Plant.
2.0 SCOPE Covers the initial and follow-up notifications of declared events to:
- Emergency Planning Zone (EPZ) Counties and the State per 10CFR50.72. [Ref: 6.2.4]
- NRC Resident Inspector.
- NRC Operations Center per 10CFR73.71. [Ref: 6.2.5]
- Other agencies such as American Nuclear Insurers (ANI), Institute of Nuclear Power Operators (INPO) & Nuclear Energy Institute (NEI).
- Department of Natural Resources (DNR) that involve a liquid release.
3.0 RESPONSIBILITIES 3.1. Emergency Coordinator (EC)/Recovery Manager (RM) 3.1.1. The Shift Manager (SM) acts as the Emergency Coordinator until relieved.
[Ref: 6.2.8]
3.1.2. The EC is responsible for initiating this procedure and authorizing the release of notifications to off-site authorities until relieved by the Recovery Manager.
3.1.3. The RM, when present in the EOF, accepts responsibility for initiating this procedure and authorizing the release of notifications to off-site authorities.
[Ref: 6.2.9, 6.2.10, 6.2.11]
3.2. Off Site Liaison Coordinator (OSL) 3.2.1. Reports to the RM in the EOF.
3.2.2. Keeps off-site authorities up-to-date regarding on-site emergency response activities, receiving responding representatives from off-site agencies, assisting in meeting their communications and logistic needs, and other duties as assigned by the RM.
Page 3 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 3.3. Control Room Communicator 3.3.1. Reports to the Control Room when an emergency is announced.
3.3.2. Initiates notifications to off-site authorities as directed by the EC.
3.3.3. If an ALERT (or higher) emergency is declared, the responsibility for communication with the NRC via the ENS line is transferred to the TSC (ENS)
Communicator and responsibility for off-site notifications is transferred to the EOF Communicator in the EOF.
3.3.4. After being relieved of communication responsibilities, may be assigned other duties or report to the appropriate coordinator in the TSC as directed by the EC.
3.4. TSC (ENS) Communicator Relieves the Control Room Communicator of Emergency Notification System (ENS) communications. Communications are initiated at the direction of the NRC.
3.5. EOF Communicator Relieves the Control Room Communicator, per Recovery Manager (RM) instruction, of all off-site notification responsibilities, except (ENS). [Ref: 6.2.12]
4.0 PREREQUISITES None
-END OF SECTION-Page 4 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 5.0 PROCEDURE INSTRUCTIONS NOTE
- EIP-ZZ-00201 Addendum A, Control Room Notification Flowchart, provides guidance for making notifications from the Control Room.
- EIP-ZZ-00201 Addendum B, TSC (ENS) Communicator Package, provides guidance for communicating with the NRC from the TSC.
- EIP-ZZ-00201 Addendum C, EOF Notification Package, provides guidance for making notifications from the EOF.
- EIP-ZZ-01211, Accident Dose Assessment, provides additional guidance on radioactive releases, including start times and duration.
5.1. Communicators Reporting to Emergency Response Facilities 5.1.1. Upon arrival at the Emergency Response Facility, ANNOUNCE your presence and availability to the appropriate Coordinator.
5.1.2. IF the primary means of communication for any notification point is unavailable, USE the appropriate back-up means of communication indicated on the notification flowchart.
5.1.3. Control Room or TSC Communicator - PRIOR to initiating any communications OR assuming communications responsibility, ENSURE there is a dial tone on the ENS telephone.
5.1.4. Control Room or EOF Communicator - PRIOR to assuming communications responsibility OR initiating any communications, ENSURE Event Notification System computer is running.
5.1.5. CHECK the verification call back line (573-676-8840) has a dial tone.
5.1.6. CHECK the backup radio is ON and displays EOC.
Page 5 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 5.2. Accelerated NRC Call NOTE These actions are required following discovery of an imminent threat or attack against the station.
Accelerated Notification to the NRC is to allow the NRC to warn other licensees and initiate Federal response in accordance with the National Response Plan and assumes the NRC was NOT the provider of the threat information.
Accelerated Notification is NOT to interfere with plant or personnel safety or physical security response.
This call is meant to be very brief, and limited to the following information only.
5.2.1. As soon as practical (within 15 minutes of discovery of the Security Event), using the ENS phone, CALL the NRC Operations Center and PROVIDE the following information: [Ref: 6.2.6, 6.2.7]
- a. Site Name (Callaway)
- b. Emergency Classification (If it has been determined prior to the accelerated call.)
- c. Nature of the threat (Briefly describe, if known, including the type of attack and attack status.)
- Armed assault by land
- Armed assault by aircraft
- Imminent attack
- Attack in progress
- Attack repelled 5.2.2. IF contact with the NRC is broken, PERFORM the following:
- a. IF NOT already completed, CLASSIFY emergency in accordance with EIP-ZZ-00101, Classification of Emergencies.
- b. PERFORM notifications in accordance with this procedure.
- c. RE-ESTABLISH communications with NRC as soon as possible.
Page 6 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 5.3. Initial Notifications NOTE Notification to State and Local Authorities is initiated and acknowledged within 15 minutes following the DECLARATION of an emergency.
Notification to NRC Operations Center is initiated as soon as possible, but at all times within 60 minutes following the DECLARATION of an emergency. The NRC Resident is also notified.
[Ref: 6.2.13, 6.2.16]
If a Notification does any of the following it is considered an Initial Notification:
- Initiates or changes an Emergency Classification Level,
- Initiates or modifies a Protective Action Recommendation (PAR),
all others Notifications are considered Follow-Up Notifications.
5.3.1. Control Room or EOF Communicator - WHEN directed by the Emergency Coordinator (or Recovery Manager), USE the Event Notification System to transmit notifications of the event simultaneously to the four EPZ counties (Callaway, Montgomery, Gasconade and Osage) and the State of Missouri.
[Ref: 6.2.13]
5.3.2. IF emergency classification changes quickly before the initial notification or update is made to the Off-site Response Organizations (OROs) and the NRC, REFER To Attachment 1 for additional guidance. [Ref: 6.2.14]
5.3.3. Control Room or TSC Communicator - at the direction of the EC, USE the Emergency Notification System (ENS), to notify NRC of emergency.
5.3.4. WHEN established, MAINTAIN communications with the NRC, until the NRC directs otherwise.
5.3.5. IF the Control Room is evacuated in accordance with OTO-ZZ-00001, Control Room Inaccessibility, REFER To Addendum A for guidance.
Page 7 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 5.4. Follow-Up Notifications 5.4.1. AFTER a transfer of Communication responsibilities has occurred, TRANSMIT a follow-up notification.
5.4.2. Approximately every 60 minutes following the initial Notification, TRANSMIT a follow-up notification.
NOTE If a Notification does any of the following it is considered an Initial Notification:
- Initiates or changes an Emergency Classification Level,
- Initiates or modifies a Protective Action Recommendation (PAR),
all others Notifications are considered Follow-Up Notifications.
5.4.3. IF plant or emergency conditions are changing, TRANSMIT follow-up notifications more frequently.
NOTE When sending information via the Event Notification System, or Attachment 4 of EIP-ZZ-00102, Emergency Implementing Actions, during Recovery or Event Closeout, use the highest EAL that the station is in (or is exiting from) in the "Emergency Action Level (EAL)" field and modify the "Emergency Action Level Description" field to explain the plant status and what is occurring. Also use the "Additional Notes" field if the "Emergency Action Level Description" field runs out of space.
5.4.4. Any concurrent EALS that have been identified should be listed in the Additional Notes section to notify the offsite agencies and to aid in Closeout and Recovery.
5.4.5. WHEN at an Unusual Event AND conditions are stable, notification frequency may be reduced, with the concurrence of SEMA and the EPZ Counties.
5.4.6. WHEN plant recovery has been declared following an Alert or higher emergency, MAKE follow up notifications ONLY when conditions change AND the results could affect off site evolutions.
Page 8 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 5.5. Transferring Notification Responsibility CAUTION Once the Event Notification System responsibilities are turned over, the Control Room Communicator is NOT to send Event Notification messages, unless accepting notification responsibilities back from the EOF.
5.5.1. WHEN the EOF Communicator is staffed, PERFORM the following:
- a. RM or Protective Measures Coordinator (PMC) - EXCEPT the ENS line, COORDINATE the transfer of notification responsibility from the Control Room to the EOF.
- c. Control Room Communicator - NOTIFY the EC/Shift Manager that the transfer is complete.
- d. EOF Communicator - WHEN notifications are assumed in the EOF, PREPARE, OBTAIN approval, and SEND a follow-up notification to ensure proper notification system operation in the EOF.
NOTE The transfer of ENS line from the Control Room to the TSC is under the guidance of the NRC.
Once communications with the NRC are established, they are maintained until the NRC directs otherwise.
If Control Room Communicator is NOT in contact with the NRC at time of transfer, it is permissible for the ENS Communicator to accept communications and then notify the NRC that the ENS line has been transferred to the TSC.
5.5.2. IF continuous contact with the NRC has been established by the Control Room Communicator, PERFORM the following to transfer communications to the TSC:
- a. Control Room Communicator - INFORM the NRC that the TSC is ready to transfer communications.
- b. RECEIVE guidance from the NRC as to how AND when they want the communications transfer to occur.
Page 9 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 5.5.3. IF continuous NRC contact is NOT currently established, PERFORM the following:
- b. TSC (ENS) Communicator - LOG the transfer of responsibility in the facility logs AND INFORM the EC that the transfer has been made.
-END OF SECTION-Page 10 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054
6.0 REFERENCES
6.1. Implementing 6.1.1. OTO-ZZ-00001, Control Room Inaccessibility 6.1.2. EIP-ZZ-00101, Classification of Emergencies 6.1.3. EIP-ZZ-00201 Addendum A, Control Room Notification Flowchart 6.1.4. EIP-ZZ-00201 Addendum B, TSC (ENS) Communicator Package 6.1.5. EIP-ZZ-00201 Addendum C, EOF Notification Package 6.1.6. EIP-ZZ-01211, Accident Dose Assessment 6.2. Developmental 6.2.1. Callaway Plant RERP 6.2.2. NUREG 0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.
6.2.3. NEI 99-02, Regulatory Assessment Performance Indicator Guideline 6.2.4. 10CFR50.72 6.2.5. 10CFR73.71 6.2.6. UNNRC 05189 6.2.7. Commitment 50110 6.2.8. RERP Section 5.1.1 (Obligation 3314) 6.2.9. NUREG 0654, 10CFR50.34, 10CFR50-Appendix E (Obligation 3946) 6.2.10. RERP Section 5.1.4 (Obligation 3361) 6.2.11. NUREG 0654, 10CFR50.34, 10CFR50-Appendix E (Obligation 42570) 6.2.12. NUREG 0654, 10CFR50.34, 10CFR50-Appendix E (Obligation 3398) 6.2.13. NUREG 0654, 10CFR50.34, 10CFR50-Appendix E (Obligation 3948) 6.2.14. RIS-07-02, NRC Regulatory Issue Summary 2007-02: Clarification of NRC Guidance for Emergency Notifications during Quickly Changing Events 6.2.15. OTO-SK-00001, Plant Security Event - Hostile Intrusion 6.2.16. CAR 201300456, Action 22 (Sig 2, Corrective Action 6)
Page 11 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 7.0 RECORDS 7.1. Printout copy of each notification from the Event Notification System. (File K171.0010) 7.2. EIP-ZZ-00201 Addendum A, Control Room Notification Flowchart. (File K171.0010) 7.3. EIP-ZZ-00201 Addendum B, TSC (ENS) Communicator Package. (File K171.0010) 7.4. EIP-ZZ-00201 Addendum C, EOF Notification Package. (File K171.0010) 8.0 DEFINITIONS 8.1. Accelerated NRC Call - A call to the NRC Operations Center using the ENS phone to notify them within approximately 15 minutes following the discovery of an imminent threat or attack against the station.
8.2. Back-Up Radio System (BURS) - An 800 MHz radio system used to communicate with the State and EPZ Counties when the Event Notification System is unavailable. There are radios located in the Control Room, Simulator, TSC, EOF, EPZ Counties, and State EOC.
8.3. Commercial Telephones - Callaway Plant Commercial Telephones are used to communicate with State and EPZ Counties as a backup to the Event Notification System and BURS.
8.4. Emergency Notification System (ENS) - An FTS telephone connecting the Callaway Plant with the NRC Operations Center. ENS lines are installed in the Control Room, Simulator, TSC, and EOF.
8.5. Event Notification System - A computerized notification system linked between the Callaway Plant, the State Emergency Management Agency (SEMA) and the four (4)
Emergency Planning Zone (EPZ) risk counties. It allows the Communicator to fill out a notification form on screen and then transmit the data simultaneously to all agencies.
Notifications from the Event Notification System can be initiated from the Control Room, Control Room Simulator, Technical Support Center and Emergency Operations Facility (EOF).
8.6. Federal Telecommunications System (FTS) - A telephone network provided for governmental use. The NRC telephone network is part of FTS.
8.7. Follow Up Notification - Any notification which periodically updates off-site emergency organizations regarding emergency conditions or changes to Protective Action Recommendations but does NOT meet the conditions of an initial notification, This includes items such as:
- Entering into plant recovery from an existing emergency classification.
- Declaration of the close out of any emergency classification.
Page 12 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 8.8. Health Physics Network (HPN) - An FTS telephone used for official communication between the Callaway Plant and the NRC Operations Center. It is primarily used for the transmittal of radiological information. HPN phones are located in the EOF and TSC.
8.9. Initial Notification - Any notification that results from the following:
- Initiates or changes an Emergency Classification Level.
- Initiates or modifies a Protective Action Recommendation (PAR).
9.0
SUMMARY
OF CHANGES Section or Page(s) Description Step Number Changed time for follow up notification from 30 minutes to 60 minutes per the 8 5.4.2 U.S. Nuclear Regulatory Commission issuance of Amendment No. 231 to Renewed Facility Operating License No. NPF-30 for Callaway Plant, Unit No. 1 on February 24, 2023 (ML22361A070). The amendment consists of changes to the Radiological Emergency Response Plan (RERP) in response to the application dated February 8, 2022, as supplemented by letter dated July 13, 2022. The amendment revises the RERP to make the following changes:
- Remove the 15-minute and 30-minute Normal Hours response and activation goals, leaving the 75-minute and 90-minute Off-Normal Hours activation goals as the station standard to cover all hours
- Extend the State and counties follow-up notification goal from 30 minutes to 60 minutes and allow for even further increases when conditions are stable, with the agreement of the State of Missouri and local counties.
CR 202200483-001 Page 13 of 14 INFORMATION USE
EIP-ZZ-00201 Rev. 054 Attachment 1 Notifications During Quickly Changing Events Sheet 1 of 1
- 1. The NRC issued clarifying guidance for making notifications during quickly changing events in which the emergency classification changes before the notification is made to the off-site response organizations (OROs) and the NRC.
- 2. The NRC recognizes that there could be exigent circumstances for exceeding this 15-minute criterion during an actual emergency response and the emergency preparedness cornerstone of the Reactor Oversight Program provides for this eventuality. Nonetheless, the licensee is required by regulation to have the capability of making the notification and acknowledgement within 15 minutes of declaring an emergency. Licensees should ensure their notification procedures and ERO training provide the capability for making notifications acknowledgement to State and local governmental agencies within 15 minutes after declaring an emergency, as required by Appendix E (10CFR Part 50).
- 3. The NRC guidance lists the following as acceptable approaches:
- If the plant condition degrades and a higher classification emergency is declared before the notifications are made for the lesser emergency declaration, the licensee should update the notification to reflect the higher emergency classification and complete the updated notifications and acknowledgement within 15 minutes of the lesser emergency declaration.
NOTE Since the OROs will take actions consistent with the higher emergency classification, it is not necessary to identify the lesser classification in the updated notification. However, the plant conditions that gave rise to the lesser classification should be identified, if still present, in the follow-up notifications.
- If the notification and acknowledgement cannot be updated and completed within 15 minutes of the lesser emergency declaration, the ERO should make the notification and acknowledgement for the lesser emergency within 15 minutes of its declaration. The notification could contain the caveat that a change in classification was forthcoming. In parallel, the licensee should prepare the notification for the higher emergency classification and make an additional notification and acknowledgement within 15 minutes of its declaration.
- If the notifications are made serially and the notifications for the lesser emergency declaration are in progress when the escalation is declared, the remaining notifications should be completed so that all OROs have the same classification information. Remaining notifications could contain a caveat that a change in classification was forthcoming. In parallel, the licensee should prepare the notification for the higher emergency classification and make an additional notification and acknowledgement within 15 minutes of the escalated declaration.
Page 14 of 14 INFORMATION USE