ONS-2017-056, Emergency Plan Implementing Procedures Manual, Volume 1, Revision 2017-004

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Emergency Plan Implementing Procedures Manual, Volume 1, Revision 2017-004
ML17208A065
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 07/14/2017
From: Hubbard D
Duke Energy Carolinas
To:
Office of Nuclear Reactor Regulation
Shared Package
ML17208A054 List:
References
ONS-2017-056
Download: ML17208A065 (20)
v • d • e


Text

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~JENERGY OCONEE NUCLEAR STATION EMERGENCY PLAN IMPLEMENTING PROCEDURES Volume 1 Dean Hubbard Director, Nuclear Organizational Effectiveness 1-J'-1-11 Date Approved Volume 1 REVISION 2017-004 June 2017

June 28, 2017 OCONEE NUCLEAR STATION

SUBJECT:

Emergency Plan Implementing Procedures Volume 1, Revision 2017-004 Please make the following changes to the Emergency Plan Implementing Procedures Volume 1.

REMOVE Cover Sheet Instructions RP/O/A/1000/003 A William R. Mcintyre Rev. 2017-003 Rev. 2017-003 Rev 002 ONS Emergency Preparedness Mgr.

INSERT Cover Sheet Instructions RP/O/A/1000/003 A Rev. 2017-004 Rev. 2017-004 Rev 003

Duke Energy Procedure No.

Oconee Nuclear Station RP/0/Nl000/003 A Revision No.

ERDS OPERATION 003 Reference Use Electronic Reference No.

OP009ADL

ERDS Operation

1. Purpose RP/0/A/1000/003 A Page 2of5 1.1 To provide the NRC with plant data when in an emergency and to meet 10CFR50.72 (4) requirements.
2. Scope 2.1 This procedure is required to be performed at an emergency classification of Alert, Site Area Emergency or General Emergency.
3. Precaution and Limitations 3.1 None.
4. General Information 4.1 ERDS shall be started within one hour if an emergency classification of Alert, Site Area Emergency or General Emergency has been declared per 10CFR 50.72(4).

Effort should be made to perform this action as soon as possible.

4.2 This procedure is an implementing procedure to the Oconee Nuclear Site Emergency Plan and must be:

4.2.1 Reviewed in accordance with 1 OCFR50.54( q) prior to approval.

4.2.2 Forwarded to Emergency Preparedness within seven (7) working days of approval.

5. Prerequisites 5.1 None.
6. Instructions RP/0/A/1000/003 A Page 3of5 6.1 ERDS Activation D 6.1. l ERDS Operation Started By: ___________ _

NOTE:

ERDS can only be activated using the following business workstations:

0 TSC NRC Communicator 0 TSC Operations 0 Unit 1 Control Room SRO 0 Unit 2 Control Room SRO 0 Unit 3 Control Room SRO 0 Process Computer Systems Unit I OAC Room 0 Process Computer Systems OOB Computer Room ERDS activation is performed by an SRO or the TSC NRC Communicator.

D 6.1.2 D 6.1.3 D 6.1.4 D 6.1.5 D 6.1.6 Ensure the manual KYM switch is set to "Business". IF required, refer to KVM Usage Instructions to login to user console.

Log onto any authorized business workstations for ERDS activation using your normal network login id.

From the Windows Desktop, Double-Click on the ERDS Activation Icon to activate ERDS Link Control and Status Display.

IF AT ANY TIME ERDS does NOT connect with the NRC after several minutes OR activation problems (Such as OAC Time Issues) are experienced, perform the following:

D Notify the NRC using the ENS Phone Line.

D Record the Date and Time of this notification.

Date Time Initials Examine the OAC time information on the right side of the display and verify that OAC Time is current time and OAC Time Rate is NOT zero for each Unit to be activated.

D Unit 1 D Unit 2 D Unit 3

D 6.1.7 RP/0/A/1000/003 A Page 4of5 Select the Connect (Activate) Target Area with the mouse to initiate ERDS communication for each ONS Unit requiring activation.

D Record the Date and Time ERDS communication was initiated below:

Unit 1 Date Time Initials Unit 2 Date Time Initials Unit 3 Date Time Initials NOTE:

The Status Column may indicate (in order) "Connecting", "Reconnecting",

"Connected", "LINK Sent", "Waiting for ACCEPT", "ACCEPT Received", "Waiting for INITIATE", or "Transmitting Data" in the process of connecting. Some statuses may NOT be seen during actual connection due to response time and update of display. The Status "Transmitting Data" with Messages Sent incrementing indicates appropriate connectivity for communications.

Other possible Statuses are:

Suspended-> NRC has suspended transmission temporarily.

Denied -> Plant's request for a connection has been denied by NRC.

If the connection was lost then regained, the status column will cycle through the same status sequence as the initial connection.

D 6.1.8 Verify the following is indicated on the ERDS Link Control and Status Display for each unit activated:

Unit l Unit2 Unit3 D

D D

Current Mode = Connect D

D D

Status = Transmitting Data D

D D

Messages Sent = "Incrementing" NOTE:

If it is desired to reconnect, it is recommended to wait a minimum of 15 minutes prior to attempting reconnect EROS after a disconnect.

D 6.1.9 D 6.1.10 IF AT ANY TIME instructed by the NRC to restart ONS ERDS communication, re-perform step 6.1.7 and step 6.1.8.

IF ERDS data will be interrupted (turnover, etc.), coordinate with the NRC regional office to determine desired timing for interruption.

RP/0/A/1000/003 A Page 5 of 5 6.2 IF required to return to your login screen, refer to Step 6.1.2, Step 6.1.3 and Step 6.1.4 for guidance.

6.3 Stopping ERDS transmission after event termination.

NOTE:

The Status Column should indicate Terminating followed by Disconnected.

7.
8.
9.

D 6.3.l D 6.3.2 Records 7.1 None On the ERDS Link Control and Status Display for ONS, Select the Disconnect (Deactivate) Target Area with the mouse to terminate ERDS communication for each ONS Unit activated.

A. Record the Date and Time ERDS communication was terminated below:

D Unit 1 Date Time Initials

-~~~~

D Unit 2 Date Time Initials

-~~~~

D Unit 3 Date Time Initials

-~~~~

Verify the following is indicated on the ERDS Link Control and Status Display for each unit activated:

Unit 1 Unit 2 Unit 3 D

D D

Current Mode = Disconnect D

D D

Status = Disconnected D

D D

Messages Sent = 0 References 8.1 None Attachments 9.1 None

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

<< 10 CFR 50.54{q) Screening Evaluation Form>>

AD-EP-ALL-0602 Rev. 1 ATTACHMENT 4 Page 1 of 5

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BNP D

EREG #: 02123808 CNS D

CR3 D

HNP D

MNS D

5AD #:

02123804 ONS x

RNP D

GO

.0 Document and Revision RP/O/A/1000/003 A Rev 003 EROS OPERATION

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Part I. Description of Activity 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):

Page /Section Current Proposed Change

1. First Note I NOTE: This procedure is an This procedure is an implementing procedure moved to new
  • implementing procedure to the to the Oconee Nuclear Site Emergency Plan Step 4.2 Oconee Nuclear Site Emergency and must be:
2. Section 1 (symptoms)/

moved to new Step 4.1

3. new section 1 Purpose
4. new section 2 Scope
5. old step 2.1.2 revised to new 6.1.2
6. Old step 2.1.6 moved to new step 6.1.5 Plan and must be:

4.2.1 Reviewed in accordance with

  • Reviewed in accordance with 1 OCFR50.54(q) prior to approval.

1 OCFR50.54(q) prior to approval.

4.2.2 Forwarded to Emergency Preparedness

  • Forwarded to Emergency within seven (7) working days of approval.

Preparedness within seven (7) workinq days of approval.

EROS shall be started within one hour EROS shall be started within one hour if an if an emergency Classification of Alert, Site Area Emergency or General Emergency has been declared per 10CFR 50.72(4). Effort should be made to perform this action as soon as possible.

NIA NIA IF required, refer to KVM Usage Instructions to login to user console and select the Business (BUS) workstation menu selection.

IF AT ANY TIME EROS does NOT connect with the NRC after several minutes OR activation problems (Such as OAC Time Issues) are emergency classification of Alert, Site Area Emergency or General Emergency has been declared per 10CFR 50. 72( 4 ). Effort should be made to perform this action as soon as possible.

1. 1 To provide the NRC with plant data when in an emergency and to meet 10CFR50.72 (4) requirements.

This procedure is required to be performed at an emergency classification of Alert, Site Area Emergency or General Emergency.

Ensure the manual KVM switch is set to "Business". IF required, refer to KVM Usage Instructions to login to user console.

IF AT ANY TIME EROS does NOT connect with the NRC after several minutes OR activation problems (Such as OAC Time Issues) are experienced, perform the followinq:

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

AD-EP-ALL-0,602 Rev. 1 ATTACHMENT 4 Page 2 of 5

<< 10 CFR 50.54(q) Screening Evaluation Form>>

experienced, perform the followini:i:

7. new note before new step 6.1.9 (old step 2.1.9)

NIA NOTE: If it is desired to reconnect, it is recommended to wait a minimum of 15 minutes prior to attempting reconnect EROS after a disconnect.

8. old steps 3.1 and 3.2 renumbered to 6.2 and 6.3
9. new format of procedure sections

. -. -~-*,

3. Subsequent Actions
1. Symptoms
2. Immediate Actions
3. Subsequent actions

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1. Purpose 2.Scope
3. Precaution and Limitations 3.1 None.
4. General Information
5. Prerequisites 5.1 None.
6. Instructions
7. Records 7.1 None.
8. References 8.1 None.
9. Attachments 9.1 None.

Part II. Activity Previously Reviewed?

Yes

\\ D No

\\ X Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design Report?

If yes, identify bounding source document number or approval reference and ensure the basis for concluding the source document fully bounds the proposed change is documented below:

Justification:

Bounding document attached (optional)

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Part Ill. Editorial Change Is this activity an editorial or typographical change only, such as formatting, paragraph numbering, spelling, or punctuation that does not change intent?

Justification:

10 CFR 50.54(q)

Effectiveness Evaluation is not required. Enter justification below and complete,

Part V.

Yes

\\ D 10 CFR 50.54(q)

Effectiveness Evaluation is not required. Enter justification and complete,

Part V & VI.

Continue to, 10 CFR 50.54(q)

Screening Evaluation Form, Part Ill 10 No I X Continue to,

Part IV and address non editorial changes

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

AD-E P-ALL-0602 Rev. 1 ATTACHMENT 4 Page 3 of 5

<< 10 CFR 50.54(q) Screening Evaluation Form>>

Part IV. Emergency Planning Element and Function Screen (Reference Attachment 1, Considerations for Addressing Screening Criteria)

Does this activity involve any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If answer is yes, then chE)ck box.

1

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1 a Responsibility for emergency response is assigned.

D 1 b The response organization has the staff to respond and to augment staff on a continuing basis D

(24-7 staffing) in accordance with the emergency plan.

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2a Prpcess ensures that onshift. emergency response responsibilities are staffed and assignE;Jd.

D 2b The process for timely augmentation of onshift staff is established and maintained.

D

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3a Arrangements for requesting and using off site assistance have been made.

D 3b State and local staff can be accommodated at the EOF in accordance with the emergency plan.

D (NA for CR3) 4a A standard scheme of emergency classification and action levels is in use.

(Requires final approval of Screen and Evaluation by EP CFAM.)

D 5a Procedures for notification of State and local governmental agencies are capable of initiating D

notification 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 D

instructions to the public within the plume exposure pathway. (NA for CR3) 5c The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D

Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. (NA for CR3)

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

AD-EP-ALL-0602 Rev. 1 ATTACHMENT 4 Page 4 of 5

<< 10 CFR 50.54(q) Screening Evaluation Form>>

Part IV. Emergency Planning Element and Function Screen (cont.)

6a Systems are established for prompt communication among principal emergency response organizations.

6b Systems are established for prompt communication to emergency response personnel.

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7a Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Cpordinate.d dissemination of public information during em~rg~ncies is ~stablished.

x x

D D

8a Adequate facilities are maintained to support emergency response.

D 8b Adequate equipment is maintained to support emergency response.

D 9a Methods, systems, and equipment for assessment of radioactive releases are in use.

X 1 Oa A range of public PARs is available for implementation during emergencies. (NA for CR3) 1 Ob 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. (NA for CR3) 1 Oc A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.

1 Od Kl is available for implementation as a protective action recommendation in those jurisdictions that chose to provide Kl to the public.

D D

D D

11 a The resources for controlling radiological exposures for emergency workers are established.

D 12a Arrangements are made for medical services for contaminated, injured individuals.

D 13a Plans for recovery and reentry are developed.

D 14a A drill and exercise program (including radiological, medical, health physics and other program areas)

D is established.

14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, D

and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.

14c Identified weaknesses are corrected.

D J~*;J;; ~,1:0*.~q~tt9':f4t(h>(1~)J1fl:ifg~!J:2~~~6~-§:P.9n.s.~:~.[a1.r:iHici",: *. ; * ::* ":.. :* _, **.:.. *:~~ ::/-_:_. * "'.<.::-.::.. -:.. :.-'._... ;... *.::.... >:*:~I->:.;

15a Training is provided to emergency responders.

D

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

AD-EP-ALL-0602 Rev. 1 ATTACHMENT 4 Page 5 of 5

<< 10 CFR 50.54(q) Screening Evaluation Form>>

Part IV. Emergency Planning Element and Function Screen (cont.)

16a Responsibility for emergency plan development and review is established.

16b Planners responsible for emergency plan development and maintenance are properly trained.

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PART IV. Conclusion If no Part IV criteria are checked, a 10 CFR 50.54(q) Effectiveness Evaluation is not required, then complete, 10 CFR 50.54(q) Screening Evaluation Form, Part V. Go to Attachment 4, 10 CFR 50.54(q)

Screening Evaluation Form, Part VI for instructions describing the NRC required 30 day submittal.

D D

D If any Attachment 4, 10 CF.R 50.54(q) Screening Eva.luation Form, Part IV criteria are checked, then complete X', 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q)

Effectiveness Evaluation. Shaded block requires final approval of Screen and Evaluation by EP CFAM.

Preparer Name (Print): Peter Kuhlman I./~.

Date:

.;- ll1 17 Reviewer Name (Print): Don Crowl Date:

5 -1 CJ ~n Approver (EP Manager Name (Print):

Pat Street Date:

st~t~r--

Approver (CFAM, as required) Name (Print)

N/A Part VI. NRC Emergency Plan and Implementing Procedure Submittal Actions Create two EREG General Assignments.

Date:

One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q),

to Licensing.

One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect.

QA RECORD D

D

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

AD-EP-ALL-0602 Rev. 1.

ATTACHMENT 5 Page 1 of 8

<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>

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BNP D

EREG #: 02123808 CNS D

CR3 D

HNP D

MNS D

SAD#:

02123804 ONS x

RNP D

GO D

Document and Revision RP/O/A/1000/003 A Rev 003 EROS OPERATION

  • /..

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Part I. Description of Proposed Change:

Pa~e /Section Current Proposed Change

1. First Note I NOTE: This procedure is an This procedure is an implementing procedure moved to new implementing procedure to the to the Oconee Nuclear Site Emergency Plan Step 4.2 Oconee Nuclear Site Emergency and must be:

Plan and must be:

4.2.1 Reviewed in accordance with

1 OCFR50.54( q) prior to approval.

4.2.2 Forwarded to Emergency Preparedness

  • Forwarded to Emergency within seven (7) working days of approval.

Preparedness within seven (7) workinq days of approval.

2. Section 1 EROS shall be started within one hour EROS shall be started within one hour if an (symptoms)/

if an emergency classification of Alert, emergency classification of Alert, Site Area moved to new Site Area Emergency or General Emergency or General Emergency has been Step 4.1 Emergency has been declared per declared per 10CFR 50.72(4). Effort should be 10CFR 50.72(4). Effort made to perform this action as soon as should be made to perform this action possible.

as soon as possible.

3. new section 1 NIA 1.1 To provide the NRC with plant data Purpose when in an emergency and to meet 1 OCFR50.72 (4) requirements.
4. new section 2 NIA This procedure is required to be performed at Scope an emergency classification of Alert, Site Area Emerqency or General Emeq::iencv.
5. old step 2.1.2 IF required, refer to KVM Usage Ensure the manual KVM switch is set to revised to new Instructions to login to user console "Business". IF required, refer to KVM Usage 6.1.2 and select the Business (BUS)

Instructions to login to user console.

workstation menu selection.

6. Old step 2.1.6 IF AT ANY TIME EROS does NOT IF AT ANY TIME EROS does NOT connect moved to new connect with the NRC after several with the NRC after several minutes OR step 6.1.5 minutes OR activation problems (Such activation problems (Such as OAC Time as OAC Time Issues) are Issues) are experienced, perform the following:

experienced, perform the followinQ:

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

AD-EP-ALL-0602 Rev. 1 ATTACHMENT 5 Page 2 of 8

7. new note before new step 6.1.9 (old step 2.1.9)
8. old steps 3.1 and 3.2 renumbered to 6.2 and 6.3
9. new format of procedure sections

<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>

NIA

3. Subsequent Actions
1. Symptoms
2. Immediate Actions
3. Subsequent actions NOTE: If it is desired to reconnect, it is recommended to wait a minimum of 15 minutes prior to attempting reconnect EROS after a disconnect.

deleted title

1. Purpose 2.Scope
3. Precaution and Limitations 3.1 None.
4. General Information
5. Prerequisites 5.1 None.
6. Instructions
7. Records 7.1 None.
8. References 8.1 None.
9. Attachments 9.1 None., 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is attached (required for IC or EAL change)

Yes D

No D

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Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

Oconee Emergency Plan Revision 82-2 December 1981 F.1.f Redundant two way communication exists for communication with the Nuclear Regulatory Commission. The Red Phone (ENS system), the HPN System, the regular station telephone system exists for the communication link with NRC, and the Southern Bell Telephone line (Figure F-4) 1.5 Meteorological Information Availability Meteorological information will be available to the nearest Crisis Management Center, the Technical Support Center, the Control Room through plant status reports and by direct telephone communication. Meteorological information will be available to the NRC through the automated ringdown phone and by direct telephone communications with the individual responsible for making offsite dose assessments either at the Technical Support Center or the Crisis Management Center.

Oconee Emergency Plan Revision 2017-002 F.1.f Redundant two way communication exists for communication with the Nuclear Regulatory Commission. The ETS system, the regular site or EOF telephone system exists for the communication link with NRC. (Figure F-1) 1.5 Meteorological Information Availability Meteorological information will be available to the Charlotte Emergency Operations Facility, the Technical Support Center, and the Control Room throuqh the automated plant data system. Meteoroloqical data averaged over a

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

<< 10 CFR 50.54{q) Effectiv~ness Evaluation Form>>

AD-EP-ALL-0602

. Rev. 1 ATTACHMENT 5 Page 3 of 8 period of 15 minutes, will be available to the NRC through the ENS phone, by direct telephone communications with the individual responsible for making offsite dose assessments at the Emergency Operations Facility or through the NRC Emergency Response Data System.

APPENDIX 7, Emergency Response Data System Appendix E Part 50,Section VI, Emergency Response Data System states EROS will supplement the existing voice transmission over the Emergency Notification System (ENS) by providing the NRG Operations Center with timely and accurate updates of a limited set of parameters from the licensee's installed onsite computer system in the event of an emergency.

RIS 2005-02, Clarifying the Process for Making Emergency Plan Changes, Rev. 1 states,

2) Emergency plan a) The document prepared and maintained by the licensee that identifies and describes the licensee's methods for maintaining emergency preparedness, and responding to emergencies. An emergency plan includes the plan as originally approved by the NRG, and all subsequent changes made by the licensee with, and without, prior NRG review and approval under 10 CFR 50.54(q).

i) The licensee's emergency plan consists of:

(1) The emergency plan as approved by the NRG via a Safety Evaluation Report (SE), or license amendment (LA) from the Office of Nuclear Reactor Regulation (NRR) or the Office of Federal and State Materials and Environmental Management Programs (FSME).

(2) Any subsequent changes to the emergency plan explicitly reviewed by the NRG through an SE, or LA from NRR or FSME, and found to meet the applicable regulations.

(3) Any subsequent changes made by the licensee without NRG review and approval after the licensee concluded that the change(s) do not constitute a decrease in effectiveness under 10 CFR 50.54(q).

The differences in ONS Emergency Plan, Revision 82-2, and the current revision of the ONS Emergency Plan have been determined to meet the regulatory requirements of the course of revisions. Each revision has been evaluated in the regulatory process has met the approval of the NRG during the inspection process.

The changes described in this evaluation do not reduce the effectiveness of the emergency plan.

Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments.

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):

10 CFR 50.47 Emergency Plans.

10 CFR 50.47(b)(6); Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.

Appendix E to Part 50-Emergency Planning and Preparedness for Production and Utilization Facilities VI. Emergency Response Data System

1. The Emergency Response Data System (EROS) is a direct near real-time electronic data link between the licensee's onsite computer system and the NRG Operations Center that provides for the automated transmission of a limited data set of selected parameters. The EROS supplements the existing voice transmission over the Emergency Notification System (ENS) by providing the NRC Operations Center with timely and accurate updates of

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>

AD-EP-ALL-0602 Rev. 1 ATTACHMENT 5 Page 4 of 8 a limited set of parameters from the licensee's installed onsite computer system in the event of an emergency.

When selected plant data are not available on the licensee's onsite computer system, retrofitting of data points is not required. The licensee shall test the EROS periodically to verify system availability and operability. The frequency of EROS testing will be quarterly unless otherwise set by NRC based on demonstrated system performance.

Changes 1,2,3,4 and 6 change the format of the procedure from a three section procedure to a fleet standard nine section procedure. Changed procedure steps to comply with the Procedure Writers Guide.

Change 5 ensures that the KVM is selected to the 'Business Network' where the icon for the EROS application is located.

All changes to the procedure continue to comply with regulation and commitments to provide automated transmission of. a limited data set of selected parameters and maintains avai.lability and operability. KVM hardware change was evaluated in EREG 405168 that replaced the keyboard operated model to a manual switch model to comply with cyber security requirements. No changes in the methods or functions were made to transmit data via EROS.

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

AD-EP-ALL-0602 Rev. 1 ATTACHMENT 5 Page 5 of 8

<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>

~-**

Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen):

10 CFR 50.47 Emergency Plans.

10 CFR 50.47(b)(6); Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.

Appendix E to. Part 50-Emergency Planning aryd Preparedness for Prqduction and Utilization Facilities.

VI. Emergency Response Data System

1. The Emergency Response Data System (EROS) is a direct near real-time electronic data link between the licensee's onsite computer system and the NRC Operations Center that provides for the automated transmission of a limited data set of selected parameters. The EROS supplements the existing voice transmission over the Emergency Notification System (ENS) by providing the NRC Operations Center with timely and accurate updates of a limited set of parameters from the licensee's installed onsite computer system in the event of an emergency.

When selected plant data are not available on the licensee's onsite computer system, retrofitting of data points is not required. The licensee shall test the EROS periodically to verify system availability and operability. The frequency of EROS testing will be quarterly unless otherwise set by NRC based on demonstrated system performance.

Two emergency planning functions have been defined for this planning standard:

(1) Systems are established for prompt communication among principal emergency response organizations.

(2) Systems are established for prompt communication to emergency response personnel.

NUREG-0654 FEMA-REP-1 Rev. 1 F. Emergency Communications; Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.

F.1.c. provision for communications as needed with Federal emergency response organizations; F.1.f. provision for communication by the licensee with NRC headquarters and NRC Regional Office Emergency Operations Centers and the licensee's near-site Emergency Operations Facility and radiological monitoring team assembly area.

F.3. Each organization shall conduct periodic testing of the entire emergency communications system (see evaluation criteria H.10, N.2.a and Appendix 3).

10 CFR 50.47 Emergency Plans.

1 O CFR 50.4 7(b)(9) Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

The following emergency planning function has been defined for this planning standard:

Methods, systems, and equipment for assessment of radioactive releases are in use.

NUREG-0654 FEMA-REP-1 Rev. 1 I. Accident Assessment

5. Each licensee shall have the capability of acquirin

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>

the criteria of Appendix 2. There shall be provisions for access to meteorological information by at least the nearsite Emergency Operations Facility, the Technical Support Center, the Control Room and an offsite NRC center. The licensee shall make available to the State suitable meteorological data processing interconnections which will permit independent analysis by the State, of facility generated data in those States with the resources to effectively use this information.

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Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

10 CFR 50.47 Emergency Plans.

10 CFR 50.47(b)(6); Provisions exist for prompt communications among principal '.es~?nse organizations to emergency personnel and to the public.

10 CFR 50.47(b)(9) Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Appendix E to Part 50-Emergency Planning and Preparedness for Production and Utilization Facilities VI. Emergency Response Data System

1. The Emergency Response Data System (ERDS) is a direct near real-time electronic data link between the licensee's onsite computer system and the NRC Operations Center that provides for the automated transmission of a limited data set of selected parameters. The ERDS supplements the existing voice transmission over the Emergency Notification System (ENS) by providing the NRC Operations Center with timely and accurate updates of a limited set of parameters from the licensee's installed onsite computer system in the event of an emergency.

When selected plant data are not available on the licensee's onsite computer system, retrofitting of data points is not required. The licensee shall test the EROS periodically to verify system availability and operability. The frequency of EROS testing will be quarterly unless otherwise set by NRC based on demonstrated system performance.

All changes to the procedure continue to comply with regulation and commitments to provide automated transmission of a limited data set of selected parameters and maintains availability and operability. KVM hardware change was evaluated in EREG 405168 that replaced the keyboard operated model to a manual switch model to comply with cyber security requirements. No changes in the methods or functions were made to transmit data via EROS among principal emergency response organizations and for prompt communication to emergency response personnel.

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Part VI. 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?

YesX NoD 2

Does the proposed change maintain the effectiveness of the emergency plan (i.e., no YesX NoD reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme?

Yes X No D 4_

Choose one of the following conclusions:

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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<< 10 CFR 50.54(q) Effectiveness Evaluation Form>>

a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current x

Emergency Action Level (EAL) scheme. Therefore, the activity can be implemented without prior NRC approval.

b The activity does not continue to comply with the requirements of 10 CFR 50.47(b) or 10 CFR 50 Appendix E or the activity does constitute a reduction in effectiveness or EAL scheme change.

0 Therefore, the activity cannot be implemented without prior NRC approval.

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Part VII. Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change determined to require prior NRC approval be either revised or I Yes 0 I No 0 rejected?

If No, then initiate a License Amendment Request in accordance 10 CFR 50.90 and AD-LS-ALL-0002, Regulatory Correspondence, and include the tracking number:

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

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<< 10 CFR 50.54(q) Effectiv.ene~.s Eyaluation Form >>

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Part VIII. Signatures: EP CFAM Final Approval is required for changes affecting risk significant planning standard 10 CFR 50.47(b)(4).

Preparer Name (Print): Peter Kuhlman Reviewer Name (Print): Don Crowl Approver (EP Manager) Name (Print):

Pat Street Approver (CFAM, as required) Name (Print):

Date:

N/A

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If the proposed activity is a change to the E-Plan or implementing procedures, then create two EREG General Assignments.

One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q),

0 to Licensing.

One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect.

D QA RECORD

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