ML022490026
| ML022490026 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/26/2002 |
| From: | Tkaczyk L Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Security and Incident Response |
| References | |
| BVY 02-68 | |
| Download: ML022490026 (14) | |
Text
SEn tergy" Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
Vermont Yankee 185 Old Ferry Rd.
P.O. Box 500 Brattleboro, VT 05302 Tel 802-257-5271 August 26, 2002 BVY 02-68 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-27 1)
Vermont Yankee Emergency Plan Implementing Procedure Change In accordance with 10 CFR 50.54(q), enclosed is the latest change to the Vermont Yankee Emergency Plan Implementing Procedure, AP 3125, Rev. 19, the change memo and the 10 CFR 50.54(q) Evaluation Checklist. These changes were determined to not need prior NRC review and approval.
If you have any questions, please contact Audra Williams, Emergency Planning Coordinator, in our Brattleboro office at (802) 258-4177.
Sincerely, ENTERGY NUCLEAR NORTHEAST VERMONT YANKEE Manager Attachments cc:
USNRC Region 1 Administrator USNRC Resident Inspector - VYNPS USNRC Project Manager - VYNPS David M. Silk, Senior Emergency Preparedness Specialist, USNRC Region 1 Vermont Department of Public Service Zý
To:
Eplan Implementing Procedure Controlled Set Holders From: Diane MccVf.A2QA-k Date:
08/22/02 Re:
VY EPlan Implementing Procedure Change #208, Instruction Sheet A new Table of Contents is included.
REVISIONS:
Please replace the following procedures:
Proc/Rev #
Procedure Title AP 3125/19 Emergency Plan Classification & Action Level Scheme m IPnruz I
Vermont Yankee Emergency Plan Implementing Procedures Table of Contents August 22, 2002 Emergency Plan Classification and Action Level Scheme AP 3125 Rev. 19 "R"
Emergency Communications OP 3504 Rev. 34 "R"
Emergency Preparedness Exercises and Drills OP 3505 Rev. 24 "IT Emergency Equipment Readiness Check OP 3506 Rev. 41 "R"
Emergency Radiation Exposure Control OP 3507 Rev. 29 "R"
On-Site Medical Emergency Procedure OP 3508 Rev. 23 "R"
Environmental Sample Collection During an Emergency OP 3509 Rev. 17 "R"
Off-Site and Site Boundary Monitoring OP 3510 Rev. 26 "R"
Off-Site Protective Action Recommendations OP 3511 Rev. 11 "R"
Evaluation of Off-Site Radiological Conditions OP 3513 Rev. 21 "R"
Emergency Actions to Ensure Accountability and Security Response OP 3524 Rev. 19 "R"
Radiological Coordination OP 3525 Rev. 9 "R"
Emergency Call-In Method OP 3531 Rev. 15 "R"
Emergency Preparedness Organization AP 3532 Rev. 10 IT' Post Accident Sampling of Reactor Coolant OP 3533 Rev. 5 "C"
Post Accident Sampling of Plant Stack Gaseous Releases OP 3534 Rev. 3 "C"
Post Accident Sampling and Analysis of Primary Containment OP 3535 Rev. 4 "C"
In Plant Air Sample Analysis with Abnormal Condition OP 3536 Rev. 1 "C"
Control Room Actions During an Emergency OP 3540 Rev. 1 "R"
Activation of the Technical Support Center OP 3541 Rev. 1 "R"
Operation of the Technical Support Center OP 3542 Rev. 1 "R"
Operation of the Operations Support Center OP 3544 Rev. 2 "R"
Activation of the Emergency Operations Facility/Recovery Center OP 3545 Rev. 1 "R"
Operation of the Emergency Operations Facility/Recovery Center OP 3546 Rev. 1 "R"
Security Actions During an Emergency OP 3547 Rev. 1 "R"
Emergency Plan Training OP 3712 Rev. 16 "I"
VERMONT YANKEE NUCLEAR POWER STATION "ADMINISTRATIVE PROCEDURE AP 3125 REVISION 19 EMERGENCY PLAN CLASSIFICATION AND ACTION LEVEL SCHEME USE CLASSIFICATION: INFORMATION LPC Effective No.
Date Affected Pages Implementation Statement: N/A I
Issue Date:
08/22/2002 AP 3125 Rev. 19 Page 1 of 7
1.0 2.0 3.0 4.0 5.0 6.0 7.0 TABLE OF CONTENTS PURPO SE, SCO PE, AND DISCUSSION.............................................................................
3 DEFINITIO NS...............................................................................................................................
3 PRIM ARY RESPO NSIBILITIES...........................................................................................
4 PRO CEDURE..............................................................................................................................
5..5 REFERENCES AND COMMITMENTS...............................................................................
6 FINAL CO NDITIONS.........................................................................................................
7 ATTACH M ENTS........................................................................................................................
7..7 AP 3125 Rev. 19 Page 2 of 7
1.0 PURPOSE, SCOPE, AND DISCUSSION 1.1.
Purpose The purpose of this procedure is to provide a mechanism for classifying off-normal events and plant conditions into one of the four emergency classifications as described in the Vermont Yankee Nuclear Power Station Emergency Plan.
1.2.
Scope Vermont Yankee personnel are trained so that when they sense that plant operations are off-normal or exceeding administrative controls, they have cause to refer to emergency operating procedures which will subsequently refer them to this procedure if necessary.
1.3.
Discussion This procedure, in chart form, is designed to assign the appropriate emergency class for events which are in progress or have occurred. The Emergency Plan is then implemented on the basis for the classification. The chart does not necessarily list all situations which would require implementation of the Emergency Plan; therefore, any off-normal condition should be evaluated in light of the "General Criteria." The minimum response to y event listed in the chart once it has occurred would be to classify the event at the Unusual Event level and to implement the Emergency Plan accordingly.
The appendix is used by Vermont Yankee personnel to classify an event into one of four classes of Emergency Action Levels:
I.
Unusual Event
- 2.
Alert
- 3.
Site Area Emergency
- 4.
General Emergency 2.0 DEFINITIONS The definitions of Emergency Classifications are:
2.1. Alert
Events are in progress or have occurred which involve an actual or potential substantial degradation of plant safety margins which could affect on-site personnel safety, could require off-site impact assessment, but is not likely to require off-site public protective action.
2.2.
General Emergency: Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guidelines exposure levels off-site for more than the immediate site area.
AP 3125 Rev. 19 Page 3 of 7
2.3.
Site Area Emergency: Events are in progress or have occurred which involve likely or actual major failures of plant functions needed for protection of the public. Any release is not expected to exceed EPA Protective Action Guidelines exposure levels except near the site boundary.
2.4.
Unusual Event: Events are in progress or have occurred which involve potential degradation of plant safety margins, which are not likely to affect personnel on-site or the public off-site or result in radioactive releases requiring off-site monitoring.
2.4.1. Unusual Event (Terminated): Event has occurred and was immediately rectified such that the condition no longer existed by the time of declaration. Further, the event or condition did not affect personnel on-site or the public off-site or result in radioactive releases requiring off-site monitoring.
3.0 PRIMARY RESPONSIBILITIES 3.1.
The Operations Duty Shift Manager, or in his absence from the Control Room, the Operations Duty Supervisory Control Room Operator is initially responsible and authority for classifying the level of the emergency.
3.2.
The Senior Manager of Vermont Yankee who assumes the overall supervision of the emergency response organization is responsible for subsequent escalation or de-escalation of the emergency classification.
3.2.1. The Technical Support Center Coordinator is the designated individual for unusual events.
3.2.2. The Site Recovery Manager is the designated individual for Alert and higher emergency classifications, upon assumption of this responsibility from the Technical Support Center Coordinator.
AP 3125 Rev. 19 Page 4 of 7
4.0 PROCEDURE 4.1.
Refer to Appendix A and based on the event to be classified, locate the appropriate "Event Categories."
4.2.
Determine if any of the Emergency Action Levels (EALs) have been reached for any of the four classes of emergency (Unusual Event, Alert, Site Area Emergency, General Emergency).
4.3.
If multiple EALs have been reached:
4.3.1. Classify the emergency at the highest emergency class for those EALs which exist.
4.3.2. For EALs which have been reached but are no longer present, the emergency must still be classified at the highest emergency class even though the conditions no longer exist.
4.3.3. If other EAL conditions exist which would not require re-classification:
4.3.3.1.
provide a timely update to the NRC and the states since these other conditions represent a significant change in the status of the classification, 4.3.3.2.
do not make a second EAL declaration for the classification already in existence.
4.4.
If events are in progress or have occurred and no specific EALs in Appendix A have been reached, but in the opinion of the responsible individual conditions warrant the implementation of the Emergency Plan or re-classification, the individual should classify the event as appropriate (refer to Appendix A, "General Criteria" Event Category).
4.5.
Once the classification has been assigned, implementation of the appropriate Emergency Operating Procedure should be initiated with the prompt notifications of off-site authorities performed, consistent with the need for other emergency actions.
AP 3125 Rev. 19 Page 5 of 7 NOTE For a EAL reached the minimum classification is Unusual Event (UE). Also, per OP 3540, it is only at the UE level that the emergency may be immediately terminated by the SS/PED.
NOTE In making the classification determination, the responsible individual should request assistance from any source immediately available (Security, Chemistry, Radiation Protection, I/C, Maintenance, Engineering Support, etc.). Input from these sources must be prompt, informal, and advisory in nature.
4.6.
Changing conditions may require re-classification. Assess conditions periodically and be prepared to initiate the appropriate change.
4.7.
Subsequent to entry into an Emergency Action Level (EAL), a second initiating condition does not require a second declaration for the classification already reached. However, it does merit a timely update to the states and the NRC since it is a significant change in the status of the classification.
5.0 REFERENCES
AND COMMITMENTS 5.1.
Technical Specifications and Site Documents 5.1.1. Vermont Yankee Nuclear Power Station Emergency Plan 5.1.2. Off-Site Dose Calculation Manual (ODCM) 5.1.3. Vermont Yankee Physical Security Plan 5.1.4. All Technical Specifications 5.1.5. Updated Final Safety Analysis Report (UFSAR) 5.2.
Codes, Standards, and Regulations 5.2.1. EPA-400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents", dated 5/92 5.2.2. NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels",
Rev. 2, dated January 1992 5.2.3. NUMARC, "Questions and Answers - Methodology for Development of Emergency Action Levels, NUMARC/NESP-007 Rev. 2", dated 6/93 5.2.4. NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" 5.2.5. NUREG-1228, "Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents" 5.2.6. USNRC EPPOS No. 1, "Emergency Preparedness Position (EPPOS) on Acceptable Deviations from Appendix 1 of NUREG-0654 Based Upon the Staff s Regulatory Analysis of NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels", dated 6/1/95 5.3.
Commitments 5.3.1. BVY-2002-015_22, Respond to item B.5.e 5.3.2. INS92140P1, "Revise AP 3125 to address concerns noted in NRC Inspection Report 50-271/92-14 per BVY 92-116" 5.3.3. INS9704_01, Address Concern With OP 3127 Requirement To Declare An Unusual Event Based On A Single Operations Indication As Being Overconservative (Seismic, Earthquake)
AP 3125 Rev. 19 Page 6 of 7
5.4.
Supplemental References 5.4.1. Letter, USNRC to VYNPC, "NRC Inspection No. 50-271/95-07", dated 6/12/95 5.4.2. Memo, E.C. Porter to Dist., "1989 Emergency Preparedness Exercise - Redundant Classification Declaration", dated 8/10/89 5.4.3. Memo, C.D. Thomas to M.J. Marian, "AP 3125, Appendix B, Fission Product Barrier Matrix Technical Basis", dated 3/30193 5.4.4. Memo, J.G. Parillo to S. Miller, "Monitor Indications for Failed Fuel", dated 6/27/95 5.4.5. OP 3540, Control Room Actions During an Emergency 5.4.6. OP 3541, Activation of the Technical Support Center (TSC) 5.4.7. OP 3542, Operation of the Technical Support Center (TSC) 5.4.8. OP 3544, Operation of the Operations Support Center (OSC) 5.4.9. OP 3545, Activation of the Emergency Operations Facility/Recovery Center (EOF/RC) 5.4.10. OP 3546, Operation of the Emergency Operations Facility/Recovery Center (EOF/RC) 5.4.11. OP 3547, Security Actions During an Emergency 6.0 FINAL CONDITIONS 6.1.
None 7.0 ATTACHMENTS 7.1.
Appendix A Chart of Categories and Events 7.2.
Appendix B Deleted AP 3125 Rev. 19 Page 7 of 7
THIS PAGE IS AN OVERSIZED DRAWING OR FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED:
APPENDIX A AP 3125 REV. 19 VY EALS WITHIN THIS PACKAGE NOTE: Because of this page's large file size, it may be more convenient to copy the file to a local drive and use the Imaging (Wang) viewer, which can be accessed from the Programs/Accessories menu.
D-1
10 CFR 50.54(q) Evaluation Checklist List of Emergency Plan Section(s)/Emergency Plan Implementing Procedure(s) or any other document to be evaluated. (Include Title and Revision No.):
AP 3125, rev. 19, Emergency Plan Classification and Action Level Scheme and EAL Technical Bases, rev. 4 A. Screening Evaluation Based on a review of the following questions, determine if the change has the potential to affect our ability to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50.
A "YES" answer to any part of the questions requires that a written evaluation be done to determine whether the effectiveness of the Emergency Plan was decreased as specified in Section B of this checklist.
A "NO" answer to all questions requires no written evaluation as specified in Section B of this checklist.
1..
Could the proposed change affect our ability to meet the following standards of 10 CFR 50.47(b):
(1) Assignment of Emergency Response Organization responsibilities YES NO (2)
Assignment of on-shift Emergency Response Organization personnelQDO YES (3)
Arrangements for Emergency Response Support and Resources "YES (4)
Emergency Classification and Action levels, including facility system and effluent parameters
@NO (5)
Notification Methods and Procedures YES (NO (6)
Emergency Communications among principal response organizations and the public (7)
Public Education and Information YES o
(8)
Adequacy of Emergency Facilities and Equipment YES j
(9)
Adequacy of Accident Assessment methods, systems and equipment YESNO (10) Plume exposure pathway EPZ protective actions YES N*
(11) Emergency Worker Radiological Exposure Control YES (
(12) Medical Services for contaminated injured individuals YES 9
(13)
Recovery and Reentry Plans YES ON (14)
Emergency response periodic drills and exercises YES (15) Radiological Emergency Response Training Y
(16) Plan development, review and distribution VYAPF 3532.01 AP 3532 Rev.
10 Page 1 of 3 RT No.
10.E06.171
10 CFR 50.54(q) Evaluation Checklist (Continued)
- 2.
Could the change affect our ability to meet the following requirements of Appendix E to 10 CFR 50.
(1)Section IV.
A - Organization (2)
Section IV. B - Assessment Actions (3)
Section IV. C - Activation of Emergency Organizations (4)
Section IV.
D - Notification Procedures (5)
Section IV.
E - Emergency Facilities and Equipment (6)
Section IV.
F - Training (7)
Section IV.
G - Maintaining Emergency Preparedness (8)
Section IV.
H -
Recovery YES SNO YES YES YES NCO)
YES NO YES YES B. Effectiveness Determination For applicable item 10 CFR 50.47(b) 4 & 9 and Appendix E.IV.B of Section A above, this change (DOES DOES NOT decrease the effectiveness of the Emergency Plan and DOES DOES NO-T) continue to meet the stated applicable standard or requiremen BASIS FOR ANSWER:
10 CFR 50.47(b)4 - changed EAL U-9-a consistent with NRC letter BVY-2002-015 (commitment BVY-2002-015 22) on site specific credible threat.
Clarified the bases document for EAL U-9-a and A-9-a consistent with NRC letter BVY-2002 015 and NEI endorsed changes.
Clarified bases document for EAL U-5-c for earthquake detection per EPRI guidelines.
Clarified bases document for EAL A-7-c, S-7-c and G-7-b on failure to scram based on 10 CFR 50.72 and NUREG 1022, rev. 1 section 3 guidance.
10 CFR 50.47(b)9 - implemented NRC Generic Letter 89-01, relocating programmatic controls of the Radiological Effluent Technical Specifications (RETS) to the Offsite Dose Calculation Manual (ODCM)
This included Radiological Effluents and Radiological Environmental Monitoring.
Appendix E.IV.B -
as above.
These changes do not decrease the effectiveness of the Emergency Plan.
VYAPF 3532.01 AP 3532 Rev.
10 Page 2 of 3 For each applicable (i.e., a "yes" answer specified) standard to 10 CFR 50.47(b) and Appendix E to 10 CFR 50 identified from Section A above, complete the evaluation form below to determine whether the change decreases the effectiveness of the Emergency Plan and whether it continues to meet the stated applicable standard or requirement.
A facsimile of the evaluation form may be used as needed and attached to this checklist.
10 CFR 50.54(q) Evaluation Checklist (Continued)
C. Conclusion (Fill out appropriate information)
The changes made do not decrease the effectiveness of the Emergency Plan and continue to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50.
0l The changes made do decrease the effectiveness of the Emergency Plan and decrease our ability to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50.
The following course of action is recommended:
El Revise proposed changes to meet applicable standards and requirements.
11 Cancel the proposed changes.
El Process proposed changes for NRC approval prior to implementation in accordance with 10 CFR 50.54(q).
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earthquake, emergency, security, RETS, ODCM SThis ch,:.mI-e does not af fcc'.t any othe do-uIents El This chanoce does affect other do!::um-aents.
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Prepared By:
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10 Page 3 of 3