ML022840301

Letter Forwarding Emergency Plan Revision 27 and Associated Emergency Plan Implementing Procedures

ML022840301
Person / Time
Site:	Palo Verde
Issue date:	09/26/2002
From:	Mauldin D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-04845-COM/SAB/RAS
Download: ML022840301 (9)

Text

-x LAMS David Mauldin Vice President Mail Station 7605 Palo Verde Nuclear Nuclear Engineering TEL (623) 393-5553 P 0 Box 52034 Generating Station and Support FAX (623) 393-6077 Phoenix, AZ 85072-2034 10 CFR 50.54(q) 102-04845-CDM/SAB/RAS September 26, 2002 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units: 1, 2, and 3 Dockets: 50-528, 50-529, 50-530 Licenses: NPF-41, NPF-51, NPF-74 PVNGS Emergency Plan Revision 27 and Associated Emergency Plan Implementing Procedures Enclosed please find revisions to the PVNGS Emergency Plan and associated Emergency Plan Implementing Procedures (EPIPs), submitted pursuant to 10 CFR 50.54(q).

Noteworthy changes made to the Emergency Plan and EPIPs include the addition of guidance for declaring Notifications of Unusual Event based upon credible security threats against the station, a new EPIP that provides instructions to ensure the Emergency Plan is implemented during security related emergency events, and the removal of the Site Manager position from Emergency Plan activities.

The Emergency Plan, EPIP-01, EPIP-02, EPIP-03, and EPIP-04 became effective on August 31, 2002. However, EPIP-09 became effective on July 26, 2002. While the implementation of EPIP-09 was prudent and timely from a physical security perspective, the subsequent failure to submit the change to the NRC within 30 days does not meet reporting requirements and is contrary to APS management expectations. Accordingly, A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway 0 Comanche Peak 0 Diablo Canyon 0 Palo Verde 0 South Texas Project 0 Wolf Creek */

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk PVNGS Emergency Plan, Revision 27 Page 2 APS is evaluating the condition in accordance with our corrective action process to ensure the condition does not recur.

Pursuant to Interim Compensatory Measure B.5.e of the NRC Order Modifying Licenses (February 25, 2002), APS has reviewed and validated the strategies for the escalation of Emergency Plan event classification and has revised the appropriate Emergency Plan and EPIPs based upon NUMARC/NESP-007 HU4 guidance previously approved 1 by the NRC.

I APS has evaluated the changes incorporated into Revision 27 of the Emergency Plan and related EPIPs and has determined the changes do not decrease the effectiveness of the Emergency Plan and the plan, as changed, continues to comply with the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50.

In accordance with 10 CFR 50.4(b) and NRC Regulatory Issue Summary 01-005, copies of this report are being forwarded to the NRC Region IVAdministrator and the resident inspector. Certain EPIPs contain information considered private or proprietary (i.e., names and telephone numbers for use during an emergency) which have been redacted in accordance with NRC Generic Letter No. 81-27.

Similarly, it is Arizona Public Service Company's position that the attached submittal, while not safeguards information, could be considered Sensitive Homeland Security Information and public release should be limited pursuant to 10 CFR §§ 9.17(a)(4) and 2.790(d)(1).

No commitments are being made to the NRC by this letter. Should you have questions regarding this submittal, please contact Thomas N. Weber at (623) 393-5764.

Sincerely, CDM/SAB/RAS/ras I NRC letter from Bruce A. Boger (Director, Division of Inspection Program Management, NRR) to Lynnette Hendricks (Director, Licensing Nuclear Generation, NEI) dated February 4, 2002.

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk PVNGS Emergency Plan, Revision 27 Page 3

Enclosures:

1. Summary of Changes - PVNGS Emergency Plan & Emergency Plan Implementing Procedures (EPIPs)

2. Revision 27 of the PVNGS Emergency Plan

3. Emergency Plan Implementing Procedure EPIP-01

4. Emergency Plan Implementing Procedure EPIP-02

5. Emergency Plan Implementing Procedure EPIP-03

6. Emergency Plan Implementing Procedure EPIP-04

7. Emergency Plan Implementing Procedure EPIP-09 cc: E. W. Merschoff (two copies / CD-ROM)

J. N. Donohew (CD-ROM)

N. L. Salgado (CD-ROM)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk PVNGS Emergency Plan, Revision 27 Page 4 NO. Pages with Redacted Information EPIP-01 7,10,13,16,17,23,46,114,115,118,119,129, 131,133, 137, 138, 148, 177, 180, 182, 185,433 EPIP-02 14, 32, 100,, 101, 104, 105, 115, 116, 117, 119, 123, 134,163,166,168, 419 EPIP-03 8, 30, 49, 117, 118, 121,122, 132 134, 136, 151,180, 183,185,188 426 EPIP-04 43, 111,112, 115, 116, 126 130, 134, 135, 145, 174, 177,179,430 EPIP-09 6,7,8,10, 14,15, 16, 18,19, 20, 24

ENCLOSURE 1

SUMMARY

OF CHANGES PVNGS EMERGENCY PLAN & EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

SUMMARY

OF CHANGES PVNGS Emergency Plan & Emergency Plan Implementing Procedures (EPIPs)

Document Page Nos. I Section(s) [ Description of Change Revised Security, Notification of Unusual Event section to encompass "notification of a credible EPLAN 39 of 92 Table 2 tra gis PVNGS."

threat against VG.

EPLAN 84 of 92 13.0 Added EPIP-09 to list of Emergency Plan Implementing Procedures.

EPIP-01 4 of 441 2.0 Deleted "Site Manager" position from responsibilities for emergency plan implementation.

EPIP-01 7 of 441 3.14 Deleted "Site Manager" notification from Affected Unit Shift Manager notifications.

EPIP-01 10 of 441 5.0 Deleted "Site Manager" notification from facility activation checklist.

Revised Table 7: Security Event Category, to include "notification of a credible threat against EPIP-01 44 of 441 Appendix A PV S.

PVNGS."

EPIP-01 49 of 441 Appendix B Added note regarding the use of Appendix G for protective action recommendations.

EPIP-01 178 of 441 Appendix I Added reference to EPIP-07 for applicable phone and fax numbers.

EPIP-01 181 of 441 Appendix I Clarified buildings and/or areas to be searched.

EPIP-01 184 of 441 Appendix J Clarified who may assist Security Director/Coordinator.

EPIP-01 185 of 441 Appendix J Clarified areas requiring search (sweeps) after a site evacuation.

EPIP-01 367 of 441 Appendix P Updated source documents.

EPIP-01 386 of 441 Appendix P Revised EAL Bases document in accordance with NUMARC/NESP-007.

EPIP-01 387 of 441 Appendix P Revised EAL Bases document in accordance with NUMARC/NESP-007.

EPIP-01 388 of 441 Appendix P Updated source documents.

EPIP-01 389 of 441 Appendix P Updated source documents.

Enclosure 1 Page 1 of 4

SUMMARY

OF CHANGES PVNGS Emergency Plan & Emergency Plan Implementing Procedures (EPIPs)

Document Page Nos. Section(s) Description of Change EPIP-01 390 of 441 Appendix P Updated source documents.

EPIP-02 30 of 427 Appendix A Revised Table 7: Security Event Category, to include "notification of a credible threat against PVNGS."

EPIP-02 35 of 427 Appendix B Added note regarding the use of Appendix G for protective action recommendations.

EPIP-02 164 of 427 Appendix I Added reference to EPIP-07 for applicable phone and fax numbers.

EPIP-02 167 of 427 Appendix I Clarified buildings and/or areas to be searched.

EPIP-02 170 of 427 Appendix J Clarified who may assist Security Director/Coordinator.

EPIP-02 171 of 427 Appendix J Clarified areas requiring search (sweeps) after a site evacuation.

EPIP-02 353 of 427 Appendix P Updated source documents.

Revised Initiating Condition, PVNGS Emergency Action Level & Technical Basis sections in accordance with NUMARC/NESP-007.

EPIP-02 373 of 427 Appendix P Updated source documents.

EPIP-02 374 of 427 Appendix P Updated source documents.

EPIP-02 375 of 427 Appendix P Updated source documents.

EPIP-02 376 of 427 Appendix P Updated source documents.

Revised Table 7: Security Event Category, to include "notification of a credible threat against EPIP-03 47 of 444 Appendix A PVNGS."

EPIP-03 52 of 444 Appendix B Added note regarding the use of Appendix G for protective action recommendations.

Enclosure 1 Page 2 of 4

SUMMARY

OF CHANGES PVNGS Emergency Plan & Emergency Plan Implementing Procedures (EPIPs)

Document Page Nos. Section(s)__ Description of Change EPIP-03 181 of 444 Appendix B Added reference to EPIP-07 for applicable phone and fax numbers.

EPIP-03 184 of 444 Appendix B Clarified buildings and/or areas to be searched.

EPIP-03 187 of 444 Appendix J Clarified who may assist Security Director/Coordinator.

EPIP-03 188 of 444 Appendix J Clarified areas requiring search (sweeps) after a site evacuation.

EPIP-03 370 of 444 Appendix P Updated source documents.

Revised Initiating Condition, PVNGS Emergency Action Level & Technical Basis sections in accordance with NUMARC/NESP-007.

EPIP-03 390 of 444 Appendix P Updated source documents.

EPIP-03 391 of 444 Appendix P Updated source documents.

EPIP-03 392 of 444 Appendix P Updated source documents.

EPIP-03 393 of 444 Appendix P Updated source documents.

Revised Table 7: Security Event Category, to include "notification of a credible threat against EPIP-04 41 of 444 AppendixA PVNGS."

EPIP-04 46 of 444 Appendix B Added note regarding the use of Appendix G for protective action recommendations.

EPIP-04 175 of 444 Appendix I Added reference to EPIP-07 for applicable phone and fax numbers.

EPIP-04 178 of 444 Appendix I Clarified buildings and/or areas to be searched.

EPIP-04 181 of 444 Appendix J Clarified who may assist Security Director/Coordinator.

EPIP-04 182 of 444 Appendix J Clarified areas requiring search (sweeps) after a site evacuation.

Enclosure 1 Page 3 of 4

SUMMARY

OF CHANGES PVNGS Emergency Plan & Emergency Plan Implementing Procedures (EPIPs)

Document Page Nos. Section(s) Description of Change EPIP-04 364 of 444 Appendix P Updated source documents.

EPIP-04 383 of 444 Appendix P Revised Initiating Condition, PVNGS Emergency Action Level & Technical Basis sections in accordance with NUMARC/NESP-007.

EPIP-04 384 of 444 Appendix P Updated source documents.

EPIP-04 385 of 444 Appendix P Updated source documents.

EPIP-04 386 of 444 Appendix P Updated source documents.

EPIP-04 387 of 444 Appendix P Updated source documents.

Note: The text included in this EPIPis new. The EPIPnumber (EPIP-09)was previously used and laterdiscontinued. To maintain the numericalsequence of EPIPrevisions, EPIP-09 is being EPIP-09 1 through 24 All re-issued as revision 2.

of 24 This procedure provides direction for the Shift Manager (SM) / Emergency Coordinator (EC) to ensure the Emergency Plan is implemented during security related emergency events.

Enclosure I Page 4 of 4