ML032250079

Transmittal of Entire EPIP Document (Copy 28)

ML032250079
Person / Time
Site:	Duane Arnold
Issue date:	07/31/2003
From:	Dunlap K Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML032250079 (14)

Text

£ NMClI Immiftted to NudearExcecfen DAEC EMERGENCY PLANNING DEPARTMENT PROCEDURE TRANSMITAL ACKNOWLEDGEMENT MEMO (TAM-55)

To: NRC-NRR Document Control Desk US NRC Washington DC 20555 Re: Entire EPIP Document (Copy 28)

PSM

Title:

nfa Distribution Date: 07/31 /2003 Effective Date of Change: 08/05/2003 Return by: 08/12/2003 Please perform the following to your assigned manual. If you have any questions regarding this TAM please contact Don A. Johnson at 319-851-7872.

REMOVE INSERT EPIP Table of Contents Revision Rev. 138 Rev. 139 EPIP 1.1 (PWR: 20824) Rev. 19 Rev. 20 EPIP EAL-03 (PWR: 21687) Rev. 2 Rev. 3 EPIP EAL-05 (PWR: 21692) Rev. rLa Rev. 0 EPIP NOTE-05 (PWR: 21824) Rev. 6 Rev. 7 ERFORMED BY:

rint Name Sign Name Date lease return to: K. Dunlap PSC/Emergency Planning 3313 DAEC Rd.

Palo, IA 52324 74o (f5 To be completed by DAEC EP personnel only:

Date TAM retumed:

EPTools updated:

iRGENY PPLE EME-: TIN P ,. EPIP 1.1 DETERMINATION OF EMERGENCY ACTION LEVELS Rev. 20 Page 1of 9 Usage Level REFERENCE I Effective Date: to TEHNICAL -E-I Prepared and Date:

Verified by: _ _ __ _ _ f /e Validated by: Date: I Eme encyelanning Staff I

PROCEDURE AP.PROVAL I am responsible for the technical content of this procedure.

Approved by.  : Date:

Manager, Emergency Planning

EMERGEC PLAN IMPLEMENTINGPR0C X EPIP 1.1 DETERMINATION OF EMERGENCY ACTION LEVELS Rev. 20 Page 2 of 9 Table of Contents Page 1.0 PURPOSE ......................................... 3 2.0 DEFINITIONS .......................................... 3 3.0 INSTRUCTIONS ......................................... 4 3.1 OVERVIEW ......................................... 4 3.2 EVENT CLASSIFICATION .......................................... 5 3.3 CRITERIA FOR EMERGENCY CLASSIFICATION CHANGES ........ 7 4.0 RECORDS .......................................... 9

5.0 REFERENCES

......................................... 9 6.0 EPIP FORMS...............................................................................................9

MERGENC PLANEY 0 EPIP 1.1 DETERMINATION OF EMERGENCY ACTION LEVELS Rev. 20 Page 3 of 9 1.0 PURPOSE (1) Provides guidance to the Operations Shift Manager (OSM), Emergency Coordinator (EC), or Emergency Response and Recovery Director (ER&RD), as applicable, when determining a need to declare or retract an emergency event at DAEC.

2.0 DEFINITIONS (1) Emergency Action Level (EAL) - A pre-determined, site-specific, observable threshold for a plant Initiating Condition that places the plant Ina given Emergency Classification Level. An EAL can be: an instrument reading, an equipment status indicator, a measurable parameter (on-site or off-site), a discrete observable event, results of analyses, entry into specific emergency operating procedures, or another phenomenon which, Hit occurs, Indicates entry into a particular Emergency Classification Level.

(2) EAL Technical Basis Document - This document was developed to:

• Provide dear documentation of how NEI generic guidance was applied in the development of DAEC upgraded EALs.

• Provide justification of any exceptions or additions to NEI generic guidance as It is applied to DAEC.

• Facilitate the regulatory approval of the upgraded EALs that is required under IOCFR50 Appendix E.

(3) Emergency Classification Level - These are taken from 10CFR50 Appendix E.

They are, Inescalating order:

• (Notification of) Unusual Event (UE): Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plantIISFSI. No releases of radioactive material requiring off-site response or monitoring are expected unless further degradation of safety systems occurs.

• Alert: Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant1lSFSI. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

• Site Area Emergency (SAE): Events are in progress or have occurred which involve an actual or likely major failure of plant functions needed for the protection of the public. Any release is not expected to exceed EPA Protective Action Guideline exposure levels except near the site

I

EM-^yERG4EXNCYPLAN PLEMENTN EPIP 1.1 DETERMINATION OF EMERGENCY ACTION LEVELS Rev. 20 Page 4 of 9 boundary.

General Emergency (GE): 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 Guideline exposure levels offsite for more that the immediate site area.

(4) ISFSI - Independent Spent Fuel Storage Installation facility and associated cask loading and storage activities.

(5) Retraction - The recanting of an Emergency Action Level that was declared due to an indeterminate condition.

3.0 INSTRUCTIONS 3.1 OVERVIEW (1) The Control Room, TSC, and EOF staff shall evaluate plantISFSI conditions to determine whether any EAL Threshold Values have been met. The OSMIECIER&RD should declare the appropriate EAL within 15 minutes once indications are available that the Threshold Value for an EAL has been exceeded.

(2) The OSMIEC/ER&RD shall ensure requisite notifications are made within the 15-minute requirement, per EPIP 1.2 'Notification'.

(3) Plant assembly and site evacuation decisions shall be made in accordance with EPIP 1.3, 'Plant Assembly and Site Evacuation'.

(4) The EC/OSM/ER&RD shall review and approve the emergency classification to determine if events/conditions have changed that may warrant upgrade, declassification, termination or retraction.

(5) The EC/OSM/ER&RD shall ensure activation of the Emergency Response Organization is underway/completed, as required.

(6) Ifan EAL has been declared due to an indeterminate condition and subsequent investigation/evaluation discovers the condition did not exist, the event may be retracted. Notifications shall be made per EPIP 1.2 'Notification'.

i - S EMERGENCY PLAN IMPLEMENTING PROCEOuIE AEPIP 1.1 DETERMINATION ,OF EMERGENCY ACTION LEVELS Rev. 20 Page 5 of 9 3.2 EVENT CLASSIFICATION (1) Emergency conditions are classified in an ascending order of severity as follows:

NOTIFICATION OF UNUSUAL EVENT (Recognition Category AU, FU, HU;..SUEU)

• ALERTi(Recognitlon Category AA, FA, HA, SA)

• SITE AREA EMERGENCY (Recognition Category AS, FS, HS, SS)

' -GENERAL'EMERGENCY (Recognition Category AG, FG, HG, SG)

(2) When a suspected emergency condition occurs, the EC/OSM/ER&RD and their associated Staff, siall make the initial analysis and determination of the classification, referring to the appropriate EAL tables in Appendix I and the EAL Basis Document The appropriate EAL should be declared within 15 minutes once indications are available that the Threshold Value for an EAL has been exceeded.

Appendix 1 of the EPIP's contains the five tables, EAL-01 through EAL-05, covering Emergency Action Levels.

(3) To determine an EAL: Categorize the general type of event, referring to the EAL tables, verify determinations by referring to the EAL Technical Basis Document.

(4) If the OSM has been fulfilling the responsibilities of the EC, upon declaring the emergency classification, the event, the time declared and the action(s) taken shall be logged in the&Shift Manager's Log.

(5) Other events not specifically included in this procedure which may be based on plantASFSI prognosis, weather, or other external events, as well as! events that have a high likelihood of occurrence may be classified as a NOTIFICATION OF UNUSUAL EVENT, ALERT, SITE AREA EMERGENCY or GENERAL EMERGENCY at the discretion of the EC/OSMIER&RD.' The primai' ry consideration for classification of these events shall be to protect the health and safety of sitepersonnel and the public.

(6) The highest emergency classification for which an Emergency Action Level (EAL) is CURRENTLY met should be declared.

• If an action level for a higher classification was exceeded, but the situation has been resolved prior to offsite reporting; the higher classification level should be REPORTED to the offsite agencies and

• th- NRC, but SHOULD NOT be declared.

• The notification must indicate the CURRENT classification, the period of time that the higher classification existed and the mitigating conditions that caused the reduction in the emergency classification.

J IEPIP 1.1 EMERGENCY PLANIMPLENTING PROCEDURE DETERMINATION OF EMERGENCY ACTION LEVELS Re.209 Page 6 of 9 (7) Reclassificabon shall be reviewed and approved by the EC/OSM/ER&RD.

• Reclassification should be based upon the guidance provided in the EAL Tables and Reference 1.

• The EC/OSM should consult with the following personnel, if available, during such evaluations:

• Site Radiation Protection Coordinator (SRPC).

• TSC Operations Supervisor

• Tech and Engineering Supervisor

• Emergency Response and Recovery Director

• The ER&RD should consult with the following personnel:

• Assistant ER&RD

• Emergency Coordinator

• EOF OPS Liaison

• The EC/OSM shall ensure that offsite agencies are notified of the reclassification in accordance with EPIP 1.2, 'Notification'. If the Emergency Operations Facility (EOF) has been declared operational, the ER&RD shall assume this responsibility, unless otherwise advised.

• If the OSM is fulfilling the responsibilities of the EC, reclassification of an event shall be documented in the Operations Shift Manager's Log or the TSC Supervisor's Log as appropriate.

(8) As plantISFSI conditions change, the EC/OSM/ER&RD shall ensure that plant/ISFSI status is monitored and the EAL Tables and EAL Basis Document are constantly consulted in order to adjust the emergency classification, as appropriate. The appropriate EAL should be declared within 15 minutes once indications are available that the Threshold Value for an EAL has been exceeded.

I S: *iI W~EME~GEN PLN NTING EPIP 1.1 DETERMINATION OF EMERGENCY ACTION LEVELS Rev. 20 Page 7of 9 3.3 CRITERIA FOR EMERGENCY CLASSIFICATION CHANGES (1) As planVISFSI conditions change, consider:

-* The probability that planVISFSI conditions will continue to improve.

• The probability that planVISFSI conditions might worsen, thereby necessitating upgrading the emergency classification once the emergency has been downgraded.

• The need to staff all or some of the emergency response facilities.

• Evaluating existing conditions with respect to the criteria established for each emergency classification per the EAL Tables.

• The control or termination of non-routine releases of radioactive material to the environment

• The control or cessation of any fire, flood, earthquake, or similar emergency conditions.

• The specified corrective action has been taken, or the plant has been

- placed in the appropriate operating mode.

• All required notifications are completed.

• The TSC technical staff has evaluated the plantISFSI status with respect to the Technical Specifications/applicable 10CFR 72 Certificate of Compliance requirements and recommends downgrading the emergency classification.

(2) An emergency condition can be considered resolved, and a Recovery Organization established, if necessary, when the following guidelines have been met or addressed:

• Existing conditions no longer meet the emergency classification criteria and it appears unlikely that conditions will deteriorate further.

• No surveillance relative to offsite protective actions is needed, except for the control of foodstuffs, water, and offsite contamination, or environmental assessment activities.

EMERGENCY PLAN IMPLEME"TING PROCEDURI EPIP 1.1 DETERMINATION OF EMERGENCY ACTION LEVELS Rev. 2C I

Page 8 of 9

• Radiation levels in affected in-planVISFSI areas are stable or decreasing to acceptable levels.

• Releases of radioactive material to the environment are under control or have ceased. - - I

• No Emergency Operating Procedure (EOP) entry condition exists.

• The reactor is in a stable and safe shutdown condition, and long-term core cooling is available as required.

• The control or cessation of any fire, flood, earthquake, or similar emergency conditions.

• All EAL notifications have been completed.

• Offsite conditions will not limit access of personnel and support resources.

I

• Discussions have been held with the Nuclear Regulatory Commission (NRC), State and local organizations with FEMA input as necessary, and agreement has been reached to terminate the emergency.

• The TSC technical staff has evaluated the plantVISFSI status with respect to the Technical Specifications/applicable 10CFR 72 Certificate of Compliance requirements and concurs with the termination of the emergency.

j

EMERGENCY PLANIMPEMENTING PROCEDUR^Et. EPIP 1.1 DETERMINATION OF EMERGENCY ACTION LEVELS Rev. 20 Page 9 of 9 4.0 RECORDS All logs, forms, and records generated must be forwarded to the EP Department and retained in accordance with QA Record Retention requirements. Authorization for disposal shall be obtained from the NRC.

5.0 REFERENCES

(1) DAEC Emergency Plan (2) DAEC EAL'Technical Basis Document (3) DAEC Technical Specifications (4) Emergency Operating Procedures (EOPs)

(5) Updated Final Safety Analysis Report (6) EPIP 1.2, 'Notifications' (7) 10CFR50 AppIendix E (8) IOCFR 72.32(c) and (d)

(9) NEI Methodology for Development of Emergency Action Levels NUMARC/NESP-007 NEI 99-01 Revision 4, May 1999/September 2002 (10) NEI Methodology for Development of Emergency Action Levels NUMARC/NESP-007 NEI 97-03 August 1997 6.0 EPIP FORMS TABLE FORM No.

Abnormal Rad LevelslRadioactive Effluent EAL-01 Fission Barrier Table EAL-02 Hazards and Other Conditions Affecting Plant Safety EAL-03 System Malfunction EAL-04 Independent Spent Fuel Storage Installation (ISFSI) EAL-05 I

EAL TABLE INDEPENDENT SPENT FUEL STORAGE INSTALLATION EVENT TYPE 4 UNUSUAL EVENT EUI Damage To A Loaded Cask Confinement Boundary Operating Modes: Not applicable Any one of the follovng natural phenomena events with resultant visible damage to or toss of a loaded cask confinement boundary

• Report by pant personnel of a tornado strike.

• Report by plant personnel of a seismic event OR The following accident condition with resultant visible damage to or loss of a loaded cask confinement boundary.

• A loaded transfer cask Isdropped as a result of normal handling or transporting.

OR INDEPENDENT Any condition Inthe opinion of the EC/OSM SPENT FUEL that indicates loss of loaded fuel storage cask STORAGE confinement boundary.

INSTALLATION (ISFSI) EU2 Confirmed Security Event With Potential Loss Of Level Of Safety Of The ISFSI Operating Modes: Not applicable Suspected sabotage devise affecting a horizontal storage module, dry shielded canister or transfer cask, or found inside ISFSI protected area.

OR Confirmed tampering with a horizontal storage module, dry shielded canister or transfer cask.

OR A hostage situation that disrupts normal ISFSI operations.

OR

, Civil disturbance or strike that disrupts normal ISFSI operations.

OR Internal disturbance that Isnot short lived or is not a harmless outburst involving one or more Individuals within the ISFSI protected area.

OR Intrusion Into the ISFSI protected area by a hostile force.

OR Any security event of Increasing severity that persists for k 30 minutes.

• Credible bomb threats

• Extortion

• Suspicious fire or Explosion

• Significant Security System Hardware Failure

• Loss of Guard Post Contact I.

EAL-05 Rev. 0

_________ . DAEC EMERGENCY ACTION LEVEL NOTIFICATION FORM INITIAL ROLL MESSAGE 1. STATUS- 2. FACILITY IN COMMAND & 3. ACCIDENT CLASSIFICATION CALL INITIATED CONTROL (Al UNUSUAL EVENT Time: [Al ACTUAL [A) Control Room .....2222 [B] ALERT

[B] TSC ............ 3333 [C] SITE AREA EMERGENCY ynn County Date: [B] DILLI(or from [C) EOF ....... . . 4444 GENERALEEMERGENCY E3 Iowa BAD SIMULATOR) ~~~~~~~~~~(EI RECOVERY 0 Iowa EMD _ MULATOR) [D] Simulator ......... 1111 M CANCELLATIONlTERMINATION (ff this notgfication Is for a PAR change ONLY, write -NA for Information In Block 4.)

4.. EAL CLASSIFIED TIME:_ _ DATE:_

(For *EAL CLASSIFiED, fill In blank below AND circle appropriate letter or number applicable under Category, ClassIficatIon and Sequence. For EALs with multiple Initiating conditions, speciry In Block 12 which Initiating condition Is applicable.)

EAL Category (circle one) Classification (cirde one) Sequence # (circle one)

A F I H I S E U I A I S l G 1 2 3 14 5 6 1 7

6. RELEASE IN PROGRESS DUE TO THIS EVENT? 0 YES (PROCEED TO BLOCK 6) 0 NO (PROCEED TO BLOCK 0) 1

6. AIRBORNE RELEASE TO ENVIRONMENT 7. TYPE OF RELEASE (mark all that apply) S. PROJECTED DURATION OF RELEASE:

[Al BELOW FEDERAL LIMITS (No High High (Al RADIOACTIVE AIRBORNE (FILTERED) [A) UNKNOWN (4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> default)

[B) AT ORN ABOVE, FEDERAL LIMITS (High High [B] RADIOACTIVE AIRBORNE (UNFILTERED) [B] RELEASE DURATION hour(s)

KAMAN alarm) IC] RADIOACTIVE LIQUID S. WIND SPEED: MILES/HR (50m value preferred) 10.WIND DIRECTION: FROM DEGREES (50m value preferred)

11. UTILITY PROTECTIVE ACTION RECOMMENDATIONS (ftlhisnotfricationis fore PAR change ONLY, note time e date. Otherwise write 'lNA'In TiME' and 'DATE' In Block 11.)

PAR DETERMINATION @ TIME: DATE_ _

1nusualO ventf:  ! ir;- St;e--Ard-E Emergen-y rMA] No actions ((B] No actions El [C] Activate the Prompt Alert and Notification System AND Place dairy animals recommended recommended within the entire EPZ on stored feed and covered water.

n IalEMergqency ......

ElD] I Q[ElJ ELF-Default Recommendations Iom EPIP 3.3, O l Dose prqectlons Ž1 REM TEDE or 5 REM CDE Dose projections 1 REM TEDE or 5 REM dose prfections Ž1 REM TEDE or 5 REM CDE l 2-5 miles fromsite boundary. CDE @5-10 miles fom site boundary.

@ 0-2 miles from site boundary.

Activate the Prompt Alert and Notification Activate the Prompt Alert and Notification Activate the Prompt Alert and Notification System, Place dairy animals within the entire System, Place dairy animals within the entire System, Place dairy animals In the entire EPZ EPZ on stored feed and covered water EPZ on stored feed and covered water on stored feed and covered water AND AND AND Evacuate within a 2 mile radius and to 5 Evacuate within a 2 mfle radius and to 5 Evacuate within a 2 mile radius, evacuate miles In the downwind subareas. miles In the downwind subareas, and shelter from 2 miles to EPZ edge in downwind downwind subareas from 5 miles to EPZ subareas, and shelter as appropriate beyond edge. EPZ edge.

12. ADDITIONAL INFORMATION:

13. APPROVED BY:

(OSM, EC, or ER&RD)

(DATE) (lIME)_l I

14. STATE PROTECTIVE ACTIONS 0-2 m 2-6 m 6-10 m 10-EPZ lShelterSubareas(clrcleapproprlatesubareas) 1 2, 3, 4, 5, 6, 7, 8 9,10,11,12,13,14,15,16,17,18,19,20,21,22 23,24 EvacuateSubareas(circleappropriatesubareas) 1 2, 3, 4, 5, 6, 7, 8 9,10,11,12,13,14,15,16,17,18,19,20,21,22 23,24 MESSAGE TRANSMITTED BY: FINAL ROLL CALL IINITIALS)

____________ Facility: Time: _ Benton: Unn: Iowa EMD:

NOTE405 1of 2 7 Rev.

DAEC EMERGENCY ACTION LEVEL NOTIFICATION FORM INSTRUCTIONS FOR USE Complete the notification form as follows:

INITIAL ROLL CALL - Dial 9999 (#S to stop the ringing) and mark appropriate box for the applicable agency as they answer the initial roll call.

MESSAGE INITIATED - Document the time and date you get at least one agency on the phone.

Read Items 1-13 on NotificationMessaae Above - Read message from Item I through to Item 13, (For example, 'One, bravo, drill. Two, delta, simulator..." etc.

Items 1. 3. 4. 5. 6. 7. 9. 10 & 11 MUST be accurate The accuracy of these items will count towards our DEP Performance Indicator. If any of these Items are In error, the Notification Is considered Inaccurate.

1. STATUS - Mark the letter corresponding to the appropriate status description. Unless an ACTUAL event is taking place, ALL Drills, Exercises, Table Top Drills and LORT notifications will be marked as 'DRILL".

2. FACILITY IN COMMAND & CONTROL - Mark letter corresponding to the facility in command & control. Phone numbers listed are Microwave numbers for the facility.

3. ACCIDENT CLASSIFICATION - Mark the letter corresponding to the latest classification issued by the ERO facility.

4. EAL CLASSIFIED - Fill in the time and date at which this new accident classification was determined. If this notification is for a PAR change ONLY, write 'NIA for information in Block 4.

EAL - Fill in and circle the current On-Site Emergency Action Level (EAL) code number.

5. RELEASE IN PROGRESS DUE TO THIS EVENT? - Mark if a release is occurring due to this event and proceed to the applicable block.

6. AIRBORNE RELEASE TO ENVIRONMENT - Mark the letter corresponding to the appropriate description.

7. TYPE OF RELEASE - Mark the letter(s) corresponding to the appropriate release type(s). Filtered releases flow through any orierable Standby Gas Treatment System, or Offgas System, to Offgas stack. An unfiltered release is one that is entering the environment by a path other than the SBGT System. If a RADIOACTIVE LIQUID release is in progress, contact the Site Rad Protection Coordinator for additional information and support. If the release has multiple paths to the environment, mark ALL appropriate types of releases.

8. PROJECTED DURATION OF RELEASE - Mark the letter corresponding to the appropriate release duration. If the release duration is known, indicate appropriate hours and minutes that the release will last.

9. WIND SPEED - Fill in the wind speed in milesihour. The 50 meter value is the preferred value to use. If it is unavailable then use the 10 meter value. If both are unavailable, contact the National Weather Service @ 1-800-803-9357

10. WIND DIRECTION - Fill in the direction in degrees, from where the wind is originating. The 50 meter value is the preferred value to use. If it is unavailable then use the 10 meter value. If both are unavailable, contact the National Weather Service

@ 1400403-9357

11. PROTECTIVE ACTION RECOMMENDATIONS - Check one of the boxes corresponding to the appropriate default Protective Action Recommendation. Refer to EPIP 3.3 for guidance on Protective Action decision-making.

PAR DETERMINATION - If this notification is for a PAR change ONLY, note time & date. Otherwise write

'N/A' in 'TIME and 'DATE' in Block 11.

12. ADDITIONAL INFORMATION - Additional information should be included when:

• A wind shift results in additional downwind subareas (see EPIP 3.3 Att. 2)

• Corrections to current State/County notifications are made

• Specify initiating condition for EALs with multiple initiating conditions

• Other information deemed necessary to inform the State and Counties

13. APPROVED BY - Authorizing signature of OSM. EC, or ER&RD.

14. STATE PROTECTIVE ACTIONS - IF AVAILABLE, circle subareas the STATE has chosen to shelter or evacuate. If not available, leave this section blank.

MESSAGE TRANSMITTED BY - Applicable Communicator writes in their name, ERO facility in Command & Control, and time message completed.

FINAL ROLL CALL - Enter initials of agency representatives receiving this notification.

NOTE-05 2of 2 Rev. 7