ML051030096
| ML051030096 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 03/30/2005 |
| From: | Connecticut Yankee Atomic Power Co |
| To: | Document Control Desk, NRC/FSME |
| References | |
| +kBR1SISP20060124, FOIA/PA-2005-0203 | |
| Download: ML051030096 (69) | |
Text
Connecticut Yankee Atomic Power Company Date of Distribution: 03-30-05 Notice of Receipt of Emergency Plan Change No.:
05-01 To:
Copy No.:
Document Control Desk Div. of Lic.
USNRC Copy #89 (code Z)
Please revise your controlled copy per instructions below:
INSERT:
Emergency Plan, Revision 7, effective 03-30-05 ATTACH:
new cover and spine to your controlled manual and note the new controlled copy number, if applicable REMOVE:
REPLACE This acknowledges receipt of the revisions listed above. In addition, all superseded pages have been removed and destroyed.
Signature:
Date:
Please Return This Sheet to the Administrative Office, Connecticut Yankee Within Thirty (30) Days.
CONNECTICUT YANKEE ATOMIC POWER COMPANY CYAPCO HNP Emergency Plan Document Control Desk Div. of Lic., USNRC Controlled Copy # 89
CONNECTICUT YANKEE ATOMIC POWER CO.
Emergency Plan CONTROLLED COPY #89 Document Control Desk
MAR 3 0 2005 I
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t CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT EMERGENCY PLAN REVISION 7
SAFElY INDEPENDENT REVIEWED DATE
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Providing accountability of personnel in the ISFSI OCA and Power Plant Industrial Area.
Conducting Relocation of site personnel as directed by the ISS.
5.2 Auwmented Positions Additional personnel will be called in at the discretion of the ISS to assist the on-shift organization. They may provide support to the ISS to assess radiological conditions, develop plans to correct technical issues, and assist with any recovery activities.
5.3 State and Federal Government Response Upon request, local government agencies (i.e., fire companies, police, and ambulances) will respond to the ISFSI or to the Power Plant site in the event of an emergency. State and Federal Government response is expected to be limited to recording the notification of the emergency, periodically receiving updated information on the emergency, and coordinating public information news releases, if necessary.
If required, provisions exist for the State of Connecticut to halt traffic on the roads leading to the Power Plant and ISFSI sites. The ISS has the authority to request such support if it is needed.
5.4 Other Organizations Providing Assistance Assistance from other commercial companies/agencies may be required. Letters of agreement have been developed to describe outside company and agency assistance and services, if required. These letters of agreement are kept current to reaffirm availability of assistance. The letters of agreement are listed in Appendix B.
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MAH 3 0 2005 Figure 5-1 Emergency Response Organization
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LIAR 3 0 2005 6.0 EMERGENCY MEASURES Emergency measures begin with the identification and classification of an emergency.
Emergency measures include assessment actions, corrective actions, and recommendation of on-site personnel protective actions. The Emergency Action Levels (EALs) have predetermined values or conditions which, when met or exceeded, require declaration of the emergency classifications, notification of State and NRC officials.
These measures are described in detail in the Emergency Operating (EO) Procedures used to implement the Emergency Plan.
6.1 Emergency Condition Recognition and Classification Recognition and classification of the incident are the responsibility of the ISFSI Shift Supervisor (ISS). When conditions specified in an EAL are determined to have existed the ISS declares an Unusual Event. Once the emergency classification is declared, the appropriate EO Procedures are implemented.
6.2 Emergency Response Organization (ERO) Responsibilities Certain conditions, as defined in Section 4.0, may occur which require the declaration of an Unusual Event. Upon classification and declaration of an Unusual Event, the ISFSI Shift Supervisor (ISS) assumes the position of the Emergency Director (ED). The on-shift organization is responsible for performing the response actions.
Additional personnel may be mobilized at the discretion of the ISS to augment the on-shift organization and assist in the implementation of corrective actions to mitigate the consequences of the event.
The following is a general summary of the actions taken in response to an Unusual Event:
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.0 ISFSI Shift Supervisor (ISS) classifies the event.
Emergency classification is announced to on-shift personnel.
On-shift personnel respond as directed by the ISS.
Key personnel are notified.
NRC/State of Connecticut is notified.
Corrective actions are implemented If necessary, emergency medical, local fire department, or law enforcement agencies are contacted to request additional resources.
If necessary, additional support from site personnel will be requested.
The ISS will update or terminate the event as appropriate.
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M, AR 3 0 2005 6.3 Radiological Assessment Initial response to an event will be to determine the significance and the potential impact to site personnel and the general public and ensure appropriate protective-measures are taken. Subsequently the cause will be ascertained and actions taken to mitigate further consequences. Radiation Protection Personnel will be contacted to initiate general area radiation and contamination surveys, as needed, to determine the actual extent of any radiological concern. The ISFSI staff will analyze results of surveys and will formulate an action plan to mitigate the event and restore the facility to its normal condition. Survey data will also be used, as appropriate, to mitigate the consequences of the event.
Following termination of the event, environmental surveys (including, but not limited to water, soil, vegetation, etc.) may be required to determine the long-term impact of the event.
6.4 Protective Actions 6.4.1 Accountability/Evacuation If determined to be necessary, the ISS can initiate an accountability of all personnel in the Power Plant or ISFSI site areas. Non-essential personnel, contractors and visitors will be relocated to a safe area.
Accountability of personnel will be accomplished within 60 minutes.
Appropriate steps will be taken to locate any unaccounted for personnel.
The Security staff will coordinate accountability of personnel. The reports are provided to the ISS.
6.4.2 Access Control Access control to the ISFSI will be established at pre-designated locations in an emergency as necessary.
Access to the Power Plant site will be controlled as necessary.
6.4.3 Aid to Affected Personnel Off-site emergency medical responders may be requested to report to the scene and initiate first aid treatment to stabilize injured personnel and prepare for transport to a medical facility (see listed Letter of Agreement in Appendix B). A First Aid Kit is located at the ISFSI Building; Injured personnel will be assessed to determine if a life threatening condition exists and ensure appropriate actions are taken. In addition, environmental factors will be taken into account regarding the need to-stabilize the patient in place or remove to a safer area (i.e., lower radiation levels, etc.).
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MAR 3 0 2C-0 6.4.4 Personnel Radiation Monitoring Personnel working in known or potential radiation areas will comply with appropriate radiation, protection procedures.
6.4.5 Coordination with Offsite Agencies Upon request, Local government agencies and supporting organizations (i.e., CT DEP, Fire, Police, and Ambulance) will respond to the site during an emergency. All actions of off-site responders will be coordinated by the ISS.
6.4.6 Emergency Action This plan permits emergency response personnel to implement reasonable action that departs from a License Condition or a Technical Specification in an emergency when this action is immediately needed to protect the public health and safety and there are no actions consistent within the License Conditions and Technical Specifications that can provide adequate or equivalent protection immediately apparent.
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MIAR 3 0 2005 K>.7.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENT e ^
7.1 Emergency Response Facility The ISFSI Monitoring Station Building is the primary facility where ISFSI conditions are monitored and corrective actions are developed to mitigate any abnormal occurrence. Emergency conditions are managed by the ISS at this location.
The ISFSI Monitoring Station Building also serves as the Technical Support Center (TSC). The adjacent operations support trailer provides additional space when needed.
The ISFSI Monitoring Station Building and support office trailer provide space for the designated members of the Emergency Response Organization and support staff to conduct analysis and support functions in response to the event. The following functions are coordinated from the ISFSI Monitoring Station Building:
emergency management, offsite notifications and communication, and facility restoration planning.
The ISFSI Monitoring Station Building and support office trailer are sized to accommodate personnel performing communications, radiological assessment, and general technical evaluations and analysis tasks. Communication systems are available to allow interaction with offsite organizations, as necessary.
7.2 Assembly area
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Personnel directed to evacuate the Protected Area will be directed to report to a safe area designated by the ISS.
7.3 Emergency Equinment Appropriate emergency equipment has been assembled and stored in the ISFSI Monitoring Station Building and support office trailer for use by the ERO.
Required supplies are inventoried to ensure operability and availability at all times.
Controlled copies of facility documents (Drawings, Procedures, Technical Specifications, SAR, etc.) are maintained in the ISFSI Monitoring Station Building. This information is readily available for the Emergency Response Organizatioin a'nd support staff use.
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MAR 3 0 2005 7.4 Communication SVstems 7.4.1 Onsite Communication Systems:'-
The commercial telephone system is the primary means of onsite communication during an emergency. This system has an independent backup power configuration, which incorporates a combination of automatic and manual transfer switches between batteries and an emergency propane generator to ensure uninterrupted operation on a loss of normal power to the ISFSI telephone system.
Communication between the ISFSI Monitoring Station Building and the Power Plant site is through the commercial telephone system or radio.
The ERO is equipped with portable radios for onsite communications, as required. One or more licensed frequencies are used for routine communications, and one or more state police frequencies are used for offsite routine and emergency communications.
7.4.2 Offsite Communication Systems Commercial telphones are used to establish communications between the ISFSI Monitoring Station Building and the Connecticut Office of Emergency Management (OEM) and CT DEP. This is the primary method of informing the State of Connecticut of a declared emergency at the ISFSI.
In the event the commercial telephone circuits fail, the Connecticut OEM and DEP can be contacted via satellite phone from the ISFSI Monitoring Station Building.
In the event of an emergency at the Power Plant site or at the ISFSI, the NRC will be notified using the ENS, satellite or commercial telephone system in accordance with 10 CFR 50.72(a). The Emergency Notification System (ENS) is not anticipated to be used continuously, but primarily to provide periodic informational updates to the NRC.
In the event that the ENS fails, commercial and satellite phones provide back up.
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M.lAR 3 0 200D 7.5 First Aid and Medical Facilities Emergency medical equipment and supplies are located in the ISFSI Monitoring Station Building. Personnel requiring off-site treatment will be transported to the hospital by ambulance, company vehicle, or employee private vehicles.
Medical equipment and supplies are also located at the Medical Facility at the Power Plant site.
7.6 Fire Suppression Fire extinguishers are located at the pre-determined areas at the ISFSI Monitoring Station Building and at the Power Plant site and can be used to extinguish or contain a fire. Requests for fire assistance will go from the ISFSI Monitoring Station Building to the local 911 system. A letter of Agreement with the Haddam Neck Fire Department to provide fire fighting support is included in Appendix B.
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I.!AR 3 0 2005 8.0 MAINTAINING EMERGENCY PREPAREDNESS The ISFSI Manager or designee is responsible for ensuring the availability of adequate emergency support staff and for approval of the EO implementing procedures.
The ISFSI Manager is also responsible for ensuring the following tasks and functions are completed:
The maintenance of readiness of the on-site emergency response facilities and equipment.
Development and maintenance of the Emergency Plan.
Development and maintenance of the associated implementing procedures.
Preparation of scenarios for training drills and exercises.
Conduct of drills and exercise.
Providing input to emergency preparedness training of the support staff.
Returning emergency equipment and supplies used during a drill, exercise or actual emergency to a state of readiness following the termination of the drill, exercise or emergency.
Providing support for the annual radiation monitoring drill and medical emergency drill.
Reviewing EALs with state and local government authorities on an annual basis in accordance with 10 CFR 50 Appendix E (IV)(B).
8.1 Traininq The Emergency Plan Training Program consists of lesson plan(s) designed to provide the skills and knowledge necessary to maintain staff proficiency. Each K>y EO procedure will be reviewed to identify activities that are not considered to be a part of on-shift ERO personnel's day-to-day routine function (i.e. use of telephones, general communication protocol, etc.). Lessons will focus on non-routine and specialized activities that are particular to the individual functions and overall emergency response actions. Training may consist of, but not be limited to, classroom lecture, self study, practical demonstrations (where necessary, as specified in the lesson plan), and facility drills.
8.1.1 Emergency Staff Training Each on-shift person will be provided training designed to
- -familiarize the person with their duties, responsibilities and expected actions in the event of an emergency. This initial training will be completed pri6r to th6 inidividual assuming the on-shift assignment. Personnel from the Power Plant Decommissioning organization and others called in will be assigned responsibilities within their specific areas of expertise.
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Each on shift staff member will be provided continuing training for their individual duties. This training will be conducted during the calendar year. Continuing training addresses general changes to the Emergency Plan, facilities,:equipment, I.....
regulations, policies and specific changes to their responsibilities (which are not considered part of their routine duties). It also addresses problem areas identified during audits, drills or exercises.
8.1.2 General Access Training The General Access Training provides all employees and contractors the basic elements of the Emergency Plan and expected actions during an emergency. Information is reviewed annually as part of maintaining site access.
8.1.3 Offsite Assistance Training Organizations, which may be called upon to render assistance onsite, will be offered general facility familiarization sessions on an annual basis.
These sessions may include a walk down of the general facility, safety, building layout, access protocol, communications capabilities, site hazards (e.g., radiological, chemical, etc.) and security requirements.
8.2 Tests, Drills and Exercises In addition to the emergency plan training described earlier, the facility staff will conduct periodic drills to enhance skills and knowledge of the practical implementation of the EP. Periodic drills will be scheduled with various objectives to demonstrate these capabilities. Offsite Response Organizations (e.g., CT DEP) will be invited to participate in the periodic drills. Some drills will focus on specific functions (such as communications capabilities) while others will involve a broader amount of the EP. These evolutions serve as an extension of the training program, allowing interaction between evaluators and responders to reinforce procedural requirements and overall process implementation.
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ieAAr 3 0 2005 8.2.1 Tests KJ 8.2.1.1 Periodic Surveillance Program S
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Facilities and equipment will be maintained in accordance with surveillance procedures. Inventories of Emergency Plan equipment will be conducted on a semi-annual basis and after facility activation (actual event or drill activity). A walk down of the ISFSI Monitoring Station Building and support trailer will be conducted on a semi-annual basis to ensure facility readiness is maintained.
Telephone numbers that are important to emergency notification and are contained in the emergency operating procedures will be verified on a quarterly basis.
8.2.1.2 Communications Systems Checks Telephone and radio systems used for on-site and off-site emergency communications will be tested monthly.
8.2.2 Drills I
In addition to training drills discussed above, the following drills will be conducted annually:
- On Shift Staff Drill - involving a combination of some of the principal functional areas of emergency response capabilities.
- Radiological Monitoring Drill - demonstrating conducting general area surveys.
- Medical Emergency Drill - demonstrating the capability for transporting an injured worker offsite.
- Fire Drill - conducted in accordance with the Fire Protection Program.
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MAR 3 0 2U00 8.2.3 Exercises An exercise will be conducted once each calendar year to demonstrate K.
the capability to implement the Emergency Plan. Objectives will be developed to ensure major elements of the emergency plan are demonstrated and evaluated to ensure the appropriate level of..,
preparedness is being maintained.
Offsite response organizations (e.g., CT DEP) will be invited to participate or observe in the exercise.
8.2.4 Drill and Exercise Evaluation Facility staff will evaluate the exercise and drills. Expectations for evaluators will be discussed with each evaluator prior to the drill/exercise. Whenever possible, evaluators should have present or recent emergency responsibilities and be assigned to evaluate functions/areas consistent with their emergency responsibilities.
Following the drill/exercise a critique of the evolution will be conducted.
Comments will be evaluated and dispositioned by the ISFSI Manager and deficiencies will be corrected through retraining, remedial drills, or by other means. Comment resolution will be assigned to appropriate personnel for final implementation.
8.3 Review and Updating of Emergency Plan and Implementing Procedures 8.3.1 Emergency Plan Review This plan, including all written agreements between CYAPCO and other parties, will be reviewed annually. Approved changes to the plan will be K.>
incorporated into the appropriate implementing procedures along with the plan changes. Letters of Agreement will be reviewed annually and verified to be in effect at the time of the plan review. This may be accomplished via written correspondence or documented telephone conversation.
This plan is a controlled document to ensure changes are incorporated into distributed copies. Plan changes will be subject to management review and approval.
8.3.2 Emergency Plan implementing procedure Review Emergency Operating procedures, which implement the EP, will be reviewed and revised in accordance with plant procedure control guidelines. Periodic revisions wvill be incorporated whenever a plan change is made that affects the procedure or other circumstances dictate a revision is necessary. EOs will be subject to management review and approval.
l 8.4 Emer-iency Plan Audit An audit of the Emergency Preparedness Program will be conducted at least once every 12 months.
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9.0 RECOVERY In any emergency, immediate response actions are directed toward limiting the consequences of the accident in a manner that will afford maximum protection to, personnel. Once the immediate corrective and on-site protective actions have been implemented, and the facility is brought to a stable condition, termination of the emergency classification condition may be initiated. The ISS will terminate the event and provide notification to appropriate off-site authorities and staff personnel. Depending on severity of the emergency, on-site recovery/re-entry measures may be required. The development and implementation of any site recovery/re-entry actions is the responsibility of the ISS. Recovery actions are described in the EOs.
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APPENDIX A DEFINITIONS, ABBREVIATIONS AND ACRONYMS
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Appnendix-A This section provides definitions of commonly used terms that are applicable to this Emergency Plan'.'
Actions Assessment Actions Those actions taken during or after an incident to obtain and process information that is necessary to make decisions to implement specific emergency measures.
Corrective Actions Actions taken to make improvements.
Emergencv Actions Those measures taken to improve or terminate an emergency situation.
Protective Actions An on-site action taken to avoid or reduce a projected dose to plant personnel.
Recovery Actions i'
Actions taken after an emergency to restore the station to pre-emergency condition.
Airborne Radioactivity Any radioactive material dispersed in the air in the form of particulates or gases.
Area Exclusion Area
. -' 'The area within the site boundary including the' protected area.
Radioloqicallv Controlled Area (RCA)
An area' of the Station where dosimetry is required.
Background Radiation Radiation arising from material other than the one directly under consideration such as from cosmic rays, the ground, the air, building materials, etc.
CYAPCO (Connecticut Yankee Atomic Power Company)
The operating company for the Haddam Neck Plant.
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MAIR 3 0 ws Condition (Also called initiating condition)
A description of a nuclear power plant event where either the potential exists for a radiological emergency, or such an emergency has occurred.-
Contamination (Radioactive)
The deposition of radioactive material in any place where it is unwanted (e.g., on persons, products or equipment).
ISFSI Monitoring Station The ISFSI Monitoring Station is the primary location where conditions of the ISFSI are monitored and where corrective actions are directed to mitigate emergencies.
Decontamination The reduction or removal of contaminating radioactive material from a person, area or object by cleaning or washing.
Emergency Action Levels (EALs)
Thresholds for initiating emergency actions as designating a particular class of emergency, initiating a notification procedure, or initiating a particular protective action.
Emerqncy Response Organization (ERO)
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The organization responsible for Station operations under emergency conditions.
Dosimeter A device that measures and displays radiation exposure.
Emergency Any abnormal condition that could affect the health and safety of people or safe operation of equipment.
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Emergency Classification SVstem i A system that arranges abn6mal coniditions in-oirder'of seVerit>: They are as follows listed in order of increasing severity.;-
UNUSUAL EVENT (State Posture
- Code, DELTA-ONE/DELTA-TWO)
Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant.
DELTA-ONE (Does not involve releases of radioactive material).
DELTA-TWO - (Involves minor releases of radioactive material).
Event Based EALs A listing of symptoms and conditions under generic event categories.
ISFSI - Independent Spent Fuel Storage Installation ISFSI Site -
area including ISFSI Monitoring Station and ISFSI Facility.
ISFSI Monitoring Station -
Building containing monitoring systems for ISFSI facility.
ISFSI Facility - Area enclosed by ISFSI Security fence that contains ISFSI Pad.
ISFSI Pad - Concrete slab for storage of vertical concrete casks filled with TSCs K>
containing spent fuel.
Incident An unexpected occurrence that could lead to an emergency.
Off-site The area outside the owner controlled area of the Haddam Neck Plant.
On-site
.5-The area inside the owner controlled area of the Haddam Neck Plant.
Procedures Abnormal Operating Procedures (AOPY Procedures which provide specific actions to mitigate the consequences of and terminate an emergency situation.
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M~fAl 3 0
- w~n Emergency Operating Procedures (EO)
I j Procedures which implement the Emergency Plan. These procedures specify the emergency organization and actions that would be required of station and other on-site personnel during an emergency.
Supplemental Procedures Station operating, health physics, radiological control, administrative, security, maintenance, and training procedures.
Projected Dose The estimated potential dose that could be received by affected.
Protective Action Guides (PAGs)
Projected absorbed dose to individuals in the general population which warrants protective action.
Radiation The emission and propagation of energy through a medium in the form of electromagnetic waves or particles which impart their energy to the medium through the creation of electrically charged ion pairs directly or indirectly in its passage through the medium.
Radioactivity The property possessed by certain unstable radionuclides of emitting charged particles, gamma photons or X-rays.
State The State of Connecticut.
State Plan The State of Connecticut Emergency Operations Plan, Annex V, Fixed Nuclear Facilities Radiological Emergency Response Plan.
Station Relocation The orderly relocation of all personnel from the protected/industrial area, except on-shift Emergency Response Organization personnel.
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Technical Support Center (TSC)
A facility located in the ISFSI Monitoring Station Building where technical support personnel respond to an emergency..
Total Effective Dose Equivalent (TEDE)
The sum of the deep-dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures).
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ABBREVIATIONS AND ACRONYMS ALARA As Low As Reasonably Achievable ARMS - --
Area Radiation Monitoring System ` -; -
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..I CC or CM3 CDE CEDE CFR CPM CYAPCO DEP dpm/100 cm2 EAL ED ENS EO EPA ERO HNP HP HPN hr ISFSI ISS ISS-ED LOP MAX Met mRem/hr NRC OEM OPS PA PAG PAP PF
-Cubic Centimeter Committed Dose Equivalent Committed Effective Dose Equivalent Code of Federal Regulations Counts per minute Connecticut Yankee Atomic Power Company Department of Environmental Protection (State of CT)
Disintegrations per minute per 100 square centimeter area Emergency Action Level Emergency Director NRC Emergency Notification System telephone Emergency Operating Procedures Environmental Protection Agency Emergency Response Organization Haddam Neck Plant Health Physics NRC Health Physics Network Telephone Hour Independent Spent Fuel Storage Installation ISFSI Shift Supervisor ISFSI Shift Supervisor - Emergency Director Loss of Power Maximum Meteorological 1/1000 Rem per hour U.S. Nuclear Regulatory Commission Office of Emergency Management (State of Connecticut)
Operations.
Public address system Protective Action Guide Personnel Access Point Protection factor QA Quality Assurance A-6
MAI 3 0 rad V>
RCA RERP RMS SCBA SDENWB SF State T or Temp Tech Spec TEDE TLD TSC Radiation Radiologically Controlled Area Roentgen-Equivalent Man. A measure of radiation exposure.
Radiological Emergency Response Plan Radiation Monitoring System Self-contained breathing apparatus Shallow Dose Equivalent/Whole Body Spent Fuel State of Connecticut Temperature Technical Specifications Total Effective Dose Equivalent Thermoluminescent dosimeter Technical Support Center uci Microcuries 0-4 A-7
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APPENDIX B LETTERS OF AGREEMENT K)-
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Appendix B Letters of Agreement Haddam Neck Volunteer Fire Department State of Connecticut Department of Public Safety, Division of State Police East Hampton Ambulance, Inc.
Middlesex Hospital
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Haddam Neck Plant Independent Spent Fuel Storage Installation (ISFSI)
- A Emergency Plan Revision 7. -
Emergency Plan - 10 CFR 50.54(g) Effectiveness Review Review
Title:
Changes to Haddam Neck Plant Emergency Plan Revision 6
Background:
On December 5,1996, Connecticut Yankee Atomic Power Company (CYAPCO) informed the NRC that CYAPCO has decided to permanently cease operation of the Haddam Neck Plant (HNP) and the fuel had been permanently removed from the reactor. The HNP was shutdown on July 22,1996.
On August 28,1998, CYAPCO received an exemption from the provisions of 10 CFR 50.54(q) that requires emergency plans to meet all of the standards of 10 CFR 50.47(b) and all of the requirements of Appendix E to Part 50 (Reference 1).
In addition, the NRC also approved the HNP Defueled Emergency Plan (DEP).
This approval allows the HNP to discontinue offsite emergency planning activities and reduce the scope of onsite emergency planning as a result of the permanently shutdown and defueled status of the facility. The standards and requirements of 10 CFR 50.47(b) and Appendix E to part 50 that remain in effect are specified in Tables 1 and 2 of Attachment 2 of CYAPCO's letter dated March 25,1998 (Reference 2). These standards and requirements are now included as and 3 to Administrative Procedure, ADM 1.1-274, "10 CFR 50.54(q) Effectiveness Reviews for Defueled Emergency Plan."
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The current Emergency Plan (Revision 6) describes CYAPCO's plan for responding to emergencies that may arise at the HNP while in a permanently shutdown and defueled configuration. In this configuration, no reactor operations can take place aiid therefore no operating accidents (e.g., LOCA, SGTR) can occur.; The fuel is stored in the Spent Fuel Pool (SFP) and at the Independent Spent Fuel instaWlatio66(iSFSl) and theplant is prohibited from vinig the fuel-from the SFP into the reactor vessel, 'and the 'reactor vessel has been removed and disposed of. An analysis of the possible design basis events and consequences are presented in Chapter 15, Accident Analysis, of the Updated Safety Analysis Report (UFSAR) and Chapter 11, Accident Analysis, of the NAC-MPC FSAR.
Currently, all of the HNP spent fuel and GTCC waste has been removed from the SFP and placed into dry storage at the ISFSI. Plant dismantlement activities are still ongoing. The spent fuel pool water will soon be processed and discharged in accordance with NPDES permit and REMODCM requirements. Other material with a significant radiological source term is being removed from the site. Any 1
AI' 3u J release of airborne radioactive materials during the balance of dismantlement and decommissioning activities will be insignificant with respect to the Environmental Protection Agency (EPA) Protective Action Guides (PAGs) at the site boundary or to on-site personnel. A Radiological Controlled Area (RCA) will be maintained as long as necessary within the Power Plant Site to control and monitor radiological exposure to on-site personnel.
Scope:
The proposed revision (Revision 7) of the HNP Emergency Plan describes CYAPCO's plan for responding to emergencies that may arise during dry spent fuel and GTCC waste storage at the ISFSI, including off-normal, accident, natural, and hypothetical events and consequences as presented in the NAC-MPC FSAR. This plan also encompasses CYAPCO's plans for responding to emergencies that may arise at the Power Plant Site during ongoing decoMfiissioning activities. An analysis of the possible design basis events and consequences are presented in Chapter 15, Accident analysis, of the UFSAR.
The analyses of the potential radiological impact of an accident at the Power Plant Site and the ISFSI site indicate that any release beyond the Power Plant Site and the ISFSI Owner Controlled Area (OCA) boundary are expected to be less than the US EPA PAG exposure levels (EPA-400-R-92-1). Exposure levels which warrant pre-planned response measures are generally limited to the Power Plant Site and ISFSI OCA boundary. For this reason, radiological emergency planning is focused on the Power Plant Site and ISFSI OCA boundary.
Summary of Changes The content of the proposed revision reflects the ongoing decommissioning activities at the HNP and transfer of all spent fuel and the GTCC waste from the SFP to the ISFSI. Although, the proposed revision of the Emergency Plan has been written using a different format when compared with the current version of the HNP Emergency Plan (Revision 6), most of the content of the current plan is maintained in the proposed revision (except where the plant conditions have changed). Sections.1, 2, and 3 of the current Emergency Plan are rewritten into fe 'propo6ed Emergency Plan Sections 1,2, and 3. Section 4.0, Classification System, includes emergency classification and emergency action level description. It now states that only the Unusual Event classification applies at the Power Plant site and at the ISFSI. 'Alert Level Emergency classification level has been removed from the emergency. assessment process based on the radiological conditions (Reference 3). Table 4-1 of the proposed revision of the Emergency Plan contains an emergency classification and emergency action level scheme. Section 5.0, Emergency Organization, describes the Emergency Response Organization and the reduced number of emergency response personnel that will respond to an emergency at the Power Plant site or at the ISFSI. Specifically, the Operations Shift Manager and Equipment Operator positions are no longer required due to the current conditions at the HNP. In 2
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'~5 addition, the Technical Response Coordinator (TRC), Radiological Assessment Coordinator (RAC), Public Information Coordinator (PIC) positions have been eliminated. Instead, Personnel will be called in to perform the functions of the, TRC, RAC, and PIC on as needed basis. Responsibilities of the Emergency Response Organization are also described. Section 6.0, Emergency Measures, has been revised to reflect the reduction in the scope of emergency measures required to respond to an emergency (Alert Level Classification has been removed and only the Unusual Event classification applies at the Power Plant site and at the ISFSI). Section 7.0, Emergency Response Facilities and Equipment, has been revised to delete use of the Control Room. Instead, the Emergency Plan will relies on the ISFSI Monitoring Station as the primary facility where ISFSI conditions are monitored and corrective actions will be developed to mitigate any abnormal occurrences. All necessary equipment is located in the ISFSI Monitoring Station. Section 8.0, Maintaining Emergency Preparedness, and Section 9.0, Recovery, have been revised to reflect that all the spent fuel is stored at the ISFSI. No major changes are proposed to these Sections.
The following Sections provide technical justification for major changes to the Emergency Plan.
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Elimination of ALERT Classification All spent fuel and GTCC has been placed in dry storage canisters and moved from the spent fuel pool to the ISFSI. These canisters are filled with helium and sealed closed by welding. There is therefore no longer a potential for a fuel handling accident to occur and no longer the potential for a noble gas release.
There is also no longer any need for any operator to take actions to mitigate the consequences of this type of accident. This is consistent with the NRC approved License Amendment 201 (Reference 4) This amendment eliminated operational requirements and certain design requirements that are no longer applicable following the transfer of all of the spent fuel from the spent fuel pool to the ISFSI.
CYAPCO no longer dewaters poly HICs filled with radioactively contaminated spent resin, so there is no longer the potential for a resin fire caused by the potential exothermic reaction associated with this type of activity. This'potential accident had been the one that generated the highest site boundary dose rate.
With these accidents no longer considered credible, conditions that would warrant the ALERT classification level no longer exist. The highest emergency classification is now the UNUSUAL EVENT. Based on the fact that the risks associated with on and off-site radiation releases have been significantly reduced, and conditions that would warrant an ALERT classification no longer are credible, the elimination of the ALERT classification does not result in a reduction in effectiveness of the Emergency Plan.
3
',1AR 30,C-;5
- 2.
Point of Control Changed from the Control Room i6 the ISFSI Monitoring Station The existing Control Room is not the original Control Room that was used when the plant was in operation. In fact, the "Control Room" name for this location could be considered a misnomer, since there were few remaining control functions. The Control Room would have more appropriately been named the Monitoring Station, since its primary purpose was facilitating monitoring of instrumentation that indicated the condition of the spent fuel. From an Emergency Plan perspective, the Control Room was a location with 24/7 staffing and necessary communications from which actions taken in response to an emergency event could be controlled.
The spent fuel is now stored in dry casks in the VCCs at the ISFSI. There is a Monitoring Station at the ISFSI, that is manned on a 24/7 basis. It is near to the location of the spent fuel and is the location where spent fuel instrumentation is displayed and monitored. It has the same telephone and radio communication systems thatthe Control Room had.
Since with the fuel and GTCC having been moved from the spent fuel pool, the Monitoring Station has the fuel monitoring instrumentation, is near to the fuel, has the needed communications and is staffed on a 24/7 basis, use of the Monitoring Station instead of the Control Room, does not result in a reduction of effectiveness of the Emergency Plan.
- 3.
Use of ISFSI Shift Supervisor (ISS) instead of Operations Shift Manager The role of the Shift Manager with respect to dealing with an Emergency Plan event in the organization that has existed in recent years has been to control primarily by being a focal point of communications and by being knowledgeable of which regulators and government officials are to be notified for the various types of problems that can occur. There are detailed procedures that provide guidance on who should be notified for the different problems that can occur.
With spent fuel now in dry storage and the potential for a fuel handling accident and the resultant noble gas release'no longer credible, and the resin fire nmo:
longer a credible event, the risks are less and the need to take actions to mitigate an event is less. The storage of fuel and GTCC in the dry casks at the ISFSI requires little action to be taken by personnel during an emergency event.
Actions to be taken for design basis accident events include monitoring, clearing obstructed vents and communicating.
Based on the decreased risk of radiological release type accidents and the nature of actions to be taken in the event of spent fuel design basis accidents, the ISFSI Shift Supervisor is capable of handing Emergency Plan events that can occur in this condition. Therefore having the ISFSI Shift Supervisor controlling 4
111AHI 3 0 2tL'-i an emergency event instead of the Shift Manager, does not result in a reduction of effectiveness for the Emergency Plan.
- 4.,
'Elimination of the Equipment O'erator, the TRO. the RAG and PlC
,e..or th
.RC th n
I Since the spent fuel and GTCC have been moved to the ISFSI, there is no longer a need to operate the various equipment associated with the Spent Fuel Nuclear Island, and there is no longer a need for the Shift Manager(SM) and the Equipment Operator (EO) positions to be staffed. This is consistent with the NRC approved License Amendment 201 (Reference 4). This amendment eliminated operational requirements and certain design requirements that are no longer applicable following the transfer of all of the spent fuel from the spent fuel pool to the ISFSI. Based on the decreased risk of radiological release type accidents and nature of actions to be taken in the event of an emergency at the Power Plant site or at the ISFSI, The call in personnel can perform the functions currently performed by the TRC, RAC, or the PIC. Therefore, the proposed change does not decrease the effectiveness of the Emergency Plan.
Evaluation:
A. The following sections describe compliance with planning standards of 10 CFR 50.47(b):
(b)(1), Responsibilities & Staffing The proposed Section 5, Emergency Organization (5.1, On-shift positions, 5.2, Augmented positions, and 5.3, State and Federal Government response),
describe primary responsibilities for emergency response by CYAPCO and State and Federal Agencies. Emergency responsibilities of the supporting organizations within CYAPCO have been identified. There is no change in the requirement as specified in the current revision of the Emergency Plan for local or state government agency response. Therefore, the proposed changes meet the planning standards of 10 CFR 50.47(b)(1).
(bj(2), On-'shift Responsibilities & Timely Augmenitation'.
Although the organizational structure and staffing requirements are different from the current Emergency Plan, the changes reflect the current plant conditions.'
The proposed Section 5, Emergency Organization, clearly defines on-shift responsibilities for emergency response, specifies adequate staffing requirements and specifies the offsite support and its response. Therefore, the proposed changes meet the planning standards of 10 CFR 50.47(b)(2).
5
.IA, 3 0,2,>~5 The following EALs have been added or revised to reflect that all the spent fuel is in the VCCs and stored at the ISFSI.
-HU2, Security Event with potential loss of level of safety to the ISFSI -
_.-,Unusual Event;
-HUl-Damage to a Loaded Cask Confinement Boundary-Unusual Event
-AUI-Unexpected Increase in ISFSI Radiation-Unusual Event The following EALs have been revised to reflect the current and ongoing decommissioning activities:
-GUI-Fire-Unusual Event
-GU2-Toxic/Flammable gases -Unusual Event
-OUI-Unplanned Release - Unusual Event (b)(5), Notification Procedures No changes are proposed to the provisions in the current revision of the Emergency Plan and the current Emergency Plan meets the planning standards of 10 CFR 50.47 (b)(5).
(b)(6), Communication Provisions No changes are proposed to the provisions in the current revision of the Emergency Plan and the current Emergency Plan meets the planning standards of 10 CFR 50.47(b)(6).
(b)(7), Public Information The position of the Public Information Coordinator has been eliminated. This function will be carried out by the personnel called in.
(b)(8), Emergency Facilities and Equipment Appropriate equipment is maintained at the ISFSI. Procedures and the drawings are distributed and controlled within the ISFSI Building in accordance with the ISFSI Procedures.
(b)(9), Radiological Assessment Methods, Systems, and Equipment There will be no methods, systems, and equipment for determination of actual offsite dose consequences. This is consistent with the approved exemption.
7
MIAR 3 0 2tiCo; (b)(10), Protective Actions
-- As there are no design basis or other credible events that would result in doses beyond the Power Plant Exclusion Area Boundary or the ISFSI Owner Controlled Area Boundary that would exceed the EPA PAGs, the Emergency Planning Zones (EPZs) and associated protective actions are not required and are therefore not provided. This is consistent with the approved exemption.
(b)(11), Radiological Exposure Control & Protective Actions Guides; (b)(12),
Medical Services; (b)(13), Recovery and Reentry Plans; (b)(14), Drills &
Exercises; (b)(15), Emergency Response Training; and (b)(16), Emergency Response Planner Responsibilities and Training No major changes are proposed to the current Emergency Plan description and the current Emergency Plan meets the above planning standards.
Summary:
Based upon the above, the proposed revision to the Emergency Plan (Revision
- 7) meets the planning standards of 10 CFR 50.47(b) and is consistent with the approved exemption.
B. The following sections describe compliance with the criteria of 10 CFR 50, Appendix E (specifically Section IV, Content of Emergency Plan):
(IV)A, Organization for Coping with Radiological Emergencies As there are no design basis or credible events that would result in doses beyond the Power Plant Exclusion Area Boundary and ISFSI Owner Controlled Area Boundary that would exceed the EPA PAGs, the coordination and implementation of offsite emergency measures are no longer required. However CYAPCO will still exchange information with offsite authorities. Identification of State and Local authorities responsible for protective actions is no longer
' required. In addition the level of emergency response required by this revision of
'the Emrgency Plan does' not require response to the plant bsy headquarters' personnel. In addition, this revision does not specify individuals with 'special
-qualifications" for emergency response. Normal Emergency services are provided by the local Police/Fire Departments, Ambulance Services and Hospitals, as appropriate. This is consistent with the current version of the Emergency Plan and with the approved exemption.
8
MAR 3 0 KCG5 (IV)B, Assessment of Radiological Emergencies As there are no design basis or other credible events that would result in doses beyond the Power. Plant Exclusion Area Boundary and ISFSI Owner Controlled Area Boundary that would exceed the EPA PAGs, offsite protective measures and monitoring are no longer required. Normal Emergency services are provided by the local Fire Departments, Ambulance Services and Hospitals, as appropriate. The HNP EAL Tables are reviewed with the Town of Haddam and CT DEP annually. This is consistent with the current version of the Emergency Plan and with the approved exemption.
(IV)C, Classifications, EALs and ERO Activation Since there are no design basis events or other credible events that would result in doses beyond the Power Plant Exclusion Area Boundary or ISFSI Owner Controlled Area Boundary that would exceed the EPA PAGs, no offsite response measures including offsite radiation monitoring is required. This is consistent with the approved exemption. Since the postulated worst-case accidents involving an ISFSI and ongoing decommissioning activities at the HNP site have insignificant consequences to the public health and safety, all ISFSI or ongoing decommissioning activities at the HNP site related emergencies are classified as Unusual Events. This is consistent with the NRC guidance contained in Regulatory Guide 1.1 01, Rev.4. For addition details, see the discussion above
((b)(4), Emergency Classification and Action Level Scheme.
(IV)D, Notification of Federal, State, and Local Agencies and the Public As there are no design basis or other credible events that would result in doses beyond the Power Plant Exclusion Area Boundary and ISFSI Owner Controlled Area Boundary that would exceed the EPA PAGs, the prompt notification of the public is not required. Notification of federal and State agencies should occur within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Similarly, no signs or other measures for notification of transient populations are required. No Alert notification system is required. This is consistent with the current version of the Emergency Plan and with the approved exemption.
h (IV)E, ERFs, Equipment, and Communications Offsite participation by State and local authorities is no longer required.
Communications will be conducted with the State and local authorities.
Equipment, for contacting State agencies, will be tested monthly. The current as well as the proposed version of the Emergency Plan does not require the use of an EOF. Effective direction and control during an emergency shall emanate from the ISFSI Monitoring Station. In addition, communications with the EOF and local emergency operation center (Operations Support Center) and these facilities themselves are no longer required. Communications, with the NRC, 9
MAR 3 0 26G5 under this plan will be tested monthly. This is consistent with the approved exemption.
(IV)F, Training, Drills, and Exercises As there are no design basis accidents or other credible events that would result in doses beyond the Power Plant Exclusion Area Boundary and ISFSI Owner controlled Area Boundary that would exceed the EPA PAGs, the training of local media is no longer required. Similarly, the public notification system will no longer be required. The offsite full participation exercise is no longer be required.
Hence remedial exercises are no longer required. However, CYAPCO will notify State and local response organizations of the scheduled exercise and determine their interest in participating. CYAPCO shall exercise the Emergency Plan once each calendar year. The current Emergency Plan does not require the use of an EOF or an OSC. Since the revised Emergency Plan has eliminated the Control Room, effective direction and control during an emergency shall emanate from the ISFSI Monitoring Station. This is consistent with the approved exemption.
(IV)G, Plans and Procedures and Surveillances of Equipment and Supplies Section 7, Emergency Response Facilities and Equipment, identifies, describes and gives locations of emergency response facilities and their equipment.
Section 8.3 describes provisions that are employed to ensure that the Emergency Plan and its implementing procedures are maintained up to date.
(IV), Re-entry and Recovery Following an Accident Section 9, Recovery, describes criteria to be used to determine when, following an accident, recovery/reentry (i.e., the ISFSI or Power Plant Site) would be appropriate.
Summary Based upon the above discussion, the proposed revision to the Emergency Plan (Revision 7) meets the requirements of 10 CFR 50, Appendix E and is consistent with the approved exemption.;
Conclusion and Approval:
Based upon the above evaluation, the proposed changes (the proposed revision of the Emergency Plan) do not decrease the effectiveness of the plan and the plan continues to meet the standards of 10 CFR 50.47(b) and Appendix E requirements.
10
MAR 3 0 T2G)
References:
(1)---T: L: Fredrich (NRC) letter to R.A. Mellor (CYAPCO), 'Exemption from
- a portion of 10 CFR 50.54(q) and Approval of Defueled Emergency
- Plan at Haddam Neck Plant", dated August 28,1998.
(2)
R. A. Mellor (CYAPCO) letter to U. S. NRC, "Additional Information for the Proposed Defueled Emergency Plan", dated March 25,1998.
(3)
Health Physics Department Technical Support Document, CH-HP-0195, "Radiological Assessment of Airborne and Liquid release After Fuel Transfer to ISFSI-ELA Classification Consideration,' Dated February 25, 2005.
(4)
D. M. Gillen (NRC) letter to W. Norton (CYAPCO), "Issuance of Amendment 201 to Facility Operating license no. DPR-61-Connecticut Yankee Atomic Power Company, Haddam Neck plant", date December 20, 2004.
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12
ISFSI DI-049AR 3 0 200O Rev. 0 Effective:
Connecticut Yankee ISFSI Department Instruction EAL Basis 1.0 OBJECTIVE 1.1 To provide guidance to the Operators when there is a question of classification of an event using EO-5, Emergency Plan Implementation, which includes a table of Emergency Action Levels (EALs).
2.0 APPLICABILITY 2.1 Applicable to classifying an event using EO-5, Emergency Plan Implementation, using EAL Table.
2.2 This revision reflects implementation of revision 7 of the Connecticut Yankee Atomic Power Company, Haddam Neck Plant, Emergency Plan.
3.0 REFERENCES
3.1 UFSAR, Section 13.3, Emergency Plan 3.2 EO-5, Emergency Plan Implementation 4.0' RESPONSIBILITY '
?
i.
4.1 The ISFSI Manager/designee responsible to keep this instruction updated as required.
5.0 INSTRUCTIONS 5.1 REFER to the appropriate section of Attachment 1, Emergency Action Level (EAL)
Basis Document, when classifying an event as necessary.
6.0 ATTACHMENTS 6.1, Emergency Action Level (EAL) Basis Document 1 of 22
ISFSI DI-02 MAR 3 0 20 Rev. 0 Effective:
7.0-,.
SUMMARY
OF CHANGESt.+--
- --~~
~T 7.1 Updated to reflect Revision 7 of the Emergency Plan, which was revised to reflect completion of fuel transfer from the Spent Fuel Pool to the ISFSI.
7.2 Various editorial and format corrections.
8.0 APPROVAL jh kf4.
ISFSI Manager/besignee 2 of 22
MAR 3 0 205 ISFSI DI-02 Rev. 0 Effective:
(1 of 20)
CONNECTICUT YANKEE EMERGENCY ACTION LEVEL (EAL)
BASIS DOCUMENT Revision 4
-~~~~~
.A t
ISFSI DI-OIAAR Rev. 0 Effective:
3 0 2(0015 (2 of 20)
DEFINITIONS...................................
D-I GENERAL NOTES FOR EAL TECHNICAL BASIS...................................
N-I UNPLANNED RELEASE (0 is for OFFSITE)....................................
0-1 OU1 Unplanned Release...................................
0-2 HAZARDS.......................................................................................................................................................................
HUI Damage to a Loaded Cask Confinement Boundary.........................
HU2 Security Event with Potential Loss of Level of Safety to the ISFSI.
H-I H-2 H-3 FIRE/GASES...................................................................................................................................................................
GUI Fire..................................
GU2 Toxic/Flammable Gases.
G-1 G-2 G-3 JUDGEMENT........
JUl Judgement...............................................
ABNORMAL RAD LEVELS......................................
AUI Unexpected Increase in ISFSI Radiation I..........................
J-1 J-2 A-1 A
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CY EAL Basis Document Revision 4 I
ISFSI DI-02 Rev. 0 Effective: MAR 3 0 ?(3?)
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11.
DEFINITIONS
.....
CY EAL Basis Document Revision 4 D-1
ISFSI DI-02 Rev. 0 Effective:
MAR 3 0,
(4 of 20)
Adjacent - In close proximity Affecting - Events such as fire, flood, or high winds causing degraded equipment performance as determined by physical observation or by indications in the Control Room or at local control stations.
Alert - Events are in process or have occurred which indicate an actual or potential substantial degradation of the level of safety of the plant personnel or to the safe containment of fuel in the spent fuel pool.
AMS - Air Monitoring System ARM-Area Radiation Monitor Bomb - An incendiary device fused to detonate under certain conditions.
CDE - Committed Dose Equivalent as defined in 10 CFR 20.1003 CEDE - Committed Effective Dose Equivalent as defined in 10 CFR 20.1003 cfm - Cubic Feet per Minute cpm - Counts Per Minute Confinement Boundary - The barrier(s) between areas containing radioactive substances and the environment.
Curie (C) -A measurement of radioactive decay rate equal to 3.70E+I 0 disintegrations per second.
DAC - Derived Air Concentration DC-Direct Current DEQ - Dose Equivalent dpm - Disintegrations Per Minute EDE-Effective Dose Equivalent as defined in 10 CFR 20.1003 Explosion - a rapid, violent, unconfined combustion, or catastrophic failure of pressurized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components.
Emergency Action Level (EAL) - A pre-determined, site-specific, observable threshold for a plant Initiating Condition that places the plant in a given Emergency Class. 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 procedures, or another phenomenon which, if it occurs, indicates entry into a particular Emergency Class.
I CY EAL Basis document Revision 4 D-2
ISFSI DI-02 Rev.0 Effective: MAR 3 0 2005 K..)
(5 of 20)
Emergency Class Same as "Emergency Classification Level", below.
Emergency Classification Level - These are taken from 10CFR50, Appendix E. All conditions listed on the EAL table are the Unusual Event (UE) classification level.
ED - Emergency Director EO - Emergency Operating Procedure Fuel Clad - The zirconium alloy or stainless steel tubes that contain the fuel pellets.
gpm - gallons per minute Hostile Force -A force intent on causing damage to the station or plant personnel.
Inadvertent - Accidental or unintentional, e.g., the event occurred because procedures were not strictly adhered to.
IDLH-Immediately Dangerous to Life or Health In service - A component or system in the appropriate configuration for normal operation and is considered "operable" as defined in the Technical Specifications.
Initiating Condition (IC) - One of a predetermined subset of nuclear power plant conditions where either the potential exists for a radiological emergency or such an emergency has occurred.
ISFSI-Independent Spent Fuel Storage Installation ISS-ISFSI Shift Supervisor MCC - Motor Control Center Microcurie (pCi) -One millionth of a curie, ie., 3.7E+4 disintegrations per second.
Millirem - One thousandth of a rem mph - miles per hour mR -milliroentgen, i.e., one thousandth of a roentgen (R)
MSL - Mean Sea Level' Notification of Unusual Event (NVOUE) - Same as "Unusual Event", below.
OBE - Operating Basis Earthquake OSM-ED - Operations Shift Manager - Emergency Director PAG - Protective Action Guide Planned - Loss of a component or system due to expected events such as scheduled maintenance and testing activities.
CY EAL Basis Document Revision 4 D-3
ISFSI DJ-2 Rev. 0 Effective: MAR 3 n
'i, (6 of 20)
'; PMH-! Proliable Maximnumi' Hurricane.
S Posture Code - A State of Connecticut mandated emergency declaration structure similar to NRC emergency classification. All EAL table conditions are either Delta I or Delta 2. Delta 2 events involve a radiological release.
psig -pounds per square inch gauge Rem - Unit of radiation dose as defined in 10 CFR 20.1004 REMODCM-Radiological Effluent Monitoring Manual/Offsite Dose Calculation Manual RMS-Radiation Monitoring System Roentgen (R) - Unit of ionizing radiation energy absorbed in a cubic centimeter of air SF - Spent Fuel Signitfcant nature - A level which requires corrective actions (e.g., damage occurs which affects the Fuel Building's capabilities to safely store the spent fuel).
TEDE - Total Effective Dose Equivalent as defined in 10 CFR 20.1003 TS - Technical Specification Uncontrolled - Condition is not the result of planned actions by the plant staff.
Unplanned - Used to preclude the declaration of an emergency where a component or system has been removed intentionally from service (e.g., for maintenance and/or testing activities.) As used in the context of radiation releases, "unplanned" includes any release for which a discharge permit was not prepared, or a release which exceeds the conditions of the applicable permit (e.g., minimum dilution flow, maximum discharge flow, alarm setpoint reached w/o release isolation).
Unusual Event (UE) - Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant.
Valid - Indication is from instrumentation determined to be operable in accordance with the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, reports from plant personnel, or radiological survey results:
VCC - Vertical Concrete Cask '
Visible Damage - Damage to equipment or structure that is readily observable without measurements, testing or analysis.
Damage is sufficient to cause concern regarding the continued operability or reliability of the affected safety structure, system, subsystem or component (e.g., deformation due to heat or impact, denting, penetration, rupture, cracking).
ZPA - Zero Point Acceleration CY EAL Basis Document Revision 4 D-4
ISFSI DI-02 Rev. 0 Effective: WtR 3 (1 "
GENERAL NOTES FOR EAL TECHNICAL BASIS CY EAL Basis Document Revision 4 N-1
ISFSI DI-02 Rev. 0 Effective:
TJA 3 0 One (8 of 20)
The following general notes apply to the Connecticut Yankee Defueled EAL Technical Basis information:
- 1. The format of the Defueled EAL Technical Basis information was developed to address training needs, facilitate NRC approval, and facilitate future revisions and IOCFR50.54(q) evaluations.
- 2.
The EAL Technical Basis information is organized by Event Category which is shown by the title on each page:
Unplanned Release (0)
Hazards (H)
Fire/Gases (G)
Judgement (J)
Abnormal Radiation Levels (A)
CY designations use two letters followed by one number. Most event categories are from the previous revision of the Emergency Plan LO was for Offsite, G is for Gas or fire, J is for Judgrnent, A is for Abnormal radiation level).
The H designation is a NEI ISFSI designation H is Hazard. The first letter corresponds to the event category as shown above. The second letter corresponds to the emergency classification level for the IC:
U - (Notification of) Unusual Event The number designates whether the IC is the first, second, third, etc., IC for that event category under that emergency classification. For example, GUI is the designator for the first Combustible Gas/Fire category IC in the Unusual Event classification, etc.
kJ
- 3.
The format, scope and some content are based on or taken from NEI 99-01, Rev. 4, "Methodology for Development of Emergency Actions Levels".
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III CY EAL Basis Document Revision 4 N-2
ISFSI DI-02 Rev. 0 Effective: MAP 3 0.
UNPLANNED RELBEASE t
CY EAL Basis Document Revision 4 0-1
ISFSI DI-02 Rev. 0 Effective: MAR 30 2l0 (10 of 20) e
,.ein,
-A-7 Emeraencv Classification Level: UNUSUAL EVENT Posture Code: DELTA 2 CY Initiating Condition: OUI Unplanned Release Generic Information:
Any UNPLANNED release of liquid radioactivity that exceeds twice REMIODCM Instantaneous Limits for 60 minutes or longer.
Specific Information:
CY does not have a perimeter radiation monitoring system, or automated real-time dose assessment capability.
The generic term UNPLANNED has been modified for CY and defined as any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions of the applicable permit (e.g., minimum dilution flow, maximum discharge flow, alarm setpoint reached w/o release isolation).
The term "applicable permit" also means that only one permit be in place at a time (i.e., two releases cannot be going at the same time even if permits have been prepared for each).
UNPLANNED releases in excess of two times REM/ODCM limits that continue for 60 minutes or longer represent a potential degradation in the level of safety.
The final integrated dose (which is very low in the Unusual Event Classification) is not the primary concern here; it is the degradation in the plant control implied by the fact that the K>
release was not isolated within 60 minutes. Releases of duration shorter than 60 minutes would be evaluated against the non-emergency threshold for reportability.
Non-Emergency UNPLANNED releases that are reportable under I OCFR50.72 and the State of Connecticut General Statutes (Chapter 446, Section 22a-135) are listed in EO-6.
All spent fuel and GTCC has been placed in dry storage canisters and moved from the spent fuel pool to the ISFSI.
These canisters are filled with helium and sealed closed by welding. There is therefore no longer a potential for a fuel handling accident to occur and no longer the potential for a noble gas release.
CYAPCO no longer dewaters poly HICs filled with radioactively contaminated spent resin, so there is no longer the potential for a resin fire caused by the potential exothermic reaction associated with this type of activity.
Thus, the CY EAL is written as:
[.
UNPLANNED Release of Liquid Radioactivity to the Environment that Exceeds two times the REM/ODCM Instantaneous Linmts for 60 minutes or Longer.
Note: An UNPLANNED release is defined as any release for which a discharge permit was not prepared, or a release which exceeds the conditions of the applicable permit (e.g., minimum dilution flow, maximum discharge flow, alarm setpoint reached w/o release isolation).
j Source Documents/References/Calculations:
- 1. NEI 99-01, Rev. 4, "Methodology for Development of Emergency Action Levels".
- 2.
Haddam Neck Plant REMIODCM CY EAL Basis Document Revision 4 0-2
ISFSI DI-02 Rev. 0 Effective:
MAR 3 0 Norl K-/
(11 of 20)
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- 7.
CY EAL Basis Document Revision 4 H-1
ISFSI DI-02 Rev. 0 Effective:
I'AAR 3 0 7,Gr, A_
w(12of 20)
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Emeraencv Classification Level: UNUSUAL EVENT Posture Code: DELTA I CY Initiating Condition: HU] Damage to a loaded cask CONFINEMENT BOUNDARY Generic Information:
The area of particular concern for this IC is the Confinement Boundary of the loaded cask. Category basis of the occurrence of an event of sufficient magnitude the confinement boundary is damaged or violated.
This includes classification based on a loaded fuel storage cask confinement boundary loss leading to the degradation of the fuel during storage or posing an operational safety problem with respect to its removal from storage.
Specific Information:
Natural phenomenon events are addressed in the NAC-MPC SAR and the NAC C of C. Based upon a review of all the events that are identified in those documents, the event that could potentially affect the loaded cask Confinement Boundary involves a tornado driven missile or seismic event Therefore, the CY EAL 1 is written as:
Natural phenomena event adversely affecting a loaded cask CONFINEMENT BOUNDARY Accident conditions affecting a loaded cask are addressed in the NAC-MPC SAR and the NAC C of C. Based upon a review of all the events that are identified in those documents, the event that could potentially affect the loaded cask Confinement Boundary involves a tip over of a vertical concrete cask or a fire at the ISFSI or actual explosion or potential for explosion capable of causing significant damage to a loaded VCC.
Therefore, the CY EAL 2 is written as:
Accident Condition adversely affecting a loaded cask CONFINEMENT BOUNDARY I
Source Documents/References/Calculations:
- 1. NEI 99-01, Rev. 4, "Methodology for Development of Emergency Action Levels".
-2. NAC-MPC Safety Analysis Report.-
- 3. NAC Certificate of Compliance.
CY EAL Basis Document H-2 R es o
4 Revision 4
ISFSI DI-02 Rev. 0 Effective: IAAR 3 ()
i' Attachment I i
(13 of 20)
Emergencv Classification Level: UNUSUAL EVENT Posture Code: DELTA I CY Initiatinn Condition: HU2 Security Event with Potential Loss of Level of Safety to the ISFSI Generic Information:
Security events which do not represent a potential degradation in the level of safety of the ISFSl, are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72.
Specific Information:
With all spent fuel transferred from the spent fuel pool to the ISFSI, there is no regulatory requirement for security provisions at the Plant, and there are therefore no Emergency Plan security events involving the Plant.
Information and guidance regarding this type of event are contained in the ISFSI Physical Security Plan and/or Security Procedures.
Thus, the CY EAL is written as:
l Security Event at the ISFSI that results in the necessity to request LLEA to respond to the ISFSI Emergency.
Source Documents/References/Calculations:
- 1. NEI 99-01, Rev. 4, "Methodology for Development of Emergency Action Levels".
- 2.
ISFSI Physical Security Plan.
CY EAL Basis Document Revision 4 H-3
ISFSI DI-02
- -- Rev. 0 Effective: lAR 3 0 : -
. (14 of20) 1
- -,'I.. ".-
FIRE/GASES CY EAL Basis Document Revision 4 G-1
ISFSI DI-02 Rev. 0 Effective: MAR 3 0 2(YP (15 of 20)
Emergencv Classification Level: UNUSUAL EVENT Posture Code: DELTA I CY Initiating Condition: GUI Fire Generic Information:
The purpose of this IC is to address a fire in the RCA involving radioactive material. The concern is that the fire could transfer this material off-site. This excludes items such as fires within administration buildings, waste-basket fires, and other fires not in the RCA.
As established in reference 3 below, the analyzed worst case site boundary dose rate for a DAW fire is only 0.6 mrern.
Specific Information:
The area of particular concern for this IC at CY is Buildings/Areas containing radioactive material.
Thus, the CY EAL is written as:
Fire involving radioactive material in the Radiation Control Area (RCA) NOT Extinguished Within 15 Minutes of detection.
Source Documents/References/Calculations:
- 1. NE1 99-01, Rev. 4, "Methodology for Development of EnergencyAction Levels".
- 2.
- 3.
Health Physics Technical Support Document number CY-HP-199, Revised Analysis of consequences of DAW fire and other Radiologically related fires for elimination of Incipient Fire Brigade and Fire Suppression Systern.
CY EAL Basis Document Revision 4 G-2
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I ISFSI DI-02 Rev. 0 Effective:
MAR 3 0 fi?
(17 of 20)
JUDGEMENT 9-.
CY EAL Basis Document Revision 4 J-1
ISFSI DI-02 Rev. 0 Effective: MAR 3 0 ?Y (18 of 20)
Emergencv Classification Level: UNUSUAL EVENT Posture Code: DELTA I CY Initiatinp Condition: JUI Judgement Generic Information:
Conditions exist which in the judgment of the ED indicate a potential degradation in the level of safety of the Power Plant Area or ISFSI.
Specific Information:
Per the Emergency Plan, the ISFSI Shift Supervisor assumes the Emergency Director position. This EAL addresses conditions that fall under the Notification of Unusual Event emergency classification description contained in the Plan.
Thus, the CY EAL is written as:
l Any Condition Which in the Judgement of the Emergency Director Indicates Potential Degradation in the Level of Safety of the ISFSI or the Plant.
Source Documents/References/Calculations:
- 1. NEI 99-01, Rev. 4, "Methodology for Development of Emergency Action Levels".
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- 2.
Connecticut Yankee Atomic Power Company, Haddam Neck Plant Emergency Plan (Revision 7).
CY EAL Basis Document Revision 4 J-2
ISFSI DI-0 Rev. O Effective:
MAR 3 0 mfYV;-
1-11).
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(19 of 20)
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UNEXPECTED INCREASE IN ISFSI RADIATION I
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. I CY EAL Basis Document Revision 4 A-1
ISFSI DI-02 Rev. 0 Effective:
MAP 0 m3 r(20'of 20)i:sw'H l.!;
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Emergency Classification Level: UNUSUAL EVENT Posture Code: DELTA 1 CY Initiating Condition: AUI Unexpected increase in ISFSI Radiation Generic Information:
The EAL addresses unplanned increases of radiation levels that represent a potential degradation in the level of safety of the ISFSI.
Specific Information:
This EAL deals with increased radiation level at the ISFSI for any reason. The criteria used is 2x the C of C/Technical Specification levels. These levels are beyond the design basis accident levels found in chapter 11 of the NAC FSAR.
The EAL assumes that the indication is from instrumentation determined to be operable or verified by other independent methods such as radiological survey results, and therefore is considered valid.
Thus, the CY EAL is written as:
ISFSI event causing valid radiation readings for irradiated spent fuel in Dry Storage Cask (i.e., > 2 times NAC certificate of compliance)
Survey of VCC Side > 340 mrem/hr (Neutron and Gamma)
OR Survey of VCC Top > 200 mrem/hr (Neutron and Gamma)
OR Survey of VCC Inlet/Outlet.> 220 mrem/r (Neutron and Gamma)
Source Documents/References/Calculations:
-1 CofC1025 for eNAC trationa1 nc. Multi-Pup6s4Canister (NAC-MPC) System
- 2.
NEI 99-01, Rev. 4, "Methodology for Development of Emergency Action Levels".
j CY EAL Basis Document Revision 4 A-2