Text

Reportable Event Rad 1.4, Rev. 10
	ML100700493
Person / Time
Site:	Oyster Creek
Issue date:	02/24/2010
From:	; - No Known Affiliation
To:	; Office of Information Services
References
	FOIA/PA-2009-0214 RAD 1.4, Rev 10
	Download: ML100700493 (25)
	v • d • e

A.

LS-AA-1120 Revision 10 Page 13 of 98 REPORTABLE EVENT RAD 1.4:

Liquid Effluent Release Requirement: 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 20.2203 (a)(3)

§ 50.73(a)(2)(viii)(B): The licensee shall report ... any liquid effluent release that, when averaged over a time period of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , exceeds 20 times the applicable concentrations specified in Appendix B to 10 CFR 20, Table 2, Column 2, at the point of entry into the receiving waters (i.e., unrestricted area) for all radionuclides except tritium and dissolved noble gases.

§ 20.2203(a)(3): ... each licensee shall submit a written report ... after learning of...

levels of radiation or concentrations of radioactive material in -

(i) A restricted area in excess of any applicable limit in .the license; or (ii) An unrestricted area in excess of 10 times any applicable limit set forth in this part or in the license (whether or not involving exposure of any individual in excess of the limits in 10 CFR 20.1301).

Time RequiredNotification(s):

Limit NONE No immediate notification is required for this Reportable Event.

Time Required Written Report(s):

Limit 30 DAYS Submit a written report to the NRC within 30 days of discovery of levels of radiation or concentrations of radioactive material in excess of the limits of

§ 20.2203(a)(3). Prepare and submit the report in accordance with the requirements of § 20.2203(b) and (c). [ 10 CFR 20.2203(a)(3)] .[T- 14]

60 DAYS Submit a Licensee Event Report to the NRC within 60 days of discovery of the occurrence of any liquid effluent release that exceeded the limits of

§ 50.73(a)(2)(viii)(B), if the release occurred within 3 years of the date of discovery. [10 CFR 50.73(a)(1), 10 CFR 50.73(a)(2)(viii)(B)] [T-10]

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LS-AA-1 120 Revision 10 Page 14 of 98 REPORTABLE EVENT RAD 1.4 (Cont'd)

Discussion:

0 NRC guidance on this Reportable Event is provided in NUREG 1022, Revision 2, Section 3.2.9.

o0 The occurrence of this event may require activation of the Emergency Plan. In that case, notification will be made per the Emergency Plan, and a duplicate notification per this Reportable Event is not required. [See SAF 1.1]

0 "Unrestricted Area" means any area at or beyond the site boundary, access to which is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials, and any area within the site boundary used for residential quarters or industrial, commercial, institutional and recreational facilities.

0 . The location used as the point of release for calculation purposes should be determined using the expanded definition, listed above, for an unrestricted area as specified in NUREG 0133 to maintain consistency with the TS.

Related ReportableEvents:

0 RAD 1.1, Events Involving Byproduct, Source or Special Nuclear Material That Cause or Threaten to Cause Significant Exposure or Release

o RAD 1.2, Events Involving Loss of Control of Licensed Material That Cause or.

Threaten to Cause Exposure or Release

References:

o NUREG 1022, Revision 2 0 NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants" 0 NRC Generic Letter 85-19, "Reporting Requirements on Primary Coolant Iodine Spikes," September 1985 o 10 CFR 50.73 o 10 CFR 20.2203 Reportability Reference Manual

LS-AA- 1120 Revision 10 Page 88 of 98 REPORTABLE EVENT RAD 1.34:

Industry Groundwater Protection Initiative (GPI) Voluntary Communication Requirement: NEI 07-07, "Industry Ground Water Protection Initiative - Final Guidance Document" (August 2007)

Objective 2.2: Make informal communication as soon as practicable (no later than the end of the next business day) to appropriate State/Local officials, with follow-up notification to the NRC, as appropriate, regarding significant on-site leaks/spills into ground water and on-site or off-site water sample results exceeding the criteria in the REMP as described in the ODCM Objective 2.3: Submit a written 30-day report to the NRC for any water sample result for on-site ground water that is or may be used as a source of drinking water that exceeds any of the criteria in the licensee's existing REMP as described in the ODCM ... for 30-day reporting of off-site water sample results. Copies of the written 30-day reports for both on-site and off-site water samples shall also be provided to the appropriate State/Local officials.

Objective 2.4: Document all on-site ground water sample results and a description of any significant on-site leaks/spills into ground water for each calendar year in the Annual Radiological Environmental Operating Report (AREOR) for REMP or the Annual Radioactive Effluent Release Report (ARERR) for the RETS as contained in the appropriate reporting procedure, beginning with the report for calendar year 2006.

Time Required Notification(s):

Limit END OF NEXT BUSINESS DAY Perform voluntary informal communications to State/local offsite agencies (as determined per HR-AA- 1001), NEI (GW Notice@nei.org) and the ANI for eventsrequiring voluntary communications as determined from the flowchart in Attachment 2. Complete Attachment 1 and provide the information on the completed attachment to the State/local offsite agencies [NEI 07-07, Objective 2.2].

30 DAYS Submit a voluntary written 30-day report to the NRC for any GPI water sample result for onsite groundwater that is or may be used as a source of drinking water that exceeds any of the criteria in the licensee's existing REMP as described in the ODCM for 30-day reporting of offsite water sample results. Copies of the written 30-day reports for both onsite and offsite water samples shall also be provided to the appropriate State/Local officials. [NEI

.07-07, Objective 2.3].

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LS-AA- 1120 Revision 10 Page 89 of 98 REPORTABLE EVENT RAD 1.34 (Cont'd)

Time Required Written Report(s):

Limit ANNUAL REPORT Voluntarily document all onsite groundwater sample results and a description of any significant onsite leaks/spills into groundwater for each calendar year in the Annual Radiological Environmental Operating Report (AREOR) for REMP or the Annual Radioactive Effluent Release Report (ARERR) for the RETS as contained in the appropriate reporting procedure, beginning with the report for calendar year,2006. [NEI 07-07, Objective 2.4].

Discussion:

o Applicability (Read entire section before determining reportability nature of the event)

The voluntary communications under this reportable event are applicable to elevated groundwater radionuclide concentrations or leaks / spills from station sources containing licensed material that meet the criteria in NEI 07-07, and are any of the following:

Newly occurring, event-related releases of licensed material.

Newly identified elevated radionuclide concentrations detected in groundwater samples above expected baseline levels for releases that have not been previously reported.

Condensation from steam releases to the air that reach the ground. Only the radionuclides in the condensation need to be considered.

Reportings of "unpermitted releases of radionuclides" as defined in 415 ILCS 5/13.6(c) from Illinois nuclear power plants per LS-MW-1320, Reportable Event RAD 3.4.

This reportable event is NOT applicable for any of the following:

Releases from station sources containing licensed material exclusively to the air.

Newly identified elevated radionuclide concentrations in groundwater monitoring wells or remediation wells installed for previously reported releases of licensed material.

Newly identified elevated radionuclide concentrations in monitoring wells attributable to changes in baseline levels not tied to station operations.

Routine batch or continuous liquid or gaseous releases conducted in accordance with Station procedures.

Releases of radioactive materials attributed solely to recapture (See NRC RIS 2008-03).

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LS-AA-1 120 Revision 10 Page 90 of 98 REPORTABLE E VENT RAD 1. 34 (Cont'd)

Releases contained wholly inside a plant building, containment unit or an outside structure with a non-permeable surface.

A spill or leak to a semi-impermeable or impermeable surface that is re-contained or remediated before the close of the next business day.

Releases, leaks or spills of radionuclides directed to NPDES (NJPDES in New Jersey) permitted outfalls.

Releases, leaks or spills of liquid Radwastes whose chemical makeup would interfere with the tritium analysis.

o Evaluation of Releases Evaluate releases for reportability as follows:

Review the circumstances of the release for applicability.

Determine reportability of the spill or leak or sample result(s) using the flowchart in Attachment 2.

Report the spill or leak or sample result(s) as required.

o End of next business day State/Local offsite agency notifications Communication to the designated State/Local officials shall be made before the end of the next business day if an inadvertent leak or spill to theenvironment has or can potentially get into the groundwater and exceeds any of the following criteria:

If a spill or leak exceeding 100 gallons from a source containing licensed material,

If the volume of a spill or leak cannot be quantified but is likely to exceed 100 gallons from a source containing licensed material, or e Any leak or spill, regardless of volume or activity, deemed by the licensee to warrant voluntary communication.

"Leak or spill" events that meet the NEI criteria shall be communicated regardless of whether or not the onsite groundwater is, or could be used as, asource of drinking water.

The quantity of liquid resulting from leaks or spills of solid materials, waste or steam leaks should be evaluated with respect the criteria above.

"Source containing licensed material" means a liquid, including steam, for which a statistically valid positive result is obtained when the sample is analyzed to a priorilower limits of detection (analytical sensitivity). The analytical sensitivity for identifying a source containing licensed material is, at a minimum, the licensee's lower limits of detection that are required for radioactive liquid effluents for all isotopes.

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LS-AA-1120 Revision 10 Page 91 of 98 REPOR TABLE E VENT RAD 1. 34 (Cont'd)

Spills or leaks with the "potential to reach groundwater" means:

Spills or leaks directly onto native soil or fill,

Spills or leaks onto an artificial surface (i.e. concrete or asphalt) if the surface is cracked or the material is porous or unsealed.

Spills or leaks that are directed into unlined or non-impervious ponds or retention basins (i.e. water hydrologically connected to groundwater).

Determine the designated State/Local local offsite agencies to be notified in accordance with HR-AA-1001. Contact onsite Regulatory Assurance to determine if there are any existing station commitments to notify specific local agencies of these events. The station shall document any agreement with State/Local officials'that differs from the NEI 07-07 industry guidance. For example, some state or local authorities have indicated that they do not wish leaks/spills to be included in the voluntary communication protocol or that the voluntary communication should be completed in a shorter timeframe. These agreements should be indicated on the HR-AA- 1001 notification list.

Communication with the designated State/Local officials shall be made before the end of the next business day for a water sample result of:

Offsite groundwater or surface water that exceeds any of the REMP reporting criteria for water as described in the ODCM, or

Onsite surface water, that is hydrologically connected to groundwater, or onsite groundwater that is or could be used as a source of drinking water, that exceeds any of the REMP reporting criteria for water as described in the ODCM.

Document the basis for concluding that the onsite groundwater is not or would not be considered a source of drinking water. Examples of a defensible basis are documents from the regulatory agency with jurisdiction over groundwater use.

When communicating to the State/Local officials, be clear and precise in quantifying the actual release information as it applies to the appropriate regulatory criteria (i.e. put it in perspective). Complete Attachment 1 and provide the information listed in the attachment as part of the informal communication.

Contact NEI by email to GWNotice@nei.org and the ANI by telephone as part of a voluntary. communication event described above.

ReportabilityReference Manual

LS-AA- 1120 Revision 10 Page 92 of 98 REPORTABLE E VENT RAD 1.34 (Cont'd) o 4-Hour NRC ENS Notification The 4-hour NRC ENS notification described under Reportable Event (SAF 1.9) is not mandatory under this reportable event because:

The State and Local communications being performed are voluntary in nature and are not required by any Federal or State regulations, and NEI and NRC are agreed that NRC will be receiving a voluntary 30-day report of the event.

However, to verify the need for performing the 4-hour NRC ENS notification described under Reportable Event (SAF 1.9), refer to the guidance for performing voluntary reporting to the NRC in LS-AA-1400, Event Reporting Guidelines 10 CFR 50.72 and 50.73 (NUREG-1022, Revision 2).

o 30-Day NRC Report All groundwater samples shall be analyzed and compared to the standards and limits contained in the station's REMP as described in the ODCM. Pre-2006 ODCM requirements specify a written 30-day report to the NRC for KEMP sample results that exceed any of the REMP reporting criteria. Under the GPI, a written 30-day NRC report is also required for all onsite sample results that exceed any of the REMIP reporting criteria and could potentially reach the groundwater that is or could be used in the future as a source of drinking water. If the groundwater is not currently used for drinking water but is potable, each station should consider the groundwater as a potential source of drinking water (See NEI 07-07, Objective 2.2, Acceptance Criterion b, for documentation needed).

The initial discovery of groundwater contamination greater than the REMP reporting criterion is the event documented in a written 30-day report.. It is not expected that. a written 30-day report will be generated each time a subsequent sample(s) suspected to be from the same "plume" identifies concentrations greater than any of the REMP criteria as described in the ODCM. The station should evaluate the need for additional reports or communications based on unexpected changes in conditions.

The 30-day NRC report should include the information listed in NEI 07-07, Objective 2.3, Acceptance Criterion b. All written 30-day NRC reports are to be concurrently forwarded to the designated State/Local officials contacted during the end of next business day State/Local offsite agency notifications.

o Annual Report The Annual Radiological Environmental Operating Report (AREOR) for REMP or the Annual Radioactive Effluent Release Report (ARERR) for the RETS shall include the information listed in NEI 07-07, Objective 2.4, Acceptance Criteria b and c.

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LS-AA-1 120 Revision 10 Page 93 of 98 REPORTABLE EVENT RAD 1.34 (Cont'd)

Definition of Terms:

1. Discharme: This term includes but is not limited to, any leaking, pumping, pouring, emitting, emptying, or dumping of material that contain radioactive materials. For purposes of this guidance, the term discharge shall not include any discharge* of licensed radioactive material to the licensed discharge point that is authorized by a license issued by the Nuclear Regulatory Commission (NRC) or a permit issued by other authorized federal or state agency.

2. New Release: The detection of a radionuclide not previously identified at specified sampling location, the unexpected increase in concentrations of a previously detected radionuclide, or a new discharge in a previously impacted area. A new release does not include expected migration of a known or historic release.

3. Confirmed result:

i) Confirmation via onsite analysis of two independent samples that the released material contains radionuclides.

ii) Confirmation via offsite analysis of two (2) independent samples that the concentration exceeds the reporting values.

iii) If material discharged is known to contain radionuclides via means other than sampling (e.g.,

the release is kniown to have originated from a system known to contain radionuclides), then the result is considered confirmed without sampling and analysis. An analysis, however, must be performed to identify the specific radionuclide concentration, although this analysis must not delay notification.

4. Knowledge of Process: The use of documented evidence (e.g., sampling data) or an individual(s) knowledge of the process (e.g., inputs, -potential inputs and operating status of a system) to determine that a system contains, potentially contains or does not contain radiologically 'contaminated liquids.

5. Recapture: Previously discharged radioactive materials in gaseous or liquid effluents (does not apply to radioactive materials in solid materials or soil) that are returned from the environment to an operating nuclearpower facility or to an operating nuclear fuel cycle facility. The NRC has determined that radioactive materialproperly released in gaseous or liquid effluents to the environment is not considered licensed material when returned to the facility as long as the concentration of radioactive material does not exceed 10 CFR Part 30, "Rules of General Applicability to Domestic Licensing of Byproduct Material," exempt concentration limits (otherwise a general or specific license is required). The water containing radioactive material returned from the environment can be used by the licensee and returned to the environment without being considered a new radioactive material effluent release. The basis for this determination is that the licensee has already accounted for this radioactive material when the effluent was originally released, provided that the subsequent use, possession, or release does not introduce a new significant dose pathway to a member of the public.

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LS-AA-l 120 Revision 10 Page 94 of 98 REPORTABLE EVENT RAD 1.34 (Cont'd)

6. Significant (leak or spill): An item or incident that is of interest to the public or stakeholders. It does not imply or refer to regulatory terminology nor is it intended to indicate that the leak or spill has public health and safety or environmental protection consequences.

7. Voluntary: Not required by statute or regulation, but is required by Exelon commitment to the /

NEI Ground Water Protection Initiative.

Related ReportableEvents:

o RAD 1.4, Liquid Effluent Release o RAD 1.8, Effluent Release o RAD 1.21, Release Of Radionuclides o RAD 1.22, Release Of Hazardous Substance (Including Radionuclides) o RAD 3.1, Events Involving Byproduct, Source, Or SNM Causing Significant Exposure Or Release o RAD 3.2, Events Involving Licensed Material Causing Exposure Or Release o SAF 1.9, News Release or Notification of Other Government Agency o RAD 3.4, Unpermitted Releases of Radionuclides at Illinois Nuclear Power Plants

References:

o NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document (August 2007) o NRC Regulatory Issue Summary (RIS) 2008-03, Return/Re-Use of Previously Discharged Radioactive Effluents o CY-AA-170-4000, Radiological Groundwater Protection Program Implementation o EN-AA-407, Response to Unplanned Discharges, Spills, and Accumulations of Licensed Radionuclides to Groundwater, Surface Water or Soil o ANI Nuclear Liability Insurance Guideline 07-01, Potential for Unmonitored and Unplanned Off-Site Releases of Radioactive Material Reportability Reference Manual

LS-AA- 1120 Revision 10 Page 95 of 98 ATTACHMENT 1 INDUSTRY GROUNDWATER PROTECTION INITIATIVE (GPI)

VOLUNTARY COMMUNICATION

1. Provide a statement that a voluntary communication is being made as part of the NEI Ground Water Protection Initiative.

2. Station Name:

3. Station Address:

4. Date and Time of Spill / Leak or Sample Result(s):

5. Specific Location of Release or Sample Result(s):

6. Source of the Spill / Leak (if known):

7. Is the leak stopped and the spill contained? YES NO

8. List of verified radionuclide contaminant concentrations (in pCi/L) in material released:

,Tritium (H3) pCi/L pCi/L pCi/L

9. Estimate of the potential or bounding annual dose to a member of the public, if available at this time:

10. Actions already taken in response to containing and mitigating the release and a general description of future actions.

11. Estimated time / date station will provide additional information or follow-up.

Date: Time:

12. Name of Individual Making Report: Telephone No.

Reportability Reference Manual

LS-AA-1 120 Revision 10 Page 96 of 98 ATTACHMENT 2 COMMUNICATION PROTOCOL FOR LEAK/SPILL AND GROUNDWATER SAMPLE RESULTS LEAKISPILL, APPLICABLE GROUNDWATER OR INADVERTENT EVENT OR EVENT SURFACE SAMPLE PERTURBATION CNNETED ReportabilityReference Manual

OP-AA-1 06-101 ExeIon. Revision 12 Page 1 of 14 Nuclear Level 3 - Information Use SIGNIFICANT EVENT REPORTING

1. PURPOSE 1.1. This procedure describes the protocol to be used for reporting occurrences and significant events to ensure proper response is initiated both onsite and offsite, and to ensure that appropriate management is promptly informed of the event or occurrence. It further delineates the Duty Officers' responsibilities and qualifications; specifically, those of the Duty Station Manager, Nuclear Duty Officer, and Duty Executive.

2. TERMS AND DEFINITIONS 2.1. Station Duty Team is a list of pre-designated on-call personnel.

3. RESPONSIBILITIES 3.1. Duty Executive 3.1.1. The Duty Executive is responsible to facilitate rapid event response for significant events.

3.2. Nuclear Duty Officer (NDO) 3.2.1. The Nuclear Duty Officer is the designated representative of Exeion Nuclear corporate management. The NDO is responsible for the initial notification to senior corporate management of an operational event or occurrence at one of the sites or related location, initial event response, and augmentation as required based on the nature of the event..

3.2.2. The NDO is appointed by the Senior Vice President and/or the Chief Nuclear Officer (CNO).

3.2.3. The Nuclear Duty Officer should be a previously-licensed/certified Senior Reactor Operator. The NDO should have experience as a member of a site operations management team.

3.3. Duty Station Manager 3.3.1. The Duty Station Manager is the designated representative of station management to whom initial notification of an event or occurrence is made by the Shift Manager.

3.3.2 The Duty Station Manager is responsible to create a one page executive summary (including simplified drawings or sketches) for events described in section 4.2.3.5 of this procedure.

OP-AA-1 06-101 Revision 12 I Page 2 of 14 3.4. Shift Manager 3.4.1. The Shift Manager is the designated representative of Station senior management and has command and control authority for the site.

3.4.2. The Shift Manager is responsible for directing appropriate immediate actions to place the unit(s) in a safe and stable condition following any transient/event, maintaining safe and conservative operation of the facility as the highest priority.

3.4.3. The Shift Manager is responsible for initial determination of all reportable or potentially reportable items, and is responsible to ensure that appropriate notifications are performed.

3.4.4. The Shift Manager is responsible for notification to Station Security of a Potential Sabotage/Tampering Event and have Security screen the event in accordance with SY-AA-101-132, "Assessment and Response to Suspicious Activity and Security Threats," to determine if any security related actions, notifications or reporting requirements are required.

3.5. Functional Area Duty Manager 3.5.1. During duty period, individual must be fit for duty at all times, available, and reachable by telephone, pager, or cell phone at all times.

3.5.2. The functional area duty person shall functionas the single point of contact for the functional area during his/her duty period. This responsibility includes:

1. When contacted (telephone, text page, etc.), the duty person must respond to all requests for emergent assistance, including conference calls.

2. Maintaining a functional area contact list so that the duty person is able to contact other members of the functional area as needed to assist with a particular issue or problem.

3. The functional area contact list should reflect individuals that are unavailable and their respective backup.

4. Assuming leadership for resolving functional area issues affecting one or more sites.

3.5.3. Functional area duty individuals have the authority to re-assign personnel within the functional area as needed to best address the issue.

3.5.4. Duty personnel must support all emergent work requests, 3.5.5. Duty personnel should interface with the sites as required and as requested by the NDO.

3.5.6. When duty personnel are interfacing with the individual sites on emergent issues, the NDO should be updated as necessary.

OP-AA-106-101 Revision 12 Page 3 of 14

4. MAIN BODY 4.1. Declaration of Emergency Plan (EP) Classification 4.1.1.

For declarations of any EP classification, notifications shall be made in accordance with applicable site emergency plan procedures.

1. Initial notification to the NDO shall be made by the Duty Station Manager or Transmission Operations dispatcher/System Operations dispatcher.

2. The NDO should immediately call the affected station to obtain plant status.

3. The NDO shall promptly report any EP event classification to the Duty Executive and the Chief Nuclear Officer.

4. The CNO shall notify the CEO of an EP emergency declaration in a timeframe consistent with the impact of the event.

5. The NDO shall perform the EP duties for the classified event per EP-AA-1 12-400-F-01, Nuclear Duty Officer Checklist.

4.2. Other Events Requiring Regulatory or Offsite Notification NOTE: Attachment 2, Shift Manager Notification Worksheet, may be used by the Shift. Manager as an aid to make the proper notifications.

4.2.1. The Shift Manager will notify station Security to perform an assessment of the potential sabotage/tampering event in accordance with SY-AA-101-132, "Assessment and Response to Suspicious Activity and Security Threats."

4.2.2. The Shift Manager will notify the Duty Station Manager for any of the events listed in Attachment 1.

1. If the Duty Station Manager cannot be reached, then the Shift Manager shall ensure notifications are made in accordance with Attachment 1.

4.2.3. The Duty Station Manager shall use Attachment 1 in determining communication requirements.

4.2.4. The Duty Station Manager is responsible for initial coordination of site response to the event or occurrence, including notification to station senior management, the NDO, and the Chief Nuclear Officer as described in step 4.2.3.5 below.

1. The Duty Station Manager is responsible to ensure that the Nuclear Duty Officer has been notified and has adequate information for communication.

OP-AA-1 06-101 Revision 12 Page 4 of 14

2. The Duty Station Manager will mobilize onsite and offsite personnel to support the needs of the Shift Manager.

3. The Duty Station Manager will mobilize the Station Duty Team personnel upon entry into a 24-hour or less unplanned shutdown LCO. The Duty Station Manager should consider mobilizing the Duty Team upon entry into a 72-hour or less unplanned shutdown LCO.

4. The Duty Station Manager will establish a conference call to discuss repair plans, normally within 30 minutes, following entry into a 24-hour or less unplanned shutdown LCO. Individuals that should be included on this conference call include the Duty Station Manager, Site VP, Plant Manager, Duty Executive, and NDO.

5. The Duty Station Manager will provide a one page executive summary to the Chief Nuclear Officer within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for a plant event involving any of the following:

- Unscheduled release of radiation; including discovery of tritium

- Likely news media interest events;

- Serious personnel injury;

. . Events that have the potential for significant financial impact;

- Unplanned reactor trips, unplanned load reductions, or any transients that proceed differently than would be expected or that involve significant complications.

4.3. Upon notification, the Nuclear Duty Officer should review the event with the Duty Station Manager and/or Site Vice President (SVP) and confirm that proper classifications and notifications have been made. Individual events may fit into several categories, e.g., EP events, NRC ENS notifications, unplanned shutdown, etc. The NDO ensures that notifications in each applicable category are completed.

4.3.1. The NDO should immediately report to the Duty Executive, Chief Nuclear Officer, and other appropriate executives, events reported by the Duty Station Manager involving the following:

- Unscheduled release of radiation; including discovery of tritium

- Likely news media interest events;

- Serious personnel injury;

- Events that have the potential for significant financial impact;

- Unplanned reactor trips, unplanned load reductions, or any transients that proceed differently than would be expected or that involve significant complications.

4.3.2. The NDO should report other events during the next working day.

4.3.3. The CNO shall notify the CEO of events described in step 4.3.1. in a timeframe consistent with the impact of the event.

OP-AA-106-101 Revision 12 Page 5 of 14 4.4. A duty call-out list should be prepared identifying the Duty Executive, NDO, and Duty Station Manager for each site. The call-out list should contain appropriate telephone and pager numbers. This call-'out list should be distributed to appropriate personnel.

4.5. Sites and the corporate office should establish and maintain a call-out structure of key personnel on a rotational basis. This structure will serve as the basis for the call-out list described above.

4.6. The on-call Duty Executive, NDO; and Duty Station Manager shall be available at all times during a scheduled tour of duty.

4.6.1. To accomplish this objective, each individual shall carry an operable personal pager at all times and have ready access to telephone communications.

4.6.2. The NDO and Duty Station Manager shall be fit for duty at all times during a scheduled tour of duty.

5. DOCUMENTATION - None

6. REFERENCES 6.1. OP-AA-1 06-101-1001, Event Response Guidelines 6.2. SY-AA-101-132, Assessment and Response to Suspicious Activity and Security Threats 6.3. OP-AA-300-1540, Reactivity Management Administration 6.4. NERC Standard CIP-001, Sabotage Reporting

7. ATTACHMENTS 7.1. Attachment 1, Notification Requirements 7.2. Attachment 2, Shift Manager's Notification Worksheet 7.3. Attachment 3, Special Notification and Reporting Requirements (Oyster Creek Only)

OP-AA-106-101 Revision 12 Page 6 of 14 ATTACHMENT 1 Notification Requirements Page 1 of 2 EVENT NOTIFY Reactivity Event, including any mis-positioned Control Rod events. El Site VP Hazardous Material Incident.

Shutdown Risk Classification > Scheduled) or Online Risk Classification E] Plant Manager

> Orange Fitness for Duty Event LI Operations Director Injury requiring offsite medical attention or transportation via ambulance to an offsite medical facility. See Note I in "Notify" column.

Major enforcement actions, fines or other sanctions or a serious E] Nuclear Duty Officer operating event that could lead to this action, including events, which have been, or may be, brought to the attention of NRC upper management. El Senior Resident Inspector Non-routine communications to/from NRC management, e.g. requests for Enforcement Discretion or Temporary Waiver of Compliance. El Site Oversight Manager Action Level II or greater chemistry parameters that lead to a plant derate or shutdown.

El Site Medical (injuries only)

An event of potential sabotage/tampering in which Station Security is coordinating investigations for confirmation of "Confirmed Tampering " in Note 1:

accordance with SY-AA-101-132. Transport of a potentially contaminated injured worker to an Any event or operating condition that occurs that is not enveloped in the offsite medical facility requires plant design basis notification to; Any event that proceeds in a way significantly different than expected; E- Emergency Communications Dispatch Center IEMA (800 -782-7860 for example:

MW Stations only) and

Unexpected 1/2 scram is received; L] Iowa HSEMD (515-323-4360) if being transported from Quad Cities.

" Any unexpected significant plant transient; Oyster Creek Only:

LCO action that will not be met within allowed time requirement;

Refer to OP-OC-106-101-1003, Contaminated Injured

Initiation of a prompt investigation or similar (OP-AA-106-101-1001). Person Worksheet.

Events of potential public interest.

Notification and response by Local Law Enforcement ENS El Site VP Oyster Creek Only: Sea Turtle notifications are to be made via ENS per LS-AA-1400 El Plant Manager El Operations Director El Nuclear Duty Officer El Experience Assessment /

Regulatory Assurance Manager El Senior Resident Inspector El Site Nuclear Oversiqht Manaqer

OP-AA-106-101 Revision 12 Page 7 of 14 ATTACHMENT I Notification Requirements Page 2 of 2 EVENT NOTIFY 0 Site VP Shutdown LCO Entry, forced entry into a 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or less shutdown LCO. 'El Plant Manager 1:1 Operations Director Nuclear Duty Officer Duty Maintenance Director Duty Engineering Director Work Week Manager Senior Resident Inspector Unplanned shutdown*or load reduction

-]Site VP

[:iplant Manager

-0Operations Director E]Nuclear Duty Officer

[:]Duty Maintenance Director E-Duty Engineering Manager

[-]Work Management Director

[-]Work Week Manager E-]Senior Resident Inspector

[]Simulator Coordinator ElSite VP Significant breakdown of plant radiological or environmental controls Any serious personnel radioactive contamination requiring extensive on- -]Plant Manager site decontamination or outside assistance.

ElOperations Director Fish or wildlife mortality attributable to plant operations Operating conditions that are non-compliant with environmental permit [:]Nuclear Duty Officer conditions or environmental regulations; or operating conditions that could reasonably escalate into non-compliant conditions. -]Duty RP Manager Tritium sample results above limits

[]Senior Resident Inspector El]Corporate Environmental Manager (for non-radiological environmental events)

OP-AA-1 06-101 Revision 12 I Page 8 of 14 Attachment 2 Shift Manager's Notification Worksheet Page 1 of 5 DATE/TIME of Event EVENT DESCRIPTION (use additional paper as necessary)

CURRENT POWER/MODE PRIOR POWER/MODE RECOVERY PLAN IF REQUIRED (use additional paper as necessary)

Does the event /condition require an EP Notify:° Tlm;..

Declaration? SOS / OD YES, Perform required communications NRC Operations Center after completing notifications required per site specific EP procedures Duty Station Manager (DSM)

Date and Time all notifications

. PM have been completed by DSM

. SVP 0 NDO w Manager, Reg. Assurance Group E ANI and INPO (Alert or higher EAL)

NRC Senior Resident Inspector Does the event/ condition require reporting to Iftime permits: Independent SRO peer check K Date,4 * .TIrno the NRC via ENS or to anoutside agency per completed NRC Form 361.

Exelon Reportability Reference Manual? SRO Signature Notify:

YES, Perform the following:-- SOS / OD Date and Time all notifications NRC Operations Center have been completed by DSM DSM

PM

SVP

NDO

Manager, Reg. Assurance Group

Manager,. Nuclear Oversight Group

Communication (as required)

Environmental (as required)

NRC Senior Resident Inspector

OP-AA-1 06-101 Revision 12 Page 9 of 14 Attachment 2 Shift Manager's Notification Worksheet Pace2 of 5 Notify: DateW I Thme Did the following events/condition occur?.

Oil discharge into/upon navigable waters or SOS / OD adjoining shoreline. National Response Center (EPA)

EPA YES, Perform notifications --

NRC Operations Center i DSM

" PM Date and Time all notifications Oyster Creek Only " SVP onl have been completed by DSM NOTE:

" NDO

" Manager, Reg. Assurance Group Refer to Attachment 3 for additional notification and reporting instructions. " First Energy (JCP&L) (Oyster Creek Only)

NRC Senior Resident Inspector i I Oyster Creek OnlyI Notify: Dated,,-` Kij" Time,.

SOS / OD Did any of the following events/conditions State DEP occur?

Ocean County Health Department

" A leak or discharge of petroleum product, NRC Operations Center or hazardous substance, from the DSM warehouse drop tank.

PM Date and Time all notifications

SVP have been completed by DSM

" Spill or discharge of hazardous materials in a quantity that constitutes a reportable

NDO discharge into or upon surface waters, " Manager, Reg. Assurance Group groundwater, or onto the ground (incl, " First Energy (JCP&L)

Petroleum products)

YES, Perform notifications -)

NOTE:

Refer to Attachment 3 for additional notification and reporting instructions. NRC Senior Resident Inspector Did the following events/condition occur? Notify: 04* It Iffitti, -

Release of designated hazardous substances SOS / OD in amounts equal to or in excess of a EPA National Response Center (EPA) reportable quantity.

State DEP

[ YES, Perform notifications -- Lacey Twp. Police (Oyster Creek Only)

Oyster Creek Only NRC Operations Center DSM NOTE: " PM Date and Time all notifications

" SVP have been completed by DSM Refer to Attachment 3 for additional notification and reporting instructions.

NDO

Manager, Reg. Assurance Group

First Energy (JCP&L) (Oyster Creek Only)

NRC Senior Resident Insoector

OP-AA-106-101 Revision 12 Page 10 of 14 Attachment 2 Shift Manager's Notification Worksheet Page 3 of 5 Did any of the following events / conditions Notify: 10.4 "1 ý ý:Arne occur?

SOS / OD

RCRA Program Exception Report State DEP Submitted Environmental Noncompliance NRC Operations Center endangering health or Environment DSM

PM Date and Time all notifications

[ YES, Perform notifications -4

SVP have been completed by DSM

NDO OysterCk OnlyC

Manager, Reg. Assurance Group NOTE:

NRC Senior Resident Inspector Refer to Attachment 3 for additional notification and reporting instructions.

Did any of the following events / conditions occur?

Notify: Maftia-. Ik T6me SOS / OD Incident threatening health or environment or National Response Center release equal to or in excess of EPA i reportable quantity State DEP NRC Operations Center YES, Perform notifications --

DSM Date and Time all notifications

" PM Oyster Creek Only have been completed by DSM

" SVP NOTE:

NDO

Manager, Reg. Assurance Group Refer to Attachment 3 for additional notification and reporting instructions.

NRC Senior Resident Inspector 4 4 4 Notify:

SOyster Creek Ony0 SOS /.OD Ocean County Police Dispatcher Did the following events/condition occur?

" Loss of 10 or more sirens NRC Operations Center

" Spurious activation signal with 1 or more DSM Date and Time all notifications sirens still sounding " PM have been completed by DSM

( YES, Perform notifications -4 " SVP

" NDO NOTE:

" Manager, Reg. Assurance Group Refer to Attachment 3 for additional notification and reporting instructions. NRC Senior Resident Inspector

OP-AA-106-101 Revision 12 Page 11 of 14 Attachment 2 Shift Manager's Notification Worksheet Page 4 of 5 Did any of the following events/conditions occur? Notify:

1. Reactivity management event per OP-AA-300-1540. SOS / OD

2. Hazardous material incident Date and Time all

3. Sentinal / Oram Risk level is / or is planned to be ORANGE DSrM notifications have been or RED PM completed by DSM

4. Fitness-for-duty event SVP

5. Injury resulting in offsite medical attention NDO

6. Major enforcement action, fine, or other sanction; serious Manager, Nuclear Oversight operating event that could result in such action; including events which have been or maybe brought to NRC upper Group management attention Communication (as required)

7. Non-routine communications to / from NRC Environmental (as required)

8. Reactor Water Chemistry above or at EPRI Action Level II 9: Any event or operation condition outside plant design basis NRC Senior Resident Inspector

10. Any event that proceeds differently than expected

a. Unexpected 1/2A-scram

b. Unexpected, significant plant transient

c. LCO action that will.not be met within deadline

d. Initiation of a prompt investigation

e. Unplanned Risk Change

[] YES, Perform notifications -->

Notify:

1. Did the event/condition force entry into a _<72hour SOS / OD shutdown LCO?

2. Did the event/condition force aplant shutdown or unplanned DSM Date and Time all power reduction?

Work Week Manager notifications have been le. Power reductions required due to high discharge

Director ,Work Mgmt. (via WWM) completed by DSM temperature or required to perform an activity such as main

Eng. Duty Manager condenser backwashing.

PM 31 Did the event/condition involve a significant breakdown of

SVP plant radiological or environmental controls? NDO

Manager, Nuclear Oversight Group YES, Perform notifications 4

Simulator Coordinator NRC Senior Resident Inspector

OP-AA-106-101 Revision 12 Page 12 of 14 Attachment 2 Shift Manager's Notification Worksheet Page 5 of 5 Notify: ý- DW5ýZ Tlffiiii, ý ý -

Oyster Creek Ony SOS/ OD Date and Time all notifications Did any of the following TS 6.9.3 Unique Reportability have been completed by DSM Requirement events occur?

1. Leak test on a sealed source that yielded >0.005 pCi of removable contamination

2. A reportable event pursuant to the ODCM DSM

Work Week Manager

3. EMRV or Safety Valve challenge or failure (non LER

Director ,Work Mgmt. (via reportable).

WWM)

a. A "challenge" is an automatic actuation outside

Eng. Duty Manager (via purposeful surveillance or testing. WWM)

PM

b. A special report is to be sent to the NRC within 60 " SVP days. " NDO

" Manager, Nuclear Oversight

4. Any of the following SLC (Liquid Poison) Technical Group Specification conditions:

a. 3.2.C.3 (b)

b. 3.2.C.3 (e) (i)

c. 4.2.E.5

5. Inoperable high-range radioactive noble gas effluent monitor (TS 3.137H)

YES, Perform notifications --

NRC Senior Resident Inspector A~- .i

m. . . .:... '3/4ýqf$

KREQUIRED WRITTEN REPORT'i K.. LCNE EVE~tE.

CHECK ONE REPORT DUE WITHIN CHECK ONE REPORT DUE WITHIN El REQUIRED E- 30 DAYS D REQUIRED C 30 DAYS D NOT REQUIRED 0l 60 DAYS 03 NOT REQUIRED 03 60 DAYS 03 OTHER _ _ OTHER i

OP-AA-106-101 Revision 12 Page 13 of 14 Oyster Creek Only Attachment 3 Special Notification and Reporting Requirements Page 1 of 2 NOTE: Normally, the Environmental Group will make governmental agency notifications (except NRC notifications) for environmental events. If this arrangement is impractical, the SM/DSM.may assign these notifications to the Communications Group or an Operations Group (Ops) representative.

For all potential NRC notifications those items should be reported in accordance with reportability manual.

ENVIRONMENTAL - SPiLLS, DISCHARGES, RELEASES OF OIL ANDIOR OTHER SUBSTAN..CES NOTIFICATION/ WRITTEN REPORT/

EVENT AGENCY DEPT. RESPONSIBLE DEPT. RESPONSIBLE National Response Center IMMEDIATE / (R!E)

Oil discharge into/upon EPA 7 60 days1 /(R/E) navigable waters or adjoining shoreline NRC 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s/ (Ops ENS) .; ,

First Energy' (JCP&L) 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s/ (R/E) 30 days/ (R/E)

NJDEP IMMEDIATE/ (R/E)' 30 days3,120days/ (R/E)

Leak or discharge of petroleum Ocean County Health Dept IMMEDIATE! (R/EY 120 daYsR/R/E) product, or hazardous NRC 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s/ (Ops ENS) . ... 1, substance, from the warehouse First Energy' (JCP&L) 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s/ (R/E) 30 days/ (R/E) drop tank....

NJDEP 15 minutes/ (Ops) 30 days/ (R/E)

Spill or discharge of hazardous Ocean County Health Dept IMMEDIATE / (Ops) 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s/!(Ops orC/R)*

materials in a quantity that NRC 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s/ (Ops ENS) ______-________________.__,_,

constitutes a reportable First Energy' (JCP&L) 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s/ (R/E) 30 days/ (R/E) discharge into or upon surface waters, groundwater, or onto the ground (incl. Petroleum products)

National Response Center IMMEDIATE / (R/E) _ _ -_ ,____

Release of designated NJDEP IMMEDIATE / (R/E) ASAP' hazardous substances in Lacey Twp. Police IMMEDIATE / (R/E) ASAP' amounts equal to or in excess of NRC 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s/ (Ops ENS) _____________________________

a EPA reportable quantity First Energy' (JCP&L) 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s/ (R/E) 30 days/ (R/E)

NOTES:

1) Written report due to EPA (40CFR 112.4(a)) if >1000 gal. Spill, or 2events within any 12-month period

2) Upon confirmation of a release from the warehouse drop tank

3) After reporting a leak into the annular space of the warehouse drop tank

4) After reporting a discharge

5) Notify First Energy (JCP&L) only if First Energy (JCP&L) personnel or facilities affected

6) Provide a follow-up report every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months until OCHD concurs in declaration of event termination

7) Following a release which requires immediate oral notification, a written follow-up report shall provide information required under 40 CFR 355.40 EVRNETL- RCRA PROGRAM 2-2Y NOTIFICATION/ WRITTEN REPORT/

EVENT AGENCY DEPT. RESPONSIBLE DEPT. RESPONSIBLE Exception Report NJDEP IMMEDIATE / (R/E)' 10 days /(RIE, Incident threatening health or National Response Center IMMEDIATE / (R/E) environment or release equal to' NJDEP IMMEDIATE / (R/E) 15 daysl(R/E) or in excess of EPA reportable NRC 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s/!(Ops ENS) - f quantity (RQ)

Incident of little or no environmental consequence 715 days/(RE)

NOTES:

1) Notification required if signed manifest not returned by disposal facility within 35 days of shipment

2) Notification required if signed manifest not returned by disposal facility within 45 days of shipmrent

3) Make notification and written report to New Jersey Emergency Response Commission as well

OP-AA-1 06-101 Revision 12 Page 14 of 14 Oyster Creek Only Attachment 3 Special Notification and Reporting Requirements Page 2 of 2 ENVIRONMENTAL -ASBESTOS 6COMMirMENT8 ___;__.._.._______, - ___.____...._*__"

EVENT AGENCY WRITTEN REPORT RRM RELATED EVENTS Exception Report' EPA Note 2 NJDEP Demolitionl NJDEP 10 days PRIOR to demolition3 ENV 2.35 ENV 2.2, ENV 2.3 ENV 2.4 NOTES:

1) Ifwaste shipment record is not received within 35 days of shipment, inquire as to the shipment status with the waste transporter or waste disposal site

2) Notification required if waste disposal site owner/operator-signed waste shipment record not received by station within 45 days of shipment.acceptance by waste transporter

3) Department generating asbestos material shall notify Radwaste/Environmental report no later than 20 days PRIOR to beoinnina demolition.

NOTE: Normally, the Communications Group (Comm) will make notifications (except NRC notification) for the following events.

PROM PT NOTWICATlON SYSTEM ýMALFUNcTIONS; . .....

NOTIFICATION/ WRITTEN REPORT/

EVENT AGENCY DEPT. RESPONSIBLE DEPT. RESPONSIBLE Loss of 10 or more sirens Ocean County Police Dispatcher IMMEDIATE/ (Comm/Ops)

NRC (SAF 1.10) 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s/ (Ops ENS)'

Spurious activation signal with 1 Ocean County Police Dispatcher IMMEDIATE/ (Comm/Ops) or more sirens still sounding NRC (SAF 1.10) 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s/ (Ops ENS)'

NOTES:

1) Provide immediate follow-up reports per SAF 1.9 guidance

2) Provide immediate follow-up reports per SAF 1.9 guidance

ML100700493

Text

References:

References:

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