ML14297A016

ISFSI, Response to Request for Additional Information and Supplement Regarding Permanently Defueled Emergency Action Levels Amendment Application Numbers 224, 268, and 253

ML14297A016
Person / Time
Site:	San Onofre
Issue date:	10/21/2014
From:	Thomas J. Palmisano Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
TAC MF3838, TAC MF3839, TAC MF3840
Download: ML14297A016 (34)

Text

J EDISON" SOUTHERN CALIFORNIA An ED[ISON INTERNA TIONA 1 Company, Thomas 1. Palmisano Vice President & Chief Nuclear Officer October 21, 2014 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Docket No. 50-206, 50-361, 50-362, and 72-041 Response to Request for Additional Information and Supplement Regarding Permanently Defueled Emergency Action Levels Amendment Application Numbers 224, 268, and 253 San Onofre Nuclear Generating Station, Units 1, 2, and 3 and ISFSI

Reference:

(1) Letter from Thomas J. Palmisano, (SCE) to Document Control Desk (NRC),

dated March 31, 2014;

Subject:

Docket Nos. 50-206, 50-361, 50-362, and 72-041, Amendment Application Numbers 224, 268, and 253, Permanently Defueled Emergency Action Level Scheme, San Onofre Nuclear Generating Station, Units 1, 2, and 3, respectively, and Independent Spent Fuel Storage Installation (ADAMS Accession No. ML14092A249)

(2) Letter from T. J. Wengert (NRC) to T. J. Palmisano (SCE) dated September 18, 2014;

Subject:

San Onofre Nuclear Generating Station, Units 1, 2, and 3, and Independent Spent Fuel Storage Installation - Request for Additional Information re: License Amendment Request for Emergency Action Level Scheme Change (TAC Nos. MF3838, MF3839, and MF3840)

Dear Sir or Madam:

By letter dated March 31, 2014 (Reference 1), Southern California Edison (SCE) requested a License Amendment Request (LAR) for the proposed Permanently Defueled Emergency Action Levels (EALs) for San Onofre Nuclear Generating Station (SONGS), Units 1, 2, 3, and Independent Spent Fuel Storage Installation (ISFSI).

By letter dated September 18, 2014 (Reference 2), the NRC provided a Request for Additional Information (RAI) related to the SCE LAR. The responses to the NRC RAIs are contained in Enclosure 1 to this letter. Some of the responses result in changes to the proposed Permanently Defueled EALs submitted with Reference 1, and those changes are identified in the individual responses. In addition, a complete and revised EAL Technical Basis Document is provided as Enclosure 2 to this letter. In addition to the changes made as a result of the SCE RAI responses, minor editorial changes have also been made to the EAL Technical Basis Document. Changes in the revised EAL Technical Basis Document are identified by a revision bar on the right side of the page. The conclusions of the no significant hazards consideration and environmental considerations contained in Reference 1 are not affected by, and remain applicable to, this revised request. f&6

.7

-1,le P.O. Box 128 San Clemente, CA 92672 (949) 368-6575 PAX 86575 Fax: (949) 568-6183 Tomn.Palnisano@sce.com 5

Document Control Desk 2 October 21, 2014 There are no new regulatory commitments in this submittal. Should you have any questions, or require additional information, please contact Ms. Andrea Sterdis at (949) 368-9985.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 1/_- 1/_ -, II--

Sincerely, : Response to NRC Request for Additional Information (RAI) Regarding Permanently Defueled Emergency Actions Levels : Modified Permanently Defueled Emergency Action Level (EAL) Technical Basis Document cc: M. L. Dapas, Regional Administrator, NRC Region IV T. J. Wengert, NRC Project Manager, SONGS Units 2 and 3 R. E. Lantz, NRC Region IV, San Onofre Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, SONGS Units 2 and 3 S. Y. Hsu, California Department of Public Health, Radiologic Health Branch

ENCLOSURE 1 Response to NRC Request for Additional Information (RAI)

Regarding Permanently Defueled Emergency Action Levels License Amendment Request

ENCLOSURE 1 Response to NRC RAI Regarding Permanently Defueled Emergency Action Levels SONGS/EAL-RAI-01 Please annotate in Section 1, "Purpose," that this document will be maintained in accordance with 10 CFR 50.54(q).

SCE Response:

The Permanently Defueled Emergency Plan (PDEP) Emergency Action Level (EAL) Technical Bases Manual will be revised to state that the manual will be maintained in accordance with 10 CFR 50.54(q).

PDEP EAL Technical Bases Manual changes in response to SONGS/EAL-RAI-01 The PDEP EAL Technical Bases Manual, Section 1.1 is revised as follows:

1.1 Purpose This document contains the Nuclear Regulatory Commission (NRC) approved set of Initiating Conditions (ICs), their associated Emergency Action Level (EAL) thresholds, and their site specific technical bases, for the Permanently Defueled (PD) San Onofre Nuclear Generating Station (SONGS), including the Independent Spent Fuel Storage Installation (ISFSI).

Any changes to this document will be made in accordance with the requirements of 10 CFR 50.54(q).

Page E-1

ENCLOSURE 1 Response to NRC RAI Regarding Permanently Defueled Emergency Action Levels SONGS/EAL-RAI-02 Please explain why the definitions for the following terms are not included, as stated in the endorsed guidance, or revise accordingly:

• Explosion,

• Fire, and

• Visible Damage.

SCE Response:

The PDEP EAL Technical Bases Manual will be revised to include the definitions of the terms Explosion, Fire, and Visible Damage in accordance with Nuclear Energy Institute (NEI)-99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012.

PDEP EAL Technical Bases Manual changes in response to SONGS/EAL-RAI-02 The following definitions will be added to the PDEP EAL Technical Bases Manual, Section 2.1:

EXPLOSION A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present.

FIRE Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

VISIBLE DAMAGE Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

Page E-2

ENCLOSURE 1 Response to NRC RAI Regarding Permanently Defueled Emergency Action Levels SONGS/EAL-RAI-03 Under Initiating Condition PD-AU1, please explain how EAL #2 is declared in a timely fashion and whether the capability to perform this evaluation is maintained on-site 24-hours per day, seven days per week (24/7).

SCE Response:

SONGS maintains staff qualified to sample and analyze liquid and gaseous effluents. The Shift Radiation Protection (RP) Technician is an on-shift position required by the proposed Permanently Defueled Emergency Plan (PDEP) and can provide timely field survey results for EAL #2. SONGS chemistry personnel are responsible for evaluating effluent samples. The chemistry personnel are not required to be on-shift positions. However, procedural restrictions support EAL #2 determination in a timely manner as described below.

For liquid radioactive releases, personnel qualified to perform sampling and analysis prepare a release permit before the release is authorized. A channel check of the affected effluent path radiation monitor is performed prior to the discharge. If the check is unsatisfactory, the release will not occur pending equipment repairs. Potentially radioactive effluent paths have continuous monitoring and procedurally identified compensatory measures. Routine sampling and analysis by qualified personnel are performed as specified in the Offsite Dose Calculation Manual (ODCM). Samples exceeding established limits are immediately reported to Operations personnel. In addition, all equipment necessary to perform the above described analysis is maintained on site.

The on-site waste gas storage system has been retired and will no longer be utilized, eliminating this as a source for planned or unplanned gaseous releases. The only available sources that can approach EPA thresholds for gaseous releases are spent fuel assemblies. The only credible scenarios to release this gas involve mechanically damaging a spent fuel assembly or assemblies during handling, or by impact of a heavy object. SONGS will modify appropriate procedures to ensure personnel qualified to perform sampling and analyses are on site prior to and during fuel movement in the fuel storage pool if the radiation monitor(s) capable of detecting this scenario are out of service.

Therefore, EAL #2 can be declared in a timely manner and the capability for these evaluations is maintained at all times.

PDEP EAL Technical Bases Manual chanqes in response to SONGS/EAL-RAI-03 None Page E-3

ENCLOSURE 1 Response to NRC RAI Regarding Permanently Defueled Emergency Action Levels SONGS/EAL-RAI-04 Under Initiating Condition PD-AU2, please clarify whether there are any remote reading alarms associated with the decrease in spent fuel pool water level, and if not, what means will be in place to ensure timely classification if warranted.

SCE Response:

Spent Fuel Pool (SFP) High/Low level annunciation will be provided in the Control Room/Command Center. The low level setpoint will be chosen to ensure annunciation is provided at a SFP level at or above the SFP low level assumed for the EAL classification. This low level annunciation will be the method used to ensure timely classification under Initiating Condition PD-AU2.

PDEP EAL Technical Bases Manual changes in response to SONGS/EAL-RAI-04 None Page E-4

ENCLOSURE 1 Response to NRC RAI Regarding Permanently Defueled Emergency Action Levels SONGSIEAL-RAI-05 Under Initiating Condition PD-SU1, please clarify whether there are any remote reading alarms associated with the increase in spent fuel pool water temperature, and if not, what means will be in place to ensure timely classification, if warranted.

SCE Response:

The Control Room/Command Center will have remote reading instrumentation with an associated alarm indication for a high SFP temperature. The high temperature setpoint will be chosen to ensure annunciation is provided at a SFP temperature at or below the SFP temperature assumed for the EAL classification. This high temperature annunciation will be the method used to ensure timely classification under Initiating Condition PD-SU1.

PDEP EAL Technical Bases Manual changqes in response to SONGS/EAL-RAI-05 None Page E-5

ENCLOSURE 2 Modified Permanently Defueled Emergency Action Level (EAL) Technical Basis Document San Onofre Nuclear Generating Station

San Onofre Nuclear Generating Station (SONGS)

Permanently Defueled Emergency Plan Emergency Action Level Technical Bases Manual (Volume 2, PDEP-2)

Prepared by:

xxxx Date Reviewed by:

xxxx Date Approved by:

xxxx Date

PDEP-2 EAL Technical Bases Manual Table of Contents INTRODUCTION ..................................................................................................................... 1-1 1 .1 P u rp o s e ....................................................................................................................... 1-1 1.2 Background/Licensing Basis ........................................................................................ 1-1 1.3 Emergency Classification Levels (ECLs) ...................................................................... 1-2 1.4 Initiating Conditions (ICs) ............................................................................................. 1-2 1.5 Emergency Action Levels (EALs) ................................................................................. 1-3 1.6 EAL Technical Bases Manual Content ......................................................................... 1-3 2 DEFINITIONS, ACRONYMS AND ABBREVIATIONS ............................................................. 2-1 2.1 Definitions .................................................................................................................... 2-1 2.2 Acronyms and Abbreviations ....................................................................................... 2-4 3 PERMANENTLY DEFUELED EAL MATRIX TABLE ............................................................... 3-1 4 EAL TECHNICAL BASES ...................................................................................................... 4-1 4.1 PD-AA1 ...................................................................................................................... 4-1 4.2 PD-AU1 ...................................................................................................................... 4-2 4.3 PD-AA2 ...................................................................................................................... 4-3 4.4 PD-AU2 ...................................................................................................................... 4-4 4.5 PD-SU1 ...................................................................................................................... 4-5 4.6 PD-HA1 ...................................................................................................................... 4-6 4.7 PD-HU1 ...................................................................................................................... 4-7 4.8 PD-HU2 ...................................................................................................................... 4-8 4.9 PD-HA3 ...................................................................................................................... 4-9 4.10 PD-HU3 ..................................................................................................................... 4-10 4 .1 1 E -HU1 ........................................................................................................................ 4 -1 0 i Revision Oa

1 INTRODUCTION 1.1 Purpose This document contains the Nuclear Regulatory Commission (NRC) approved set of Initiating Conditions (ICs), their associated Emergency Action Level (EAL) thresholds, and their site specific technical bases, for the Permanently Defueled (PD) San Onofre Nuclear Generating Station (SONGS), including the Independent Spent Fuel Storage Installation (ISFSI).

Any changes to this document will be made in accordance with the requirements of 10 CFR 50.54(q).

Decision-makers responsible for implementation of SO123-VIII-1, Recognition and Classification of Emergencies, and EP(123) 1, Emergency Classification and Event Code Chart, may use this document as a technical reference and an aid in EAL interpretation'.

This document is also used to facilitate review of any proposed changes to the SONGS PD EALs.

1.2 Background and Licensing Basis SONGS has previously been operated under a 10 CFR § 50 license. In 2013 Southern California Edison Co. (SCE) notified the NRC that plant operations had ceased and that all fuel had been permanently removed from the associated reactor vessels. Spent fuel will continue to be stored wet within the associated spent fuel pools for some period of time until it can all be relocated to the ISFSI and ultimately turned over to the Department of Energy.

A permanently defueled station is essentially an interim spent fuel storage facility where the fuel is stored in a pool of water that serves as both a cooling medium (i.e., removal of decay heat) and shield from direct radiation. These primary functions of the spent fuel storage pool are the focus of the PD ICs and EALs.

SCE has proposed and expects to receive approval from the NRC for exemption from specific emergency planning requirements. The exemption is reflected in a Permanently Defueled Emergency Plan (PDEP). The exemption and corresponding plan changes reflect the lowered radiological source term and risks associated with spent fuel pool storage relative to reactor at-power operation. Source terms and accident analyses associated with design basis accidents are documented in the SONGS Final Safety Analysis Report (FSAR).

With regard to event recognition and classification, regulations specific to the declaration of emergencies are provided in planning standard 10 CFR 50.47(b)(4) and 10 CFR 50 Appendix E.IV.B.

The NRC, by letter to Nuclear Energy Institute (NEI) dated 03/28/13 (ML12346A436),

documented its review of the draft version of NEI 99-01, Revision 6, dated November 2012 (ML12326A805), and found it acceptable for use by licensees seeking to upgrade their emergency action levels (EAL) in accordance with 10 CFR 50 Appendix E. The regulatory and technical analysis for this endorsement can be retrieved through ADAMS Accession No. ML13008A736.

' Emergency event declaration is required to be made as soon as conditions warranting classification are present and recognizable, but within 60 minutes in all cases of conditions being present. Use of this document for assistance is not intended to delay event declaration.

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1.3 Emergency Classification Levels (ECLs)

As defined in NUREG-0654/FEMA-REP-1, nuclear power plant emergencies are separated into four Emergency Classification Levels (ECLs):

• Notification of Unusual Event

• Alert

• Site Area Emergency

• General Emergency The ECLs are escalated from least severe to most severe according to the relative threat to the health and safety of the public and emergency workers. An ECL is determined to be met by identifying abnormal conditions and then comparing them to ICs through EALs threshold values as discussed below. When multiple EALs are met, event declaration is based in the highest ECL reached.

The permanently defueled ICs and EALs within this document use the two lower of the four ECLs. The source terms and release motive forces associated with a permanently defueled plant are not sufficient to require declaration of a Site Area Emergency or General Emergency.

1.4 Initiating Conditions (ICs)

An IC is a general description of an event or condition that aligns with the definition of one of the four ECLs by virtue of the potential or actual effects or consequences.

Each IC is given a unique identification code consisting of two letters and one number. The first letter identifies the recognition category, the second letter identifies the ECL, and the number identifies the sequence of the IC within the recognition category. The EAL identification codes are developed as follows:

Permanently Defueled Recognition Categories

" PD-A - Abnormal Rad Levels / Radiological Effluent

• PD-H - Hazards and Other Conditions Affecting Plant Safety

" PD-S - System Malfunctions Independent Spent Fuel Storage Installation (ISFSI) Recognition Categories

• E-H- Hazards and Other Conditions Affecting ISFSI Permanently Defueled Emergency Classification Levels (lowest to highest)

" U - Notification of Unusual Event

• A - Alert For a permanently defueled station, the Notification of Unusual Event ICs provide for an increased awareness of abnormal conditions while the Alert ICs are specific to actual or potential impacts to spent fuel. Radiological effluent IC and EALs were included to provide a basis for classifying events that cannot be readily classified based on an observable events or plant conditions alone.

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1.5 Emergency Action Levels (EALs)

An EAL is a pre-determined, site specific, observable threshold for an IC that, when met or exceeded, places the plant in a given ECL.

EAL thresholds may utilize a variety of criteria including instrument readings and status indications; observable events; results of calculations and analyses; entry into particular procedures; and the occurrence of natural phenomena.

EALs are individually identified by the IC identification code followed by the EAL number, such as AA1.1 for an effluent release or HU1.1 for a security condition.

All EAL classification assessments shall be based upon valid indications, reports or conditions.

A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicator's operability, the condition's existence, or the report's accuracy.

For EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary. When an EAL that specifies a time duration for the off-normal condition is assessed, the "clock" for the EAL time duration runs concurrently with the emergency classification process "clock". For a full discussion of this timing requirement, refer to NSIRJDPR-ISG-01.

The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments); the EAL and/or the associated basis discussion will identify the necessary analysis. In these cases, the 60-minute declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift).

A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that 1) the activity proceeds as planned and 2) the site remains within the limits imposed by the license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 § CFR 50.72.

1.6 EAL Technical Bases Manual Content EAL Matrix Table This manual contains an EAL matrix table that addresses all of the recognition categories for the PD and ISFSI EAL thresholds.

The EAL matrix table is designed as an evaluation tool that organizes the ECLs from the highest (Alert) on the left to the lowest (Notification of Unusual Event) on the right. Evaluating the EALs for each ECL from highest to lowest reduces the possibility that an event will be under classified. All EALs are to be reviewed for applicability prior to event declaration.

1-3 Revision Oa

Other user aids such as wallboards may be developed from the EAL matrix table to support evaluation of abnormal conditions in other human factored formats.

EAL Documentation Format Each EAL within the technical bases manual is documented in the following manner:

• IC Identification Number

• Initiating Condition

• EALs Threshold Value(s)

• Basis

• Basis Reference(s) 1-4 Revision Oa

2 DEFINITIONS, ACRONYMS AND ABBREVIATIONS 2.1 Definitions ALERT Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of hostile action. Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.

CONFINEMENT BOUNDARY The outside surfaces of a storage cask containing spent fuel that act as a barrier between the radioactive substances contained within and the environment.

EMERGENCY ACTION LEVEL (EAL)

A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the plant in a given emergency classification level.

EMERGENCY CLASSIFICATION LEVEL (ECL)

One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:

• Notification of Unusual Event (UE)

• Alert

• Site Area Emergency (SAE)

" General Emergency (GE)

EXCLUSION AREA BOUNDARY (EAB)

The exclusion area is that area surrounding the reactor, in which the reactor licensee has the authority to determine all activities including exclusion or removal of personnel and property from the area. For SONGS, the EAB is roughly formed by two semicircles with radii of 1967.5 ft.

each, centered on the Unit 2 Containment dome and a point 134 ft. southeast of the Unit 3 Containment dome, with a tangent connecting the landward arcs and seaward arcs of the two semicircles. The EAB is depicted in UFSAR Figure 2.1-5.

EXPLOSION A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present.

FIRE Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

2-1 Revision Oa

HOSTAGE A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION An act toward SONGS or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on SONGS. Non-hostile-action-based EALs are used to address such activities (i.e., this may include violent acts between individuals within the vehicle barrier system area).

HOSTILE FORCE One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

IMMINENT The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

INITIATING CONDITION (IC)

An event or condition that aligns with the definition of one of the four emergency classification levels by virtue of the potential or actual effects or consequences.

NORMAL LEVELS As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.

NOTIFICATION OF UNUSUAL EVENT (NOUE)

Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

OWNER CONTROLLED AREA For SONGS, the owner controlled area is the SCE SONGS controlled property, to include facilities and parking lots located on the west side of the Interstate 5 freeway, extending westward from Old Highway 101 to the median high-tide line, bordered on the north and south by the State Park Beach.

PROJECTILE An object directed toward SONGS that could cause concern for its continued operability, reliability, or personnel safety.

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PROTECTED AREA The protected area is an area encompassed by physical barriers and to which access is controlled. For SONGS, the Units 2/3 (plant) protected area is the property surrounding Units 2 and 3 that is encompassed by physical barriers to which access is controlled. This area is within the security isolation zone and is depicted on Drawing 21090, Owner Controlled Area Plot Plan.

The Independent Spent Fuel Storage Installation is designated as a separate protected area.

SAFETY SYSTEM A system required for cooling the spent fuel pool in the permanently defueled mode of operation.

SECURITY CONDITION Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a hostile action.

UNPLANNED A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

VEHICLE BARRIER SYSTEM (VBS)

Vehicle control measures (passive or active) used to protect against the malevolent use of a land vehicle. The VBS consists of both active and passive components, terrain features, man-made structural features, and vehicle access checkpoints as defined in the SONGS Security Plan.

VISIBLE DAMAGE Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

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2.2 Acronyms and Abbreviations CDE .................................................................................................. Committed Dose Equivalent CFR ................................................................................................. Code of Federal Regulations DBA ........................................................................................................... Design Basis Accident EAB ...................................................................................................... Exclusion Area Boundary EAL ......................................................................................................... Emergency Action Level ECL ............................................................................................. Emergency Classification Level EPA .......................................................................................... Environmental Protection Agency EPIP ........................................................................... Emergency Plan Implementing Procedure FAA ............................................................................................. Federal Aviation Administration FBI ............................................................................................... Federal Bureau of Investigation FEMA .......................................................................... Federal Emergency Management Agency FHB .......................................................................................................... Fuel Handling Building FSAR ............................................................................................... Final Safety Analysis Report IC ..................................................................................................................... In itia ting C o n d itio n ISFSI ....................................................................... Independent Spent Fuel Storage Installation LCO ............................................................................................. Limiting Condition of Operation mR, m Rem , mrem, mREM ............................................................ milli-Roentgen Equivalent Man NEI ......................................................................................................... Nuclear Energy Institute NRC ........................................................................................... Nuclear Regulatory Commission NORAD ............................................................... North American Aerospace Defense Command NOUE ............................................................................................. Notification of Unusual Event OCA .......................................................................................................... Owner Controlled Area ODCM ........................................................................................ Offsite Dose Calculation Manual ORO ............................................................................................ Off-site Response Organization PA ......................................................................................................................... Protected Area PAG ................................................................................................... Protective Action Guideline R ................................................................................................................................... Ro e ntg e n Rem , rem , REM ................................................................................... Roentgen Equivalent Man RW B ................................................................................................. Radiological W aste Building SAR .......................................................................................................... Safety Analysis Report SCE ................................................................................................... Southern California Electric SONGS ........................................................................... San Onofre Nuclear Generating Station TEDE ........................................................................................... Total Effective Dose Equivalent VBS .......................................................................................................... Vehicle Barrier System 2-4 Revision Oa

3 PERMANENTLY DEFUELED EAL MATRIX TABLE ALERT NTFCION FUUUA VN PD-AA1 PD-AU1 Release of gaseous or liquid radioactivity resulting in Release of gaseous or liquid radioactivity greater offsite dose greater than 10 mrem TEDE or 50 than 2 times the ODCM limits for 60 minutes or mrem thyroid CDE. longer.

Notes: Notes:

" The Emergency Director should declare the Alert " The Emergency Director should declare the promptly upon determining that the applicable Notification of Unusual Event promptly upon time has been exceeded, or will likely be determining that 60 minutes has been exceeded, exceeded. or will likely be exceeded.

• If an ongoing release is detected and the release

• If an ongoing release is detected and the release start time is unknown, assume that the release start time is unknown, assume that the release duration has exceeded 15 minutes. duration has exceeded 60 minutes.

• If the effluent flow past an effluent monitor is " If the effluent flow past an effluent monitor is known to have stopped, indicating that the release known to have stopped, indicating that the path is isolated, the effluent monitor reading is no release path is isolated, the effluent monitor longer valid for classification purposes. reading is no longer valid for classification

" The pre-calculated effluent monitor values purposes.

presented in EAL #1 should be used for 1. Reading on ANY effluent radiation monitor emergency classification assessments until dose greater than 2 times the alarm setpoint assessment results are available. established by a current radioactivity discharge

1. Reading on ANY of the following radiation permit for 60 minutes or longer.

monitors equal to or greater than the reading 2. Sample analysis for a gaseous or liquid release shown for 15 minutes or longer: indicates a concentration or release rate greater

" Plant Vent (2RE7865) ...... 1.0E+8 pCi/sec than 2 times the ODCM limits for 60 minutes or

• Plant Vent (3RE7865) ...... 1.0E+8 pCi/sec longer.

2. Dose assessment using actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the EAB.

3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the EAB for one hour of exposure.

4. Field survey results indicate EITHER of the following at or beyond the EAB:

" Closed window dose rates greater than 10 mr/hr expected to continue for 60 minutes or longer.

• Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.

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I ALR NOIICTO OF UNSA VN PD-AA2 PD-AU2 UNPLANNED rise in plant radiation levels that UNPLANNED rise in plant radiation levels.

impedes plant access required to maintain spent

1. a. UNPLANNED water level drop in the spent fuel integrity.

fuel pool as indicated by ANY of the

1. UNPLANNED dose rate greater than 15 mr/hr in following:

ANY of the following areas requiring continuous

• local level indicator occupancy to maintain control of radioactive material or operation of systems needed to AND maintain spent fuel integrity: b. UNPLANNED rise in area radiation levels as

• Command Center indicated by ANY of the following radiation monitors.

• Central Alarm Station

• 2(3)RE7850, Fuel Handling Building Spent

2. Survey results that indicate an UNPLANNED Fuel Cask Area Radiation Monitor rise of 100 mr/hr over NORMAL LEVELS that impedes access to ANY of the following areas 2. Area radiation monitor reading or survey result indicates an UNPLANNED rise of 25 mR/hr over needed to maintain control of radioactive material or operation of systems needed to NORMAL LEVELS.

maintain spent fuel integrity:

0 U2 63' Fuel Handling Building 0 U3 63' Fuel Handling Building PD-SUI UNPLANNED spent fuel pool temperature rise.

1. UNPLANNED spent fuel pool temperature rise to greater than 140 0 F.

PD-HA1 PD-HU1 HOSTILE ACTION within the VEHICLE BARRIER Confirmed SECURITY CONDITION or threat.

SYSTEM or airborne attack threat within 30 minutes. 1. A SECURITY CONDITION that does not involve

1. A HOSTILE ACTION is occurring or has a HOSTILE ACTION as reported by the Security occurred within the VEHICLE BARRIER Shift Supervisor.

SYSTEM as reported by the Security Shift 2. Notification of a credible security threat directed Supervisor. at the site.

2. A validated notification from the NRC of an 3. A validated notification from the NRC providing aircraft attack threat within 30 minutes of the information of an aircraft threat.

site.

3-2 Revision Oa

I ALER NOIICTOO F UNS UA VN PD-HU2 Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.

Op. Modes: Not Applicable

1. a. The occurrence of ANY of the following hazardous events:

0 Seismic event (earthquake)

S Internal or external flooding event S High winds or tornado strike S FIRE S EXPLOSION S Other events with similar hazard characteristics as determined by the Shift Manager AND

b. The event has damaged at least one train of a SAFETY SYSTEM needed for spent fuel cooling.

AND

c. The damaged SAFETY SYSTEM train(s) cannot, or potentially cannot, perform its design function based on EITHER:

• Indications of degraded performance

• VISIBLE DAMAGE PD-HA3 PD-HU3 Other conditions exist which in the judgment of the Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert. Emergency Director warrant declaration of a Notification of Unusual Event.

1. Other conditions exist which in the judgment of the Emergency Director indicate that events are 1. Other conditions exist which in the judgment of in progress or have occurred which involve an the Emergency Director indicate that events are actual or potential substantial degradation of the in progress or have occurred which indicate a level of safety of the plant or a security event that potential degradation of the level of safety of the involves probable life threatening risk to site plant or indicate a security threat to facility personnel or damage to site equipment because protection has been initiated. No releases of of HOSTILE ACTION. Any releases are expected radioactive material requiring offsite response or to be limited to small fractions of the EPA monitoring are expected unless further Protective Action Guideline exposure levels. degradation of safety systems occurs.

3-3 Revision Oa

I ALER NOIIAINO NSAIVN E-HUI Damage to a loaded cask CONFINEMENT BOUNDARY.

1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by dose rates greater than either of the following:

• 520 mR/hr (gamma) 3 feet from the surface at the top centerline.

• 190 mR/hr (gamma) 3 feet from the surface of the neutron shield at the mid-height centerline.

3-4 Revision Oa

4 EAL TECHNICAL BASES 4.1 PD-AA1 Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.

EALs:

Notes:

" The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

• If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

• If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer valid for classification purposes.

• The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until dose assessment results are available.

1. Reading on ANY of the following radiation monitors equal to or greater than the reading shown for 15 minutes or longer:

• Plant Vent Stack (2RE7865) .............................................................. 1.OE+08 pCi/sec

• Plant Vent Stack (3RE7865) .............................................................. 1.OE+08 pCi/sec

2. Dose assessment using actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the EAB.

OR

3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the EAB for one hour of exposure.

OR

4. Field survey results indicate EITHER of the following at or beyond the EAB:

• Closed window dose rates greater than 10 mr/hr expected to continue for 60 minutes or longer.

• Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

4-1 Revision Oa

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer valid for classification purposes.

Additional SONGS Site Specific Bases Information:

Dose assessment calculations using SONGS dose assessment computer model (RADDOSE-V Version RD5v3.0i) for a fuel handling building accident with a KR-85 noble gas release, wind speed of 6.7 mph and stability class D (prevalent values for 2011 and 2012) indicates that a dose of 10 mrem for one hour of exposure at the EAB would require a noble gas release rate of 5.60E+08 uCi/sec. The Plant Vent Stack Wide Range Gas Monitors 2RE7865 and 3RE7865 have a readable range of 1.OE-04 to 1.OE+08 uCi/sec, therefore a reading corresponding to 10 mrem at the EAB would be off-scale high. The upper limit (max readable value, indicator will go beyond value before reaching offscale-high) of the monitors range has been selected as the threshold to classify an Alert in accordance with EAL PD-AA1, this will correspond to 3.6 mrem for one hour of exposure, assuming a wind speed of 6.7 mph and stability class D.

Since the gases mix in the continuous exhaust plenum before entering the stack, a reading on any unit monitor would correspond to a similar reading in the other monitor, and only one valid reading will be needed to classify this event.

Plant Vent Stack radiation monitor 2/3RE7808G is not used for this EAL because the upper limit is 4.OE+07 uCi/sec (Action Request 070100476-7), and it will be off-scale high before the wide range monitors listed above.

Basis Reference(s):

1. NEI 99-01 Rev 6, PD-AA1 4.2 PD-AU1 Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

EALs:

Notes:

" The Emergency Director should declare the Notification of Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.

• If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.

" If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer valid for classification purposes.

4-2 Revision Oa

1. Reading on ANY effluent radiation monitor greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.

OR

2. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times the ODCM limits for 60 minutes or longer.

Basis:

This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer valid for classification purposes.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

EAL #1 - This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

EAL #2 - This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Escalation of the emergency classification level would be via IC PD-AA1.

Additional SONGS Site Specific Bases Information:

None Basis Reference(s):

1. NEI 99-01 Rev 6, PD-AU1 4.3 PD-AA2 Initiating Condition:

4-3 Revision Oa

UNPLANNED rise in plant radiation levels that impedes plant access required to maintain spent fuel integrity.

EALs:

1. UNPLANNED dose rate greater than 15 mR/hr in ANY of the following areas requiring continuous occupancy to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity:

• Command Center

• Central Alarm Station OR

2. Survey results that indicate an UNPLANNED rise of 100 mr/hr over NORMAL LEVELS that impedes access to ANY of the following areas needed to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity:

• U2 63' Fuel Handling Building

• U3 63' Fuel Handling Building Basis:

This IC addresses increased radiation levels that impede necessary access to areas containing equipment that must be operated manually or that requires local monitoring, in order to maintain systems needed to maintain spent fuel integrity. As used here, 'impede' includes hindering or interfering, provided that the interference or delay is sufficient to significantly threaten necessary plant access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant.

This IC does not apply to anticipated temporary increases due to planned events.

Additional SONGS Site Specific Bases Information:

Areas for EAL#2 are based on areas inhabited during an operator walk down of equipment needed to maintain or restore Spent Fuel cooling or water level.

Basis Reference(s):

1. NEI 99-01 Rev 6, PD-AA2

2. S023-13-23 Loss of Spent Fuel Pool Cooling 4.4 PD-AU2 Initiating Condition:

UNPLANNED rise in plant radiation levels.

EALs:

1. a. UNPLANNED water level drop in the spent fuel pool as indicated by ANY of the following:

• local level indicator AND

b. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors.

4-4 Revision Oa

. 2(3)RE7850, Fuel Handling Building Spent Fuel Cask Area Radiation Monitor OR

2. Area radiation monitor reading or survey result indicates an UNPLANNED rise of 25 mr/hr over NORMAL LEVELS.

Basis:

This IC addresses elevated plant radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events. The increased radiation levels are indicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials. Either condition is a potential degradation in the level of safety of the plant.

A water level decrease will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel or video camera observations (if available). A significant drop in the water level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered. Note that EAL #1 is applicable only in cases where the elevated reading is due to an UNPLANNED water level drop. EAL #2 excludes radiation level increases that result from planned activities such as use of radiographic sources and movement of radioactive waste materials.

Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.

Additional SONGS Site Specific Bases Information:

Tech. Spec 3.7.16 documents the minimum requirement of 23' over the top of irradiated fuel assemblies seated in the storage racks.

Basis Reference(s):

1. NEI 99-01 Rev 6, PD-AU2

2. SONGS Tech Spec 3.7.16 4.5 PD-SU1 Initiating Condition:

UNPLANNED spent fuel pool temperature rise.

EALs:

1. UNPLANNED spent fuel pool temperature rise to greater than 140 0 F.

Basis:

This IC addresses a condition that is a precursor to a more serious event and represents a potential degradation in the level of safety of the plant. If uncorrected, boiling in the pool will occur, and result in a loss of pool level and increased radiation levels.

Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.

Additional SONGS Site Specific Bases Information:

Per procedure S023-13-23 Loss of Spent Fuel Pool Cooling, a Spent Fuel Pool temperature

>140°F is the point at which operators must take actions to restore cooling capabilities.

Basis Reference(s):

4-5 Revision Oa

1. NEI 99-01 Rev 6, PD-SU1

2. S023-13-23 Loss of Spent Fuel Pool Cooling 4.6 PD-HA1 Initiating Condition:

HOSTILE ACTION within the VEHICLE BARRIER SYSTEM or airborne attack threat within 30 minutes.

EALs:

1. A HOSTILE ACTION is occurring or has occurred within the VEHICLE BARRIER SYSTEM as reported by the Security Shift Supervisor.

OR

2. A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.

Basis:

This IC addresses the occurrence of a HOSTILE ACTION within the VEHICLE BARRIER SYSTEM or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.

Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the VEHICLE BARRIER SYSTEM. This includes any action directed against an ISFSI that is located within the VEHICLE BARRIER SYSTEM.

EAL #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with (site-specific procedure).

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC.

4-6 Revision Oa

In some cases, it may not be readily apparent if an aircraft impact within the VEHICLE BARRIER SYSTEM was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan.

Additional SONGS Site Specific Bases Information:

VEHICLE BARRIER SYSTEM is utilized in place of the Owner Controlled Area (OCA) due to the extreme size of the current OCA.

Basis Reference(s):

1. NEI 99-01 Rev 6, PD-HA1 4.7 PD-HU1 Initiating Condition:

Confirmed SECURITY CONDITION or threat.

EALs:

1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.

OR

2. Notification of a credible security threat directed at the site.

OR

3. A validated notification from the NRC providing information of an aircraft threat.

Basis:

This IC addresses events that pose a threat to plant personnel or the equipment necessary to maintain cooling of spent fuel, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HAI.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

4-7 Revision Oa

EAL #1 references (site-specific security shift supervision) because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.

EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with (site-specific procedure).

EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with (site-specific procedure).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan.

Escalation of the emergency classification level would be via IC PD-HA1.

Additional SONGS Site Specific Bases Information:

None Basis Reference(s):

1. NEI 99-01 Rev 6, PD-HU1 4.8 PD-HU2 Initiating Condition:

Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.

EALs:

1 (1) a. The occurrence of ANY of the following hazardous events:

• Seismic event (earthquake)

• Internal or external flooding event

• High winds or tornado strike

• FIRE

" EXPLOSION

" Other events with similar hazard characteristics as determined by the Shift Manager AND

b. The event has damaged at least one train of a SAFETY SYSTEM needed for spent fuel cooling.

AND 4-8 Revision Oa

c. The damaged SAFETY SYSTEM train(s) cannot, or potentially cannot, perform its design function based on EITHER:

• Indications of degraded performance

" VISIBLE DAMAGE Basis:

This IC addresses a hazardous event that causes damage to at least one train of a SAFETY SYSTEM needed for spent fuel cooling. The damage must be of sufficient magnitude that the system(s) train cannot, or potentially cannot, perform its design function. This condition reduces the margin to a loss or potential loss of the fuel clad barrier, and therefore represents a potential degradation of the level of safety of the plant.

For EAL 1 .a, the event titled "Tsunami" has not been included in the PD EALs because it is already covered under "Internal or external flooding event" and does not constitute a separate and distinct hazardous event.

For EAL 1 .c, the first bullet addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available.

For EAL 1.c, the second bullet addresses damage to a SAFETY SYSTEM train that is not in service/operation or readily apparent through indications alone. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level could, depending upon the event, be based on any of the Alert ICs; PD-AA1, PD-AA2, PD-HA1 or PD-HA3.

Additional SONGS Site Specific Bases Information:

None.

Basis Reference(s):

1. NEI 99-01 Rev 6, PD-HU2 4.9 PD-HA3 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.

EALs:

1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.

4-9 Revision Oa

Additional SONGS Site Specific Bases Information:

None Basis Reference(s):

1. NEI 99-01 Rev 6, PD-HA3

2. EPA-400, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents 4.10 PD-HU3 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Notification of Unusual Event.

EALs:

1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Notification of Unusual Event.

Additional SONGS Site Specific Bases Information:

None Basis Reference(s):

1. NEI 99-01 Rev 6, PD-HU3 4.11 E-HU1 Initiating Condition:

Damage to a loaded cask CONFINEMENT BOUNDARY.

EALs:

1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by dose rates greater than either of the following:

• 520 mR/hr (gamma) 3 feet from the surface at the top centerline.

• 190 mR/hr (gamma) 3 feet from the surface of the neutron shield at the mid-height centerline.

Basis:

4-10 Revision Oa

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of "damage" is determined by radiological survey. The technical specification multiple of "2 times", which is also used in PD-AU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the "on-contact" dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.

Security-related events for ISFSIs are covered under ICs PD-HU1 and PD-HA1.

Additional SONGS Site Specific Bases Information:

SONGS storage cask Technical Specifications are based on values three feet from the top and mid-height surfaces.

Basis Reference(s):

1. NEI 99-01 Rev 6, E-HU1

2. ISFSI Admin Tech Spec 5.2.4.d, Radiation Protection Program, S023-1-30.9 rev 20 (Step 6.7.26) 4-11 Revision Oa