ML17173A188
| ML17173A188 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/19/2017 |
| From: | Southern California Edison Co |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML17173A188 (68) | |
Text
Attachment 1 SONGS Permanently Defueled Emergency Action Levels -
Revision 2
San Onofre Nuclear Generating Station (SONGS)
Permanently Defueled Emergency Plan Emergency Action Level Technical Bases Manual (Volume 2, PDEP-2)
PDEP-2 EAL Technical Bases Manual 1
INTRODUCTION 1.1 Purpose This document contains the Nuclear Regulatory Commission (NRG) 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 m.ade in accordance with the requirements of 10 CFR 50.54(q).
Decision-makers responsible for implementation of S0123-Vlll-ER0-2, Shift Manager I Emergency Director Checklist, may use this document as a technical reference and an aid in EAL interpretation 1.
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 NRG 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 I Cs and EALs.
SCE has received approval from the NRG 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 1 O CFR 50.47(b)(4) and 10 CFR 50 Appendix E.IV.B.
1 Emergency event declaration is required to be made as soon as conditions warranting classification are present and recognizable, but within 30 minutes in all cases of conditions being present. Use of this document for assistance is not intended to delay event declaration.
1-1 Revision 2
PDEP-2 EAL Technical Bases Manual Table of Contents 1
INTRODUCTION............................................................................................................ 1-1 1.1 Purpose.............................................................................................................. 1-1 1.2 Background and 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............................................................... 1-4 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.............................................................................................................. 4-3 4.3 PD-AA2.............................................................................................................. 4-5 4.4 PD-AU2.............................................................................................................. 4-6 4.5 PD-SU1.............................................................................................................. 4-7 4.6 PD-HA 1.............................................................................................................. 4-8 4.7 PD-HU1............................................................................................................ 4-10 4.8 PD-HU2........................................................,......................,............................ 4-12 4.9 PD-HA3............................................................................................................ 4-14 4.10 PD-HU3............................................................................................................ 4-15 4.11 E-HU1............................................................................................................... 4-16 Revision 2 I
PDEP-2 EAL Technical Bases Manual 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 LEVE Ls (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.
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 I Cs through EAL threshold values as discussed below. When multiple EALs are met, event declaration is based in the highest ECL reached.
The permanently defueled I Cs 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 I 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 1-2 Revision 2 I
PDEP-2 EAL Technical Bases Manual For a permanently defueled station, the NOTIFICATION OF UNUSUAL EVENT ICs provide for an increased awareness of abnormal conditions while the ALERT I Cs 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.
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 pheno'mena.
EALs are individually identified by the IC identification code followed by the EAL number, such as PD-AA1.1 for an effluent release or PD-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 NSIR/DPR-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 30-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 the activity proceeds as planned and 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.
1-3 Revision 2 I
PDEP-2 EAL Technical Bases Manual 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.
Other user aids such as wallboards may be developed from the EAL matrix table to support evaluation of abnormal conditions ln 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 2 I
PDEP-2 EAL Technical Bases Manual 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 potential or actual effects or consequences, and resulting onsite and offsite response actions. The EMERGENCY CLASSIFICATION LEVELS, in ascending order of severity, are:
NOTIFICATION OF UNUSUAL EVENT (NOUE)
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 over-pressurization. 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 2 I
PDEP-2 EAL Technical Bases Manual 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.
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 appli~d 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 Beach Park.
PROJECTILE An object directed toward SONGS that could cause concern for its continued operability, reliability, or personnel safety.
PROTECTED AREA That onsite area within the security boundary as defined in the station's Security Plan.
2-2 Revision 2
PDEP-2 EAL Technical Bases Manual 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 the result of an intended evolution or an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.
VEHICLE BARRIER SYSTEM Vehicle control measures (passive or active) used to protect against the malevolent use of a land vehicle. The VEHICLE BARRIER SYSTEM 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.
2-3 Revision 2 I
PDEP-2 EAL Technical Bases Manual 2.2 Acronyms and Abbreviations COE................................................................................................... Committed Dose Equivalent CFR................................................................................................... Code of Federal Regulations EAB............................................................................................ EXCLUSION AREA BOUNDARY EAL....................................................................... *................................... Emergency Action Level
- ECL............................................................................... EMERGENCY CLASSIFICATION LEVEL EPA............................................................................................ Environmental Protection Agency FAA............................................................................................... Federal Aviation Administration FBI................................................................................................ Federal Bureau of Investigation FEMA............................................................................ Federal Emergency Management Agency FSAR................................................................................................. Final Safety Analysis Report IC............................................................................................................ INITIATING CONDITION ISFSI................................................. INDEPENDENT SPENT FUEL STORAGE INSTALLATION 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 PA.................................................................................................................. PROTECTED AREA PAG..................................................................................................... Protective Action Guideline R..................................................................................................................................... Roentgen Rem, rem, REM..................................................................................... Roentgen Equivalent Man SCE...................................................................................................... Southern California Edison SONG,S............................................................................ San Onofre Nuclear Generating Station TEDE............................................................................................ Total Effective Dose Equivalent 2-4 Revision 2 I
PDEP-2 EAL Technical Bases Manual 3
PERMANENTLY DEFUELED EAL MATRIX TABLE ALERT NOTIFICATION OF UNUSUAL EVENT 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 than 2 times the ODCM limits for 60 minutes or 50 mre.m thyroid CDE.
longer.
Notes:
Notes:
- The Emerger:icy Director should declare the
- The Emergency Director should declare the ALERT promptly upon determining that the NOTIFICATION OF UNUSUAL EVENT promptly applicable time has been exceeded, or will likely upon determining that 60 minutes has been be 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 ODCM limits for assessment results are available.
60 minutes or longer.
- 1. Reading on EITHER of the followi'ng radiation
- 2. Sample analysis for a gaseous or liquid release monitors equal to or greater than the reading indicates a concentration or release rate greater shown for 15 minutes or longer:,
than 2 times the ODCM limits for 60 minutes or
- Plant Vent (2RE7865)............. 1.0E+B µCi/sec longer.
~ Plant Vent (3RE7865)............. 1.0E+B µCi/sec
- 2.
Dose assessment using actual meteorology indicates doses greaterthan 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the EAB.
- 3.
Sample analysis for a liquid release 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:
- 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.
3-1 Revision 2 I
PDEP-2 EAL Technic.al Bases Manual ALERT NOTIFICATION OF UNUSUAL EVENT PD-AA2 UNPLANNED rise in plant radiation levels that impedes plant access required to maintain spent fuel integrity.
- 1.
UNPLANNED dose rate greater than 15 mR/hr in EITHER 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
- 2.
UNPLANNED area radiation monitor readings or survey results indicate a rise of 100 'mR/hr over NORMAL LEVELS that impedes access to EITHER 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 PD-HA1 PD-AU2 UNPLANNED rise in plant radiation levels.
- 1.
- a.
UNPLANNED water level drop in the spent
- fuel pool as indicated by Local Level Indicator
- 2.
- b.
AND UNPLANNED rise in area radiation levels as indicated by 2(3)RE7850, Fuel Handling Building Spent Fuel Cask Area Radiation Monitor.
Area radiation monitor reading or survey result indicates an UNPLANNED rise of 25 mR/hr over NORMAL LEVELS.
PD-SU1 UNPLANNED spent fuel pool temperature rise.
- 1.
UNPLANNED spent fuel pool temperature rise to Qreater than 140°F.
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 occurred within the VEHICLE BARRIER SYSTEM as reported by the Nuclear Security Shift Supervisor.
- 2. A validated notification from the NRC of an aircraft attack threat within 30 minutes of the site.
a HOSTILE ACTION as reported by the Nuclear Security Shift Supervisor.
- 2.
Notification of a credible security threat directed at the site.
- 3.
A validated notification from the NRC providing information of an aircraft threat.
3-2 Revision 2 I
PDEP-2 EAL Technical Bases Manual ALERT NOTIFICATION OF UNUSUAL EVENT PD-HA3 Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT.
- 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.
PD-HU2 Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.
- 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
- 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-HU3 Other conditions exist which in the judgment of the 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 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.
E-HU1 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.
3-3 Revision 2 I
PDEP-2 EAL Technical Bases Manual 4
EAL TECHNICAL BASES 4.1 PD-AA1 INITIATING CONDITION:
Release of gaseous or liquid radioactivity resulting in offsite dose greater than 1 O 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 EITHER of the following radiation monitors equal to or greater than the reading shown for 15 minutes or longer:
Plant Vent Stack (2RE7865)............................................................... 1.0E+08 µCi/sec Plant Vent Stack (3RE7865)............................................................... 1.0E+08 µCi/sec OR
- 2.
Dose assessment using actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the EAB.
. 3.
Sample analysis for a liquid release indicates a concentration or release rate that would result in doses greater than 1 O 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:
Basis:
Dose rates greater than 1 O 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.
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 unmonitored 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 2 I
PDEP-2 EAL Technical Bases Manual 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 COE was established in consideration of the 1 :5 ratio of the EPA PAG for TEDE and thyroid COE.
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.
If dose rates are obtained with portable instruments, then closed window readings are used.
The largest contributor to total body exposure is gamma radiation, which is represented by closed window readings.
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 µCi/sec. The Plant Vent Stack Wide Range Gas Monitors 2RE7865 and 3RE7865 have a readable range of 1.0E-04 to 1.0E+08 µCi/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-AA 1, 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 4.0E+07 µCi/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-AA 1 4-2 Revision 2 I
PDEP-2 EAL Technical Bases Manual 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.
- 1.
Reading on ANY effluent radiation monitor greater than 2 times the ODCM limits for 60 minutes or longer.
- 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 unmonitored, 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 ODCM limit. This EAL is associated with continuous releases (e.g., Turbine Plant Sump, North Industrial Area Yard_ Drain Sump, Plant Vent Stack) and planned batch releases (e.g., radwaste).
4-3 Revision 2 I
PDEP-2 EAL Technical Bases Manual 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 4-4 Revision 2 I
PDEP-2 EAL Technical Bases Manual 4.3 PD-AA2 INITIATING CONDITION:
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 EITHER 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.
UNPLANNED area radiation monitor readings or survey results indicate a rise of 100 mR/hr over NORMAL LEVELS that impedes access to EITHER 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 impai~ed access that results in the actual or potential substantial degradation of the level of safety of the plant.
This IC does not apply to antidpated temporary increases in radiation levels due to planned events.
If dose rates are obtained with portable instruments, then closed window readings are used.
This IC is based on access impediments due to a total body exposure to plant personnel. The largest contributor to total body exposure is gamma radiation, which is represented by closed window readings.
- Additional SONGS Site-Specific Bases Information:
EAL #1 applies to dose rates in the CAS or Command Center even if personnel were able to relocate from those areas.
Areas for EAL #2 are based on areas inhabited during an operator walkdown 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 4-5 Revision 2 I
PDEP-2 EAL Technical Bases Manual 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 Local Level Indicator AND
- b.
UNPLANNED rise in area radiation levels as indicated by 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 radioactivewaste materials.
If dose rates are obtained with portable instruments, then closed window readings area used.
The largest contributor to total body exposure is gamma radiation, which is represented by closed window readings.
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 4-6 Revision 2 I
PDEP-2 EAL Technical Bases Manual 4.5 PD-SU1 INITIATING CONDITION:
UNPLANNED spent fuel pool temperature rise.
UNPLANNED spent fuel pool temperature rise to greater: than 140°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):
- 1.
NEI 99-01 Rev 6, PD-SU1
- 2.
S023-13-23, Loss of Spent Fuel Pool Cooling 4-7 Revision 2 I
PDEP-2 EAL Technical Bases Manual 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 Nuclear Security Shift Supervisor.
__ 2.
A vali_dated 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 conimi.mications between Nuclear 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 heighte*ned 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, within 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 S023-13-25, Operator Actions During Security Events.
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.
4-8 Revision 2 I
PDEP-2 EAL Technical Bases_Manual 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.
- NEl 99-01 Rev.6,-PD,.HA1
- 2.
S023-13-25, Operator Actions During Security Events 4-9 Revision 2 I
PDEP-2
_ EAL Technical Bases Manual_
4.7 PD-HU1 I
INITIATING CONDITION:
Confirmed SECURITY CONDITION or threat.
-EALs:
- 1.
A SECURITY CONDITION-that does not involve a HOSTILE ACTION as reported by the Nuclear Security Shift Supervisor.
- - 2. -~ Notification of a credible security threat directed-at the site.
- 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 ma-intain cooling of spent-fuel, and thus represen( a potential degradatiorHn the level-of plant
- safety. Security events which do not nieet one o_f_these EALs are adequately addressed by the requirements of 10 CFR § 73.71or10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA1.
Timely and accurate communications between Nuclear 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 OB.Os.
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].
EAL #1 references Nuclear Security Shift Supervisor 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 1 O CFR § 2.39 information.
EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with the SONGS Security Contingen_cy Plan and S0123-IV-13.100, Security Tactical Response Plan.
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 S023-13-25, Operator Actions During Security Events.
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-HA 1.
4-10 Revision 2 I
PDEP-2 EAL Technical Bases Manual Additional SONGS Site-Specific Bases Information:
None.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, PD-HU1
- 2.
SONGS Security Contingency Plan_
- 3.
S0123-IV-13.100, Security Tactical Response Plan 4:
8023-13-25; Operator Actions During Security Events I
I 4-11 Revision 2 I
I I -
PDEP-2 EAL Technical Bases Manual 4.8 PD-HU2 INITIATING CONDITION:
Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.
EALs:
- 1.
- a.
The occurrence of ANY of the following hazardous events:
Seismic event (earthquake)
Internal or*external flooding event High winds or lor:nado str:ike.
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 neededfor - * - - -*
- c.
Basis:
spent fuel cooling.
AND The damaged SAFETY SYSTEM train(s) cannot, or potentially cannot, pe.rform its
.. df3~igri_ f_L!n~tion b~s-~~ _on __ E:~:rH~~:
Indications of degraded performance VISIBLE DAMAGE 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 de.gradation 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 everit, be based on any of the ALERT I Cs; PD-AA 1, PD-AA2, PD-HA 1 or PD-HA3.
4-12 Revision 2 I
I
-- J.. _.-
PDEP-2 EAL Technical Bases Manual Additional SONGS Site-Specific Bases Information:
Electrical power is a SAFETY SYSTEM that is required for cooling the SFP. The SONGS boundary for the electrical power SAFETY SYSTEM,* as it applies to this EAL, is the on site equipment including the switchyard. EAL #1 applies to both units if offsite power is lost due to a listed hazardous event that damages onsite equipment and the onsite backup power _supply (Diesel Generator) is unavailable for any reason. Damage to onsite equipment must be visible or apparent via degraded performance. Time can be taken to walk down SAFETY SYSTEMs to determine if damage exists due to the hazardous event when there is no indication of degraded performance.
The SFP Cooling System is considered to have two trains; therefore, EAL #1 is applicable wh~D -
damage occurs to either train due to a listed hazardous event. This is true even though the sec6ndary co-olin!;f systems may be cross-tied between units~* EAL #r applies if one oftlie SFP-
- Cooling System chillers is.damaged by a listed hazardous eVehtsuch that it'ca_nnofoperate and perform its design function.
The SFP liner, at or be]ow thE! level of the SFP Pri_mary Cooling Pump suction (see Note 1 ), is considered a component of the SFP Cooling SAFETY SYSTEM. *EAL #1 applies if a listed hazardous event causes a leak in the SFP liner that is beyond makeup capacity and the SFP inventory is approaching the-level at which the SFP Primary Cooling Pumps-take-a suction. -- -
. This-is true even if.the si:;p PrimarY Cooling Pump -is secured-prior to vacuum:breaker-uncovery- - -
to prevent equipment damage.
NOTE 1:
Vacuum-breaker(anti:Csiptton) holes-in-the SFP Primary Cooling Pump suction-- -
---~-
pipe are at 23'6".
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, PD-HU2 4-13 Revision 2 I
PDEP-2 EAL Technical Bases Manual 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 ttireatening -risl<-to -sitef persO-nher or damage to siteeql.iip-ment b-ecaUsEn5t 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.
Additional_SONGS Site-Specific Bases_lnformation: __ H None.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, PD-HA3
-------- -- ------- -- _4~.
r;eA:-'.4Q.Q,Jlil~nu8-tQfJ?r9t~Qtiy~ -A~tiQ!:L ~_uiQ§§ aric;l_ Prot_~_ctiy_e_A_Gtie>.rts.Jor__N_l,J_~l~8-r-___ _
- Incidents 4-14 Revision 2 I
PDEP-2 4.10 PD-HU3 INITIATING CONDITION:
EAL Technical Bases Manual 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
- - - --~-initiatea. Noreleases of ractioactive materrarrequiringoffsife--re_sponse-o(monitoring: ate expected -~nl~ss fur:_therdegradationpL~~EETYSYSTEMS 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 a NOTIFICATION OF UNUSUAL EVENT.
_ _ _ ____ _ ___ l\\dditionaLSONGS. Site-oSpecific Bases Information:_
None.
Basis Reference(s):
- 1.
NEI 99-01-Rev 6, PD-HU3 4-15 Revision 2 I
/
PDEP-2 EAL Technical Bases Manual 4.11 E-HU1 INITIATING CONDITION:
Damage to a loaded cask CONFl[\\JEMENT BOUNDARY.
EALs:
f --
_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.
i 190 mR/hr (gamma) 3 feet from tile surface of the neutron shield at the mid-height -
-centerline.
Basis:
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 thaf 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 storag~.
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 oUhe spent fuel cask and-not the magnitude ofthe assoCiated -
-- -- ------------ -dosEfl'.>l' dos-Efrateclt is-recognized tharirnhefcaseofextrenreaarr1a9e*m-:a-1oaaeacask,-tnefacr-*----- -- --------
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 ISFSls are covered under I Cs PD-HU1 and PD-HA 1.
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-l-30.9 4-16 Revision 2 I Report and Analysis Summary of Permanently Defueled Emergency Action Level Changes
Reference:
80123-Vlll-ADMIN-4 San Onofre Nuclear Generating Station Report and Analysis Summary 10 CFR 50.54(q)(5)
Document Number: 80123-Vlll-PDEP-2
Title:
San Onofre Nuclear Generating Station (SONGS) Permanently Defueled Emergency Plan Emergency Action Level Technical Bases Manual, Revision 2 SONGS Corrective Action: NN 203362618 task 5 Change Description The 10CFR50.54(q) evaluation for PDEP-2 Revision 2 was performed under NN 203362618 task 5.
Changes to PDEP-2 Revision 2 include:
EAL PD-AU1.1 and PD-AU1 bases changed to clarify effluent release wording.
PD-AU2 bases changed to specify survey readings.
EAL PD-AA 1.3 changed to make the wording consistent with PD-AU1.2.
EAL PD-AA 1.4 and PD-AA 1 bases changed to make the wording consistent with PD-AA2 and to specify survey readings.
EAL PD-AA2.2 and PD-AA2 bases changed to allow the use of area radiation monitor readings and to specify survey readings.
PREPARED BY: Lucia Sischo DATE: 06-19-2017 Analysis Summary After incorporation of the changes in PDEP-2, Revision 2, the Permanently Defueled Emergency Plan continues to have a standard scheme of emergency classification and action levels in use.
The Permanently Defueled Emergency Plan continues to meet the regulatory requirements of 1 OCFR50.47(b) and 1 OCFR50 Appendix E,Section IV, as exempted.
The changes do not modify the licensing basis with regards to a reduction in effectiveness. The capability and timeliness to perform the planning functions are not altered by the changes described above. The capability and timeliness to perform the associated elements are also maintained.
The chances can be implemented without prior NRC aooroval.
REVIEWED BY: Kevin Sheek DATE: 06-19-2017 Page 1 of 1 EP(123) SOA Rev 1 06/2017 Revised Permanently Defueled Emergency Plan Implementing Procedures
Emergency Preparedness Program Drill Development and Evaluation Procedure Usage Requirements Reference Use Review and understand the procedure before performing any steps, including the prerequisite section.
Have a copy or applicable pages/sections open at the work site.
Use Placekeeping method according to 80123-XV-HU-3.
If any portion of the document is performed from memory, do so in the sequence specified. Perform each step as written, except when an approved process specifically allows deviation.
Refer to the procedure or instruction at least once to ensure completion of the task in accordance with the requirements.
Review the document at the completion ofthe task to verify that all appropriate steps are performed and documented.
Color Usage I
This Document Does Not Contain Relevant Color QA PROGRAM AFFECTING 50.59 DNA/ 72.48 DNA/ 50.54(q) Applies 50123-Vlll-ADMIN-3 REV: 1 Page 1 of 18 I
Sections ALL Location ALL Procedure Type Procedure Owner General Kelli Gallion
S0123-Vlll-ADMIN-3 Emergency Preparedness Program Drill Development REV: 1 and Evaluation Page 2of18 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCOPE................................................................................................................... 3 2.0 RESPONSIBILITIES.......................................................................................................................... 3 3.0 DEFINITIONS.................................................................................................................................... 4 4.0 PRECAUTIONS................................................................................................................................. 6 5.0 PREREQUISITES.............................................................................................................................. 6 6.0 PROCEDURE.................................................................................................................................... 6 6.1 Drill/Exercise Schedule.......................................................................................................... 6 6.2 Selection of Drill/Exercise Objectives..................................................................................... 8 6.3 Scenario Development.............................'.............................................................................. 9 6.4 Scenario Manual.................................................................................................................. 10 6.5 Scenario Security................................................................................................................. 11 6.6 Conduct of Drill and Exercises............................................................................................. 11
- 6. 7 Drill and Exercise Evaluation................................................................................................ 13 6.8 Corrective Actions................................................................................................................ 15 6.9 Mini-Drills.............................................................................................................................. 16 6.1 O Actual Emergency Classification Events.............................................................................. 16 7.0 RETENTION OF RECORDS........................................................................................................... 16
8.0 REFERENCES
I COMMITMENTS.................................................................................................. 16 ATTACHMENT 1
Summary of Changes..................................................................................................................... 18 REFERENCE USE
80123-Vlll-ADMIN-3 Emergency Preparedness Program Drill Development REV: 1 and Evaluation Page 3of18 1.0 PURPOSE AND SCOPE 1.1 To describe the Drill Development and Evaluation Program that implements the requirements outlined in the SONGS Permanently Defueled Emergency Plan.
1.2 To provide guidelines for development, conduct, evaluation, and records maintenance of Emergency Plan drills and exercises.
1.3 To establish a system for tracking and correcting deficiencies and weaknesses identified during a drill or exercise.
1.4 To provide guidelines for evaluation and records maintenance of Emergency Plan declared events.
2.0 RESPONSIBILITIES 2.1 Emergency Preparedness Manager 2.1.1 Implementing SONGS Emergency Preparedness Drill and Exercise Development and Evaluation program by:
2.1.1.1 Ensuring the program maintains the level of proficiency of the Emergency Response Organization (ERO).
2.1.1.2 Ensuring drill/exercise six-year plan is maintained and up-to-date.
2.1.1.3 Ensuring drills and exercises required by the Emergency Plan are scheduled, conducted and evaluated.
2.1.1.4 Coordinating with site management for resource assignment to a Scenario Development Team (SOT).
2.1.1.5 Ensuring actions are identified and resolved for objectives "not met" and for deficiencies, weaknesses or improvement areas.
2.1.1.6 Approving the annual drill and the biennial exercise scenario manual and critique report.
2.1.1. 7 Briefing the site management team and the NRG inspection team of the exercise evaluation results.
2.1.1.8 Ensuring distribution or availability of the annual drill and the biennial exercise report.
2.1.1.9 Ensuring lessons-learned are disseminated or available to ERO personnel.
2.1.1.1 O Ensuring remediation is provided for personnel demonstrating unsatisfactory performance during drills or exercises.
REFERENCE USE
50123-Vlll-ADMIN-3 Emergency Preparedness Program Drill Development REV: 1 and Evaluation Page 4of18 2.2 Site Management Team 2.2.1 Ensuring required station support is identified and provided for the development and conduct of drills and exercises.
2.3 Scenario Development Team 2.3.1 Leading the development, validation, and approval of scenarios.
2.3.2 Coordinating the assembly of the drill/exercise package and coordinate the distribution to the assigned controllers and evaluators.
2.3.3 Ensuring scenario confidentiality for evaluated drills and exercises.
2.3.4 Ensuring drill/exercise controllers, evaluators, and participants are identified and notified of the drill schedule.
2.3.5 Managing the overall conduct of the drill/exercise.
2.4 Emergency Preparedness staff or designees 2.4.1 Assisting in the development and validation of the scenario.
2.4.2 Assisting in the preparation of the drill/exercise scenario packages.
2.4.3 Supporting the selection and notification of controllers, evaluators and participants.
2.4.4 Supporting drills and exercises in the role of controller 2:4.5 Supporting in developing and maintaining the six-year plan.
3.0 DEFINITIONS Refer to SONGS Permanently Defueled Emergency Plan, Volume 1, for.
additional definitions and acronyms applicable to Emergency Preparedness Program.
3.1 Controller
An individual assigned to present information or data within the conduct of the drill.
3.2 Deficiencies
Items that identify the EP program or procedures do not conform to the provisions of applicable federal regulations.
3.3 Demonstration Criteria: A list of attributes that, if performed correctly, define completion of a performance objective. Failure to satisfactorily demonstrate a demonstration criterion does not necessarily mean failure of a performance objective, unless specifically noted.
REFERENCE USE
Emergency Preparedness Program Drill Development S0123-Vlll-ADMIN-3 REV: 1 and Evaluation Page 5of18
3.4 Drill
A controlled scenario event conducted to provide supervised training and practice for the participants. Drills may also include evaluated objectives and demonstration criteria as part of meeting periodic performance objective requirements as pre-designated by the scenario.
3.5 Evaluator
An individual who judges the performance of the participants, as well as the adequacy of the Radiological Emergency Plan, procedures, facilities, and equipment, against designated objectives and demonstration criteria.
3.6 Exercise
An event that evaluates the integrated capability and a major portion of the basic elements against designated objectives and demonstration criteria.
3.7 Frequency
The required periodicity for objective performance. The following frequencies are used:
Monthly (M) - Once per calendar month Quarterly (Q) - Once per calendar quarter (Jan-Mar, Apr-Jun, Jul-Sep, and Oct-Dec)
Semi-Annual (S) -Twice per calendar year (1st: Jan 1 -Jun 30; and 2nd: Jul 1 - Dec 31)
Annual (1Y) - Once every calendar year (Jan 1 - Dec 31)
Biennial (2Y) - Once every other calendar year Triennial (3Y) - Once every three calendar years Cyclic (6Y) - Once every six calendar years
3.8 Objective
A major element of the EP program selected for performance in a scenario. The objective describes the task, behavior, or activity to be demonstrated and provides criteria to measure satisfactory demonstration.
3.9 Other Issues: Items not quality affecting or of regulatory concern. These are items noted for trending purposes and actions intended to improve the emergency preparedness program.
3.10 Planning Standard: NUREG 0654 categories that outline the evaluation criteria used to measure the adequacy of evaluation criteria against the requirements of Title 10, Part 50.47(b) to the Code of Federal Regulations (CFR), as exempted.
3.11 Scenario Development Team (SOT): A multidiscipline team whose exact composition will vary based on the type and scope of the scenario.
3.12 Scenario Manual: A manual that provides generic information that relates to the scenario and specific information relating to control and evaluation of scenario activities.
3.13 Weaknesses: Items of documented performance that could have precluded effective implementation of the Emergency Plan in the event of an actual emergency.
REFERENCE USE
Emergency Preparedness Program Drill Development 50123-Vlll-ADMIN-3 REV: 1 and Evaluation Page 6of18 4.0 PRECAUTIONS 4.1 Security and Safety procedures shall remain in effect during drills and exercises.
4.2 Drill or exercise activities shall be suspended in the event of an actual emergency.
4.3 Electronic communications of information related to the drill or exercise with offsite agencies should be identified as drill or exercise information by prefacing them with the statement, "This is a drill."
This statement should also be repeated periodically on communication lines (telephone, radio) that are kept open for extended periods or could be monitored or overheard by non-participants.
5.0 PREREQUISITES 5.1 VERIFY this document is current by using one of the methods described in S0123-XV-HU-3.
5.2 VERIFY Level of Use requirements on the first page of this procedure.
6.0 PROCEDURE Steps in this procedure may be performed in any order as long as the intent is not changed.
6.1 Drill/Exercise Schedule 6.1.1 Emergency Preparedness will develop and maintain a Drill and Exercise Schedule that allows demonstration of all major portions of the emergency plan over a six-year period, and supports achievement of the minimum drill frequencies and types listed as specified below:
6.1.1.1 Cyclic (6Y) 6.1.1.1.1 Augmentation drills once every 6 years.
6.1.1.1.2 Off-hours activation once every 6 years.
6.1.1.1.3 Unannounced exercise once every 6 years.
REFERENCE USE
50123-Vlll-ADMIN-3 Emergency Preparedness Program Drill Development REV: 1 and Evaluation Page 7of18 6.1.1.2 Biennial (2Y)
SONGS will allow observers from Federal, state, and local governments, when requested, to observe scheduled exercises.
6.1.1.2.1 6.1.1.2.2 6.1.1.3 6.1.1.3.1 6.1.1.3.2 6.1.1.3.3 6.1.1.4 6.1.1.4.1 6.1.1.5 6.1.1.5.1 REFERENCE USE Exercise - tests the integrated capability and a major portion of the basic elements of the Emergency Plan.
Alternate Year Integrated Drill - Drill that tests the integrated capability and a major portion of the basic elements of the Emergency Plan.
Annual (1Y)
Medical Emergency Drill, involving a simulated contaminated individual, and containing provisions for participation by local support services organizations (i.e., ambulance and support hospital) is conducted annually. The offsite portions of the medical drill may be performed as part of the required biennial exercise Environmental Monitoring Drill - collection and analysis of all sample media (water, vegetation, soil and air) at or near the Exclusion Area Boundary. These drills will include demonstration of communications and record keeping. At least once during the drill cycle, State and local organizations will be invited to participate.
Fire Drill with participation by Camp Pendleton Fire Department.
Semi-Annual (S)
Radiation Protection Drills.
Monthly (M)
Communications Drill. Communications with State, local agencies, NRC Headquarters, and NRC Regional Office Operations Center will be tested monthly in accordance with S0123-Vlll-ADMIN-1. The respective procedure documentation, when completed, will serve as a written critique.
50123-Vlll-ADMIN-3 Emergency Preparedness Program Drill Development REV: 1 and Evaluation Page 8of18 6.1.2 Biennial exercises and alternate year integrated drills will allow the ERO to demonstrate the following principal functional areas at least once every six years:
6.1.3 6.1.3.1 6.1.4 Activities such as management and coordination of emergency response Accident assessment Event classification Notification of offsite authorities Assessment of onsite impact of radiological releases System repair and mitigate action implementation An opportunity to consider accident management strategies An opportunity by the Operating Staff to resolve problems (success paths)
Emergency Preparedness will develop an Annual drill and exercise schedule for the coming year before the end of the current year.
Coordinate drill dates with affected offsite agencies when establishing the drill schedule.
Any changes to the exercise or drill schedule shall be confirmed with all affected internal and external organizations, and approved by the Emergency Preparedness Manager.
6.2 Selection of Drill/Exercise Objectives 6.2.1 SOT will identify which drill objectives will be evaluated prior to the drill.
6.2.2 The selection of objectives shall be based upon:
6.2.2.1 Areas of improvement I weaknesses identified in previous drills/exercises 6.2.2.2 Review Action Requests/Inspection Reports/Drill Critiques/Operating Experience 6.2.2.3 Revisions to the Emergency Plan 6.2.2.4 Six-year schedule and objective demonstration tracking.
6.2.2.5 Verification of the effectiveness of corrective actions initiated from previous drills.
REFERENCE USE
6.2.3 6.2.4 6.2.4.1 Emergency Preparedness Program Drill Development 50123-Vlll-ADMIN-3 REV: 1 and Evaluation Page 9of18 Update EP(123) PDE following each drill/exercise.
Review EP(123) PDE against accomplished objectives frequently enough to ensure all required objectives have been accomplished or scheduled within their periodicity (recommend review completed by second quarter). Complete EP(123) PDE during the fourth quarter.
~
Document the review and completion in accordance with S0123-Vlll-ADMIN-1.
6.3 Scenario Development 6.3.1 The Biennial Exercise and alternate year integrated drill scenarios should vary to allow the demonstration of the principal functional areas listed in Step 6.1.2.
6.3.2 Assemble an SOT based on the type and scope of the scenario.
6.3.3 Use EP(123) DCL to develop the biennial exercise and alternate year integrated drill.
6.3.4 SOT will coordinate the required resources with site management.
6.3.5 Review EALs used during previous drills/exercises to ensure a va'riety of EALs are being utilized.
6.3.6 The scenario shall provide the necessary information and guidance to achieve the identified objectives.
6.3. 7 Scope of the drill or exercise should be developed to indicate:
Participants Types and extent of responses by the Emergency Response organization including extent of notifications and degree of simulation Offsite participation 6.3.8 Emergency Preparedness Manager will approve the scenario prior to commencement of the drill or exercise.
REFERENCE USE
Emergency Preparedness Program Drill Development 50123-Vlll-ADMIN-3 REV: 1 I
and Evaluation Page 10of18 6.4 Scenario Manual The scenario manual varies with the type of drill/exercise, simple for a mini-drill and very detailed for an integrated drill or exercise. Federally required scenarios must include enough information to adequately evaluate those types.
of drills.
6.4.1 The scenario manual may contain any or all of the elements listed in this section:
6.4.1.1 REFERENCE USE Summary Sequence of Events List of objectives to be demonstrated Extent of play including at least the date(s), time period, place(s), and participating organizations Messages and Cue Cards Meteorological, radiological and chemistry data Evaluation Forms Drill Controller List Controller Instructions Participant Instructions The scenario manual used for the biennial exercise and alternate year integrated drills will include, but not be limited to the following:
The basic objective(s) used in the exercise.
The date(s}, time period, place(s), and participating organizations.
A time schedule of real and simulated initiating events.
A narrative summary describing the conduct of the drill to include such items as simulated casualties, off site fire assistance, rescue of personnel, use of protective clothing.
Emergency Preparedness Program.Drill Development 50123-Vlll-ADMIN-3 REV: 1 and Evaluation Page 11 of 18 6.5 Scenario Security 6.5.1 Scenario security shall be maintained for drill/exercise evaluated objectives and unannounced drills.
6.5.2 Each individual, except Federal, State, and Local agency representatives, knowledgeable of the scenario scheduled for a biennial exercise are expected to sign a confidentiality agreement.
6.6 Conduct of Drill and Exercises 6.6.1 Before the drill/exercise starts:
If offsite agencies are participating, then ensure objectives and extent of play by offsite agencies have been determined.
Notify participants and drill/exercise controllers and evaluators of their participation and conduct briefs.
Ensure preliminary activities needed for conduct of the drill or exercises are taken.
Use EP(123) DCL, Drill Checklist, to conduct drill/exercise readiness checks.
Ensure controllers establish drill control communications at pre-determined time.
Inform offsite agencies and/or offsite controllers of the start of the exercise or drill.
I Inform' the Command Center crew and the CAS/SAS operator of the drill and start time and any extent of play that may or may not involve the actual staff.
Make a plant announcement of the drill/exercise start and instructions for nonparticipants.
REFERENCE USE
50123-Vlll-ADMIN-3 Emergency Preparedness Program Drill Development REV: 1 and Evaluation Page 12of18 6.6.2 During the drill/exercise:
Start the drill/exercise at the scheduled time.
Controllers ensure the events are running according to the scenario timeline.
Lead Controller may determine the need for modification of scenario information, or if necessary, the suspension or termination of the drill/exercise.
The Lead Controller will inform other Controllers when major events are about to occur.
Controllers may resolve discrepancies in data or field information with concurrence of the Lead Controller.
Controllers shall distribute messages and cues as scheduled in the scenario with concurrence of the Lead Controller.
Controllers will inform the Lead Controller of problems encountered that impact the timeline and completion of major events.
Evaluators and controllers will maintain a chronological record of sequence of events and participant responses in a sufficient detail in their assigned area to provide an accurate record of activities.
6.6.3 Termination of the drill/exercise:
Lead Controller shall obtain concurrence from the other Controllers and any participating agency (local, state, and federal) that all applicable objectives were demonstrated and evaluated.
Once concurrence is obtained, all Controllers will agree on a termination time.
Lead Controller shall inform the Command Center and CAS/SAS that the exercise or drill is terminated.
A plant announcement should be made for the drill/exercise termination.
The Lead Controller will ensure participating federal, state, local agencies, and any state or federal agency controller/evaluators are notified that the drill/exercise is terminated.
Lead Controller will coordinate the following activities:
REFERENCE USE Verify all participants, controllers, and evaluators have signed an attendance sheet and collect all the sheets.
Ensure all drill/exercise paperwork is collected from each participant.
Ensure participants restore or restock emergency response supplies and equipment, including forms and procedures.
Ensure participants complete emergency response equipment inspections in accordance with 80123-Vlll-ADMIN-1, Emergency Preparedness Program Maintenance.
50123-Vlll-ADMIN-3 Emergency Preparedness Program Drill Development REV: 1 and Evaluation Page 13of18
- 6. 7 Drill and Exercise Evaluation
- 6. 7.1 Drills and exercises should be evaluated against criteria identified by the specific objectives using EP(123) ODC.
6.7.2 Post Drill/Exercise Participant Critique 6.7.2.1 A Participant critique shall be conducted with the ERO at the conclusion of the drill/exercise.
6.7.2.1.1 Drill Participants unable to attend the post-drill critique shall be provided an opportunity to provide feedback using the drill/exercise critique or feedback sheets.
6.7.2.2 Immediately after the drill or exercise, the controllers will hand out drill/exercise critique or feedback sheets to Participants.
6.7.2.3 Participants will complete the critique which will provide the opportunity to self-identify errors and performance based issues.
6.7.2.3.1 Participants should generate actions per the corrective action process to address evaluated objectives not met, facility, equipment, process, or procedure issues identified during the drill/exercise 6.7.2.4 The Controllers should provide additional observations and evaluations.
- 6. 7.2.5 At the conclusion of the participant critique, the Lead Controller will collect completed Participant critique documentation.
6.7.3 Post Drill/Exercise Controller/Evaluator Debrief
- 6. 7.3.1 A Controller debrief will be scheduled to discuss the preliminary findings.
6.7.3.2 Emergency Preparedness Manager or designee should ensure the Controller debrief remains focused on evaluation of objectives, NOT the development of Corrective Action Plans.
6.7.3.3 At the controller debrief, it will be determined whether the items in the preliminary findings are deficiencies, weaknesses, and other issues.
6.7.3.4 The preliminary status of each objective is listed on a "tally sheet" in order to facilitate a synopsis review at the end of the Controller debrief.
6.7.3.5 The cognizant Controller(s) will generate actions per the corrective action process to address evaluated objectives not met, facility, equipment, process, or procedure issues identified during the drill/exercise if not already generated by drill Participants.
REFERENCE USE
6.7.3.6 6.7.3.7 6.7.4 6.7.4.1 6.7.4.2 6.7.4.3 6.7.4.4 Emergency Preparedness Program Drill Development
$0123-Vlll-ADMIN-3 REV: 1 and Evaluation Page 14of18 After the Controller debrief, the Lead Controller will compile the information from the evaluation forms, response records, drill data, drill/exercise critique, feedback sheets, participant comments, and other drill records.
Evaluation form(s) should indicate if evaluated objectives were*met or not, and actions generated per the corrective action process.
Draft Critique Report A draft critique report will be completed for the Biennial Exercise and the alternate year integrated drill.
The draft critique report for the biennial exercise should be completed prior to the agreed upon NRC exit meeting for a Biennial Exercise.
Review findings with Nuclear Oversight to ensure all significant Licensee critique comments are incorporated prior to NRC exit meeting for a Biennial Exercise.
The Critique Report shall contain the following elements, as applicable for the drill/exercise scenario:
Executive Summary Drill/Exercise Description Introduction Participation Summary Sequence of Events I Drill Summary Drill/Exercise Evaluation Results Drill/Exercise Objectives Evaluation Strengths, deficiencies, weaknesses and other issues Condition Report Summary Command Center Evaluation Facility and Equipment Issues Procedure Quality Issues Program Administration and Maintenance Issues Demonstration Criteria (DC) results as an attachment Participants, Controllers and Evaluators Lists as an attachment REFERENCE USE
6.7.5 6.7.5.1 6.7.5.2 6.7.6 6.7.6.1 6.7.6.2 50123-Vlll-ADMIN-3 Emergency Preparedness Program Drill Development REV: 1 and Evaluation Page 15of18 Management Critique Meeting A Management Critique Meeting will be completed for the Biennial Exercise and the alternate year Integrated Drill.
Emergency Preparedness will conduct the Management Critique Meeting.
Final Critique Report A final critique report incorporating comments from the Management Critique Meeting will be completed for the Biennial Exercise and the alternate year Integrated Drill.
The final critique report should be approved by the Emergency Preparedness Manager and distributed to site management team and Shift Managers within 30 days of the drill/exercise.
6.8 Corrective Actions 6.8.1 Actions will be generated per the corrective action process to address evaluated objectives not met, facility, equipment, process, or procedure issues identified during the drill and exercise.
6.8.2 Observations identified as a result of drills and exercises will be evaluated in relation to applicable federal regulations and the SONGS Emergency Plan.
6.8.3 Observations are grouped in three categories: deficiencies, weaknesses, or other issues.
6.8.4 Risk Significant Planning Standards (RSPS) are 10 CFR 50.47(b)(4),
50.47(b)(5), 50.46(b)(9), and 50.49(b)(10). All other 10 CFR 50.57(b) planning standards are not risk significant.
EP personnel are to generate Action Requests for issues related to 10 CFR 50.74(b) planning standards.
6.8.4.1 Include the following information in the Action Request:
REFERENCE USE If the issue is related to an applicable RSPS, state "Risk Significant Planning Standard".
Is it a deficiency, weakness, or other issue?
The Division responsible for resolution.
Emergency Preparedness Program Drill Development 50123-Vlll-ADMIN-3 REV: 1 and Evaluation Page 16of18 6.9 Mini-Drills 6.9.1 Mini-drills may be conducted periodically to provide training to Emergency Response Personnel and to correct identified drill weaknesses or deficiencies.
6.10 Actual Emergency Classification Events 6.10.1 6.10.2 Actual Emergency Classification Events should be evaluated incorporating applicable elements of section 6.7.
Actual*Emergency Classification Events identified issues should be evaluated and corrected incorporating applicable elements of section 6.8.
7.0 RETENTION OF RECORDS 7.1 Drill and Exercise Records shall be maintained in EP files for a period of six years in accordance with the evaluation cycle.
7.2 Scenarios used to conduct drills and exercises by EP in accordance with Periodic Drill and Exercise Requirements shall be maintained in EP files for a period of six years.
7.3 The final critique report shall be sent to Records Management within three months of the date it is signed.
7.4 A copy of the critique report shall be kept on file at EP for a period of six years.
8.0 REFERENCES
I COMMITMENTS 8.1 Implementing Reference 8.1.1 Procedures 8.1.1.1 80123-Vlll-ADMIN-1, Emergency Preparedness Program Maintenance 8.1.1.2 80123-XV-HU-3, Written Instruction Use and Adherence 8.1.1.3 80123-XV-50, Corrective Action Program 8.1.2 Forms 8.1.2.1 EP(123) PDE, Matrix of Periodic Drill and Exercises Objectives 8.1.2.2 EP(123) DCL, Drill Checklist 8.1.2.3 EP(123) ODC, Objectives Demonstration Criteria REFERENCE USE
50123-Vlll-ADMIN-3 Emergency Preparedness Program Drill Development REV: 1 and Evaluation Page 17of18 8.2 Developmental References 8.2.1 8.2.1.1 8.2.1.2 8.2.1.3 8.2.2 8.2.2.1 Commitments SONGS Permanently Defueled Emergency Plan, Volume 1 SONGS Permanently Defueled Emergency Plan, Volume 2, EAL Technical Bases Manual 10 CFR 50.47(b)
Other NU REG 0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants REFERENCE USE
Emergency Preparedness Program Drill Development S0123-Vlll-ADMIN-3 REV: 1 and Evaluation Page 18of18 Summary of Changes I Attachment 1 Notification tracking 10 CFR 50.54(q): 203232420 Author:
Steve Giannell
~N, Order, or.
Step, Section, Other Description of Change Reviewer(s)
Attachment or Action
- Page 203232420 Change terminology "Site boundary" to "Exclusion Area Step 6.1.1.3.2 Boundary" Correct Section reference.
Churchill Step 6.10.2 Betterment Add reference to corrective action program procedure.
Sh eek Step 8.1.1.3 Sischo Change NN or Corrective Action to Action Request.
Alchaar Step 6.2.2.2, Section 6.8.4 Comments Revise Steps to better integrate annual drill and biennial Steps 2.1.1 '.,6 exercises.
and 6.3.1 Reviewer Title Reviewer Name:
Owner Sischo Emergency Planning Sh eek Cyber Security Alchaar NOD (Nuclear Oversight Gray Division)
Approvers:
NOD Final Approval:
Churchill or designee CFDM I Designee Final Gallion Approval:
REFERENCE USE Page 1 of 1
50123-Vlll-ER0-1 PDEP Standard~ and Expectations REV: 1 Page 1 of 14 Procedure Usage Requirements I
Sections Information Use The user may complete the task from memory. However, the ALL user is responsible for performing the activity according to the
- procedure.
Information use documents that contain a specific process order are performed in the given order unless otherwise specified within the document.
Color Usage I
This Document Does Not Contain Relevant Color LEVEL 1 QA PROGRAM AFFECTING 50.59 DNA/ 72.48 DNA I RX DNA/ 50.54(q) APPLIES Location ALL Procedure Type Procedure Owner General Kelli Gallion
S0123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 2of14 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCOPE................................................................................................................... 3 2.0 RESPONSIBILITIES.......................................................................................................................... 3 3.0 DEFINITIONS.................................................................................................................................... 7 4.0 PRECAUTIONS................................................................................................................................. 7 5.0 PREREQUISITES.............................................................................................................................. 7 6.0 PROCEDURE.................................................................................................................................... 7 6.1 Emergency Plan Exercises and Drills.................................................................................... 7 6.2 Emergency Response Facilities and Emergency Plan Equipment Surveillance.................... 8 6.3 Coordination with Offsite Response Organizations................................................................ 8 6.4 Coordination of Offsite Response Organizations Training..................................................... 9 6.5 Audits [10 CFR 50.54 (t)]............................................................ ~........................................... 9 6.6 Nuclear Regulatory Affairs Notification................................................................................. 10 6.7 Emergency Response Personnel......................................................................................... 10 6.8 Permanently Defueled Emergency Plan Implementing Procedures.................................... 11 6.9 Emergency Plan Training..................................................................................................... 11 7.0 RETENTION OF RECORDS........................................................................................................... 11
8.0 REFERENCES
I COMMITMENTS.................................................................................................. 12 ATTACHMENT 1
Summary of Changes..................................................................................................................... 14 INFORMATION USE
50123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 3of14 1.0 PURPOSE AND SCOPE 1.1 To assign responsibilities and define organizational jurisdiction for the control of emergencies at SONGS in accordance with the Permanently Defueled Emergency Plan (PDEP).
1.2 To identify the requirements for maintaining an effective emergency preparedness program. These requirements relate to the:
Emergency Response Organization PDEP Drills Emergency Facilities and Equipment Surveillance PDEP Implementing Procedures PDEP Training 1.3 To identify the requirements for coordination and management of the local, State, and Federal offsite emergency preparedness activities associated with SONGS in accordance with the PDEP, State, and Federal guidance and requirements (Reference Section 8.2.1 ).
2.0 RESPONSIBILITIES 2.1 Southern California Edison (SCE) is responsible for the safe and reliable maintenance of SONGS.
2.2 SONGS has primary responsibility for planning and implementing emergency measures within the Exclusion Area Boundary including overall accident assessment. These emergency measures include mitigation, corrective actions, protective measures, and aid for personnel onsite.
2.3 The state and counties are responsible for maintaining plans that specify the responsibilities and functions for the major agencies, departments, and key individuals of their organizations. These plans address multiple types of accidents that may occur at facilities within their jurisdictions. State and county information dissemination is performed in accordance with state and local plans.
Notifications and messages to the public are delivered through the media in accordance with state and local plans.
2.4 The company's Corporate Communications Department is responsible for the dissemination of information during an event at the station. The Communications Department will disseminate information to the public through press releases and media conferences in accordance with current Corporate Communications Department protocols.
INFORMATION USE
50123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 4of14 2.5 The Emergency Preparedness Manager is responsible for the overall radiological emergency preparedness program associated with the station and for administering the program to ensure availability of resources in the event of an emergency. Specific responsibilities include the following:
Maintaining and updating the PDEP and associated procedures Documenting review of PDEP and associated procedures Coordinating PDEP with other station programs and procedures.
Overseeing Emergency Preparedness Training Program and ensuring proper records are maintained to document training and retaining of the ERO.
Overseeing and documenting Emergency Preparedness Drill and Exercise Program Documenting and maintaining Emergency Preparedness Facilities and Equipment Documenting and maintaining Emergency Preparedness interfaces with offsite agencies.
Performing and documenting appropriate evaluations of program and of classified emergency events Ensuring onsite personnel and offsite response organizations are notified of updates to the Emergency Plan or procedures.
Ensuring all Letters of Agreement are reviewed annually and updated as needed.
2.6 The Emergency Response Organization (ERO) is responsible for implementing the actions described in the PDEP. The ERO is made up of on-shift personnel, augmented by the Duty ERO Coordinator, Radiation Protection Coordinator, and other supplemental positions.
- 2. 7 On-shift personnel are responsible to provide the initial response to an event. Members of the on-shift organization are trained on their responsibilities and duties in the event of an emergency and are capable of performing all necessary response actions until the augmenting ERO arrives or the event is terminated. The normal shift staffing assignments include the roles and responsibilities for their emergency response functions. The relationship between normal and emergency response positions for the shift personnel is unchanged when an event occurs. The skills and knowledge required to perform plant stabilization and mitigation are a normal function of operations specific positions. Operators receive routine training to ensure proficiency in this area.
INFORMATION USE
50123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 5of14 2.8 The Shift Manager is the on-shift individual responsible for declaring the initial emergency classification and assumes the role of Emergency Director upon event declaration. The Shift Manager has the authority and responsibility to immediately and unilaterally initiate any emergency actions. In accordance with 10 CFR 50.54(x) and (y), the Shift Manager has the authority to suspend any security measure described in the Physical Security Plan or any license condition or technical specification as necessary to facilitate response to emergency conditions.
2.8.1 Non-delegable responsibilities of the Emergency Director include the following:
Event classification and declaration Authorize notification of offsite authorities (State/local and NRC notifications)
Authorization for the use of EPA-400 emergency exposure controls (emergency worker dose limits that exceed 10 CFR 20 occupational exposure limits).
2.8.2 Key delegable responsibilities of the Emergency Director include the following:
Management of available station resources Initiation of assessment and mitigative/corrective actions Initiation of onsite protective actions Decision to call for offsite police, fire or ambulance assistance Augment the emergency staff as deemed necessary Notify SCE corporate officers and the company's duty spokesperson 2.9 The RP Technician Is the on-shift individual responsible for radiological assessment and radiation protection duties. Additional RP Technicians may be called to supplement the ERO. When an event is classified and the PDEP is implemented, the Technicians report to the Radiation Protection Coordinator if this position is activated. Responsibilities when implementing the PDEP include:
Performing radiological monitoring and surveys as directed Ensuring the habitability of the occupied areas of the plant
- . Monitoring personnel exposures Performing radioisotopic analysis as directed (e.g. air and water samples).
Establishing and monitoring Radiological Control Areas (RCAs)
Providing radiological and first aid support to search and rescue and medical emergencies.
Maintaining a record of event activities and surveys performed Performing decontamination functions as necessary INFORMATION USE
50123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 6of14 2.1 O The *certified Operator is the on-shift individual responsible to perform system and component manipulations and basic radiation surveys as needed. If the Shift Manager is unavailable or incapacitated for any reason the Certified Operator will assume duties until another Shift Manager arrives.
2.11 Station Security personnel are on-shift individuals responsible to assist the Emergency Director as directed.
2.12 The Duty ERO Coordinator responsibilities when implementing the PDEP include:
Reporting to the Command Center and assist Emergency Director with assessment, mitigation, and communications tasks.
Assisting the Emergency Director to supplement the emergency staff as deemed necessary.
Coordinating supplemental personnel and resource to support for emergency response.
2.13 The Radiation Protection Coordinator responsibilities when implementing the PDEP include:
Monitoring personnel accumulated dose Advising the Emergency Director concerning Radiological EALs Augmenting the emergency staff as deemed necessary Establishing Radiological Controls Performing Dose Assessment Establishing and maintaining communications as desired by the Emergency Director Maintaining a record of event activities 2.14 The Technical Coordinator may be called to supplement the ERO. The responsibilities of the Technical Coordinator when implementing the PDEP include:
Assisting with and arrange for other resources to evaluate technical data pertinent to plant conditions Augmenting the emergency staff as deemed necessary Assisting with incident assessment and recommend mitigative and corrective actions Assisting with search and rescue actions Coordinating maintenance and equipment restoration Establishing and maintain communications as desired by the Emergency Director Maintaining a record of event activities 2.15 Director, Nuclear Regulatory Affairs (NRA) is responsible for supporting the 1 O CFR 50.54(t) evaluation.
INFORMATION USE
50123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 7of14 2.16 Director, Nuclear Oversight Division (NOD) is responsible for performing the 10 CFR 50.54(t) evaluation.
2.17 Directors and Division Managers are responsible for:
Ensuring the Emergency Response Personnel staffing for their respective section(s) is maintained sufficiently to mitigate any emergency event.
Conducting assigned Emergency Plan equipment surveillances.
Implementing drill deficiency corrective actions.
Ensuring the coordination and appropriate identification of emergency response training program requirements.
3.0 DEFINITIONS 3.1 None.
4.0 PRECAUTIONS 4.1 None 5.0 PREREQUISITES 5.1 VERIFY this document is current by using one of the methods described in 80123-XV-HU-3.
5.2 VERIFY Level of Use requirements on the first page of this procedure.
6.0 PROCEDURE 6.1 Emergency Plan Exercises and Drills 6.1.1 A biennial Emergency Plan exercise shall be conducted to verify the integrated capability and adequacy of a major portion of the basic elements of the Emergency Plan.
6.1.2 Emergency Plan drills shall be conducted per the PDEP, at a minimum.
6.1.3 All exercise and drill evaluations/critiques shall include corrective actions for any identified weaknesses or deficiencies. Such corrective actions shall be completed in accordance with the Corrective Action Program.
INFORMATION USE
80123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 8of14 6.2 Emergency Response Facilities and Emergency Plan Equipment Surveillance 6.2.1 All Emergency Response Facility surveillances and Emergency Plan equipment surveillances shall be performed and documented in accordance with approved procedures or instructions.
6.2.2 Discrepancies discovered in Emergency Response Facilities and equipment, noted in scheduled surveillances and/or Emergency Plan drills, shall be corrected in accordance with station procedures.
6.3 Coordination with Offsite Response Organizations The National Response Framework (NRF) is the guide to how the Nation responds to all types of disasters and emergencies. It is built on scalable, flexible, and adaptable concepts identified in the National Incident Management System (NIMS) to align key roles and responsibilities across the Nation. The NRF describes the principles, roles, and responsibilities, and coordinating structures for delivering the core capabilities required to respond to an incident and, further describes how response efforts integrate with those of the other mission areas. The federal organizational response for an emergency at a SONGS station is made up of the following:
Nuclear Regulatory Commission (NRC),,
Department of Homeland Security (OHS)
Marine Corps Base, Camp Pendleton Federal Bureau of Investigation (FBI) 6.3.1 Activities relative to state and local agencies SHALL be coordinated to ensure compliance with emergency plans, regulations, and guidance.
6.3.2 The agreements between SONGS and other support organizations SHALL be reviewed annually and updated as needed.
6.3.3 Liaison with the United States Marine Corps (USMC), Camp Pendleton, for SONGS Emergency Preparedness issues SHALL be provided.
6.3.4 Initial Emergency Action Levels (EALs) SHALL be reviewed and agreed upon by the State and local agencies jurisdictions.
6.3.4.1 EALs SHALL be reviewed annually with the State and local agencies.
INFORMATION USE
50123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 9of14 6.4 Coordination of Offsite Response Organizations Training 6.4.1 Non-SONGS organizations that may provide specialized services during an emergency (i.e., local law enforcement, firefighting, rescue, medical services, transport of injured) are provided or formally offered annual training.
6.4.2 Training of offsite response organizations is described in their respective local agencies emergency plans, with support provided by SONGS as requested.
6.4.3 Records for training offered and/or provided for the offsite responders is to be documented and maintained.
6.5 Audits [10 CFR 50.54 (t)]
6.5.1 To meet the requirements of 10 CFR 50.54 (t), SONGS coordinates an annual independent review of the Emergency Preparedness Program to examine conformance with 10 CFR 50.47, 10 CFR 50.54, and 10 CFR 50 Appendix E. Included in the 6.5.2 6.5.3 6.5.3.1 audit/assessment are the following:
The PDEP and associated Implementing Procedures.
The emergency preparedness training including drills and exercises as well as any activation of the PDEP since the last program audit.
The readiness of the station Emergency Response Organization to perform its function.
The readiness of facilities and equipment to perform as outlined in the PDEP and procedures.
The interfaces between SONGS and local agencies pertaining to the overall Emergency Preparedness Program.
Results of this review are submitted to the Chief Nuclear Officer and Corporate Management's Internal Nuclear Managing Group (INMG).
The Emergency Preparedness Manager ensures any findings that deal with offsite interfaces are reviewed with the appropriate agencies.
Written notification will be provided to State and local agencies of the performance of the audit and the availability of the audit records for review at SONGS facilities.
INFORMATION USE
80123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 10of14 6.6 Nuclear Regulatory Affairs Notification 6.6.1 Nuclear Regulatory Affairs SHALL be notified within 15 days of PDEP or PDEP Implementing Procedures issuance to facilitate NRC submittal requirements per S0123-XV-3.3, NRC Reporting Requirements and Assessments.
- 6. 7 Emergency Response Personnel 6.7.1 Emergency Response Personnel shall meet the criteria set forth in the PDEP, PDEP Implementing Procedures, and other applicable approved procedures and instructions.
6.7.2 Personnel with assigned Emergency Response Personnel (ERP) qualification codes shall:
- 6. 7.2.1 Receive documented training regarding their specific responsibilities and duties during an emergency event.
6.7.2.2 Maintain ERO qualifications and Protected Area access.
6.7.2.3 Review the posted drill/ training schedule to ensure participation when assigned.
6.7.2.4 Review this procedure section annually. (Emergency Preparedness will issue an annual required reading assignment to document the procedure section review.)
6.7.2.5 Read all Emergency Preparedness Bulletins that are distributed.
6.7.2.6 Maintain contact and call-in information up-to-date.
6.7.2.7 Be available and prepared to provide relief support to the immediate ERO responders in the event of an actual emergency or drill.
6.7.3 When on duty for an ERO position:
6.7.3.1 Ensure no concurrent assignment to another on-duty ERO position or on-shift ERO position.
6.7.3.2 Be prepared to arrive ready to perform responsibilities at the Command Center or other report location within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of alert declaration.
6.7.3.3 Be prepared with Southern California Edison (SCE) identification (i.e., security photo ID badge), second identification, proper attire, and PPE.
6.7.3.4 Remain Fit-for-Duty and refrain from alcohol consumption during the entire period of time on-duty. This includes the 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> period prior to beginning on duty.
6.7.3.5 Ensure home arrangements (e.g., child care, transportation availability, etc.) are made in advance in preparation of being called-in in response to an emergency or drill.
INFORMATION USE I.
6.7.3.6 6.7.3.7 6.7.3.8 50123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 11 of 14 Ensure access to a well maintained vehicle with sufficient fuel.
IF unable to fulfill on-duty responsibilities, THEN arrange for duty coverage by another fully qualified individual in the same ERO position and inform the SM to update required documents (e.g., SM Turnover).
Maintain Duty Week coverage from 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> on the Monday the corresponding Crew is on Day Shift to 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> the next Monday.
6.8 Permanently Defueled Emergency Plan Implementing Procedures 6.8.1 PDEP Implementing Procedures shall be provided to direct the actions of Emergency Response Personnel during emergency conditions in accordance with PDEP.
6.9 Emergency Plan Training 6.9.1 Training for Emergency Response personnel shall be conducted in accordance with applicable Training Procedures.
7.0 RETENTION OF RECORDS 7.1 Training records shall be transmitted to Training in accordance with S023-XXl-REC.
7.2 The independent review of the Emergency Preparedness Program performed in accordance with 10 CFR 50.54 (t) shall be forwarded to Records Management for a minimum 5-year retention (Reference Section 6.5).
INFORMATION USE
PDEP Standards and Expectations
8.0 REFERENCES
I COMMITMENTS 8.1 Implementing Reference 8.1.1 Procedures 8.1.1.1 S0123-XV-HU-3, Human Performance Program 50123-Vlll-ER0-1 REV: 1 Page 12of14 8.1.1.2 S0123-Vlll-ADMIN-1, Emergency Preparedness Program Maintenance 8.1.1.3 S0123-Vlll-ADMIN-2, Emergency Preparedness Training Program Description 8.1.1.4 S0123-Vlll-ADMIN-3, Emergency Preparedness Program Drill Development and Evaluation 8.1.1.5 SO 123-VI 11-ER0-2, Shift Manager/Emergency Director Checklist 8.1.1.6 S0123-Vlll-ER0-3, Duty ERO Coordinator Checklist 8.1.1.7 S0123-Vlll-ER0-4, Technical Coordinator Checklist 8.1.1.8 SO 123-VI 11-ER0-5, Radiation Protection Coordinator Checklist 8.1.1.9 S023-XXl-REC, Training Records 8.1.1.10 S0123-XV-3.3, NRC Reporting Requirements and Assessments 8.2 Developmental References 8.2.1 Commitments 8.2.1.1 SONGS Permanently Defueled Emergency Plan, Volume 1 8.2.1.2 SONGS Permanently Defueled Emergency Plan, Volume 2, EAL Technical Bases Manual 8.2.1.3 10 CFR 50.47, Emergency Plans 8.2.1.4 10 CFR 50.54 (t), Conditions of licenses 8.2.1.5 1 O CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities INFORMATION USE
50123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 13of14 8.2.2
()th er 8.2.2.1 NUREG-0728, US Nuclear Regulatory Commission, Concept of ()perations: NRC Incident Response 8.2.2.2 National Response Framework 8.2.2.3 State of California Emergency Response Plan INFORMATION USE
S0123-Vlll-ER0-1 PDEP Standards and Expectations REV: 1 Page 14of14 Summary of Changes I Attachment 1 Notification tracking 10 CFR 50.54 (q):
203246495 Author:
Lucia Sischo
.NN, Order, or Step, Section, Other Description of Change Reviewer(s)
Attachment or Action Page 203246495 Correct typos and title.
Steps 2.7, 2.8 203232420 Revise verbiage from "site boundary" to Step 2.2 "Exclusion Area Boundary".
EP 203233338 Revise wording to align with PDEP-1.
NOD Step 2.8.1, Owner Sections 6.3 and 6.4 Comment Revise Step to clarify RP Tech reporting to Step 2.9 activated position.
Reviewer Title Reviewer Name:
Owner Sischo Emergency Planning Sh eek NOD (Nuclear Oversight Gray Division)
Approvers:
NOD Final Approval:
Churchill or designee CFDM I Designee Final Gallion Approval:
INFORMATION USE Page 1 of 1 Report and Analysis Summary of Permanently Defueled Emergency Plan Implementing Procedures Changes
Reference:
S0123-Vlll-ADMIN-4 San Onofre Nuclear Generating Station Report and Anaiysis Summary 10 CFR 50.54(q)(5)
Document Number: 80123-Vlll-ADMIN-3
Title:
Emergency Preparedness Program Drill Development and Evaluation, Revision 1 SONGS Corrective Action: NN 203232420 task 32 Change Description The 10CFR50.54(q) evaluation for S0123-Vlll-ADMIN-3 Revision 1 was performed under NN 203232420 task 32.
Changes to S0123-Vlll-ADMIN-3 Revision 1 include:
Correct Site Boundary to Exclusion Area Boundary, as the boundary referred to in this case is the boundary where potential radiological impact analysis are performed and compare to EPA-400 PAGs for radiological concerns.
Corrects wording to match actual documents approved by the Emergency Preparedness Manager.
Removes a statement referring to substantially different scenarios used during sequential exercises and integrated drills and replaces it with actual requirements listed in section 6.1.2. The Permanently Defueled Emergency Plan does not contain commitments requiring substantially different scenarios. Exemption from 10 CFR Part 50, Appendix E,Section IV.F.2.i requirement to include a wide spectrum of radiological releases and events in drill and exercise scenarios was granted by the NRC and documented in ML15082A204.
Editorial chani:ies.
PREPARED BY: Lucia Sischo DATE: 06-19-2017 Analysis Summary After incorporation of the changes in S0123-Vlll-ADMIN-3, Revision 1, the Permanently Defueled Emergency Plan continues to have:
adequate methods for assessing and monitoring actual or potential consequences of a radiological emergency condition, conduction of periodic drills to develop and maintain key skills, and correction of deficiencies identified as a result of exercises or drills.
The Permanently Defueled Emergency Plan continues to meet the regulatory requirements of 1 OCFR50.47(b) and 1 OCFR50 Appendix E,Section IV, as exempted.
The changes do not modify the licensing basis with regards to a reduction in effectiveness. The capability and timeliness to perform the planning functions are not altered by the changes described above. The capability and timeliness to perform the associated elements are also maintained.
The changes can be implemented without prior NRC approval.
REVIEWED BY: Kevin Sheek DATE:.06-19-2017 Page 1 of 1 EP(123) SOA Rev 1 06/2017
Reference:
80123-Vlll-ADMIN-4 San Onofre Nuclear Generating Station Report and Analysis Summary 10 CFR 50.54(q)(5)
Document Number: S0123-Vlll-ER0-1
Title:
PDEP Standards and Expectations, Revision 1 SONGS Corrective Action: NN 203246495 task 2 Change Description The 10CFR50.54(q) evaluation for S0123-Vlll-ER0-1 Revision 1 was performed under NN 203246495 task 2.
Changes to S0123-Vlll-ER0-1 Revision 1 include:
Corrects Site Boundary to Exclusion Area Boundary. The boundary referred to in this case is the boundary in which the reactor licensee has the authority to determine all activities including exclusion or removal of personnel and property.
Corrects a non-delegable responsibility of the Emergency Director from "Notification of offsite authorities (State/local and NRC notifications)" to "Authorize notification of offsite authorities (State/local and NRC notifications)" to be consistent with the Permanently. Defueled Emergency Plan (PDEP-1 ).
Adds clarification regarding when the RP Technicians report to the Radiation Protection Coordinator to be consistent with PDEP-1.
Removes reference to the lnterjurisdictional Planning Committee (IPC) for activities related to state and local agencies. This is consistent with PDEP-1, which specifically refers to state and local agencies.
Revises wording for agreements to align with PDEP-1.
Revises wording for Offsite Response organizations training to align with PDEP-1.
Editorial changes.
PREPARED BY: Lucia Sischo DATE: 06-19-2017 Analysis Summary After incorporation of the changes in S0123-Vlll-ER0-1, Revision 1, the Permanently Defueled Emergency Plan continues to have:
assigned responsibilities for emergency response, staffed and assigned on-shift responsibilities to provide initial facility accident response and a process for timely augmentation of response capabilities, provisions for radiological emergency response training to those who may be called on to assist in an emergency, assigned responsibilities for plan development and review.
The Permanently Defueled Emergency Plan continues to meet the regulatory requirements of 1 OCFR50.47(b) and 1 OCFR50 Appendix E,Section IV, as exempted.
The changes do not modify the licensing basis with regards to a reduction in effectiveness. The capability and timeliness to perform the planning functions are not altered by the changes described above. The capability and timeliness to perform the associated elements are also maintained.
The changes can be implemented without prior NRC approval.
REVIEWED BY: Kevin Sheek DATE: 06-19-2017 Page 1 of 1 EP(123) SOA Rev 1 06/2017