Text

Supplement to Request for Licensing Action to Revise the Emergency Plan
	ML17250B169
Person / Time
Site:	Beaver Valley
Issue date:	09/07/2017
From:	Bologna R; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CAC MF8448, CAC MF8449, L-17-275
	Download: ML17250B169 (56)
	v • d • e

FENOC- Beawr Valley Fouer Sfafian P.A. tux 4 ftxEnagy fUffir +era t*g fuipny Shippingprt, PA 1fi77 Rlcltard D. Bologna 724482-5234 Sde Vice Pusrdenl Fex:724{H3{oG9 September 7, 2017 L-17-275 10 CFR 50, Appendix E ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Stration, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR46 BV-z Docket No. 50,412, License No. NPF-73 S_uEplement to Rquest for Licensinq Action to Revise the Emeroency Plan (9AQ Nqp. MF&{aB AND MFBaa9)

By conespondence dated September 28, 2016 (Accession No. ML16277A194), as supplemented by conespondence dated May 10, 2017 (Accession No. ML1714A4Ul FirstEnergy Nuclear Operating Company (FENOC) submitted a request to revise the cunent Beaver Valley Power Station Units 1 and 2 (BVPS) Emergency Plan emergency action level scheme to one based on Nuclear Energy lnstitute (NEl) 99-01, "Development of Emergency Action Levels for Non-Passive Reac'tors,' Revision 6.

After consultation with officials from the Commonwealth of Pennsylvania FENOC has determined not to pursue the Emergency Action Level (EAL) change recommended in EPFAQ 2015-013. Therefore, FENOC has revised the original license amendment request contained in the September 28, 2016 letter, to include the lnitiating Condition HGl. As a result, the Emergency Action Level (EAL) Bases Document has been revised to incorporate HGl into the security related EALs. Enclosure A provides the marked-up security-related EAL Bases Document, Enclosure B provides the resulting clean pages associated with the security F.ALs, and Enclosure C provides an EAL Comparison Matrix for HGl.

The infonnation contained in this supplement does not impact the conclusions of the significant hazards consideration determination or environmental consklerations of the original reguest provided in Enclosure A of FENOC letter dated September 28, 2016 (Accession No. ML1 6277A1 g4).

Beaver Valley Power Station, Unit Nos. 1 and Z L-17-275 Page 2 There are no regylatory commitments contained in this letter. lf there are any questions or if additional information isrequired, ptease contact Mr. Thomas A. Lentz, Manager-Fleet Licensing, at 330-761-8071.

I declare under penatty of perjury that the foregoing is true and correct. Executed on September 7 , ZO1T.

Sincerely, Richard D.

Enclosures:

A. lmergency Action Level (EAL) Bases Document - Security lnitiating Conditions Only (Mark-Up)

B. Er"tg"ncy Action Level (EAL) Bases Document - Security lnitiating Conditions Only (Retyped)

C. Beaver Valley Power Station, Unit Nos. 1 and 2, NEI gg-01, Revision 6, EAL Comparison Matrix for HG1 cc: NRC Region lAdministrator NRC Resident lnspector NRC Project Manager Director BRP/DEP Site BRPIDEP Representative

Enclosure A L-17-275 Emergency Action Level (EAL) Bases Document - Security lnitiating Conditions Only (Mark-Up)

(22 Pages Follow)

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases aT,TACHMENT 1.:

Unit 1 EAL Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety HUl.1 Subcategory: 1 - Security lnitiating Condition: Confirmed SECURITY CONDITION or threat EAL:

HUl.1 Unusual Event A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Secu rity Shift Supervisor Mode Applicability:

Ail Basis:

This lC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the Nevel of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR $ 73.71 or 10 CFR $ 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under lCs HA1"f;+-HS1 , and.HGl.

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

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Seeurity Plan, Training and Qualification Plan, Safeguards Contingency Plan .

This EAL references the Shift Security 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 10 CFR $

2.39 information.

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 Iocation, Security-sensitive information should be contained in non-public documents such as the BVPS Physical Security Plan/Contingency Plan (ref. 1).

Escalation of the emergency classification level would be via lC HA1 .

Basis Reference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HU1 4 - 102

Section 4 Emergency Preparedness PIan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:

Unit 1 EAL TeghEical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety HU 1 .2 Subcategory: 1 - Security lnitiating Condition: Confirmed SECURITY CONDITION or threat EAL:

HUl.2 Unusual Event Notification of a credible security threat directed at the site Mode Applicability:

All Basis:

This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR $ 73.71 or 10 CFR $ 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under lCs HA1,#d HS1 , and HGl.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations.

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 This EAL addresses the receipt of a credible security threat. The credlbility of the threat is assessed in accordance with the BVPS Physical Security Plan/Contingency Plan (ref. 1).

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 theBVPS Physical Security Plan/Contingency Plan (ref . 1).

Escalation of the emergency classification level would be via lC HA1 .

Basis Reference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HU1 4 - 103

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:

Unit 1 EAL Technical Bases Category: H - Hazards and Other Conditions Affecting PIant Safety HU'l .3 Subcategory: 1 - Security lnitiating Gondition: Confirmed SECURITY CONDITION or threat EAL:

HUI.3 Unusual Event A validated notification from the NRC providing information of an aircraft threat Mode Applicability:

All Basis:

This lC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR $ 73.71 or 10 CFR $ 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under lcs HA1,{nd HS1 and HGl.Timely and accurate communications between Security Shift Superuision 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 Offsite Response Organizations.

Security plans and terminology are based on the guidance provided by NEI 03-1 2, Template for the Security Plan, Training and Qualificatian Plan, Safeguards Contingency This EAL 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 the (site-specific procedure).

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

Escalation of the emergency classification level would be via lC HA1 .

Basis Reference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HU1 4 - 104

Section 4 Emergency Preparedness PIan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:

No Changes - lnformation Only Unit 1 EAL fgchnical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety HAl .1 Subcategory: 1 - Security lnitiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL H41.1 Alert A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor Mode Applicability:

Ail Basis:

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

Timely and accurate communications between the Security Shift Supervisor 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.

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.9., evacuation, dispersa! or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations (OROs), allowing them to be better prepared should it be necessary to consider further actions.

This lC 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.

This EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA.

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 Iocation. Security-sensitive information should be contained in non-public documents such as the BVPS Physical Security Plan/Contingency PIan (ref . 1).

4 - 105

Section 4 Emergency Preparedness Plan EMEHGENCY AGTION LEVEL Bases ATTACHMENT 1:

No Changes - Information Only Unit 1 EAL Technical Bases HAl .1 Escalation of the emergency classification level would be via lC HS1.

Basis Reference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HAI 4 - 106

Section 4 Emergency Preparedness PIan EMERGENCY ACTION LEVEL Bases No Changes - lnformation Only ATTACHFI,ENT 1:

Unit 1 EAL Technical BAs.qs Category: H - Hazards and Other Conditions Affecting Plant Safety HAl .2 Subcategory: 1 - Security lnitiating Condition: HOSTILE AGTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL HA1.2 Alert A validated notification from NRC of an aircraft attack threat within 30 min. of the site Mode Applicability:

Alt Basis:

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

Timely and accurate communications between the Security Shift Supervisor or 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 03-1 2, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan.

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.9., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Flesponse Organizations (OROs), allowing them to be better prepared should it be necessary to consider further actions.

This lC 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.

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

The NRC Headquafters 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.

4-107

Section 4 Emergency Preparedness PIan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:

No Changes - lnformation Only Unit 1 EAL Technical Bases HAl .2 ln some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). lt is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. ln this case, the appropriate federal agency is intended to be NORAD, FBl, FAA or NRC. The emergency declaration, including one based on other lCs/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 BVPS Physical Security Plan/Contingency Plan (ref. 1).

Escalation of the emergency classification level would be via lC HS1.

Basis Reference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Flev. 6 HA1 4 - 108

Section 4 Emergency Preparedness PIan EMERGENGY ACTION LEVEL Bases ATTACHMENT 1:

Unit 1 EAL Ieql$ical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety HSl .1 Subcategory: 1 - Security lnitiating Condition: HOSTILE ACTION within the PROTECTED AHEA EAL:

HSl.1 Site Area Emergency A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the Security Shift Supervisor Mode Applicability:

Ail Basis:

This lC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA.

This event will require rapid response and assistance due to the possibility for damage to plant equipment.

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

Security plans and terminology are based on the guidance provided by NEI 03-1 2, Template for the Security Plan, Training and Qualificatian Plan, Safeguards Cantingency Plan .

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.9., evacuation, dispersal or sheltering). The Site Area Emergency declaration will mobilize Offsite Response Organization (ORO) resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This lC does not apply to incidents that are accidental events, acts of civil disobedlence, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FOBCE. 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.

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 BVPS Physical Security Plan/Contingency PIan (ref . 1).

Escalation of the emergency classification level would be via lC F+ilHG'1_.

4 - 109

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases No Changes - lnformation only ATTAGHMENT 1:

Unit 1 EAL Technical Bases HSl .1 Basis Reference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HSI 4 - 110

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:

Unit 1 EAL Technical Bases Cateoorv: H - Hazards and Othe r Conditions Affectino Plant Safetv HGl .1 Subcateqorv: 1 - Securitv lnitiatinq Condition: HOSTILE ACTION resultinq in loss of physical control of the facility.

EAL:

HGI.1 General Emerqencv A HOSTILE ACTION is occurrino or has occurred within the PROTECTED AREA as lal*a annni{ia 6AAnritu a}ri{* ar rhanriaan\

hi r \vrfv vJr/vvrr rv vvvvr ru vr rrr l vuFrvr v r9vr r/

AND EITHEH of the followino has occurred:

1. ANY of the followinq safetv functions cannot be controlled or maintained.

o Reactivitv Control (abilitv to shut down the reactor and keep it shut down) r Core Cooling IPWRI / RPV water le o RCS heat removal OR

2. Damaqe to spent fuel has occurred or is IN/IMINENT Mode Applicabilitv:

AII Basis:

This lC addresses an event in which a HOSTILE FORCE has taken physical control of the facilitv to the extent that the plant staff can no noer ooerate eouioment necessarv to m arn tain kev safetv functions. It also addresses a HOSTILE ACTION leadinq to a loss of phvsical control that results in actual or INIIVIINENT damaoe to spent fuel due to 1)damage to a spent fuel pool coolinq svstem (e.q. Dumps. heat exc hanoers. controls. etc.) or. 2) loss of soent fuel pool inteqritv such that sufficient water level cannot be maintained as determined bv the lowerinq of the spent fuel pool Ievel (Ll-1 FC-2004/B) reading s 0.5 ft. (Level 3) or cannot be monitored for two hours or lonqer.

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

4 - 111

Section 4 Emergency Preparedness PIan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:

Unit 1 EAL Technical Bases HG1.1 ans and terminolo are b on th n for the Securitv Plan. Trainino and Oualifica Plan, Safeauards Continoencv Plan fand lndependent Spent Fuel Storage lnstallation Securi{y froaraml.

enti cedures are blic d me h EAL not incoroorate Securitv-sensitive inform ion. This includes information that mav be advantaoeous to a ootential adversarv" such the particulars concernino a soecific threat or on. Secu -sensitive information rn such as the BVPS Phvsical Se curitv/Continoencv Plan (ref 1).

Basis Reference(s):

1 B VPS Phvsical Securitv Pla ontinoencv PIan (Safeouards)

2. NEI 99-01 Flev. 6 HG1

3. NEI 99-01 Rev. 6 AS2

4. ECP No. 13-0561-000. Referen ce Documents for ECP-13-0561 - Installation of Soent Fuel Pool Level lnstrumentation for nd Desion Basis External Events 4 -'.112

Section 4 Emergency Preparedness PIan EMERGENCY ACTION LEVEL Bases ATTAGHMENT 3:

Unit 2 EAL Technical Bases Category: H - Hazards HUl.1 Subcategory: 1 - Security lnitiating Gondition: Confirmed SECURITY CONDITION or threat EAL:

HUl.1 Unusual Event A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor Mode Applicability:

Ail Basis:

This lC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 1 0 CFR $ 73.71 or 10 CFR $ 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under lCs HA1,fid HS1 and HG1.

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

Security plans and terminology are based on the guidance provided by NEI 03-1 2, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan .

This EAL references the Shift Security 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 and10 CFR $ 2.39 information.

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 BVPS Physical Security Plan/Gontingency Plan (ref. 1).

Escalation of the emergency classification level would be via lC HA1 .

Basis Reference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HU1 4-322

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHM.ENT 3:

Unit 2 EAL Technical Bases Category: H - Hazards HU1.2 Subcategory: 1 - Security lnitiating Condition: Confirmed SECURITY CONDITION or threat EAL:

HUl.2 Unusual Event Notification of a credible security threat directed at the site Mode Applicability:

Alr Basis:

This lC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR $ 73.71 or 10 CFR $ 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under lCs HA1,nd HS1 and HG1.

Timely and accurate communications between Security Shift Superuision 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 Offsite Response Organ izations.

Security plans and terminology are based on the guidance provided by NEI 03-1 2, Template far the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan.

This EAL addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with the BVPS Physical Security Plan/Contingency Plan.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 theBVPS Physical Security Plan/Contingency Plan (ref. 1).

Escalation of the emergency classification level would be via lC HA1.

Basis Reference(s):

1 . BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HU1 4-323

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 3:

Unit 2 EAL Technical Bases Category: H - Hazards HUl.3 Subcategory: 1 - Security lnitiating Condition: Confirmed SECURITY CONDITION or threal EAL:

HUl.3 Unusual Event A validated notification from the NRC providing information of an aircraft threat Mode Applicability:

Ail Basis:

This lC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR $ 73.71 or 10 CFR $ 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under lCs HA1-fid HS1 and HG1.

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

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.

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

Emergency plans and implementing procedures are public documents;therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the BVPS Physical Security Plan/Contingency Plan (ref. 1).

Escalation of the emergency classification level would be via lC HA1.

Basis Reference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HU1 4-324

Section 4 Emergency Preparedness PIan EMERGENCY ACTION LEVEL Bases ATTACHMENT 3:

No Changes - lnformation Only Unit 2 EAL Technica! Bases Gategory: H - Hazards HAl .1 Subcategory: 1 - Security lnitiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL HA1.I Alert A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor Mode Applicability:

Ail Basis:

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

Timely and accurate communications between the Security Shift Supervisor and the Control Floom 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.

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.9., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations (OROs), allowing them to be better prepared should it be necessary to consider fu rther actions.

This lC does not apply to incidents that are accidental events, acts of civil disobedience, or othenruise 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.

This EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA.

4-325

Seetion 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases AJTACHMENT 3:

Unit 2 EAL Technical Bases No Changes - lnformation Only HAl .1 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 BVPS Physical Security Plan/Contingency Plan (ref . 1).

Escalation of the emergency classification level would be via HSl.

Basis Reference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HA1 4-326

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases No Changes - tnformation only '

ATTACHMENT 3:

Unit 2 EAL Technical Bases Category: H - Hazards HAl .2 Subcategory: 1 - Security lnitiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL H41.2 Alert A validated notification from NRC of an aircraft attack threat within 30 min. of the site Mode Applicability:

Ail Basis:

This lC addresses the occurrence of a HOSTILE ACTION within the OWNEH CONTROLLED AREA 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 potentia! aircraft impact.

Timely and accurate communications between the Security Shift Supervisor 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.

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.9., evacuation, dispersal or sheltering). The Alert declaration wil! also heighten the awareness of Offsite Response Organizations (OROs), allowing them to be better prepared should it be necessary to consider further actions.

This lC 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 S 73.71 or 10 CFR S 50.72.

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

4-327

Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 3:

Unit 2 EAL Tp.ghniqal,Bases No Changes - !nformation Only HAl .2 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.

ln some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). lt is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. ln this case, the appropriate federal agency is intended to be NORAD, FBl, FAA or NRC. The emergency declaration, including one based on other lCs/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 BVPS Physical Security Plan/Contingency Plan (ref. 1).

Escalation of the emergency classification level would be via HS1 Basis Heference(s):

1. BVPS Physical Security Plan/Contingency Plan (Safeguards)

2. NEI 99-01 Rev. 6 HA1 4-328

Section 4 Emergency Preparedness PIan EMERGENCY ACTION LEVEL Bases ATTACHMENT 3:

Unit.2 EAL Technical Basgs Category: H - Hazards HSl .1 Subcategory: 1 - Security lnitiating Condition: HOSTILE ACTION within the PROTECTED AREA EAL:

HSl.1 Site Area Emergency A HOSTILE ACTION is occurring or has occurred within the PHOTECTED AREA as reported by the Security Shift Supervisor Mode Applicability: