L-17-275, 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) | |
Text
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:
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 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 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 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.
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 Ievel would be via lC F++HG1.
4-329
Section 4 Emergency Preparedness Plan E]itrERGEHCY ACTION LEVEL BASES ATTACHMENT 3:
Unit 2 EAL Technical Bases No Changes - lnformation Only HSl .1 Basis Reference(s):
- 1. BVPS Physical Security Plan/Contingency Plan (Safeguards)
- 2. NEI 99-01 Rev. 6 HS1 4-330
Section 4 Emergency Preparedness Plan EMERGEHCY ACTION LEVEL BAses ATTACHMENT 3:
Unit 2 EAL Technical Bases Cateqorv: H - Hazards HGl.1 Subcateqorv: 1 - Security lnitiatinq Gondition: HOSTILE ACTION Itino in loss of ohvsical control of the facilitv.
EAL HG1.1 General Emerqencv A HOSTILE ACTION is occurrino or has occurred within the PROTECTED AREA as reported bv the Securitv Shift Supervisor AND EITHER of the followins has occured:
- 1. ANY of the followino safetv functions cannot be controlled or maintained.
. Reactivitv control (abilitv to shut down the reactor and keep it shut down) r Core coolinq IPWRI /RPV water le
- 2. Damaqe to the spent fuel has occurred or is IIUhIINENT Mode Applicabilitv:
All Basis:
This lC addresses an event in which a HOSTILE F o R C Eh as take n nhvs cal contro o f t h e facilitv to the extent that the plant staff can]to Ionqer operate equipment necessary to maintain kev safetv functions. lt also addresses a HOSTILE ACTION leadinq to a loss of phvsical control that results in actual or lh/Jt/INENT damaoe to spent fuel due to 1) damaoe to a spent fuel pool coolinq svstem (e.q., pumps, heat exchanqers, controls. etc.) or, 2) loss of spent fuel pool inteqritv such that sufficient water level can not be maintained as determined by the Iowerinq of the spent fuel pool level (2FNC-Ll101A/B) reading s 0.5 ft. (Level 3) or cannot be monitored for two hours or lonoer.
Timely and accurate communications between Securitv Shift Supervision and the Control Room is essential for proper class ification of a securitv-related event 4-331
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases AI-TACHMENT 3:
Unit 2 EAL Technical Bases HGl.1 Securitv olans and terminoloov are based on e ouidance provided bv NEI 03-12. Template for the Securitv Plan. Trainino and Plan. Safeauards Continaencv Plan fand lndependent Spent Fuel Staraqe Installation Securitv Proaraml Emeroencv plans and imolementino orocedu are public documents: therefore. EALs should not incoroorate Securitv-sensitive informa ion. This includes information that mav be advantaoeous to a potential adversary, such as the particulars concerninq a specific threat or threat location. Securitv-sensitive information should be contained in non-public documents such as the BVPS Phvsical ritv/Continoencv Plan (ref. 1).
Basis Reference(s):
- 1. BVPS Phvsical Security Plan/Continqency Plan (Safeguards)
- 2. NEI 99-01 Rev. 6 HG1
- 3. NEI 99-01 Rev. 6 AS2
- 4. ECP No. 13-0561-000. Reference Documents for ECP-13-0561 - lnstallation of Soent Fuel Pool Level Instrumentation for B e nd Desion Basis External Events 4-332
Enclosure B L-17-275 Emergency Action Level (EAL) Bases Document - Security Initiating Conditions Only (Retyped)
(22 Pages Follow)
Section 4 Emergency Preparedness PIan EMERGENCY ACTION LEVEL Bases ATTACHMENT 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:
HUI.I Unusual Event A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor Mode Applicability:
AII 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 , 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 lnitiate 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 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 conf irmation 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 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 HA1.
Basis Heference(s):
- 1. BVPS Physical Security Plan/Contingency Plan (Safeguards)
- 2. NEI 99-01 Rev. 6 HU1 4-102
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:
Unit 1 EAL Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety HU1.2 Subcategory: 1 - Security lnitiating Condition: Confirmed SECURITY CONDITION or threat EAL:
HU1.2 Unusual Event Notification of a credible security threat directed at the site 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 CFFI $ 73.71 or 10 CFR $ 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under lCs HA1 , 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 credibility 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 Heterence(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 Plant Safety HUl.3 Subcategory: 1 - Security lnitiating Gondition: Confirmed SECURITY CONDITION or threat EAL:
HU1.3 Unusual Event A validated notification from the NRC providing information of an aircraft threat Mode Applicability:
AII 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 , 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 far 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 Headquafters 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 Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:
No Changes - lnformation Only Unit 1 EAL TechniqAl Bases Category: H - Hazards and Other Conditions Affecting Plant Safety HAI .1 Subcategory: 1 - Security lnitiating Condition: HOSTILE ACTION within the OWNER CONTHOLLED 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 Superuisor 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 Floom 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 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 location. Security-sensitive information should be contalned in non-public documents such as the BVPS Physical Security PlanlContingency Plan (ref . 1).
4 - 105
Section 4 Emergency Preparedness Plan EIIIIERGEHCY ACTIOH LEVEL Bases ATTACHMENT 1; No Changes - lnformation Only Unit 1 EAL Technical Bases HAl .1 Escalation of the emergency classification level would be via lC HS1.
Basis Heference(s):
- 1. BVPS Physical Security Plan/Contingency Plan (Safeguands)
- 2. NEI 99-01 Rev. 6 HA1 4 - 106
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:
No Changes - Information Only Unit 1 FAL Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety HAl .2 Subcategory: 1 - Security lnitiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL H41.2 AIert A validated notification from NRC of an aircraft attack threat within 30 min. of the site Mode Applicability:
Ail Basis:
This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attackthreat. 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 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 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.
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 - 107
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:
No Changes - Information 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 AHEA 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, 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 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 Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:
Unit 1 EAL Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety HS1 .1 Subcategory: 1 - Security lnitiating Condition: HOSTILE ACTION within the PROTECTED AREA EAL:
HSI.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 Superuisor 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 onslte 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 clvil 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.
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 HG1.
4 - 109
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:
Unit 1 EAL Technical Bases No Changes - lnformation Only HSl .1 Basis Referenee(s):
- 1. tsVPS Physical Security Plan/Contingency Plan (Safeguards)
- 2. NEI 99-01 Rev. 6 HS1 4 - 110
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTAQHMENT 1:
Unit 1 EAL Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety HGI .1 Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION resulting in loss of physical control of the facility.
EAL:
HGl.1 General Emergency A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the Security Shift Supervisor AND EITHER of the following has occurred:
- 1. ANY of the following safety functions cannot be controlled or maintained.
. Reactivity Control (ability to shut down the reactor and keep it shut down)
. Core Cooling
- 2. Damage to spent fuel has occurred or is IMMINENT Mode Applicability:
AII Basis:
This lC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions. lt also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to 1)damage to a spent fuel pool cooling system (e.g. pumps, heat exchangers, controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot be maintained as determined by the Iowering of the spent fuel pool level (Ll-1FC-2004/B) reading s 0.5 ft. (Level 3) or cannot be monitored for two hours or longer.
Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.
4 - 111
Section 4 Emergency Preparedness PIan EMERGENCY ACTION LEVEL Bases ATTACHMENT 1:
Unit 1 EAL Technical Bases HGl .1 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 [and lndependent Spent Fuel Storage lnstallation Security Programl.
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/Contingency Plan (ref 1).
Basis Reference(s):
- 1. BVPS Physical Security Plan/Contingency PIan (Safeguards)
- 2. NEI 99-01 Rev. 6 HG1
- 3. NEI 99-01 Rev. 6 AS2
- 4. ECP No. 13-0561-000, Reference Documents for ECP-13-0561 - lnstallation of Spent Fuel Pool Level lnstrumentation for Beyond Design Basis External Events 4-112
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHhIIENT 3:
Unit 2 EAL Technical Bases Category: H - Hazards HUl.1 Subcategory: 1 - Security lnitiating Condition: Confirmed SECURITY CONDITION or threat EAL:
HUl.l 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 Ievel 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 S 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under lCs HA1 , 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 Response Organizatio ns.
Security plans and terminology are based on the guidance provided by NEI 03-1 2, Template for the Eecurity 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/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 4-322
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 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:
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 , 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 Response 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 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 Ptan/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 threat EAL:
HUl.3 Unusual Event A validated notification from the NRC providing information of an aircraft threat Mode Applicability:
AII 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 , 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 PIan (Safeguards)
- 2. NEI 99-01 Rev. 6 HU1 4-324
Section 4 Emergency Preparedness PIan EMERGENCY ACTION LEVEL Bases ATTACHMENT 3:
Unit 2 EAL Jechnical Bases No Changes - Information Only Category: H - Hazards HA1 ,1 Subcategory: 1 - Security lnitiating Condition: HOSTILE ACTION within the OWNEH CONTROLLED AREA or airborne attack threat within 30 minutes EAL HAl.l Alert A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor Mode Applicability:
AII 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 03-1 2, Template for the Security Plan, Training and Qualification Plan, Safeguards Gontingency 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 $ 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
Section 4 Emergency Preparedness PIan EMERGENGY ACTION LEVEL Bases ATTAC#MENT 3:
Unit 2 EAL Technical Bas.eq 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 HS1.
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 ATTACHMENT 3:
No Changes - lnformation Only Unit 2 EAL Technical Bases Category: H - Hazards HAl .2 Subcategory: 1 - Security lnitiating Condition: HOSTILE ACTION WithiN thE OWNEH 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:
AII 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, 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 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 smal! 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.
4-327
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases AITACHMENT 3, Unit 2 EAL Technical Baqes No Changes - Information 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 NHC.
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). It 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 Reference(s):
- 1. BVPS Physical Security Plan/Contingency Plan (Safeguards)
- 2. NEI 99-01 Rev. 6 HA1 4-328
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL BaseS ATTACHMENT 3:
Unit 2 EAL Technical Bases Category: H - Hazards HSl .1 Subcategory: 1 - Security lnitiating Gondition: HOSTILE ACTION within the PROTECTED AREA 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:
All 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 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 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 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.
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 HG1.
4-329
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 3:
Unit 2 EAL Technical Bases No Changes - lnformation Only HSl .1 Basis Reference(s):
- 1. BVPS Physical Security Plan/Contingency Plan (Safeguards)
- 2. NEI 99-01 Rev. 6 HS1 4-330
Section 4 Emergency Preparedness Plan EMERGENCY ACTION LEVEL Bases ATTACHMENT 3:
Unit 2 EAL Technical Bases Category: H - Hazards HGl.l Subcategory: 1 - Security lnitiating Condition: HOSTILE ACTION resulting in loss of physical control of the facility.
EAL:
HGl.1 General Emergency A HOSTILE ACTION is occurring or has occurred within the PHOTECTED AREA as reported by the Security Shift Supervisor .
AND EITHER of the following has occured:
- 1. ANY of the following safety functions cannot be controlled or maintained.
. Reactivity control (ability to shut down the reactor and keep it shut down)
. Core cooling
- 2. Damage to the spent fuel has occurred or is IMMINENT Mode Applicability:
AII Basis:
This lC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions. lt also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to 1) damage to a spent fuel pool cooling system (e.9., pumps, heat exchangers, controls. etc.) or, 2) loss of spent fuel pool integrity such that sufficient water Ievel can not be maintained as determined by the lowering of the spent fuel pool level (2FNC-LI101A/B) reading s 0.5 ft. (Level 3) or cannot be monitored for two hours or longer.
Timely and accurate communications between Security Shift Supervision and the Control Floom is essential for proper classification of a security-related event.
4-331
Section 4 Emergency Preparedness Plan EMERGENCY AGTION LEVEL Bases ATTACHMENT 3:
Unit 2 EAL Technical Bases HG1.1 Security plans and terminology are based on the guidance provided by NE! 03-1 2, Template for the Security Plan, Training and Qualification Plan, Safeguards Cantingency Plan [and lndependent Spent Fuel Storage lnstallation Security Programl.
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/Contingency Plan (ref. 1).
Basis Reference(s):
- 1. BVPS Physical Security Plan/Contingency PIan (Safeguards)
- 2. NEI 99-01 Rev. 6 HG1
- 3. NEI 99-01 Rev. 6 AS2
- 4. ECP No. 13-0561-000, Reference Documents for ECP-13-0561 - lnstallation of Spent Fuel Pool Level lnstrumentation for Beyond Design Basis External Events 4-332
Enclosure C L-17-275 Beaver Valley Power Station, Unit Nos. 1 and 2, NEI 99-01 , Revision 6, EAL Comparison lvlatrix for HG1 (7 Pages Follow)
Beaver Valley Power Station Unit 1&2 NEI 99-01 Revision 6 HG1 EAL Comparison Matrix Page 1 of 7
BVPS Unit No. 1 EAL Comparison Matrix NEI IC# NEI lC Wordinq BVPS !C# BVPS lC Wordinq Difference/Deviation J ustification HG1 HG1 HOSTILE ACTION resulting Deviations:
HOSTILE ACTION resulting None in loss of physical control of in loss of physical control of the facility. the facility.
Differences:
MODE: All MODE: All None NEI Ex NEI Example EAL Wording BVPS BVPS EAL Wording Diff ere nce/Deviation J u stif ication EAL# Example EAL#
A Hostile Action is occurring 1
- a. A HOSTILE HG1.1 or has occurred within the Deviations:
None ACTION is occurring or has PROTECTED AREA as occurred within the reported by the Security Differences:
PROTECTED AREA as reported by the (site-specific Shift Supervisor . The security shift supervision is defined as the security shift supervision). Security Shift Supervisor.
AND EITHER of the AND following has occurred: o Added the following clarification to Reactivity
- b. EITHER of the
- 1. ANY of the following Control "ability to shut down the reactor and keep following has occurred: it shut down)"
safety tunctions cannot
- 1. ANY of the following be controlled or I BVPS is a PWR and thus RPV water level does safety functions maintained cannot be controlled . Reactivity not apply.
or maintained. control (ability to I Reactivity control shut down the reactor and
. Core cooling keep it shut lPr4/FllRPV down) water level . Core cooling IBWRI t RGS heat
. RCS heat removal removal OR OR
- 2. Damage to spent fuel has occurred or is
- 2. Damage to spent fuel has IMMINENT.
occurred or is IMMINENT.
Page 2 ol 7
BVPS Unit No. 1 EAL Comparison Matrix NEI Example Basis Wording BVPS Basis Wording D iffere nce/D eviation J u stif ication This lC addresses an event in which a This lC addresses an event in which a HOSTILE Deviations:
HOSTILE FORCE has taken physical control FORCE has taken physical control of the facility to None of the facility to the extent that the plant staff the extent that the plant staff can no longer operate can no longer operate equipment necessary equipment necessary to maintain key safety Difference:
to maintain key safety functions. !t also functions. lt also addresses a HOSTILE ACTION addresses a HOSTILE ACTION leading to a leading to a loss of physical control that results in a Added the following clarification to loss of physical control that results in actual or actual or IMMINENT damage to spent fuel due to 1) basis section to address irnminent IMMINENT damage to spent fuel due to 1) damage to a spent fuel pool cooling system (e.9. damage to spent fuel pool "as damage to a spent fuel pool cooling system pumps, heat exchangers, controls, etc.) or, 2) loss determined by the lowering of the (e.9. pumps, heat exchangers, controls, etc.) of spent fuel pool integrity such that sufticient water spent fuel pool level (Ll-1FC-or, 2) loss of spent fuel pool integrity such that level cannot be maintained as determined by the 200A/B) reading s 0.5 ft. (Level 3) sufficient water level cannot be maintained. lowering of the spent fuel pool level (LI-1FC-or cannot be monitored for two 2004/8) reading < 0.5 ft. (Level 3) or cannot be hours or longer."
Timely and accurate communications monitored for two hours or longer.
between Security Shift Supervision and the Control Room is essential for proper Timely and accurate communications between a Basis section was revised to classification of a security-related event. Security Shift Supervision and the Control Room is reference "BVPS Physical essential for proper classification of a security- Security/Contingency Plan (ref 1 )"
Security plans and terminology are based on related event. as it is the site-specific Security the guidance provided by NEI 03-12, Plan.
Template for the Security Plan, Training and Security plans and terminology are based on the Qualification Plan, Safeguards Conti nge ncy guidance provided by NEI 03-12, Template for the l Added the site-specific list of HG1 Plan [and lndependent Spent Fuel Storage Security Plan, Training and Qualification Plan, basis references.
I nstal lation Secu rity P rograml. Safeguards Contingency Plan [and lndependent Spent Fuel Storage lnstallation Security Programl.
Emergency plans and implementing procedures are public documents; therefore, Emergency plans and implementing procedures are EALs should not incorporate Security- public documents; therefore, EALs should not sensitive information. This includes incorporate Security-sensitive information, This information that may be advantageous to a includes information that may be advantageous to a potential adversary, such as the particulars potential adversary, such as the particulars concerning a specific threat or threat location. concerning a specific threat or threat location.
Security-sensitive information should be Security-sensitive information should be contained contained in non-public documents such as in non-public documents such as the BVPS Physical the Security Plan. Security/Contingency Plan (ref 1 ).
Page 3 of 7
BVPS Unit No. 1 EAL Gomparison Matrix Basis Reference(s):
- 1. BVPS Physical Security PIan/Contingency Plan (Safeguards)
- 2. NEI gg-01 Rev. 6 HG1
- 3. NEI 99-01 Hev. 6 AS2
- 4. ECP No. 13-0561-CI00, Reference Documents for EGP-13-0561 lnstallation of Spent Fuel Pool Level lnstrumentation for Beyond Design Basis External Events Page 4 ol 7
BVPS Unit No. 2 EAL Comparison Matrix NEI IC# NEI lC Wordinq BVPS IC# BVPS lC Wordino D ifference/Deviation J ustif ication HG1 HG1 Deviations:
HOSTILE ACTION resulting HOSTILE ACTION None in loss of physical control of resulting in loss of physical the facility. contro! of the facility.
Differences:
MODE: All MODE: All None NEI Ex NEI Example EAL Wording BVPS BVPS EAL Wording D ifference/Deviation J ustif ication EAL# Example EAL#
A Hostile Action is Deviations:
1
- a. A HOSTILE ACTION HG1.1 occurring or has occurred None is occurring or has occurred within the PROTECTED within the PROTECTED AREA as reported by the Differences:
AREA as reported by the The security shift supervision is defined as the Security Security Shift Supervisor (site-specific security shift Shift Supervisor.
supervision). AND EITHER of the AND following has occurred: Added the following clarification to Reactivity Control "ability to shut down the reactor and keep it shut down)"
- b. EITHER of the
- 1. AHY of the following following has occurred: safety functions BVPS is a PWR and thus FIPV water level does not
- 1. ANY of the following cannot be controlled apply.
safety functions cannot or maintained be controlled or I Reactivity maintained. control (ability
. Reactivity control to shut down the reactor
. Core cooling and keep it IP[/YHI/RPV water shut down) level [Bl#F] . Core cooling
. RCS heat . RCS heat removal removal OR OR
- 2. Damage to spent fuel has 2. Damage to spent fuel occurred or is IMMINENT has occurred or is IMMINENT.
Page 5 ot 7
BVPS Unit No. 2 EAL Comparison Matrix NEI Example Basis Wording BVPS Basis Wording Difference/Deviation Justif ication This lC addresses an event in which a This lC addresses an event in which a HOSTILE Deviations:
HOSTILE FORCE has taken physical FORCE has taken physical control of the facility to None control of the facility to the extent that the the extent that the plant staff can no longer operate plant staff can no longer operate equipment equipment necessary to maintain key safety Difference:
necessary to maintain key safety functions. functions. lt also addresses a HOSTILE ACTION It also addresses a HOSTILE ACTION leading to a loss of physical control that results in a Added the following clarification to leading to a loss of physical control that actual or IMMINENT damage to spent fuel due to 1) basis section to address imminent results in actual or IMMINENT damage to damage to a spent fuel pool cooling system (e.9., damage to spent fuel pool "as spent fuel due to 1) damage to a spent fuel pumps, heat exchangers, controls, etc.) or, 2) loss of determined by the lowering of the pool cooling system (e.9. pumps, heat spent fuel pool integrity such that sufficient water spent fuel pool level (2FNC-11101 exchangers, controls, etc.) or,2l loss of level can not be maintained as delermined by the tuB) reading s 0.5 ft. (Level 3) or spent fuel pool integrity such that sufficient lowering of the spent fue! pool level (2FNC-LI101A/B) cannot be monitored for two hours or water level cannot be maintained. reading < 0.5 ft. (Level 3) or cannot be monitored for two hours or longer. longer."
Timely and accurate communications between Security Shift Supervision and the Timely and accurate communications between I Basis section was revised to Control Room is essential for proper Security Shift Supervision and the Control Room is reference "BVPS Physical classification of a security-related event. essential for proper classification of a security- Security/Contingency Plan (ref 1)" as related event. it is the site-specific Security Plan.
Security plans and terminology are based on the guidance provided by NEI 03-12, Security plans and terminology are based on the I Added the site-specific list of HG1 Template for the Security Plan, Training guidance provided by NEI 03-12, Template for the basis references.
and Qualification Plan, Safeguards Security Plan, Training and Qualification Plan, Contingency Plan [and lndependent Spent Safeguards Contingency Plan [and lndependent Fuel Storage lnstallation Security Programl, $penf Fuel Storage lnstallation Security Programl.
Emergency plans and implementing Emergency plans and implementing procedures are public documents; procedures are public documents; therefore, therefore, EALs should not incorporate EALs should not incorporate Security-sensitive Security-sensitive information. This includes information. This includes information that may be information that may be advantageous to a advantageous to a potential adversary, such as the potential adversary, such as the particulars particulars concerning a specific threat or threat concerning a specific threat or threat location. Security-sensitive information should be location. Security-sensitive information contained in non-public documents such as the should be contained in non-public BVPS Physical Security/Contingency Plan (ref. 1).
documents such as the Security Plan.
Page 6 of 7
BVPS Unit No. 2 EAL Comparison Matrix Basis Reference{s):
- 1. BVPS Physical Security Plan/Gontingency Plan (Safeguards)
- 2. NEI 99-01 Rev. 6 HG1 S. NEI gg-01 Rev. 6 ASZ
- 4. EGP No. 13-0561-000, Reference Documents for ECP-13-0561 - lnstallation of Spent Fuel Pool Level lnstrumentation for Beyond Design Basis External Events Page 7 of 7