ML18317A059
| ML18317A059 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/08/2018 |
| From: | Entergy Nuclear Operations |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| 2.18.063 | |
| Download: ML18317A059 (16) | |
Text
Attachment 1 Letter Number 2.18.063 Response to Request for Additional Information - License Amendment Request to Revise the Pilgrim Nuclear Power Station Emergency Plan and Emergency Action Level Scheme to Address the Permanently Defueled Condition I
Letter Number 2.18.063 Page 1 of 3 A U.S. Nuclear Regulatory Commission (NRC) request for additional information (RAI) regarding a license amendment request to revise the Pilgrim Nuclear Power Station (PNPS)
Site Emergency Plan (SEP) was received by Entergy Nuclear Operations, Inc. (ENO) via electronic mail (email) dated October 12, 2018. ENO responses to the RAI request are provided below.
NRCREQUEST By application dated August 1, 2018, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 18218184), Entergy Nuclear Operations,' Inc., submitted changes to the site emergency plan (SEP) and emergency action level (EAL) scheme for the Pilgrim Nuclear Power Station (PNPS) for Commission review and prior approval pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR). The proposed changes would revise the SEP and EAL scheme to reflect a permanently defueled condition.
The NRC staff has reviewed the licensee's submittal and determined that additional information is required to enable the NRG staff to make an independent assessment regarding its technical review.
NRC RAI-PNPS-1 Evaluation Criterion E.4 in Attachment 1 to NSIRIDPR-ISG-02 provides guidance on the contents of emergency messages based on the permanently shutdown .and defueled condition of the facility, and includes that licensee will communicate a "[m.] request for any needed onsite support by offsite organizations." However, the content of messages, as described in Section 5. 1.2, "Commonwealth and Local Government Notification," to Enclosure 1 of Entergy's August 1, 2018 letter, does not appear to address this criterion.
Please describe the method being used by the licensee for conveying this information to State and local organizations, or basis for not addressing this criterion in emergency message content.
ENO Response to RAI-PNPS-1 The commercial telephone network and the emergency messages described in Section 5.1.2 of the Permanently Defueled Emergency Plan (PDEP), "Commonwealth and Local Government Notification," are used to request any needed onsite support from offsite organizations. The list of information contained in the emergency messages, provided in Section 5.1.2 of the proposed PDEP, has been revised to specifically include a request for any needed support from offsite organizations. The revisions to the proposed PDEP are included in Attachment 2 of this response.
NRC RAI-PNPS-2 Evaluation Criteria N.1.a and bin Attachment 1 to NSIRIDPR-ISG-02 state, in part:
- a. An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency preparedness plans and organizations.
Exercises shall be conducted as set forth in 10 CFR 50, as exempted, and in
Letter Number 2.18.063 Page 2 of 3 accordance with applicable portion to Section JV. G (Challenging Drills and Exercises) to NSIRIDPR-/SG-01, "Emergency Planning for Nuclear Power Plants."
- b. The scenario should be varied from year to year such that all major elements of the plans and preparedness organizations are tested.
Please explain why there is no provision in Section 14.0, "Exercises and Drills," to Enclosure 1, page 25, of Entergy's August 1, 2018 letter, for exercises and drills being conducted as set forth in 10 CFR 50, and in accordance with applicable portion to Section JV.G to NSIRIDPR-
/SG-01, for the scenario to be varied from year to year.
ENO Response to RAI-PNPS-2 PNPS conducts exercises and drills in accordance with 10 CFR Part 50 and will continue to conduct exercises and drills as set forth in 10 CFR Part 50, as exempted, including the provision that exercise scenarios be varied from year to year, to the extent practicable, such that all major elements of the plans and preparedness organizations are tested. Section 14.0 of the PDEP, "Exercises and Drills," is revised to clarify that exercise and drills will be conducted as set forth in 10 CFR Part 50, and in accordance with applicable portion to Section IV.G to NSIR/DPR-ISG-01, for the scenario to be varied from year to year. The revisions to the proposed PDEP I
are included in Attachment 2 of this response.
NRC RAI-PNPS-3 Nuclear Energy Institute (NE/) 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012 (ADAMS Accession Number ML12326A805) was endorsed by the NRG by letter dated March 28, 2013 (ADAMS Accession Number ML12346A463).
In "Recognition Category PD EAL Bases," to Attachment 1, page 21, PD-AA 1, EAL 3 states:
"Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid COE at or beyond the site boundary." However, it does not include the following NE/ language - "for one hour of exposure," nor is any justification provided for the difference.
I Please explain why the reference NE/ language is not included.
ENO Response to RAI-PNPS-3 The referenced NEI language was unintentionally omitted and is added to the Permanently Defueled Emergency Action Level Technical Bases Document (Enclosure 2 of the LAR).
These revisions are included in Attachment 3 of this response. Conforming changes are also made to the Permanently Defueled Emergency Action Level Scheme Matrix (Enclosure 3 of the LAR) and the Comparison Matrix for Permanently Defueled EALs Based on NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (Attachment 2 of the LAR) and are included in Attachments 4 and 5 of this response, respectively.
Letter Number 2.18.063 Page 3 of 3 NRC RAI-PNPS-4 In "Recognition Category PD EAL Bases," to Attachment 1, page 28, PD-HU1, the following NE/ language is absent: "Escalation of the emergency classification level would be via IC PD-HA 1," nor is any justification provided for the difference.
Please explain why the reference NE/ language is not included.
ENO Response to RAI-PNPS-4 The basis language provided in NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (NEI 99-01) for Permanently Defueled Emergency Action Level (PD EAL) PD-HU1 includes the statement, "Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA 1." This language is present in the PNPS Basis for PD-HU1. The statement, "Escalation of the emergency classification level would be via IC PD-HA1," appeared redundant, and was not included in the PNPS Basis. The Comparison Matrix for Permanently Defueled EALs Based on NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6, included as Attachment 2 of the LAR, included a Comparison column that stated that PNPS site-specific basis information was included.
However, omission of this statement was not specifically addressed.
To better align with NEI 99-01, the referenced NEI language is added to the Permanently Defueled Emergency Action Level Technical Bases Document (Enclosure 2 of the LAR).
These revisions are included in Attachment 3 of this response. Conforming changes are also made to Attachment 2 of the LAR and included in Attachment 5 of this response.
Attachment 2 Letter Number 2.18.063 Revised Pages of the PNPS Permanently Defueled Emergency Plan (Enclosure 1 of the LAR)
PNPS PERMANENTLY DEFUELED EMERGENCY PLAN 5.1.1 . Emergency Response Organization Activation On-site staff are informed of an emergency condition through the use of the facility public address system, office telephone, and/or wireless devices capable of receiving telephone calls and text messages. In the event that personnel required to staff ERO positions are not on-site at the time an emergency is declared, they may be contacted by commercial telephone including land lines and/or wirel~ss devices capable of receiving telephone calls and text messages. Mobilization of the ERO will be conducted under the direction of the Emergency Director, according to personnel assignments and telephone numbers maintained in various telephone directories.
5.1.2 Commonwealth and Local Government Notification Notification to the responsible Commonwealth and Town of Plymouth authorities is required within 60 minutes of the emergency classification.
The commercial telephone network serves as the primary means to provide emergency notification to Commonwealth and Town of Plymouth agencies. It is used to provide initial and updated notifications and for general information flow between these agencies.
PNPS, in coordination with the Commonwealth of Massachusetts, have established the contents of the initial emergency messages to be sent from PNPS in the event an emergency is declared. These messages contain the following information if it is known and appropriate:
- Notification Type, i.e. "This is a Drill" or "This is an Actual Event."
- Identity of caller and receiver of call
- The date and time of classification and notification
- Emergency classification
- EAL identification and whether a release is in progress
- Wind direction and speed
- Response actions underway
- Request for any needed onsite support by offsite organizations
- Prognosis for.worsening or termination of event based on facility' information In the event the commercial telephone system is unavailable, wireless communications can be used to make emergency notifications. Ir:,
addition, electronic means may be used to transmit the notification message.
13 Revision TBD
PNPS PERMANENTLY DEFUELED EMERGENCY PLAN
- Documenting all proceedings of the event and reviewing the effectiveness of the emergency organization in reducing public hazard and plant damage When plant conditions allow a transition from the emergency phase to the recovery phase, the Emergency Director conducts a plant emergency management meeting to discuss the recoverY organization. The actions taken by this organization concerning termination of the emergency proceeds in accordance with a recovery plan developed specifically for the accident conditions.
14.0 EXERCISES AND DRILLS Periodic exercises are conducted to evaluate major portions of emergency response capabilities. Periodic drills are conducted to develop and maintain key emergency response skills. Deficiencies as a result of exercises or drills are identified and corrected.
Exercises and drills shall be conducted as set forth in 10 CFR Part 50, as exempted, and in accordance with applicable portion to Section IV.G to NSIR/DPR-ISG-01, "Emergency Planning for Nuclear Power Plants."
14.1 Exercises Biennial exercises shall be conducted to test the timing and content of implementing procedures and methods and to ensure that emergency personnel are familiar with their duties. Offsite organizations are offered the opportunity to participate to the extent assistance would be expected during an emergency declaration. However, participation by offsite organizations is not required, nor are offsite response organizations evaluated.
14.2 Drills Communication checks with offsite agencies, fire drills, medical drills, radiological monitoring drills and health physics drills are performed as indicated in the following sections.
14.2.1 Medical Drills Medical emergency drills, involving an individual who is simulated to be injured and contaminated, are conducted at least annually. The local ambulance service and Beth Israel Deaconess Hospital - Plymouth are invited to participate in an annual exercise and/or scheduled drill(s) to demonstrate and practice the receipt and treatment of contaminated patients. Involvement by hospital and medical transport services may be included as part of any drill or exercise.
14.2.2 Accountability Drills An accountability drill shall be conducted annually. This drill shall include identifying the locations of all personnel onsite. This drill can be performed as part of any drill or exercise.
25 Revision TBD
PNPS PERMANENTLY DEFUELED EMERGENCY PLAN
- Objective(s)
- Date, time period, place and participating organizations
- Simulation lists
- Timeline of real and simulated events
- A narrative summary
- List of controllers and participants The scenario varies year to year. Within an eight-year period, the scenario content is varied to test all the major elements of the Emergency Preparedness Program.
The final scenario shall be approved by a designated member of senior facility management. Drill/Exercise confidentiality must always be maintained.
14.4 Critique/Evaluation Critiques will evaluate the participant's performance during a drill or exercise.
The ability of participants to self-evaluate weaknesses and identify areas of improvement is the key to successful exercise/drill conduct.
Exercise and drill performance objectives are evaluated against measurable demonstration criteria. As soon as possible following the conclusion of each drill/exercise, a critique, including participants, controllers, and evaluators, is conducted to evaluate the ability of the participants to meet the performance objectives. Deficiencies are identified and entered into the corrective action system.
A written report is prepared including the evaluation of designated objectives.
The report evaluates and documents the participants' response to the emergency situation. The report will also contain reference to corrective action and recommendations resulting from the drill/exercise.
15.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING Radiological emergency response training is provided to those who may be called on to assist in an emergency. PNPS Management is responsible to ensure all members of the Emergency Response Organization receive the required initial training and continuing training.
15.1 Emergency .Response Training The training program for ERO personnel is based on applicable requirements of Appendix E to 10 CFR Part 50 and position-specific responsibilities as defined in the PDEP. Emergency response personnel in the following categories receive initial training and annual retraining.
27 Revision TBD
Attachment 3 Letter Number 2.18.063 Revised Pages of the Permanently Defueled Emergency Action Level Technical Bases Document (Enclosure 2 of the LAR)
Attachment 1 Recognition Category PD EAL Bases
- 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid COE at or beyond the site boundary for one hour of exposure .
. 4. Field survey results indicate EITHER of the follow ing at or beyond (site-specific dose receptor point):
(-
- Closed window dose rates greater than 10 mR/h r expected to continue for 60 minutes or longer.
- Analyses of field survey samples indicate thyroid COE greater than 50 mrem for one hour of inhalation.
This IC addresses a release of gaseous or liquid radio activity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monito red releases. Releases of this magnitude represent an actual or potential substantia l degradation of the level of safety of the facility as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).
Radiological effluent EALs are also included to provi de a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of facility conditions alone. The inclusion of both facility cond ition and radiological effluent EALs more fully addresses the spectrum of possible accid ent events and conditions.
The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid COE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid COE.
Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
The radiation monitor that detects gaseous radio activity effluent release to the_
environment is the Reactor Building Ventilation Exha ust (RBVE) monitors RM-1705-32A/B on Panel C910 (ref .1 ).
Complete assumptions and inputs for these EAL thres hold values are documented from the calculation in PNPS082-CALC-001 Revision 0, PD-AAL Gaseous Effluent EAL Threshold (ref. 2).
The threshold of > 2. 75E5 is limited to a maximum value of 8E+5 cps to assure an on-scale readable value.
Pilgrim Nuclear Power Station Permanently Defueled EAL Technical Bases Rev. O Page 21
Attachment 1 Recognition Category PD EAL Bases EAL #3 addresses the threat from the impact of an aircra ft on the facility. The NRC Headquarters Operations Officer (HOO) will communica te to the licensee if the threat
- involves an aircraft. The status and size of the plane may al;so be provided by NORAD through the NRC. Validation of the threat is performed in accor dance with PNPS 5.3.14.1, "Airborne Threat" (Ref. 2.)
Escalation of the emergency classification level would be via IC PD-HA 1.
- 1. PNPS 5.3.14m "Security Incidents"
- 2. PNPS 5.3.14.1, "Airborne Threat" Pilgrim Nucle ar Power Station Permanently Defueled EAL Technical Bases Rev. O Page 28
Attachment 4 Letter Number 2.18.063 Revised Pages of the Permanently Defueled Emergency Action Level Scheme Matrix (Enclosure 3 of the LAR)
ALERT ~NUSUALgVENT PO-AA1 ~.... of gaHous or Rquld radk>ktlvfty resulting In ottslt* dOH gr*.ter than 10 mrem PO-AU1 RelNM Of gaseoos or llquld radioactivity greater than 2 Umes Offslte Dose TEDE or 50 mrem t h ~ COE. Calculation Manual (OOCM) llmHs for IO mlnutff or longer, EMERGENCY ACTION LEVEL (EALI: (1 or 2 or 3 o r 4) EMERGENCY ACTION LEVEL (EAL): 11 or 2)
= The Emergency Director should declare the Alert prompUy upon determining l ime has been exceeded, Of will likely be exceeded.
lhat the applicable = The Eme, gency Otrector should declare the event promptly upon determining that the applicable time has been exCflded, or win likely be eX"Ceeded.
If an ongoing release Is detected and the release &tart time is uiknown. assume that the If an or"90ing release is detected and the release start hme i5 unknown. asSl.ffle that the release durallon has exceeded 15 minutn. release duration has exceeded 60 m1nu:es If the effluent now past an effluent monitor is known to have stopped due lo actions to Isolate If the effluent flow past an etfluerl: monitor is known to have stopped due to actions to the release path, then the effluent mooilor reading is no lor9er valid for cla&Sification purposes isolate the release path, then the effluent monitor reading is no longer va lid for clas&ification pUl"poses.
The pre-calculated effluert monitor values presented 1n EAL 1 1 should be used for em ergency classification aaansments until the results from II dose assessment using actual meteorology 1 Reading on ANY Table A-1 effluerl: radialton mOflltor greater than 2 times the alarm setpotnt established by a cl.l"rent radioactivity discharge permit for 60 minules or longer.
are available 1 Reading oo ANY Table A-1 effluent rad1at1on monitor that is g1eater than the reading shown in col umn * ~ert" for 15 minutes or longer Table A-1 Effluent M onitor Oassification Thresholds Table A-1 Effl uent Monitor Classification Thresholds Release Point M onitor Alert UE Effluent Release Point M onitor Alert UE ~
Radiation => RM-1705-32A/B Rx Bldg Vent 2.7Se5 2X H I-HI
~ (Panel C910- units of
~
RM -1705*32A/B ~ Exhaust cps Alarm
@ Rx Bldg Ve nt (Panel C910- units of 2.7S ES 2X H l* HI cps)
~ Exhaust cps Alarm cps) 0 Rad wast e
"' 5 RM -1705-30 (Pa nel 2X HI- H1 A Radwaste RM -1705-30 (Panel 2X Hl* H I cJ Discharge Effl uent C910 - unit s of cps)
N/A Alarm Abnormal Rad Discha rge N/ A Levets / Rad C910 - units of cps) Alarm Effluent Effluent 2 Sample anal ysis for a gaseous or liquid release 1nd1cates a concentratlOfl or release rate greater lhan 2 hmes the ODCM limits for 60 m ini.lies or longer 2 Dose assessment using actual meteorology irdicates doses grealer than 10 mrem TEDE or 50 mrem thyroid COE at or beyond the &ite botmary.
- 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE al or beyond the site boundary for one
~ofexposure
- 4. Field wrvey results indicate EITHER of the following at or beyond (site-specific dose recept0t potnt)*
Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes Of longer
- Analyses of field survey samples indicate thyr01d COE greater then 50 mrem for one hour of inhalation.
PO-AA2 UNPLANNED rise In facility radiation levels that Impedes facility acces s required lo PO-AU2 UNPLANNED riH In facility rad iation levels.
maintain spent fuel Integrity.
EM ERGENCY ACTION LEVEL (EAL) : 11 or 21 EMERGENCY ACTION LEVEL {EAL): (1 or 2) 1 UNPLANNED dose rate greater than 15 mRn,r m ANY of the followmg areas requiring continuous occupancy to maintain control of radioactive matenal Of operation of systems needed to mairl:am a. UNPLANNED water level drop in the apenl fuel pool as indicated by AN Y of the follow ing spent fuel integrity. * "SPENT FUEL POOL LEVEL LO" (C903R-B2)
- Main Control Room (RIS-181~2A, PaJ"lel C911 ) * "FUEL POOL LOW LEVEL" ( C39-F1)
Plant Rad
- Central Alarm Station (CAS) (by ~ y) A ND Levels b UNPLANNED rise tn area radiation levels as indicated by the following radiation monitor:
- 2. UNPLANNED Area Radiat10n Monitor readings or survey indtcate a nse by 100 mRhv over
- Spent Fuel Pool Area (RIS-181>3F)
NORMAL LEVELS that impedes access to AHY of the following areas needed to ma1nta1n control of radioactive material or operation of systems needed to mamtain spent fuel integrity 2 ~~:tr~~n1tor read ing or survey result 1ndica!es an UNPLANNED rise of 25 mR/hr over lwx Bay 3' elevation Reactor Buil ding 11 T elevation. Refueling Floor
- Reactor Building 74' elevation, North
- Reactor Building 91 ' elevation, South and West PO-HA1 HOSTILE ACTION wil hin the OWNER CONTROLLED AREA or airborn e attack threat PD-HU1 Confirmed SECURITY CONDITION or threat.
w ithin 30 minutes.
EMERGENCY ACTION LEVEL (EAL}: 11 or 2) EMERGENCY ACJlQN LEVEL (EAL): (1 or 2 or 3)
- 1. A HOSTILE ACTION is occurring Of has OCCU1Ted within the OWNER CONTROLLED AREA as 1 A SECURITY CONDITION that does not involve II HOSTILE AC TI ON as reported by lhe Station Security reported by the Station Sec\Jrily Force SectxityForce 2 Notdicahon of a cred ible secunty threat directed at the site 2 A validated noHficallon from NRC of an aircraft attack threat within 30 m1nt.Aes of the site
- 3. A validated notification from the NRC providing 1nformation of ;an aircraft threat.
PD-HU2 Hazardous event affecting equ ipment necessary for spent fuel cooling.
EMERGENCY ACTION LEVEL (EAL):
1 a The occurrence of ANY of the following hazardous events Seismic l!Vent (earthquake)
Internal Of external flooding event High winds or tornado stnke FIRE H
EXPLOSION Natural &
Seawater bay level > +13"6" MSL (Ll-38J1A/8)
Destrucifve Phe nomena Seawater bay level< -13"9 " MSL ( Ll-38J1A/B)
Haza rd s Other everts with similar hazard characteristics as determined by the Control Room Supervisor A ND b The event has damaged at least one train of a system needed for spent fuel cooling A ND c The damaged sr-tem trai n(s) cannot. or potentially cannot. perform i~ design function based on EITHER
- Indications of degraded performance
- VISIBLE DAMAGE PD-HAJ Other condlllons exist wMch In the Judgment or the Emergency Director warran t PD-HUJ Other conditions exist which In the Judgment or the Emergency Director warrant declaraHon of an A lert . declaration or an Unusual Event.
EMERGENCY ACTION LEVEL jEAL) : EMERGENC Y ACTION LEVEL (EAL):
Judgment 1. Other conditions exist which in the judgment of the Emergency Dit ectOf indicate that evenl9 are in 1 Other conditions exist which in the judgment of the Emergency Director indicate that r.rents are progress or heve occurred which 1!"1\IOlve an actual or potential substarl:1al degradation of the level of 1n progress or have OCC\Jrred which indicate a potential degradation of the level of safety of the safety of the faciijty or a security event that involves proba ble life tlTeatening risk to site personnel or facility or indicate a security threat to facility prolection has been initiated. No releases of damage to site equipment because of HOSTILE ACTION. My releases are expected to be limited to radioacuve m aterial requiring offsite response or monitoring are expected unless further smal fractions of the EPA Protective Acbon Guideline exposure levels degradation of aystems needed lo maintain s pent fuel cooling occurs PO-SU1 UNPLANNED s ~ fuel poof temperature rise.
s System Malfunction .
Non*
EMERGEN C Y ACTION LEyEL (EAL):
1 UNPLANNED spent fuel pool temperature nse lo greater than 125 "F.
E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.
EMERGENCY ACTION LEVEL (EALJ:
1 Damage to a loaded cask CON FIMENT BOUNDARY as indicated by an on-contact radiation reading greater than EITHER the fonowing.
E Non* 11 60 mremhv (gamma + neutron) on the lop of the OVERPACK ISFSI OR b 600 mremhv (gamma+ neutron) on lhe side of the OVER PACK, excluding inlet and outlet duct, PERMANENTLY DEFUELED CONDITIONS Pilgrim Nuclear Power Station IC/EAL Identifier Emergency Action Level Matrix PD or E-XX#.# - Example (PD-HA1 .2) ea,....., (A, H. s. El Emergencv CJassiflca!lon (A. U)
catego,y escalation ,enH number
Attachment 5 Letter Number 2.18.063 Revised Pages of the Comparison Matrix for Perm anently Defueled' EALs Based on NEI 99-01, "Development of Emergency Action Levels for Non-P assive Reactors," Revision 6 (Attachment 2 of the LAR)
ATTA CHME NT 2 to Letter No. 2.18.035 NEI 99-01 Rev 6 Appe ndix C - Proposed Permanently Defueled Permanently Defueled Station Comparison EAL for PNPS ICs/EALs
- 1) Reading on ANY of the following radiation monitors greate r than 1. Reading on ANY Table A-1 effluent radiation
- Added additional site-specific the reading shown for 15 minute s monito r that is greate r than the reading shown in information regarding radiation or longer: column "Alert" for 15 minutes or longer. monitors and annunciator panels and references for the information (site-specific monito r list and Table A-1 Effluent Monitor Classification Thresholds added.
threshold values) Release Point Monitor Alert NOUE
- Included Table A-11 to provide
- 2) Dose assessment using actual en effluent monito r description and
- J 0 Rx Bldg Vent RM-17 05-32N B 2X HI-meteorology indicates doses Q) 2.75E5 threshold values, and show en Exhaust (Panel C910 - HI greater than 10 mrem TEDE or (ll cps escalation path.
(.9 units of cps) Alarm 50 mrem thyroid COE at or beyond (site-specific dose
- Added "site boundary" as the site receptor point). specific dose receptor point.
-0 Radwaste RM-1705-30 2X HI-
- 3) Analysis of a liquid effluent *s O" Discharge (Panel C910 - N/A HI sample indicates a concentration :.:J Effluent units of cps) or release rate that would result in Alarm -,
doses greate r than 10 mrem TEDE or 50 mrem thyroid COE at or beyond (site-specific dose 2. Dose assess ment using actual meteo rology receptor point) for one hour of indicates doses greate r than 10 mrem TEDE or 50 exposure. mrem thyroid COE at or beyond the site boundary.
- 4) Field survey results indicate EITHER of the following at or 3. Analysis of a liquid effluent sample indicates a beyond (site-specific dose concentration or release rate that would result in receptor point): doses greate r than 10 mrem TEDE or 50 mrem thyroid COE at or beyond the site bound ary for one
- Closed window dose rates hour of exposure .
- greater than 10 mR/hr expec ted to continue for 60 minutes or longer. 4. Field survey results indicate EITHER of the following at or beyond (site-specific dose receptor point):
- Analyses of field survey sampl es indicate thyroid COE greate r than
- Closed window dose rates greate r than 10 50 mrem for one hour of mR/hr expected to continue for 60 minutes or inhalation. longer. -,
- Analys es of field survey samples indicate thyroid COE greate r than 50 mrem for one hour
/ Page 14 of 36
ATTA CHM ENT 2 to Letter No. 2.18.035 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Permanently Defueled Station Comparison EAL for PNPS ICs/EALs Timely and accurate communications events will initiate appropriate threat-related notific between Security Shift Supervision and the ations to facility personnel and OROs.
Control Room is essential for proper classification of a security-related event. Security plans and terminology are based on the guidance Classification of these events will initiate provided by NEI 03-12, Template for the Security Plan, Training appropriate threat-related notifications to and Qualification Plan, Safeguards Contingency Plan [and plant personnel and OROs. Independent Spent Fuel Storage Installation Security Program].
Security plans and terminology are based EAL #1 references the Station Security Force becau se these are on the guidance provided by NEI 03-12, the* individuals trained to confirm that a secur ity event is Template for the Security Plan, Training occurring or has occurred. Training on secur ity event and Qualification Plan, $afeguards confirmation and classification is controlled due to the nature of Contingency Plan [and independent Spent Safeguards and 10 CFR § 2.39 information.
Fuel Storage Installation Security EAL #2 addresses the receipt of a credible security Program]. threat. The credibility of the threat is assessed in accordance with PNPS EAL #1 references (site-specific security 5.3.14, "Security Incidents" (Ref. 1.)
shift supervision) because these are the EAL #3 addresses the threat from the impact of an aircra individuals trained to confirm that a ft on the facility. The NRC Headquarters Operations Office security event is occurring or has occurred. r (HOO) will communicate to the licensee if the threat involves an Training on security event confirmation and aircraft. The status and size of the plane may also be provided classification is controlled due to the nature by NORA D through the NRC. Validation of the threat is of Safeguards and 10 CFR § 2.39 performed in accordance with PNPS 5.3.14.1, "Airborne Threat" information. (Ref. 2.)
Escalation of the emerg ency classification level would EAL #2 addresses the receipt of a credible be via IC PD-HA1.
security threat. The credibility of the threat
- is assessed in accordance with (site- PNPS Basis Reference(s):
specific procedure).
- 2. PNPS 5.3.14.1, "Airborne Threat" 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).
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