Text

Emergency Plan, Rev. 59. Part 1 of 2
	ML17269A334
Person / Time
Site:	Palo Verde
Issue date:	09/15/2017
From:	; Arizona Public Service Co
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML17264A609	List: ML17263B248; ML17263B249; ML17269A334;
References
	102-07585-CS/DWC
	Download: ML17269A334 (167)
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Enclosure 1 PVNGS Emergency Plan, Revision 59

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 1 of 332 PVNGS EMERGENCY PLAN REVISION 59 Digitally signed by David Crazier DN: cn=David Crozier, o=Emergency David Crozier

^ I ^ 1^11. VIIi^aviu u ennail=David.Crozier#apsxom, csUS Originator: Reason: I authored this document Date: 2017XI8.1S 16:4S:16-0r0(y Williams, Todd Digitally signed by Williams, Todd B(Z05663)

DN:cn=Williams.Todd B(Z05663)

B(Z05663) Reason: I have reviewed this document Date: 2017.08.18 1657:18 -0700' Reviewer:

Arbuckle, Danny Digitally signed by Arbuckle, Danny R(Z02626)

DN: cn=Arbuckle. Danny R(Z02626)

R(Z02626) Reason: I am approving this document Date: 2017.08.1817:22:51 -OT'OO Approval:

EFFECTIVE DATE: August 22, 2017

PVNGS EMERGENCY PLAN REVISION 59 PAGE 2 of 332 PVNGS EMERGENCY PLAN REVISION 59 I

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PVNGS EMERGENCY PLAN REVISION 69 PAGE 3 of 332 DESCRIPTION OF CHANGES Revised Section 5.2 £ind Eliminated Table 2 Revised section 5.2 to remove guidance and EAL Technical Bases associated with Nuclear Energy Institute (NEI) 99-01, Revision 5, Methodology for Development of Emergency Action Levels and replaced it with wording to describe the addition of NEI 99-01 Revision 6 and its associated guidance. Removed associated Table 2, Initiating Conditions and EAL Thresholds, this is now incorporated into new Appendix A of the Plan.

Added an Appendix A to the Emergency Plan On September 8, 2016, the NRC issued a letter titled, Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Issuance of Amendments to Revise Emergency Action Levels to a Scheme Based on Nuclear Energy institute NEI 99-01, Revision 6 (CAC NOS. MF6803, MF6804 and MF6805. This letter provided Amendment No. 198 to Renewed Facility Operating License No. NPF-41, Amendment No. 198 to Renewed Facility Operating License No. NPF-51 and Amendment No. 198 to Renewed Facility Operating License No.

NPF-74 for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, respectively.

The NRC also included a copy of the an approved Safety Evaluation. Appendix A provides this new classification guidance and EAL Technical Basis. The content of Appendix A is identical to the submittal as approved by the NRC which includes minor errors and tjT)e-os that will be revised in Revision 60 of the PVNGS Emergency Plan.

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 4 of 332 TABLE OF CONTENTS SECTION PAGE

- - - - <<********************************************************************************<<*******************<<*** 7 1.0 DEFINITIONS AND ABBREVIATIONS.......................................................................................... 7 1.1 DEFINITIONS...................................................................................................................7 1.2 ABBREVIATIONS...........................................................................................................12 2.0 SCOPE AND APPLICABILITY........................................................................................................14 3.0

SUMMARY

OF THE PVNGS EMERGENCY PLAN.....................................................................14 4.0 ORGANIZATIONAL CONTROL OF EMERGENCIES................................................................ 15 4.1 NORMAL ORGANIZATIONS....................................................................................... 15 4.2 THE EMERGENCY RESPONSE ORGANIZATION................................................. 16 4.3 NON-LICENSEE SUPPORT......................................................................................... 28 4.4 COORDINATION WITH PARTICIPATING GOVERNMENT AGENCIES......... 28 4.5 INSTITUTE OF NUCLEAR POWER OPERATIONS (INPO)................................. 32 4.6 LETTERS OF AGREEMENT (LOAs)...........................................................................32 5.0 EMERGENCY CONDITIONS AND CLASSIFICATIONS.......................................................... 41 5.1 EMERGENCY CONDITIONS....................................................................................... 41 5.2 BASIS FOR PALO VERDE NUCLEAR GENERATING STATION (PVNGS)

CLASSIFICATION CRITERIA.................................................................................... 42 6.0 EMERGENCY MEASURES............................................................................................................. 43 6.1 EVENT ASSESSMENT.................................................................................................... 43 6.2 CLASSIFICATION AND DECLARATION................................................................. 43 6.3 NOTIFICATION............................................................................................................. 43 6.4 MOBILIZATION..............................................................................................................44 6.5 CONSEQUENCE ASSESSMENT.................................................................................44 6.6 CORRECTIVE ACTIONS.............................................................................................. 46 6.7 PROTECTIVE ACTIONS............................................................................................... 46 6.8 AID TO AFFECTED PERSONNEL..............................................................................51 6.9 MEDIA RELATIONS..................................................................................................... 52 7.0 EMERGENCY FACILITIES AND EQUIPMENT........................................................................ 56 7.1 EMERGENCY CENTERS............................................................................................. 56 7.2 COMMUNICATIONS SYSTEMS..................................................................................59 7.3 ASSESSMENT EQUIPMENT.......................................................................................67 7.4 PROTECTIVE FACILITIES AND EQUIPMENT...................................................... 70 7.5 FIRST AID AND MEDICAL FACILITIES.................................................................. 70 7.6 DAMAGE CONTROL EQUIPMENT AND SUPPLIES.............................................70 7.7 PROMPT NOTIFICATION SIREN SYSTEM............................................................. 70

PVNGS EMERGENCY PLAN REVISION 59 PAGE 5 of 332 8.0 MAINTAINING EMERGENCY PREPAREDNESS................................................................71 8.1 ORGANIZATIONAL PREPAREDNESS................................................................71 8.2 REVIEW AND UPDATING OF THE EMERGENCY PLAN................................. 80 8.3 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT AND SUPPLIES..............................................................................................................................81 9.0 RECOVERY............................................................................................................................. 81 9.1 RECOVERY ORGANIZATION. . . . . . . . . . . . . . . . . . . . . . . 82 9.2 RECOVERY EXPOSURE CONTROL. . . . . . . . . . . . . . . . . . . . 82 9.3 RE-ENTRY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83 10.0 AGREEMENT LETTERS........................................................................................................ 83 TABLE OF CONTENTS SECTION PAGE 11.0 REFERENCED INTERFACING EMERGENCY PLANS....................................................... 87 12.0 MAPS....................................................................................................................................... 88 13.0 EMERGENCY PLAN IMPLEMENTING PROCEDURES..................................................... 95 14.0 IDENTIFICATION OF EMERGENCY KITS BY GENERAL CATEGORY............................95 15.0 ACCIDENT DOSE PROJECTION AND SOURCE TERM ESTIMATION.............................95 15.1 DOSE ASSESSMENT MODEL..............................................................................95 16.0 CROSS REFERENCE TO NUREG 0654.................................................................................96 17.0 CORPORATE EMERGENCY SUPPORT.............................................................................. 101 18.0 PUBLIC INFORMATION......................................................................................................101

18.1 INTRODUCTION

.................................................................................................101 18.2 ACTIVATION AND OPERATION....................................................................... 101 18.3 STAFFING AND LOCATION.............................................................................. 101 19.0 DEVELOPMENTAL REFERENCES...................................................................................102 TABLES AND FIGURES TABLE 1 MINIMUM SHIFT STAFFING FOR EMERGENCIES.................................................. 33 TABLE 2 INITIATING CONDITIONS AND EAL THRESHOLDS................................................ 49 TABLE 3 EMERGENCY RESPONSE FACILITY COMMUNICATIONS LINKS...........................66 FIGURE 1 ONSHIFT EMERGENCY ORGANIZATION............................................................... 34 FIGURE 2 TECHNICAL SUPPORT CENTER ORGANIZATION............................................... 35 FIGURE 3 OPERATIONS SUPPORT CENTER ORGANIZATION.............................................36 TABLE OF CONTENTS SECTION PAGE FIGURE 4 EMERGENCY OPERATIONS FACILITY ORGANIZATION.................................... 37

PVNGS EMERGENCY PLAN REVISION 59 PAGE 6 of 332 FIGURE 5 JOINT INFORMATION CENTER ORGANIZATION................................................38 FIGURE 6 ONSITE/OFFSITE EMERGENCY ORGANIZATION INTERFACE......................... 39 FIGURE 7 STATE, COUNTY & LOCAL EMERGENCY OPS CENTER ORGANIZATION..... 40 FIGURE 8 NOTIFICATION ALERT NETWORK (NAN)............................................................ 53 FIGURE 9 NAN NOTIFICATION FLOW....................................................................................54 FIGURE 10 COMMUNICATION LEADING TO PROTECTIVE ACTION RECOMMENDATIONS

.......................................................................................................................................... 55 FIGURE 11 POPULATION EVACUATION ROUTE SECTIONS & EVACUATION ROUTING.. 88 FIGURE 12 DEMOGRAPHY WITHIN PLUME EXPOSURE PATHWAY EPZ.......................... 89 FIGURE 13 SITE EXCLUSION AREA BOUNDARY AND PROPERTY BOUNDARY............... 91 FIGURE 14 INGESTION EXPOSURE PATHWAY EMERGENCY PLANNING ZONE............. 92 FIGURE 15 RECEPTION AND CARE CENTERS.......................................................................93 FIGURE 16 PROMPT NOTIFICATION SYSTEM SIREN LOCATIONS.....................................94 APPENDICES APPENDIX A CLASSIFICATION GUIDANCE AND EAL TECHNICAL BASIS

PVNGS EMERGENCY PLAN REVISION 59 PAGE 7 of 332 INTRODUCTION Palo Verde Nuclear Generating Station (PVNGS) is a jointly-owned three-unit Pressurized Water Reactor (PWR) power station operated by Arizona Public Service (APS). The station is located in Maricopa County, South of Wintersburg, Arizona.

THE PVNGS EMERGENCY PLAN:

Describes the organization formed and facilities available to manage emergency situations;

Classifies emergencies according to severity of consequences;

Defines and assigns responsibibties for emergency response actions;

Outbnes courses of action and protective measures to mitigate the consequences of an accident and to safeguard station personnel and the pubhc;

Presents a general post-emergency plan and organization to restore the plant to a normal operating status;

Defines methods and processes to inform the public.

The accidents which might occur at PVNGS are analyzed in Chapter 15 of the PVNGS UFSAR in terms of severity of consequence. The Independent Spent Fuel Storage Installation (ISFSI), which is stationary and centrally located within the PVNGS exclusion area boundary, is analyzed in the Cask UFSAR and satisfies the requirements for off-normal radiological dose. The PVNGS UFSAR analyzed accidents reflect the design characteristics of a Pressurized Water Reactor (PWR) and are addressed by PVNGS Emergency Operating Procediues (EOPs) and Emergency Plan Implementing Procedures (EPIPs). Postulated events concerning the ISFSI are encompassed by the scheme of EALs designated for PVNGS.

1.0 DEFINITIONS AND ABBREVIATIONS 1.1 DEFINITIONS The following are definitions of terms commonly used in this Emergency Plan.

Area Radiation Monitoring System (ARMS)

An instrumentation system designed to detect abnormal area radiation levels and activate corresponding station alarms.

Assessment Actions Are actions performed during or after an incident, to obtain and process information necessary to determine the character and magnitude of the incident and to implement specific emergency measures.

Committed Dose Equivalent (CPE)

CDE is the dose equivalent to organs or tissues of reference that will be received from an intake of radioactive material by an individual during the 50-year period following the intake.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 8 of 332 Committed Effective Dose Equivalent (CEDE)

CEDE is the sum of the products of the weighting factors applicable to each of the body organs or tissues that are irradiated and the CDE to these organs or tissues.

Controlled Area An area outside of the Restricted Area but inside the Site Boundary access that can be limited by the licensee for any reason.

Corrective Actions Measures taken to terminate an emergency situation at or near the source of the problem.

County Emergency Operations Center (Countv EOC)

The County EOC is located at the Maricopa County Department of Emergency Management (MCDEM) Headquarters at 5630 E. McDowell Road, Phoenix, Arizona, and is the primary point through which the Cheiirman, Maricopa County Board of Supervisors/designee exercises coordination over county emergency response actions conducted within the EPZ.

Deep-Dose Equivalent (DDE)

DDE is the dose equivalent at a tissue depth of 1 cm (1000 mg/cm2), which applies to external whole- body exposiue.

Dose Equivalent (DE)

DE is the product of the absorbed dose in tissue, quality factor and all other necessary modifying factors at the location of interest. The units of dose equivalent are the rem and Sievert (Sv).

Effective Dose Equivalent (EDE)

EDE is the sum of the products of the dose equivalent to each organ or tissue and a weighting factor applicable to each of the body organs or tissues that are irradiated.

Emergency Action Levels IE AT.si Parameters used to designate a particular classification of emergency. These parameters may include radiological dose rates, levels of airborne or waterborne activity, or instrument indications/plant parameter values.

Emergency Response Organization (ERO)

The individuals within the PVNGS organization designated to respond to an emergency.

Exclusion Area Boundary An area surrounding the reactor in which the reactor licensee has the authority to determine all activities, including exclusion or removal of personnel and property from the area.

Full Participation Full participation when used in conjvmction with emergency preparedness exercises for a particuleir site means appropriate offsite local and State authorities and licensee personnel physically and actively take part in testing their integrated capability to adequately assess and respond to an accident at a commercial nuclear power plant. Full participation includes testing major observable portions of the onsite and offsite emergency plans and mobilization of State, local and licensee personnel and other resources in sufficient numbers to verify the capability to respond to the accident scenario.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 9 of 332 Hostile Action An act towards a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidates the licensee to achieve an end.

This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the nuclear power plant. Non-terrorist-based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area).

Independent Spent Fuel Storage Installation (ISFSI)

A complex designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. The PVNGS ISFSI is located approximately 605 feet northeast of the PVNGS Power Plant Protected Area.

Inpcstion Exnosure Pathway Emergency Planning Zone (IPZ)

The IPZ is the fifty-mile radius area (Figure 14), centered on the vertical axis of the Unit 2 Containment Building for which protective actions for the general population, farmers, dairy farmers, ranchers, food processors and distributors are planned.

Inplant The area located within the confines of the PVNGS Power Plant Protected Area.

Joint Information Center (JIC)

Combined PVNGS/state/county function; located at 600 North Airport Road, Building A, Buckeye, Arizona. The JIC is responsible for issuing news information during an Alert or higher level emergency classification.

Nuclear Administrative and Technical Manual (NATM)

The collection of onsite programs and procedures which prescribes how PVNGS is controlled, operated, maintained, and tested to meet the requirements of applicable licenses, standards, codes, Euid guides. It estabhshes effective management practices.

Offsite Any position or area not located within the confines of the Site Boundary.

Offsite Response Organization (PRO)

The emergency Offsite Response Organization for state and local governments described in the Offsite Emergency Response Plan for the Palo Verde Nuclear Generating Station.

Offsite Emergency Response Plan for Palo Verde Nuclear Generating Station Is the State of Arizona/ Maricopa County Plan for governmental response to emergencies at PVNGS? The Plan sets forth specific responsibilities and procedures for state, local and volunteer agencies responsible for offsite emergency operations and protection of the affected population.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 10 of 332 On-Shift Emergency Response Organization The emergency response positions on shift as designated in Table 1, Minimum Shift Staffing for Emergencies. Typically positions required by plant technical specifications, fire protection program, security plan and the radiological emergency plan designated to respond in the initial phase of an emergency.

Onsite Any position or area located within the confines of the Site Boundary.

Onsite Emergency Response Organization The augmented PVNGS emergency response organization used to staff the Technical Support Center, Operations Support Center, Emergency Operations Facility, Joint Information Center, etc.. Table 1, Minimum Shift Staffing for Emergencies denotes the required augmented positions.

Owner Controlled Area The area owned by the licensee and located within the confines of the Site Boundary as shown in Figure 13.

Partial Participation Partial participation when used in conjunction with emergency preparedness exercises for a particular site means appropriate offsite authorities shall actively take part in the exercise sufficient to test direction and control functions; i.e., (a) protective action decision making related to emergency action levels, and (b) communication capabilities among affected State and local authorities and the Hcensee.

Plant Property Line The boundary enclosing the area owned by the licensee and corresponding to the Site Boundary, with the addition of purchased property located immediately north of the northwest comer of the Site Boundary and extending to the Buckeye-Salome Highway.

Plume Exposure Pathway Emergency Planning Zone (EPZ)

The Plume Exposure Pathway EPZ is the ten-mile radius area, centered on the vertical axis of the Unit 2 Containment Building, for which protective actions are planned.

Ponulation-at-Risk Persons for whom protective actions are being, or would be, implemented.

Process Radiation Monitoring System (PRMS)

An instrumentation system designed to detect abnormal radiation levels in process and effluent pathways, and to activate appropriate alarms.

Protective Actions Emergency measures taken to avoid or reduce radiation dose. These commonly include sheltering, evacuation, and prophylaxis.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 11 of 332 Protective Action Guides (PAGs)

The projected dose to individuals that would warrant consideration of protective action against an accidental release of radioactive material.

Protected Area(s) (PA)

An area, located within the PVNGS Exclusion Area Boundary, encompassed by physical barriers and to which access is controlled per 10 CFR 73.55. The PVNGS Power Plant Protected Area and the ISFSI Protected Area are two Protected Areas located within the PVNGS Owner Controlled Area.

Recovery Actions Are post-emergency actions to restore the station to a normal operating condition.

Restricted Area An area access to which is limited by the Hcensee for the purpose of protecting individuals against imdue risks from exposure to radiation and radioactive materials.

Site Boundary The boundary of a reactor site beyond which the land or property is not owned, leased, or otherwise controlled by the licensee.

State Emergency Operations Center (State EOC)

The State EOC is located at the ADEM Headquarters and is the primary point through which the Govemor/designee exercises overall control and coordination of governmental offsite emergency response operations.

Technical Operations Center (TOC)

The TOC is co-located with the State EOC. The TOC is the offsite location that provides for overall control of radiological technical operations.

Total Effective Dose Equivalent (TEDE)

TEDE is the sum of the Deep-Dose Equivalent (for external exposmes) and the CEDE (for internal exposures).

Unrestricted Area An area access to which, is neither limited nor controlled by the licensee.

Vital Area An area within the PVNGS Power Plant Protected Area encompassed by additional physical barriers and to which access is controlled per 10 CFR 73.55. Vital areas contain equipment considered vital to the operation of the plant.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 12 of 332 1.2 ABBREVIATIONS The following are abbreviations of terms commonly used at PVNGS.

ADEM - Arizona Division of Emergency Management ADV - Atmospheric Dump Valve APS - Arizona Public Service Company AREA - Arizona Radiation Regulatory Agency ASU - Arizona State University BOP - Balance of Plant BPD - Buckeye Police Department CDE - Committed Dose Equivalent CEDE - Committed Effective Dose Equivalent CEDMCS - Control Element Drive Mechanism Control System CEO - Chief Executive Officer GET - Core Exit Thermocouple CFR - Code of Federal Regulations CNO - Chief Nuclear Officer CR - Control Room CRDR - Condition Report Disposition Request CRS - Control Room Supervisor CTMT - Containment DDE - Deep Dose Equivalent DE - Dose Equivalent DEMA - Department of Emergency and MiUtary Affairs DHS - Department of Homeland Security DOE - Department of Energy DPS - (Arizona) Department of Public Safety EAL - Emergency Action Level EAS - Emergency Alert System EC - Emergency Coordinator EDE - Effective Dose Equivalent EDG - Emergency Diesel Generator EMT - Emergency Medical Technician ENS - Emergency Notification System EOC - Emergency Operations Center EOD - Emergency Operations Director EOF - Emergency Operations Facility EOP - Emergency Operating Procedure EPA - Environmental Protection Agency EPABX - Electronic Private Automatic Branch Exchange EPD - Electronic Personal Dosimeter EPIP - Emergency Plan Implementing Procedure EPZ - Emergency Planning Zone ERDS - Emergency Response Data System ERFDADS - Emergency Response Facility Data Acquisition & Display System ERF - Emergency Response Facility ERO - Emergency Response Organization ESF Engineered Safety Features

PVNGS EMERGENCY PLAN REVISION 59 PAGE 13 of 332 1.2 ABBREVIATIONS (CONTINUED)

FEMA _ Federal Emergency Management Agency FPS - Fire Protection System FSS - Fire Suppression System FTS - Federal Teleconummications System FWLB - Feed-water Line Break GPM - Gallons per Minute HP - Health Physics HPN - Health Physics Network HPSI - High Pressure Safety Injection I&C - Instnunentation and Control INPO - Institute of Nuclear Power Operations IPZ - Ingestion Pathway Zone ISFSI - Independent Spent Fuel Storage Installation JIC - Joint Information Center JPIP - Joint Public Information Procedure KI - Potassium Iodide LAN - Local Area Network LCO - Limiting Condition for Operation LOAF - Loss of All Feed LOCA - Loss of Coolant Accident LPSI - Low Pressure Safety Injection LWR - Light Water Reactor MODEM - Maricopa County Department of Emergency Management MCPL - Management Counterpart Link MCSO - Maricopa County Sheriffs Office MSLB - Main Steam Line Break NAN - Notification Alert Network NATM - Nuclear Administrative and Technical Manual NOAA - National Oceanic and Atmospheric Administration NRC - Nuclear Regulatory Commission NSSS - Nuclear Steam Supply System NWS - National Weather Service OBE - Operating Basis Earthquake ODCM - Offsite Dose Calculation Manual OSC - Operations Support Center PAD - Protective Action Decision PAG - Protective Action Guide PAR - Protective Action Recommendation PASP - Preplanned Alternate Sampling Program PBX - Private Branch Exchange PI - Plant Information PIO - Public Information Officer PMCL - Protective Measures Coimterpart Link PSIG - Po\mds Per Square Inch Gauge PVAR - Palo Verde Action Request PVNGS - Palo Verde Nuclear Generating Station PWR - Pressurized Water Reactor QSPDS Qualified Safety Parameter Display System

PVNGS EMERGENCY PLAN REVISION 59 PAGE 14 of 332 1.2 ABBREVIATIONS (CONTINUED)

RAC Radiological Assessment Coordinator RACOMM Radiological Assessment Communicator RCS Reactor Coolant System REAT Radiological Emergency Assistance Team RFAT Radiological Field Assessment Team RMS Radiation Monitoring System RP Radiation Protection RPC Radiological Protection Coordinator RPM Radiation Protection Monitor RPS Reactor Protection System RSCL Reactor Safety Counterpart Link RSP Remote Shutdown Panel RVLMS Reactor Vessel Level Monitoring System SGTR Steam (Generator Tube Ruptvne SIM (Control Room) Simulator SPDS Safety Parameter Display System SM Shift Manager STA Shift Technical Advisor STSC Satellite Technical Support Center SWMS Site Work Management System TEDE Total Effective Dose Equivalent TLD Thermoluminescent Dosimeter TOC Technical Operations Center TSC Technical Support Center UFSAR Updated Final Safety Analysis Report UPS Uninterruptible Power Supply 2.0 SCOPE AND APPLICABILITY This Emergency Plan is applicable to PVNGS. Specific procedures to implement the Emergency Plan are listed in Section 13.0, Emergency Plan Implementing Procedures.

There are also various supporting and complementing emergency plans, including those of Federal Agencies, the State of Arizona and Maricopa County.

3.0

SUMMARY

OF THE PVNGS EMERGENCY PLAN The Emergency Plan is designed to adhere to Nuclear Regulatory Commission (NRC) emergency planning regulations and guidehnes applicable to commercial nuclear power stations. The Emergency Plan is based upon NRC and Federal Emergency Management Agency (FEMA) guidance as contained in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", and EPA guidance as contained in EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" October, 1991. Radiological emergency planning for the PVNGS has been coordinated with state and local emergency response agencies.

V.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 15 of 332 The State of Arizona and local government agencies who may be involved in emergency response operations are aware of the emergency response measures described in the PVNGS Emergency Plan and are advised of changes or modifications to these measures resulting from plan reviews, audits, drills and/or exercises along with changes to Regulatory guidance.

Both the Offsite Emergency Response Plan for PVNGS and the PVNGS Emergency Plan contain clear-cut definitions of areas of authority and responsibility. The DEMA, acting imder the direction and authority of the Governor, is responsible for overall coordination of offsite governmental emergency operations. The PVNGS Emergency Organization is responsible for onsite emergency operations and for providing timely and accurate plant status information to offsite emergency authorities. The ARRA has been assigned technical (radiological) responsibihty for governmental response within Arizona. Emergency operations within the Plume Exposure Pathway EPZ are the responsibility of Maricopa Coimty.

4.0 ORGANIZATIONAL CONTROL OF EMERGENCIES In the event of an emergency, the normal station operational organization is supplemented with an organization specifically designed to respond to emergency situations. Depending on the severity of the emergency, the Emergency Organization may consist of an on-shift emergency response organization, or of an augmented emergency response organization comprised of station, corporate and contract personnel. This section describes the On-shift, On-site and Off-site Emergency Organizations.

4.1 NORMAL ORGANIZATIONS The Executive Vice President & Chief Nuclear Officer, reports to the APS President &

Chief Executive Officer. The Executive Vice President & Chief Nuclear Officer has the overall responsibility and authority for the operation and technical support of PVNGS.

The Executive Vice President & Chief Nuclear Officer and the nuclear organization have the overall responsibility and authority to ensure that all activities associated with APS nuclear facilities are carried out with the highest standards of safety and ensuring the station is operated in accordance with (LAW) the licenses granted by the NRG, the Technical Specifications, and the requirements and commitments stated in the UFSAR.

The onsite station organization is divided into four main groups which report to the Executive Vice President & Chief Nuclear Officer.

Each group is divided into subordinate departments and sections. The four groups are as follows; Nuclear Site Operations Regulatory Affairs Oversight and Performance Improvement Operations Support Engineering

PVNGS EMERGENCY PLAN REVISION 59 PAGE 16 of 332 4.2 THE EMERGENCY RESPONSE ORGANIZATION

[Ref. INPO lER LI 13-10, Recommendation Sg, lER L2 11-39, Recommendation 3]

The Emergency Response Organization (ERO) consists of personnel staffing in the Control Room/STSC, Operations Support Center (OSC), Technical Support Center (TSC), Emergency Operations Facility (EOF) and the Joint Information Center (JIC).

The PVNGS ERO is supported by designated facilities as described in Section 7.0, Emergency Facihties and Equipment. The on-shift emergency response organization is augmented at declaration of an Alert or higher emergency classification level.

In the event a member of the ERO minimum staff becomes incapacitated or is otherwise unavailable, they shall be replaced as soon as reasonably possible.

Operating unit staff who are ERO members are governed by PVNGS Technical Specification 5.2 and its exceptions.

During normal station work hours, notification of on-site ERO may occur via PA announcement, emergency evacuation system and/or mobile devices.

During off-hours, notification of ERO is accomplished by activating the automated callout system. A manual system is also available if the automated system is not available.

For an Unusual Event classification, on-shift personnel respond to the emergency and the event is directed from the affected unit Control Room/ STSC. Command of the situation remains there with the on-shift Emergency Coordinator (EC) until termination/recovery or reclassification to a higher level emergency occurs. For events affecting all three units, command and control is in Unit 1. APS/Palo Verde Communications provides media interface during an Unusual Event.

In the event of an Alert or higher classification level, the on-shift EC orders the activation of the TSC, OSC, EOF, and JIC. The on-site ERO is directed by the EC-TSC. The EOD in the EOF provides overall coordination of the event and direction of the ERO.

4.2.1 ON-SHIFT EMERGENCY ORGANIZATION Palo Verde Nuclear Generating Station on shift emergency organization is sufficient to permit the required mitigation response and effectively implement the Emergency Plan as required in 10CFR50 Appendix E.

Table 1 of the Emergency Plan reflects the results of the Palo Verde On-Shift Emergency Response Organization Staffing and Capabilities analysis as required by 10 CFR 50, Appendix E. The Palo Verde On-Shift Emergency Response Organization Staffing and Capabilities analysis is retained as Correspondence # 090-05063 (RCTSAI 4164598).

PVNGS EMERGENCY PLAN REVISION 59 PAGE 17 of 332 The On-shift Emergency Organization (Figure 1) consists of the following positions:

4.2.1.1 Emergency Coordinator (EC)

[Ref. INPO lER LI 13-10, Recommendation 5i]

The affected unit Shift Manager (SM) or designee initially assumes the responsibilities of the EC and is responsible for direction and coordination of the response. Members of the normal shift organization assume emergency positions to carry out actions as described below.

The EC has the responsibility and authority to inunediately and imilaterally initiate emergency actions, including providing notification and Protective Action (PAR) Recommendations to governmental agencies responsible for implementing off-site emergency measures.

The EC is also responsible for commiuiication of plant status and radiological conditions including dose projection results as appropriate.

Procedures provide for accelerated calls and verbal notification to the NRC using the Emergency Notification System (ENS) of Security-based events considered to be a credible imminent threat or Hostile Action.

The affected unit Shift Manager may choose to be relieved as EC by another individual qualified as an EC.

At an Alert or higher emergency classification level, the EC directs the Security Director to initiate callouts to the ERO in accordance with the associated implementing procedure. Upon arrival of the designated EC-TSC, the EC-STSC conducts a briefing and is relieved as the Emergency Coordinator.

At the onset of an incident, the EC has the following responsibilities:

Notification of offsite emergency response agencies and off-site emergency organizations (non-delegable duty until relieved by EOD)

Provision of PARs as necessary to off-site emergency management agencies (non-delegable duty until relieved by EOD)

Subsequent reclassification of emergency events (non-delegable)

Determination of the necessity for site evacuation authorization for emergency workers to exceed 10CFR20 exposure limits

Initiate activation of on-site and off-site ERO organizations for an alert or higher emergency classification level 4.2.1.2 Control Room Supervisor The Control Room Supervisor (CRS) located in the imit control rooms, reports to the EC. The CRS performs initial assessment and evaluation of any abnormal or emergency conditions. After the EC declares an emergency, the CRS maintains the normal duties of directing the Nuclear Operators and assisting the EC.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 18 of 332 4.2.1.3 Fire Team The Fire Team (minimum of 5 individuals) reports to the CRS and is maintained on-site at all times. The Leader of Fire Protection Department is responsible for ensuring sufficient members of the Fire Team are Emergency Medical Technician (EMT) qualified and available at all times.

4.2.1.4 Fire Team Advisor The Fire Team Advisor is a Reactor Operator/Auxiliary Operator that supports the Fire Team dm-ing a fire. The Fire Team Advisor should have no collateral duties that interfere with the ability to support the Fire Team.

4.2.1.5 Control Room Operators The Control Room Operators report to the CRS and conduct the safe and proper operation of the unit at all times, and respond to emergency conditions, as necessary.

4.2.1.6 Radiation Monitoring Technician The Radiation Monitoring Technician reports to the Radiation Protection Monitor (RPM) and establishes a response area in the Radiation Monitoring office and conducts in-plant area surveys as necessary.

4.2.1.7 Radiation Protection Monitor (RPM)

The Radiation Protection Monitor (RPM) an ANSI 3.1 Senior Radiation Protection Technician responds to the STSC and reports to the EC. The RPM conducts offsite dose calculations rnitil relieved. The RPM authorizes exposures up to 10CFR20 Limits, recommends potassium iodide administration to the EC and directs in-plant, onsite and offsite Radiation Monitoring Teams.

4.2.1.8 STSC Communicator The STSC Communicator is filled by an Auxiliary Operator. Upon direction from the EC, the STSC Communicator makes the initial notifications to state and local agencies and the ERO.

4.2.1.9 Emergency NotiRcation System (ENS) Communicator The ENS Communicator is filled by an individual knowledgeable of the plant (e.g., RO, SRO, STA, previously licensed individual, etc.) and keeps an open fine of commimications with the NRC, as requested.

This communicator should not have any other E-Plan collateral duties (or other duties that interfere with the communicator function).

4.2.1.10 Security Director The Security Director initially responds to the Shift Manager/EC and then reports to the EC in the TSC. The Secmity Director (assmned by the on-shift Secmity Section Leader) provides for continued personnel accountability, site access control and requests offsite emergency assistance, upon direction from the EC.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 19 of 332 4.2.1.11 Security Force The Security Force reports to locations as directed by the Security Director and assists in performing assigned duties.

4.2.1.12 Shift Manager The Shift Manager is also the EC-STSC until relieved by the EC-TSC.

Following tvunover the Shift Manager reports to the EC. The Shift Manager performs initial classification and declaration of an emergency, maintains control of unit operations, and mitigates accident conditions.

4.2.1.13 Shift Technical Advisor The Shift Technical Advisor (STA) responds to the Control Room or STSC of the affected unit and reports to the EC. The affected unit STA advises the EC on activities that impact the safe operation of the unit, and independently verifies emergency classifications, as time permits.

For events classified as an Alert or higher emergency classification level, the affected unit STA activates ERDS.

4.2.1.14 Shift Technical Advisor (Unaffected Unit)

The unaffected imit STA assesses core damage, and provides electrical and mechanical technical support until relieved by the TSC. The STA also monitors various data displays throughout the course of the emergency and provides assistance to the Control Room personnel.

4.2.1.15 Technicians Technicians report to the EC and if necessary, may be assigned to Emergency Repair or Survey teams. The Chemistry Technicians, Maintenance Technicians (Mechanics, Electrical, Instrument and Control) respond to the OSC for assignment.

4.2.1.16 Operations Advisor The Operations Advisor responds to the STSC and reports to the EC.

The Operations Advisor provides technical and operational advice to the EC-STSC. Following TSC activation, the Operations Advisor maintains the flow of information between the EC-TSC and Control Room.

4.2.1.17 Survey/Environmental Teams A Survey/Environmental Team is formed and responds to the OSC, upon request from the Radiation Protection Monitor (RPM). The team performs radiological monitoring activities and at least one member of the team is a Radiation Protection Technician.

4.2.1.18 Emergency Repair Teams The Emergency Repair Team conducts repairs and may consist of Chemistry and Maintenance Technicians, Plant Operators and a Radiation Protection Technician, and reports to the EC.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 20 of 332 4.2.2 TECHNICAL SUPPORT CENTER (TSC) ORGANIZATION (ONSITE)

The TSC Organization is located on-site and is illustrated in Figure 2 and consists of the following positions.

4.2.2.1 Emergency Coordinator TSC (EC-TSC)

The EC-TSC responds to the TSC and is responsible for direction and coordination of the onsite Emergency Organization.

4.2.2.2 Emergency Coordinator (EC) Technical Assistant The EC Technical Assistant responds to the TSC and reports to the EC.

The EC Technical Assistant follows procedures that the Control Room is using, and keeps the EC informed of the operational impact of events in progress. The EC Technical Assistant has no coimterpart in the on-shift Emergency Organization.

4.2.2.3 Maintenance Manager The Maintenance Manager responds to the TSC and reports to the EC.

The Maintenance Manager coordinates the repair and damage control for all plant systems and directs the emergency response activities of the Emergency Repair Teams (4.2.1.17). The Maintenance Manager directs the OSC Manager to form and dispatch any team that is required and maintains communication with the OSC concerning repair team efforts.

4.2.2.4 Engineering Manager The Engineering Manager responds to the TSC and reports to the EC.

The Engineering Manager directs systems analysis, engineering and any procedure development as required by the emergency and maintains liaison with the Engineering Director in the EOF.

4.2.2.S Mechanical Engineer The Mechanical Engineer responds to the TSC and reports to the Engineering Manager. The Mechanical Engineer assumes the duties of Technical Support Mechanical from the STA in the STSC £uid provides mechanical engineering analyses.

4.2.2.0 Operations Manager The Operations Manager responds to the TSC and reports to the EC.

The Operations Manager receives technical and operational input from the Operations Advisor and maintains the flow of information between the TSC and Control Room.

4.2.2.7 Radiation Protection Coordinator The Radiation Protection Coordinator responds to the TSC and reports to the EC-TSC. The Radiation Protection Coordinator receives and evaluates dose projection information from the TSC Staff and provides Protective Action Recommendations to the EC-TSC. Once the EOF is activated, the Radiation Protection Coordinator coordinates efforts with the Radiological Assessment Coordinator in the EOF.

r

PVNGS EMERGENCY PLAN REVISION 59 PAGE 21 of 332 4.2.2.S Security Director The Security Director responds to the TSC once activated and reports to the EC-TSC. The on-shift Security Section Leader assumes the duties and responsibilities as the Security Director. The Security Director requests emergency off-site assistance upon direction of the EC-TSC and directs the onsite security force in the areas of personnel accoimtability, access control, site security, evacuation, medical transportation, and personnel and equipment security control.

4.2.2.9 Reactor Analyst The Reactor Analyst responds to the TSC and reports to the Engineering Manager. The Reactor Analyst assumes responsibilities from the STA.

The Reactor Analyst performs detailed analyses of core physics and heat transfer parameters to assess reactor core status and to evaluate the integrity of fuel cladding.

4.2.2.10 Radiation Protection Support Technician The Radiation Protection Support Technician responds to the TSC and reports to the Radiation Protection Coordinator. The Radiation Protection Support Techmcian performs habitability surveys of the TSC.

4.2.2.11 Safety Analysis Engineer The Safety Analysis Engineer responds to the TSC and reports to the Engineering Manager. The Safety Analysis Engineer performs calculations and analyses that are used in the effort to reduce or minimize offsite releases.

4.2.2.12 Administrative Staff The Administrative Staff responds to the TSC and assists the TSC Emergency Organization in all matters requiring clerical support.

4.2.2.13 Chemistry Coordinator The Chemistry Coordinator responds to the TSC and reports to the Engineering Manager. The Chemistry Coordinator provides analysis and evaluation of coolant samples and air samples to eud in determination of reactor core conditions and release potentials, and provides chemical analyses for evaluation of plant systems.

4.2.2.14 Electrical Engineer The Electrical Engineer responds to the TSC and reports to the Engineering Manager. The Electrical Engineer provides electrical engineering analyses and assumes the duties of Technical Support Electrical from the STA in the STSC.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 22 of 332 4.2.2.15 ERF Communicator The ERF Communicator responds to the TSC emd reports to the Emergency Coordinator Technical Assistant. The ERF Communicator maintains communications with the ERF Communicators in the OSC, EOF and JIC, and provides information to the Emergency Coordinator Technical Assistant regarding the overall emergency activities and maintains Plant Status electronic media display and/or status boards.

4.2.2.16 Shift Technical Advisor An augmented Shift Technical Advisor responds to the TSC and reports to the Operations Manager. The Shift Technical Advisor monitors plant system data via ERFDADS, maintains Uaison with the NSSS vendor, architect engineer concerning technical status and proposes recommendations to the Operations Manager.

4.2.2.17 ENS Communicator The ENS Communicator responds to the TSC and reports to the Operations Manager. The ENS Communicator maintains continuous phone communications with the NRC, when requested, concerning operational events and reactor plant status.

4.2.3 OSC ORGANIZATION The OSC Emergency Organization is illustrated in Figure 3.

4.2.3.1 OSC Manager The OSC Manager responds to the STSC for a briefing and reports to the EC. Following the briefing, the OSC Manager responds to the OSC, coordinates available resources and upon direction from the Maintenance Manager in the TSC, assembles and dispatches emergency teams.

4.2.3.2 Radiation Protection Group Lead The Radiation Protection Group Lead reports to the OSC Manager and provides overall control and direction of in-plant monitoring teams and radiological controls.

4.2.3.3 Repairs Coordinator The Repairs Coordinator ensures that Maintenance Technicians and Repair Teams are dispatched at the direction of the OSC Manager. The Repairs Coordinator reports to the OSC Manager.

4.2.3.4 Repair Teams Teams are formed if emergency repair operations are necessary. The teams may consist of Chemistry Technicians, Maintenance Technicians (Mechanical, Electrical, Instrmnentation and Control), or Radiation Protection Technician as required to address conditions and Plant Operators.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 23 of 332 4.2.3.5 RFAT Driver The RFAT Driver responds to the RFAT vehicles and serves as a driver for the RFAT vehicle.

4.2.3.6 Radiation Protection Technicians Radiation Protection Technicians respond to the OSC and report to the Radiation Protection Group Lead. As required, the RP Technicians may be assigned to Repair or Survey/Environmental Teams.

4.2.3.T Chemistry Technicians Chemistry Technicians respond to the OSC and report to the Radiation Protection Group Lead. As required, Chemistry Technicians may be assigned to Repair or Survey Teams, or to conduct sampling activities.

4.2.3.S Mechanics Mechanics respond to the OSC and report to the Repairs Coordinator.

Mechanics may be assigned to repair teams as needed.

4.2.3.9 Electricians Electricians respond to the OSC and report to the Repairs Coordinator.

Electricians may be assigned to repair teams as needed.

4.2.3.10 I&C Technicians I&C Technicians respond to the OSC and report to the Repairs Coordinator. I&C Technicians may be assigned to repair teams as needed.

4.2.3.11 ERF Communicator The ERF Communicator responds to the OSC and reports to the OSC Manager. The ERF Communicator maintains communications with his counterparts in the TSC, EOF, and JIC, and provides information to the OSC Manager regarding the overall emergency activities.

4.2.3.12 Administrative Staff The Administrative Staff responds to the OSC and assists the OSC Emergency Organization in all matters requiring clerical support.

4.2.4 EOF ORGANIZATION The EOF Emergency Organization is illustrated in Figure 4. The interfaces between the Onsite and Offsite Emergency Organizations are shown in Figure 6.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 24 of 332 4.2.4.1 Emergency Operations Director The Emergency Operations Director (EOD) is in command of emergency operations and is responsible for:

Overall coordination of onsite and offsite emergency functions.

Interfacing with federal/state/county emergency response agencies.

Commmiication of plant status updates and radiological release data including dose projection results as appropriate to NRC, State/Coimty EOCs, TOC, and JIC personnel.

Notification of state and county agencies concerning recommended protective actions.

Directs administrative, technical, and logistical support to station emergency operations.

Ensuring continuity of emergency organization resources.

EstabUshing a recovery organization when appropriate.

Upon the assumption of this position the EOD accepts from the EC-STSC, the following non-delegable offsite organizational responsibilities:

Notification of offsite emergency management agencies.

Making protective action recommendations as necessary to offsite emergency management agencies.

4.2.4.2 Assistant Emergency Operations Director The Assistant Emergency Operations Director (AEOD) responds to the EOF and reports to the EOD to assist with duties and responsibilities as assigned.

4.2.4.3 Radiological Assessment Coordinator The Radiological Assessment Coordinator responds to the EOF and reports to the EOD. The Radiological Assessment Coordinator is the principal liaison of the emergency response organization with the ARRA.

The Radiological Assessment Coordinator receives and evaluates dose projection information from the EOF Staff and provides protective action recommendations to the EOD.

4.2.4.4 Engineering Director The Engineering Director responds to the EOF, reports to the EOD and provides evaluation of projected occurrences and corrective actions.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 25 of 332 4.2.4.5 Security Manager The Security Manager responds to the EOF and reports to the EOD. The Security Manager provides overall security support and coordinates closely with the Security Director in the TSC. ITie Security Manager also coordinates with the Administrative/Logistics Coordinator in providing site support to facilitate arrivals of offsite personnel.

4.2.4.6 ERF Communicator The ERF Communicator responds to the EOF and reports to the Engineering Director. The ERF Communicator maintains communications with his counterparts in the TSC, OSC, and JIC.

This position also monitors ERFDADS data displayed through PI, provides information to the Engineering Director regarding the overall emergency activities and maintains Plant Status boards.

4.2.4.7 Information Coordinator The Information Coordinator responds to the EOF and reports to the AEOD. The Information Coordinator will gather information and prepare plant-related press materials for EOD/AEOD approval, and provide approved information to the JIC ERF Communicator and Spokesperson Coordinator.

4.2.4.S Radiological Assessment Communicator The Radiological Assessment Communicator responds to the EOF and reports to the Radiological Assessment Coordinator. The Radiological Assessment Communicator communicates with radiological assessment personnel at the TSC and directs the activities of the onsite/offsite Survey/Environmental Teams.

4.2.4.9 Administrative / Logistics Coordinator The Administrative / Logistics Coordinator responds to the EOF and reports to the AEOD. The Administrative/Logistics Coordinator mobilizes offsite resources and obtains logistical support for the Emergency Organization.

4.2.4.10 Dose Assessment Health Physicist The Dose Assessment Health Physicist responds to the EOF and reports to the Radiological Assessment Coordinator to perform radiological dose projections and other calculations or evaluations as directed.

4.2.4.11 Systems Engineering Systems Engineering responds to the EOF and reports to the Engineering Director. Systems Engineering performs engineering analyses, as required, and maintains the equipment status boeu-d.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 26 of 332 4.2.4.12 Administrative Staff The Administrative Staff reports to the Administrative/Logistics Coordinator in the EOF and assists the Emergency Organization in all matters requiring clerical support.

4.2.4.13 HPN Communicator The HPN Communicator responds to the EOF and reports to the Radiological Assessment Coordinator. The HPN Communicator will maintain an open line with the NRC upon request.

4.2.4.14 NAN Communicator The NAN Conummicator responds to the EOF and reports to the AEOD.

The NAN Communicator makes offsite notifications once the EOF is activated and relieves the STSC Communicator of this responsibility.

4.2.4.15 Information Services (IS) Manager The Information Services Manager responds to the EOF and reports to the AEOD. The Information Services Manager ensures that IT equipment located in the EOF remains in good working order and provides assistance to EOF personnel with IT equipment operation when needed.

4.2.4.16 RFAT Team The RFAT Teams respond to the RFAT vehicle parking area and report to the Radiological Assessment Communicator in the EOF.

4.2.4.17 Offsite Technical Representative The Offsite Technical Representative interfaces with state response agency personnel at the State EOC/TOC, provides up-to-date information on plant status, and clarifies how plant systems operate, via briefings and face-to-face contact with EOC staff, the TOC Shift Supervisor, and the TOC Technical Director. The Offsite Technical Representative is located at the TOC in Phoenix and reports to the AEOD.

4.2.5 JOINT INFORMATION CENTER (JIC) ORGANIZATION The JIC Organization is illustrated in Figure 5.

4.2.5.1 JIC Manager The JIC Manager is the PVNGS representative that oversees public information activities at the JIC including preparation of media statements, media briefings and the flow of information to the Rumor Control Unit. The JIC Manager reviews the technical content of media statements.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 27 of 332 4.2.5.2 Spokesperson Coordinator The Spokesperson Coordinator is the PVNGS representative in the JIC who coordinates the Spokespersons and advises and prepares materials for the Palo Verde Spokesperson in the preparation for media briefings.

4.2.S.3 Palo Verde Spokesperson The Palo Verde Spokesperson is the representative within the JIC organization authorized to speak about actual emergency conditions at PVNGS.

4.2.5.4 ERF Communicator The ERF Communicator is the JIC Palo Verde representative that provides any necessary technical explanations to the JIC Manager and the Palo Verde Spokesperson. The JIC ERF Communicator interfaces with the ERF Communicator in the EOF. The ERF Communicator, maintains communications with his counterparts in the TSC, OSC, and EOF, and provides information to the JIC Spokesperson Coordinator and the Palo Verde Spokesperson regarding the overall emergency activities.

4.2.S.5 Distribution Services Coordinator The Distribution Services Coordinator coordinates the timely dissemination of accurate incident information to the media through electronic communication pathways (e.g., e-mail or fax) and the pubhc via the Arizona Emergency Information Network Web site; and provides translation and other services for special needs and multilingual populations.

4.2.S.6 Rumor Control/Public Inquiry The Rumor Control/Pubhc Inquiry is operated by the Arizona Public Service Customer Care Center (CCC) Operators and augments State Pubhc Inquiry smd Rumor Control initiatives. CCC Operators provide information from approved media statements transmitted to the CCC fi"om the JIC.

4.2.5.7 Video/Photo Coordinator The Video/Photo Coordinator operates audio/video equipment at the JIC, including the EEC Auditorium. The Video/Photo Coordinator maintains copies of media briefings for archives.

4.2.5.S ResearcbAVriting Coordinator The ResearcbAVriting Coordinator writes materials such as media statements, fact sheets, flyers, and talking points for use by the JIC staff as needed.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 28 of 332 4.3 NON-LICENSEE SUPPORT Support from outside PVNGS consists of local service companies, institutions, agencies, INPO, and contractor support.

4.3.1 LOCAL SERVICES SUPPORT In emergency situations, PVNGS may need supplementary assistance from outside companies and service agencies. Such assistance may include transportation of injured and/or contaminated personnel, medical treatment and hospital facilities for station personnel, and fire suppression assistance.

4.3.2 CONTRACT SUPPORT Contract support may include the Nuclear Steam Supply System (NSSS) supplier, the Architect Engineer, dosimetry, laboratory contractors, and decontamination and radwaste disposal firms. PVNGS has arranged for selected contract support firms to provide this assistance upon request.

4.4 COORDINATION WITH PARTICIPATING GOVERNMENT AGENCIES For a complete discussion of authority, assigned responsibilities, capabilities, and activation and communication arrangements refer to the Offsite Emergency Response Plan for Palo Verde Nuclear Generating Station. PVNGS personnel coordinate emergency operations with state/ county government Emergency Operations Centers.

The state, county, and city Emergency Operations Center Organization is shown in Figure 7. Safeguards and secvuity team response are described in the PVNGS Security Plan and its implementing procedures.

4.4.1 STATE OF ARIZONA The Governor of the State of Arizona is responsible for state government operations.

The governors decision authority is assumed by a successor in his/her absence in accordance with the succession stipulated in the Arizona Revised Statutes, Title 26, Chapter 2, Article 1. Heads of state departments and agencies are responsible for the accomplishment of emergency and recovery tasks assigned by the governor or his/her authorized representative.

In addition to the support outlined in the Letters of Agreement, the Offsite Emergency Response Plan for Palo Verde Nuclear Generating Station provides for the following support functions for PVNGS in the event of an emergency from the indicated agencies.

Also, mutual aid compacts and agreements between the State and other government emd private entities defined in the Offsite Emergency Response Plan multiply the resources available to PVNGS in an emergency.

4.4.1.1 Arizona Department of Emergency and Military Affairs The Arizona Department of Emergency and Military Affairs (DEMA) is assigned to coordinate the cooperative effort of all non-technical governmental agencies, including the Federal government, Arizona State government and its political subdivisions, and provides the necessary direction and control of state personnel and equipment for offsite response actions during radiological emergencies. It is referred to in the Offsite Emergency Response Plan for PVNGS as the Operations Directorate.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 29 of 332 4.4.1.2 Arizona Division of Emergency Management The Arizona Division of Emergency Management (ADEM) is a division of the DEMA and is located on the Papago Military Reservation at 5636 East McDowell Road, Phoenix, Arizona. The Director, ADEM, provides advice and assistance to the governor concerning emergency preparedness, operations and recovery. The director is responsible for coordinating the emergency planning, operations and recovery efforts of state agencies and political subdivisions on the governors behalf. The director is the designated PoUcy Chief for offsite government response to a radiological incident at PVNGS.

ADEM receives initial and follow up notifications from PVNGS and coordinates the collection, analysis and dissemination of information during an incident at the Palo Verde Nuclear Generating Station (PVNGS). This process is conducted in consort with the PVNGS, Maricopa Coimty Dept, of Emergency Management (MODEM), Arizona Radiation Regulatory Agency (AREA) and other federal, state, local. Tribal Nation and volunteer agencies.

ADEM coordinates with ARRA and MODEM to ensure monitoring of evacuees for possible radioactive contamination and supervision and monitoring of any decontamination efforts. ADEM oversees requests for and coordination of federal technical support and exchanges of field data and accident assessment information with PVNGS.

An emergency classification or notification may require governmental or private sector emergency organizations to commit resources to onsite at the request of the PVNGS. Emergency resources may include, but are not limited to, law enforcement, firefighting, medical support and groimd or air services.

Assistance may be requested from other state governments and private sector resources in states adjoining Arizona. These resources may include medical capabihties, emergency response equipment, and emergency response personnel. The state Emergency Operations Center (EOC) Policy Chief or the Arizona Radiation Regulatory Agency (ARRA) Technical Director will initiate requests.

4.4.1.3 Arizona Radiation Regulatory Agency The Director, Arizona Radiation Regulatory Agency (ARRA) is responsible for providing technical support in response to a radiological incident and provides Protective Action Recommendations to the governor and IC. The ARRA Director serves as the Technical Director in the state EOC. Arizona statutes require that the Emergency Response Plan be binding on other governmental agencies and therefore. Section 10.0 does not list separate letters of agreement with all agencies.

ARRA is the agency with primary offsite responsibihty for carrying out radiological emergency assessment actions, coordinating the technical offsite agency response and providing protective action recommendations to the Govemor/designee. It is referred to in the Offsite Emergency Response Plan for PVNGS as the Technical Operations Center, the Radiological Emergency

PVNGS EMERGENCY PLAN REVISION 59 PAGE 30 of 332 Assistance Team Center, and the Radiological Emergency Assistance Team Lab.

AREA receives initial and follow up notifications from PVNGS and provides for collection and analysis of data fi*om the plant, field radiation surveys and sample collection. ARRA representatives share information with EOF staff regarding field team locations, field data and protective action decisions and collects data to assess the accident, project dose and project plume.

ARRA field monitors conduct radiation surveys to determine ambient radiation levels, track the pliune and collect environmental and foodstuff samples for analysis and dispatches a mobile laboratory to Buckeye Airport during the emergency (plume) phase for rapid evaluation of air samples.

ARRA conducts just-in-time radiological training and provides equipment for alternate persormel prior to being deployed in response to a HAB incident.

4.4.1.3 Arizona Department of Public Safety The Department of Public Safety (DPS) provides law enforcement support for ADEM and MCSO. DPS also serves as the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months point of contact for the State of Arizona in the event of an emergency at the PVNGS.

4.4.2 MARICOPA COUNTY Maricopa County is the only county within the 10-mile Plmne Exposure Pathway Emergency Planning Zone. Portions of four other counties (La Paz, Hnal, Ymna, and Yavapai) are included in the 50-mile Ingestion Exposure Pathway EPZ.

The Chairman of the Maricopa County Board of Supervisors is responsible for decision making at the county level. Maricopa County Department and Agency directors are responsible for the accomplishments of emergency and recovery tasks assigned by the Director of MODEM.

4.4.2.1 Maricopa County Department of Emergency Management The Director, Maricopa Coimty Department of Emergency Management (MODEM) provides technical and professional input to the Maricopa Coimty Administrative Officer concerning planning, response and recovery activities in the event of an emergency. The director is also responsible for the coordination of emergency planning, response and recovery activities with other Maricopa County agencies as well as municipal entities.

Maricopa County Department of Emergency Management receives initial and follow up notifications from PVNGS and provides for the implementation of emergency measures, public warning, reception and care center operation 4.4.2.2 Maricopa County Sheriffs Office The Maricopa County Sheriffs Office (MCSO) receives initial and follow up notifications fi*om PVNGS on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months basis. The Maricopa County Sheriffs Office (MCSO) performs the Emergency Pubhc Warning (alerting and public information), evacuation control and reentry, public protective action implementation, reception £ind care center security and support (KI transport

PVNGS EMERGENCY PLAN REVISION 59 PAGE 31 of 332 and impound security), just in time radiological training, support control of food embargos MCSO provides coordinated on-site/offsite direction and control in accordance with the Maricopa County Peacetime Disaster Plan (PDP). The PDP authorizes the Sheriff to request assistance when an incident is beyond the ability of the Office to resolve and works under the Incident Command System (ICS) when responding to PVNGS Hostile Action Based (HAB) incidents.

MCSO is responsible for the initial and on-going assessment of the situation to determine if terrorism is involved or responsible for the HAB incident. If and when this determination is made, the Federal Bureau of Investigation (FBI) will be notified.

4.4.3 FEDERAL GOVERNMENT 4.4.3.1 Nuclear Regtdatory Commission (NRC)

The NRC is responsible for licensing and regulating nuclear facilities and materials. These responsibilities include protecting the pubhc health and safety, protecting the environment, and protecting and safeguarding materials and nuclear plants in the interest of national security. The NRC Incident Response Plan objectives are to provide for protection fi-om the effects of radiological incidents that may occur at licensed facilities or which involve licensed materials. In addition to fulfilling its regulatory responsibilities, it is expected that the NRC will provide technical assistance and recommendations.

The NRC acts as the lead federal agency regarding technical matters during a nuclear incident, with the Chairman of the Commission as the senior NRC authority for all response aspects. The Chairman can transfer control of emergency response activities when deemed appropriate.

Incident Response Centers have been established at each of the four NRC regional offices and at NRC Headquarters to centralize and coordinate NRCs emergency response. Each NRC Region is prepared to send a team of qualified specialists to an accident scene. For Site Area and General Emergencies, a NRC Region IV site team is expected to be dispatched to PVNGS with arrival in four to eight hours following notification. Office space, telephones, and other equipment is provided for NRC personnel at the TSC, EOF and JIC.

4.4.3.2 Federal Emergency Management Agency (FEMA)

By the National Response Framework, FEMA is responsible for the overall coordination of a multi-agency Federal response to a significant radiological incident. The primary role of FEMA is to support the states by coordinating the delivery of federal non-technical assistance. FEMA coordinates state and tribal requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary, FEMA will establish a nearby Federal Response Center from which it will manage its assistance activities.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 32 of 332 4.4.3.3 U.S. Department of Energy (DOE)

The DOE has agreed to provide radiological assistance upon request, and has radiological monitoring equipment and personnel resources that it can assemble and dispatch to the scene of a radiological incident. Following a radiological incident, DOE operates as outlined in the Federal Radiological Monitoring and Assessment Plan (FRMAP). DOE has the responsibility to establish the Federal Radiological Monitoring and Assessment Center (FRMAC), which would provide comprehensive post-accident radiological monitoring and assessment.

4.4.3.4 Federal Bureau of Investigation (FBI)

Support from the FBI is available through its statutory responsibility, based in Public Law and the US code, and through a memorandmn of understanding for cooperation with the NRC. Notification to the FBI of emergencies in which they would have an interest will be through the provisions of the PVNGS Security Plan, or by the NRC.

4.4.3.S National Weather Service (NWS)

NWS provides meteorological information during emergency situations, if required. Data available will include existing and forecasted wind directions, wind speeds, and ambient air temperatures.

4.4.3.B Environmental Protection Agency (EPA)

The EPA can assist with field radiological monitoring, sampling, and non plant related recovery and reentry guidance.

INSTITUTE OF NUCLEAR POWER OPERATIONS (INPO)

INPO aids nuclear utihties in obtaining resources beyond their usual capabilities during recovery from an emergency. As one of its roles, INPO will assist affected utilities by appl5dng the resources of the nuclear industry to meet the needs of an emergency.

4.6 LETTERS OF AGREEMENT (LOAs)

Letters of Agreement (LOAs) are not necessary with federal and state agencies that are legally required to respond to an emergency; however, agreements are necessary if an agency is expected to provide assistance not required by law. Written agreements have been developed which establish the extent of operations between PVNGS and other support organizations which have an emergency response role consistent with this plan. These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information. PVNGS has obtained LOAs with private contractors and others who provide emergency support services. LOAs, as a minimvun, state that the cooperating organization will provide their normal services in support of an emergency at PVNGS. Letters of Agreement are referenced in Section 10 and the actual letters are maintained on file.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 33 of 332 SHIFT STAFFING immediate Response)

MAJOR FUNCTIONAL StafGng/Unit Shared Site Site Staffing AREA POSITION/FUNCTION TITLE Staffing Totals Shift Manager / Emergency Coordinator 1 3 Control Room Supervisor 1 3 Plant Operations and Control Room Operators 2 6 Assessment of Fire Team Advisor 1 1 Operational Aspects Auxiliary Operators 4 12 Radiation Protection Monitor 1 1 Shift Technical Advisor 2 2 Notification/ STSC Communicator (Covered by See AO above Communications Affected Unit)

ENS Communicator 1 1 Chemistry Technician (OSC) 2 2 Electrical Technician (OSC) 3 3 Mechanical Technician (OSC) 2 2 l&C Technician (OSC) 1 1 RFAT Driver (Water Rec Facility) 1 1 Radiation Protection Technician (OSC) 3 3 Support Staff Radiation Monitoring Technician 1 1 RM or RP Technician (OSC) 1 1 Survey Qualified Position (OSC) 1 1 Security Section Leader/Director (TSC) 1 1 (not committed to armed response)

Fire Suppression / Plant Fire Department / Emergency Rescue Operations and Medical Technicians (At least 2 Fire 5 5 First Aid Team Members are EMT qualified)

Site Access Control and Staffing per Staffing per Plant Security Personnel Accountability Security Plan Security Plan TOTALS 8/Unit =24 26 Shared Total 50 AUGMENTATION STAFFING MAJOR FUNCTIONAL POSITION TITLE ON SHIFT Normal Hours Off Hours AREA 60 MINUTES 120 MINUTES Emergency Direction and Emergency Coordinator (TSC) 1 1 Control Emergency Operations Dir (EOF) 1 1 Technical Support Electrical (TSC) 1 1 Plant System Engineering / Technical Support Mechanical (TSC) 1 1 Reactor Analyst (TSC) 1 1 Repair and Corrective Actions 6 - Immediate 6 Radiation Protection Technicians (OSC) During Normal Protective Actions Homs Engineering Director (EOF) 1 1 Communications NAN Communicator (EOF) 1 1 Offsite Support 45 Minutes Fire Suppression Offsite Fire Department from time of request Offsite Support Rescue Operations and First 45 Minutes Aid Offsite Ambulance from time of request TOTALS 13 13 TABLE 1 MINIMUM SfflFT STAFFING FOR EMERGENCIES

PVNGS EMERGENCY PLAN REVISION 59 PAGE 34 of 332 CONTROL ROOM / STSC EMERGENCY COORDINATOR (EC)

Control Room Unit Shm Radiation STSC Supenrisor Communicator j Security Diractor Technical Advisor Protection Monitor

-I CR Operator* I

Radiation Monitoring ENS I Security Force I Technician Communicator Fire Team

! Radiation ! Operations Advisor I Monitoring Team* j Shift Technical Advisor (Unaffected Unit) i OSC Manager ;

Repair Team* l Dashed box denotes Positions not physically located in the CR Augmented Staffing FIGURE 1 - ONSfflFT EMERGENCY ORGANIZATION

PVNGS EMERGENCY PLAN REVISION 59 PAGE 35 of 332 TECHNICAL SUPPORT CENTER (TSC)

Emergency Coordinator (TSC)

Radiation Emergency Operations Maintenance Engineering Protection Security Director Manager Manager Manager Coordinator Coordinator AssistantTech ENS ERF CorTYTiunicator RTechnician P Support Security Force OSC Manager Electrical Engineer Communicator Mechanical Administrative Shift Technical Repairs l Engineer Staff I Reactor Analy^

Repair Teams (OSC)

Safety Analysis Engineer Chemistry Coordinator FIGURE 2 - TECHNICAL SUPPORT CENTER ORGANIZATION

PVNGS EMERGENCY PLAN REVISION 59 PAGE 36 of 332 OPERATIONS SUPPORT CENTER (OSC)

OSC Manager ERF Administrative Communicator Support Rad Protection Repairs Group Lead Coordinator RP Technicians ' - Mechanics Chemistry Electricians Technicians l&C Technicians Repair Team Mambara, aa naadad RFAT Driver FIGURE 3 - OPERATIONS SUPPORT CENTER ORGANIZATION

PVNGS EMERGENCY PLAN REVISION 59 PAGE 37 of 332 EMERGENCY OPERATIONS FACILITY (EOF)

EMERGENCY OPERATIONS DIRECTOR Engineering Security Assist Emergency Assessment Operations Director Manager Director Coordinator Dose Assessment Systems Health Physicist Administrative/

Engineering Logistics Coordinator HPN Communicator NAN Communicator Radiological Assessment Communicator RFAT Teams S Offsite Technical Representative FIGURE 4 - EMERGENCY OPERATIONS FACILITY ORGANIZATION

PVNGS EMERGENCY PLAN REVISION 59 PAGE 38 of 332 JOINT INFORMATION CENTER (JIC)

JIC Manager Distribution Services Public Inquiry/

Rumor Control Palo Varda ERF Communicator CMiar Spokespersons FIGURE 5 - JOINT INFORMATION CENTER ORGANIZATION

PVNGS EMERGENCY PLAN REVISION 59 PAGE 39 of 332 OFFSITE COUNTY EMERGENCY OPERATIONS CENTER STATE BUCKEYE POLICE DEPARTMENT JOINT EMERGENCY INFORMATION OPERATIONS CENTER CENTER EMERGENCY OPERATIONS FACILITY ONSITE TECHNICAL SUPPORT CENTER OPERATIONS SUPPORT CENTER CONTROL ROOM I

FIGURE 6 - ONSITE/OFFSITE EMERGENCY ORGANIZATION INTERFACE

PVNGS EMERGENCY PLAN REVISION 59 PAGE 40 of 332 POLICY GROUP - GOVERNOR CHAIRMAN. MARICOPA COUNTY BOARD OF SUPERVISORS DIRECTOR. ADEM AZ HOMELAND SECURITY DIRECTOR OF OPERATIONS RADIOLOGICAL STATE MARICOPA EMERGENCY OPERATIONS COUNTY BUCKEYE POLICE ASSISTANCE TEAM DIRECTORATE EOC DEPARTMENT (ARRA) (ADEM) (MODEM)

HEALTH SHERIFFS OFFSITE OEPARTMEMT OFFICE REAT FORWARD TECH REP VOLUNTEER DEPARTMENT OF AGENCIES TRANSPORTATION MONITOR FIELD POOL TEAMS CIVIL AIR PATROL CORPORATE COMMISSION DEPARTMENT OF ECONOMIC SECURITY DEPARTMENT OF AGRICULTURE DEPARTMENT OF TRANSPORTATION DEPARTMENT OF HEALTH SERVICES DEPARTMENT OF EMERGENCY AND DEPARTMENT OF PUBLIC SAFETY MILITARY AFFAIRS DEPARTMENT OF WATER RESOURCES RED CROSS OPERATIONS RESOURCE RESPONSE RESPONSE FIGURE 7 - STATE, COUNTY & LOCAL EMERGENCY OPERATIONS CENTER ORGANIZATION

PVNGS EMERGENCY PLAN REVISION 59 PAGE 41 of 332 5.0 EMERGENCY CONDITIONS AND CLASSIFICATIONS 5.1 EMERGENCY CONDITIONS Emergency classification is divided into four classification levels. Emergency Action Levels (EALs), based on indications available in the control room and correlated to the emergency classifications, are provided to the operator.

The EALs were discussed and agreed upon by Palo Verde and state and county governmental authorities, and approved by the NRC. EALs are reviewed with the State and local governmental authorities on an annual basis.

PVNGS has and maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an EAL has been exceeded. Upon identification of the appropriate emergency classification level the emergency condition will be promptly declared.

The foim emergency classification levels are described in the following sections:

EMERGENCY CLASSIFICATION LEVEL DESCRIPTIONS There are three considerations related to emergency classification levels. These are:

(1) The potential impact on radiological safety, either as known now or as can be reasonably projected; (2) How far the plant is beyond its predefined design, safety, and operating envelopes; and (3) Whether or not conditions that threaten health are expected to be confined to within the site boundary.

The ICs deal explicitly with radiological safety impact by escalating from levels corresponding to releases within regulatory limits to releases beyond EPA Protective Action Guideline (PAG) plume exposure levels.

UNUSUAL EVENT (UE);

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

AT.ERT:

Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 42 of 332 SITE AREA EMERGENCY (SAE):

Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; 1) toward site personnel or equipment that could lead to the hkely failure of or; 2) that prevent effective access to, equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA PAG exposiire levels beyond the site boundary, GENERAL EMERGENCY (GE):

Events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA PAG exposure levels off-site for more than the immediate site area.

5.2 BASIS FOR PALO VERDE NUCLEAR GENERATING STATION (PVNGS)

CLASSIFICATION CRITERIA EMERGENCY ACTION LEVELS (EALs)

The site specific implementation of the guidance was approved by the NRC in a safety evaluation dated September 8, 2016 and incorporated into Appendix A of the PVNGS Emergency Plan Revision 59 and in the Emergency Preparedness Implementing Procedures.

Palo Verde Generating Stations Emergency Classification and Emergency Action Level (EAL) scheme is based on the U.S. Nuclear Regulatory Commission (NRC) Amendment No. 198 to Renewed Facility Operating License No. NPF-41, Amendment No. 198 to Renewed Facility Operating License No. NPF-51 and Amendment No. 198 to Renewed Facility Operating License No. NPF-74 for the Palo Verde Generating Station, Units 1, 2, and 3, respectively. The amendments consist of changes to the emergency action level (EAL) scheme in response to a Palo Verde Generating Station application dated October 9, 2015, as supplemented by letter dated May 12, 2016.

The amendments revised Palo Verde Generating Stations EAL scheme based on the Nuclear Energy Institute (NEI) guidance document NEI 99-01, Revision 5, "Development of Emergency Action Levels for Non-Passive Reactors," to one based on NEI 99-01, Revision 6.

NEI 99-01, Revision 6, which was endorsed by the NRC by letter dated March 28, 2013 (Agency-wide Documents Access and Management System Package Accession No. ML13091A209).

PVNGS EMERGENCY PLAN REVISION 59 PAGE 43 of 332 6.0 EMERGENCY MEASURES This section establishes the methodology of emergency response and is the basis for the EPIPs which define the emergency actions to be taken during an emergency.

Emergency measures follow a sequential process which contains the following definable elements; Event Assessment Classification and Declaration Notification Mobilization Consequence Assessment Protective Actions Corrective Actions 6.1 EVENT ASSESSMENT Initial recognition of emergency conditions should normally occur in the Control Room. Emergency conditions may be indicated by alarms, instrument readings or reports to the Control Room. The Control Room Supervisor (CRS) should provide initial evaluation of the indicators and notify the Shift Manager (SM). The SM evaluates the conditions against the established EALs to determine if an EAL has been reached or exceeded.

6.2 CLASSIFICATION AND DECLARATION An emergency shall be classified and declared if the SM finds that a specific EAL has been reached, exceeded, or if the SM determines that it is imminent that the specific EAL set-point will be reached or exceeded.

When the SM declares an emergency to the Control Room personnel, an announcement will be made over the unit public address system, and the other Control Rooms and Security will be notified.

For those abnormal situations potentially involving more than one unit, the Unit 1 SM is responsible for initially classifying and declaring the emergency and assuming the position of EC. Exceptions are considered for selected security events.

6.3 NOTIFICATION Initial notifications are made to state and county warning points and the NRC in accordance with established procedures. The procedures include a means of message verification. The initial notifications to state and county warning points are made within 15 minutes of the declaration of the emergency. The Notification Alert Network (NAN) is the dedicated telephone circuit designed for this purpose (Figures 7 and 8).

The NRC is notified immediately after State and County notification and within one hour. This notification occurs via the ENS Une or the designated alternative if not available.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 44 of 332 6.4 MOBILIZATION The emergency organization for an Unusual Event consists of normal shift personnel.

Augmentation of this organization may occur at the discretion of the EC. At an Alert or higher level emergency classification, the ERO is augmented. ERO personnel will be notified via an automated callout system, Group Paging System, and site PA system.

6.5 CONSEQUENCE ASSESSMENT Assessment actions will continue throughout the emergency. Continued assessment may result in reclassification of the emergency and alteration of emergency response actions.

Priority will be given to continuing assessment actions that result in:

Protective Action Recommendations for the health and safety of the general public

Protective Actions for onsite personnel

Maintaining control of the plant

Resolving an emergency situation

Corrective actions to reduce the consequences of an emergency 6.5.1 Assessment Action for Control of Plant Operations The existence of any emergency condition causes increased monitoring of Control Room instrumentation to monitor trends of appropriate parameters, particularly the indicated values that triggered the emergency and those that may be related.

Additional monitoring equipment may be used to assess the nature of the emergency condition. A Safety Parameter Display System (SPDS) display console is in the Control Room and is accessible to Control Room personnel.

6.5.2 Environmental Assessment for Protection of the Health & Safety of the Public PVNGS has the responsibility to perform a preliminary assessment of the offsite consequences of an incident. Environmental Assessment for Protection of the Health and Safety of the Public is performed by Palo Verde NGS using two methods:

Dose Assessment Environmental Surveys Dose Assessment is performed by trained personnel using computer generated dose projections based on plant parameters and/or site effluent release data. The initial assessment Avill be performed within 30 minutes of the declaration of any emergency classification. The dose assessment program and EPIPs provide recommendations for protective action recommendations when indicated by dose assessment results.

Environmental Surveys will be initiated as a minimum following the declaration of Alert or higher. An Environmental Team will be deployed within 30 minutes to support these surveys. Environmental Teams measure dose rate readings and noble gas and iodine concentrations.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 45 of 332 PVNGS maintains fully equipped and dedicated vehicles to support Environmental Teams. Air monitoring equipment has the capability to detect under field conditions, radioiodine concentrations in air as low as E-7 microcuries per cubic centimeter.

PVNGS deploys Survey Teams offsite at least until ARRA has mobilized its Radiological Emergency Assistance Team (REAT). Approximately three (3) hours is estimated for REAT deployment. Long-term offsite assessments and dose to the public (ingestion pathway EPZ) are the responsibifity of ARRA and supported by Federal resources.

Radiological data developed by either of these techniques is used to assess appropriateness of Classification and Protective Action Recommendations.

Environmental assessment is supported by a permanent meteorological installation which continuously indicates and records wind speed, direction and temperature differentials. Meteorological data may be obtained from the National Weather Service. This system is described in section 7.3.1.1.

6.5.3 In-plant Radiological Controls During the cotrrse of an emergency, elevated radiation or contamination levels may be experienced. It may then be necessary to impose additional radiological controls beyond the controls established by the normal in-plant radiological controls program.

In-plant radiological controls in an emergency situation may differ from normal radiological control activities in the following aspects:

Maintaining strict access control into affected plant areas Availability and use of augmented dosimetry Additional use of portable radiation monitoring devices, particularly high range monitoring devices, for monitoring contamination and area radiation levels Increased availability and use of protective clothing and respiratory devices Increased air sampling for the purpose of limiting the number of persons subject to exposure Increased whole body counting and other bio-assays Initial assessment of the need for in-plant radiological controls may be based on plant readings, RMS readings, in-plant EPD readings and system status reports.

Additional information concerning in-plant radiological conditions may be gained during the debriefing of personnel deployed with Emergency Repair and Survey Teams.

6.5.4 Reactor Core Damage Assessment Initial assessment of the status of the reactor core is performed by the STA. Initial assessment of core conditions is based on readings of Control Room instrumentation and assessment of SPDS data.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 46 of 332 Prior to TSC activation, the STA in the STSC provides additional capability for assessment of reactor core damage.

When the TSC is activated, the Reactor Analyst assesses core conditions imder the direction of the Engineering Manager. Information is obtained from the SPDS and critical parameter values from ERFDADS.

Palo Verdes Core Damage Assessment program was developed based on the Combustion Engineering Owners Group Task 467, Development of the Comprehensive Procedure Guidelines for Core Damage Assessment.

6.6 CORRECTIVE ACTIONS PVNGS procedures contain steps for preventive and/or corrective actions to avoid or mitigate serious consequences of an incident. These steps are contained in AOP, EOP, and other plant procedxires.

6.7 PROTECTIVE ACTIONS A range of protective actions has been developed for emergency workers and the public.

The guidelines for emergency workers are consistent with EPA emergency worker and lifesaving activity protective action guides.

Protective actions are emergency measures taken during and after an emergency so that onsite personnel and the general public are alerted and actions are initiated for the protection of their health and safety. Protective actions are initiated if radiation or airborne radioactivity levels exceed predetermined values or when situations threaten the health and safety of onsite personnel or the general public.

The responsibility for the determination of Protective Actions for Workers and the General Public is implemented as follows:

Protective actions for onsite personnel and visitors are the responsibility of the PVNGS Emergency Coordinator.

Protective Actions for Emergency Workers operating under the State or County Emergency Plan are the responsibility of the ARRA. Measures for the protection of these Emergency Workers are detailed in the Offsite Emergency Response Plan for PVNGS.

Protective Measures for the General Public are directed by the Governor of Arizona and implemented by Maricopa County. It is the responsibility of PVNGS to provide Protective Action Recommendations for the Evacuation and/or Shelter of the General Public within the 10 Mile EPZ in addition to a recommendation for Potassium Iodide when appropriate. PVNGS in coordination with the State of Arizona (ADEM and ARRA) along with Maricopa County have formulated a protective action strategy consistent with the guidance contained within NUREG 0654, Supplement 3, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Guidance for Protective Action Strategies, November 2011.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 47 of 332 The current evacuation time estimate (and annual updates as necessary) is used to assist in formulating protective actions by the offsite authorities. Measures for the protection of the general public are detailed in the Offsite Emergency Response Plan for PVNGS. The communications flow path associated with Protective Action Recommendations is illustrated in Figure 10.

6.7.1 PROTECTIVE ACTION FOR ONSITE PERSONNEL Protective actions for onsite personnel may include alerting, personnel assembly, accountability, and evacuation as well as security procedures, access control, monitoring and decontamination. Protective actions may also be taken for onsite personnel for emergencies such as fires or natural disasters where personnel safety is threatened.

6.7.1.1 Hostile Action Onsite protective of employees during a hostile action involves a combination of restricted movement, movement to safe locations, and site evacuation depending on the nature of the hostile event and advance warning. Site procedures provide specific actions to take during hostile action based events.

6.7.1.2 Alerting Unit personnel are alerted by an audible signal and an announcement over the imit public address system. Site personnel are alerted by activation of an audible signal followed by public address system announcements.

Evacuation/accoimtabihty is assured in high noise work areas by the use of audible alarms, flashing Hghts, and/or administrative measures.

The PVNGS Site Warning Siren/Public Address System consists of electronic sirens with four distinct sounds: (1) assembly signal, (2) evacuation signal, (3) fire signal, and (4) all-clear signal. These signals are introduced in training prior to initial site access and are available on a phone recording. The emergency signal can be activated from the Control Room, the TSC, or Simulator A.

6.7.1.3 Assembly Personnel assembly is mandatory at the Site Area Emergency or higher level classification. Assembly of site personnel outside of the Protected Areas is accomplished by all personnel reporting to designated assembly areas. Assembly may be initiated at any time site management deems it appropriate for personnel safety reasons. In the case of a hostile action threat or event, designated assembly points will be announced via the Public Address System. The designated assembly points may include on-site assembly points or offsite mustering points. Assembly may also be used as a tool to initiate the Two-Man Rule during Security events.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 48 of 332 6.7.1.4 Accountability Personnel accountability within the Protected Area is mandatory at the Site Area Emergency. Accountability may be initiated at other times at the discretion of the EC to support worker safety.

Accountability of personnel within the Protected Areas is accomplished within 30 minutes of the declaration of Site Area Emergency or higher, and maintained continuously thereafter, using Protected Area(s) boimdary access control as described in the PVNGS Security Plan. If there are station personnel who are unaccounted for, the Unit Evacuation System and site wide page are used to locate them, or, in extreme cases (fire, toxic gas release, explosions, structural damage, etc.), trained search and rescue personnel are deployed to search for and assist the missing personnel.

6.7.1.5 Evacuation The decision to evacuate non-essential personnel is made by the EC. Non-essential personnel must be evacuated in the event of a Site Area Emergency or General Emergency. However, in certain situations it may be desirable to evacuate earlier to enhance worker protection.

6.7.1.6 Security and Access Control PVNGS Security personnel at Security Access Control Points are instructed to admit only emergency personnel and designated County, State and NRC personnel. Special onsite security measures have been developed to facilitate rapid access by emergency response personnel. In case of a Security contingency event such as a direct armed attack, Securitys response actions may be primarily focused on the Security event emd take precedence over emergency response duties.

6.7.1.7 Monitoring and Decontamination Personnel are monitored for contamination at the Security Access Points as they depart the Power Plant Protected Area by portal monitors. Personnel located outside the Power Plant Protected Area are monitored as required by radiological conditions. If decontamination of personnel is required, they are decontaminated by trained personnel.

Onsite emergency personnel are monitored for contamination at their respective emergency stations. Decontamination of onsite emergency personnel is conducted at onsite decontamination facilities.

6.7.1.8 Protective Equipment and Supplies A variety of protective equipment is available onsite to minimize radiological exposures, contamination problems and fire fighting hazards.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 49 of 332 6.7.1.8.1 Respiratory Protection Equipment Respiratory protection equipment includes full face canister respirators, self-contained breathing apparatus and air-fed respirators. Radiation Protection personnel determine when the use of respiratory protection equipment is appropriate and select the correct type of equipment for conditions expected to be encountered.

6.7.1.8.2 Protective Clothing Protective clothing is maintained onsite for routine use and is available for use during emergencies.

6.7.1.8.3 Thyroid Blocking Agent The EC is the only individual who may authorize the volvmtaiy use of potassium iodide (KI) for emergency personnel. The EC-TSC authorizes the use of KI with the advice of the Radiation Protection Coordinator. The use of KI is based on the potential for release, or on the magnitude of an actual release, of iodine. KI is distributed to emergency workers when its use is authorized.

6.7.1.8.4 Emergency Dosimetry Dosimetry is located in close proximity to all emergency centers and available for issue to emergency personnel as necessary by Radiation Protection personnel.

6.7.2 OFFSITE PROTECTIVE ACTIONS Protective Actions for the General Public in response to radiological emergencies include sheltering or evacuation of the public and the issuance of Potassium Iodide based on consideration of the relative benefits of each action. The action which affords the higher level of dose avoidance, when offsite doses are expected to exceed Protective Action Guides, is preferred. However, other factors such as release duration, mobilization time or adverse weather are important considerations affecting offsite protective action recommendations. Evacuation route sections and evacuation routing are shown in Figure 11. It is the responsibility of PVNGS to make Protective Action Recommendations, the Governor of the State of Arizona to make Protective Action Decisions and Maricopa County to implement the Protective Action Decision.

PVNGS has performed an Evacuation Time Estimate as required by 10CFR50, Appendix E. PVNGS will estimate EPZ permanent resident population changes during the years between decennial censuses using U. S. Census Bureau data. State and local government population data is used if available. These estimates shall occur no more than 365 days apart. Licensees shall maintain these estimates available for NRC inspection during the period between censuses and shall submit these estimates to the NRC with any updated ETEs. If at any time during the decennial period, the population increases so that the ETE for the 2-mile zone or 5-mile zone, including all affected ERPAs, or for the entire EPZ, increases by 25 percent or 30 minutes, whichever is less, for the scenario with the longest ETE, the ETE analysis will be updated to reflect the impact of that population increase.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 50 of 332 6.7.2.1 Protective Actions for the General Public The basis for developing and providing Protective Action Recommendations is EPA-400, "Manual of Protective Action Gmdes and Protective Actions For Nuclear Incidents." Protective action recommendations for the general public consider the time required for notification of offsite authorities, for public alerting and for implementation of protective actions. In the case of a core melt situation, evacuation of at least a two-mile radius around the plant site and at least five miles downwind for affected sectors is recommended. A Shelter recommendation may be made if known impediments to evacuation exist or the release conditions dictate.

Governmental officials will also be advised to consider the use of Potassium Iodide (KI) as a protective measure. When evacuation is ordered, the Offsite Emergency Response Plan for Palo Verde Nuclear Generating Station provides, as a minimum, for evacuation by 22.5 degree sectors considering first the sector in which the central axis of the plume is located and then the adjacent sector on each side. Implementation of protective actions for the general public is described in the Offsite Emergency Response Plan for Palo Verde Nuclear Generating Station. Time estimates for evacuation within the Plume Exposure Pathway Emergency Planning Zone are maintained in the files of Emergency Preparedness Department. The demography within the Plume Exposure Pathway is shown in Figure 12.

Offsite authorities receive an immediate notification for:

Change in emergency classification

Change in the release status

Change in Protective Action Recommendations

Change in the Protective Action zone 6.7.3 CONTAMINATION CONTROL MEASURES 6.7.3.1 Plant Site Specific area limits have been established for control of contamination within the PVNGS facility. The basis for these limits is that contamination shall be controlled so that hazards to personnel are minimized and compUance with personnel exposure limits (internal and external) is assured. As necessary, Contamination Areas are established and posted. Details of contamination control measures for onsite personnel and equipment are contained in the PVNGS Radiation Protection Program.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 51 of 332 6.7.3.2 Offsite Criteria and measures for contamination control in offsite areas are detailed in the Offsite Emergency Response Plan for Palo Verde Nuclear Generating Station.

6.8 AID TO AFFECTED PERSONNEL 6.8.1 EMERGENCY PERSONNEL DOSE CRITERIA Emergency workers carry dosimeters in addition to Thermoluminescent Dosimeters (TLDs). Dosimeters are read at intervals dependent upon radiation levels in accordance with PVNGS Nuclear Administrative and Technical Manual Procedures.

Emergency dosimetry is provided on a 24-hour basis by Radiation Protection persormel. Every effort is made to minimize emergency worker doses through the use of protective equipment and supplies and by minimizing exposure time.

Emergency exposures above administrative guidehnes are authorized by the Radiation Protection Coordinator or the EC-TSC. The Radiation Protection Monitor (RPM) or Radiation Protection Coordinator authorizes exposures up to the 10 CFR 20 limits, and the EC-TSC authorizes exposures above 10 CFR 20 hmits, in accordance with procedures.

Emergency worker dose criteria are based on three categories of actions:

sampling imder accident conditions, lifesaving actions, and corrective/protective actions.

The EC-TSC is notified of accidental or emergency dose in excess of occupational limits. Affected individuals are not assigned to further emergency team operations with the possibility of exposure. Decisions to accept doses in excess of occupational limits in life-saving situations are on a volunteer basis. In no case, are planned doses permitted to exceed 25 Rem Total Effective Dose Equivalent (TEDE).

6.8.2 DECONTAMINATION AND FIRST AID Provisions exist to assist personnel who are injiued and who have received high radiation doses, or who have been contaminated. Decontamination materials and portable first aid kits are available at strategic locations throughout the station and offsite. There are personnel trained in first aid and decontamination procedures. In addition, onsite decontamination areas equipped with decontamination faciUties, supplies, and other specialized equipment are located near the access control point on the 140 ft. elevation in the Auxiliary Building of each unit. Personnel found to be externally contaminated are decontaminated.

Where contamination of large, open wounds is involved, personnel are transported to Banner Good Samaritan Medical Center or Banner Estrella Medical Center. Contaminated PVNGS evacuees are decontaminated at the offsite relocation area. Waste fluids and wastes from decontamination of personnel or material are collected and handled as radioactive wastes in accordance with the PVNGS Nuclear Administrative and Technical Manual, except at the offsite relocation area, where radioactive wastes are handled imder the guidance of ARRA.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 52 of 332 6.8.3 MEDICAL TRANSPORTATION Injured/extemally contaminated personnel who require medical attention are transported to Banner Good Samaritan Medical Center or Banner Estrella Medical Center by an available onsite or offsite ambulance.

6.8.4 MEDICAL TREATMENT Letters of agreement for treating externally contaminated patients exist for Banner Good Samaritan Medical Center and Banner Estrella Medical Center.

Treatment of individuals injured may occur at the onsite medical facility during normal working hours or by EMT quabfied personnel on weekends or backshift. Serious injuries may require the patient to be transferred to the nearest offsite treatment facility appropriate to the injury.

6.9 MEDIA RELATIONS Provisions for media relations during the course of an emergency are detailed in the Joint Public Information Procedure. When an Unusual Event is declared, news media relations are conducted from APS/Palo Verde Communications. At the Alert or higher classification level, the Joint Information Center is activated at 600 North Verrado Way, Building A, Buckeye, Arizona, in accordance with the guidelines of the Joint Public Information Procedure. The Pubhc Inquiry Center at the State EOC and the Rumor Control Center at the APS Customer Care Center respond to public inquiries.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 53 of 332 PALO VERDE NUCLEAR GENERATING STATION CONTROL CONTROL CONTROL ROOM/STSC ROOM/STSC ROOM/STSC UNIT 1 UNIT 2 UNIT 3 MCSO ADEM ARRA MCDEM (EOC) (EOC)

GOVERNMENT ORGANIZATIONS FIGURE 8 - NOTIFICATION ALERT NETWORK (NAN)

PVNGS EMERGENCY PLAN REVISION 59 PAGE 54 of 332 NORMAL WORKING HOURS PVNGS ADEM ARRA MCSO MODEM DIRECTOR DIRECTOR DIRECTOR DISTRICT 10 AND AND ONSCENE AND COMMANDER OPERATIONS TECHNICAL COMMANDER OPERATIONS RESPONSE RESPONSE RESPONSE AGENCIES AGENCIES AGENCIES ARRA DUTY OFFICER CHAIRMAN MARICOPA COUNTY BOARD OF OPERATIONS OFF-DUTY HOURS PVNGS MCSO ADEM DUTY ARRA DUTY MCDEMDUTY OFFICER OFFICER OmCER DIRECTOR DIRECTOR DIRECTOR AND AND AND OPERATIONS TECHNICAL OPERATIONS RESPONSE RESPONSE RESPONSE AOIENCIES AGENCIES AGENCIES GOVERNOR CHAIRMAN MARICOPA COUNTY BOARD OF SUPERVISORS FIGURE 9 - NAN NOTIFICATION FLOW

PVNGS EMERGENCY PLAN REVISION 59 PAGE 55 of 332 Onshift Onsite and Offsite Organization Organization activated activated CONTROL ROOM (STSC)

RADIATION PROTECTION RADIOLOGICAL MONITOR ASSESSMENT PROVIDES PROTECTIVE COORDINATOR EMERGENCY ACTION ADVICE FOR COORDINATOR RADIOLOGICAL EVENT (EC)

SHIFT EMERGENCY TECHNICAL OPERATIONS ADVISORS DETERMINES DIRECTOR PROTECTIVE ACTION RECOMMENDA TION NAN STSC COMMUNICATOR COMMUNICATOR MAKES OFFSITE NOTIFICATION VIA NAN PHONE FIGURE 10 - COMMUNICATIONS LEADING TO PROTECTIVE ACTION RECOMMENDATION (PAR)

PVNGS EMERGENCY PLAN REVISION 59 PAGE 56 of 332 EMERGENCY FACILITIES AND EQUIPMENT This section describes emergency response facilities, onsite and offsite communications system links, assessment equipment and facilities, first aid and medical facilities, and damage control equipment.

EMERGENCY CENTERS f'7.

7.1.1 CONTROL ROOM (CR) 5 ' The CR is in the Control Building on the 140-foot level and is designed to be habitable ri during Design Basis Accidents. The CR, which includes the Shift Managers office, contains full plant instriunentation, ERFDADS/SPDS, a Qualified SPDS display, and communication links as described in Table 3 and Section 7.2, and technical drawings.

Protective breathing apparatus, emergency radiological monitoring equipment, and protective clothing are stored in the emergency kit outside the CR.

7.1.2 REMOTE SHUTDOWN PANEL ROOM (RSP)

An emergency requiring the evacuation of the CR results in shutdown control from the RSP. The RSP has two redundant and independent sets of plant controls. Each redimdant control area has its own Radio Console and administratively dedicated phone line, as well as EPABX telephone and sound-powered phone as described in Table 3 and Section 7.2.

7.1.3 SATELLITE TECHNICAL SUPPORT CENTER (STSC)

It provides direct technical support to the CR personnel in the areas of:

Engineering and technical anal5dical support Reactor anal5dical support Radiological analytical support An ERFDADS/SPDS display and various communications equipment, as described in Table 3 and Section 7.2, are available in the STSC.

7.1.4 OPERATIONS SUPPORT CENTER (OSC)

The OSC is the entire 140 level of the Auxiliary Building and Operations Support Building of each unit. Emergency equipment required is stored in emergency kits in the OSC. The OSC also includes the Radiation Protection area which provides a decontamination facility, a fixed radiological counting facility, and access to the stations radiation protection records and forms. The OSC serves as the point of origin for Environmental Teams and Repair Teams. Various commimications links, as described in Table 3 and Section 7.2, are available in the OSC.

In the event the OSC becomes uninhabitable, an imaffected unit OSC may be used as an alternate OSC.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 57 of 332 7.1.5 TECHNICAL SUPPORT CENTER (TSC)

The TSC is the focal point for onsite emergency operations and for directing and assisting the Control Room during unit emergency conditions. Key station management and technical personnel are stationed at the TSC during the emergency to provide the guidance required for accident termination and mitigation.

The TSC is staffed and activated during an Alert, Site Area Emergency, or General Emergency and is located below grade immediately southwest of Bldg. "D" inside the Protected Area.

The TSC is centrally located within ten minutes walking time from the CR of each of the three Palo Verde units. The functions performed in the TSC include; Manage onsite emergency response Direct in-plant radiological protection activities Direct emergency maintenance Direct personnel accountability and site security Coordinate safety and hazards control through the Control Room and the Onsite Fire Dept.

Perform engineering and technical analyses for control room support Perform reactor analyses for control room support Provide I & C technical support Coordinate computer technical support Provide chemistry technical support The TSC has ERFDADS/SPDS computer terminals, which display CR parameters for each imit, the Radiation Monitoring System (RMS), the station meteorological system, and other parameters. Capability exists in the TSC to rapidly retrieve plant documents, drawings, procedures and plans. The TSC (when activated) is the central location for the receipt and analysis of in-plant radiological monitoring data. The TSC has various communications links available as described in Table 3 and Section 7.2. The TSC has shielding and ventilation to ensme habitability following design basis accidents.

The TSC contains an area with a microwave and refrigerator, conference room, eui emergency supply storage area, and an area reserved for NRC personnel. The TSC contains equipment required for emergency response. The TSC is also equipped with an airborne radiation monitor.

In the event the TSC becomes uninhabitable, the TSC command function will operate out of the affected units STSC (Unit 1, if multiple units are impacted) and the support staff will be relocated to an OSC.

i

PVNGS EMERGENCY PLAN REVISION 59 PAGE 58 of 332 7.1.6 EMERGENCY OPERATIONS FACILITY (EOF)

The EOF is located approximately 20 miles east of PVNGS at 600 North Verrado Way, Bvulding A, Buckeye, Arizona.

The EOF is the focal point for coordination of onsite and offsite emergency response activities. Management and technical personnel assigned to the EOF are responsible for protective action recommendations, liaison with offsite governmental organizations and response facilities, and overall coordination of the Emergency Organization.

The EOF has space allocated for housing emergency personnel and space for NRC, FEMA and state/county emergency personnel. The EOF has various communications links available as described in Table 3 and Section 7.2. The EOF is staffed and activated for an Alert or higher level emergency classification. The EOF also has ERFDADS data displayed through PI computer capability. The capability exists in the EOF to rapidly retrieve plant documents, drawings, procedures and plans.

7.1.7 ALTERNATIVE FACILITY The EEC-EOF is designated as the Alternative Facility for staging of ERO personnel. In the event of a Security or Hostile Action Based threat or event, the EEC-EOF may also serve as a re-location area for TSC and OSC personnel. The Alternative Facility has the capabihty to communicate with the Control Room, Security and the EOF. The EOF may also be used as an Alternate facility for any event where site access is not possible i.e.

Beyond Design Bases External Event (BDBEE) or FLEX event.

7.1.8 JOINT INFORMATION CENTER (JIC)

The JIC, located at 600 North Verrado Way, Building A, Buckeye, Arizona, serves as the primary point for dissemination of information to the news media representatives for an Alert or higher emergency classification level.

Provision is made at the JIC to allow media personnel to communicate with their base facilities. State, county and federal agency officials share office space with the staff at the JIC.

The communications links available at the JIC are described in Table 3 and Section 7.2.

7.1.9 PALO VERDE AND APS EXTERNAL COMMUNICATIONS DEPARTMENTS Palo Verde Communications and APS External Communications are responsible for developing media statements and coordinating media briefings during Unusual Event classifications. At Alert and higher classification level, the JIC assumes the responsibihty for this function. At Alert or Site Area Emergency classifications involving non-radiological events, Palo Verde Communications will work with the JIC to coordinate plant visits and briefings. Palo Verde Communications is equipped with EPABX telephones and fax machines for onsite and offsite communications.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 59 of 332 7.1.10 STATE EMERGENCY OPERATIONS CENTER (STATE EOC)

The State EOC is the primaiy point from which the CJovemor/designee exercises overall coordination of offsite emergency response operations through the ADEM. The State EOC is located at ADEM Headquarters in Phoenix at 5636 East McDowell Road. Staffing of the State EOC consists of authorized representatives of:

Office of the (jovemor

Arizona Department of Emergency and Military Affairs (DEMA)

Arizona Division of Emergency Management (ADEM) ir :

Arizona Radiation Regulatory Agency (ARRA) f

Arizona Department of Public Safety (AZ DPS)

Arizona Department of Transportation (ADOT)

Arizona Department of Economic Security (AZ DES)

Maricopa Covmty Department of Emergency Management (MCDEM)

PVNGS (Utility Technical Representative)

Others (as notified/required).

PVNGS communications links with ADEM are described in Table 3.

7.1.11 THE MARICOPA COUNTY EMERGENCY OPERATIONS CENTER (EOC)

The Maricopa County EOC is the focal point of the local government emergency response activity. It is located at 5630 E. McDowell Road, Phoenix. Emergency response actions of the Maricopa Cormty Sheriffs Office, Health Depari;ment and Department of Transportation, together with emergency response actions of volimteer agencies, are coordinated by the MCDEM at the County EOC.

7.2 COMMUNICATIONS SYSTEMS The PVNGS communications system is designed to ensure the reliable, timely flow of information and action directives between all parties designated and empowered to mitigate emergencies. To ensure the reliabihty of the communications systems, the following provisions have been designed into these systems:

Redimdancy

Alternative radio communications

Telephone ring down circuits (voice and data) to offsite emergency organizations, to preclude delays due to system overload

Routine use of many of the systems, which lowers the probability of imdetected system failures

PVNGS EMERGENCY PLAN REVISION 59 PAGE 60 of 332 Communication systems are tested at the frequency specified by 10 CFR 50 Appendix E, as a minimum. Onsite emergency telephone lines are divided among three onsite EPABX switches. Each EPABX switch is provided with a backup battery for reliability.

This system will function during emergencies as it does during normal operations.

Telephones have the capability of trunk access (via local provider) and the APS owned private communications system which provides direct dial capabilities to the entire APS voice system via the company owned private communications system. The PVNGS telephone EPABX Systems through which all PVNGS telephone calls pass, are equipped with uninterruptible power supplies (battery chargers and batteries) and dedicated priority switching to ensure the rehability of the telephone system. The PVNGS EPABXs are the primary links for PVNGS phones. There are also administratively dedicated hnes for the CR, STSC, TSC, EOF, and OSC.

The CR, TSC, and OSC each have dedicated phone Unes that can be used to connect between any two of the facilities. In addition, each of these facihties can use these dedicated lines to connect to the following dedicated phones for the listed EOF positions:

Radiological Assessment Coordinator Environmental Assessment Line

Radiological Assessment Coordinator Control Room Line

Engineering Director Technical Line

Admin and Logistics Coordinator OSC Line

Radiological Assessment Commimicator TSC Line Each of the phones on the dedicated lines also functions as a normal in-plant PVNGS phone. These lines are discussed in more detail in the appUcable subsections that follow.

The EC/EOD Line, Maintenance Line, and Radiological Line are administratively dedicated hnes that are also available for use in an emergency and are discussed in the subsections that follow. The phones hsted below consist of single line and multi-hne phones. The multi-line phones are equipped with a power fail line and a PBX hne.

7.2.1 CONTROL ROOM LINE The Control Room Line has a dedicated primary line providing communications links with conference capability between the Control Room, the TSC, the Unit STSC, the EOF, the OSC, and the RSP.

7.2.2 ENVIRONMENTAL ASSESSMENT LINE The Environmental Assessment Line has a dedicated primary and backup line providing communications links with conference capabihty between the TSC, EOF, the Unit and the RSP.

7.2.3 EC/EOD LINE The EC/EOD line has a separate dedicated primary line with conference capabihty among the EOF, TSC, the Unit, and the RSP.

This hne provides a commimications link between the ECs. It also permits three-way conversations between the EC-TSC, EOD and the Shift Manager.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 61 of 332 7.2.4 EOF LINE The EOF Line has a dedicated primary line providing communications Unks with conference capability between the EOF, the Control Room, the TSC, the Unit STSC, the OSC, and the RSP.

7.2.5 MAINTENANCE CONTROL LINE The Maintenance Control Line has a dedicated primary line providing a communications link with conference capability between the TSC, OSC, Control Room, and RSP.

7.2.6 OSC LINE The OSC Line has an administratively dedicated primary line providing communications links with conference capability between the OSC, the Control Room, the TSC, the Unit STSC, the EOF, and the RSP.

7.2.7 RADIOLOGICAL LINE The Radiological Line has a dedicated primary line providing commimications links with conference capability between the RP Office, TSC, the Unit, the OSC, and the RSP.

7.2.8 STSC LINE l5. :

The STSC Line has a dedicated primary line providing communication links with conference capability between the Unit STSC, the Control Room, the TSC, the EOF, the OSC, and the RSP.

7.2.9 TECHNICAL LINE The Technical Line has a dedicated primary line providing communications links with conference capability between the TSC, the Unit STSC, the EOF, the RSP, and the Control Room.

7.2.10 TSC LINE The TSC Line has an administratively dedicated primary line providing communications links with conference capability between the TSC, the EOF, the Control Room, the Unit STSC, the OSC, and the RSP.

7.2.11 REMOTE SHUTDOWN PANEL (RSP) LINE The RSP Line has an administratively dedicated primary line providing commimications links with conference capability between the TSC, the EOF, the Control Room, the Unit STSC, and the OSC.

7.2.12 NRC EMERGENCY NOTIFICATION SYSTEM (ENS)

The NRC ENS is a Federal Telecommunications System (FTS) telephone that connects PVNGS with the NRC Headquarters Operations Center. NRC Headquarters has the capability to patch in the Region IV office on this line. It is to be used for reporting emergencies. Commercial telephone lines are available as backup communications.

Transmittal of operations related data should be on this system. The purpose of this line is to provide reliable communications with the NRC. The ENS phones are located at each Unit STSC, the TSC, and the EOF.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 62 of 332 7.2.13 NRC HEALTH PHYSICS NETWORK (HPN)

The NRC HPN is a Federal Telecommunications System (FTS) telephone that connects PVNGS with the NRC Headquarters Operations Center. The HPN is designed to provide health physics and environmental information to the NRC in the event of an emergency.

Other commercial telephone lines are available as backup communications. The HPN phones are located in both the TSC and EOF.

7.2.14 NRC LOCAL AREA NETWORK (LAN)

The NRC has a data link available as part of the FTS network in the EOF and TSC.

The lines are tested by PVNGS and maintained by the NRC.

7.2.15 NRC MANAGEMENT COUNTERPART LINK (MCPL)

The MCPL is a dedicated NRC communication link between the NRC in the EOF, TSC and NRC Headquarters personnel. The lines are tested by PVNGS and maintained by the NRC.

7.2.16 NRC PROTECTIVE MEASURES COUNTERPART LINK (PMCL)

The PMCL is a dedicated NRC communication link between the NRC in the EOF, TSC, and NRC Headquarters personnel. The lines are tested by PVNGS and maintained by the NRC.

7.2.17 NRC REACTOR SAFETY COUNTERPART LINK (RSCL)

The RSCL is a dedicated NRC communication link between the NRC in the EOF, TSC, and NRC Headquarters personnel. The lines are tested by PVNGS and maintained by the NRC.

7.2.18 EOD/CEO (FIBER OPTIC)

The EOD/CEO circuit is a fiber optic link between the EOF/JIC and the APS Executive Floor Corporate.

7.2.19 NOTIFICATION ALERT NETWORK (NAN)

NAN is a dedicated telephone/radio system that provides a communications link among the Unit STSCs, TSC, EOF, ADEM, ARRA, MODEM, MCSO, DPS, and Buckeye Police Dept.

NANs primary function is to provide a communications link for notifications to offsite agencies. In the event of NAN failiire, a channel on the APS Corporate radio system or the commercial phone lines is used to make initial notifications.

7.2.20 OPERATIONS #1 (HARDWIRED)

The Operations #1 circuit is a hardwired ring-down line with connections to the ADEM, ARRA, EOF, Unit STSC and the TSC.

7.2.21 OPERATIONS #2 (HARDWIRED)

The Operations #2 circuit is a hardwired ring-down line with connections to the ADEM, the EOF, and the TSC.

7.2.22 OPERATIONS #3 (FIBER OPTIC)

The Operations #3 circuit is a fiber optic ring-down line with connections to the ADEM, the EOF, and the TSC.

^ ^-.A. .w-

PVNGS EMERGENCY PLAN REVISION 59 PAGE 63 of 332 7.2.23 OPERATIONS #4 (FIBER OPTIC)

The Operations #4 circuit is a fiber optic ring-down line with connections to the ADEM, the AREA, the EOF, and the TSC.

7.2.24 PUBLIC INFORMATION RING-DOWN CIRCUIT #1 The PI #1 circuit is an intercom link from the EOF to the JIC.

7.2.25 PUBLIC INFORMATION RING DOWN CIRCUIT #2 The PI #2 circuit is an intercom link between the EOF to the JIC.

7.2.26 CELLULAR PHONE Each STSC, the TSC, and the EOF have a cellular phone to provide an additional independent line of communication.

7.2.27 FACSIMILE TRANSMISSION Facsimile transmission provides "hard copy" communications to:

TSC (through PVNGS EPABX)

EOF 1' .

Ring-down Facsimile Machine Circuits #1 (Fiber Optic) and #2 (Hardwire) link the EOF, TSC, STSCs, JIC, ADEM, AREA and APS Corporate Offices.

7.2.28 PVNGS RADIO SYSTEM PVNGS operates a tnmked radio system, with separate talk groups available for departments such as Operations, Security, Fire Protection, Radiation Protection, Emergency Preparedness, the Water Reclamation Facility, etc. This system includes base station consoles at various locations and emergency facilities throughout the site. Some of the radios used during emergencies are portable radios at various site locations, mobile radios in the RFAT vehicles, and base station consoles at the TSC, EOF, Unit OSCs, Unit, and Unit Control Rooms. PVNGS Fire Protection also maintains radios that are used to contact the air ambulance service to provide landing instructions.

7.2.29 TELEPHONE RDVGDOWN CIRCUITS These voice circuits serve as a primary communications Unk for providing technical information to offsite agencies, public information communications, and the communication of protective action recommendations to offsite authorities.

7.2.30 RADIOLOGICAL EMERGENCY ASSISTANCE TEAM (REAT) RADIO SYSTEM The APS Corporate 800 MHZ Radio system provides a communications link between the State and State deployed field monitoring teams. Field monitoring information will be transmitted over the radio system. The States EOF representative has access to the 800 MHZ radio system from the EOF. Hard copy of data is transmitted via FAX fi-om the EOF to REAT Forward.

7.2.31 MOBILE DEVICES Mobile devices are provided to key members of the emergency response organization.

This provides a reliable means of contact with key members 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day, 7 days a week.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 64 of 332 7.2.32 AREA PAGING SYSTEM The area paging system provides a reliable means of notifying and providing instructions to personnel. Access to this system is through the EPABX system telephones by use of dedicated numbers.

7.2.33 ALARMS Audible alarms are a quick and effective means of communicating emergency warnings. The alarm systems are described in the following sections.

7.2.33.1 Emergency Evacuation Alarm System / Public Address System / Area Paging System The Emergency Site Evacuation Alarm System consists of pole-mounted electronic outdoor warning sirens. They are located outside each power block and are provided to alert personnel within the security boundaries of PVNGS.

These sirens are initiated from a siren command module in each units control room. A microphone is provided to permit annomicements over this system.

Accountability/evacuation is assured in high noise work areas (>95 dB) by use of audible alarms, flashing lights and/or administrative measures.

The Public Address (PA) System consists of sirens and speakers that serve to alert personnel within a unit area. The Emergency Evacuation Alarm System consoles in the control rooms are used to send announcements to the PA system.

Telephones located inside and outside of the power block may also send announcements to the PA system. The Public Address System also has voice capability using microphone in each control unit, and is cross- connected to the Area Paging System to permit site-wide announcements.

There are distinct signals provided for assembly, evacuation, fire and all-clear.

7.2.34 NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION (NOAA)

WEATHER BROADCASTS Weather broadcasts can be monitored for "weather alert" information at CR, TSC and EOF.

7.2.35 AUTOMATED CALLOUT An automated callout system is used to call out emergency response personnel. The system can also be activated from any touch tone telephone with offsite access capability. The servers are located offsite at two different remote locations and can place multiple calls simultaneously. Telephone numbers to be contacted and notification messages are pre-programmed on the system. If proper acknowledgment does not occur, the system periodically redials the number.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 65 of 332 7.2.36 ADDITIONAL OFFSITE COMMUNICATION LINKS Communication Links in Addition to Those Described Above Include:

Public Information Unlisted Dial-up Telephone Circuit - ADEM to JIC High speed internet connections - JIC Public Information Unlisted Dedicated Dial-up Facsimile Machine Circuit #2 -

ADEM to JIC PVNGS Emergency Alert System (EAS) Ring-down Telephone Circuit - hardwire from MCDEM and MCSO to AM Broadcast Station KTAR and to FM Broadcast Station KPKX

.'J/.

Public Information Unlisted Dedicated Dial-up Telephones - JIC (4 general circuits)

Public Information Unlisted, Receive-only Telephone Circuits - JIC (6 circuits Public Information Media Dial-up Telephone Circuits - JIC (30 circuits)

Unlisted Dedicated Dial-up Facsimile - ADEM (EOC) to MCDEM Public Information Unlisted Dial-up Telephone Circuit - JIC to MCDEM ADEM Business Dial-up Telephone - ADEM general use (24 circuits), ADEM Pubhc Inquiry (3 circuits)

Public Information Unlisted Dial-Up Facsimile Machine Circuit - MCDEM to JIC t.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 66 of 332 Facility Communication and Data Links EOF Line Maintenance Line OSC Line RSP Line STSC Line Technical Line TSC Line i^ontroi Koom Radio Base Station ENS ERF ADS Fax Control Room Environmental EC Line EOF Line Line Line STSC OSC Line Radiological Line Technical Line TSC Line RSP Line NAN Line Ops #1 Ops #3 Cellular Phone ERFDADS Fax Radio Base Station Control Room Environmental STSC Line EOF Line Line Line Technical Support Maintenance Line OSC Line Radiological Line EC/EOD Line Center Technical Line RSP Line ENS NAN Line Ops #1 Ops #2 Ops #3 Ops #4 Radio Base Station HPN LAN (NRC)

MCPL (NRC) PMCL (NRC) RSCL (NRC) ERFDADS Fax Cellular Phone Control Room EOF Line Maintenance Line STSC Line Operations Line Support Center Radiological Line TSC Line RPS Line Control Room Environmental EC/EOD Line OSC Line Line Line Emergency STSC Line Technical Line TSC Line Operation Facility RSP Line HPN (NRC) ENS (NRC) LAN MCPL (NRC) PMCL (NRC) RSCL (NRC) EOD/CEO Line NAN Line Ops#l Ops #2 Ops #3 Ops #4 Public Info #I Public Info #2 Cellular Phone ERFDADS via PI Fax Radio Base Station REAT Radio Joint Information EOD/CEO Line Public Info #I Public Info #2 Fax Center Control Room Environmental EC/EOD Line EOF Line Line Line SIMA Maintenance Line OSC Line Radiological Line Technical Line TSC Line RSP Line NAN Line Ops #2 Ops #4 ERFDADS via PI Fax Radio Base Station ENS Control Room Environmental EC/EOD Line EOF Line Line Line Sound-powered Remote Shutdown phone Panel (RSP)

Maintenance Line OSC Line Radiological Line STSC Line Technical Line TSC Line Radio Base Station NAN Line Ops #1 Ops #2 Ops #3 ADEM Ops #4 Fax REAT Radio Radio Base Station NAN Line Ops#l Ops #4 Fax ARRA REAT Radio Radio Base Station DPS NAN Line Radio Base Station MCDEM NAN Line Radio Base Station MCSO NAN Line Radio Base Station Buckeye PD NAN Line Radio Base Station TABLE 3 - EMERGENCY RESPONSE FACILITY COMMUNICATIONS

PVNGS EMERGENCY PLAN REVISION 59 PAGE 67 of 332 7.3 ASSESSMENT EQUIPMENT This section describes onsite and offsite facilities and monitoring equipment used for initial and continuing assessment.

7.3.1 ONSITE SYSTEMS AND EQUIPMENT Onsite equipment is described below.

7.3.1.1 GEOPHYSICAL DATA (1) Meteorology Proyram The PVNGS meteorology atmospheric transport and diffusion assessment program has been established using the guidance of NUREG-0654 and Regulatory Guide 1.23, Rev. 0. The PVNGS meteorological tower has the following instrumentation: temperature, differential temperature (between top and bottom sensors), precipitation, dew point, wind speed, and wind direction. Display of meteorological indications is available in the Control Room on ERFDADS. Precipitation data is available in the STSC via a modem connected to the MET Tower. MET data is available in the TSC, the Units STSC, and the EOF. In the event the PVNGS meteorological monitoring system is unavailable. National Weather Service broadcasts can be monitored from the Control Rooms, EOF, and TSC. Meteorological data can be obtained from the National Weather Service in the event that PVNGS instrumentation is insufficient or out of service during an emergency.

(2) Seismic Instruments Information is obtained from passive and active instruments giving absolute peak ground acceleration in three mutually orthogonal directions. The system determines whether operating basis or safe shutdown maximum accelerations are exceeded in any of three directions.

Recorded information is available in the Unit 1 Control Room.

7.3.1.2 RADIATION MONITORING SYSTEM (RMS)

The Radiation Monitoring System is divided into three basic groups of detector systems.

(1) Process Monitoring System Process monitors provide information to Control Room operators to assure proper functional performance of the monitored system, provide for the early detection of radioactive leakage into non-radioactive systems, provide continuous remote indication and recording of airborne radioactivity levels in areas where personnel have routine access, and provide a means of process sample collection.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 68 of 332 (2) Effluent Monitoring System The Effluent Monitoring System provides continuous sampling, recording and indications of gaseous activity levels and, as a minimum, provides continuous representative sampling of particulate and radioiodine activity levels at principal effluent discharge points, provides for monitoring, alarm annunciation, and automatic closure of the gaseous waste discharge valve to maintain releases from the waste gas decay tanks below ODCM limits, provides radiation level indication and alarm annunciation to Control Room operators whenever Technical Specification hmits are approached or exceeded, and provides a means for collection of samples for laboratory analyses at effluent points.

(3) Area Monitoring System The area monitoring system immediately notifies plant personnel entering or working in non-radiation or low-radiation areas of abnormally high or increasing radiation levels to prevent inadvertent overexposure, and informs Control Room Operators of the occurrence and location of abnormal radiation level increases in non-radiation or low-radiation areas.

7.3.1.3 SYSTEM MONITORS These monitors detect and/or control problems within plant systems and include pressure detectors, heat detectors, heat rise detectors, or similar devices designed to monitor plant parameters. Many of these detectors are capable of initiating control actions to prevent and mitigate damage or release of radioactive material.

7.3.1.4 FIRE PROTECTION SYSTEM The Fire Protection System (FPS) and Fire Suppression System (FSS) detect, contain, and extinguish fires in the unit. The FPS for each unit has monitoring, detection, alarm, suppression, and extinguishing facilities specifically selected to protect the area or equipment from damage by fire.

A computer terminal is provided in the Control Room of each unit for incoming FPS/FSS alarms (including identification of affected areas and suppression actions initiated by the FSS system).

7.3.1.5 RADIOACTIVITY ANALYSIS Liquid samples are drawn in the individual Units via the Nuclear Sampling System. A built-in sample bomb is in each primary sample sink.

Containment air samples are taken via Containment Air Monitor XJSQBRU0001**INTCPM.

Grab samples are drawn and diluted as necessary, utilizing procedural direction to minimize operator dose. The grab samples are analyzed in the radiochemistry laboratory via a gamma energy anal5dical detector system.

In the event the affected unit cannot perform the analysis, backup analysis is done in one of the unaffected units. The Arizona Radiation Regulatory Agency is equipped to do isotopic analysis as an offsite backup to PVNGS capabilities.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 69 of 332 7.3.1.6 PORTABLE SURVEY INTRUMENTS These instruments provide flexibility and backup capabibty for radiation measurements in areas not served by installed monitors, or where installed monitors may be inoperative.

7.3.1.7 EMERGENCY RESPONSE FACILITY DATA ACQUISITION AND DISPLAY SYSTEM (ERFDADS)

The ERFDADS provides a centralized location within the CR for display of plant parameters from which the safety status of operations can be assessed.

Displays of data, including graphical displays, available on demand include plant temperatures, pressures, and flow rates; equipment and valve status, i.e., on, off, open, closed; process and area RMS readings; meteorology system data; and in-core parameters.

In addition to the above parameters, the SPDS portion of ERFDADS contains a graphical display which provides immediate indication of deviation from safe operating values. From this display, additional specific data concerning the system in question is accessed on demand.

The ERFDADS is designed to include the data acquisition system requirements of NUREG-0696. ERFDADS displays are available at each Unit Control Room, each Unit STSC and the TSC. ERFDADS displays are available in the EOF via PI displays.

7.3.1.8 QUALIFIED SAFETY PARAMETER DISPLAY SYSTEM (QSPDS)

The QSPDS is designed to provide indications to detect the approach to, the existence of, and the recovery from inadequate core cooUng. It also provides a minimum set of seismically qualified parameters from which abnormal plant operating conditions may be quickly assessed.

7.3.1.9 EMERGENCY RESPONSE DATA SYSTEM (ERDS)

The ERDS is a direct electronic transmission system to NRC Operations Center. The system is intended to provide to the NRC, on a near real-time basis, selected parameters from plant computer systems whose values indicate the condition of the plant during an emergency condition of Alert or higher. ERDS is tested quarterly to verify system availability and operability.

Any hardware or software changes that affect the transmitted data points identified in the ERDS data point library, must be submitted to the NRC within 30 days after changes are completed. Hardware or software changes that could affect the transmission format and computer communication protocol to the ERDS must be provided to the NRC as soon as practicable and at least 30 days prior to the modification.

7.3.2 OFFSITE SYSTEMS AND EQUIPMENT The Offsite Dose Calculation Manual (ODCM) refers to the location of the environmental radiological monitoring sampling stations, as well as Thermoluminescent Dosimeter (TLD) stations. Environmental samples routinely collected and analyzed include: water, vegetation, food products and milk. Backup and cross-check environmental surveillance are performed by ARRA.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 70 of 332 PROTECTIVE FACILITIES AND EQUIPMENT Control Room shielding and ventilation allow personnel habitability during Design Basis Accident conditions. The TSC has shielding and ventilation similar to the CR for habitability during an incident. Communications equipment, respiratory protection equipment and protective clothing are available in, or near the CR, STSC, TSC, and OSC. Portable radiation monitoring instnimentation is located near the unit RP Islands.

FIRST AID AND MEDICAL FACILITIES A first aid treatment center is maintained onsite. In addition, a first aid room is located in each unit at the 140-foot level of the Auxiliary Building. First aid treatment of injured individuals is administered by trained personnel. Advanced medical care, if required, is obtained by transporting the individuals to an offsite medical facility.

DAMAGE CONTROL EQUIPMENT AND SUPPLIES Fire hose stations, extinguishers and hydrants are strategically located throughout the station for use in fire. PVNGS maintains self-contained breathing apparatus storage areas throughout station to be used for firefighting, entry into airborne radioactivity areas, or entry into toxic gas areas.

7.7 PROMPT NOTIFICATION SIREN SYSTEM PVNGS maintains the Prompt Alert and Notification Systems as approved by FEMA in the PVNGS Alert and Notification System (ANS) FEMA 350 Report dated July 2014.

The Prompt Notification Siren System consists of high sovmd output sirens located throughout the 10-mile Plume Exposure Pathway Emergency Planning Zone. Its operation is at the discretion of the state and coimty governmental agencies responsible for notification and alerting of the public. This system alerts the people within the 10-mile EPZ to monitor radio or TV emergency broadcasts for specific information regarding the situation at PVNGS and/or protective actions. This system is operated from any of the four control point locations:

Maricopa Coxmty Emergency Operations Center

Arizona Department of Pubhc Safety

M^u^copa County Sheriffs Office

Building E Normally the sirens are activated from the Maricopa County Emergency Operations Center or from the Maricopa County Sheriffs OfBce. The system is tested periodically to ensure its readiness.

In the event of a failure of the Prompt Notification System, a FEMA approved backup notification method is available and is implemented by Offsite Response Organizations.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 71 of 332 8.0 MAINTAINING EMERGENCY PREPAREDNESS 8.1 ORGANIZATIONAL PREPAREDNESS The emergency preparedness program consists of (1) ERO training, (2) drills and exercises, and (3) regular emergency plan review and evaluation by personnel and management.

8.1.1 TRAINING The Emergency Response Training Program ensures that personnel who are in the emergency response organization are familiar with the contents and responses in the Emergency Plan and associated implementing procedures. The Emergency Preparedness Manager is responsible for ensuring that the Emergency Response Training Program meets the requirements of the Plan. Non-ERO employees receive general information on emergency preparedness annually.

Personnel assigned key duties in the Emergency Response Organization receive initial training and annual continuing training.

New personnel or existing ERO members assigned to fill an ERO position in which they have not previously qualified, complete initial and continuing training for that position.

Emergency Preparedness Training is developed using a process similar to that described within the Nuclear Training Department Administrative Procedimes or other approved training program guidance.

As necessary, additional continuing training of individuals should be conducted when significant changes to the Emergency Preparedness Program occurs as determined by the Emergency Preparedness Manager and the Nuclear Training Department Leader.

The Emergency Response Training Program includes specific training and indicates, where applicable, quahfication requirements for key members of the Emergency Organization.

Evaluated training drills and evolutions provide for critiques in order to identify weak or deficient areas. Weaknesses or deficiencies that are identified are corrected.

Training for the Emergency Preparedness Staff is completed in accordance with Emergency Preparedness Department processes.

8.1.1.1 Site Access Training for Emergency Preparedness Personnel requiring unescorted access into the Protected Area(s) receive general instructions on the Emergency Plan as part of training prior to receiving tmescorted access. Continuing training is conducted annually.

8.1.1.2 Specialized Training for Key Emergency Organization Personnel Specialized trairung is provided annually to key personnel involved in emergency response actions. This special training includes instruction £md review in the technical and practical aspects of emergency response actions.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 72 of 332 In addition to training, drills and exercises are conducted to develop and maintain emergency response skills. Specialized training for designated ERO position categories is listed below.

Directors and/or Coordinators of the Plant Emergency Organization Initial training to provide for classification and notification processes and requirements. Continuing training to provide program/procedure/equipment change and industry events updates.

Personnel Responsible for Accident Assessment. Including CR Shift Personnel Initial training to provide accident identification, appropriate procedural responses and support organization activity on criteria. Continuing training provides program/procedure/equipment change and industry events updates.

Radiological Monitoring Teams Initial training to provide for emergency radiological monitoring procedures, techniques and emergency communications. Continuing training to provide program/procedure/equipment change and industry events updates.

Fire Control Teams (Fire Brigades)

PVNGS utilizes a full time onsite Fire Department. Fire personnel are trained in fire and medical emergency response in accordance with the Fire Protection Program.

Additionally they are provided training in basic radiological control concepts.

Continuing training to provide program/procedure/equipment change and industry events updates.

Repair and Damage Control Teams Initial training provides for emergency radiological and industrial safety, communications. Continuing training to provide program/procedure/equipment change and industry events updates.

First Aid and Rescue Teams PVNGS utilizes a full time onsite Fire Department. Fire personnel are trained in fire and medical emergency response in accordance with the Fire Protection Program.

Additionally they are provided training in basic radiological control concepts.

Contintung Training to provide program/procediu-e/equipment change and industry events updates.

Medical Support Personnel Initial training of medical support personnel in addition to Fire Department personnel provided with basic radiological control concepts. Onsite medical staff, excluding administrative support personnel, receives training similar in content to that which is provided to offsite hospitals. Continuing Training to provide program/procedure/equipment change and industry events updates.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 73 of 332 Licensee's Headquarter Support Personnel Some headquarters support personnel respond to the Joint Information Center. These personnel receive initial training prior to qu2ilification. Continuing training is provided on an annual basis.

Security Personnel Emergency response training is incorporated into the initial Member of the Security Force training received by new security force members during initial qualifications.

Additional initial training is provided to Security members assigned to staff positions within the Emergency Response Facilities in support of Emergency Preparedness.

The additional training includes lines of communication with offsite support organizations as well as logistics support. Continuing training to provide program/procedure/equipment change and industry events updates.

Offsite Organization Training As appropriate, training for the members of selected offsite support organizations shall occur on an annual beisis.

Briefings are specific to the agencies response assignment(s) and, at a minimum, include the following; Basic radiation protection Emergency response procedures Interface with the PVNGS Emergency Response Organization Lesson Plans and examinations are not required for offsite support organization training. PVNGS maintains records associated with offsite support organization training. A radiological orientation training program is made available to local services personnel; e.g., local emergency services/MCDEM, local law enforcement personnel, local news media persons.

8.1.1.3 Training for Participating Agencies Training for participating agencies is provided by the individual agencies. Training personnel are available to describe the special conditions and constraints involved in dealing with PVNGS emergency radiological release situations. Radiological orientation continuing training is available annually for local services personnel, including local news media personnel.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 74 of 332 8.1.1.4 Public Education PVNGS, ADEM, AREA, and MODEM jointly prepare an educational calendar for distribution to the public within the Plume Exposure Pathway EPZ. The calendar is mailed annually to residents within a 10-mile radius of the station, using postal procedures that ensirre maximum distribution. The calendar outlines, in lay language, the stations operational concept, lists the various classifications of emergencies, summarizes the emergency plan developed to safeguard the general public, reviews appropriate protective actions including Potassium Iodide (KI), and indicates pubhc warning signals. The calendar also contains material on radiation, contacts for additional information and means for advising governmental authorities about special needs of EPZ residents.

In addition to this written material, PVNGS conducts public information seminars and meetings as needed or requested with local groups within the 10-mile EPZ. Local groups may be invited to participate in drills and exercises to maintain emergency preparedness and to test specific segments of emergency plans and procedures that are affected by, or may affect, 10-mile EPZ residents.

Methods are also established to provide emergency and protective information to the transient population within the PVNGS 10-mile EPZ. Inserts are placed in telephone books. Information is posted in local stores, businesses, schools, churches, post offices, truck stops, and recreational vehicle parks.

8.1.1.5 Media Familiarization Annual programs are provided to acquaint media personnel with the PVNGS Emergency Plan, information concerning basic nuclear plant operation and radiation, and the locations and means employed to disseminate public emergency information.

8.1.1.6 Documentation All emergency preparedness training is documented and training records are maintained in accordance with established procedures.

8.1.2 EXERCISES PVNGS conducts drills and exercises over a wide range of accident conditions that tests a major portion of the basic elements existing within the emergency plan and supporting organizations. Exercises shall test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communications networks, test the public notification system, and ensure that emergency organization personnel are familiar with their duties.

The scenarios for the drills and exercises are diverse and include a wide spectrum of radiological conditions and events including hostile actions. The scenarios used over the eight year cycle will be sufficiently varied to ensure that essentially all of the emergency action levels are included in performance enhancing drills or exercises.

To the extent practical, initiating conditions and failed equipment should be varied to minimize preconditioning of the emergency response organization.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 75 of 332 No more than one EAL should be shared with the previous exercise or any practice drill or exercise leading up to the biennial exercise. Drill scenarios should not be used for any biennial exercise within two years. To the extent practical, scenario should be held in confidence from the participating ERO team members until after the exercise. While an ERO team may be aware of the nature of the upcoming drills (i.e. hostile action based exercise), the specific elements of the drill should be held in confidence and the initiating event varied so the same conditions are not used from the practice to evaluated exercise.

Joint participation exercises between PVNGS and the offsite response agencies are conducted to ensure the appropriate integration of the emergency plans and identify areas of weakness and opportunities for improvement. A post drill or exercise critique is conducted to aid in the identification of weaknesses and improvement opportimities. Consistent with NRC and FEMA regulation, a full participation exercise is conducted once every two years, PVNGS, the State of Arizona (ADEM and ARRA) and Maricopa County will jointly exercise their emergency plans. The full participation biennial exercise is evaluated by the NRC and FEMA and is used in determining reasonable assurance that PVNGS and the supporting offsite emergency plans can protect the health and safety of the public, plant staff and emergency workers. The biennial exercises are varied over the eight year period (starting with the year of the first hostile action exercise in 2015) to include the following; Hostile action directed at the plant site involving the integration of offsite resources with onsite response; (See RCTSAI 2831902 and contact Reg. Affairs for any change to this commitment.)

An initial classification of, or rapid escalation to, a Site Area Emergency or General Emergency; No radiological release or an unplanned minimal radiological release that requires the site to declare a Site Area Emergency, but does not require declaration of a General Emergency.

Ingestion Pathway Exercise PVNGS will submit the scenario used for the biennial exercise to the NRC in accordance with 10CFR50.4 sixty (60) days before its use in a full scale biennial exercise. The scenario will be held in confidence until after the exercise is completed.

PVNGS will maintain adequate records to demonstrate the exercises and scenarios used over the eight year exercise cycle.

Each biennial exercise conducted by PVNGS will include the opportunity to demonstrate the following key skills:

Timely classification of events; Timely notification of offsite authorities; Assessment of radiological releases onsite and offsite; Development of protective action recommendations; Dissemination of information to the public via media channels; Engineering assessment, repair plan development, and repair of critical equipment under emergency conditions;

PVNGS EMERGENCY PLAN REVISION 59 PAGE 76 of 332 Mitigative action implementation; Protection of workers during emergency response, including medical care; Response to operational transients while implementing the emergency plan; Coordination with offsite response organizations.

Each biennial exercise at PVNGS will include the following elements at a minimum:

Event classification.

Timely notification of offsite authorities.

PAR development (development of PARs involving public evacuation or sheltering is required only in exercises that include a General Emergency).

Radiological assessment.

Shift staff response to accident transients or other events that meet EAL criteria while implementing the emergency plan.

ERO response and ERF activation following declared emergencies.

Integration of Ucensee response with OROs to include briefings, coordination of worker protection, and, as appropriate to the scenario, coordination of public protective actions, radiological release monitoring, and offsite response to the site.

Communications that support response between onsite and offsite ERFs.

Dissemination of information to the public via media channels and press briefings.

Development and implementation of radiological or physical protection (i.e., in response to hostile action) protective actions for onsite workers as appropriate to the scenario.

Operational and engineering assessment of accident sequences.

Accident mitigation through the simulated repair of equipment.

o This must include mechanical, electrical, and/or instrumentation and control activities.

o The scenario should be designed to allow some repairs to be successful, but must provide the opportunity to demonstrate mitigation planning and repair execution.

Radiological control activities must support some repair teams.

In addition to the biennial exercise, PVNGS conducts a partial scale off year exercise that involves an integrated testing of the key emergency response facilities. The off year exercise may also be a full scale exercise not evaluated by FEMA or NRC. During the off year exercise, the offsite response organization will be encouraged to participate in order to maintain key ERO skills between the onsite and offsite organization.

The principal functional areas of emergency response include activities such as management and coordination of emergency response, accident assessment, event classification, notification of offsite authorities, and assessment of onsite and offsite impact of radiological releases, protective action recommendation development, protective action decision making, plant system repair and mitigative action implementation.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 77 of 332 During routine drills, activation of all of the PVNGS emergency response facilities (Technical Support Center (TSC), Operations Support Center (OSC), and the Emergency Operations Facility (EOF)) would not be necessary, PVNGS may use these drills for the opportunity to consider accident management strategies, supervised instruction, operating staff in all participating facilities would have the opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills may focus on the onsite exercise training objectives in lieu of a broader set.

The PVNGS ERO shall be provided the opportunity to develop and maintain key emergency response skills in response to the following scenario elements during the conduct of biennial exercises over the coimse of the eight year exercise cycle:

Response to hostile action, including interface with LLEAs.

o Hostile action scenarios should realistically include collateral damage that may occur (e.g., loss of offsite power and loss of use of certain onsite facilities and areas).

o Engineering assessment, repair plan development, and simulated repair of critical equipment damaged by hostile action after the active attack, but before the site is fully secured by LLEAs.

o Prioritization of repair team dispatch and protection in the aftermath of hostile action through coordination with site security and LLEAs to determine when the site is secure enough to allow limited movement of personnel.

Response to one scenario with no radiological release or an unplanned minimal radiological release that does not require evacuation or sheltering of the public.

Response to scenarios with radiological releases that require evacuation and/or sheltering of the public.

Response to a scenario that begins with a Site Area Emergency or General Emergency, or escalates rapidly (within 30 minutes) to a Site Area Emergency or General Emergency.

!

The successful simulated repair of simulated damaged equipment to prevent or mitigate core damage, reactor pressure boundary loss, and/or containment loss.

Demonstration of the abihty to mitigate an accident caused by hostile action or other initiators, through the simulated use of equipment, procedures, and strategies developed in compliance with 10 CFR 50.54(hh)(2).

All PVNGS ERO teams (not necessarily each individual) shall be provided the opportunity to develop and maintain key emergency response skills within the scope of their duties during each exercise cycle. Additionally, the ERO (not necessarily each ERO team) shall be provided the opportunity to demonstrate key skills in response to the following scenario elements in drills or exercises during each exercise cycle. Drills are considered to be performance-enhancing experiences (exercises, drills, functional drills, tabletop drills, mini-drills, etc.) that reasonably simulate the interactions between appropriate ERFs and/or individuals that would be expected to occur during emergencies.

All functions in each ERF (e.g., all ERFs that are responsible for dose assessment perform those duties in response to a radiological release).

PVNGS EMERGENCY PLAN REVISION 59 PAGE 78 of 332 Use of alternative facilities to stage the ERO for rapid activation during hostile action.

Real-time staffing of facilities during off-hours (i.e., 6:00 p.m. to 4:00 a.m.).

Some drills or exercises should be imannounced.

Providing medical care for injured, contaminated personnel (every two years).

Response to essentially 100 percent of initiating conditions identified in the site emergency plan implementing procedure for classification of emergencies.

Response to actual industry event sequences appropriate for the nuclear plant technology (e.g., BWR or PWR).

All Ucensee ERO teams must be provided the opportunity to demonstrate key skills within the scope of their duties.

Use of procedures developed in response to an aircraft threat and in compliance with 10 CFR 50.54(hh)(l).

Use of the strategies associated with 10 CFR 50.54(hh)(2) to mitigate spent fuel pool damage scenarios (all strategies, such as makeup, spray, and leakage control, but not every variation of a given strategy).

Use of the strategies associated with 10 CFR 50.54(hh)(2) to mitigate reactor accidents and maintain containment (7 strategies for pressurized water reactors, but not every variation of a given strategy).

Certain drills (i.e., fire, and medical emergency), and tests (i.e., communications and notification), are coordinated with offsite participating agencies. The Emergency Preparedness Manager has overall responsibiUty for meeting all drill requirements.

Specific tasks may be delegated to operating departments.

Communications links and notification procedures with offsite state and county agencies are tested periodically using a simulated emergency message transmitted offsite for subsequent fan-out alerting by state/county authorities. NRC communications links are tested in accordance with 10CFR50, Appendix E.

Communications tests also evaluate the understanding of the content of the messages.

PVNGS conducts the following drills:

Fire drills are conducted in accordance with the PVNGS Updated Fined Safety Analysis Report (UFSAR) and Fire Protection Program.

Health Physics (HP) Drills are conducted semi-annually, and may be in connection with exercises or Environmental Monitoring Drills. These drills involve response to, and analysis of, simulated elevated radioactivity in airborne samples and direct radiation measurements in the plant.

Medical Emergency Drills with Offsite Medical Facilities involving treatment of a simulated externally contaminated person are conducted annually with provision for participation by an offsite ground or air ambulance.

Environmental Monitoring Drills are conducted annually for both onsite and offsite Environmental Team personnel. These drills include collection and analysis of appropriate sample media, e.g., vegetation, soil, and air, communications, and record keeping. Since PVNGS is located in a desert area and there are no nearby bodies of water, liquid environmental samples are not collected or analyzed during Radiological Monitoring or Health

PVNGS EMERGENCY PLAN REVISION 59 PAGE 79 of 332 Physics drills. These drills are coordinated with offsite organizations where appropriate.

Following exercises and drills, a critique is held to identify deficiencies, weakness, and improvement opportunities. Deficiencies and weaknesses will be corrected and improvement opportunities will be incorporated as deemed appropriate by the Emergency Preparedness Manager. Critiques shall use the Palo Verde Condition Reporting process for capturing items identified during drills and exercises.

Remedial exercises will be required if the emergency plan is not satisfactorily tested during the biennial exercise, such that NRC, in consultation with FEMA, cannot find reasonable assurance that adequate protective measmes can be taken in the event of a radiological emergency. The extent of state and county participation in remedial exercises must be sufficient to show that appropriate corrective measures have been taken regarding the elements of the plan not properly tested in the previous exercise.

8.1.3 DRILLS Drills for the emergency organization are conducted periodically to test response and familiarity with implementing procedures and methods, to test emergency equipment, and to ensure that members of the emergency organization are familiar with their duties and develop and maintain key skills.

Instructional emergency drills are conducted as scheduled, with emphasis placed upon orderly implementation of activities prescribed within the Emergency Plan and its implementing procedures.

Drill performance is critiqued by personnel acting as drill controllers who may offer on-the-spot corrections to erroneous performance. Each controller is assigned a specific area for evaluation and receives written drill instructions. Written evaluations of drill performance are provided to appropriate management personnel.

Follow-up action is then taken by the responsible Department Leaders to upgrade areas where shortcomings are noted; they report their progress to the Emergency Preparedness Manager.

Following all drills, a drill controller critique is held and all aspects of drill performance are discussed. All significant deficiencies are incorporated into action items and tasked to the affected department.

Certain drills (i.e., fire, and medical emergency), and tests (i.e., communications and notification), are coordinated with offsite participating agencies. The Emergency Preparedness Manager has overall responsibility for meeting all drill requirements.

Specific tasks may be delegated to operating departments.

Communications links and notification procedures with offsite state and county agencies are tested periodically using a simulated emergency message transmitted offsite for subsequent fan-out alerting by state/county authorities. NRC communications links are tested in accordance with 10CFR50, Appendix E.

Communications tests also evaluate the understanding of the content of the messages.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 80 of 332 Fire drills are conducted in accordance with the Fire Protection Program and PVNGS Updated Final Safety Analysis Report (UFSAR).

Health Physics (HP) Drills are conducted semi-annually, and may be in connection with exercises or Environmental Monitoring Drills. These drills involve response to, and analysis of, simulated elevated radioactivity in airborne samples and direct radiation measurements in the plant.

Medical Emergency Drills with Offsite Medical Facilities involving treatment of a simulated externally contaminated person are conducted annually with provision for participation by an offsite ground or air ambulance.

Environmental Monitoring Drills are conducted annually for both onsite and offsite Environmental Team personnel. These drills include collection and analysis of appropriate sample media, e.g., vegetation, soil, and air, communications, and record keeping. Since PVNGS is located in a desert area and there are no nearby bodies of water, hquid environmental samples are not collected or analyzed during Radiological Monitoring or Health Physics drills. These drills are coordinated with offsite organizations where appropriate.

8.1.4 SCENARIOS Drill and exercise scenarios are written to allow a certain amoimt of free play for decision making. Controllers are instructed at pre-drill and pre-exercise briefings as to which portions of the scenario permit free play and which portions require strong controller management. The Emergency Preparedness Manager is responsible for k' overall drill and exercise control.

A 8.2 ORGANIZATION FOR MAINTAINING EMERGENCY PREPAREDNESS The Executive Vice President Nuclear & Chief Nuclear Officer has overall responsibility and authority for all nuclear activities, including emergency response planning. The Emergency Preparedness Manager has been assigned the responsibility to develop and maintain a coordinated PVNGS, Federal, State, and local government emergency preparedness program. The Emergency Preparedness Manager participates in meetings, seminars, and conferences that are aimed at maintaining a current and accurate Emergency Plan, and current knowledge of regulations and guidelines. The Emergency Preparedness Manager is responsible for the Emergency Plan, and implements Plan revisions and updates.

8.3 REVIEW AND UPDATING OF THE EMERGENCY PLAN The Emergency Plan is reviewed annually and updated as needed. The update takes into account changes identified by drills and exercises. The Emergency Preparedness Manager maintains documentation substantiating the annual review. Special attention is devoted to reviewing PVNGS/govemmental agency interfaces, updating offsite response agreements, maintaining effective communication channels, and, on a quarterly basis, ensuring up-to-date contact and notification lists. Liaison with state and local agencies ensures uniform updating. Independent audits/reviews by individuals who have no direct responsibihty for the implementation of the Emergency Preparedness Program are conducted at least once every 24 months using the performance-based option permitted by 10 CFR 50, Appendix E and 10 CFR

PVNGS EMERGENCY PLAN REVISION 59 PAGE 81 of 332 50.54(t), or more frequently when necessary to meet these regulations.

The Emergency Preparedness Manager is responsible for ensuring that EPIPs are updated and revised as necessary.

Emergency Plan revisions and changes are conducted lAW PVNGS Administrative Policies and Procedures. Plan changes will be reviewed for any reduction in effectiveness per 10CFR50.54 (q).

The revised Emergency Plan and procedures are handled lAW document control procedures. Changes to the Emergency Plan and procedures are approved by the Emergency Preparedness Manager, or designated alternate, and transmitted to the Executive Vice President Nuclear and Chief Nuclear Officer, and to the Offsite Safety Review Committee. Changes to the Emergency Plan shall be submitted to the NRC within 30 days of such changes.

MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT AND SUPPLIES Quarterly inspections of the operational readiness of emergency equipment and supplies are conducted by the Emergency Preparedness Department. Deficiencies noted during inspections are corrected. The use of inspection procedures with checklists and follow-up actions ensures that equipment is ready for use. Sufficient reserves of instruments/equipment are maintained to replace those undergoing calibration or repair. Calibration of equipment is conducted at intervals set forth in the UFSAR. In addition, planned use of coromunications, first aid, firefighting, and radiation measuring equipment during scheduled drills further ensures the availability and operabihty of emergency equipment.

9.0 RECOVERY Recovery operations include long term post-emergency efforts that follow a major incident. These operations are performed by station personnel, contract experts and specialists, and qualified engineers under the direction of the recovery organization.

Post-accident recovery actions are designed to identify the extent of plant damage, prepare specific plans and programs for station repair and restoration, implement recovery plans and programs, and return the plant to a normal operating status.

The following plant status conditions serve as general guidelines for decisions on the initiation of post-emergency recovery efforts:

Radiation levels are stable or decreasing with time

Releases of radioactive materials to the environment have ceased or are controlled within permissible hcense limits Fire or similar emergency conditions no longer constitute a hazard to the plant or station personnel

Measures have been successfully instituted to correct or compensate for malfunctioning equipment.

Based on consideration of these criteria, as well as other pertinent items, the EOD determines when to activate the recovery organization. Manpower and equipment

PVNGS EMERGENCY PLAN REVISION 59 PAGE 82 of 332 resources supporting the individual functional segments of the recovery organization may vary according to the severity of damage and specific situational needs.

Entering into recovery will not necessarily result in de-escalation of the emergency classification in that, the loss of a fission product barrier may not be recoverable until recovery is complete. Entering into recovery denotes the plant is stable and further degradation is unlikely. Repair and restoration of plant systems will be needed to fiilly exit the recovery phase.

RECOVERY ORGANIZATION The responsibilities and functions of the Recovery Organization Managers are summarized as follows:

The Recovery Manager has overall corporate responsibility for restoring the station to a normal operating configuration.

The Station Operations Manager manages day-to-day inplant operations and, during recovery, is responsible for ensuring that repairs and modifications optimize post-recovery plant operational effectiveness and safety.

The Nuclear Support Manager focuses necessary engineering, design, and construction resources on those aspects of plant recovery requiring redesign, modification, or new construction; directs and coordinates NSSS and Balance-of-Plant (BOP) engineering and construction/repair work.

The Radiological Services Manager develops plans and procedures to process and control liqmd, gaseous, and solid wastes to minimize adverse effects on the health and safety of the pubUc and station recovery personnel. In addition, the Radiological Services Manager coordinates the activities of staff Radiological Engineers and radiation protection personnel engaged in waste treatment operations.

The Technical Support Manager provides analyses, plans, schedules, and procedures in direct support of plant operations.

The Quality Assurance Manager assures that the overall conduct of recovery operations is performed in accordance with corporate poUcy and rules and regulations governing activities which affect public health and safety.

The Planning/Scheduhng Manager prepares plans and schedules, and tracks/expedites recovery operations.

The Administrative/Logistics Manager supphes administrative, logistic, communications, and personnel support for the recovery operation.

PVNGS Communications coordinates the flow of media information concerning recovery operations.

9.2 RECOVERY EXPOSURE CONTROL The Recovery Manager, via the Recovery Organization, is responsible for evaluating the advisability of initiating recovery and reentry. Information on existing conditions, interviews with employees evacuated during the emergency, regulatory exposure

PVNGS EMERGENCY PLAN REVISION 59 PAGE 83 of 332 guidelines, and counsel from recognized experts are used to formulate decisions on reentry and recovery.

During recovery operations, actions are preplanned to limit exposures. Access to areas is controlled and exposure to personnel documented.

Estimates of total population dose are available if any releases are required or occur during recovery operations.

9.3 RE-ENTRY If a site evacuation is ordered, re-entry to the site is controlled in accordance with estabhshed procedures. Respiratory protection equipment, protective clothing, and thyroid blocking agent are maintained onsite for the use of individuals remaining or arriving onsite before, during, or after the emergency.

10.0 AGREEMENT LETTERS This section Usts written agreements referring to the concept of operations developed between Federal, State, and local agencies and other support organizations having an emergency response role within the EPZ. Original copies of agreements are maintained in the files of Emergency Preparedness Department.

The agreements are listed below.

Letter of Agreement from National Weather Service (NWS), Weather Forecast Office (WFO)

The NWS provides general weather forecasts, severe weather and flood warnings, transport and dispersion plume forecasts, and localized weather forecasts. The NWS also provides broadcasts of tone alarmed and encoded public emergency messages on NOAA Weather Radio. If available, a meteorologist will be detailed to the Arizona Emergency Operations Center (EOC) or Maricopa Coimty EOC or the PV EOF and WFO Phoenix will coordinate with Department of Energy meteorologists assigned to the Federal Radiological Monitoring Assessment Center (FRMAC) to support the state, county and PVNGS emergency efforts.

Letter of Agreement from Institute of Nuclear Power Operations (INPO)

Coordinates technical information from PV to the nuclear industry and government agencies, coordinates the procurement and shipping of equipment and supplies, locates personnel with techniced expertise, facihtates industry vendor and commercial supplier support, obtains technical information and operating experience on plant components and systems, and provides an INPO liaison to facilitate interface.

Combustion Engineering Contract (#PV81-4765)

Combustion Engineering furnishes technical assistance as requested in the event of an emergency arising from a nuclear incident at PVNGS.

Letter of Agreement from Banner University Medical Center (BUMC)

Banner BUMC provides hospital treatment for victims of radiological and hazardous materials incidents including contaminated individuals from PVNGS, maintains response capacity as a support facihty, and makes appropriate personnel available for training and participation in medical drills and exercises.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 84 of 332 Letter of Agreement from Banner EstreUa Medical Center Banner Estrella Medical Center provides hospital treatment for victims of radiological and hazardous materials incidents including contaminated individuals from PVNGS, maintains response capacity as a support facility, and makes appropriate personnel available for training and participation in medical drills and exercises.

Letter of Agreement from City of Phoenix Fire Department Provides fire suppression. Emergency Medical Services (EMS), Hazardous Materials (HAZMAT) and other technical services when requested at their discretion and maintains a contingency in place to provide services for >24 hours if necessary.

Phoenix Fire Department coordinates the valley-wide Fire Department Automatic Aid Agreement.

Letter of Agreement from Air Evac air ambulance service Air Evac provides transportation for victims of radiological materials accidents including contaminated individuals and makes appropriate personnel available for training and participation in medical drills and exercises.

Letter of Agreement from Native American air ambulance service Native American Air Ambulance provides transportation for victims of radiological materials accidents including contaminated individuals and makes appropriate personnel available for training and participation in medical drills and exercises.

Letter of Agreement from Tonopab Valley Fire District Tonopah Valley Fire District provides back-up fire protection, haz-mat decontamination assistance, mass casualty Emergency Medical System (EMS),

wildland fire suppression and technical rescue assistance to PVNGS. The initial response includes a Basic Life Support (BLS) fire engine and/or a BLS squad with at least 2 persons. Tonopah also allows storage of PVNGS firefighting resources at Tonopah fire station 341.

Letter of Understanding from Salt River Project (SRP)

SRP agrees to have SRP personnel assigned to the PV switchyard for >5 days site access training and provide SRP employees with site evacuation and emergency planning info.

10.1 Offsite Emergency Response Plan for Palo Verde Nuclear Generating Station In addition to the support outhned in the Letters of Agreement, the Offsite Emergency Response Plan for Palo Verde Nuclear Generating Station provides for the following support functions for PVNGS in the event of an emergency from the indicated agencies. Also, mutual aid compacts and agreements between the State and other government and private entities defined in the Offsite Emergency Response Plan multiply the resources available to PVNGS in an emergency.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 85 of 332 10.1.2 The Maricopa County Sheriffs Office (MCSO) performs the following:

Emergency Public Warning

a. Back-up warning by patrol units for progressively developing emergencies When initial notification is a Site Area Emergency or General Emergency:

(1) Warning message preparation (2) Activation of siren system (3) Dissemination of warning using the EAS and/or Media Alert System (4) Implementation of plant recommended protective actions if required Denial of entry into evacuated areas and patrol evacuated areas to determine effectiveness.

Control of evacuee and access traffic on coimty and farm roads is the responsibility of MCSO, which coordinates with Arizona Department of Public Safety (DPS) for traffic movement from county/farm roads to state highways and to lnterstate-10.

MCSO will provide security within the evacuated area.

Based on the location of the Reception and Care Centerfs) (RCC), MCSO, AZ DPS or local jurisdiction law enforcement will provide RCC security and crowd control as necessary.

MCSO or local law enforcement will provide temporary impound security for contaminated vehicles and personal effects while the RCC is operational.

MCSO will transport K1 to designated Reception and Care Centers.

MCSO and AZ DPS may assist the AZ Department of Agriculture in enforcing produce and food project check points and embargos.

MCSO conducts just-in-time radiological training and provides equipment for alternate personnel prior to being deployed in response to a Hostile Action Based event.

The MCSO provides coordinated on-site/offsite direction and control in accordance with the Maricopa County Peacetime Disaster Plan (PDP). The PDP authorizes the Sheriff to request assistance when an incident is beyond the ability of the Office to resolve and works imder the Incident Command System (ICS) when responding to PVNGS Hostile Action Based (HAB) incidents.

MCSO is responsible for the initial and on-going assessment of the situation to determine if terrorism is involved or responsible for the HAB incident. If and when this determination is made, the Federal Bureau of Investigation (FBI) will be notified.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 86 of 332 10.1.3 DPS provides traffic control on portions of evacuation routes comprising state highways and maintains denial of reentry into evacuated areas.

MCSO and AZ DPS will jointly coordinate access to the boundaries of the evacuated area based on whether the access points are on county/farm roads or state highways or Interstate-10.

The Department of Public Safety (DPS) Remote Mobile Investigation Unit (RMU) can work in contaminated areas and is available for 24-hour use.

10.1.4 The State of Arizona provides the following support to PVNGS in an emergency:

Monitoring of evacuees for possible radioactive contamination and supervision and monitoring of any decontamination effort.

Requests for and coordination of federal technical support.

Exchanges field data and accident assessment information with PVNGS from Field Monitors.

Any classification or notification may require governmental or private sector emergency organizations to commit resources onsite at the request of the facility.

Emergency resources may include, but are not hmited to, law enforcement, firefighting, medical support and ground or air services. Assistance may be requested from other state governments and private sector resources in states adjoining Arizona. These resources may include medical capabilities, emergency response equipment, and emergency response personnel. The State Emergency Operations Center Pohcy Chief (EOC P(5) or Technical Director (TD) will initiate requests.

The Arizona Radiation Regulatoiy Agency (ARRA) provides for collection and analysis of data from the plant, field radiation surveys and sample collection. ARRA representatives share information with EOF staff regarding field team locations, field data and protective action decisions and collects data to assess the accident, project dose and project plume.

ARRA field monitors conduct radiation surveys to determine ambient radiation levels, track the plume and collect environmental and foodstuff samples for analysis and dispatches a mobile laboratory to Buckeye Airport during the emergency (plume) phase for rapid evaluation of air samples.

The Arizona Division of Emergency Management (ADEM) coordinates the collection, analysis and dissemination of information during an incident at the Palo Verde Nuclear Generating Station (PVNGS). This process is conducted in consort with the PVNGS, Maricopa County Dept, of Emergency Management (MODEM), Arizona Radiation Regulatory Agency (ARRA) and other federal, state, local. Tribal Nation and volunteer agencies.

PVNGS EMERGENCY PLAN REVISION 59 PAGES? of 332 For HAB incidents where Offsite Response Organizations (ORO) receive pre-incident intelligence information, applicable OROs will contact the PVNGS Security Central Alarm Station or Security Director.

General response capabilities for a HAB incident are as follows:

PVNGS: Armory; pre-established unit locations; personnel

MCSO: SWAT Teams; armored vehicles; personnel

AZ DPS: SWAT Teams; armament as necessary; helicopter and fixed wing aircraft

National Guard/ MiUtary: ground forces and aircraft as necessary ARRA conducts just-in-time radiological training and provides equipment for alternate personnel prior to being deployed in response to a HAB incident.

10.1.5 Maricopa County provides the following support:

Emergency Public Warning Warning message preparation Activation of siren systems Dissemination of EAS warning messages Provides direction and control for county level activities Installation of evacuation route signs on coimty and farm roads and installation of barricades and signs for entry control of evacuated areas.

Coordinates RCC operations and registers evacuees.

The county directs th3rroid protection operations for county emergency workers.

11.0 REFERENCED INTERFACING EMERGENCY PLANS

State of Arizona/Maricopa County Offsite Emergency Response Plan - PVNGS

National Response Framework, June 2016 (updated)

PVNGS EMERGENCY PLAN REVISION 59 PAGE 88 of 332 12.0 MAPS FIGURE 11 - POPULATION EVACUATION ROUTE SECTIONS AND EVACUATION ROUTING

PVNGS EMERGENCY PLAN REVISION 59 PAGE 89 of 332 t- ' '

t2in-FIGURE 12 - DEMOGRAPHY WITHIN THE PLUME EXPOSURE PATHWAY EMERGENCY PLANNING ZONE PAGE 1 OF 2

r PVNGS EMERGENCY PLAN REVISION 59 PAGE 90 of 332 Palo Verde Population Survey October 2016 r-1 2 0-2 3 4 5 0-5 6 7 8 9 10 o-io

^ Sector Miles Miles Miles A 0 118 118 728 90 262 1197 177 82 129 90 87 1762 B 0 45 45 138 407 175 765 114 51 236 83 19 1268 C 0 3 3 81 134 411 628 343 54 45 62 28 1159 D 0 0 0 88 116 279 483 388 169 0 41 310 1391 E 0 0 0 33 45 152 231 255 72 22 172 40 791 F 0 0 0 0 219 114 333 85 44 11 25 32 529 G 0 0 0 0 52 58 110 0 152 80 3 0 344 H 0 0 0 0 0 0 0 0 0 3 29 24 56 J 0 0 0 0 0 0 0 0 0 0 0 0 0 K 0 0 0 0 5 3 8 0 0 0 0 0 8 L 0 3 3 3 14 11 30 0 3 0 0 0 33 M 0 33 33 0 0 27 60 31 11 0 0 0 101 N 11 0 11 4 0 0 15 0 0 0 0 0 15 P 14 0 14 0 0 0 14 0 0 0 0 0 14 Q 0 22 22 0 0 8 30 16 11 17 45 230 348 R 0 22 22 11 229 137 399 8 34 30 528 51 1049 Mile Ring 25 245 269 1085 1309 1638 4301 1417 681 572 1077 821 8869 Total Students Staff Total Arlington School 256 40 296 Palo Verde School 460 77 537 Ruth Fisher School 702 58 760 Tonopah High School 458 80 538 Crossroads Academy* 17 2 19 Total 1852 227 2131

The Crossroads Academy is a charter high school within the Travel Centers of America (TA)

Truck Stop facility located at 1010 N. 339'" Ave, Tonopah, AZ.

FIGURE 12 - DEMOGRAPHY WITHIN THE PLUME EXPOSURE PATHWAY EMERGENCY PLANNING ZONE PAGE 2 OF 2

PVNGS EMERGENCY PLAN REVISION 59 PAGE 91 of 332 I-LEGEND FIGURE 13 - SITE EXCLUSION AREA BOUNDARY AND PROPERTY BOUNDARY

' i-PVNGS EMERGENCY PLAN REVISION 59 PAGE 92 of 332 Palo Verde 50>Mile Emergency Planning Zcme

-> ; l.J * ^

FIGURE 14 - INGESTION EXPOSURE PATHWAY EMERGENCY PLANNING ZONE

PVNGS EMERGENCY PLAN REVISION 59 PAGE 93 of 332 Km

C#rlr

/ Wittaufih

t ^

A ) R

\,w^. <<.h

1. Wickenburg High School 2. Youngker High School 3. Desert Edge High School 1090 S. Vulture Mine Road 3000 S. Apache Road 15778 W. Yuma Road Wickenburg, AZ. 85390 Buckeye, AZ 85326 Groodyear, AZ. 85338 FIGURE 15 - RECEPTION AND CARE CENTERS

PVNGS EMERGENCY PLAN REVISION 59 PAGE 94 of 332 PALO VERDE NUCLEAR GENERATING STATION SIREN MAP e

m LLEy HISH am^ujIE 3

ARiJWDTOft n#Tnr yy^BYseCiNElRO m

/a m n FIGURE 16 - PROMPT NOTIFICATION SYSTEM SIREN LOCATIONS

PVNGS EMERGENCY PLAN REVISION 59 PAGE 95 of 332 13.0 EMERGENCY PLAN IMPLEMENTING PROCEDURES Designator Title Plan Section EP-0900 ERO Position Checklists 4 EP-0901 Emergency Classification 5,6 EP-0902 Notification 6,7 EP-0903 Accident Assessment 6,7 EP-0904 ERO / ERF Activation and Operation 4,7 EP-0905 Protective Actions 6,15 EP-0906 Termination and Recovery 5,9 40AO-9ZZ24 Deliberate Acts Against PVNGS 6 14.0 IDENTIFICATION OF EMERGENCY KITS BY GENERAL CATEGORY Kit Equipment TSC STSC Offsite Ambulance EOF Medical Hospitals Units (1-3)

OSC RFAT Facility, Near RP Evacuation Island Decon.

Protective Equipment Communications Equipment Radiological Monitoring Equipment Emergency Supplies 15.0 ACCIDENT DOSE PROJECTION AND SOURCE TERM ESTIMATION The method used for dose projection at PVNGS is the Raddose computer software program, which runs on several computers throughout the plant.

15.1 DOSE ASSESSMENT MODEL PVNGS uses a site-specific version of the Raddose dose assessment computer software. The Raddose software meets the requirements of NUREG 0654, Appendix 2, and uses a variable trajectory, puff advection model. Calculations can be performed using multiple release points or accident t3rpes from multiple units.

Based on EPA 400; MANUAL OF PROTECTIVE ACTION GUIDES AND PROTECTIVE ACTIONS FOR NUCLEAR INCIDENTS dated 1991 dose conversion factors and the source term provided in the PVNGS Updated Final Safety Analysis Report (based on TID-14844, "Calculation of Distance Factors for Power and Test Reactors").

The Raddose dose assessment software is designed to:

Estimate source terms based on high range Containment radiation monitors, effluent process radiation monitors, and steam line radiation monitors under anticipated accident conditions.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 96 of 332 Estimate source terms using alternate monitors or default values when the primary instruments are off-scale or inoperable.

Estimate source terms based on grab sample results and back-calculation using field monitoring team data.

Estimate atmospheric effluent transport and diffusion during and immediately following an accidental airborne radioactive release using actual or estimated meteorology.

Adjust atmospheric diffusion rates based on atmospheric stability.

Report plume dimensions, position, and expected arrival time at various downwind distances.

Calculate TEDE, Thyroid Committed Dose Equivalent, committed EDE from inhalation, external EDE due to plume exposure, and exposure to ground deposition at various downwind locations.

Calculate deposition estimates at various downwind locations.

Report maximum integrated values and rates at the Site Boundary, 2 miles, 5 miles, and 10 miles for TEDE, Thyroid Committed Dose Equivalent, external EDE, and ground deposition.

Report effluent release rate data and pliune ground level airborne concentration.

Raddose provides Protective Action Recommendations based on radiological data.

Actual Protective Action Recommendations are derived from Emergency Plan Implementing Procedures.

16.0 CROSS REFERENCE TO NUREG 0654 Cross reference between NUREG-0654 and the Palo Verde Nuclear Generating Station Emergency Plan.

A. Assignment of Responsibility (Organizational Control)

A.l.a Section 4.2, 4.3 A.l.b Section 4 A.1.C Figures 1 through 6 A.l.d Section 4.2.1.1, 4.2.2.1, 4.2.4.1 A.l.e Section 4.2.1 A.2.a NA A.2.b NA A.3 Section 10 A. 4 Section 4.2.4 B. Onsite Emergency Organization B.l Section 4.1, 4.2 B.2 Section 4.2.1.1 B.3 Section 4.2.1.1, 4.2.2.1, 4.2.4.1 B.4 Section 4.2.1.1, 4.2.2.1, 4.2.4.1 B.5 Section 4.2, Figures 1 through 6, Table 1 B.6 Section 4.2, 4.3, Figures 1 through 6

PVNGS EMERGENCY PLAN REVISION 59 PAGE 97 of 332 B.7 Section 4.2 B.7.a Section 4.2.4 B.7.b Section 9 B.7.C Section 4.2.4 B.7.d Section 4.2.4, 18 B.8 Section 4.3.2 B.9 Section 4.3, 6.8.3, 6.8.4,10 C. Emergency Response Support and Resources C.l.a Section 4.2.1.1, 4.2.2.1, 4.2.4.1 C.l.b Section 4.4.3 C.l.c Section 7.1, 7.2, Table 3 C.2.a NA C.2.b Section 4.2.5.5 C.3 Section 7.3.1.5 C.4 Section 4.2.4, 10 D. Emergency ClassiRcation System D.l Table 2 D.2 Section 5.2, Table 2 D.3 NA D.4 NA E. Notification Methods and Procedures E.l Section 6.3 E.2 Section 6.4 E.3 Section 6.3 E.4.a Section 6.3 E.4.b Section 6.3 E.4.C Section 6.3 E.4.d Section 6.3 E.4.e Section 6.3 E.4.f Section 6.3 E.4.g Section 6.3 E.4.h Section 6.3 E.4.i Section 6.3 E.4.j Section 6.3 E.4.k Section 6.3 E.4.1 Section 6.3 E.4.m Section 6.3 E.4.n Section 6.3 E.5 NA E.6 Section 6.3, 6.7.2, 7.7, Figure 16 E.7 Section 6.3, 6.7.2 F. Emergency Communications F.l.a Section 6.3, 7.2.21, Figures 7 & 8 F.l.b Section 6.3, 7.2.21, Figures 7 & 8 F.l.c Section 4.2.4, 4.3, 6.3, 7.2.14 F.l.d Section 7.2, Table 3 F.l.e Section 6.3 F.l.f Section 7.2

PVNGS EMERGENCY PLAN REVISION 59 PAGE 98 of 332 F.2 Section 7.2 F.3 Section 8.1.3, 8.3 G. Public Education and Information G.l Section 8.1.1.4 G.2 Section 8.1.1.4 G.3.a Section 7.1.8 G.3.b Section 7.1.8 G.4.a Section 4.2.5, 18 G.4.b Section 18 G.4.C Section 6.9 G.5 Section 8.1.1.5 H. Emergency Facilities and Equipment H.l Section 7.1.3, 7.1.4, 7.1.5 H.2 Section 7.1.6 H.3 NA H.4 Section 6.3, 6.4 H.5.a Section 7.3.1.1 H.5.b Section 7.3.1.2, 7.3.1.6 H.5.C Section 7.3.1.3 H.5.d Section 7.3.1.4 H.e.a Section 7.3.1.1 H.e.b Section 7.3.2 H.6.C Section 7.3.1.5 H.7 Section 7.3.2 H.8 Section 6.5.2, 7.3.1.1 H.9 Section 7.1.4 H.10 Section 8.3 H.ll Section 14 H.12 Section 7.1.6 I. Accident Assessment I.l Table 2 1.2 Section 7.3.1.2, 7.3.1.5 I.3.a Section 15 I.3.b Section 15 1.4. Section 15 1.5 Section 6.5.2, 7.1.3, 7.1.5, 7.1.6, 7.3.1.1, 7.3.1.9 1.6 Section 15 1.7 Section 6.5.2 1.8 Section 6.5.2 Note: PVNGS is a dry site and has no monitored liquid release pathways 1.9 Section 6.5.2 I.IO Section 6.5.2, 15 I.ll NA J. Protective Response J.l.a Section 6.7.1.1 J.l.b Section 6.7.1.1 J.l.c Section 6.7.1.1

.'ll

PVNGS EMERGENCY PLAN REVISION 59 PAGE 99 of 332 J.l.d Section 6.7.1.1 J.2 Section 6.7.1.4 J.3 Section 6.8.2 J.4 Section 6.7.1.4, 6.8.2 J.5 Section 6.7.1.3 j.e.a Section 6.7.1.7.1, 9.2 j.e.b Section 6.7.1.7.2, 9.2 J.6.C Section 6.7.1.7.3, 9.2 J.7 Section 6.7.2.1, Figure 9 J.8 Section 6.7.2.1 J.9 NA J.lO.a Figures 11 & 15 J.lO.b Figure 12 J.lO.c Section 6.7.2.1, 7.7, Figure 16 J.lO.d Section NA J.lO.e Section NA J.lO.f Section NA J.lO.g Section NA J.lO.h Section NA J.lO.i Section NA J.lO.j Section NA J.lO.k Section NA J.10.1 Section NA J.lO.mSection 6.7.2, 6.7.2.1 J.ll Section NA J.12 Section NA K. Radiological Exposure Control Kl.a Section 6.8.2, 6.8.3, 6.8.4 Kl.b Section 6.8.2, 6.8.3, 6.8.4 Kl.c Section 6.8.2, 6.8.4, 6.8.4 Kl.d Section 6.8.2, 7.5 Kle Section 6.8.2 Kl.f Section 6.8.3 Kl.g Section 6.8.4, 7.5 K.2 Section 6.8.1 K.3.a Section 6.7.3.1, 6.7.3.2, 6.8.1 K.3.b Section 6.8.1 K.4 NA K.5.a Section 6.8.1, 6.8.2 K.5.b Section 6.8.1, 6.8.2 K.6.a Section 6.7.3 K.6.b Section 6.7.3, K.6.C Section 6.7.3, 9.0 K.7 Section 6.8.2, 6.8.4 L. Medical and Public Health L.l Section 6.8.2, 6.8.3, 6.8.4 L.2 Section 6.8.2, 7.5 L.3 NA

PVNGS EMERGENCY PLAN REVISION 59 PAGE 100 of 332 L.4 Section 6.8.3 M. Recovery and Reentry Planning and Post Accident Operations M.l Section 9.0 Through 9.3 M.2 Section 9.1 M.3 Section 9.0 Through 9.3 M.4 Section 9.2 N. Exercises and Drills N.l.a Section 8.1.2 N.l.b Section 8.1.2 N.2.a Section 8.1.3 N.2.b Section 8.1.3 N.2.C Section 8.1.3 N.2.d Section 8.1.3 N.2.e.l Section 8.1.3 N.2.e.2 Section 8.1.3 N.3.a Section 8.1.2, 8.1.3 N.3.b Section 8.1.2, 8.1.3 N.3.C Section 8.1.2, 8.1.3 N.3.d Section 8.1.2, 8.1.3 N.3.e Section 8.1.2, 8.1.3 N.3.f Section 8.1.2, 8.1.3 N.4 Section 8.1.2, 8.1.3 N.5 Section 8.1.2, 8.1.3 O. Radiological Emergency Response Training 0.1 Section 8.1.1 O.l.a Section 8.1.1, 10 O.l.b NA 0.2 Section 8.1.1.2, 8.1.3 0.3 Section 4.2.1.3, 6.8.2 0.4.a Section 8.1.1 0.4.b Section 8.1.1 0.4.C Section 8.1.1 0.4.d Section 8.1.1 0.4.e Section 8.1.1 0.4.f Section 8.1.1 0.4.g Section 8.1.1.3 0.4.h Section 8.1.1 0.4.i Section 8.1.1 0.4.J Section 8.1.1 0.5 Section 8.1.1.2 P. Responsibility for the Planning Effort: Development, Periodic review and Distribution of Emergency Plans P.l Section 8.1.1 P.2 Section 8.1.5 P.3 Section 8.1.5 P.4 Section 8.2 P.5 Section 8.2 P.6 Section 11.0

PVNGS EMERGENCY PLAN REVISION 59 PAGE 101 of 332 P.7 Section 13.0 P.8 Table of Contents, Section 16 P.9 Section 8.2 P.IO Section 8.2 17.0 CORPORATE EMERGENCY SUPPORT The EOD will request and coordinate required support.

18.0 PUBLIC INFORMATION

18.1 INTRODUCTION

The purpose of this section is to briefly summarize the responsibilities, operation and staffing of the Palo Verde Communications, APS External Commimications Department and the Joint Information Center (JIC). A detailed Joint Public Information Procedure is provided.

18.2 ACTIVATION AND OPERATION The purpose of the Palo Verde Communications, APS External Communications Department and the JIC is to provide information about an emergency at PVNGS to the news media and the general public.

At an Unusual Event, Palo Verde Communications and APS External Communications Department provide the media interface for the site.

At an Alert or higher classification level, the JIC is activated and assumes responsibility for the public information function.

18.3 STAFFING AND LOCATION Palo Verde Commimications Department personnel are located at PVNGS and the APS External Communications Department personnel are located at the APS Corporate Headquarters, 400 N.

5th Street, Phoenix, AZ.

The JIC is located at 600 North Verrado Way, Buckeye, AZ. The JIC staff consists of APS/PVNGS and government public information and support personnel. PVNGS coordinates and releases information with government authorities. Each principal organization represented at the JIC has a designated spokesperson that has access to all necessary information. JIC procedures are designed to allow the timely exchange of information among spokespersons.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 102 of 332 19.0 DEVELOPMENTAL REFERENCES

1. 10 CFR 50.47(B) "Emergency Plans,"

2. 10 CFR 50.54(q), Conditions of Licenses, Decrease in Effectiveness

3. APPENDIX E TO 10CFR PART 50 "Emergency Planning and Preparedness for Production and Utilization Facilities,"

4. NUREG 0578, TMI-2 Lessons Learned Task Force: Status Report and Short-Term Recommendations; July, 1979

5. NUREG 0737, Clarification of TMI Action Plan Requirements; November, 1980 6.10 CFR 20, Standards for Protection against Radiation

7. 10 CFR 50, Domestic Licensing of Production and Utilization Facilities

8. NUREG-0654 / FEMA-REP-1, Revision 1 "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants".

9. NUREG 0654, Supplement 3, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Guidance for Protective Action Strategies, November 2011.

10. EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents; October, 1991

11. Reg. Guide 1.97, Revision 2, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident; December, 1980

12. NUREG-0696, Functional Criteria for Emergency Response Facilities, 1981

13. NEI 99-01, Methodology for Development of Emergency Action Levels Rev. 6

14. NUREG/CR 7002, Criteria for Development of Evacuation Time Estimate Studies, published in November 2011.

15. NUREG 1394, Emergency Response Data System (ERDS) Implementation, Revision 1, June 1991 and the related Generic Letter 93 01, Emergency Response Data System Test Program, March 3, 1993

16. NRC Regulatory Issue Summary 2005 02 Clarifying the Process for Making Emergency Plan Changes, February 14, 2005

17. Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors.

18. NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants,

19. NRC Information Bulletin 2005-02, Emergency Preparedness and Response for Security Based Events

20. Nuclear Energy Institute (NEI) 99-01, Revision 6, Methodology for Development of Emergency Action Levels, endorsed by the U.S. Nuclear Regulatory Commission (NRC or the Commission) by letter dated March 28, 2013 (Thaggard, M., U.S. Nuclear Regulatory Commission, letter to Susan Perkins-Grew, Nuclear Energy Institute, "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, dated November, 2012 (TAC No. D92368)," dated March 28, 2013. [ADAMS Accession No. ML12346A463].

21. NRC letter dated September 8, 2017, Palo Verde Nuclear Generating Station, Units 1, 2, and 3 -

Issuance of Amendments to Revise Emergency Action Levels to a Scheme Based on Nuclear Energy institute NEI 99-01, Revision 6 (CAC NOS. MF6803, MF6804 and MF6805. This letter provided Amendment No. 198 to renewed Facility Operating License No. NPF-41, Amendment No. 198 to Renewed Facility Operating License No. NPF-51 and Amendment No. 198 to Renewed Facility Operating License No. NPF-74 for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, respectively. The amendments consist of changes to the emergency action level (EAL) scheme including the NRC approved Safety Evaluation.

PVNGS EMERGENCY PLAN REVISION 59 PAGE 103 of 332 EP-0901 Appendix B Revision 0 Page 1 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 104 of 332 APPENDIX A CLASSIFICATION GUIDANCE AND EAL TECHNICAL BASIS TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE............................................................................................................................................. 3 2.0 DISCUSSION....................................................................................................................................... 3 2.1 Background...................................................................................................................................3 2.2 Fission Product Barriers............................................................................................................. 4 2.3 Fission Product Barrier Classification Criteria....................................................................... 4 2.4 ElAL Organization.........................................................................................................................5 2.5 Technical Bases Information...................................................................................................... 6 2.6 Operating Mode Applicability..................................................................................................... 8 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS.................................................9 3.1 General Considerations................................................................................................................9 3.2 Classification Methodology....................................................................................................... 10

4.0 REFERENCES

................................................................................................................................... 13 4.1 Developmental............................................................................................................................ 13 4.2 Implementing.............................................................................................................................. 13 5.0 DEFINITIONS, ABBREVIATIONS, & ACRONYMS....................................................................14 5.1 Definitions................................................................................................................................... 14 5.2 Abbreviations/Acronsnms............................................................................................................19 6.0 PVNGS-TO-NEI 99-01, Rev. 6, EAL CROSS-REFERENCE.......................................................22 7.0 ATTACHMENTS................................................................................................................................26 Attachment 1 - Emergency Action Level Technical Bases..........................................................27 Category R Abnormal Rad Release / Rad Effluent.................................................... 27 Category E Independent Spent Fuel Storage Installation (ISFSI)........................ 58 Category C Cold Shutdown / Refueling SystemMalfunction................................... 61 Category H Hazards and Other Conditions Affecting Plant Safety........................ 96 Category S System Malfunction................................................................................. 129 Category F Fission Product Barrier Degradation................................................... 172 Attachment 2 - Fission Product Barrier Loss / Potential Loss Matrix and Bases..................... 177 Attachment 3 - Safe Operation & Shutdown Rooms Tables R-2 & H-2 Bases...........................226 Attachment 4 - Palo Verde Safety System List............................................................................... 229 Page 2 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 105 of 332 1.0 PURPOSE This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the EAL Upgrade Project for Palo Verde Nuclear Generating Station (PVNGS).

Decision-makers responsible for implementation of EP-0901, Classifications, may use this document as a technical reference in support of EAL interpretation. This information may assist the Emergency Coordinator in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification.

Because the information in a basis document can affect emergency classification decision making (e.g., the Emergency Coordinator refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10CFR 50.54(q).

2.0 DISCUSSION 2.1 Background EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the PVNGS Emergency Plan.

In 1992, the NRC endorsed NUMARC/NESP-007, Methodology for Development of Emergency Action Levels, as an alternative to NUREG-0654 EAL guidance.

NEI 99-01 (NUMARC/NESP-007), Revisions 4 and 5, were subsequently issued for industry implementation. Enhancements over earlier revisions included:

Consolidating the system malfunction initiating conditions and example emergency action levels which address conditions that may be postulated to occur during plant shutdown conditions.

Initiating conditions and example emergency action levels that fully address conditions that may be postulated to occur at permanently Defueled Stations and Independent Spent Fuel Storage Installations (ISFSIs).

Simplifying the fission product barrier EAL threshold for a Site Area Emergency.

Subsequentiy, Revision 6 of NEI 99-01 incorporated resolutions to numerous implementation issues including the NRC EAL Frequently Asked Questions (FAQs). Using NEI 99-01, Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (ref. 4.1.1), PVNGS conducted an EAL implementation upgrade project that produced the EALs discussed herein.

Page 3 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 106 of 332 2.2 Fission Product Barriers Fission product barrier thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment.

Many of the EALs derived from the NEI methodology are fission product barrier threshold based. That is, the conditions that define the EALs are based upon thresholds that represent the loss or potential loss of one or more of the three fission product barriers. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. A Loss threshold means the barrier no longer assures containment of radioactive materials. A Potential Loss threshold implies an increased probability of barrier loss and decreased certainty of maintaining the barrier.

The primary fission product barriers are:

A. Fuel Clad (FC): The FC Barrier consists of the cladding material that contains the fuel pellets.

B. Reactor Coolant System (RCS): The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves and other connections up to and including the primary isolation valves.

C. Containment (CTMT): The CTMT Barrier includes the containment building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve.

Containment Barrier thresholds are used as criteria for escalation of the emergency classification level (ECL) from Alert to a Site Area Emergency or a General Emergency 2.3 Fission Product Barrier Classification Criteria The following criteria are the bases for event classification related to fission product barrier loss or potential loss; Alert:

Any loss or any potential loss of either Fuel Clad or RCS barrier Site Area Emergency:

Loss or potential loss of any two barriers General Emergency:

Loss of any two barriers and loss or potential loss of the third barrier Page 4 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 107 of 332 2.4 EAL Organization The PVNGS EAL scheme includes the following features:

Division of the EAL set into three broad groups:

EALs applicable under an^ plant operating modes - This group would be reviewed by the EAL-user any time emergency classification is considered.

EALs applicable only under hot operating modes - This group would only be reviewed by the EAL-user when the plant is in 1 - Power Operation, 2 - Startup, 3

- Hot Standby or 4 - Hot Shutdown mode.

EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in 5 - Cold Shutdown, 6 - Refueling or Defueled mode.

The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the user for a given plant condition, reduces user reading burden and, thereby, facilitates timely identification of the EAL that applies to the emergency.

Within each group, assignment of EALs to categories and subcategories:

Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. The PVNGS EAL categories are aligned to and represent the NEI 99-01 Recognition Categories. Subcategories are used in the PVNGS scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The PVNGS EAL categories and subcategories are listed below.

Page 5 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 108 of 332 EAL Groups, Categories and Subcategories EAL Group/Category EAL Subcategory Anv Ooeratina Mode:

R - Abnormal Rad Levels / Rad Effluent 1 - Radiological Effluent 2 - Irradiated Fuel Event 3-Area Radiation Levels H - Hazards and Other Conditions Affecting 1 - Security Plant Safety 2 - Seismic Event 3 - Natural or Technological Hazard 4 - Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - Emergency Coordinator Judgment E - ISFSI 1 - Confinement Boundary Hot Conditions:

S - System Malfunction 1 - Loss of Emergency AC Power 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - RCS Activity 5 - RCS Leakage 6 - RPS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier Degradation None Cold Conditions:

C - Cold Shutdown / Refueling System 1 - RCS Level Malfunction 2 - Loss of Emergency AC Power 3 - RCS Temperature 4 - Loss of Vital DC Power 5 Loss of Communications 6 - Hazardous Event Affecting Safety Systems The primary tool for determining the emergency classification level is the EAL Classification Matrix. The user of the EAL Classification Matrix may (but is not required to) consult the EAL Technical Bases Document in order to obtain additional information concerning the EALs under classification consideration. The user should consult Section 3.0 and Attachments 1 & 2 of this document for such information.

2.5 Technical Bases Information EAL technical bases are provided in Attachment 1 for each EAL according to EAL group (Any, Hot, Cold), EAL category (R, C, H, S, E and F) and EAL subcategory. A summary explanation Page 6 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 109 of 332 of each category and subcategory is given at the beginning of the technical bases discussions of the EALs included in the category. For each EAL, the following information is provided; Category Letter & Title Subcateqorv Number & Title Initiating Condition (1C)

Site-specific description of the generic 1C given in NEI 99-01, Rev. 6.

EAL Identifier (enclosed in rectangle)

Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier:

1. First character (letter); Corresponds to the EAL category as described above (R, C, H, S, E or F)

2. Second character (letter): The emergency classification (G, S, A or U)

G = General Emergency S = Site Area Emergency A = Alert U = Unusual Event

3. Third character (number): Subcategory number within the given category.

Subcategories are sequentially numbered beginning with the number one (1). If a category does not have a subcategory, this character is assigned the number one (1).

4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. If the subcategory has only one EAL, it is given the number one (1).

Classification (enclosed in rectangle):

Unusual Event (U), Alert (A), Site Area Emergency (S) or General Emergency (G)

EAL (enclosed in rectangle)

Exact wording of the EAL as it appears in the EAL Classification Matrix Mode Applicability One or more of the following plant operating conditions comprise the mode to which each EAL is applicable: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 -

Cold Shutdown, 6 - Refueling, DEF - Defueled, or Any. (See Section 2.6 for operating mode definitions)

Definitions:

If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1.

Basis:

A basis section that provides PVNGS-relevant information concerning the EAL as well as a a description of the rationale for the EAL as provided in NEI 99-01, Rev. 6.

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 110 of 332 PVNGS Basis Reference(s):

Site-specific source documentation from which the EAL is derived 2.6 Operating Mode Applicability (ref. 4.1.6) 1 Power Operation Keff > 0.99 and reactor thermal power > 5%

2 Startup Keff > 0.99 and reactor thermal power < 5%

3 Hot Standby Keff < 0.99 and average coolant temperature > 350°F 4 Hot Shutdown Keff < 0.99 and average coolant temperature 350°F > Tavg > 210 °F and all reactor vessel head closure bolts fully tensioned 5 Cold Shutdown Keff < 0.99 and average coolant temperature < 210°F and all reactor vessel head closure bolts fully tensioned 6 Refueling One or more reactor vessel head closure bolts less than fully tensioned D Defueled All fuel assemblies have been removed from Containment and placed in the spent fuel pit and the SFP transfer canal gate valve is closed.

The mode in effect at the time that an event or condition occurred, and prior to any plant or operator response, is the mode that determines whether or not an 1C is applicable. If an event or condition occurs, and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event or condition was initiated (and not when it was declared). Once a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition. For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response. In particular, the fission product barrier EALs are applicable only to events that initiate in the Hot Shutdown mode or higher.

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 111 of 332 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 3.1 General Considerations When making an emergency classification, the Emergency Coordinator must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the Emergency Action Level (EAL) plus the associated Operating Mode Applicability, Notes and the informing basis information. In the Recognition Category F matrices, EALs are based on loss or potential loss of Fission Product Barrier Thresholds.

3.1.1 Classification Timeliness NRC regulations require the licensee to establish and maintain the capability to assess, classify and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants (ref. 4.1.9).

When assessing an EAL that specifies a time duration for the off-normal condition, the clock for the EAL time duration runs concurrently with the emergency classification process dock.

3.1.2 Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicators operability, the conditions existence, or the reports accuracy. For example, verification could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel. The validation of indications should be completed in a manner that supports timely emergency declaration.

3.1.3 Imminent Conditions For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.

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

4.1.4).

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 112 of 332 3.1.5 Classification Based on Analysis The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments, chemistry sampling, RCS leak rate calculation, etc.). For these EALs, the EAL wording or the associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift).

3.1.6 Emergency Coordinator Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 EAL scheme provides the Emergency Coordinator with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The Emergency Coordinator will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition. A similar provision is incorporated in the Fission Product Barrier Tables; judgment may be used to determine the status of a fission product barrier.

3.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL must be consistent with the related Operating Mode Applicability and Notes. If an EAL has been met or exceeded, the associated 1C is likewise met, the emergency classification process clock starts and the ECL must be declared in accordance with plant procedures no later than fifteen minutes after the process clock started.

When assessing an EAL that specifies a time duration for the off-normal condition, the clock for the EAL time duration runs concurrently with the emergency classification process clock.

For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.9).

3.2.1 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified is declared. For example:

If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at two different units, a Site Area Emergency should be declared.

There is no additive effect from multiple EALs meeting the same ECL. For example:

If two Alert EALs are met, whether at one unit or at two different units, an Alert should be declared.

Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events (ref. 4.1.2).

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 113 of 332 3.2.2 Consideration of Mode Changes During Classification The mode in effect at the time that an event or condition occurred and prior to any plant or operator response, is the mode that determines whether or not an 1C is applicable. If an event or condition occurs and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event or condition was initiated (and not when it was declared). Once a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition.

For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response. In particular, the fission product barrier EALs are applicable only to events that initiate in the Hot Shutdown mode or higher.

3.2.3 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Coordinator must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Coordinator, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all ECLs, this approach is particularly important at the higher emergency classification levels since it provides additional time for implementation of protective measures.

3.2.4 Emergency Classification Level Upgrading and Downgrading An ECL may be downgraded when the event or condition that meets the highest 1C and EAL no longer exists and other site-specific downgrading requirements are met. If downgrading the ECL is deemed appropriate, the new ECL would then be based on a lower applicable IC(s) and EAL(s). The ECL may also simply be terminated.

As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02 (ref. 4.1.2).

3.2.5 Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events include an earthquake or a failure of the reactor protection system to automatically trip the reactor followed by a successful manual trip.

3.2.6 Classification of Transient Conditions Many of the ICs and/or EALs employ time-based criteria. These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions.

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 114 of 332 EAL momentarily met during expected plant response - In instances where an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected and operator actions are performed in accordance with procedures.

EAL momentarily met but the condition is corrected prior to an emergency declaration - If an operator takes prompt manual action to address a condition and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required. For illustrative purposes, consider the following example; An ATWS occurs and the high pressure ECCS systems fail to automatically start.

Reactor vessel level rapidly decreases and the plant enters an inadequate core cooling condition (a potential loss of both the fuel clad and RCS barriers). If an operator manually starts a high pressure ECCS system in accordance with an EOP step and clears the inadequate core cooling condition prior to an emergency declaration, then the classification should be based on the ATWS only.

It is important to stress that the 15-minute emergency classification assessment period (process clock) is not a grace period during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event.

Emergency classification assessments must be deliberate and timely, with no undue delays.

The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the Emergency Coordinator completing the review and steps necessary to make the emergency declaration. This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions.

3.2.7 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.

In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR 50.72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

3.2.8 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3).

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 115 of 332

4.0 REFERENCES

4.1 Developmental 4.1.1 NEI 99-01, Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805.

4.1.2 RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications during Quickly Changing Events, February 2, 2007.

4.1.3 NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73 4.1.4 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors 4.1.5 10 CFR 50.73, License Event Report System 4.1.6 Technical Specifications Table 1.1-1, Modes 4.1.7 Procedure 40EP-9E010, LM-Containment Evacuation and Closure, Appendix 249 4.1.8 Procedure Writers Manual PVNGS Plant Procedure Writers Manual 4.1.9 NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants 4.1.10 PVNGS Emergency Plan 4.1.11 Procedure 40DP-9ZZ30, Reduced Inventory Operations 4.1.12 Procedure 20DP-0SK49, Security Integrated Response Plan (Proprietary Information) 4.2 Implementing 4.2.1 Procedure, EP-0901, Classifications 4.2.2 PVNGS-TO-NEI 99-01, Rev. 6, EAL CROSS-REFERENCE 4.2.3 PVNGS EAL Matrix Page 13 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 116 of 332 5.0 DEFINITIONS, ABBREVIATIONS, & ACRONYMS 5.1 Definitions (ref. 4.1.1 except as noted)

Selected terms used in Initiating Condition and Emergency Action Level statements are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

Alert Events are in progress, or have occurred, which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of hostile action. Any releases are expected to be small fractions of the EPA Protective Action Guideline exposure levels.

Confinement Boundary The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the PVNGS ISFSI, Confinement Boundary is defined as the Transportable Storage Canister (TSC) for the NAC-UMS.

Containment Closure The procedurally defined actions taken to secure containment and its associated structures, systems and components as a functional barrier to fission product release under shutdown conditions.

As applied to PVNGS, Containment Closure is established when the requirements of procedure 40EP-9E010, LM-Containment Evacuation and Closure, Appendix 249, for containment closure are met (ref. 4.1.7).

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

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

EPA PAGs Environment Protection Agency Protective Action Guidelines. The EPA PAGs are expressed in terms of dose commitment: 1 Rem TEDE or 5 Rem CDE Thyroid. Actual or projected offsite exposures in excess of the EPA PAGs requires PVNGS to recommend protective actions for the general public to offsite planning agencies.

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 117 of 332 Explosion A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events require a post-event inspection to determine if the attributes of an explosion are present.

Faulted The term applied to a steam generator that has a steam or feedwater leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

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

Fission Product Barrier Threshold A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.

Flooding A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

General Emergency Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or hostile actions that result in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

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

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

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

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 118 of 332 Imminent The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Impede(d)

Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Independent Spent Fuel Storage Installation (ISFSI)

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

Initiating Condition (iC)

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

Intrusion The act of entering without authorization. Discovery of a bomb in a specified area is indication of intrusion into that area by a hostile force.

Maintain Take appropriate action to hold the value of an identified parameter within specified limits.

Projectile An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

Plant or ISFSI Protected Area An area, located within the PVNGS Exclusion Area Boundary, encompassed by physical barriers and to which access is controlled per 10 CFR 73.55. The PVNGS Power Plant Protected Area and the ISFSI Protected Area are two Protected Areas located within the PVNGS OWNER CONTROLLED AREA (ref 4.1.10).

RCS Intact The RCS should be considered intact when the RCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams, pressurizer manway and safeties installed).

Reduced Inventory Plant condition when fuel is in the reactor vessel and Reactor Coolant System level is less than or equal to the 111 foot elevation (ref. 4.1.11).

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 119 of 332 Refueling Pathway The reactor refueling pool, fuel storage pool and fuel transfer canal comprise the refueling pathway.

Ruptured The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

Restore Take the appropriate action required to return the value of an identified parameter to the applicable limits Safety System A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10 CFR 50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary:

(2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Security Owner Controlled Area (SOCA)

An area encompassed by physical barriers to which access is controlled, (ref 4.1.12).

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

Site Area Emergency Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or hostile actions that result in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed ERA Protective Action Guidelines exposure levels beyond the site boundary.

Site Boundary The boundary of a reactor site beyond which the land or property is not owned, leased, or othenwise controlled by the licensee (ref. 4.1.10).

Unisolable An open or breached system line that cannot be isolated, remotely or locally.

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..lii

PVNGS EMERGENCY PLAN REVISION 59 PAGE 120 of 332 Unplanned A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

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

Valid An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

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

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PVNGS EMERGENCY PLAN REVISION 59 PAGE 121 of 332 5.2 Abbreviations/Acronyms

°F............................................................................................................ Degrees Fahrenheit

................................................................................................................................... Degrees AC............................................................................................................ Alternating Current AOP................................................................... Abnormal Operating Procedure ATWS......................................................................... Anticipated Transient Without Scram CET................................................................................................ Core Exit Thermocouple CDE........................................................................................... Committed Dose Equivalent CFR.......................................................................................... Code of Federal Regulations CR.................................................................................................................... Control Room CSFST.......................................................................... Critical Safety Function Status Tree CTMT................................................................................................................... Containment DBA................................................................................................... Design Basis Accident DC.................................................................................................................... Direct Current DEF........................................................................................................................... Defueled DG............................................................................................................. Diesel Generator EAL..................................................................................................Emergency Action Level ECCS................................................................................Emergency Core Cooling System ECL.....................................................................................Emergency Classification Level EOC.....................................................................................Emergency Operations Center EOF.....................................................................................Emergency Operations Facility EOP..................................................................................Emergency Operating Procedure EPA..................................................................................Environmental Protection Agency EPABX....................................................... Electronic Private Automatic Branch Exchange ERG.................................................................................... Emergency Response Guideline EPIP...................................................................Emergency Plan Implementing Procedure ESF............................................................................................ Engineered Safety Feature ESW............................................................................................ Emergency Service Water FAA.....................................................................................Federal Aviation Administration FBI.......................................................................................Federal Bureau of Investigation FEMA................................................................. Federal Emergency Management Agency GE..........................................................................................................General Emergency 1C.............................................................................................................. Initiating Condition IPEEE.................Individual Plant Examination of External Events (Generic Letter 88-20)

Keff............................................................................ Effective Neutron Multiplication Factor LCO.....................................................................................Limiting Condition of Operation LER....................................................................................................Licensee Event Report LOCA............................................................................................. Loss of Coolant Accident LWR........................................................................................................Light Water Reactor MPC....................................Maximum Permissible Concentration/Multi-Purpose Canister Page 19 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 122 of 332 mR, mRem, mrem, mREM ................................................. milli-Roentgen Equivalent Man MSL............................................................................................................. Main Steam Line MW.......................................................................................................................... Megawatt NEI................................................................................................... Nuclear Energy Institute NESP......................................................................National Environmental Studies Project NPP.......................................................................................................Nuclear Power Plant NRC.................................................................................... Nuclear Regulatory Commission NSSS....................................................................................Nuclear Steam Supply System NORAD.....................................................North American Aerospace Defense Command (NO)UE.....................................................................................Notification of Unusual Event OBE........................................................................................... Operating Basis Earthquake OCA....................................................................................................Owner Controlled Area ODCM............................................................................... Off-site Dose Calculation Manual ORO................................................................................... Offsite Response Organization OSC............................................................................................. Operations Support Center PA................................................................................................................... Protected Area PAG............................................................................................ Protective Action Guideline PPS.................................................................................................. Plant Protection System PRA/PSA..................... Probabilistic Risk Assessment / Probabilistic Safety Assessment PWR........................................................................................... Pressurized Water Reactor PSIG................................................................................... Pounds per Square Inch Gauge R...............................................................................................................................Roentgen RCC................................................................................................. Reactor Control Console RCS..................................................................................................Reactor Coolant System Rem, rem, REM........................................................................... Roentgen Equivalent Man Rep CET................................................................Representative Core Exit Thermocouple RETS...........................................................Radiological Effluent Technical Specifications RFAT.......................................................................... Radiological Field Assessment Team R(P)V............................................................................................ Reactor (Pressure) Vessel RVLIS....................................................................Reactor Vessel Level Indicating System RVLMS.................................................................Reactor Vessel Level Monitoring System RWLIS..................................................................Refueling Water Level Indicating System RWT......................................................................................Refueling Water Storage Tank SAR.................................................................................................... Safety Analysis Report SBO.............................................................................................................. Station Blackout SBOG.........................................................................................Station Blackout Generator SCBA.......................................................................... Self-Contained Breathing Apparatus SG.............................................................................................................. Steam Generator SI.................................................................................................................. Safety Injection SIAS................................................................................ Safety Injection Actuation System Page 20 of 230

r PVNGS EMERGENCY PLAN REVISION 59 PAGE 123 of 332 SOCA............................................................................Security Owner Controlled Area SPDS.........................................................................Safety Parameter Display System SRO....................................................................................... Senior Reactor Operator STSC........................................................................ Satellite Technical Support Center SUT................................................................................................Startup Transformer TEDE............................................................................ Total Effective Dose Equivalent TOAF................................................................................................. Top of Active Fuel TSC....................................................................................... Technical Support Center UFSAR.................................................................Updated Final Safety Analysis Report WOG................................................................................ Westinghouse Owners Group Page 21 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 124 of 332 6.0 PVNGS-TO-NEI 99-01, Rev. 6, EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of a PVNGS EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the PVNGS EALs based on the NEI guidance can be found in the EAL Comparison Matrix.

PVNGS NEI 99-01, Rev. 6 Example EAL 1C EAL RU1.1 AU1 1.2 RU1.2 AU1 3 RU2.1 AU2 1 RA1.1 AA1 1 RA1.2 AA1 2 RA1.3 AA1 3 RA2.1 AA2 1 RA2.2 AA2 2 RA2.3 AA2 3 RA3.1 AA3 1 RA3.2 AA3 2 RS1.1 AS1 1 RSI .2 AS1 2 RSI .3 AS1 3 RS2.1 AS2 1 RG1.1 AG1 1 RG1.2 AG1 2 RG1.3 AG1 3 RG2.1 AG2 1 CU1.1 GUI 1 CU1.2 GUI 2 Page 22 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 125 of 332 PVNGS NEI 99-01, Rev. 6 Example EAL IC EAL CU2.1 CU2 1 CU3.1 CU3 1 CU3.2 CU3 2 CU4.1 CU4 1 CU5.1 CU5 1.2,3 CA1.1 CA1 1 CA1.2 CA1 2 CA2.1 CA2 1 CA3.1 CA3 1,2 CA6.1 CA6 1 CS1.1 CS1 3 CG1.1 CG1 2 FA1.1 FA1 1 FS1.1 FS1 1 FG1.1 FG1 1 HU1.1 HU1 1,23 HU2.1 HU2 1 HU3.1 HU3 1 HU3.2 HU3 2 HU3.3 HU3 3 HU3.4 HU3 4 HU4.1 HU4 1 HU4.2 HU4 2 HU4.3 HU4 3 HU4.4 HU4 4 Page 23 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 126 of 332 PVNGS NEI 99-01, Rev. 6 Example EAL IC EAL HU7.1 HU7 1 HA1.1 HA1 1,2 HA5.1 HAS 1 HA6.1 HA6 1 HA7.1 HA7 1 HS1.1 HS1 1 HS6.1 HS6 1 HS7.1 HS7 1 HG7.1 HG7 1 SU1.1 SU1 1 SU3.1 SU2 1 SU4.1 SU3 1 SU4.2 SU3 2 SU5.1 SU4 1,2,3 SU6.1 SU5 1 SU6.2 SU5 2 SU7.1 sue 1.2, 3 SU8.1 SU7 1,2 SA1.1 SA1 1 SA3.1 SA2 1 SA6.1 SA5 1 SA9.1 SA9 1 SS1.1 SSI 1 SS2.1 SS8 1 SS6.1 SS5 1 Page 24 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 127 of 332 PVNGS NEI 99-01, Rev. 6 Example EAL IC EAL SG1.1 SGI 1 SG1.2 SG8 1 EU1.1 EU1 1 I'.

Page 25 Of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 128 of 332 7.0 ATTACHMENTS Attachment 1 - Emergency Action Level Technical Bases Attachment 2 - Fission Product Barrier Loss/Potential Loss Matrix and Basis Attachment 3 - Safe Operation & Shutdown Rooms Tables R-2 & H-2 Bases Attachment 4 - Palo Verde Safety System List Page 26 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 129 of 332 ATTACHMENT 1 EAL Technical Bases Category R - Abnormal Rad Release / Rad Effluent EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Radioactivity release through degradation of fission product barriers is not always apparent via non-radiological symptoms.

Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification.

At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Elevated area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.

Events of this category pertain to the following subcategories:

1. Radiological Effluent Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.

2. Irradiated Fuel Event Conditions indicative of a loss of adequate shielding or damage to irradiated fuel may preclude access to vital plant areas or result in radiological releases that warrant emergency classification.

3. Area Radiation Levels Sustained general area radiation levels which may preclude access to areas requiring continuous occupancy also warrant emergency classification.

Page 27 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 130 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity > 2 times the ODCM limits for 60 minutes or longer EAL:

RU1.1 Unusual Event Reading on any Table R-1 effluent radiation monitor > column "UE" for > 60 minutes (Notes 1,2, 3)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer VALID for classification purposes.

Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent Low RU-143 Ch 1 1.04E-02 pCi/cc 1.22E-03 pCi/cc Plant Vent High RU-144 Ch 1 1.04E+00 pCi/cc 1.04E-01 pCi/cc Gaseous Fuel Building Low RU-145 Chi 1.13E-02 pCi/cc RU-146 Ch 1 3.50E+00 pCi/cc 3.50E-01 pCi/cc Fuel Building High RU-146 Ch2 3.50E+01 pCi/cc Mode Applicability:

All Definition(s):

None Basis:

The column UE" gaseous release values in Table R-1 represent two times the appropriate ODCM release rate limits associated with the specified monitors (ref. 1,2).

This 1C addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous radiological release, monitored or un monitored.

Page 28 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 131 of 332 ATTACHMENT 1 EAL Technical Bases Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

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

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

This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous effluent pathways.

Escalation of the emergency classification level would be via IC RA1.

PVNGS Basis Reference(s):

1. Offsite Dose Calculation Manual Palo Verde Nuclear Generating Station Units 1, 2 and 3

2. Letter 102-05894-DCM/CJS, Dated 9/15/08, PVNGS Units 1, 2, 3, and ISFSI Docket Nos. 50-528, 50-529, 50-530, and 72-44 Proposed PVNGS Emergency Plan Change to Implement NEI 99-01, Revision 5, Emergency Action Levels (EALs) Attachment 1 Radiological Calculations

3. NEI 99-01, AU1 Page 29 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 132 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

EAL:

RU1.2 Unusual Event Sample analysis for a gaseous release indicates a concentration or release rate

> 2 X ODCM limits for ^ 60 minutes (Notes 1,2)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Note 2; If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

Ail Definition(s):

None Basis:

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

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

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

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

This EAL addresses uncontrolled gaseous releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways.

Escalation of the emergency classification level would be via IC RA1.

Page 30 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 133 of 332 ATTACHMENT 1 EAL Technical Bases PVNGS Basis Reference(s):

1. Offsite Dose Calculation Manual Palo Verde Nuclear Generating Station Units 1, 2 and 3

2. NEI 99-01, AU1 Page 31 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 134 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

RA1.1 Alert Reading on any Table R-1 effluent radiation monitor > column "ALERT" for >15 minutes (Notes 1,2, 3,4)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer VALID for classification purposes.

Note4 The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for tr^

emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table R-1 Effluent Monitor Classification Thresholds

+ Monitor GE SAE Alert UE Plant Vent Low RU-143 Ch 1 1.04E-02 pCi/cc 1.22E-03 pCi/cc Plant Vent High RU-144 Ch 1 1.04E+00 pCi/cc 1.04E-01 pCi/cc -

Fuel Building Low RU-145 Ch1 1.13E-02 pCi/cc RU-146 Ch 1 3.50E+00 pCi/cc 3.50E-01 pCi/cc Fuel Building High RU-146 Ch 2 3.50E+01 pCi/cc Mode Applicability:

All Definition(s):

None Page 32 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 135 of 332 ATTACHMENT 1 EAL Technical Bases Basis:

This EAL address gaseous radioactivity releases, that for \whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed either:

lOmRemTEDE 50 mRem CDE Thyroid The column ALERT gaseous effluent release values in Table R-1 correspond to calculated doses of 1% (10% of the SAE thresholds) of the ERA Protective Action Guidelines (TEDE or CDE Thyroid) (ref. 1).

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

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

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

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

Escalation of the emergency classification level would be via 1C RSI.

PVNGS Basis Reference(s):

1. Letter 102-05894-DCM/CJS, Dated 9/15/08, PVNGS Units 1, 2, 3, and ISFSI Docket Nos. 50-528, 50-529, 50-530, and 72-44, Proposed PVNGS Emergency Plan Change to Implement NEI 99-01, Revision 5, Emergency Action Levels (EALs) Attachment 1 Radiological Calculations

2. NEI 99-01, AA1 Page 33 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 136 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

RA1.2 Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - The boundary of a reactor site beyond which the land or property is not owned, leased, or otherwise controlled by the licensee.

Basis:

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

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

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

Escalation of the emergency classification level would be via 1C RSI.

PVNGS Basis Reference(s):

1. Procedure EP-0903, Accident Assessment

2. NEI 99-01, AA1 Page 34 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 137 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

RA1.3 Alert Field sun/ey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates >10 mR/hr expected to continue for > 60 minutes

Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 minutes of inhalation.

(Notes 1,2)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - The boundary of a reactor site beyond which the land or property is not owned, leased, or otherwise controlled by the licensee.

Basis:

Procedure EP-0904, ERO/ERF Activation and Operation, provides guidance for emergency or post-accident radiological environmental monitoring (ref. 1).

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

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

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

Escalation of the emergency classification level would be via 1C RSI.

Page 35 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 138 of 332 ATTACHMENT 1 EAL Technical Bases PVNGS Basis Reference(s):

1. Procedure EP-0904, ERO/ERF Activation and Operation

2. NEI 99-01, AA1

-t; Page 36 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 139 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

RS1.1 Site Area Emergency Reading on any Table R-1 effluent radiation monitor > column "SAE" for ^15 minutes (Notes 1,2, 3, 4)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer VALID for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RSI .1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Aiert UE Plant Vent Low RU-143 Ch 1 1.04E-02 pCi/cc 1.22E-03 pCi/cc Plant Vent High RU-144 Ch 1 1.04E+00 pCi/cc 1.04E-01 pCi/cc Fuel Building Low RU-145 Ch1 1.13E-02 pCi/cc RU-146 Ch 1 3.50E+00 pCi/cc 3.50E-01 pCi/cc Fuel Building High RU-146 Ch 2 3.50E+01 pCi/cc Mode Applicability:

All Definition(s):

None Page 37 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 140 of 332 ATTACHMENT 1 EAL Technical Bases Basis:

This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed either:

100 mRem TEDE

500 mRem CDE Thyroid The column SAE gaseous effluent release value in Table R-1 corresponds to calculated doses of 10% of the ERA Protective Action Guidelines (TEDE or CDE Thyroid) (ref. 1).

This 1C addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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

Escalation of the emergency classification level would be via 1C RG1.

r.= PVNGS Basis Reference(s):

1. Letter 102-05894-DCM/CJS, Dated 9/15/08, PVNGS Units 1, 2, 3, and ISFSI Docket Nos. 50-528, 50-529, 50-530, and 72-44 Proposed PVNGS Emergency Plan Change to Implement NEI99-01, Revision 5, Emergency Action Levels (EALs) Attachment 1 Radiological Calculations

2. NEI 99-01, AS1 Page 38 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 141 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

RSI .2 Site Area Emergency Dose assessment using actual meteorology indicates doses >100 mrem TEDE or 500 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - The boundary of a reactor site beyond which the land or property is not owned, leased, or otherwise controlled by the licensee.

Basis:

This 1C addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via 1C RG1.

PVNGS Basis Reference(s):

1. Procedure EP-0903, Accident Assessment

2. NEI 99-01, AS1 Page 39 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 142 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

RSI .3 Site Area Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates >100 mR/hr expected to continue for > 60 minutes

Analyses of field survey samples indicate thyroid CDE > 500 mrem for 60 minutes of inhalation.

(Notes 1,2)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - The boundary of a reactor site beyond which the land or property is not owned, leased, or otherwise controlled by the licensee.

Basis:

Procedure EP-0904, ERO/ERF Activation and Operation, provides guidance for emergency or post-accident radiological environmental monitoring (ref. 1).

This 1C addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equai to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via 1C RG1.

Page 40 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 143 of 332 ATTACHMENT 1 EAL Technical Bases PVNGS Basis Reference(s):

1. Procedure EP-0904, ERO/ERF Activation and Operation

2. NEI 99-01, AS1 Page 41 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 144 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

RG1.1 General Emergency Reading on any Table R-1 effluent radiation monitor > column "GE" for ^15 minutes (Notes 1,2, 3, 4)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer VALID for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent Low RU-143 Ch 1 1.04E-02 pCi/cc 1.22E-03 pCi/cc Plant Vent High RU-144 Ch 1 1.04E+00 pCi/cc 1.04E-01 pCi/cc Fuel Building Low RU-145 Ch1 1.13E-02 pCi/cc RU-146 Ch 1 3.50E+00 pCi/cc 3.50E-01 pCi/cc Fuel Building High RU-146 Ch2 3.50E+01 pCi/cc Mode Applicability:

All Definition(s):

None Page 42 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 145 of 332 ATTACHMENT 1 EAL Technical Bases Basis:

This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed either:

1000 mRem TEDE

5000 mRem CDE Thyroid The column GE gaseous effluent release values in Table R-1 correspond to calculated doses of 100% of the ERA Protective Action Guidelines (TEDE or CDE Thyroid) (ref. 1).

This 1C addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

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

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

PVNGS Basis Reference(s):

1. Letter 102-05894-DCM/CJS, Dated 9/15/08, PVNGS Units 1, 2, 3, and ISFSI Docket Nos. 50-528, 50-529, 50-530, and 72-44 Proposed PVNGS Emergency Plan Change to Implement NEI 99-01, Revision 5, Emergency Action Levels (EALs) Attachment 1 Radiological Calculations

2. NEI 99-01, AG1 Page 43 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 146 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

RG1.2 General Emergency Dose assessment using actual meteorology indicates doses > 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - The boundary of a reactor site beyond which the land or property is not owned, leased, or othenwise controlled by the licensee.

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the ERA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

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

PVNGS Basis Reference(s):

1. Procedure EP-0903, Accident Assessment

2. NEI 99-01, AG1 Page 44 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 147 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

RG1.3 General Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 1,000 mR/hr expected to continue for > 60 minutes

Analyses of field survey samples indicate thyroid CDE > 5,000 mrem for 60 minutes of inhalation.

(Notes 1,2)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY-The boundary of a reactor site beyond which the land or property is not owned, leased, or othenwise controlled by the licensee.

Basis:

Procedure EP-0904, ERO/ERF Activation and Operation, provides guidance for emergency or post-accident radiological environmental monitoring (ref. 1).

This 1C addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

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

Page 45 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 148 of 332 ATTACHMENT 1 EAL Technical Bases PVNGS Basis Reference(s):

1. Procedure EP-0904, ERO/ERF Activation and Operation

2. NEI 99-01, AG1 Page 46 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 149 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: UNPLANNED loss of water level above irradiated fuel EAL:

RU2.1 Unusual Event UNPLANNED water level drop in the REFUELING PATHWAY as indicated by low water level alarm (PCN-E02) or level indication (installed plant indicator/camera or RWLIS)

AND UNPLANNED alert alarm on any of the following corresponding radiation monitors:

RU-16 Containment Operating Level Area

RU-17 Incore Instrument Area (when installed)

RU-19 New Fuel Area

RU-31 Spent Fuel Pool Area

RU-33 Refueling Machine Area (when installed)

Mode Applicability:

All Definition(s):

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

REFUELING PATHWAY- The reactor refueling pool, fuel storage pool and fuel transfer canal comprise the refueling pathway.

Basis:

The low water level alarm in this EAL refers to the Fuel Pool low level alarm (procedure 40AL-9PC01, Fuel Pool Cooling and Cleanup Local Alarm Panel PCN-E02 Responses) (ref. 1). During the fuel transfer phase of refueling operations, the fuel transfer canal is normally in communication with the fuel storage pool and the refueling pool in the Containment is in communication with the fuel transfer canal when the fuel transfer tube is open. A lowering in water level in the SFP, fuel transfer canal or refueling pool is therefore sensed by the SFP low level alarm, (ref. 1,2).

The SFP is locally monitored in the Fuel Building by Level indicators PCN-LIT-3/5 on PCNE02.

These level indicating transmitters also initiate local panel alarms via level switches PCN-LSHL-3/PCN-LSL-5 on low and low low SFP level respectively. The alarms are also located on PCNE02 and annunciate a general Control Room alarm on window FUEL POOL CLG SYS TRBL indicating an alarm is in on the local panel.

Page 47 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 150 of 332 ATTACHMENT 1 EAL Technical Bases Level is also indicated in the Control Room visually via digital camera feed and in the back panel area on panel PCN-E015 by a digital level indicator. This Control Room indication does not have associated annunciation.

Technical Specification LCO 3.7.14 (ref. 3) requires at least 23 ft of water above the Fuel Storage Pool storage racks. Technical Specification LCO 3.9.6 (ref. 4) requires at least 23 ft of water above the Reactor Vessel flange in the refueling pool. During refueling, this maintains sufficient water level in the fuel transfer canal, refueling pool and SFP to retain iodine fission product activity in the water in the event of a fuel handling accident.

The listed radiation monitors are those expected to see increased area radiation levels as a result of a loss of REFUELING PATHWAY inventory (ref. 2). Increasing radiation indications on these monitors in the absence of indications of decreasing REFUELING PATHWAY level are not classifiable under this EAL. The Alert alarms are set very low (3 X normal background) and would promptly alert operators of any increase in area radiation (ref. 5).

When the spent fuel pool and reactor cavity are connected, there could exist the possibility of uncovering irradiated fuel. Therefore, this EAL is applicable for conditions in which irradiated fuel is being transferred to and from the reactor vessel and spent fuel pool.

This IC addresses a decrease in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.

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

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may increase due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an unplanned loss of water level.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance with Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC RA2.

PVNGS Basis Reference(s):

1. Procedure 40AL-9PC01, Fuel Pool Cooling and Cleanup Local Alarm Panel PCN-E02 Responses

2. Procedure 40AO-9ZZ23, Loss of SFP Level or Cooling

3. Technical Specification LCO 3.7.14, Fuel Storage Pool Water Level

4. Technical Specification LCO 3.9.6, Refueling Water Level - Fuel Assemblies

5. Design Basis Manual - Radiation Monitoring System

6. NEI 99-01, AU2 Page 48 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 151 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

RA2.1 Alert Uncovery of irradiated fuel in the REFUELING PATHWAY Mode Applicability:

All Definition(s):

REFUELING PATHWAY - The reactor refueling pool, fuel storage pool and fuel transfer canal comprise the refueling pathway.

Basis:

This IC addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

This EAL applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC EU1.1.

Escalation of the emergency would be based on either Recognition Category R or C ICs.

This EAL escalates from RU2.1 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve).

Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect an increase in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC RS1.

PVNGS Basis Reference(s):

1. Procedure 40AO-9ZZ23, Loss of SFP Level or Cooling

2. NEI 99-01, AA2 Page 49 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 152 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

RA2.2 Alert Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by high alarm on any of the following:

RU-16 Containment Operating Level Area

RU-17 Incore Instrument Area (when installed)

RU-19 New Fuel Area

RU-31 Spent Fuel Pool Area

RU-33 Refueling Machine Area (when installed)

RU-37/38 Containment Purge Exhaust Area

r.

RU-143 Plant Vent

RU-145 Fuel Building Vent Mode Applicability:

All Definition(s):

None Basis:

The specified radiation monitors are those expected to see increase area radiation levels as a result of damage to irradiated fuel (ref. 1,2).

This IC addresses events that have caused actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

This EAL applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with EU1.1.

Escalation of the emergency would be based on either Recognition Category R or C ICs.

This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

Page 50 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 153 of 332 ATTACHMENT 1 EAL Technical Bases Escalation of the emergency classification level would be via IC RS1, PVNGS Basis Reference(s):

1. Design Basis Manual - Radiation Monitoring System

2. Procedure 40AO-9ZZ22, Fuel Damage

3. NEI 99-01, AA2 Page 51 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 154 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

RA2.3 Alert Spent fuel pool level < 125 ft. (Level 2)

Mode Applicability:

All Definition(s):

None Basis:

For PVNGS, Level 2, which corresponds to 10 ft. above the top of the fuel racks in the SFP (9 ft.

based on instrument indication margin), is an indicated level oM25 ft. (ref. 2).

This 1C addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actuai or potential substantial degradation of the level of safety of the plant.

Escalation of the emergency would be based on either Recognition Category R or C ICs.

Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

PVNGS Basis Reference(s):

1. Letter 102-06728, dated July 11, 2013, and Adams Accession #13199A033, Response to Request for Additional Information for the PVNGS Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Level Instrumentation (Order Number EA-12-051)

2. Evaluation 4512970 3 NEI 99-01, AA2 Page 52 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 155 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level at the top of the fuel racks EAL:

RS2.1 Site Area Emergency Spent fuel pool level < 116 ft. (Level 3)

Mode Applicability:

All K

Definition(s):

I: , None Basis:

For PVNGS, Level 3, which corresponds to 0 ft. above the top of the fuel racks in the SFP, is an indicated level of 116 ft. (includes a 1 ft.10 inches instrument indication error margin) (ref. 2).

This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

It is recognized that this 1C would likely not be met until well after another Site Area Emergency 1C was met; however, it is included to provide classification diversity.

Escalation of the emergency classification level would be via 1C RG1 or RG2.

PVNGS Basis Reference(s):

1. Letter 102-06728, dated July 11,2013 and Adams Accession #13199A033, Response to Request for Additional Information for the PVNGS Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Level Instrumentation (Order Number EA-12-051)

2. Evaluation 4512970

3. NEI 99-01, AS2 Page 53 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 156 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer EAL:

RG2.1 General Emergency Spent fuel pool level cannot be restored to at least 116 ft. (Level 3) for > 60 minutes (Note 1)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

All Definition(s):

None Basis:

For PVNGS, Level 3, which corresponds to 0 ft. above the top of the fuel racks in the SFP, is an indicated level of 116 ft. (includes a 1 ft.10 inches instrument indication error margin) (ref. 2).

This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment.

It is recognized that this 1C would likely not be met until well after another General Emergency 1C was met; however, it is included to provide classification diversity.

PVNGS Basis Reference(s):

1. Letter 102-06728, dated July 11,2013 and Adams Accession #13199A033, Response to Request for Additional Information for the PVNGS Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Level Instrumentation (Order Number EA-12-051)

2. Evaluation 4512970

3. NEI 99-01, AG2 Page 54 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 157 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

RA3.1 Alert Dose rates > 15 mR/hr in EITHER of the following areas:

Control Room OR Central Alarm Station (CAS) (by survey)

Mode Applicability:

All Definition(s):

None Basis:

Areas that meet this threshold include the Control Room and the Central Alarm Station (CAS).

The Radiation Monitoring System monitors the Control room for area radiation (ref. 1). If unavailable local radiation surveys can be performed. The CAS is included in this EAL because of its importance to permitting access to areas required to assure safe plant operations.

There is no permanently installed CAS area radiation monitor that may be used to assess this EAL threshold. Therefore this threshold must be assessed via local radiation survey for the CAS (ref. 1).

This 1C addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Coordinator should consider the cause of the increased radiation levels and determine if another 1C may be applicable.

Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.

PVNGS Basis Reference(s):

1. Design Basis Manual - Radiation Monitoring System

2. NEI 99-01, AA3 Page 55 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 158 of 332 ATTACHMENT 1 EAL Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

RA3.2 Alert An UNPLANNED event results in radiation levels that prohibit or IMPEDE access to any Table R-2 rooms (Note 5)

Note 5; If the equipment in the listed room was already inoperable or out-of-service before the event occurred, then no emergency classification is warranted.

Table R-2 Safe Operation & Shutdown Rooms Room Mode Applicability Control Building 100 ft. Class DC Equipment Room C 4,5 Control Building 100 ft. Class DC Equipment Room D 4,5 Mode Applicability:

4 - Hot Shutdown, 5 - Cold Shutdown Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

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

Basis:

If the equipment in the listed room was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact I-.'

beyond that already allowed by Technical Specifications at the time of the event.

The list of plant rooms with entry-related mode applicability identified specify those rooms that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room (ref. 1).

This 1C addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or Page 56 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 159 of 332 ATTACHMENT 1 EAL Technical Bases potential substantial degradation of the level of safety of the plant. The Emergency Coordinator should consider the cause of the increased radiation levels and determine if another IC may be applicable.

For RA3.2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as K' impeded if extraordinary measures are necessary to faciiitate entry of personnel into the affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply:

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation increase occurs and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

>'.'V

The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).

The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

The access control measures are of a conservative or precautionary nature and would not actually prevent or impede a required action.

Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.

NOTE: EAL RA3.2 mode applicability has been limited to the applicable modes identified in Table R-2 Safe Operation & Shutdown Rooms/Areas. If due to plant operating procedure or plant configuration changes, the applicable plant modes specified in Table R-2 are changed, a corresponding change to Attachment 3 Safe Operation & Shutdown Areas Tables R-2 & H-2 Bases and to EAL RA3.2 mode applicability is required.

PVNGS Basis Reference(s):

1. Attachment 3 - Safe Operation & Shutdown Areas Tables R-3 & H-2 Bases

2. NEI 99-01, AA3 Page 57 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 160 of 332 ATTACHMENT 1 EAL Technical Bases Cateqorv E - Independent Spent Fuel Storage Installation (ISFSI)

EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

An independent spent fuel storage installation (ISFSI) is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a canister must escape its packaging and enter the environment for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel.

A Notification of Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask confinement boundary is damaged or violated.

Page 58 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 161 of 332 ATTACHMENT 1 EAL Technical Bases Category: ISFSI Subcategory: Confinement Boundary Initiating Condition: Damage to a loaded cask CONFINEMENT BOUNDARY EAL:

EU1.1 Unusual Event Damage to a loaded canister CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading on the surface of a loaded spent fuel cask greater than any of the following:

100 mrem/hr (neutron + gamma) on the side of the cask

100 mrem/hr (neutron + gamma) on the top of the cask 200 mrem/hr (neutron + gamma) at the air inlets or outlets Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the PVNGS ISFSI, Confinement Boundary is defined as the Transportable Storage Canister (TSC) for the NAC-UMS.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) - A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Basis:

The PVNGS ISFSI utilizes the NAC-UMS dry spent fuel storage system for dry spent fuel storage.

The system consist of a Transportable Storage Canister (TSC) and concrete Vertical Concrete Cask (VCC). The TSC is the CONFINEMENT BOUNDARY. The TSC is welded and designed to provide confinement of all radionuclides under normal, off-normal and accident conditions (ref. 1, 2).

Confinement boundary is defined as the barrier(s) between areas containing radioactive substances and the environment. Therefore, damage to a confinement boundary must be a confirmed physical breach between the spent fuel and the environment for the TSC.

The values shown represent 2 times the limits specified in the ISFSI Certificate of Compliance (C of C) Technical Specification for radiation external to a loaded TSC for a NAC-UMS canister (ref.

1)

Page 59 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 162 of 332 ATTACHMENT 1 EAL Technical Bases This 1C addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of damage is determined by radiological survey. The ISFSI C of C technical specification multiple of 2 times, which is also used in Recognition Category R 1C RU1, is used

fw '

here to distinguish between non-emergency and emergency conditions. The emphasis for this i- ^

classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the on-contact dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.

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

PVNGS Basis Reference(s):

1. USNRC Certificate of Compliance for NAC Internationals UMS Spent Fuel Storage Casks No. 1015, Amendment 5 .Appendix A, Technical Specifications for the NAC-UMS System

2. NEI 99-01, E-HU1 Page 60 of 230

>> .1 PVNGS EMERGENCY PLAN REVISION 59 PAGE 163 of 332 ATTACHMENT 1 EAL Technical Bases Category C - Cold Shutdown / Refueling System Malfunction EAL Group; Cold Conditions (RCS temperature 5 210°F); EALs in this category are applicable only in one or more cold operating modes.

Category C EALs are directly associated with cold shutdown or refueling system safety functions.

Given the variability of plant configurations (e.g., systems out-of-service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended outage has less significance than a similar loss occurring during the first week after shutdown. Compounding these events is the likelihood that instrumentation necessary for assessment may also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to RCS integrity, containment closure and fuel clad integrity for the applicable operating modes (5 - Cold Shutdown, 6 - Refueling, D - Defueled).

The events of this category pertain to the following subcategories:

1. RCS Level RCS water level is directly related to the status of adequate core cooling and, therefore, fuel clad integrity.

2. Loss of Emergency AC Power Loss of emergency plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 4.16KV AC emergency buses.

3. RCS Temperature Uncontrolled or inadvertent temperature or pressure increases are indicative of a potential loss of safety functions.

4. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125V DC vital buses.

5. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.

6. Hazardous Event Affecting Safety Systems Certain hazardous natural and technological events may result in visible damage to or degraded performance of safety systems warranting classification.

Page 61 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 164 of 332 ATTACHMENT 1 EAL Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory for 15 minutes or longer EAL:

CU1.1 Unusual Event UNPLANNED loss of reactor coolant results in RCS water level less than a required lower limit for > 15 minutes (Notes 1,10)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Note 10: Variations in RCS boron concentration, temperature and Containment Temperature from those used in RWLIS calibration will induce indication errors. Refer to Operator Assistance Program RWLIS_Spreadsheet xls.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

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

Basis:

With the plant in Cold Shutdown, RCS water level is normally maintained above the partial drain condition of 10% pressurizer level (117 ft. RWLIS W.R.) (ref. 1). However, if RCS level is being controlled below the pressurizer partial drain setpoint, or if level is being maintained in a designated band in the reactor vessel it is the inability to maintain level above the low end of the designated control band due to a loss of inventory resulting from a leak in the RCS that is the concern.

Wth the plant in Refueling mode, RCS water level is normally maintained at or above the reactor vessel flange (Technical Specification LCO 3.9.6 requires at least 23 ft. of water above the top of the reactor vessel flange in the refueling pool during refueling operations) (ref. 2).

Procedure 40OP-9ZZ16, RCS Drain Operations, provides direction regarding variations in RCS boron concentration, temperature and Containment Temperature from those used in RWLIS calibration will induce indication errors, which are addressed by a controlled program, Operator Assistance Program RWLIS_Spreadsheet.xls (ref. 1).

This 1C addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that decrease RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasing below a procedurally required Page 62 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 165 of 332 ATTACHMENT 1 EAL Technical Bases limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

This EAL recognizes that the minimum required RCS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.

The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either 1C CA1 or CA3.

PVNGS Basis Reference(s):

1. Procedure 40OP-9ZZ16, RCS Drain Operations

2. Technical Specification LCO 3.9.6, Refueling Water Level - Fuel Assemblies

3. NEI 99-01, CU1 Page 63 of 230

PVNGS EMERGENCY PLAN REVISION 59 PAGE 166 of 332 ATTACHMENT 1 EAL Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory for 15 minutes or longer EAL:

CU1.2 Unusual Event RCS level cannot be monitored AND EITHER

UNPLANNED increase in any Table C-1 sump/tank level due to loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Table C-1 Sumps/Tanks

Containment Sumps

Reactor Cavity Sump

Auxiliary Building Sumps

eves Holdup Tank

Reactor Drain Tank

Refueling Water Tank Equipment Drain Tank Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

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

Basis:

In Cold Shutdown mode, the RCS will normally be intact and standard RCS level monitoring means are available.

In the Refuel mode, the RCS is not intact and reactor vessel level may be monitored by different means, including the ability to monitor level visually.

In this EAL, all water level indication is unavailable and the RCS inventory loss must be detected by indirect leakage indications (Table C-1). Level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage. If the make-up rate to the RCS unexplainably rises above the pre-established rate, a loss of RCS inventory may be occurring Page 64 of 230

ML17269A334

Text

SUMMARY

18.1 INTRODUCTION

SUMMARY

18.1 INTRODUCTION

4.0 REFERENCES

4.0 REFERENCES

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