Text

ISFSI - Revision 13 to the Emergency Plan
	ML16020A010
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	12/01/2015
From:	Recasha Mitchell; Connecticut Yankee Atomic Power Co
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
	CY-15-043
	Download: ML16020A010 (48)
	v • d • e

CONNECTICUT YANKEE ATOMIC POWER COMPANY 362 INJUN HOLLOW ROAD

EAST HAMPTON, CT 06424-3099

~HADDAM NECK PLANT December 1, 2015 CY- 15-043 Re: 10 CFR 50.54(q)(5) 10 CFR 72.44(f) 10 CFR 50.4(b)(5) 10 CFR 72.4 ATTN: Document Control Desk, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation NRC License Nos. DPR-61 and SFGL-21 (NRC Docket Nos. 50-213 and 72-39)

Subject:

Revision 13 to the Haddam Neck Plant ISFSI Emergency Plan In accordance with 10 CFR 50.54(q)(5), 10 CFR 72.44(f), 10 CFR 50.4(b)(5), and 10 CFR 72.4, Connecticut Yankee Atomic Power Company (CYAPCO) is providing Revision 13 of the Haddam Neck Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan, and a summary of the analysis that determined that the changes do not constitute a reduction in commitment, nor a decrease in effectiveness of the Haddam Neck ISFSI Emergency Plan. provides a summary of the evaluation that provides the basis for concluding the Haddam Neck ISFSi Emergency Plan, as changed, continues to meet the standards of 10 CER 50.47(b) and the requirements of Appendix E to Part 50 as modified by the existing exemptions for the Haddam Neck ISFSI. provides a copy of Revision 13 of the Haddam Neck ISFSI Emergency Plan. It was effective on December 1, 2015 .This letter contains no commitments.

If you have any questions regarding this submittal, please do not hesitate to contact me at (860) 267-6426 ext. 303.

S / *-/Respectfully, Robert Mitche 1 ISFSI Manager

Connecticut Yankee Atomic Power Company CY-15-043/December 1, 2015/Page 2 Attachments and Enclosures - Summary of 10 CFR 50.54(q) Evaluation for Changes to the Haddam Neck ISFSI Emergency Plan - Haddam Neck ISFSI Emergency Plan, Revision 13 cc: D. H. Dorman, NRC Region I Administrator R. Powell, Chief, Decommissioning Branch, NRC, Region I J. Goshen, NRC Project Manager J. Semancik, Director, CT DEEP, Radiation Division M. Firsick, CT DEEP, Radiation Division G. McCahill, CT DEEP, Radiation Division S. Eckersley, CT State Police, Troop K, Colchester, CT CT State Police, Emergency Planning Officer J. Agapito, U.S. Coast Guard, Sector Long Island Sound D. Ferrari, Department of Emergency Management & Homeland Security A. Alonzo, Town of Haddam R. McGarry, Haddam Neck Volunteer Fire Department

Attachment 1 to CY-15-043 Summary of Proposed Changes to the Haddam Neck ISFSI Emergency Plan Section /Table Description of Proposed Change Justification of Proposed Change Section 3.1.3 Change word "Sever" to "Severe" This was an editorial change.

in title.

Section 5.3, Changed "off normal" to This change is a clarification. The ISFSI First Bullet "emergency." Shift Supervisor (ISS) is trained and responsible to recognize emergency events to implement the Emergency Plan.

The ISS is also trained and responsible to recognize off normal events but these events do not implement the Emergency

______ _____Plan.

Section 5.5.4 Deleted airborne monitoring and This change is a clarification. The protective clothing, responsibility to do airborne monitoring and maintain the airborne monitoring equipment lies with the Radiation Protection contractor. BO procedures have been revised to reflect this responsibility. The Radiation Protection contractor is responsible to provide Protective Clothing as necessary.

Section 8.4 Deleted reference to SP-1 1, A self-assessment identified only BO -1, "Testing and Maintenance of EO-2 and EO-5 as Emergency Plan Security Equipment." Implementing Procedures. SP-1 1 had been previously identified as an Emergency Preparedness Implementing Procedure because testing of equipment listed in the Emergency Plan was completed in this procedure. The assessment mentioned above noted that SP-1 1 is actually a supporting document not an implementing procedure since testing of equipment did not meet the intent or definition of an implementing procedure in accordance with Appendix E of Part 50. This section has been changed to state that testing is completed in accordance with approved procedure(s).

Appendix A, Added parenthesis around rem This is a change to clarifyr what a remn is.

Abbreviations explanation.

and Acronyms Appendix C, Deleted EO-6, Non-Emergency EO-6 never implemented the Emergency Emergency Event Assessment Plan. A self-assessment identified that Plan although the actions in EO-6 were Implementing necessary they did not meet the intent or Procedures ________________definition of an implementing procedure.

Page 1 of 3

Attachment 1 to CY-15-043 Summary of Proposed Changes to the Haddam Neck ISFSI Emergency Plan Section /Table Description of Proposed Change IJustification of Proposed Change The actions that were in EO-6 have been incorporated into other procedures as follows:

Medical Response - ES-i1 Spills - ES-4 The assessment identified the following procedures as Emergency Plan Implementing Procedures in accordance with Appendix E to Part 50:

EO-1 - Emergency Plan Implementation EO Response to Accident and Natural Phenomena Events EO Emergency Plan Administration These procedures contain the following as required by Appendix E of Part 50:

Organization (Emergency)

Assessment Actions

Activation of the Emergency Organization

Notification Procedures oEmergency Facilities and Equipment

Training

Maintaining Emergency Preparedness

Recovery Page 2 of 3

Attachment 1 to CY-15-043 Summary of Proposed Changes to the Haddam Neck ISFSI Emergency Plan Section /Table Description of Proposed Change Justification of Proposed Change Appendix C, Deleted SP-1 1, Testing and A self-assessment identified only EQ -1, Emergency Maintenance of Security EO-2 and EO-5 as Emergency Plan Plan Equipment Implementing Procedures. SP-1 1 had Implementing been previously identified as an Procedures Emergency Preparedness Implementing Procedure because testing of equipment listed in the Emergency Plan was completed in this procedure. The assessment mentioned above noted that SP-1 1 is actually a supporting document not an implementing procedure since testing of equipment did not meet the intent or definition of an implementing procedure in accordance with Appendix E of Part 50.

Through-out Minor clerical and grammatical These changes are considered to be the Emergency changes. administrative in nature.

Plan ______________________________

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ENCLOSURE 1 TO CY-15-043 HIADDAM NECK ISFSI EMERGENCY PLAN, REVISION 13

CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 Effective Date: DEC 01 2015

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 TABLE OF CONTENTS Section Page

1.0 INTRODUCTION

...................................................................... 1-1 2.0 FACILITY DESCRIPTION 2.1 Site................................................................................ 2-1 2.2 Surrounding Area................................................................ 2-1 2.3 Independent Spent Fuel Storage Installation (ISFSI) ........................ 2-1 3.0 ACCIDENTS 3.1 Off-Normal Events....................3-1 3.2 Accidents ........................................................................ 3-2 4.0 CLASSIFICATION 4.1 Classification of Accidents ..................................................... 4-1 4.2 Emergency Action Levels (EALs)............................................. 4-1 4.3 Unusual Event ................................................................... 4-2 5.0 RESPONSE 5.1 Recognition and Classification................................................. 5-1 5.2 Notification and Activation .................................................... 5-1 5.3 Emergency Response Organization (ERO) Actions.......................... 5-1 5.4 Radiological Assessment ....................................................... 5-2 5.5 Protective Measures............................................................. 5-3 5.6 FirstAid and Medical........................................................... 5-4 5.7 Fire Fighting..................................................................... 5-5 5.8 Termination...................................................................... 5-5 5.9 Recovery ......................................................................... 5-5 6.0 FACILITIES AND EQUIPMENT 6.1 Normal Facilities................................................................ 6-1 6.2 Emergency Facilities............................................................ 6-1 6.3 Systems, Equipment and Advisory Services.................................. 6-1 6.4 Communications ...................................................... :.......... 6-2 7.0 ORGANIZATION AND RESPONSIBILITIES 7.1 Normal Organization............................................................ 7-1 7.2 Emergency Response Organization (ERO).................................... 7-i 7.3 Local/Off-Site Support ......................................................... 7-3 7.4 State and Federal Government Response ..................................... 7-3 8.0 MAINTAINING EMERGENCY PREPAREDNESS 8.1 Training .......................................................................... 8-1 8.2 Drills and Exercises............................................................. 8-2 8.3 Review and Update of Emergency Plan and Implementing Procedure .... 8-3 8.4 Periodic Surveillances...................8-3 8.5 Independent Review ............................................................ 8-4 I

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 APPENDICES A. Definitions, Abbreviations and Acronyms.................................... A-i B. Letters of Agreements........................................................... B-i!

C. Implementing Procedtures ...................................................... C-i ii

HADDAM NECK ISFSI EMERGENCY PLAN~

REVISION 13

1.0 INTRODUCTION

This document describes Connecticut Yankee Atomic Power Company's (CYAPCO's) plans for responding to emergencies that may arise at the Haddam Neck Independent Spent Fuel Storage Installation (ISFSI).

This document provides the plan for responding to emergencies that may arise during dry storage of spent nuclear fuel and Greater Than Class C (GTCC) Waste at the ISFSI, including off-normal and accident events and consequences as presented in the NAC Multi-Purpose Canister (NAC-MPC) System Final Safety Analysis Report (ESAR).

There are no power plant or decommissioning accidents addressed in this Emergency Plan such as those previously described in the CYAPCO HKP UIFSAR.

The analyses of the radiological impact of potential accidents at the ISFSI site conclude that any releases beyond the ISFSI Controlled Area boundaries are expected to be less than the U. S. Environmental Protection Agency (EPA) Protective Action Guide (PAG) exposure levels, as detailed in EPA-400-R-92-00l, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents". Exposure levels, which warrant pre-planned response measures, are generally limited to the ISFSI pad and nearby vicinity, and for this reason radiological emergency planning is focused on this area.

Since the postulated worst-case accidents involving the ISFSI have insignificant consequences to the public health and safety, all emergencies are classified as no higher than Unusual Events. If an emergency condition develops, the ISFSI Shift Supervisor (ISS) is responsible for classifying the event and assuming the role of the Emergency Director (IS S/ED). The on-shift organization is responsible for performing response activities and may be augmented with additional emergency response personnel at the discretion of the ISS/ED. Notification is made to the Connecticut Department of Emergency Management and Homeland Security (DEMIHS), Connecticut Department of Energyand Environmental Protection (CT DEEP) and Nuclear Regulatory Commission (NRC). Conditions are assessed and corrective actions are implemented to restore the facility to a normal, stable condition. While the need to implement is unlikely, protective actions, including on-site evacuation, accountability and access control can be implemented as determined by the IS S/ED.

Thne ISFSIl Manager is responsible for overall management of the Emergency Preparedness Program.

The CYAPCO HNP Emergency Plan is based on applicable regulations, industry guaidelines and the NAC-MIPC Final Safety Analysis Report (FSAIR) accident analysis for spent fuel storage. Regulations include 10 CFR 50.47(b), 10 CFR 50 Appendix E, 10 CFR 50.54(q) and 10 CFR 50.54(t). The Emergency Action Levels (EALs) are based on Nuclear Energy Institute (NEI) 99-0 1 Rev.4 "Methodology for Development of Emergency Action Levels". This revision of the Emergency Plan is intended for end state conditions where power plant dismantlement and decommissioning have been completed and the ISFSI is the only thing remaining on the site, therefore the Emergency 1-1

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 Plan addresses only the off-normal events and accidents described in Chapter 11 of the NAC-MPC Final Safety Analysis Report (FSAR).

Although not required, the Connecticut Yankee Emergency Action Level Basis Document was kept current though Revision 1. Since the above listed items are the basis for the Emergency Plan, the practice of maintaining a separate basis document has been discontinued.

1-2

IHADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 2.0 FACILITY DESCRIPTION 2.1 Site The Haddam Neck Plant (JI-INP) site, which was the site of the Haddam Neck Nuclear power plant, is located in the town of Haddam Neck, Middlesex County, Connecticut, on the east bank of the Connecticut River. The Haddam Neck Plant site, which is approximately 525 acres, is situated approximately 9 miles southeast of downtown Middletown, and approximately 20 miles southeast of Hartford.

Of the 525 acres, approximately 5.7 acres is retained under an NRC License in which the ISFSI is located as shown on Figure 2.1.

2.2 Surrounding Area Except for several small towns and villages and a portion of Middletown, the area within a ten mile radius is predominantly rural. The majority of this area is wooded, with the remaining area devoted to general farming, resorts and some minor industry.

2.3 Independent Spent Fuel Storage Installation (ISFSI)

All of the CYAPCO spent nuclear fuel and GTCC waste has been placed into dry storage at the ISFSI. The ISFSI contains a total of 43 Vertical Concrete Casks (VCCs). Forty (40) VCCs (10 rows with four VCCs per row) are used for storage of the HNP spent nuclear fuel. Three additional VCCs are used for storage of GTCC waste. The ISFSI provides storage until the spent fuel and GTCC is removed by the Department of Energy for transfer to a federal long term storage facility.

The ISFSI is located near the south end of the HNP site and just north of the ridge that parallels the discharge canal. The ISFSI pad is surrounded by a Protected Area (PA) fence and a Security fence. The ISFSI has a Controlled Area that extends at least 300 meters from the spent nuclear fuel storage area.

There is a Restricted Area at the ISFSI which facilitates controlling and monitoring radiological exposure to on-site personnel. The Protected Area Boundary is located at the Restricted Area Boundary.

There is an ISFSI Monitoring Station Building near and southeast of the ISFSI that houses the ISFSI Staff and Security, colmmunication and other miscellaneous equipment. Access to the ISFSI Protected Area is controlled and monitored by the ISFSI staff from this location. There is also an ISFSI Support Facility near the ISFSI Monitoring Station Building.

2-1

LIADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 Implementation of protective actions related to the emergency events is not considered necessary beyond the approximate NRC Licensed Area in which the ISFSI Protected Area, ISFSI Monitoring Station and ISFSI Support Facility are located.

The ISFSI is designed for interim storage of fuel in a contained shielded system.

GYAPCO utilizes the NAG International Inc. (NAG) Multi-Purpose Canister (MPC) spent fuel cask storage system (NAC-MPC) in an ISFSI at the HNP under the provisions of a general license. A general license is granted by 10 CFR 72.2 10 for storage of spent nuclear fuel in an ISFSI at power reactor sites to persons that are authorized to possess or operate nuclear power reactors under 10 GFR 50. Currently, GYAPCO is only authorized by the NRC to store and possess the spent fuel at the HNP by the Possession Only License (No. DPR-61) pursuant to the provisions of 10 GFR 50. Thus, CYAPCO has been granted a general license (Docket No. 72-0039) for the storage of spent fuel at an ISESI at the IN-P site.

The NAG-MPG System is a canister based system for the storage and transportation of spent nuclear fuel. The primary components of the NAC-MPC System consist of the Transportable Storage Canister (TSC), the storage pad and the Vertical Concrete Cask (VCG). The TSC is intended to be compatible with the NAG-Storable Transport Cask (STC) to allow future shipment. The VCC provides radiation shielding and contains internal airflow paths that allow decay heat from the TSC spent fuel contents to be removed by natural air circulation around the canister wall.

2-2

PROPERTY BOUNDARY C

C E* PROPERTY c-?

U- PROPERTY BOUNDARY 22

-o jDRAv*J~ ecu e4-2013 CONNECTICUT YANKEE PROPERTY BOUNDARY NOTE I: THE ISF51 SITE CONSISTS OP APPROXIMATELY 5,7 ACRES.

NOTE 2: THE CONTROLLED AREA IS DEFINED AS 3D0 METERS FROM THE PROTECTED AREA GENERAL SITE PLAN FENCELIHE, NOTE 3: THE PROPERTY CONSISTS OF APPROXIMATELY 525 ACRES. AND IS BOUNDED BY THE CONNECTICUT RIVER TO THE SOUTHWEST AND ThE SALMON RIVER TO THE EAST AND)

SHEET 1 OF 1 NORTHEAST.

CrI L Fkicure 2.1 j13

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 3.0 ACCIDENTS The following is a list of off-normal events and a brief description of the design basis accidents described in Chapter 11 of the NAC-MPC Safety Analysis Report. There are no power plant or decommissioning accidents addressed in this Emergency Plan, such as those previously described in the CYAPCO HiNP UFSAR.

3.1 Off-Normal Events There are several off-normal events. It is unlikely that these will occur, but they are postulated events that could occur once during any calendar year of operation.

The off-normal events described below do not result in any serious consequences.

Canister off-normal handling problems are no longer considered, since the ISFSI loading is complete.

3.1.1 Blockage of Half of the Air"Inlets This is a hypothetical event that assumes one-half of the air inlets of a NAC-MPC storage cask are blocked at the normal ambient temperature.

There are no adverse consequences for this off-normal condition. The maximum component temperatures are less than the allowable temperatures. The NAC-MiPC storage cask continues to perform its function with one-half of the air inlets blocked. There are no significant radiological consequences for this event. There is dose to a worker that is clearing the inlets.

3.1.2 Failure of Instrumentation This is a hypothetical event that assumes that the temperature-sensing system to measure the outlet air temperature at each of the four air outlets for a NAC-MPC cask fails. The NAC-MPC canister and storage casks are a large thermal sink. During the period of loss of instrumentation, no significant change in canister temperature will occur under normal conditions. There are no radiological consequences for this event.

3.1i.3 Severe Environmental Conditions (i00°F and -40°F)

An analysis of the steady state effects of high and low ambient temperature conditions on the performance of a NAC-MPC cask was performed. There are no adverse consequences for this off-normal condition. The maximum component temperatures are within the allowable temperature values. The materials used are not subject to low temperature brittle fracture. There are no radiological consequences for this event.

3-1

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 3.1.4 Small Release of Radioactive Particulates from the Canister Exterior An analysis was performed to determine the consequences of a release from a slightly contaminated external surface of a canister that went undetected. The projected dose at a boundary located 100 meters from the CY-MPC cask ISFSI, is calculated to be less than 2 moremo. These analyses are highly conservative and demonstrate that the potential off-site radiological consequences from the release of canister surface contamination are negligible.

Procedural steps were employed to ensure that the canister surface was generally free of surface contamination prior to its installation in the storage cask. The surface of the canister is free of traps that could hold contamination. Thus, the presence of external surface contamination on the canister is unlikely.

3.2 Accidents Results of analyses of design basis and hypothetical accident conditions evaluated for the NAG-MPG system show that there is substantial design margin for safety to the public and on-site personnel. The following accidents are considered very low probability events.

3.2.1 Accident Pressurization This is a hypothetical event that assumes the failure of all fuel rods at the maximum internal temperature. Pressurization is caused by release of fission and fill gases. There are no radiological consequences for this accident and canister performance is not significantly affected. There are no corrective actions required.

3.2.2 Earthquake The Analysis shows that the design basis earthquake does not affect the NAG-MPG vertical concrete cask performance. The vertical concrete cask does not tip over for the design-basis earthquake having ground accelerations of 0.25g.

Inspection of the storage casks is required following an earthquake. While the cask does not tip over, there is potential for movement of a cask relative to other casks and for superficial damage at the bottom edge due to that movement. The temperature monitoring system should be checked for operation as movement of a cask could disconnect or damage the monitoring system.

3-2

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 3.2.3 Explosion An explosion is unlikely because administrative controls exclude explosive substances in the vicinity of the ISFSI.

There are no radiological consequences for this accident. Inspection of the VCCs is required to ensure that the air inlets and outlets are free of debris and to ensure that the monitoring system is intact. There are no recovery or corrective actions required for this accident event.

3.2.4 Failure of All Fuel Rods with a Subsequent Ground Level Breach of the Canister There is no mechanistic failure of the confinement boundary of the canister.

3.2.5 Fire A fire is a very unlikely occurrence since there are no flammable materials stored in the area of the ISFSI. Concrete that reaches 300°F could separate from the cask resulting in increased radiation levels, but this is not expected to occur.

Following a fire, the concrete cask should be inspected for general deterioration of the concrete, loss of shielding (spalling of concrete),

exposed reinforcing bar, and surface discoloration that could affect heat rejection. This inspection would determine the repair activities necessary to return the concrete storage cask to its design basis configuration.

3.2.6 Flood The NAC-MPC system is not adversely affected by a desig-n basis flood having a depth of water of 50 feet and a flow Vielocity of 15 feet per second. This flood is fully immersing for the NAG-MPG.

There are no radiological consequences for this accident.

The NAC-MPC vertical concrete cask system performance is not affected by the design basis flood; the concrete cask will not slide and will not overturn.

Inspection of the VCCs is required following a flood event. While the casks do not tip over or slide, there is a potential for the collection of debris or the accumulation of silt at the base of the cask, which could clog or obstruct the air inlets. Operation of the temperature monitoring system must be verified, as flood conditions may impair its operation.

3:~-3

TIADDAM NECK ISFSI EMERGENCY- PLAN REVISION 13 3.2.7 Fresh Fuel Loading This is an unlikely event now that ISFSI loading has been completed.

3.2.8 Full Blockage of Air Inlets and Outlets The likely cause of this event is a catastrophic event such as a greater than design basis earthquake or a land slide.

This is not a credible event.

3.2.9 Lightning The NAC-MPC storage cask does not experience adverse effects due to a lightning strike.

A lightning strike is a random weather related event. Since the NAC-MPC storage cask is located on an unsheltered pad, the storage cask may be subject to a lightning strike.

A lightning strike on a storage cask may be visually detected at the time of the strike, or by visible surface discoloration at the point of entry or exit of the current flow.

The current path analyzed is from a strike point on the outer radius of the top flange of the storage cask, down through the carbon steel liner and the bottom plate to the ground.

There are no radiological consequences for this accident.

The vertical concrete cask's performance is not affected by a lightning strike.

There are no recovery or corrective actions required for this accident event.

3.2.10 Maximum Anticipated Heat Load (125°F Ambient Temperature)

The cause of this condition is a weather event that causes the NAC-MPC to be subject to a 125°F ambient temperature with full sun exposure.

There are no radiological consequences, or adverse consequences for this accident condition. The maximum component temperatures are less than the allowable temperatures for accident conditions and are also less than the temperature limits for normal conditions of storage. No corrective actions are required for this accident condition.

3-4

HAD)DAM NECK ISFSI EMERGENCY PLAN REVISION 13 3.2.11 Drop of Vertical Concrete Cask This event involves dropping a loaded vertical concrete cask during routine handling operations. This event may be due to the failure of one or more of the cask lifting jacks or of the air pad system. This is unlikely to happen now that the JSFSI is fully loaded. There are no radiological consequences for this event.

3.2.12 Tip-Over of Vertical Concrete Cask A hypothetical non-credible accident condition has been postulated involving the non-mechanistic tip-over of a vertical concrete storage cask.

Functionally, the cask is not expected to suffer significant adverse consequences due to this event. The concrete cask and canister are expected to continue providing design basis shielding, geometry control of contents, and contents confinement performance. There is an adverse localized radiological consequence due to the hypothetical tip-over event since the bottom end of the concrete cask has significantly less shielding than the sides and top of these same components. For Yankee Atomic, the estimated dose rate from the bottom of a tipped-over cask is calculated to be approximately 156 rem/hr at 1 meter and 32 rem/hr at 5 meters. The CY cask bottom is constructed differently than the Rowe cask and the CY cask bottom dose rates are therefore lower than those calculated for the Rowe-MPC System.

Following a tip-over event, supplemental shielding should be used until the concrete cask can be up-righted. Surface top and bottom edges of the concrete cask are expected to exhibit cracking and possible loss of concrete down to the layer of reinforcing bar. The increased dose rate due to this cracking is not expected to be significant.

3.2.13 Tornado and Tornado Driven Missiles A tornado is a random weather event having a higher probability of occurrence at certain times of the year and in certain geographical areas.

The postulated tornado wind loading and missile impacts are not capable of overturning the cask, or penetrating the boundary established by the concrete cask.

There is little potential for significant damage to the concrete cask, which provides radiation shielding. For CY the worst tornado missile impact is expected to result in a local surface radiation dose rate at the point of penetration of 1000 mrem/hr. Since the area of reduced shielding is very small, there would not be a noticeable increase in the dose rate at the site boundary.

3J-5

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 A tornado event is not expected to result in the need to take any corrective action other than an inspection of the ISFSI. This inspection would be directed at ensuring that inlets and outlets had not become blocked by wind-blown debris and at checking for obvious (concrete) surface damage.

In the worst case, a tornado driven missile could dislodge concrete to a depth of approximately 6 inches.

3-6

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 4.0 CLASSIFICATION 4.1 Classification of Accidents This Plan provides for an emergency classification system based on NUREG-0654/FEMA REP 1, Revision 1, Appendix 1, "Emergency Action Level Guidelines for Nuclear Power Plants", and Nuclear Energy Institute (KEI) 99-01 (NUMARC/NESP-007), Revision 4, "Methodology for Development of Emergency Action Levels".

Based on NUREG-1 140, Regulatory Analysis of Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees, the NRC has determined that there are no credible design basis accidents that would exceed the EPA PAGs at an ISFSI Controlled Area boundary.. Emergency classification guidance in Appendix E of Nuclear Energy Institute document NEI 99-0 1 (Rev. 4),

"Methodology for Development of Emergency Action Levels", states, "The expectation of offsite response to an 'alert' classified under 10 CFR 72.32 emergency plan are generally consistent with those for a notification of unusual event in a 10 CFR 50.47 emergency plan, i.e., to provide assistance if requested".

The NEBI 99-01 guidance is utilized in this plan to classify ISFSI emergency events. The NRC Regulatory Analysis for Rev. 4 of Reg. Guide 1.101 to accept NET 99-0 1, determined that the guidance in NET 99-0 1 is appropriate for developing site specific EALs, to meet the intent of 10 CFR 50.47(b) (4) and Appendix E to Part 50.

Accidents and off-normal events that are analyzed for the ISFSI, including some events considered to be non-credible, have been reviewed and assigned a classification. There are no credible design basis accidents that would exceed the EPA PAGs at the ISFSI Controlled Area boundary. Table 4-1 summarizes events that are classified as an Unusual Event.

This plan classifies events based on predetermined Emergency Action Levels (EALs). This approach provides a simple, predetermined response to an emergency event or accident, allowing a coordinated approach to the eventual mitigation of the conditions and restoring the facility to a safe status.

The State of Connecticut Radiological Emergency Response Plan (RERP) requires that incidents be assigned a posture code at the time of classification. The ISFSI Shift Supervisor will report both the NRC Incident Classification and the State Posture Code during an event at the ISESI to State authorities (CT DEMIHIS and CT DEEP).

4.2 Emergency Action Levels (EALs)

An event is classified based on specific information contained in the table of Emergency Action Levels (EALs), Table 4.1. This table lists possible Initiating Conditions (ICs) and Emergency Action Levels (EALs) associated with possible 4-1

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 incidents. EALs include predetermined values or conditions and are used to determine that the severity of an event has progressed to that which warrants being classified as an Unusual Event.

During an event, the ISFSI Shift Supervisor is responsible for evaluating the conditions that exist, comparing them to the EALs and declaring an Unusual Event if EAL criteria is met.

Upon declaring an Unusual Event, the IS S/ED uses the Emergency Operating (EO) Procedures, which implement the Emergency Plan and detail the steps to be taken to deal with the emergency that exists.

4.3 Unusual Event The Unusual Event classification sig-nifies that events are in progress or have occurred which indicate a potential degradation of the level of safety at the facility. Unusual events are not expected to cause a release of radioactive material requiring offsite response to the ISFSI.

The purpose of an Unusual Event classification is to bring the on-shift staff to a state of readiness and to provide a systematic means of handling information and decision making.

4-2

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 TABLE 4-1 EMERGENCY ACTION LEVELS Initiating Conditions Emergency Action Level NRC Emergency Connecticut Classification State Posture Level Code ITU - DAMAGE TO 1. Natural Phenomena Events UNUSUAL DELTA ONE A LOADED CASK Affecting a Loaded Cask EVENT CONFINEMENT Confinement Boundary BOUNDARY 2. Accident Conditions Affecting a Loaded Cask Confinement Boundary

3. Any Condition in the opinion of the Emergency Director that indicates loss of Loaded Fuel Storage Cask Confinement Boundary.

HUJ2 - CONFIRMED Security Event at the ISFSI That UNUSUAL DELTA ONE SECURITY EVENT Results in the necessity to request EVENT WITH POTENTIAL LLEA to respond to the ISFSI LOSS OF LEVEL OF emergency.

SAFETY TO THE ISFSI________________________________

Note: DELTA ONE, does not involve a release of radioactive material.

4-3

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 5.0 RESPONSE 5.1 Reco~onition and Classification Recognition and classification of the incident are the responsibility of the 1SS/ED.

When conditions described in a specific Emergency Action Level (EAL) are reached, the ISS/ED classifies the event and declares an Unusual Event. Once the emergency classification is declared, the appropriate implementing procedures (listed in Appendix C) are implemented.

5.2 Notification and Activation The ISS/ED will notify on-shift and other appropriate ERG personnel of the emergency condition and any declaration of Unusual Event made, utilizing the notification channels found on Figure 5.1.

Upon declaration of an Unusual Event, the ISS/ED will notify the Connecticut Department of Emergency Management and Homeland Security (CT DEMHS),

Connecticut Department of Energy and Environmental Protection (CT DEEP) and N-RC within one hour of classifying the emergency. A representative from the CT DEEP may contact the ISFSI Monitoring Station Building and request additional information or might come to the site.

The ISS/ED will notify management personnel of any requests for public information. CY JSFSI Management personnel will handle and coordinate any public news releases and announcements.

5.3 Emergency Response Organization (ERG) Actions Conditions may occur which require the declaration of an Unusual Event. Upon classification and declaration of an emergency, ISFSI Shift Supervisor (ISS) assumes the position of Emergency Director (ED).

The following is a general summary of the actions taken in response to an Unusual Event:

ISS recognlizes emergency condition and assesses its significance.

IS S/ED assesses danger to on-site personnel and provides protective action guidance.

On-shift personnel respond as directed by the IS S/ED.

If necessary, emergency medical, fire department, or law enforcement agencies are notified and requested to provide assistance.

Corrective actions are implemented.

o Management personnel are notified.

Additional ERG support personnel are notified, as desired.

ISS classifies the event, declares the Unusual Event and assumes the role of ED.

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HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13

Emergency classification is communicated to on-shift personnel.

NRC and Connecticut DEMHS and DEEP are notified within one hour of declaration.

The ISS/ED will notify management personnel of any requests for public information. CY ISFSI management personnel will handle and coordinate any public news releases and announcements.

Recovery actions are implemented, as appropriate

ISS/ED will terminate the event, as appropriate.

5.4 Radiological Assessment Radiological assessment may be initiated upon classification of an emergency.

However, the only signaificant radiological consequences associated with the accident analyses presented in Chapter 11 of the NAC-MPC FSAR are associated with elevated dose rates caused by:

,o A hypothetical VCC tip-over exposing the bottom of the cask that has limited shielding.

VCC damage resulting from a design basis tornado induced missile that causes concrete to be removed from a small area on the VCC.

None of the NAC-MPC postulated accidents result in a loss of canister confinement boundary, so a radiological release is not expected. Even if the confinement boundary was affected, the consequences to the public health and safety would be insignificant, as there is no driving force for the release of radioactive material.

As a result, radiological assessment and protective actions would be limited to the determination of dose rates in the area of an affected VCC, the establishment of controls to prevent personnel from entering the area, and to assure that any recovery or repair activities are planned and executed in a manner that minimizes exposure.

5.4.1 Radiological Monitoring The level of monitoring activity will depend on the severity of the accident. The ISS/ED has the responsibility to determine the level of monitoring required, and to have radiation dose rate measurements taken as necessary. On-shift personnel will perform radiation dose rate measurements as necessary.

Exposure of individuals performing emergency functions is consistent with the limits specified in facility procedures. Every attempt will be made to keep personnel exposure As Low As Reasonably Achievable (ALARA).

5-2

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 5.4.2 Radiological Exposure Control The ISSiED is responsible for emergency radiological protection activities for facility staff and support personnel. The IS S/ED approves personnel exposure limits. 'When required by RP Procedures, all emergency response personnel are issued a Thenrno Luminescent Dosimeter (TLD) subject to provisions contained in Emergency Operating Procedures. Emergency response personnel dose records will be based upon the results of TLD data, as soon as the TLDs can be processed.

During an incident, higher than normal levels of radiation may be encountered. Under all situations, steps will be taken to minimize personnel radiation exposure. Specific exposure guidelines for entry or re-entry into areas in order to remove injured persons (rescue operations) or undertake corrective actions will be in accordance with the guidance set forth in facility procedures. The IS S/ED will authorize emergency exposure limits or more restrictive limits, dependent upon incident conditions. Medical responders and the ISS/ED will discuss the hazards involved in rescue operations prior to undertaking a rescue mission of this nature. The IS S/ED will administer emergency radiation exposure control. Authorization to allow emergency response personnel to receive doses in excess of 10 CFR 20 limits shall be made only by the IS S/ED and only during declared emergencies. Considerations to be made prior to allowing personnel to accept risks associated with rescue operations or high dose missions are defined in facility procedures.

5.5 Protective Measures 5.5.1 Accountability/Evacuation If determined to be necessary, the IS S/ED can initiate an accountability of all personnel on site, in accordance with Emergency Operating Procedures. Initial and continuous accountability of personnel will be coordinated by Security. All reports are provided to the IS S/ED.

In the unlikely event that the ISS/ED decides that an evacuation is needed, the IS S/ED will notify personnel of the need to evacuate. Individuals leaving the site will go to an assembly area designated by the IS S/ED.

Following an evacuation, accountability of personnel will be accomplished within 60 minutes. Appropriate steps will be taken to locate any unaccounted-for personnel.

ERO personnel remaining on-site or arriving on-site following an evacuation shall report to the Emergency Response Facility or alternate location, as directed.

5-3

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 5.5.2 Decontamination Capabilities Survey instrumentation for personnel frisking is available. Personnel contamination identified during the initial survey will require the contaminated individual to remove apparel, re-survey, and if skin contamination levels are identified, perform decontamination as specified in Emergency Operating Procedures.

In the event that accident conditions result in a contaminated injured individual, the victim's rescue and medical treatment take precedence over the victim's radiation exposure due to bodily contamination. Gross decontamination of the victim (generally limited to the removal of contaminated articles of clothing) will be accomplished to the extent that the health of the patient is not affected. Decontamination measures associated with wounds will be performed by the appropriately trained medical staff at the hospital under the supervision of the attending physician.

5.5.3 Access Control Access will usually be controlled at the vehicle barrier on the access road or other similar location, but access control could be established at other locations in an emergency as necessary.

5.5.4 Protective Equipment and Supplies Radiation dose rate survey and personnel contamination survey equipment is available and surveys will be conducted as necessary to ensure that personnel responding to an emergency are provided appropriate protection.

5.6 First Aid and Medical On-Shift personnel receive first aid training. A First Aid kit is located in the Emergency Response Facility.

Injured persons requiring off-site medical care will be transported to the Middlesex Hospital for treatment. Arrangements have been made with the Middlesex Hospital and the East Hampton Ambulance service to provide medical care for radiologically contaminated, injured individuals. Both the Middlesex Hospital and the East Hampton Ambulance service have personnel trained in radiation protection measures. Personnel requiring off-site treatment will be transported to the hospital by emergency vehicles, company vehicle, or employee private vehicle.

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HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 5.7 Fire Fighting On-Shift personnel are capable of using a portable fire extinguisher to put out a small, incipient stage fire. The Haddam Neck Volunteer Fire Department is responsible for all other fire fighting on site. On-Shift ISESI personnel will coordinate on-site activities with the Fire Department.

5.8 Termination In any Emergency, immediate response actions are directed toward limiting the consequences of the incident in a manner that will afford maximum protection to on-site personnel. Once the immediate corrective and on-site protective actions have been implemented, and the facility is restored to a stable and safe condition, termination of the emergency classification condition may be initiated. The IS S/ED will terminate the event and provide notification to appropriate off-site authorities and on-site personnel.

5.9 Recovery The primary objective of the facility staff is to mitigate the consequences of an emergency and restore the facility to a safe condition. Restoration of the facility effectively begins with the first action taken in response to the event and terminates when the facility resumes normal operations.

When conditions have stabilized and a full assessment of the event has been conducted, the facility staff will focus on establishing a plan to verify operability of all systems/components necessary to maintain and monitor the integrity of the spent fuel.

The ISFSI Manager or designee will coordinate the restoration of the facility and has the authority to take the necessary actions to ensure the facility is returned to a safe condition. Recovery responsibilities of the ISFSJ Manager inchlude but are not limited to:

Develop the site recovery plan.

Prioritize clean-up of affected areas/equipment.

Isolate and repair damaged equipment/systems.

Document actions taken related to recovery operations.

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HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 FIGURE 5.1 NOTIFICATION CHANNELS NOTES:

1) Notification will initially be made from the ISFSI Monitoring Station Building

2) NRC will be notified via FTSiENS

3) CT DEMLIS and DEEP will be notified via commercial telephone

4) Back-up communications will be via satellite telephone

5) Site Personnel will be notified via direct face-to-face, radio or telephone

6) Additional ERO personnel will be notified via telephone 5-6

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 6.0 FACILITIES AND EQUIPMENT 6.1 Normal Facilities Under normal conditions, the ISFSI Monitoring Station Building is the area where site access control, badging and ISFSI monitoring are performed.

6.2 Emergency Facilities 6.2.1 Emergency Response Facility During an emergency, the ISFSI Monitoring Station Building is the primary facility where JSFSI conditions are monitored and corrective actions are developed to mitigate any abnormal occurrence. Emergency conditions are managed by the IS S/ED at this location. The ISFSI Monitoring Station Building also serves as the Technical Support Center. The adjacent ISFSJ Support Facility provides additional space when needed.

The ISFSI Monitoring Station Building and ISFSI Support Facility are designated as the Emergency Response Facility (ERF) for members of the Emergency Response Organization to conduct analysis and support functions in response to the event.

During an emergency, access will be controlled, and dosimetry will be issued (if applicable) to local/support organizations entering the site at this location. The ERF also supports accountability, when required.

6.2.2 Assembly Areas Should a site evacuation be necessary, personnel will be directed to report to a safe assembly area designated by the IS S/ED.

6.2.3 First Aid Supplies Emergency medical equipment and supplies are located in the ERF and first aid treatment can be provided in the ERF.

6.3 Systems. Equipment and Advisory Services 6.3.1 Equipment Appropriate emergency equipment is stored in the Emergency Response Facility for use by the ERG. Supplies are inventoried to ensure operability and availability at all times.

Controlled copies of facility documents (Drawings, Procedures, Technical Specifications, SAR, etc.) are maintained or are accessible in the ISFSI Monitoring Station Building or ISFSI Support Facility. This information is readily available for the Emergency Response Organization to use.

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HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 6.3.2 Meteorological System General meteorological information can be obtained using the internet, telephone or other media when dealing with an emergency.

6.3.3 Fire Detection System and Protection Fire extinguaishers are located at the pre-determined areas at the Emergency Response Facility and can be used to extinguish or contain a fire.

The ISFSI Monitoring Station Building, the Electrical Equipment Enclosure (EEE), the Vehicle Barrier System Enclosure (VB-i) and the ISFSJ Support Facility have fire detection equipment.

6.3.4 VCC Temperature Monitoring System The VCC Temperature Monitoring System measures the exit air temperature from each of the VCC air outlet vents and the ambient air temperature. The System displays the individual VCC air outlet temperatures at a computer in the ISFSI Monitoring Station Building.

6.3.5 Off-Site Advisories The internet and other media can be assessed to obtain weather information, news, and other real time information.

6.4 Communication Communication and information flow is extremely important to ensure proper emergency response. A diagram showing Emergency Response Organization information flow is shown in Figure 6.1.

6.4.1 Onsite Communication Systems The on-site telephone system is the primary means of communication during an emergency. This system has an independent backup power configuration, which incorporates a combination of automatic and manual transfer switches between batteries and an emergency back up generator to ensure uninterrupted operation on a loss of normal power to the ISFSI telephone system.

The ERG is equipped with portable radios for onsite communications, as required. One or more licensed frequencies are used for routine communications.

6-2

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 6.4.2 Offsite Communication Systems A commercial telephone line is provided by the local phone company that facilitates off site communications. Power for this line is provided by the local phone company. A satellite phone and cellular phones provide back up methods of off site communications.

Commercial telephones are used to establish communications between the ISFSJ Monitoring Station Building and the Connecticut Department of Emergency Management and Homeland Security (CT DEMi-IS) and CT DEEP. This is the primary method of informing the State of Connecticut of a declared emergency at the ISFSI.

In the event the commercial telephone circuits fail, the Connecticut DEMHUS and DEEP can be contacted via satellite or cellular phone from the ISFSI Monitoring Station Building.

One or more state police frequencies are used for offsite routine and emergency communications.

In the event of an emergency at the ISFSI, the NRC will be notified in accordance with 10 CFR 50.72(a) using the Emergency Notification System (ENS). The ENS is a circuit of the Federal Telecommunications System (FTS). It is not anticipated to be used continuously, but primarily to provide periodic informational updates to the NRC. In the event that the ENS fails, commercial and satellite phones provide back up.

6.4.3 Facsimile Machine A facsimile machine allows hard copy sheets of information to be transmitted between the Emergency Response Facility and the off-site Agencies.

6.4.4 Backup Power Supply for Communications On-site telephones and other emergency communications equipment, including the satellite telephone, have backup power supply capabilities.

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HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 FIGURE 6.1 ERO COMMUNICATIONS FLOW Emergency

Response

Organization 6-4

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 7.0 ORGANIZATION AND RESPONSIBILITIES 7.1 Normal Organization The Connecticut Yankee ISFSI organization is headed by the ISFSI Manager.

On-Shift supervision is provided by an ISFSI Shift Supervisor (IS S), who reports to the ISFSI Manager. The ISS performs ISFSI operational duties and manages the ISFSI staff.

The minimum staff on duty during all shifts consists of one (1) ISS and the Security Force.

The Connecticut Yankee JSFSI organization is supported by the ISFSI Support Staff and off-site contracted personnel.

The ISFSI Manager is responsible for the overall management of the Emergency Preparedness Program.

7.2 Emergency Response Organization (ERO)

The Emergency Response Organization is comprised of on-shift ISFSI personnel.

Detection and recog-nition of conditions that warrant declaration of an emergency, in accordance with the EALs, is the responsibility of the ISS/ED. Upon declaration of an emergency, the on-shift organization assumes their emergency response duties and implements this plan.

The ISS/ED can call in additional Security personnel and/or local/off-site support (fire, police and ambulance) in numbers and disciplines as desired to support the response and recovery actions required for the event, as outlined in Figure 7.1. In addition, ISFSI Management can be utilized to augment the ERO. The ISS/ED will ensure personnel are given appropriate instructions and assignments to ensure that assistance resources are used effectively. Additional Security personnel are expected to respond in approximately two hours from the time that they are contacted.

7.2.1 On-Shift Organization When initiating conditions result in an EAL being reached, the ISS has the authority and responsibility to classify the emergency and initiate any actions to mitigate the consequences of the incident. The ISS assumes the responsibilities of Emergency Director (ED) and is the person in charge of the ERO. On-Shift personnel and personnel called in to augment the ERO interface with the ISSiED or his/her designee regarding the emergency.

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HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 Actions that the ISS/ED can not delegate are:

Classification of Incident.

Notification of incident.

Ordering of evacuation.

Authorization of radiation exposure in excess of 10 CFR 20 limits.

The primary responsibilities of the IS S/ED are:

Direction of emergency response activities.

a Colmmand and control of the ERG.

Classification and notification.

Assessment of dose consequences, if necessary

Authorization of onsite protective actions.

,, Determination of the need for and requesting assistance.

, Implementation of Emergency Plan and Emergency Operating Procedures.

Prioritization of ERG staff activities.

Periodic updates to the NRC and the State.

Assist ISFSI Manager with mitigation and recovery.

Interface with offsite agencies.

Communications.

Termination of the Event.

The ISS/ED may delegate administrative responsibilities, including logistical and clerical support, to available personnel not otherwise involved with the emergency. The ISS/ED has overall responsibility for the coordination of the emergency response activities of the augmented ERG.

The ISS/ED is responsible for directing all aspects of the response to an emergency. The IS S/ED will usually do this from the ISFSI Monitoring Station Building (ERF), but depending on the situation, the ISS/ED may carry out designated functions from another location.

The on-shift personnel are responsible for conducting all actions to bring the facility to a stable condition, including any necessary corrective actions, on-site protective actions, dose assessments, and first aid. These actions include notification to the NRC, CT DEMUS and CT DEEP and key management personnel.

The Security Staff is responsible for maintaining facility security in accordance with the Haddam Neck ISFSI Physical Security Plan. Security responds to threats to physical security, performs accountability, and assists in the evacuation of on-site personnel as directed by the IS S/ED.

Security personnel report to the ISS/ED or desig-nee.

7-2

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 On-Shift ISFSI personnel are capable of using a portable fire extinguisher to put out a small, incipient stage fire. The Haddam Neck Volunteer Fire Department is responsible for all other fire fighting on site. ISFSI personnel will coordinate on-site activities with the Fire Department.

7.2.2 Augmented Organization On-shift ISFSI personnel can implement the Emergency Plan without assistance from others. Additional personnel are available to assist the ERO, if desired, and are anticipated to respond in approximately two hours from the time they are contacted.

Personnel called in to augment the ERO may be assigned to perform activities such as the following, if required:

Performing spent fuel storage condition assessments.

Assessing the extent of damaged equipment.

Identifying short and long-term repair needs.

Supporting maintenance and repair activities.

, Developing plans to correct technical issues.

Establishing repair priorities and deploying repair teams.

o Coordinating available resources to restore equipment and systems.

, Handling logistical needs.

Performing radiological surveys and assessments.

Developing public information materials for release to the news media.

Facilitating communications with the NRC, the state and the news media.

7.3 Local/Off-Site Support Arrangements have been made with local organizations to provide:

Ambulance service for the transportation of injured personnel, including a contaminated injured person.

,, Hospital services for the treatment of injured or radioactively-contaminated injured individuals.

Fire fighting services. LLEA will provide additional support.

7.4 State and Federal Government Response State and Federal government response is expected to be limited to recording the notification of the emergency, periodically receiving updated information on the emergency, and coordinating public information news releases, if necessary.

7-3

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 If required, provisions exist for the State of Connecticut to halt traffic on the roads leading to the ISFSI site. The ISS/ED has the authority to request such support if it is needed.

7-4

HADDAM NECK ISFSI EM'vERGENCY PLAN REVISION 13 FIGURE 7.1 EMERGENCY RESPONSE ORGANIZATION Emergency Director Augmented Organization Local /Offsite Support On-Shift

Additional Security

Fire Department Organization Personnel

Ambulance

ISFSI Management o Hospitals

Police 7-5

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 8.0 MAINTAINING EMERGENCY PREPAREDNESS The ISFSI Manager has the overall responsibility for maintaining the Emergency Preparedness Program. The ISFSI Manager or designee is responsible for ensuring the availability of adequate resources and for ensuring the following tasks and functions are completed:

Maintenance of readiness of the on-site emergency response facilities and equipment.

Development and maintenance of the Emergency Plan.

Development and maintenance of the implementing procedures.

Preparation of scenarios for training drills and exercises.

Conduct of drills and exercises.

Providing input to emergency preparedness training of the support staff.

SReturning emergency equipment and supplies used during a drill, exercise or actual emergency to a state of readiness.

SProviding support for the annual radiation monitoring drill and medical emergency drill.

Reviewing EALs with state and local government authorities on an annual basis in accordance with 10 CFR 50 Appendix E (TV)(B).

8.1 Trai4pnin Training consists of lesson plan(s) designed to provide the skills and knowledge necessary to maintain staff proficiency. Each implementing procedure will be reviewed to identify activities that are not considered to be a part of on-shift ERO personnel's day-to-day routine function (e.g., use of telephones, general communication protocol, etc.). Lessons will focus on non-routine and specialized activities that are particular to the individual functions and overall emergency response actions. Training may consist of, but not be limited to, classroom lecture, self study, practical demonstrations, and facility drills.

8.1.1. Emergency Staff Training iDdLii U111i-Lt]~*i Wilt L* pJiUViU*U LldnLrgiic Uigiitlii LU familiarize the person with their duties, responsibilities and expected actions in the event of an emergency. This initial training will be completed prior to the individual assuming the on-shift assignment. Personnel called in will be assigned responsibilities within their specific areas of expertise.

Each on-shift person will be provided continuing training for their individual duties. This training will be conducted during the calendar year.

Continuing training addresses general changes to the Emergency Plan, facilities, equipment, regulations, policies and specific changes to their responsibilities (which are not considered part of their routine duties). It also addresses problem areas identified during audits, drills or exercises.

8-1

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 8.1.2 ISFSI Access Training The ISFSI Access Training provides personnel the basic elements of the Emergency Plan and expected actions during an emergency. Informnation is reviewed annually as part of maintaining site access authorization.

8.1.3 Off-Site Assistance Training Organizations, which may be called upon to render assistance onsite, will be offered general facility familiarization sessions on an annual basis.

These sessions may include a walk down of the facility, safety, building layout, access protocol, communications capabilities, and security requirements. Radiological orientation training will also be offered annually.

8.2 Drills and Exercises In addition to the emergency plan training described earlier, the facility staff will conduct periodic drills to enhance skills and knowledge of the practical implementation of the EP and demonstrate the adequacy of emergency facilities, equipment and procedures. Drills serve as an extension of the training program, allowing interaction between evaluators and ERO personnel to reinforce procedural requirements and overall process implementation. Periodic drills will be scheduled with various objectives to demonstrate these capabilities. Some drills will focus on specific functions (such as communications capabilities) while others will involve a broader amount of the Emergency Plan.

Off-Site support organizations (e.g., ambulance service, fire department and police department) and CT DEEP may be invited to participate in drills.

At least one drill shall be conducted between exercises, which are conducted every other year that involves a combination of some of the principal areas of on-site response capabilities (management, accident assessment, protective and corrective actions).

8.2.1 Drills In addition to training drills discussed above, the following drills will be conducted annually:

- Radiological Monitoring Drill - demonstrating conducting general area surveys.

- Medical Emergency Drill - demonstrating the capability for transporting an injured worker offsite.

- Fire Drill - conducted in accordance with the Fire Protection Program.

8-2

IIADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 8.2.2 Exercises An exercise will be conducted once every two years to demonstrate the capability to implement the Emergency Plan. Objectives will be developed to ensure major elements of the emergency plan are demonstrated and evaluated to ensure the appropriate level of preparedness is being maintained.

Off-site response organizations will be invited to participate in or observe the exercise.

8.2.3 Drill and Exercise Evaluation Facility staff will evaluate the exercise and drills. Expectations for evaluators will be discussed with each evaluator prior to the drill/exercise.

Evaluators should be assigned to evaluate functions/areas consistent with their expertise. Following the drill/exercise a critique of the evolution will be conducted. Comments will be evaluated and dispositioned by the ISFSI Manager and deficiencies will be corrected through retraining, remedial drills, or by other means. Comment resolution will be assigned to appropriate personnel for final implementation.

8.3 Review and Update of Emergency Plan and Implementing Procedures 8.3.1 Emergency Plan Review This plan, including all written agreements between CYAPCO and other parties, will be reviewed annually. Approved changes to the plan will be incorporated into the appropriate implementing procedures along with the plan changes. Letters of Agreement will be reviewed annually and verified to be in effect at the time of the plan review. This may be accomplished via written correspondence or documented telephone conversation.

This plan is a controlled document to ensure changes are incorporated into distributed copies. Plan changes will be approved by the ISFSI Manager.

8.3.2 Emergency Plan Implementing Procedure Review Procedures, which implement the EP, will be reviewed and revised in accordance with procedure control guidelines. Periodic revisions will be incorporated whenever a plan change is made that affects the procedure or other circumstances dictate a revision is necessary. Implementing procedures will be approved by the ISFSI Manager.

8.4 Periodic Surveillance Facilities and equipment will be maintained in accordance with written procedures or instructions. Inventories of Emergency Plan equipment will be conducted on a semi-annual basis and after facility activation (actual event or drill activity).

8-3

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 Telephone numbers that are important to emergency notification are maintained and are verified on a quarterly basis.

Telephone and radio systems used for on-site and off-site emergency communications are tested monthly using the applicable approved procedure(s).

8.5 Independent Review All Emergency Plan program elements shall be reviewed by persons having no direct responsibility for the implementation of the Emergency Preparedness Program at least once every 12 months to satisfy the requirements of 10 CFR 50.54 (t). A QAP audit covering all program elements satisfies this requirement.

8-4

HIADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 APPENDIX A DEFINITIONS, ABBREVIATIONS AN]) ACRONYMS DEFINITIONS Assessment Actions Those actions taken during or after an incident to obtain and process information that is necessary to make decisions to implement specific emergency measures.

Corrective Actions Actions taken to make improvements.

Emer.*encv Actions Those measures taken to improve or terminate an emergency situation.

Protective Actions An action taken to avoid or reduce radiological exposure to ISFSI personnel.

Recovery Actions Actions taken after an emergency to restore the facility to pre-emergency condition.

Airborne Radioactivity Any particulate or gaseous radioactive material dispersed in the air.

Confinement Boundary The confinement boundary of the canister consists of the canister shell, bottom plate, shield lid, structural lid, the two port covers, and the welds that join these components.(See Transportable Storage Canister definition)

Contamination (Radioactive)

Radioactive material in any place where it is unwanted (e.g., on persons, products or equipment).

Controlled Area An area defined by a 300 meter radius from the Protected Area fence.

Decontamination The reduction or removal of contaminating radioactive material from a person, area or object by cleaning or washing.

A-I

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 Emerffencv Action Level (EAL)

Thresholds for initiating emergency designating a particular class of emergency.

Emergency Director (ED)

The person in charge during an emergency.

Emergency Response Organization (ERG)

The organization responsible under emergency conditions.

Evacuation The orderly evacuation of personnel from the Protected Area, or Controlled Area, except for essential on-shift or Emergency Response Organization personnel.

Initiating Condition (IC)

An event where either the potential exists for a radiological or security emergency, or such an emergency has occurred.

ISFSI - Independent Spent Fuel Storagte Installation The facility designed and constructed to provide on-site dry storage of spent fuel and GTCC waste.

ISFSI Monitorin2 Station Building The primary location where conditions of the ISFSI are monitored and where actions are directed from during an emergency.

ISFSI Support Facility The structure adjacent to and providing addition space in support of the ISFSI Monitoring Station Building.

NAC-MPC System The NAC Intemnational Inc. Multi-Purpose Canister System which is being used to store spent fuel and GTCC waste. The NAC-MPC System consists of the Vertical Concrete Cask (VCC), the Transportable Storage Canister (TSC) and the ISESI storage pad.

Property Boundary Boundary line for the 525 acre Haddain Neck Plant site.

Protective Action Guides (-PAGs)

Proj ected absorbed dose to individuals in the general population which warrants protective action.

A-2

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 Radioactive Material Area (RMA)

Any area or room where there is stored an amount of licensed material exceeding 10 times the quantity of such material specified in Appendix C to 10 CFR 20.

Restricted Area:

An area, access to which is limited for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive material.

Site Boundary Boundary of the area that remains within the 10 CFR 50 License.

Transportable Storage canister (TSC)

The welded canister that provides containmaent for the spent fuel or GTCC waste. The loaded TSCs are placed inside of the VCCs for onsite dry storage.

Unusual Event (UIE)

Events are in progress or have occurred which indicate a potential for degradation of the level of safety of the facility. No release of radioactive material requiring offsite response is expected.

Vertical Concrete Cask (VCC)

The cask positioned on the ISFSI pad to store spent fuel and GTCC waste.

A-3

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 ABBREVIATIONS / ACRONYMS ALARA - As Low As Reasonably Achievable CFR - Code of Federal Regulations CT DEMiHS - Connecticut Department of Emergency Management and Homeland Security (was previously Office of Emergency Management (OEM))

CT DEEP - Connecticut Department of Energy and Environmental Protection EAL - Emergency Action Level ED - Emergency Director ENS - Emergency Notification System (NRC telephone circuit)

ERF - Emergency Response Facility ERO - Emergency Response Organization FTS - Federal Telecommunications System (NRC telephone system)

GTCC - Greater Than Class "C" (waste)

HNP - Haddam Neck Plant ISFSI - Indepefident Spent Fuel Storage Installation ISS - ISFSI Shift Supervisor mrem/hr - milli-rem (1/1000 rem) per hour NRC - U.S. Nuclear Regulatory Commission PA - Protected Area PAG - Protective Action Guide QAP - Quality Assurance Program rein - Roentgen Equivalent Man. (A measure of radiation exposure.)

TLD - Then-no Luminescent Dosimeter TSC - Transportable Storage Canister A-4

HADDAM NECK ISFSI EMERGENCY PLAN REVISION 13 APPENDIX B LETTERS OF AGREEMENT This appendix lists the letters of agreement in effect between Connecticut Yankee Atomic Power Company and off-site authorities and organizations. These agreements are reviewed annually with the involved parties. Signed copies of these agreemnents are maintained by the ISFSI Manager and are available for review upon request.

Organizations Haddam Neck Volunteer Fire Department State of Connecticut Department of Emergency Services and Public Protection, Division of State Police East Hampton Ambulance, Inc.

Middlesex Hospital B-I

HADDAM NECK ISFSI EM7ERGENCY PLAN REVISION 13 APPENDIX C EMERGENCY PLAN IMPLEMENTING PROCEDURES I. Emergency Plan Implementing Procedures

1. EQ-i Emergency Planning Administration

2. EO-2 Response to Accident and Natural Phenomena Events

3. EO-5 Emergency Plan Implementation C-1

CONNECTICUT YANKEE ATOMIC POWER COMPANY 362 INJUN HOLLOW ROAD

EAST HAMPTON, CT 06424-3099

~HADDAM NECK PLANT December 1, 2015 CY- 15-043 Re: 10 CFR 50.54(q)(5) 10 CFR 72.44(f) 10 CFR 50.4(b)(5) 10 CFR 72.4 ATTN: Document Control Desk, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation NRC License Nos. DPR-61 and SFGL-21 (NRC Docket Nos. 50-213 and 72-39)

Subject:

Revision 13 to the Haddam Neck Plant ISFSI Emergency Plan In accordance with 10 CFR 50.54(q)(5), 10 CFR 72.44(f), 10 CFR 50.4(b)(5), and 10 CFR 72.4, Connecticut Yankee Atomic Power Company (CYAPCO) is providing Revision 13 of the Haddam Neck Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan, and a summary of the analysis that determined that the changes do not constitute a reduction in commitment, nor a decrease in effectiveness of the Haddam Neck ISFSI Emergency Plan. provides a summary of the evaluation that provides the basis for concluding the Haddam Neck ISFSi Emergency Plan, as changed, continues to meet the standards of 10 CER 50.47(b) and the requirements of Appendix E to Part 50 as modified by the existing exemptions for the Haddam Neck ISFSI. provides a copy of Revision 13 of the Haddam Neck ISFSI Emergency Plan. It was effective on December 1, 2015 .This letter contains no commitments.

If you have any questions regarding this submittal, please do not hesitate to contact me at (860) 267-6426 ext. 303.

S / *-/Respectfully, Robert Mitche 1 ISFSI Manager

Connecticut Yankee Atomic Power Company CY-15-043/December 1, 2015/Page 2 Attachments and Enclosures - Summary of 10 CFR 50.54(q) Evaluation for Changes to the Haddam Neck ISFSI Emergency Plan - Haddam Neck ISFSI Emergency Plan, Revision 13 cc: D. H. Dorman, NRC Region I Administrator R. Powell, Chief, Decommissioning Branch, NRC, Region I J. Goshen, NRC Project Manager J. Semancik, Director, CT DEEP, Radiation Division M. Firsick, CT DEEP, Radiation Division G. McCahill, CT DEEP, Radiation Division S. Eckersley, CT State Police, Troop K, Colchester, CT CT State Police, Emergency Planning Officer J. Agapito, U.S. Coast Guard, Sector Long Island Sound D. Ferrari, Department of Emergency Management & Homeland Security A. Alonzo, Town of Haddam R. McGarry, Haddam Neck Volunteer Fire Department

Attachment 1 to CY-15-043 Summary of Proposed Changes to the Haddam Neck ISFSI Emergency Plan Section /Table Description of Proposed Change Justification of Proposed Change Section 3.1.3 Change word "Sever" to "Severe" This was an editorial change.

in title.

Section 5.3, Changed "off normal" to This change is a clarification. The ISFSI First Bullet "emergency." Shift Supervisor (ISS) is trained and responsible to recognize emergency events to implement the Emergency Plan.

The ISS is also trained and responsible to recognize off normal events but these events do not implement the Emergency

______ _____Plan.

Section 5.5.4 Deleted airborne monitoring and This change is a clarification. The protective clothing, responsibility to do airborne monitoring and maintain the airborne monitoring equipment lies with the Radiation Protection contractor. BO procedures have been revised to reflect this responsibility. The Radiation Protection contractor is responsible to provide Protective Clothing as necessary.

Section 8.4 Deleted reference to SP-1 1, A self-assessment identified only BO -1, "Testing and Maintenance of EO-2 and EO-5 as Emergency Plan Security Equipment." Implementing Procedures. SP-1 1 had been previously identified as an Emergency Preparedness Implementing Procedure because testing of equipment listed in the Emergency Plan was completed in this procedure. The assessment mentioned above noted that SP-1 1 is actually a supporting document not an implementing procedure since testing of equipment did not meet the intent or definition of an implementing procedure in accordance with Appendix E of Part 50. This section has been changed to state that testing is completed in accordance with approved procedure(s).

Appendix A, Added parenthesis around rem This is a change to clarifyr what a remn is.

Abbreviations explanation.

and Acronyms Appendix C, Deleted EO-6, Non-Emergency EO-6 never implemented the Emergency Emergency Event Assessment Plan. A self-assessment identified that Plan although the actions in EO-6 were Implementing necessary they did not meet the intent or Procedures ________________definition of an implementing procedure.

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Attachment 1 to CY-15-043 Summary of Proposed Changes to the Haddam Neck ISFSI Emergency Plan Section /Table Description of Proposed Change IJustification of Proposed Change The actions that were in EO-6 have been incorporated into other procedures as follows:

Medical Response - ES-i1 Spills - ES-4 The assessment identified the following procedures as Emergency Plan Implementing Procedures in accordance with Appendix E to Part 50:

EO-1 - Emergency Plan Implementation EO Response to Accident and Natural Phenomena Events EO Emergency Plan Administration These procedures contain the following as required by Appendix E of Part 50:

Organization (Emergency)

Assessment Actions

Activation of the Emergency Organization

Notification Procedures oEmergency Facilities and Equipment

Training

Maintaining Emergency Preparedness

Recovery Page 2 of 3