L-21-008, License Amendment Request to Approve Pilgrim Nuclear Power Station Independent Spent Fuel Storage Installation Only Emergency Plan

License Amendment Request to Approve Pilgrim Nuclear Power Station Independent Spent Fuel Storage Installation Only Emergency Plan

ML21049A192
Person / Time
Site:	Pilgrim
Issue date:	02/18/2021
From:	Sterdis A Holtec Decommissioning International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
HDI-PIL-21-008
Download: ML21049A192 (96)

Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 50.90 10 CFR 50.54(q)(4)

February 18, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Spent Fuel Storage Installation Only Emergency Plan Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket Nos. 50-293 and 72-1044

REFERENCE:

1. Letter, ENTERGY to US NRC, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, dated June 10, 2019, (Accession No. ML19161A033)

2. NRC Order Approving Direct and Indirect Transfer of License and Conforming License Amendment, dated August 22, 2019 (ML19170A265)

3. Letter, Holtec Decommissioning International, LLC to US NRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, dated March 31, 2020 (ML20091M858)

Pursuant to Title 10, Code of Federal Regulations (CFR) 50.90, Holtec Decommissioning International, LLC (HDI) hereby requests U.S. Nuclear Regulatory Commission (NRC) review and approval of the Pilgrim Nuclear Power Station (PNPS) Independent Spent Fuel Storage Installation Facility (ISFSI) Only Emergency Plan (IOEP).

By letter dated June 10, 2019 (Reference 1), Entergy submitted certifications for permanent cessation of reactor operations at PNPS and permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1). Therefore, as specified in 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for PNPS no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

On August 27, 2019, pursuant to the NRC Order (Reference 2), PNPS ownership and the PNPS operating licenses were transferred to Holtec Pilgrim, LLC and HDI, respectively. By letter dated March 31, 2020 (Reference 3), HDI provided an updated decommissioning schedule indicating that off-load of the PNPS spent fuel pool (SFP) and transfer of the spent fuel to the ISFSI is expected to be completed in early 2022. In support of this condition, revisions to the PNPS Emergency Plan and associated Emergency Action Level (EAL) Scheme are proposed to comport with the requirements for a facility configuration with all spent nuclear fuel in dry storage within an ISFSI.

HDI-PIL-21-008 Page 1 of 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 The reason for this proposed amendment request is to obtain NRC approval of the Pilgrim ISFSI Only Emergency Plan (IOEP) and associated EAL Scheme. The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4). to this letter provides a description and evaluation of the proposed ISFSI Only Emergency Plan. Attachment 1 to the Enclosure provides a clean version (no mark-up) of the PNPS IOEP and Attachment 2 to Enclosure 1 provides a clean version of the associated IO EALs.

HDI requests approval of the proposed emergency plan by September 30, 2021. Based on lessons learned from the Spring 2020 PNPS Spent Fuel Dry Cask Campaign and ongoing Oyster Creek Spent Fuel Dry Cask Transfers, HDI anticipates completion of PNPS spent fuel transfer to complete in November of 2021.

The proposed changes have been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c), and HDI has determined that this change involves no significant hazards consideration. HDI has also determined that the proposed changes satisfy the criteria for categorical exclusion in accordance with 10 CFR 51.22(c)(9) and do not require an environmental review. Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is required.

Pursuant to 10 CFR 50.91, Notice for public comment; State consultation, paragraph (b), a copy of this submittal is being provided to the Commonwealth of Massachusetts, Emergency Management Agency.

Should you have any questions or require further information, please contact me at (856) 797-0900, x 3813.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 18, 2021.

Sincerely, Digitally signed by Andrea Sterdis Andrea DN: cn=Andrea Sterdis, c=US, o=Holtec Decommissioning International, ou=HDI, Sterdis email=a.sterdis@holtec.com Date: 2021.02.18 10:31:00 -05'00' Andrea L. Sterdis Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC ALS/mjg HDI-PIL-21-008 Page 2 of 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 : Description of Proposed Changes, Technical and Regulatory Evaluation, Significant Hazards Determination, and Environmental Consideration.

Attachment 1: PNPS ISFSI Only Emergency Plan Attachment 2: PNPS ISFSI Only Emergency Action Levels and Technical Bases cc:

USNRC Regional Administrator, Region I USNRC Project Manager, NMSS - Pilgrim Nuclear Power Station USNRC Region I, Lead Inspector - Pilgrim Nuclear Power Station Director, Massachusetts Emergency Management Agency HDI-PIL-21-008 Page 3 of 3

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-008 Enclosure 1 Description of Proposed Changes, Technical and Regulatory Evaluation, Significant Hazards Determination, and Environmental Considerations License Amendment Request to Approve the Pilgrim Nuclear Power Station Emergency Plan and Emergency Action Level Scheme to Address the Independent Spent Fuel Storage Installation Facility Condition (22 pages follow)

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 DESCRIPTION OF PROPOSED CHANGES, TECHNICAL AND REGULATORY EVALUATION, SIGNIFICANT HAZARDS DETERMINATION, AND ENVIRONMENTAL CONSIDERATIONS

Subject:

License Amendment Request to Approve the Pilgrim Nuclear Power Station Emergency Plan and Emergency Action Level Scheme to Address the Independent Spent Fuel Storage Installation Facility Condition

3.0 PROPOSED CHANGE

S 3.1 Elimination of SFP Initiating Conditions and EALs 3.2 Emergency Response Organization Revision 3.3 Replacement of the Shift Manager with the ISFSI Shift Supervisor 3.4 ISFSI Only Emergency Plan 3.5 ISFSI Only Emergency Action Levels

4.0 TECHNICAL EVALUATION

4.1 Radiological Consequences of Design Basis Events 4.2 Radiological Consequences of Postulated Events 5.0

6.0 REGULATORY EVALUATION

6.1 Applicable Regulatory Requirements/Criteria No Significant Hazards Consideration 6.2 Aircraft Related Emergency Action Levels 6.3 No Significant Hazards Consideration Determination 6.4 Precedent 6.5 Conclusion

7.0 ENVIRONMENTAL CONSIDERATION

S

8.0 REFERENCES

, Pilgrim Nuclear Power Station ISFSI Only Emergency Plan , Pilgrim Nuclear Power Station ISFSI Only Emergency Action Level and Technical Bases Document to HDI-PIL-22-008 Page 1 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

1.0 INTRODUCTION

This evaluation supports a request to amend the Renewed Facility Operating License (OL)

DPR-35 for Pilgrim Nuclear Power Station (PNPS)

By letter on June 10, 2019 (Reference 1), Entergy Nuclear Operations, Inc provided certification of the permanent removal of fuel from the Reactor Vessel to the Nuclear Regulatory Commission (NRC) in accordance with 10 CFR Part 50.82(a)(1)(i) and (ii). Therefore, the 10 CFR Part 50 license PNPS no longer permits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR Part 50.82(a)(2).

By letter dated January 2, 2020, the NRC issued License Amendment No. 251 to Renewed Facility Operating License No. DPR-35 for PNPS approving the PNPS Permanently Defueled Emergency Plan (PDEP) and associated Permanently Defueled Emergency Action Levels (EALs) (Reference 2). The PDEP and EALs rely upon exemptions from certain emergency planning requirements as approved by NRC letter dated December 18, 2019 (Reference 3).

Additional changes to the PNPS PDEP and PDEP EAL Technical Bases Document are warranted to reflect the future storage of all PNPS fuel in the Independent Spent Fuel Storage Installation (ISFSI) facility.

On November 16, 2018 (Reference 4), HDI submitted the Post-Shutdown Decommissioning Activities Report (PSDAR) and on March 31, 2020 (Reference 5), HDI submitted a Report on the Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations. The Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage documented the HDI expectation that all PNPS spent fuel be completely transferred to the ISFSI by mid-January 2022. To comport to the reduced scope of potential radiological accidents with all PNPS spent fuel in dry cask storage within the ISFSI, HDI determined that implementation of the ISFSI Only Emergency Plan (IOEP) and the ISFSI Only EAL Technical Bases Document will be warranted.

The proposed ISFSI only emergency plan is related to the operation of the ISFSI and would be implemented after all PNPS spent fuel has been removed from the spent fuel pool (SFP) and placed in dry storage within the PNPS site controlled ISFSI. Implementation of the proposed IOEP would involve the establishment of administrative controls for radiological source term accumulation limits and methods to control the accidental dispersal of the radiological source. to HDI-PIL-22-008 Page 2 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

2.0 DESCRIPTION

The proposed amendment would modify the PNPS license by replacing the existing PDEP and the associated EAL scheme with the IOEP and the ISFSI Only EAL scheme to reflect the storage of all PNPS fuel on the ISFSI. The proposed changes reduce the scope of onsite emergency planning requirements to reflect the reduced scope of potential radiological accidents with all PNPS spent fuel in dry cask storage within the ISFSI. After all spent fuel is in dry cask storage within the ISFSI, the number and severity of potential radiological accidents possible at PNPS are substantially lower. There continues to be no need for offsite emergency response plans at PNPS because no postulated design basis accident or reasonably conceivable beyond design basis accident can result in a radioactive release that exceeds Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the site boundary, as described in EPAs PAG Manual "Protective Action Guides and Planning Guidance for Radiological Incidents" dated January 2017 (EPA PAG Manual) (Reference 6).

The robust nature and high integrity of the spent fuel storage system selected for use at the ISFSI is designed to prevent the release of radioactivity in the event of an accident, including environmental phenomena (e.g., earthquake and flooding). As a result of the high integrity dry shielded canisters design and the substantial protection afforded the canisters, leakage of fission products from a canister is not considered to be a credible event.

The source term for an accidental release at the defueled reactor site is reduced significantly by the transfer of spent fuel from the SFP to the ISFSI and by the removal or decay of radioactive materials remaining in the plant. PNPS has developed a methodology to determine potential doses at the Site Boundary if a radiological release were to occur during decontamination and dismantlement of radioactive structures, systems, and components (SSCs). In planning and preparation for decontamination and dismantlement activities, application of this methodology will consider administrative and engineering controls that will be in place to limit radiological source term accumulation as well as methods to limit the dispersal of radioactive materials.

These controls will ensure that if a radiological release were to occur, doses at the Site Boundary would not exceed two times the Offsite Dose Calculation Manual (ODCM) limits (2 times 1500 millirem/year) for 60 minutes, and therefore not result in doses to the public above EPA PAGs beyond the controlled area boundary. By ensuring that dose rates that could occur during decontamination and dismantlement activities cannot exceed twice the ODCM limit, the current radiological effluent EALs are no longer necessary and can be eliminated. Methods necessary to ensure a radiological release would not exceed two times the ODCM limits would be in addition to the requirements already specified in the ODCM for control of effluent releases and the requirement to maintain radiation doses received by personnel As Low As Reasonably Achievable.

The current EAL scheme was approved for use at PNPS on January 2, 2020 (Reference 2) and is based on Nuclear Energy Institute (NEI) 99-01, "Development of Emergency Action Levels for to HDI-PIL-22-008 Page 3 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Non-Passive Reactors, Revision 6 (Reference 7). The proposed EAL scheme continues to be based on NEI 99-01, Revision 6, as appropriate, after the transfer of the spent fuel from the SFP to the ISFSI. The proposed revisions constitute a change in the emergency planning function commensurate with the ongoing and anticipated reduction in radiological source term at PNPS.

3.0 PROPOSED CHANGE

S Replacement of the PNPS PDEP and associated EAL Technical Bases Document with the IOEP and the ISFSI Only EAL Technical Bases Document involves the following major changes to the PNPS PDEP:

1) Removal of the various emergency actions related to the SFP,

2) Removal of non-ISFSI-related emergency event types,

3) Clarifying definitions for security EALs

4) Revision of the Emergency Response Organization (ERO), and

5) Identification of the ISFSI Shift Supervisor (ISS) title as the position that assumes the Emergency Director (ED) responsibilities following an emergency declaration.

The off-normal events and accidents addressed in the IOEP are related to the dry storage of spent nuclear fuel within the ISFSI and include only the off-normal, accident, natural phenomena, and hypothetical events and consequences presented in the Holtec International Final Safety Analysis Report for the HI-STORM 100 Cask System Revision 17, for Certificate Number 1014, Docket No. 72-1014, Amendment 12 (Reference 8). After all fuel is removed from the PNPS SFP, there will no longer be any potential for the accidents previously described in the PNPS Emergency Plan that would increase risk to the health and safety of the public.

These accidents included events specifically related to the storage of the spent fuel in the SFP.

After the transfer of the spent fuel from the SFP to the ISFSI, the spent fuel storage and handling systems will be removed from operation.

The proposed revisions to the PNPS Emergency Plan and associated EAL scheme are commensurate with the reduction in radiological hazards associated with the transfer of the spent fuel from the SFP to the ISFSI and will allow the facility to transition to an emergency plan and EAL scheme specifically related to the storage of the spent fuel in the ISFSI. The proposed changes are necessary to properly reflect the conditions of the facility and to maintain the effectiveness of the emergency plan.

3.1 Elimination of SFP Initiating Conditions and EALs The Initiating Conditions (ICs) and EALs associated with emergency classification in the PDEP are based on NEI 99-01, Revision 6. Specifically, Appendix C of NEI 99-01 contains a set of ICs and EALs for permanently defueled nuclear power plants that had previously operated under a 10 CFR Part 50 license and have permanently ceased power operations.

After all spent fuel has been transferred from the SFP to dry storage within the ISFSI, the NEI 99-01, Appendix C ICs and EALs that are specifically associated with the SFP are no to HDI-PIL-22-008 Page 4 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 longer required to be in the emergency plan. Additionally, certain ICs and EALs, the primary function of which is not associated with the SFP, are also no longer required to be in the emergency plan when administrative controls are established to limit source term accumulation and the offsite consequences of uncontrolled effluent releases. Therefore, the ICs listed in Table 1, below, are proposed for elimination and are not included in the IOEP and EAL scheme.

Table 1 - Emergency Plan Initiating Conditions Being Deleted ALERT UNUSUAL EVENT PD-AA1 Release of gaseous or liquied PD-AU1 Release of gaseous or liquid radioactivity resulting in offsite dose greater radioactivity to the enviroment greater than than 10 mrem TEDE or 50 mrem thyroid 2 times the ODCM limit for 60 minutes or CDE. longer.

PD-AA2 UNPLANNED rise in facility PD-AU2 UNPLANNED rise in facility radiation levels that impedes facility access radiation levels required to maintain spent fuel integrity.

PD-HA1 HOSTILE ACTION within the PD-HU1 Confirmed SECURITY OWNER CONTROLLED AREA or airborne CONDITION or threat (1 or 2 or 3) at the attack threat within 30 minutes. (1 or 2) is Independent Spent Fuel Storage occuring or has occurred. Installation (ISFSI)

1. Notification by the Security Force of a

1. 1. Notification by the Securrity Force A SECURITY CONDITION that does that a A HOSTILE ACTION is not involve a HOSTILE ACTION as occurring or has occurred within the reported by the Security Shift OWNER CONTROLLED AREA. as Supervisor.

reported by the Security Shift Supervisor. OR

2. A validated notification from NRC of 2. Notification of a credible secuity an aircraft attack threat< 30 minutes threat directed at the site from the site. OR

3. A validated notification from the NRC providing information of an aircraft threat.

PD-HU2 Hazardous Event affecting eqipment necessary for spent fuel cooling.

(1)

PD SU1 UNPLANNED spent fuel pool temperature rise.

(1)

For a facility in which all spent fuel is stored in the ISFSI, the condition addressed by PD-HU2 remains fully addressed by IC E-HU1 to HDI-PIL-22-008 Page 5 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 The ICs being deleted include all ICs associated with the categories of abnormal radioactive release and system malfunction associated with the SFP as well as security conditions associated with aircraft. These categories apply to the storage of spent fuel in the SFP and are not necessary or appropriate for a facility in which all spent fuel is stored in the ISFSI.

The ICs listed in Table 2, below, are being retained. The ICs being retained in the ISFSI Only Emergency Plan and associated EAL scheme are appropriate to address the condition of a facility in which all spent fuel is stored in the ISFSI.

Table 2 - ISFSI Only Emergency Plan Initiating Condtions ALERT UNUSUAL EVENT Independent Spent Fuel Storage Installation E-HU1: Damage to a loaded cask CONFINEMENT BOUNDARY.

Hazards and Other Conditions PD-HA1 HOSTILE ACTION is occurring or PD-HU1 Confirmed SECURITY has occurred. CONDITION or threat.

PD-HA3 Other conditions exist which in the PD-HU3 Other conditions exist which in the judgment of the Emergency Director warrant judgment of the Emergency Director warrant declaration of an ALERT. declaration of an UNUSUAL EVENT.

3.2 Emergency Response Organization Revision The current PNPS PDEP provides for two (2) ERO augmented positions: a Technical Coordinator and a Radiation Protection Coordinator. The PDEP requires the ERO to be activated at an Alert classification (can be activated in part or in whole at the discretion of the ED for an Unusual Event) with the goal of the ERO to augment the on-shift staff within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of an Alert classification. The proposed PNPS IOEP proposes replacing these positions with a Resource Manager and an individual trained in radiological monitoring and assessment. to HDI-PIL-22-008 Page 6 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 The Resource Manager is provided to assist in assessing the event and obtaining needed resources. The Resource Manager is required to be in contact with the Emergency Director within two (2) hours of declaration of an Unusual Event or an Alert. Entry into the ISFSI Only Emergency Plan would result from an extreme natural phenomenon (beyond design basis) or a security condition, either of which would negatively impact or restrict the ability of responding personnel to access to the site.

The Resource Manager augments the Emergency Director by assisting in assessing the emergency condition and coordinating the required resources, including serving as the public information interface. Services provided to the Emergency Director by the Resource Manager can be provided remotely and do not necessitate an onsite response by the Resource Manager. By responding remotely, the actual response time is decreased (as compared to the ERO response required by the PDEP as described above) with no negative impact to services and functional responsibilities provided by the Resource Manager. The Resource Manager's functional responsibilities could be performed in a timely manner either by reporting to the site or performing the function remotely in the specified timeframe.

In addition, PNPS proposes that a minimum of one person trained in radiological monitoring and assessment will report to the ISFSI within four (4) hours of an emergency declaration for an event involving radiological consequences.

The proposed PNPS ISFSI Only Emergency Plan also provides that additional personnel resources may be directed to report to the ISFSI to provide support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available from PNPS staff and can be requested from various contractors.

3.3 Replacement of the "Shift Manager" with the "ISFSI Shift Supervisor" The current PNPS PDEP assigns the authority and responsibility for command and control of emergencies to the Shift Manager. If an emergency condition develops, the Shift Manager assumes the role of Emergency Director. The proposed PNPS ISFSI Only Emergency Plan proposes replacing the Shift Manager position with the ISFSI Shift Supervisor (ISS).

The ISS is an on-shift position at the PNPS site on a continuous, 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis, and is the senior management position during off-hours. This position is responsible for monitoring ISFSI conditions and managing the activities at the PNPS ISFSI. This position assumes overall command and control of the response as the Emergency Director and is responsible for monitoring conditions and approving all onsite activities. The ISFSI Only Emergency Plan clearly identifies non-delegable responsibilities, along with other designated tasks assigned to the ISS. to HDI-PIL-22-008 Page 7 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 3.4 ISFSI Only Emergency Plan The ISFSI Only Emergency Plan describes PNPSs plan for responding to emergencies while all spent fuel is in dry cask storage within the ISFSI. The ISFSI Only Emergency Plan is provided in Attachment 1 to Enclosure 1 of this submittal for NRC review and approval.

This proposed emergency plan is associated with EALs for events related to the ISFSI.

The ISFSI Only Emergency Plan addresses the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans" and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities" (as previously exempted), and is consistent with regulations in 10 CFR 72.32 and applicable guidelines established 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" (Reference 9).

The PNPS ISFSI Only Emergency Plan conservatively provides that the emergency planning zone for the ISFSI is the area within the Site Boundary. The Site Boundary establishes the perimeter of the Owner Controlled Area. The Site Boundary completely encompasses the ISFSI controlled area. The ISFSI controlled area, as defined in 10 CFR 72.3, "Definitions," means the area immediately surrounding the ISFSI for which PNPS exercises authority over its use and within which ISFSI operations are performed.

The ISFSI controlled area is established to limit dose to the public during normal operations, anticipated occurrences, and DBAs in accordance with the requirements of 10 CFR 72.104, "Criteria for Radioactive Materials in Effluents and Direct Radiation from the ISFSI or MRS (Monitored Retrievable Storage)," and 10 CFR 72.106, "Controlled Area of the ISFSI or MRS." HDI's analysis of the radiological impact of potential accidents at the ISFSI concluded that any releases beyond the ISFSI controlled area are expected to be less than the EPA PAGs. The ISFSI controlled area is completely enclosed within the Site Boundary. Thus, any radiological releases beyond the Site Boundary will also be less than the EPA PAGs.

Based on the reduced number and consequences of potential radiological events with all spent fuel in dry storage within the ISFSI, the current offsite Comprehensive Emergency Management Plan (CEMP) approach will continue to be an effective method to protect the health and safety of the public. Additionally, the scope of the onsite emergency response organization and corresponding requirements in the Emergency Plan may be reduced without an undue risk to the public health and safety. The current PNPS PDEP describes interfaces with the Commonwealth of Massachusetts including notifications of emergency declarations and annual reviews of the PNPS emergency classification system with appropriate State representatives. The proposed PNPS ISFSI Only Emergency Plan proposes to maintain these interfaces. to HDI-PIL-22-008 Page 8 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 The analysis of the potential radiological impact of an accident in a condition with all irradiated fuel stored in the ISFSI indicates that any releases beyond the Site Boundary are below the EPA PAG exposure levels detailed in Reference 6. Exposure levels, which warrant pre-planned response measures, are limited to onsite areas. For this reason, radiological emergency planning remains focused onsite.

3.5 ISFSI Emergency Action Levels Attachment 2 to this Enclosure 1 provides the PNPS ISFSI Only EAL Technical Bases Document, which contains the proposed PNPS ISFSI Only EAL Scheme for NRC review and approval. The current PNPS EAL Scheme was approved by the NRC on January 2, 2020 (Reference 2). The proposed ISFSI Only EAL scheme would be implemented with the PNPS ISFSI Only Emergency Plan (Attachment 1 to this Enclosure) Deletions from the currently approved EAL Scheme are identified in Table 1, "Emergency Plan Initiating Conditions Being Deleted," in Section 3.1, "Elimination of SFP Initiating Conditions and EALs," above.

Operating Modes and Applicability The proposed ISFSI Only EAL Scheme is only applicable after all PNPS spent nuclear fuel has been transferred out of the SFP and placed in dry storage within the ISFSI.

State and Local Government Review of Proposed Changes Commonwealth of Massachusetts and local emergency management officials are advised of EAL changes that are implemented. Prior to implementation of this License Amendment Request (LAR), HDI will provide an overview of the new classification scheme to Commonwealth of Massachusets and local emergency management officials in accordance with 10 CFR 50, Appendix E, Section IV.B.1.

4.0 TECHNICAL EVALUATION

4.1 Radiological Consequesnces of Design Basis Events Pilgrim Nuclear Power Station (PNPS) is located in the town of Plymouth, Plymouth County, in the Commonwealth of Massachusetts. PNPS is a single cycle, forced circulation, boiling water nuclear reactor and associated electric generating equipment (the facility),

owned by Holtec Pilgrim, LLC and maintained and operated for decommissioning by Holtec Decommissioning International, LLC (HDI). The facility is located on the western shore of Cape Cod Bay in the town of Plymouth on the Holtec Pilgrim site in Plymouth County, Massachusetts. to HDI-PIL-22-008 Page 9 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Chapter 6 of the PNPS Defueled Safety Analysis Report (DSAR) (Reference 13) describes the only DBA scenario that is applicable to PNPS with fuel stored in the SFP. This chapter discusses a postulated fuel handling accident (FHA) as the DBA associated with fuel movement until the fuel has been transferred to the ISFSI. However, after transfer of all irradiated fuel from the SFP to dry storage within the ISFSI, the accident scenario postulated in the DSAR is no longer possible.

The off-normal events and accidents addressed in the PNPS ISFSI Only Emergency Plan are related to the dry storage of spent nuclear fuel within the ISFSI and include only the off-normal, accident, natural phenomena, and hypothetical events and consequences presented in the the Hi-Storm 100 Cask System FSAR (Reference 8). After all fuel is removed from the PNPS SFP, there will no longer be any potential for the accidents previously described in the PNPS DSAR that would increase risk to the health and safety of the public. These accidents included events specifically related to the storage of the spent fuel in the SFP. After the transfer of the spent fuel from the SFP to the ISFSI, the spent fuel storage and handling systems will be removed from operation consistent with the HDI Revised PNPS PSDAR (Reference 4).

The HI-STORM 100 Cask System FSAR describes the DBAs applicable to the PNPS ISFSI along with the radiological dose calculation results. The analyses of the potential radiological impacts of postulated off-normal, natural phenomena, and accident events involving the ISFSI indicate that any releases would result in a dose to the public below the radiation limits established in 10 CFR 72.106(b). Exposure levels which warrant pre-planned response measures are limited to the ISFSI and immediate vicinity, and for this reason radiological emergency planning is focused on this area.

The ISFSI is a passive storage system that does not rely on electric power for heat transfer.

After removal of the spent fuel from the SFP, there are no credible fuel-related accidents for which actions are required to prevent occurrence or to mitigate the consequences. There is no credible accident resulting in radioactive releases requiring offsite protective measures, as discussed in Section 3.4 above.

PNPS fuel movement to dry storage was initiated in 2015 in accordance with HI-STORM 100S CoC No 1014, Amendments 7 and 12. The remaining spent fuel in the SFP is planned to be moved to dry storage in accordance with the Holtec Hi-Storm 100S CoC 1014 Amendment 14. All remaining fuel in the PNPS SFP is scheduled to be placed into the ISFSI by January 2022 (Reference 5).

The robust design and construction of the spent fuel storage systems selected for use at the ISFSI prevents the release of radioactivity in the event of an off~normal or accident event as described in the Holtec FSAR for the HI-STORM 100 Cask System (Reference 8).

Leakage of fission products from a canister confinement boundary breach is not considered to be a credible event, given the high integrity nature of the canister's design and the to HDI-PIL-22-008 Page 10 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 additional protection afforded by the storage casks.

After all spent fuel has been removed from the SFP, the estimated radiological inventory (non-fuel) that remains at the reactor facility is primarily attributable to activated reactor components and structural materials. There are no credible accident scenarios that can mobilize a significant portion of this inventory for release. As a result, the potential accidents that could occur during decommissioning the reactor facility have negligible offsite and onsite radiological consequences.

With all spent nuclear fuel in dry storage within the ISFSI, the radiological status of the facility required for implementing the proposed ISFSI Only Emergency Plan is summarized as follows:

• The remaining radiological source term at PNPS will not create an unplanned/unanticipated increase in radiation or in liquid or airborne radioactivity levels that would result in doses to the public above EPA PAG limits at the Site Boundary.

• Source term accumulation from activities during decontamination and dismantlement of radioactive SSCs are controlled at a level that would preclude declaring an Unusual Event.

• Necessary radiological support personnel will be administratively required to be onsite during active decontamination and dismantlement of radioactive SSCs.

The ISFSI Only Emergency Plan describes the PNPS plan for responding to emergencies while all spent fuel is in dry storage within the ISFSI, and is not intended to apply to the decontamination and dismantlement of radioactive SSCs.

NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," (NUREG-0586) (Reference 10) supports this conclusion in the following statement (Section 4.3.9.3):

"The staff has reviewed activities associated with decommissioning and determined that many decommissioning activities not involving spent fuel that are likely to result in radiological accidents are- similar to activities conducted during the period of reactor operations. The radiological releases from potential accidents associated with these activities may be detectible. However, work procedures are designed to minimize the likelihood of an accident and the consequences of an accident, should one occur, and procedures will remain in place to protect health and safety while the possibility of significant radiological accident exists." to HDI-PIL-22-008 Page 11 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 NUREG-0586 also includes the following statement (Section 4.3.9.4):

"The staff has considered available information, including comments received on the draft of Supplement 1 of NUREG-0586, concerning the potential impacts of non-spent fuel related radiological accidents resulting from decommissioning. This information indicates, that with the mitigation procedures in place, the impacts of radiological accidents are neither detectible nor destabilizing. Therefore, the staff makes the generic conclusion that impacts of non-spent fuel related radiological accidents are SMALL. The staff has considered mitigation and concludes that no additional measures are likely to be sufficiently beneficial to be warranted."

Accordingly, controls designed to minimize the likelihood and consequence of off-normal or accident events would be implemented when decontamination or dismantling activities involving radioactive SSCs are being performed. Examples of potential controls for radiological source term accumulation limits include:

• limits on radioactive materials collected on filter media and resins (dose rate limit),

• limits on contaminated materials collected in shipping containers (dose rate limit),

• limits on surface or fixed contamination on work areas that may create airborne radioactive material (activity limits), and

• limits on contaminated materials collected in radioactive liquid storage tanks (activity concentration limits).

Examples of potential methods to control accidental dispersal of the radiological source term include limitations on dispersal mechanisms that may cause a fire (e.g., limits on combustible material loading, and use of fire watch to preclude fire), placement of a berm around a radioactive liquid storage tank, and packaging radioactive materials within confined boundaries with ventilation controls established.

4.2 Radiological Consequences of Postulated Events

1. Cask Drop Event (Fuel-Related Event)

HDI is the holder of a general license for the storage of spent fuel in the ISFSI at decommissioning nuclear power sites in accordance with the provisions of 10 CFR 72.210 and 10 CFR 72.212. The generally licensed ISFSI at PNPS is used for interim, onsite, dry storage of spent nuclear fuel assemblies in the Holtec HI-STORM 100 Cask System (Certificate of Compliance (CoC) No.1014).

As documented in the Hi-Storm 100 Cask System FSAR (Reference 8) analysis of the normal events, including drop events, determined that canister drops can be sustained without breaching the confinement boundary, preventing removal of spent fuel assemblies, or creating a criticality accident. There are no evaluated normal conditions, or off-normal or to HDI-PIL-22-008 Page 12 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 accident events, that result in damage to the canister producing a breach in the confinement boundary. Neither normal conditions of operation or off-normal events preclude retrieval of the fuel for transport and ultimate disposal.

The dry spent fuel storage casks used at PNPS are approved for storage of spent fuel per 10 CFR 72.214; and, as such, are in compliance with the requirements of 10 CFR 72.24 and 10 CFR 72.122 for off-normal and accident events to ensure that they will provide safe storage of spent fuel during all analyzed off-normal and accident events. Therefore, no radiological release would be expected to occur.

2. Radioactive Material Handling Accident (Non-Fuel-Related Event)

The limiting non-fuel related event involves the release of radioactive material from either a liquid radioactivity storage tank or from a concentrated source, such as filters, resins, and shipping containers as discussed in NUREG-0586, Appendix I (Reference 10).

For liquid releases, the PNPS Decommissioning Safety Analysis Report (DSAR) states there are no credible accidents that could exceed 10 CFR 20 limits.

For a concentrated solid source, the evaluated initiator to these events could be a fire, explosion, or a fuel handling event (cask drop). After all spent fuel has been moved to the ISFSI, there would be no concentrated source of radioactive material available to be released to the environment in an amount that could exceed two (2) times the Offsite Dose Calculation Manual (ODCM) limit at the site boundary (2 times 1500 millirem/year). During decontamination and dismantlement activities, administrative controls would be applied to the handling of open containers or other packages containing filters, resins, and other dispersable materials generated during dcommissioning activities such that a release to the environment from concentrated sources of these radioactive materials would not exceed two times the ODCM limit at the Site Boundary.

3. Accidents Initiated by External Events The effects of external events, such as aircraft impacts, fires, floods, wind (including tornadoes), earthquakes, lightning, and physical security breaches on the ISFSI remain unchanged from the effects that were considered under the existing PDEP. Externally initiated events are addressed by the proposed ISFSI Only EALs.

In summary, there continues to be a low likelihood of any postulated event resulting in radiological releases requiring offsite protective measures, and there is no credible radioactive material event (non-fuel related) resulting in radiological releases requiring declaration of an emergency. to HDI-PIL-22-008 Page 13 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 5.0

SUMMARY

Pilgrim Nuclear Power Station (PNPS) permanently ceased power operations on May 31, 2019.

On June 10, 2019 Entergy Nuclear Operations, Inc (ENOI) certified that PNPS had permanently removed all fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1)(ii) (Reference 1).

Therefore, as specified in 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for PNPS no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

On August 27, 2019, pursuant to the NRC Order (Reference 2), PNPS ownership and the PNPS operating licenses were transferred to Holtec Pilgrim, LLC and HDI, respectively.

The fuel campaign to transfer the remaining PNPS spent fuel from the SFP to the ISFSI is expected to complete complete by January 2022. Based on the reduced scope of potential radiological accidents with all spent fuel in dry cask storage within the ISFSI, HDI proposes the implementation of a revised emergency plan and corresponding EAL scheme, to be implemented after completion of the transfer of all PNPS spent fuel to the ISFSI.

This proposed amendment would replace the existing PNPS PDEP and its associated Permanently Defueled EAL Scheme with the ISFSI Only Emergency Plan (IOEP) and its associated EAL Scheme, as appropriate for the condition wherein all spent nuclear fuel is in dry storage within the ISFSI. The IOEP and ISFSI Only EAL Scheme are being submitted to the NRC for approval, as required under Section IV.B.2 of Appendix E to 10 CFR Part 50.

Additionally, 10 CFR 50.54(q)(4) and 10 CFR 72.44(f) require that proposed changes receive prior approval by the NRC because they are considered to reduce the effectiveness of the Emergency Plan.

6.0 REGULATORY EVALUATION

The proposed emergency plan does not meet all of the standards of 10 CFR 50.47(b) and requirements of 10 CFR Part 50, Appendix E. However, PNPS was previously granted exemptions from portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and 10 CFR 50, Appendix E, Section IV, by letter dated December 18, 2019 (Reference 3). The bases for these exemptions have not changed and remain in effect for the emergency plan changes requested in this document. Considering the previously granted exemptions, the emergency plan, as proposed, will continue to meet the remaining applicable requirements in 10 CFR Part 50, Appendix E and the remaining applicable planning standards of 10 CFR 50.47(b). to HDI-PIL-22-008 Page 14 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 6.1 Applicable Regulatory Requirements/Criteria No Siginificant Hazards Consideration The regulatory requirements, as exempted, are discussed below.

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.47, "Emergency Plans,"

set forth emergency plan requirements for nuclear power plant facilities. The regulations in 10 CFR 50.47(a)(1)(i) state, in part:

"No initial .operating license for a nuclear power reactor will be issued unless a finding is made by the NRG that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency."

Section 50.47(b) establishes the standards that emergency response plans must meet for NRG staff to make a positive finding that there is reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency.

• Planning Standard (1) of Section 50.47(b) states, in part: "[E]ach principal response organization has staff to respond and to augment its initial response on a continuous basis."

• Planning Standard (2) of Section 50.47(b) states, in part: "On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available."

• Planning Standard (4) of Section 50.47(b) requires that a licensee's emergency response plan contain the following: "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee."

• Planning Standard (8) of Section 50.47(b) states, in part: "Adequate emergency facilities and equipment to support the emergency response are provided and maintained."

10 CFR 50.54(q)(4) specifies the process for revising emergency plans where the change reduces the effectiveness of the plan. This regulation states the following:

"The changes to a licensee's emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC."

Section IV.A of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, states, in part: "The organization for coping with radiological emergencies shall be described, including definition of authorities, to HDI-PIL-22-008 Page 15 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 responsibilities, and duties of individuals assigned to the licensee's emergency organization Section IV.C.1 of Appendix E requires that each emergency plan define the emergency classification levels that determine the extent of participation of the emergency response organization.

Section IV .E of Appendix E states, in part: "Adequate provisions shall be made and described for emergency facilities and equipment. .. " As identified in 10 CFR 72.13, "Applicability," the applicable emergency plan requirements for the ISFSI associated with a general license are specified in 10 CFR 72.32(c) and (d).

The proposed emergency plan continues to rely on previously granted exemptions from certain emergency planning requirements (Reference 3) since the bases for these exemptions have not changed and remain in effect.

In November 2012, NEI published NEI 99-01, Revision 6 (Reference 7). The NRC endorsed NEI 99-01, Revision 6, by letter dated March 28, 2013 (Reference 11). The changes being requested herein are based on Revision 6 to NEI 99-01. The proposed changes are conservatively being considered as a change to the EAL scheme development methodology. Pursuant to 10 CFR Part 50, Appendix E, Section IV.B.2, a revision to an entire EAL scheme must be approved by the NRC before implementation.

6.2 Aircraft-Related Emergency Action Levels Security-based ICs and EALs were provided to licensees in NRC Bulletin 2005-02, "Emergency Preparedness and Response Actions for Security Based Events," dated July 18, 2005 (Reference 12). Bulletin 2005-02 was addressed to all holders of operating licenses for nuclear power reactors, except those who had permanently ceased power operations and had certified that fuel had been removed from the reactor vessel.

In 2009, the NRC amended its security regulations adding new security requirements pertaining to nuclear power reactors. This rulemaking established and* updated generically applicable security requirements similar to those previously imposed by Commission orders issued after the terrorist attacks of September 11, 2001. In the Statements of Consideration (SOC) for the Final Rule for Power Reactor Security Requirements (74 Federal Register(FR) 13926; March 27, 2009), the Commission stated, in part:

Current reactor licensees comply with these requirements through the use of the following 14 strategies that have been required through an operating license condition. These strategies fall into the three general areas identified by§§ 50.54{hh){2)(i), (ii), and (iii). The firefighting response strategy reflected in § 50.54{hh){2)(i) encompasses the following elements: to HDI-PIL-22-008 Page 16 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

7. Spent fuel pool mitigation measures As such, the staff maintained EALs for potential or actual aircraft threats for facilities transitioning into decommissioning with spent fuel stored in a SFP, in addition to maintaining the mitigative strategies license conditions required by NRC Order, EA-02-026, "Interim Compensatory Measures (ICM) Order," issued February 25, 2002 (67 FR 9792; March 4, 2002).

The SOC further stated, in part:

The NRC believes that it is inappropriate that§ 50.54{hh) should apply to a permanently shutdown defueled reactor where the fuel was removed from the site or moved to an ISFSI.

Therefore, the ICs proposed for deletion also include those associated with the mitigative strategies and response procedures for potential or actual aircraft attack procedures as the spent fuel will have been removed from the SFP and stored in the ISFSI prior to the implementation of the changes requested herein.

6.3 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.92, Holtec Decommissioning International, LLC (HDI) has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration because the proposed changes satisfy the criteria in 10 CFR 50.92(c).

These criteria require that operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The proposed changes would revise the Pilgrim Nuclear Power Station (PNPS) site Emergency Plan and emergency action level (EAL) scheme commensurate with the hazards associated with a permanently shut down and defueled facility that has transferred all spent fuel from the spent fuel pool (SFP) to dry cask storage within the independent spent fuel storage installation (ISFSI).

The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard. to HDI-PIL-22-008 Page 17 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed amendment would modify the PNPS facility operating license by revising the Emergency Plan and EAL scheme. PNPS has permanently ceased power operations and is permanently defueled. The proposed amendment is conditioned on all spent nuclear fuel being removed from wet storage in the SFP and placed in dry storage within the ISFSI. Occurrence of postulated accidents associated with spent fuel stored in a SFP are no longer credible in a SFP devoid of such fuel. The proposed amendment has no effect on plant structure system components (SSCs) and therefore can neither affect the capability of any plant SSC to perform its design function nor increase the likelihood of the malfunction of any SSC. The proposed amendment would have no effect on any of the previously evaluated accidents in the PNPS Defueled Safety Analysis Report (DSAR) or the Holtec HI-STORM Final Safety Analysis Report (FSAR) for all the dry casks to be stored in the ISFSI.

Because PNPS has permanently ceased power operations, the generation of fission products has ceased and the remaining source term continues to decay. This continues to significantly reduce the consequences of previously evaluated postulated accidents. Furthermore, previously generated source term materials have been removed from the site in accordance with applicable regulations and permitting requirements.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed amendment constitutes a revision of the emergency planning function commensurate with the ongoing and anticipated reduction in radiological source term at PNPS.

The proposed amendment does not involve a physical alteration of the plant. No new or different types of equipment will be installed and there are no physical modifications to existing equipment as a result of the proposed amendment.

Similarly, the proposed amendment would not physically change any SSC involved in the mitigation of any postulated accidents. Thus, no new initiators or precursors to HDI-PIL-22-008 Page 18 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 of a new or different kind of accident are created. Furthermore, the proposed amendment does not create the possibility of a new failure mode associated with any equipment or personnel failures. The credible events for the ISFSI remain unchanged.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Because the 10 CFR Part 50 license for PNPS no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2), the postulated accidents associated with reactor operation are no longer credible. In addition, with all spent nuclear fuel transferred out of wet storage from the SFP and placed in dry storage within the ISFSI, a fuel handling accident is no longer credible. Therefore, there are no credible events that would result in radiological releases beyond the site boundary exceeding the EPA Protective Action Guide (PAG) exposure levels, as detailed in the EPA's "Protective Action Guide and Planning Guidance for Radiological Incidents," dated January 2017.

The proposed amendment does not involve a change in the plant's design, configuration, or operation. The proposed amendment does not affect either the way in which the plant structures, systems, and components perform their safety function or their design margins. Because there is no change to the physical design of the facility, there is no change to these margins.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, HDI concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

6.4 Precedent Similar changes to emergency plans and associated EAL Schemes approved by the NRC for plants that have transferred all fuel from the SFP to dry cask storage in the ISFSI include: 1) the La Crosse Boiling Water Reactor facility on September 8, 2014 (Reference 14), 2) the Zion Facility on May 14, 2015 (Reference 15) and December 20, 2016 (Reference 16), 3) the Kewaunee Power Station on March 2, 2017 (Reference 17), 4) the to HDI-PIL-22-008 Page 19 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Crystal River Unit 3 Nuclear Generating Plant on March 22, 2017 (Reference 18), 5)

Vermont Yankee Nuclear Power Station on March 30, 2018 (Reference 19) and 6) Fort Calhoun Station Unit No1 on January 10, 2020 (Reference 20).

6.5 Conclusion Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations as exempted, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 ENVIRONMENTAL CONSIDERATION

S This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as follows:

(i) The amendment involves no significant hazards consideration.

As described in Section 6.3 of this evaluation, the proposed changes involve no significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a change in the type or amount of effluent release offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a significant increase in individual or cumulative occupational radiation exposure.

Based on the above, HDI concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment. to HDI-PIL-22-008 Page 20 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

8.0 REFERENCES

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, dated June 10, 2019, (ML19161A033)

2. Letter USNRC to Holtec Decommissioning International, LLC, "Pilgrim Nuclear Power Station - Issuance of Amendment No. 251 Re: Changes to the Emergency Plan for Permanently Defueled Emergency Plan and Emergency Action Level Scheme (EPID L-2018-LLA-0221) dated January 2, 2020 (ML19274C674)

3. USNRC Letter to Holtec Decommissioning International, LLC, Pilgrim Nuclear Power Station - Exemptions from Certain Emergency Planning Requirements and Related Safety Evaluation (EPIP L-2018-LLE-0011), dated December 18, 2019 (ML19142A060)

4. Letter, Holtec Decommissioning International, LLC to USNRC, " Notification of Revised Post-Shutdown Decommissioning Activities Report and Revised Site-Specific Decommissioning Cost Estimate for Pilgrim Nuclear Power Station, dated November 16, 2018 (ML18320A040)

5. Letter from Holtec Decommissioning International, LLC to USNRC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations, dated March 31, 2020 (ML20091M858)

6. U.S. Environmental Protection Agency, "Protective Action Guide and Planning Guidance for Radiological Incidents," dated January 2017 (EPA-400/R-17/001)

7. Nuclear Energy Institute (NEI) 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012 (ML12326A805)

8. Holtec International Final Safety Analysis Report for the HI-STORM 100 Cask System Revision 17, dated May 3, 2019, for Certificate Number 1014, Docket No. 72-1014, Amendment 12, Effective Date February 25, 2019 (ML19343A908)

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

1, November 1980.

10. NUREG-0586, "Generic Environmental Impact Statement of Decommissioning of Nuclear Facilities," Supplement 1, Volume 1, November 2002

11. USNRC to Nuclear Energy Institute (NEI), "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, Dated November, 2012 (TAC No. D92368),"

dated March 28, 2013 (ML12346A463) to HDI-PIL-22-008 Page 21 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

12. NRC Bulletin 2005-02, "Emergency Preparedness and Response Actions for Security Based Events," dated July 18, 2005 (ML051740058)

13. Pilgrim Nuclear Power Station, Defueled Safety Analysis Report, Rev 1, issued September 14, 2020

14. Letter from U.S. Nuclear Regulatory Commission to Dairyland Power Cooperative (La Crosse Boiling Water Reactor), "Issuance of Amendment Relating to the Dairyland Power Cooperative La Crosse Boiling Water Reactor Request for Changes to the Emergency Planning Requirements," dated September 8, 2014 (ML14155A112)

15. Letter from U.S. Nuclear Regulatory Commission to ZionSolutions LLC (Zion Nuclear Power Station), "Safety Evaluation Report for Defueled Station Emergency Plan License Amendments for Zion Units 1 and 2, dated May 14, 2015 (ML15092A423)

16. Letter from U.S. Nuclear Regulatory Commission to ZionSolutions LLC (Zion Nuclear Power Station), "Issuance of Amendments Related to Changes to a Proposed Revision to the Zion Nuclear Power Station Defueled Station Emergency Plan (TAC NOs. L53114 and L53115),

dated December 20, 2016 (ML16211A060)

17. Letter from U.S. Nuclear Regulatory Commission to Dominion Nuclear, "Safety Evaluation for the Proposed Revision to the Kewaunee Power Station Defueled Station Emergency Plan (TAC No. L53082), dated March 2, 2017 (ML16195A323)

18. Letter from U.S. Nuclear Regulatory Commission to Crystal River Nuclear Plant, "Crystal River Unit 3 Nuclear Generating Plant - Issuance of Amendment Approving Independent Spent Fuel Storage Installation (ISFSl)-Only Emergency Plan and ISFSl-Only Emergency Action Level Bases Manual (TAC NO. L53129), dated March 22, 2017 (ML17048A474)

19. Letter from U.S. Nuclear Regulatory Commission to Vermont Yankee Nuclear Power Station, Vermont Yankee Nuclear Power Station - Issuance Of Amendment to Change the Emergency Plan and Emergency Action Level Scheme to Reflect An ISFSI-Only Configuration (EPID No. L-2017-EPR-0001), dated March 30, 2018 (ML18053A111)

20. Letter from U.S. Nuclear Regulatory Commission to Omaha Public Power District, Fort Calhoun Station, Unit No. 1 - Issuance Of Amendment To Change the Emergency Plan snd Emergency Action Level Scheme to Reflect an ISFSI-Only Configuration (EPID NO. L-2019-LLA-0057) dated January 10, 2020 (ML19346D682) to HDI-PIL-22-008 Page 22 of 22

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Letter Number HDI-PIL-21-008 Enclosure 1 Attachment 1 PILGRIM NUCLEAR POWER STATION ISFSI ONLY EMERGENCY PLAN (45 pages follow)

Procedure Number: Revision:

DPP-PIL-EP-001 0 ISFSI Only Emergency Plan Use Category:

Reference Use Page 1 of 45 FOREWORD The Pilgrim Nuclear Power Station (PNPS) Independent Spent Fuel Storage Installation (ISFSI) Only Emergency Plan (IOEP) describes PNPS's plans for responding to emergencies that may arise at the PNPS ISFSI.

__________________________________________ Date: _________________

Sr. Manager, Compliance

__________________________________________ Date: _________________

Independent Safety Review

__________________________________________ Date: _________________

HDI Decommissioning Site Vice President Effective Date: ____________

SUMMARY

OF REVISIONS Revision 0: Initial issue. Previous revision is EP-PP-01, Revision 44 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

Procedure Number: Revision:

DPP-PIL-EP-001 0 ISFSI Only Emergency Plan Use Category:

Reference Use Page 2 of 45 TABLE OF CONTENTS

1.0 INTRODUCTION

5 1.1 Purpose 5 1.2 Scope 6 2.0 DISCUSSION 6 2.1 Overview of ISFSI Emergency Plan 6 2.2 Facility Description 7 2.3 Summary of Emergency Actions 8 3.0 DEFINITIONS AND ACRONYMS 8 3.1 Definitions 8 3.2 Acronyms 14

4.0 REFERENCES

14 5.0 ASSIGNMENT OF RESPONSIBILITY 15 5.1 Emergency Response and Responsibilities 15 5.2 Offsite Response Organizations 16 6.0 EMERGENCY RESPONSE ORGANIZATION 17 6.1 On-Shift Positions 17 6.2 Augmented ERO Positions 19 6.3 Functional Responsibilities 19 7.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES 21 8.0 EMERGENCY CLASSIFICATION SYSTEM 21 8.1 Emergency Classification System 21 8.2 Emergency Action Levels and Postulated Accidents 23 9.0 NOTIFICATION METHODS AND PROCEDURES 23 9.1 Basis for Notification 23 9.2 Emergency Messages 23 9.3 Means of Providing Emergency Notification 24 10.0 EMERGENCY COMMUNICATIONS 25 11.0 PUBLIC INFORMATION 26 12.0 EMERGENCY FACILITY AND EQUIPMENT 26 12.1 Emergency Response Facility 26 12.2 Emergency Equipment and Supplies 27 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 3 of 45 13.0 ACCIDENT ASSESSMENT 27 14.0 PROTECTIVE ACTIONS 28 14.1 Accountability 28 14.2 Personnel and Visitors Located Outside the ISFSI Protected Area 28 15.0 RADIOLOGICAL EXPOSURE CONTROL 29 15.1 Exposure Guidelines 29 15.2 Radiation Protection 29 15.3 Personnel Contamination Control 30 16.0 MEDICAL AND HEALTH SUPPORT 31 16.1 Onsite First Aid 31 16.2 Medical Transportation 31 16.3 Offsite Medical Support 31 17.0 EMERGENCY TERMINATION AND RECOVERY 32 17.1 Emergency Termination and Notification 32 17.2 Recovery Operations 32 17.3 Termination of Recovery Operations 33 18.0 EXERCISES AND DRILLS 33 18.1 Emergency Plan Exercises and Drills 33 18.2 Equipment and Proficiency Drills 34 18.3 Critique Evaluation 35 19.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING 36 19.1 Emergency Response Personnel Training 36 19.2 Non-PNPS Emergency Response Support Organizations 38 19.3 Annual Emergency Action Level Training 38 20.0 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 38 20.1 Emergency Preparedness Responsibilities 38 20.2 Review and Updating of the IOEP 39 20.3 Training 40 20.4 Maintenance and Inventory of Emergency Equipment and Supplies 40 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 4 of 45 APPENDICES PAGE APPENDIX A Emergency Equipment, Supplies, and Reference Materials 41 APPENDIX B Cross Reference IOEP Section to Planning Standards/Requirements/Criteria and EPIPs 43 LIST OF TABLES TABLE 6-1 Emergency Response Organization Staffing and Responsibilities 20 TABLE 10-1 Communications Systems 26 TABLE 15-1 Response Worker Emergency Dose Limits 30 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 5 of 45

1.0 INTRODUCTION

By letter dated June 10, 2019, Entergy submitted certifications, pursuant to 10 Code of Federal Regulations (CFR) 50.82(a)(1)(i) and (a)(1)(ii), for the permanent cessation of power operations, the permanent removal of fuel from the PNPS reactor vessel, and the placement of the fuel in the spent fuel pool (ADAMS Accession No. ML19161A033). Subsequently, all spent fuel has been transferred to the on-site Independent Spent Fuel Storage Installation (ISFSI) facility.

The PNPS ISFSI Only Emergency Plan (IOEP) describes the plan for responding to emergencies that may arise at the ISFSI. In this condition, no reactor operations can take place and all irradiated fuel has been removed from the Spent Fuel Pool.

This IOEP adequately addresses the risks associated with PNPS's current conditions.

The Holtec International (Holtec) Final Safety Analysis Report (FSAR) for the HI-STORM 100 Cask System describes the Design Basis Accidents (DBAs) applicable to the PNPS ISFSI along with the radiological dose calculation results.

As provided in the Holtec FSAR, the analyses of the potential radiological impacts of postulated off-normal, natural phenomena, and accident events involving the ISFSI indicate that any releases would result in a dose to the public below the radiation limits established in 10 CFR 72.106(b). The analyses of the potential radiological impact of DBAs indicate that any releases beyond the Site Boundary are below the Environmental Protection Agency (EPS) Protective Action Guide (PAG) exposure levels, as detailed in the EPAs Protective Action Guide and Planning Guidance for Radiological Incidents, dated January 2017. Exposure levels, which warrant pre-planned response measures are limited to the ISFSI and immediate vicinity, and for this reason, radiological emergency planning is focused on this area. The PNPS 10 CFR 72.212 Report for the HI-STORM 100 System discusses compliance with Amendments 2 and 10 of the Holtec HI-STORM 100 System Certificate of Compliance (CoC) terms, conditions, and specifications.

1.1 Purpose The purpose of the IOEP is to ensure an adequate level of preparedness to cope with the spectrum of emergencies that could be postulated to occur. This plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations expected to respond to potential emergencies.

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Reference Use Page 6 of 45 1.2 Scope The IOEP has been developed to respond to potential radiological emergencies at the PNPS ISFSI. Because there are no postulated off-normal, natural phenomena or accident events that would result in dose consequences that are large enough to require offsite emergency planning, the overall scope of the IOEP details the actions necessary to safeguard onsite personnel.

The concepts presented in the IOEP address the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans," and Appendix E to 10 CFR 50, "Emergency Planning and Preparedness for Production and Utilization Facilities." The IOEP is consistent with the applicable guidelines established 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."

Appendix B Contains a cross-reference to the applicable guidance in NUREG-0654.

Exemptions from selected portions of 10 CFR 50.47 and Appendix E to 10 CFR Part 50 were approved by the Nuclear Regulatory Commission (NRC) on December 18, 2019 (ADAMS Accession Number ML19142A043).

2.0 DISCUSSION 2.1 Overview of ISFSI Emergency Plan In the event of an emergency at the PNPS ISFSI, actions are required to identify and assess the nature of the emergency and to respond in a manner that protects the health and safety of the public and onsite personnel. This plan describes the organization and responsibilities for implementing emergency measures and describes interfaces with Federal, Commonwealth of Massachusetts, and local organizations which may be notified in the event of an emergency and may provide assistance.

Emergency services are provided by local, public, and private entities. Fire support services are provided by the Plymouth Fire Department; law enforcement support services are provided by local, Commonwealth, and Federal law enforcement authorities, as appropriate; ambulance services are provided by American Medical Response (AMR), Inc.; and medical services are provided by Beth Israel Deaconess Medical Center.

PNPS is licensed under the requirements of 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities." Consistent with the requirements of 10 CFR Part 50, the IOEP is based on the requirements of 10 CFR Part 50, Section 50.47(b) and Appendix E, "Emergency Planning and Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 7 of 45 Preparedness for Production and Utilization Facilities, with approved exemptions.

Sections 5.0 thru 20.0 of this IOEP address the standards outlined in 10 CFR 50.47(b)(1) through (16). PNPS is licensed to store spent fuel in the ISFSI under the General License provisions of 10 CFR 72.210 and 10 CFR 72.212.

Because there are no postulated events that would result in offsite dose consequences large enough to require off site emergency planning, emergencies are divided into two classifications: 1) Notification of Unusual Event (Unusual Event) and 2) Alert. The classification scheme, developed in accordance with NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors", Revision 6, November 2012, has been discussed and agreed upon with responsible offsite organizations and is compatible with their respective emergency plans (CEMP). If determined appropriate by government officials, protective actions may be implemented to protect the public using the existing all hazards emergency planning.

PNPS is responsible for planning and implementing emergency measures within the site boundary. The IOEP is provided to meet that responsibility. To carry out specific emergency measures discussed in the IOEP, detailed emergency plan implementing procedures (EPIPs) are established and maintained. A list of EPIPs is included in Appendix B.

In addition to the description of activities and steps that can be implemented during an emergency, the IOEP also provides a general description of the steps taken to recover from an emergency. It also describes the training, exercises and drills, planning, and coordination appropriate to maintain an adequate level of emergency preparedness.

2.2 Facility Description Pilgrim Nuclear Power Station (PNPS) is located in the town of Plymouth, Plymouth County, in the Commonwealth of Massachusetts. The ISFSI facility is located on the northern portion of the 134-acre property located within the site boundary, owned by Holtec Pilgrim and maintained and operated for decommissioning by Holtec Decommissioning International (HDI). The facility is located on the western shore of Cape Cod Bay in the town of Plymouth on the Holtec Pilgrim site in Plymouth County, Massachusetts.

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Reference Use Page 8 of 45 Upon docketing of the 10 CFR 50.82(a)(1) certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, the 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. Since PNPS was permanently shut down and defueled, no additional fission products will be generated from the plant after shutdown and the decay heat load on the spent fuel will continue to decline. All spent fuel has been transferred to the ISFSI which is located to the southwest of the Plant. The PNPS ISFSI is a robust and high integrity facility for the spent fuel storage system. This facility is designed to prevent the release of radioactivity in the event of accidents, including environmental phenomena (e.g., earthquake and flooding).

2.3 Summary of Emergency Actions The IOEP is activated by the ISFSI Shift Supervisor (ISS) upon identification of an emergency situation based upon the Emergency Action Level (EAL) criteria.

The ISS assumes the position of the Emergency Director upon classification of an emergency. The emergency measures described in the subsequent sections and EPIPs are implemented in accordance with the classification and nature of the emergency, and at the direction of the Emergency Director. Regulatory authorities and offsite support organizations are notified in accordance with this Plan. The Emergency Director has authority and responsibility for control and mitigation of the emergency, including emergency response resources, coordination of radiological assessment activities, and recovery implementation.

The following sections of this IOEP describe the detailed plans and actions of the PNPS Emergency Response Organization (ERO), including interfaces with offsite support organizations.

3.0 DEFINITIONS AND ACRONYMS 3.1 Definitions 3.1.1 Accountability A discretionary protective action taken for all persons onsite (within the ISFSI Protected Area) that involves the gathering of personnel into pre-designated areas and subsequent verification that the location of all personnel is known.

3.1.2 Alert Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the ISFSI or a security event that involves probable life-threatening risk to site personnel or damage to ISFSI equipment because of hostile action. Any releases are expected to be limited to Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 9 of 45 small fractions of the Environmental Protection Agency (EPA) Protective Action Guideline (PAG) exposure levels.

3.1.3 Annual Once per calendar year, unless otherwise stated.

3.1.4 Assessment Actions Those actions taken during or after an emergency for the purposes of obtaining and processing the information necessary to make decisions to implement specific emergency measures.

3.1.5 Biennial Once per two calendar years, unless otherwise stated.

3.1.6 Corrective Action Those emergency measures taken to mitigate or terminate an emergency situation at or near the source of the problem in order to prevent an uncontrolled release of radioactive material or to reduce the magnitude of a release (e.g.,

equipment shutdown, firefighting, equipment repair, and damage control).

3.1.7 Design Basis Accident (DBA)

Credible accident events as analyzed in the ISFSI Updated Final Safety Analysis Report.

3.1.8 Emergency Action Level (EAL)

A pre-determined, site-specific, observable threshold for an Initiating Condition (IC) that, when met or exceeded, places the ISFSI in a given emergency classification level.

3.1.9 Emergency Classification System A system of classification in which emergency occurrences are categorized according to specific protective action levels. The two emergency classification levels, in ascending order of severity, are: Notification of Unusual Event (Unusual Event) and Alert.

3.1.10 Emergency Director This position is the highest level of authority for the PNPS Emergency Response Organization (ERO) and on-site emergency activities. This position is held by the ISFSI Shift Supervisor (ISS) or designated alternate. The ISS in the IOEP is equivalent to the Lead Security Shift Supervisor (LSSS) as defined in the ISFSI Only Security Plan.

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Reference Use Page 10 of 45 3.1.11 Emergency Plan Implementing Procedure (EPIP)

Specific procedures describing actions taken by plant staff to activate and implement the IOEP.

3.1.12 Emergency Response Facility (ERF)

Facility containing the communications equipment necessary for emergency conditions. It is operated under the direction of the Emergency Director and serves as the primary location for classification of the emergency, notification of the emergency to offsite agencies, assessment actions, and emergency action direction.

3.1.13 Emergency Response Organization (ERO)

Organization comprised of assigned individuals who would respond and assist during a classified emergency.

3.1.14 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.

3.1.15 Frequency That unit of time specified (monthly, quarterly, etc.) plus or minus 25 percent, unless otherwise specifically stated. This definition does not apply to "Annual" when it is related to the conduct of the Biennial Exercise. Biennial Exercises are performed within the calendar year.

3.1.16 Hostile Action An act toward the ISFSI 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 the ISFSl. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the Owner Controlled Area).

3.1.17 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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Reference Use Page 11 of 45 3.1.18 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.

3.1.19 ISFSI Controlled Area That area immediately surrounding an ISFSI or MRS (Monitored Retrievable Storage Installation) for which the licensee exercises authority over its use and within which ISFSI or MRS operations are performed.

3.1.20 Initiating Condition (IC)

An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.

3.1.21 Local Assembly Area A pre-designated area where personnel report to for organization, roll-call, and supervision when ISFSI accountability is initiated.

3.1.22 Notification of Unusual Event (Unusual Event)

Events are in progress or have occurred which indicate a potential degradation of the level of safety of the ISFSI or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected.

3.1.23 Owner Controlled Area (OCA)

The OCA is that Licensee-owned property located between Rocky Hill Road and Cape Cod Bay comprising PNPS excluding the Security Owner Controlled Area and Protected Area.

3.1.24 Protected Area The area normally within the facility security fence designated to implement the security requirements of 10 CFR 73.

3.1.25 Protective Actions Those measures taken in anticipation of, or after an uncontrolled release of radioactive material, for the purpose of preventing or minimizing radiological exposures to persons that would be likely to occur if the actions were not taken.

3.1.26 Protective Action Guide (PAG)

The projected dose to an individual, resulting from a radiological incident at which specific protective actions to reduce or avoid that dose are warranted.

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Reference Use Page 12 of 45 3.1.27 Radioactive Release Any radioactive material beyond pre-emergency levels and not attributable to normal ISFSI operations, either detected or suspected of migrating beyond the Protected Area, while in a classified emergency.

3.1.28 Radioactive Control Area (RCA)

An area in which radioactive material is present and the potential exists for the spread of radioactive contamination. The area is posted for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.

3.1.29 Recovery The condition declared after the immediate hazards to life and safety due to the emergency have been removed and efforts are directed to returning affected areas to normal.

3.1.30 Recovery Actions Those actions taken after the emergency has been controlled in order to restore the ISFSI to safe conditions.

3.1.31 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 ISFSI. A security condition does not involve a hostile action.

3.1.32 Site That property within the fenced boundary of Pilgrim which is owned by Holtec.

3.1.33 Site Boundary That line beyond which the land is not owned, leased, or otherwise controlled by the licensee. This line establishes the perimeter of the Owner Controlled Area (OCA).

3.1.34 Substantial Degradation Unanticipated conditions which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.

3.2 Acronyms ALARA As Low As Reasonably Achievable CDI Comprehensive Decommissioning International, LLC Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 13 of 45 DBA Design Basis Accident EAL Emergency Action Level ENS Emergency Notification System EPA Environmental Protection Agency EPIP Emergency Plan Implementing Procedure ERF Emergency Response Facility ERO Emergency Response Organization FSAR Final Safety Analysis Report FTS Federal Telecommunication System HDI Holtec International Decommissioning, LLC IC Initiating Condition IOEP ISFSI Only Emergency Plan ISFSI Independent Spent Fuel Storage Installation ISS ISFSI Shift Supervisor LLEA Local Law Enforcement Agency LSSS Lead Security Shift Supervisor MEMA Massachusetts Emergency Management Agency NRC Nuclear Regulatory Commission OCA Owner Controlled Area ORO Offsite Response Organization PAG Protective Action Guide RCA Radiological Control Area REAC/TS Radiation Emergency Assistance Center/Training Site PNPS Pilgrim Nuclear Power Station

4.0 REFERENCES

4.1 10 CFR 50.47, Emergency Plans 4.2 Appendix E to 10 CFR Part 50, "Emergency Planning and Preparedness for production and Utilization Facilities" Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 14 of 45 4.3 10 CFR Part 20, "Standards and Protection Against Radiation" 4.4 NUREG-0578, "TMl-2 Lessons Learned Task Force Status Report and Short-Term Recommendations" (July 1979) 4.5 NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Rev. 1 4.6 Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors" 4.7 Certificate of Compliance No. 1014, Amendment 7 for the HI-STORM 100 Cask System, dated December 28, 2009 (ADAMS Accession No. ML093620049) 4.8 Certificate of Compliance No. 1014, Amendment 12 for the HI-STORM 100 Cask System, dated February 25, 2019, with corrected date of December 23, 2019 (ADAMS Accession No. ML19343A908) 4.9 Holtec International Final Safety Analysis Report for the HI-STORM 100 Cask System Revision 9, dated February 13, 2010, for Certificate Number 1014, Docket No. 72-1014, Amendment 7, Effective Date December 28, 2009 4.10 Holtec International Final Safety Analysis Report for the HI-STORM 100 Cask System Revision 17, dated May 3, 2019, for Certificate Number 1014, Docket No. 72-1014, Amendment 12, Effective Date February 25, 2019 4.11 Pilgrim Nuclear Power Station, 10 CFR 72.212 Report for the HI-STORM 100 System, Revision 5, dated May 14, 2020 4.12 NRC Bulletin (BL) 2005-02, "Emergency Preparedness and Response Actions for Security Based Events," dated July 18, 2005 (ADAMS Accession No. ML051740058) 4.13 Nuclear Energy Institute (NEI) 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012 (ADAMS Accession No. ML12326A805) 4.14 EPA's "Protective Action Guides and Planning Guidance for Radiological Incidents, dated January 2017 (EPA PAG Manual) 4.15 Letter, Entergy Nuclear Operations, Inc. to USNRC, "Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel," dated June 10, 2019 (ADAMS Accession No. ML19161A033) 4.16 Letter, USNRC to Holtec Decommissioning International, "Pilgrim Nuclear Power Station - Exemptions from Certain Emergency Planning Requirements and Related Safety Evaluation, dated December 18, 2019 (ADAMS Accession Number ML19142A043)

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Reference Use Page 15 of 45 4.17 NUREG-0586, "Generic Environmental Impact Statement of Decommissioning of Nuclear Facilities," Supplement 1, Volume 1, November 2002 4.18 NRC Information Notice No. 90-08: KR-85 Hazards from Decayed Fuel 4.19 10 CFR 72.13, "Applicability

4.20 10 CFR 72.32, "Emergency Plan" 4.21 10 CFR 72.44, "License Conditions" 4.22 10 CFR 72.106, "Controlled Area of an ISFSI or MRS" 4.23 ISFSI Physical Security Plan 4.24 ISFSI EAL Technical Bases Document 5.0 ASSIGNMENT OF RESPONSIBILITY Primary responsibilities for emergency response have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

5.1 Emergency Response and Responsibilities HDI is responsible for the safe storage of spent fuel in accordance with NRC regulations. Responsibility for planning and implementing all emergency measures rests with HDI. The PNPS ISFSI Organization has complete capability at all times to perform the detection, classification, initial response, and notification functions required during an emergency. The organization has an inherent emergency response and recovery function in its overall management and operation.

The ISFSI Shift Supervisor (ISS) is at PNPS on a continuous, 24-hour per day basis, and is the senior management position during off-hours. This position is responsible for monitoring ISFSI conditions and managing the activities at the PNPS ISFSI. The ISS has the responsibility and authority to declare an emergency and initiate appropriate actions in accordance with written procedures to mitigate the consequences. When an off-normal, natural phenomenon, or accident event becomes apparent, the ISS shall assess the condition and assume the position of Emergency Director once an emergency declaration has been made.

The Emergency Director is responsible for the direction of all activities at the ISFSI site during an emergency. Should evaluation indicate the need, the Emergency Director has the authority to direct any or all personnel to relocate from the ISFSI and surrounding area and to notify all applicable agencies of the ISFSI status. The Emergency Director ensures that appropriate actions are taken Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 16 of 45 and management and applicable offsite supporting organizations and regulatory agencies are notified, as necessary. The functions associated within the Emergency Director's scope of responsibilities are specified on Table 6-1.

The Emergency Director does not have concurrent duties which conflict with the above responsibilities.

The on-shift staff positions are staffed on a 24-hour per day basis. The on-shift staff can perform all required IOEP actions. At the direction of the Emergency Director, additional personnel will be activated to support the on-shift staff.

A Resource Manager assists in assessing the event and obtaining additional resources needed to respond to the event.

5.2 Offsite Response Organizations The Emergency Director coordinates the Offsite Response Organization (ORO) response (fire, ambulance, local law enforcement agencies (LLEA), and medical), access, and radiological controls with the onsite activities. Notification of an emergency declaration or change in classification is provided to the Massachusetts Emergency Management Agency (MEMA) via the commercial telephone system.

The response of the MEMA and Commonwealth of Massachusetts agencies are in accordance with each agency's plans and procedures and are commensurate with the hazard posed by the emergency. The OROs listed below are capable of emergency response on a 24-hour per day basis.

5.2.1 Fire Department Arrangements exist with the Plymouth Fire Department to provide response and support services as requested. The fire department is located approximately 5 miles from PNPS, allowing for a timely response.

5.2.2 Ambulance Service Notification via a commercial phone line to the Plymouth Fire Department (the ambulance Dispatcher) provides for a coordinated communications link to the ambulances responding to PNPS or transporting personnel from the from PNPS.

Radiation monitoring services shall be provided by PNPS whenever it becomes necessary to use the ambulance service for the transportation of contaminated persons.

5.2.3 Hospitals PNPS establishes communications with Beth Israel Deaconess (BID) Hospital -

Plymouth and Morton Hospital via commercial telephone or a wireless system.

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Reference Use Page 17 of 45 treatment of patients from PNPS who have Injuries complicated by radioactive contamination. The hospitals have trained personnel and detailed procedures for handling radioactively contaminated patients from PNPS.

5.2.4 Law Enforcement Agencies Law enforcement support services are provided by the local law enforcement agency (LLEA), State, and Federal law enforcement authorities, as appropriate.

5.2.5 Nuclear Regulatory Commission In the event of an emergency at the PNPS ISFSI, the NRC Operations Center in Rockville, Maryland will be notified immediately after notification of the Commonwealth of Massachusetts and not later than 60 minutes after an emergency declaration or change in classification. Classification and radiological information are communicated to this office over the commercial telephone line or via a wireless system from the PNPS ISFSI Emergency Response Facility (ERF).

The NRC is the primary Federal agency providing coordination and support to the licensee in the event of an emergency at the PNPS ISFSI. NRC responsibilities are directed toward a coordination of Federal efforts to provide assistance to the licensee and State and local governments in their planning and implementation of emergency preparedness procedures.

The NRC response must be regarded primarily as supportive of, and not a substitute for, responsible action by PNPS and other key response organizations.

The NRC must be continually informed of status and possible radiological consequences and be frequently updated on plans for emergency and recovery actions and needs for assistance.

6.0 EMERGENCY RESPONSE ORGANIZATION Emergency Response Organization (ERO) responsibilities for emergency response are identified in Table 6-1, "Emergency Response Organization Staffing and Responsibilities."

6.1 On-Shift Positions PNPS maintains on-shift personnel capable of providing the initial response to an off-normal, natural phenomenon, or accident event on a 24-hour per day basis.

Members of the on-shift organization are trained on their responsibilities and duties in the event of a declared emergency and are capable of performing all necessary response actions until any necessary augmenting staff arrives or the event is terminated. The on-shift staffing assignments include the roles and responsibilities for their emergency response functions.

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Reference Use Page 18 of 45 6.1.1 ISSI Shift Supervisor/Emergency Director The ISS is at the PNPS ISFSI on a 24-hour per day basis and is the senior management position during off-hours. This position is responsible for monitoring conditions and approving all onsite activities and has the requisite authority, management ability, technical knowledge, and staff to manage the site, emergency response, and recovery organizations.

The ISS has the responsibility and authority to declare an emergency and to initiate appropriate actions to mitigate the consequences of the emergency in accordance with written procedures. The ISS assumes the position of Emergency Director with overall command and control once an emergency classification has been made. The Emergency Director is responsible for the direction of the total emergency response effort and has the company authority to accomplish this responsibility.

The Emergency Director cannot delegate the following responsibilities:

• Classification of an event

• Approval of emergency notifications to Massachusetts, and the NRC (although the task of making the notifications may be delegated)

• Authorization of radiation exposures in excess of 10 CFR Part 20 limits The Emergency Director is responsible for assuring that appropriate corrective and protective actions are taken to mobilize emergency response personnel and for notifying management, OROs, and regulatory agencies, as necessary. Other responsibilities assumed by the Emergency Director associated with the functions listed in Table 6-1 include:

• Notification of the emergency classification to the NRC and Massachusetts

• Management of available station resources

• Initiation of mitigative actions

• Initiation of mitigative, corrective, and onsite protective actions

• Decision to call for LLEA, fire, or ambulance assistance

• Augmentation of the emergency staff, as deemed necessary

• Coordination of security activities

• Termination of the emergency condition when appropriate

• Performance of initial radiological assessment

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• Suspending security measures 6.1.2 Security Security is maintained in accordance with the ISFSI Physical Security Plan.

Security performs accountability as directed by the ISS or Emergency Director.

6.2 Augmented ERO Positions PNPS maintains the necessary personnel and resources to support the PNPS ISFSI Emergency Director in responding to an emergency.

In addition to the resources listed below, additional personnel resources may be directed to report to the PNPS ISFSI by the Emergency Director to provide additional support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available from PNPS staff and can be requested from various contractors.

6.2.1 Resource Manager The Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration. The Resource Manager will augment the Emergency Director by assisting in the assessment of the emergency condition and coordinating any required resources, including serving as the public information interface. The Resource Manager does not need to physically report to PNPS to perform the assigned responsibilities.

6.2.2 Augmented Responder For a declared emergency involving radiological consequences, a minimum of one person trained in radiological monitoring and assessment will report to the PNPS ISFSI within four (4) hours of the emergency declaration.

6.2.3 Offsite Response Organizations Additional support is available from OROs, as described in Section 5.2 of this Plan.

6.3 Functional Responsibilities Table 6-1 lists the functional responsibilities that fulfill emergency staffing capabilities.

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Reference Use Page 20 of 45 TABLE 6-1 Emergency Response Organization Staffing and Responsibilities FUNCTIONAL LOCATION ON-SHIFT STAFF AUGMENTED AREA RESPONSE Assessment of Emergency Emergency Resource Manager Condition Response Facility Director (Emergency Declaration Emergency Emergency Emergency ---

Direction and Response Facility Director Control Notifications / Emergency Emergency ---

Communications Response Facility Director Radiological Emergency Emergency Resource Accident Response Facility / Director Manager*

Assessment and On Scene Protective Actions Augmented Responder**

Corrective Actions Emergency Emergency ---

Response Facility / Director On Scene Fire Fighting On Scene Per Fire Protection Offsite Response Plan Organization Rescue and First On Scene *** Offsite Response Aid Treatment Organization Site Access Control Security Station Per ISFSI Physical ---

and Accountability Security Plan

• As described in Section 6.2.1

• • As described in Section 6.2.2

• • • Provided by on-shift personnel who may be assigned other functions.

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Reference Use Page 21 of 45 7.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES Arrangements for requesting and effectively using resources have been made and other organizations capable of augmenting the planned response have been identified.

Letters of Agreement are in place for those local organizations (fire, ambulance, LLEA, and medical) listed in Section 5.2 that will respond to an emergency at the PNPS ISFSI.

Letters of Agreement for each organization are maintained on file.

The Emergency Director coordinates the fire, ambulance, and LLEA response as previously discussed in Section 5.2.

The Emergency Director is authorized to request Federal assistance as needed. The NRC will act as the lead Federal agency providing coordination and support in response to an emergency at PNPS as described in Section 5.2.5.

8.0 EMERGENCY CLASSIFICATION SYSTEM A standard emergency classification and emergency action level scheme is in use. This section describes emergency classifications, Initiating Conditions (ICs), EALs, and postulated emergency situations.

8.1 Emergency Classification System The emergency classification system covers the entire spectrum of possible radiological and non-radiological emergencies at the PNPS ISFSI. The emergency classification system categorizes accidents and/or emergency situations into one of two emergency classification levels depending on emergency conditions at the time of the incident: Unusual Event and Alert. Each of these emergency classifications require notification of the ERO, MEMA, and to the NRC.

The emergency classification system is based on NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors", Revision 6. The classification system referenced in NEI 99-01, Revision 6 has been endorsed by the NRC and provides a standard method for classifying emergencies.

Once indications are available that an EAL is met, the event is classified, and the corresponding emergency classification level is promptly declared. Refer to the ISFSI Only Emergency Action Level Technical Bases for actual parameter values, and status used to classify emergencies.

Incidents may initially be classified as an Unusual Event and then escalated to an Alert if the situation deteriorates. The following Sections outline the actions at each emergency classification level.

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Reference Use Page 22 of 45 Refer to the ISFSI Only EAL Technical Bases Document for actual parameter values and status used to classify emergencies.

8.1.1 Unusual Event EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INDICATE A POTENTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE ISFSI 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.

The purpose of the Unusual Event declaration is to: 1) provide for an increased awareness of abnormal conditions; 2) provide for systematic handling of information and decision-making, and 3) augment on-shift personnel, if deemed necessary by the Resource Manager.

Upon declaration of an Unusual Event, offsite authorities shall be informed of the emergency declaration and the necessary documentation will be completed as specified in the EPIPs. The classification shall be maintained until the emergency is terminated or the emergency escalates to an Alert. If an escalation to an Alert occurs, offsite authorities will be informed of the change within 60 minutes of the change in classification.

8.1.2 Alert EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVE AN ACTUAL OR POTENTIAL SUBSTANTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE ISFSI OR A SECURITY EVENT THAT INVOLVES PROBABLE LIFE THREATENING RISK TO SITE PERSONNEL OR DAMAGE TO ISFSI EQUIPMENT BECAUSE OF HOSTILE ACTION. ANY RELEASES ARE EXPECTED TO BE LIMITED TO SMALL FRACTIONS OF THE EPA PAG EXPOSURE LEVELS.

The purpose of the Alert declaration is to: 1) perform event mitigation and radiation monitoring, if required, and 2) ensure that all necessary resources are being applied to accident mitigation.

Upon classification of an Alert, offsite authorities will be informed of the emergency and the necessary documentation will be completed as specified in the EPIPs. The classification shall be maintained until the emergency is terminated. PNPS may enter Recovery operations while in the Alert classification.

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Reference Use Page 23 of 45 8.2 Emergency Action Levels and Postulated Accidents Both emergency classifications are characterized by EALs consisting of specific instrument readings and/or observations which indicate to the ISS that an IC has been met. These EALs are used to ensure that the initial classification of emergencies can be accomplished rapidly, allowing for the prompt identification of the necessary mitigating actions.

EALs and ICs are provided under the following categories:

• ISFSI Malfunction

• Hazards and Other Conditions The Holtec HI-STORM FSAR describes the DBAs applicable to the PNPS ISFSI and the radiological dose calculation results. Specific guidance for classifying emergencies is found in EPIPs and the ISFSI EAL Technical Bases Document.

The emergency classification system and the EALs are reviewed with the authorities of Massachusetts on an annual basis.

9.0 NOTIFICATION METHODS AND PROCEDURES Procedures are established for the prompt notification to MEMA and local organizations and for notification of PNPS emergency personnel in the event of an emergency declaration. PNPS has established the means for notification and dissemination of emergency messages. The content of initial and follow-up messages to response organizations has been established.

9.1 Basis for Notification The notification of personnel and emergency response organizations is commensurate with the hazard posed by the emergency. The emergency classification system described in Section 8.0 is the primary bases for notification and has been mutually agreed upon by applicable State and Federal organizations.

9.2 Emergency Messages The Emergency Director is responsible for the notification of an emergency declaration to MEMA, the Plymouth Fire Department, and the NRC within 60 minutes of the event classification or change in classification.

The format and content of the initial message to MEMA and the Plymouth Fire Department is specified in EPIPs and has been established with the review and agreement of responsible state authorities. The initial notification contains the following information, as available:

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• Identification of the facility

• Identification of the message sender

• Date and Time of the emergency declaration

• Emergency classification, including EAL

• Whether a release has occurred, is occurring, or is anticipated to occur

• Actual or projected dose rates at the site boundary Follow-up reports are provided as additional information describing the emergency situation becomes available, or as requested by MEMA and the Plymouth Fire Department, until such time that the emergency condition has been terminated.

9.3 Means of Providing Emergency Notification Various communications systems, as described in Section 10.0 are available to perform emergency notifications. The Emergency Director is the primary individual for initiating notifications. However, the Emergency Director may designate an individual to perform the notifications. EPIPs and emergency telephone directories identify organizations and individuals to be notified and contain appropriate listings of telephone numbers.

The following sections describe the means of notifying, alerting, and mobilizing the various organizations or individuals.

9.3.1 Commonwealth of Massachusetts Notification of an emergency declaration, and specific emergency information, is conveyed to MEMA using the commercial telephone system. This system is available in the ERF on a 24-hour per day basis and is staffed continuously in the State Police dispatching points.

Other commercial means, including the use of wireless communications, will serve as a backup to the commercial telephone system.

9.3.2 NRC Event Notification The NRC is notified immediately following notification of the MEMA and local government agencies, and not later than 60 minutes after the time of initial emergency declaration, escalation, termination, or entry into recovery phase.

NRC notifications will be performed utilizing the commercial phone system.

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Reference Use Page 25 of 45 9.3.3 ERO Notification The Resource Manager is notified of an emergency declaration by an onsite announcement and the commercial telephone system, or other commercial means which may include land line and/or wireless devices. The Emergency Director is responsible for the notification to the Resource Manager. As described in Section 5.1 of this Plan, the on-shift staff positions are staffed on a 24-hour per day basis and can perform all required IOEP actions.

As described in Section 6.2, the Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration.

Additionally, a Radiological Responder will be contacted for an event requiring radiological accident assessment. At the direction of the Emergency Director, additional personnel will be activated to augment the on-shift staff.

9.3.4 Notification of Offsite Response Organizations The ORO support services described in Section 5.2 of this Plan are primarily notified of the need for assistance via 911 utilizing the commercial telephone system. Requests for ORO support services are the responsibility of the Emergency Director.

10.0 EMERGENCY COMMUNICATIONS Provisions exist for prompt communications between principal response organizations and emergency response personnel. The communications systems listed in Table 10-1 provide 24-hour onsite and offsite communications capability allowing for prompt notification and activation of emergency personnel. In the event of an emergency declaration, these communications systems provide the appropriate means for alerting or activating emergency personnel in each response organization and allow continued means for contact throughout the emergency.

Communications systems providing the capability for onsite and offsite communications are tested to verify proper operation at the frequencies specified in Table 10-1. A testing frequency of "Frequent Use" indicates that the associated equipment is normally used at a sufficiently high regularity (e.g., multiple times each day), such that a dedicated testing frequency is not needed. Functionality is verified through normal (frequent) use of the system.

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Reference Use Page 26 of 45 TABLE 10-1 Communication Systems Communication System Testing Frequency Commercial Telephone System Weekly Portable Radios Frequent Use 11.0 PUBLIC INFORMATION The Emergency Director or Resource Manager will notify the corporate public affairs office of an emergency declaration. Public affairs office personnel will monitor media activity and coordinate with senior management to address rumors and disseminate information to the public.

To ensure timely dissemination of information to the public, news conferences can be conducted onsite or at other locations, as necessary. Corporate public affairs personnel, or senior PNPS or corporate management will represent the facility as the company spokesperson.

12.0 EMERGENCY FACILITY AND EQUIPMENT Adequate emergency facilities and equipment to support the emergency response are provided and maintained. This section of the IOEP identifies and describes the ERF, assessment equipment, the first aid and medical facilities, and protective equipment and supplies that can be utilized during an emergency.

12.1 Emergency Response Facility During an emergency, command and control functions are managed within the ERF. From this location, the Emergency Director (or other personnel, as directed) can assess ISFSI conditions; evaluate the magnitude and potential consequences of abnormal conditions; initiate preventative and corrective actions; and perform emergency notifications.

The ERF is staffed in accordance with Section 6.0 of this Plan. The facility provides sufficient space to accommodate anticipated response personnel and provides 24-hour availability of the communications systems specified in Section 10.0.

Radiological conditions resulting from the DBAs specified in the Holtec HI-STORM FSAR do not inhibit staffing of the ERF.

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Reference Use Page 27 of 45 12.2 Emergency Equipment and Supplies This section describes the monitoring instruments used to initiate emergency measures and provide continuing assessment of conditions throughout the course of an emergency.

12.2.1 Portable Radiation and Contamination Monitoring Instruments PNPS maintains portable radiation and contamination monitoring equipment necessary for monitoring the conditions of the ISFSI. These instruments are normally utilized and maintained by radiation monitoring personnel and are available for emergency use.

12.2.2 Communication Systems Communications systems providing for 24-hour per day onsite and offsite communications capabilities are identified and tested as described in Section 10.0.

12.2.3 Emergency Supplies Emergency equipment and supplies necessary to carry out the provisions of the IOEP and support procedures are maintained in the ERF.

Appendix A, "Emergency Equipment, Supplies, and Reference Materials," lists equipment, supplies, and. reference materials that are to be maintained in the ERF and other onsite locations.

13.0 ACCIDENT ASSESSMENT Effective response to a potential emergency situation requires assessment to determine the nature of the emergency and its actual and potential consequences. PNPS has established various methods to evaluate and monitor the effects of a potential emergency and has the appropriate means to ensure adequate assessment.

The assessment activities required to evaluate a particular emergency depend on the specific nature and classification of the emergency. The Emergency Director is responsible for the initial measurement of ISFSI dose rates after off-normal, natural phenomena, or accident events. The EALs identify the parameter value to determine the emergency condition. Classification of events is performed by the Emergency Director in accordance with the EAL scheme.

If the measured ISFSI dose rates exceed the EAL threshold, the Emergency Director ensures a radioactive release assessment in the vicinity of the affected storage module or cask is performed. After the assessment is complete, the Emergency Director contacts the Resource Manager for assistance in interpreting the results of the radioactive release assessment.

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Reference Use Page 28 of 45 Notification of the radiological release assessment is performed in accordance with Section 9.0.

14.0 PROTECTIVE ACTIONS Protective actions for onsite personnel are provided for their health and safety.

Implementation guidelines for onsite protective actions are provided in EPIPs.

Additionally, implementing procedures provide for a range of protective actions to protect onsite personnel during hostile actions.

14.1 Accountability The Emergency Director has the authority to initiate personnel accountability.

Accountability should be considered and used as a protective action whenever a risk to health or safety exists, or at the discretion of the Emergency Director. If personnel accountability is required, at the direction of the Emergency Director, all individuals at the facility (including employees without emergency assignments, visitors, and contractor personnel) shall be notified of the emergency and provided with instructions.

Accountability of all personnel inside the ISFSI Protected Area should be accomplished within 60 minutes after event declaration and maintained thereafter at the discretion of the Emergency Director. Following announcement of an emergency declaration, onsite personnel are responsible for reporting to designated areas and aiding the accountability process. If personnel are not accounted for, the Emergency Director is notified and onsite announcements are made. If personnel are still unaccounted for following the onsite announcements, Security will initiate sweeps to locate the missing individual(s).

Accountability may be modified or suspended if the safety of personnel could be jeopardized by a security event or other event hazardous to personnel health and safety.

14.2 Personnel and Visitors Located Outside the ISFSI Protected Area Other areas within the Site Boundary may be affected by the need to relocate personnel. If required, the Emergency Director will determine the specific areas requiring protective actions. Personnel and visitors located outside of the ISFSI Protected Area but within the Site Boundary, will be directed to report to an assembly area or exit the site as appropriate, in accordance with EPIPs. The Emergency Director is responsible for controlling access to the site when the IOEP is activated.

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Reference Use Page 29 of 45 15.0 RADIOLOGICAL EXPOSURE CONTROL The means for controlling radiological exposures during an emergency are established for emergency workers. The means for controlling radiological exposures include exposure guidelines consistent with the Environmental Protection Agency's (EPA)

Emergency Worker and Lifesaving Activity Protective Action Guides (PAGs).

15.1 Exposure Guidelines During an emergency, doses above normal occupational radiation exposure limits may be authorized by the Emergency Director for activities such as saving a life, preservation of valuable equipment, or controlling exposure.

All reasonable measures shall be taken to control the radiation exposure to emergency response personnel providing rescue, first aid, decontamination, emergency transportation, medical treatment services, corrective actions, or assessment actions within applicable limits specified in 10 CFR Part 20. The Emergency Director is responsible for authorizing emergency response personnel to receive doses in excess of 10 CFR Part 20 limits. This authority cannot be delegated.

Table 15-1 contains the guidelines for emergency exposure criteria, which is consistent with Table 2-2, "Response Worker Guidelines," of the EPA's "Protective Action Guide and Planning Guidance for Radiological Incidents."

15.2 Radiation Protection PNPS maintains a radiological exposure control program to ensure that protection against radiological exposure, as set forth in 10 CFR Part 20, is provided. Exposure to individuals providing emergency functions will be consistent with the limits specified in Table 15-1 with every attempt, made to keep exposures As Low As Reasonably Achievable (ALA RA).

15.2.1 Access Control During a classified emergency, radiological surveys of the ISFSI and its immediate vicinity will be performed to determine the extent of the radiological concern. The Emergency Director will ensure Radiological Control Areas (RCAs) and access controls are established to prevent personnel from entering the area.

Recovery and corrective actions will be planned and executed in a manner that minimizes personnel exposure.

15.2.2 Personnel Exposure Monitoring Personal dosimeters are utilized to monitor the exposure of personnel during normal or emergency conditions. Adequate supplies of dosimeters are maintained for use during an emergency. Procedures describe the types of Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 30 of 45 personal dosimeter devices, the manner in which they are to be used, who is to wear them, and how they are to be cared for.

Emergency worker dose records are maintained in accordance with Radiation Protection procedures.

15.3 Personnel Contamination Control Various contamination control measures are utilized. These include access control measures and the means for the decontamination of personnel, areas, and equipment. These activities are addressed in facility procedures and are briefly described below.

All personnel are monitored for radioactive contamination prior to leaving the site.

Portable contamination monitoring instruments are available to frisk personnel for potential contamination.

During normal or emergency conditions, contamination should be removed from any part of a person's body prior to leaving the RCA. All personnel decontamination, including during an emergency, will be performed in accordance with established Radiation Protection procedures.

Documentation of surveys, contamination, and decontamination activities shall be maintained in accordance with Radiation Protection procedures.

TABLE 15-1 Response Worker Emergency Dose Limits Guideline Activity Condition 5 Rem All occupational exposures All reasonably achievable actions have been taken to minimize dose.

10 Rem (a) Protecting valuable property Exceeding 5 rem unavoidable and necessary for public welfare all appropriate actions taken to reduce dose. Monitoring available to project or measure dose.

25 Rem (b)(c) Lifesaving or protection of Exceeding 5 rem unavoidable and large populations all appropriate actions taken to reduce dose. Monitoring available to project or measure dose.

(a) For potential doses > 5 rem, medical monitoring programs should be considered.

(b) In the case of a very large incident, consider the need to raise the property and lifesaving Response Worker Guideline to prevent further loss.

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Reference Use Page 31 of 45 (c) Response actions that could cause exposures in excess of the 25 rem should only be undertaken with an understanding of the potential acute effects of radiation to the exposed responder and only when the benefits of the action clearly exceed the associated risks.

Note 1: Reference for this table is Table 2-2 of the EPA PAG Manual.

Note 2: The dose limits in Table 15-1 are in addition to any annual occupational dose already received.

16.0 MEDICAL AND HEALTH SUPPORT Arrangements are made for medical services for injured individuals and/or contaminated injured individuals. PNPS maintains on-shift personnel and supplies to provide first-aid for personnel working at the site. Medical emergency supplies are located in various locations.

If immediate professional medical help is required, arrangements exist with local ambulance and medical services to assist in the transport and treatment of injured personnel, as described in Section 5.2. Assistance is requested via 911 utilizing the commercial telephone system.

16.1 Onsite First Aid First aid assistance at the PNPS ISFSI is designed to address a wide range of common injuries. This task is accomplished by on-site individuals trained in basic first aid.

16.2 Medical Transportation Plymouth Fire Department provides 24-hour per day ambulance dispatch for emergency transportation of personnel for offsite treatment, including the transport of contaminated injured workers. Transportation is also available via PNPS vehicles or private vehicles, if necessary.

When personnel are transported to Beth Israel Deaconess Hospital - Plymouth or Morton Hospital in a contaminated condition, personnel trained in radiological monitoring will be dispatched to monitor and maintain radiological controls.

16.3 Offsite Medical Support Beth Israel Deaconess Hospital - Plymouth and Morton Hospital accepts and treats personnel with routine industrial injuries as well as injuries complicated by radioactive contamination or radiation exposure. The hospital maintains the capability and facilities to provide radioactive decontamination. These services and facilities are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.

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Reference Use Page 32 of 45 17.0 EMERGENCY TERMINATION AND RECOVERY PNPS has established general plans described in the following sections to address recovery from potential emergencies at the PNPS ISFSI. The recovery organization will be based on the normal PNPS ISFSI organization. The senior management position directs the recovery organization and is responsible for:

• Ensuring the PNPS ISFSI is maintained in a safe condition;

• Managing onsite recovery activities during the initial recovery phase;

• Keeping corporate support apprised of PNPS ISFSI activities and requirements.

17.1 Emergency Termination and Notification Termination of a declared emergency is the responsibility of the Emergency Director. The Emergency Director is also responsible for providing notification of the emergency termination and initiation of recovery operations to MEMA, Plymouth Fire Department, PNPS ISFSI personnel, the NRC, and other organizations that may be providing on-site support.

At the discretion of the Emergency Director, PNPS may enter recovery operations and the ISFSI could be returned to a stable condition before terminating the emergency.

17.2 Recovery Operations PNPS is responsible for recovery measures and restoring the ISFSI to a stable condition. In an emergency event, immediate response actions are directed towards limiting the consequences of the emergency in a manner that will afford maximum protection to onsite personnel. Once the immediate assessment and protective actions have been implemented, the restoration and recovery measures can be initiated.

The extent and nature of the corrective and protective actions and the extent of recovery will depend on the emergency conditions and the status of the ISFSI.

The general goals for recovery include:

• An orderly evaluation of the cause and effect of the emergency and implementation of solutions to prevent immediate recurrence of the incident

• A planned approach for returning the ISFSI to a stable condition by obtaining the appropriate resources, materials, and equipment

• A planned approach to coordinate with offsite authorities to identify and resolve situations that may impact the general public Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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• An evaluation of the radiation exposure records for all onsite emergency response personnel involved in the incident

• A planned approach to ensure that radiation exposures and contamination controls are consistent with the ALARA program ISFSI recovery activities shall be in accordance with the ISFSI Technical Specifications and other licensee documents. During ISFSI recovery, the radiation exposure limits of 10 CFR Part 20 shall apply.

• If, during recovery operations, an emergency situation occurs, recovery efforts will be suspended until the emergency condition is resolved. The Emergency Director will re-evaluate ISFSI conditions prior to resuming recovery.

17.3 Termination of Recovery Operations The recovery operations will be terminated by PNPS's senior management position directing the recovery organization after the ISFSI is returned to a stable condition.

18.0 EXERCISES AND DRILLS Periodic exercises are conducted to evaluate major portions of PNPS's emergency response capabilities. Periodic drills are conducted to develop and maintain key skills.

Deficiencies as a result of exercises or drills are identified and corrected.

An exercise tests the execution of the overall emergency preparedness and the integration of this preparedness. A drill is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular response function. A summary of exercises and drills, including the associated elements for each, is outlined below.

18.1 Emergency Plan Exercises and Drills A Biennial Exercise is conducted for the purposes of testing: 1) the adequacy of timing and content of implementing procedures and methods; 2) emergency equipment and communication networks, and; 3) to ensure that emergency personnel are familiar with their duties. PNPS offers the following organizations the opportunity to participate to the extent that their assistance would be expected during an emergency declaration. However, participation is not required.

• MEMA

• Plymouth Fire Department

• Beth Israel Deaconess Hospital - Plymouth

• Morton Hospital Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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• LLEAs At least one drill involving a combination of some of the principal functional areas of emergency response shall be conducted in the interval between Biennial Exercises for the purpose of testing, developing, and maintaining the proficiency of emergency responders.

Exercise and Drill scenarios will include, at a minimum, the following:

• The basic objective(s) of the exercise/drill

• The date(s), time period, place(s), and participating organizations

• A time schedule of real and simulated events

• A narrative summary describing the conduct of the drill to include such items as simulated casualties, offsite fire assistance, rescue of personnel, and use of protective clothing The scenarios will be varied from year to year such that all major elements of the plans and preparedness organizations are tested.

18.2 Equipment and Proficiency Drills Drills are conducted for the purpose of training, developing, and maintaining the proficiency of emergency responders. Additionally, drills may be used to test and evaluate the adequacy of the ERF, equipment, procedures, communication channels, actions of emergency response personnel, and coordination between OROs and the facility.

18.2.1 Communication Drills To ensure that emergency communications systems described in Section 10.0 are operable, communications tests are conducted as outlined below.

1. To test the capability to notify MEMA utilizing commercial telephone system, the capability is functionally tested annually. This drill will include the aspect of understanding the content of the message.

2. To test the capability to communicate with the NRC, communication systems are tested annually.

3. The following communications systems, as detailed in Section 10.0, are used on a frequent basis, therefore periodic testing of these systems is not necessary:

• Commercial Telephone System

• Portable Radios Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 35 of 45 Performance of the Communication Drills satisfies the testing requirements specified in Section 10.0.

18.2.2 Staff Augmentation Drills An unannounced, off-shift, staff augmentation drill shall be conducted annually.

These drills shall involve implementation of the ERO callout system procedure and documentation of the estimated response time for each responder. This drill shall serve to demonstrate the capability to augment the Emergency Director after an emergency declaration.

18.2.3 Radiological Monitoring Drills Radiological monitoring drills are conducted annually. These drills demonstrate the ability to perform radiological survey and assessment and can be performed separately or as part of an Emergency Plan exercise or drill.

18.2.4 Medical Emergency Drills To evaluate the training of medical response personnel, a medical drill is conducted annually involving a simulated contaminated injured individual and may also contain provisions for participation by local fire department(s) and hospital(s) This drill may be performed separately or as part of the Biennial Exercise.

18.2.5 Fire Drills Fire Drill are conducted in accordance with the PNPS Fire Protection Program.

18.3 Critique Evaluation Critiques are used to evaluate the performance of participating facility personnel and the adequacy of the ERF, equipment, and procedures. The ability of emergency response personnel to self-evaluate weaknesses and identify areas for improvement is key to successful exercise or drill conduct.

Exercise and drill performance objectives are evaluated against measurable demonstration criteria. As soon as possible following the conclusion of each exercise or drill, a critique, including participants and evaluators, is conducted to evaluate the ability of the ERO to implement the IOEP and associated procedures. Deficiencies identified during exercises or drills are entered into the corrective actions program.

A written report is prepared following an exercise or drill involving the evaluation of designated objectives. The report evaluates and documents the ability of the ERO to respond to a simulated emergency situation. The report will also contain reference to corrective actions and recommendations for revisions to the IOEP, Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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19.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING Radiological emergency response training is provided to those who may be called on to assist in an emergency. All personnel at the PNPS ISFSI who fill required positions in the ERO will take part in a training program to ensure adequate preparedness to assist in an emergency situation. OROs that may be called upon for emergency assistance will also be invited to participate in appropriate training programs.

19.1 Emergency Response Personnel Training Requirements for emergency preparedness training are specified in the Emergency Preparedness Training Program. This program identifies the level and the depth to which individuals are to be trained. The training program for emergency response personnel is based on position-specific responsibilities as defined in the IOEP. Emergency response personnel in the following categories receive initial training and annual retraining.

19.1.1 ISFSI Shift Supervisors/Emergency Directors and Resource Managers The ISS/Emergency Directors and Resource Managers shall have training conducted such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.

• EAL classification

• Offsite notification procedures

• ERO activation

• Dose rate meter operation

• Radioactive release assessment

• Emergency exposure control

• Protective actions for onsite personnel

• ISFSI DBAs

• Review of applicable drill and exercise-identified deficiencies Personnel available during declared emergencies who may be called upon to perform emergency response activities as an extension of their normal duties Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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19.1.2 First Aid Personnel First Aid training is provided to personnel assigned on-shift in accordance with site training and qualification plan.

19.1.3 Radiation Monitoring Personnel Radiation monitoring personnel shall have training conducted such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.

• Use of Radiation Protection procedures

• Use of emergency survey equipment

• Communications

• Field Surveys

• Role of dose assessment in an emergency

• Monitoring of radioactive releases

• Protective actions for onsite personnel

• Review of applicable drill and exercise-identified deficiencies 19.1.4 Personnel Badged for Unescorted Access Personnel who are badged for unescorted access receive access training annually. Information pertaining to their safety and the safety of visitors under escort during a classified emergency is included in this training.

Access training shall include the following emergency preparedness topics:

• Basic Emergency Plan and implementing preparedness topics

• Emergency classification levels

• Call out of personnel during an emergency

• Personnel accountability procedures Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 38 of 45 19.2 Non-PNPS Emergency Response Support Organizations Training is offered annually to OROs that may be requested to provide assistance in the event of an emergency at the PNPS ISFSI (e.g., law enforcement, firefighting, rescue, medical services, transport of injured, etc.). The training shall be structured to meet the needs of the particular organization with respect to the nature of their support. Training topics such as event notification, site access procedures, basic radiation protection, and interface activities between the ORO and PNPS are included in the training.

19.3 Annual Emergency Action Level Training The emergency classification system specified in Section 8.0 and the EALs are reviewed with the authorities of the Commonwealth of Massachusetts, annually.

20.0 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW, AND DISTRIBUTION Responsibilities for IOEP development and review and for distribution of the IOEP are established and planners are properly trained.

20.1 Emergency Preparedness Responsibilities 20.1.1 Overall Authority and Responsibility A member of PNPS's senior management has the overall authority and responsibility for emergency response planning and implementation of the IOEP.

This responsibility includes ensuring that the emergency preparedness program is maintained and implemented as described in the IOEP, and that applicable requirements and regulations are met.

20.1.2 Maintaining the IOEP The PNPS ISFSI senior management position is responsible for maintaining an adequate knowledge of emergency preparedness regulations, emergency planning techniques, and the latest applications of emergency equipment and supplies. The position is responsible for the following tasks:

• Maintaining and updating this Plan and associated procedures

• Ensuring exercise and drill commitments stated in this Plan are met

• Ensuring material readiness of the ERF

• Overseeing the Emergency Preparedness Training Program

• Maintaining Emergency Preparedness interfaces with OROs Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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• Performing and documenting appropriate evaluations of the Emergency Preparedness program and classified emergency events Individuals assigned the duties of maintaining the IOEP are required to maintain an adequate knowledge of regulations, planning techniques, and the latest applications of emergency equipment and supplies. Training for these individuals includes 10 CFR 50.54(q) Evaluation Qualification.

20.1.3 Audits Independent audits of the emergency preparedness program meeting the requirements of 10 CFR 50.54(t) will be performed. All aspects of emergency preparedness, including exercise documentation, capabilities, procedures, and interfaces with state and local governments are audited.

20.2 Review and Updating of the IOEP The IOEP, the associated EPIPs, and the ISFSI Only EAL Technical Bases Documents are reviewed at least annually, and updated as needed, in accordance with the requirements of 10 CFR 50.54(q). The review shall encompass the need for changes based upon the following:

• Written critiques and evaluations of drills and exercises

• Changes in the organizational structure

• Changes in the functions and capabilities of supporting agencies

• Changes in Federal or State regulations

• Modifications to the facility which would affect emergency planning

• Recommendations or agreement changes received from other organizations Any changes shall be incorporated in the IOEP, EPIPs, and the ISFSI Only EAL Technical Bases Document. Proposed activities that may impact the IOEP must be evaluated per 10 CFR 50.54(q).

20.2.1 Emergency Telephone Directory Names and telephone numbers of the ERO and supporting OROs shall be reviewed at least annually and updated as necessary).

20.2.1 Letters of Agreement Written agreements with outside support organizations listed are evaluated biennially to determine if these agreements remain valid. If agreements are determined to no longer be valid, then they are updated and renewed with the applicable organization.

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Reference Use Page 40 of 45 20.3 Training The Emergency Preparedness position shall assist senior management in coordinating and/or providing emergency planning-related training. The position shall ensure that the training described in Section 19.0 is properly coordinated to ensure adequate qualifications, training, and retraining of personnel.

20.4 Maintenance and Inventory of Emergency Equipment and Supplies Specific emergency response equipment and reference materials are listed in Appendix A. The items listed in Appendix A are inspected, inventoried, and operationally checked quarterly and after each use. Sufficient reserves are maintained to replace those which are removed for calibration or repair.

Equipment in these inventories is checked and calibrated in accordance with approved procedures.

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Reference Use Page 41 of 45 APPENDIX A EMERGENCY EQUIPMENT, SUPPLIES, AND REFERENCE MATERIALS Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 42 of 45 APPENDIX A EMERGENCY EQUIPMENT, SUPPLIES AND REFERENCE MATERIALS EMERGENCY RESPONSE FACILITY Procedures / Reference Materials

• ISFSI Only Emergency Plan

• ISFSI Only EAL Technical Bases Document

• Emergency Telephone Directory

• EPIPs Equipment

• Portable radiation monitoring instrument

• Portable emergency lighting

• Medical emergency response kit ONSITE LOCATIONS Equipment / Supplies

• Portable radiation and contamination monitoring instruments

• Contamination control supplies

• Decontamination control supplies

• Protective clothing

• Dosimeters

• Radiological postings and barricades Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 43 of 45 APPENDIX B CROSS-REFERENCE IOEP SECTION TO PLANNING STANDARDS/REQUIREMENTS/CRITERIA AND EPIPS Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 44 of 45 APPENDIX B-1 CROSS-REFERENCE BETWEEN THE PDEP, NUREG-0654/FEMA-REP-1, 10 CFR 50.47(b) PLANNING STANDARDS, AND APPENDIX E.IV PLANNING REQUIREMENTS IOEP Planning Planning NUREG-0654 Procedure Section Standard Requirement Section II Evaluation (10CFR50.47)** (Appendix E.IV)** Criteria 5.0 (b)(1) A.1,2,4,7 A TBD 6.0 (b)(2) A.1,2,4,9; C.1 B TBD 7.0 (b)(3) A.6,7 C TBD 8.0 (b)(4) B.1,2;C.1,2 D TBD 9.0 (b)(5) A.6,7;C.1,2;D.1,3;E E TBD 10.0 (b)(6) C.1;D.1,3;E F TBD 11.0 (b)(7) Exempt G TBD 12.0 (b)(8) E;G H TBD 13.0 (b)(9) A.4;B.1;C.2;E I TBD 14.0 (b)(10) C.1;E;I J TBD 15.0 (b)(11) E K TBD 16.0 (b)(12) A.6,7;E L TBD Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Reference Use Page 45 of 45 17.0 (b)(13) H M TBD 18.0 (b)(14) E9;F N TBD 19.0 (b)(15) F O TBD 20.0 (b)(16) G P TBD

• • as exempted Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

Letter Number HDI-PIL-21-008 Enclosure 1 Attachment 2 PILGRIM NUCLEAR POWER STATION ISFSI ONLY EMERGENCY ACTION LEVELS (EALs)

AND TECHNICAL BASES (23 pages follow)

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Bases Reference Use Page 1 of 23 SEE PROCEDURE EP-AD-270 FOR EQUIPMENT IMPORTANT TO EMERGENCY RESPONSE (EITER)

SUMMARY

OF REVISIONS Revision 0: Implement ISFSI Only Emergency Plan by aligning Emergency Action Levels (EALs) with DPP-PIL-EP-001 Previous revision is EP-IP-100.1, Revision 13 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 2 of 23 TABLE OF CONTENTS PURPOSE ............................................................................................................ 3 DISCUSSION ....................................................................................................... 3 2.1 Permanently Defueled Facility .............................................................................. 3 2.2 Independent Spent Fuel Storage Installation ........................................................ 4 KEY TERMINOLOGY USED ................................................................................ 4 3.1 Emergency Classification Levels (ECLs) .............................................................. 4 3.2 Initiating Condition (IC) ......................................................................................... 5 3.3 Emergency Action Level (EALs) ........................................................................... 6 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ............................ 6 4.1 General Considerations ........................................................................................ 6 4.2 Classification Methodology ................................................................................... 7 4.3 Classification of Multiple Events and Conditions .................................................. 7 4.4 Classification of Imminent Conditions ................................................................... 7 4.5 Emergency Classification Level Upgrading and Termination ............................... 8 4.6 Classification of Short-Lived Events ..................................................................... 8 4.7 Classification of Transient Conditions ................................................................... 8 4.8 After-the-Fact Discovery of an Emergency Event or Condition ............................ 8 4.9 Retraction of an Emergency Declaration .............................................................. 9 REFERENCES ..................................................................................................... 9 5.1 Developmental...................................................................................................... 9 5.2 Implementing ........................................................................................................ 9 5.3 Commitments ....................................................................................................... 9 ACRONYMS & DEFINITIONS ............................................................................ 10 6.1 Acronyms ........................................................................................................... 10 6.2 Definitions ........................................................................................................... 10 ATTACHMENTS................................................................................................. 12 Attachment 1, EAL Matrices ...................................................................................... 13 Attachment 2, EAL Bases .......................................................................................... 16 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 3 of 23 PURPOSE This document provides the detailed set of Emergency Action Levels (EALs) applicable to the Pilgrim Nuclear Power Station (PNPS) when all nuclear fuel has been located at the Independent Spent Fuel Storage Installation (ISFSI) and the associated Technical Bases using the EAL development methodology found in NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (NEI 99-01, Appendix C, Rev. 6). As a permanently defueled facility, PNPS will use the Recognition Category "PD" (Permanently Defueled) to provide a site-specific emergency classification scheme including a set of Initiating Conditions (ICs) and EALs associated with the permanently defueled condition and Recognition Category "E" ICs for the ISFSI. Permanently defueled station ICs and EALs are addressed in Appendix C of NEI 99-01, Rev. 6. All recommendations for changes to this document or associated implementing procedures are reviewed in accordance with 10 CFR 50.54(q).

This document should be used to facilitate review of the PNPS EALs, provide historical documentation for future reference, and serve as a resource for training. Individuals responsible for the classification of events will refer to the ICs and EALs contained in the matrix of this document. They may use the information in the associated "Basis" and "Notes" sections as a reference in support of EAL interpretation. An EAL matrix may be provided as a user aid.

Emergency classifications are to be made as soon as conditions are present and recognizable for the classification in accordance with the applicable EALs; but within 30 minutes in all cases after the availability of indications to operators that an EAL threshold has been reached. Use of this document for assistance is not intended to delay the emergency classification.

DISCUSSION 2.1 Permanently Defueled Facility NEI 99-01, Appendix C, Rev. 6, provides guidance for an emergency classification scheme applicable to a permanently defueled facility. This is a facility that generated spent fuel under a 10 CFR Part 50 license, has permanently ceased operations and will store the spent fuel onsite for an extended period of time. The emergency classification levels applicable to permanently defueled facility are consistent with the requirements of 10 CFR Part 50 and NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1" (NUREG-0654).

The NRC has approved specific exemptions to Emergency Planning regulations for PNPS confirming that no credible event can result in a significant radiological release Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 4 of 23 beyond the site boundary. There is no source term and motive force available in the permanently defueled condition to warrant classifications of a Site Area Emergency or General Emergency.

Therefore, the generic ICs and EALs applicable to a permanently defueled facility may only result in either a Notification of UNUSUAL EVENT (UNUSUAL EVENT) or ALERT classification.

2.2 Independent Spent Fuel Storage Installation Selected guidance in NEI 99-01, Rev. 6, is applicable to licensees electing to use their 10 CFR Part 50 emergency plan to fulfill the requirements of 10 CFR 72.32 for a stand-alone Independent Spent Fuel Storage Installation (ISFSI). The emergency classification levels applicable to an ISFSI are consistent with the requirements of 10 CFR Part 50. The initiating conditions germane to a 10 CFR 72.32 emergency plan (as described in NUREG-1567, "Spent Fuel Dry Storage Facilities") are subsumed within the classification scheme for a 10 CFR 50.47 emergency plan.

The analysis of potential onsite and offsite consequences of accidental releases associated with the operation of an ISFSI is contained in NUREG-1140, "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees" (NUREG-1140). NUREG-1140 concluded that the postulated worst-case accident involving an ISFSI has insignificant consequences to public health and safety.

This evaluation shows that the maximum offsite dose to a member of the public due to an accidental release of radioactive materials would not exceed 1 rem Total Effective Dose Equivalent.

Regarding the above information, the expectations for an offsite response to an ALERT classified under a 10 CFR 72.32 emergency plan are generally consistent with those for an UNUSUAL EVENT in a 10 CFR 50.47 emergency plan (e.g., to provide assistance if requested). Also, the licensee's Emergency Response Organization (ERO) required for 10 CFR 72.32 emergency plan is different from that prescribed for a 10 CFR 50.47 emergency plan (e.g., there is no emergency technical support function required).

KEY TERMINOLOGY USED There are several key terms that appear throughout the NEI 99-01, Rev. 6, methodology. These terms are introduced in this section to support understanding of subsequent material.

3.1 Emergency Classification Levels (ECLs)

One of a set of names or titles established by the U.S. Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 5 of 23 effects or consequences, and (2) resulting onsite and offsite response actions. The ECLs that remain applicable to PNPS, in ascending order of severity, are:

3.1.1 UNUSUAL EVENT(UE)

Events are in progress or have occurred which indicate a potential degradation of the level of safety of the facility 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.

Purpose:

The purpose of this classification is to assure that the first step in future response has been carried out, to bring the operations staff to a state of readiness, and to provide systematic handling of UNUSUAL EVENT information and decision-making.

3.1.2 ALERT Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the facility 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 Environmental Protection Agency (EPA)

Protective Action Guides (PAG) exposure levels.

Purpose:

The purpose of this classification is to assure that emergency personnel are readily available to respond if the situation becomes more serious or to perform confirmatory radiation monitoring if required and provide offsite authorities current information on facility status and parameters.

3.2 Initiating Condition (IC)

An event or condition that aligns with the definition of one of the two ECLs by virtue of the potential or actual effects or consequences.

Discussion: An IC describes an event or condition, the severity or consequences of which meets the definition of an ECL. An IC can be expressed as a continuous, measurable parameter (e.g., radiation monitor readings) or an event (e.g., an earthquake).

Appendix 1 of NUREG-0654 does not contain example EALs for each ECL, but rather ICs (i.e., conditions that indicate that a radiological emergency, or events that could lead to a radiological emergency, have occurred). NUREG-0654 states that the ICs form the basis for establishment by a licensee of the specific facility instrumentation readings (as applicable) which, if exceeded, would initiate the emergency classification. Thus, it is the specific instrument readings that would be the EALs.

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Bases Reference Use Page 6 of 23 3.3 Emergency Action Level (EALs)

A pre-determined, site-specific, observable threshold for an IC that, when met or exceeded, places the facility in a given ECL.

Discussion: EAL statements may utilize a variety of criteria including instrument readings and status indications, observable events, results of calculations and analyses, entry into particular procedures, and the occurrence of natural phenomena.

GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 4.1 General Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an IC. This includes the EAL plus Notes and the informing Basis information.

All emergency classification assessments should 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 indicator's operability, the condition's existence, or the report's accuracy. For example, validation could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by personnel. The validation of indications should be completed in a manner that supports timely emergency declaration.

For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 60 minutes, etc.), the Emergency Director 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.

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 facility 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.

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., gaseous and liquid effluent sampling, etc.); the EAL and/or the associated basis discussion will identify the necessary analysis. In these cases, the declaration period starts with the Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 7 of 23 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).

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, Rev. 6, scheme provides the Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the ECL definitions (refer to PD-HU3 and PD-HA3). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.

4.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e.,

the relevant facility indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL(s) must be consistent with the Notes.

If an EAL has been met or exceeded, then the IC is considered met and the associated ECL is declared in accordance with facility procedures.

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

4.3 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 during this review is declared.

For example:

• If an UNUSUAL EVENT EAL and an ALERT EAL are met, an ALERT should be declared.

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

• If two UNUSUAL EVENT EALs are met, an UNUSUAL EVENT 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."

4.4 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director 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 Director, meeting an EAL is Imminent, the emergency classification should Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 8 of 23 be made as if the EAL has been met. While applicable to all ECLs, this approach is particularly important at the higher ECL since it provides additional time for implementation of protective measures.

4.5 Emergency Classification Level Upgrading and Termination An ECL may be terminated when the event or condition that meets the IC and EAL no longer exists. Events will not be downgraded.

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

4.6 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 would be an earthquake or explosion.

4.7 Classification of Transient Conditions It is important to stress that the emergency classification assessment period 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.

4.8 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, "Event Report Guidelines 10 CFR 50.72 and 50.73," is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR 50.72 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.

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REFERENCES 5.1 Developmental 5.1.1 NEI 99-01 Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012 5.1.2 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities 5.1.3 RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2007 5.1.4 NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 5.1.5 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors 5.1.6 NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 5.1.7 10 CFR 72.32, Emergency Plan 5.1.8 NUREG-1567, Spent Fuel Dry Storage Facilities 5.1.9 10 CFR 50.47, Emergency Plans 5.1.10 NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees 5.2 Implementing 5.2.1 EP-PP-01 R. 54, ISFSI Only Emergency Plan 5.2.2 EP-IP-100.1, R. 14 Emergency Action Levels and Bases 5.3 Commitments None Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 10 of 23 ACRONYMS & DEFINITIONS 6.1 Acronyms ABN ................................................................................ Abnormal Operating Procedure CDE ..................................................................................... Committed Dose Equivalent CFR ..................................................................................... Code of Federal Regulations cpm ...................................................................................................... Counts per Minute EAL ............................................................................................ Emergency Action Level ECL ................................................................................. Emergency Classification Level EPA ............................................................................. Environmental Protection Agency FAA ................................................................................. Federal Aviation Administration FBI .................................................................................. Federal Bureau of Investigation FEMA ............................................................. Federal Emergency Management Agency ISFSI ........................................................... Independent Spent Fuel Storage Installation IC.......................................................................................................... Initiating Condition mRem .............................................................................. milli-Roentgen Equivalent Man MSL ........................................................................................................ Mean Sea Level NEI ............................................................................................. Nuclear Energy Institute NORAD .................................................. North American Aerospace Defense Command NRC .............................................................................. Nuclear Regulatory Commission ODCM .......................................................................... Off-site Dose Calculation Manual PAG ............................................................................................. Protective Action Guide PD ................................................................................................. Permanently Defueled rem .......................................................................................... Roentgen Equivalent Man TEDE .............................................................................. Total Effective Dose Equivalent

µCi/cc......micro Curies per Cubic Centimeter UFSAR ............................................................. Final Safety Analysis Report as Updated 6.2 Definitions NOTE: Selected terms used in IC and EAL statements are set in all capital letters (e.g., ALL CAPS).

ALERT: Refer to Section 3.1.2.

CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.

Emergency Action Level (EAL): Refer to Section 3.3.

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Bases Reference Use Page 11 of 23 Emergency Classification Level (ECL): Refer to Section 3.1.

Initiating Condition (IC): Refer to Section 3.2.

HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) 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 the NPP. 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: Any 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.

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.

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.

NORMAL LEVELS: As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.

OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business.

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

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.

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.

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Bases Reference Use Page 12 of 23 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.

ATTACHMENTS Attachment 1: EAL Matrices Attachment 2: EAL Basis Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 13 of 23 ATTACHMENT 1 Table PD-1: Recognition Category "PD" and E Initiating Condition Matrix ALERT UNUSUAL EVENT Independent Spent Fuel Storage Installation E-HU1: Damage to a loaded cask CONFINEMENT BOUNDARY Hazards and Other Conditions PD-HA1 HOSTILE ACTION is occurring or PD-HU1 Confirmed SECURITY CONDITION has occurred. or threat.

PD-HA3 Other conditions exist which in the PD-HU3 Other conditions exist which in the judgment of the Emergency Director warrant judgment of the Emergency Director warrant declaration of an ALERT. declaration of an UNUSUAL EVENT.

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Bases Reference Use Page 14 of 23 ATTACHMENT 1 Table PD-1: Recognition Category "PD" and E Initiating Condition Matrix ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Facility Safety PD-HA1 HOSTILE ACTION is occurring or has PD-HU1 Confirmed SECURITY CONDITION or threat.

occurred.

Hostile Action Emergency Action Level (EAL): Emergency Action Level (EAL):

1. A HOSTILE ACTION is occurring or has 1. Notification of a credible security threat directed occurred as reported by the Security Shift at the site Supervisor.

OR

2. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.

PD-HA3 Other conditions exist which in the judgment PD-HU3 Other conditions exist which in the judgment of the Emergency Director warrant of the Emergency Director warrant declaration of an ALERT. declaration of an UNUSUAL EVENT.

Emergency Director Judgment Emergency Action Level (EAL): Emergency Action Level (EAL):

Other conditions exist which, in the judgment of the Other conditions exist which in the judgment of the Emergency Director, indicate that events are in Emergency Director indicate that events are in progress progress or have occurred which involve an actual or or have occurred which indicate a potential degradation potential substantial degradation of the level of safety of the level of safety of the facility or indicate a security of the facility or a security event that involves probable threat to facility protection has been initiated. No life-threatening risk to site personnel or damage to site releases of radioactive material requiring offsite equipment because of HOSTILE ACTION. Any response or monitoring are expected unless further releases are expected to be limited to small fractions of degradation of equipment required for spent fuel cooling the EPA Protective Action Guideline exposure levels. occurs.

Emergency Director Judgment Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 15 of 23 ATTACHMENT 1 Table PD-1: Recognition Category "PD" and E Initiating Condition Matrix ALERT UNUSUAL EVENT ISFSI Malfunction E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

Emergency Action Level (EAL):

1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than EITHER of the following:

60 mrem/hr (gamma + neutron) on the top of the OVERPACK OR ISFSI 600 mrem/hr (gamma + neutron) on the side of the OVERPACK, excluding inlet and outlet ducts Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 16 of 23 ATTACHMENT 2 - EAL BASIS Recognition Category PD EAL Basis Recognition Category PD provides a stand-alone set of ICs/EALs for a Permanently Defueled nuclear facility to consider for use in developing a site-specific emergency classification scheme. For development, it was assumed that the plant had operated under a 10 CFR Part 50 license and that the operating company has permanently ceased plant operations. Further, the company intends to store the spent fuel within the plant for some period of time.

PNPS received NRC approval for exemptions from specific emergency planning requirements. These exemptions reflect the lowered radiological source term and risks associated with spent fuel pool storage relative to reactor at-power operation.

Subsequently all spent fuel has been removed from the Spent Fuel Pool and located within the ISFSI. Source terms and accident analyses associated with plausible accidents are documented in the ISFSI Final Safety Analysis Report (FSAR), and site Decommissioning Safety Analysis Report (DSAR). As a result, each licensee will need to develop a site-specific emergency classification scheme using the NRC-approved exemptions, revised source terms, and revised accident analyses.

Recognition Category PD uses the same ECLs as operating reactors; however, the source term and accident analyses limit the ECLs to an UNUSUAL EVENT and ALERT.

The UNUSUAL EVENT ICs provide for an increased awareness of abnormal conditions while the ALERT ICs are specific to actual or potential impacts to spent fuel. The source terms and release motive forces associated with a permanently defueled facility would not be sufficient to require declaration of a Site Area Emergency or General Emergency.

A permanently defueled facility where all fuel has been located to the ISFSI is essentially a spent fuel storage facility. The ISFSI relies on passive decay heat removal and passive shielding further reducing the potential for events.

In NEI 99-01, Rev. 6, appropriate ICs and EALs from Recognition Category H was modified and included in Recognition Category PD to address a spectrum of the events that may affect an ISFSI.

Recognition Category E EAL Basis Recognition Category E provides a set of ICs/EALs for an ISFSI. An 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 cask must escape its packaging and enter the atmosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel. Formal offsite planning is not required because the postulated worst-case accident involving an ISFSI has insignificant consequences to the public health and safety.

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ISFSI Only Emergency Action DPP-PIL-EP-002 0 Levels (EALs) and Technical Use Category:

Bases Reference Use Page 17 of 23 ATTACHMENT 2 - EAL BASIS An 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.

This includes classification based on a loaded fuel storage cask confinement boundary loss leading to the degradation of the fuel during storage or posing an operational safety problem with respect to its removal from storage.

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ISFSI Only Emergency Action DPP-PIL-EP-002 0 Levels (EALs) and Technical Use Category:

Bases Reference Use Page 18 of 23 ATTACHMENT 2 - EAL BASIS PD-HA1 Initiating Condition:

HOSTILE ACTION is occurring or has occurred.

Emergency Action Level (EAL):

1. A HOSTILE ACTION is occurring or has occurred as reported by the Security Shift Supervisor.

Basis:

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

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

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

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

EAL #1 Basis This EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the facility PROTECTED AREA.

Basis Reference(s):

1. NEI 99-01 Rev 6, PD-HA1

2. Station Security Plan Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 19 of 23 ATTACHMENT 2 - EAL BASIS PD-HU1 Initiating Condition:

Confirmed SECURITY CONDITION or threat.

Emergency Action Level (EAL):

1. Notification of a credible security threat directed at the site.

OR

2. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.

Basis:

This IC addresses events that pose a threat to facility personnel or ISFSI, and thus represent a potential degradation in the level of facility safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs PD-HA1.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

EAL #1 Basis Addresses the receipt of a credible security threat.

EAL #2 Basis References Security Force because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.

Escalation of the emergency classification level would be via IC PD-HA1.

Basis Reference(s):

1. NEI 99-01 Rev 6, PD-HU1

2. Station Security Plan Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 20 of 23 ATTACHMENT 2 - EAL BASIS PD-HA3 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT.

Emergency Action Level (EAL):

1. Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the facility 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 Protective Action Guideline exposure levels.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an ALERT.

Basis Reference(s):

1. NEI 99-01, Rev 6, PD-HA3 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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Bases Reference Use Page 21 of 23 ATTACHMENT 2 - EAL BASIS PD-HU3 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT.

Emergency Action Level (EAL):

1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the facility 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 equipment required for spent fuel cooling occurs.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENT.

Basis Reference(s):

1. NEI 99-01, Rev 6, PD-HU3 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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ISFSI Only Emergency Action DPP-PIL-EP-002 0 Levels (EALs) and Technical Use Category:

Bases Reference Use Page 22 of 23 ATTACHMENT 2 - EAL BASIS E-HU1 Initiating Condition Damage to a loaded cask CONFINEMENT BOUNDARY.

Emergency Action Level (EAL):

1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than EITHER of the following:

• 60 mrem/hr (gamma + neutron) on the top of the OVERPACK OR

• 600 mrem/hr (gamma + neutron) on the side of the OVERPACK, excluding inlet and outlet ducts PNPS Basis:

CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.

This IC 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 technical specification multiple of 2 times, which is also used in Recognition Category A IC AU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this 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.

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Bases Reference Use Page 23 of 23 ATTACHMENT 2 - EAL BASIS E-HU1 (cont)

While multiple loading arrangements may exist at any one time, the administrative controls regarding on-contact radiation readings are consistent for all loading arrangements at PNPS. On-contact radiation readings are defined as 30 mrem/hr on the top of the overpack, and 300 mrem/hr on the sides of the overpack, excluding near the inlet and outlet ducts per the cask system technical specifications (Ref. 1). The thresholds in this EAL incorporate the two times multiple described above.

Figure E-1 illustrates the HI-STORM 100 Overpack.

Security-related events for ISFSIs are covered under ICs HU1 and HA1.

Basis Reference(s):

1. Technical Specifications for the HI-STORM 100 Cask System, Administrative Control 5.7.4 Figure E-1: HI-STORM 100 This diagram is also applicable for the MPC-68 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful