ML103260157

Report of Emergency Plan Change

ML103260157
Person / Time
Site:	Rancho Seco, 07200011
Issue date:	11/11/2010
From:	Ronningen E Sacramento Municipal Utility District (SMUD)
To:	John Hickman, Staab C Document Control Desk, NRC/NMSS/SFPO
References
DPG 10-229
Download: ML103260157 (39)

Text

QsMUE SACRAMENTO MUNICIPAL UTILITY DISTRICT P The Power To Do More.

P.O. Box 15830, Sacramento, CA 95852-1830; 1-888-742-SMUD (7683)

DPG 10-229 November 11, 2010 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Director, Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 Docket No. 72-11 Rancho Seco Independent Spent Fuel Storage Installation License No. SNM-2510 REPORT OF EMERGENCY PLAN CHANGE Attention: John Hickman and Christopher Staab In accordance with 10 CFR 50.54(q), 10 CFR 50.4(b)(5)(ii), 10 CFR 72.44(f), and 10 CFR 72.4 we are informing the NRC of Change 6, Revision I to our Emergency Plan.

This revision results from organizational changes that have occurred in transitioning from a proprietary to a contract Security force. SMUD Security remains posted at the Primary Alarm Station but Contract Security is now posted at Rancho Seco. This has established a 24/7 Security Shift Supervisor (contract) at Rancho Seco with the SMUD Security Operations Supervisor remaining on-shift at the Primary Alarm Station. Because a Supervisor is now posted 24/7 at the facility, the responsibility for implementing the emergency plan and assuming the Emergency Coordinator duties has been transferred from the ISFSI Supervisor/Technician to the on-shift Security Supervisor. In addition, because a Supervisor is always on-shift at the facility, the on-call Emergency Coordinator position has been eliminated. This organizational change is consistent with the contract security organization that will assume the responsibilities of the Independent Spent Fuel Storage Installation (ISFSI) Supervisor/Technician during the activation of the emergency plan.

RANCHO SECO NUCLEAR PLANT

• 14440 Twin Cities Road, Herald,CA 95638-9799; (209) 333-2935

J. Hickman & C. Staab DPG 10-229 Our 10 CFR 50.54(q) / 72.44(f) evaluation determined that the changes made in Emergency Plan, Change 6, Revision 1 do not decrease the effectiveness of the plan. Therefore, these changes can be made without prior NRC approval.

If you, or members of your staff, have questions requiring additional information or clarification, please contact me at (916) 732-4817.

Sincerely, Einar Ronningen Superintendent, Rancho Seco Assets Cc: NRC Region IV

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 1 of 37 LEAD DEPARTMENT EFFECTIVE DATE:

SITE SUPERINTENDENT 10/01/2010 REVISION

SUMMARY

1. This revision transfers responsibility of implementing the emergency plan and assuming the Emergency Coordinator duties from the ISFSI Supervisor/Technician to the on-shift Security Supervisor.

2. Amended the augmented Emergency Response Organization to remove references to specific positions augmenting the response, in favor of using the Emergency Preparedness On-call Duty Officer to coordinate internal SMUD resources and external agencies. This change brings in-line this plan with other Emergency Plans utilized by the District.

3. Added a definition for Security Supervisor, referencing role as the Emergency Coordinator and that this person may be an employee or contractor.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 2 of 37 TABLE OF CONTENTS SECTION PAGE SECTION 1: INTRODUCTION 5 1.1 Scope 5 1.2 Regulatory Requirements 6 1.3 State of California Nuclear Emergency Planning Requirements 6 1.4 Hazardous Chemicals - Right to Know 6 1.5 Site and Near Site description 6 1.6 ISFSI Description 7 1.7 Related Plans, Programs and Procedures 7 1.8 Governmental Agencies 8 Figure 1-1 Emergency Planning Zones 9 Figure 1-2 Rancho Seco Near Site 10 SECTION 2: TYPES OF ACCIDENTS 11 2.1 lOS Building (10 CFR 50) Accidents 11 2.2 ISFSI (10 CFR 72) Accidents 12 2.3 Detecting Accidents 14 SECTION 3: EMERGENCY CLASSIFICATION OVERVIEW 15 3.1 Emergency Classification System 15 Table: 3-1 (10CFR 50 Events) EAL Summary - Unusual Event 17 Table: 3-2 (10 CFR 72 Events) EAL - ISFSI Alert 17 SECTION 4: ORGANIZATIONAL CONTROL OF EMERGENCIES 18 4.1 Scope 18 4.2 Normal District Organization 18 4.3 Emergency Organization 18 4.4 (10 CFR 50) Reentry and Recovery 22 4.5 (10 CFR 72) ISFSI Closeout and Restoration Activities 22 4.6 Support Services 23 Figure 4-1 Rancho Seco Organization 25 Figure 4-2 Coordinated Emergency Response Structure 26 SECTION 5: EMERGENCY MEASURES 27 5.1 Scope 27 5.2 Emergency Notifications 27 5.3 Radiation Monitoring 27 5.4 Protective Actions 27 5.5 Reports 29

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 3 of 37 TABLE OF CONTENTS SECTION PAGE SECTION 6: EMERGENCY FACILITIES AND EQUIPMENT 30 6.1 Scope 30 6.2 Onsite Emergency Response Facilities and Equipment 30 6.3 Offsite Emergency Response Facilities 30 6.4 Onsite Warning Systems 31 6.5 Miscellaneous Monitoring Systems 31 SECTION 7: MAINTAINING EMERGENCY PREPAREDNESS 32 7.1 Scope 32 7.2 Training 32 7.3 Drills and Exercises 32 7.4 Review and Revision of Plans and Procedures 34 7.5 Audits 34 7.6 Emergency Preparedness Surveillance Program 34 7.7 Updates of Telephone Lists, Emergency Assignments and Support Agreements 35 SECTION 8: REFERENCES, DEFINITIONS AND ACRONYMS 36 8.1 Scope 36 8.2 References 36 8.3 Definitions 37 8.4 Acronyms 39

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 4 of 37

1.0 INTRODUCTION

This document describes Sacramento Municipal Utility District's (District's) plan for responding to emergencies that may occur at Rancho Seco while the site is in the long-term storage mode and the used fuel is in dry storage at the Independent Spent Fuel Storage Installation (ISFSI)and the greater than Class C waste (GTCC) is stored in the Rancho Seco Interim Onsite Storage Building (IOSB).

This Emergency Plan includes emergency response for the IOSB and ISFSI. The following indicates applicability.

Sections of the Plan that are applicable to the IOSB only are indicated by (10 CFR

50) at the beginning of the section.

Sections of the Plan that are applicable to the ISFSI are indicated by (10 CFR 72) at the beginning of the section.

Sections with no indication of (10 CFR 50) or (10 CFR 72) are applicable to both the IOSB and the ISFSI.

1.1 SCOPE This plan outlines response actions necessary to safeguard site personnel and equipment in the event an emergency involves, or potentially involves, the release of radioactive material or creates a site wide personnel safety hazard during activities and emergencies that may occur at Rancho Seco ISFSI or IOSB.

It is the District's policy to maintain all radiation exposure as low as reasonably achievable (ALARA). This concept applies to occupationally exposed personnel and to the general public. The Rancho Seco Emergency Plan has incorporated ALARA practices, and is written to deal with emergency conditions where ALARA concerns could be greater than normal.

Major topics of the plan include:

• Facility and near site description.

• Types and detection of accidents.

• Classification system for emergency events.

• Organizational response to emergencies.

• Assessment and mitigating actions.

• Notification procedures.

• Offsite response organization functions, notification and coordination.

• Emergency facilities and equipment.

" Training drills and exercises.

• Maintaining emergency preparedness.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 5 of 37 1.2 REGULATORY REQUIREMENTS This Plan meets the requirements established by, and describe in, the following parts and sections of the Code of Federal Regulations:

1.2.1 (10 CFR 50) Domestic Licensing of Production and Utilization Facilities, Section 47(b), Section 54(q), and Appendix E, as modified by exemptions granted by the NRC, to Rancho Seco Nuclear Generating Station. The exemptions were granted in USNRC letter dated February 22, 1991, to Mr. Dan Keuter, AGM, Nuclear, from Dennis M. Crutchfield, Director, Division of Advanced Reactors and Special Projects, Office of Nuclear Reactor Regulation.

1.2.2 (10 CFR 72) "Licensing Requirements for the Independent storage of Spent Nuclear Fuel and High-Level Radioactive Waste Storage", Section 32(a),

"Emergency Planning".

1.3 STATE OF CALIFORNIA NUCLEAR EMERGENCY PLANNING REQUIREMENTS California Health And Safety Code, Chapter 4, Part 9, Division 104, §114650-114685, The Radiation Protection Act of 1999, requires joint Utility, State and local government emergency planning for plume and ingestion pathways associated with nuclear power plants with a generating capacity of 50 megawatts or more.

Rancho Seco is in the long-term storage mode with spent fuel in dry storage at the ISFSI.

The generating capacity of Rancho Seco does not meet the 50-megawatt criteria established by the State of California. Therefore, Rancho Seco is not required to meet the requirements of The Radiation Protection Act of 1999.

1.4 HAZARDOUS CHEMICALS - RIGHT TO KNOW Rancho Seco submits a Business Plan to Sacramento County Environmental Management Department annually. The submittal includes hazardous material information specific to Rancho Seco. The Business Plan is available for use during emergency response activities. The Business Plan satisfies the requirements of the Emergency Planning and Community Right-to-Know Act of 1986, Title Ill, Pub. L.99-949, with respect to hazardous materials.

1.5 SITE AND NEAR SITE DESCRIPTION Rancho Seco is located in Sacramento County in the State of California, 25 miles southeast of the City of Sacramento, and 26 miles northeast of the City of Stockton.

The site occupies approximately 87 acres of the District owned 2480 acres, which is flat to rolling terrain. The Sierra Nevada Mountain Range is located to the east, with the Pacific Coast Range to the west. Rancho Seco is approximately 26 miles north-northeast of Stockton and 25 miles southeast of Sacramento, the two largest cities within a 50-mile radius of the site. The nearest population center of 25,000 or more is the city of Lodi, which is about 17 miles southwest of the site. State Route 104 runs north of the site in an east-west direction. Route 104 connects with U.S. Route 99 and Interstate 5 to the west, and

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 6 of 37 State Routes 88 and 12 to the east.

The area near the site is sparsely populated and is used primarily as grazing land and grape vineyards. SMUD also maintains the Cosumnes Power Plant, a gas fired, 500-megawatt facility immediately south of Rancho Seco. The only public use facility within a 5-mile radius of the site is the Rancho Seco Reservoir and Recreation Area, which is located approximately 1 mile to the southeast of the site, and is within the land owned by the District.

The climate near Rancho Seco is typical of the central valley of California. No indication of geological faulting is present at the site.

(10 CFR 50) The Emergency Planning Zone for Rancho Seco is the fenced around the Interim Onsite Storage Building. Any potential radiological releases are not expected to exceed the State of California Protective Action Guidelines, or the U.S. Environmental Protection Agency (EPA) protective action guide (PAG) exposures as detailed in EPA-400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents".

Maps of the site and near site areas are shown in Figures 1-1 and 1-2.

1.6 (10 CFR 72) ISFSI DESCRIPTION The Rancho Seco ISFSI design provides temporary dry storage for 100% of Rancho Seco's spent fuel. It is designed with safety features that eliminate the need for an operable spent fuel pool to recover from unlikely accident scenarios. The spent fuel will be stored in this manner until the Department of Energy accepts it.

The ISFSI consists if a concrete slab approximately 225 feet long, 170 feet wide, and 2 feet thick at the location of the Horizontal Storage Modules (HSM). There are 22 HSMs on the concrete slab. A security fence surrounds the slab.

The ISFSI Protected Area is the area bounded by the double fence surrounding the concrete slab. The ISFSI Emergency Planning Zone is the nuisance fencing surrounding the ISFSI at approximately 100 meters in all four directions.

1.7 RELATED PLANS, PROGRAMS AND PROCEDURES 1.8.1 The Rancho Seco Emergency Plan and Emergency Plan Implementing Procedures (EPIPs) have been coordinated with the ISFSI Physical Protection Plans to ensure site personnel safety during a security event.

1.8.2 Provisions for radiological control at Rancho Seco are described in the Radiation Control Manual.

1.8.3 Initial mitigating actions for most emergency situations are provided by departmental response procedures. Departmental response procedures work in conjunction with the Emergency Plan Implementing Procedures (EPIPs).

1.8.4 Response to control and cleanup of chemical and hazardous wastes are in accordance with Rancho Seco administrative and departmental procedures.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 7 of 37 1.8 GOVERNMENTAL AGENCIES The following governmental agencies interface with Rancho Seco in the emergency planning process:

1.8.1 Sacramento County Office of Emergency Operations (OEO)

The Sacramento County OEO is the lead emergency response agency within the County and has the role of coordinating emergency activities within Sacramento County as the Sacramento Operational Area.

For significant emergencies the Sacramento Operational Area Emergency Operations Center (EOC) may be activated. Emergency notifications to Sacramento County OEO are conducted as specified in Section 5 of this Plan.

1.8.2 California Emergency Management Agency (Cal-EMA)

Cal-EMA has authority and responsibility for planning and coordination of the State response to nuclear power plant emergencies.

Responsibilities of Cal-EMA include providing assistance to local governments by alerting state agencies, coordinating state resources, requesting and coordinating federal assistance identified in the Federal Radiological Emergency Response Plan, and coordinating state radiological monitoring.

Under the Standardized Emergency Management System (SEMS), an emergency may warrant activation of the Regional Emergency Operations Center (REOC) and/or the State Emergency Operations Center (SEOC). Emergency notifications to the State Operations Center are conducted as specified in Section 5 of this Plan.

1.8.3 California Department of Health Services California Department of Health Services has overall responsibility for the state's technical assessment of accidents involving the release of radioactive material from nuclear power plants to the environment within the State. State OES coordinates the activities of California Department of Health Services.

1.8.4 United States Nuclear Regulatory Commission (NRC)

During a radiological emergency the NRC ensures that the public health and safety are protected and may provide technical assistance onsite and assessment information and recommendations to state and local officials. Emergency notifications to the NRC Operations Center are conducted as specified in Section 5 of this Plan.

1.8.5 Sacramento County Sheriff's Department (SCSD)

SCSD is the primary local law enforcement agency (LLEA) designated to respond and assist with security incidents at Rancho Seco and the ISFSI.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 8 of 37 IOSB Area Boundary (10CFR50)

Emergency Planning Zone (EPZ)

(Chain Link Fenced Area)

ISFSI Controlled Area Boundary (10CFR72)

Emergency Planning Zone (EPZ)

(Chain-Link Fenced Area) t~ ti 0 ~S 400 j.1

~M6 341 wv0, 3kSh Its

&. GooaiN Towm

• 22 9ý Sowsidry$Jw P*Ie S A" a 0A of Ser4o

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 9 of 37 FIGUREC -N2AR RANCHO SECO - NEAR SITE I ia2 .0 I 112 C I ~s1l.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 10 of 37 2.0 TYPES OF ACCIDENTS The consequences of potential accidents were considered in the development of the emergency preparedness program for the Rancho Seco. These potential accidents form the basis for the response described in this plan.

2.1 IOSB (10 CFR 50) ACCIDENTS 2.1.1 ANALYSIS OF POSTULATED ACCIDENTS The accidents that might occur at Rancho Seco while the facility is in the long-term storage mode have been analyzed for their severity of consequences and probability of occurrence. The analysis of these accidents are contained in the Defueled Safety Analysis Report (DSAR) 2.1.2 ACCIDENTS CONSIDERED CREDIBLE DURING DECOMMISSIONING Rancho Seco DSAR Section 14.2.2, Accidents During DECON, states,"The accidents discussed in NUREG/CR-0130, Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station, associated with immediate dismantlement would be applicable during Decon at Rancho Seco. However, the potential consequences of these accidents would be less because of a reduction in the Rancho Seco radionuclide inventory due to decontamination efforts made before Decon, prior radioactive waste shipments and radioactive decay. Therefore, the potential DECON accidents at Rancho Seco are bounded by the accident evaluation specified in NUREG/CR-01 30".

2.1.2.1 DSAR, Section 14.2.2, Accidents During Decon Operational accidents during DECON could result from equipment failure, human error, and service conditions. Operational accidents during Decon are categorized as:

2.1.2.2 Radioactive waste transportation accidents Off-site Radioactive waste transportation is conducted in accordance with Department of Transportation (DOT) regulations and is beyond the scope of this Emergency Plan.

2.1.2.3 Explosions and/or fires associated with explosive/combustible materials Responses to explosions and/or fires are included in District emergency procedures.

2.1.2.4 Loss of Contamination Control As long-term storage progresses, fire loads and contaminated water will be reduced thereby reducing the potential for loss of contamination control.

Response to loss of contamination control is in accordance with the Rancho Seco Radiation Control Program and is not of the magnitude that would require initiating the Emergency Plan.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 11 of 37 2.1.2.5 Natural phenomena Response to natural phenomena is included as an Emergency Action Level (EAL) for the ISFSI and is described in Section 3 of this Plan.

2.1.2.6 Human caused events external to Rancho Seco If a human caused event external to Rancho Seco occurs and personnel or facilities within the Rancho Seco Industrial Area are affected, appropriate actions will be taken to protect personnel and facilities.

No emergency response is expected for human caused event external to Rancho Seco during long-term storage.

2.2 ISFSI (10 CFR 72) ACCIDENTS 2.2.1 ISFSI SAR Postulated Accidents 2.2.1.1 Dry Shielded Canister (DSC) Leakage Vol. I, Section 8.2.2 DSC Leakage, analyzes a DSC leakage accident.

The analysis concludes that no credible condition can breach the DCS shell or the double seal welds at each end of the DSC. Therefore, an EAL on DSC leakage is not needed.

2.2.1.2 Accident Pressurization of a DSC Vol. I, Section 8.2.3, Accident Pressurization, analyzes an accident pressurization of the DSC. The analysis of the DSCs for the accident pressurization load shows that no significant deformations occur to the DSC which could prevent retrieval from the Horizontal Storage Module (HSM) or, inhibit normal transport or on-site transfer operation. In addition, the DSC pressure boundaries are analyzed to withstand the accident internal pressure to prevent release of any radioactive materials to the environment. Therefore, an EAL for Accident Pressurization is not necessary.

2.2.1.3 Earthquake Vol. I, Section 8.2.4, Vol. I1.Section 8.3.2 and Vol. II1.Section 8.3.2, analyze an earthquake event and all three sections state that overturning due to the design basis seismic event will not occur. Therefore an Earthquake EAL specific to the ISFSI, HSM or DSC is not necessary.

2.2.1.4 Fire Vol. I, Section 8.2.5 analyzes the effect of a fire involving 300 gallons of diesel fuel and states that direct engulfment of the HSM or DSC during storage in the HSM is not a credible event. Therefore, a Fire EAL for storage of spent fuel in the HSMs is not necessary.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 12 of 37 2.2.1.5 Tornado winds and tornado generated missiles Vol. II,Section 8.3.1 and Vol. II1., Section 8.3.1 analyze tornado and tornado generated missiles and state that the cask is designed to withstand the tornado wind and tornado missile loads without damage to the containment structure. Therefore, an EAL specific to the ISFSI, HSM or DSC is not necessary.

2.2.1.6. Flood Vol. II.Section 8.3.3 and Vol. II1., Section 8.3.3 analyze design basis flood and state that no corrective actions are required in the event of a flood.

Therefore, an EAL for a flood is not required.

2.2.1.7 Lightning effects Vol. II., Section 8.3.4 and Vol. II1., Section 8.3.5 analyze lightening events and states the likelihood of lightning striking the HSM and causing an off-normal condition is not considered to be a credible event. Also there are no radiological consequences. Therefore, an EAL specific to the ISFSI, HSM or DSC is not necessary.

2.2.1.8 Complete blockage of HSM Air inlet and outlet vents Vol. II,Section 8.3.5, analyzes the consequences of complete blockage of HSM air inlet and outlet vents and causing an off-normal condition is not considered to be a credible event. Therefore, an EAL specific to the blockage of HSM air inlet and outlet vents is not necessary.

2.2.1.9 Reduced HSM Air Inlet and Outlet Shielding Vol. II., Section 8.3.6, analyzes the consequences of Reduced HSM Air Inlet and Outlet Shielding. The analysis shows that there are no radiological or thermal consequences. An EAL for reduced HSM air inlet and outlet shielding is not needed 2.2.1.10 Snow and ice loads Vol. II., Section 8.3.7, analyses the consequences of snow and ice loads.

The SAR states that snow and ice loads are not required for Rancho Seco Site. Therefore, an EAL for snow and ice loads is not required.

2.2.1.11 Radiological Sabotage The Rancho Seco ISFSI Technical Specifications, Section 5.5.8, Security, states: "Based on source term calculations for failure of all fuel rods within one DSC, as an act of sabotage could not cause a radiological release that would exceed the limits in 10 CFR 100. Therefore, radiological sabotage as defined in 10 CFR 73.2 is not a credible event".

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 13 of 37 2.2.1.12 Accidental Drop Drop of the MP-187 Cask, containing a DSC, during transfer operations has been evaluated using a bounding 80 inch drop. (Ref. Volume I, Section 8.2.1, ISFSI SAR). DSC integrity is not compromised by the bounding drop. Therefore, an EAL specific to the ISFSI is not necessary.

However, conservatively, an EAL for a severe man-made incident is included in the Alert EALs as described in Section 3 of the Plan.

2.3 DETECTING ACCIDENTS 2.3.1 Due to the relative passive status of the facility, detection of abnormal conditions or accidents occurs early by workers involved in and around the tasks being performed, based on visual, audible, and other sensory observations.

Site personnel notify telephone extension 4311 of abnormal or unsafe conditions.

This phone is answered at the Secondary Alarm Station. All personnel who are granted unescorted access authorization within either Emergency Planning Zone receive General Employee Training, which stresses telephoning 4311 to report any emergency or abnormal conditions.

2.3.2 Fixed and portable instrumentation may be used to detect abnormal conditions.

2.3.3 On-shift personnel are made aware of abnormal conditions or of other dangers during long-term storage activities, by the Plant Information Computer System (PICS) indications and annunciators.

2.3.4 (10 CFR 72) The Rancho Seco ISFSI Technical specifications, Section 5.5.2, Radiological Monitoring Programs, states: "Operation of the Rancho Seco ISFSI will not create any radioactive materials or results in any credible liquid or gaseous effluent release. Accordingly, no (effluent) monitoring or alarms are required (at the ISFSI)". Monitoring Badges will be utilized for monitoring radiation at the ISFSI as part of the Radiological Environmental Monitoring Program (REMP).

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 14 of 37 3.0 EMERGENCY CLASSIFICATION OVERVIEW The Emergency Plan and Emergency Plan Implementing Procedures (EPIPs) have been established to respond to emergencies at Rancho Seco. Actions for classifying emergencies and responding to the emergency conditions through pre-designated actions are conducted in accordance with EPIP-01, "Emergency Actions".

3.1 EMERGENCY CLASSIFICATION SYSTEM 3.1.1 Initiating Conditions Generic abnormal site events or conditions, which form the basis for initiating specific Emergency Action Levels.

3.1.2 Emergency Action Levels (EALs)

Site specific system, effluent or personnel safety off-normal parameter values that, if exceeded, will initiate an emergency classification.

The accidents described in Section 2.0, "Types of Accidents", of this plan, are used as a basis for specific EALs.

3.1.3 (10 CFR 50) Long-term Storage Classification Level:

Unusual Event An incident indicated by abnormal conditions where the safe storage and containment of radiobiological materials has been compromised. An Unusual Event may involve or potentially involve a low-level release of radioactive material to the environment that requires monitoring and/or assistance from external responders.

An Unusual Event could require cessation of normal activities and require greater than normal attention to protection of site personnel.

The primary purpose for declaration of an Unusual Event is to notify internal staff, emergency responders and regulatory agencies that an atypical situation exists.

Declaration of an Unusual Event brings SMUD and external agencies to a state of readiness and provides a systematic handling of incident information and decision-making to mitigate the incident.

A summary of Unusual Events is listed in Table 3-1. The Summary of EALs is generic, with specific threshold values for the EALs listed in EPIP-01, "Emergency Actions", Attachment 2, "Classification of Emergencies".

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 15 of 37 3.1.4 (10 CFR 72) ISFSI Classification Level:

ISFSI Alert An incident indicated by abnormal or accident conditions associated with the Rancho Seco ISFSI.

An ISFSI Alert is an event that affects the integrity of ISFSI structures or creates a safety hazard to personnel, or a security event that has serious consequences.

The primary purpose for declaration of an ISFSI Alert is to notify internal staff, emergency responders and regulatory agencies that an atypical situation exists.

Declaration of an ISFSI Alert brings SMUD and external agencies to a state of readiness and provides a systematic handling of incident information and decision-making to mitigate the incident.

The EALs for an ISFSI Alert are listed in Table 3-3.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 16 of 37 TABLE 3-1 (10CFR 50 EVENTS)

EAL

SUMMARY

- UNUSUAL EVENT

1. Transportation of a radiologically contaminated injured individual from on-site to the hospital.

2. Communications with security supervision has confirmed the seriousness or credibility of any of the following events related to the storage of materials within the IOSB:

0 Actual or probable sabotage within the IOSB 0 Attempted theft of nuclear material from the IOSB

3. or Emergency Coordinator's discretion for other conditions within the IOSB that require the assistance of external emergency responders to evaluate and mitigate the incident to safeguard the public and environment.

TABLE 3-2 (10 CFR 72 EVENTS)

EAL - ISFSI ALERT

1. A severe man-made incident or natural phenomenon, which affects the integrity of ISFSI structures or creates a significant personnel safety hazard. (For example: explosions or aircraft crash.)

2. Communications with security supervision has confirmed the seriousness or credibility of any of the following events in accordance with the Rancho Seco ISFSI Physical Protection Plan:

• Bomb, attack or terrorist threat made against Rancho Seco

• Internal or external civil disturbance related to the storage of nuclear materials

• Actual or probable sabotage

• Attempted theft of special nuclear material

3. Emergency Coordinator's discretion for other conditions within the ISFSI that require the assistance of external emergency responders to evaluate and mitigate the incident to safeguard the public and environment.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 17 of 37 4.0 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.1 SCOPE This section describes the Emergency Response Organization (ERO), typical staffing, basic duties, responsibilities, and support services during response to an emergency.

4.2 NORMAL DISTRICT ORGANIZATION The overall District organization is shown in the Defueled Safety Analysis Report (DSAR).

The General Manager administers the affairs of the District under the policies of the elected Board of Directors. Upon request from the Emergency Coordinator, the General Manager directs District resources to provide support and outside assistance. The Site Superintendent, Rancho Seco Assets is responsible for the activities at Rancho Seco and provides policy oversight to the Emergency Coordinators.

4.2.1 Rancho Seco Shift Staffing 4.2.1.1 Security Supervisor This position is the senior Rancho Seco person on-shift and their responsibilities include:

• ISFSI and IOSB security oversight

• Supervision of on-site Security Officers

• Rancho Seco Emergency Plan implementation 4.2.1.2 On-shift Security Officers The on-shift Security Officers report to the Security Supervisor and are responsible for maintaining onsite security in accordance with the Rancho Seco ISFSI Physical Protection Plan.

4.3 EMERGENCY ORGANIZATION 4.3.1 The Emergency Response Organization (ERO) consists of on-shift staff, augmented responders, District resources, and external emergency responders.

This organizational structure is described below. The ERO is shown on Figure 4-1.

4.3.1.1 On-shift Emergency Response Organization

• On-shift Security Supervisor

• On-shift Security Officer(s).

• Primary Alarm Station Dispatcher at Headquarters.

• Other onsite personnel may be enlisted to assist in responding to the event.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 18 of 37 4.3.1.2 Augmented Emergency Response The augmented ERO staff is notified of the emergency to support and assist the on-shift staff in the response to the activation of the Rancho Seco Emergency Plan. This coordination is available on-shift or on-call to respond and coordinate the Rancho Seco response with internal SMUD resources and external agencies.

The SMUD Emergency Preparedness group maintains an on-call duty officer to coordinate emergency and disaster response for the District.

When an emergency is declared, the on-call duty officer fulfills the following function:

• Offsite A-gency Liaison- responsible for gathering and interpreting information related to the emergency, notification and communications with outside agencies.

4.3.1.3 District Emergency Operations Center (EOC):

The District Emergency Operations Center provides overall direction, support and coordination on-behalf of the SMUD General Manager.

The District EOC consists of staff from throughout the organization to evaluate, communicate, and mitigate events utilizing the California Standardized Emergency Management System (SEMS) and National Incident Management System (NIMS).

The District EOC is activated once an emergency has been declared, remaining activated until the emergency is closed out.

4.3.1.4 Local Offsite Agency Assistance:

The Sacramento County Sheriff's Department provides the primary local law enforcement response for the area, assuming the role of law enforcement incident commander for criminal events. Through their cooperative and mutual aid agreements, the Sheriff's office is supported by numerous other law enforcement agencies at the local, state, and federal level.

The Herald Fire Protection District provides the primary fire and rescue response for the area, assuming the role of fire incident commander for fire department related events. Through mutual aid agreements, the Herald Fire Protection District is supported by numerous other fire agencies at the local, state, and federal level.

The Cosumnes Community Services District provides the primary medical and hazardous materials team response for the area, assuming a critical role in emergency medical and hazardous materials related events. Through mutual aid agreements, the Cosumnes Community Services District is supported by numerous other fire, ambulance and hazardous materials resources at the local, state, and federal level.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 19 of 37 The University of California, Davis Medical Center provides the primary trauma center and radiological response hospital for the area, assuming the patient care duties.

4.3.2 Emergency Coordinator Delegation of Authority The Superintendent, Rancho Seco Assets, as the senior Rancho Seco staff member, serves as the primary Emergency Coordinator for the implementation of the Rancho Seco Emergency Plan.

In the event the Superintendent, Rancho Seco Assets, is unavailable onsite the following delegation of authority determines who assumes the role of Emergency Coordinator from those staff available onsite:

1. On-Shift Security Supervisor,

2. Other trained Emergency Coordinator (See the Emergency Response Telephone Directory for delegation list),

4.3.3 Emergency Coordinator Duties Until relieved by the Superintendent, Rancho Seco Assets:

4.3.3.1 Assume overall control and direction of the incident 4.3.3.2 Classify the incident as an emergency.

4.3.3.3 Request activation of the Augmented ERO.

4.3.3.4 Conduct incident assessment.

4.3.3.5 Initiate mitigation and protective measures.

4.3.3.6 Request offsite emergency response assistance.

4.3.3.7 Direct action to mitigate the consequences of the incident.

4.3.3.8 Assume or delegate additional actions as necessary.

4.3.3.9 Authorize Emergency Exposure Limits and exemptions for emergency workers, as necessary.

4.3.3.10 Initiate Reentry and Recovery activities or Restoration activities, as appropriate.

4.3.3.11 Closeout the emergency 4.3.4 Security Officer(s) Duties Under the direction of the Security Supervisor:

4.3.4.1 Maintain physical security per the District and ISFSI Security Plans.

4.3.4.2 Perform response actions as directed by the Emergency Coordinator with the approval of the Security Supervisor.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 20 of 37 4.3.5 Offsite Agency Liaison Under the direction of the Emergency Coordinator:

4.3.5.1 Acquire and maintain necessary equipment and supplies during the emergency.

4.3.5.2 Assume responsibilities for required notifications and communications to the State of California, Sacramento County and NRC.

4.3.5.3 Maintain a log and record of all emergency related communications.

4.3.5.4 Maintain and open telephone line with the NRC as requested by the NRC.

4.3.5.5 Coordinate and maintain liaison duties with offsite agencies.

4.3.5.6 Maintain and document key information related to the emergency response.

4.3.5.7 Post incident: gather and package all incident documentation and provide to the Superintendent, Ranch Seco Assets.

4.3.6 Security Supervisor Under the direction of the Emergency Coordinator:

4.3.6.1 Maintain physical security per the District and ISFSI Physical Protection Plan.

4.3.6.2 Perform response actions as directed by the Sacramento Sheriff's Department and Emergency Coordinator.

4.3.6.3 Coordinate the security response to the emergency.

4.3.7 Augmented Emergency Response On-call Requirements In order to successfully implement the provisions of the Rancho Seco Emergency Plan, the augmented emergency response must be available and fit for duty to conduct assigned activities under this plan. When serving on-call, the augment ERO must be reachable by the communications mechanism identified in the Emergency Response Telephone Directory, and respond to a declared emergency as follows:

4.3.7.1 Within 30 minutes acknowledge the activation and be capable of carrying duties identified in this plan.

4.3.7.2 Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> respond to the Rancho Seco site, District EOC in Sacramento, or a Command Post in the Herald area, as determined at the time of the incident.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 21 of 37 4.4 (10 CFR 50) REENTRY AND RECOVERY FOR SITE ACTIVITIES Reentry and recovery operations may be required after an emergency, depending on the severity of the emergency. Reentry and Recovery activities are to be conducted in coordination with local, state and federal responders and regulators.

The Emergency Coordinator is responsible for closeout of emergencies, which includes determining if reentry and recovery operations are required.

4.4.1 Reentry Reentry activities are a coordinated and authorized entry into an area that was evacuated during a declared emergency due to personnel or radiological hazards.

The purpose of reentry is to evaluate the conditions of the area. Reentry will be conducted in accordance with the EPIPs.

4.4.2 Recovery Recovery activities may be initiated after a declared emergency has been closed out, and it has been determined that a dedicated organization is necessary to recover from the hazards remaining from an emergency. Recovery operations will be conducted in accordance with EPIPs.

4.5 (10 CFR 72) ISFSI CLOSEOUT AND RESTORATION ACTIVITIES The Emergency Coordinator is responsible for closeout of emergencies, which includes determining if the incident is under control and the consequences have been mitigated.

After closeout, restoration activities are initiated, as required, to return the ISFSI to a safe condition.

ISFSI Closeout and Restoration activities are to be conducted in coordination with local, state and federal responders and regulators.

4.6 SUPPORT SERVICES An emergency will likely warrant the utilization of offsite organizations and agencies. As a result, support service arrangements have been made with specific offsite organizations and agencies to provide aid in the event of an emergency at Rancho Seco.

4.6.1 Local Support services Resources encompass the local, state and federal agencies located in the area.

Under the California Master Mutual Aid Agreement, Rancho Seco has the ability to access these resources for assistance. Local emergency response agencies can be contacted via 9-1-1. Access to area State and federal resources are through the California Emergency Management Agency Warning Center.

The District is also a participant in the Sacramento County Operational Area Agreement as part of the Standardized Emergency Management System and National Incident Management System, providing additional resources as necessary.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 22 of 37 4.6.2 Medical Support 4.6.2.1 Site personnel will call 9-1-1 when helicopter or ambulance and associated Emergency Medical Service assistance is required.

4.6.2.2 Cosumnes Service District (formerly Gait Fire Protection District), located approximately 15 miles southwest of the site, is the primary responder to medical emergencies at Rancho Seco.

4.6.2.3 Site staff will provide radiological information, dosimetry, and escort services to offsite medical assistance personnel upon arrival on site as necessary.

4.6.2.4 Injuries that involve radioactive contamination will be directed to University of California Davis Medical Center (UCD). Although under their accreditation standards, all local hospitals providing basic emergency room care should be equipped to handle a contaminated patient if UCD is unavailable. Transportation may be by helicopter or ambulance.

4.6.2.5 Qualified hospital personnel will provide radiation protection coverage at the hospital whenever a contaminated patient is transported for treatment.

4.6.3 Fire Suppression Support 4.6.3.1 Site personnel will call 9-1-1 when fire suppression support is required.

4.6.3.2 Herald Fire Protection District, located approximately eight miles southwest of the site, is the primary responder to fires at Rancho Seco.

4.6.3.2 Site staff will provide radiological information, dosimetry, and escorts (as needed) to offsite fire suppression personnel upon arrival on site.

4.6.4 Law Enforcement Support 4.6.4.1 Sacramento County Sheriffs Department, FBI, and/or other law enforcement agencies, may be requested to assist Rancho Seco Security in accordance with the Rancho Seco ISFSI Physical Protection Plan.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 23 of 37 FIGURE 4-1 RANCHO SECO ORGANIZATION ON-SHIFT NORMAL OPERATIONS RANCHO SECO EMERGENCY RESPONSE OPERATIONS ORGANIZATION I EMERGENCY COORDINATOR SUPERINTENDENT, RANCHO SECO ASSETS or DELEGATE I

Information Officer On-call From HQ (as needed)

-4 Offsite Agency Liaison U

I I

Security Supervisor Rancho Seco Security I

H l Officer(s) I Other Staff Available On-site

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 24 of 37 FIGURE 4-2 COORDINATED EMERGENCY RESPONSE STRUCTURE I

I FEDERAL RESPONSE STRUCTURE (NRC/DOE)

I........................................... I1 INLAND REGION EOC/

CALIFORNIA SOC U

I I I I U U SACRAMENTO I SMUD GENERAL MANAGER OR DESIGNEE mI n

OPERATIONAL AREA EOC m

• nnnu

a. * .

unuunun. .n..

I SMUD EMERGENCY OPERATIONS CENTER un. .

nn. .nu I. .a Other SMUD Resources m

EMRGNC

• ORDNAO UNIFIED INCIDENT COMMAND Command & Control

............. Coordination & Support

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 25 of 37 5.0 EMERGENCY MEASURES 5.1 SCOPE Emergency measures will be initiated upon classification of an emergency. Initial mitigating response to most events will be in accordance with departmental and District response procedures. The augmented emergency response will be activated as described in Section 4.0.

This section identifies:

5.1.1 Methods and procedures for assessment actions.

5.1.2 Protective actions to minimize radiological exposure.

5.2 EMERGENCY NOTIFICATIONS 5.2.1 Initial, follow-up and closeout emergency notifications will be transmitted to Sacramento County OEO, State Warning Center, and NRC Operations Center.

5.2.2 Notifications must be completed within 60 minutes after the declaration of the emergency classification.

5.2.3 The NRC shall be notified immediately after local jurisdictions, and not later than 60 minutes after declaration of the emergency classification.

5.2.4 Notifications will inform the State, County and NRC of the status of the event, radiological releases and actions being taken. The notification process is described in EPIP-01, "Emergency Actions", Attachment 3, "Emergency Notifications".

5.2.5 Appropriate SMUD personnel will be contacted for all emergency notifications made to outside agencies. SMUD Management, the public information group, and SMUD Distribution Operations are notified to provide support from other SMUD groups.

5.3 RADIOLOGICAL MONITORING During the initial phase of an emergency, on shift personnel will review and monitor radiological conditions as warranted. As needed, augmented personnel will accomplish continued radiological monitoring as they arrive.

5.4 PROTECTIVE ACTIONS Protective actions are emergency measures taken for the purpose of notifying onsite personnel and initiating actions to minimize their exposure to radiological or general safety hazards. Implementation criteria for protective actions are listed in the EPIP-01, "Emergency Actions".

5.4.1 Onsite Protective Actions 5.4.1.1 Onsite notification of an emergency At the declaration of an emergency, a radio system announcement will be

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 26 of 37 broadcast to onsite personnel to notify them of the emergency and any instructions necessary.

5.4.1.2 Site Dismissal during Emergencies A Dismissal is the evacuation process of directing non-emergency response personnel to leave site when their safety is of concern. A Dismissal may be conducted at the discretion of the Emergency Coordinator as a protective or precautionary measure due to existing, or potential emergencies, including: radiological hazards, physical safety hazards, terrorism incident, or a hazardous material release resulting from an emergency event.

Personnel will be Dismissed out the East gate and remain in the parking area for further instructions.

5.4.1.3 Accountability during Emergencies Accountability of onsite personnel must be performed when a Dismissal has been conducted. When accountability is complete, Search and Rescue Teams will be assembled and dispatched to locate any personnel who are identified as missing.

5.4.2 Radiation Exposure Control Normal administrative radiation exposure limits established in RP.312.14, Occupational Radiation Exposure Limits and Extensions will be used for emergency response except as specified below:

5.4.2.1 Radiation Protection Exemptions during emergencies:

If a Radiological Assessment Coordinator is present, Radiation Protection Exemptions may be implemented with the approval of the Emergency Coordinator/Incident Commander for Emergency Response personnel.

These exemptions allow varying from certain aspects of established radiological controls procedures under the direction and control of the Radiological Assessment Coordinator. Radiation Protection Exemptions are implemented as specified in EPIP-01, "Emergency Actions",

Attachment 7, "RP Exemptions".

5.4.2.2 Emergency Exposure Limits The Emergency Coordinator may authorize emergency exposure limits for Emergency Response personnel, in accordance with the EPIP-01, "Emergency Actions", Attachment 8, "Emergency Exposures".

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 27 of 37 5.4.3 Decontamination Skin decontamination supplies are maintained onsite and are readily available.

Decontamination is conducted in accordance with Rancho Seco Radiation Control Manual.

5.4.4 Fire Responses to fires will be performed as described in District procedures.

5.4.5 Security Contingency Response to security contingencies is conducted in accordance with the Rancho Seco Emergency Plan, District Security Procedures, and the Rancho Seco ISFSI Physical Protection Plan. Security response and emergency response are coordinated to protect personnel during response activities.

5.4.6 Medical Response to injuries to personnel onsite that require first aid will be conducted in accordance with departmental response procedures.

5.4.6.1 If the injury involves radioactive contamination, radiation monitoring personnel will be dispatched in accordance with EPIP-01, "Emergency Actions".

5.4.6.2 Emergency medical supplies are available at various locations throughout Rancho Seco for response to medical emergencies.

5.4.6.3 Medical support will be requested from offsite support agencies as specified in District procedures.

5.5 REPORTS A written notification of emergency event closeout will be provided to the State of California and Sacramento County within five working days of emergency closeout.

A written follow-up report must be submitted to NRC within 30 days following an Initial Emergency Notification, as specified in RSAP-0903, External Plant Reports and Posting of Notices.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 28 of 37 6.0 EMERGENCY FACILITIES AND EQUIPMENT 6.1 SCOPE This section describes the onsite facilities, equipment and supplies that are maintained for use during response to an emergency.

6.2 ONSITE EMERGENCY RESPONSE FACILITIES AND EQUIPMENT 6.2.1 Secondary Alarm Station (SAS)

The Secondary Alarm Station (SAS) is located near the ISFSI, and contains communications equipment used for making emergency notifications.

6.2.1.1 Procedure manuals are accessible (as necessary) in the Secondary Alarm Station/Control Room.

Examples include:

• Emergency Plan and Implementing Procedures

• Operating Procedures Manuals 6.2.2 Technical Support Center The Technical Support Center is available for use when an emergency is declared. The TSC is maintained by Emergency Preparedness staff.

6.2.3 Radiation Monitoring Instruments and supplies are located onsite. The equipment is reserved for emergency response use only.

6.2.4 Medical Supplies and Equipment:

6.2.4.1 Medical supplies and equipment for first aid are located throughout the facility and are clearly identified.

6.2.5 Skin Decontamination Supplies 6.2.5.1 Skin decontamination supplies are available and maintained on-site by the Radiation Protection group.

6.3 OFFSITE EMERGENCY RESPONSE FACILITIES 6.3.1 Primary Alarm Station The District maintains a Primary Alarm Station for monitoring and communicating information in support of the Secondary Alarm Station at Rancho Seco.

6.3.2 Emergency Operations Center The District maintains an Emergency Operations Center (EOC) for coordination of District-wide emergencies. This organization is tasked with overall direction and information management for major emergencies in accordance with the Standardized Emergency Management System (SEMS) used in California to direct and coordinate emergencies by participating agencies.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 29 of 37 6.4 ONSITE WARNING SYSTEMS 6.4.1 Emergency Alert Notification A number of other types of communications systems may be utilized to alert site workers. These systems include but are not limited to: portable radios, pagers, portable megaphones, building fire alarms, vehicle public address systems, and/or word-of-mouth notification.

6.5 MISCELLANEOUS MONITORING SYSTEMS 6.5.1 Plant Information Computer System Plant Information Computer System (PICS) displays and annunciates site-monitoring data.

6.5.2 Fire Protection Devices Fire protection at the Rancho Seco facility is provided in accordance with the Rancho Seco Decommissioning Fire Protection Plan.

6.5.3 Seismic Data Seismic data is obtained from State or Federal agencies. .

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 30 of 37 7.0 MAINTAINING EMERGENCY PREPAREDNESS 7.1 SCOPE To assure the maintenance of emergency preparedness, an integrated program has been developed and includes:

• Training, drills and exercises

• Emergency Plan and EPIP reviews and revisions

• Routine Test program

• Biennial audits Maintaining and updating the emergency preparedness program is the responsibility of the General Services Department.

7.2 TRAINING The Emergency Preparedness Group is responsible for developing, scheduling and conducting emergency response training.

7.2.1 General Training All personnel who are granted unescorted access authorization receive initial and annual emergency preparedness overview training in General Employee Training.

The District may also provide training to offsite agencies or support organizations that may be called upon to provide assistance during emergencies.

7.2.2 Emergency Response Organization (ERO) Training Designated ERO personnel receive training specific to their assignments.

The objectives of the training program are:

• To familiarize personnel with the emergency preparedness program.

• To familiarize personnel with their assignments and responsibilities during an emergency.

• To familiarize personnel with the external emergency response process.

7.2.3 First Aid Rancho Seco's First Aid responders are provided first aid and cardio-pulmonary resuscitation (CPR) training, and recertification in accordance with American Red Cross or equivalent requirements.

7.3 DRILLS AND EXERCISES 7.3.1 General The Emergency Preparedness Group is responsible for developing, planning, scheduling and conducting drills and exercises.

Drills are conducted and evaluated in accordance with the EPIP-02, "Emergency Preparedness Training".

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 31 of 37 A critique must be conducted following all required drills. Deficiencies identified must be evaluated and corrected.

The 10 CFR 50 and ISFSI (10 CFR 72) drills and exercises may be conducted in conjunction with each other, if the scenario and objectives are sufficiently comprehensive to be appropriate for both 10 CFR 50 activities and the ISFSI.

7.3.2 Drill and Exercise Objectives.

7.3.2.1 To test the adequacy, effectiveness and content of the Emergency Plan and EPIPs.

7.3.2.2 To test emergency equipment, supplies, and facilities.

7.3.2.3 To test the readiness of emergency response organization personnel, thereby evaluating training effectiveness.

7.3.2.4 To familiarize personnel with their duties, assignments, and equipment under simulated emergency conditions.

7.3.3 Fire Drill (10CFR 50 and 10 CFR 72)

Annually, a fire drill shall be conducted with participation by off-site fire suppression assistance when possible, and shall be conducted in accordance with District procedures.

7.3.4 Medical Drill (10CFR 50 and 10 CFR 72)

Annually, a medical drill shall be conducted involving the simulated radioactive contamination of injured personnel. The Site's First Aid Responders and off-site ambulance service will participate in the drill. When possible, the University of California Davis Medical Center or other appropriate hospital shall participate in the drill. The medical drill includes health physics and radiological monitoring.

7.3.5 Biennial Site Drill (10 CFR 50)

Biennially, a site drill shall be conducted which simulates emergencies affecting some of the principal functional areas of the Rancho Seco's onsite emergency response capabilities. This drill may include health physics, radiological monitoring, Dismissal and Accountability, and may involve off-site agencies.

7.3.6 Biennial Exercise (10CFR 50 and 10 CFR 72)

Biennially, an exercise shall be conducted which simulates emergencies affecting the entire site. The Biennial Exercise will be conducted on alternating years with the 10 CFR 50 Biennial Site Drill.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 32 of 37 This exercise may include health physics, radiological monitoring, security, site dismissal and accountability, and may involve offsite agencies. NRC and local response agencies shall be invited to observe the biennial exercise.

Both the 10 CFR 50 and ISFSI Biennial Exercise may be conducted as one exercise, if the exercise objectives are sufficiently comprehensive to include both routine Site activities and the ISFSI.

7.4 REVIEW AND REVISION OF PLANS AND PROCEDURES The Emergency Plan and Emergency Plan Implementing Procedures shall be reviewed by the Rancho Seco staff and/or District Emergency Preparedness personnel every 2 years in accordance with RSAP-0506, "Procedure Review", and shall be updated as necessary.

Changes to the Plan or EALs will be reviewed with the State OES and Sacramento County OEO, as necessary.

7.5 AUDITS An independent audit of the Long-term storage Emergency Planning Program will be conducted biennially in accordance with the Rancho Seco Quality Manual. The Quality Audit will review the following:

7.5.1 Emergency Plan and Implementing Procedures 7.5.2 Emergency Preparedness Program organization and administration 7.5.3 Emergency Response Organization Training 7.5.4 Records of Surveillances on emergency facilities, equipment and supplies 7.5.5 Records associated with offsite agency response meetings, training and letters of agreement 7.5.6 Records for drills, communication system test and any associated corrective actions 7.5.7 Activation of the Emergency Plan since last audit.

7.6 EMERGENCY PREPAREDNESS ROUTINE TEST PROGRAM 7.6.1 Emergency Communication System Test

• (10 CFR 50) Quarterly, a test of the Emergency Communications System shall be conducted to test and verify the operability of communication equipment as specified in EPIP-03, "Emergency Preparedness Routine Test Program".

(10 CFR 72) Semi-Annually, a test of the Emergency Communications System shall be conducted to test and verify the operability of communication equipment as specified in EPIP-03, "Emergency Preparedness Routine Test Program". The Semi-annual test requirement may be fulfilled by conducting the Quarterly (10 CFR 50) test.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 33 of 37 7.6.2 Emergency Equipment and Supplies 7.6.2.1 Equipment and supplies that are used in the site on a routine basis, and may be used during an emergency, are maintained by site procedures.

7.6.2.2 Dedicated emergency equipment and supplies (held in reserve only for use in emergencies) will be periodically checked and calibrated.

Inspection intervals shall be in accordance with the EPIP-03, Emergency Preparedness Routine Test Program".

Instruments and equipment shall be calibrated in accordance with station procedures.

7.6.2.3 Any equipment or supplies found to be defective or inoperable during inventories and checks are repaired or replaced as soon as possible.

7.7 UPDATES OF TELEPHONE LISTS, EMERGENCY ASSIGNMENTS AND SUPPORT AGREEMENTS 7.7.1 Telephone Lists and Emergency Assignments Emergency telephone numbers are located in the Emergency Response Telephone Directory, which is verified and updated semiannually. The Emergency Response Telephone Directory contains the list of qualified ERO personnel and their emergency assignments.

7.7.2 Support Group Agreements As necessary, Rancho Seco enters into agreements with off-site individuals, groups, and agencies that support Rancho Seco during emergency conditions.

These agreements may be established and maintained via contracts, Letters of Agreement or Memoranda of Understanding. All such agreements are to be reviewed annually and the results documented. All Letters of Agreement and contracts should be renewed every four years.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 34 of 37

8.0 REFERENCES

, DEFINITIONS AND ACRONYMS 8.1 SCOPE This section provides the references, definitions of terms and acronyms that are used throughout the Emergency Plan and Emergency Plan Implementing Procedures (EPIPs).

8.2 REFERENCES

Regulatory guidance on emergency planning is intended to address planning for accidents with potential for public exposure to radioactive releases exceeding Environmental Protection Agency recommended limits. Some references are not specifically applicable to Rancho Seco and are listed because they provided useful insights into the purpose and intent of emergency plans.

8.2.1 10 CFR 20 - "Standards for Protection Against Radiation."

8.2.2 10 CFR 50.47 - "Emergency Plans" 8.2.3 10 CFR 50.54 - "Conditions of Licenses" 8.2.4 10 CFR 50 Appendix E - "Emergency Planning and Preparedness for Production and Utilization Facilities".

8.2.5 10 CFR 30, Rules of General Applicability to Domestic Licensing of Byproduct Material.

8.2.6 10 CFR 72 - Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High Level Radioactive Waste".

8.2.7 Regulatory Guide 3.67 - Standard Format and Contents for Emergency Plans for Fuel Cycle and Materials Facilities 8.2.8 EPA-400-R-92-001 - Manual of Protective Action Guides and Protective Actions for Nuclear Incidents 8.2.9 NUREG-0654 - "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1, November 1980."

8.2.10 NUREG/CR-0130, Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station 8.2.11 Rancho Seco Defueled Safety Analysis Report.

8.2.12 Rancho Seco Post Shutdown Decommissioning Activities Report.

8.2.13 Rancho Seco Independent Spent Fuel Storage Installation Safety Analysis Report.

8.2.14 Rancho Seco Independent Spent Fuel Storage Installation Technical Specifications.

8.2.15 Rancho Seco Radiation Control Manual 8.2.16 Rancho Seco Dosimetry Manual

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 35 of 37 8.2.17 Rancho Seco Quality Manual 8.2.18 Rancho Seco Administrative Procedures.

8.2.19 Rancho Seco ISFSI Physical Protection Plan 8.2.20 Rancho Seco Decommissioning Fire Protection Plan.

8.2.21 California Code of Regulations, Title 19, Division 2 8.3 DEFINITIONS 8.3.1 Accountability - The process of identifying missing on-site personnel after a Dismissal has been conducted.

8.3.2 (10 CFR 50) Alert - An event, which results in significant hazards due to radiological conditions, safety hazards that warrants a Dismissal, or Security events that have serious consequences.

8.3.3 Close out - The process of verifying that the circumstances, which initiated an emergency declaration, have been terminated and the effected system, components and/or area have been restored to a safe condition.

8.3.4 (10 CFR 50) DECON- A decommissioning alternative, which consists of either removing contaminated equipment, components, systems and structures for disposal at a site authorized to receive such contamination or reducing the radioactive contamination to a level that permits unrestricted use.

8.3.5 Dismissal - The process of releasing non-emergency response personnel when safety of the general site population is of concern due to general safety hazards, radiological hazards or hazardous material releases during a declared emergency.

8.3.6 District - Sacramento Municipal Utility District (SMUD).

8.3.7 Emergency Action Level - Specific values related to off-normal conditions, which, if exceeded, will initiate an emergency classification.

8.3.8 Emergency Planning Zone (EPZ) - The geographic area within which provisions are established for responding to postulated emergencies.

8.3.9 First Aid Team - A team of personnel trained in first aid that are dispatched to

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 36 of 37 provide response to personnel injuries.

8.3.10 Incident - An undesirable or unexpected event that may result in radiological exposure to personnel, physical injury to personnel, physical damage to property, or a potential for an uncontrolled release of radioactive material to the environment.

8.3.11 Independent Spent Fuel Storage Installation (ISFSI) - The facility for dry storage of spent reactor fuel.

8.3.12 Industrial Area - The area of Rancho Seco that is enclosed by security fences and contains the Reactor Building, Auxiliary Building, Turbine Building, Nuclear Service Electric Building, Training and Records Building, and other facilities.

8.3.13 (10 CFR 50) Notification of Unusual Event - Events indicated by abnormal site conditions that, by themselves, do not constitute a site wide hazard to personnel.

An Unusual Event is minor in nature and may involve a low-level release of radioactive material to the environment that requires monitoring. An Unusual Event could require cessation of normal activities and require greater than normal attention to protection of site personnel or equipment. Normally referred to as an "Unusual Event".

8.3.14 Nuclear Regulatory Commission (NRC) - The agency of the Federal government with primary responsibility to coordinate emergency response with the District.

8.3.15 Offsite - The area outside of the Industrial Area or Protected Area.

8.3.16 Protected Area - As defined in the ISFSI Physical Security Protection Plan, the ISFSI area enclosed by a double chain link fence.

8.3.17 Protective Actions - Emergency measures taken to prevent or minimize radiological exposure or physical harm to individuals.

8.3.18 Rancho Seco Administrative Exposure Limits - Exposure limits established by the District for Rancho Seco radiation workers during routine operations.

8.3.19 Recovery - Actions and activities that occur after a declared emergency has been closed out and damage resulting from the emergency is being corrected.

8.3.20 Reentry - Coordinated and authorized entry into an area which was previously evacuated or isolated during an emergency due to radiation or safety hazards.

8.3.21 Security Supervisor - The senior person on-shift supervisor responsible for maintaining site security and coordination of NRC licensed activities at Rancho Seco on a 24/7 basis. The on-duty Security Supervisor acts as the Emergency Coordinator until relieved. This person may be a SMUD employee or contractor.

MANUAL: RANCHO SECO EMERGENCY PLAN (CHANGE 6) REVISION 1 PAGE 37 of 37 8.4 ACRONYMS ALARA -As Low As Reasonably Achievable Aux Bldg - Auxiliary Building Cal-EMA - California Emergency Management Agency CFR - Code of Federal Regulations EAL - Emergency Action Level EOC - Emergency Operations Center EPA - Environmental Protection Agency EPIP - Emergency Plan Implementing Procedure EPZ - Emergency Planning Zone ERO - Emergency Response Organization IC - Incident Commander ICS - Incident Command System IOSB - Interim Onsite Storage Building ISFSI - Independent Spent Fuel Storage Installation NIMS - National Incident Management System NRC - Nuclear Regulatory Commission PAS- Primary Alarm Station RWP - Radiation Work Permit SAR - Safety Analysis Report SAS - Secondary Alarm Station SEMS - Standardized Emergency Management System SMUD - Sacramento Municipal Utility District Tech Specs - Technical Specifications TSC - Technical Support Center