Text

Enclosure 5: Draft Consolidated Emergency Plan, Rev. 2.08.2019
	ML19073A252
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	02/08/2019
From:	; Consolidated Interim Storage Facility
To:	; Division of Spent Fuel Management
Shared Package
ML19073A272	List: ML19073A251; ML19073A252; ML19073A253;
References
	E-53819
	Download: ML19073A252 (79)
	v • d • e

Enclosure 5 Draft Consolidated Emergency Plan Revision 2.08.2019

PLAN Effective Date ERP-100 EMERGENCY RESPONSE Revision 02-08-2019 Page 1 of78 WASTE CONTROL SPECIALISTS CONSOLIDATED EMERGENCY RESPONSE CONSOLIDATED EMERGENCY RESPONSE PLAN PROCEDURE APPROVALS:

Jay Britten INCIDENT COMMANDER/ VP SITE GENERAL MANAGER Jay Cartwright

INDICATES RSO HAS DETERMINED THAT ANY MODIFICATION RES ADMINISTRATION CONTROLS THAT ARE AT LEAST EQUIVALENT TOT Jose Jerez DIRECTOR OF SITE OPERATIONS Jeff Shouse DATE

Effective Date Emergency Procedures ERP-100 WASTE CONTROL SPECIALISTS Consolidated Emergency Response Plan Revision 2-08-2019 Page 2 of 78 Table of Contents

1.0 INTRODUCTION

............................................................................................................................................ 6 1.1 PURPOSES AND IMPLEMENTATION OF THE ERP.......................................................................................................... 6 1.2 CONCEPT OF OPERATIONS..................................................................................................................................... 6

1.3 DESCRIPTION

OF LICENSED AND PERMITTED ACTIVITIES.............................................................. A.......................... 7

1.4 DESCRIPTION

OF FACILITY AND SITE....................................................................................

............................. 8

1.5 DESCRIPTION

OF THE AREA NEAR THE SITE......................................................................

................................. 8 1.6 METEOROLOGY....................................................................................................

2.0 TYPES OF ACCIDENTS...............................................................................

2.1 DESCRIPTION

OF POSTULATED ACCIDENTS..................................................

2.2 DETECTION OF ACCIDENTS...................................................................

3.0 OPERATIONAL EMERGENCY EVENT CLASSES..........................

3.1 CLASSIFICATIONS OF ACCIDENTS.................................................

............................................ 14 3.2 NOTIFICATION AND COORDINATION.................................................

................................................ 16 4.0 4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11 5.o*

5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 5.9 5.10 6.0 6.1 6.2 6.3 7.0 7.1 7.2 7.3 NORMAL FACILITY ORGANIZATION.......................

WCS EMERGENCY RESPONSE ORGANIZATION (ERO)

EMERGENCY PROGRAM DIRECTION AND COORDINATIO INCIDENT COMMANDER (IC).......................................

HEALTH AND SAFETY SPECIALISTS *......

RSO......................................

SECURITY OFFICERS.............

............................................................................. 21

........................................................................... 22

......................................................................... 22

.............................................................................. 23 ES.............................................................................. 24

........................................................................................................... 25

......................................................................................................... 25

...................................................................................................... 27

....................................................................................................................... 29

...................................................................................................................... 32

....................................................................................................................... 34

...................................................................................................................... 37 NEL...................................................................................................................... 37 RANSPORTATION......................................................................................................... 38 Y PLANNING ZONE (EPZ)................................................................................................... 39 DOWNGRADE AND TERMINATION..................................................................................................................... 39 EMERGENCY RESPONSE EQUIPMENT AND FACILITIES................................................................................ 39 EOC....*............*..............*............................................................................................................................... 39 COMMUNICATIONS EQUIPMENT........................................................................................................................... 40 EMERGENCY EQUIPMENT....**..........*.........*................................**.....................................*................................. 40 MAINTAINING EMERGENCY PREPAREDNESS CAPABILITY........................................................................... 41 WRITTEN EMERGENCY PROCEDURES..................................................................................................................... 41 TRAINING................................****...................*.*.......*..............*.....*.................**..*.*.......................................... 42 DRILLS AND EXERCISES........................................................................................................................................ 43 2-08-2019

WASTE CONTROL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date, Revision 2-08-2019 ERP-100 Page 3 of 78 7.4 INDEPENDENT AUDIT.......................................................................................................................................... 44 7.5 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT, INSTRUMENTATION, AND SUPPLIES.................................... 4~

7.6 LETTERS OF AGREEMENT..................................................................................... _................................................ 45 8.0 RECORDS AND REPORTS............................................................................................................................. 45 9.0 RECOVERY AND FACILITY RESTORATION.................................................................................................. 45 9.1 RE-ENTRY......................................................................................................................

9.2 RECOVERY *****************.**********.****.*********.********************* :..............................................

9.3 REPORTING AND INVESTIGATING INCIDENTS...............................................................

10.0 COMPLIANCE WITH COMMUNITY RIGHT-TO-KNOW ACT.....................

11.0 REFERENCES

2-08-2019

WASTE C,ONTRQL S.PECIAL!STS Emergency Procedures Consolidated Emergency Response Plan LIST OF TABLES Table A - WCS SP&D Facilities Emergency Classification Table B - WCS CISF Emergency Classificatio~[JC1J Table C -WCS CISF Isotope Specific Release Rate Table D - Protective Action Guides Effective Date Revision 2-08-2019 Table E - WCS SP&D Emergency Response Guides for Hazardous Chemicals TABLE OF FIGURES Figure 1 - WCS Site Evacuation Plan Figure 2 - Emergency Planning Map-50 Mile Radius Figure 3 - Emergency Planning Map-10 Mile Radius Figure 4 - Detail Map Eunice, New Mexico Figure 5 - Location of the WCS Emergency Operations Center a Figure 6 - Site and RCRA Boundaries 2-08-2019 ERP-100 Page4 of78 15 16 29 35 36 49 50 51 52 53 54

WASTE; CONTROL SPE:CIAL.ISTS Emergency Procedures Consolidated Emergency Response Plan APPENDICES Appendix A - Acronyms Appendix B - Definitions Appendix C - WCS SP&D Facility Emergency Action Levels Appendix D - WCS CISF Facility Emergency Action Levels Appendix E - External Agreements Appendix F - Evacuation Roles and Responsibilities 2-08-2019 Effective Date Revision 2-08-2019

. ERP-100 Page 5 of78 55 57 60 62 63 77

Effective Date Emergency Procedures ERP-100 WASTE CONTROL SPECIALISTS Consolidated Emergency Response Plan Revision 2-08-2019 Page 6 of78

1.0 INTRODUCTION

The institutional foundation of emergency preparedness at Waste Control Specialists LLC (WCS) is ERP-100, Consolidated Emergency Response Plan (ERP), which is the site plan for the management, planning, preparedness, response to, mitigation of and recovery from emergencies affecting the site. The ERP provides the framework for response to radiological and hazardous material events that may involve workers, public health and safety and the envir.g~ment. The ERP is consistent with regulatory and industry standards. It also addresses all sta4.~Emergency Management System functions associated with the treatment, storage an~:W13osal of waste containing radiological and hazardous constituents. The ERP uses the gy[ ii'!2iiV contained in United States Nuclear Regulatory Commission (NRC) Regulatory GyJs{~~.. andard Format and Content for Emergency Plans for Fuel Cycle and Materials Faejfilj,es, as We multiple

~ources con~ained wi~hin 30 Texas Administrative Code (TA~):.-1}tl~ latest revisi he ERP includes National Incident Management System (NIMS) cons1ger~f1ons.

The ERP provides controls for emergency planning, pre,:i ess and response toe

!3!iJcies at the WCS Storage, Processing and Disposal(SP&DJJ~~11t1es and t~§"dQterim Storage P ffners

{ISP) Consolidated Interim Spent Fuel (WCS CISF) tai:JICX in Andre~ieounty, Texas. The WCS CISF will be owned by ISP and operated by WCS und~r~et-!gi.o'{Crarating agreement with ISP.

The ERP establishes organizational direction for ensuring 1!1ty operation, protection of the workers, the public and the environment. It describes a prog spending to and mitigating radiological and non-radiological incident

lly associate perations at waste management facilities that includes, but i

, fires, ha JIS material releases (radioactive, non-radioactive and radioact :,;,,~ 1x d natu ~ents as they may impact the hazardous waste products managed on..:stt~-

1.1 1.2 rations app ica regulatory requirements. The 1ological emergency incidents that are o routine operations of the facility. In nt emergency response capabilities for

'tions associated with the operation of the P is the governing document for ensuring the health and safety of site personn and the public; and for protecting the environment in the event of an operational emergency. The ERP and its supporting documents will enable WCS to respond to an emergency in a timely, efficient and effective manner resulting in the mitigation of incident consequences.

Site-wide emergency planning is consistent with comprehensive emergency management concepts. These concepts are inclusive of the following:

1.2.1 Planning Planning involves the development and preparation of hazard assessments, emergency plans and procedures and the identification of necessary personnel and resources to provide an effective response.

2-08-2019

Effective Date Emergency Procedures ERP-100 WASTE CONTROL SPECIALISTS Consolidated Emergency Response Plan Revision 2-08-2019 Page 7 of 78 1.2.2 Preparedness 1.2.3 1.2.4 Preparedness includes the training of personnel, acquisition and maintenance of resources, and involvement in exercising of plans, procedures, personnel and resources essential for emergency response.

Response

A Response represents the implementation of planning and prepareaness during an emergency and involves the effective decisions, actions a lication of resources to both mitigate consequences and to recovem.... an emergency.

Drills and Exercises

~

The conduct of drills and exercises involves d~~pi'ng and mai

iQ_g a program for ensuring individual and organiz~I proficiency for ~~r1Jency response. While drills are instructional in e, exerc.i.ses are evaluatl9~-

demonstrations of proficiency.

V The extent of emergency planning a arednE;1s~uired is based upon, and is ~~f!lmensurate with, the hazard~ an.

q~~~ a~sociated ":'ith th~.

fac1ht1es (SP&D and CISF). All actions in

~ 1t1gating the acc1dent/inc1dent must meet the requirements set forth in Fe lation including: Emergency Planning and Communit o-Know Act (

), Resource Conservation and Recov~ry A~t (~CR sive Envi *..,~Q_tal Response, Compensation L1ab1hty Ac,*,~

und A~~dments and Reauthorization Act (SARA);Utle Ill, ealth & Safety Act (OSHA) and applicable NRC Regulat~b' t e?*t a strative Code and the Toxic Substances Act (TSCY.i.

1.3 Descri tion of I.:!

, sed an rm itted

ies WCS poss~~feVa 10 CF.

61 low le~if~adioactive material license (RML), R04100, under theif{F~me~t sta

tli~Texas Co~mission _on Environmental Quality (TCEQ) th~ *utti

rea m

,,.,,w:age, processing and disposal of low-level radioactive w greater than Class C {GTCC) low-level radioactive waste. The

~t!P,!~£,t..spent h-level radioactive waste, byproduct material as defined in 30

_,f~~~61i~j)(b),

lly~Occurring ~ad)oactive Material_ (NORM), haz~rdous IA'.aste,

,~)'trfclustrials'o,a

ste, al waste, liquid waste, explosive or pyrophoric materials are specifically p,

ed un his license.

In addition, the se allows for possession of multiple curies of various radionuclides for e term of the

e. Storage capability includes Naturally-Occurring Radioactive erials, pre-P,.<'? aged and treated low-level waste and mixed waste, including greater w~,lass C {~e (on a c~se-by-case basis), -~~ansurani_c (TRU), b~product material, ana*

~Q)Jrces. Authorized process capab1ht1es for mixed waste include conso I r(, sorting, repackaging, in-container and bulk stabilization of mixed, deconta, nation of equipment/waste and a variety of other waste management services.

WCS possesses a TCEQ RML R05807 that authorizes the disposal of byproduct material, as described in 30 TAC 336.1105, and is currently limited to materials formerly stored in Silos 1 and 2 of the Fernald Waste Management Plant. The disposal of low-level radioactive waste, mixed low-level radioactive waste, naturally-occurring radioactive material, hazardous waste, industrial solid waste, municipal waste, liquid waste explosive or pyrophoric materials are specifically prohibited under this license.

WCS also possesses Texas Department of State Health Services RML L06153 that authorizes the possession and use of calibration reference sources, calibrations sources and sources used within nuclear soil density gauges. Radioactive materials shall only be 2-08-2019

Effective Date Emergency Procedures ERP-100 WASTE CONTROL SPECIALISTS Consolidated Emergency Response Plan Revision 2-08-2019 Page 8 of78 used by, or under the supervision of, individuals designated by the Radiation Safety Officer (RSO).

WCS has two RCRA permits from the TCEQ and a TSCA authorization from the United States Environmental Protection Agency (EPA), which authorizes treatment, storage and land disposal of hazardous and toxic waste. The current treatment capabilities include consolidation, repackaging and stabilization for a wide variety of RCR~l~d TSCA wastes.

WCS also has a US Nuclear Regulatory Commission (NRG) 10 CF~~li 72 license for Independent Storage of Spent Nuclear Fuel and High-Level Radi9~'We Waste, SNM-1050.

,,~il(,

1.4 Description of Facility and Site Located in Andrews County, Texas, the WCS SP&D f§..gll!o/ is an approxi

§ly, 1,338-acre site that is authorized for the treatment, storagsi~landfill disposal o~sg_ous, toxic, exempt wastes, byproduct material and lo-$Sf radioactive wastes, ana,~~)llent and storage of LLRW, mixed wastes and bypr

"'F-material. j\\l)proximately 14,0GO-acres surround the permitted site as a buffer zone.

ility is. ('"'=n~d, designed and built in compliance with all applicable local, state and The WCS CISF will comprise 320 acres of land no*

includes; a cask handling building, used to store up to 500 metric to*

storage systems licensed by the Criteria, occurs before-a treated and dispo 1.5 D.escrt ieo of the closed and equipped with automatic pressurized hoses. There are also orage building compatible with hose epartments.

~re?:~~~

1

?nc~n a~;~~~~~ t~~~~a!~~ r~: ~~i~i:nie:eM::~~~-T~::te is located appro

ely on 1le north of Texas State Highway 176. The permitted portion of the site is lo

-* entirely in Texas. The area within 1 mile of the permitted facility oundaries is lafily undeveloped and used for cattle ranching, sanitary waste disposal a County L9,Q~y11) and oil & gas production. There are no landowners located next to

. ~j;tcility pel!fiJJ'fed boundary. A six-foot chain-link fence topped with three strands of baro~ * *

?founds the operating boundaries within the permitted area of the facility.

The a provided by the 23 square miles of owner-controlled land surrounding the faci,

rovides further separation from any other adjacent landowner and the public.

There are no residential areas within a 3-mile radius of the facility. The terrain at the site and surrounding area consists of gently sloping grassland with scattered small mesquite trees.

Industrial facilities near WCS include a gravel and caliche mining/crushing facility located approximately one mile to the west of the facility boundary, the Lea County landfill located about one mile to the south-southwest and URENCO USA, a facility for enriching uranium located one mile west of the permitted boundary.

Access to the site is via State Highway 176. Trucks carrying hazardous, mixed waste and low level radioactive waste materials turn north off of State Highway 176 onto the facility's access road. The facility's access road is located immediately east of the state border 2-08-2019

Effective Date Emergency Procedures ERP-100 WASTE C.ONTROL SPECIALISTS Consolidated Emergency Response Plan Revision 2-08-2019 Page 9 of78 1.6 with New Mexico. Trains access the site from west to east on a rail spur off the Texas-New Mexico Railroad line in Eunice, New Mexico to a rail loop, which surrounds the WCS site.

The city of Eunice, New Mexico, located in Lea County, is the closest populated area to the site, located about 6 miles west of the site. The population of Eunice is approximately 2,922 according to the 2010 census. Lea County had a 2~ 0 population of 64,727. The city of Andrews, Texas is located approximately 30 il~to the east.

Andrews is the largest city in the county and has a 2010 populati 1,088.The 2010 population of the 1,500 square mile Andrews County was 14,7 nearest public gathering place (church, school, park, etc.) is approximately lltlt the facility and outside the Emergency Planning Zone (EPZ). All nearby Rl:!:BJf. gatli laces are shown on the 10-mile radius Emergency Planning Map j Plgure 3.

,,'~01 The WCS site is located in a sparsely populated are est Texas. The is*

of the operating facilities within the site, undevelope use around the faciliti large owner controlled buffer area surrounding t ilities are vorable charact rJsfics that limit any potential radiological impact fro*

peratio e facilities to the public and the environment.

to semi-arid and rate of the area is greater thly rainfall ranges from approximately 16 inches.

facilities during tornado season although retches from Texas through Oklahoma and

, ogist, using the National Oceanic and s indicated that Andrews County should have oes per 100 square miles per 30 years (1954 - 1983).

, snow and icy conditions are possible since the temperature may ovember to April. However, as with most areas in Texas, the

~

for extended periods.

nditions are not expected to hamper emergency response. The oding is minimal due to the small amount of precipitation in the area.

e site is relatively flat to slightly undulating with minor drainage relief.

tream or stream drainages capable of producing flash floods within ies boundaries.

on-site meteorological tower for conducting environmental monitoring.

Therefor, real time meteorological data is available for use in emergency response. Data collected over the last six years from the on-site meteorological tower that is located near the Guard House, indicate that the prevailing wind direction is from the south-southeast.

The winds throughout the months of December to February shift occasionally to the southwest. The wind velocity increases from March to May with fhe winds increasing from the south and south-southwest. During the months of June to November, the wind direction is predominantly from the south and south-southeast. The average wind velocity throughout the year is approximately 11 miles per hour. In the event of an airborne release of radioactive material, wind velocity is a key factor in determining the radionuclide concentration at the location of an off-site receptor. As wind velocity increases, the dilution of the radionuclide concentration at the location of an off-site receptor increases. The wind 2-08-2019

Effective Date Emergency Procedures ERP-100 WASTE CONTROL SPECJAL.ISTS Consolidated Emergency Response Plan Revision 2-08-2019 Page 10 of 78 2.0 blows in the direction of the closest off-site receptors (to the west of the facility) only about 5 to 6% of the time on average and most frequently in the 8 to 12 miles per hour range.

Atmospheric stability is a measure of the dispersive capability of the atmosphere and depends on the horizontal temperature gradient of the air. In the event of an airborne release of radioactive material, good atmospheric dispersion dilutes the release and minimizes the radionuclide concentration at the location of an off-site r ptor. Unstable atmospheric conditions (stability class A-C) provide greater dispersio

~ stable conditions (stability class D-F). The atmospheric stability data fro ailj te data collected from the years 2000 - 2005 indicate that the atmosphere at theA~ms unstable 25% of the time, neutral (stability class D) 69% of the time and stable 5%,pfilJ;le' ~. Thus, on av;rage, at1:1ospheric conditions (unstable and neutral) m~~ora

,, dispersion occur TYPES :~A:;~;:::S Information that was used to develop potential operati, ilures lee;!~ to potential accr~ents is found in the site's documents that serve as its basis o ~. '*' tions.

l:fefse documents include the licenses, permits, authorizations and hazard analysis p, ""

'fstems and or operations.

Hazards analysis will be conducted for new systems /ope d any new or unique hazardous or radioactive material inventories. These data will be used to late accident scenarios that, through human or equipment failures, mait~a reviously u

ated accident types. The Incident Commander (IC) then prepares S ""'

At scenario

~erve as the baseline for development of emergency management resgonse rpora tt5Y the appropriate response equipment, on-site emergency response an'& i-site s

ifications.

2.1 2.1.1 Fire scenarios produce greater consequences than other containment failure events because fire offers an increased off-site transport potential. Fire generates heat and combustion gases that may destroy or stress the material and/or the substrate upon which the radioactive materials may be deposited, compromise barriers and/or pressurize containers/enclosures that may lead to the airborne release of contained materials. Mass flux and vapors from the fire suspend material in air. This material mixes with general convection currents that provide transport for particulate materials.

The primary exposure pathways to workers and the public are through inhalation and direct external exposure. The dose from external exposure is much less than dose from 2-08-2019

WASTE C.ONTROL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 2-08-2019 ERP-100 Page 11 of 78 inhalation exposures outside of the facility structures, therefore, protective actions are typically based on inhalation exposures.

Secondary emergencies that may result from the onset of the primary condition include medical emergencies, personal injury accidents and property damage accidents. A power failure will not constitute an emergency requiring implementation of the ERP, unless it causes an increased threat of fire or release to the environment. I 2.1.2 WCS CISF Facility The postulated accident scenarios for the WCS CISF facility implementation of the ERP includes a transportation accid suit in the ility (with fire),

ts, a fire ood, and a impact.

cask drop accidents during transfers, blockage of stora f3 c Air Inlet within one of the storage, staging or processing area hquakes, lightn tornado. Each of the scenarios has been assesse,

'termine the environ Secondary emergencies that may result from t medical emergencies, personal injury accide failure will not constitute an emergency requin caus*es an increased threat of fire or release to t accidents that could lead to a release of radioactiv event classification (see Table C, e Specific Re 2.1.3 Potential emergencies th occur at any industrial facih 2.1.3.1

mary condition I de age accidents. A power n of the ERP, unless it ent. There are no postulated I that would trigger an ALERT ates, in Section 5.2 below).

dioactive particulates ials at other buildings on-site or caus_e heat fighting fires with extinguishing chemicals onnel e physical structures of the facility crete in the storage overpack and increase in WCS CISF e rate

. on Shield and increase in WCS CISF general area dose S~

hazard from flying fragments or shock waves

""'i e other hazardous waste at the facility amage other containers or tanks at the facility that would result in release of toxic and/or radioactive material Injury to personnel Spalling of concrete in the storage overpack and increase in WCS CISF general area dose rate Damage to Neutron Shield and increase in WCS CISF general area dose rates 2.1.3.3 Material Release (applicable to WCS SP&D Facilities ONLY)

Release of flammable liquids or vapors capable of causing a fire or gas explosion Release of toxic and/or radioactive contaminated liquids or fumes Contamination of surface soil 2-08-2019

WASTE CONTROL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Injury to personnel 2.1.3.4 Accident (vehicle or equipment)

Fire, explosion or spill Mixing of incompatible chemicals Effective Date Revision 2-08-2019 Release of toxic and/or radioactive materials Injury to personnel N

ERP-100 Page 12 of 78 Damage to Neutron Shield and increase in WCS CISF. ~ral area dose rates

'"c Damage to the storage overpack and increase~i~.'".c.ef,&~ **, general area dose rates

,';~'"

"'3\\';/f' 2.1.3.5 Natural Events tornados Ii htnin 4arth uakes flo Safety hazard from flying debris Damage to the physical structures Fires, releases and other conse Injury to personnel Damage to Neutron Shield and incr rates Damage to the stora dose rates Blockage of Air inlet/a 2.1.3.6 licable eutron Shield and increase in ISP CISF general area dose rates rates in ISP CISF general area from bottom of the Overpack

, s are d *cumented by the pre-acceptance procedures as developed tamer data and sample analysis or initial waste screening for any ste handled by the facilities. Potential adverse human health effects bstances released in an emergency are summarized below:

e materials - The primary dangers are external exposures or internal res from ingestion or inhalation of radioactive particles or gases. All types dioactive emitters are accepted and are stored in containers that limit the potential for involvement and release for most types of accidents.

Ignitable substances - The primary dangers are those associated either with burns or with injuries due to the concussive forces of possible detonation upon ignition.

The RCRA Part B permitted facilities accept all types of hazardous materials including highly ignitable wastes. WCS does not store ignitable liquid wastes in bulk. All ignitable liquids and solids are either stored in drums and placed in the Container Storage Building (CSB) or contained in roll-off bins, tank trucks or vans.

There is a diked 4000-gallon gasoline tank and bulk liquefied petroleum gas tanks for vehicular use on the facility.

Toxic substances -Adverse health effects (whether acute or chronic) may include injury to the skin, the eyes, the mucous membranes, the respiratory system, the 2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 13 of 78 2.2 2.2.1 digestive system, the circulatory system, the nervous system, the endocrine system, the reproductive system, or other bodily organs and functions. The current RCRA Part B permitted facilities accept all types of hazardous materials.

Bulk tank storage is not provided for toxic liquids. All highly toxic substances are contained in drums and stored in the CSB or contained roll-off bins, tank trucks or vans. Large storage tanks to store highly toxic liquids are not used at this facility.

Corrosive substances - The adverse health effects could invol e *njuries to skin, hair, eyes, mucous membranes and the respiratory system.

RCRA Part B permitted facilities accept all types of hazardous materials. B lk tank storage is not provided for corrosive wastes. All corrosive wastes a o t ined within drums and stored within the CSB or contained in roll-off bi s nk tr cl< or vans.

Alarm Systems T e employee reporting a potential emergency is responsible (if it can be done safely) for obtaining initial information for the IC (or designee) in order to assess the degree of hazard to life, property and/or the environment. This information is used to make preliminary determinations of the necessity for declaration of an emergency and notification to regulatory agencies or to decide whether a request for assistance should be made to other off-site agencies under mutual aid agreements.

2.2.2 WCS CISF Facility

[Detection of accidents is dependent on personnel observation, by fire and smoke alarms and radiation monitoring instrumentation within the affected buildings 2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 14 of 78 3.0 and/or at the Security and Administration Building central alarm panel within the Central Alarm Station (CAS). The CAS is manned 24/7 with Security personneL![JC3J Employees who detect a potential emergency shall notify Security, his/her supervisor/manager and the IC (or designee) immediately. Notification of WCS Security in an attempt to notify the IC is acceptable. The notification is made in one or more of the following ways:

Radio Voice Telephone Alarm Systems agreements.

3.1 Classifications of Accidents 2-08-2019

Effective Date Emergency Procedures ERP-100 WAST CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 15 of 78 Classification Alert Site Area Emergency (Applicable to the SP&D Facility Onl Table A - WCS SP&D Facilities Emergency Classification Criteria An alert is defined as an incident that led or could lead to a release to the environment of radioactive or hazardous material, but the release is not expected to require a response by an off-site response organization to protect persons off-site. An alert requires mobilization of the WCS Emergency Response Organization, either in a standby mode that will activate some portions of the organization or full mobilization, but does not indicate an expectation of off-site consequences. However, an alert may require off-site response organizations to respond to on-site conditions such as a fire or contaminated injured worker.

Response

Activate WCS Emergency Response Organization. Acti ate off-site response personnel, if required, or place on stand-by.

nal ite

y predetermined protective actions for on-site nel.

IC or Designee Notifies the following and any additi nal agencies needed listed in Attachement F of EP-1.1; Executive Director (ED) of the Texas Commission on Environmental Quality (TCEQ)

If off-site response organizations are required, Notify th Executive Director (ED) of the Texas Commission on Environmental Quality (TCEQ) immediately after off-site notifications are made and no later than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after off-ite response orgainizations are requested..

If off-site response organizations are required, Notify th NRC immediately after off-site notifications are made and no I ter than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after off-site response orgainizations are requested.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 16 of 78 Classification Information ONLY. Not a Classification Notification of Unusual Event (NOUE)

Alert able 8-WCS CISF Erner Criteria

Response

Conduct appropriate assessments.

Mitigate the severity of the occurrel'(ce or its consequen es.

IC or Designee Notifies the f Ho ing and any additi nal agencies needed listed in chement F of EP-1.1; INRC Operations Cente Conduct approp

te assessments.

Mitigate t An alert is defined as an incident that led or could lead to a release to the environment of radioactive or hazardous material, but the release is not expected to require a response by an off-site response organization to protect persons off-site. An alert requires mobilization of the WCS Emergency Response Organization, either in a standby mode that will activate some portions of the organizatio or full mobilization, but do s n in ate ations are required, Notify th NRC ifications are made and no I ter sponse orgainizations are

![JC6]

an expectation o ff-1te

ve Director (ED) of the Texas Commission on n ental Quality (TCEQ).

3.2.1 off-st response organizations are required, Notify th Exec t1ve Director (ED) of the Texas Commission on n ronmental Quality (TCEQ) immediately after off-site notifications are made and no later than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after off-ite response organizations are requested.

Operational Emergencies involving actual or potential release of hazardous materials both radiological and non-radiological are the primary concern at WCS.

Depending on the type of emergency encountered, the need for outside resources may be necessary. The IC, or designee, at their discretion will contact outside agencies for help in resolving the emergency. This help can range from fire and ambulance service to activation of county and city Emergency Operations Center (EOC) facilities. The IC will be responsible for ensuring required off-site notifications are mad~[SH7J (See notification list Appendix F of procedure EP-1.1, Consolidated Emergency Response).

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 17 of 78 4.0 3.2.2 On-site Notifications 3.2.3 It is the policy of WCS to ensure prompt emergency response by the WCS Emergency Response Organization (ERO). The IC performs a complete activation of the ERO or appropriate elements within the ERO. The Emergency Operations Center shall serve as the single point of establishment for the ERO. The IC may use the following systems to communicate the activation messa e:

Facility Telephone WCS Public Address (PA) System Electric Horn Intercom System Cell Phones On-Site Emergency Notification S Reverse 911 System (R911) 4.1 a ~aei ihPOrganization Normal =~erations are under the control of the Vice President/Site General Manager. The Vice PresidenUSite General Manager is also the primary IC. Alternate Incident Commanders are available to be designated by inner office memo in the event the primary IC is off site or unavailable. The Radiation Safety Officer is an alternate IC, and will provide guidance during emergencies, but also is empowered to assume control and have the authority to institute corrective actions, including shutdown of operations when necessary in emergency situations or unsafe conditions in accordance with 30 TAC 336.210 and/or 10 CFR 72.32 (a). The additional alternate ICs are selected based on their levels of qualification and training.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CON T ROL SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 18 of 78 4.2 4.3 WCS Emergency Response Organization (ERO)

The WCS Consolidated ERP expresses the philosophy that the WCS Site shall be as self-sufficient as possible in handling emergencies within the facility. Further, the ERP establishes and identifies the groups of individuals to assemble for various types of emergencies at the site. These groups together constitute the ERO.

In an emergency, the IC or designee activates the IERP (after hours, t information relayed from the Security Officer on scene at the emer immediately to the IC or designee).![JCBJ Accordingly, the IC or his designee is re po sible for immediately directing and taking appropriate emergency response actions wit i tfi site boundary and for immediate (within 15 minutes) notification to state and I al me gen jurisdictions, as needed. Protective action recommendations to the state an ocal jurisclicti s are an integral part of the initial notification. The IC may deleg te pecific duties toot er qualified personnel. Personnel elements of the ERO are:

First Responders Incident Commander (IC)

Radiation Safety Officer (RSO)

Operations Manager Emergency Operations Cent The facility personnel receive emergency specific training and are organized to respond to emergencies effectively. This response occurs at several levels as described below:

4.3.1 First Responders First responders are operational and security personnel most likely to discover an emergency. These personnel initiate the emergency response actions of the facility by notifying their supervisor/manager and the IC (or designee). Personnel included in this group could be Operations personnel, Radiation Safety Technicians (RST), Lab Technicians and Security personnel. These personnel are trained so they can:

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP ECIALI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 19 of 78 4.4 Understand the risks presented by the hazardous and radioactive substances at the facility Understand the potential outcomes associated with an emergency involving the hazardous and radioactive substances at the facility Recognize the presence of hazardous and radioactive substances at the emergency scene Identify the hazardous and radioactive substances inll v Cordon of the area from a safe distance to preve Utilize basic risk assessment techniques 4.3.2 ERO Members Several persons within the organizatio n e E ergency Response Coordinator

. ublic Information Officer (PIO)

Radiation Safety Officer (RSO)

Radiation Safety Technician (RST)

Maintenance Incident Commander (IC)

The IC or designee is the individual who is responsible for managing the activities outlined under this ERP. IC duties, authorities and responsibilities are presented in this section.

The persons qualified to act as IC are listed on Attachment F, Emergency Information List of procedure EP-1.1, Consolidated Emergency Response. The names of the primary and alternate ICs are submitted to The Texas Commission of Environmental Quality {TCEQ).

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 20 of 78 The IC or alternate is either on the facility premises or on call 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day (i.e.,

!available to activate the ERP based on information relayed from the Security Officer on scene at the emergency and respond to an emergency by reaching the facility within less than one hour if after working hourS,[JC91). /In the absence or unavailability of the primary IC, there are 3 alternate ICs designated and can act as the primary IC if the primary IC is not responding. The Security Supervisor/Manager is trained to act on behalf of the IC until the IC is in communication and/or at the site. If, in the opinion of the S ity Supervisor/Manager, notification needs to be made to the appropria orities/support organizations for the event occurring while the IC is in process of notified, they are trained and authorized to do so. The ICs ar~[SH1DJ thoroughly amilia with all aspects of this ERP, all the hazardous and radiological waste operatic s a a tiv1fes at the facility, the location of all hazardous waste records within the facilitY.

d the a iii layout.

When called to an emergency, the responsibilities of tfie I are:

Declaring an emergency Classifying emergencies (Site Area Erner e Decisions regarding off-site assistance Activating the ERO Directing response activities Declaring a site evacuation will assure that all recovered waste, soil, anage

entities ICs who have been trained to coordinate the respons o the ERO to an emergency event. These personnel may not always be present t t e facility when an event occurs. One of the ICs listed in Attachment F, Emerg ncy Information List of EP-1.1, Consolidated Emergency Response is alwa o -call. If the on-call IC is not at the facility, then he/ she is available to ~he Officer on scene at the emergency through communication devices or means. Depending upon the nature of the event, the on-call IC may signate certain duties to those present at the facility by phone or electronic communication.((JC11J The IC position meets the requirements of OSHA 1910.120(q) for an on-scene Incident Commander. Beyond acquiring the minimum skills for the first responder, and emergency response training of the emergency response organization, the IC or designee must have competency in the following areas:

Implementation of the ERP Understanding the risks presented by the hazardous substances present at the facility Interaction of emergency response at the facility with local and regional emergency response organizations 2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP ECIA LISTS Consolidated Emergency Response Plan Revision 2-08-2019 Page 21 of 78 4.5 Know and understand the importance of emergency decontamination procedures 4.4.2 Authority The IC has been granted the authority necessary to implement this ERP in the event of an emergency. These authorities include:

Deployment equipment Direction company personnel Contacting emergency response agencies Contacting regulatory agencies Contracting for commercial vendors Health and Safety Specialists The Health and Safety Specialists 4.6 RSO 4.7 E

urin a onitoring and decontamination station is set up to determine if personnel t e site were contaminated, exposed, or injured during cleanup of the ra i t1ve materials release, and to ensuring that contamination is not spread by such personnel Preparing reports as required Calculating potential off-site radiological doses Security Officers The Security Officers are responsible for:

Controlling access to emergency scenes by off-site personnel Contacting the Sheriff's DepartmenUs to provide armed deputies, if requested by the IC 2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 22 of 78 4.8 Managers and Supervisors The Managers and Supervisors are responsible for:

Area supervisors are responsible for overseeing evacuation from their work area Reviewing evacuation routes and expectations with employees Managers working with supervisors to select their designated locar s, assembly points and evacuation route as directed by the IC Instructing employees on the evacuation protocol Assisting employees to designated areas of refuge and t en area 4.9 Local Off-site Assistance 4.9.1 Fire and Explosion 4.9.2 rmian Regional Medical Center is located approximately 30 miles to the east in Andrews, Texas. The hospital is fully equipped to handle most types of emergencies. Transport by helicopter of severely injured personnel to Covenant Medical Center in Lubbock, Texas or the Parkland Memorial Hospital in Dallas, Texas for treatment is available. Helicopters are staged at Covenant Medical Center. A flight time of 35-45 minutes is normal from Lubbock to Andrews. Copies of the ERP and a list of waste materials likely to undergo treatment, storage or disposal at the WCS facility have been forwarded to Permian Regional Medical Center and Lea Regional Hospital. Hospital personnel are asked to review the plan. A listing of medical facilities indicating they are ready and willing to provide any emergency care necessary is in Appendix D. These medical treatment facilities have entered into Memoranda of Understanding (MOU) letters with WCS.

The letters will be updated periodically.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP ECIA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 23 of 78 4.10 4.9.3 Ambulance The City of Andrews Police Department also serves as the ambulance service for the entire county. All City of Andrews police officers are trained and certified EMTs. The Andrews Police Department has agreed to provide emergency medical assistance and evacuation for the facility. Response time for medical assistance to the site is about 30 minutes from Andrews (see endix D).

Additional ambulance service is available through the EuniG F." e and Rescue Service, which has agreed to provide emergency medic ca e to the facility. The Eunice Fire and Rescue Service is approximately 6 iles f o the facility. They can respond within ten minutes.

4.9.4 Traffic Control and Residential Evacuation The Andrews County Sheriff's Departme and residential evacuation. The Sheri '

emergency dispatch service for all e erg nt ol or potential loss of requiring further If a e rgency is declared, notify the DSHS emergency number (see ol a

ment F, Emergency Information List) within one hour of contacting off-site e ponse agencies, in accordance with 30 TAC 327.3.

Whenever notification is made to TCEQ or DSHS, the following information will be provided:

IC name and telephone number The facility The time and type of incident (e.g., release, fire)

The type and quantity of material(s) involved, to the extent known The extent of injuries, if any The possible hazards to human health and the environment outside the facility 2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP ECIA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 24 of 78 4.11 When required, based on the amount released exceeding the applicable Reportable Quantity, the National Response Center (see Attachment F, Emergency Information List) must also be notified 4.10.2 WCS CISF Facility Activation of the ERP requires notification of the following:

Activation of an ALERT for any reason is reported to the NR see Attachment F, Emergency Information List of procedure EP-1.1, Consolioaled Emergency Response) in accordance with Table B above for the W S IS I

Whenever notification is made to NRC, the followin IC name and telephone number The facility The extent of injuries, if any ou the DE>C' resources be inadequate or inappropriate, the DOC refers requests for sup rt t e tate EOC in Austin. The Division of Emergency Management (DEM) opera es th State EOC and coordinates emergency resource support for local governm nts with various state agencies on a daily basis. In the event of a significant emergency, the State Emergency Management Council (which includes all major State agencies and the State liaison of the American Red Cross) will be called into session at the State EOC to manage the State response. The State Emergency Management Council has the authority to employ virtually all State resources, including (with approval of the Governor) the National Guard and Texas State Guard.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP ECIA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 25 of 78 5.0 5.1 Pursuant to provisions of the State Emergency Management Plan, DEM increases its readiness during Alerts and Site Area Emergencies and the State Emergency Management Council may be called in as necessary.

The State of Texas will request Federal assistance from FEMA Region VI in Denton, Texas, in the event that State resources are inadequate to respond to a major emergency.

Requests for Federal assistance are coordinated by DEM and signed b he Governor of the State of Texas.

tfhe DSHS, TCEQ, EPA and NRC (in accordance with NUREG-0 regulatory oversight responsibilities and would provide advisor diagnosing the situation, help isolate critical problems, and action and additional precautionary measures are necess radioactive materials that are released into the environ

t. NRC woul dvt e the licensee and, as applicable, State/local/tribal authori ies nd other Federal age 1;;ies. The DSHS, TCEQ, EPA and NRC have statutory resP,0 s*, 1lities for controlling the is ibution of contaminated food and restricting use of conta ated publ" water.

C pers nnel are responsible for reporting potential emergency conditions and incide st e IC or designated alternate. Such emergency conditions and incidents categoriz d and classified to ensure proper emergency response actions are taken and occurrence-reporting procedures are followed. The IC is responsible for categorizing operational emergencies. An incident determined to be an operational emergency is further classified as an alert or site area emergency in those cases in which the release of a radiological or hazardous material is a potential or actual consequence of the emergency event. When emergency circumstances warrant, local and state jurisdictions will be notified.

Declaration of an emergency is the responsibility of the IC. An IC is on call 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day.

Once it has been determined that an emergency exists, the IC activates the ERO. Under most circumstances, outside help is not summoned unless the emergency cannot be controlled by the WCS ERO. The RSO is listed as an Alternate IC with the authority to 2-08-2019

WAST CONTRO L SP ECIA LI STS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 2-08-2019 ERP-100 Page 26 of 78 assume control to institute corrective actions, including shutdown of operations when necessary in emergencies or unsafe conditions with out being deligated.

Whenever there is an emergency, the IC (or on-site designee when the IC is off-site) immediately activates the internal facility notification systems, when applicable, to warn all facility personnel. Whenever there is an emergency, the IC or designee is responsible for ensuring the character, exact source, amount and extent of any release, material is immediately identified. This is accomplished by observation and by rev1e of facility manifests and other facility records as required.

5.1.1 General Response Steps The steps taken to implement the ER 5.1.1.1 ition of the event, if possible character, source, amount and the extent of I are protected against exposures or injury t n medical attention for any injured persons For spills or material releases, contain and control Prepare for re-entry as directed and authorized by the IC or delegated authority Post-Emergency Recovery - IC or designated ERO personnel Restrict access to affected areas Ensure an adequate recovery plan is in place and implemented before normal activities are resumed Notify public authorities that recovery operations are complete and normal operations will resume 5.1.2 Safety during Emergency Response The IC or designee specifies the appropriate safety procedures to mitigate potential adverse effects for each category of hazards present at the scene.

2-08-2019

PLAN Effective Date ERP-100 EMERGENCY RESPONSE WAST E CONTRO L SP ECIA LI STS Revision 02-08-2019 Page 27 of 78 CONSOLIDATED EMERGENCY RESPONSE Personal protective equipment may include but is not limited to safety glasses, gloves, boots, Tyvek suits, full-face respirators and self-contained breathing apparatus. Toxic, flammable, reactive and radioactive wastes are accessed on a waste-by-waste basis depending on the potential routes by which the waste can adversely affect the safety of ERO personnel.

5.1.3 Initial Response and Notification e

Various atmospheric transport and dispersal models that utilize on-site meteorological data are available for use to develop consequence analyses to determine the potential effects of an accidenUincident at the WCS SP&D facilities. In conducting consequence analyses during an accidenUincident, all information available in the EOC will be utilized.

Information such as modeling outputs, real-time meteorological data and forecasts, monitoring data from field response teams, and hazardous material inventories and data will be used to make recommendations concerning consequences that could be expected.

PLAN Effective Date ERP-100 EMERGENCY RESPONSE Revision 02-08-2019 Page 28 of 78 WASTE CONTRO L SP EC IA LISTS CONSOLIDATED EMERGENCY RESPONSE The primary dispersion/dose assessment model used for consequence analysis will be Hotspot 2.06, or equivalent. This model can accept real time meteorological data from the on-site meteorological tower.

As a backup, manual meteorological data from Hobbs, New Mexico or Andrews, Texas can be input into Hotspot 2.06. Meteorological data can be obtained refr'\\otely via the internet web brousers and individual desktop computer drives at the te consequence assessment.

canisters to be stored at the WCS CISF are designed to be leak tight

-normal, and accident conditions. Therefore, the confinement of the e is maintained under all conditions. The only exceptions to this are the Shielded Canisters (DSCs or canisters) that were leak tested to a 10-5 std-cm3/sec. The accident source terms for these canisters are presen Table C below and are based on the containment evaluation in Appendix A.11 of me wcs CISF SAR.[JC17]

PLAN Effective Date ERP-100 EMERGENCY RESPONSE WAST E CONTRO L SP ECIA LI STS Revision 02-08-2019 Page 29 of 78 CONSOLIDATED EMERGENCY RESPONSE TABLE C -Accident Source Terms to be used for the FO-, FC-, FF-Dry Storage Canisters, Qi Nuclide Type Accident (Ci/sec)

Cs-137 Volatile 4.0SSE-13 Ba-137m Volat ile 4.0SSE-13 Y-90 Volatile 2.614E-13 Sr-90 Volatile 2.614E-13 Pu-241 Fine Am-241 Fine Pu-238 Fine Cm-244 Fine Kr-85 Gas Pu-240 Fine Eu-154 Fine Pu-239 Ni-63 Sm-151 H-3 9.161E-16 9.122E-16 7.558E-16 6.053E-16 4.885E-13 Crud l.561E-12 ce term based on a single canister.

t e event of a catastrophic fire, the Andrews Police Department and the Andrews County Sherriff's Department in Texas and the [Eunice Police in New Mexico are [lSH18Jresponsible for directing traffic along Highway 176 and aiding the evacuation of any of the general public surrounding the facility that may be affected by windblown or gaseous wastes. These parties may request assistance from the Texas Department of Public Safety and/or the New Mexico State Police as needed. Conduct of all fire-fighting activities is always upwind of the fire at the facility. The Andrews Fire Department has a suppressant foam producing truck, if one is required to mitigate a fire. Andrews County also has agreements with surrounding fire departments from neighboring counties for assistance during large-scale fire events.

The Andrews County Fire Department is trained and equipped to handle large fires. They are known for their wellhead firefighting ability, have experience

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SPEC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 30 of 78 5.3.2 fighting fires that may produce toxic fumes, and can respond in approximately 30 minutes. The Eunice Fire Department may also respond and is also known for fighting large fires and has worked with the Andrews firefighting team often in the field. Radiological response training has been, and will continue to be, offered to the Andrews Fire Department and Eunice Fire Department.

WCS emergency response personnel have the ability to handle mall scale fires located within a confineed area. The Andrews Fire Departme t ar:ia/or the Eunice Fire Department may be summoned if a fire is extensive, bree es a confinement barrier or is too intense for WCS employees to handle.

A vehicle accident may cause a fire or explosion due to rupture of the vehicle fuel tank, the spillage of liquid wastes, or mixing of incompatible wastes and/or release of hazardous and/or radioactive materials to the environment. Personnel selected for emergency response train to handle these types of emergencies. Portable fire extinguishers and extended pressurized water hoses are available throughout the site for such emergencies.

If an on-site accident involving contamination of property and facilities occurs, WCS will deploy equipment to clean up the release and decontaminate the site.

2-08-2019

PLAN Effective Date ERP-100 EMERGENCY RESPONSE Revision 02-08-2019 WAST E CONTRO L SP EC IA LISTS Page 31 of 78 CONSOLIDATED EMERGENCY RESPONSE If an incident occurs off-site, WCS will, if requested, supply technical support along with monitoring equipment. Andrews County has a mutual agreement with the City of Odessa, Texas to supply a HazMat team to respond to any incident.

The City of Hobbs, New Mexico also has a HazMat team that will respond to any incidents in Lea County and if requested, they will respond in n ews County.

5.3.4 Mitigation of Natural Events 5.3.5 1cal emergency involving radiologically contaminated individuals occurs a d

the individuals cannot be decontaminated on-site or must be transported i mediately due to life threatening injuries, trained WCS employees will accompany the individuals to the treatment facility and will assist in performing decontamination and contamination control activities. The primary treatment facility for radiological contaminated individuals will be the Carlsbad Medical Center in Carlsbad, New Mexico due to its proximity to the Carlsbad Environmental Monitoring Research Center. The hospital emergency staff is trained by Waste Isolation Pilot Plant (WIPP) personnel to handle radioactive material incidents and have their own decontamination procedures. The New Mexico Department of Homeland Security and Emergency Management and Carlsbad Medical Center will be notified in the event that a contaminated person is being transported to the Carlsbad Medical Center.

PLAN Effective Date ERP-100 EMERGENCY RESPONSE Revision 02-08-2019 WAST E CONTRO L SP EC IA L ISTS Page 32 of 78 CONSOLIDATED EMERGENCY RESPONSE If life threatening injuries are present, the injuries always take precedence over choice of facility.

Personnel who are severely injured and are radiologically contaminated may be covered with protective material and transported to the nearest medical facility.

Hospital personnel shall be alerted to the radiological contami ation and shall employ contamination control practices during treatment of th i jured.

Radiological decontamination may involve removing conta i ted clothing from the injured individual, placing the individual in an emerg ncy hower or sponging the individual with a wet sponge and detergent. Con am* at d Lathing is collected in an appropriate container, surveyed, and evaluated ior to *sp al. Emergency shower water is drained to a collection point to a alyzed. Alte a

ely, water may be taken off-site to an authorized facilit rsonnel who assist a radiologically contaminated person must w ar. appropriate personal pr te ive equipment.

5.4 Protective Actions 5.4.1 Assembly Area The Staging Area for employees evacuating the site is important for personnel safety and for locating all personnel. If the site is evacuated, the Staging Area is beyond the Guard House located at the entrance to the TSDF, beyond the employee gate entrance located at the LLRW employee parking area or outside the security fence on the west side of the WCS CISF Securty & Administrative Building unless otherwise specified by the IC. After WCS Security, with concurrence from the IC, has accounted for all employees and radiation safety personnel have monitored employees for potential contamination (in the event of a radioactive material release),

employees may then proceed down the private access road to Highway 176. If any assembly area is downwind from the incident, the IC will direct personnel to an alternate location on-site.

Protective actions that may be used in the event of an emergency include, but are not limited to:

WAST E CONTROL SP EC IA LI STS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 2-08-2019 Personnel are notified of impending danger via PA announcement, telephone, email and radio broadcast Personnel are directed to shelter Site personnel evacuate from the affected area only ERP-100 Page 33 of 78 Affected personnel evacuate to the assigned assembly point Personnel in vehicles are directed to remain i vehicle, and personnel working outdoors are directed to ak efuge indoors If a radiological release occurs, Radiatio S ety personnel shall monitor all potentially contaminated peso s 5.4.2 Use of Personal Protective Equipment and SupP.lie 5.4.3 Contamination Control are two variations of limiting actions/discontinuances:

5.4.4.1 5.4.4.2 Temporary shutdown, Examples of temporary shutdown conditions are:

Severe Weather: Tornado/tornado warnings, severe thunderstorms, heavy lightning, large hail, continuous rain, winter storms, severe winds Large fire/industrial accident with equipment or personnel disabling effects such that continued operations would subject the remainder of the Site or personnel to unnecessary danger Complete Shutdown, 2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP ECIALI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 34 of 78 5.5 A complete shutdown of operations may occur in the event of a large-scale radiological or hazardous material spill/contamination.

Shutdown operations are the responsibility of the affected building personnel. All operations personnel train to safely shutdown facilities and equipment they are qualified to operate.

The IC or designee may direct temporary shutdown shutdowns.

5.4.5 WCS SP&D Off-site Protective Actions After declaration of a Site Emergency, the IC has t al<

Exposure Control 2-08-2019

WASTE CONTRO L SP EC IA LI STS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 2-08-2019

!Table D Protective Action Guide~[JC19J[SH20J Projected Dose (REM) to the Population 1 to < 5a Recommended Actions No planned protective actions.

recommended protective a t10 reconsidered or termina eel.

ERP-100 Page 35 of 78

/Reference - "Summary Table for PAGs, Guide of the PAG Manual: Protective Action Guides an r Radiological Incidents,"

diological Incidents (EPA-400/R-17/001, January 2017)./[JC21J PG-1 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing other than mild, transient, adverse health effects or perceiving a clearly defined objectionable odor.

5.5.2 ERPG-2 ERPG-2 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 36 of 78 5.5.3 ERPG-3 ERPG-3 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing life threatening health effects.

Table E lists the recommended actions for each ERPG.

Projected Concentration

< Emergency Response Planning Guideline-1

> Emergency Response Planning Guideline-1 and

< Emergency Response Planning Guideline-2

> Emergency Response Planning Guideline-2 And

< Emergency Response Planning Guideline-3

> Emergency Response Pia mn Mandatory evacuation. Monitor environmental levels and adjust area for evacuation based on these levels. Control access. Seek shelter if Guideline-3 vacuation is not immediately possible and uration of exposure is short (minutes).

.---...., e curre tA erican Conference of Governmental Industrial Hygienists'

---uhan book, hr shold Limit Values for Chemical Substances and Physical Ag ts," is th~uia for accidental releases of materials inside a room or building.

The S o Term Ii R sure Limit is the criteria at which protective actions are taken. he Short T rm Exposure Limit is defined as; "the concentration to which workers be exposed continuously for a short period of time without suffering from 1) ihit tion, 2) chronic or irreversible tissue damage, or 3) narcosis of suffici nt egree to increase the likelihood of accidental injury, impair self-rescue, te *ally reduce work efficiency, and if the daily Threshold Limit Value Time-i ed Average is not exceeded". A Short Term Exposure Limit is further efi ed as a 15-minute Time-Weighted Average that should not be exceeded any t1 e during a workday." Accidental releases exceeding the Short Term Exposure Limit or other exposure limit will be cause for evacuation of the area until the exposure limit returns to a safe level as determined by Environmental, Safety and Health personnel.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 37 of 78 5.6 Radiation Protection Program The on-site Radiation Protection program implemented during emergencies is described in RSP-100, Radiation Safety Program.

This program includes:

Methods to comply with exposure guidelines

_A Identification of individuals, by position or title, who can authorize rkers to receive emergency doses Procedures for permitting on-site volunteers to receive rad*a *ooao es in the course of carrying out lifesaving and other emergency activities 5.7 Decontamination of Personnel The RST may respond to both radiological and chemical contaminations. Injured personnel that are contaminated and must be evacuated due to the severity of their injury are normally decontaminated before being evacuated from the site. Area and personnel decontamination will be performed in accordance with approved facility-specific radiation safety decontamination procedures. Decontamination may involve removing all contaminated clothing from the injured individual and placing the individual in an emergency shower (chemical, corrosive exposure) or dry removal/gentle sponging to remove the contamination with a wet sponge and mild detergent (radiological). All contaminated clothing is collected in a container and properly disposed.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAS T E CONTRO L SP EC IA LISTS Consolidated Emergency Response Plan Revision 2-08-2019 Page 38 of 78 5.8 All emergency shower and washing water are collected for disposal. Dry wastes are also collected for proper disposal.

If decontamination is not practical based on the condition of the injured, the individual is placed on plastic, life-sustaining care provided and the individual is evacuated to the nearest/appropriate medical facility where they are treated and hospital personnel employ contamination control practices. Medical personnel should be provided copy of the SOS with chemical contamination. Hospital personnel are offered training i a contamination techniques and requirements, and WCS radiation safety personne will accompany the individual(s) and assist hospital personnel in decontamination activities.

Conduct all personnel radiological decontamination in accor, nee w* h standard Radiation Safety procedures.

OSHA approved first aid stations r MWTF - Lunchroom WCS will attempt to maintain approximately five employees that are trained in first aid, CPR and use of the defibrillation machine. WCS also maintains at least one licensed EMT on staff that has access to an emergency trauma bag. Emergency first-aid treatment and decontamination will be administered in the area where an incident occurs if it is considered safe to do so. If the area is contaminated or considered unsafe, the injured employee will be moved to the primary emergency treatment area. If necessary, off-site emergency medical personnel (ambulance) will be called. The estimated arrival time for an ambulance is approximately 10 minutes. Upon arrival at the Guard House, they will be escorted to the location of the injured person. Emergency medical contacts are listed on form Attachment F, Emergency Information List of EP-1.1, Consolidated Emergency Response and are updated as contact information changes.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 39 of 78 5.9 If a medical emergency involving radiologically contaminated individuals that cannot be decontaminated on-site occurs, trained WCS employees will accompany the individual to the treatment facility and will assist in performing decontamination and contamination control activities. The primary treatment facilities for radiological contaminated individuals will be Carlsbad Medical Center in Carlsbad, New Mexico, and/or Lea Regional Medical Center in Hobbs, New Mexico. The emergency staff at the hospital has been trained by WIPP personnel to handle radioactive material incidents and have thei o n decontamination procedures.

WCS will offer orientation training as requested for medical sup. ort staff (EMS and hospital nursing staff) and physicians at the secondary (Permj n i al) facility in Andrews, Texas, and Eunice, NM EMS. WCS' orientation t in* g fo m r ency situations involving radiologically contaminated individua s it include tyees of radiation, radiation detection and risks, signs and symptoms of :aai ion exposure, c nt ination control and methods of decontamination. The length o t aining will range fro

o to four hours depending on personnel knowledge, expe i n -e and previous training.

This size EPZ is sufficiently large Erner: e <i es once categorized, shall be reviewed periodically to ensure classification is comme s rate with response activities. If the protective action recommendation is modified r lifted, notification will then be transmitted to all activated government agencies.

6.0 EMERGENCY RESPONSE EQUIPMENT AND FACILITIES 6.1 EOC WCS has a central facility from which management and support personnel carry out coordinated emergency response activities. The EOC is the location having appropriate communications and informational materials to carry out the assigned emergency response mission. The primary EOC is the Executive Conference Room located in the southern section of the main administrative building within the boundaries of the existing facility.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAS T E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 40 of 78 6.2 6.3 The secondary EOC is the LLRW Administration Building. The locations of the primary and secondary site EOCs are shown on the site map in Figure 5. The location of an incident determines which EOC is utilized or evacuated as determined by many factors such as; environmental conditions, plumes, etc.

When activated, the EOC has the following communications and accident assessment capabilities and equipment capabilities:

Radio equipment to monitor and communicate on all radio nets s Overhead video capabilities for displaying information to occ. a s of the EOC A public address system for announcements, status repo s an b i fings to be heard by all EOC personnel Communications Equipment The WCS ERP is based on the philosophy that the facility should be as self-sufficient as possible in handling on-site emergency situations. The facilities that serve in various capacities during an emergency situation are discussed in the following sections.

Emergency equipment, including communications and information handling and display equipment, used or issued during emergency operations varies depending on each situation. The equipment contained in the facility will also vary depending on the operations performed and potential emergencies that can occur.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST CONTRO L SP EC IA LI ST S Consolidated Emergency Response Plan Revision 2-08-2019 Page 41 of 78 The facility is equipped with all necessary communication and emergency response equipment required to respond to foreseeable emergencies including the following:

Internal and external communication and alarm systems capable of providing immediate and highly audible emergency instruction and warning A telephone or other communication device available in all areas of operation that is capable of calling emergency assistance from in-house emergenc~ 'e ponse organization Adequate volumes of water to supply water hoses, automatic p Orf lers and water spray systems The emergency firewater syste tank and a diesel-operated fire p a full facility power outage.

Du to e

~tial for radiological consequences during emergency situations, the Radiol ica 1eam Leader on the Emergency Response Organization has the respons bi 1ty to obtain calibrated and response checked count rate and dose rate instrumentation when responding to emergencies.

7.0 MAINTAINING EMERGENCY PREPAREDNESS CAPABILITY 7.1 Written Emergency Procedures ired by All information (emergency contact lists, equipment lists, action levels, etc.) necessary to implement this Plan are included in Procedure EP-1.1, Consolidated Emergency Response. Attachments to EP-1.1 provide current detail for contact information and the availability of equipment. The attachments to EP-1.1 will be continually updated as information and conditions change. Copies of all attachments to EP-1.1 are located in the EOC, the Administration Building and the Guard House for use by the IC and the ERO.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 42 of 78 7.2 All Emergency Response documents are approved and controlled in accordance with standard WCS policy and procedures. ifhe Vice PresidenUSite General Manager is the primary IC and responsible for developing, maintaining and updating the CERP![JC24J.

Changes and updates to these documents can occur for the following reasons:

Changes to emergency organizational structures Changes made in site operations that could impact the site emerg model The facility permits and/or licenses are revised The facility operations change in a way that alters the Pia The ERP fails in an emergency Requested changes from the NRC and/or TCEQ 7.2.1 ed, evaluated and updated C §336.210. Comments r up t days and be provided to ommunications will be rocedure.![JC25J personnel regarding their responsibilities during an emergency Inform ersonnel of any weaknesses detected during drills and exercises, c n es to plans and procedures, lessons learned from emergencies at the a i 1ty and training needed to remedy these situations

' rovide training based on employee and emergency responder tasks to be p~rformed during an emergency 7.2.2 Emergency Response Personnel ERO training is completed in accordance with requirements listed in TRN-1.1, WCS Training Plan. Emergency response employees training includes but is not limited to Radiation Worker, 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months HAZWOPER, basic RCRA training, how to use personal protection equipment (respirators, eye and ear protection, breathing apparatus, protective clothing) and how to perform basic first aid. Emergency response personnel are not certified fire fighters but do understand the correct methods and techniques for eliminating and responding to fire emergencies. Drills and exercises are part of the training curriculum.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP ECIA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 43 of 78 7.3 At least one employee from each operational area is trained for emergency response. This ensures that at least one member of the emergency response organization can describe the waste types and hazards associated with the operational area. After the employee is qualified for emergency response activities, the employee must attend required refresher courses.

In addition, all ERP procedure changes are trained on and prov* ed to all ERO members and documented in the members personal training ile.

7.2.3 Off-Site Response Teams f he assis ance agreement between the WCS facility and Lea Regional Medical e ter, Permian Regional Medical Center and Carlsbad Medical Center if any person has been exposed to hazardous materials at the WCS facility, all inform o regarding the specific material will be forwarded to the hospital. The He tli d Safety Manager, Radiation Safety Officer, or designee may also ride wit

ured personnel to a medical facility to explain the type of waste the in F idual has come in contact with to medical professionals.

Drills and Exercises Emergency drills and exercises are conducted systematically utilizing a "building block" concept to maintain a high state of emergency readiness, improve response capabilities and enhance worker safety through protective actions. The methodology includes classroom training; team and site-level drills and full-scale exercises that may include external agencies.

The goal of drills and exercises is to develop, maintain and demonstrate skills, expertise, and emergency response capabilities of the WCS ERO and site personnel. Additionally, drills and exercises build teamwork, trust and confidence. In support of that goal, drills and exercises may:

2-08-201§

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 44 of 78 7.4 Reveal planning weaknesses Reveal resource gaps Improve coordination Clarify roles and responsibilities Improve individual performance and experience Improve operations Improve emergency decision making and planning skills Improve effectiveness and skills of the ERO Validate adequacy of facilities, equipment, plans, and pr he requirements in 10 CFR 72.32 (a),documented quarterly ns checks with off-site response organizations will include the check and I necessary telephone numbers.![JC30J Independent Audit The Emergency Response Program will be audited annually by qualified staff. Included in this review will be the emergency plan and its procedures; training activities; emergency facilities, equipment, and supplies; and records associated with off-site support agency interface to ensure the overall emergency preparedness program is being adequately maintained. The Individual performing the review will not have direct responsibility for implementing the emergency response program.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SPEC IALI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 45 of 78 7.5 Maintenance and Inventory of Emergency Equipment. Instrumentation, and Supplies Frequent inspections under the WCS Health and Safety program ensure that the equipment and instrumentation are in good working condition and that an adequate stock of supplies is maintained. A quarterly inventory will be conducted to ensure all emergency equipment and supplies are intact and in good operating condition, including instrumentation for operation and calibration, demand respirators, self-o tained breathing apparatus, fire-fighting equipment and gear, and supplemental lighti mely corrective actions are to be taken when deficiencies are found during these n 7.6 Letters of Agreement Letters of agreement (Appendix D) for the WCS facility fr ith a 8.0 RECORDS AND REPORTS ill be maintained and controlled through the site's document io s of emergency equipment and supplies Maintena c, un,eillance, calibration and testing of emergency equipment and supplies Agreement off-site support organizations Reviews and updates of the emergency plan Notification of all personnel and off-site agencies affected by an update of the plan or its implementing procedures Records of quarterly communication checks with the off-site responding organizations 9.0 RECOVERY AND FACILITY RESTORATION Based on the nature of potential emergency events at WCS, the response phase to an emergency will normally be very short when compared to the recovery phase. Recovery is defined as the actions taken, after the facility has been brought to a stable or shutdown condition, to return the site to normal operation. Recovery is event dependent.

2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP ECIALI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 46 of 78 As a result, recovery planning is initiated in the early stages of emergency response and the Recovery Plan is produced only after the consequences of a specific event are reasonably well understood.

9.1 9.2 Re-entry 0

0 0

surveillance of facilities aterials control and accountability functions (as qualified)

Re-entry will include the use of appropriate protective clothing and respiratory protection and shall include specific criteria for aborting re-entry.

Recovery Recovery is the final phase of the emergency management cycle. Recovery continues until all systems return to normal or near normal. The recovery process will be addressed at the time of the incident. It will be situation dependent in establishing the restoration to a safe pre-emergency environment. The Director of Operations or his/ her designee will serve as the Recovery Manager. Recovery team(s) will be established by the Recovery Manager to restore all vital systems back to normal operation. Examples of these systems include water, electrical power and communications. Some of these systems will be 2-08-2019

Effective Date Emergency Procedures ERP-100 WAST E CONTRO L SP EC IA LI STS Consolidated Emergency Response Plan Revision 2-08-2019 Page 47 of 78 9.3 10.0 restored shortly after the accident/incident and may not be included in the recovery process.

Recovery includes those actions necessary to return an incident and the surrounding environment to pre-emergency conditions. Exposure levels are established for estimating dosage and for protecting workers and the general public from hazardous exposure during recovery activities. The IC is responsible for determining when an emer ency situation is sufficiently stable to enter the recovery phase. The IC, through the Pl,,, 1sseminates information regarding the relaxation of public protective actions. T r,overy team(s) develops and coordinates plans and schedules for recovery operatio s.

The WCS Site General Manager and IC shall ensure the fol 0 prior to initiating the Recovery Plan:

Recovery strategy Recovery tasks and assignments Regulatory notifications and follow-ups Insurance and risk management notificati n Logistical support needs Off-site logistical support needs 2-08-2019

WAST E CONTRO L SP EC IA LI STS

11.0 REFERENCES

Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 2-08-2019 ERP-100 Page 48 of 78 11.1 American Conference of Governmental Industrial Hygienists' handbook, "Threshold Limit Values for Chemical Substances and Physical Agents" 11.2 USNRC Regulatory Guide 3.67 - Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities 11.3 WCS program RSP-100, Radiation Safety Program 11.4 WCS procedure, EP-1.2, Emergency Response Training a 11.5 WCS procedure EP-1.1, Consolidated Emergency Re

11.6 WCS plan TRN-1.1, Training Plan 11.7 WCS procedure, QA-5.1, Standard Operatin 11.8 11.9 Manual of Protective Action Guid uclear Accidents; USEPA, 1992 11.10 Texas Administrative Code Title 30 ency Plan for Responding to a Release 11.11 11.12 11.13 Radioactive Materials License R04100 Radioactive Materials License R05807 11.17 Regula Guide 3.67, Standard Format and Content Guide for Emergency Plans for Fuel Cycle and Materials Facilities, Revision 1, April 2011 11.18 NRC Interim Staff Guidance 16, Emergency Planning, June 14, 2000 11.19 Manual of Protective Action Guides and Protective Actions for Nuclear accidents, U.S.

Environmental Protection Agency, 1992 11.20 10 CFR 72.32 Emergency Plan 11.21 10 CFR 72.44 License Conditions 2-08-2019

-MUM

-*ffAI l1\\IJ-U\\laltD:ll0 -/~-

~=

LANDFILL UNITS LEGEND

~ (,-,L<rfll>>U.

"'l'Wfl,iilfOl,I.

wcs WAST E CONTROL SPECIALISTS

' * ----. )

Emergency Procedures Consolidated Emergency Response Plan Figure 1 - WCS Site Evacuation Plan

. ~,...

I Rm~

) -- ---- -

- ~*:_~

I I

I

_ _________ _______________. __ J Effective Date Revision 01-15-2019

\\

Q ERP-100 Page 49 of 78 r-

,-.~---*-*

\\

WASTE CONTRO L SP EC IA LI STS Emergency Procedures Consolidated Emergency Response Plan Effective Date ERP-100 Page 50 of 78 Figure 2 - Emergency Planning Map-50 M"/e Hope

.Oe'!J.IIf Gr *nfit1d. ~

Artesia '.

t4 E W

( ffl

/:¥;co R~r s,.,.~ Riv*rs Uncoln on<\\lforest 180

,1 E

,.. bug.,

So..U.lud Bue~'"'

(lOlJ Close*

~ 'iio.

Clti, AUOurntJ

l<J.,r,d

Acketly

Tt,r t

'""'l"'-"'""-~~~~..--~~.J L**outr Knott

Un (1

VVAST E CONTRO L SP ECIALI STS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 03-15-2017 Figure 3 - Emergency Planning Map-10 Mile Radius ERP-100 Page 51 of 78

WASTE CONTRO L SP ECIALI STS 176 Emergency Procedures Consolidated Emergency Response Plan Effective Date ERP-100 N

WASTE CONTRO L SP ECIA LI STS Emergency Procedures Consolidated Emergency Response Plan Effective Date ERP-100

WAST E CONTRO L SP ECIA LI STS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 01-15-2019 Figure 6 - Site and RCRA Boundaries ERP-100 Page 54 of 78

WASTE GONTRQL SPECIALISTS APPENDIX A - ACRONYMS Emergency Procedures Consolidated Emergency Response Plan As Low As Reasonably Achievable Committed Effective Dose Equivalent Effective Date Revision 02-08-2019 ALARA CEDE CERCLA CFR CISF CPR CSB CWF DOC DEM Comprehensive Environmental Response Compensation Liabilit

\\

DSHS EAL ED EMT EOC EPA or USEPA EPCRA EPZ ERO ERP ERPG FEMA FWF HAZWOPER IC ICS KSA LLRW MOU MWTF NEC NFPA NIMS NORM NRC or USNRC Code of Federal Regulation Consolidated Interim Storage Facility Cardio-Pulmonary Resuscitation Container Storage Building Compact Waste Facility Disaster District Committee Division of Emergency Response Department of State Health Services Emergency Action Level Executive Director Emergency Medical Technician Emergency Oper Low Level Radioactive Waste Memorandum of Understanding Mixed Waste Treatment Facility National Electric Code National Fire Protection Agency National Incident Management System Naturally Occurring Radioactive Materials Nuclear Regulatory Commission ERP-100 Page 55 of78

\\

OSHA PA PAG PCBs PIO R911 RCRA RSO RST SARA SDS SP&D TAC TCEQ TRU TSCA TSDF wcs WIPP WASTE CONTROL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Occupational Safety & Health Administration Public Address Protective Action Guide Polychlorinated Biphenyls, also known as Araclor Public Information Officer Reverse 911 System Resource Conservation and Recovery Act Radiation Safety Officer Radiation Safety Technician Superfund Amendments and Reauthoriza

Safety Data Sheet Storage, Processing & Disposal Texas Administrative Code Texas Commission on Envir Transuranic Effective Date Revision 02-08-2019 ERP-100 Page 56 of 78

WASTE CONTROL SPECIALISTS APPENDIX B - DEFINITIONS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 ERP-100 Page 57 of78 Agency -Any organization that acts in the place of a government and by its authority (e.g., the Federal Emergency Management Agency is an agency of the Federal Government).

Alert - An Alert is an emergency class within the Operational emergency. An Alert reP.

having occurred which involve an actual or potential reduction for the level of facility. a e SP&D -Any environmental release of hazardous materials is expected to be limite.~*r PAG or ERPG at the facility.

s events in progress or and protection. For the WCS ractions of the appropriate Consequence Assessment - A consequence assessment is the evaluati~Jild interpretatio diological or other hazardous materials measurements and other information to provide a b.

Siror decision-makin,

Corrective Actions - Corrective Actions are measures taken to ter f an emergency at or near the source of the emergency.

Dosimetry - The theory and application of the principles and tech m measuring and recording radiation doses.

Drill - A supervised, hands-on instruction period intend capability. A drill is often a component of an exercise Emergency - An emergency is the most serious evenf phenomenon, or security occurrence that could endang Emergency Equipment -Any equipment that may be r emergency situation.

Emergency Action Level - Specifi emergency class of Operational measurable parameter for fac* i phenomenon that indicates ent ntrol, or mitigate the consequences of an criteria used to detect, recognize, and determine the instrument reading, an equipment status indicator, a le event, results of analysis, or another observed Emergency Class - The class fu potential consequenc erge tiates an emergency by the degree of severity, depending on the actual or tion. For the Operational Emergency subcategories, the classes are: Alert, Site Area Emerge Erne Emergency planning, pr emergency respo

location having app mission. EOC is locat

. cy Management include the development, coordination, and direction of activities.

Emergency Managemen ~* - A brief, clear and concise description of the overall emergency Response Organization, designation of responsibilities, and procedures, including notifications, involved in coping with any or all aspects of a potential credible emergency.

Emergency Planning Zones - Off-site zone established as a contingency for planning in the event of a release of hazardous materials.

Emergency Response - Emergency Response Actions encompass implementation of planning and preparedness during an emergency involving the effective decisions, actions, and application of resources that should be accomplished to mitigate consequences and recover from an emergency.

Emergency Response Organization -The Emergency Response Organization consists of a designated group(s) of personnel responsibl~ for coping with and minimizing or mitigating the effects of any emergency.

WASTE CONTROL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 ERP-100 Page 58 of 78 Emergency Response Planning Guidelines - A hazardous material personnel exposure level or range which, when exceeded by a short term or acute exposure, may cause irreversible or other serious health effects in humans. The ERPGs are approved by a committee of the American Industrial Hygiene Association.

Essential Personnel - Personnel who have assigned duties that prevent their immediate de arture from the site during an evacuation.

Evacuation -An evacuation of personnel from all areas of the site within the secured, Exercise - A scheduled and planned large-scale activity that tests the integrated emergency management program associated with a particular facility Federally Permitted Release - Any release that satisfies the definition of "f e

CFR 302.3.

General Emergency -A general emergency is an emergency class which a significant release to the environment of radioactive or ot response by an off-site organization is required.

Hazard Assessment - Used as the foundation for emergency plan hazards and targets unique to a facility, analyses of potential accidents event consequences.

Hazardous Materials - Any solid, liquid, or gaseous reactive, or unstable upon prolonged storage in quanti This definition is an omnibus term used to include both Transportation Act and "hazardous substances" as defin and Liability Act.

t is an incident in in progress and

includes the identification of any,

, and evaluation of potential accident or e, radioactive, corrosive, chemically life, property, or the environment.

fined by the Hazardous Materials nvironmental Response, Compensation, Hazardous Substances - Any pollu Toxic Control Act; any other subs water pollution or hazardous air pollution rules, or the osing a substantial danger when released into the environment.

Incident Co reporting an Ingestion Exp such as milk, fresh nal Safety and Health Administration 40 Code of rrosivity, reactivity, or toxicity.

whose area of expertise deals with radiation protection.

the Emergency Response Organization response at the EOC and is responsible for overall control, mitigation, way in which exposure occurs after ingestion of contaminated water or foods ic foodstuffs.

Non-Essential Perso ential personnel are site personnel whose assistance has been deemed unnecessary to mitigate ency by the EC.

Pasquill Stability Class -A tegorization scheme used to estimate the intensity of turbulence near the ground using the wind speed at 1 Om, incoming solar radiation, cloud cover and time of day. These categories of turbulent intensity, from "A" (most unstable) to "F (most stable) are used in Gaussian plume models to estimate the lateral and vertical spread of a pollutant as a function of downwind distance from the source.

Safety Data Sheets - Written information provided by manufacturers and compounders (blenders) of chemicals, with minimum information about: chemical composition, physical and chemical properties, health and safety hazards, emergency response, and waste disposal of the material.

Protective Action - Physical measures, such as evacuation or sheltering, taken to prevent potential health hazards resulting from a release of hazardous materials to the environment from adversely affecting employees or the off-site population.

Effective Date WASTE CONTROL SPE<;:IALISTS Emergency Procedures Consolidated Emergency Response Plan Revision 02-08-2019

. ERP-100 Page 59 of 78 Protective Action Guide - The Protective Action Guide is a radiation personnel exposure level index or range beyond which protective action may be considered. PAG values should reflect a balance of risks and costs to Facility personnel, public health and safety, and the environment weighed against the benefits obtained from protective actions.

Radiation Safety Technician -A Radiation Safety Technician is an employee who performs qualitative and quantitative radiological evaluations.

Release -A release is any spilling, leaking, pumping, pouring, emitting, emptying, dis leaching, dumping, or otherwise disposing of substances into the environment. This

type or receptacle containing substances or the stockpiling of a reportable quanti unenclosed containment structure. A radiological release (accidental or unplan radioactive material that can result in a dose rate to the public in excess of Reportable Quantity - For any CERCLA hazardous substance, the qua -

of 40 CFR Part 302, the release of which requires prompt notification also identified in 40 CFR 355 Appendix A, and by the State of Tex g, injecting, escaping, abandoning/discarding any dous substance in an a release of a quantity of Recovery - Actions taken after a facility has been brought to a st

ondition to return the facility to normal operation.

Respirator - A respirator is a device to filter contaminants from breathi Response - Response refers to all actions taken to.

ects of any emergency.

Safety Device/System - This term is intended to mea

nstalle

.. ty-related equipment that related to processes, other major equipment, major personnel ha~rw. etc.

de to include boundary ropes, chains, goggles, handrails, and any other of a host of minor item~at CQ.,,,

, under literal compliance. Problems with minor items fall under this reporting syste

'. Asequences of a level with reportable criteria.

Security Emergencies - Security E ption of the routine operation of the facility or event that jeopardized the health and safety.

ats, civil demonstrations, or hostage situations.

Self-Contained Breathing AP.~

Apparatus is self-contained device that supplies breathing air in hazardous atmo Site Area Emerge represents event systems need Any environ exposure le Source Term -

manufacturing or utilities operations.

Within the context of an Operational Emergency, a Site Area Emergency ccurred involving actual or likely failure(s) of facility safety or safeguards nel, the public health and safety, the environment, or national security.

Is that are not expected to exceed the appropriate PAG or ERPG s the amount of radioactive material available for release.

y spilling, leaking, pumping, pouring, emitting, or dumping of oil or other hazardous Spill Control Material - Ma I use to stabilize, absorb, and/or neutralize releases of hazardous materials to minimize hazards and to facilitate cleanup.

Effective Date Emergency Procedures ERP-100 WASTE CONTROL SPECIALISTS Consolidated Emergency Response Plan Revision 02-08-2019 Page 60 of 78 Incident High Winds/

Tornadoes Winter Storm Range Fire Spill/Release Fire Explosion Airplane Crash APPENDIX C - WCS SP&D FACILITY EMERGENCY ACTION LEVELS Alert High winds strike causing major damage to one or more Facility structures.

or--------

Susta ined wind speeds > 90 mph in the area, which have been confirmed.

Accumulation of snow approaching roof design load limits.

or--------

M aj or egress routes from the Facility a impassable because of snow or ice.

Major fire not under control that threatens facilities.

Major spill or release not u that may spread beyond the origin.

ned explosion with potential for more explosions.

or------

An unplanned explosion in an operations area resulting in structural or process related damage.

A plane crash on Facility property.

Site Area Emergency damage to a facility d/or hazardous materials.

release in a hazardous material or ica controlled area which may result in to the off-site environment or exposure neral public Major fire not under control that has spread to other areas.

or------

A fire in a hazardous material or radiologically controlled area that may result in a release to the off-site environment or exposure to the general public.

Explosion causing major damage and/or injury.

A plane crash impacting a hazardous material or radiologically controlled area.

Effective Date Emergency Procedures ERP-100 WASTE CONTROL SPECIALISTS Consolidated Emergency Response Plan Revision 02-08-2019 Page 61 of 78 Incident Government or Commercial Vehicle Site Intrusion Bomb Threat Non-radiological HAZMAT*

Radioactive Plume Alert Accident involving a potential release of hazardous and/or radioactive material at the scene of an accident.

Alarm or visual observation indicating armed personnel entry at the Facility.

or--------

U nauthorized entry to a restricted access facility by non-WCS personnel.

Bomb threat with any detail aimed at a specific Facility, building, or personnel

or--------

A suspicious object when i evaluated/analyzed by se to possess the component in a facility from an lease of radioactive acility workers.

Site Area Emergency Accident which involves a release of hazardous material which has the potential of resulting in exposure to the gen ublic at the exclusion

or--------

of an actual device or reasonable that a bomb has been or will be property.

or--------

ion where initial investigation or information indicates a possible bomb as the initiating cause.

Release > the ERPG (level 2) at a facility boundary or that requires evacuation of multiple buildings.

>500 mrem CEDE but <1 rem CEDE from an accidental release of radioactive material to the general public.

or-------

> 1 rem CEDE, calculated at a facility boundary, from an accidental release of radioactive material to Facility workers.

WAST E CON T RO L SP ECIA LI STS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 ERP-100 Page 62 of 78

!,Appendix D - WCS C/SF Facility Emergency Action leve/~[JC32J Incident E-HU1 Damage to a loaded cask confinement boundary HU1 Confirmed Security Condition or Threat HA1 HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes Unusual Event Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific technical specification allowable radiation level) on the surface of the spent fuel cask.

(1) A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported the security shift supervisior.

(2) Notification of a credible security thre directed at the site.

(3) A validated notification fr providing information of an afrci N/A Alert (2) A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.

WASTE CONTROL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 Appendix E - External Agreements MEMORANDUM OF UNDERSTANDING ERP-100 Page 63 of 78 BETWEEN THE ANDREWS TEXAS POLICE DEPARTMENT AND WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTERNS LLC The purpose of this Memorandum of Understanding is to provide for the cooperation Andrews Police Department and Waste Control Specialists LLC (YVCS) and lnteri WCS operates a fully permitted and licensed hazardous and low level radioacti ste tr disposal facility. ISP operates a licensed Consolidated Interim Storage Fa itiM WCS CISF) fo Fuel. In the event of an emergency, and the potential need for services ndrews Police Depa respond to the facility and provide law enforcement services should e needed at the facility.

Therefore, during the construction, operations and decommission disposal facilities and the WCS CISF in Andrews County, the followi

1. The Andrews Police Department will provide s as may be required to address WCSNVCS C emergencies at or near the WCSNVCS CISF to the deployment of additional staff within fifte

2. In the event of an emergency at the facility, the under a consolidated emergency nse plan t and evacuation services shou eded at County Sheriff's Office will c.

Local Law Enforcement.

3. The Andrews Police D law enforcement deployment

. ement of applicable laws in

':vft//? olice Department commits

ic'ation of need.

ent will coordinate with WCS/ISP ement, investigative, traffic control ility. Once present on-scene, the Andrews onse as the Primary Emergency Authority for rs dispatched for support will arrive with d emergency response. All Andrews Police main under the operational control of their

4.

nsure that responding personnel dispatched by Andrews ing authority and provide support for take-back services,

6.

7.

t agree that if a security situation is critical to classified waste or itional law enforcement assistance. The response time of additional t agrees that they will provide long-term support beyond the event itself ned in the event, as needed.

1ewed every five years.

WASTE; CONT~OL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 ERP-100 Page 64 of 78 In witness whereof, the parties have executed this Memorandum of Understanding on the date indicated.

Name (print)

Signature

. Title Waste Control Specialists LLC Date:

Name (print)

Signature Title Interim Storage Partners LLC Date:

Name (print)

WASTE ~QNTRQL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 MEMORANDUM OF UNDERSTANDING BETWEEN ERP-100 Page 65 of 78 THE ANDREWS COUNTY SHERIFF'S OFFICE AND WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTNERS LLC The purpose of this Memorandum of Understanding is to provide for the cooperation a Andrews County Sheriff's Office and Waste Control Specialists LLC (WCS) and lnte

dination between the age Partners LLC (ISP).

WCS operates a fully permitted and licensed hazardous and low level radioacf ent, storage and disposal ear Fuel. In the event of facility. ISP operates a licensed Consolidated Interim Storage Facility (WCS I

) for Spe an emergency, and the potential need for services, the Andrews County s Office will re provide Primary Law Enforcement Services should they be needed at cility.

Therefore, during the construction, operations and decommissio facilities and the WCS CISF in Andrews County, the following is a

1.

2.

3.

4.

5.

iate law enforcement deployment as ent of applicable laws in emergencies "ff's Office commits to the deployment Office will coordinate with WCS/ISP law en ement, investigative, traffic control and

. When present on-scene, the Andrews County Sheriff's

mary Emergency Authority for Local Law Enforcement.

responders dispatched for support will arrive with emergency response. All Andrews County Sheriff's der the operational control of their respective agency.

ill ensur esponding personnel from the Sheriff's Office would ide take-back services, when needed.

grees that if a security situation is critical to classified waste or w enforcement assistance. The response time of additional support ffice agrees that they will provide long-term support beyond the event tained in the event, as needed.

every five years.

WASTE i;:oNTRQL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 ERP-100 Page 66 of78 In witness whereof, the parties hc;1ve executed this Memorandum of Understanding on the date indicated.

Name (print)

Signature Title Waste Control Specialists LLC Date:

Name (print)

Signature Title Interim Storage Partners LLC Date:

Name (print)

Signat

WASTE CONTRQL SPECIALI.STS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 MEMORANDUM OF UNDERSTANDING BElWEEN ERP-100 Page 67 of78 THE CARLSBAD MEDICAL CENTER AND WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTNERS LLC

~

The purpose of this Memorandum of Understanding is to provide for the cooperation an Carlsbad Medical Center and Waste Control Specialists LLC (WCS) and Interim Stor WCS operates a fully permitted and licensed hazardous and low level radioacti facility. ISP operates a licensed Consolidated Interim Storage Facility (WCS I

an emergency, there is a potential need for hospital medical services for or visiting the facility.

Therefore, during the construction, operations and decommissio facilities and WCS CISF in Andrews County, the following is agree*

1. The Carlsbad Medical Center agrees to work with WCS/ISP in c assistance during the construction, operatic

.!'!ii,;

Andrews County.

2. In the event of an emergency at the facility, th WCS/ISP and local emergency response organ ent, storage and disposal ar Fuel. In the event of ed by, contracted by, ing emergency plans and procedures for s of the WCS/WCS CISF facilities in ical Center will coordinate with

3. If at any time the Carlsbad Medical enter, in th

, deter es they do not have the resources to respond to the request for sen{

CS/IS other obligations or events, the Carlsbad Medical Center will be held harmles

4. The Carlsbad Medical C exercises.

5. All Carlsbad Medical their respective unit(s).

6. This agreeme written no***

in joint training and emergency preparedness drills and sonnel will remain under the operational control of five years. Either party may terminate this agreement with a ninety day

WASTE C<JNTRQL SPECIA\\.f.ST~

Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 ERP-100 Page 68of78 In witness whereof, the parties have executed this Memorandum of Understanding on the date indicated.

Name (print)

Signature Title Waste Control Specialists LLC Date:

Name (print)

Signature Title Interim Storage Partners LLC Date:

Name (print)

WASTE CONTROL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 MEMORANDUM OF UNDERSTANDING BElWEEN ERP-100 Page 69 of 78.

THE CITY OF ANDREWS AND WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTNERS LLC The purpose of this Memorandum of Understanding is to provide for the cooperation and ga9,tGlination between the City of Andrews and Waste Control Specialists LLC (WCS) and Interim Storage Partners LLC.I WCS operates a fully permitted and licensed hazardous and low level radioactive~-

s~ tment, storage and disposal facility. ISP operates a licensed Consolidated Interim Storage Facility for Spent.Jfilear ~~-

the event of an emergency, and the potential need for services, the City of Andrews will res

~fo the fac1 1 d provide Primary Fire Fighting Services, Emergency Medical Services and Police services shou be needed a cility.

Therefore, during the construction, operations and decommissionin facilities and the WCS CISF in Andrews County, the following is e and disposal

1. The City of Andrews agrees to work with WCS/ISP in coordi assistance during the construction, operation and decommissio gency plans and procedures for ses of the WCS/WCS CISF facilities in Andrews County.

2. In the event of an emergency at the facility, th Emergency Medical and Fire Fighting Services have jurisdiction as the Primary Emergency Aut ~

Andrews County Sheriff's Office will coordinate a Enforcement. A separate WCS partme

3. At the request of the City of ubject t will respond to an emerg art and

4. If at any time City of request for services fro of any consequences.

5. The City of sponse exists.

pproval of WCS, WCS trained responders and equipment direction of the City of Andrews.

s they do not have the resources to respond to the ns or events, the City of Andrews will be held harmless in joint training and emergency preparedness drills and nd personnel will remain under the operational control of their respective every five years. Either party may terminate this agreement with a ninety day

WASTE CCJNTRQL SPE(;:IALI.S;TS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 ERP-100 Page 70 of78 In witness whereof, the parties have executed this Memorandum of Understanding on the date indicated.

Name (print)

Signature Title Waste Control Specialists LLC Date:

Name (print)

Signature Title Date:

WASTE CONTRQL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 MEMORANDUM OF UNDERSTANDING BETWEEN ERP-100 Page 71 of78 EUNICE FIRE AND RESCUE AND WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTNERS LLC The purpose of this Memorandum of Understanding is to provide for the cooperation an Eunice Fire and Rescue and Waste Control Specialists LLC (WCS) and Interim Stora WCS operates a fully permitted and licensed hazardous and low level radioacf facility. ISP operates a licensed Consolidated Interim Storage Facility for S t

emergency, and the potential need for services, Eunice Fire and Rescue Emergency Medical and Fire Fighting Services should they be neede Therefore, during the construction, operations and decommissio

facilities and the WCS CISF in Andrews County, the following is a

1. Eunice Fire and Rescue agrees to work with WCS/ISP in coor assistance during the construction, operatic Andrews County.

2.

In the event of an emergency at the facility, Eu Fire Fighting and Emergency Medical Services ent, storage and disposal e event of an d provide mergency plans and procedures for es of the WCS/WCS CISF facilities in inate with WCS/ISP to provide nee on-scene, the City of Andrews will have jurisdiction as the Prima Fire Fi g Services.

3. If at any time Eunice Fire and respond to the request for be held harmless of any

4. At the request of Eun*

equipment will respon

5. Eunice Fire and Rescue

6.

7.

Wrl etermines they do not have the respurces to other obligations or events, Eunice Fire and Rescue will e approval of WCS, WCS trained responders and ft of and at the direction of Eunice Fire and Rescue.

e in joint training and emergency preparedness drills and e years. Either party may terminate this agreement with a ninety day

WASTE CONTROL SPECIALI.STS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 ERP-100 Page 72 of 78 In witness whereof, the parties have executed this Memorandum of Understanding on the date indicated.

Name (print)

Signature Title Waste Control Specialists LLC Date:

Name (print)

Signature Signat Title Interim Storage Partners LLC Date:

I/I/ASTE C9NTROL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 MEMORANDUM OF UNDERSTANDING

. BElWEEN ERP-100 Page 73 of 78 THE EUNICE NM POLICE DEPARTMENT AND WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTNERS LLC The purpose of this Memorandum of Understanding is to provide for the cooperation Eunice Police Department and Waste Control Specialists LLC (WCS) and Interim rdination between the rtners LLC (ISP).

WCS operates a fully permitted and licensed hazardous and low level radio cti waste tre

, storage and disposal vent of an facility. ISP operates a licensed Consolidated Interim Storage Facility for,

Nuclear Fuel.

emergency, and the potential need for services, the Eunice Police De

and provide law enforcement services should they be needed at the facility.

Therefore, during the construction, operations and decommissioni facilities and WCS CISF in Andrews County, the following is agreed t

1. The Eunice Police Department will provide s required to address WCS/WCS CISF site pr near the WCS/WCS CISF site. Additionally, th additional staff within fifteen (15) minutes after enforcement deployment as may be licable laws in emergencies at or mmits to the deployment of

2. In the event of an emergency at the facility, the Depa ent will coordinate with WCS/ISP under a consolidated emergency plan law enf nt, investigative, traffic control and evacuation services ene, the Andrews County Sheriff's Office will should they be needed at t coordinate the local polic

3. The Eunice Police De

4.

5.

gency Authority for Local Law Enforcement.

dispatched for support will arrive with necessary cy response. All Eunice Police Department 111 remain he operational control of their respective agency.

ure that responding personnel dispatched by Eunice Police "ty to detain adversaries until Texas law enforcement arrives.

at if a security situation is critical to classified waste or information it nforc assistance. The response time of additional support will vary.

grees that they will provide long-term support beyond the event itself and he event, as needed.

every five years.

WASTE CONTRQL.SPECIALI.STS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 02-08-2019 ERP-100 Page 74 of78 In witness whereof, the parties have executed this Memorandum of Understanding on the date indicated.

Name {print)

Signature Title Waste Control Specialists LLC Date:

Name {print)

Signature Title Interim Storage Partners LLC Date:

Name {print)

WASTE CONTROL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 01-15-2019 ERP-100 Page 75 of78 MEMORANDUM OF UNDERSTANDING BETWEEN THE LEA REGIONAL MEDICAL CENTER AND WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTNERS LLC The purpose of this Memorandum of Understanding is to provide for the cooperation an Regional Medical Center and Waste Control Specialists LLC (WCS) and Interim Stora WCS operates a fully permitted and licensed hazardous and low level radioacti facility. ISP operates a licensed Consolidated Interim Storage Facility for Sp emergency, there is a potential need for hospital medical services for citiz visiting the facility.

Therefore, during the construction, operations and decommissio i facilities and the WCS CISF in Andrews County, the following is a ciination between the Lea ners LLC (WCS).

ent, storage and disposal he event of an by, contracted by, or

1. The Lea Regional Medical Center agrees to work with WCS/IS inating emergency plans and issioning phases of the WCS/WCS procedures for assistance during the constru.,,,,

eration and CISF facilities in Andrews County.

2. In the event of an emergency at the facility, th local emergency response organizations to esta *~

3. If at any time the Lea Regional Medical Center, i resources to respond to the re rvices f Medical Center will be held

4. The Lea Regional Medic preparedness drills an r will coordinate with WCS/ISP and rvices as needed.

t, ines they do not have the due to other obligations or events, the Lea Regional

s.

ate in joint training and emergency

5. All Lea Regional Medi their respective unit(s).

6. This agreemen written noti personnel will remain under the operational control of five years. Either party may terminate this agreement with a ninety day In witness wher Name (print)

Signature Title Waste Control Specialists LLC Date:

is Memorandum of Understanding on the date indicated.

Title Interim Storage Partners LLC Date:

Name (print)

Signature Title Lea Regional Medical Center Date:

WASTE CONTROL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 01-15-2019 ERP-100 Page 76 of 78 MEMORANDUM OF UNDERSTANDING BETWEEN THE PERMIAN REGIONAL MEDICAL CENTER AND WASTE CONTROL SPECIALISTS LLC AND INTERIM STORAGE PARTNERS LLC The purpose of this Memorandum of Understanding is to provide for the cooperation a Permian Regional Medical Center and Waste Control Specialists LLC (WCS) and In '"'

rdination between the rage Partners LLC (ISP).

WCS operates a fully permitted and licensed hazardous and low level radioacti facility. ISP operates a licensed Consolidated Interim Storage Facility for S t

emergency, there is a potential need for hospital medical services for citi visiting the facility.

Therefore, during the construction, operations and decommissionl!

facilities and the WCS CISF in Andrews County, the following is ag

1. The Permian Regional Medical Center agrees t procedures for assistance during the constru CISF facilities in Andrews County.

2. In the event of an emergency at the facility, the and local emergency response organizations to e

3. If at any time the Permian Region ical Cent resources to respond to the r Regional Medical Center w*

sequences.

nt, storage and disposal be event of an y, contracted by, or oordinating emergency plans and issioning phases of the WCSNVCS ter will coordinate with WCS/ISP

4. The Permian Regional preparedness drills a rticipate in joint training and emergency

5. All Permian Regional operational control of their

6. This agreem written no*

In witness wher Signature Title Waste Control Specialists LLC Date:

y and personnel will remain under the is Memorandum of Understanding on the date indicated.

Signature Title Interim Storage Partners LLC Date:

Name (print)

Signature Title Permian Regional Medical Center Date:

\\NASTE CONTROL SPECIALISTS Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 01-15-2019 Appendix F - Evacuation Roles and Responsibilities All Employees:

Your supervisor is the Evacuation Assistant (EA) for your work area At no time is anyone expected or authorized to take any uncommon personal risk services, unless included in your position description Evacuate upon the direction of the Incident Commander or upon hearing t Place your work in a safe configuration Secure sensitive work documents as predetermined by manage Take personal belongings with you only as time permits. Do not re-en sounds Immediately leave the building using designated eva area. DO NOT leave the designated area until instruct The designated location is:

Offer assistance to any emplo ur abilities allow ERP-100 Page 77 of 78 on ate basis) you have a responsibility to follow the steps in the istance in order to facilitate orderly and rapid evacuation of all occupants, rm is sounding or when prohibited by authorized staff Return imm proper notification, tractors in your work area, have them follow you to the designated assembly Managers:

Review evacuation procedur and expectations with employees, When reviewing evacuation procedures with a group of employees, inform them that if they require assistance with evacuation to inform their supervisor, It is up to employees to self-disclose their need for assistance. Individual employees shall not be asked if they require assistance, As supervisors change assignments and leave work areas, ensure replacements are obtained, Managers work with supervisors to select their designated locations, assembly points and evacuation route.

WASTE COf\\JTROL SPF;CIALIST~

Employees Requiring Assistance:

Emergency Procedures Consolidated Emergency Response Plan Effective Date Revision 01-15-2019 ERP-100 Page 78 of 78 If you will require assistance to evacuate the building during an emergency, contact your su.

The Incident Commander and RSC/Director of ESH&Q will designate where safe are will get to each of them in case of an emergency evacuation Ask any supervisor for assistance when you are away from your regularly assi Evacuation Assistants (Supervisors):

Instruct employees on the evacuation plans Because of privacy laws, DO NOT inquire about the disability, on employee may share information about their disability while discussi Assist employees to designated areas of refuge and th Assistants shall not remain behind if the person insis If a person requiring assistance cannot be found on his evacuate immediately. Report to the IC that you were n s for evacuation. However, the ly area. To minimize risk, Evacu_ation ssistance not ing at the designated area of refuge, oyee.

ML19073A252

Text

1.0 INTRODUCTION

1.3 DESCRIPTION

1.4 DESCRIPTION

1.5 DESCRIPTION

2.1 DESCRIPTION

11.0 REFERENCES

1.0 INTRODUCTION

Response

Response

Response

11.0 REFERENCES

Navigation menu

Search