Text

Attachment 1: Current to Proposed Emergency Plan Comparison Review
	ML19207A495
Person / Time
Site:	Vallecitos, Vallecitos Nuclear Center
Issue date:	07/01/2019
From:	; GE Hitachi Nuclear Energy
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML19182A197	List: M190099, Attachment 4: Vallecitos Nuclear Center Reactor Facilities Radiological Emergency Plan; M190131, GE Hitachi Nuclear Energy License Amendment Request - Revision to Radiological Emergency Plan (REP) Public; ML19207A492; ML19207A495;
References
	M190099
	Download: ML19207A495 (46)
	v • d • e

Attachment 1 Current to Proposed Emergency Plan Comparison Review Page 1 of 45 Current to Proposed Emergency Plan Comparison Review

1. INTRODUCTION This comparison review identifies the differences between the current Emergency Plan (January 2018) and the proposed Emergency Plan. Differences of intent are further evaluated to determine whether the adoption of the proposed Emergency Plan would constitute a potential reduction in effectiveness from the current Emergency Plan.

Review Methodology The comparison between the proposed Emergency Plan and the current Emergency Plan was made as follows:

1. The first step compares the content of the proposed emergency plan to the current emergency plan to determine whether there was any change. Comparisons where the wording is the same are identified as No Change.

2. Where a difference does exist between the wording of the two documents, it is evaluated as one of three types:

Editorial - Differences that include typographical, spelling, grammar, punctuation, title, formatting and paragraph numbering changes; or administrative changes that do not change intent or level of commitment.

No Reduction in Effectiveness (Non-RIE) - Differences that sustain or improve the licensee's capability to perform an emergency planning function in the event of a radiological emergency.

Reduction in Effectiveness (RIE) - Differences that results in reducing the licensee's capability to perform an emergency planning function in the event of a radiological emergency.

2.

SUMMARY

The results of the comparison between the current Emergency Plan and the proposed Emergency Plan revealed the following changes that could be considered reductions in effectiveness (RIEs). Potential RIEs are further evaluated and documented in Attachment 2, VNC REP Reduction in Effectiveness Review, of this submittal package.

5, 61, 66 The proposed REP removes applicability to the SNM facilities also located on the VNC site.

The proposed REP does not include EAL thresholds for facilities other than NTR and the SAFSTOR reactor facilities.

The proposed REP removes EPZs for buildings that do not apply to the REP and do not have a regulatory requirement for an emergency plan.

31, 35 The proposed REP does not require an Emergency Director (previously titled EOC) to be on site 24/7.

47 The proposed REP removes specific information regarding the location and name of the medical services treatment facilities.

57 The proposed REP does not include the Site Area Emergency classification level.

71 The proposed REP specifies the time requirement for State notification

(( )).

Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 2 of 45 Current to Proposed Emergency Plan Comparison Review Note: Tables and figures contained in the current and the proposed common emergency plans are not included in the following comparison table. Red text is used in the comparison table to refer to these items. All tables and figures were reviewed for possible commitments and key items were included at the end of the comparison table.

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

1. 1 INTRODUCTION Editorial Planning Standard (ANSI/ANS-15.16 Section 3.1 & Administrative change -

NUREG-0849 Section 1.0) Planning Standard wording The plan shall briefly introduce the type of reactor, the added to provide basis reactors purpose, where it is located, and the purposes information directly within the of the emergency plan. emergency plan.

The purpose of the introduction is to provide a general orientation and common understanding about the reactor and the objectives of the plan for those members of the reactor organization, the public, and local, county, state, and federal agencies that will read and study the plan.

2. 1.1 Objective

1.0 INTRODUCTION

Editorial This emergency plan contains security related The purpose of this plan is to establish the organization Administrative change -

information and describes the approach used to identify, and procedures for coordinating the Vallecitos Nuclear Paragraph rewritten as an communicate, respond to and minimize the Centers (VNC) capability and off-site support objective.

consequences of classified emergencies; it documents organizations for handling radiological emergencies regulatory compliance and site specific commitments; involving the VNC reactor facilities. Effective and provides a basis for the response and maintenance implementation of this plan will minimize injury to implementing procedure instructions. This plan will be personnel on site and minimize loss of property.

provided to external stakeholders as appropriate. Instructions for implementation of this plan are provided in the document, Site Emergency Procedures -

Vallecitos Nuclear Center, which, in conjunction with procedures for specific facilities or areas, where appropriate, will provide the guidance for emergency preparedness and response to reactor-related emergencies.

Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 3 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

3. 1.2 Scope and Regulatory Basis

1.0 INTRODUCTION

Editorial 1.2.1 Scope At VNC there are four reactor facilities licensed by the Administrative change -

There are four reactor facilities at the Vallecitos Nuclear NRC. A research reactor (the NTR) has an operating Planning Standard wording Center (VNC) that are licensed by the NRC under 10 license; the other three reactor facilities (VBWR, added to provide basis CFR 50 requirements; the Nuclear Test Reactor (NTR), EVESR, and GETR) are in a SAFSTOR information directly within the which has a current operating license, and the other decommissioning mode and have possess only emergency plan.

three reactor facilities which are in a shutdown licenses.

SAFSTOR decommissioning mode with possess only licenses:

Vallecitos Boiling Water Reactor (VBWR) DPR-1

ESADA Vallecitos Experimental Superheat Reactor (EVESR) DR-10

GE Test Reactor (GETR) TR-1

4. This emergency plan has been developed for the NTR, Editorial license R-33, in accordance with the applicable Administrative change - Specific regulations, guidance and information documents. Per wording added to provide basis NRC letter dated 03/19/13 and DRK-2013-14 response information directly within the the NTR emergency plan and implementing procedures emergency plan.

are sufficient to meet the emergency planning requirements for the three shutdown defueled reactors (spent fuel for the SAFSTOR facilities is no longer maintained or stored on site).

5. Other VNC facilities which are governed under Special

1.0 INTRODUCTION

RIE Nuclear Material (SNM) federal and state licenses do VNC also has two other major radioactive material The proposed REP removes not contain sufficient radioactive materials to require an handling areas, Building 102 and Building 103. Building applicability to the SNM facilities emergency plan (NRC Letter SNM-960 Amendment 5 102 houses the sites hotcell facilities and Building 103 also located on the VNC site.

12/20/90 and GEH 03/08/18 Memo, Evaluation that a contains radiochemistry laboratories and the site SNM facilities were added VNC Radiological Emergency Plan is not Required for countlab. inappropriately in 2013.

Radioactive Material Authorized by the State of All areas on-site are bounded, for radiological release, California). by the core material type and radiological activity of the

Building 102 contains administrative offices and operating reactor at NTR.

shielded facilities (hotcells) for experiments, sealed source manufacture, and examination of irradiated 1.2 Other Facilities materials. The building also includes radiological Building 102 contains administrative offices and equipment repair and refurbishment shop areas, the shielded facilities (hotcells) for experiments, sealed storage pool and dry pit storage as well as a source manufacture, and examination of irradiated radiochemistry laboratory equipped with standard materials. The radiological areas encompass multiple chemical and radiochemical apparatus. shielded (hot cell) facilities equipped with remote manipulators to conduct experiments and analyses with Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 4 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

Building 103 consists of administrative offices and irradiated reactor fuels and other radioactive materials.

laboratories equipped and designed to handle small The building also includes radiological equipment repair amounts of radioactive materials in the performance and refurbishment shop areas, the storage pool and dry of research, development, and analytical chemistry pit storage as well as a radiochemistry laboratory and metallurgical services. equipped with standard chemical and radiochemical apparatus. This laboratory is primarily used to analyze

Building 105 contains laboratory areas with samples of materials prepared in B102. The hot cells in equipment for research and special measurement the radiochemistry laboratory are not as heavily that involves minimal amounts of radioactive shielded as the main hot cells and typically only small material used in conjunction with spectrometric quantities of irradiated material are examined in this equipment. area.

Building 106 houses support facilities (e.g., Building 103 consists of administrative offices and electrical shop, instrument shop, radiological laboratories equipped and designed to handle small instrument calibration facilities, etc.), an x-ray room, amounts of radioactive materials in the performance of and offices. research, development, and analytical chemistry and

Building 349 contains the site low-level liquid waste metallurgical services. The two-story buildings evaporator. laboratories are variously equipped with apparatus

400 and 401 Areas consists of offices and spaces designed to handle quantities of radioactive materials that may contain laboratory quantities of radioactive that are typically less than 1gm and are limited to less material. than a critical mass.

Hillside Storage Area is used to store Low Level Building 104 is a warehouse and normally is used only Radwaste. Irradiated fuel segments and hardware for storage.

are stored in the (( ))area. Building 105 contains laboratory areas with equipment for research and special measurement activities. This work involves minimal amounts of radioactive material that are used in conjunction with spectrometric equipment.

Building 106 houses support facilities (e.g., electrical shop, instrument shop, radiological instrument calibration facilities, etc.), an x-ray room, and offices.

Building 349 contains the site low-level liquid waste evaporator. The concentrates from the evaporation process are solidified and packaged for off-site shipment to a licensed burial contractor.

The 400 Area consists of offices and nonradioactive material laboratories.

The 401 Area consist of offices and nonradioactive material laboratories Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 5 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type Hillside storage area is used to store Low Level Radwaste. Irradiated fuel segments and hardware are stored in the (( )) area. These materials are stored on an interim basis awaiting shipment off site for permanent disposal.

6. The VNC Emergency Response Organization (ERO) Non-RIE may be used to address events occurring at those Added description on use of the facilities outside of a declared emergency. Event NTR REP ERO for events to response involving SNM facilities are primarily other site facilities that do not fall controlled through site industrial / hazards procedures under the requirements of 10 that are outside the scope of this emergency plan. CFR 50.

7. 1.2.2 NTR Regulatory Basis

1.0 INTRODUCTION

Editorial NRC Regulatory Guide 2.6, Emergency Planning for VNC is maintaining this site emergency preparedness Administrative change - Added Research and Test Reactors, provides test and plan using the requirements for research reactors as detail from RG 2.6 regarding the research reactor licensees with a method that the NRC detailed in Regulatory Guide 2.6 and ANSI/ANS specific regulations that apply to considers acceptable for use in complying with the Standard 15.16. VNC has determined using this NTR.

following regulations on the content of their emergency emergency preparedness plan is sufficient in attaining plans: an acceptable state of Site emergency planning and

10 CFR 50.34(b)(6)(v) requires that each preparedness.

application for a Part 50 license to operate a facility include a final safety analysis report that contains, along with other information, the applicants plans for coping with emergencies, including the items specified in Appendix E to 10 CFR 50.

Note - NTR is the only facility at VNC that is required to maintain a safety analysis report.

10 CFR 50.54(q) requires Part 50 licensees to follow and maintain the effectiveness of emergency plans that meet the requirements of 10 CFR 50 Appendix E.

Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 6 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

10 CFR 50 Appendix E identifies the minimum requirements for emergency plans. It also indicates that because operation of test reactors involve distinct considerations, the size of the emergency preparedness zone (EPZ) and degree of compliance with requirements in Appendix E, sections I through V, as necessary, will be determined on a case-by-case basis using this regulatory guide for research and test reactor, and other non-power production and utilization facility emergency response plans.

Regulatory Guide 2.6 Revision 2 endorses the consensus standard ANSI/ANS-15.16-2015, stating that it provides specific acceptance criteria that; (1) comply with the applicable requirements contained in the above listed regulations, and (2) supply a basis to develop acceptable emergency response plans and improve emergency preparedness.

Consistent with ANSI/ANS-15.16, NUREG-0849 provides areas of review, planning standards, and items for NRC staff to evaluate a licensees compliance with the applicable emergency planning requirements.

NUREG-0849 is used as a basis for the level of planning detail included in this document.

8. 1.3 Location

1.0 INTRODUCTION

Editorial VNC, owned and operated by General Electric Hitachi The Vallecitos Nuclear Center (VNC) is located 4.1 air Administrative change - Updated (GEH), is located in the west-central portion of the State miles south-southeast of Pleasanton, California, VNC location description and of California about 15 miles east of the southern end of approximately 35 air miles east-southeast of San maps.

San Francisco Bay, approximately 35 air miles east- Francisco and 20 air miles north of San Jose. Figure 1 southeast of San Francisco and 20 air miles north of locates VNC in the San Francisco Bay Area. The VNC San Jose. It lies on the north side of the Vallecitos facilities are described below. Figure 2 shows building Valley. The nearest sizeable towns are Pleasanton, locations.

located 4.1 miles to the north-northwest and Livermore, [Figure 1 - Bay Area Map]

located 6.2 miles to the northeast.

[Figure 2 - Vallecitos Nuclear Center Site Map]

The site is on the north side of Vallecitos Road (State Route 84), which is a two and four-lane paved highway.

The majority of the site is undeveloped with hills ranging in elevation from 600 to 900 feet above mean sea level.

Access to Vallecitos Road from the south-west is via Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 7 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type Interstate Highway 680, and from the north-east via Stanley Boulevard or Interstate Highway 580.

[Figure 1 VNC Bay Area Map]

9. 1.4 Reactor Description 1.1 Reactor Facilities Editorial The NTR, located in Building 105, is a heterogeneous The Nuclear Test Reactor (NTR) is located in Building Administrative change - Updated enriched-uranium graphite-moderated and -reflected 105. The NTR is a heterogeneous, enriched-uranium, descriptions of the reactor light-water-cooled thermal reactor. The reactor is a graphite-moderated and -reflected, light-water-cooled facilities.

variable level neutron source used in the research, thermal reactor licensed to operate at power levels not development, analytical and commercial programs of in excess of 100 kW (thermal). The core is cooled by GEH and its customers. The NTR is primarily engaged either natural or forced circulation of deionized light in neutron radiography non-destructive material water circulated in an aluminum primary system located imaging. Per the General Electric Nuclear Test Reactor inside a heavy concrete, thick-walled shielded cell. The Safety Analysis Report Section 1.1, the NTR is licensed reactor is a variable level neutron source used in the to operate at power levels not in excess of 100 kW research, development, analytical and commercial (thermal). programs of GE and its customers.

GETR and related structures are located in the 200 The deactivated General Electric Test Reactor (GETR)

Area. VBWR and EVESR and related structures are and related structures are located in the 200 Area. The located in the 300 Area. These facilities are not GETR has a possess only license, and all fuel has occupied. Only relatively minor activities associated with been shipped from the facility. Only relatively minor inspection and maintenance of the deactivated facilities activities associated with inspection and maintenance of are currently performed. No fuel assemblies from these the deactivated plant are currently performed. Normally, reactors remain on-site. Radiation and contamination the facility is unoccupied and is in the NRC levels in all of the SAFSTOR facilities are significantly decommissioning status of SAFSTOR.

reduced since shut-down several decades ago and well The Vallecitos Boiling Water Reactor (VBWR) and the below values typical of operating research & test ESADA Vallecitos Experimental Superheat Reactor reactors. (EVESR) located in the 300 Area have been Those and other areas regulated under separate deactivated and have possess only licenses. The licenses at VNC that contain radioactive material are NRC-licensed portions of the facilities are inspected illustrated below. periodically and maintenance performed as necessary.

[Figure 1 VNC Site Layout] Normally, the facilities are unoccupied and are in the NRC decommissioning status of SAFSTOR.

Contamination levels in all reactors are significantly reduced from when the reactors were shutdown and well below typical operating research reactor cores. The highest recorded general area dose rates are

((

)).

10. 2 DEFINITIONS Editorial Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 8 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type Planning Standard (& ANSI/ANS-15.16 Section 3.2 & Administrative change -

NUREG-0849 Section 2.0) Planning Standard wording Terms unique to the reactor facility or that have a added to provide basis special meaning when used in the plan shall be defined information directly within the in the plan. emergency plan.

11. Assessment Actions - Those actions taken during or 2.2 Assessment Actions No Change after an emergency to obtain and process information Those actions taken during or after an emergency to necessary to make decisions to implement corrective, obtain and process information necessary to make protective and recovery actions. decisions to implement corrective, protective and recovery actions.

12. Corrective Actions - Those actions taken to arrest and 2.3 Corrective Actions No Change terminate an emergency. Those actions taken to arrest and terminate an emergency.

13. Direct - Directing involves obtaining data and 2.8 Direct No Change recommendations, processing this input, and then Directing involves obtaining data and recommendations, ensuring the performance of one or more actions or processing this input, and then ensuring the activities such as additional assessment, protective or performance of one or more actions or activities such as corrective actions. The performance of actions or additional assessment, protective or corrective actions.

activities is generally through responsible The performance of actions or activities is generally intermediaries. through responsible intermediaries.

14. Emergency Action Level (EAL) - A pre-determined, Editorial site-specific, observable threshold for an initiating Administrative change - Added condition that, when met or exceeded, result in actions VNC definition developed using such as (a) establishing emergency classes and (b) ANSI/ANS-15.16 definition.

initiating appropriate emergency measures.

15. Emergency Classification Level (ECL) - One of a set Editorial of names or titles established by the US Nuclear Administrative change - Added Regulatory Commission (NRC) for grouping off-normal VNC definition developed using events or conditions according to (1) potential or actual NEI 99-01 R6 definition.

effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:

Unusual Event (UE)

Alert

Site Area Emergency (SAE)

General Emergency (GE)

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

16. Emergency Control Center (ECC) - The primary base Editorial of VNC emergency operations during a declared event Administrative change - Added to facilitate the management and coordination of overall VNC definition developed using emergency response. GE Wilmington definition.

17. Emergency Planning Zone (EPZ) - Area for which off- Editorial site emergency planning is performed to assure that Administrative change - Added prompt and effective actions can be taken to protect the VNC definition developed using public in the event of an accident. The EPZ size is ANSI/ANS-15.16 definition.

dependent on reactor power level and the distance beyond the site boundary at which the protective action guides could be exceeded.

Refer to Section 6 for the VNC facility specific EPZs.

18. Fire - Combustion characterized by heat and light. Editorial Sources of smoke such as slipping drive belts or Administrative change - Added overheated electrical equipment do not constitute fires. NEI 99-01 definition.

Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

19. Holding Statement - A statement reviewed and Editorial approved for accuracy prior to issuance, that provides Administrative change - Added prepared information to distribute in response to rumors VNC definition developed using or inquiries from news or social media outlets, GE Wilmington definition.

community officials, regulatory agencies, or other interested parties.

20. 2.6 Normal Working Hours Non-RIE The VNC operates on flex time between (( Removed definition. Term is no longer used to formally describe

)) ERO site presence. Refer to change #31 for details regarding ERO response.

21. 2.7 Off-hours Non-RIE The off-hours are all hours not defined as normal Removed definition. Term is no working hours. longer used to formally describe ERO site presence. Refer to change #31 for details regarding ERO response.

22. Off-Normal Condition - A situation or event, other than Editorial those addressed by site personnel on a routine basis, Administrative change - Added which are evaluated for emergency plan entry the VNC definition developed using Emergency Director. GE Wilmington definition.

23. Off-Site - The geographical area that is beyond the site No Change Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 10 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type boundary.

24. On-Site - The geographical area that is within the site No Change boundary.

25. Operations Boundary - The area within the site 2.9 Operations Boundary Non-RIE boundary such as the reactor building (or the nearest The operations boundary is the nearest physical Revised to specifically define the physical personnel barrier in cases where the reactor personnel barrier that encloses the reactor facility operations boundaries for the building is not a principal physical personnel barrier) defined in the reactor license or technical specifications. reactor facilities.

where GEH has direct authority over all activities. The area within this boundary shall have prearranged evacuation procedures known to personnel frequenting the area.

Refer to Section 6.0 for the site specific reactor facility operational boundaries.

26. Protective Actions - Those actions taken to mitigate 2.4 Protective Actions No Change the consequences of an emergency. Those actions taken to mitigate the consequences of an emergency.

27. Recovery Actions - Those actions taken after an 2.5 Recovery Actions No Change emergency to restore the area to the pre-emergency Those actions taken after an emergency to restore the condition. area to the pre-emergency condition.

28. Site Boundary - The site boundary is a boundary that 2.1 Site Editorial does not necessarily have restrictive barriers and The site for purposes of this plan is the GE property Administrative change - Added surrounds the operations boundary wherein GEH may designated as the Vallecitos Nuclear Center. The VNC definition developed using directly initiate emergency activities. The area within the surrounding fence is the site boundary. ANSI/ANS-15.16 definition.

site boundary may be frequented by people unacquainted with the reactor operations.

For purposes of this plan, the site boundary is the GEH property fence designated as the Vallecitos Nuclear Center.

29. 3 ORGANIZATION AND RESPONSIBILITIES 3.0 ORGANIZATION AND RESPONSIBILITIES Editorial Planning Standard (ANSI/ANS-15.16 Section 3.3 & VNC personnel, are capable of handling any Administrative change -

NUREG-0849 Section 3.0) foreseeable emergency condition on site. Several off- Planning Standard wording Responsibility for planning and implementing all site organizations are available, however, to assist and replaced generalized wording to emergency measures within the site boundary rests with support personnel in coping with emergencies. provide basis information directly the owner/operator of the reactor facility. The plan shall within the emergency plan.

describe the emergency organization that would be activated to cope with radiological emergencies that includes the on-site emergency organization and any augmentation from off-site groups. Persons or groups that will fill positions in the emergency organization should be identified by their normal everyday title.

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

30. 3.1 VNC Emergency Response Organization (ERO) 3.1 On-Site Emergency Control Organization Non-RIE VNC emergency preparedness response adapts the The Emergency Control Organization is as shown in General description revised to normal site organization into an ERO that is activated Figure 3. . The organizational structure provides for remove reference to initial and upon declaration of an emergency classification level. an initial response phase and a secondary response secondary phase.

The VNC ERO is shown below. phase for emergencies. ERO Figure revised to move fire

[Figure 3 VNC Emergency Response Organization [Figure 3 - VNC Emergency Control Organization] response under Emergency and Support Interface] Director rather than under BEC.

31. An off-normal condition is initially evaluated by the 3.1.2 Emergency Operations Coordinator RIE Emergency Director. An Emergency Director is present (( The proposed REP does not on site whenever the reactor (NTR) is operational or require an Emergency Director entries into EVESR, GETR, or VBWR are in progress. (previously titled EOC) to be on Otherwise, the Emergency Director may be offsite. ))(( site 24/7.

When the Emergency Director is on site, they are )) are GE employees trained for typically made aware of an off-normal condition implementing and coordinating emergency response

(( activities and assigned to provide continuous coverage

)). When the at the site on a five-day-per-week schedule.

Emergency Director is not on site they will be contacted In the rare instances when the regularly assigned by (( ((

))is absent from the site or otherwise unavailable for emergency response, the ((

)).

Following evaluation of the event, the Emergency )). ((

Director will determine whether an emergency declaration is warranted, staff the appropriate ERO positions and notify Federal and State agencies.

)) will assume Initial Response EOC responsibilities during off-hours.

((

)).

3.1.5 VNC Staff Emergency Assignments Personnel are assigned responsibilities to be performed during emergencies. These individuals are responsible to the EOC. During off-hours, these individuals may be called in.

Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 12 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

32. Responsibilities and authority of members of the ERO, 3.1 On-Site Emergency Control Organization No Change management, and support specialists include those Responsibilities and authority of members of the listed below. Additional responsibilities and duties may Emergency Control Organization, management, and be assigned in implementing procedures. support specialists shall include those listed below.

Additional responsibilities and duties may be assigned in implementing procedures.

33. 3.1.1 Emergency Director 3.1 On-Site Emergency Control Organization Non-RIE As part of overall command and control of the event, the . From the moment he becomes aware of an Specified ED responsibilities Emergency Director coordinates the collection and emergency, an Emergency Operations Coordinator were organized and aligned to evaluation of information from the event location, (EOC) is responsible for coordinating emergency the current REP and SRP.

prioritizes response and mitigating activities of response activities. Also, eliminated terms for EOC dispatched personnel, and manages the Emergency 3.1.1 (( initial response phase and Control Center (ECC) and ERO in order to provide secondary response phase.

continuous assessment of the situation regarding the Establishing initial and secondary magnitude of the emergency, projected consequences, )) has the responsibility and authority to declare an emergency whenever, in his opinion, it is EOC responders provided a and effectiveness of the response measures taken. means for a seniority based warranted by an incident or condition that involves an Specifically, the Emergency Director has the overall actual or potential degradation of the level of safety of a augmentation and assumed two responsibility and authority for VNC emergency facility or the site. individuals be simultaneously response activities, including: available. The proposed REP The responsibility and authority for directing and does not require ERO relief

Classifying and declaring emergencies coordinating emergency response activities are based on seniority, but does not

Designating a location for the ECC, (( assigned to the Emergency Operations Coordinator prevent it if a more senior staff

)) (EOC). Duties and authorities of the EOC during initial member qualified as ED desires and secondary phases of an emergency are discussed to relieve the ED in charge of the

Ensuring notification of the VNC ERO and below.

augmenting as necessary event. Typically, a single ED 3.1.2 Emergency Operations Coordinator remains in charge until relieved

Ensuring notification of the appropriate offsite The EOC has the responsibility and authority for the by another ED for shift relief or agencies following: when the event is terminated. All

Mobilizing corporate and other support resources as 1. Initiation and implementation of the emergency plan EDs are trained and qualified to necessary and procedures, including declaring the emergency, fully perform the responsibilities

Coordinating response activities (including off-site notifying offsite agencies, and making protective of the position.

assistance if requested) to mitigate the action decisions, and coordination of emergency Refer to Changes #31 and #35 consequences of the event response activities of the Emergency Control for RIE discussion relaxing ED

Directing on-site protective actions to prevent or Organization (and off-site assistance) for the presence onsite 24/7.

minimize personnel hazard and injury duration of the declared emergency. These responsibilities can only be delegated to personnel

Authorizing reentry into facilities or areas that may qualified as an EOC.

have been evacuated during the emergency

2. The Initial Response EOC shall coordinate activities until relieved by the Secondary Response EOC; his duties and responsibilities include:

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

Authorizing volunteer emergency workers to incur a. Assessment of the indicated or reported radiation exposures in excess of normal situation and initiation of whatever action is occupational limits deemed necessary to minimize personnel injury

Escalating the emergency classification level or and property damage.

terminating the event b. Prompt notification of the Secondary Response These responsibilities can only be delegated to other EOC, if needed. Upon request by the personnel qualified as an Emergency Director. Secondary Response EOC, initiation of actions such as designating the location of the The Emergency Director is also responsible for Emergency Support Center; notifying Manager, providing holding statement information about the VNC and other Emergency Control emergency to the corporate communications and public Organization members and off-site support relations function for release to the news media and the agencies or personnel; and initiating public. implementation procedures.

c. Provide a status report and relinquish command to the Secondary Response EOC when he arrives on site.

3. Upon arrival on site and receipt of a status report from the Initial Response EOC, the Secondary Response EOC assumes all EOC responsibilities for implementation of the emergency plan and procedures including declaring the emergency, notifying offsite agencies, and making protective action decisions, and coordination of emergency response activities; his duties and responsibilities include:

a. Activation of emergency teams, if needed, and coordination of their activities.

b. Notification of appropriate management representatives, ancillary-advisory function personnel, and off-site agencies.

c. Coordination of the collection and evaluation of information from the emergency location, the special teams, the emergency communications center, management, and advisory personnel in order to provide continuous assessment of the situation regarding the magnitude of the emergency, projected consequences, and effectiveness of the control measures in progress.

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

d. Performance of specific duties designated as EOC responsibility in the emergency plan and procedures.

3.1.5.8 Off-Site Communications The EOC is responsible for providing information about the emergency to the communications and public relations function for release to the news media and the public.

34. 3.1.2 (( 3.1.5.6 (( Non-RIE Specified security position

)) in controlling access responsible for informing the

))on site. Emergency Director of an off to (( )). normal condition.

(( (( ))

communications center. The security force will

((

))of the nature and location of an emergency. The security force is

))

((

)).

35. 3.1.3 (( 3.1.3 (( RIE The proposed REP does not require an Emergency Director (previously titled EOC) to be on

)) This site 24/7.

position is the Initial Response EOC and will respond to an emergency and make an assessment. When acting

)). This includes dose assessments and as the Initial Response EOC, this position is responsible recommendation of on-site protective actions as for immediate corrective and protective action and for appropriate. calling for assistance if required. If assistance is required for corrective and protective action or additional assessment action, (( )) is responsible for directing these activities until relieved by

(( )) or his emergency response alternate. ((

] absent from the emergency communications center, a designated individual (site security or other personnel) will be responsible for communication; (( ))

Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 15 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type will ((

)).

((

))

will advise the EOC on radiological survey and assessment, personnel decontamination, and facility decontamination. This includes on-site and off-site dose assessments and recommendation of protective actions as appropriate.

36. 3.1.4 (( 3.1.4 (( )) Non-RIE The (( )) and Removed misleading statement

))repair/damage control teams associated authority to declare an emergency whenever, in his for the (( )) to with accident mitigation. The (( )) opinion, it is warranted by an incident or condition that declare an emergency (it is a assesses the personnel resources and technical skill involves an actual or potential degradation of safety in non-delegable responsibility of levels required to mitigate the emergency situation and his area. the Emergency Director).

requests augmentation of the ERO staff as appropriate. Specified the responsibilities of the (( )).

37. 3.1.4.1 (( 3.1.5.7 (( )) Non-RIE

(( )) in addition to Removed statement regarding

] to those assigned to the BET, may be called to respond to recovery phase, which is emergencies during normal working hours and may be emergencies during normal working hours and may be described in Section 9.

called in during off-hours to assist in emergencies. called in during off-hours to assist in emergencies.

Appropriate maintenance and craft technicians in conjunction with a (( ))

may be used for recovery activities under the direction of the EOC or (( )).

38. 3.1.5 (( 3.1.5.1 (( )) Editorial The (( )) is responsible Administrative change - Moved

)) for for providing radiological engineering assessment of the program maintenance supporting assessment of the emergency and directing emergency and directing assessment, corrective, and responsibilities to Section 10.

assessment, corrective, and protective activities protective activities concerning criticality safety and concerning criticality safety and radiation protection. radiation protection. He also is responsible for coordinating and planning radiological emergency preparedness, updating the emergency plan, and coordinating plans with other appropriate organizations.

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39. 3.1.6 (( 3.1.5.2 (( Editorial Administrative change -

)) who will respond to an )) response activities which may include first Reworded heading and section emergency during normal working hours, communicate aid, radiation monitoring, and equipment operation and coordinator and team title and conditions and take local corrective and protective maintenance. The BET, under the direction of the description.

actions. If needed, the BET may be called in during off- (( )), is hours. The BET includes personnel trained to perform responsible for responding to an emergency during emergency response activities which may include first normal working hours and making initial assessment aid, radiation monitoring, and equipment operation and and corrective and protective actions. If needed, the maintenance particular to their facility. BET may be called in during off-hours. Upon involvement of the Initial Response EOC, the BEC will work under his direction. The firefighting function is provided by a site fire team which responds to fires in all buildings.

40. 3.1.6.1 (( 3.1.5.5 (( Editorial

)) at an Grammar change.

)) They are responsible evacuation assembly area. He is responsible for for communicating with the BEC and for accounting for communicating with the BEC and for accounting for all all personnel who work in the evacuated area. personnel who work in the evacuated area.

41. 3.1.7 (( )) 3.1.5.4 (( Non-RIE

(( )) when )) Reworded paragraph to describe onsite and may be called in during off-hours. They are training of designated personnel assigned to the site fire site fire response as it applies to the REP.

(( team. The ((

))during normal working hours and may be called Removed training statement as that is governed under a

)). in during off-hours. He is responsible for assisting and separate fire protection program

(( advising the BEC and the EOC in matters involving and industrial safety regulations.

firefighting efforts. The fire team will attack incipient-stage fires only. Fires which have progressed or

)) Fires threaten to progress to the interior structural fire stage which have progressed or threaten to progress to the must be handled by off-site assistance.

interior structural fire stage or during off-hours will be handled by off-site assistance.

42. 3.2 Off-Site Agencies Editorial Federal, state and local agency response assistance is Administrative change - Added not anticipated since no radiological event at VNC is introduction paragraph to clarify capable of reaching a level requiring protection of the support role of offsite agencies public (local source term resulting in a release of regarding the VNC REP.

radioactivity is not sufficient to result in exposure which exceed EPA PAG levels beyond the site boundary).

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type Offsite agencies are notified of declared emergencies as described in Section 7.

43. 3.2.1 Federal Agencies Editorial Control, responsibility and interface of federal Administrative change - Added organizations is governed by the National Response description of NRC role for REP Framework (NRF) and the Nuclear/Radiological Incident declared events.

Annex to the NRF when they are notified of an event at a nuclear research or test reactor facility.

The NRC acts as the lead federal agency with regard to technical matters during a nuclear incident including radiological assistance. The NRC maintains an Incident Response Plan (IRP). The IRP objectives are to provide for protection of the public health and safety, property, and the environment, from the effects of radiological incidents that may occur at licensed facilities. The objectives of the agency plan set forth the organizational and management concepts and responsibilities needed to assure that NRC has an effective emergency response program.

Department of Homeland Security (DHS) may provide leadership capabilities in the event there are incidents related to security.

44. 3.2.2 State Agencies Editorial The California Office of Emergency Services (OES) is Administrative change - Added the state authority for coordination of all state response. description of State role for REP Cal OES is also the primary state response agency that declared events.

coordinates the state's response to requests for assistance from local jurisdictions.

If an event is of significant magnitude to require establishment of a near site Incident Command Post (ICP), it will be established through Cal OES and the Emergency Director will communicate with and potentially provide a liaison to the ICP to assist in coordinating response efforts.

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45. 3.3 Off-Site Support Organizations 3.2 Off-Site Agencies Editorial Certain supporting services that may be needed during Certain supporting services that may be needed during Administrative change -

or after a radiological emergency are available from or after a radiological emergency are available from Changed the title to provide local off-site organizations. These services are local off-site agencies. These services are described distinction between offsite described below. below. governmental agencies that may response from a regulatory perspective and offsite service providers that support VNC response activities.

46. 3.3.1 First Aid Assistance 3.2.2 First Aid Assistance Non-RIE First aid assistance is available through the Alameda Additional first aid assistance is available from the Revised description to reflect the County Office of Emergency Services dispatcher (911). California Department of Forestry & Fire Protection, offsite agency process to Typically, local fire Emergency Medical Service (EMS) Alameda County Sheriffs Department, and the State of responding to requests for units are sent to respond for first aid related issues. California Highway Patrol. medical assistance at the site.

However, other trained personal, such as from local law Added commitment for enforcement, may be dispatched for first aid service as maintenance of a written determined by the county dispatch process. agreement with organizations A written agreement is maintained with local emergency that would provide medical medical services for assistance that would be requested services on-site (within the VNC to come on-site. security area).

47. 3.3.2 Medical Treatment Facilities 3.1.5.3 Medical Services RIE Access to local area medical facilities and professional An occupational health care clinic is located The proposed REP removes care for radiation-exposed or contaminated individuals approximately 15 miles from the site for routine care of specific information regarding the requiring medical treatment is provided through written occupational injuries or illnesses beyond that provided location and name of the medical agreement with a private professional organization. by on-site first aiders. If the nature of the emergency or services treatment facilities.

injury warrants, 911 is called and injured personnel are transported via ambulance to one of several local area emergency rooms. Regulatory Compliance maintains the written agreement regarding off-site treatment of injured personnel that are radioactively contaminated.

3.2.1 Medical Treatment Facilities

(( )) will provide medical facilities and care for radiation-exposed or contaminated individuals requiring medical treatment.

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48. 3.3.3 Ambulance Service 3.2.3 Ambulance Service Non-RIE Ambulance service is available through the Alameda Ambulance service is available from a county Revised description to reflect the County Office of Emergency Services dispatcher (911). emergency dispatcher (911). offsite agency process to for If the nature of the emergency or injury warrants, 911 is dispatching an ambulance to the called and injured personnel are transported via site.

ambulance to one of several local area medical Added commitment for facilities. maintenance of a written A written agreement is maintained with a local private agreement with organizations ambulance service company regarding transport of that would provide ambulance injured or ill personnel to an offsite medical treatment services on-site (within the VNC facility, who may be contaminated. security area).

49. 3.3.4 Firefighting Assistance 3.2.4 Firefighting Assistance Non-RIE When needed, a request for firefighting assistance will VNC has off-site firefighting assistance from the Revised description to reflect the be made through the Alameda County Office of participants in the California Fire Service and Rescue offsite agency process to Emergency Services dispatcher (911). Emergency Mutual Aid Plan. Typically, the primary responding to requests for Assistance for VNC is provided by the participants in the response will be from the (( firefighting at the site.

California Fire Service and Rescue Emergency Mutual Added commitment for Aid Plan. Typically, the primary response will be from maintenance of a written Alameda County Fire Services. If additional assistance agreement with organizations beyond the county capability is needed, personnel and that would provide firefighting equipment are requested through the California services on-site (within the VNC Department of Forestry & Fire Protection (CDF). security area).

A written agreement is maintained with local fire services for assistance that would be requested to come on-site. )).

50. 3.3.5 Police Assistance 3.2.5 Police Assistance Non-RIE Police assistance is available for law enforcement Police assistance is available for off-site traffic and/or Removed specific agency titles activities and off-site traffic and/or crowd control from crowd control (( as law enforcement agencies county and state law enforcement agencies with )). maintain interagency agreements jurisdiction over the areas and roadway surrounding for coordination that can use VNC. interjurisdictional resources.

A written agreement is maintained with local law Added commitment for enforcement for assistance that would be requested to maintenance of a written come on-site. agreement with organizations that would provide firefighting services on-site (within the VNC security area).

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51. 4 EMERGENCY CLASSIFICATION SYSTEM Editorial Planning Standard (ANSI/ANS-15.16 Section 3.4 & Administrative change -

NUREG-0849 Section 4.0) Planning Standard wording The emergency plan shall describe several classes of added to provide basis emergency situations covering the spectrum of information directly within the emergency conditions that involve the alerting or emergency plan.

activating of progressively larger segments of the emergency organization. To provide for improved communications between the licensee or owner/operator and federal, state, and local agencies and organizations, the most severe accidents are standardized in four classes of emergency conditions that group the accidents according to the severity of off-site radiological consequences. Each emergency plan shall include only those standard classes appropriate for dealing with accident consequences determined to be credible for the specific facility.

Each class of emergency should be associated with particular emergency action levels and with particular immediate actions to provide appropriate graded response.

52. This plan is based on the classification system 4.0 EMERGENCY CLASSIFICATION SYSTEM Editorial described in ANSI/ANS-15.16-2015. Events are This plan uses the classification system described in Administrative change - Updated standardized in four classes of emergency conditions ANSI/ANS Standard 15.16-1982, Emergency Planning basis reference and reworded which group them according to the severity of off-site for Research Reactors, and the revised Appendix I to paragraph.

radiological consequences. These classes in order of NUREG-0849, Standard Review Plan for the Review increasing severity are: and Evaluation of Emergency Plans for Research and

Unusual Event Test Reactors. These standards characterize several classes of emergency situations that involve the alerting

Alert or activating of progressively larger segments of the

Site Area Emergency emergency organization. Events are standardized in

General Emergency four classes of emergency conditions which group them according to the severity of off-site radiological All four classes are included in this section of the consequences. These classes in order of increasing emergency plan for completeness even though credible severity are:

radiological accident consequences for NTR are covered by the first two classes.

Notification of Unusual Events (NOUE)

Alert

Site Area Emergency

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type All four classes are included in this section of the emergency plan for completeness even though credible accident consequences are covered adequately by the first three classes. No credible accident sequences exist for the General Emergency classification level.

53. 4.1 Unusual Event 4.1 Notification of Unusual Events (NOUE) Editorial Unusual events may be initiated by either man made Notification of unusual events may be initiated by either Administrative change -

events or natural phenomena that can be recognized as man-made events or natural phenomena that can be Reworded ERO response creating a significant hazard potential that was recognized as creating a significant hazard potential paragraph for clarity.

previously nonexistent. There is usually time available that was previously nonexistent. There is usually time Relocated initiating condition to to take precautionary and corrective steps to prevent available to take precautionary and corrective steps to be with the EAL technical bases the escalation of the accident or to mitigate the prevent the escalation of the accident or to mitigate the descriptions in Section 5.

consequences should it occur. No releases of consequences should it occur. No releases of radioactive material requiring off-site responses are radioactive material requiring off-site responses are expected. expected.

Although the situation may not have caused damage to One or more elements of the emergency organization the reactor, it may warrant an immediate shutdown of are likely to be activated or notified to increase the state the reactor or interruption of nonessential routine of readiness as warranted by the circumstances.

functions. Although the situation may not have caused damage to The ED ERO position will be activated, with other ERO the reactor, it may warrant an immediate shutdown of positions potentially notified to increase the state of the reactor or interruption of nonessential routine readiness as warranted by the circumstances. functions. Situations that may lead to this class include:

(a) threats to or breaches of security, such as bomb threats or civil disturbances directed toward the reactor; (b) natural phenomena such as tornados in the immediate vicinity of the reactor, hurricanes, or earthquakes felt in the facility; and (c) facility emergencies such as prolonged fires, fuel damage indicated by high coolant fission product activity, or high off-gas activity.

During Unusual Events, there is usually time available to take precautionary and corrective steps to prevent the escalation of the unusual event or to mitigate the consequences should it occur. It is not expected that there will be a release of radioactive material requiring off-site response.

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54. Actions taken in response to this emergency class are: 5.1 Notification of Unusual Event Action Levels Non-RIE Actions taken in response to this emergency class are: Revised particular immediate

1. Notify State and NRC of Unusual Event emergency (1) Ensure that the first step in any response later found actions that provide appropriate declaration per Section 7.1.2 to be necessary has been carried out graded response as called for in

2. Augment ERO resources if needed (2) Bring the operating staff to a state of readiness. the ANSI standard.

3. Assess and respond (3) Provide systematic handling of unusual events

4. Escalate to a more severe class, if appropriate information and decision making.

or Terminate the emergency with verbal summary to offsite authorities

55. 4.2 Alert 4.2 Alert Editorial Events leading to an Alert would be of such radiological Events leading to an alert would be of such radiological Administrative change -

significance as to require notification of the GE and off- significance as to require notification of the emergency Reworded ERO response site emergency organizations and their response as organization and its response as appropriate for the paragraph for clarity.

appropriate for the specific emergency situation. Under specific emergency situation. Under this class, it is Relocated initiating condition to this class, it is unlikely that off-site response or unlikely that off-site response or monitoring would be be with the EAL technical bases monitoring would be necessary. Reactor shutdown is a necessary. Substantial modification of reactor operating descriptions in Section 5.

highly probable response action. Protective evacuations status is a highly probable corrective action. Protective or isolation of certain areas within the operations evacuations or isolation of certain areas within the boundary or within the site boundary may be necessary. operations boundary or within the site boundary may be necessary. Situations that may lead to this class include: (a) severe failure of fuel cladding or of fueled experiments where containment boundaries exist to reduce releases or less severe cladding failures in situations where fission products are not well contained; and (b) significant releases of radioactive materials as a result of experiment failures.

56. Actions taken in response to this emergency class are: 5.2 Alert Action Levels Non-RIE Actions taken in response to this emergency class are: Revised particular immediate

1. Notify State and NRC of Alert emergency (1) Ensure that emergency personnel are readily actions that provide appropriate declaration per Section 7.1.2 available to respond if the situation becomes more graded response as called for in

2. Augment ERO resources and staff the ECC serious or to perform confirmatory radiation monitoring if the ANSI standard.

3. Dispatch on-site monitoring teams required.

4. Assess and respond (2) Provide current off-site authorities with status

5. Make staff available for consultation with NRC and information.

State on a periodic basis

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type offsite authorities

57. 4.3 Site Area Emergency 4.3 Site Area Emergency RIE A site area emergency may be initiated when events A site area emergency may be initiated when events The proposed REP does not such as major damage of fuel or cladding and actual or such as (( include the Site Area Emergency imminent failure of other physical barriers containing classification level.

fission products in reactor fuel or fueled experiments ))

have occurred, and projected off-site radiological have occurred, and projected off-site radiological consequences exceed action levels in section 5.0. consequences exceed action levels in section 5.0.

Monitoring at the site boundary should be conducted to Monitoring at the site boundary should be conducted to assess the need for off-site protective actions. assess the need for off-site protective actions.

Protective measures on-site may be necessary. Protective measures on-site may be necessary.

The results of NTR Safety Analysis Report (SAR)

Section 13 accident analyses show that there are no

((

credible events that could cause fuel melt or a significant release of fission products from the fuel.

Even if catastrophic non-mechanistic failure of the NTR facilities is assumed, there are no potential consequences more severe than those associated with the accidents analyzed in SAR Chapter 13.

SAR Section 13.5.3.1 provides radiological consequence analysis of accidental explosions. ))

Assuming a 1% release and stable atmospheric 5.3 Site Area Emergency Action Levels conditions (inversion), maximum site boundary doses Actions taken in response to this emergency class are:

are less than 20 mRem to the thyroid and 1 mRem to (1) Ensure that response centers are manned.

the whole body under this combination of (2) Ensure that monitoring teams are dispatched.

circumstances.

(3) Ensure that personnel required for evacuation of on-SAR Table 13-3 provides dose summaries for site site areas are at duty stations.

boundary exposure to the NTR Design Basis Accident (4) Provide consultation with off-site authorities.

(DBA), which is an experiment accident event. Total Body 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months submersion dose is 4.54E-3 Rem (4.5 (5) Provide information for the public through off-site mRem) and CDE Thyroid is 1.61E-1 Rem (161 mRem). authorities.

The limiting EAL exposure threshold is for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

((

))

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58. 4.4 General Emergency 4.4 General Emergency Editorial A general emergency may be initiated by accidents that A general emergency may be initiated by accidents that Administrative change - Added result in an uncontrolled release of radioactive material result in an uncontrolled release of radioactive material reference to the location of the into the air, water, or ground to the extent that protective into the air, water, or ground to the extent that protective technical basis that the GE actions off-site may be necessary. This class of actions off-site may be necessary. This class of classification level is not accident is not credible for most research reactors. accident is not credible for most research reactors. applicable to VNC.

Therefore, most research reactors would not include Therefore, most research reactors would not include this class as part of their emergency plans. this class as part of their emergency plans. No credible Refer to the technical basis in Section 4.3, Site Area accident situation has been identified at the Vallecitos Emergency, documenting that the NTR radiological Site, which approaches the General Emergency action source term is insufficient to meet the level of Site Area levels.

Emergency or General Emergency classification levels.

59. 5 EMERGENCY ACTION LEVELS Editorial Planning Standard (ANSI/ANS-15.16 Section 3.5 & Administrative change -

NUREG-0849 Section 5.0) Planning Standard wording Because of the wide diversity of research reactors added to provide basis (power level, engineered safety features, site information directly within the environment, etc.), those conditions that might initiate or emergency plan.

signal a radiological incident having particular off-site consequences will vary widely among facilities. Action levels should be established in terms of effluent monitors or other plant parameters from which the dose rates and radiological effluent releases at the site boundary can be projected.

To establish effluent action levels, facilities that have meteorological information available may base the action levels on actual meteorological conditions; otherwise, the criteria to be used for downwind concentration should be taken from ANSI/ANS-15.7-1977; R1986 (withdrawn), Research Reactor Site Evaluation, Sec. 4, Criteria for Downwind Concentration [3]. Each emergency plan shall establish EALs appropriate for the specific facility and consistent with Table 1.

The emergency plan shall include EALs to initiate protective actions for members of the general public and facility staff on-site.

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60. 5.0 EMERGENCY ACTION LEVELS Editorial The basis for establishing emergency action levels for Administrative change -

each class of emergency is the potential off-site Removed introduction paragraph radiological exposure. Action levels are described below which was replaced by planning for each of the three classes of emergencies that are standard wording.

assumed to be possible at VNC reactor facilities. The General Emergency class emergency is not considered credible. Events or conditions which might initiate or signal a radiological incident of each class emergency are listed below.

61. 5.1 Unusual Event 5.1 Notification of Unusual Event Action Levels RIE 5.2 Alert 5.2 Alert Action Levels The proposed REP does not 5.3 Site Area Emergency Action Levels include EAL thresholds for facilities other than NTR and the SAFSTOR reactor facilities.

62. 6 EMERGENCY PLANNING ZONES (EPZs) Editorial Planning Standard (ANSI/ANS-15.16 Section 3.6 & Administrative change -

NUREG-0849 Section 6.0) Planning Standard wording As part of emergency planning, the reactor licensee or added to provide basis owner/operator of a facility that identifies radiological information directly within the emergencies that result in off-site plume exposures emergency plan.

exceeding 10 mSv deep dose (1 rem whole body) or 50 mSv (5 rem) thyroid shall identify an EPZ.

The postulated radioactive releases from credible accidents provide the basis for determining the need for an EPZ. The EPZ size depends on the distance at which the protective actions are calculated to be warranted. As an alternative to performing such calculations, the EPZ sizes in Table 2 may be adopted according to the power level. Table 2 is based upon highly conservative dose calculations that are generically applicable to research reactors.

63. 6.0 EMERGENCY PLANNING ZONES (EPZS) Editorial In accordance with ANSI/ANS 15.16-1982, Emergency Administrative change -

Planning for Research Reactors, Section 3.6, the Reference to the basis moved operations boundary is defined as the EPZ boundary for under the applicable facility each reactor facility. For purposes of this plan, the description.

following are the operations boundaries for the radiological facilities:

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64. 6.1 NTR EPZ The maximum operating power for the NTR is 100 kW. Non-RIE Per the NTR Safety Analysis Report Section 1.1, the * (( Revised NTR operational NTR is licensed to operate at power levels not in excess boundary to Building 105 since of 100 kW (thermal). )) areas not occupied by the NTR Thus, based upon ANSI/ANS-15.16-2015 Section 3.6 facilities are not isolable.

and Table 2, the applicable EPZ for NTR is the operations boundary for the reactor facility.

The NTR operations boundary is established as

(( )).

65. 6.2 GETR, VBWR, and EVESR EPZs The other three reactor facilities are in a deactivated Editorial The other three reactor facilities are in a defueled status. Administrative change - Clarified SAFSTOR status with the spent fuel no longer

GETR, VBWR, and EVESR - reactor building SAFSTOR facility operational remaining on site. boundary. boundary from reactor building Since the emergency planning requirements for these to containment enclosure as facilities are deferred to this VNC Regulatory Guide 2.6 correct terminology.

emergency plan, their EPZ is based on the same specification as the NTR.

GETR, VBWR, and EVESR operations boundaries are established as their respective reactor containment enclosure.

66.

B102 - Building 102 boundary RIE

B103 - Building 103 boundary The proposed REP removes

B106 - Radiological Equipment Calibration Shop EPZs for buildings that do not Boundary apply to the REP and do not have a regulatory requirement for an emergency plan.

67. 7 EMERGENCY RESPONSE Editorial Planning Standard (ANSI/ANS-15.16 Section 3.7 & Administrative change -

NUREG-0849 Section 7.0) Planning Standard wording Emergency response measures shall be identified for added to provide basis each emergency. These response measures should be information directly within the related to the emergency class and action levels that emergency plan.

specify what measures are to be implemented.

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68. 7.0 EMERGENCY RESPONSE Editorial The response to emergency situations at VNC reactor Administrative change -

facilities is accomplished by activating the Emergency Removed introduction paragraph Control Organization (described in Section 3.0). The which was replaced by planning Building Emergency Team assesses the emergency standard wording.

and initiates immediate corrective and protective actions. Continuing assessment is directed by the EOC.

The EOC is responsible for classifying the emergency and notifying any off-site authorities if required.

Instructions for response of the emergency control organization are provided in the document, Site Emergency Procedures - Vallecitos Nuclear Center.

Where necessary, more detailed instructions will be provided for the specific facility.

69. 7.1 Activation of Emergency Organizations Editorial Site Emergency Procedures (SEPs) are established for Administrative change - added notification and mobilization of emergency response general wording to the parent personnel. section to state details of mobilization for how to implement the following subsections are contained in procedures.

70. 7.1.1 Notification of Onsite Personnel and 7.1 Activation of Emergency Control Organization Non-RIE Mobilization of the ERO The response to emergency situations is typically Revised paragraph to clarify Notification of onsite personnel occurs each time an initiated (( notification and mobilization of emergency classification level is declared by the ERO personnel, and included Emergency Director (initial event declaration and any )). During normal reference to the REP section that escalation) via (( working hours, the site emergency personnel are details the commitments to the process.

notified (( )).

Refer to Changes #31 and #35

(( for RIE discussion relaxing ED

)). presence onsite 24/7.

Provisions are made to alert personnel in high noise areas and outbuildings as applicable.

))

Notification and mobilization of the VNC ERO is described in section 3.1.

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71. 7.1.2 (( 3.2.6 Federal and State Agencies RIE

)) The NRC and State of CA will be notified of any The proposed REP specifies the radiological emergency in accordance with the time requirement for State

(( ))is declared requirements of Title 10 of the Code of Federal notification (( )).

or upgraded, initial notifications are made to continually Regulations, Part 20, and the applicable NRC license The original through to the

(( )). and Title 17, California Code of Regulations. current REP is silent on a time

(( commitment. Regulation calls for 15 minutes.

))1. State Agencies (Cal OES)

Cal OES is notified (( )) of an event declaration (initial or an escalation).

2. Nuclear Regulatory Commission (NRC)

The NRC is notified immediately after notification of Cal OES ((

)) declaration (initial or an escalation).

72. 7.1.3 (( Non-RIE Added specific items required on the event notification form based on SRP elements.

))

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73. 7.2 Assessment Actions Editorial 7.2.1 Plant Parameters and Corresponding Administrative change - added Emergency Classification general wording and reference to Recognizable EAL thresholds have been developed in REP section 5 content regarding accordance with Regulatory Guide 2.6 and the NRC how EAL thresholds are integral endorsed methodology in ANSI/ANS-15.16-2015 (refer to assessment actions (in to section 5). alignment with ANSI standard).

EAL technical bases document the VNC site specific indications and parameters used to determine the thresholds that correlate to a particular emergency classification level (refer to section 5).

74. 7.2.2 Onsite Accident Assessment Capabilities 7.2 Assessment Actions Non-RIE On-site capabilities and resources are available to Effective coordination and direction of all elements of Reworded paragraph to better provide information for accident assessment throughout the Emergency Control Organization require continued describe methods, systems, and the course of an event. Data will be obtained from in- assessment and evaluation of the emergency situation. equipment for gathering and place radiation monitors, portable instrumentation, and For emergency situations which have the potential to processing information and data.

from observation and measurement by specific release radioactive material, information relating to: Information regarding exposure emergency teams. (1) the magnitude of the release, to onsite personnel is contained Radiological instrumentation readings and sampling are (2) the area and amount of resulting contamination, and in REP Section 7.4 (Change used to project dose rates at the Site Boundary, and to #80).

(3) exposure to personnel will dictate the actions taken.

determine the integrated dose received for events involving a release of radioactivity. Site emergency Data will be obtained from in-place radiation monitors, procedures address calculating accumulated or portable instrumentation, and by observation and projected dose. measurement by specific emergency teams. The emergency classification will be changed as appropriate based on current information.

75. 7.3 Corrective Actions 7.3 Corrective Actions Non-RIE VNC has strategies for mitigation of designated For major disruptions such as a fire or earthquake, the Reworded paragraph to emergencies (such as radiological, fire, security threat, Emergency Control Organization is activated and is encompass all types of events and other hazards) and has equipment available to be responsible for taking corrective actions such as that apply to the REP.

used in those strategies/mitigative actions. firefighting, deactivation of process systems or The Emergency Director is responsible for assessing restoration of disabled equipment needed to mitigate the need for and directing mitigation activities such as the consequences of the emergency.

deactivation of process systems or restoration of disabled equipment needed to mitigate the consequences of an emergency. Additional assistance may be provided by other ERO positions upon arrival or via remote communications.

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

76. 7.4 Protective Actions 7.4 Protective Actions Editorial Preventive measures are implemented, to the extent Emergency situations can result in potential exposure of Administrative change - revised practical, to prevent exposure of on-site personnel to on-site personnel to radiological hazards. Preventive wording to better describe radiological hazards; and in the event that prevention measures are implemented, to the extent practical, to protective actions in general and techniques fail, protective measures are in place to prevent exposure of on-site personnel to radiological as introduction to subsequent minimize the effects of such emergencies. hazards; and in the event that prevention techniques subsections.

Protective measures are taken by ERO personnel and fail, protective measures are preplanned to mitigate the any support organization personnel called to the site. effects of such emergencies. Protection must be Initial actions to protect non-emergency team personnel provided not only to the community of GE employees, may involve evacuation from facilities followed by but also to members of the emergency response team.

search for and rescue of missing persons, medical Initial action to protect nonemergency team personnel treatment, decontamination, and other actions judged may involve evacuation from the building followed by appropriate by the Emergency Director dependent on rescue of injured/trapped persons, medical treatment, existing conditions. decontamination, and other actions judged appropriate by the EOC dependent on the character of the emergency in progress.

77. 7.4.1 Personnel Evacuation from Immediate Area 7.4.1 Personnel Evacuation from Immediate Area Non-RIE Personnel may be evacuated from an area affected by Personnel may be evacuated from an area affected by Revised wording to provide an emergency or moved to areas controlled for safety an emergency. The evacuation is initiated by additional process detail purposes. The evacuation is initiated by (( (( consistent with the ANSI

)). )). (( )) immediately evacuate the standard.

Typically, personnel evacuate their facility by following building and go to the designated assembly area.

established routes to a pre-designated assembly area, Additional instructions may be relayed by the EOC which is posted in each facility. Alternate routes and/or ((

alternate assembly areas may be determined and directed by the Building Emergency Coordinator if travel )).

to or conditions at the designated assembly area are The Assembly Leader shall conduct interviews with hazardous. The Building Emergency Teams will assist persons at the assembly area to account for missing in the orderly evacuation of facilities. Additional employees; security personnel will identify visitors.

instructions may be relayed by the Emergency Director Reports of missing persons shall be relayed to the EOC

(( for appropriate action.

)).

The Assembly Area Leader from the Building Emergency Team will conduct personnel accountability at the assembly area to determine whether there missing employees; security personnel will identify visitors that were expected to be at that location.

Reports of missing persons are relayed to the Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 31 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type Emergency Director for appropriate search and rescue action.

78. 7.4.2 Contamination Control Measures 7.4.4 Contamination Control Measures Non-RIE In response to an emergency involving a potential In response to any emergency situation involving Revised wording to provide release of radioactive material, it is assumed that a potential release of radioactive material, it is always additional process detail and release has occurred. The ERO establishes access assumed that a release has occurred. The Building improve organization of controls to the area (such as rope/tape barriers, building Emergency Team or the EOC controls access to the information (such as moving access points, postings, control point watches, periodic area, determines if radioactive contamination is present, SCBA and PPC information into announcements, etc.), determines whether radioactive and takes appropriate steps to identify affected areas this one section).

contamination is present by survey, and takes and control exposure to or spread of radioactive appropriate steps to limit personnel exposure to and the contamination. Contaminated individuals are treated spread of radioactive contamination. Area and decontaminated in isolated areas.

contamination information is provided to the Emergency Director and tracked by the ERO.

Emergency workers are protected from contamination by protective clothing available in emergency supply lockers. In order to protect emergency workers in areas of radioactive airborne contamination, self-contained breathing apparatuses (SCBA) or filtered respirators are available for use as appropriate.

Contaminated individuals are treated and decontaminated in isolated areas.

79. 7.4.3 Personnel Decontamination/First Aid 7.4.5 Personnel Decontamination/First Aid Editorial Individuals are surveyed and then decontaminated as Individuals are surveyed and then decontaminated or Administrative change - revised necessary. If an individual is contaminated and injured, administered first aid. The order of decontamination/first wording for clarity regarding the order of decontamination/first aid administration is aid administration is dependent on the severity of the contaminate injured priority (does dependent on the severity of the contamination and contamination and injury. The criteria for deciding the not presuppose a contaminated injury. The criteria for deciding the order is that which is order is that which is least detrimental to the overall individual is injured.

least detrimental to the overall health of the individual. health of the individual.

80. 7.4.4 Emergency Exposure Control and Guidelines 7.4.2 Emergency Exposure Control Non-RIE Identification and control of radiation areas is performed In order to protect emergency workers from airborne Revised wording to update PAG the same as described in Section 7.4.2 for radioactive contaminants, self-contained breathing apparatuses basis EAP reference and to contamination. Measures and criteria for radiation, high (SCBA) are available for their use. improve organization of radiation and locked high radiation areas encountered Emergency workers are protected from unnecessary information (such as moving during a declared emergency are established the same contamination by protective clothing available in SCBA and PPC information into as those used during normal operations as much as emergency supply lockers. previous section).

possible.

Direct exposures of emergency workers are monitored Direct exposures of emergency workers are monitored by remote area monitoring (RAM) devices, portable by remote area monitoring (RAM) devices, portable survey instruments, and by the individuals own survey instruments, and by the individuals own Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 32 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type personal monitoring devices (such as electronic personal monitoring devices. Information is provided to dosimeters). A supply of electronic dosimeters that can the EOC.

be set to alarm for dose and dose rate values are 7.4.3 Emergency Exposure Guidelines maintained on site for emergency worker use. The information provided in U.S EPA Manual of Personnel exposure information is provided to the Protective Action Guides for Nuclear Incidents EPA Emergency Director and tracked by the ERO. 520/1-75/001 was used to arrive at the guidance listed Emergency exposure guidelines for emergency in Table 1.

workers, consistent with EPA 400-R-92-001, Manual of Note: the Suggested Values (SV) listed in the table Protective Action Guides and Protective Actions for should be used except for situations in which local Nuclear Incidents, U.S. Environmental Protection constraints would make them impractical to use; in Agency, May 1992, Table 2-2, "Guidance on Dose those cases, the Maximum (Max) values may be used.

Limits for Workers Performing Emergency Services," [Table 1 - PAG for Limiting Exposure to Radiation and have been established as follows: Radioactive materials Under Emergency Conditions]

[Emergency exposure guidelines table]

81. 8 EMERGENCY FACILITIES AND EQUIPMENT Editorial Planning Standard (ANSI/ANS-15.16 Section 3.8 & Administrative change -

NUREG-0849 Section 8.0) Planning Standard wording The emergency plan should briefly describe the added to provide basis emergency facilities, types of equipment and their information directly within the location. emergency plan.

82. 8.0 EMERGENCY FACILITIES AND EQUIPMENT Editorial The Vallecitos Nuclear Center maintains extensive Administrative change -

facilities and inventory of equipment on site. These Removed introduction paragraph facilities and equipment are all available during an which was replaced by planning emergency, and some are reserved solely for standard wording.

emergency use.

83. 8.1 Emergency Control Center (ECC) 8.1 Emergency Support Center Editorial During an emergency (( (( Administrative change - Revised

))in (( description and title primary VNC response facility.

)). ((

))

((

)). The communications center will be occupied at all times. The EOC will designate adjacent areas which, along with the communications center, will be the emergency support center.

))

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

84. 8.2 Assessment Facilities 8.2 Assessment Facilities Editorial The reactor facilities are monitored by area radiation The reactor facilities at the site are appropriately Administrative change - Revised monitors (ARMs) and effluent radiation (stack) monitors monitored by direct radiation monitors and airborne description of facilities and as required by their technical specifications. Radiation radiation monitors. Industrial emergencies are also equipment for clarity.

monitors with remote readouts permit continuous monitored by such devices as fire alarms. These assessment in some areas. devices activate appropriate local or emergency Other monitoring devices are utilized to identify off- communications center alarms for immediate response normal conditions, such as smoke detectors, criticality, and assessment.

fire and flood alarms, and onsite and offsite seismic and Radiation monitors with remote readouts permit meteorological indicators. Several of these devices continuous assessment in some areas. Portable survey activate alarms locally and/(( )) for equipment and samplers and counting laboratories are immediate response and assessment. maintained on site.

Portable survey and personnel monitoring instruments Company vehicles are available for use by emergency are maintained throughout the site and are available for response personnel such as the ((

use during an emergency. Sampling equipment and )).

counting laboratories are available on site for specific Communication from the area experiencing the radionuclide identification and analysis. emergency is possible using the ((

Company vehicles are available for use by emergency response personnel. Communication from the area experiencing the emergency is possible using the )).

((

)).

85. 8.3 First Aid and Medical Facilities 8.3 First Aid and Medical Facilities Editorial The site contains numerous areas where radioactive The site contains numerous areas where radioactive Administrative change -

materials are used. Consequently, there are numerous materials are used. Consequently, there are numerous Reworded content for clarity and areas where contaminated injured individuals may be areas where injured contaminated individuals may be removed information regarding relocated for first aid administration and relocated for first aid administration and first aid trained personnel and decontamination. On site company vehicles are decontamination. Company vehicles are available for agreements which are contained available for transportation. transportation. in other sections of the REP.

First aid supplies, stretchers and industrial showers are A number of site employees are trained in first aid. First located around the site. aid supplies, stretchers and industrial showers are GEH will provide a radiation monitor to assist in the located around the site.

control and cleanup of contamination of ambulance and Regulatory Compliance maintains an agreement with a offsite medical facilities used when treating local area medical facility for emergency medical contaminated injured personal transported from the site treatment of contaminated or radiation exposed as necessary. individuals. GE will provide a radiation monitor to assist in the control and cleanup of contamination as necessary.

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

86. 8.4 (( )) 8.4 (( )) Editorial 8.4.1 (( )) 8.4.1 (( )) Title changes.

(( ((

))

87. 8.4.2 (( )) ((

((

))

88. 8.4.3 (( )) 8.4.2 (( )) Editorial

(( (( Title change.

)) .))

89. 8.4.4 (( )) 8.4.3 (( )) No Change

(( ((

)) ))

90. 8.4.5 (( )) 8.4.4 (( )) No Change

(( ((

)) .))

91. 8.4.6 (( 8.4.5 (( No Change

)) ))

(( ((

)) ))

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

92. 8.5 Contingency Planning Non-RIE Procedures include instructions for consideration in Added section to conform with case the emergency renders the ECC or equipment ANSI standard.

employed during the response unusable. The VNC site contains several facilities that can be designated response locations should the ECC be unavailable.

First-aid, personnel protective clothing, radiological, fire-fighting, etc. equipment and resources are maintained throughout the site such that access restrictions to a particular area would not likely result in the inability to perform necessary response activities.

Mutual aid agreements between offsite support agencies provides assurance that fire, medical and law enforcement resources would be available when called upon.

93. 9 RECOVERY Editorial Planning Standard (ANSI/ANS-15.16 Section 3.9 & Administrative change -

NUREG-0849 Section 9.0) Planning Standard wording This element of the emergency plan should describe the added to provide basis criteria for restoring the reactor facility to a safe status information directly within the including reentry into the reactor building or portions of emergency plan.

the facility that-may have been evacuated because of the accident. The operations to recover from most severe accidents will.be complex and depend on the actual conditions at the facility. It is not practicable to plan detailed recovery actions for all conceivable situations.

94. 9.0 RECOVERY Editorial While it is not practical or even possible to plan detailed Administrative change -

recovery actions for all conceivable situations, general Removed introduction paragraph criteria applicable to any recovery operation are which was replaced by planning presented. standard wording.

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

95. 9.1 Reentry 9.1 Re-entry Non-RIE During an emergency, immediate actions are directed Re-entry into an affected facility during an emergency Reworded re-entry content toward limiting the consequences of the accident to situation may be necessary to rescue injured or trapped contained in (and referenced to) afford maximum protection to personnel onsite. Once personnel and to limit the actual or potential release of other sections of the REP.

corrective measures have been taken and effective radioactive materials. In the case of a fire, re-entry may control of the facility has been reestablished, a more be necessary to effectively terminate the emergency.

methodical approach to reentry is taken. Reentry into Section 7 discusses exposure control and allowable two separate categories: exposure for emergency workers.

Reentry during the emergency phase of an accident is performed to save a life, control a release of radioactive material, prevent further damage to or restore equipment. If necessary, this category of reentry may be performed using emergency exposure limits. Briefings, rather than written procedures, may be used when making these reentries.

All reentry activities conducted during the emergency are authorized by the Emergency Director and coordinated by Incident Command.

Reentry during the recovery phase of an accident is performed using normal occupational exposure limits. Either normal procedures or procedures developed specifically for each reentry are used to control post-emergency activities.

Reentry activities during the recovery phase are authorized by a Recovery Director or the VNC Manager, and coordinated by the recovery personnel directing and performing the reentry.

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

96. 9.2 Recovery 9.2 System/Facility Restoration Non-RIE During a declared emergency, a point will be reached Detailed assessment is accomplished after termination Expanded REP content for when the facility will be restored to a stable condition. of the emergency to determine the extent of damage Recovery process that The Emergency Director will determine when there is no and the ability of the system/facility to contain encompasses termination of the longer a need to keep the ERO activated and the site radioactivity. Specific actions are taken to (1) minimize declared emergency in general can return to a normal organization for control. personnel exposure, (2) restore necessary equipment to terms in accordance with the The extent and nature of the corrective and protective an operational status, (3) insure further release of ANSI standard.

measures and the extent of facility recovery will depend radioactive material is prevented, and (4) Removed restoration and on the remaining conditions, if any, and the status of decontaminate affected areas to acceptable levels. The resumption of operation site areas and equipment. The general goals for restoration phase is continued to the extent required to information that does not apply to recovery are: restore the system/facility to a safe condition as a emergency response activities.

An orderly evaluation of the cause and effect of the minimum. Further repair, etc., will be accomplished event and the implementing of actions to prevent assuming that continued operation of the system/facility recurrence of the incident. is warranted.

A planned approach for maintaining the facility in a 9.3 Resumption of Operations stable condition by obtaining the appropriate Following even minor incidents where consequences manpower, materials, and equipment needed to (potential or actual) were inconsequential, at the request accomplish that end. of the Facility Manager or Manager, Regulatory Compliance, investigations are made to determine the

An evaluation of the emergency radiation exposure cause and to recommend appropriate actions to prevent records for all on-site emergency response recurrence. As the severity of an incident increases, personnel involved in the incident. regulations require reports be submitted, corrective

A planned approach to ensure that further radiation actions performed and, in some cases, require detailed exposures and contamination control are restored review of the incident by regulatory agencies prior to under 10 CFR 20 requirements and are in keeping resumption of operations.

with the ALARA program. These constraints are adequate to insure that a Procedures have been developed for the systematic system/facility will be returned to a safe operating transition from the declared state of emergency to condition and the engineered safety systems are recovery and termination. capable of performing their intended function prior to resumption of operations of a system/facility.

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type

97. 10 MAINTAINING EMERGENCY PREPAREDNESS Editorial Planning Standard (ANSI/ANS-15.16 Section 3.10 & Administrative change -

NUREG-0849 Section 10.0) Planning Standard wording The emergency plan shall describe the elements added to provide basis necessary for maintaining an acceptable state of information directly within the emergency preparedness. A description shall be emergency plan.

provided of how the effectiveness of the emergency plan will be maintained, including training, review, and update of the emergency plan and associated implementing procedures along with maintenance and inventory of equipment and supplies that would be used in emergencies. Frequent coordination with emergency support organizations should also be maintained to ensure the necessary training and the efficient use of their capabilities.

98. 10.1 Training and Drills 10.1 Training and Drills Non-RIE 10.1.1 Training Personnel are instructed in reporting and responding to Added detail regarding general ERO personnel receive the appropriate level of site alarms. Building Emergency Team members receive topics of REP training and basis access, radiological, communications systems, facility initial training and annual reviews in respiratory for its content.

evacuation, and position specific training. The training protection, radiological protection, first aid, fire for ERO personnel is primarily developed from the protection and emergency support as appropriate for position specific responsibilities and tasks as defined in their assigned responsibilities.

this plan and the site emergency procedures.

Emergency response and other personnel in the following categories receive knowledge and/or performance based training initially and annual retraining thereafter:

99. 1. Emergency Directors Non-RIE This position receives training to maintain proficiency on Added REP detail to conform the topics listed below: with ANSI standard.

Event Classification / Emergency Action Levels

Event Notification and Communications

Accident Assessment and Mitigation

Protective Actions / Emergency Exposure Control Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 39 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type 100. 2. Accident Assessment Personnel Non-RIE Accident assessment activities are performed by Added REP detail to conform Emergency Directors, Facilities Managers (as with ANSI standard.

applicable), and GEH operations, radiological, security and maintenance managers as a function of their areas of expertise and ERO roles.

101. 3. Radiological Monitoring and Analysis Teams Non-RIE Radiological monitoring personnel will receive training Added REP detail to conform for the actions they will be expected to perform during with ANSI standard.

an emergency as part of their training. The following general topics will be included in the training:

Equipment and Equipment Checks

Emergency Communications

Radiological Release Surveys and Sampling

Emergency Exposure Control 102. 4. First Aid and Rescue Personnel 8.3 First Aid and Medical Facilities Editorial A number of site employees are trained in first aid. . Moved content Basic search and rescue activities may be performed by A number of site employees are trained in first aid. . Non-RIE ERO personnel as part of event response. Added statement for basic search and rescue capability by VNC ERO.

103. 5. Medical Support Personnel Non-RIE VNC does not maintain medical support personnel, Added REP detail to conform such as a site nurse on staff. with ANSI standard.

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type 104. 6. Police, Security, Ambulance and Fire-Fighting and Non-RIE Other Personnel Added REP detail to conform a) Training of site security personnel is controlled with ANSI standard.

by the VNC Security Plan.

b) Building Emergency Team members receive initial training and annual reviews in respiratory protection, radiological protection, first aid, fire protection and emergency support as appropriate for their assigned responsibilities.

c) The Site Fire Chief is responsible for fire protection training of designated personnel assigned to the site fire team, which is controlled outside this emergency plan as defined by the site fire protection program.

d) Training is offered to the offsite support organizations that may be called upon to provide assistance in the event of an emergency (i.e., local law enforcement, fire-fighting, rescue, medical services, ambulance).

The training made available is designed to acquaint the participants with the special characteristics of VNC (e.g. potential radiation and radiological contamination areas),

notification procedures, and their expected roles.

Organizations that must enter the site also receive instructions as to the identity (by position and title) of those VNC persons who will control their support activities.

e) Badged site personnel who are not part of the ERO are instructed in reporting and responding to alarms.

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type 105. 10.1.2 Conduct of Drills 10.1 Training and Drills Non-RIE Drills are conducted annually to provide supervised Periodically, emergency drills are conducted to test the Added REP detail to conform instruction, training and practice opportunities for ERO adequacy of emergency plans and procedures. The with ANSI standard.

members and are executed as realistically as is drills will be planned and performed to specifically test reasonably possible. the following:

Written scenarios, prepared in advance, govern the

System for notification of personnel.

conduct of annual drill and include the following as

Prompt and effective evacuation of the involved applicable: facility or area.

General Information - A section containing the

Performance of the emergency organization.

scope of the scenario, time period, place(s), and participating organizations.

Availability of emergency equipment.

Timeline - A section containing the time schedule of

System for notification of off-site organizations.

initiating events. Drills are completed at least annually in each occupied

Messages - A section for plant data, injects, building at the VNC Site, drills are held to test the messages, and symptomology cards. integrated response of the on-site emergency control organization to simulated fire, Criticality and High

Onsite Radiological Data - A section for area Radiation. There will be an evacuation drill from all radiation maps and display system snapshots, if occupied buildings. At least every two years, drills are warranted by the scenario events. performed to test the system for notification of off-site

Objectives - A section containing a table of organizations.

performance objectives expected to be demonstrated during the scenario.

Participant/Controller/Evaluator/Observer Instructions - as applicable to the drill.

Smaller response proficiency drills, such as evacuation drills, may be performed in addition to the larger scope annual drill in each occupied building at VNC.

At least every two years, a drill shall be offered that contains provisions for coordination with off-site emergency personnel and should test, at a minimum, the communication links and notification procedures with those off-site agencies and support organizations.

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type 106. 10.1.3 Critique of Drills 10.1 Training and Drills Non-RIE Following the observation of drills, a critique is A critique is held for each drill performed. Lessons Added REP detail to conform conducted to evaluate areas such as personnel learned and pertinent observations will be identified and with ANSI standard.

performance, response procedure processes, and reported to management for evaluation. If appropriate, facility and equipment adequacy and identify issues. changes to emergency plans and procedures will be Specifically, the critique is performed as soon as made.

possible following the conclusion of a drill using preselected performance objectives that are evaluated against measurable demonstration criteria.

A written critique report is prepared a drill to document whether the objectives were successfully demonstrated.

Failed or degraded performance objectives are entered into the corrective action program (CAP). Failed or degraded demonstration criteria, improvement items and recommendations are dispositioned within the report and may be entered into the CAP.

107. 10.2 Plan Review and Update 3.1.1 Manager, Vallecitos Nuclear Center (VNC) Editorial 10.2.1 Responsibility for the Plan The Manager, VNC, is the senior GE employee on site. Administrative change -

The Manager, VNC is the senior GEH employee on site He or his delegated alternate has overall responsibility Changed titles and wording for with overall authority for site operations. This authority for emergency response and preparedness activities. clarity.

includes the responsibility for overall emergency His authority extends to that of enjoiner; and in the face preparedness activities at VNC. of conflict or indecision, his judgment is final.

The Manager, RC & EHS, is responsible for 10.2 Plan Review and Update administering the program by coordinating and planning . Responsibility for maintenance of this plan is radiological emergency preparedness, updating the assigned to the Regulatory Compliance Manager.

emergency plan, and coordinating plans with other appropriate organizations.

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Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type 108. 10.2 Plan Review and Update 10.2 Plan Review and Update Editorial 10.2.2 Review and Update A biennial review is made of this plan and the Administrative change - Added implementing procedures to assure that they reflect detail for review and update The Emergency Plan will be reviewed to be current on a current operations on the site. . requirements.

biennial basis, and updated if necessary. Any changes due to regulatory revisions, issues identified by drills Document control is achieved and assured by and exercises, or other updates will be incorporated into compliance with administrative procedures. This plan is the Emergency Plan. a controlled document. This document is required to be maintained on-site for NRC.

Agreements with supporting organizations will be reviewed on a biennial basis, and updated if necessary.

Changes to agreements may be coordinated with the biennial review of the Emergency Plan.

Emergency plan implementing and administrative procedures are reviewed biennially or when revised as needed.

Changes will be processed in accordance with 10 CFR 50.54(q) requirements and distributed per site procedures.

109. 10.3 Maintenance and Inventory of Emergency 10.3 Maintenance and Inventory of Radiological Non-RIE Equipment, Instrumentation, and Supplies Emergency Equipment, Instrumentation, and Added REP detail to conform In addition to supplies of normal use equipment and Supplies with ANSI standard.

instruments, emergency kits are maintained at VNC. A periodic audit of emergency equipment and supplies Annual inventories and quarterly surveillances are is performed. The audit will include follow-up action performed to verify supplies and kit contents, and items to correct any deficiencies discovered. Portable inspect and operationally check emergency use radiation monitoring instruments are calibrated upon equipment/instruments. The inventories will utilize the initial acquisition, after major maintenance and at least corrective action program to document follow-up action annually. Equipment which is not used routinely such as items that correct any deficiencies discovered. Sufficient the HICON phone is tested on a regular basis.

reserves of instruments and equipment are maintained to replace those removed from emergency kits or lockers for calibration or repair.

Requirements to operationally check emergency equipment and instruments prior to use, if needed, are contained in site procedures.

Requirements to calibrate emergency equipment and instruments are specified in site procedures.

Portable radiation monitoring instruments are calibrated upon initial acquisition, after major maintenance and at least annually. Radiation Protection is responsible for Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page 44 of 45 Current to Proposed Emergency Plan Comparison Review

Proposed Emergency Plan Current Emergency Plan (January 2018) Change Type the maintenance and storage of radiological equipment and instruments.

Proposed Emergency Plan Figure 3 VNC Emergency Response Organization and Support Interface Emergency Director Offsite Incident GEH Headquarters Command Emergency Response Offsite Response Support Support Nuclear / Licensing / Rad Safety / EHS Support Communications / Media Support Bldg Emergency Fire Chief & Fire Facilities Manager RC & EHS Manager Coordinator Team Nuclear / Licensing / Bldg Emergency Team Maintenance and Craft Rad Safety / Security / / Assembly Area Personnel EHS Personnel Leader Security-Related Information - Withhold from Public Disclosure per 10CFR2.390 Page45 of45 Current to Proposed Emergency Plan Comparison Review Current Emergency Plan Figure 3 - VNC Emergency Control Organization l ~ *** .

ergency INCIDENT COMMANDER jl.. ~,ri] ~* 'lffill'1j

~

I' I

rations Coordinator (EOC}

,-I I

GEH HQ, Wilmington, NC iI I

-r ~

i*

I I

__.. EMERGENCY RESPONSE SUPPORT OFF-SITE

RESPONSE

, I PERSONNEL BUILDING . "- ~*- ..

EMERGENCY COORDINATOR NUCLEAR/ LICENSING /

(BE C) * ~ 1 RADIOLOGICAL SAFETY/

EHSSUPPORT FACILITIES MANAGER Maintenance & Craft Support BUILDING EMERGENCY TEAM i COMMUNICATIONS/

(BET) ~ MEDIA SUPPORT Assembly Leader REGULATORY COMPLIANCE Fire Chief MANAGER Response Teams Nuclear, Radiological, EHS, Licensing, & Security Support L__ _ _

Ses~rit:y Related 1Rfe~ati9R \ftJitt:lt:lgld frgm P~blis Oisslgs~re per 1QCFR2.3QQ

ML19207A495

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SUMMARY

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1.0 INTRODUCTION

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RESPONSE

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ML19207A495

Text

SUMMARY

1.0 INTRODUCTION

1.0 INTRODUCTION

1.0 INTRODUCTION

1.0 INTRODUCTION

1.0 INTRODUCTION

RESPONSE

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