Text

Attachment 1 - Revised Emergency Plan Implementing Procedure
	ML21014A349
Person / Time
Site:	San Onofre
Issue date:	01/05/2021
From:	; Southern California Edison Co
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML21014A347	List: ML21014A348; ML21014A349; ML21014A350;
References
	Download: ML21014A349 (29)
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Attachment 1 Revised Emergency Plan Implementing Procedure

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~ 8 Reference Use Emergency Response Procedure Usage Requirements Review and understand the procedure before perfonning any steps, including the prerequisite section Have a copy or applicable pages/sections open at the work site.

Use Placekeeping method according to ADM-3 If any portion of the document 1s perfonned from memory, do so ir:i the sequence specrf1ed. Perfonn each step as written, except when an approved process specrfically allows deviation.

Refer to the procedure or instruction at least once to ensure completion of the task in accordance with the requirements.

Review the document at the completion of the task to verify that all appropnate steps are perfonned and documented.

NOT QA PROGRAM AFFECTING EPP-1 REVISION 1 Page 1. of_ 28 I

Sections Section 6.0, Procedure Type Procedure Owner Emergency Preparedness Kelli Galllon-Sholler INFORMATION USE

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~ 8 Page 2 of 28 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCO_PE.................................................................................................................... 3 2.0 RESPONSIBILITIES........... :... ;.......................................................................................................... 3 3.0 DEFINITIONS.................................................................................................................................... 4 4.0 PRECAUTIONS AND.LIMITATIONS.. ;........................................................ -..................................... 4 5.0 PREREQUISITES...................................................,........................................................................... 4 6.0 PROCEDURE..................................................................................................................................... 6 6.1 Assessment, Classification, and Declaration......................................................................... 5 6.2 Initial Notifications.................................................................................................................. 7 6.3 Abnormal Radiation Levels................................................................................................. 1 O 6.4 Event-Relate.d Radiological Release in Progress................................................................ 1 O 6.5 Contamination Detected............................................................... -...................................... 11 6.6 Contaminated Injury................................................................................................,............ 11 6.7 Emergency Authorization.............................................,...................................................... 12 6.8 Follow-Up Notifications.................................................................. _........ _............................... 13

6.9 Ongoing Coordination Actions.............................................................................................. 14 6.1 O On site Protective Actions..................................................................................................... 16

. 6.11 Mitigative Actions............................................................... :................................................ 18 6.12 Shift Turnover....................................................................................................................... 19 6.13 Emergency Termination and Recovery lnitiation.................................................................. 21 7.0 ACCEPTANCE CRITERIA.............................................................................................................. 23 8.0 RETENTION OF RECORDS........................................................................................................... 23

9.0 REFERENCES

/ COMMITMENTS.................................................................................................. 23 ATTACHMENT 1

Recovery......................................................................................................................................... 25 2

Summary of Changes.................................................................................................................... 28 INFORMATION USE

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~ 8 Page 3 of 28 1.0 PURPOSE AND SCOPE 1.1 Provide guidance to the Emergency Response Organization for responding to an emergen_cy at the SONGS Independent Spent Fuel Storage Installation (ISFSI).

1.2 Provide guidance to the ISFSI Shift Supervisor (ISS) / Emergency Director (ED) for assessing, classifying, and declaring emergencies.

1.3 Provide guidance on making emergency notifications.

1.4 Provide guidance on implementing the ISFSI-Only Emergency Plan (IOEP) for events at the SONGS ISFSI.

2.0 RESPONSIBILITIES 2.1 The ISS is responsible for* initial assessment, classification, and declaration of emergencies.

2.2 The ISS will, upon declaration of an emergency, assume the responsibilities of the ED. The ED has the authority and responsibility to immediately and unilaterally initiate any emergency actions and control access to the site. The ED can assign members of the on-shift organization to cany out prioritized actions as described in this procedure.

2.3

!E necessary to facilitate response to emergency conditions, THEN th~ ED has the authority and responsibility to immediately and unilaterally suspend any security measure described in the Physical Security Plan or any license condition or technical specification in accordance with 10 CFR 50.54(x) and (y).

2.4 IF the ISS is unavailable or incapacitated, THEN -another on-shift person qualified as ED will assume the ED duties.

2.5 The ISS/ED is responsible for the following actions:

2.5.1 Non-delegable responsibilities:

Classifying and declaring emergencies Authorizing notification of offsite agencies (State and local government agencies, Marine Corps Base Camp Pendleton, and NRC notifications)

Authorizing the use of EPA-400 emergency exposure controls (emergency worker dose limits that exceed 10 CFR 20 occup_ational exposure limits) per EP EEA, Emergency Exposure Authorization INFORMATION USE

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~s Page 4 of 28 2.5.2 Key delegable responsibilities:

Managing available station resources Initiating assessment and mitigative/corrective actions Initiating protective actions within the Exclusion Area Boundary (EAB)

Deciding to call for offsite law enforcement, firefighting, search and rescue or ambulance assistance using EP ERO, Emergency Response Directory Augmenting the Emergency Response Organization as deemed necessary using EP ERO, Emergency Response Directory Notifying SCE corporate officers and the SCE Corporate Communications Department using EP ERO, Emergency Response Directory Notifying offsite agencies (State*and local government agencies, Marine Corps Base Camp Pendleton, and NRC) using EP SNF, SONGS Notification Form, and NRC Form 361, Reactor Plant Event Notification Worksheet Maintaining a record of event activities and decisions made (Reference EP ELS, ERO Logbook) 2.6 The Resource Manager (RM) is responsible for the following actions:

Being available to assist the ISS/ED within two hours of a declared emergency.

Assisting the ED with assessment and tasks Assisting the ED to supplement the ERO as deemed necessary Coordinating supplemental personnel and resources to support the emergency response Maintaining a record of ~vent activities and decisions made (Reference EP ELS, ERO Logbook) 3.0 DEFINITIONS None 4.0 PRECAUTIONS AND LIMITATIONS 4.1 None 5.0 PREREQUISITES 5.1 None INFORMATION USE

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~s Page 5 of 28 REFERENCE USE 6.0 PROCEDURE 6.1 Assessment. Classification, and Declaration NOTE

1.

Emergency declaration is required to be made as soon as possible once information warranting classification is available, AND within 30 minutes in all cases.

2.

T = O for classification: When information that ISFSI conditions have met an EAL is available to the ISS.

6.1.1 IF an off-normal, natural phenomenon, or accident event becomes apparent, THEN ASSESS the condition using available indications, verbal reports, and/or radiological survey.

6.1.2 IF performing a radiological survey, THEN PERFORM the following:

NOTE Steps 6.1.2 1, 6.1.2.2, and 6.1.2.3 may be performed concurrently or in any order.

6.1.2.1 6.1.2.2 6.1.2.2.1 6.1.2.2.2 6.1.2.3 6.1 2.4 REFERENCE USE OBTAIN a TLD (located in ISFSI Emergency Kit).

OBTAIN an electronic dosimeter with a display reading "ENTER" (located in ISFSI Emergency Kit).

DEPRESS the black square button to start the dosimeter monitoring dose (the dosimeter chirp rate is set to 1 mrem and the alarm setpoint is 500 mrem.)

VERIFY the display reads "d 0.0", or similar, indicating that the Dosimeter is measuring dose.

OBTAIN radiation monitoring equipment (located in ISFSI Emergency Kit)

PERFORM surveys using EP CBA, Confinement Boundary Assessment.

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6.1.2.5 6.1.2.6 6.1.3 6.1.4 6.1.5 6.1.6 6.1.6.1 6.1.6.2 6.1.7 EPP-1 Emergency Response REVISION 1 Page 6 of 28

!E dose rates exceed an EAL threshold, THEN PERFORM a radiological release assessment in the vicinity of the affected storage module or cask using open-window vs. closed-window readings downwind on a beta-gamma instrument (reference IOEP-1 Section 9.0).

!Ea radiological event is In progress, THEN do NOT delay actions to PERFORM OR DIRECT performance of Section 6.3, Abnormal Radiation Levels, and Section 6.4, Event-Related Radiological Release in Progress.

REVIEW IOEP-2, SONGS ISFSI-Only Emergency Plan EAL Technical Bases Manual, to determine whether conditions warrant an emergency classification.

!E time permits, THEN OBTAIN an independent verification for emergency classification from a qualified individual.

!E conditions do NOT meet the criteria to declare an emergency,

, THEN EXIT this procedure.

!E conditions do meet the criteria to declare. an emergency, THEN PERFORM the following:

CLASSIFY AND DECLARE the emergency event within 30 minutes of conditions being present AND recognizable.

RECOijD the event classification: ____ _

RECORD the time the event was classified.

(!E an independent verification was obtained, THEN ENTER the time when the classification was agreed upon.): _____ _

ASSUME the duties of ED.

START AND MAINTAIN a log of events and decisions (Reference EP ELB, ERO Logbook).

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~s Page 7 of 28 6.2 Initial Notifications 6.2.1 NOTIFY station personnel of the emergency declaration AND response actions via radio using EP SPA, Station Protective Action Notification.

6.2.1.1 RECORD the time radio notification was completed: _____ _

6.2.1.2 IF there are known personnel working in ISFSI high noise areas or outbuildings, THEN DIRECT available personnel to notify them.

6.2.2 ENSURE Courtesy Notification email is completed within 15 minutes of emergency declaration:

6.2.2.1 COMPLETE EP SNF, SONGS Notification F~rm.

6.2.2.2 CREATE an Email with subject line: "SONGS Emergency Notification."

6.2.2.3 SEND EP SNF, SONGS Notification Fann, to group email list "SONGS Emergency Notification" within 15 minutes of emergency declaration.

6.2.2.4 RECORD the time email was sent: _____ _

6.2.3 TRANSMIT information to station personnel via Alert Media using EP SPA, Station Protective Action Notification, as a guide.

6.2.3.1 RECORD the time notification was transmitted: ------

6.2.4 ENSURE the Security Shift Supervisor has control of access to the site (station) at the Site Boundary (fences and gates) as directed by the ED.

6.2.5 CONTACT the on-duty RM as soon as possible, AND within two hours of emergency declaration.

6.2.5.1 RECORD the time RM was contacted: ------

6.2.5.2 REVIEW event details with the RM.

6.2.5.3 IF the declared emergency is due to initiating condition E-HU1, THEN REQUEST the RM to assist in interpreting the radiological release assessment results.

6.2.5.4 DIRECT the RM to perfonn actions needed in support of the emergency.

6.2.5.5 IF the declared emergency involves radiological consequences (E-HU1),

REFERENCE USE THEN DIRECT the RM to ensure a minimum of one person trained in radiological monitoring and assessment reports to the Emergency Response Facility (ERF) within four hours of the emergency declaration.

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~B Page 8 of 28 NOTE

1.

Verbal Notifications to State and local government agencies, Marine Corps Base Camp Pendleton, and to the NRC are required within 60 minutes of emergency declaration, escalation, or change in radiological release status.

2.

Verbal Notifications will be performed primarily via commercial telephone.

Cellular and/or satellite phones may be used as the back-up means of communication.

6.2.6 CALL the following agencies within 60 minutes of emergency declaration, AND ENSURE EP SNF, SONGS Notification Form, was received and understood:

6.2.6.1 IF an agency reports that EP SNF, SONGS Notification Form, was NOT received, THEN verbally PROVIDE them the information from the completed form.

6.2.6.1.1 RECORD the time each notification is completed:

AGENCY TIME State of California (Cal OES)

Orange County San Diego County Marine Corps Base Camp Pendleton 6.2.7 COMPLETE NRC Form 361, Reactor Plant Event Notification Worksheet.

6.2.7.1 CALL the NRC Headquarters Operations Officer (HOO) immediately after notification of the appropriate State and local offsite agencies and Marine Corps Base Camp Pendleton, AND within 60 minutes of emergency declaration.

6.2.7.2 RECORD the time NRC HOO was contacted: ____ _

6.2.7.3 PROVIDE the information on the completed NRC Form 361, Reactor Plant Event Notification Worksheet.

6.2.8 CALL SCE Corporate Communications Department, AND ENSURE EP SNF, SONGS Notification Form, was received and understood.

6.2.8.1 REVIEW event details.

6.2.8.2 VERIFY SCE Corporate Communications Department accepts responsibility to notify SCE Corporate Officers in accordance with Corporate Communications Guideline.

6.2.8.3 RECORD the time SCE Corporate Communications call was completed: _____ _

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SONGS 6.2.9 6.2.9.1 EPP-1 Emergency Response REVISION 1 Page 9 of 28 ENSURE supplemental personnel are called in as needed using EP ERO, Emergency Response Directory.

PERSONNEL FUNCTION DIRECT the called-in supplemental personnel to report to the:

[] ERF

[] other ________________________ _

6.2.9.2 ADVISE the called-in supplemental personnel of any areas to avoid upon arrival.

6.2.10

!Ethe declared emergency is an Alert, THEN ENSURE American Nuclear Insurers (ANI) is nottfied, AND requests for assistance are made as necessary.

6.2.10.1 RECORD the time ANI was notified: ____ _

6.2.11 CONDUCT a formal briefing per Step 6.9.4.

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~s Page 10 of 28 6.3 Abnormal Radiation Levels 6.4 6.3.1 PERFORM OR DIRECT perfonnance of radiological surveys.

6.3.2 ENSURE an RP Technician is dispatched to establish access controls to any Radiation Areas or Contamination Areas 6.3.3 ENSURE exposure accountability is maintained AND proper personnel radiological monitoring equipment is provided for personnel during emergency conditions.

6.3.4 ENSURE access to High Radiation Areas is only permitted with prior approval.

6.3.5 ENSURE personnel are NOT allowed to enter known or potential High Radiation Areas unless their exposure has been properly evaluated.

Event-Related Radiological Release in Progress 6.4.1 6.4.1.1 6.4.1.2 6.4.1.3 6.4.1.4 6.4.2 6.4.2 1

!Ethe declared emergency involves radiological consequences (e.g., E-HU1),

THEN ENSURE an RP Technician is dispatched to measure downwind dose rates at the Site Boundary within the EAB (refer to map in the ERO notebook)

ENSURE the RP Technician reports to the ERF prior to deployment to test radiological survey equipment that will be used.

ENSURE the RP Technician is provided a briefing.

ENSURE communications with the RP Technician are performed via radio or cell phones.

TRACK the following:

Personnel dispatched Time dispatched Location(s) while dispatched Time personnel return Radiation dose received IF dose rates greater than background are measured at the Site Boundary (along Old Hwy 101), THEN ENSURE an RP Technician is dispatched to measure downwind dose rates at the EAB.

!Ethe downwind direction is towards the ocean, THEN the dose rates at the Site Boundary are considered as the does rates at the EAB.

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~ SONGS 6.4.3 6.4.3.1 6.4.4 6.4.5 EPP-1 Emergency Response REVISION 1 Page 11 of 28

!E dose rates greater than background are measured at the EAB, THEN ENSURE an RP Technician is dispatched to perform offsite field monitoring.

CONSIDER implementing appropriate onsite protective actions per Section 6.10, Onsite Protective Actions, and obtaining additional resources.

!E uncontrolled releases of radioactivity have occurred, THEN PROHIBIT eating and drinking until habitability surveys indicate that such activities are permissible.

DIRECT the RP Technician to evaluate ongoing radiological conditions.

6.5 Contamination Detected 6.5.1 6.5.2 6.5.2.1 6.5.3 RESTRICT access to contaminated areas.

ADHERE to normal station contamination control criteria as much as possible.

IF conditions warrant, THEN these criteria may be modified.

DIRECT an RP Technician 'to perform radiological surveys, AND release of areas, material, and/or personnel in accordance with SDS-RP1-PCD-1001, SDS-RP1-PCD-1004, SDS-RP1-PCD-1005, and SDS-RP1-PCD-3001.

6.6 Contaminated Injury Transportation of injured personnel is available via local emergency medical services, SONGS vehicles, -0r private vehicles.

6.6.1 IF a contaminated injury occurs, THEN DIRECT an RP Technician to decontaminate the injured individual before transportation and accompany the victim to prevent the further spread of contamination, as long as the activity does NOT interfere with providing medical attention or cause an unnecessary delay in transporting the injured person in accordance with SDS-RP1-PCD-1004.

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6. 7 Emergency Authorization 6.7.1 6.7.1.1 6.7.2 6.7.2.1 IF it is necessary to exceed normal occupational radiation exposure limits (5 Rem TEDE) to save a life, protect the puplic, or save vital equipment, THEN AUTHORIZE emergency exposure limits using EP EEA, Emergency Exposure Authorization.

LOG names of individuals on the completed EP EEA, Emergency Exposure Authorization.

IF necessary to facilitate response to emergency conditions, THEN SUSPEND any security measure described In the Physical Security Plan in accordance with 10 CFR 50.54(x) and (y).

NOTIFY the NRC as soon as practical, AND in all cases within 60 minutes of the occurrence of any deviation from the station's Physical Security Plan authorized pursuant 10 CFR 50.54(x) using NRC Form 361, Reactor Plant Event Notification Worksheet.

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Emergency Response REVISION 1 SONGS Page 13 of 28 6.8 Follow-Up Notifications 6.8.1 Unless it is interrupted by an event reclassification, ENSURE Follow-up Notifications are completed Within 60 minutes of a change in radiological release status; OR Wrthin 60 minutes of a significant change in event status as determined by the ED AND Every two hours after completion of the last notification (Initial or Follow-up) 6.8.1.1 COMPLETE EP SNF, SONGS Notification Form.

6.8.1.2 CREA TE an Email with subject line: "SONGS Emergency Notification."

6.8.1.3 SEND EP SNF, SONGS Notification Fonn, to group email list "SONGS Emergency Notification" within two hours of previous notification, OR when conditions change.

6.8.1.4 CONTACT the following agencies AND ENSURE EP SNF, SONGS Notification Form, was received and understood:

6.8.1.4.1 IF an agency reports that EP SNF, SONGS Notification Form, was NOT received, THEN verbally PROVIDE them the infonnat1on from the completed fonn.

6.8.1.4.2 RECORD the time each notification is completed:

AGENCY TIME State of California (Cal OES)

Oranae Countv San Dieao Countv Marine Corps Base Camp Pendleton 6.8.1.5 CONDUCT a formal briefing per Step 6.9.4.

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~..,:,.,..~8c Page 14 of 28 6.9 Ongoing Coordination Actions 6.9.1 MAINTAIN a log of events and decisions (Reference EP ELB, ERO Logbook).

6.9.2 IF onsite protective actions are required due to the emergency (refer to Section 6.10, Onsite Protective Actions), THEN NOTIFY station personnel using EP SPA, Station Protective Action Notification, AND DIRECT Marine Corps Base Camp Pendleton to notify the public beyond the SONGS Site Boundary, but within the EAB.

6.9.3

!E assembly is warranted, THEN NOTIFY station personnel of assembly AND location of assembly area using EP SPA, Station Protective Action Notification.

6.9.3.1 DIRECT Security to provide accountability of individuals remaining within the ISFSI Protected Area within 60 minutes of emergency declaration AND account for all individuals within the ISFSI Protected Area continuously thereafter.

6.9.3.1.1 DIRECT Security to contact assembled personnel AND provide event status and direction.

6.9.3.1.2 DISPATCH teams to locate personnel who are unaccounted for.

6.9.4

coNDUCT formal briefing after initial AND follow-up notifications using the following guidance:

Current Emergency Classification Level [Alert or Unusual Event]

Current Emergency Action Level The current hazards The onsite p~otective actions Actions being taken AND the associated priorities Additional resources or personnel needed The potential event escalation criteria 6.9.5 ASSESS staffing needs AND ENSURE personnel are called in as required using EP ERO, Emergency Response Directory:

RM Supplemental personnel REFERENCE USE

6.9.5.1 6.9.6 6.9.6.1 Emergency Response EPP-1 REVISION 1 Page 15 of 28 ENSURE supplemental personnel are briefed/trained (including Just-In-Time training) commensurate with the situation and task to be performed, including radiological/ other specific hazards, and Visitor/Escort responsibilities for personnel who are NOT badged for unescorted ISFSI PA access.

ESTABLISH AND MAINTAIN communications with dispatched personnel regarding change in emergency status or conditions.

TRACK the following:

Personnel dispatched Time dispatched Location(s) while dispatched Time personnel return Radiation dose received 6.9.7 IF the event is currently classified as a UE, THEN ASSESS conditions continually for possible escalation to. an Alert.

6.9.8 ASSESS conditions and available ISFSI parameters to determine the status of spent fuel. Consider the following:

6.9.9 6.9.9.1 6.9.9.2 6.9.10 Are the spent fuel canisters adequately cooled?

Are there any conditions that threaten the ability to cool spent fuel canisters?

Are there any conditions threatening the physical integrity of the spent fuel, canisters or associated radiation shielding?

IF necessary for radiological assessment of the event, THEN PERFORM OR DIRECT performance of radiological surveys (refer to Sections 6.3, Abnormal Radiation Levels, and 6.4, Event-Related Radiological Release in Progress).

IF dispatching teams from the ERF is required, THEN PROVIDE a briefing, including communications method, to personnel being dispatched.

TRACK the following:

Personnel dispatched Time dispatched

_ Location(s) while dispatched Time personnel return Radiation dose received ASSESS any security issues threatening normal ISFSI operations.

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SONGS Page 16 of 28 6.10 Onsite Protective Actions 6.10.1 MAINTAIN awareness of any conditions that may require taking protective actions for station personnel and personnel located within the EAB. Conditions may include:

Hostile Action Increasing Radiation Levels Airborne Hazards (radioactive or hazardous gases)

Fires Spill of hazardous materials Flooding Structural Damage Security issues Any other condition which may present a hazard to personnel REFERENCE USE

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~ 8 6:10.2 EPP-1 Emergency Response REVISION 1 Page 17 of 28 DIRECT appropriate protective actions, including but not limited to:

Relocation of personnel during Hostile Action Personnel take cover during Hostile Action Precautionary dismissal of non-essential personnel Relocation of personnel from the ISFSI Protected Area per Section 6.9, Ongoing Coordination Actions Relocation of non-essential personnel from within the EAB Assembling onsite personnel relocated from the ISFSI Protected Area per Section 6.9, Ongoing Coordination Actions Accounting for personnel inside the ISFSI Protected Area within 60 minutes of declaration of an emergency per Section 6.9, Ongoing Coordination Actions Maintaining accountability of assembled personnel per Section 6.9, Ongoing Coordination Actions Dispatching teams to lo_cate personnel who are unaccounted for per Section 6.9, Ongoing Coordination Actions Search and rescue Monitoring of relocated personnel for radiological contamination AND applying contamination control measures if radiological contamination is found Controlling onsite access to potentially radiologically contaminated potable water and food supplies Restricting access to contaminated areas and items Contamination Controls (during emergency conditions, normal ISFSI contamination control criteria will be adhered to as much as possible; however, these limits may be modified should conditions warrant)

Relocating AND treating onsite injured personnel, including potentially contaminated personnel Use of protective clothing 6.10.3 IF relocation of personnel from within the EAB is required, THEN CONTACT the Marine Corps Base Camp Pendleton.

6.10.3.1 DIRECT relocation of personnel from within the EAB, AND establishment of EAB access control.

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~ 8 Page 18 of 28 6.10.4 IF dispatching teams from the ERF, THEN PROVIDE a briefing, including communications method, to personnel being dispatched.

6.10.4.1 TRACK the following:

Personnel dispatched Time dispatched Location(s) while dispatched Time personnel return Radiation dose received 6.11 Mitigative Actions NOTE The ED is authorized to request Federal assistance as needed. The Nuclear Regulatory Commission (NRG) will act as the lead Federal agency providing coordination and support in response to a nuclear incident.

6.11.1 DETERMINE appropriate actions required to mitigate the effects of the event with input from RP Technicians and/or other technical support (if available).

6.11 2 IF necessary to mitigate the event, THEN OBTAIN needed resources to perfonn mitigative actions, AND radiation protection duties.

6.11 3 DIRECT mitigative actions.

6.11.4

!E dispatching teams from the ERF, THEN PROVIDE a briefing, including communications method, to personnel being dispatched.

6.11.4.1 TRACK the following:

Personnel dispatched Time dispatched Location(s) while dispatched Time personnel return Radiation dose received REFERENCE USE

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~_i.~s Page 19 of 28 6.12 Shift Turnover 6.12.1 DEVELOP an ERO relief shift roster approximately two hours prior to shift turnover using the table below as a guideline.

6.12.1.1 Security personnel can be obtained from the already_scheduled watch bill.

ENTER "Scheduled" in the DATE/TIME CALLED column ENTER scheduled reporting time in DATE/TIME REPORTING column 6.12.1.2 For other personnel, ENSURE incoming relief shift personnel:

Are qualified to fill the ERO positions.

Have been called in (use EP ERO or Alert Media for contact infom,ation)

(ENTER date and time contacted in DATE/TIME CALLED column)

Will report as requested (ENTER planned reporting time in DATE/TIME REPORTING column)

POSITION / QUALIFICATION INCOMING RELIEF SHIFT DATE/TIME DATE/TIME (Name or N/A If not required.)

CALLED REPORTING ISFSI Shift Supervisor (ERP 101)

Security Supervisor (ERP 101)

Security Officer (ERP 102)

Resource Manager (ERP 103)

RP Support (per SOS training program)

Other supplemental personnel:

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~;,..:.;.Cos 6.12.2 6.12.3 6.12.4 6.12.5 6.12.6 Emergency Response REVIEW the following items with the oncoming ERO:

Completed forms Current ISFSl/site conditions Additional EAL thresholds met Current protective actions Mitigative actions in progress Numbers AND names of ERO and support personnel onsite ERO Logbook ANNOUNCE turnover of responsibilities to the ERF (ED, only).

REPORT turnover of responsibilities to the ED (RM, only).

EPP-1 REVISION 1 Page 20 of 28 PROVIDE TLD and electronic dosimeter to Radiation Protection personnel.

LOG the time of turnover of responsibilities.

REFERENCE USE

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~s Page 21 of 28 6.13 Emergency Termination and Recovery Initiation 6.13.1 6.13.2 6.13.3 6.13.4 WI-IEN all of the following conditions are met, THEN TERMINATE the emergency, AND INITIATE Recovery.

Conditions do NOT continue to meet the criteria to declare an emergency Any event-related radiological releases have been stopped Conditions are stable OR improving Site radiation levels are stable AND decreasing wrth time Any fire, flooding, security issues, or similar emergency conditions are under control OR no longer exist Any previously met EAL threshold criteria have been evaluated SONGS Manager, ISFSI has been notified of the impending emergency termination AND Recovery initiation ANNOUNCE emergency termination AND Recovery initiation to the ERF.

LOG the time of emergency termination AND Recovery initiation.

NOTIFY station personnel of the following using EP SPA, Station Protective Action Notification:

Emergency termination

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Recovery initiation Response actions 6.13.5 NOTIFY the active ERO of emergency termination AND Recovery initiation.

6.13.5 1 RELEASE the active ERO.

6.13.6 ENSURE notification of emergency termination AND Recovery initiation is completed within 60 minutes:

6.13.6.1 COMPLETE EP SNF, SONGS Notification Form 6.13.6.2 CREA TE an Email with subject line: "SONGS Emergency Notification "

6.13.6.3 SEND the EP SNF, SONGS Notification Form, to group Email: "SONGS Emergency Notification."

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, 6.13.6.4 CONTACT the following agencies within 60 minutes of emergency tennination, AND ENSURE EP SNF, SONGS Notification Form, was received and understood:

6.13.6.4.1 IF an agency reports that EP SNF, SONGS Notification Form, was NOT received, THEN verbally PROVIDE them the information from the completed form.

6.13.6.4.2 RECORD the time each notification is completed:

AGENCY TIME State of California (Cal OES)

OranQe County San Dieao County Marine Corps Base Camp Pendleton 6.13.6.5 COMPLETE NRC Form 361, Reactor Plant Event Notification Worksheet.

6.13.6.6 CONTACT the NRC HOO immediately after notification of the appropriate State and local offsite agencies and Marine Corps Base Camp Pendleton.

6.13.6. 7 PROVIDE the emergency tennination AND Recovery initiation information on the completed NRC Form 361, Reactor Plant Event Notification Worksheet.

6.13. 7 COORDINATE with SCE Corporate Communications Department to review emergency termination details.

6.13.8 MEET with the SONGS Manager, ISFSI to determine who will fill the Recovery Director position.

6.13.9 DIRECT the Recovery Director to implement Recovery per Attachment 1.

6.13.1 O ENSURE all documentation pertaining to the event (e.g., logs, procedures, attachments, completed forms, checklists, etc.) is assembled and organized.

6.13.11 PROVIDE TLD and electronic dosimeter to Radiation Protection personnel.

6.13.11.1 REVIEW documentation for completeness and accuracy.

6.13.11.2 PROVIDE documentation to the Emergency Preparedness Manager.

6.13.12 PARTICIPATE in post-event critiques/ reviews.

REFERENCE USE

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Emergency Response REVISION 1 SONGS Page 23 of 28 INFORMATION USE 7.0 ACCEPTANCE CRITERIA 7.1 None 8.0 RETENTION OF RECORDS 8.1 Emergency Response Records shall be maintained in EP files for a period of six years.

9.0 REFERENCES

/ COMMITMENTS 9.1 Implementing References 9.1.1 Procedures 9.1.1.1 ADM-3, Human Performance Program 9.1.1.2 SDS-RP1-PCD-1001, Radiological Surveys 9.1.1.3 SDS-RP1-PCD-1004, Survey and Release of Personnel 9.1.1.4 SDS-RP1-PCD-1005, Radiological Posting and Controls 9.1.1.5 SDS-RP1-PCD-3001, Material Release Surveys 9.1.2 Forms 9.1.2.1 EP CBA, Confinement Boundary Assessment 9.1.2.2 EP EEA, Emergency Exposure Authorization 9.1.2.3 EP ELB, ERO Logbook 9.1.2.4 EP ERO, Emergency Response Directory 9.1.2.5 EP SNF, SONGS Notification Form 9.1.2.6 EP SPA, Station Protective Action Notification 9.1.2.7 NRC Form 361, Reactor Plant Event Notification Worksheet INFORMATION USE

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Emergency Response REVISION 1

~s Page 24 of 28 9.2 Developmental References 9.2.1 Commitments 9.2.1.1 IOEP-1, SONGS ISFSI-Only Emergency Plan 9.2.1.2 IOEP-2, SONGS ISFSI-Only Emergency Plan EAL Technical Bases Manual 9.2.2 Procedures 9.2.2.1 EPP-2, Emergency Preparedness Program Maintenance 9.2.2.2 SDS-PM1-PLN-0008, SOS Site Communication and Reportability Plan 9.2.2.3 SDS-RP3-PCD-1001, Dosimetry Issue, Change Out, and Processing 9.2.2.4 SDS-RP3-PGD-1007, Dose Limit Extension 9.2.2.5 SDS-RP3-PCD-1014, Radiation Monitoring and Exposure Controls 9.2.2.6 SDS-RP3-PGM-1000, Site Radiological Access and Personnel Monitoring Program 9.2.2.7 SDS-RP4-PCD-1018, MGPI Electronic Dosimeters INFORMATION USE

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EPP-1 Emergency Response REVISION 1

~s Page 25 of 28 Recovery I Attachment 1 1.0 1.1 1.2 NOTE

1.

The Emergency Director (ED) will detem,ine when there is no longer a need to keep the ERO in effect. The ED will terminate the emergency AND initiate Recovery.

2.

The extent and nature of the corrective and protective measures and the extent of Recovery will depend on the emergency conditions experienced and the status of the ISFSI facilities and equipment. The general goals for Recovery are.

An evaluation of the cause and effect of the emergency and the implementation of solutions to prevent the immediate recurrence of the emergency.

A planned approach for returning the ISFSI to a stable condition by obtaining the appropriate resources An evaluation of the radiation exposure records for all onsite emergency response personnel involved in the emergency.

Ensuring radiation exposures and contamination control meet ALARA requirements.

RECOVERY PLAN DEVELOPMENT (SONGS Manager, ISFSI Responsibility)

ASSIGN a Recovery Director.

COORDINATE with the Recovery Director to gain full understanding of the emergency.

1.2.1 COLLECT documentation of the emergency (logs, fom,s, procedures, etc.) from the Emergency Preparedness Manager.

1.2.2 REVIEW documentation of the emergency (logs, forms, procedures, etc.) with the Recovery Director.

1.2.3 CONDUCT interviews with ERO members.

REFERENCE USE Page 1 of 3

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EPP-1

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Emergency Response REVISION 1

~s Page 26 of 28 Recovery I Attachment 1 1.3 ASSESS Recovery Plan requirements with the Recovery Director, based on understanding of the emergency, considering:

Equipment to be repaired or replaced Licensing implications Special training requirements Offsite support Determination of causes AND consequences 1.4 DEVELOP a Recovery Plan outline (checklist and timeline) with the Recovery Director, based on topical areas:

Physical Security Radiological conditions Non-radiological hazards Equipment repair/replacement Regulatory requirements (e.g., notification and reporting requirements)

Coordination of offsite resources (e.g., engineering consultants, workforce, specialized equipment/vehicles, etc )

Senior Management status updates News media releases (coordinated with SCE Corporate Communications Department) 2.0 RECOVERY ORGANIZATION (Recovery Director Responsibility) 2.1 DEVELOP a Recovery organization based on normal SONGS organizations and functions with the SONGS Manager, ISFSI being responsible for site activities.

2.2 AUGMENT the SONGS organizations with offsite resources as they are obtained.

REFERENCE USE Page 2 of 3

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~s Emergency Response Recovery 3.0 RECOVERY PLAN IMPLEMENTATION (SONGS Manager, ISFSI Responsibility)

DIRECT the Recovery Director to implement the Recovery Plan.

MONITOR the Recovery Plan implementation activities.

REVISE OR HALT activities as circumstances dictate EPP-1 REVISION 1 Page 27 of 28 I Attachment 1 3.1 3.2 3.3 3.4 3.5 REPORT status of Recovery Plan progress to SONGS co-participants and NRC, as requested.

WHEN the ISFSI has been returned to a stable condition, AND ALL Recovery Plan steps have been completed, THEN TERMINATE Recovery.

REFERENCE USE Page 3 of 3

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EPP-1 tl8To~

Emergency Response REVISION 1

~s Page 28 of 28 Summary of Changes I Attachment 2 Author.

Lucia Sischo I Frank Grovich AR Tracking 50.54(q):

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0820-76520 Added steps to ensure that the electronic dosimeter is ready and Page 5 monitoring dose rates.

0920-50190 Added steps to develop an ERO relief roster and call in required Page 19 personnel.

0920-50142 Clanfled that fonnal briefings are required after initial and Pages 9, 13, 14 follow-up notifications, and added steps to perfonn bnefmgs.

All 0920-38223 Added steps to document the event classification and time of the Page 6 classification 0920-10835 Clarified conditions for perfonning Follow-up Not1flcat1ons Page 13 Bettennent Changed SOS Mass Notification System to Alert Media Page 7 Recfufr'kd R*~yfewE?r:s

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Emergency Plan 50 54(q)

APPLIES Lucia Sischo Physical Secunty Plan 50.54(p)

DNA Fire Protection 50.48(f)

DNA 50 59 DNA 72.48 DNA Cyber Security DNA Nuclear Oversight DNA Procedure Owner or designee Lucia Sischo

otner,Reviewers '.

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Security Rob Doeing Shift Manager Tim Cusick t**,

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Cognizant Supervisor NIA for Revision Nuclear Oversight Final N/A CFDM / Deslgnee Final Kelli Gallion-Sholler INFORMATION USE Page 1 of 1

ML21014A349

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9.0 REFERENCES

9.0 REFERENCES

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