L-21-098, Response to Request for Additional Information (RAI) - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan
| ML21250A345 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/07/2021 |
| From: | Sterdis A Holtec Decommissioning International |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| HDI-PIL-21-098 | |
| Download: ML21250A345 (85) | |
Text
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 50.90 10 CFR 50.54(q)(4)
September 7, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Pilgrim Nuclear Power Station Renewed Facility Operating License No. DPR-35 Docket No. 50-293 and 72-1044
Subject:
Response to Request for Additional Information (RAI) - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan
References:
- 1. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan, February 18, 2021 (ML21049A192)
- 2. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, Supplemental Information to Update - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan, May 20, 2021 (ML21140A045)
- 3. US NRC Letter to Andrea Sterdis (HDI) Pilgrim Nuclear Power Station - Request for Additional Information Regarding Pilgrim - License Amendment Request Independent Spent Fuel Storage Installation Only Emergency Plan (EPID: L-2021-LLA-0021), July 9, 2021 (ML21161A107)
- 4. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, Response to Request for Additional Information (RAI) - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan, July 29, 2021 (ML21210A381)
- 5. US NRC Letter to Andrea Sterdis (HDI) Pilgrim Nuclear Power Station - Request for Additional Information Regarding Pilgrim - License Amendment Request Independent Spent Fuel Storage Installation Only Emergency Plan (EPID: L-2021-LLA-0021), August 16, 2021 (ML21223A239)
HDI-PIL-21-098 Page 1 of 3
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909
- 6. US NRC Clarification Memo to Holtec Decommissioning International, LLC Summary of August 26, 2021, Clarification Call with Holtec Decommissioning International, LLC, Regarding Emergency Preparedness Request for /additional Information (EPID: L-2021-LLA-0021)
By letter dated February 18, 2021 (Reference 1) Holtec Decommissioning International, LLC, (HDI) submitted a License Amendment Request (LAR) for Pilgrim Nuclear Power Station (PNPS). The proposed amendment would revise the site emergency plan for the Independent Site Fuel Storage Installation (ISFSI) Only condition.
Subsequently, by letter dated May 20, 2021 (Reference 2), HDI submitted supplemental information to update the LAR based on requests for additional information (RAIs) received by Oyster Creek Nuclear Generating Station on an LAR for a change to their ISFSI only emergency plan.
By letter dated July 9, 2021, the NRC issued a formal RAI (Reference 3) and requested a response no later than August 10, 2021.
Subsequently, by letter dated July 29, 2021 (Reference 4), HDI submitted the information requested in the RAI.
By letter dated August 16, 2021, the NRC issued a formal RAI (Reference 5) and requested a response no later than September 10, 2021 On August 26, 2021, during a clarification call (Reference 6) with the NRC, each RAI question was reviewed with the NRC to ensure that Holtec understood the level of detail needed to respond to the second set of RAIs issued. to this letter provides HDIs response to the NRCs RAI. Attachment 2 provides a complete copy of the updated ISFSI Only Emergency Plan. Attachment 3 provides a complete copy of the updated ISFSI Only Emergency Actions Levels (EALs) and Technical Basis. Attachment 4 provides Section 5.5, Roles and Responsibilities of the Town of Plymouth Pilgrim Nuclear Power Station (PNPS) Response Plan, dated November 2020.
HDI has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Reference 1.
The additional information provided in this submittal does not affect the previously stated bases in Reference 1 for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor HDI-PIL-21-098 Page 2 of 3
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 an environmental assessment needs to be prepared in connection with the proposed amendment.
The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4).
There are no regulatory commitments contained in this submittal.
If you have any questions or require additional information, please contact me at (856) 797-0900, ext. 3813 or a.sterdis@holtec.com.
I declare under penalty of perjury that the foregoing is true and correct. Executed on September 07, 2021.
Sincerely, Digitally signed by Andrea Sterdis Andrea DN: cn=Andrea Sterdis, c=US, o=Holtec Decommissioning International, ou=HDI, Sterdis email=a.sterdis@holtec.com Date: 2021.09.07 14:49:40 -04'00' Andrea L. Sterdis HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC . Response to NRCs Request for Additional Information . Complete copy of the updated Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan (IOEP) . Complete copy of the updated ISFSI Only Emergency Actions Levels (EALs) and Technical Basis. . Pilgrim Nuclear Power Station (PNPS) Response Plan, Town of Plymouth, Section 5.5, Roles and Responsibilities, dated November 2020 cc:
USNRC Regional Administrator, Region I USNRC Project Manager, NMSS - Pilgrim Nuclear Power Station USNRC Region I, Lead Inspector - Pilgrim Nuclear Power Station Director, Massachusetts Emergency Management Agency (MEMA)
HDI-PIL-21-098 Page 3 of 3
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-098 Attachment 1 Independent Fuel Storage Installation Only Emergency Plan Response to NRCs Request for Additional Information (6 pages follow)
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909
SUMMARY
By application dated February 18, 2021 (Reference 1), as supplemented by the letters dated May 20, 2021 and July 29, 2021 (Reference 2 and Reference 4 respectively), Holtec Decommissioning International, LLC (HDI) requested approval by the U.S. Nuclear Regulatory Commission (NRC) of the proposed Pilgrim Nuclear Power Station (PNPS)
Independent Spent Fuel Storage Installation Facility (ISFSI) Only Emergency Plan (IOEP) to support the planned off-load of the PNPS spent fuel pool and transfer of the spent fuel to the ISFSI.
The following are clarifications to the responses provided for the requests for additional information (RAIs). Changes made to the previously submitted PNPS ISFSI Only Emergency Plan are shown as markups at the end of the RAI response as necessary. to this submittal supplement contains a complete copy of the updated PNPS ISFSI Only Emergency Plan, Attachment 3 to this submittal supplement contains a complete copy of the PNPS ISFSI Only Emergency Actions Levels (EALs) and Technical Basis, and Attachment 4 contains Pilgrim Nuclear Power Station (PNPS) Response Plan, Town of Plymouth, Section 5.5, Roles and Responsibilities, dated November 2020 NRC RAIs and HDIs (PNPS) RAI RESPONSES NRC RAI-1 Previous RAI Request: Please clarify that American Medical Response provides transportation for contaminated injured personnel.
Brewster Ambulance Service is currently under contract with the town of Plymouth to provide medical transportation service to the Plymouth area. PNPS has confirmed that Brewster Ambulance Service is capable of transporting contaminated injured personnel.
American Medical Response no longer provides this service to the Plymouth area.
DPP-PIL-EP-001 (IOEP), Section 2.1 Overview of ISFSI Emergency Plan on page 6 has been changed as follows:
Emergency services are provided by local, public, and private entities. Fire support services are provided by the Plymouth Fire Department; law enforcement support services are provided by local, Commonwealth, and Federal law enforcement authorities, as appropriate; ambulance services are provided by Brewster Ambulance Service; and medical services are provided by Beth Israel Deaconess Medical Center and Morton Hospital.
HDI-PIL-21-098 Page 1 of 6
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Issue:
However, it is not clear to the NRC staff that there is a letter of agreement with the Brewster Ambulance Service.
Request:
Please clarify if there is a letter of agreement with the Brewster Ambulance Service and if it specifically states that they would provide transportation of injured personnel for PNPS, including contaminated injured personnel. If this agreement is provided through a contract with the town of Plymouth, please provide documentation that specifically states the Brewster Ambulance Service would provide transportation of injured personnel for PNPS, including contaminated injured personnel.
HDI (PNPS) Response to RAI-1 The Town of Plymouths PNPS Response Plan, Section 5.5, Roles and Responsibilities specifically states that the Brewster Ambulance Service provides the logistics for the transportation of the contaminated injured individual. The latest version of the Plan dated November 2020 was approved by the Town of Plymouth Board of Selectmen.
Section 5.5 of the Town of Plymouths PNPS Response Plan, Brewster Ambulance Service states:
Brewster Ambulance Service
- a. Provides emergency medical services, under the direction of the Fire Department.
- b. Provides logistics for transportation of contaminated injured individuals. to this submittal provides a copy of Section 5.5 to the Town of Plymouths PNPS Response Plan.
NRC RAI-2 Previous RAI Request: Please clarify how the Plymouth Township will be notified for an emergency at the PNPS ISFSI.
Procedures have been established for the prompt notification to MEMA
[Massachusetts Emergency Management Agency] and the Town of Plymouth in the event of an emergency declaration. PNPS Procedure EP-IP-100, Emergency Assessment and Response, Attachment 9.2 Event Notification Checklist provides HDI-PIL-21-098 Page 2 of 6
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 the contact number for the Town of Plymouth that would be used by the Emergency Director to notify the town of an event at the Station.
Issue:
However, the sections of the proposed IOEP identified previously in the RAI have not been revised in response to the RAI.
Request:
Please revise the proposed IOEP as appropriate.
HDI (PNPS) Response to RAI-2 DPP-PIL-EP-001 (IOEP), Section 9.2, Emergency Notification on page 23 has been changed as follows:
The Emergency Director is responsible for the notification of an emergency declaration to MEMA, the Plymouth Fire Department, and the NRC within 60 minutes of the event classification or change in classification. The commercial telephone network serves as the primary means to provide emergency notification to Commonwealth and Town of Plymouth agencies. It is used to provide initial and updated notifications and for general information flow between these agencies. to this submittal provides a complete copy of DPP-PIL-EP-001 (IOEP).
NRC RAI-5 Previous RAI Request: Please clarify how onsite announcements are made.
Procedures have been established for the prompt notification of ISFSI personnel in the event of an emergency declaration. Announcements, are made via security radios utilizing PNPS Procedure EP-IP-100, Emergency Assessment and Response, Attachment 9.2 Event Notification Checklist.
Issue:
However, it is not clear to the NRC staff how personnel (public, as well as workers) in the ISFSI Controlled Area as well as the decommissioning reactor site located within the Owner Controlled Area (or within the site boundary) would be notified of an emergency declaration or any potential protective actions.
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Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Request:
Please clarify how onsite announcements are made to personnel without security radios in the ISFSI Controlled Area, as well as the decommissioning reactor site located within the Owner Controlled Area of an emergency declaration or any potential protective actions.
HDI (PNPS) Response to RAI-5 Based on the work being performed within the licensed property during the current phase of decommissioning activities, notifications will be made to the following:
- Industrial security force personnel
- Radiological checkpoint
- Support Building public address system Site procedure EP-IP-100, Emergency Classification and Notification will be revised to add these notifications.
NRC RAI-6 Previous RAI Request: Please clarify if weekly testing of the commercial telephone system is required.
At the ISFSI, testing of both the portable radios and commercial telephone system is done by Security on a more frequent basis in accordance with Security procedures, therefore weekly testing of the commercial telephone system is not required.
Issue:
However, Section 10.0, Table 10-1 Communication Systems, of Enclosure 1, Attachment 1, has not been revised and provides the testing frequency for the commercial telephone system as weekly.
Request:
Please revise the proposed IOEP as appropriate.
HDI (PNPS) Response to RAI-6 DPP-PIL-EP-001 (IOEP), Table 10-1, Communication Systems on page 26 has been changed as follows:
TABLE 10-1 Communication Systems HDI-PIL-21-098 Page 4 of 6
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Communication System Testing Frequency Commercial Telephone System Daily Portable Radios Frequent Use to this submittal provides a complete copy of DPP-PIL-EP-001 (IOEP).
New Clarification RAI discussed in the August 11, 2021 call.
Issue:
Table 1, Emergency Plan Initiating Conditions Being Deleted, of Section 3.1, Elimination of SFP Initiating Conditions and EALs, of the February 18, 2021 application provides, PD-HU1 Confirmed SECURITY CONDITION or threat (1 or 2 or 3) at the Independent Spent Fuel Storage Installation (ISFSI)
However, Table PD-1: Recognition Category PD and E Initiating Condition Matrix, in the, ISFSI Only Emergency Action Levels (EALs) and Technical Bases, of the February 18, 2021 application, as well as the May 20, 2021 supplement provides, PD-HU1 Confirmed SECURITY CONDITION or threat.
Request:
Please indicate what version of PD-HU1 is accurate and is to be reflected in the approval.
HDI (PNPS) Response to New Clarification RAI discussed in the August 11, 2021 call DPP-PIL-EP-002, ISFSI Only Emergency Action Levels (EALs) and Technical Basis, Table PD-1: Recognition Category PD and E Initiating Condition Matrix on page 11 has been changed as follows:
HDI-PIL-21-098 Page 5 of 6
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Facility Safety PD-HA1 HOSTILE ACTION is occurring or has PD-HU1 Confirmed SECURITY CONDITION or threat occurred. at the Independent Fuel Storage Installation (ISFSI)
Emergency Action Level (EAL):
Hostile Action
- 1. A HOSTILE ACTION is occurring or has occurred as Emergency Action Level (EAL):
reported by the Security Shift Supervisor.
- 1. Notification of a credible security threat directed at the site OR
- 2. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.
Attachment 3 to this submittal provides a complete copy of DPP-PIL-EP-002, ISFSI Only Emergency Action Levels (EALs) and Technical Basis.
References:
- 1. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan, February 18, 2021 (ML21049A192)
- 2. Letter from HDI to US NRC, Supplemental Information to Update - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan, May 20, 2021 (ML21140A045)
- 3. US NRC Letter to Andrea Sterdis (HDI) Pilgrim Nuclear Power Station - Request for Additional Information Regarding Pilgrim - License Amendment Request Independent Spent Fuel Storage Installation Only Emergency Plan (EPID: L-2021-LLA-0021) July 9, 2021 (ML21161A107)
- 4. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, Response to Request for Additional Information (RAI) - License Amendment Request to Approve the Pilgrim Nuclear Power Station Independent Fuel Storage Installation Only Emergency Plan, July 29, 2021 (ML21210A381)
- 5. Pilgrim Nuclear Power Station (PNPS) Response Plan, Town of Plymouth, dated November 2020 HDI-PIL-21-098 Attachment 1 Page 6 of 6
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-098 Attachment 2 Updated PNPS Independent Fuel Storage Installation Only Emergency Plan (IOEP)
(44 pages follow)
Procedure Number: Revision:
DPP-PIL-EP-001 0 ISFSI Only Emergency Plan Use Category:
Reference Use Page 1 of 44 FOREWORD The Pilgrim Nuclear Power Station (PNPS) Independent Spent Fuel Storage Installation (ISFSI) Only Emergency Plan (IOEP) describes PNPS's plans for responding to emergencies that may arise at the PNPS ISFSI.
__________________________________________ Date: _________________
Sr. Manager, Compliance
__________________________________________ Date: _________________
Independent Safety Review
__________________________________________ Date: _________________
HDI Decommissioning Site Vice President Effective Date: ____________
SUMMARY
OF REVISIONS Revision 0: Initial issue. Previous revision is EP-PP-01, Revision 44 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 2 of 44 TABLE OF CONTENTS
1.0 INTRODUCTION
5 1.1 Purpose 5 1.2 Scope 6 2.0 DISCUSSION 6 2.1 Overview of ISFSI Emergency Plan 6 2.2 Facility Description 7 2.3 Summary of Emergency Actions 8 3.0 DEFINITIONS AND ACRONYMS 8 3.1 Definitions 8 3.2 Acronyms 12
4.0 REFERENCES
13 5.0 ASSIGNMENT OF RESPONSIBILITY 15 5.1 Emergency Response and Responsibilities 15 5.2 Offsite Response Organizations 16 6.0 EMERGENCY RESPONSE ORGANIZATION 17 6.1 On-Shift Positions 17 6.2 Augmented ERO Positions 19 6.3 Functional Responsibilities 19 7.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES 21 8.0 EMERGENCY CLASSIFICATION SYSTEM 21 8.1 Emergency Classification System 21 8.2 Emergency Action Levels and Postulated Accidents 23 9.0 NOTIFICATION METHODS AND PROCEDURES 23 9.1 Basis for Notification 23 9.2 Emergency Messages 23 9.3 Means of Providing Emergency Notification 24 10.0 EMERGENCY COMMUNICATIONS 25 11.0 PUBLIC INFORMATION 26 12.0 EMERGENCY FACILITY AND EQUIPMENT 26 12.1 Emergency Response Facility 26 12.2 Emergency Equipment and Supplies 27 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 3 of 44 13.0 ACCIDENT ASSESSMENT 27 14.0 PROTECTIVE ACTIONS 28 14.1 Accountability 28 14.2 Personnel and Visitors Located Outside the ISFSI Protected Area 28 15.0 RADIOLOGICAL EXPOSURE CONTROL 29 15.1 Exposure Guidelines 29 15.2 Radiation Protection 29 15.3 Personnel Contamination Control 30 16.0 MEDICAL AND HEALTH SUPPORT 31 16.1 Onsite First Aid 31 16.2 Medical Transportation 31 16.3 Offsite Medical Support 31 17.0 EMERGENCY TERMINATION AND RECOVERY 32 17.1 Emergency Termination and Notification 32 17.2 Recovery Operations 32 17.3 Termination of Recovery Operations 33 18.0 EXERCISES AND DRILLS 33 18.1 Emergency Plan Exercises and Drills 33 18.2 Equipment and Proficiency Drills 34 18.3 Critique Evaluation 35 19.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING 36 19.1 Emergency Response Personnel Training 36 19.2 Non-PNPS Emergency Response Support Organizations 38 19.3 Annual Emergency Action Level Training 38 20.0 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 38 20.1 Emergency Preparedness Responsibilities 38 20.2 Review and Updating of the IOEP 39 20.3 Training 40 20.4 Maintenance and Inventory of Emergency Equipment and Supplies 40 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 4 of 44 APPENDICES PAGE APPENDIX A Emergency Equipment, Supplies, and Reference Materials 41 APPENDIX B Cross Reference IOEP Section to Planning Standards/Requirements/Criteria and EPIPs 43 LIST OF TABLES TABLE 6-1 Emergency Response Organization Staffing and Responsibilities 20 TABLE 10-1 Communications Systems 26 TABLE 15-1 Response Worker Emergency Dose Limits 30 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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1.0 INTRODUCTION
By letter dated June 10, 2019, Entergy submitted certifications, pursuant to 10 Code of Federal Regulations (CFR) 50.82(a)(1)(i) and (a)(1)(ii), for the permanent cessation of power operations, the permanent removal of fuel from the PNPS reactor vessel, and the placement of the fuel in the spent fuel pool (ADAMS Accession No. ML19161A033). Subsequently, all spent fuel has been transferred to the on-site Independent Spent Fuel Storage Installation (ISFSI) facility.
The PNPS ISFSI Only Emergency Plan (IOEP) describes the plan for responding to emergencies that may arise at the ISFSI. In this condition, no reactor operations can take place and all irradiated fuel has been removed from the Spent Fuel Pool.
This IOEP adequately addresses the risks associated with PNPS's current conditions.
The Holtec International (Holtec) Final Safety Analysis Report (FSAR) for the HI-STORM 100 Cask System describes the Design Basis Accidents (DBAs) applicable to the PNPS ISFSI along with the radiological dose calculation results.
As provided in the Holtec FSAR, the analyses of the potential radiological impacts of postulated off-normal, natural phenomena, and accident events involving the ISFSI indicate that any releases would result in a dose to the public below the radiation limits established in 10 CFR 72.106(b). The analyses of the potential radiological impact of DBAs indicate that any releases beyond the Site Boundary are below the Environmental Protection Agency (EPS) Protective Action Guide (PAG) exposure levels, as detailed in the EPAs Protective Action Guide and Planning Guidance for Radiological Incidents, dated January 2017. Exposure levels, which warrant pre-planned response measures are limited to the ISFSI and immediate vicinity, and for this reason, radiological emergency planning is focused on this area. The PNPS 10 CFR 72.212 Report for the HI-STORM 100 System discusses compliance with Amendments 2 and 10 of the Holtec HI-STORM 100 System Certificate of Compliance (CoC) terms, conditions, and specifications.
1.1 Purpose The purpose of the IOEP is to ensure an adequate level of preparedness to cope with the spectrum of emergencies that could be postulated to occur. This plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations expected to respond to potential emergencies.
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Reference Use Page 6 of 44 1.2 Scope The IOEP has been developed to respond to potential radiological emergencies at the PNPS ISFSI. Because there are no postulated off-normal, natural phenomena or accident events that would result in dose consequences that are large enough to require offsite emergency planning, the overall scope of the IOEP details the actions necessary to safeguard onsite personnel.
The concepts presented in the IOEP address the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans," and Appendix E to 10 CFR 50, "Emergency Planning and Preparedness for Production and Utilization Facilities." The IOEP is consistent with the applicable guidelines established in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
Appendix B Contains a cross-reference to the applicable guidance in NUREG-0654.
Exemptions from selected portions of 10 CFR 50.47 and Appendix E to 10 CFR Part 50 were approved by the Nuclear Regulatory Commission (NRC) on December 18, 2019 (ADAMS Accession Number ML19142A043).
2.0 DISCUSSION 2.1 Overview of ISFSI Emergency Plan In the event of an emergency at the PNPS ISFSI, actions are required to identify and assess the nature of the emergency and to respond in a manner that protects the health and safety of the public and onsite personnel. This plan describes the organization and responsibilities for implementing emergency measures and describes interfaces with Federal, Commonwealth of Massachusetts, and local organizations which may be notified in the event of an emergency and may provide assistance.
Emergency services are provided by local, public, and private entities. Fire support services are provided by the Plymouth Fire Department; law enforcement support services are provided by local, Commonwealth, and Federal law enforcement authorities, as appropriate; ambulance services are provided by Brewster Ambulance Service; and medical services are provided by Beth Israel Deaconess Medical Center and Morton Hospital.
PNPS is licensed under the requirements of 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities." Consistent with the requirements of 10 CFR Part 50, the IOEP is based on the requirements of 10 CFR Part 50, Section 50.47(b) and Appendix E, "Emergency Planning and Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 7 of 44 Preparedness for Production and Utilization Facilities, with approved exemptions.
Sections 5.0 thru 20.0 of this IOEP address the standards outlined in 10 CFR 50.47(b)(1) through (16). PNPS is licensed to store spent fuel in the ISFSI under the General License provisions of 10 CFR 72.210 and 10 CFR 72.212.
Because there are no postulated events that would result in offsite dose consequences large enough to require off site emergency planning, emergencies are divided into two classifications: 1) Notification of Unusual Event (Unusual Event) and 2) Alert. The classification scheme, developed in accordance with NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors", Revision 6, November 2012, has been discussed and agreed upon with responsible offsite organizations and is compatible with their respective emergency plans (CEMP). If determined appropriate by government officials, protective actions may be implemented to protect the public using the existing all hazards emergency planning.
PNPS is responsible for planning and implementing emergency measures within the site boundary. The IOEP is provided to meet that responsibility. To carry out specific emergency measures discussed in the IOEP, detailed emergency plan implementing procedures (EPIPs) are established and maintained. A list of EPIPs is included in Appendix B.
In addition to the description of activities and steps that can be implemented during an emergency, the IOEP also provides a general description of the steps taken to recover from an emergency. It also describes the training, exercises and drills, planning, and coordination appropriate to maintain an adequate level of emergency preparedness.
2.2 Facility Description Pilgrim Nuclear Power Station (PNPS) is located in the town of Plymouth, Plymouth County, in the Commonwealth of Massachusetts. The ISFSI facility is located on the northern portion of the 134-acre property located within the site boundary, owned by Holtec Pilgrim and maintained and operated for decommissioning by Holtec Decommissioning International (HDI). The facility is located on the western shore of Cape Cod Bay in the town of Plymouth on the Holtec Pilgrim site in Plymouth County, Massachusetts.
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Reference Use Page 8 of 44 Upon docketing of the 10 CFR 50.82(a)(1) certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, the 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. Since PNPS was permanently shut down and defueled, no additional fission products will be generated from the plant after shutdown and the decay heat load on the spent fuel will continue to decline. All spent fuel has been transferred to the ISFSI which is located to the southwest of the Plant. The PNPS ISFSI is a robust and high integrity facility for the spent fuel storage system. This facility is designed to prevent the release of radioactivity in the event of accidents, including environmental phenomena (e.g., earthquake and flooding).
2.3 Summary of Emergency Actions The IOEP is activated by the ISFSI Shift Supervisor (ISS) upon identification of an emergency situation based upon the Emergency Action Level (EAL) criteria.
The ISS assumes the position of the Emergency Director upon classification of an emergency. The emergency measures described in the subsequent sections and EPIPs are implemented in accordance with the classification and nature of the emergency, and at the direction of the Emergency Director. Regulatory authorities and offsite support organizations are notified in accordance with this Plan. The Emergency Director has authority and responsibility for control and mitigation of the emergency, including emergency response resources, coordination of radiological assessment activities, and recovery implementation.
The following sections of this IOEP describe the detailed plans and actions of the PNPS Emergency Response Organization (ERO), including interfaces with offsite support organizations.
3.0 DEFINITIONS AND ACRONYMS 3.1 Definitions 3.1.1 Accountability A discretionary protective action taken for all persons onsite (within the ISFSI Protected Area) that involves the gathering of personnel into pre-designated areas and subsequent verification that the location of all personnel is known.
3.1.2 Alert Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the ISFSI or a security event that involves probable life-threatening risk to site personnel or damage to ISFSI equipment because of hostile action. Any releases are expected to be limited to Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 9 of 44 small fractions of the Environmental Protection Agency (EPA) Protective Action Guideline (PAG) exposure levels.
3.1.3 Annual Once per calendar year, unless otherwise stated.
3.1.4 Assessment Actions Those actions taken during or after an emergency for the purposes of obtaining and processing the information necessary to make decisions to implement specific emergency measures.
3.1.5 Biennial Once per two calendar years, unless otherwise stated.
3.1.6 Corrective Action Those emergency measures taken to mitigate or terminate an emergency situation at or near the source of the problem in order to prevent an uncontrolled release of radioactive material or to reduce the magnitude of a release (e.g.,
equipment shutdown, firefighting, equipment repair, and damage control).
3.1.7 Design Basis Accident (DBA)
Credible accident events as analyzed in the ISFSI Updated Final Safety Analysis Report.
3.1.8 Emergency Action Level (EAL)
A pre-determined, site-specific, observable threshold for an Initiating Condition (IC) that, when met or exceeded, places the ISFSI in a given emergency classification level.
3.1.9 Emergency Classification System A system of classification in which emergency occurrences are categorized according to specific protective action levels. The two emergency classification levels, in ascending order of severity, are: Notification of Unusual Event (Unusual Event) and Alert.
3.1.10 Emergency Director This position is the highest level of authority for the PNPS Emergency Response Organization (ERO) and on-site emergency activities. This position is held by the ISFSI Shift Supervisor (ISS) or designated alternate. The ISS in the IOEP is equivalent to the Lead Security Shift Supervisor (LSSS) as defined in the ISFSI Only Security Plan.
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Reference Use Page 10 of 44 3.1.11 Emergency Plan Implementing Procedure (EPIP)
Specific procedures describing actions taken by plant staff to activate and implement the IOEP.
3.1.12 Emergency Response Facility (ERF)
Facility containing the communications equipment necessary for emergency conditions. It is operated under the direction of the Emergency Director and serves as the primary location for classification of the emergency, notification of the emergency to offsite agencies, assessment actions, and emergency action direction.
3.1.13 Emergency Response Organization (ERO)
Organization comprised of assigned individuals who would respond and assist during a classified emergency.
3.1.14 Fire Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.
3.1.15 Frequency That unit of time specified (monthly, quarterly, etc.) plus or minus 25 percent, unless otherwise specifically stated. This definition does not apply to "Annual" when it is related to the conduct of the Biennial Exercise. Biennial Exercises are performed within the calendar year.
3.1.16 Hostile Action An act toward the ISFSI or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the ISFSl. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the Owner Controlled Area).
3.1.17 Hostile Force One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
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Reference Use Page 11 of 44 3.1.18 Independent Spent Fuel Storage Installation (ISFSI)
A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.
3.1.19 ISFSI Controlled Area That area immediately surrounding an ISFSI or MRS (Monitored Retrievable Storage Installation) for which the licensee exercises authority over its use and within which ISFSI or MRS operations are performed.
3.1.20 Initiating Condition (IC)
An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.
3.1.21 Local Assembly Area A pre-designated area where personnel report to for organization, roll-call, and supervision when ISFSI accountability is initiated.
3.1.22 Notification of Unusual Event (Unusual Event)
Events are in progress or have occurred which indicate a potential degradation of the level of safety of the ISFSI or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected.
3.1.23 Owner Controlled Area (OCA)
The OCA is that Licensee-owned property located between Rocky Hill Road and Cape Cod Bay comprising PNPS excluding the Security Owner Controlled Area and Protected Area.
3.1.24 Protected Area The area normally within the facility security fence designated to implement the security requirements of 10 CFR 73.
3.1.25 Protective Actions Those measures taken in anticipation of, or after an uncontrolled release of radioactive material, for the purpose of preventing or minimizing radiological exposures to persons that would be likely to occur if the actions were not taken.
3.1.26 Protective Action Guide (PAG)
The projected dose to an individual, resulting from a radiological incident at which specific protective actions to reduce or avoid that dose are warranted.
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Reference Use Page 12 of 44 3.1.27 Radioactive Release Any radioactive material beyond pre-emergency levels and not attributable to normal ISFSI operations, either detected or suspected of migrating beyond the Protected Area, while in a classified emergency.
3.1.28 Radioactive Control Area (RCA)
An area in which radioactive material is present and the potential exists for the spread of radioactive contamination. The area is posted for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.
3.1.29 Recovery The condition declared after the immediate hazards to life and safety due to the emergency have been removed and efforts are directed to returning affected areas to normal.
3.1.30 Recovery Actions Those actions taken after the emergency has been controlled in order to restore the ISFSI to safe conditions.
3.1.31 Security Condition Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the ISFSI. A security condition does not involve a hostile action.
3.1.32 Site That property within the fenced boundary of Pilgrim which is owned by Holtec.
3.1.33 Site Boundary That line beyond which the land is not owned, leased, or otherwise controlled by the licensee. This line establishes the perimeter of the Owner Controlled Area (OCA).
3.1.34 Substantial Degradation Unanticipated conditions which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.
3.2 Acronyms ALARA As Low As Reasonably Achievable CDI Comprehensive Decommissioning International, LLC Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 13 of 44 DBA Design Basis Accident EAL Emergency Action Level ENS Emergency Notification System EPA Environmental Protection Agency EPIP Emergency Plan Implementing Procedure ERF Emergency Response Facility ERO Emergency Response Organization FSAR Final Safety Analysis Report FTS Federal Telecommunication System HDI Holtec International Decommissioning, LLC IC Initiating Condition IOEP ISFSI Only Emergency Plan ISFSI Independent Spent Fuel Storage Installation ISS ISFSI Shift Supervisor LLEA Local Law Enforcement Agency LSSS Lead Security Shift Supervisor MEMA Massachusetts Emergency Management Agency NRC Nuclear Regulatory Commission OCA Owner Controlled Area ORO Offsite Response Organization PAG Protective Action Guide RCA Radiological Control Area REAC/TS Radiation Emergency Assistance Center/Training Site PNPS Pilgrim Nuclear Power Station
4.0 REFERENCES
4.1 10 CFR 50.47, Emergency Plans 4.2 Appendix E to 10 CFR Part 50, "Emergency Planning and Preparedness for production and Utilization Facilities" Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 14 of 44 4.3 10 CFR Part 20, "Standards and Protection Against Radiation" 4.4 NUREG-0578, "TMl-2 Lessons Learned Task Force Status Report and Short-Term Recommendations" (July 1979) 4.5 NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Rev. 1 4.6 Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors" 4.7 Certificate of Compliance No. 1014, Amendment 7 for the HI-STORM 100 Cask System, dated December 28, 2009 (ADAMS Accession No. ML093620049) 4.8 Certificate of Compliance No. 1014, Amendment 12 for the HI-STORM 100 Cask System, dated February 25, 2019, with corrected date of December 23, 2019 (ADAMS Accession No. ML19343A908) 4.9 Holtec International Final Safety Analysis Report for the HI-STORM 100 Cask System Revision 9, dated February 13, 2010, for Certificate Number 1014, Docket No. 72-1014, Amendment 7, Effective Date December 28, 2009 4.10 Holtec International Final Safety Analysis Report for the HI-STORM 100 Cask System Revision 17, dated May 3, 2019, for Certificate Number 1014, Docket No. 72-1014, Amendment 12, Effective Date February 25, 2019 4.11 Pilgrim Nuclear Power Station, 10 CFR 72.212 Report for the HI-STORM 100 System, Revision 5, dated May 14, 2020 4.12 NRC Bulletin (BL) 2005-02, "Emergency Preparedness and Response Actions for Security Based Events," dated July 18, 2005 (ADAMS Accession No. ML051740058) 4.13 Nuclear Energy Institute (NEI) 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012 (ADAMS Accession No. ML12326A805) 4.14 EPA's "Protective Action Guides and Planning Guidance for Radiological Incidents, dated January 2017 (EPA PAG Manual) 4.15 Letter, Entergy Nuclear Operations, Inc. to USNRC, "Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel," dated June 10, 2019 (ADAMS Accession No. ML19161A033) 4.16 Letter, USNRC to Holtec Decommissioning International, "Pilgrim Nuclear Power Station - Exemptions from Certain Emergency Planning Requirements and Related Safety Evaluation, dated December 18, 2019 (ADAMS Accession Number ML19142A043)
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Reference Use Page 15 of 44 4.17 NUREG-0586, "Generic Environmental Impact Statement of Decommissioning of Nuclear Facilities," Supplement 1, Volume 1, November 2002 4.18 NRC Information Notice No. 90-08: KR-85 Hazards from Decayed Fuel 4.19 10 CFR 72.13, "Applicability
4.20 10 CFR 72.32, "Emergency Plan" 4.21 10 CFR 72.44, "License Conditions" 4.22 10 CFR 72.106, "Controlled Area of an ISFSI or MRS" 4.23 ISFSI Physical Security Plan 4.24 ISFSI EAL Technical Bases Document 5.0 ASSIGNMENT OF RESPONSIBILITY Primary responsibilities for emergency response have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
5.1 Emergency Response and Responsibilities HDI is responsible for the safe storage of spent fuel in accordance with NRC regulations. Responsibility for planning and implementing all emergency measures rests with HDI. The PNPS ISFSI Organization has complete capability at all times to perform the detection, classification, initial response, and notification functions required during an emergency. The organization has an inherent emergency response and recovery function in its overall management and operation.
The ISFSI Shift Supervisor (ISS) is at PNPS on a continuous, 24-hour per day basis, and is the senior management position during off-hours. This position is responsible for monitoring ISFSI conditions and managing the activities at the PNPS ISFSI. The ISS has the responsibility and authority to declare an emergency and initiate appropriate actions in accordance with written procedures to mitigate the consequences. When an off-normal, natural phenomenon, or accident event becomes apparent, the ISS shall assess the condition and assume the position of Emergency Director once an emergency declaration has been made.
The Emergency Director is responsible for the direction of all activities at the ISFSI site during an emergency. Should evaluation indicate the need, the Emergency Director has the authority to direct any or all personnel to relocate from the ISFSI and surrounding area and to notify all applicable agencies of the ISFSI status. The Emergency Director ensures that appropriate actions are taken Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 16 of 44 and management and applicable offsite supporting organizations and regulatory agencies are notified, as necessary. The functions associated within the Emergency Director's scope of responsibilities are specified on Table 6-1.
The Emergency Director does not have concurrent duties which conflict with the above responsibilities.
The on-shift staff positions are staffed on a 24-hour per day basis. The on-shift staff can perform all required IOEP actions. At the direction of the Emergency Director, additional personnel will be activated to support the on-shift staff.
A Resource Manager assists in assessing the event and obtaining additional resources needed to respond to the event.
5.2 Offsite Response Organizations The Emergency Director coordinates the Offsite Response Organization (ORO) response (fire, ambulance, local law enforcement agencies (LLEA), and medical), access, and radiological controls with the onsite activities. Notification of an emergency declaration or change in classification is provided to the Massachusetts Emergency Management Agency (MEMA) via the commercial telephone system.
The response of the MEMA and Commonwealth of Massachusetts agencies are in accordance with each agency's plans and procedures and are commensurate with the hazard posed by the emergency. The OROs listed below are capable of emergency response on a 24-hour per day basis.
5.2.1 Fire Department Arrangements exist with the Plymouth Fire Department to provide response and support services as requested. The fire department is located approximately 5 miles from PNPS, allowing for a timely response.
5.2.2 Ambulance Service Notification via a commercial phone line to the Plymouth Fire Department (the ambulance Dispatcher) provides for a coordinated communications link to the ambulances responding to PNPS or transporting personnel from the from PNPS.
Radiation monitoring services shall be provided by PNPS whenever it becomes necessary to use the ambulance service for the transportation of contaminated persons.
5.2.3 Hospitals PNPS establishes communications with Beth Israel Deaconess (BID) Hospital -
Plymouth and Morton Hospital via commercial telephone or a wireless system.
An agreement is in place with BID- Plymouth and Morton Hospital for medical Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 17 of 44 treatment of patients from PNPS who have Injuries complicated by radioactive contamination. The hospitals have trained personnel and detailed procedures for handling radioactively contaminated patients from PNPS.
5.2.4 Law Enforcement Agencies Law enforcement support services are provided by the local law enforcement agency (LLEA), State, and Federal law enforcement authorities, as appropriate.
5.2.5 Nuclear Regulatory Commission In the event of an emergency at the PNPS ISFSI, the NRC Operations Center in Rockville, Maryland will be notified immediately after notification of the Commonwealth of Massachusetts and not later than 60 minutes after an emergency declaration or change in classification. Classification and radiological information are communicated to this office over the commercial telephone line or via a wireless system from the PNPS ISFSI Emergency Response Facility (ERF).
The NRC is the primary Federal agency providing coordination and support to the licensee in the event of an emergency at the PNPS ISFSI. NRC responsibilities are directed toward a coordination of Federal efforts to provide assistance to the licensee and State and local governments in their planning and implementation of emergency preparedness procedures.
The NRC response must be regarded primarily as supportive of, and not a substitute for, responsible action by PNPS and other key response organizations.
The NRC must be continually informed of status and possible radiological consequences and be frequently updated on plans for emergency and recovery actions and needs for assistance.
6.0 EMERGENCY RESPONSE ORGANIZATION Emergency Response Organization (ERO) responsibilities for emergency response are identified in Table 6-1, "Emergency Response Organization Staffing and Responsibilities."
6.1 On-Shift Positions PNPS maintains on-shift personnel capable of providing the initial response to an off-normal, natural phenomenon, or accident event on a 24-hour per day basis.
Members of the on-shift organization are trained on their responsibilities and duties in the event of a declared emergency and are capable of performing all necessary response actions until any necessary augmenting staff arrives or the event is terminated. The on-shift staffing assignments include the roles and responsibilities for their emergency response functions.
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Reference Use Page 18 of 44 6.1.1 ISSI Shift Supervisor/Emergency Director The ISS is at the PNPS ISFSI on a 24-hour per day basis and is the senior management position during off-hours. This position is responsible for monitoring conditions and approving all onsite activities and has the requisite authority, management ability, technical knowledge, and staff to manage the site, emergency response, and recovery organizations.
The ISS has the responsibility and authority to declare an emergency and to initiate appropriate actions to mitigate the consequences of the emergency in accordance with written procedures. The ISS assumes the position of Emergency Director with overall command and control once an emergency classification has been made. The Emergency Director is responsible for the direction of the total emergency response effort and has the company authority to accomplish this responsibility.
The Emergency Director cannot delegate the following responsibilities:
- Classification of an event
- Approval of emergency notifications to Massachusetts, and the NRC (although the task of making the notifications may be delegated)
- Authorization of radiation exposures in excess of 10 CFR Part 20 limits The Emergency Director is responsible for assuring that appropriate corrective and protective actions are taken to mobilize emergency response personnel and for notifying management, OROs, and regulatory agencies, as necessary. Other responsibilities assumed by the Emergency Director associated with the functions listed in Table 6-1 include:
- Notification of the emergency classification to the NRC and Massachusetts
- Management of available station resources
- Initiation of mitigative actions
- Initiation of mitigative, corrective, and onsite protective actions
- Decision to call for LLEA, fire, or ambulance assistance
- Augmentation of the emergency staff, as deemed necessary
- Coordination of security activities
- Termination of the emergency condition when appropriate
- Performance of initial radiological assessment Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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- Maintaining a record of event activities
- Suspending security measures 6.1.2 Security Security is maintained in accordance with the ISFSI Physical Security Plan.
Security performs accountability as directed by the ISS or Emergency Director.
6.2 Augmented ERO Positions PNPS maintains the necessary personnel and resources to support the PNPS ISFSI Emergency Director in responding to an emergency.
In addition to the resources listed below, additional personnel resources may be directed to report to the PNPS ISFSI by the Emergency Director to provide additional support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available from PNPS staff and can be requested from various contractors.
6.2.1 Resource Manager The Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration. The Resource Manager will augment the Emergency Director by assisting in the assessment of the emergency condition and coordinating any required resources, including serving as the public information interface. The Resource Manager does not need to physically report to PNPS to perform the assigned responsibilities.
6.2.2 Augmented Responder For a declared emergency involving radiological consequences, a minimum of one person trained in radiological monitoring and assessment will report to the PNPS ISFSI within four (4) hours of the emergency declaration.
6.2.3 Offsite Response Organizations Additional support is available from OROs, as described in Section 5.2 of this Plan.
6.3 Functional Responsibilities Table 6-1 lists the functional responsibilities that fulfill emergency staffing capabilities.
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Reference Use Page 20 of 44 TABLE 6-1 Emergency Response Organization Staffing and Responsibilities FUNCTIONAL LOCATION ON-SHIFT STAFF AUGMENTED AREA RESPONSE Assessment of Emergency Emergency Resource Manager Condition Response Facility Director (Emergency Declaration Emergency Emergency Emergency ---
Direction and Response Facility Director Control Notifications / Emergency Emergency ---
Communications Response Facility Director Radiological Emergency Emergency Resource Accident Response Facility / Director Manager*
Assessment and On Scene Protective Actions Augmented Responder**
Corrective Actions Emergency Emergency ---
Response Facility / Director On Scene Fire Fighting On Scene Per Fire Protection Offsite Response Plan Organization Rescue and First On Scene *** Offsite Response Aid Treatment Organization Site Access Control Security Station Per ISFSI Physical ---
and Accountability Security Plan
- As described in Section 6.2.1
- As described in Section 6.2.2
- Provided by on-shift personnel who may be assigned other functions.
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Reference Use Page 21 of 44 7.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES Arrangements for requesting and effectively using resources have been made and other organizations capable of augmenting the planned response have been identified.
Letters of Agreement are in place for those local organizations (fire, ambulance, LLEA, and medical) listed in Section 5.2 that will respond to an emergency at the PNPS ISFSI.
Letters of Agreement for each organization are maintained on file.
The Emergency Director coordinates the fire, ambulance, and LLEA response as previously discussed in Section 5.2.
The Emergency Director is authorized to request Federal assistance as needed. The NRC will act as the lead Federal agency providing coordination and support in response to an emergency at PNPS as described in Section 5.2.5.
8.0 EMERGENCY CLASSIFICATION SYSTEM A standard emergency classification and emergency action level scheme is in use. This section describes emergency classifications, Initiating Conditions (ICs), EALs, and postulated emergency situations.
8.1 Emergency Classification System The emergency classification system covers the entire spectrum of possible radiological and non-radiological emergencies at the PNPS ISFSI. The emergency classification system categorizes accidents and/or emergency situations into one of two emergency classification levels depending on emergency conditions at the time of the incident: Unusual Event and Alert. Each of these emergency classifications require notification of the ERO, MEMA, and to the NRC.
The emergency classification system is based on NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors", Revision 6. The classification system referenced in NEI 99-01, Revision 6 has been endorsed by the NRC and provides a standard method for classifying emergencies.
Once indications are available that an EAL is met, the event is classified, and the corresponding emergency classification level is promptly declared. Refer to the ISFSI Only Emergency Action Level Technical Bases for actual parameter values, and status used to classify emergencies.
Incidents may initially be classified as an Unusual Event and then escalated to an Alert if the situation deteriorates. The following Sections outline the actions at each emergency classification level.
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Reference Use Page 22 of 44 Refer to the ISFSI Only EAL Technical Bases Document for actual parameter values and status used to classify emergencies.
8.1.1 Unusual Event EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INDICATE A POTENTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE ISFSI OR INDICATE A SECURITY THREAT TO FACILITY PROTECTION HAS BEEN INITIATED. NO RELEASES OF RADIOACTIVE MATERIAL REQUIRING OFFSITE RESPONSE OR MONITORING ARE EXPECTED UNLESS FURTHER DEGRADATION OF SAFETY SYSTEMS OCCURS.
The purpose of the Unusual Event declaration is to: 1) provide for an increased awareness of abnormal conditions; 2) provide for systematic handling of information and decision-making, and 3) augment on-shift personnel, if deemed necessary by the Resource Manager.
Upon declaration of an Unusual Event, offsite authorities shall be informed of the emergency declaration and the necessary documentation will be completed as specified in the EPIPs. The classification shall be maintained until the emergency is terminated or the emergency escalates to an Alert. If an escalation to an Alert occurs, offsite authorities will be informed of the change within 60 minutes of the change in classification.
8.1.2 Alert EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVE AN ACTUAL OR POTENTIAL SUBSTANTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE ISFSI OR A SECURITY EVENT THAT INVOLVES PROBABLE LIFE THREATENING RISK TO SITE PERSONNEL OR DAMAGE TO ISFSI EQUIPMENT BECAUSE OF HOSTILE ACTION. ANY RELEASES ARE EXPECTED TO BE LIMITED TO SMALL FRACTIONS OF THE EPA PAG EXPOSURE LEVELS.
The purpose of the Alert declaration is to: 1) perform event mitigation and radiation monitoring, if required, and 2) ensure that all necessary resources are being applied to accident mitigation.
Upon classification of an Alert, offsite authorities will be informed of the emergency and the necessary documentation will be completed as specified in the EPIPs. The classification shall be maintained until the emergency is terminated. PNPS may enter Recovery operations while in the Alert classification.
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Reference Use Page 23 of 44 8.2 Emergency Action Levels and Postulated Accidents Both emergency classifications are characterized by EALs consisting of specific instrument readings and/or observations which indicate to the ISS that an IC has been met. These EALs are used to ensure that the initial classification of emergencies can be accomplished rapidly, allowing for the prompt identification of the necessary mitigating actions.
EALs and ICs are provided under the following categories:
- ISFSI Malfunction
- Hazards and Other Conditions The Holtec HI-STORM FSAR describes the DBAs applicable to the PNPS ISFSI and the radiological dose calculation results. Specific guidance for classifying emergencies is found in EPIPs and the ISFSI EAL Technical Bases Document.
The emergency classification system and the EALs are reviewed with the authorities of Massachusetts on an annual basis.
9.0 NOTIFICATION METHODS AND PROCEDURES Procedures are established for the prompt notification to MEMA and local organizations and for notification of PNPS emergency personnel in the event of an emergency declaration. PNPS has established the means for notification and dissemination of emergency messages. The content of initial and follow-up messages to response organizations has been established.
9.1 Basis for Notification The notification of personnel and emergency response organizations is commensurate with the hazard posed by the emergency. The emergency classification system described in Section 8.0 is the primary bases for notification and has been mutually agreed upon by applicable State and Federal organizations.
9.2 Emergency Messages The Emergency Director is responsible for the notification of an emergency declaration to MEMA, the Plymouth Fire Department, and the NRC within 60 minutes of the event classification or change in classification. The commercial telephone network serves as the primary means to provide emergency notification to Commonwealth and Town of Plymouth agencies. It is used to provide initial and updated notifications and for general information flow between these agencies.
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Reference Use Page 24 of 44 The format and content of the initial message to MEMA and the Plymouth Fire Department is specified in EPIPs and has been established with the review and agreement of responsible state authorities. The initial notification contains the following information, as available:
- Identification of the facility
- Identification of the message sender
- Date and Time of the emergency declaration
- Emergency classification, including EAL
- Whether a release has occurred, is occurring, or is anticipated to occur
- Actual or projected dose rates at the site boundary Follow-up reports are provided as additional information describing the emergency situation becomes available, or as requested by MEMA and the Plymouth Fire Department, until such time that the emergency condition has been terminated.
9.3 Means of Providing Emergency Notification Various communications systems, as described in Section 10.0 are available to perform emergency notifications. The Emergency Director is the primary individual for initiating notifications. However, the Emergency Director may designate an individual to perform the notifications. EPIPs and emergency telephone directories identify organizations and individuals to be notified and contain appropriate listings of telephone numbers.
The following sections describe the means of notifying, alerting, and mobilizing the various organizations or individuals.
9.3.1 Commonwealth of Massachusetts Notification of an emergency declaration, and specific emergency information, is conveyed to MEMA using the commercial telephone system. This system is available in the ERF on a 24-hour per day basis and is staffed continuously in the State Police dispatching points.
Other commercial means, including the use of wireless communications, will serve as a backup to the commercial telephone system.
9.3.2 NRC Event Notification The NRC is notified immediately following notification of the MEMA and local government agencies, and not later than 60 minutes after the time of initial Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 25 of 44 emergency declaration, escalation, termination, or entry into recovery phase.
NRC notifications will be performed utilizing the commercial phone system.
9.3.3 ERO Notification The Resource Manager is notified of an emergency declaration by an onsite announcement and the commercial telephone system, or other commercial means which may include land line and/or wireless devices. The Emergency Director is responsible for the notification to the Resource Manager. As described in Section 5.1 of this Plan, the on-shift staff positions are staffed on a 24-hour per day basis and can perform all required IOEP actions.
As described in Section 6.2, the Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration.
Additionally, a Radiological Responder will be contacted for an event requiring radiological accident assessment. At the direction of the Emergency Director, additional personnel will be activated to augment the on-shift staff.
9.3.4 Notification of Offsite Response Organizations The ORO support services described in Section 5.2 of this Plan are primarily notified of the need for assistance via 911 utilizing the commercial telephone system. Requests for ORO support services are the responsibility of the Emergency Director.
10.0 EMERGENCY COMMUNICATIONS Provisions exist for prompt communications between principal response organizations and emergency response personnel. The communications systems listed in Table 10-1 provide 24-hour onsite and offsite communications capability allowing for prompt notification and activation of emergency personnel. In the event of an emergency declaration, these communications systems provide the appropriate means for alerting or activating emergency personnel in each response organization and allow continued means for contact throughout the emergency.
Communications systems providing the capability for onsite and offsite communications are tested to verify proper operation at the frequencies specified in Table 10-1. A testing frequency of "Frequent Use" indicates that the associated equipment is normally used at a sufficiently high regularity (e.g., multiple times each day), such that a dedicated testing frequency is not needed. Functionality is verified through normal (frequent) use of the system.
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Reference Use Page 26 of 44 TABLE 10-1 Communication Systems Communication System Testing Frequency Commercial Telephone System Daily Portable Radios Frequent Use 11.0 PUBLIC INFORMATION The Emergency Director or Resource Manager will notify the corporate public affairs office of an emergency declaration. Public affairs office personnel will monitor media activity and coordinate with senior management to address rumors and disseminate information to the public.
To ensure timely dissemination of information to the public, news conferences can be conducted onsite or at other locations, as necessary. Corporate public affairs personnel, or senior PNPS or corporate management will represent the facility as the company spokesperson.
12.0 EMERGENCY FACILITY AND EQUIPMENT Adequate emergency facilities and equipment to support the emergency response are provided and maintained. This section of the IOEP identifies and describes the ERF, assessment equipment, the first aid and medical facilities, and protective equipment and supplies that can be utilized during an emergency.
12.1 Emergency Response Facility During an emergency, command and control functions are managed within the ERF. From this location, the Emergency Director (or other personnel, as directed) can assess ISFSI conditions; evaluate the magnitude and potential consequences of abnormal conditions; initiate preventative and corrective actions; and perform emergency notifications.
The ERF is staffed in accordance with Section 6.0 of this Plan. The facility provides sufficient space to accommodate anticipated response personnel and provides 24-hour availability of the communications systems specified in Section 10.0.
Radiological conditions resulting from the DBAs specified in the Holtec HI-STORM FSAR do not inhibit staffing of the ERF.
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Reference Use Page 27 of 44 12.2 Emergency Equipment and Supplies This section describes the monitoring instruments used to initiate emergency measures and provide continuing assessment of conditions throughout the course of an emergency.
12.2.1 Portable Radiation and Contamination Monitoring Instruments PNPS maintains portable radiation and contamination monitoring equipment necessary for monitoring the conditions of the ISFSI. These instruments are normally utilized and maintained by radiation monitoring personnel and are available for emergency use.
12.2.2 Communication Systems Communications systems providing for 24-hour per day onsite and offsite communications capabilities are identified and tested as described in Section 10.0.
12.2.3 Emergency Supplies Emergency equipment and supplies necessary to carry out the provisions of the IOEP and support procedures are maintained in the ERF.
Appendix A, "Emergency Equipment, Supplies, and Reference Materials," lists equipment, supplies, and. reference materials that are to be maintained in the ERF and other onsite locations.
13.0 ACCIDENT ASSESSMENT Effective response to a potential emergency situation requires assessment to determine the nature of the emergency and its actual and potential consequences. PNPS has established various methods to evaluate and monitor the effects of a potential emergency and has the appropriate means to ensure adequate assessment.
The assessment activities required to evaluate a particular emergency depend on the specific nature and classification of the emergency. The Emergency Director is responsible for the initial measurement of ISFSI dose rates after off-normal, natural phenomena, or accident events. The EALs identify the parameter value to determine the emergency condition. Classification of events is performed by the Emergency Director in accordance with the EAL scheme.
If the measured ISFSI dose rates exceed the EAL threshold, the Emergency Director ensures a radioactive release assessment in the vicinity of the affected storage module or cask is performed. After the assessment is complete, the Emergency Director contacts the Resource Manager for assistance in interpreting the results of the radioactive release assessment.
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14.0 PROTECTIVE ACTIONS Protective actions for onsite personnel are provided for their health and safety.
Implementation guidelines for onsite protective actions are provided in EPIPs.
Additionally, implementing procedures provide for a range of protective actions to protect onsite personnel during hostile actions.
14.1 Accountability The Emergency Director has the authority to initiate personnel accountability.
Accountability should be considered and used as a protective action whenever a risk to health or safety exists, or at the discretion of the Emergency Director. If personnel accountability is required, at the direction of the Emergency Director, all individuals at the facility (including employees without emergency assignments, visitors, and contractor personnel) shall be notified of the emergency and provided with instructions.
Accountability of all personnel inside the ISFSI Protected Area should be accomplished within 60 minutes after event declaration and maintained thereafter at the discretion of the Emergency Director. Following announcement of an emergency declaration, onsite personnel are responsible for reporting to designated areas and aiding the accountability process. If personnel are not accounted for, the Emergency Director is notified and onsite announcements are made. If personnel are still unaccounted for following the onsite announcements, Security will initiate sweeps to locate the missing individual(s).
Accountability may be modified or suspended if the safety of personnel could be jeopardized by a security event or other event hazardous to personnel health and safety.
14.2 Personnel and Visitors Located Outside the ISFSI Protected Area Other areas within the Site Boundary may be affected by the need to relocate personnel. If required, the Emergency Director will determine the specific areas requiring protective actions. Personnel and visitors located outside of the ISFSI Protected Area but within the Site Boundary, will be directed to report to an assembly area or exit the site as appropriate, in accordance with EPIPs. The Emergency Director is responsible for controlling access to the site when the IOEP is activated.
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Reference Use Page 29 of 44 15.0 RADIOLOGICAL EXPOSURE CONTROL The means for controlling radiological exposures during an emergency are established for emergency workers. The means for controlling radiological exposures include exposure guidelines consistent with the Environmental Protection Agency's (EPA)
Emergency Worker and Lifesaving Activity Protective Action Guides (PAGs).
15.1 Exposure Guidelines During an emergency, doses above normal occupational radiation exposure limits may be authorized by the Emergency Director for activities such as saving a life, preservation of valuable equipment, or controlling exposure.
All reasonable measures shall be taken to control the radiation exposure to emergency response personnel providing rescue, first aid, decontamination, emergency transportation, medical treatment services, corrective actions, or assessment actions within applicable limits specified in 10 CFR Part 20. The Emergency Director is responsible for authorizing emergency response personnel to receive doses in excess of 10 CFR Part 20 limits. This authority cannot be delegated.
Table 15-1 contains the guidelines for emergency exposure criteria, which is consistent with Table 3-1, "Response Worker Guidelines," of the EPA's "Protective Action Guide and Planning Guidance for Radiological Incidents."
15.2 Radiation Protection PNPS maintains a radiological exposure control program to ensure that protection against radiological exposure, as set forth in 10 CFR Part 20, is provided. Exposure to individuals providing emergency functions will be consistent with the limits specified in Table 15-1 with every attempt, made to keep exposures As Low As Reasonably Achievable (ALA RA).
15.2.1 Access Control During a classified emergency, radiological surveys of the ISFSI and its immediate vicinity will be performed to determine the extent of the radiological concern. The Emergency Director will ensure Radiological Control Areas (RCAs) and access controls are established to prevent personnel from entering the area.
Recovery and corrective actions will be planned and executed in a manner that minimizes personnel exposure.
15.2.2 Personnel Exposure Monitoring Personal dosimeters are utilized to monitor the exposure of personnel during normal or emergency conditions. Adequate supplies of dosimeters are maintained for use during an emergency. Procedures describe the types of Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 30 of 44 personal dosimeter devices, the manner in which they are to be used, who is to wear them, and how they are to be cared for.
Emergency worker dose records are maintained in accordance with Radiation Protection procedures.
15.3 Personnel Contamination Control Various contamination control measures are utilized. These include access control measures and the means for the decontamination of personnel, areas, and equipment. These activities are addressed in facility procedures and are briefly described below.
All personnel are monitored for radioactive contamination prior to leaving the site.
Portable contamination monitoring instruments are available to frisk personnel for potential contamination.
During normal or emergency conditions, contamination should be removed from any part of a person's body prior to leaving the RCA. All personnel decontamination, including during an emergency, will be performed in accordance with established Radiation Protection procedures.
Documentation of surveys, contamination, and decontamination activities shall be maintained in accordance with Radiation Protection procedures.
TABLE 15-1 Response Worker Emergency Dose Limits Guideline Activity Condition 5 Rem All occupational exposures All reasonably achievable actions have been taken to minimize dose.
10 Rem (a) Protecting valuable property Exceeding 5 rem unavoidable and necessary for public welfare all appropriate actions taken to reduce dose. Monitoring available to project or measure dose.
25 Rem (b)(c) Lifesaving or protection of Exceeding 5 rem unavoidable and large populations all appropriate actions taken to reduce dose. Monitoring available to project or measure dose.
(a) For potential doses > 5 rem, medical monitoring programs should be considered.
(b) In the case of a very large incident, consider the need to raise the property and lifesaving Response Worker Guideline to prevent further loss.
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Note 1: Reference for this table is Table 2-2 of the EPA PAG Manual.
Note 2: The dose limits in Table 15-1 are in addition to any annual occupational dose already received.
16.0 MEDICAL AND HEALTH SUPPORT Arrangements are made for medical services for injured individuals and/or contaminated injured individuals. PNPS maintains on-shift personnel and supplies to provide first-aid for personnel working at the site. Medical emergency supplies are located in various locations.
If immediate professional medical help is required, arrangements exist with local ambulance and medical services to assist in the transport and treatment of injured personnel, as described in Section 5.2. Assistance is requested via 911 utilizing the commercial telephone system.
16.1 Onsite First Aid First aid assistance at the PNPS ISFSI is designed to address a wide range of common injuries. This task is accomplished by on-site individuals trained in basic first aid.
16.2 Medical Transportation Plymouth Fire Department provides 24-hour per day ambulance dispatch for emergency transportation of personnel for offsite treatment, including the transport of contaminated injured workers. Transportation is also available via PNPS vehicles or private vehicles, if necessary.
When personnel are transported to Beth Israel Deaconess Hospital - Plymouth or Morton Hospital in a contaminated condition, personnel trained in radiological monitoring will be dispatched to monitor and maintain radiological controls.
16.3 Offsite Medical Support Beth Israel Deaconess Hospital - Plymouth and Morton Hospital accepts and treats personnel with routine industrial injuries as well as injuries complicated by radioactive contamination or radiation exposure. The hospital maintains the capability and facilities to provide radioactive decontamination. These services and facilities are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
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Reference Use Page 32 of 44 17.0 EMERGENCY TERMINATION AND RECOVERY PNPS has established general plans described in the following sections to address recovery from potential emergencies at the PNPS ISFSI. The recovery organization will be based on the normal PNPS ISFSI organization. The senior management position directs the recovery organization and is responsible for:
- Managing onsite recovery activities during the initial recovery phase;
17.1 Emergency Termination and Notification Termination of a declared emergency is the responsibility of the Emergency Director. The Emergency Director is also responsible for providing notification of the emergency termination and initiation of recovery operations to MEMA, Plymouth Fire Department, PNPS ISFSI personnel, the NRC, and other organizations that may be providing on-site support.
At the discretion of the Emergency Director, PNPS may enter recovery operations and the ISFSI could be returned to a stable condition before terminating the emergency.
17.2 Recovery Operations PNPS is responsible for recovery measures and restoring the ISFSI to a stable condition. In an emergency event, immediate response actions are directed towards limiting the consequences of the emergency in a manner that will afford maximum protection to onsite personnel. Once the immediate assessment and protective actions have been implemented, the restoration and recovery measures can be initiated.
The extent and nature of the corrective and protective actions and the extent of recovery will depend on the emergency conditions and the status of the ISFSI.
The general goals for recovery include:
- An orderly evaluation of the cause and effect of the emergency and implementation of solutions to prevent immediate recurrence of the incident
- A planned approach for returning the ISFSI to a stable condition by obtaining the appropriate resources, materials, and equipment
- A planned approach to coordinate with offsite authorities to identify and resolve situations that may impact the general public Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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- An evaluation of the radiation exposure records for all onsite emergency response personnel involved in the incident
- A planned approach to ensure that radiation exposures and contamination controls are consistent with the ALARA program ISFSI recovery activities shall be in accordance with the ISFSI Technical Specifications and other licensee documents. During ISFSI recovery, the radiation exposure limits of 10 CFR Part 20 shall apply.
- If, during recovery operations, an emergency situation occurs, recovery efforts will be suspended until the emergency condition is resolved. The Emergency Director will re-evaluate ISFSI conditions prior to resuming recovery.
17.3 Termination of Recovery Operations The recovery operations will be terminated by PNPS's senior management position directing the recovery organization after the ISFSI is returned to a stable condition.
18.0 EXERCISES AND DRILLS Periodic exercises are conducted to evaluate major portions of PNPS's emergency response capabilities. Periodic drills are conducted to develop and maintain key skills.
Deficiencies as a result of exercises or drills are identified and corrected.
An exercise tests the execution of the overall emergency preparedness and the integration of this preparedness. A drill is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular response function. A summary of exercises and drills, including the associated elements for each, is outlined below.
18.1 Emergency Plan Exercises and Drills A Biennial Exercise is conducted for the purposes of testing: 1) the adequacy of timing and content of implementing procedures and methods; 2) emergency equipment and communication networks, and; 3) to ensure that emergency personnel are familiar with their duties. PNPS offers the following organizations the opportunity to participate to the extent that their assistance would be expected during an emergency declaration. However, participation is not required.
- Plymouth Fire Department
- Beth Israel Deaconess Hospital - Plymouth
- Morton Hospital Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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- LLEAs At least one drill involving a combination of some of the principal functional areas of emergency response shall be conducted in the interval between Biennial Exercises for the purpose of testing, developing, and maintaining the proficiency of emergency responders.
Exercise and Drill scenarios will include, at a minimum, the following:
- The basic objective(s) of the exercise/drill
- The date(s), time period, place(s), and participating organizations
- A time schedule of real and simulated events
- A narrative summary describing the conduct of the drill to include such items as simulated casualties, offsite fire assistance, rescue of personnel, and use of protective clothing The scenarios will be varied from year to year such that all major elements of the plans and preparedness organizations are tested.
18.2 Equipment and Proficiency Drills Drills are conducted for the purpose of training, developing, and maintaining the proficiency of emergency responders. Additionally, drills may be used to test and evaluate the adequacy of the ERF, equipment, procedures, communication channels, actions of emergency response personnel, and coordination between OROs and the facility.
18.2.1 Communication Drills To ensure that emergency communications systems described in Section 10.0 are operable, communications tests are conducted as outlined below.
- 1. To test the capability to notify MEMA utilizing commercial telephone system, the capability is functionally tested annually. This drill will include the aspect of understanding the content of the message.
- 2. To test the capability to communicate with the NRC, communication systems are tested annually.
- 3. The following communications systems, as detailed in Section 10.0, are used on a frequent basis, therefore periodic testing of these systems is not necessary:
- Commercial Telephone System
- Portable Radios Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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18.2.2 Staff Augmentation Drills An unannounced, off-shift, staff augmentation drill shall be conducted annually.
These drills shall involve implementation of the ERO callout system procedure and documentation of the estimated response time for each responder. This drill shall serve to demonstrate the capability to augment the Emergency Director after an emergency declaration.
18.2.3 Radiological Monitoring Drills Radiological monitoring drills are conducted annually. These drills demonstrate the ability to perform radiological survey and assessment and can be performed separately or as part of an Emergency Plan exercise or drill.
18.2.4 Medical Emergency Drills To evaluate the training of medical response personnel, a medical drill is conducted annually involving a simulated contaminated injured individual and may also contain provisions for participation by local fire department(s) and hospital(s) This drill may be performed separately or as part of the Biennial Exercise.
18.2.5 Fire Drills Fire Drill are conducted in accordance with the PNPS Fire Protection Program.
18.3 Critique Evaluation Critiques are used to evaluate the performance of participating facility personnel and the adequacy of the ERF, equipment, and procedures. The ability of emergency response personnel to self-evaluate weaknesses and identify areas for improvement is key to successful exercise or drill conduct.
Exercise and drill performance objectives are evaluated against measurable demonstration criteria. As soon as possible following the conclusion of each exercise or drill, a critique, including participants and evaluators, is conducted to evaluate the ability of the ERO to implement the IOEP and associated procedures. Deficiencies identified during exercises or drills are entered into the corrective actions program.
A written report is prepared following an exercise or drill involving the evaluation of designated objectives. The report evaluates and documents the ability of the ERO to respond to a simulated emergency situation. The report will also contain reference to corrective actions and recommendations for revisions to the IOEP, Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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19.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING Radiological emergency response training is provided to those who may be called on to assist in an emergency. All personnel at the PNPS ISFSI who fill required positions in the ERO will take part in a training program to ensure adequate preparedness to assist in an emergency situation. OROs that may be called upon for emergency assistance will also be invited to participate in appropriate training programs.
19.1 Emergency Response Personnel Training Requirements for emergency preparedness training are specified in the Emergency Preparedness Training Program. This program identifies the level and the depth to which individuals are to be trained. The training program for emergency response personnel is based on position-specific responsibilities as defined in the IOEP. Emergency response personnel in the following categories receive initial training and annual retraining.
19.1.1 ISFSI Shift Supervisors/Emergency Directors and Resource Managers The ISS/Emergency Directors and Resource Managers shall have training conducted such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.
- EAL classification
- Offsite notification procedures
- ERO activation
- Dose rate meter operation
- Radioactive release assessment
- Emergency exposure control
- Protective actions for onsite personnel
- Review of applicable drill and exercise-identified deficiencies Personnel available during declared emergencies who may be called upon to perform emergency response activities as an extension of their normal duties Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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19.1.2 First Aid Personnel First Aid training is provided to personnel assigned on-shift in accordance with site training and qualification plan.
19.1.3 Radiation Monitoring Personnel Radiation monitoring personnel shall have training conducted such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.
- Use of Radiation Protection procedures
- Use of emergency survey equipment
- Communications
- Field Surveys
- Role of dose assessment in an emergency
- Monitoring of radioactive releases
- Protective actions for onsite personnel
- Review of applicable drill and exercise-identified deficiencies 19.1.4 Personnel Badged for Unescorted Access Personnel who are badged for unescorted access receive access training annually. Information pertaining to their safety and the safety of visitors under escort during a classified emergency is included in this training.
Access training shall include the following emergency preparedness topics:
- Basic Emergency Plan and implementing preparedness topics
- Emergency classification levels
- Call out of personnel during an emergency
- Personnel accountability procedures Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 38 of 44 19.2 Non-PNPS Emergency Response Support Organizations Training is offered annually to OROs that may be requested to provide assistance in the event of an emergency at the PNPS ISFSI (e.g., law enforcement, firefighting, rescue, medical services, transport of injured, etc.). The training shall be structured to meet the needs of the particular organization with respect to the nature of their support. Training topics such as event notification, site access procedures, basic radiation protection, and interface activities between the ORO and PNPS are included in the training.
19.3 Annual Emergency Action Level Training The emergency classification system specified in Section 8.0 and the EALs are reviewed with the authorities of the Commonwealth of Massachusetts, annually.
20.0 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW, AND DISTRIBUTION Responsibilities for IOEP development and review and for distribution of the IOEP are established and planners are properly trained.
20.1 Emergency Preparedness Responsibilities 20.1.1 Overall Authority and Responsibility A member of PNPS's senior management has the overall authority and responsibility for emergency response planning and implementation of the IOEP.
This responsibility includes ensuring that the emergency preparedness program is maintained and implemented as described in the IOEP, and that applicable requirements and regulations are met.
20.1.2 Maintaining the IOEP The PNPS ISFSI senior management position is responsible for maintaining an adequate knowledge of emergency preparedness regulations, emergency planning techniques, and the latest applications of emergency equipment and supplies. The position is responsible for the following tasks:
- Maintaining and updating this Plan and associated procedures
- Ensuring exercise and drill commitments stated in this Plan are met
- Ensuring material readiness of the ERF
- Overseeing the Emergency Preparedness Training Program
- Maintaining Emergency Preparedness interfaces with OROs Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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- Performing and documenting appropriate evaluations of the Emergency Preparedness program and classified emergency events Individuals assigned the duties of maintaining the IOEP are required to maintain an adequate knowledge of regulations, planning techniques, and the latest applications of emergency equipment and supplies. Training for these individuals includes 10 CFR 50.54(q) Evaluation Qualification.
20.1.3 Audits Independent audits of the emergency preparedness program meeting the requirements of 10 CFR 50.54(t) will be performed. All aspects of emergency preparedness, including exercise documentation, capabilities, procedures, and interfaces with state and local governments are audited.
20.2 Review and Updating of the IOEP The IOEP, the associated EPIPs, and the ISFSI Only EAL Technical Bases Documents are reviewed at least annually, and updated as needed, in accordance with the requirements of 10 CFR 50.54(q). The review shall encompass the need for changes based upon the following:
- Written critiques and evaluations of drills and exercises
- Changes in the organizational structure
- Changes in the functions and capabilities of supporting agencies
- Changes in Federal or State regulations
- Modifications to the facility which would affect emergency planning
- Recommendations or agreement changes received from other organizations Any changes shall be incorporated in the IOEP, EPIPs, and the ISFSI Only EAL Technical Bases Document. Proposed activities that may impact the IOEP must be evaluated per 10 CFR 50.54(q).
20.2.1 Emergency Telephone Directory Names and telephone numbers of the ERO and supporting OROs shall be reviewed at least annually and updated as necessary).
20.2.1 Letters of Agreement Written agreements with outside support organizations listed are evaluated biennially to determine if these agreements remain valid. If agreements are determined to no longer be valid, then they are updated and renewed with the applicable organization.
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Reference Use Page 40 of 44 20.3 Training The Emergency Preparedness position shall assist senior management in coordinating and/or providing emergency planning-related training. The position shall ensure that the training described in Section 19.0 is properly coordinated to ensure adequate qualifications, training, and retraining of personnel.
20.4 Maintenance and Inventory of Emergency Equipment and Supplies Specific emergency response equipment and reference materials are listed in Appendix A. The items listed in Appendix A are inspected, inventoried, and operationally checked quarterly and after each use. Sufficient reserves are maintained to replace those which are removed for calibration or repair.
Equipment in these inventories is checked and calibrated in accordance with approved procedures.
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Reference Use Page 42 of 44 APPENDIX A EMERGENCY EQUIPMENT, SUPPLIES AND REFERENCE MATERIALS EMERGENCY RESPONSE FACILITY Procedures / Reference Materials
- ISFSI Only Emergency Plan
- Emergency Telephone Directory
- EPIPs Equipment
- Portable radiation monitoring instrument
- Portable emergency lighting
- Medical emergency response kit ONSITE LOCATIONS Equipment / Supplies
- Portable radiation and contamination monitoring instruments
- Contamination control supplies
- Decontamination control supplies
- Protective clothing
- Dosimeters
- Radiological postings and barricades Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 43 of 44 APPENDIX B CROSS-REFERENCE IOEP SECTION TO PLANNING STANDARDS/REQUIREMENTS/CRITERIA AND EPIPS Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Reference Use Page 44 of 44 APPENDIX B-1 CROSS-REFERENCE BETWEEN THE PDEP, NUREG-0654/FEMA-REP-1, 10 CFR 50.47(b) PLANNING STANDARDS, AND APPENDIX E.IV PLANNING REQUIREMENTS IOEP Planning Planning NUREG-0654 Procedure Section Standard Requirement Section II Evaluation (10CFR50.47)** (Appendix E.IV)** Criteria 5.0 (b)(1) A.1,2,4,7 A TBD 6.0 (b)(2) A.1,2,4,9; C.1 B TBD 7.0 (b)(3) A.6,7 C TBD 8.0 (b)(4) B.1,2;C.1,2 D TBD 9.0 (b)(5) A.6,7;C.1,2;D.1,3;E E TBD 10.0 (b)(6) C.1;D.1,3;E F TBD 11.0 (b)(7) Exempt G TBD 12.0 (b)(8) E;G H TBD 13.0 (b)(9) A.4;B.1;C.2;E I TBD 14.0 (b)(10) C.1;E;I J TBD 15.0 (b)(11) E K TBD 16.0 (b)(12) A.6,7;E L TBD 17.0 (b)(13) H M TBD 18.0 (b)(14) E9;F N TBD 19.0 (b)(15) F O TBD 20.0 (b)(16) G P TBD
- as exempted Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-098 Attachment 3 Updated PNPS ISFSI Only Emergency Actions Levels (EALs) and Technical Basis (23 pages follow)
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and Technical Bases Reference Use Page 1 of 23 SEE PROCEDURE EP-AD-270 FOR EQUIPMENT IMPORTANT TO EMERGENCY RESPONSE (EITER)
SUMMARY
OF REVISIONS Revision 0: Implement ISFSI Only Emergency Plan by aligning Emergency Action Levels (EALs) with DPP-PIL-EP-001 Previous revision is EP-IP-100.1, Revision 13 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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and Technical Bases Reference Use Page 2 of 23 TABLE OF CONTENTS PURPOSE ............................................................................................................ 3 DISCUSSION ....................................................................................................... 3 2.1 Permanently Defueled Facility .............................................................................. 3 2.2 Independent Spent Fuel Storage Installation ........................................................ 4 KEY TERMINOLOGY USED ................................................................................ 4 3.1 Emergency Classification Levels (ECLs) .............................................................. 4 3.2 Initiating Condition (IC) ......................................................................................... 5 3.3 Emergency Action Level (EALs) ........................................................................... 6 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ............................ 6 4.1 General Considerations ........................................................................................ 6 4.2 Classification Methodology ................................................................................... 7 4.3 Classification of Multiple Events and Conditions .................................................. 7 4.4 Classification of Imminent Conditions ................................................................... 7 4.5 Emergency Classification Level Upgrading and Termination ............................... 8 4.6 Classification of Short-Lived Events ..................................................................... 8 4.7 Classification of Transient Conditions ................................................................... 8 4.8 After-the-Fact Discovery of an Emergency Event or Condition ............................ 8 4.9 Retraction of an Emergency Declaration .............................................................. 9 REFERENCES ..................................................................................................... 9 5.1 Developmental...................................................................................................... 9 5.2 Implementing ........................................................................................................ 9 5.3 Commitments ....................................................................................................... 9 ACRONYMS & DEFINITIONS ............................................................................ 10 6.1 Acronyms ........................................................................................................... 10 6.2 Definitions ........................................................................................................... 10 ATTACHMENTS................................................................................................. 12 Attachment 1, EAL Matrices ...................................................................................... 13 Attachment 2, EAL Bases .......................................................................................... 16 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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and Technical Bases Reference Use Page 3 of 23 PURPOSE This document provides the detailed set of Emergency Action Levels (EALs) applicable to the Pilgrim Nuclear Power Station (PNPS) when all nuclear fuel has been located at the Independent Spent Fuel Storage Installation (ISFSI) and the associated Technical Bases using the EAL development methodology found in NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (NEI 99-01, Appendix C, Rev. 6). As a permanently defueled facility, PNPS will use the Recognition Category "PD" (Permanently Defueled) to provide a site-specific emergency classification scheme including a set of Initiating Conditions (ICs) and EALs associated with the permanently defueled condition and Recognition Category "E" ICs for the ISFSI. Permanently defueled station ICs and EALs are addressed in Appendix C of NEI 99-01, Rev. 6. All recommendations for changes to this document or associated implementing procedures are reviewed in accordance with 10 CFR 50.54(q).
This document should be used to facilitate review of the PNPS EALs, provide historical documentation for future reference, and serve as a resource for training. Individuals responsible for the classification of events will refer to the ICs and EALs contained in the matrix of this document. They may use the information in the associated "Basis" and "Notes" sections as a reference in support of EAL interpretation. An EAL matrix may be provided as a user aid.
Emergency classifications are to be made as soon as conditions are present and recognizable for the classification in accordance with the applicable EALs; but within 30 minutes in all cases after the availability of indications to operators that an EAL threshold has been reached. Use of this document for assistance is not intended to delay the emergency classification.
DISCUSSION Permanently Defueled Facility NEI 99-01, Appendix C, Rev. 6, provides guidance for an emergency classification scheme applicable to a permanently defueled facility. This is a facility that generated spent fuel under a 10 CFR Part 50 license, has permanently ceased operations and will store the spent fuel onsite for an extended period of time. The emergency classification levels applicable to permanently defueled facility are consistent with the requirements of 10 CFR Part 50 and NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1" (NUREG-0654).
The NRC has approved specific exemptions to Emergency Planning regulations for PNPS confirming that no credible event can result in a significant radiological release beyond the site boundary. There is no source term and motive force available in the Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Therefore, the generic ICs and EALs applicable to a permanently defueled facility may only result in either a Notification of UNUSUAL EVENT (UNUSUAL EVENT) or ALERT classification.
Independent Spent Fuel Storage Installation Selected guidance in NEI 99-01, Rev. 6, is applicable to licensees electing to use their 10 CFR Part 50 emergency plan to fulfill the requirements of 10 CFR 72.32 for a stand-alone Independent Spent Fuel Storage Installation (ISFSI). The emergency classification levels applicable to an ISFSI are consistent with the requirements of 10 CFR Part 50. The initiating conditions germane to a 10 CFR 72.32 emergency plan (as described in NUREG-1567, "Spent Fuel Dry Storage Facilities") are subsumed within the classification scheme for a 10 CFR 50.47 emergency plan.
The analysis of potential onsite and offsite consequences of accidental releases associated with the operation of an ISFSI is contained in NUREG-1140, "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees" (NUREG-1140). NUREG-1140 concluded that the postulated worst-case accident involving an ISFSI has insignificant consequences to public health and safety.
This evaluation shows that the maximum offsite dose to a member of the public due to an accidental release of radioactive materials would not exceed 1 rem Total Effective Dose Equivalent.
Regarding the above information, the expectations for an offsite response to an ALERT classified under a 10 CFR 72.32 emergency plan are generally consistent with those for an UNUSUAL EVENT in a 10 CFR 50.47 emergency plan (e.g., to provide assistance if requested). Also, the licensee's Emergency Response Organization (ERO) required for 10 CFR 72.32 emergency plan is different from that prescribed for a 10 CFR 50.47 emergency plan (e.g., there is no emergency technical support function required).
KEY TERMINOLOGY USED There are several key terms that appear throughout the NEI 99-01, Rev. 6, methodology. These terms are introduced in this section to support understanding of subsequent material.
Emergency Classification Levels (ECLs)
One of a set of names or titles established by the U.S. Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The ECLs that remain applicable to PNPS, in ascending order of severity, are:
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Events are in progress or have occurred which indicate a potential degradation of the level of safety of the facility or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.
Purpose:
The purpose of this classification is to assure that the first step in future response has been carried out, to bring the operations staff to a state of readiness, and to provide systematic handling of UNUSUAL EVENT information and decision-making.
ALERT Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the facility or a security event that involves probable life-threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the Environmental Protection Agency (EPA)
Protective Action Guides (PAG) exposure levels.
Purpose:
The purpose of this classification is to assure that emergency personnel are readily available to respond if the situation becomes more serious or to perform confirmatory radiation monitoring if required and provide offsite authorities current information on facility status and parameters.
Initiating Condition (IC)
An event or condition that aligns with the definition of one of the two ECLs by virtue of the potential or actual effects or consequences.
Discussion: An IC describes an event or condition, the severity or consequences of which meets the definition of an ECL. An IC can be expressed as a continuous, measurable parameter (e.g., radiation monitor readings) or an event (e.g., an earthquake).
Appendix 1 of NUREG-0654 does not contain example EALs for each ECL, but rather ICs (i.e., conditions that indicate that a radiological emergency, or events that could lead to a radiological emergency, have occurred). NUREG-0654 states that the ICs form the basis for establishment by a licensee of the specific facility instrumentation readings (as applicable) which, if exceeded, would initiate the emergency classification. Thus, it is the specific instrument readings that would be the EALs.
Emergency Action Level (EALs)
A pre-determined, site-specific, observable threshold for an IC that, when met or exceeded, places the facility in a given ECL.
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and Technical Bases Reference Use Page 6 of 23 Discussion: EAL statements may utilize a variety of criteria including instrument readings and status indications, observable events, results of calculations and analyses, entry into particular procedures, and the occurrence of natural phenomena.
GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS General Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an IC. This includes the EAL plus Notes and the informing Basis information.
All emergency classification assessments should be based upon valid indications, reports or conditions. A valid indication, report, or condition is one that has been verified through appropriate means such that there is no doubt regarding the indicator's operability, the condition's existence, or the report's accuracy. For example, validation could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by personnel. The validation of indications should be completed in a manner that supports timely emergency declaration.
For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 60 minutes, etc.), the Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.
A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that 1) the activity proceeds as planned and 2) the facility remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain, or modify a system or component. In these cases, the controls associated with the planning, preparation, and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72.
The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., gaseous and liquid effluent sampling, etc.); the EAL and/or the associated basis discussion will identify the necessary analysis. In these cases, the declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available).
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and Technical Bases Reference Use Page 7 of 23 While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01, Rev. 6, scheme provides the Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the ECL definitions (refer to PD-HU3 and PD-HA3). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.
Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e.,
the relevant facility indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL(s) must be consistent with the Notes.
If an EAL has been met or exceeded, then the IC is considered met and the associated ECL is declared in accordance with facility procedures.
When assessing an EAL that specifies a time duration for the off-normal condition, the EAL time duration runs concurrently with the emergency classification time duration.
Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared.
For example:
There is no "additive" effect from multiple EALs meeting the same ECL. For example:
- If two UNUSUAL EVENT EALs are met, an UNUSUAL EVENT should be declared.
Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, "Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events."
Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is Imminent). If, in the judgment of the Emergency Director, meeting an EAL is Imminent, the emergency classification should be made as if the EAL has been met. While applicable to all ECLs, this approach is particularly important at the higher ECL since it provides additional time for implementation of protective measures.
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and Technical Bases Reference Use Page 8 of 23 Emergency Classification Level Upgrading and Termination An ECL may be terminated when the event or condition that meets the IC and EAL no longer exists. Events will not be downgraded.
As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02.
Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events would be an earthquake or explosion.
Classification of Transient Conditions It is important to stress that the emergency classification assessment period is not a "grace period" during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event; emergency classification assessments must be deliberate and timely, with no undue delays.
After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.
In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022, "Event Report Guidelines 10 CFR 50.72 and 50.73," is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR 50.72 within one hour of the discovery of the undeclared event or condition.
The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.
Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022.
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and Technical Bases Reference Use Page 9 of 23 REFERENCES Developmental NEI 99-01 Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2007 NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 10 CFR 72.32, Emergency Plan NUREG-1567, Spent Fuel Dry Storage Facilities 10 CFR 50.47, Emergency Plans NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees Implementing EP-PP-01 R. 54, ISFSI Only Emergency Plan EP-IP-100.1, R. 14 Emergency Action Levels and Bases Commitments None Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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and Technical Bases Reference Use Page 10 of 23 ACRONYMS & DEFINITIONS Acronyms ABN ................................................................................ Abnormal Operating Procedure CDE ..................................................................................... Committed Dose Equivalent CFR ..................................................................................... Code of Federal Regulations cpm ...................................................................................................... Counts per Minute EAL ............................................................................................ Emergency Action Level ECL ................................................................................. Emergency Classification Level EPA ............................................................................. Environmental Protection Agency FAA ................................................................................. Federal Aviation Administration FBI .................................................................................. Federal Bureau of Investigation FEMA ............................................................. Federal Emergency Management Agency ISFSI ........................................................... Independent Spent Fuel Storage Installation IC.......................................................................................................... Initiating Condition mRem .............................................................................. milli-Roentgen Equivalent Man MSL ........................................................................................................ Mean Sea Level NEI ............................................................................................. Nuclear Energy Institute NORAD .................................................. North American Aerospace Defense Command NRC .............................................................................. Nuclear Regulatory Commission ODCM .......................................................................... Off-site Dose Calculation Manual PAG ............................................................................................. Protective Action Guide PD ................................................................................................. Permanently Defueled rem .......................................................................................... Roentgen Equivalent Man TEDE .............................................................................. Total Effective Dose Equivalent
µCi/cc......micro Curies per Cubic Centimeter UFSAR ............................................................. Final Safety Analysis Report as Updated Definitions NOTE: Selected terms used in IC and EAL statements are set in all capital letters (e.g., ALL CAPS).
ALERT: Refer to Section 3.1.2.
CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.
Emergency Action Level (EAL): Refer to Section 0.
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Initiating Condition (IC): Refer to Section 0.
HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) or its personnel that includes the use of violent force to destroy equipment, take Hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force.
Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).
HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
Imminent: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.
INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.
NORMAL LEVELS: As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.
OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business.
PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.
SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.
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and Technical Bases Reference Use Page 12 of 23 VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.
ATTACHMENTS Attachment 1: EAL Matrices Attachment 2: EAL Basis Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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and Technical Bases Reference Use Page 13 of 23 ATTACHMENT 1 Table PD-1: Recognition Category "PD" and E Initiating Condition Matrix ALERT UNUSUAL EVENT Independent Spent Fuel Storage Installation E-HU1: Damage to a loaded cask CONFINEMENT BOUNDARY Hazards and Other Conditions PD-HA1 HOSTILE ACTION is occurring or has PD-HU1 Confirmed SECURITY CONDITION or occurred. threat.
PD-HA3 Other conditions exist which in the PD-HU3 Other conditions exist which in the judgment of the Emergency Director warrant judgment of the Emergency Director warrant declaration of an ALERT. declaration of an UNUSUAL EVENT.
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and Technical Bases Reference Use Page 14 of 23 ATTACHMENT 1 Table PD-1: Recognition Category "PD" and E Initiating Condition Matrix ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Facility Safety PD-HA1 HOSTILE ACTION is occurring or has PD-HU1 Confirmed SECURITY CONDITION or threat occurred. at the Independent Fuel Storage Installation (ISFSI)
Hostile Action Emergency Action Level (EAL):
- 1. A HOSTILE ACTION is occurring or has Emergency Action Level (EAL):
occurred as reported by the Security Shift Supervisor. 3. Notification of a credible security threat directed at the site OR
- 4. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.
PD-HA3 Other conditions exist which in the judgment PD-HU3 Other conditions exist which in the judgment of the Emergency Director warrant of the Emergency Director warrant declaration of an ALERT. declaration of an UNUSUAL EVENT.
Emergency Director Judgment Emergency Action Level (EAL): Emergency Action Level (EAL):
Other conditions exist which, in the judgment of the Other conditions exist which in the judgment of the Emergency Director, indicate that events are in Emergency Director indicate that events are in progress progress or have occurred which involve an actual or or have occurred which indicate a potential degradation potential substantial degradation of the level of safety of the level of safety of the facility or indicate a security of the facility or a security event that involves probable threat to facility protection has been initiated. No life-threatening risk to site personnel or damage to site releases of radioactive material requiring offsite equipment because of HOSTILE ACTION. Any response or monitoring are expected unless further releases are expected to be limited to small fractions of degradation of equipment required for spent fuel cooling the EPA Protective Action Guideline exposure levels. occurs.
Emergency Director Judgment Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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and Technical Bases Reference Use Page 15 of 23 ATTACHMENT 1 Table PD-1: Recognition Category "PD" and E Initiating Condition Matrix ALERT UNUSUAL EVENT ISFSI Malfunction E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.
Emergency Action Level (EAL):
- 1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than EITHER of the following:
60 mrem/hr (gamma + neutron) on the top of the OVERPACK OR ISFSI 600 mrem/hr (gamma + neutron) on the side of the OVERPACK, excluding inlet and outlet ducts Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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and Technical Bases Reference Use Page 16 of 23 Recognition Category PD EAL Basis Recognition Category PD provides a stand-alone set of ICs/EALs for a Permanently Defueled nuclear facility to consider for use in developing a site-specific emergency classification scheme. For development, it was assumed that the plant had operated under a 10 CFR Part 50 license and that the operating company has permanently ceased plant operations. Further, the company intends to store the spent fuel within the plant for some period of time.
PNPS received NRC approval for exemptions from specific emergency planning requirements. These exemptions reflect the lowered radiological source term and risks associated with spent fuel pool storage relative to reactor at-power operation.
Subsequently all spent fuel has been removed from the Spent Fuel Pool and located within the ISFSI. Source terms and accident analyses associated with plausible accidents are documented in the ISFSI Final Safety Analysis Report (FSAR), and site Decommissioning Safety Analysis Report (DSAR). As a result, each licensee will need to develop a site-specific emergency classification scheme using the NRC-approved exemptions, revised source terms, and revised accident analyses.
Recognition Category PD uses the same ECLs as operating reactors; however, the source term and accident analyses limit the ECLs to an UNUSUAL EVENT and ALERT.
The UNUSUAL EVENT ICs provide for an increased awareness of abnormal conditions while the ALERT ICs are specific to actual or potential impacts to spent fuel. The source terms and release motive forces associated with a permanently defueled facility would not be sufficient to require declaration of a Site Area Emergency or General Emergency.
A permanently defueled facility where all fuel has been located to the ISFSI is essentially a spent fuel storage facility. The ISFSI relies on passive decay heat removal and passive shielding further reducing the potential for events.
In NEI 99-01, Rev. 6, appropriate ICs and EALs from Recognition Category H was modified and included in Recognition Category PD to address a spectrum of the events that may affect an ISFSI.
Recognition Category E EAL Basis Recognition Category E provides a set of ICs/EALs for an ISFSI. An ISFSI is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a cask must escape its packaging and enter the atmosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel. Formal offsite planning is not required because the postulated worst-case accident involving an ISFSI has insignificant consequences to the public health and safety.
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This includes classification based on a loaded fuel storage cask confinement boundary loss leading to the degradation of the fuel during storage or posing an operational safety problem with respect to its removal from storage.
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HOSTILE ACTION is occurring or has occurred.
Emergency Action Level (EAL):
- 1. A HOSTILE ACTION is occurring or has occurred as reported by the Security Shift Supervisor.
Basis:
This IC addresses the notification of an aircraft attack threat or an occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the facility and staff for a potential aircraft impact.
Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
As time and conditions allow, these events require a heightened state of readiness by the facility staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The ALERT declaration will also heighten the awareness of Offsite Response Organizations (ORO), allowing them to be better prepared should it be necessary to consider further actions.
This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.
EAL #1 Basis This EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the facility PROTECTED AREA.
Basis Reference(s):
- 1. NEI 99-01 Rev 6, PD-HA1
- 2. Station Security Plan Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Confirmed SECURITY CONDITION or threat.
Emergency Action Level (EAL):
- 1. Notification of a credible security threat directed at the site.
- 2. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.
Basis:
This IC addresses events that pose a threat to facility personnel or ISFSI, and thus represent a potential degradation in the level of facility safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs PD-HA1.
Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
EAL #1 Basis Addresses the receipt of a credible security threat.
EAL #2 Basis References Security Force because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.
Escalation of the emergency classification level would be via IC PD-HA1.
Basis Reference(s):
- 1. NEI 99-01 Rev 6, PD-HU1
- 2. Station Security Plan Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT.
Emergency Action Level (EAL):
- 1. Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the facility or a security event that involves probable life-threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.
Basis:
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an ALERT.
Basis Reference(s):
- 1. NEI 99-01, Rev 6, PD-HA3 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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Other conditions exist which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT.
Emergency Action Level (EAL):
- 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the facility or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of equipment required for spent fuel cooling occurs.
Basis:
This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENT.
Basis Reference(s):
- 1. NEI 99-01, Rev 6, PD-HU3 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
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and Technical Bases Reference Use Page 22 of 23 E-HU1 Initiating Condition Damage to a loaded cask CONFINEMENT BOUNDARY.
Emergency Action Level (EAL):
- 1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than EITHER of the following:
- 60 mrem/hr (gamma + neutron) on the top of the OVERPACK OR
- 600 mrem/hr (gamma + neutron) on the side of the OVERPACK, excluding inlet and outlet ducts PNPS Basis:
CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.
This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.
The existence of damage is determined by radiological survey. The technical specification multiple of 2 times, which is also used in Recognition Category A IC AU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the on-contact dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.
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and Technical Bases Reference Use Page 23 of 23 E-HU1 (cont)
While multiple loading arrangements may exist at any one time, the administrative controls regarding on-contact radiation readings are consistent for all loading arrangements at PNPS. On-contact radiation readings are defined as 30 mrem/hr on the top of the overpack, and 300 mrem/hr on the sides of the overpack, excluding near the inlet and outlet ducts per the cask system technical specifications (Ref. 1). The thresholds in this EAL incorporate the two times multiple described above.
Figure E-1 illustrates the HI-STORM 100 Overpack.
Security-related events for ISFSIs are covered under ICs HU1 and HA1.
Basis Reference(s):
- 1. Technical Specifications for the HI-STORM 100 Cask System, Administrative Control 5.7.4 Figure E-1: HI-STORM 100 This diagram is also applicable for the MPC-68 Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-098 Attachment 4 Pilgrim Nuclear Power Station (PNPS) Response Plan, Town of Plymouth, Section 5.5, Roles and Responsibilities, dated November 2020 (5 pages follow)
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 0
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