ML22027A667

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Shine Technologies, LLC, Operating License Application Supplement No. 16 Submittal of a Revision to the Shine Emergency Plan
ML22027A667
Person / Time
Site: SHINE Medical Technologies
Issue date: 01/27/2022
From:
SHINE Technologies
To:
Office of Nuclear Reactor Regulation
Shared Package
ML22027A664 List:
References
2022-SMT-0020 EMG-01-01, Rev. 1
Download: ML22027A667 (74)


Text

ENCLOSURE 2 SHINE TECHNOLOGIES, LLC SHINE TECHNOLOGIES, LLC OPERATING LICENSE APPLICATION SUPPLEMENT NO. 16 SUBMITTAL OF A REVISION TO THE SHINE EMERGENCY PLAN SHINE EMERGENCY PLAN PUBLIC VERSION

EMG-01-01 Rev. 1 Emergency Plan REVISION LOG Revision # Description of Changes EMG-01-01 Superseded 2800-12-01 Rev 5. Updated for adoption of 1 REM accident dose criterion. Updated EALs to reflect CALC-2020-0027 changes and removed reference to CALC-2018-0048. Updated FSAR 0 reference to correct section for CAAS in section 9.4. Updated Figures 1 and 2 to current revision. Updated Appendix 2 list of radioactive and hazardous materials. Updated Appendix 5 list of EPIPs. Updated section 9.2.1 to reflect available equipment.

Per IMR 2021000384 action A191174, updated Section 3.2.1 to reflect roles and responsibilities of plant management: Added Diagnostics General Manager, Director of Plant Operations, Director of Corporate Support; Deleted COO and Plant Manager. Updated Figure 10 with accurate organizational chart.

Removed ICP-OES (elemental identification) as a laboratory capability from Section 9.4.3. Updated Section 8.6.2 by replacing SHINE Building One with SHINE Headquarters breakroom as the contingency off-site assembly area and updated descriptions of the main production facility breakroom (primary ESC) and main production facility conference room. Updated Section 8.1.4 1

to reflect the correct Document IDs for the Radiation Protection Program and the Respiratory Protection Program. Updated Section 10.2 by adding the requirement that personnel are trained in specific recovery actions required by the SHINE Safety Analysis. Updated Section 11.1 with the addition of specific recovery actions required by the SHINE Safety Analysis as a training topic. Updated Section 9.2.2 by replacing SHINE Building One with SHINE Headquarters breakroom as the contingency emergency support center. Updated Figure 3 to show SHINE Headquarters on area map.

Minor administrative changes made.

Emergency Plan Page 2 of 74

EMG-01-01 Rev. 1 Emergency Plan TABLE OF CONTENTS 1 Introduction ......................................................................................................................... 4 2 Definitions ........................................................................................................................... 7 3 Organization and Responsibilities ....................................................................................... 9 4 Emergency Classification System ..................................................................................... 17 5 Emergency Action Levels.................................................................................................. 18 6 Emergency Planning Zones .............................................................................................. 19 7 Activation of the ERO and Notification .............................................................................. 19 8 Emergency Response ....................................................................................................... 21 9 Emergency Facilities and Equipment ................................................................................ 29 10 Recovery........................................................................................................................... 37 11 Maintaining Emergency Preparedness.............................................................................. 38 12 References ....................................................................................................................... 46 Figures ............................................................................................................ 47 Radioactive and Hazardous Materials ............................................................. 58 Agreement Letters ........................................................................................... 64 Emergency Action Levels ................................................................................ 67 Emergency Plan Implementing Procedure (EPIP) List ..................................... 74 Emergency Plan Page 3 of 74

EMG-01-01 Rev. 1 Emergency Plan 1 INTRODUCTION 1.1 Purpose The purpose of the SHINE Technologies, LLC. (SHINE) emergency plan is to describe the essential elements of advance planning and necessary provisions for coping with and mitigating the consequences of emergencies within and beyond the SHINE site boundary. The plan is primarily focused on situations that may cause or threaten to cause radiological hazards that could affect employee or public health and safety. The plan also includes provisions for coping with other on-site emergency situations commensurate with their severity.

1.2 Scope This emergency plan applies to the SHINE facility.

This plan was written to conform with 10 CFR 50, Appendix E, following the guidance of:

Regulatory Guide 2.6, Revision 2, Emergency Planning for Research and Test Reactors and Other Non-Power Production and Utilization Facilities; ANSI/ANS-15.16-2015, Emergency Planning for Research Reactors; ANSI/ANS-8.23-2007, Nuclear Criticality Accident Emergency Planning and Response; and NUREG-0849, Standard Review Plan for the Review and Evaluation of Emergency Plans for Research and Test Reactors.

NUREG-1520, Revision 2, Standard Review Plan for the Review of a License Application for a Fuel Cycle Facility 1.3 Overview The emergency plan includes descriptions of the facility and organizations, and of emergency classifications, responses, recovery processes, and preparedness.

SHINE management is committed to ensuring this emergency plan is established, exercised and maintained.

Emergency personnel may deviate from actions described in the plan for unusual or unanticipated conditions at the direction of the Emergency Director. Reasonable actions that depart from license conditions or technical specifications may be authorized by a senior licensed operator in accordance with 10 CFR 50.54(x) and (y) if immediately needed to protect the public health and safety, and no action consistent with license conditions and technical specifications that can provide adequate or equivalent protection is immediately apparent.

1.4 SHINE Facility The SHINE facility is owned and operated by SHINE Technologies, LLC, and is located at 4021 South US Highway 51, Janesville WI, 53546.

The SHINE facility includes the following structures (see Figure 1):

Main production facility Resource building Material staging building Emergency Plan Page 4 of 74

EMG-01-01 Rev. 1 Emergency Plan Storage building N2PS structure The SHINE facility involves the use of a non-reactor based, subcritical fission process for the purpose of manufacturing medical isotopes. The SHINE facility contains irradiation units (IUs),

each with a target solution vessel (TSV) with a licensed fission power of 125 kWth, located in the irradiation facility (IF) area of the main production facility. Also located in the IF are rooms and cells housing off-gas handling equipment, cooling equipment, tritium purification equipment, and an area for servicing neutron drivers.

The radioisotope production facility (RPF) area of the main production facility contains a hot cell bank (the supercell); below-grade vaults containing tanks, other process components, and storage space; two laboratories; and areas for waste-handling, cooling, and other equipment. The remaining areas of the facility, the control room area and the administrative annex area, contain the control room, electrical equipment, additional auxiliary equipment, and other miscellaneous areas. The general layout of the main production facility is provided in Figure 2.

1.5 Site Description The SHINE site consists of an approximately 91-acre parcel in the City of Janesville, Rock County, Wisconsin. The dominant land use in the region is agricultural/cultivated crops. The northern limits of the City of Beloit are located approximately 4 miles to the south. The SHINE site is accessed from U.S. Highway 51.

The figures provided in Appendix 1 depict major features of the SHINE site and surrounding area:

Figure 1 contains the site boundary, fences, gates, roads and parking lots on site, on-site structures and tanks, and U.S. Highway 51.

Figure 2 shows the general arrangement layout of the main production facility, which includes the following four areas:

o Irradiation facility (IF) o Radioisotope production facility (RPF) o Control room area o Administrative annex area Figure 3 provides an aerial view of the area surrounding the SHINE site, including the location of on-site structures and sensitive facilities near the SHINE site (0-1 mile),

including churches, parks, residences, airstrips, and educational facilities. Farms are distributed throughout the one-mile radius of the SHINE site. There are no medical facilities within one mile of the SHINE site.

Figure 4 shows a general area map, constructed from U.S. Geological Survey (USGS) topographical quadrangles (7.5 minute series), and includes the SHINE facility site boundary.

Figures 5 through 8 show the individual USGS topographical quadrangles (7.5 minute series) containing or adjacent to the SHINE site.

1.6 Facility Activities and Materials The licensed activities and other major activities conducted at the SHINE facility include:

Preparation and irradiation of uranyl sulfate target solution; and Emergency Plan Page 5 of 74

EMG-01-01 Rev. 1 Emergency Plan Extraction, purification and packaging of medical isotopes from irradiated target solution inside hot cells.

The SHINE facility contains radioactive and hazardous materials that are part of the overall medical isotope production process. Appendix 2 provides the types, quantities and locations of radioactive and hazardous materials normally on the SHINE site.

1.7 Facility Emissions The SHINE main production facility contains a facility vent stack at a height of 67 ft and a flow rate of approximately 26,200 cfm. The stack uses high efficiency particulate air (HEPA) filters and single stage high efficiency gas adsorption (HEGA) filter equipment for emission control. A stack release monitor provides information on radiation released from the facility stack.

1.8 Community Right to Know SHINE certifies that the responsibilities under the Emergency Planning and Community Right To Know Act (EPCRA) of 1986 (Title Ill, Public Law 99-499) in accordance with 10 CFR 70.22(i)(3)(xiii) will be met.

1.9 Accident Summary The following general types of accidents may require the implementation of protective actions:

Failure of the primary system boundary leading to a spill of target solution inside an irradiation unit (IU) cell.

Malfunction of the TSV off-gas system (TOGS) leading to a gaseous release of fission products inside an IU or TOGS shielded cell.

Failure of one or more neutron drivers leading to a release of gaseous tritium inside an IU cell.

Failure of tritium-containing equipment leading to a release of gaseous tritium inside the tritium purification system (TPS) room or the IF general area.

Malfunction of isotope extraction equipment leading to a spill of target solution or other radioactive material inside the supercell.

Leak or spill of target solution or other radioactive material into the radioactive liquid waste enclosure, or into a tank vault, pipe trench, or other shielded location.

Fire in a process vessel vent system (PVVS) carbon guard bed or carbon delay bed.

Unshielded criticality accident in the uranium storage or target solution preparation areas.

Additional information on potential facility accidents can be found in Chapter 13 of the SHINE Final Safety Analysis Report (FSAR).

Measures and equipment used to respond to and detect accidents and to detect releases are described in Section 9.

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EMG-01-01 Rev. 1 Emergency Plan 2 DEFINITIONS 2.1 Emergency action levels (EALs): Specific instrument readings or observations, radiological dose or dose rates, or specific contamination levels of airborne, waterborne, or surface-deposited radioactive materials that may be used as recognized conditions that result in actions such as a) establishing emergency classes and b) initiating appropriate emergency measures.

2.2 Emergency

An emergency is a condition that calls for immediate action, beyond the scope of normal operating procedures, to avoid an accident or to mitigate the consequences of one.

2.3 Emergency classes: Emergency classes are classes of accidents grouped by severity level for which predetermined emergency measures should be taken or considered. In order of increasing severity, the emergency classes applicable to this plan consist of 1)

Notification of Unusual Event, 2) Alert, and 3) Site Area Emergency, consistent with ANSI/ANS-15.16-2015.

2.4 Emergency plan: An emergency plan is a document that provides the basis for actions to cope with an emergency. It outlines the objectives to be met by the emergency procedures and defines the authority and responsibilities to achieve such objectives.

2.5 Emergency plan implementing procedures (EPIPs): EPIPs are documented instructions that detail the implementation actions and methods required to achieve the objectives of the emergency plan.

2.6 Emergency planning zone (EPZ): Area for which emergency planning is performed to assure that prompt and effective actions can be taken to protect the public in the event of an accident. The SHINE EPZ is the operations boundary.

2.7 Emergency response: Actions taken from the time of identification of a suspected, imminent, or actual accident or event to stabilization of the event, including the assumption that an accident has occurred, response to the emergency, and actions to begin subsequent recovery operations.

2.8 Hostile action: An act towards a facility or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end.

2.9 Immediate evacuation zone: The area surrounding a potential accident location that must be evacuated without hesitation if an alarm signal (e.g., criticality accident alarm or radiation area alarm) is activated.

2.10 Non-essential personnel: Those personnel not needed for the continuing existence or functioning of the Emergency Response Organization (ERO). They are personnel not required to fill certain positions in the ERO. Identification of non-essential personnel is circumstance-oriented as determined by the Emergency Director.

2.11 Off-site: The geographical area that is beyond the site boundary.

2.12 On-site: The geographical area that is within the site boundary.

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EMG-01-01 Rev. 1 Emergency Plan 2.13 Operations boundary: The area within the site boundary where the shift supervisor has direct authority over all activities. The area within this boundary has prearranged evacuation procedures known to personnel frequenting the area. The controlled access area fence and the perimeter walls of the main production facility, the material staging building, the storage building, and the resource building are the SHINE operations boundary.

2.14 Protective actions: Actions to be taken to prevent or minimize exposure to radiation, radioactive materials, and other hazardous materials following a release.

2.15 Radiologically Controlled Area (RCA): An area where access is controlled by SHINE to limit exposure to radiological hazards.

2.16 Site boundary: The site boundary is that boundary, not necessarily having restrictive barriers, surrounding the operations boundary wherein the Emergency Director may directly initiate emergency activities. The area within the site boundary may be frequented by people unacquainted with the facility operations. The SHINE site boundary is the property line of the SHINE site. The site boundary is synonymous with the (owner) controlled area.

2.17 Technical staff: Personnel with specific skills and experience who can assist in the implementation of the requirements defined in this plan. Such personnel may include, but are not limited to, criticality safety, health and safety, and facility process support personnel. Technical staff includes, but is not limited to, engineering, radiation protection and maintenance personnel.

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EMG-01-01 Rev. 1 Emergency Plan 3 ORGANIZATION AND RESPONSIBILITIES 3.1 Emergency Response Organization The Emergency Response Organization (ERO) is responsible for taking actions in an emergency to avoid an accident or to mitigate the consequences of one. The ERO is staffed with trained and qualified ERO personnel. ERO members attend formal initial and continuing training and participate in drills and exercises. The ERO consists of two groups: 1) the facility emergency organization and 2) the emergency support organizations.

Figure 9 illustrates the interrelationship between the facility emergency organization and the emergency support organizations within the total emergency response effort.

The facility emergency organization consists of SHINE staff members who are on-site at the time of the emergency or who may be called in to assist as required.

The emergency support organizations are those organizations and agencies that may be called upon for specific assistance based on the type of emergency. The roles of these agencies are described in Section 3.4. Agreement letters with these support agencies can be found in Appendix 3.

The ERO described in this section comprise the key positions of the recovery organization.

Additional information on ERO roles and responsibilities is provided in the EPIP addressing Emergency Response Organization Responsibilities.

3.2 Normal Facility Operating Organization The initial response to any emergency is by the normal SHINE facility on-shift organization present at the site. Off-shift personnel may be called in to assist as required, as described in Section 7.

3.2.1 Normal Operating Organization Chief Executive Officer (CEO): The CEO is responsible for the overall management and leadership of the company.

Diagnostics General Manager: The Diagnostics General Manager is responsible for operational aspects of the diagnostics division.

Director of Plant Operations: The Director of Plant Operations is responsible for the overall operation of the facility.

Director of Corporate Support: The Director of Corporate Support is responsible for facility radiation protection, security, and training.

Operations: The facility operations personnel are responsible for the operation of the facility, and the safe, reliable, efficient plant operations.

Security: The facility security personnel are responsible for the physical security of the facility.

Engineering: The facility engineering personnel are responsible for providing technical expertise and support of facility operation and maintenance, and for controlling the physical facility configuration to ensure that facility operation, maintenance and configuration are maintained in accordance with the design basis. Engineering personnel are part of the facility technical staff and include criticality safety engineers, i.e., individuals with experience, training and qualification in criticality safety.

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EMG-01-01 Rev. 1 Emergency Plan Radiation Protection: The facility radiation protection personnel are responsible for handling and monitoring of radioactive materials. Radiation protection personnel are part of the facility technical staff.

Maintenance: The facility maintenance personnel are responsible for performing maintenance on facility equipment in accordance with facility procedures, instructions and technical requirements.

Chemistry: The facility chemistry personnel are responsible for sampling, analysis, and product quality control activities. They are considered part of the facility technical staff.

Executive, support, administrative, and other personnel (support personnel): These individuals have various responsibilities involving procurement, licensing, quality, finance, etc., and may include personnel normally stationed off-site.

3.2.2 On-shift personnel, include, but are not limited to:

Shift supervisor: A senior licensed operator responsible for the safe operation of the facility.

Licensed operators (including any additional on-shift senior licensed operators, if present): Responsible for ensuring licensed activities are conducted safely and in accordance with the facility license and procedures.

Non-licensed operating staff: Responsible for conducting operations in the facility in accordance with procedures and under the direction of licensed operators.

Security personnel: Responsible for the physical security of the facility.

Radiation protection individual: At least one individual capable of monitoring radiation dose rates and contamination levels is present on each shift.

The organization for managing and operating the SHINE facility is provided in Figure 10.

3.3 Facility Emergency Organization The facility emergency organization is initially staffed by on-shift personnel. Upon activation of the ERO, designated off-shift personnel will be notified to report to the Emergency Support Center (ESC), once it has been activated, or the control room if the ESC has not yet been activated.

Sufficient SHINE staff, with relevant expertise, comprise the facility emergency organization, such that SHINE is able to maintain a continuous around-the clock emergency response effort for as long as necessary.

The duties of the below listed ERO roles may be assumed by any of the individuals authorized for that role upon their arrival at the facility, and be passed from one individual to another, but only after being thoroughly briefed on status of the event and the currently proposed plan of action.

Individuals may delegate their actual duties, with the exception of the non-delegable responsibilities of the Emergency Director, but may not delegate the responsibility for their duties.

The facility emergency organization is shown in Figure 11.

3.3.1 Emergency Director The Emergency Director is authorized to and responsible for directing and coordinating the overall emergency response. The role of the Emergency Director is initially filled by the on-shift shift supervisor. Only individuals who have received Emergency Director training are authorized to assume the Emergency Director responsibilities. In the event Emergency Plan Page 10 of 74

EMG-01-01 Rev. 1 Emergency Plan the shift supervisor or the subsequent Emergency Director is absent from the facility or incapacitated, the Emergency Director responsibility will be assumed by the most senior operations department individual on-site, until a relief Emergency Director arrives at the facility. The Emergency Director has the following non-delegable responsibilities:

Emergency event classification and decision to declare an emergency; Decision to activate the ERO; Decision to initiate on-site protective actions; Decision to notify off-site response authorities; Decision to request support from off-site organizations; Authorization of reentry into portions of the facility or site that may have been evacuated during the emergency; Authorization of volunteer emergency workers to incur radiation exposures in excess of normal 10 CFR 20 occupational limits; and Decision to terminate the emergency and initiate recovery actions.

The Emergency Director has the following additional, delegable, responsibilities:

Activation of the ERO; Notification of off-site response authorities when a Notification of Unusual Event, Alert, or Site Area Emergency has been declared within 15 minutes of event classification; Notification of the NRC Operations Center within one hour of declaring the emergency; Assessment of damage to and status of the facilitys capabilities to safely control radioactive material or hazardous chemicals associated with licensed activities; Prioritizing responses to concurrent emergencies; and Informing the ERO of planned emergency organization actions or changes.

3.3.2 Shift Supervisor The shift supervisor acts as the initial Emergency Director upon declaration of an emergency. In the event the shift supervisor is absent from the facility or incapacitated, the most senior licensed operator will assume the shift supervisor responsibilities, in accordance with facility procedures. While acting as the Emergency Director, the shift supervisor will take immediate action during an emergency and will activate the ERO, as appropriate. Additionally, the shift supervisor has the following responsibilities, whether or not he or she is acting as the Emergency Director:

Implementing immediate actions to respond to the emergency in accordance with facility emergency procedures; Directing and supervising the activities of the control room staff; and Emergency Plan Page 11 of 74

EMG-01-01 Rev. 1 Emergency Plan The responsibility for the safe operation of the plant in compliance with the facility NRC operating license, technical specifications, facility operating procedures and the requirements for their use. During an emergency, personnel may deviate from actions described in the plan for unusual or unanticipated conditions.

3.3.3 Emergency Communicator The Emergency Communicator assists the Emergency Director in the execution of the Emergency Directors duties. The role of the Emergency Communicator is initially filled by an individual on-site, typically a member of the normal on-shift staff or on-site support personnel, appointed by the Emergency Director. A relief Emergency Communicator may be called in as part of the ERO activation, if required. The individuals authorized to assume the role of the Emergency Communicator are various SHINE personnel, including support personnel, who are designated to fill the roll, as described in the EPIP addressing Emergency Response Organization Responsibilities. In the event the Emergency Communicator becomes absent from the facility or incapacitated, the Emergency Director shall appoint another individual present at the facility to assume the role of Emergency Communicator until a relief Emergency Communicator arrives at the facility.

The Emergency Communicator is responsible for Exchanging information with off-site authorities responsible for coordinating and implementing off-site emergency measures, including transmitting dose projections and monitoring and surveying information; Relating information about the emergency situation to the news media and the public; and Ensuring a record of the events during and following the emergency is maintained.

3.3.4 Radiation Safety Coordinator The Radiation Safety Coordinator is responsible for making radiological assessments and advising the Emergency Director, including responsibility for Making on-site and off-site dose assessments and projections; Recommending protective actions; and Identifying exposed personnel and determining their radiation dose.

The Radiation Safety Coordinator may collect on-site and off-site field monitoring data or monitor radiation dose rates and contamination levels if required. The role of the Radiation Safety Coordinator is initially filled by an on-site individual with radiation protection experience. A relief Radiation Safety Coordinator may be called-in as part of the activation of the ERO, if required. The individuals authorized to assume the responsibilities of the Radiation Safety Coordinator are radiation protection department personnel and members of the facility technical or operational staff with radiation protection experience. In the event the Radiation Safety Coordinator is absent from the facility or incapacitated, the Technical Support Coordinator will assume the responsibilities until a relief Radiation Safety Coordinator arrives at the facility.

Emergency Plan Page 12 of 74

EMG-01-01 Rev. 1 Emergency Plan 3.3.5 Technical Support Coordinator The Technical Support Coordinator is responsible for coordinating the technical response to the event, including Performing technical assessments of facility emergencies; Assisting the Emergency Director and Radiation Safety Coordinator in technical matters; and Coordinating the technical staff to augment the ERO on an as needed basis to support accident assessment and mitigation activities.

The individuals authorized to assume the responsibilities of the Technical Support Coordinator are members of the facility technical staff. In the event the Technical Support Coordinator is absent from the facility or incapacitated, the Radiation Safety Coordinator will assume the responsibilities until a relief Technical Support Coordinator arrives at the facility.

3.3.6 Criticality Safety Engineer A criticality safety engineer is called-in upon activation of the ERO if a criticality event is suspected or confirmed, at the discretion of the Emergency Director or Technical Support Coordinator. The criticality safety engineer, when required, is responsible for Advising and assisting the Emergency Director in responding to the criticality accident; and Assisting the Radiation Safety Coordinator in conducting a radiological dose assessment appropriate for a criticality accident.

The criticality safety engineer role is filled by a designated, criticality safety qualified and trained facility engineer. If the criticality safety engineer is absent or incapacitated when required, the Radiation Safety Coordinator assumes the responsibilities until a relief criticality safety engineer arrives at the facility.

3.3.7 Security Personnel Security personnel that are present at the facility when an emergency is declared will implement EPIPs appropriate to the event classification. In the event Security personnel become absent or incapacitated, additional Security personnel may be called-in, if required. Security personnel are responsible for Performing personnel Accountability, if required; Implementing access control of facility areas, at the direction of the Emergency Director, if required.

3.3.8 Operations Personnel Operations personnel that are present at the facility when an emergency is declared will implement EPIPs appropriate to the event classification. In the event operations personnel become absent or incapacitated, additional operations personnel may be called-in, if required.

Operations personnel are responsible for Emergency Plan Page 13 of 74

EMG-01-01 Rev. 1 Emergency Plan Monitoring facility instrumentation and reporting results to the Emergency Director; and Implementing corrective actions at the direction of the Emergency Director.

3.3.9 Assessment Teams Assessment Teams are comprised of facility operations, technical staff, or support personnel who have completed Assessment Team training, who may be called-in upon activation of the ERO by the Emergency Director, as required for the situation.

Assessment Teams assist the Radiation Safety Coordinator in making radiological assessments by monitoring or collecting radiation dose rates and contamination levels.

Assessment Team personnel assigned to perform duties related to monitoring or collecting radiation dose rates and contamination levels are trained and qualified to do so. In the event Assessment Team personnel become absent or incapacitated, additional Assessment Team personnel may be called-in, if required.

Assessment Teams are responsible for Collecting on-site and off-site field monitoring data; Monitoring radiation dose rates and contamination levels; and Assessing collateral damage to the facility.

3.3.10 Reentry and Damage Control Teams Reentry and Damage Control Teams are comprised of facility operations, technical staff, or support personnel who have completed Reentry and Damage Control Team training, who may be called-in upon activation of the ERO by the Emergency Director, as required by accident conditions. Reentry and Damage Control Team personnel are trained in emergency response and reentry. Individuals may be assigned to both Assessment and Reentry and Damage Control Teams, depending on their experience, training, and qualifications. In the event Reentry and Damage Control Team personnel become absent or incapacitated, additional Reentry and Damage Control Team personnel may be called-in, if required. Reentry and Damage Control Teams are responsible for Reentering an immediate evacuation zone during the emergency on a voluntary basis after being informed of the potential hazards and risks; and Performing actions associated with controlling and stabilizing emergency events in-progress, at the direction of the Emergency Director.

3.4 Emergency Support Organizations In the event the decision is made by the Emergency Director to request support from off-site organizations, the following off-site support agencies and organizations would provide assistance as described below. Written agreements with these agencies can be found in Appendix 3. Local government agencies and organizations will be initially notified as described in Section 7 by contacting the Rock County 911 Communications Center. SHINE does not anticipate the need for Federal assistance.

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EMG-01-01 Rev. 1 Emergency Plan 3.4.1 Janesville Fire Department Fire Support If off-site fire support is needed, the Rock County 911 Communications Center will dispatch Janesville Fire Department personnel. The nearest Janesville Fire Station is Station #2, approximately 2.5 mi from the SHINE facility. If additional fire equipment is needed, or if the Janesville Fire Department is unavailable, the Rock County 911 Communications Center will activate existing mutual aid agreements with neighboring communities for dispatch of fire equipment and personnel to the site. In instances where radioactive/hazardous materials are involved, the Emergency Director or designee will ensure information and assistance is provided to the responding off-site personnel.

Information specific to the SHINE facility is located in the Rock County 911 Communications Centers response information binder, which includes a prohibition on the use of firefighting foam inside the facility, due to criticality safety concerns.

First Aid Support If immediate on-site first aid support is needed, the Rock County 911 Communications Center will dispatch Janesville Fire Department personnel. The Fire Department employs emergency medical technicians and individuals trained in first aid and qualified to provide immediate medical assistance required for radiological emergencies on-site.

Ambulance Services Transportation of an injured person from the SHINE facility to an off-site medical facility will be provided by Janesville Fire Department ambulances and dispatched by the Rock County 911 Communications Center. In the event that the Janesville Fire Department ambulances are not available, the Rock County 911 Communication Center will activate existing mutual aid agreements with neighboring communities for dispatch of an ambulance to the SHINE site.

Hazardous Materials Response If hazardous materials assistance is needed, the Janesville Fire Department Hazardous Material (HazMat) Response Team will be dispatched by the Rock County 911 Communication Center or by the local Fire Department Incident Commander.

3.4.2 Janesville Police Department If law enforcement support is needed, the Rock County 911 Communications Center will dispatch law enforcement personnel. If needed, the Janesville Police Department will contact the Rock County Sheriff's Department or Wisconsin State Patrol, which maintain sheriff's deputies and State troopers in the Janesville area that can respond if additional resources are needed. Emergency law enforcement support may include the following:

Providing traffic control; Controlling access to areas affected by the emergency; Assisting security personnel; Responding to emergencies at the facility, as necessary.

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EMG-01-01 Rev. 1 Emergency Plan 3.4.3 Hospitals The following local hospital has medical services available and staff that are trained and prepared to handle radiological emergencies:

SSM Health St. Mary's Hospital - 3400 East Racine Street - Janesville WI Any radiation exposed or contaminated injured individuals from the site would be transported to the above facility for treatment.

3.4.4 Rock County Emergency Management The Rock County Emergency Management organization is responsible for coordinating major emergencies, disaster response and recovery efforts in support of county and local governments. Rock County Emergency Management may provide additional resources to the response effort at its discretion.

3.4.5 State of Wisconsin The State of Wisconsin has the general authority and responsibility to assist local units of government and local law enforcement agencies in responding to a disaster or the imminent threat of a disaster. The State of Wisconsin coordinates its response with Rock County Emergency Management as needed.

3.5 Maintaining Emergency Preparedness The following individuals have roles related to maintaining emergency preparedness. Activities related to maintaining emergency preparedness are periodic or ongoing, and not required to be performed as part of the activation of the facility emergency organization. However, individuals responsible for maintaining emergency preparedness may also have roles in the facility emergency organization.

3.5.1 Operations Manager The Operations Manager is responsible for Coordinating emergency preparedness planning; Reviewing and updating the emergency plan and procedures; Coordinating plans with other applicable organizations, and Ensuring that any written arrangements with off-site agencies are reviewed and renewed, as necessary.

The Operations Manager may delegate these responsibilities and authorities to any designated member of the Operations organization.

3.5.2 Criticality Safety Lead Engineer The Criticality Safety Lead Engineer is responsible for Identifying potential criticality accident locations; Evaluating and characterizing potential criticality accidents, including making radiological dose predictions; Defining the immediate evacuation zone around the potential criticality accident locations; and Emergency Plan Page 16 of 74

EMG-01-01 Rev. 1 Emergency Plan Participating in the planning, conduct, and evaluation of exercises and drills.

These responsibilities may be delegated to any designated, qualified criticality safety engineer.

3.5.3 Radiation Protection Manager The Radiation Protection Manager is responsible for Determining the instrumentation and equipment requirements for emergency response activities.

Ensuring instrumentation and equipment is calibrated and maintained as required.

These responsibilities may be delegated to any designated member of the radiation protection organization.

3.5.4 Rock County Emergency Management The Rock County Emergency Management organization is responsible for preparing response agencies, volunteer organizations, the private sector, and citizens to respond to and recover from disasters through planning and training.

4 EMERGENCY CLASSIFICATION SYSTEM 4.1 Basis for Emergency Classifications The emergency plan provides for classification of emergencies into three standardized classes according to the severity of off-site radiological consequences: 1) Notification of Unusual Event,

2) Alert, and 3) Site Area Emergency, consistent with Table 1 of ANSI/ANS-15.16-2015. There are no credible accidents identified for the SHINE facility that would result in radiological levels exceeding the action levels for General Emergencies specified in Table 1 of ANSI/ANS-15.16-2015 at the site boundary. Therefore, the emergency plan does not include provisions for the General Emergency classification of event.

4.2 Emergencies Less Severe Than Notification of Unusual Events SHINE recognizes emergencies of lesser consequences than the Notification of Unusual Event classification. These include physical occurrences within the facility requiring facility emergency organization response. The initial assessment of these events should indicate that it is unlikely that an off-site hazard will be created. Protective evacuations or isolations of certain areas within the facility may be necessary. Responses to these emergencies of lesser consequence than a Notification of Unusual Event are based on the recognition of immediate need for on-site staff to implement emergency measures to provide aid to affected persons or to mitigate the consequences of damage to equipment; coupled with assessing radiological monitors to determine if the possibility of a more serious emergency is present.

Situations of lesser consequence than Notification of Unusual Events that may warrant implementation of portions of this emergency plan or select EPIPs include:

1) Severe injuries to personnel;
2) Fires in the incipient stage or industrial safety hazards;
3) Transportation accidents less than one mile from the facility involving radioactive or licensed material; Emergency Plan Page 17 of 74

EMG-01-01 Rev. 1 Emergency Plan

4) Spills or releases of non-radioactive hazardous materials not associated with processing of licensed materials; or
5) Other situations that warrant precautionary activation of the ERO, at the discretion of the Emergency Director.

4.3 Notification of Unusual Event A Notification of Unusual Event includes man-made events and natural phenomena creating a significant hazard potential that was previously non-existent. There is usually time available to take precautionary and corrective steps to prevent the escalation of the accident or to mitigate the consequences should it occur. No releases of radioactive or hazardous materials requiring off-site responses are expected.

Elements of the ERO will be activated or notified to increase the state of readiness as warranted by the circumstances.

Although the situation may not have caused damage to the facility, it may warrant preventive or mitigative actions or interruption of nonessential routine functions. Protective evacuations or isolation of certain areas of the facility may be necessary.

4.4 Alert An Alert means events may occur, are in progress, or have occurred, that could lead to a release of radioactive material or hazardous chemicals incident to the processing of licensed materials; however, the release is not expected to require a response by an off-site response organization to protect persons off-site. Substantial modification of facility operating status is a highly probable corrective action. Protective evacuations or isolation of certain areas within the operations boundary or within the site boundary may be necessary.

4.5 Site Area Emergency A Site Area Emergency means events may occur, are in progress, or have occurred that could lead to a significant release of radioactive material or hazardous chemicals incident to the processing of license material and that could require a response by off-site emergency response organizations to protect persons off-site.

A Site Area Emergency may be initiated when events such as major damage of primary boundaries containing radioactive or hazardous materials incident to the process of licensed material have occurred and actual or imminent failure of other physical barriers preventing releases have occurred and projected off-site radiological consequences exceed the action levels.

Monitoring at the site boundary should be conducted to assess the need for off-site protective actions. Protective measures on site may be necessary.

5 EMERGENCY ACTION LEVELS Emergency action levels (EALs) for the events described in the above emergency classes are found in Appendix 4.

These EALs have been established in terms of effluent monitors and other facility parameters from which the dose rates and radiological effluent releases at the site boundary can be projected.

Some EALs listed in Appendix 4 include estimated radiological doses to the public that may result from the event. Dose estimates are listed in terms total effective dose equivalent (TEDE) to the whole body in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, TEDE to the whole body in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and total dose equivalent (TDE) to the thyroid in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at site boundary. TDE is the sum of committed dose equivalent (CDE) and Emergency Plan Page 18 of 74

EMG-01-01 Rev. 1 Emergency Plan dose equivalent (DE) from external exposures to an organ. Estimated doses found in Appendix 4 are based on average meteorological conditions (i.e., 50th percentile atmospheric dispersion factors).

EALs are used as criteria for determining the need for notification and participation of local agencies and the Commission. This emergency plan includes EALs that are used for determining when and what type of protective actions for the facility staff on-site to protect health and safety.

The protective action guidelines are one rem whole body or five rem thyroid.

The SHINE safety analysis does not identify any events that could lead to a release of hazardous chemicals incident to the processing of license material that would require activation of the SHINE emergency response organization to protect persons on-site, or that would require a response by an off-site response organization to protect persons off-site. For this reason, there are no EALs related to releases of hazardous chemicals incident to the processing of license material.

6 EMERGENCY PLANNING ZONES There are no identified radiological emergencies at the SHINE facility that result in off-site plume exposure exceeding one rem whole body or five rem thyroid. Therefore, SHINE has identified an Emergency Planning Zone (EPZ) in accordance with the alternate method described in NUREG-0849 and ANSI/ANS-15.16-2015. The combined licensed power for all eight IU cells is less than 2 MW. Accordingly, the EPZ for the SHINE facility is the operations boundary.

7 ACTIVATION OF THE ERO AND NOTIFICATION The activation of the Emergency Response Organization will be staged with the immediate activation of all or portions of the facility emergency organization, followed by the activation of emergency support organizations as required.

7.1 Activation and Notification of the Facility Emergency Organization The shift supervisor or another individual authorized to assume the Emergency Director position shall implement the Activation of the Emergency Response Organization EPIP when it is determined that conditions exist exceeding the EALs or if conditions warrant activation of the facility emergency organization in the opinion of the shift supervisor. Notifications of the emergency declaration will be made to on-site personnel and on and off-site ERO members in accordance with the EPIP addressing Activation of the Emergency Response Organization.

Emergency notification rosters are maintained in the control room and ESC, and in all controlled copies of the Emergency Plan Implementing Procedures Manual.

At the Notification of Unusual Event classification, select ERO personnel are notified and requested to either report to the facility or to remain available to respond, as the situation dictates.

At an Alert classification or higher, ERO personnel are notified for activation of the ESC.

7.2 Activation of the Emergency Support Organizations The Emergency Director shall initiate the activation of the emergency support organizations upon the classification of a Site Area Emergency. The Emergency Director may activate all or part of the emergency support organizations for lower classes of emergencies in accordance with the EPIPs when off-site support is needed for the particular event, at the discretion of the Emergency Director.

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EMG-01-01 Rev. 1 Emergency Plan The emergency support organizations are activated by calling the Rock County 911 Communications Center, in accordance with the EPIP addressing Activation of the Emergency Response Organization. This EPIP contains instructions for message authentication and to ensure the message was received.

7.3 Notification of Off-site Organizations The Emergency Director ensures notifications are promptly made to off-site emergency response organizations as follows:

1) Local Agencies A notification shall be made to the Rock County 911 Communications Center within 15 minutes of the emergency classification.
2) Nuclear Regulatory Commission (NRC)

An event will be reported to the NRC Operations Center immediately after notification of the appropriate local agencies, but not later than one hour after declaration of an emergency.

3) State Agencies A notification will be made to the State of Wisconsin promptly after notification of the NRC Operations Center following the declaration of an emergency.

Follow-up notifications shall be made promptly whenever event conditions change significantly (e.g., event classification escalation, projected dose estimate changes), at the discretion of the Emergency Director, or at the request of an off-site organization.

Notifications are made in accordance with the EPIP addressing Notification and Communication, using concise, preformatted messages and standard reporting checklists to facility timely notification. The EPIP contains instructions for message authentication and to ensure the message was received.

Initial and follow-up notifications to off-site emergency response organizations including the NRC will contain the following information, to the extent known:

Name, title, and telephone number of the caller; Location of the incident; Emergency class; Description of the emergency event; Date and time of incident initiation; Type and quantity of radionuclides or hazardous material released or expected to be released; and Impact of releases and recommended off-site emergency actions.

Rock County Emergency Management, contacted via the Rock County 911 Communication Center, has processes in place for prompt notification of the public if required, which include a backup method. The responsibility for activating public alert and notification systems remain with the appropriate governmental authorities.

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EMG-01-01 Rev. 1 Emergency Plan The Emergency Communicator remains in periodic contact with off-site organizations via commercial telephone or other mutually agreeable mechanism to coordinate the emergency response and transmit updated dose projections, dose rates, contamination levels, or the results of field monitoring as necessary.

7.4 Activation of the Emergency Support Center The ESC is activated at an Alert classification or higher. Activation for other events is optional, at the discretion of the Emergency Director. Activation of the ESC is described in the Activation of the Emergency Response Organization EPIP.

8 EMERGENCY RESPONSE 8.1 Responses Applicable to All Emergencies 8.1.1 Protective Action Guidelines The Protective Actions for all classifications are based upon a guideline of one rem dose equivalent for whole body and five rem dose equivalent thyroid. Credible accidents at the SHINE facility do not result in off-site doses in excess of these guidelines.

8.1.2 Off-site Organization Responses Medical assistance shall be provided to injured personnel requiring more than first aid.

Off-site fire support shall be requested to respond to all fires that progress beyond the incipient stage.

Law enforcement shall be requested to respond to credible security events.

8.1.3 Voluntary Emergency Worker Exposures The Emergency Director may authorize volunteer emergency workers to incur radiation exposure in excess of 10 CFR 20 limits, according to the following guidelines:

Up to 10 rem TEDE for saving vital equipment Up to 25 rem TEDE for life-saving actions

>25 rem TEDE for life-saving actions only for people fully aware of the risks involved Individuals volunteering to receive doses in excess of 25 rem shall be briefed on the risks involved including the numerical levels of dose at which acute effects of radiation will be incurred and numerical estimates of the risk of delayed effects.

8.1.4 Provisions for Emergency Responders Use of Respirators: SHINE personnel use respiratory protection in any environment involving exposure to high level gaseous activity or oxygen deficient atmosphere, or where air quality is in doubt. In the presence of airborne particulates, emergency response personnel may be directed by the Radiation Safety Coordinator or radiation protection personnel to use full-face filter type respirators. The criteria for issuance of respiratory protection are described in RAD-01-03, Respiratory Protection Program.

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EMG-01-01 Rev. 1 Emergency Plan Use of Protective Clothing: Anti-contamination clothing, located in the facility dress out area and in the ESC is available for use by on-site personnel. The criteria for issuance of protective clothing are described in RAD-01-01, Radiation Protection Program.

8.1.5 Evacuation, Access Control, and Radiological Controls Evacuation is the primary protective action anticipated for on-site personnel. Additional information related to evacuation is found in Section 8.6.

The Emergency Director may direct isolation and access control of facility areas to minimize exposures to radiation and the spread of radioactive contamination. Access control is implemented by site Security. Additional information on contamination control is found in Section 9.5.

8.1.6 Concurrent Emergencies The ERO may implement more than one EPIP at any given time in order to respond to concurrent emergencies (e.g., fire, personnel injury or security incidents). The Emergency Director has the authority to prioritize emergency responses as necessary.

8.2 Emergencies Less Severe Than Notification of Unusual Events 8.2.1 Activation and Notification Actions The shift supervisor may activate the ERO, or portions of the ERO, if he or she feels conditions warrant activation.

Off-site emergency response organizations may be contacted for assistance if required.

8.2.2 Additional Actions Assessment, Corrective and Protective actions may be implemented in accordance with EPIPs, as required for the situation, at the discretion of the Emergency Director.

No radiological monitoring is anticipated to be required for this type of emergency, with the exception of transportation incidents. Personnel with portable survey equipment may be dispatched to assess the impact of transportation accidents involving licensed materials.

8.3 Notification of Unusual Event 8.3.1 Activation and Notification Actions The Emergency Director shall notify off-site organizations as described in Section 7.3.

Facility emergency organization personnel are notified as described in Section 7.1.

Personnel and requested to either report to the facility or to remain available to respond, at the discretion of the Emergency Director.

8.3.2 Assessment Actions During emergencies involving airborne radioactivity, facility and surrounding area airborne radioactivity levels shall be determined by the stack release monitor and carbon delay bed effluent monitor, installed area radiation monitors and continuous air monitors, and portable monitoring equipment used by members of the ERO and communicated to the Emergency Director.

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EMG-01-01 Rev. 1 Emergency Plan Assessment Team personnel may be dispatched to visually assess collateral damage to the facility caused by the event, or to monitor for potential releases inside or outside the facility.

The Emergency Director shall use this information and Appendix 4 to determine that the emergency is appropriately classified, and to determine release rates and contamination magnitudes, and to estimate projected exposures to on-site personnel.

8.3.3 Corrective Actions Shutdown and/or isolation of affected or at-risk equipment or suspension of related activities should be considered by the Emergency Director. Physical barriers to contain radioactivity shall be maintained or implemented where necessary.

Specific corrective actions are provided in the EPIP addressing Emergency Classification and Initial Accident Assessment and the applicable Emergency Response EPIP.

8.3.4 Protective Actions Protective actions may include instructing personnel to take shelter from severe natural phenomena, or evacuation of a room or small area of the SHINE facility.

8.4 Alert 8.4.1 Activation and Notification Actions The Emergency Director shall notify off-site organizations as described in Section 7.3.

ERO personnel are notified and the facility emergency organization is activated as described in Section 7.1.

o The criticality safety engineer shall report to the facility for situations involving or suspected of involving a criticality hazard.

The ESC is activated as described in Section 7.4.

8.4.2 Assessment Actions During emergencies involving airborne radioactivity, facility airborne radioactivity levels shall be determined by the stack release monitor and carbon delay bed effluent monitor, installed area radiation and continuous air monitors, and portable monitoring equipment used by members of the ERO and communicated to the Emergency Director.

During emergencies involving criticality hazards, criticality accident alarm system (CAAS) instrumentation shall be monitored for event escalation criteria.

Assessment Team personnel may be dispatched to visually assess collateral damage to the facility caused by the event, or to monitor for potential releases inside or outside the facility.

The Emergency Director shall use this information and Appendix 4 to determine that the emergency is appropriately classified, and to determine release rates and contamination magnitudes, and to estimate projected exposures to on-site and off-site personnel.

8.4.3 Corrective Actions Shutdown and/or isolation of affected equipment and suspension of related activities shall be considered by the Emergency Director. Physical barriers to contain radioactivity shall be maintained or implemented where necessary.

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EMG-01-01 Rev. 1 Emergency Plan Specific corrective actions are provided in the EPIP addressing Emergency Classification and Initial Accident Assessment and the applicable Emergency Response EPIP.

8.4.4 Protective Actions Protective actions may include evacuation of specific areas.

For emergencies involving criticality hazards, the Emergency Director shall order a precautionary evacuation of the affected area immediate evacuation zone for non-essential personnel.

Personnel shall be instructed to evacuate or take shelter from severe natural phenomena, security events, or other severe incidents, as appropriate.

The Emergency Director should consider evacuation of all non-essential personnel to outside the operations boundary.

8.5 Site Area Emergency 8.5.1 Activation and Notification Actions The Emergency Director shall notify off-site organizations as described in Section 7.3.

ERO personnel are notified and the facility emergency organization is activated as described in Section 7.1.

o The Criticality Safety Engineer shall report to the facility for situations involving or suspected of involving imminent or actual uncontrolled criticalities.

o Assessment Teams shall report to the facility for Site Area Emergencies.

Emergency support organizations are activated as described in Section 7.2.

Emergency support organizations will consider precautionary notification of the public near the site, in accordance with their internal processes.

The ESC is activated as described in Section 7.4.

Assembly and Accountability for the site is initiated, as described in Sections 8.6.2 and 8.6.3, unless doing so would adversely affect site personnel (e.g., severe weather or security threats).

8.5.2 Assessment Actions Facility and site boundary airborne radioactivity levels shall be determined by the stack release monitor and carbon delay bed effluent monitor, installed area radiation monitors and continuous air monitors, and portable monitoring equipment used by members of the ERO and communicated to the Emergency Director.

During emergencies involving criticality events, CAAS instrumentation shall be monitored for event status, and the criticality safety engineer shall evaluate the consequences of the criticality accident, including those from radioactive and nonradioactive hazardous materials that might be released as a result of the accident.

Assessment Team personnel may be dispatched to visually assess collateral damage to the facility caused by the event, and should be dispatched to monitor for potential releases outside the facility and at the site boundary.

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EMG-01-01 Rev. 1 Emergency Plan The Emergency Director shall use this information and Appendix 4 to determine release rates and contamination magnitudes and to estimate projected exposures to on-site and off-site personnel.

8.5.3 Corrective Actions Shutdown and/or isolation of all irradiation units and suspension of all activities involving target solution and or other radioactive material shall be directed by the Emergency Director. Physical barriers to contain or mitigate radioactivity releases shall be maintained or implemented where possible.

Emergency support organizations mobilize to the site and/or set up an incident command center to respond to the emergency.

Specific corrective actions are provided in the EPIP addressing Emergency Classification and Initial Accident Assessment and the applicable Emergency Response EPIP.

8.5.4 Protective Actions Protective actions may include evacuation of specific areas of the SHINE facility.

For emergencies involving criticality events, the Emergency Director shall order an evacuation of the affected area immediate evacuation zone.

Personnel shall be instructed to evacuate or take shelter from severe natural phenomena, security events, or other severe incidents, as appropriate.

Non-essential personnel shall be evacuated off-site unless doing so would adversely affect personnel leaving the site (e.g., severe weather or security threats).

8.6 Evacuation, Assembly and Accountability 8.6.1 Evacuation Various classes of emergency events may require evacuation of personnel. Evacuation is the primary protective action anticipated for on-site personnel. When an evacuation is initiated, all personnel within the immediate evacuation zone shall evacuate without hesitation by planned evacuation routes to established assembly stations.

All areas within the operations boundary have established immediate evacuation zones and evacuation routes. Sufficient exits from the immediate evacuation zones exist to enable rapid and unobstructed evacuation of personnel. Immediate evacuation for personnel protection shall take precedence over contamination control or security considerations. Evacuation routes are planned to minimize the total risk considering all potential hazards, including chemical, industrial, and radiation.

The public address system, and/or audible alarms and flashing lights are used to initiate area or facility evacuations. In the event of an evacuation, visitors are the responsibility of the facility employee being visited. A register of visitors is kept by Security and is available to the Emergency Director.

Evacuation is followed by Assembly and Accountability (see Section 8.6.2 and 8.6.3).

Radiation levels shall be monitored in occupied areas adjacent to the immediate evacuation zone and periodically at the assembly station after initiation of the emergency response. Collected information shall be provided to the Radiation Safety Coordinator. If this monitoring indicates that the dose rate exceeds 100 mrem/hour in areas that continue to be occupied, non-essential personnel shall be evacuated from those areas.

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EMG-01-01 Rev. 1 Emergency Plan Evacuation zones, planned evacuation routes, and other detailed information are provided in the EPIP addressing Evacuation, Assembly, and Accountability.

8.6.2 Assembly Assembly stations are those areas to where personnel shall report if an evacuation of any area of the facility has been called, or if a Site Area Emergency has been declared.

Personnel are trained to report to their primary assembly area, and to listen for instructions provided by the ERO. If it is determined that the primary assembly area(s) is unfit for personnel, the Emergency Director may designate alternate assembly area(s) and direct personnel using appropriate communication systems. Assembly stations are clearly identified in the EPIP addressing Evacuation, Assembly, and Accountability and posted in the area.

Assembly stations consist of:

Control room - primary assembly area for on-duty control room and Operations personnel Main production facility breakroom (primary ESC) - primary assembly area for ERO and non-essential personnel Main production facility conference room - alternate on-site assembly area for non-essential personnel Storage building office area (backup ESC) - alternate on-site assembly area SHINE Headquarters breakroom - contingency alternate off-site assembly area Security personnel shall individually report their location(s) to the ERO, and then perform their Accountability duties as described in the EPIP addressing Evacuation, Assembly, and Accountability.

Personnel evacuating the facility will be monitored for contamination by the portal monitors as they exit the radiologically controlled area (RCA), or with portable friskers at assembly areas. Potentially contaminated personnel arriving at assembly areas will be segregated from non-contaminated individuals until they have been monitored. Additional decontamination information is described in Section 9.5.

SHINE has the capability of quickly identifying individuals who have received doses of 10 rads or more due to a criticality accident via reading of electronic dosimeters worn by personnel in the RCA.

The Radiation Safety Coordinator is responsible for identifying exposed personnel and determining their radiation dose, in order to ensure appropriate medical assistance is provided.

8.6.3 Accountability The purpose of Accountability is to determine the locations of all personnel at the site and to muster emergency personnel at prearranged locations in the event of a Site Area Emergency. Accountability is also performed after Evacuation and Assembly, to ensure personnel are no longer located within evacuation zone(s). When Accountability of on-site personnel is determined to be necessary by the Emergency Director, all personnel on-site shall be accounted for and the names of missing individuals (if any) are determined and Emergency Plan Page 26 of 74

EMG-01-01 Rev. 1 Emergency Plan reported to the Emergency Director. Accountability is performed in accordance with the EPIP addressing Evacuation, Assembly, and Accountability.

As part of Assembly and Accountability, the Emergency Director may also direct isolation and access control of facility areas to minimize exposures to radiation and the spread of radioactive contamination.

8.7 Assessment Action Information This section contains additional details on the Assessment Actions described in Sections 8.2, 8.3, 8.4 and 8.5.

8.7.1 Projections of Off-site Impacts Facility emergency organization personnel make projections of off-site radiation dose based on field monitoring data or installed facility instrumentation, coupled with the results of previously performed calculations. For all credible accidents, the worst-case projected accident consequences for off-site individuals are below 1 rem for radiological releases and below protective action guidelines for hazardous chemicals incident to the processing of licensed materials. Therefore, dose projections using real-time meteorological information or specifically-designed computer codes are not required for the SHINE facility.

Instructions for completing off-site exposure estimates are found in the EPIP addressing Emergency Radiation Exposure Control.

Off-site dose projections will be made available to off-site emergency support organizations and NRC personnel following initial determination and following any significant changes to the predictions as described in Section 7.3.

8.7.2 Source Terms Estimated radiological and chemical source term data are available in the EPIP addressing Emergency Radiation Exposure Control for use by the ERO.

Information from facility instrumentation readings, operations logs, and technical staff may be used to augment or update the source term data. If requested, source term information related to the emergency will be made available to appropriate off-site emergency response organizations and the NRC through the established communication lines.

8.7.3 On-site and Off-site Surveying As part of the assessment process, Assessment Teams may be dispatched to collect samples, perform area radiation readings, and observe conditions throughout the facility and around the site boundary, in order to gather information about radiation dose rates and contamination levels. Assessment Teams report information to the Emergency Director or designee using hand-held radios, mobile phones, or directly by returning to the control room or ESC.

Radiation doses are measured by portable Geiger counters and handheld survey equipment.

Contamination levels are measured by portable air samplers via collecting samples for subsequent analysis in the on-site laboratory.

Hazardous chemicals incident to the processing of licensed materials, i.e., uranium particulate, are measured by portable alpha-emitter detection equipment. Other Emergency Plan Page 27 of 74

EMG-01-01 Rev. 1 Emergency Plan hazardous chemicals are detected by Geiger counters or air samplers due to their expected coincident with gamma radiation.

Instrumentation and equipment used for assessment is described in more detail in Section 9.4.

Monitoring outside the facility and at the site boundary shall be implemented within two hours of declaring a Site Area Emergency involving a potential or actual release.

Monitoring should be continued periodically as necessary to monitor the progress of the event. Monitoring outside the facility may be implemented at the discretion of the Emergency Director for less severe emergency classifications.

Monitoring inside the facility is normally accomplished by installed equipment. Assessment teams may be dispatched to augment data obtained from installed equipment at the discretion of the ERO.

Although postulated accidents at the SHINE facility do not require off-site monitoring or protective actions, the capability for off-site monitoring using Assessment Teams and equipment is available, if required.

Field monitoring and assessments are performed in accordance with the EPIPs addressing Emergency Radiation Exposure Control and Damage Assessments.

8.8 Criticality Event Responses 8.8.1 Notification The criticality safety engineer reports to the facility as part of the activation of the ERO for Alerts involving the discovery of a critical-mass quantity of special nuclear material in an unsafe geometry container or other condition that creates a criticality hazard; for Site Area Emergencies involving imminent or actual occurrences of an uncontrolled criticality; or whenever his or her assistance is deemed necessary at the discretion of the Emergency Director.

8.8.2 Reentry All activities associated with reentry and rescue shall be coordinated and authorized by the Emergency Director.

Reentry shall be planned to minimize risks to personnel. The possibility of a continuing or recurring criticality accident shall be considered. Reentry during the emergency shall only be made by personnel trained in emergency response and reentry.

Reentry should be made only if a preliminary radiological survey indicates that the radiation levels are acceptable for reentry. Existing instrumentation or temporary sensors with remote readout may be used. All reentries shall be made with continuous radiation monitoring. Both neutron and gamma instruments should be used Personnel who reenter the immediate evacuation zone during the emergency shall be informed of the potential hazards and shall choose to accept the associated risk. Reentry should be performed by more than one person, as part of a Reentry and Damage Control Team. If personnel need to be rescued, the rescue shall be planned so as not to expose rescuers to life threatening radiation doses. The requirements for voluntary emergency worker exposures described in Section 8.1.3 apply to all reentries during the emergency.

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EMG-01-01 Rev. 1 Emergency Plan 8.8.3 Stabilization All activities associated with stabilization of a criticality event shall be coordinated and authorized by the Emergency Director. The Emergency Director may delegate authority to the criticality safety engineer, Technical Support Coordinator, or Radiation Safety Coordinator.

If the system remains critical and is possibly causing excessive damage or significant releases of radioactive material, an early reentry effort to disable the system may be permitted. The method for disabling the system shall be carefully planned and implemented to minimize risks to the Reentry and Damage Control Team.

The Criticality Safety Engineer shall determine if the system is subcritical and shall advise the ERO of methods to ensure stabilization of affected equipment and safe conditions for personnel. This might include placing the fissile material in a favorable geometry, diluting the fissile solution below a critical concentration, or using neutron absorbers to maintain subcriticality.

Neutron absorbers are available for use in shutting down or stabilizing a criticality event.

Neutron absorbers are stored in the storage building. Prior to being selected for use, the effect of the neutron absorbers under accident conditions shall be evaluated by the criticality safety engineer. Consideration shall be given to material compatibility and to cases under which addition of the neutron absorber can increase system neutron multiplication.

9 EMERGENCY FACILITIES AND EQUIPMENT Emergency facilities and equipment are available for emergency assessment, communications, first aid and medical care, and performing corrective and recovery actions.

9.1 Control Room The control room is the centralized on-site location from which the facility is operated, and from which effective direction can be given and effective control can be exercised during an emergency. The control room is located within the safety-related area of the main production facility. It is equipped with instrumentation to supply information on the facility status and is continuously staffed with qualified licensed operators while the facility is operating. Available control room indications are further described in Sections 9.4.1, 9.4.4, and 9.4.5.

The control room is provided with communications equipment to communicate within and outside the facility, including commercial telephones, sound powered phones, base station radios, and the ability to broadcast on the public address system. Communications equipment is further described in Section 9.8. The control room contains a controlled copy of the EPIP Manual and current notification rosters.

Emergency response activities are coordinated from the control room until the ESC is activated.

9.2 Emergency Support Center (ESC) 9.2.1 Primary and Backup Locations The ESC is an on-site facility from which effective direction can be given and effective control can be exercised during an emergency. The ESC is located to oversee operations in the control room and the facility, but it is separated from actual activities.

The primary location of the ESC is the main production facility breakroom.

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EMG-01-01 Rev. 1 Emergency Plan The backup location of the ESC is the storage building office area.

Both locations for the ESC are equipped with communications equipment, including commercial telephones, a base station radio, and the ability to broadcast on the public address system. Communications systems are further described in Section 9.8.

Both locations for the ESC are adequately sized to seat at least six people, and contain the following supplies and equipment:

A controlled copy of the EPIP Manual and current notification rosters; First Aid equipment; Handheld lights; Electronic dosimeters for use by emergency personnel; and A supply of anti-contamination clothing.

9.2.2 Contingency Location If both ESC locations are unsuitable for use, the ESC may be relocated to SHINE Headquarters breakroom located at 3400 Innovation Ct, Janesville, 53546.

9.3 Off-site Response and Coordination Facilities The Rock County Emergency Operations Center, located at 3530 County Road F, Janesville WI 53545, is the facility used by Rock County Emergency Management. Rock County Emergency Management may use this facility at its discretion for coordinating responses to emergencies involving the SHINE site.

In the unlikely event that the emergency renders SHINE emergency facilities and equipment unusable, alternate facilities and equipment may be supplied by Rock County Emergency Management. Written letters of agreement pertaining to alternate facilities and equipment are found in Appendix 3.

9.4 Assessment Facilities and Equipment This section describes the instrumentation, facility and equipment used to assess emergency events.

9.4.1 Installed Facility Radiological Instrumentation This section describes installed instrumentation that provides information on radiological conditions. Unless specified otherwise, all indications are available inside the control room. Once the ESC is activated, information will be relayed to ESC staff via the communications systems described in Section 9.8.

Criticality Accident Alarm System The criticality accident alarm system (CAAS) provides information on the occurrence of an actual criticality within the facility. The CAAS detectors are located in the IF and RPF and are arranged so that each area within the IF and RPF generally receives coverage from at least three detectors. The CAAS is powered by the facility redundant, safety-related uninterruptible power supply system (UPSS), which is expected to be available during any credible emergency event. The CAAS is described in FSAR Section 6b.3.3.

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EMG-01-01 Rev. 1 Emergency Plan Area Radiation Monitoring Detectors for monitoring direct radiation in occupied areas comprise the radiation area monitoring system (RAMS). RAMS detectors are located in the general areas of the IF and RPF. The RAMS is described in FSAR Section 7.7.3.

Process Radiation Monitoring Safety-related detectors for monitoring radiation in the facility HVAC are located in the exhaust of each hot cell of the supercell, in the exhaust from the primary closed loop cooling system (PCLS) located in each IU cell, and in the general HVAC exhaust to the facility stack. These detectors comprise the radiation monitors of the engineered safety feature actuation system (ESFAS) and the target solution vessel reactivity protection system (TRPS). These monitors are described in FSAR Section 7.7.1.

Process Tritium Monitoring Detectors for monitoring tritium levels within facility processes are provided in the tritium purification system (TPS). These safety-related tritium monitors provide signals to the safety-related facility control systems, and are described in FSAR Section 7.7.1.

Airborne Contamination Monitoring Continuous air monitoring system (CAMS) detectors provide information on airborne alpha-beta and tritium contamination levels within the facility. CAMS detectors are located in the general areas of the IF and RPF. The CAMS is described in FSAR Section 7.7.4.

Effluent Monitoring The stack release monitor (SRM) measures radiation levels in the main facility stack, and the carbon delay bed effluent monitor (CDBEM) monitors for noble gases at the exhaust of the process vessel vent system (PVVS) carbon delay beds to provide information on radiation levels in that flow path. The effluent monitors are described in FSAR Section 7.7.5.

Criticality Accident Dosimeters Criticality dosimeters or instruments are located within the facility which, when recovered and evaluated, provide spectrum information and assist in reconstruction of a criticality incident. Information from criticality dosimeters is not available in the control room or in real time.

Environmental Monitoring Information from installed environmental monitoring equipment is not available in the control room or in real time. Samples must be collected and analyzed in a laboratory.

Four continuous air samplers are installed around the SHINE site boundary. Assessment Teams may collect samples from these locations for analysis at the on-site laboratory.

Sixteen direct radiation monitors (i.e., TLDs or equivalent) are also installed around the SHINE site boundary. These monitors may be collected and analyzed at an off-site laboratory if required.

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EMG-01-01 Rev. 1 Emergency Plan 9.4.2 Portable Instrumentation and Equipment Portable radiological monitoring equipment is primarily stored in the health physics office inside the main production facility . Supplies and equipment are also stored in the storage building.

Inventory lists, calibration schedules, and other detailed information for portable radiological monitoring equipment are contained in the EPIP addressing Emergency Equipment and Supplies. Equipment available for emergency use includes the following:

Sampling kits Handheld lights Portable battery-powered radiation protection instruments (e.g., portable alpha-beta and alpha-beta-gamma probes and meters) 9.4.3 Laboratories The SHINE facility contains two laboratories. Both laboratories are located inside the main production facility, within the radiologically controlled area. The laboratories include instrumentation for specific radionuclide identification and analysis. The laboratories have the following capabilities:

Alpha-beta meters and counters Gamma spectrometer with high purity germanium (HPGe) detector Alpha spectrometer ICP-MS (isotopic identification)

Liquid scintillation counter (LSC)

High-performance liquid chromatograph (HPLC))

9.4.4 Non-Radiological Monitors and Instrumentation This section describes installed instrumentation that provides information on non-radiological conditions. Unless specified otherwise, all indications are available inside the control room. Once the ESC is activated, information will be relayed to ESC staff via the communications systems described in Section 9.8.

Fire Detection Fire detection and alarm systems are located throughout the main production facility and support buildings. The systems are designed, installed, located, inspected, tested, and maintained in accordance with NFPA 72, National Fire Alarm Code.

Fire detection consists of early warning air sampling smoke detection and gas monitoring system in general areas of the RCA, and smoke detection systems in other normally occupiable areas of the facility, in accordance with the facility Fire Hazards Analysis.

Seismic Monitoring The seismic monitoring system includes instrumentation, control cabinets and a dedicated computer for monitoring seismic activity in the safety-related portion of the facility. The seismic monitoring system provides event recording time histories for seismic events and provides indication of a seismic event to the process integrated control system for alarm Emergency Plan Page 32 of 74

EMG-01-01 Rev. 1 Emergency Plan in the facility control room. Data may be retrieved from the seismic monitoring system by either the dedicated computer or via the operator workstation in the facility control room.

Weather Monitoring The control room contains a weather band radio to assess potential meteorological threats to the facility.

9.4.5 Irradiation and Radioisotope Production Facility Process Monitoring and Instrumentation The facility control room allows for monitoring and controlling the production facility processes. Indications described are available in the control room. Once the ESC is activated, information will be relayed to ESC staff via the communications systems described in Section 9.8. The following indications are important for assessing the status of emergencies and determining appropriate event classification in accordance with EALs:

Variables associated with a breach of the primary system boundary:

Target solution vessel (TSV) level TSV dump tank level Variables used in determining and assessing the magnitude of radioactive material release external to the facility:

Stack release monitor Carbon delay bed effluent monitor RVZ1 RCA exhaust radiation detectors RVZ2 RCA exhaust radiation detectors Variables used in determining and assessing the magnitude of radioactive material release inside the facility:

Radiation area monitors (RAMS)

Continuous air monitors (CAMS) 9.5 Decontamination Facilities, Supplies, and Controls This section contains information on decontamination and contamination control during emergencies.

Personnel are considered contaminated if they are found by direct frisk or use of a portal monitor to have contamination above background, as defined in the EPIP addressing Emergency Radiation Exposure Control. Equipment is considered contaminated if a survey of accessible surfaces results in contamination above background, as defined in the EPIP addressing Emergency Radiation Exposure Control.

9.5.1 Normal Controls and Facilities During emergency conditions, normal facility contamination control practices, as discussed in radiation protection implementing procedures, will be adhered to as much as possible.

A decontamination room is located inside the main production facility at the main exit from the RCA. The decontamination room is used to decontaminate personnel for their own Emergency Plan Page 33 of 74

EMG-01-01 Rev. 1 Emergency Plan protection as well as to prevent spreading contamination to other areas. The decontamination room contains a sink, a shower, and a supply cabinet.

9.5.2 Emergency Controls and Supplies Temporary decontamination areas can also be set up at various locations if necessary.

Decontamination supplies (e.g., buckets, hoses, soap, brushes, etc.) for use in temporary decontamination areas are stored in the health physics office. Specific inventory lists are available in the EPIP addressing Emergency Equipment and Supplies.

When affected personnel must be transported, measures will be taken to prevent the spread of contamination. Such measures will include placing affected personnel in "clean" protective clothing or wrapping in blankets. The Emergency Director will ensure that the emergency support organizations providing transportation and treatment are alerted if injured personnel are contaminated.

Potentially contaminated emergency vehicles will be surveyed before they are allowed to leave the site. SHINE is responsible for decontaminating contaminated vehicles. Off-site decontamination, if necessary, of equipment, facilities and personnel for the emergency support organizations will be accomplished by those organizations. Decontamination process details are found in the EPIP addressing Emergency Radiation Exposure Control.

9.6 Personnel Monitoring Equipment SHINE employees responding to a radiological emergency will use their normally assigned dosimetry (i.e., thermoluminescent dosimeter (TLD) badges or equivalent) to monitor beta and gamma exposure, plus any added high range or specialized dosimetry deemed necessary by the Emergency Director or Radiation Safety Coordinator.

Personnel entering areas with a potential for neutron radiation are verified to have or are supplied neutron dosimeters (e.g., thermoluminescent albedo dosimeters, electrochemically etched plastics (CR-39), or equivalent) prior to entering the area.

Personnel entering areas with a potential for a criticality accident are supplied personal criticality accident dosimeters (i.e., as specified in ANSI N13.3-1969 (R1981), Dosimetry for Criticality Accidents) prior to entering the area.

All personnel responding to the radiological emergency are given electronic dosimeters.

Equipment for prompt on-site readout of electronic dosimeters is maintained in the health physics office.

Emergency support organization personnel are given dosimetry (gamma, beta, neutron, and/or criticality accident monitoring, and electronic dosimeters) prior to entering the affected area. A supply of emergency dosimetry is maintained in the health physics office and is readily available to emergency personnel. Details related to personnel dosimetry use during emergencies are found in the EPIP addressing Emergency Radiation Exposure Control.

Bioassay sample collection is used for assessing internal exposure, in accordance with the facility radiation protection procedures.

Exposure records are maintained in accordance with the normal facility radiation protection and records processes.

9.7 First Aid and Medical 9.7.1 On-site First Aid Assistance, Equipment and Supplies First aid equipment is strategically located in the following areas, at minimum:

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EMG-01-01 Rev. 1 Emergency Plan Control room Main production facility breakroom (primary ESC)

Storage building office area (backup ESC)

Main production facility shipping/receiving dock First Aid supply inventory information is found in the EPIP addressing Emergency Equipment and Supplies.

Facility emergency organization personnel are trained in basic first aid. Personnel who require care beyond first aid will be treated by emergency support organization personnel and transported to off-site medical facilities as necessary.

9.7.2 Off-site Medical Arrangements and Facilities SHINE has made arrangements with the City of Janesville Fire Department and local hospitals to transport and treat personnel injured or exposed to radiation, including those who may be contaminated. Provisions for handling contaminated personnel are described in Section 9.5.

The City of Janesville Fire Department has personnel who can provide emergency on-site first aid and transportation of affected individuals to off-site facilities for treatment.

SSM Health St. Mary's Hospital - 3400 East Racine Street - Janesville WI Additional details about arrangements and communications with off-site organizations are provided in Section 3.4 and in the EPIP addressing Notification and Communication.

9.8 Communications This section describes the communications systems available for use by the ERO.

Communications plans are contained in the EPIP addressing Notification and Communication, containing titles and alternates for those in charge at both ends of the communication links and the primary and backup means of communication.

9.8.1 Normal Commercial Telephones The facility uses a commercial telephone communication system that provides for on-site two-way communication, paging and public address, and party-line-type voice communications. Stations for this system are located throughout the main production facility and outbuildings. These phones provide two-way normal communication between personnel within the SHINE campus and between the SHINE campus and off-site persons. Normal commercial telephones are the primary on-site and off-site communication system. The normal telephone communication system contains redundant servers and a battery backup.

9.8.2 Public Address The public address (PA) system uses the telephone communication system to initiate public address announcements. The system also includes dedicated base transmitting units, which are designed to continue to function in the event of a failure of the phone system. Announcements can be made site-wide or to specific predefined zones. The public address system is audible in the following areas:

Occupiable areas of the main production facility RCA Emergency Plan Page 35 of 74

EMG-01-01 Rev. 1 Emergency Plan Normally occupied areas of the main production facility and support buildings Hallways and corridors of the main production facility and support buildings Outdoor areas on the SHINE campus within the controlled access area fence The PA system is a primary on-site communications system.

9.8.3 Sound Powered Phones Sound-powered phones supplement the telephone system for on-site communications.

The system uses portable sound-power telephones that can plug into local terminal jacks.

The sound powered telephones are located in areas where critical operations and response activities are anticipated to occur. The sound powered telephones utilize the users voice to create the necessary power for reliable and uninterrupted communications in the event of an emergency. The phones operate independent of any power source and are not affected by loss of power to the facility.

Control room Main production facility breakroom (primary ESC)

IF general area RPF general area 9.8.4 Radio Handheld portable radios are available for use by facility emergency organization personnel as an additional on-site backup communication device. Handheld radios are powered by replaceable, rechargeable battery packs that maintain the ability to be independent of the facility power once charged. Base units are placed throughout the SHINE campus and communicate with the portable radios. Base stations are located at the following locations, at minimum:

Control room Main production facility breakroom (primary ESC)

Storage building office area (backup ESC)

The radio system also contains radios, antenna, battery backups, and amplifiers capable of communicating with the Janesville Wisconsin fire and police departments (emergency support organizations). Radios are a backup on-site communications system.

9.8.5 Mobile Telephones An emergency mobile telephone is stored in the control room. Personal mobile telephones normally carried by SHINE personnel and emergency support organization personnel are also expected to be present in the facility. Mobile telephones serve as a backup on-site and off-site communications system.

9.9 Equipment Required to Maintain Safe Shutdown The following facility equipment is relied upon to maintain a safe shutdown state:

Target solution vessel off-gas system (TOGS)

Emergency Plan Page 36 of 74

EMG-01-01 Rev. 1 Emergency Plan The TOGS is required to circulate gas within an irradiation unit to recombine hydrogen and oxygen generated from radiolysis. The TOGS is required to continue operating for five minutes after an irradiation unit has been shut down. The TOGS is described in FSAR Sections 4a2.1 and 4a2.8.

Uninterruptible power supply system (UPSS)

The UPSS provides power to the TOGS in the event normal power sources are lost. The UPSS also provides power to instrumentation and control systems and other systems used for monitoring facility status. The UPSS is described in FSAR Section 8a2.2.

Nitrogen purge system (N2PS)

The N2PS is required to prevent the accumulation of elevated levels of hydrogen in the irradiation units and in process tanks and vessels containing irradiated target solution.

The N2PS is described in FSAR Sections 6b.2.3 and 9b.6.2.

10 RECOVERY Recovery consists of those actions required to restore the facility and its impact on public health and safety to a safe status.

The Emergency Director determines when the emergency condition no longer exists, and Recovery can begin. The Emergency Director may secure from the emergency when conditions no longer meet an Emergency Action Level and it appears unlikely that conditions will deteriorate.

The Emergency Response Organization will also be the Recovery Organization. The Emergency Communicator will ensure that records of the event are compiled, evaluated, and retained.

10.1 Criteria The criteria used to determine when reentry of the facility following an accident is appropriate are:

Preliminary radiological survey indicates that the radiation levels are acceptable for reentry. Existing instrumentation or temporary sensors with remote readout may be used.

Reentry personnel can perform the required activities within normal 10 CFR 20 exposure limits.

Any fire, flood, earthquake, hazardous chemical release or similar emergency condition or threat to security no longer poses an immediate danger to reentry personnel or has been mitigated to an acceptably safe level.

The criteria used to determine when operation of the facility may be resumed following an emergency are:

All applicable technical specifications and associated surveillance requirements are satisfied.

Any fire, flood, earthquake, hazardous chemical release or similar emergency condition or threat to security no longer exists.

Damage to affected facility structures, systems and components (SSC) designated for re-start has been repaired, and post maintenance tests and inspections have been completed satisfactorily, in accordance with normal facility procedures.

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EMG-01-01 Rev. 1 Emergency Plan Any SSC that cannot or will not be repaired, or where the repair will be deferred until a later date, have been appropriately isolated or abandoned, as applicable, and a technical justification (e.g., design change, technical report, etc.) of the acceptability of the existing condition has been prepared and approved in accordance with normal facility procedures.

10.2 Recovery Actions and Procedures Recovery plans and procedures will be written and approved as needed. These procedures include those used to determine the necessary actions to reduce any ongoing releases of radioactive material or hazardous chemicals incident to the processing of licensed material and to prevent further incidents.

The recovery plans and procedures will be prepared by the facility technical staff, with input from the emergency support organizations, as applicable. Recovery plans and procedures will be evaluated and approved by an individual authorized to assume the role of the Emergency Director. Recovery plans and procedures will include elements such as stabilization actions, repair methods, and decontamination methods, as needed. The recovery plans and procedures will be compiled, kept and retained in accordance with the normal SHINE document control and records management processes.

SHINE has made the following provisions for accomplishing required restoration and recovery actions:

Personnel are trained in specific recovery actions required by the SHINE Safety Analysis Summary Report.

The Emergency Director is assigned the responsibility for assessing the damage to and status of the facilitys capabilities to safely control radioactive material and hazardous chemicals incident to the processing of licensed materials.

Recovery assessments will be performed by Assessment Teams, using guidance contained in the EPIP addressing Damage Assessment.

Normal processes for controlling personnel exposure, facility maintenance, and configuration control are in place.

11 MAINTAINING EMERGENCY PREPAREDNESS The Operations Manager is responsible for maintaining emergency preparedness, including administration of the Emergency Plan training program.

11.1 Facility Emergency Organization Training SHINE personnel with roles and responsibilities within the facility emergency organization receive initial training prior to being assigned those responsibilities, and receive annual refresher training, on the following topics:

Emergency plan overview; Emergency procedure usage; Facility layout; Specific recovery actions required by the SHINE Safety Analysis Summary Report; Emergency Plan Page 38 of 74

EMG-01-01 Rev. 1 Emergency Plan Characteristics of a criticality event; Radiation safety; First aid; and Use of protective equipment and monitoring devices.

Team training, i.e., training of individuals together in groups consistent with their normal shift or assigned ERO team, is not required due to the small size of the total facility staff.

Initial training on the above topics is expected to take eight hours. Annual refresher training is expected to take four hours.

Additionally, individuals with authority to assume the roles described in Section 11.1.1 through 11.1.7 receive additional initial and annual refresher training in the specified topics below.

11.1.1 Emergency Director Individuals who have authority to assume the role of the Emergency Director receive additional training on the following topics:

Emergency action levels and accident assessment; Notifications and communication with off-site organizations Initial training on the above topics is expected to take four hours. Annual refresher training is expected to take two hours.

11.1.2 Control Room Staff Individuals assigned to the control room staff, i.e., licensed operators, receive additional training on the following topics:

Emergency action levels and accident assessment; Notifications and communication with off-site organizations Initial training on the above topics is expected to take four hours. Annual refresher training is expected to take two hours.

11.1.3 Emergency Communicator Individuals who have the authority to assume the role of the Emergency Communicator receive additional training on the following topics:

Notifications and communication with off-site organizations Initial training on the above topics is expected to take two hours. Annual refresher training is expected to take one hour.

11.1.4 Assessment Teams Individuals assigned to Assessment Teams receive additional training on one or more of the following topics, depending on their particular role:

Radiological monitoring; Damage assessment; Respirator use Emergency Plan Page 39 of 74

EMG-01-01 Rev. 1 Emergency Plan o Respirator training is administered in accordance with the normal respiratory protection program Initial training on the above topics is expected to take two to four hours, depending on the individuals assigned duties. Annual refresher training is expected to take one to two hours.

11.1.5 Reentry and Damage Control Teams Individuals assigned to Reentry and Damage Control Teams receive additional training on one or more of the following topics, depending on their particular role:

Damage control and repair; Response to criticality accidents, including reentry and stabilization; Respirator use o Respirator training is administered in accordance with the normal respiratory protection program Initial training on the above topics is expected to take two to four hours, depending on the individuals assigned duties. Annual refresher training is expected to take one to two hours.

11.1.6 Criticality Safety Engineer Criticality safety engineers are trained qualified as part of the facility normal criticality safety program. In addition, criticality safety engineers receive training on their duties and responsibilities described in this Emergency Plan in the event of a criticality accident.

11.1.7 Security Personnel Security Personnel receive initial and annual refresher training on access control, Assembly, and Accountability during emergencies.

Initial training is expected to take two hours. Annual refresher training is expected to take one hour.

11.2 Off-site Organization Training and Orientation This section describes training, briefings, and orientation for off-site organizations.

11.2.1 Emergency Support Organization Training Training is offered annually to off-site emergency support organization personnel. SHINE personnel will meet with each off-site assistance group to accomplish training and review items of mutual interest including relevant changes to the program. This training may include:

Facility tours; Reentry procedures; Facility hazards; Information concerning facility access control (normal and emergency);

Permitted manual fire suppression techniques; Emergency Plan Page 40 of 74

EMG-01-01 Rev. 1 Emergency Plan Potential accident scenarios; EALs; Notification procedures; Exposure guidelines; Personnel monitoring devices; Communications; Contamination control; and The off-site assistance organization role in responding to an emergency at SHINE, as appropriate.

11.2.2 Community Orientation Radiological and SHINE facility orientation opportunities are offered biannually to other local services personnel (e.g., local news media, local government officials, etc.). The orientation may include:

Emergency Plan purpose and/or brief overview; Facility tours; and/or Radiation safety overview.

11.3 General Site Personnel This section describes training, briefings, and orientation related to the emergency response that are provided to individuals who may be on-site, including non-emergency response personnel.

11.3.1 SHINE Personnel SHINE employees and other individuals with unescorted access to the facility, including those who are not assigned duties as part of the ERO, receive initial orientation training on the following topics:

Emergency plan introduction Facility layout, evacuation, assembly, and accountability; and Facility alarm recognition.

Orientation training is expected to take two hours. The training emphasizes that emergency actions, including evacuation, should be performed in a manner to reduce risk of injury.

Additionally, SHINE employees and other individuals with unescorted access to the facility receive additional training:

Individuals who are permitted to enter the RCA receive radiation safety training in accordance with normal Radiation Protection processes.

Individuals who manage, work in, or work near facilities where the potential exists for a criticality accident receive criticality safety training in accordance with normal Criticality Safety processes.

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EMG-01-01 Rev. 1 Emergency Plan 11.3.2 Visitors Visitors to the site are briefed that they shall ensure a facility employee being visited is aware of their location at all times and shall follow SHINE personnel instructions in the event of an emergency.

11.4 Drills and Exercises Periodic drills and exercises are conducted to test the adequacy of EPIPs, to test emergency equipment and communications networks, and to ensure that ERO personnel are familiar with their duties. Drills are primarily on-site tests of one or more portions of the integrated capability of emergency response plans, equipment and organizations with off-site support functions being simulated. An exercise is a type of drill that is a full-scale test of the ERO, and off-site organizations are invited to participate. Drills and exercises are conducted in accordance with the EPIP addressing Exercises, Drills, and Critiques.

SHINE is committed to conducting exercises and drills in a manner that demonstrates the capability of the organization to plan and perform an effective response to an emergency.

11.4.1 Facility Emergency Organization Participation Individuals who are assigned roles within the facility emergency organization are required to participate in at least one exercise or drill involving a combination of some of the principal functional areas of the ERO emergency response capabilities every two years to demonstrate task-related knowledge, and update and reinforce their previous response training.

Principal functional areas include the management and coordination of emergency response, accident assessment, event classification, notification of off-site authorities, assessment of the on-site and off-site impact of radiological releases, protective action recommendation development, protective action decision making, plant system repair and mitigative action implementation.

11.4.2 Planning and Controlling Drills and Exercises Drills and exercises should be planned to demonstrate the following objectives:

To test the capabilities of the emergency organizations and communication system and to reinforce emergency training.

Resources are effectively used to control the site, mitigate further damage, control radiological releases, perform required on-site activities under simulated radiation or airborne and other emergency conditions, accurately assess the facilitys status during an accident, and initiate recovery.

Personnel protection measures, including controlling and minimizing hazards to individuals during fires, medical emergencies, mitigation activities, search and rescue, and other similar events, are implemented effectively and demonstrated via inclusion of these types of events in scenarios.

On-site communications effectively support emergency response activities.

The Emergency Communicator disseminates accurate, reliable, timely, and understandable information.

Emergency Plan Page 42 of 74

EMG-01-01 Rev. 1 Emergency Plan Exercise and drill scenarios, as appropriate, emphasize coordination among on-site and off-site responses.

Exercises and drills shall be developed as written scenarios, and should be planned and controlled by personnel who are not direct participants (players) in the exercise. The technical staff shall participate in the planning of drills and exercises. Exercises shall have defined objectives that specify the aspects of emergency response selected for testing or reinforcing.

Off-site organizations or governments, including city, county, and state agencies, shall be invited and allowed to participate in drills or exercises at their request.

Prior to the beginning of the exercise or drill, effective player, controller, evaluator, and observer pre-drill briefings are conducted. The pre-staging of equipment and personnel is minimized to realistically test the activation and staffing of emergency facilities.

During the exercise or drill, scenario data and messages provided by the controllers effectively maintain the timeline and do not interfere with the emergency organizations response to exercise scenario events, except when safety considerations are involved.

11.4.3 Drills Drills are conducted annually, at minimum. The performance of an exercise fulfills this minimum requirement. The maximum interval between drills or between a drill and an exercise will not exceed 15 months. The maximum interval provides operational flexibility only and is not to be used to reduce frequency. The established frequency will be maintained over the long term.

The required annual drill shall test some combination of the principal functional areas of the ERO emergency response capabilities, and is conducted as an action drill. An action drill tests the integrated capability of the emergency plan, or a component thereof, and may include instruction periods to develop and maintain skills in a particular operation.

Drills may also be conducted to test a particular portion of the emergency plan, to consider accident management strategies or to instruct or train ERO personnel. One drill (or exercise) per year should include a realistic scenario involving a simulated criticality.

Additionally, evacuation drills shall be conducted at least annually. An evacuation may be included as part of the required annual drill or conducted separately. Evacuation drills should be scheduled to include all personnel who routinely work within the immediate evacuation zone. The drills shall be preannounced by written notice, posted signs, or public address announcement to minimize the possibility that accident or injury could result. A response to a false alarm can only be substituted for an evacuation drill if the required actions are observed or demonstrated.

11.4.4 Exercises The on-site and off-site emergency plans shall be exercised every two years with full participation by each off-site authority having a role under the plans. The maximum interval between exercises will not exceed 30 months. The maximum interval provides operational flexibility only and is not to be used to reduce frequency. The established frequency will be maintained over the long term.

Off-site emergency support organizations shall be invited to participate in the planning, conduct and execution of the full participation exercise. If any off-site organizations or governments refuse to participate, their participation is not required in accordance with 10 Emergency Plan Page 43 of 74

EMG-01-01 Rev. 1 Emergency Plan CFR 50.47(c)(1). In such cases, an exercise shall be held with the facility emergency organization and such governmental entities as elect to participate in the emergency planning process.

11.5 Operational Readiness The following activities are conducted in order to maintain operational readiness of the ERO and emergency equipment and supplies.

11.5.1 Communications Communication checks are conducted quarterly with off-site emergency support organizations to verify the functionality of initial notification points, including backup communications systems, in accordance with the EPIP addressing Notification and Communications.

Communication checks are conducted annually with the NRC in accordance with the EPIP addressing Notification and Communications.

Emergency telephone numbers contained in rosters and emergency response telephone directories are verified and updated as part of the communication checks.

11.5.2 Equipment and Supplies Portable instrumentation and equipment described in Section 9.4.2 will be functionally tested quarterly, and inventoried, maintained and calibrated at least annually, in accordance with the EPIP addressing Equipment and Supplies.

First Aid supplies and equipment described in Section 9.7.1 will be inventoried annually, in accordance with the EPIP addressing Equipment and Supplies.

11.6 Critiques Exercises, drills, and training that provide performance opportunities to develop, maintain, or demonstrate key skills must provide for formal critiques in order to identify weak or deficient areas that need correction. Any weaknesses or deficiencies that are identified in a critique of exercises, drills, or training must be corrected. Critiques for exercises and drills should involve observers, controllers and representative participants. Critiques are performed in accordance with the EPIP addressing Exercises, Drills, and Critiques. Deficiencies that are identified are entered into the Issue Management system, and corrective actions will be taken, as necessary. If updates to the emergency plan or EPIPs are required as a result of the critiques, they will be processed in accordance with SHINE administrative requirements for revising the emergency plan and EPIPs and the normal Document Control processes.

11.7 Emergency Plan and Procedure Use and Maintenance SHINE maintains procedures for implementing the requirements of the emergency plan. A list of EPIPs is found in Appendix 5. Controlled copies of the emergency plan and EPIPs are retained in the normal electronic SHINE Document Control system and controlled hard copies of the EPIP Manual are stored in the control room, primary ESC and backup ESC.

SHINE maintains emergency procedures for each area in which licensed special nuclear material is handled, used, or stored to ensure that all personnel withdraw to an area of safety upon the sounding of a CAAS alarm. This information is found in the Emergency Response EPIP.

Copies of current EPIPs are retained in accordance with the normal Records Management process for the life of the facility, and copies of and revised or superseded EPIPs are retained for at least three years.

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EMG-01-01 Rev. 1 Emergency Plan The emergency plan and EPIPs are annually reviewed for accuracy by the Operations Manager, or designated member of the facility emergency organization. The emergency plan, EPIPs and agreement letters are reviewed by those responsible every two years. Emergency action levels (Appendix 4) are reviewed with local governmental authorities on an annual basis.

The emergency plan and EPIPs are reviewed, revised, updated, approved and distributed in accordance with SHINE administrative requirements for revising the emergency plan and EPIPs and the normal SHINE Document Control process. SHINE implements the requirements of 10 CFR 50.54(q) and Appendix E to Part 50,Section IV.B.2 in its document control processes.

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EMG-01-01 Rev. 1 Emergency Plan 12 REFERENCES 12.1 RAD-01-01, Radiation Protection Program 12.2 RAD-01-03, Respiratory Protection Program 12.3 American National Standards Institute/American Nuclear Society, ANSI/ANS-15.16-2015, "Emergency Planning for Research Reactors," ANS, LaGrange Park, IL 12.4 American National Standards Institute/American Nuclear Society, ANSI/ANS-8.23-2007, "Nuclear Criticality Accident Emergency Planning and Response," ANS, LaGrange Park, IL 12.5 American National Standard Institute/American Nuclear Society, ANSI/ANS-8.21-1995, Use of Fixed Neutron Absorbers in Nuclear Facilities Outside Reactors, ANS, LaGrange Park, IL 12.6 American National Standard Institute/American Nuclear Society, ANSI/ANS-8.20-1991, Nuclear Criticality Safety Training, ANS, LaGrange Park, IL 12.7 U.S. Nuclear Regulatory Commission, "Emergency Planning for Research and Test Reactors," Regulatory Guide 2.6, Revision 2 12.8 U.S. Nuclear Regulatory Commission, "Standard Review Plan for the Review and Evaluation of Emergency Plans for Research and Test Reactors," NUREG-0849, October 1983 (ML062190191) 12.9 U.S. Nuclear Regulatory Commission, "Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content," NUREG-1537, Part 1, February 1996 (ML042430055) 12.10 U.S. Nuclear Regulatory Commission, "Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content," NUREG-1537, Part 2, February 1996 (ML042430048) 12.11 U.S. Nuclear Regulatory Commission, "FINAL Interim Staff Guidance Augmenting NUREG-1537, Part 1, "Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content," for Licensing Radioisotope Production Facilities and Aqueous Homogeneous Reactors," October 17, 2012 (ML12156A069) 12.12 U.S. Nuclear Regulatory Commission, "FINAL Interim Staff Guidance Augmenting NUREG-1537, Part 2, "Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria," for Licensing Radioisotope Production Facilities and Aqueous Homogeneous Reactors,"

October 17, 2012 (ML12156A075) 12.13 Los Alamos National Laboratory; "A Review of Criticality Accidents," LA-13638, May 2000 12.14 CALC-2020-0027, Best Estimate Radiological Dose Consequences for Determining Emergency Action Levels 12.15 TECRPT-2018-0033, Hazardous Chemical Inventories of SHINE Production Facility 12.16 CHM-01-01, Chemical Control Program 12/3/2021 12.17 TECRPT-2020-0016, SHINE Safety Analysis Summary Report Emergency Plan Page 46 of 74

EMG-01-01 Rev. 1 Emergency Plan FIGURES Figure 1 - SHINE Facility Site Layout Emergency Plan Page 47 of 74

Security-Related Information - Withheld from public disclosure under 10 CFR 2.390(d)

EMG-01-01 Rev. 1 Emergency Plan Figure 2 - SHINE Main Production Facility General Arrangement Emergency Plan Page 48 of 74

EMG-01-01 Rev. 1 Emergency Plan Figure 3 - SHINE Site Buildings and Surrounding Area School Generac Distribution Center Residential /

Commercial SHINE Headquarters Southern Dollar General Residential /

Wisconsin SHINE Distribution Farms Regional Center Airport Farm Church Commercial School Church SITE BOUNDARY SAFETY-RELATED AREA 1 MILE (1.6 KM) RADIUS Emergency Plan Page 49 of 74

EMG-01-01 Rev. 1 Emergency Plan Figure 4 - SHINE Site General Area Map Emergency Plan Page 50 of 74

EMG-01-01 Rev. 1 Emergency Plan Figure 5 - U.S. Geological Survey Janesville West Quadrangle Emergency Plan Page 51 of 74

EMG-01-01 Rev. 1 Emergency Plan Figure 6 - U.S. Geological Survey Beloit Quadrangle Emergency Plan Page 52 of 74

EMG-01-01 Rev. 1 Emergency Plan Figure 7 - U.S. Geological Survey Janesville East Quadrangle Emergency Plan Page 53 of 74

EMG-01-01 Rev. 1 Emergency Plan Figure 8 - U.S. Geological Survey Shopiere Quadrangle Emergency Plan Page 54 of 74

EMG-01-01 Rev. 1 Emergency Plan Figure 9 - Emergency Organization Interrelationships Emergency Plan Page 55 of 74

EMG-01-01 Rev. 1 Emergency Plan Figure 10 - SHINE Normal Facility Operation Organization Chart Emergency Plan Page 56 of 74

EMG-01-01 Rev. 1 Emergency Plan Figure 11 - SHINE Facility Emergency Organization Emergency Plan Page 57 of 74

EMG-01-01 Rev. 1 Emergency Plan RADIOACTIVE AND HAZARDOUS MATERIALS Approximate Maximum Chemical Name Hazard Location Storage State Site Inventory MPF Chemical Storage 1L Acetone Chemical Storage Building 4L Liquid MPF Laboratories 1L MPF Chemical Storage 1 kg Activated Charcoal Chemical Storage Building 25 kg Solid MPF Laboratories 500 g MPF Chemical Storage 500 g Storage Building 1 kg Solid Powder MPF Laboratories 100g Alpha Benzoin Oxime Chemical Subgrade Waste Tanks 448 g Supercell 10 g Liquid RLWI 3g MPF Chemical Storage 1 x 2.5 L Container Ammonium Hydroxide Storage Building 2 x 2.5 L Containers Chemical Liquid (35 wt% in storage) MPF Laboratories 1 x 2.5 L Container Supercell 22 g Chemical Subgrade Waste Tanks 18 kg Ammonium Nitrate Radiological / Supercell 50 g Liquid Chemical RLWI 132 g Storage Building 10 kg Ammonium Thiocyanate Chemical Solid Powder MPF Laboratories 2 kg MPF Chemical Storage 50 g Barium Chloride Chemical Solid Powder Storage Building 50 g Storage Building 10 L Chloroform Chemical Liquid MPF Laboratories 2L Emergency Plan Page 58 of 74

Proprietary Information - Withheld from public disclosure under 10 CFR 2.390(a)(4)

Export Controlled Information - Withheld from public disclosure under 10 CFR 2.390(a)(3)

EMG-01-01 Rev. 1 Emergency Plan Approximate Maximum Chemical Name Hazard Location Storage State Site Inventory Storage Building 30 L Ethyl Acetate Chemical Liquid MPF Laboratories 10 L Storage Building 1 kg Solid MPF Laboratories 100 g TSPS Room 620 g Target Solution Loop

[ ]PROP/ECI Chemical and Subgrade Target 3 kg Solution Storage Liquid Subgrade Waste Tanks 186 g Supercell 310 g RLWI 3g MPF Chemical Storage 2 x 2.5 L Containers Storage Building 4 x 2.5 L Containers Hydrochloric Acid Chemical MPF Laboratories 2 x 2.5 L Containers Liquid (36-38 wt% in storage)

Subgrade Waste Tanks 19 g Supercell 10 g RLWI <1g Hydrogen Flammable In Process 60 g Gas MPF Chemical Storage 10 x 1 L Containers Hydrogen Peroxide Storage Building 20 x 1 L Containers Chemical Liquid (30 wt% in storage) MPF Laboratories 1L TSPS Room 3 kg Supercell 10 g Emergency Plan Page 59 of 74

EMG-01-01 Rev. 1 Emergency Plan Approximate Maximum Chemical Name Hazard Location Storage State Site Inventory Hydrous Zirconium MPF Chemical Storage 1 kg Chemical Solid Powder Oxide Storage Building 10 kg MPF Chemical Storage 1L Isopropanol Chemical Storage Building 4L Liquid MPF Laboratories 1L Storage Building 16 L Methanol Chemical Liquid MPF Laboratories 4L Storage Building 500 g Molybdenum Trioxide Chemical Liquid MPF Laboratories 100 g MPF Chemical Storage 5 x 2.5 L Containers Chemical Storage Building 10 x 2.5 L Containers Nitric Acid MPF Laboratories 2 x 2.5 L Containers Liquid (70 wt% in storage)

Subgrade Waste Tanks 18 kg Radiological /

Supercell 1 kg Chemical RLWI 131 g Nitrogen Asphyxiant /

N2PS Storage 722 ft3 at 2800 psig Gas (Compressed gas) Chemical Nitrogen Asphyxiant / Liquid Outdoor Bulk 18,000 gal Liquid (Liquid) Chemical Storage Tanks Emergency Plan Page 60 of 74

EMG-01-01 Rev. 1 Emergency Plan Approximate Maximum Chemical Name Hazard Location Storage State Site Inventory MPF Chemical Storage 10 g Solid Powder Storage Building 10 g Potassium Chemical MPF Laboratories 10 g Hexachlororuthenate Subgrade Waste Tanks 7g Supercell 10 g Liquid RLWI <1g Storage Building 2 kg Potassium Iodide Chemical Solid Powder MPF Laboratories 500 g MPF Chemical Storage 500 g Solid Powder Storage Building 2 kg Potassium MPF Laboratories 250 g Chemical Permanganate Subgrade Waste Tanks 473 g Liquid Supercell 10 g RLWI 3g MPF Chemical Storage 10 g Storage Building 10 g Solid Powder MPF Laboratories 10 g Rhodium Chloride Chemical Subgrade Waste Tanks 9g Supercell 10 g Liquid RLWI <1g MPF Chemical Storage 100 g Storage Building 500 g Crystal Powder Silver Nitrate Chemical MPF Laboratories 100 g Supercell 10 g Liquid Emergency Plan Page 61 of 74

EMG-01-01 Rev. 1 Emergency Plan Approximate Maximum Chemical Name Hazard Location Storage State Site Inventory MPF Chemical Storage 5 kg Storage Building 20 kg Sodium Hydroxide Chemical Liquid MPF Laboratories 4 kg Supercell 517 g MPF Chemical Storage 500 g Storage Building 500 g Solid Sodium Iodide Chemical MPF Laboratories 100 g Supercell 10 g Liquid Storage Building 2 kg Sodium Nitrite Chemical Crystal Powder MPF Laboratories 250 g Subgrade Waste Tanks 3 kg Sodium Sulfite Chemical Supercell 100 g Liquid RLWI 23 g Storage Building 500 g Stannous Chloride Chemical Crystal Powder MPF Laboratories 250 g MPF Chemical Storage 4 x 2.5 L Containers Chemical Storage Building 8 x 2.5 L Containers MPF Laboratories 2 x 2.5 L Containers TSPS Room 10 kg Sulfuric Acid Target Solution Loop Liquid and Subgrade Target 55 kg Radiological / Solution Storage Chemical Subgrade Waste Tanks 562 kg Supercell 6 kg RLWI 4 kg Emergency Plan Page 62 of 74

Proprietary Information - Withheld from public disclosure under 10 CFRE 2.390(a)(4)

Export Controlled Information - Withheld from public disclosure under 10 CFR 2.390(a)(3)

EMG-01-01 Rev. 1 Emergency Plan Approximate Maximum Chemical Name Hazard Location Storage State Site Inventory Asphyxiant /

Sulfur Hexafluoride IU Cells 1440 kg Gas Chemical Tritium Radiological In Process 30 g Gas Solid Pieces Chemical URSS Room 620 kg

~ 20% enrichment Uranium Metal Neutron Multipliers x 8 Radiological IU Cells [ ]PROP/ECI Natural Enrichment Radiological / URSS Room 731 kg Uranium Oxide Solid Powder Chemical TSPS Room 9 kg Radiological /

Uranyl Peroxide TSPS Room 12 kg Solid Powder Chemical TSPS Room 191 kg Target Solution Loop and Subgrade Target 858 kg Uranyl Sulfate Radiological Solution Storage Liquid Subgrade Waste Tanks 73 kg Supercell 95 kg RLWI 1 kg Emergency Plan Page 63 of 74

EMG-01-01 Rev. 1 Emergency Plan AGREEMENT LETTERS This appendix contains letters of agreement that SHINE has obtained with off-site organizations for support of the Emergency Plan.

Emergency Plan

EMG-01-01 Rev. 1 Emergency Plan EMERGENCY ACTION LEVELS Classification Category Event Emergency Action Levels Notification of Threat to Credible report from facility personnel or local authorities of a bomb threat, Security Unusual Event Security civil disturbance, or other security threat directed toward the facility.

Ongoing security event, including the threat of an imminent hostile action, that a) Threatens or compromises site security; Alert Security Security Event b) Risks the safety of site personnel; OR c) Potentially degrades the level of safety of the facility.

Site Area 1) Hostile action at the facility, OR Security Hostile Action Emergency 2) Imminent or actual loss of physical control of the facility.

Criticality Discovery of a critical-mass quantity of special nuclear material in an unsafe Alert Criticality Hazard geometry container or other condition that creates a criticality hazard.

Imminent or actual occurrence of an uncontrolled criticality, indicated by Site Area Uncontrolled Criticality a) Valid actuation of the criticality accident alarm system (CAAS); OR Emergency Criticality b) Credible report from facility personnel.

Emergency Plan Page 67 of 74

EMG-01-01 Rev. 1 Emergency Plan Classification Category Event Emergency Action Levels Fire in the main production facility or the material staging building not Notification of Fire Prolonged Fire extinguished within 15 minutes of control room notification of the fire or Unusual Event receipt of a control room fire alarm.

1) Fire in a carbon delay bed, indicated by a carbon monoxide level of 42 ppm in the affected bed.

Fire Potentially Affecting Results in a calculated 36 mrem TEDE in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 36 mrem TEDE in Radioactive 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and 36 mrem TDE thyroid in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at site boundary Alert Fire Material or

2) Explosion or fire within the safety-related area of the main production Safety-Related facility or within the material staging building, with the potential to affect SSCs radioactive material OR cause damage to safety-related SSCs that provide a barrier to the release of radioactive materials.
1) Fire in a carbon guard bed, indicated by a temperature of 150°C in the affected bed Results in a calculated 37 mrem TEDE in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 37 mrem TEDE in Fire 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and 840 mrem TDE thyroid in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at site boundary Compromising 2) Fire within the safety-related area of the main production facility or within Site Area Radioactive the material staging building Fire Emergency Material or Safety-Related a) Involving radioactive material; SSCs b) Causing visible damage to safety-related SSCs that provide a barrier to the release of radioactive materials; OR c) Causing loss of the safety function of a safety-related SSC that provides a barrier to the release of radioactive materials.

Emergency Plan Page 68 of 74

EMG-01-01 Rev. 1 Emergency Plan Classification Category Event Emergency Action Levels

1) Tornado confirmed by direct observation by facility personnel or credible report from local authorities of a tornado in the immediate vicinity of the facility.
2) Seismic event, confirmed by at least two of the following:

a) Seismic event alarm in control room Severe Natural b) Earthquake felt in the facility Notification of External Phenomena or c) A response event for the SHINE site location, reported by the Unusual Event External Event U.S. Geological Survey National Earthquake Information Center

3) Uncontrolled flooding inside the main production facility or the material staging building.
4) Aircraft crash on-site.
5) Other severe external event or natural phenomena on-site that creates a significant hazard potential, as determined by the Emergency Director.

Emergency Plan Page 69 of 74

EMG-01-01 Rev. 1 Emergency Plan Classification Category Event Emergency Action Levels

1) Tornado strike of the main production facility or the material staging building.
2) Seismic event, meeting the criteria of an NOUE seismic event, that jeopardizes the function of safety-related SSCs that provide a barrier to the release of radioactive materials, OR potentially affects radioactive External Event material.

Potentially

3) Aircraft crash into the main production facility or the material staging Affecting building.

Alert External Radioactive Material or 4) Uncontrolled flooding within the main production facility or the material Safety-Related staging building that jeopardizes the function of safety-related SSCs that SSCs provide a barrier to the release of radioactive materials, OR potentially affects radioactive material.

5) Other severe external event or natural phenomena affecting the facility that jeopardizes the function of safety-related SSCs that provide a barrier to the release of radioactive materials, OR potentially affects radioactive material, as determined by the Emergency Director.

Credible report or observation by facility personnel of any of the Alert-Level External Event External Events Compromising a) Actually compromising the integrity of radioactive material; Site Area Radioactive External b) Causing visible damage to safety-related SSCs that provide a Emergency Material or Safety-Related barrier to the release of radioactive materials; OR SSCs c) Causing loss of the safety function of a safety-related SSC that provides a barrier to the release of radioactive materials.

Notification of Radiological Equipment Event resulting in actual or projected radiological effluents at the site Unusual Event Release Malfunction boundary exceeding 15 mrem whole body (TEDE) accumulated in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Emergency Plan Page 70 of 74

EMG-01-01 Rev. 1 Emergency Plan

1) Failure of primary system boundary (PSB) with release of target solution into the IU cell or gas headspace release in Modes 2, 3 or 4, indicated by
a. Evidence of PSB failure (IU Cell Safety Actuation or N2PS actuation signals, OR RVZ1e radiation monitoring

> 5x background),

AND

b. Elevated radiation levels or airborne contamination levels in the IF (factor of 100 over normal levels), as indicated by facility RAMS, CAMS, or portable instruments.

Results in a calculated 1 mrem TEDE in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 39 mrem TEDE in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and 425 mrem TDE thyroid in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at site boundary

2) Failure of RLWI system within the RLWI enclosure resulting in spill of irradiated liquid waste onto floor as indicated:

Equipment Radiological Failure or a) Reports from the field Alert Release Release within AND the Facility b) Elevated radiation levels or airborne contamination levels in the RPF (factor of 100 over normal levels), as indicated by facility RAMS, CAMS, or portable instruments.

Results in a calculated 38 mrem TEDE in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 38 mrem TEDE in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and 14 mrem TDE thyroid in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at site boundary

3) Elevated radiation levels or airborne contamination levels WITHIN a site building that indicate severe loss of control (factor of 100 over normal levels), as indicated by facility RAMS, CAMS, or portable instruments.
4) Event resulting in actual or projected radiological effluents at the site boundary exceeding 75 mrem whole body (TEDE) accumulated in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
5) Radiation levels at the nearest site boundary of 20 mrem/hr for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> whole body (TEDE) or 100 mrem thyroid dose (TDE).

Emergency Plan Page 71 of 74

EMG-01-01 Rev. 1 Emergency Plan Classification Category Event Emergency Action Levels

1) TOGS pressure boundary failure during Mode 2, 3 or 4 with pressurized release (N2PS actuation), indicted by a) Evidence of pressure boundary failure (N2PS actuation signals OR RVZ1e radiation monitoring > 5x background),

AND b) Elevated radiation levels or airborne contamination levels in the IF (factor of 100 over normal levels), as indicated by facility RAMS, Severe CAMS, or portable instruments.

Equipment Results in a calculated 2 mrem TEDE in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 67 mrem TEDE in 24 Site Area Radiological Accident or hours, and 776 mrem TDE thyroid in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at site boundary Emergency Release Release to Environment 2) Elevated radiation levels or airborne contamination levels OUTSIDE the main production facility that indicate a significant release to the environment (factor of 100 over normal levels), as indicated by portable instruments.

3) Event resulting in actual or projected radiological effluents at the site boundary exceeding 375 mrem whole body (TEDE) accumulated in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
4) Radiation levels at the nearest site boundary of 100 mrem/hr for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> whole body (TEDE) or 500 mrem thyroid dose (TDE).

Notification of Other Unusual Other conditions exist that warrant precautionary activation of the ERO, at Other Unusual Event Events the discretion of the Emergency Director.

Other conditions that warrant activation of the ERO, at the discretion of the Alert Other Other Alerts Emergency Director.

Emergency Plan Page 72 of 74

EMG-01-01 Rev. 1 Emergency Plan Classification Category Event Emergency Action Levels Other conditions that warrant activation of off-site emergency response Site Area Other Site Area Other organizations or precautionary notification of the public near the site, at the Emergency Emergencies discretion of the Emergency Director.

Emergency Plan Page 73 of 74

EMG-01-01 Rev. 1 Emergency Plan EMERGENCY PLAN IMPLEMENTING PROCEDURE (EPIP) LIST The following is a topical list of Emergency Plan Implementing Procedures (EPIPs).

Emergency Response Organization Responsibilities Emergency Classification and Initial Accident Assessment, addressing o Notification of Unusual Event o Alert o Site Area Emergency Activation of the Emergency Response Organization Notification and Communication Emergency Radiation Exposure Control, including o Exposure Projections o Radiological Monitoring o Emergency Dosimetry o Emergency Exposure Authorization o Emergency Contamination Control Evacuation, Assembly, and Accountability Emergency Equipment and Supplies Damage Assessments Exercises, Drills, and Critiques Emergency Response, including information on o Security threat, event, or hostile action response o External event response o Fire response o Criticality emergency response o Radiological release response o Hazardous or toxic chemical spill or release response o Equipment malfunction, failure or severe accident response Emergency Plan Page 74 of 74