Text

Enclosures 1 to 5: SONGS ISFSI-Only Emergency Plan IOEP-1, Revision 2, SONGS ISFSI-Only Emergency Action Level Technical Bases Manual (IOEP-2), Summary of the Analysis Supporting the Changes Revision 2 of IOEP-1 and IOEP-2, Revised Epips
	ML22066B023
Person / Time
Site:	San Onofre
Issue date:	03/03/2022
From:	; Southern California Edison Co
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML22066B026	List: ML22066B023; ML22066B024;
References
	Download: ML22066B023 (193)
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Enclosure 1 SONGS ISFSI-Only Emergency Plan IOEP-1, Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan San Onofre Nuclear Generating Station (SONGS)

Independent Spent Fuel Storage Installation {ISFSI)

Only Emergency Plan Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan TABLE OF CONTENTS Section Page PART I ....................................................................................................................................... 1

1.0 INTRODUCTION

............................................................................................................ 1 1.1 PURPOSE ....................................................................................................................................1 1.2 SCOPE .........................................................................................................................................1 2.0 DISCUSSION ................................................................................................................. 2 2.1 OVERVIEW OF ISFSI ONLY EMERGENCY PLAN (IOEP) .........................................................2 2.2 FACILITY DESCRIPTION ............................................................................................................2 2.3

SUMMARY

OF EMERGENCY ACTIONS ....................................................................................3

3.0 REFERENCES

......................................................................................................~********4 4.0 DEFINITIONS AND ABBREVIATIONS ......................................................................... 6 4.1 DEFINITIONS ..............................................................................................................................6 4.2 ABBREVIATIONS ......................................................................................................................10 PARTII ..................................................................................................................................... 11 1.0 ASSIGNMENT OF RESPONSIBILITY (ORGANIZATION CONTROL) ....................... 11 1.1 EMERGENCY RESPONSE AND RESPONSIBILITIES ............................................................. 11 1.2 OFFSITE RESPONSE ORGANIZATIONS (ORO) ..................................................................... 12 2.0 EMERGENCY RESPONSE ORGANIZATION (ERO) .................................................. 13 2.1 ON-SHIFT POSITIONS ..............................................................................................................13 2,2 AUGMENTED POSITION ..........................................................................................................14 2.3 SUPPLEMENTAL PERSONNEL ............................................................................................... 14 2.4 FUNCTIONAL RESPONSIBILITIES .......................................................................................... 15 3.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES ....................................... 16 4.0 EMERGENCY CLASSIFICATION SYSTEM ................................................................ 17 4.1 UNUSUAL EVENT .....................................................................................................................17 4.2 ALERT ........................................................................................................................................17 4.3 EMERGENCY ACTION LEVELS AND POSTULATED ACCIDENTS ........................................ 18 5.0 NOTIFICATION METHODS AND PROCEDURES ...................................................... 19 6.0 EMERGENCY COMMUNICATIONS ............................................................................ 21 7.0 PUB~IC INFORMATION .................................................... 1......................................... 22 8.0 EMERGENCY FACILITY AND EQUIPMENT .............................................................. 23 8.1 EMERGENCY RESPONSE FACILITY ......................................................................................23 8.2 EMERGENCY EQUIPMENT ......................................................................................................23 ii Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 9.0 ACCIDENT ASSESSMENT ......................................................................................... 24 10.0 PROTECTIVE ACTIONS ............................................................................................. 25 11.0 RADIOLOGICAL EXPOSURE CONTROL .................................................................. 26 12.0 MEDICAL AND HEALTH SUPPORT ........................................................................... 28 13.0 EMERGENCY TERMINATION AND RECOVERY ....................................................... 30 14.0 EXERCISE AND DRILLS ............................................................................................. 31 15.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING ........................................... 34 15.1 EMERGENCY RESPONSE PERSONNEL TRAINING .............................................................. 34 15.2 SUPPORT ORGANIZATIONS TRAINING .................................................................................36 16.0 MAINTAINING EMERGENCY PREPAREDNESS ....................................................... 37 16.1 EMERGENCY PREPAREDNESS RESPONSIBILITIES ............................................................ 37 16.2 REVIEW AND UPDATING OF THE IOEP .................................................................................38 PART Ill ..................................................................................................................................... 39 APPENDIX A Emergency Equipment, Supplies, and Reference Materials .................... 39 APPENDIX B Cross Reference IOEP Section to Planning Standards / Requirements /

Criteria and Procedures ............................................................................... 40 APPENDIXC List of Letters and Memoranda of Agreement.. .......................................... 41 iii Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan PARTI

1.0 INTRODUCTION

The San Onofre Nuclear Generating Station (SONGS) is owned by Southern California Edison (SCE), San Diego Gas and Electric (SDG&E) and the cities of Anaheim and Riverside, California.

SCE is authorized to act as agent for the participants and has exclusive responsibility for the operation of the facility.

The SONGS INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) Only Emergency Plan (IOEP) describes the plan for responding to emergencies that may arise at the station's ISFSI.

In this condition, no reactor operations can take place and all irradiated fuel is removed from the Spent Fuel Pools (SFPs). This IOEP addresses the risks associated with SONGS' ISFSI-Only conditions.

As provided in the ISFSI storage system Final Safety Analysis Reports (FSARs) and 10 CFR 72.212 evaluations, the analyses of the potential radiological impacts of postulated off-normal, natural phenomenon, and accident events in an ISFSI-Only condition indicates that any releases beyond the CONTROLLED AREA boundary would result in a DOSE to the public below the radiation limits established in 10 CFR 72.106(b). Areas where exposure levels could potentially warrant pre-planned response measures are generally limited to the ISFSI pad and nearby vicinity; for this reason, radiological emergency planning is focused on this area.

1.1 PURPOSE The purpose of the IOEP is to assure an adequate level of preparedness to cope with a spectrum of emergencies. This Plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations expected to respond to emergencies.

1.2 SCOPE The SONGS IOEP is developed to respond to potential radiological emergencies at the SONGS ISFSI. Because there are no postulated off-normal, natural phenomenon, or accident events that would result in OFFSITE DOSE consequences that are large enough to require OFFSITE emergency planning, the overall scope of this Plan delineates the actions necessary to safeguard ONSITE personnel. The concepts presented in this Plan address the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans" and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities". The Plan is consistent with the applicable guidelines established in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" and NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors" Rev. 6.

Exemptions from selected portions of 10 CFR 50.47 and 10 CFR 50 Appendix E for SONGS were granted by the Nuclear Regulatory Commissic;m (NRC) on June 4, 2015 (ADAMS Accession Number: ML15082A204). .

The IOEP revision O was approved per NRC Safety Evaluation dated November 30, 2017.

1 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 2.0 DISCUSSION 2.1 OVERVIEW OF ISFSI ONLY EMERGENCY PLAN (IOEP)

In the event of an emergency at the SONGS ISFSI, actions are required to identify and assess the nature of the emergency and to respond in a manner that protects the health and safety of the public and ONSITE personnel.

This Plan describes the organization and responsibilities for implementing emergency measures. It describes interfaces with OFFSITE government agencies (Federal, State and local) which may be notified in the event of an emergency and may provide assistance. Fire, rescue and ambulance services are provided by the United States Marine Corps Camp Pendleton Fire Department (USMC CPFD). Law enforcement services are provided by the Federal Bureau of Investigation (FBI) and local public entities. Medical services are provided by Mission Hospital in Mission Viejo, California.

Additionally, Tri-City Medical Center in Oceanside, California, can provide the medical services specified in this Plan.

Because there are no postulated events that would result in OFFSITE DOSE consequences that are large enough to require OFFSITE emergency planning, emergencies are divided into two EMERGENCY CLASSIFICATION LEVELS: UNUSUAL EVENT (UE) and ALERT.

SONGS is responsible for planning and implementing emergency measures associated with the SONGS ISFSI. This Plan is provided to meet this responsibility. To carry out specific emergency measures discussed in this Plan, detailed implementing procedures are established and maintained.

In addition to the description of activities and steps that can be implemented during a potential emergency, this Plan also provides a general description of the steps taken to recover from an emergency situation. It also describes the training, drills, exercises, planning, and coordination appropriate to maintain an adequate level of EMERGENCY PREPAREDNESS.

2.2 FACILITY DESCRIPTION SONGS has permanently ceased power operations and all Units 2 and 3 irradiated fuel has been removed from the SFPs and placed into dry storage within the SONGS ISFSI.

SONGS Unit 1 has been permanently shut down since 1993 and is in the decommissioning phase.

Above-ground structures have been dismantled. Unit 1 fuel is stored in the SONGS ISFSI and in the GE-Hitachi Morris facility.

By letter dated June 12, 2013, SCE certified its intention to permanently cease power operations at SONGS Units 2 and 3 as of June 7, 2013, pursuant to 10 CFR 50.82(a)(1)(i). By letters dated June 28, 2013 and July 22, 2013, SCE certified permanent removal of fuel from the Unit 2 and Unit 3 reactor vessels, pursuant to 10 CFR 50.82(a)(1)(ii). The 10 CFR 50 licenses for SONGS Units 2 and 3 no longer authorize operation of the reactors, or emplacement or retention of fuel into the reactor vessels, as specified in 10 CFR 50.82(a)(2).

The San Onofre ISFSI is located on the coast of southern California in San Diego County, near the border with Orange County. The site is located entirely within the boundaries of the United States Marine Corps Base, Camp Pendleton, California. There is public access between the beaches north and south of the station. Interstate Highway 5 and the Atchison, Topeka, and Santa Fe Railway pass within 1000 feet of the station.

2 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 2.3

SUMMARY

OF EMERGENCY ACTIONS This Plan is activated by the ISFSI Shift Supervisor (ISS), who assumes the position of EMERGENCY DIRECTOR (ED) upon DECLARATION of an emergency based upon CLASSIFICATION of an event according to the EMERGENCY ACTION LEVEL (EAL) criteria. The emergency measures described in the subsequent sections and implementing procedures are implemented in accordance with the CLASSIFICATION and nature of the emergency at the direction of the ED. Regulatory authorities and OFFSITE support organizations are notified in accordance with this Plan. The ED has authority and responsibility for control and mitigation of the emergency, including emergency response resources, coordination of radiological ASSESSMENT ACTIVITIES, recovery implementation, and coordination of emergency response activities. The following sections of this Plan describe the detailed plans and actions of the SONGS EMERGENCY RESPONSE ORGANIZATION (ERO), including interfaces with OFFSITE support organizations.

3 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan

3.0 REFERENCES

References consulted in the writing of this Plan are listed in this section. With exception of regulatory requirements, inclusion of material on this list does not imply adherence to all criteria or guidance stated in each individual reference.

3.1 10 CFR 20, "Standards for Protection Against Radiation" 3.2 10 CFR 50.47, "Emergency Plans" 3.3 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities" 3.4 10 CFR 72.13, "Applicability" 3.5 10 CFR 72.32, "Emergency Plans" 3.6 10 CFR 72.44, "License conditions" 3.7 10 CFR 72.106, "Controlled area of an ISFSI or MRS" 3.8 NUREG-1140, Final Report published January 1988, "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees" 3.9 NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities" 3.10 NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (November 1980) 3.11 NUREG-0728, Report to Congress, "NRG Incident Response Plan" 3.12 US NRG Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors", revision 4, July, 2003 3.13 NRC Information Notice No. 85-44, "Emergency Communication System Monthly Test" 3.14 NRG Information Notice No. 90-08, "KR-85 Hazards From Decayed Fuel" 3.15 EPA-400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents", October 1991 3.16 ANI Information Bulletin 11-01 (Rev. 1), February 18, 2021 3.17 NRC letter dated June 4, 2015, SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION-EXEMPTIONS FROM CERTAIN EMERGENCY PLANNING REQUIREMENTS AND RELATED SAFETY EVALUATION (TAC NOS. MF3835, MF3836, AND MF3837). (ADAMS Accession Nos: Letter ML15082A204; Exemption: ML15082A143 on June 4, 2015).

3.18 San Onofre 2 & 3 UFSAR (DSAR) 4 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 3.19 Updated Final Safety Analysis Report for the Standardized Advance NU HOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, ANUH-01.0150, Revision 9 3.20 Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System, Holtec Report#

Hl-2115090, Revision 4 3.21 NEI 99-01, Rev. 6, "Development of Emergency Action Levels for Non-Passive Reactors" 3.22 Environmental Protection Agency, "Protective Action Guide and Planning Guidance for Radiological Incidents," Draft for Interim Use and Public Comment (March 2013) 3.23 10 CFR 72.3, "Definitions" 3.24 DCS-001, TN ISFSI 10 CFR 72.212 Evaluation, Revision 11 3.25 DCS-002, Holtec ISFSI 10 CFR 72.212 Evaluation, Revision 2 5 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 4.0 DEFINITIONS AND ABBREVIATIONS 4.1 DEFINITIONS This section provides definitions that are used in this document. Terms capitalized in the text of the definitions indicate that they are defined elsewhere in this section.

Accident Assessment - Accident assessment consists of a variety of actions taken to determine the nature, effects and severity of an accident.

Accountability - A procedural or discretionary PROTECTIVE ACTION taken for all persons within the ISFSI PROTECTED AREA, which involves the gathering of personnel into pre-designated areas, and the subsequent verification that the location of these personnel is known.

Alert - Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the ISFSI or a security event that involves probable life-threatening risk to station personnel or damage to ISFSI equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guide exposure levels.

Annual - Frequency of occurrence is met if performed within 1.25 times a 12-month interval as measured from the previous performance. This definition does not apply to the term "annual" when it relates to the conduct of the EMERGENCY PREPAREDNESS Exercise and drills, which are performed within the calendar year.

Assessment Activities - Actions taken during or after an emergency for the purpose of obtaining and processing the information that will be used to make the decisions to implement specific emergency measures.

Biennial - Occurring every two calendar years.

Classification - The comparison of conditions, indications, and reports associated with an off-normal, natural phenomenon, or accident event to the approved emergency classification system, to determine the most accurate EMERGENCY ACTION LEVEL.

Command and Control - When in Command and Control of the event, the designated individual has overall responsibility for the SONGS emergency response efforts.

Controlled Area - The area immediately surrounding the SONGS ISFSI for which SCE exercises authority over its use and within which ISFSI operations are performed. The minimum distance from the ISFSI to this boundary is 100 meters to meet 10 CFR 72.106(b). The Controlled Area includes a portion of the Pacific Ocean and limited portions of the adjacent beach and beach walk-way.

Corrective Action - Those emergency measures taken to lessen or terminate an emergency situation to prevent an uncontrolled release of radioactive material, or to reduce the magnitude of a release. Corrective actions include, but are not limited to, equipment repair or shutdown, installation of emergency structures, firefighting, repair, and damage control.

6 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan Declaration - Official determination by the EMERGENCY DIRECTOR that conditions at the ISFSI meet the criteria for an EMERGENCY ACTION LEVEL warranting*CLASSIFICATION of an emergency at the UNUSUAL EVENT or ALERT EMERGENCY CLASSIFICATION LEVEL.

Decontamination - The reduction or removal of radioactive material contamination from a structure, area, material, object, br person. Decontamination may be accomplished by (1) treating the surface so as to remove or decrease the contamination, (2) letting the material stand so that the radioactivity is decreased as a result of natural decay, and (3) covering the contamination.

Design Basis Accident (OBA) - Credible accident events as analyzed in the ISFSI storage system Final Safety Analysis Reports (FSARs) and 10 CFR 72.212 evaluations.

Dose - A generic term that means absorbed dose, dose equivalent, effective dose equivalent, deep dose equivalent, committed dose equivalent, committed effective dose equivalent, or TOTAL EFFECTIVE DOSE EQUIVALENT.

Dose Rate - The amount of ionizing (or nuclear) radiation to which an individual would be exposed per unit of time. As it would apply to DOSE rate to a person, it is usually expressed as rems per hour or in submultiples of this unit, such as millirems per hour. The DOSE rate is commonly used to indicate the level of radioactivity in a contaminated area.

Emergency Action Level (EAL) - A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that when met or exceeded places the station in a given EMERGENCY CLASSIFICATION LEVEL.

Emergency Classification Level (ECL) - One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to potential or actual effects or consequences, and the resulting ONSITE and OFFSITE response actions. The Emergency Classification Levels applicable to the SONGS ISFSI, in ascending order of severity, are:

UE

ALERT Emergency Director (ED) -The Director of the facility in COMMAND AND CONTROL of the event.

The ISFSI Shift Supervisor fills the role of ED throughout an event.

Emergency Plan Implementing Procedures (EPIPs) - Specific procedures describing actions needed to implement the IOEP and describing the methods established to maintain and monitor the IOEP.

Emergency Preparedness (EP) - A state of readiness that provides reasonable assurance that adequate protective measures can and will be taken upon implementation of the Emergency Plan in the event of a radiological emergency. Also, the SCE organization responsible for the Emergency Preparedness program.

Emergency Response Facility (ERF) - The security center of the station from which the ISFSI can be monitored. The facility containing the communication equipment necessary for both normal and emergency conditions. It is operated under the direction of the ISS/ED and serves as the primary location for event CLASSIFICATION, emergency DECLARATION and Notifications to OFFSITE agencies, ASSESSMENT ACTIVITIES, and CORRECTIVE ACTION direction.

7 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan Emergency Response Organization (ERO) - Organization of personnel who may be called upon during an emergency to perform duties to mitigate accident conditions at SONGS.

Emergency Response Personnel - Personnel who may be called upon during an emergency to perform duties to mitigate accident conditions at SONGS.

Essential Personnel - SONGS personnel that either have assigned emergency response duties, are security personnel, are required for maintaining the safe operation of the ISFSI, or are personnel either identified as essential by the ISS/ED or performing critical tasks under the direction of the ISS/ED.

Exclusion Area - The area surrounding the reactor where the licensee has the authority to determine all activities, including exclusion or removal of personnel and property (1 O CFR 100.3).

The Exclusion Area is determined as an area of such size that an individual located at any point on its boundary for two hours immediately following ohset of the postulated fission product release would not receive a total radiation DOSE to the whole body in excess of 25 rem or a total radiation DOSE in excess of 300 rem to the thyroid from iodine exposure [10 CFR 100.11 (a)(1)]. In accordance to the letter dated March 31, 2014 (ADAMS Accession No. ML14092A332), SONGS analyses demonstrate that the radiological consequences of design basis accidents at SONGS will not exceed the 1 rem limit of the EPA PAGs at the EXCLUSION AREA BOUNDARY.

Exclusion Area Boundary (EAB) - For SONGS, the Exclusion Area Boundary (EAB) is roughly formed by two semicircles with radii of 1967.5 ft. each, centered on the Unit 2 Containment dome and a point 134 ft. southeast of the Unit 3 Containment dome, with a tangent connecting the landward arcs and seaward arcs of the two semicircles. The EAB is depicted in the San Onofre 2 &

3 UFSAR (DSAR) Figure 2.1-5.

Hostage - A person(s) held as leverage against the station to ensure that demands will be met by the station.

Hostile Action - An act toward the SONGS ISFSI or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end.

This includes attack by air, land or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

Hostile Action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the SONGS ISFSI. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals within the VEHICLE BARRIER SYSTEM boundary).

Hostile Force - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

Independent Spent Fuel Storage Installation (ISFSI) - A complex designed and constructed for the interim storage of spent nuclear fuel, solid reactor-related Greater Than Class C (GTCC) waste, and ot~er radioactive materials associated with spent fuel and re~ctor-related GTCC waste storage.

Initiating Condition (IC) - An event or condition that aligns with the definition of one of the ECLs by virtue of the potential or actual effects or consequences.

Integrated Drill - A drill that incorporates multiple demonstration requirements to be conducted in connection with one another.

8 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan Local Government Agencies - Orange County and San Diego County.

Offsite - The area around the station that lies beyond the EAB.

Onsite - The area around the station that lies within the EAB.

Projectile - An object directed toward the SONGS ISFSI that could cause concern for its continued capability, reliability, or personnel safety.

Protected Area (PA) - That area within the ISFSI security boundary as defined in SONGS's Security Plan.

Protective Actions - Those emergency measures taken for the purpose of preventing or minimizing radiological, or other hazard, exposures to affected population groups.

Quarterly - Frequency of occurrence is met if performed within 1.25 times a 92-day interval as measured from the previous performance.

Radiologically Controlled Area (RCA) - An area in which radioactive material is present and the potential exists for the spread of radioactive contamination. The area will be posted for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.

Site Boundary - The plant easement boundary (or site boundary) is delineated in the San Onofre 2

& 3 UFSAR (DSAR) Section 2.1.1.2. The site, comprising 83.63 acres, is approximately 4500 feet long and 800 feet wide. The San Onofre State Beach is located along the Pacific Coast on both the north and south ends of the site. Old U.S. Highway 101 is immediately adjacent to the east boundary line of the site. Access between open beach areas is provided by a walkway (the beach passage-way) adjacent to the NIA and Units 2&3 seawalls.

Staffed Warning Point - OFFSITE agency location that is staffed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day such as 911 call-centers or other staffed watch locations.

Total Effective Dose Equivalent (TEDE) - The sum of the effective DOSE equivalent (for external exposure) and the committed effective DOSE equivalent (for internal exposure).

Unusual Event (UE) - Events are in process or have occurred which indicate a potential degradation of the level of safety of the ISFSI or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring OFFSITE response or monitoring are expected unless further degradation of safety systems occurs.

9 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 4.2 ABBREVIATIONS Cal OES - California Governor's Office of Emergency Services CFR - Code of Federal Regulations DBA - Design Basis Accident DSAR - Defueled Safety Analysis Report EAB - Exclusion Area Boundary EAL - Emergency Action Level ECL - Emergency Classification Level ED - Emergency Director EP - Emergency Preparedness EPIP - Emergency Plan Implementing Procedure ERF - Emergency Response Facility ERO - Emergency Response Organization FSAR - Final Safety Analysis Report IOEP - ISFSI-Only Emergency Plan ISFSI - Independent Spent Fuel Storage Installation NRC - Nuclear Regulatory Commission PA - Protected Area RCA - Radiologically Controlled Area TEDE - Total Effective Dose Equivalent UE - Unusual Event UFSAR - Updated Final Safety Analysis Report 10 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan PART II 1.0 ASSIGNMENT OF RESPONSIBILITY (ORGANIZATION CONTROL)

Planning Standard 50.47(b)(1) (as exempted in Reference 3.17) - Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

1.1 EMERGENCY RESPONSE AND RESPONSIBILITIES The ISFSI Shift Supervisor (ISS) is at the station 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day and is the senior management position at the station during off-hours. This position is responsible for monitoring ISFSI conditions and managing ISFSI activities.

The individual in charge of the SONGS emergency response is given the title of EMERGENCY DIRECTOR (ED). When an off-normal, natural phenomenon, or accident event becomes apparent, the ISS shall assess the condition and declare an emergency if warranted. When an emergency is declared the ISS assumes the position of the EMERGENCY DIRECTOR (ED).

During an emergency, the EMERGENCY RESPONSE ORGANIZATION (ERO) replaces the normal station organization. The ERO provides the following functions:

Control and operation of station activities

Mitigation of the emergency condition

Protection of ONSITE personnel

Event CLASSIFICATION and emergency DECLARATION

Radiological monitoring

Emergency notifications to Federal, State and LOCAL GOVERNMENT AGENCIES

Coordination of emergency support for firefighting, security and rescue/first aid The on-shift personnel are available 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day. The on-shift personnel can perform all required response actions, including manning of communications, until individuals arrive to augment shift personnel. The ERO maintains the depth and capability for continuous 24-hour coverage of the emergency response for a protracted period.

11 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 1.2 OFFSITE RESPONSE ORGANIZATIONS (ORO}

Agreements are maintained with OFFSITE organizations who do not take part in the organizational control of the emergency, that provide assistance when called upon during an emergency or during the recovery phase. These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information during an event. The actual letters and memoranda of agreement are maintained in Emergency Preparedness files, with the exception of the Law Enforcement agreements which are maintained per the Security Plan. These organizations provide services of:

a. Fire protection;

b. Rescue operations;

c. Ambulance services;

d. Medical and hospital services; e: Law enforcement.

State and LOCAL GOVERNMENT AGENCY response will be in accordance with each agency's plans and procedures, and commensurate with the hazard posed by the emergency.

United States Marine Corps Camp Pendleton Fire Department USMC CPFD provides fire response per Agreement.

United States Marine Corps Camp Pendleton Fire Department USMC CPFD provides rescue operations per Agreement.

United States Marine Corps Camp Pendleton Fire Department Agreement for prompt ambulance transport of personnel is maintained with USMC CPFD. Such service is available on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day basis.

Mission Hospital Agreement for hospital and medical services is maintained with Mission Hospital. This facility is equipped and qualified for receiving and treating contaminated and/or injured persons requiring immediate hospital care.

Tri-City Medical Center Agreement for hospital and medical services is maintained with Tri-City Medical Center. This facility is equipped and qualified for receiving and treating contaminated and/or injured persons requiring immediate hospital care.

Law Enforcement Law enforcement services are provided by the FBI and local public entities per the Security Plan.

12 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 2.0 EMERGENCY RESPONSE ORGANIZATION (ERO)

Planning Standard 50.47(b)(2) - On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

2.1 ON-SHIFT POSITIONS SONGS has personnel on-shift at all times that provide the initial response to an event. Members of the on-shift organization are trained on their responsibilities and duties in the event of an emergency and are capable of performing all necessary response actions until the augmentation personnel arrive or the event is terminated. The normal shift staffing assignments include the roles and responsibilities for their emergency response functions. The relationship between normal and emergency response positions for the shift personnel is unchanged when an event occurs. (See Table 2-1.)

ISFSI Shift Supervisor (ISS)IEMERGENCY DIRECTOR (ED)

The ISFSI Shift Supervisor (ISS) is the on-shift individual who makes the initial event CLASSIFICATION and assumes the role of ED upon emergency DECLARATION and has the authority and responsibility to immediately and unilaterally initiate any emergency actions. If the ISS is unavailable or incapacitated, another on-shift person qualified as ED will assume the ED duties.

The ED has the authority to suspend any security measure described in the Physical Security Plan as necessary to facilitate response to emergency conditions.

The Non-delegable responsibilities of the ISS/ED include the following:

Event CLASSIFICATION and emergency DECLARATION

Decision to notify OFFSITE agencies

Authorization for the use of EPA-400 emergency exposure controls (emergency worker DOSE limits that exceed 10 CFR 20 occupational exposure limits)

Key delegable responsibilities of the ED include the following:

Management of available station resources

Initiation of assessment and mitigative/CORRECTIVE ACTIONS

Initiation of ONSITE PROTECTIVE ACTIONS

Decision to call for OFFSITE law enforcement, firefighting or ambulance assistance

Augmentation of the EMERGENCY RESPONSE ORGANIZATION as deemed necessary

Notification of SCE corporate officers and the SCE Corporate Communications Department

Notification of OFFSITE agencies (State and LOCAL GOVERNMENT AGENCIES, Marine Corps Base Camp Pendleton and NRC) 13 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan Security Station Security is administered by the Security Plan and reports to the ED when implementing the IOEP. Security personnel assist the ED as directed.

2.2 AUGMENTED POSITION The ERO is responsible for implementing the actions described in this Plan. The ERO is made up of on-shift personnel (described in section 2.1), augmented by the Resource Manager. Supplemental personnel are contacted as needed.

Resource Manager The Resource Manager will be in contact with the ED within two hours of CLASSIFICATION. The Resource Manager will augment the ED by assisting in assessment of the emergency conditions (refer to Table 2-1) and coordinating required resources, including public information interface. The Resource Manager does not need to physically report to SONGS to perform their responsibilities.

Supplemental personnel shall report at the discretion of the ED and/or the Resource Manager.

2.3 SUPPLEMENTAL PERSONNEL Additional personnel resources may be directed to report to SONGS to provide support as needed to assess radiological conditions, conduct maintenance and repair activities, develop and implement CORRECTIVE ACTION plans, and assist with recovery actions. The supplemental personnel are available from SONGS staff and SCE, and can be requested from various contractors.

14 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 2.4 FUNCTIONAL RESPONSIBILITIES Table 2-1 below lists the functional responsibilities of on-shift and augmented positions that fulfill emergency staffing capabilities.

TABLE 2-1 EMERGENCY RESPONSE ORGANIZATION Staffing and Responsibility AUGMENTED OFFSITE FUNCTIONAL AREA LOCATION SHIFT STAFFING

RESPONSE

One (1)

EMERGENCY ISFSI Shift Supervisor/ One (1)

Assessment of Condition RESPONSE FACILITY EMERGENCY Resource Manager DIRECTOR (a)

Emergency Direction EMERGENCY EMERGENCY and Control RESPONSE FACILITY DIRECTOR (a)

Notifications / EMERGENCY EMERGENCY Communications RESPONSE FACILITY DIRECTOR (a)

Radiological ACCIDENT Resource Manager (b)

EMERGENCY ISFSI Shift Supervisor/

ASSESSMENT and RESPONSE FACILITY/ EMERGENCY PROTECTIVE One (1) or more On Scene DIRECTOR (a)

ACTIONS RP Support (c)

EMERGENCY Resource Manager (b) I CORRECTIVE EMERGENCY RESPONSE FACILITY/ Supplemental / Support ACTIONS DIRECTOR (a)

On Scene Personnel Per Fire Protection OFFSITE Response Firefighting On Scene Program Plan Organization OFFSITE Response Rescue On Scene --- Organization First Aid On Scene Shift Personnel ---

Security Per Security Plan Per Security Plan ---

(a) One person comprising the on-shift minimum staff. May perform concurrent functions.

(b) One person comprising the augmented ERO. May perform concurrent functions.

(c) For a declared emergency involving radiological consequences (E-HU1), a minimum of one person trained in radiological monitoring and assessment will report to the SONGS ISFSI within four hours of the emergency DECLARATION.

15 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 3.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES Planning Standard 50.47(b)(3) (as exempted in Reference 3.17) -Arrangements for requesting and effectively using assistance resources have been made and other organizations capable of augmenting the planned response have been identified.

Letters and Memoranda of Agreement for OFFSITE organizations that have pre-agreed arrangements to support ONSITE response actions are maintained on file.

No other specific assistance has been pre-identified.

Fire, Ambulance and Local Law Enforcement Agency response is at the request and direction of the ED as previously discussed in Part II, Section 1.2 of this Plan.

The ED is authorized to request Federal assistance as needed. The Nuclear Regulatory Commission (NRC) will act as the lead Federal agency providing coordination and support in response to a nuclear incident.

16 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 4.0 EMERGENCY CLASSIFICATION SYSTEM Planning Standard 50.47(b)(4) (as exempted in Reference 3.17) -A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee.

SONGS utilizes NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors" as its basis for classifying emergencies. The CLASSIFICATION system referenced in NEI 99-01, Rev. 6 has been endorsed by the NRC and offers a standard method for classifying emergencies. EALs are addressed in site procedures and the ISFSI-Only Emergency Plan Emergency Action Level Technical Bases Manual (IOEP-2).

This Plan addresses two (2) CLASSIFICATIONS of emergencies (UNUSUAL EVENT and ALERT),

which represent a hierarchy of emergencies based on potential accidents that could occur at the SONGS ISFSI. Once indications are available that an EAL is met, the event is assessed and classified, and the corresponding EMERGENCY CLASSIFICATION LEVEL is promptly declared as soon as possible.

4.1 UNUSUAL EVENT Events are in progress or have occurred which indicate a potential degradation of the level of safety of the SONGS ISFSI or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring OFFSITE response or monitoring are expected. State and LOCAL GOVERNMENT AGENCIES, Marine Corps Base Camp Pendleton, and the NRC are notified of an UNUSUAL EVENT.

The purpose of the UNUSUAL EVENT CLASSIFICATION is to bring the on-shift staff to a state of readiness and to provide for systematic handling of event information and its relatfld decision making.

4.2 ALERT Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the SONGS ISFSI or a security event that involves probable life-threatening risk to site personnel or damage to ISFSI equipment because of HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.

As in the case of the UNUSUAL EVENT, the ALERT CLASSIFICATION includes emergency situations which are not expected to threaten the public, but for which notification of the State and LOCAL GOVERNMENT AGENCIES, Marine Corps Base Camp Pendleton, and the NRC is required.

17 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 4.3 EMERGENCY ACTION LEVELS AND POSTULATED ACCIDENTS

Both EMERGENCY CLASSIFICATION LEVELS are characterized by EALs consisting of specific instrument readings and/or observations which are used to tell the SONGS ISS that an INITIATING CONDITION has been met. These EALs are used to assure that the initial CLASSIFICATION of emergencies can be accomplished rapidly, allowing for the prompt identification of the nature of mitigating activities needed.

EALs and INITIATING CONDITIONS are provided under the following categories for the SONGS ISFSI:

Hazards and Other Conditions

ISFSI Malfunction The applicable ISFSI Storage System FSARs and 10 CFR 72.212 evaluations describe the DESIGN BASIS ACCIDENTS (DBAs) applicable to the SONGS ISFSI, along with the radiological DOSE calculation results. Specific guidance for classifying emergencies is found in site procedures and the ISFSI-Only Emergency Plan Emergency Action Level Technical Bases Manual (IOEP-2).

EALs shall be reviewed with State and LOCAL GOVERNMENT AGENCIES and Marine Corps Base Camp Pendleton on an ANNUAL basis.

18 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 5.0 NOTIFICATION METHODS AND PROCEDURES Planning Standard 50.47(b)(5) (as exempted in Reference 3.17) - Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and fol/owup messages to response organizations has been established.

Notification and Mobilization of SONGS EMERGENCY RESPONSE PERSONNEL EPIPs are established to alert and notify ONSITE EMERGENCY RESPONSE PERSONNEL of the initial CLASSIFICATION or any escalation of an emergency by verbal announcement over portable radios. Each emergency CLASSIFICATION may result in augmentation personnel being notified to respond.

Bases for Notification of OFFSITE Agencies SONGS, in cooperation with State and LOCAL GOVERNMENT AGENCIES and Marine Corps Base Camp Pendleton, has established mutually agreeable methods and procedures for notification of OFFSITE Response Organizations consistent with the approved emergency CLASSIFICATION and action level scheme. Notifications to OFFSITE agencies include a means of verification.

Commercial telephone is the communication process used to notify the State and LOCAL GOVERNMENT AGENCIES and Marine Corps Base Camp Pendleton of a declared emergency.

Notification to the State and LOCAL GOVERNMENT AGENCIES and Marine Corps Base Camp Pendleton is required within 60 minutes of emergency DECLARATION, escalation, or change in radiological release status.

The following OFFSITE agencies, at a minimum, will receive emergency messages:

State of California

Orange County

San Diego County

Marine Corps Base Camp Pendleton Follow-up messages will be made to these agencies approximately every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months utilizing a notification form.

19 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan SONGS, in coordination with State and LOCAL GOVERNMENT AGENCIES and Marine Corps Base Camp Pendleton, has established the content of the emergency messages to be sent from SONGS. These messages shall contain the following information if it is known and appropriate:

Location of incident (SONGS), and name and telephone number (or communications channel identification) of caller.

Date I time of incident.

Class of emergency and EAL.

SONGS emergency response actions underway.

Request for any needed ONSITE support by OFFSITE agencies.

Prognosis for worsening or termination of event based upon facility (instrumentation or response team) information.

NRC Event Notification The NRC is notified immediately following notification of the appropriate State and LOCAL GOVERNMENT AGENCIES and Marine Corps Base Camp Pendleton, and not later than 60 minutes after the time of initial emergency DECLARATION, escalation, termination or entry into the recovery phase. Notification to the NRC is the responsibility of the ED. Communications with the NRC Operations Center will be performed primarily via commercial telephone. Cellular and/or satellite phone may be used as the back-up means of communication.

Support Organizations Medical, rescue, and firefighting support services are notified for assistance, using commercial telephone, as the situation dictates.

American Nuclear Insurers (ANI) is notified as soon as possible in the event of a nuclear incident that requires notification to State or Federal authorities.

20 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 6.0 EMERGENCY COMMUNICATIONS Planning Standard 50.47(b)(6) (as exempted in Reference 3. 17) - Provisions exist for prompt communications among principal response organizations to emergency personnel.

Reliable Communications SONGS has reliable primary and backup communication systems installed. Communications with all organizations will be performed primarily via commercial telephone. Cellular and/or satellite phone may be used as the back-up means of communication.

SONGS maintains the capability to make initial notifications to the designated State and LOCAL GOVERNMENT AGENCIES, Marine Corps Base Camp Pendleton, and NRC STAFFED WARNING POINTS on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day basis. Communications will be performed primarily via commercial telephone. Cellular and/or satellite phone may be used as the back-up means of communication.

Communications with the California Governor's Office of Emergency Services (Cal OES), Orange County, San Diego County, Marine Corps Base Camp Pendleton, and NRC are provided from the ERF.

ERO augmentation personnel notification will be made by the ISS, and other ERO supplemental personnel notification may be performed by the use of call trees. ONSITE communications amongst the ERO are by use of portable radios.

Coordinated communications exist with ambulance and hospital services.

The communication systems listed in Table 6-1 below provide 24-hour ONSITE and OFFSITE communications capability. Communication systems are tested to verify proper operation at the testing frequency specified in the table below. Communication systems that are listed with a testing frequency of "Frequent Use" indicates that the associated equipment is normally used at a sufficiently high regularity (e.g., multiple times each day), such that separate additional testing is not needed. Functionality is verified through normal (frequent) use of the system.

TABLE 6-1 Communication Systems Communication System Testing Frequency Commercial telephone system Frequent Use Portable radios Frequent Use Mobile communications dE3vices (cellular and/or satellite phones) l QUARTERLY*

Performance of drill requirements specified in Section 14 satisfies the testing frequency 21 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 7.0 PUBLIC INFORMATION Planning Standard 50.47(b)(7) (as exempted in Reference 3. 17) - The principal points of contact with the news media for dissemination of information during an emergency are established in advance, and procedures for coordinated dissemination of information to the public are established.

As the principle point of contact for the dissemination of information during an event at the station, SCE Corporate Communications Department personnel will be notified of a declared emergency.

SCE Corporate Communications Department will monitor media activity and coordinate with senior management disseminating public information per communication protocols. As necessary, news conference(s) can be conducted at the site or other coordinated location. SCE Corporate Communications Department personnel, or senior SONGS management will represent the facility as the spokesperson. If an event occurs at the SONGS ISFSI, information will be disseminated to the public in a timely manner.

The SCE Corporate Communications Department personnel address any misinformation related to a declared emergency.

22 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 8.0 EMERGENCY FACILITY AND EQUIPMENT Planning Standard 50.47(b)(8) - Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

This section of the Plan identifies and describes the emergency response facilities, the communication systems, the assessment facilities and equipment, the first aid and medical facilities, and protective equipment and supplies that can be utilized during an emergency.

8.1 EMERGENCY RESPONSE FACILITY EMERGENCY RESPONSE FACILITY (ERF) is staffed in accordance with Section 2.0. The ERF is open on a continuous basis. There is no activation needed.

The emergency COMMAND AND CONTROL functions are managed within the ERF. Within the ERF, the ED (or other personnel as directed) can assess conditions, evaluate the magnitude and potential consequences of abnormal conditions, initiate preventative and CORRECTIVE ACTIONS; and perform notifications.

Radiological conditions as a result of DBAs specified in the ISFSI storage system FSARs and 10 CFR 72.212 evaluations do not inhibit staffing of the ERF.

8.2 EMERGENCY EQUIPMENT This section describes the monitoring instruments used to initiate emergency measures and provide continuing assessment of conditions throughout the course of an emergency.

Portable Radiation and Contamination Monitoring Instruments Portable radiation and contamination monitoring instruments normally utilized and maintained by the station are available for emergency use.

Communication Systems Communication systems are identified and tested as described in Section 6.

Emergency Supplies Emergency kit contents listed in Appendix A are inspected, inventoried, and operationally checked at least QUARTERLY and anytime a kit is opened and used. Sufficient reserves of instruments/equipment are provided to replace those which are removed from emergency kits for calibration or repair. Calibration of instruments has been established at intervals recommended by instrument suppliers, or as required by Federal regulations.

First Aid Facilities First aid supplies and equipment are located at the SONGS ISFSI. Qualified personnel are available 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day to provide medical treatment as referenced in Section 12.

23 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 9.0 ACCIDENT ASSESSMENT Planning Standard S0.47(b)(9) (as exempted in Reference 3. 17) - Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

The ASSESSMENT ACTIVITIES required to evaluate a particular emergency depend on the specific nature and CLASSIFICATION of the emergency. The ED is responsible for the initial measurement of ISFSI DOSE RATES after an off-normal, natural phenomenon, or accident event.

The EALs identify the parameter value to determine the emergency condition. CLASSIFICATION of events is performed by the ED in accordance with the EAL scheme.

If the measured ISFSI DOSE RATES exceed the EAL threshold, the ED then performs a radiological release assessment in the vicinity of the affected storage module or cask. After completing the assessment, the ED contacts the Resource Manager to assist in interpreting the radiological release assessment results.

Notification of a radiological release assessment is in accordance with Section 5.0.

24 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 10.0 PROTECTIVE ACTIONS Planning Standard 50.47(b)(10) (as exempted in Reference 3.17) -A range of protective actions has been developed for emergency workers and the public.

PROTECTIVE ACTIONS for ONSITE personnel are provided for their health and safety.

Implementation guidelines for ONSITE PROTECTIVE ACTIONS are provided in EPIPs.

Additionally, the EPIPs provide for a range of PROTECTIVE ACTIONS (e.g. relocation of personnel and personnel take cover) to protect ONSITE personnel during HOSTILE ACTIONS.

ACCOUNTABILITY ACCOUNTABILITY should be considered and used as a PROTECTIVE ACTION whenever a site wide risk to health or safety exists and prudence dictates. If personnel ACCOUNTABILITY is required, at the direction of the ED all individuals at the site (including employees without emergency assignments, visitors, and contractor personnel) shall be notified of the emergency.

ACCOUNTABILITY of all personnel inside the ISFSI PROTECTED AREA (PA) should be accomplished within 60 minutes after emergency DECLARATION and maintained thereafter. If personnel are unaccounted for, teams shall be dispatched to locate the personnel.

Non-ESSENTIAL PERSONNEL located outside of the ISFSI PA but within the SITE BOUNDARY will be directed to report to an assembly area or exit the site, as appropriate. The ED is responsible for controlling access to the site when the IOEP is activated.

25 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 11.0 RADIOLOGICAL EXPOSURE CONTROL Planning Standard 50.47(b)(11)- Means for controlling radiological exposures, in an emergency, are estab/ishedfor emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

SONGS maintains a radiological exposure control program to assure that protection against radiological exposure, as set forth in 10 CFR Part 20 is provided. This program is implemented through the radiological protection procedures which cover both normal and emergency radiation protection measures.

Means for controlling radiological exposures in an emergency are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

Exposure Guidelines During an emergency, DOSES above normal occupational radiation exposure limits may be authorized by the ED for activities such as saving a life, preservation of valuable equipment, or controlling exposure. Table 11-1 contains the guidelines for emergency exposure criteria, which is consistent with the EPA's, "Protective Action Guide and Planning Guidance for Radiological Incidents," Table 2-2, "Guidance on Dose Limits for Workers Performing Emergency Services".

Radiation Protection The purpose of a Radiation Protection Program is to assure that radiation DOSES received by personnel are kept as low as reasonably achievable and do not exceed the prescribed limits for both normal and emergency conditions. The established measures to provide this assurance include access control, personnel monitoring, and contamination control.

Access Control During a declared emergency, radiological surveys of the ISFSI area will be performed to determine the actual extent of the radiological conditions. As necessary, the ED will ensure RCAs and access controls are established to prevent personnel from entering the area. Recovery and CORRECTIVE ACTIONS will be planned and executed in a manner that minimizes exposure to personnel.

Contaminated areas are isolated with appropriate radiological protection and access control.

Personnel leaving contaminated areas are monitored for radioactive contamination. Supplies, instruments, and equipment that are in contaminated areas or have been brought into contaminated areas will be monitored prior to removal.

Restricted areas and contaminated items will be returned to normal use when contamination levels have been returned to acceptable levels. Contamination control criteria for returning areas and items to normal use ,are contained in the station procedures.

26 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan Personnel Exposure Monitoring Personal dosimeters are utilized to monitor the exposure of personnel during emergency conditions. Adequate supplies of dosimeters are maintained for use during an emergency.

Procedures describe in detail the types of personal dosimeter devices, the manner in which they are to be used, who is to wear them, and how they are to be cared for.

Emergency worker DOSE records are maintained in accordance with station procedures.

Contamination Control Various contamination control measures are utilized. These include access control measures and means for the DECONTAMINATION of personnel, areas, and equipment. These activities are addressed in facility procedures and are briefly described below. All personnel are monitored for radioactive contamination prior to leaving the RCA. During normal or emergency conditions, contamination should be removed from any part of a person's body prior to their leaving the RCA.

All personnel DECONTAMINATION, even during an emergency, will be performed under the supervision of personnel trained in radiological monitoring and assessment and in accordance with established procedures.

Portable contamination monitoring instruments are available to frisk personnel for potential contamination.

Documentation of surveys, contamination, and DECONTAMINATION activities shall be maintained in accordance with station procedures.

Table 11-1 Emergency Worker Guidelines Guideline DOSE Limit Activity Condition (Rem TEDE) 5 All occupational exposures All Emergency Workers may be authorized up to 5 Rem Emergency Exposure for the emergency; however all reasonably achievable actions should be taken to minimize DOSE. Attempts should be made to keep exposures within 10 CFR 20 limits.

10 (a) Protecting valuable property Lower DOSE not practicable.

necessary for public welfare 25 (b) Lifesaving or protection of large Lower DOSE not practicable.

populations

> 25 (b) Lifesaving or protection of large Only on a voluntary basis to persons fully aware populations of the risks involved.

Limit DOSE to the lens of the eye to 3 times the above values and DOSES to any other organ (including skin and body extremities) to 1O times the above values;'

(a) For potential DOSES >5 rem, medical monitoring programs should be considered.

(b) In the case of a very large incident, may need to consider raising the property and lifesaving emergency.worker guidelines to prevent further loss of life and massive spread of destruction.

27 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 12.0 MEDICAL AND HEALTH SUPPORT Planning Standard 50.47(b)(12) -Arrangements are made for medical services for contaminated injured individuals.

Medical assistance is available ONSITE and OFFSITE for treatment of SONGS ISFSI personnel.

Various means of transportation are available to transport individuals for radiological and non-radiological injuries.

The individuals and organizations providing emergency medical assistance as identified in this section either have the capability for evaluation of radiation exposure and uptake or they are provided this capability from SCE in the form of personnel and/or equipment. SCE assures that persons providing these services are adequately prepared to handle contaminated individuals through detailed training classes, drills and exercises. Letters of Agreement with OFFSITE organizations and individuals for medical support are listed in Appendix C.

ONSITE First Aid First aid assistance at the SONGS ISFSI is designed to handle a wide range of injuries. This task is accomplished by ONSITE individuals trained in basic first aid procedures.

Medical Transportation Transportation of injured personnel is available via local emergency medical services, SONGS vehicles, or private vehicles. When personnel are transported to Mission Hospital or Tri-City Medical Center while in a contaminated condition, a person trained in radiological monitoring will be dispatched to monitor and maintain radiological controls.

OFFSITE Medical Support The Mission Hospital in Mission Viejo, California, has medical facilities capable of handling various types of injuries. Mission Hospital is capable of treating patients with injuries of a non-radiological or radiological nature.

In addition, Tri-City Medical Center in Oceanside, California, has medical facilities capable of handling various types of injuries. Tri-City Medical Center is likewise capable of treating patients with injuries of a non-radiological or radiological nature.

Table 12-1 lists the main capabilities of the medical centers. Mission Hospital_ fully meets the requirements for medical support of the ISFSI Only Emergency Plan. Tri-City Medical Center is included solely as an additional resource for convenience and does not constitute a separate site-specific commitment for medical support.

28 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan Table 12-1 Medical Centers Capabilities Capability Mission Hospital Tri-City Medical Center General medical treatment Yes Yes Emergency medical Yes Yes treatment for individuals with injuries Emergency medical Yes Yes treatment for individuals with injuries complicated by radioactive contamination Emergency medical Yes Yes treatment for individuals exposed to excessive levels of radiation Physical capacity, personnel, Yes Yes medical equipment and resources to provide evaluation and treatment of contaminated injured individuals 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day Distance to SONGS 19 miles 27 miles 29 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 13.0 EMERGENCY TERMINATION AND RECOVERY Planning Standard 50.47(b)(13) - General plans for recovery and reentry are developed.

SCE has established general plans described in the following sections to conduct recovery from potential emergencies at the SONGS ISFSI. The recovery organization will be based on the normal SONGS organization and would function with the senior management position being responsible for site activities.

Emergency Termination and Notification Termination of an emergency status is the responsibility of the ED. The ED is also responsible for providing notification of the emergency termination and initiation of Recovery operations to the NRC, State and LOCAL GOVERNMENT AGENCIES and Marine Corps Base Camp Pendleton, the SONGS ERO and other organizations that may be providing ONSITE support.

Recovery Operations Recovery operations begin immediately following emergency termination and will address the specific emergency circumstances. Recovery planning includes equipment to be repaired or replaced, licensing implications, special training requirements, OFFSITE support, and determination of causes and consequences. Site procedures addressing Recovery operations provide an outline for a short-term Recovery plan.

The senior management position shall be responsible for the development and implementation of the Recovery plan and shall provide for detailed monitoring of the implementation and status reporting. The senior management position also has the authority to revise or halt activities as circumstances dictate.

The ISFSl recovery will be terminated by the SONGS senior management position after the lSFSI has been returned to a stable condition.

30 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 14.0 EXERCISE AND DRILLS Planning Standard 50.47(b)(14) - Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

Exercise and Drill SONGS conducts a BIENNIAL Exercise to test the adequacy of timing and content of implementing procedures and methods; to test emergency equipment and communication networks; and to ensure that emergency personnel are familiar with their duties. Each exercise will be evaluated by station evaluators and possibly Federal evaluators. SONGS will invite Federal, State, and LOCAL GOVERNMENT AGENCIES to participate or observe scheduled exercises.

For alternating years, an INTEGRATED DRILL is conducted for the purpose of testing, developing, and maintaining the proficiency of emergency responders. BIENNIAL Exercises and alternate year INTEGRATED DRILLS will allow the ERO to demonstrate principal functional areas.

Exercise and drill scenarios are developed to provide reasonable assurance that anticipatory responses will not result from preconditioning of participants. Exercise and drill scenarios, as appropriate, emphasize coordination among ONSITE and OFFSITE Response Organizations.

Exercise and drills allow free play for decision making. The scenarios for use in exercises and drills include, at a minimum, the following:

The basic objective(s) of each drill and exercise and appropriate evaluation criteria;

The date(s), time period, place(s), and participating organizations;

The simulated events;

A time schedule of real and simulated initiating events;

A narrative summary describing the conduct of the exercises or drills to include such things as simulated casualties, OFFSITE fire department assistance, rescue of personnel, use of protective clothing; and,

A description of the arrangements for and advance materials to be provided to official observers.

The scenario should be varied from year to year such that all major elements of the plans and preparedness organizations are tested.

31 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan Equipment and Proficiency Drills Drills are conducted to provide supervised instruction, training and practice opportunities for ERO members. Drills may be performed as part of the BIENNIAL exercise, INTEGRATED DRILL or as an independent drill. A drill may be a component of an exercise. Drills are supervised and evaluated by qualified personnel. Drills are conducted, in addition to the exercise at the frequencies indicated below:

Communication Drills A communications drill with State and LOCAL GOVERNMENT AGENCIES is conducted ANNUALLY. A communications drill with NRG Headquarters is conducted ANNUALLY.

Communication drills include the aspect of understanding the content of messages.

Fire Drills A fire drill is conducted in accordance with SONGS Fire Protection Program.

Medical Emergency Drills A medical emergency drill, involving a simulated contaminated individual, which contains provisions for participation by local support services organizations (i.e., ambulance and support hospital), is conducted ANNUALLY. The OFFSITE portions of the medical drill may be performed as part of the required BIENNIAL exercise or INTEGRATED DRILL.

Radiation Protection Drills A Radiation Protection drill is conducted ANNUALLY.

Augmentation Drills An unannounced augmentation drill is conducted ANNUALLY. This drill involves implementation of the ERO callout system procedure and documentation of the estimated response time for each responder. This drill demonstrates the capability to augment the ED after an emergency is declared.

Critique and Evaluation Critiques shall be scheduled at the conclusion of each exercise or alternate year INTEGRATED DRILL to evaluate the performance of the organization. The ability of EMERGENCY RESPONSE PERSONNEL to self-evaluate weaknesses and identify areas for improvement is the key to successful exercise/ drill conduct.

Exercise and drill objectives are evaluated against measurable demonstration criteria. Following the conclusion of each exercise or drill, a critique, including participants and evaluators, is conducted to evaluate the ability of the ERO to implement the IOEP and its implementing procedures.

Official observers from the NRG should observe, evaluate, and critique the required exercises.

A formal evaluation in the form of a written critique report is prepared following an exercise or DRILL involving the evaluation of designated objectives. The report evaluates and documents the ability of the ERO to respond to a simulated emergency situation. The report will also contain reference to Corrective Action Program documents and recommendations.

32 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan The critique process is used as the means for evaluating observer and participant comments to identify areas of ERO performance and the EMERGENCY PREPAREDNESS Program that require improvement, including emergency plan procedural changes. The Emergency Preparedness Manager is responsible for ensuring that items identified in the critique are correctly dispositioned, appropriate assignment of responsibility is made and that corrective actions are implemented in accordance with the Corrective Action Program.

33 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 15.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING Planning Standard 50.47(b)(15) - Radiological emergency response training is provided to those who may be called on to assist in an emergency.

15.1 EMERGENCY RESPONSE PERSONNEL TRAINING Requirements for EMERGENCY PREPAREDNESS training are specified in the EMERGENCY PREPAREDNESS Training Program. This program identifies the level and the depth to which individuals are to be trained. SONGS or Non-SONGS personnel who are brought in to assist with response, mitigating, or recovery actions who have not received emergency planning training will receive Just-In-Time training prior to performing response actions. This includes training on radiological hazards and Visitor/Escort responsibilities for personnel who are not badged for unescorted ISFSI PA access.

EMERGENCY PREPAREDNESS Training Program The training for ERO personnel is developed from the position-specific responsibilities as defined in this Plan. Members of the ERO receive initial training and ANNUAL retraining. They also receive recurring Emergency Plan-related training ANNUALLY through General Employee Training and position-specific training as appropriate.

Specific training requirements for ERO, supplemental, and support personnel are delineated below:

ISFSI Shift Supervisors/EMERGENCY DIRECTORS and Resource Managers Trained such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum initially and on an ANNUAL basis.

Emergency CLASSIFICATION

State and LOCAL GOVERNMENT AGENCIES, Marine Corps Base Camp Pendleton, and NRC notifications

ERO activation

DOSE RATE meter operation

Radiological release assessment

Emergency exposure control

PROTECTIVE ACTIONS for ONSITE personnel

ISFSI DBAs Personnel Responsible for ACCIDENT ASSESSMENT The skills and knowledge required to perform monitoring of the ISFSI are provided to personnel qualified as ISS/ED. ' ,

Resource Managers who assist with ACCIDENT ASSESSMENT, CORRECTIVE ACTIONS, PROTECTIVE ACTIONS, and related activities receive appropriate training.

34 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan Radiological Assessment Personnel Resource Managers who assist with radiological assessment, CORRECTIVE ACTIONS, PROTECTIVE ACTIONS, and related activities receive appropriate training.

Radiation Protection Technicians (SONGS or Non-SONGS) who may be called to supplement the ERO are trained in the course of their normal work to be able to provide support for radiological ACCIDENT ASSESSMENT and PROTECTIVE ACTIONS. Support activities include access control; radiological coverage (e.g., monitoring, surveys, and support) for personnel conducting repairs, CORRECTIVE ACTIONS, search and rescue, first aid, firefighting, contaminated injury response (including transport); as well as providing personnel monitoring and dosimetry.

Fire Control Teams Station personnel are trained to report any fire to the ISFSI Alarm Station, then use available fire protection equipment within their level of competency. Responding USMC CPFD personnel are invited to receive training, as outlined in Section 15.2.

Medical Support Personnel Mission Hospital personnel and Tri-City Medical Center personnel are invited to receive training, as outlined in Section 15.2.

Security and Law Enforcement Personnel Station Security personnel are trained in accordance with the Security Plan. Local Law Enforcement Agency support personnel are invited to receive training, as outlined in Section 15.2.

First Aid and Rescue Teams Selected individuals assigned on-shift ERO responsibility receive first aid training equivalent to Red Cross Adult First Aid/CPR/AED). Station personnel are trained to report any injury or medical emergency to the ISS, then provide first aid treatment within their level of competency. Responding USMC CPFD support personnel are invited to receive training as outlined in Section 15.2.

Personnel who are badged for unescorted ISFSI PA access receive initial and ANNUAL refresher training on general station procedures and policies. This training includes required actions to be taken if an emergency is declared at the SONGS ISFSI.

Personnel assigned to work at the station who do not require unescorted ISFSI PA access, including visitors, receive information on the actions to be taken if an emergency is declared at the SONGS ISFSI.

35 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 15.2 SUPPORT ORGANIZATIONS TRAINING Training is made available to support organizations that may be called upon to provide assistance in the event of an emergency.

Non-SONGS organizations that may provide specialized services during an emergency (i.e., law enforcement, firefighting, rescue, medical services, and transport of injured personnel) are provided or offered site-specific emergency response training, ANNUALLY.

The training made available is structured to meet the needs of that organization with respect to the nature of their support. Training topics such as event notification, basic radiation protection, and interface activities between the OFFSITE organization and SONGS are made available.

36 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan 16.0 MAINTAINING EMERGENCY PREPAREDNESS Planning Standard 50.47(b)(16) - Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

16.1 EMERGENCY PREPAREDNESS RESPONSIBILITIES SONGS ISFSI Senior Management Position Southern California Edison (SCE) is responsible for the maintenance of SONGS EMERGENCY PREPAREDNESS Program. The issuance and control of this Plan and the activities associated with EMERGENCY PREPAREDNESS at SONGS shall be the overall responsibility of the SONGS ISFSI Senior Management Position.

Emergency Preparedness Manager Responsible for the following tasks:

Maintaining and updating this IOEP and associated procedures, and documenting reviews and revisions

Coordinating the IOEP with other station programs and procedures

Overseeing the EMERGENCY PREPAREDNESS Training Program and ensuring that proper records are maintained to document training of the ERO

Overseeing and documenting the EMERGENCY PREPAREDNESS Drill and Exercise Program

Documenting and maintaining the EMERGENCY PREPAREDNESS Facilities and Equipment

Documenting and maintaining the EMERGENCY PREPAREDNESS interfaces with OFFSITE agencies

Performing and documenting appropriate evaluations of the EMERGENCY PREPAREDNESS Program and of declared emergency events

Ensuring that the ERO is notified of updates to the IOEP or EPIPs

Ensuring that the OFFSITE Response Organizations are notified of updates to the IOEP

Ensuring that all the Letters and Memoranda of Agreement with support organizations are reviewed ANNUALLY and updated as needed

Maintaining current knowledge of changes in Federal regulations and other guidance that impact emergency planning activities

Submitting IOEP and related controlled document revisions to the NRC

Ensuring that an independent review of the EMERGENCY PREPAREDNESS Program is conducted to meet the requirements of 10 CFR 50.54(t) 37 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan The individual assigned as the Emergency Preparedness Manager receives training in order to maintain an adequate knowledge of regulations, planning techniques and the latest applications of emergency equipment and supplies. This training may include:

Courses specific or related to EMERGENCY PREPAREDNESS

Observation of or participation in drills and/or exercises at other stations

Participation in industry review and evaluation programs

Participation in regional cir national EMERGENCY PREPAREDNESS seminars, committees, workshops or forums

10 CFR 50.54(q) and 10 CFR 72.44(f) Evaluation Qualification and/or Training 16.2 REVIEW AND UPDATING OF THE IOEP It is important that a state of EMERGENCY PREPAREDNESS be maintained at all times. The IOEP is reviewed ANNUALLY and updated, as needed. The ANNUAL IOEP review/update includes required changes identified during 10 CFR 50.54(t) reviews, assessments, training, drills, and exercises.

Any needed changes shall be incorporated in the IOEP, IOEP Emergency Action Level .Technical Bases Manual, and appropriate implementing procedures. The IOEP, IOEP Emergency Action Level Technical Bases Manual, and EPIPs are distributed on a controlled basis.

Changes to the IOEP, IOEP Emergency Action Level Technical Bases Manual, and EPIPs are subject to evaluation under 10 CFR 50.54(q) and 10 CFR 72.44(f).

EMERGENCY ACTION LEVELS (EALs) State and LOCAL GOVERNMENT AGENCY Review The EALs shall be made available for review with State and LOCAL GOVERNMENT AGENCIES ANNUALLY.

Implementing and Supporting Procedures EPIPs provide specific instructions to be taken for each emergency CLASSIFICATION including responsibilities, notification of OFFSITE emergency organizations, and mobilization of the ERO.

These procedures provide specific instructions to personnel for response to events and actions required to administer the EMERGENCY PREPAREDNESS Program. EPIPs are updated as appropriate, in consideration of improvement opportunities identified during exercises, drills and training. Changes to these procedures are subject to evaluation under 10 CFR 50.54(q) and 10 CFR 72.44(f).

Emergency Response Directory Names and telephone numbers of the augmented ERO, supplemental personnel and applicable supporting OFFSITE organizations shall be reviewed and updated at least QUARTERLY.

j Letters and Memoranda of Agreement ANNUALLY, each Letter or Memorandum of Agreement with support organizations is reviewed and verified current in order to assure the availability of assistance from each supporting organization.

38 Revision 2 I.

IOEP-1 SONGS ISFSI-Only Emergency Plan PART Ill APPENDIX A Emergency Equipment, Supplies, and Reference Materials EMERGENCY RESPONSE FACILITY Procedures/ Reference Material ISFSI-Only Emergency Plan (IOEP-1)

ISFSI-Only EAL Technical Bases Manual (IOEP-2)

Emergency Response Directory (EP ERO)

EMERGENCY PLAN IMPLEMENTING PROCEDURES Equipment Communications equipment (portable radios, cellular phone, satellite phone)

Portable radiation monitoring equipment Portable emergency lighting Medical emergency response bag Dosimeters Supplies Contamination control supplies DECONTAMINATION supplies Protective clothing 39 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan APPENDIX B Cross Reference IOEP Section to Planning Standards/ Requirements/ Criteria and Procedures Table B-1 NUREG-0654, IOEP Planning Planning Section II Part II Standard Requirement Procedure Evaluation Section (10 CFR 50.47)** (Appendix E.IV)**

Criteria A.1, 2, 4, 7 EPP-1, 1.0 (b)(1) A EPP-2 2.0 (b)(2) A.1, 2, 4; C.1 8 EPP-1 3.0 (b)(3) A.6, 7 C EPP-2 4.0 (b)(4) 8.1, 2; C.1, 2 D EPP-1 5.0 (b)(5) A.6, 7; C.1; D.1,3; E E EPP-1 6.0 (b)(6) C.1; D.1, 3; E F EPP-1 7.0 (b)(7) Exempt G EPP-1 E;G EPP-1, 8.0 (b)(8) H EPP-2 9.0 (b)(9) A.4; 8.1; C.2; E I EPP-1 10.0 (b)(10) C.1; E J EPP-1 11.0 (b)(11) E K EPP-1 A.6, 7; E EPP-1, 12.0 (b)(12) L EPP-2 13.0 (b)(13) H M EPP-1 14.0 (b)(14) E9; F N EPP-2 15.0 (b)(15) F 0 EPP-2, ADM-30 16.0 (b)(16) G p EPP-2

- Refer to the SONGS exemptions from portions of 10 CFR 50.47 and Appendix E for applicability.

40 Revision 2

IOEP-1 SONGS ISFSI-Only Emergency Plan APPENDIX C List of Letters and Memoranda of Agreement Organization Applicable To Mission Hospital Medical Treatment, including Contaminated Injured Person Tri-City Medical Center Medical Treatment, including Contaminated Injured Person Marine Corps Installation West- Firefighting / Search & Rescue / Transport, Marine Corps Base Camp Pendleton including Contaminated Injured Person The actual letters and memoranda of agreement are maintained in Emergency Preparedness files.

41 Revision 2

Enclosure 2 SONGS ISFSI-Only Emergency Action Level Technical Bases Manual IOEP-2, Revision 2

IOEP-2 EAL Technical Bases Manual San Onofre Nuclear Generating Station (SONGS)

Independent Spent Fuel Storage Installation {ISFSI)

Only Emergency Plan Emergency Action Level Technical Bases Manual Revision 2

IOEP-2 EAL Technical Bases Manual TABLE OF CONTENTS Section Page

1.0 INTRODUCTION

................................................................................................................................1 1.1 PURPOSE ..............................................................................................................................1 1.2 EMERGENCY CLASSIFICATION LEVELS (ECLS) ..............................................................2 1.3 INITIATING CONDITIONS (ICS) ............................................................................................3 1.4 EMERGENCY ACTION LEVELS (EALS) ..............................................................................3 1.5 EAL TECHNICAL BASES MANUAL CONTENT ................................................................... .4 2.0 DEFINITIONS AND ABBREVIATIONS .............................................................................................5 2.1 DEFINITIONS .........................................................................................................................5 2.2 ABBREVIATIONS ..................................................................................................................8 3.0 EAL MATRIX TABLE ........................................................................................................................9 4.0 EAL TECHNICAL BASES ...............................................................................................................11 4.1 PD-HA 1 ................................................................................................................................ 11 4.2 PD-HU1 ................................................................................................................................ 12 4.3 PD-HA3 ................................................................................................................................ 13 4.4 PD-HU3 ................................................................................................................................ 14 4.5 -E-HU1 .................................................................................................................................15 ii Revision 2

IOEP-2 EAL Technical Bases Manual

1.0 INTRODUCTION

1.1 PURPOSE This document contains the Nuclear Regulatory Commission (NRC) approved set of INITIATING CONDITIONS (ICs), their associated EMERGENCY ACTION LEVEL (EAL) thresholds, and their site-specific technical bases, for the San Onofre Nuclear Generating Station (SONGS)

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI), using the EAL development methodology found in NEI 99-01 Revision 6.

Any changes to this document will be made in accordance with the requirements of 10 CFR 50.54(q) and 10 CFR 72.44(f).

Personnel responsible for emergency CLASSIFICATION and declaration shall use this document as a technical reference and an aid in EAL interpretation. 1 The primary tool for determining the EMERGENCY CLASSIFICATION LEVEL is the EAL Matrix Table in this manual. The user of the EAL Matrix Table may (but is not required to) consult the Emergency Action Level Technical Bases Manual in order to obtain additional information concerning the EALs being considered for CLASSIFICATION of an emergency.

This document is also used to facilitate review of any proposed changes to the SONGS ISFSI-Only EALs.

The SONGS ISFSI is essentially an interim spent fuel storage facility where the spent fuel is surrounded by inert gas inside a container called a canister. The canisters used at SONGS are stainless steel cylinders that are welded closed. The fuel is cooled by natural airflow around the canister. The fuel was moved to dry storage after several years in spent fuel pools, so the heat given off by the fuel has significantly decreased. Each canister is surrounded by additional steel, concrete, or other material to provide physical protection, structural integrity, and additional radiation shielding to workers and members of the public. These primary functions of the ISFSI are the focus of the ISFSI-Only ICs and EALs.

SCE was granted exemptions from portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and 10 CFR 50 Appendix E, Section IV. The basis for these exemptions has not changed and remains in effect for the ISFSI-Only Emergency Plan (IOEP). The changes to this Technical Bases Manual reflect the lowered radiological source term and risks associated with ISFSI storage relative to reactor at power operation or storage in spent fuel pools. Source terms and accident analyses associated with design basis accidents are documented in the dry storage systems' Final Safety Analysis Reports (FSARs) and 10 CFR 72.212 evaluations.

With regard to event recognition and CLASSIFICATION, regulations specific to the declaration of emergencies are provided in planning standard 10 CFR 50.47(b)(4), 10 CFR 50 Appendix E.IV.B, and 10 CFR 72.32(a)(3).

1 Emergency event declaration is required to be made as soon as possible and within 30 minutes after the availability of the indications that an EMERGENCY ACTION LEVEL has been exceeded. Use of this document for assistance is not intended to delay event declaration.

1 Revision 2

IOEP-2 EAL Technical Bases Manual The NRC, by letter to Nuclear Energy Institute (NEI) dated 03/28/13 (ML12346A463), documented its review of the draft version of NEI 99-01, Revision 6, dated November 2012 (ML12326A805), and found it acceptable for use by licensees seeking to upgrade their EMERGENCY ACTION LEVELS (EALs) in accordance with 10 CFR 50 Appendix E. The regulatory and technical analysis for this endorsement can be retrieved through ADAMS Accession No. ML13008A736.

1.2 EMERGENCY CLASSIFICATION LEVELS (ECLS)

As defined in NUREG-0654/FEMA-REP-1, nuclear power plant emergencies are separated into four ECLs:

UNUSUALEVENT(U~

ALERT

Site Area Emergency

General Emergency The ECLs are escalated from least severe to most severe according to the relative threat to the health and safety of the public and emergency workers. An ECL is determined to be met by identifying abnormal conditions and then comparing them to ICs through EAL threshold values as discussed below. When multiple EALs are met, event declaration is based in the highest ECL reached.

The ISFSI Only ICs and EALs within this document use the lower two of the four EC Ls. The source terms and release motive forces associated with an ISFSI are not sufficient to require declaration of a Site Area Emergency or General Emergency.

2 Revision 2

IOEP-2 EAL Technical Bases Manual 1.3 INITIATING CONDITIONS (ICS)

An IC is a general description of an event or condition that aligns with the definition of one of the ECLs by virtue of the potential or actual effects or consequences.

Each IC is given a unique identification code consisting of a hyphenated letter combination, a separate letter and one number. The hyphen*ated letter combination identifies the recognition category, the separate letter identifies the ECL, and the number identifies the sequence of the IC within the recognition category. The EAL identification codes are developed as follows:

Permanently Defueled Recognition Category Applicable to ISFSI

PD-H - Hazards and Other Conditions ISFSI Recognition Category

E-H - ISFSI Malfunction ISFSI Only ECLs (lowest to highest)

U- UNUSUAL EVENT

A-ALERT For an ISFSI-Only station, the UNUSUAL EVENT ICs provide for an increased awareness of abnormal conditions while the ALERT ICs are specific to actual or potential impacts to spent fuel.

Security and Judgment ICs and EALs were included to provide a basis for classifying events that cannot be readily classified based on observable events or physical conditions alone.

1.4 EMERGENCY ACTION LEVELS (EALS)

An EAL is a pre-determined, site-specific, observable threshold for an IC that, when met or exceeded, places the ISFSI in a given ECL.

EAL thresholds may utilize a variety of criteria including instrument readings and status indications; observable events; and entry into particular procedures.

EALs are individually identified by the IC identification code followed by the EAL number, such as E-HU1 .1 for damage to a loaded canister CONFINEMENT BOUNDARY or PD-HA1 .1 for a HOSTILE ACTION within the VEHICLE BARRIER SYSTEM (VBS).

All EAL CLASSIFICATION assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicator's operability, the condition's existence, or the report's accuracy.

3 Revision 2

IOEP-2 EAL Technical Bases Manual 1.5 EAL TECHNICAL BASES MANUAL CONTENT EAL Matrix Table This manual contains an EAL Matrix Table that addresses all of the recognition categories for the ISFSI EAL thresholds.

The EAL Matrix Table is designed as an evaluation tool that organizes the ECLs from the highest (ALERT) on the left to the lowest (UNUSUAL EVENT) on the right. Evaluating the EALs for each ECL from highest to lowest reduces the possibility that an event will be under classified. All EALs are to be reviewed for applicability prior to event declaration.

Other user aids, such as wallcharts, may be developed from the EAL Matrix Table to support evaluation of abnormal conditions in other human factored formats.

EAL Documentation Format Each EAL within the technical bases manual is documented in the following manner:

IC Identification Number

INITIATING CONDITION

EAL Threshold Value(s)

Basis

Basis Reference(s) 4 Revision 2

IOEP-2 EAL Technical Bases Manual 2.0 DEFINITIONS AND ABBREVIATIONS 2.1 DEFINITIONS Advanced Horizontal Storage Module (AHSM) - The Transnuclear AHSM is a reinforced concrete structure for storage of a loaded DRY SHIELDED CANISTER (DSC) at a spent fuel storage facility.

Alert - Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the ISFSI or a security event that involves probable life-threatening risk to site personnel or damage to ISFSI equipment because of HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Classification - The comparison of conditions, indications, and reports associated with an off-normal, natural phenomenon, or accident event to the approved emergency classification system, to determine the most accurate EMERGENCY ACTION LEVEL.

Confinement Boundary - The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As applied to the SONGS ISFSI, the Confinement Boundary is defined by the inner surface of the sealed Transnuclear DSC or Holtec MULTl-PURPOSE CANISTER (MPC).

Dry Shielded Canister (DSC) - A Transnuclear welded pressure vessel that provides confinement of intact or damaged fuel assemblies in an inert atmosphere.

Emergency Action Level (EAL) - A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that, when met or exceeded, places the station in a given ECL.

Emergency Classification Level (ECL) - One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to potential or actual effects or consequences, and the resulting ONSITE and OFFSITE response actions. The Emergency Classification Levels applicable to the SONGS ISFSI, in ascending order of severity, are:

UE

ALERT Exclusion Area Boundary (EAB) - For SONGS, the Exclusion Area Boundary (EAB) is roughly formed by two semicircles with radii of 1967.5 ft. each, centered on the Unit 2 Containment dome and a point 134 ft. southeast of the Unit 3 Containment dome, with a tangent connecting the landward arcs and seaward arcs of the two semicircles. The EAB is depicted in the San Onofre 2 &

3 UFSAR (DSAR) Figure 2.1-5.

Hostage - A person(s) held as leverage against the station to ensure that demands will be met by the station.

5 Revision 2

IOEP-2 EAL Technical Bases Manual Hostile Action - An act toward the SONGS ISFSI or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end.

This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

Hostile Action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the SONGS ISFSI.. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals within the VBS boundary).

Hostile Force - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

Independent Spent Fuel Storage Installation (ISFSI) - A complex designed and constructed for the interim storage of spent nuclear fuel, solid reactor-related Greater Than Class C (GTCC) waste, and other radioactive materials associated with spent fuel and reactor-related GTCC waste storage.

Initiating Condition (IC) - An event or condition that aligns with the definition of one of the ECLs by virtue of the potential or actual effects or consequences.

Multi-Purpose Canister (MPC) - A Holtec sealed spent nuclear fuel canister which provides the CONFINEMENT BOUNDARY for the contained radioactive materials.

Offsite - The area around the station that lies beyond the EAB.

Onsite - The area around the station that lies within the EAB.

Projectile - An object directed toward the SONGS ISFSI that could cause concern for its continued capability, reliability, or personnel safety.

Protected Area (PA) - That area within the ISFSI security boundary as defined in SONGS' Security Plan.

Security Condition - Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety. A Security Condition does not involve a HOSTILE ACTION.

Transfer Cask - Container designed to contain the Transnuclear DSC or Holtec MPC during and after loading of spent fuel assemblies, prior to and during unloading, and to transfer the DSC or MPC to or from the Transnuclear AHSM or Holtec VERTICAL VENTILATED MODULE (WM).

Site Boundary - The plant easement boundary (or site boundary) is delineated in the San Onofre 2

& 3 UFSAR (DSAR) Section 2.1.1.2. The site, comprising 83.63 acres, is approximately 4500 feet long and 800 feet wide. The San Onofre State Beach is located along the Pacific Coast on both the north and south ends of the site. Old U.S. Highway 101 is immediately adjacent to the east boundary line of the site. Access between open beach areas is provided by a walkway (the beach

passage-way) adjacent to the NIA and Units 2&3 seawal'is.

Unusual Event (UE) - Events are in progress or have occurred which indicate a potential degradation of the level of safety of the ISFSI or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring OFFSITE response or monitoring are expected unless further degradation of occurs.

6 Revision 2

IOEP-2 EAL Technical Bases Manual Vehicle Barrier System (VBS) - Vehicle control measures (passive or active) used to protect against the malevolent use of a land vehicle. The VBS consists of both active and passive components, terrain features, man-made structural features, and vehicle access checkpoints as defined in the SONGS Security Plan.

Vertical Ventilated Module (WM) - A subterranean type overpack, which receives and contains the sealed Holtec MPC for interim spent fuel storage at an ISFSI. The Holtec WM supports the MPC in a vertical orientation and provides gamma and neutron shielding, and also provides air flow through cooling passages to promote heat transfer from the MPC to the environs.

7 Revision 2

IOEP-2 EAL Technical Bases Manual 2.2 ABBREVIATIONS AHSM - Advanced Horizontal Storage Module CFR - Code of Federal Regulations DSC - Dry Shielded Canister EAB - Exclusion Area Boundary EAL - Emergency Action Level ECL - Emergency Classification Level ED - Emergency Director EPA - Environmental Protection Agency FAA - Federal Aviation Administration FBI - Federal Bureau of Investigation FEMA - Federal Emergency Management Agency FSAR - Final Safety Analysis Report IC - Initiating Condition ISFSI - Independent Spent Fuel Storage Installation ISS - ISFSI Shift Supervisor MPC - Multi-Purpose Canister mR - milli-Roentgen Equivalent Man NEI - Nuclear Energy Institute NORAD - North American Aerospace Defense Command NRC - Nuclear Regulatory Commission PA - Protected Area SCE - Southern California Edison SONGS - San Onofre Nuclear Gererating Station SSS - Security Shift Supervisor UE - Unusual Event VBS - Vehicle Barrier System WM - Vertical Ventilated Module 8 Revision 2

IOEP-2 EAL Technical Bases Manual 3.0 EAL MATRIX TABLE ALERT UNUSUAL EVENT .

PD-HA1 HOSTILE ACTION within the VBS boundary. PD-HU1 Confirmed SECURITY CONDITION or threat.

PD-HA1.1 A HOSTILE ACTION is occurring or has PD-HU1.1 A SECURITY CONDITION that does not involve a occurred within the VBS boundary as HOSTILE ACTION as reported by the SSS.

reported by the SSS.

PD-HU1 .2 Notification of a credible security threat directed at the site.

PD-HA3 Other conditions exist which in the judgment PD-HU3 Other conditions exist which in the judgment of the of the ISS/ED warrant declaration of an ALERT. ISS/ED warrant declaration of an UNUSUAL EVENT.

PD-HA3.1 Other conditions exist which in the PD-HU3.1 Other conditions exist which in the judgment of the judgment of the ISS/ED indicate that ISS/ED indicate that events are in progress or have events are in progress or have occurred occurred which indicate a potential degradation of which involve an actual or potential the level of safety of the ISFSI or indicate a substantial degradation of the level of security threat to the ISFSI has been initiated. No safety of the ISFSI or a security event that releases of radioactive material requiring OFFSITE involves probable life-threatening risk to response or monitoring are expected unless further site personnel or damage to ISFSI degradation occurs.

equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guide exposure levels.

CONTINUED ON NEXT PAGE 9 Revision 2

IOEP-2 EAL Technical Bases Manual 3.0 EAL MATRIX TABLE (Continued)

ALERT UNUSUAL EVENT E-HU1 Damage to a loaded canister CONFINEMENT BOUNDARY.

E-HU1.1 Damage to a loaded Transnuclear canister CONFINEMENT BOUNDARY as indicated by dose rates greater than ANY of the following:

520 mR/hr (gamma) 3 feet from the surface at the top centerline.

190 mR/hr (gamma) 3 feet from the surface of the neutron shield at the mid-height centerline.

100 mR/hr on the surface of the front inlet bird screen of the AHSM. Two dose rate measurements are taken for each front inlet bird screen for the AHSM. These dose rate measurements are approximately 30 inches measured vertically from the surface of the ISFSI pad and within 24 inches from the centerline horizontally of each front bird screen.

20 mR/hr on the outside surface of the AHSM door. Five dose rate measurements are taken on each door; one at the door center, and four others at equidistant locations around the door center at a radius of approximately 25 inches.

E-HU1.2 Damage to a loaded Holtec canister CONFINEMENT BOUNDARY as indicated by dose rates greater than EITHER of the following:

44 mR/hr (gamma + neutron) on the top of the WM (closure lid cover plate). A minimum of four dose rate measurements shall be taken on the top of the WM. These measurements shall be taken on the side of the closure lid approximately mid-height and adjacent to the inlet vent. One measurement per each lid side, rotationally symmetric by approximately 90 degrees.

7,000 mR/hr (gamma+ neutron) on the side of the TRANSFER CASK. A minimum of four dose rate measurements shall be taken on the side of the TRANSFER CASK, approximately at the cask mid-height plane. The measurement locations shall be approximately 90 degrees apart around the circumference of the cask. Dose rates shall be measured between the radial ribs of the water jacket.

10 Revision 2

IOEP-2 EAL Technical Bases Manual 4.0 EAL TECHNICAL BASES 4.1 PD-HA1 1*111itiating GQndition:t * * ~

HOSTILE ACTION within the VBS boundary.

I EAL:**

PD-HA1 .1. A HOSTILE ACTION is occurring or has occurred within the VBS boundary as reported by the s.ecurity Shift Supervisor.

I Basis: . . '.-~ ';, \'. ...

This IC addresses the occurrence of a HOSTILE ACTION within the VBS boundary. This event will require rapid response and assistance due to the possibility of the attack progressing to the ISFSI PROTECTED AREA.

Timely and accurate communications between SSS and the ISS is essential for proper CLASSIFICATION of a security-related event.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the staff and implementation of ONSITE protective measures (e.g., evacuation, dispersal or sheltering). The ALERT declaration will also heighten the awareness of OFFSITE Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.

Reporting of these types of events is adequately addressed by the requirements of 10 CFR 73. 71 or 10 CFR 50.72.

EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, within the VBS boundary.

This includes any action directed against the ISFSI that is located within the VBS boundary.

In some cases, it may not be readily apparent if an aircraft impact within the VBS boundary was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.

Additional SONGS Site-Specific Bases Information:

None.

I Basis

Reference:

I

1. NEI 99-01 Rev 6, PD-HA 1 11 Revision 2

IOEP-2 EAL Technical Bases Manual 4.2 PD-HU1 1* 1nitiating-Condition:

Confirmed SECURITY CONDITION or threat.

IEALs:

PD-HU1 .1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.

PD-HU 1.2. Notification of a credible security threat directed at the site.

I Basis: : . '*

This IC addresses events that pose a threat to station personnel or the spent fuel, and thus represent a potential degradation in the level of station safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA 1.

Timely and accurate communications between SSS and the ISS is essential for proper CLASSIFICATION of a security-related event. CLASSIFICATION of these events will initiate appropriate threat-related notifications to station personnel and OFFSITE Response Organizations.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

EAL #1 references Security Shift Supervisor because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and CLASSIFICATION is controlled due to the nature of Safeguards and 10 CFR 2.390 information.

EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with Security procedures. Credible security threat includes a HOSTILE ACTION within the SITE BOUNDARY outside of the VBS boundary.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.

Escalation of the ECL would be via IC PD-HA 1.

Additional SONGS Site-Specific Bases Information:

None.

I Basis

Reference:

1. NEI 99-01 Rev 6, PD-HU1 12 Revision 2

IOEP-2 EAL Technical Bases Manual 4.3 PD-HA3 I Initiating Condition: I Other conditions exist which in the judgment of the ISS/ED warrant declaration of an ALERT.

EAL:

PD-HA3.1. Other conditions exist which in the judgment of the ISS/ED indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the ISFSI or a security event that involves probable life-threatening risk to site personnel or damage to ISFSI equipment because of HOSTILE ACTION. Any releases are ex ected to be limited to small fractions of the EPA Protective Action Guide ex osure levels.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the ISS/ED to fall under the ECL description for an ALERT.

Additional SONGS Site-Specific Bases Information:

None.

I Basis Reference(s):

1. NEI 99-01 Rev 6, PD-HA3

2. EPA-400, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents 13 Revision 2

IOEP-2 EAL Technical Bases Manual 4.4 PD-HU3 I Initiating Condition:

Other conditions exist which in the judgment of the ISS/ED warrant declaration of a UE.

PD-HU3.1. Other conditions exist which in the judgment of the ISS/ED indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the ISFSI or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring OFFSITE response or monitoring are expected unless further degradation occurs.

l'Basis: .*.

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the ISS/ED to fall under the ECL description for a UE.

Additional SONGS Site-Specific Bases Information:

None.

I Basis

Reference:

1. NEI 99-01 Rev 6, PD-HU3 14 Revision 2

IOEP-2 EAL Technical Bases Manual 4.5 -E-HU1 I Initiating Conctition:

Damage to a loaded canister CONFINEMENT BOUNDARY.

I EAL:

E-HU1 .1. Damage to a loaded Transnuclear canister CONFINEMENT BOUNDARY as indicated by dose rates greater than ANY of the following:

520 mR/hr (gamma) 3 feet from the surface at the top centerline.

190 mR/hr (gamma) 3 feet from the surface of the neutron shield at the mid-height centerline.

100 mR/hr on the surface of the front inlet bird screen of the AHSM. Two dose rate measurements are taken for each front inlet bird screen for the AHSM. These dose rate measurements are approximately 30 inches measured vertically from the surface of the ISFSI pad and within 24 inches from the centerline horizontally of each front bird screen.

20 mR/hr on the outside surface of the AHSM door. Five dose rate measurements are taken on each door; one at the door center, and four others at equidistant locations around the door center at a radius of approximately 25 inches.

E-HU1 .2. Damage to a loaded Holtec canister CONFINEMENT BOUNDARY as indicated by dose rates greater than EITHER of the following:

44 mR/hr (gamma+ neutron) on the top of the WM (closure lid cover plate).

A minimum of four dose rate measurements shall be taken on the top of the WM.

These measurements shall be taken on the side of the closure lid approximately mid-height and adjacent to the inlet vent. One measurement per each lid side, rotationally symmetric by approximately 90 degrees.

7,000 mR/hr (gamma + neutron) on the side of the TRANSFER CASK. A minimum of four dose rate measurements shall be taken on the side of the TRANSFER CASK, approximately at the cask mid-height plane. The measurement locations shall be approximately 90 degrees apart around the circumference of the cask. Dose rates shall be measured between the radial ribs of the water jacket.

I Basis:*

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage canister containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage canister is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the canister or fuel from storage.

The existence of "damage" is determined by radiological survey. The EAL threshold values, which are a technical specification multiple of "2 times", are used here to distinguish between non-emergency and emergency conditions. The emphasis for this CLASSIFICATION is the degradation in the level of safety of the-'spent fuel canister and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded canister, the fact that the "on-contact" dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the canister.

Security-related events for ISFSls are covered under ICs PD-HU1 and PD-HA1.

15 Revision 2

IOEP-2 EAL Technical Bases Manual Additional SONGS Site-Specific Bases Information:

Transnuclear Technical Specifications for the Standardized Advanced Nuhoms System Operating Controls and Limits" Amendment 4, Appendix A to CoC 1029, Section 5.2.4 (Radiation Protection Program) and Section 5.4.2 (AHSM or AHSM-HS Dose Rate Evaluation Program Limits and Locations) contain radiation dose rates for the DSC that should not be exceeded based on whether the DSC is being transported inside the TRANSFER CASK or while it is stored in the AHSM. Keeping in line with NEI guidance that an UNUSUAL EVENT is warranted for radiation conditions at a level of 2 times the Technical Specification value, the values chosen for EAL E-HU1 .1 represent these values.

Holtec "Technical Specifications for the HI-STORM UMAX Canister Storage System" Amendment 4, Appendix A to CoC 1040, Section 5.3 (Radiation Protection Program) contains radiation dose rates for the MPC that should not be exceeded based on whether the MPC is being transported inside the TRANSFER CASK or while it is stored in the VVM. Keeping in line with NEI guidance that an UNUSUAL EVENT is warranted for radiation conditions at a level of 2 times the Technical Specification value, the values chosen for EAL E-HU1 .2 represent these values.

1. NEI 99-01 Rev 6, E-HU1

2. Certificate of Compliance No. 1029, Amendment 4, Appendix A, Technical Specifications for the Advanced NUHOMS System 5.2.4.e and 5.4.2

3. Certificate of Compliance No. 1040, Amendment 4, Appendix A, Technical Specifications for the HI-STORM UMAX Canister Storage System 5.3.4, 5.3.8.a, and 5.3.8.c

4. Holtec Report Hl-2177667 Rev 6, HI-STORM UMAX CoC Dose Rate Limits for SONGS 16 Revision 2

Enclosure 3 Revision 2 Summary of Changes and Analysis

Reference:

EPP-2 SAN ONOFRE NUCLEAR GENERATING STATION REPORT AND ANALYSIS

SUMMARY

10 CFR 50.54(q)(5) / 10 CFR 72.44(f)

Document Number: IOEP-1, Revision 2

Title:

San Onofre Nuclear Generating Station (SONGS) Independent Spent Fuel Storage Installation (ISFSI) Only Emergency Plan Action Request#: 1220-90589 Change Description Analysis Summary The 10CFR50.54(q) evaluation for EPP-1 Revision 1 is covered The changes do not contradict the licensing basis or the emergency plan content. The under AR 1220-90589 assignment 4. This revision includes: changes do not modify the licensing basis with regards to a reduction in effectiveness.

Added 10 CFR 72.212 evaluations along with the ISFSI storage The change to clarify the intent of the statement for agreements maintained with offsite system FSARs, as the evaluations provide site-specific analyses organizations and the change to indicate that the Law Enforcement agreements are based on the FSARs. maintained per the Security Plan by the Security Organization ensure that the concept

Replaced Exclusion Area Boundary (EAB) with Controlled Area of operations for organizations that have an operational role is clearly identified, and its boundary when referring to the ISFSI storage system Final relationship to the emergency effort is understood.

Safety Analysis Reports and the 10 CFR 72.212 evaluations.

Clarified that the term 'annual' with regards to Emergency Removing the use of call trees for notification to augmentation personnel and clarifying Preparedness drills means 'within the calendar year'. that call tress may be used to notify other ERO supplemental personnel ensure that the

Updated the definition of Controlled Area. processes for notification to augmentation and supplemental personnel are properly

Updated the Site Boundary definition to align with the latest Units described.

2/3 DSAR revision 7.

Clarified the intent of the statement for agreements maintained Updating information to reflect that American Nuclear Insurers (ANI) notifications are with offsite organizations, indicating that implementation criteria performed in accordance with their current requirements ensure that the processes for and exchange of information refer to the event. notification to support organizations are properly described.

Clarified that the Law Enforcement agreements are maintained per the Security Plan by the Security Organization, not Addition of the 10 CFR 72.212 evaluations along with the ISFSI storage system FSARs, Emergency Preparedness. as the evaluations provide site-specific analyses based on the FSARs ensures that the methods and systems for assessing and monitoring actual or potential offsite

Removed the use of call trees for notification to augmentation consequences of a radiological emergency condition are properly described.

personnel and clarified that call tress may be used to notify other ERO supplemental personnel.

The replacement of Exclusion Area Boundary (EAB) with Controlled Area boundary

Updated information to reflect that American Nuclear Insurers when referring to the ISFSI storage system Final Safety Analysis Reports and 10 CFR (ANI) notifications are performed in accordance with their current 72.212 evaluations align with the latest revisions to the 10 CFR 72.212 evaluations requirements.

which indicate that the Controlled Area boundary is based on 10 CFR 72.106(b)

Removed wording indicating that dosimeters are utilized to requirements instead of the bounding EAB. These changes ensure that the methods monitor the exposure of personnel during normal conditions.

and systems for assessing and monitoring actual or potential offsite consequences of a

Removed the need for Federal, State, and local government radiological emergency condition are properly described.

agencies to request an invitation to participate or observe schedule exercises. Updating the definition of Controlled Area align with the latest revisions to the 10 CFR

Removed the word "overview" from "emergency planning 72.212 evaluations. This change ensures that the methods and systems for assessing overview traininq."

EP SOA Rev O 08/20 Page 1 of 3

Clarified that station personnel are trained to report any fire to and monitoring actual or potential offsite consequences of a radiological emergency the ISFSI Alarm Station. condition are properly described.

Editorial changes.

The Site Boundary definition is used in IOEP-1 Section 10.0, Protective Actions, to specify that non-essential personnel located outside of the ISFSI PA but within the Site Boundary may be directed to report to an assembly area or exit the site, as appropriate.

Updating the definition ensures adequate protective measures are taken as needed.

The removal of wording indicating that dosimeters are utilized to monitor the exposure of personnel during normal conditions aligns the Emergency Plan with Radiation Protection practices since the Radiation Protection program does not require the use of dosimeters at the ISFSI during normal conditions.

Clarifying the term annual for Emergency Preparedness drills aligns them with the periodicity for Biennial Exercise and the Integrated Drill. As stated in IOEP-1, drills may be performed as part of the Biennial Exercise, Integrated Drill or as an independent drill.

The Biennial Exercise and the Integrated Drill do not have the requirement to be performed within 1.25 times a 12-month interval, they are performed any time during the year. Therefore, this periodicity is also applicable to the annual drills, either when they are part of the biennial exercise or integrate drill, or when they are performed as independent drills.

Proactively inviting Federal, State, and local government agencies to participate or observe scheduled exercises ensures consistency in the exercise preparation process.

This change ensures that exercises and drills are conducted periodically, and offsite organizations are invited to participate or observe.

The word "overview" is being removed from "emergency planning overview training", as it is not used in the specific training modules, and it may cause misunderstanding. This change ensures the Emergency Plan properly reflects the training practices The clarification that station personnel are trained to report any fire to the ISFSI Alarm Station ensures that the Emergency Plan properly reflects the training practices.

The Emergency Plan continues to meet the regulatory requirements of 10CFR50.47(b) and 10CFR50 Appendix E, as exempted.

The changes do not modify the licensing basis with regards to a reduction in effectiveness. Responsibility for emergency response is assigned. Methods, systems, and equipment for assessment of radioactive releases are in use. A range of Protective Actions is available for implementation during emergencies. A range of protective actions is available for emergency workers during emergencies, including hostile action events. The resources for controlling radiological exposures for emergency workers are established. A drill and exercise program (including radiological, medical, health physics, or other program areas) is established. Training is provided to emergency responders. The capability and timeliness of the functions described are not altered by EP SOA Rev 0 08/20 Page 2 of 3

the changes. The capability and timeliness to perform the associated elements are also maintained.

The chanqes can be implemented without prior NRC aooroval.

PREPARED BY: Lucia Sischo REVIEWED BY: Kelli Sholler DATE: 02-03-2022 DATE: 02-08-2022 EP SOA Rev 0 08/20 Page 3 of 3

Reference:

EPP-2 SAN ONOFRE NUCLEAR GENERATING STATION REPORT AND ANALYSIS

SUMMARY

10 CFR 50.54(q)(5) / 10 CFR 72.44(f)

Document Number: IOEP-2, Revision 2

Title:

San Onofre Nuclear Generating Station (SONGS) Independent Spent Fuel Storage Installation (ISFSI) Only Emergency Plan Emergency Action Level Technical Bases Manual Action Request#: 0321-90298 Change Description Analysis Summary The 10CFR50.54(q) evaluation for EPP-1 Revision 1 is covered The changes do not contradict the licensing basis or the emergency plan content. The under AR 0321-90298 assignment 15. This revision includes: changes do not modify the licensing basis with regards to a reduction in effectiveness.

Added 10 CFR 72.212 evaluations along with the ISFSI storage The Site Boundary definition added is used in IOEP-2, Section 4.2, PD-HU1, Basis for system FSARs, as the evaluations provide site-specific analyses EAL#2. This change ensures adequate emergency classifications are performed.

based on the FSARs.

Added the Site Boundary definition as it is used in section 4.2 PD- The Emergency Action Level (EAL) E-HU1 .2 and corresponding EAL basis was HU1, Basis for EAL#2. This definition aligns with the latest Units changed to align with Certificate of Compliance No. 1040, Amendment 4, Appendix A, 2/3 DSAR revision 7. Technical Specifications for the HI-STORM UMAX Canister Storage System 5.3.4,

Changed Emergency Action Level E-HU1 .2 and corresponding 5.3.8.a, and 5.3.8.c and Holtec Report Hl-2177667 Rev 6, HI-STORM UMAX CoC Dose EAL basis to align with Certificate of Compliance No. 1040, Rate Limits for SONGS. In accordance with NEI 99-01 Rev 6, E-HU1 emergency action Amendment 4, Appendix A, Technical Specifications for the HI- level threshold is "Damage to a loaded cask CONFINEMENT BOUNDARY as indicated STORM UMAX Canister Storage System and the Holtec Report by an on-contact radiation reading greater than (2 times the site-specific cask specific Hl-2177667 Rev 6, HI-STORM UMAX CoC Dose Rate Limits for technical specification allowable radiation level) on the surface of the spent fuel cask".

SONGS. The revised EAL threshold for EAL E-HU1 .2 is two times the Technical Specification

Moved Transnuclear information from Basis section *to Additional allowable radiation levels for a HI-STORM UMAX loaded WM with a Version B lid. The SONGS Site-Specific Bases Information section. measurement locations for the radiation readings have changed as indicated in the

Added Holtec information to Additional SONGS Site-Specific Technical Specifications. The thresholds for EAL E-HU1 .2 continue to be two times the Bases Information section. Technical Specification allowable radiation levels. Therefore, the same classification

Editorial changes. scheme as specified in NEI 99-01 Rev 6 is maintained. The changes result in a difference from the approved Emergency Action Levels. This difference is necessary to effectively perform the function of using a standard scheme of emergency classification and action levels.

Transnuclear basis information was moved to the Additional SONGS Site-Specific Bases Information section. Holtec basis information was added to the Additional SONGS Site-Specific Bases Information section These changes ensure site-specific bases for both ISFSI systems are provided and it is located in the correct section.

Addition of the 10 CFR 72.212 evaluations along with the ISFSI storage system FSARs, as the evaluations provide site-specific analyses based on the FSARs ensures that the methods and systems for assessing and monitoring actual or potential offsite consequences of a radioloqical emergency condition are properly described.

EP SOA Rev 0 08/20 Page 1 of 2

The Emergency Plan continues to meet the regulatory requirements of 10CFR50.47(b) and 10CFR50 Appendix E, as exempted.

The changes do not modify the licensing basis with regards to a reduction in effectiveness. A standard scheme of emergency classification and action levels is in use. Methods, systems, and equipment for assessment of radioactive releases are in use. The capability and timeliness of the functions described are not altered by the changes. The capability and timeliness to perform the associated elements are also maintained.

The chan es can be im lemented without PREPARED BY: Lucia Sischo REVIEWED BY: Kelli Sholler DATE: 02-03-2022 DATE: 02-08-2022 EP SOA Rev 0 08/20 Page 2 of 2

Enclosure 4 EPIP EPP-1, Revision 2 and EPIP EPP-2, Revision 2

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SONGS Emergency Response REVISION 2 Page 1 of 28 Procedure Usage Requirements I Sections Reference Use

Review and understand the procedure before performing any Section 6.0, steps, including the prerequisite section. Attachment 1

Have a copy or applicable pages/sections open at the work site.

Use Placekeeping method according to ADM-3.

If any portion of the document is performed from memory, do so in the sequence specified. Perform each step as written, except when an approved process specifically allows deviation.

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

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

NOT QA PROGRAM AFFECTING Procedure Type Procedure Owner Emergency Preparedness Kelli Gallion-Sholler INFORMATION USE

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Emergency Response REVISION 2 Page 2 of 28 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCOPE ...................................................................................................................3 2.0 RESPONSIBILITIES ..........................................................................................................................3 3.0 DEFINITIONS ....................................................................................................................................4 i

4.0 PRECAUTIONS AND LIMITATIONS ................................................................................................4 5.0 PREREQUISITES ..............................................................................................................................4 6.0 PROCEDURE ....................................................................................................................................5 6.1 Assessment, Classification, and Declaration .........................................................................5 6.2 Initial Notifications ..................................................................................................................7 6.3 Abnormal Radiation Levels .................................................................................................. 10 6.4 Event-Related Radiological Release in Progress ................................................................. 10 6.5 Contamination Detected ....................................................................................................... 11 6.6 Contaminated Injury ....................................................................................................'. ........ 11

6. 7 Emergency Authorization ..................................................................................................... 12 6.8 Follow-Up Notifications .........................................................................................................13 6.9 Ongoing Coordination Actions ..............................................................................................14 6.10 Onsite Protective Actions ..................................................................................................... 16 6.11 Mitigative Actions ................................................................................................................. 18 6.12 ShiftTurnover .......................................................................................................................19 6.13 Emergency Termination and Recovery lnitiation ..................................................................21 7.0 ACCEPTANCE CRITERIA ..............................................................................................................23 8.0 RETENTION OF RECORDS ...........................................................................................................23

9.0 REFERENCES

/ COMMITMENTS ..................................................................................................23 ATTACHMENT 1 Recovery ......................................................................................................................................... 25 2 Summary of Changes ..................................................................................................................... 28 INFORMATION USE

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. SONGS Emergency Response REVISION 2 Page 3 of 28 1.0 PURPOSE AND SCOPE 1.1 Provide guidance to the Emergency Response Organization for responding to an emergency at the SONGS Independent Spent Fuel Storage Installation (ISFSI).

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

1.3 Provide guidance on making emergency notifications.

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

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

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

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

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

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

2.5.1 Non-delegable responsibilities:

Classifying and declaring emergencies

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

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

....__ !EIHtliQ~ EPP-1 tfht

~ ~ SONGS Emergency Response REVISION 2 Page 4 of 28 2.5.2 Key delegable responsibilities:

Managing available station resources

Initiating assessment and mitigative/corrective actions

Initiating protective actions within the Exclusion Area Boundary (EAB)

Deciding to call for offsite law enforcement, firefighting, search and rescue or ambulance assistance using EP ERO, Emergency Response Directory

Augmenting the Emergency Response Organization as deemed necessary using EP ERD, Emergency Response Directory

Notifying SCE corporate officers and the SCE Corporate Communications Department using EP ERD, Emergency Response Directory

Notifying offsite agencies (State and local government agencies, Marine Corps Base Camp Pendleton, and NRC) using EP SNF, SONGS Notification Form, and NRC Form 361, Reactor Plant Event Notification Worksheet

Maintaining a record of event activities and decisions made (Reference EP ELB, ERO Logbook) 2.6 The Resource Manager (RM) is responsible for the following actions:

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

Assisting the ED with assessment and tasks

Assisting the ED to supplement the ERO as deemed necessary

Coordinating supplemental personnel and resources to support the emergency response

Maintaining a record of event activities and decisions made (Reference EP ELB, ERO Logbook) 3.0 DEFINITIONS None 4.0 PRECAUTIONS AND LIMITATIONS 4.1 None 5.0 PREREQUISITES 5.1 None INFORMATION USE

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Emergency Response REVISION 2 Page 5 of 28 REFERENCE USE 6.0 PROCEDURE 6.1 Assessment, Classification, and Declaration

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

2. T = 0 for classification: When information that ISFSI conditions have met an EAL is available to the ISS.

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

6.1.2 !E performing a radiological survey, THEN PERFORM the following:

NOTE Steps 6.1.2.1, 6.1.2.2, and 6.1.2.3 may be performed concurrently or in any order.

6.1.2.1 OBTAIN a TLD (located in ISFSI Emergency Kit).

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

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

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

6.1.2.3 OBTAIN radiation monitoring equipment (located in ISFSI Emergency Kit) 6.1.2.4 PERFORM surveys using EP CBA, Confinement Boundary Assessment.

REFERENCE USE

EPP-1 Emergency Response REVISION 2 Page 6 of 28 6.1.2.5 !E dose rates exceed an EAL threshold, THEN PERFORM a radiological release assessment in the vicinity of the affected storage module or cask using open-window vs. closed-window readings downwind on a beta-gamma instrument (reference IOEP-1 Section 9.0).

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

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

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

6.1.5 !E conditions do NOT meet the criteria to declare an emergency, THEN EXIT this procedure.

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

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

RECORD the event classification: _ _ _ __

RECORD the time the event was classified.

(IF an independent verification was obtained, THEN ENTER the time when the classification was agreed upon.): _ _ _ _ __

6.1.6.2 ASSUME the duties of ED.

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

REFERENCE USE

EPP-1

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~~ SONGS Emergency Response REVISION 2 Page 7 of 28 6.2 Initial Notifications 6.2.1 NOTIFY station personnel of the emergency declaration AND response actions via radio using EP SPA, Station Protective Action Notification.

6.2.1.1 RECORD the time radio notification was completed: _ _ _ _ __

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

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

6.2.2.1 COMPLETE EP SNF, SONGS Notification Form.

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

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

6.2.2.4 RECORD the time email was sent: _ _ _ _ __

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

6.2.3.1 RECORD the time notification was transmitted: _ _ _ _ __

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

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

6.2.5.1 RECORD the time RM was contacted: _ _ _ __

6.2.5.2 REVIEW event details with the RM.

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

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

6.2.5.5 !Ethe declared emergency involves radiological consequences (E-HU1),

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

REFERENCE USE

EPP-1 Emergency Response REVISION 2 Page 8 of 28 6.2.5.6 lE the declared emergency is NOT an Alert, THEN DIRECT the RM to ensure American Nuclear Insurers (ANI) is notified using EP ERO, AND requests for assistance are made as necessary.

NOTE

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

2. Verbal Notifications will be performed primarily via commercial telephone.

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

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

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

6.2.6.1.1 RECORD the time each notification is completed:

AGENCY TIME State of California (Cal OES)

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

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

6.2.7.2 RECORD the time NRC HOO was contacted: ------

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

REFERENCE USE

f::j[DISON, EPP-1 Emergency Response REVISION 2 Page 9 of 28 6.2.8 CALL SCE Corporate Communications Department, AND ENSURE EP SNF, SONGS Notification Form, was received and understood.

6.2.8.1 REVIEW event details.

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

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

6.2.9 ENSURE supplemental personnel are called in as needed using EP ERO, Emergency Response Directory.

PERSONNEL FUNCTION 6.2.9.1 DIRECT the called-in supplemental personnel to report to the:

[] ERF

[]Other _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

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

NOTE

1. Notifications to American Nuclear Insurers (ANI) are performed in accordance with the latest ANI Information Bulletin 11-01.

2. ANI will receive copies of EP SNF as it is included in the SONGS Emergency Notifications group email.

6.2.10 IF the declared emergency is an Alert, THEN ENSURE American Nuclear Insurers (ANI) is notified using EP ERO, AND requests for assistance are made as necessary.

6.2.10.1 RECORD the time ANI was notified: _ _ _ _ __

6.2.11 CONDUCT a formal briefing per Step 6.9.4.

REFERENCE USE

EPP-1 Emergency Response REVISION 2 Page 10 of 28 6.3 Abnormal Radiation Levels 6.3.1 PERFORM OR DIRECT performance of radiological surveys.

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

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

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

6.4 Event-Related Radiological Release in Progress 6.4.1 lE the declared emergency involves radiological consequences (e.g., E-HU1),

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

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

6.4.1.2 ENSURE the RP Technician is provided a briefing.

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

6.4.1.4 TRACK the following:

Personnel dispatched

Time dispatched

Location(s) while dispatched

Time personnel return

Radiation dose received 6.4.2 lE dose rates greater than background are measured at the eastern portion of the Site Boundary (along Old Hwy 101), THEN ENSURE an RP Technician is dispatched to measure downwind dose rates at the EAB.

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

REFERENCE USE

~ £191,t~Q.,:/. EPP-1 t&)t.

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SONGS.

Emergency Response REVISION 2 Page 11 of 28 6.4.3 !E dose rates greater than background are measured at the EAB, THEN ENSURE an RP Technician is dispatched to perform offsite field monitoring.

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

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

6.4.5 DIRECT the RP Technician to evaluate ongoing radiological conditions.

6.5 Contamination Detected 6.5.1 RESTRICT access to contaminated areas.

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

6.5.2.1 IF conditions warrant, THEN these criteria may be modified.

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

6.6 Contaminated Injury 6.6.1 DIRECT injury response per SE 911, 911 Emergency Response.

NOTE Transportation of injured personnel is available via local emergency medical services, SONGS vehicles, or private vehicles.

6.6.2 !Ea contaminated injury occurs, THEN DIRECT an RP Technician to decontaminate the injured individual before transportation and accompany the victim to prevent the further spread of contamination, as long as the activity does NOT interfere with providing medical attention or cause an unnecessary delay in transporting the injured person in accordance with SOS-RP 1-PCD-1004.

6.6.3 !Ea contaminated injury occurs, AND individuals are transported by means other than Camp Pendleton Fire Department (CPFD) ambulance, THEN ENSURE the hospital is contacted using EP ERO to provide information and advance notification to prepare to receive radioactively contaminated injured individuals.

REFERENCE USE

~ - SONGS Emergency Response EPP-1 REVISION 2 Page 12 of 28

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

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

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

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

REFERENCE USE

EPP-1 REVISION 2

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~ - SONGS Emergency Response Page 13 of 28 6.8 Follow-Up Notifications 6.8.1 Unless it is interrupted by an event reclassification, ENSURE Follow-up Notifications are completed:

Within 60 minutes of a change in radiological release status; OR

Within 60 minutes of a significant change in event status as determined by the ED AND

Every two hours after completion of the last notification (Initial or Follow-up) 6.8.1.1 COMPLETE EP SNF, SONGS Notification Form.

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

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

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

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

6.8.1.4.2 RECORD the time each notification is completed:

AGENCY TIME State of California (Cal OES)

OranQe County San Dieoo Countv Marine Corps Base Camp Pendleton 6.8.1.5 CONDUCT a formal briefing per Step 6.9.4.

REFERENCE USE

EPP-1 Emergency Response REVISION 2 Page 14 of 28 6.9 Ongoing Coordination Actions 6.9.1 MAINTAIN a log of events and decisions (Reference EP ELB, ERO Logbook).

6.9.2 !E onsite protective actions are required due to the emergency (refer to Section 6.10, Onsite Protective Actions), THEN

NOTIFY station personnel using EP SPA, Station Protective Action Notification, AND

DIRECT Marine Corps Base Camp Pendleton to notify the public located in the beach walkway and beyond the SONGS Site Boundary, but within the EAB.

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

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

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

6.9.3.1.2 DISPATCH teams to locate personnel who are unaccounted for.

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

Current Emergency Classification Level [Alert or Unusual Event]

Current Emergency Action Level

The current hazards

The onsite protective actions

Actions being taken AND the associated priorities

Additional resources or personnel needed

The potential event escalation criteria 6.9.5 ASSESS staffing needs AND ENSURE personnel are called in as required using EP ERO, Emergency Response Directory:

RM

Supplemental personnel REFERENCE USE

~- la rn!~Ri:/ EPP-1

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~~ SONGS Emergency Response REVISION 2 Page 15 of 28 6.9.5.1 ENSURE SONGS and Non-SONGS personnel who are brought in to assist with response, mitigating, or recovery actions who have not received emergency planning training are briefed/trained (including Just-In-Time training) commensurate with the situation and task to be performed, including radiological/ other specific hazards, and Visitor/Escort responsibilities for personnel who are NOT badged for unescorted ISFSI PA access.

LOG the personnel names and a summary of brief/training provided.

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

6.9.6.1 TRACK the following:

Personnel dispatched

Time dispatched

Location(s) while dispatched

Time personnel return

Radiation dose received 6.9.7 !Ethe event is currently classified as a UE, THEN ASSESS conditions continually for possible escalation to an Alert.

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

Are the spent fuel canisters adequately cooled?

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

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

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

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

6.9.9.2 TRACK the following:

Personnel dispatched

Time dispatched

Location(s) while dispatched

Time personnel return

Radiation dose received 6.9.1 O ASSESS any security issues threatening normal ISFSI operations.

REFERENCE USE

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..:::_~ Emergency Response

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

Hostile Action

Increasing Radiation Levels

Airborne Hazards (radioactive or hazardous gases)

Fires

Spill of hazardous materials

Flooding

Structural Damage

Security issues

Any other condition which may present a hazard to personnel REFERENCE USE

EPP-1 Emergency Response REVISION 2 Page 17 of 28 6.10.2 DIRECT appropriate protective actions, including but not limited to:

Relocation of personnel during Hostile Action

Personnel take cover during Hostile Action

Precautionary dismissal of non-essential personnel

Relocation of personnel from the ISFSI Protected Area per Section 6.9, Ongoing Coordination Actions

Relocation of non-essential personnel from within the EAB

Assembling onsite personnel relocated from the ISFSI Protected Area per Section 6.9, Ongoing Coordination Actions

Accounting for personnel inside the ISFSI Protected Area within 60 minutes of declaration of an emergency per Section 6.9, Ongoing Coordination Actions

Maintaining accountability of assembled personnel per Section 6.9, Ongoing Coordination Actions

Dispatching teams to locate personnel who are unaccounted for per Section 6.9, Ongoing Coordination Actions

Search and rescue

Monitoring of relocated personnel for radiological contamination AND applying contamination control measures if radiological contamination is found

Controlling onsite access to potentially radiologically contaminated potable water and food supplies

Restricting access to contaminated areas and items

Contamination Controls (during emergency conditions, normal ISFSI contamination control criteria will be adhered to as much as possible; however, these limits may be modified should conditions warrant)

Relocating AND treating onsite injured personnel, including potentially contaminated personnel

Use of protective clothing 6.10.2.1 Direct response actions per SE 911, ONO-1, or other applicable security procedures as required.

REFERENCE USE

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Emergency Response REVISION 2

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~ - SONGS 6.10.3 !E relocation of personnel from within the EAB is required, THEN CONTACT the Marine Corps Base Camp Pendleton.

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

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

6.10.4.1 TRACK the following:

Personnel dispatched

Time dispatched

Location(s) while dispatched

Time personnel return

Radiation dose received 6.11 Mitigative Actions NOTE The ED is authorized to request Federal assistance as needed. The Nuclear Regulatory Commission (NRC) will act as the lead Federal agency providing coordination and support in response to a nuclear incident.

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

6.11.2 IF necessary to mitigate the event, THEN OBTAIN needed resources to perform mitigative actions, AND radiation protection duties.

6.11.3 DIRECT mitigative actions.

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

6.11.4.1 TRACK the following:

, Personnel dispatched

Time dispatched

Location(s) while dispatched

Time personnel return

Radiation dose received REFERENCE USE

EPP-1 Emergency Response REVISION 2 Page 19 of 28 .

6.12 Shift Turnover 6.12.1 DEVELOP an ERO relief shift roster approximately two hours prior to shift turnover using the table below as a guideline.

6.12.1.1 Security personnel can be obtained from the already scheduled watch bill.

ENTER "Scheduled" in the DATE/TIME CALLED column

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

Are qualified to fill the ERO positions.

Have been called in (use EP ERO or Alert Media for contact information)

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

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

INCOMING RELIEF SHIFT DATE/TIME DATE/TIME POSITION / QUALi FiCATION (Name or NIA if not required.) CALLED REPORTING ISFSI Shift Supervisor (ERP 101)

Security Supervisor (ERP 101 or ERP 104)

Security Officer (ERP 102)

Resource Manager (ERP 103)

RP Support (per SOS training program)

Other supplemental personnel:

REFERENCE USE

' E)EDISON EPP-1

,\* Emergency Response REVISION 2

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~ - SONGS Page 20 of 28 6.12.2 REVIEW the following items with the oncoming ERO:

Completed forms

Current ISFSl/site conditions

Additional EAL thresholds met

Current protective actions

Mitigative actions in progress

Numbers AND names of ERO and support personnel onsite

ERO Logbook 6.12.3 ANNOUNCE turnover of responsibilities to the ERF (ED, only).

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

6.12.5 PROVIDE TLD and electronic dosimeter to Radiation Protection personnel.

6.12.6 LOG the time of turnover of responsibilities.

REFERENCE USE

EPP-1 Emergency Response REVISION 2 Page 21 of 28 6.13 Emergency Termination and Recovery Initiation 6.13.1 WHEN all of the following conditions are met, THEN TERMINATE the emergency, AND INITIATE Recovery:

Conditions do NOT continue to meet the criteria to declare an emergency

Any event-related radiological releases have been stopped

Conditions are stable OR improving

Site radiation levels are stable AND decreasing with time

Any fire, flooding, security issues, or similar emergency conditions are under control OR no longer exist

Any previously met EAL threshold criteria have been evaluated

SONGS Manager, ISFSI has been notified of the impending emergency termination AND Recovery initiation 6.13.2 ANNOUNCE emergency termination AND Recovery initiation to the ERF.

6.13.3 LOG the time of emergency termination AND Recovery initiation.

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

Emergency termination

Recovery initiation

Response actions 6.13.5 NOTIFY other organizations that may be providing onsite support of emergency termination and Recovery initiation.

6.13.6 NOTIFY the active ERO of emergency termination AND Recovery initiation.

6.13.6.1 RELEASE the active ERO.

6.13. 7 ENSURE notification of emergency termination AND Recovery initiation is completed within 60 minutes:

6.13.7.1 COMPLETE EP SNF, SONGS Notification Form.

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

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

REFERENCE USE

EPP-1 Emergency Response REVISION 2 Page 22 of 28 6.13.7.4 CONTACT the following agencies within 60 minutes of emergency termination, AND ENSURE EP SNF, SONGS Notification Form, was received and understood:

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

6.13.7.4.2 RECORD the time each notification is completed:

AGENCY TIME State of California (Cal OES)

Orange County San Dieqo County Marine Corps Base Camp Pendleton 6.13.7.5 COMPLETE NRC Form 361, Reactor Plant Event Notification Worksheet.

6.13. 7 .6 CONTACT the NRC HOO immediately after notification of the appropriate State and local offsite agencies and Marine Corps Base Camp Pendleton.

6.13.7.7 PROVIDE the emergency termination AND Recovery initiation information on the completed NRC Form 361, Reactor Plant Event Notification Worksheet.

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

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

6.13.1 O DIRECT the Recovery Director to implement Recovery per Attachment 1.

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

6.13.12 PROVIDE TLD and electronic dosimeter to Radiation Protection personnel.

6.13.12.1 REVIEW documentation for completeness and accuracy.

6.13.12.2 PROVIDE documentation to the Emergency Preparedness Manager.

6.13.13 PARTICIPATE in post-event critiques/ reviews.

REFERENCE USE

EPP-1

~ Emergency Response REVISION 2

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

9.0 REFERENCES

/ COMMITMENTS 9.1 Implementing References 9.1.1 Procedures 9.1.1.1 ADM-3, Human Performance Program 9.1.1.2 SDS-RP1-PCD-1001, Radiological Surveys 9.1.1.3 SDS-RP1-PCD-1004, Survey and Release of Personnel 9.1.1.4 SDS-RP1-PCD-1005, Radiological Posting and Controls 9.1.1.5 SDS-RP1-PCD-3001, Material Release Surveys 9.1.1.6 ONO-1, Off-Normal Operations 9.1.2 Forms 9.1.2.1 EP CBA, Confinement Boundary Assessment 9.1.2.2 EP EEA, Emergency Exposure Authorization 9.1.2.3 EP ELB, ERO Logbook 9.1.2.4 EP ERO, Emergency Response Directory 9.1.2.5 EP SNF, SONGS Notification Form 9.1.2.6 EP SPA, Station Protective Action Notification 9.1.2. 7 NRC Form 361, Reactor Plant Event Notification Worksheet 9.1.2.8 SE 911, 911 Emergency Response INFORMATION USE

EPP-1 Emergency Response REVISION 2

. Page 24 of 28 9.2 Developmental References 9.2.1 Commitments 9.2.1.1 IOEP-1, SONGS ISFSI-Only Emergency Plan 9.2.1.2 IOEP-2, SONGS ISFSI-Only Emergency Plan EAL Technical Bases Manual 9.2.2 Procedures 9.2.2.1 EPP-2, Emergency Preparedness Program Maintenance 9.2.2.2 SDS-PM1-PLN-0008, SOS Site Communication and Reportability Plan 9.2.2.3 SDS-RP3-PCD-1001, Dosimetry Issue, Change Out, and Processing 9.2.2.4 SDS-RP3-PCD-1007, Dose Limit Extension 9.2.2.5 SDS-RP3-PCD-1014, Radiation Monitoring and Exposure Controls 9.2.2.6 SDS-RP3-PGM-1000, Site Radiological Access and Personnel Monitoring Program 9.2.2.7 SDS-RP4-PCD-1018, MGPI Electronic Dosimeters 9.2.3 Other 9.2.3.1 ANI Information Bulletin 11-01 (Rev. 1), February 18, 2021 INFORMATION USE

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ff::JEDISON SONGS.

Emergency Response EPP-1 REVISION 2 Page 25 of 28 Recovery I Attachment 1 NOTE

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

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

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

A planned approach for returning the ISFSI to a stable condition by obtaining the appropriate resources.

An evaluation of the radiation exposure records for all onsite emergency response personnel involved in the emergency.

Ensuring radiation exposures and contamination control meet ALARA requirements.

1.0 RECOVERY PLAN DEVELOPMENT (SONGS Manager, ISFSI Responsibility) 1.1 ASSIGN a Recovery Director.

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

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

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

1.2.3 CONDUCT interviews with ERO members.

REFERENCE USE Attachment 1 Page 1 of 3

EPP-1 REVISION 2

~ Emergency Response

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

Equipment to be repaired or replaced

Licensing implications

Special training requirements

Offsite support

Determination of causes AND consequences 1.4 DEVELOP a Recovery Plan outline (checklist and timeline) with the Recovery Director, based on topical areas:

Physical Security

Radiological conditions

Non-radiological hazards

Equipment repair/replacement

Regulatory requirements (e.g., notification and reporting requirements)

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

Senior Management status updates

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

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

REFERENCE USE Attachment 1 Page 2 of 3

~ !::::IH:ti9.~ EPP-1 fJ\~

~s Emergency Response REVISION 2 Page 27 of 28 Recovery Attachment 1 3.0 RECOVERY PLAN IMPLEMENTATION (SONGS Manager, ISFSI Responsibility) 3.1 DIRECT the Recovery Director to implement the Recovery Plan.

3.2 MONITOR the Recovery Plan implementation activities.

3.3 REVISE OR HALT activities as circumstances dictate.

3.4 REPORT status of Recovery Plan progress to SONGS co-participants and NRC, as requested.

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

REFERENCE USE Attachment 1 Page 3 of 3

EPP-1 Emergency Response REVISION 2 Page 28 of 28 Summary of Changes j Attachment 2 Author: Lucia Sischo/ Frank Grovich AR Tracking 50.54(q) :

-0121-93223 Reviewer(s) Step, Section, Reason Description of Change (by title or Attachment or division) Page 0121-65891 Added instructions for the ED to notify other organizations that may be providing onsite support of the termination of the 21 emergency and initiation of recovery operations.

0321-26355 Added step to direct injury response per SE 911 . 11 , 23 0721-33010 Added step for contaminated injuries. 11 0621-59239 Clarify instruction for training required for personnel brought in to All 15 assist.

0121-93223 Add ERP 104 to table 19 0721-53184 Add notification of ANI using EP ERO per ANI Information 8, 9, 24 Bulletin 11-01 Rev 1 0621-34262 Coordinate EPP-1 with SE 911 and ONO-1 17, 23 1121-82307 Clarify the Site Boundary. 7, 10, 14 Required Reviewers Name Emergency Plan 50.54(q) APPLIES Lucia Sischo Physical Security Plan 50.54(p) DNA Fire Protection 50.48(f) DNA 50.59 DNA 72.48 DNA Cyber Security DNA Nuclear Oversight DNA Procedure Owner or designee Lucia Sischo Other Reviewers Third Party 50.54(q) Reviewer Complete per L. Sischo Security Lucas Waldeck NRA Mark Morgan EP Manager Kelli Gallion-Sholler sos Donald Karstetter Approvers:

Cognizant Supervisor N/A for Revision CFDM / Designee Final Kelli Gallion-Sholler INFORMATION USE Attachment 2 Page 1 of 1

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~ .SONGS Emergency Preparedness Program Maintenance REVISION 2 Page 1 of 89 Procedure Usage Requirements Sections I

Reference Use

Review and understand the procedure before performing any Section 6.0 steps, including the prerequisite section. Attachments 1

Have a copy or applicable pages/sections open at the work site. through 17

Use Placekeeping method according to ADM-3.

If any portion of the document is performed from memory, do so in the sequence specified. Perform each step as written, except when an approved process specifically allows deviation.

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

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

NOT QA PROGRAM AFFECTING Procedure Type Procedure Owner Emergency Preparedness Kelli Gallion-Sholler

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 2 of 89 TABLE OF CONTENTS Section Page 1.0 PURPOSE AND SCOPE ...................................................................................................................3 2.0 RESPONSIBILITIES ..........................................................................................................................5 4.0 PRECAUTIONS AND LIMITATIONS ..............................................................................................15 5.0 PREREQUISITES ............................................................................................................................16 6.0 PROCEDURE ..................................................................................................................................17 6.1 IOEP Maintenance ............................................................................................................... 17 6.2 10 CFR 50.54(q) and 10 CFR 72.44(f) Screenings and Evaluations ................................... 24 6.3 Emergency Preparedness Training Program .......................................................................27 6.4 Drill and Exercise Program ...................................................................................................36 7.0 ACCEPTANCE CRITERIA ..............................................................................................................45 8.0 RETENTION OF RECORDS ...........................................................................................................45

9.0 REFERENCES

/ COMMITMENTS ..................................................................................................46 ATTACHMENTS 1 Emergency Equipment. ................................................................................................................... 50 2 IOEP-1, IOEP-2, and MOEE Review ............................................................................................. 53 3 Security Plan and Emergency Plan Coordination ........................................................................... 54 4 Annual EAL Review ........................................................................................................................ 55 5 Letters or Memoranda of Agreement Review ................................................................................. 56 6 Emergency Response Directory Review ......................................................................................... 58 7 IOEP-1 and MOEE Distribution Review .......................................................................................... 59 8 Matrix of Periodic Drill and Exercise Objectives Review ................................................................. 60 9 Emergency Equipment and Supplies Inspection ............................................................................. 61 10 Emergency Communications Quarterly Test ................................................................................. 62 11 Emergency Equipment - Compensatory ......................................................................................... 65 12 Hospital Supplies Inspection ........................................................................................................... 67 13 Completing EP QSC, 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening Form .............................. 68 14 Completing EP QEV, 10 CFR 50.54(q) Eval.uation Form ................................................................ 74 15 Planning Standard Functions List ................................................................................................... 81 16 Emergency Preparedness Program Review ................................................................................... 84 17 Alert Media Test ..... ~ ..........................................................................................'. ............................. 85 18 Emergency Preparedness Training Program Curriculum ............................................................... 86 19 Ownership of ERO Training Elements ............................................................................................ 87 20 Summary of Changes ..................................................................................................................... 88 INFORMATION USE

EPP-2 Emergency Preparedness Program Maintenance. REVISION 2

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~ - SONGS Page 3 of 89 1.0 PURPOSE AND SCOPE 1.1 IOEP Maintenance 1.1.1 To ensure the SONGS ISFSI-Only Emergency Plan (IOEP), consisting of the SONGS ISFSI-Only Emergency Plan (IOEP-1) and SONGS ISFSI-Only Emergency Plan Emergency Action Level Technical Bases Manual (IOEP-2), and the Emergency Plan Implementing Procedures (EPIPs) required by 10 CFR 50.47(b) and 10 CFR 50 Appendix E, as exempted, 10 CFR 72.32(c), and other Emergency Preparedness related documents, equipment and facilities, are maintained current.

1.1.2 To provide guidance for maintenance and control of the following:

IOEP-1

IOEP-2

EPIPs (Appendix B of IOEP-1)

Manual of-Emergency Events (MOEE)

Letters and Memoranda of Agreement (Appendix C of IOEP-1)

Emergency Response Organization (ERO) Roster Review

IOEP and MOEE Distribution Lists

Matrix of Periodic Drill and Exercises Objectives 1.1.3 To ensure equipment used for emergency classification and response is properly maintained in a state of readiness. Equipment whose surveillance or testing is covered by Technical Specifications or Licensee Controlled Specifications is outside the scope of this program.

1.1.4 To define the responsibilities for surveillance and maintenance of emergency equipment and the reporting of emergency equipment status.

1.1.5 To provide the process for identifying emergency equipment, communicating equipment issues, using appropriate compensatory measures, and applying an appropriate priority to the restoration of the equipment or facilities.

1.1.6 To test emergency communications with Federal, State, and local government agencies and to test communications equipment in the Emergency Response Facility (ERF) in accordance with 10 CFR 50, Appendix E, Section IV.E.9.a-d, as exempted.

1.1.7 To identify, report and track communications equipment malfunctions.

1.1.8 To ensure the requirements of 10 CFR 50.54(t) for independent review of the SONGS ISFSI emergency preparedness program are met.

INFORMATION USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 4 of 89 1.2 10 CFR 50.54(q) and 10 CFR 72.44(f) Screenings and Evaluations 1.2.1 To perform 10 CFR 50.54(q) and 10 CFR 72.44(f) screenings and evaluations.

1.2.2 To ensure changes to the IOEP, consisting of IOEP-1 and IOEP-2, and EPIPs (listed on Appendix B of IOEP-1) required by 10 CFR 50.47(b) and 10 CFR 50 Appendix E, as exempted, 10 CFR 72.32(c), and the equipment and facilities described in those documents, are maintained in accordance with 10 CFR 50.54(q) and 10 CFR 72.44(f) to prevent a reduction in the effectiveness of the Emergency Plan.

1.2.3 This procedure section is developed in accordance with Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors.

Since no guidance exists for 10 CFR 72.44(f) and in accordance with 10 CFR 72.32(c),

this procedure section shall be used to evaluate changes to the IOEP.

1.3 ERO Training 1.3.1 To describe the SONGS Emergency Preparedness Training Program, which implements the requirements contained in IOEP-1.

1.3.2 The Emergency Preparedness Training Program is designed to train Emergency Response Organization (ERO) personnel to perform emergency response duties as described in initial and continuing training. The initial training program ensures personnel have the required knowledge and skills to perform the duties as emergency responders.

Continuing training ensures the incumbents maintain and improve job performance through development of job-related knowledge and skills.

1.3.3 ADM-30 and SDS-TN1-PGM-0001 identify the level and depth to which individuals are to be trained.

1.4 Drills and Exercises 1.4.1 To describe the SONGS Emergency Preparedness Drill and Exercise Program which implements the requirements contained in IOEP-1.

1.4.2 The Emergency Preparedness Drill and Exercise Program is designed to:

Provide guidelines for development, conduct, evaluation, and records maintenance of IOEP drills and exercises.

Establish a system for identifying deficiencies and weaknesses identified during a drill or exercise.

Provide guidelines for evaluation and records maintenance of actual declared emergencies.

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1. Some IOEP equipment program elements are administered by other personnel with Emergency Preparedness Manager (EPM) oversight.

2. SONGS Decommissioning Solutions (SOS), as the decommissioning general contractor for SONGS, is responsible for supporting the planning and implementation of emergency preparedness at SONGS.

2.1 SONGS Manager, ISFSI:

2.1.1 Southern California Edison (SCE) is responsible for the maintenance of SONGS Emergency Preparedness Program. The issuance and control of the ISFSI-Only Emergency Plan and the activities associated with Emergency Preparedness at SONGS are the overall responsibility of the Manager, ISFSI.

2.1.2 Reviewing and approving changes other than editorial for the IOEP.

INFORMATION USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 6 of 89 2.2 Emergency Preparedness Manager:

2.2.1 Maintaining and updating the IOEP and associated procedures, and documenting reviews and revisions.

2.2.2 Coordinating the IOEP with other station programs and procedures.

2.2.3 Overseeing the EMERGENCY PREPAREDNESS Training Program and ensuring that proper records are maintained to document training of the ERO.

2.2.4 Overseeing and documenting the EMERGENCY PREPAREDNESS Drill and Exercise Program.

2.2.5 Documenting and maintaining the EMERGENCY PREPAREDNESS Facilities and Equipment.

2.2.6 Documenting and maintaining the EMERGENCY PREPAREDNESS interfaces with OFFSITE agencies.

2.2.7 Performing and documenting appropriate evaluations of the EMERGENCY PREPAREDNESS Program and of declared emergency events.

2.2.8 Ensuring that the ERO is notified of updates to the IOEP or EPIPs.

2.2.9 Ensuring that the OFFSITE Response Organizations are notified of updates to the IOEP.

2.2.10 Ensuring that all the Letters and Memoranda of Agreement with support organizations are reviewed ANNUALLY and updated as needed.

2.2.11 Maintaining current knowledge of changes in Federal regulations and other guidance that impact emergency planning activities.

2.2.12 Submitting IOEP and related controlled document revisions to the NRC.

2.2.13 Ensuring that an independent review of the EMERGENCY PREPAREDNESS Program is conducted to meet the requirements of 10 CFR 50.54(t).

2.3 Cognizant Divisions:

2.3.1 Scheduling, inspecting, and maintaining emergency equipment contained under their area of responsibility in accordance with associated procedures and SONGS Preventive Maintenance Program.

2.3.2 Notifying the ISFSI Shift Supervisor (ISS) when maintenance and inspection activities reveal problems resulting in emergency equipment being out of service for other than planned maintenance.

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~ :*i~L- Emergency Preparedness Program Maintenance REVISION 2 Page 7 of 89 2.3.3 Personnel Who Prepare and Review 10 CFR 50.54(q) and 10 CFR 72.44(f) Screens or Evaluations:

Ensuring qualification IOEPQM to perform the task is current.

Ensuring all questions and conclusions are answered accurately and completely with sufficient detail for a technically competent individual to understand the rationale supporting the answer.

Requesting assistance by a subject matter expert via the EPM if the scope of 10 CFR 50.54(q) and 10 CFR 72.44(f) screening or evaluation extends beyond his/her expertise.

2.3.4 Technical Reviewers:

Performing technical review of 10 CFR 50.54(q) and 10 CFR 72.44(f) documentation associated with IOEP and EPIP revisions.

2.3.5 Monitoring ERO performance and conducting remediation to correct unsatisfactory performance.

2.3.6 Administration of Emergency Preparedness-related training, including identifying, developing, maintaining and revising training materials.

2.3.7 Ensuring ERO training requirements are met.

2.3.8 Ensuring required station support is identified and provided for the development and conduct of drills and exercises.

2.4 ISFSI Shift Supervisor 2.4.1 Ensuring appropriate actions, including identification, tracking, and compensatory measures, are taken when emergency equipment or facilities are degraded or removed from service.

2.4.2 Maintaining the ERF in a state of readiness.

2.4.3 Ensuring pre-staged copies of EP-related documents in the ERF are current.

2.5 ISFSI Engineering Manager:

2.5.1 Determining emergency equipment and system availability when emergency equipment problems are identified.

2.5.2 Ensuring a design change process identifies any impacts to IOEP commitments and emergency response capabilities.

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~ - SONGS 2.6 Regulatory Affairs:

2.6.1 Providing guidance on compliance with the station licensing basis and related reportability issues.

2.6.2 10 CFR 50.54(q) and 10 CFR 72.44(f) Screenings and Evaluations 2.6.3 Performing compliance reviews of 10 CFR 50.54(q) and 10 CFR 72.44(f) documentation associated with IOEP changes.

2. 7 ** Maintenance:

2.7.1 Ensuring work on emergency response equipment within the scope of the station work control program is appropriately prioritized and scheduled.

2.8 SONGS Decommissioning Solutions (SDS) 2.8.1 SOS will perform Emergency Preparedness functions and support per SOS-EP1-PLN-0001, including but not limited to the following:

2.8.1.1 Maintaining emergency communications services and/or equipment under their area of responsibility, in order to provide a means to ensure notification of protective actions for onsite personnel.

2.8.1.2 Notifying the ISFSI Shift Supervisor (ISS) when emergency communications equipment is out of service for other than planned maintenance.

2.8.1.3 Replenish RP equipment and supplies for the ISFSI Emergency Kit as requested.

2.8.1.4 For an emergency involving radiological consequences (E-HU1), ensuring a minimum of one person, trained in radiological monitoring and assessment, reports to the SONGS ISFSI within four hours of the emergency declaration.

2.8.1.5 Providing RP Emergency Preparedness-related support for the ISFSI.

2.8.1.6 Reporting any condition to the ISS that might require entry into the ISFSI Only Emergency Plan.

2.8.1.7 Ensuring changes to the emergency communications services and/or equipment are assessed for impacts to IOEP commitments and emergency response capabilities.

2.8.1.8 Administrating RP Emergency Preparedness-related training, including identifying, developing, maintaining and revising training materials.

2.8.1.9 Entering Identified deficiencies into SOS CAP for correction.

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~~ SONGS Page 9 of.89 2.8.1.10 Ensuring SOS General Employee Training and Visitor Information contain information on the actions to be taken if an emergency is declared at the SONGS ISFSI.

2.8.1.11 Ensuring SOS General Employee Training and Visitor Information contain information to ensure events such as fires, hazmat spills, injuries or medical emergencies are reported to the ISFSI Shift Supervisor.

2.9 SONGS Emergency Response Personnel:

2.9.1 SONGS Emergency Response Personnel shall meet the criteria set forth in the IOEP, EPIPs and other applicable approved procedures and instructions.

2.9.2 Personnel with assigned Emergency Response Personnel (ERP) qualification codes shall:

2.9.2.1 Receive documented training regarding their specific responsibilities and duties during a declared emergency at the SONGS ISFSI.

2.9.2.2 Maintain SONGS ERO qualifications and Protected Area access.

2.9.2.3 Review the posted drill / training schedule to ensure participation when assigned.

2.9.2.4 Read all Emergency Preparedness Bulletins that are distributed.

2.9.2.5 Maintain contact and call-out information up-to-date.

2.9.2.6 Be available and prepared to provide relief support to the initial SONGS ERO responders in the event of an actual emergency or drill.

2.9.2.7 Notify the EPM of planned employment termination.

2.9.3 When on duty for an ERO position:

2.9.3.1 Ensure no concurrent assignment to another on-duty SONGS ERO position or on-shift SONGS ERO position.

2.9.3.2 Be prepared to establish contact, ready to perform SONGS ERO responsibilities within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of emergency declaration.

2.9.3.3 Be prepared with Southern California Edison (SCE) identification (i.e., security photo ID badge), second identification, proper work attire, and PPE.

2.9.3.4 Remain fit for duty during the entire period of time on-duty.

(Reference SCE-HR-EECONDUCT-PL-303).

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. Page 10 of 89 2.9.3.5 Ensure home arrangements (e.g., childcare, transportation availability, etc.) are made in advance in preparation for being called-in in response to an emergency or drill.

2.9.3.6 Ensure access to a well-maintained vehicle with sufficient fuel.

2.9.3.7 IF unable to fulfill on-duty responsibilities, THEN arrange for duty coverage by another fully qualified individual in the same SONGS ERO position and inform the ISS to update required documents (e.g., ISS Turnover).

2.9.3.8 Maintain Duty Week coverage from 0700 hours0.0081 days 0.194 hours 0.00116 weeks 2.6635e-4 months on the first Monday of the Duty Week to 0700 hours0.0081 days 0.194 hours 0.00116 weeks 2.6635e-4 months the following Monday.

3.0 DEFINITIONS Activity A series of events or actions that may result in a change to the IOEP or affect the implementation of the IOEP. The following items are applicable in determining what an activity is as defined here:

An activity sets in motion the need to determine impact on certain licensing bases documents using regulatory review criteria such as 10 CFR 50.54(q) and 10 CFR 72.44(f).

Activities may range from something as simple as making an editorial change or an organizational change, to making complicated facility modifications.

For the purposes of 10 CFR 50.54(q) and 10 CFR 72.44(f), activities may also originate outside of the licensee's responsibility such as permanent hospital closings or changes to local agencies.

Capability The capacity to implement the response actions or fulfill the administrative provisions identified in the IOEP. Capability is typically described by the following:

Methods: The procedural means or manner of implementing the response actions or fulfilling the administrative provisions identified in the IOEP.

Resources: The personnel, procedures, equipment, communications, instrumentation, analytical equipment, transportation, supplies, and other items needed to implement the response actions or fulfill the administrative provisions identified in the IOEP.

State or Condition: The material means of implementing the response actions or fulfilling the administrative provisions identified in the IOEP; such as operative, physical, or spatial.

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~ SONGS Page 11 of 89 3.0 DEFINITIONS Change An action that results in modification of, addition to, or removal from, the licensee's IOEP. Types of changes include:

Editorial and typographical changes such as formatting, paragr.aph numbering, spelling, or punctuation that does not change intent.

Conforming changes are those changes that are made based on previous regulatory approved changes (for example, DSAR or Tech.

Spec. equipment changes, EAL scheme changes, etc.).

Interdependent changes involve two or more activities that collectively affect a function (these are typically where one change compensates for another change).

Technical changes .

Commitment A general term used to describe a regulatory commitment, management directive, or other obligation of the licensee.

A regulatory commitment is an explicit statement to take a specific action agreed to or volunteered by a licensee and submitted in writing on the docket to the NRC. A regulatory commitment is an intentional undertaking by a licensee to restore compliance with regulatory requirements or complete a specific action to address an NRC issue or concern (e.g., generic letter, bulletin, order, RAI responses, etc.).

A management commitment is a restriction or recurring action established by facility management that is neither required by regulation nor a regulatory commitment, but has importance or safety significance (e.g., independent technical review, courtesy notifications, maintenance of equipment no longer required per the IOEP).

An obligation is any condition or action that is a legally binding requirement imposed on licensees through applicable rules, regulations, orders, and licenses (including technical specifications and license conditions).

Compensatory A temporary means of mitigating the degradation or loss of an emergency Measure response function, or of maintaining the emergency response function until the emergency equipment is restored to a fully functional condition.

Controller An individual assigned to present information or data within the conduct of the drill.

Deficiencies Items that identify the EP program or procedures do not conform to the provisions of applicable federal regulations.

Demonstration A list of attributes that, if performed correctly, define completion of a Criteria performance objective. Failure to satisfactorily demonstrate a demonstration criterion does not necessarily meah failure of a performance objective, unless specifically noted.

Drill A controlled scenario event conducted to provide training and practice for the participants. Drills may also include evaluated objectives and demonstration criteria as part of meeting periodic performance objective requirements as pre-designated by the scenario.

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EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 12 of 89 3.0 DEFINITIONS Emergency Plan The document(s) prepared and maintained by the licensee that identify and describe the elements for maintaining emergency preparedness and responding to emergencies.

The Emergency Plan includes the IOEP (IOEP-1 and IOEP-2) that the NRC originally approved and all subsequent changes made by the licensee with, and without, prior NRC review and approval under 10 CFR 50.54(q) and 10 CFR 72.44(f).

The Emergency Plan includes any document that describes the programmatic methods that the licensee uses to maintain emergency preparedness and to respond to emergencies. Programmatic methods are equivalent to program elements.

Emergency Systems, structures, and components, as well as essential tools and Response equipment, necessary to implement the IOEP.

Equipment Emergency The security center of the station from which the ISFSI can be monitored.

Response Facility The facility containing the communication equipment necessary for both (ERF) normal and emergency conditions. It is operated under the direction of the ISS/ED and serves as the primary location for event classification, emergency declaration and notifications to offsite agencies, assessment activities, and corrective action direction.

Emergency Organization of personnel who may be called upon during an emergency Response to perform duties to mitigate accident conditions at SONGS.

Organization (ERO)

Emergency Personnel who may be called upon during an emergency to perform duties Response to mitigate accident conditions at SONGS.

Personnel (ERP)

Evaluation An individual who judges the performance of the participants, as well as (Drill/Exercise) the adequacy of the Radiological Emergency Plan, procedures, facilities, and equipment, against designated objectives and demonstration criteria.

Evaluator (Training) An Individual who observes and assesses the trainee's performance during the qualification process. An Evaluator is someone qualified in the ERO position or a Subject Matter Expert in the specific task(s) being evaluated.

Exercise An event that evaluates the integrated capability and a major portion of the basic elements against designated objectives and demonstration criteria.

An exercise may involve participation of personnel from Federal, State, and local government agencies.

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=-- SONGS Page 13 of 89 3.0 DEFINITIONS Frequency The following frequencies are used:

Quarterly (Q) - Frequency of occurrence is met if performed within 1.25 times a 92-day interval as measured from the previous performance.

Semi-Annual (S) - Twice per calendar year (1st: Jan 1 - Jun 30; and 2nd: Jul 1 - Dec 31).

Annual (1Y) - Frequency of occurrence is met if performed within 1.25 times a 12-month interval as measured from the previous performance. This definition does not apply to the term "annual" when it relates to the conduct of the Emergency Preparedness drills which are performed within the calendar year.

Biennial (2Y) - Occurring every two calendar years .

Cyclic (6Y) - Occurring every six calendar years .

Integrated Drill A drill that incorporates multiple demonstration requirements to be conducted in connection with one another.

Local Government Orange County and San Diego County.

Agencies Other Issues Items not quality affecting or of regulatory concern. These are items noted for trending purposes and actions intended to improve the emergency preparedness program.

Planning Standard A capability or resource necessary to prepare for and respond to a Function radiological emergency, as set forth in 10 CFR 50.47(b) and 10 CFR 50 Appendix E Section IV, as exempted, which meets the requirements of 10 CFR 72.32(c).

Planning Standards The 16 standards identified in 10 CFR 50.47(b), as exempted, that (PS) Emergency Plans are required to meet in order for the NRC to make their reasonable assurance determination for public health and safety.

Program Element An item that comprises the implementation aspects of an emergency planning function. These items correspond to the evaluation criteria in NSIR-DPR-ISG-02 (or other alternative methods, and approved exemptions, for which the licensee obtained approval) that identify specific acceptable methods for complying with an emergency planning function.

Protected Area (PA) That onsite area within the ISFSI security boundary as defined in SONGS' Security Plan.

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EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 14 of 89 3.0 DEFINITIONS Reduction in A change to the Emergency Plan that results in reducing the licensee's Effectiveness (RIE) capability to perform an emergency planning function in the event of an emergency.

RIE is an evaluation concept that is used with 10 CFR 50.54(q) and 10 CFR 72.44(f) to differentiate between changes that a licensee is allowed to make without prior NRC approval and those that require prior NRC approval.

RIE is evaluated against capability and timeliness of affected planning standard functions, program elements, and commitments.

Regulatory Any emergency preparedness related requirement, including the planning Requirement standards in 10 CFR 50.47(b) and 10 CFR 50 Appendix E, as exempted, 10 CFR 72.32(c), 10 CFR 50.54(q), 10 CFR 50.54(t), and 10 CFR 72.44(f) commitments made in the Emergency Plan, commission orders, and commitments made with regard to compensatory actions under 10 CFR 50.47(c) or 10 CFR 50.54(s)(2)(ii).

Risk-Significant A subset of the PS, identified by the NRC to provide Reactor Oversight Planning Standards Process (ROP) focus on planning standards that have the greatest impact (RSPS) on the ability to protect the health and safety of the public and the workers which includes the following four PS: 10 CFR 50.47(b)(4) - emergency classification system, (b)(5) - emergency notifications, (b)(9) _.:.

emergency assessment capability, or (b)(10) - emergency protective actions, as exempted, and supported by the corresponding Sections of Appendix E to 10 CFR Part 50, as exempted. Note that parts of 10 CFR 50.47(b)(10) are treated as not risk significant. Also note that ROP metrics described in NEI 99-02 and significance determination described in IMC0609 App. B, for the purpose of NRC inspection do not apply to ISFSI Only facilities.

Scenario Manual A manual that provides generic information that relates to the scenario and specific information relating to control and evaluation of scenario activities.

SONGS ERO A subset of the broader ERO described in IOEP-1 Part-II, Section 2.0.

Those ERO positions that are on-shift or augmented, filled by SONGS personnel, i.e., ISS/ED and Resource Manager (RM).

Subject Matter A person who has attained a level of expertise by education, experience,

Expert or plant/vendor task qualification.

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EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 15 of 89 3.0 DEFINITIONS Timeliness The capability to complete an activity within a specified timeframe.

Timeliness depends on several factors, including the availability of adequate qualified personnel to perform the activity; the number of multiple duties assigned to these personnel; augmentation time by off-shift personnel; and sufficient procedures, tools, instrumentation, equipment, and other material necessary to complete the activity.

Timeliness includes any change that modifies how the timeliness criterion is evaluated (e.g., "when the clock starts and stops").

SONGS ISFSI Management expects SONGS will resolve a weakness identified during an exercise, drill or training in a timely manner consistent with its risk significance. An RS PS-related weakness is typically corrected within 90 days of identification. A PS-related weakness is typically corrected within 180 days of identification.

SONGS ISFSI Management expects equipment that is used for RSPS and that does not have a compensatory measure is returned to service within seven days.

Weaknesses Items of documented performance during an exercise, drill or training that could have precluded effective implementation of the Emergency Plan in the event of an actual emergency.

4.0 PRECAUTIONS AND LIMITATIONS 4.1 Precautions 4.1.1 IOEP Maintenance

The IOEP is designed as a last line of defense to address emergencies at an ISFSI including the capability of protecting public health and safety during and following the event. Therefore, regulations that govern emergency equipment may require more timely restoration than technical specifications or other administrative controls.

Emergency equipment must be capable of functioning at all times. IF there is a loss of function, THEN compensatory measures must be evaluated and used to restore the function until the emergency equipment is repaired.

A loss of function of the IOEP requires a determination regarding reportability in accordance with SEC-15 (10 CFR 50.72).

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EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 16 of 89 4.1.2 Drills and Exercises

Security, Radiological Protection and Safety procedures shall remain in effect during drills and exercises.

Drill or exercise activities shall be suspended in the event of an actual emergency.

Electronic communications of information related to the drill or exercise with offsite agencies should be identified as drill or exercise information by beginning and ending them with the statement, "This is a drill." This statement should also be repeated periodically on communication lines (telephone, radio) that are kept open for extended periods or could be monitored or overheard by nonparticipants.

4.1.3 10 CFR 50.54(q) and 10 CFR 72.44(f) Screenings and Evaluations

In order to properly evaluate a proposed change to the IOEP, licensees need to understand the basis for the NRC's approval of the original plan and the basis for any subsequent change, whether it has been approved by the NRC or implemented by the licensee under 10 CFR 50.54(q) and 10 CFR 72.44(f).

4.2 Limitations 4.2.1 IOEP Maintenance

None 4.2.2 ERO Training

None 4.2.3 Drills and Exercises

None 4.2.4 10 CFR 50.54(q) and 10 CFR 72.44(f) Screenings and Evaluations

10 CFR 50.54(q) and 10 CFR 72.44(f) requires licensees that are authorized to possess and operate an ISFSI under a 10 CFR Part 50 general license to follow and maintain the effectiveness of an Emergency Plan that meets the standards in 10 CFR 50.47(b) and the requirements in Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR 50, "Domestic Licensing of Production and Utilization Facilities, as exempted."

5.0 PREREQUISITES 5.1 VERIFY this document is current by using one of the methods described in ADM-3.

5.2 VERIFY Level of Use 'requirements on the first page of this procedure.

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SONGS Emergency Preparedness Program Maintenance REFERENCE USE EPP-2 REVISION 2 Page 17 of 89 NOTE Steps in this procedure may be performed in any order as long as the intent is NOT changed.

6.0 PROCEDURE 6.1 IOEP Maintenance 6.1.1 IOEP and EPIP Revisions 6.1.1.1 REVISE IOEP-1, IOEP-2, or EPIPs (Appendix B of IOEP-1) in accordance with station procedure revision requirements (refer to ADM-10).

6.1.1.2 Prior to issuing IOEP-1, IOEP-2, or EPIPs, ENSURE:

10 CFR 50.54(q) and 10 CFR 72.44(f) screen/evaluation has been performed, and the results indicate that the changes can be made without prior NRC approval, OR

Prior approval from the NRC to make the changes has been received.

6.1.1.3 lE changes other than editorial will be made to IOEP-1 and IOEP-2, THEN OBTAIN the required additional review and approval:

Technical review

ISFSI-Only Security Plan Review

Third party review of 10 CFR 50.54(q) and 10 CFR 72.44(f)

Screening/Evaluation

Nuclear Regulatory Affairs (NRA) compliance review

SONGS Manager, ISFSI review and approval 6.1.1.4 Validate changes to IOEP-2 EALs to ENSURE the EALs can be implemented in a timely manner.

6.1.1.5 DISTRIBUTE IOEP-1, IOEP-2, and EPIPs to locations responsible for IOEP implementation on a controlled basis in accordance with the distribution list.

6.1.1.6 COMMUNICATE changes to IOEP-1, IOEP-2, and EPIPs to ERO personnel.

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~ - SONGS Page 18 of 89 6.1.1.7 WHEN IOEP-1 OR IOEP-2 are issued, OR EPIPs are issued for changes requiring a full 10 CFR 50.54(q)/10 CFR 72.44(f) evaluation, THEN within 15 days of issuance, INITIATE an Action Request Assignment to NRA for the 30-day and six-month NRC reporting requirements. [Reference 10 CFR 50.54(q)(5) and 10 CFR 72.44(f)].

COMPLETE EP SOA, for changes requiring a report to the NRC and forward to NRA.

6.1.1.8 NOTIFY offsite response organizations of updates to the IOEP.

6.1.2 Lower-tiered Document Revisions 6.1.2.1 REVISE lower-tiered documents NOT listed in Appendix B of IOEP-1 in accordance with station procedure revision requirements (refer to ADM-10).

6.1.2.2 REVIEW technical changes to EP SNF with Cal OES, Orange County, San Diego County and Marine Corps Base Camp Pendleton (MCBCP).

Document review and concurrence in conjunction with the changes using CAP (refer to ADM-5).

6.1.2.3 IF an Emergency Plan requirement is removed from the IOEP AND relocated to a lower tiered document, THEN the lower tiered document must be reviewed in accordance with 10 CFR 50.54(q) and 10 CFR 72.44(f). In this case, the lower tiered document now contains the Emergency Plan license requirement AND should be listed in Appendix B of IOEP-1.

6.1.2.4 Communicate changes to Emergency Preparedness documents to affected ERO personnel.

6.1.2.5 ENSURE the ISS updates the ERO Notebooks with changes to Emergency Preparedness documents that are pre-staged for an emergency, to satisfy the requirements of ADM-3 for verifying documents are current.

6.1.3 Review of Emergency Preparedness Documents 6.1.3.1 The EPM or designee shall REVIEW IOEP-1 annually to identify changes to be incorporated in the next revision.

Document the review on Attachment 2.

6.1.3.2 The EPM or designee shall REVIEW IOEP-2, and the MOEE annually to identify changes to be incorporated in the next rrvision.

Document the review on Attachment 2.

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~ SONGS Page 19 of 89 6.1.3.3 The EPM or designee shall REVIEW IOEP requirements relative to the ISFSI-Only Security Plan requirements annually.

Document the review on Attachment 3.

6.1.3.4 The EPM or designee shall REVIEW the EALs with the State and local government agencies and MCBCP annually.

Document the review on Attachment 4.

6.1.3.5 The EPM or designee shall be responsible for agreements involving firefighting, rescue, transport of injured person, medical treatment, and law enforcement (per the SONGS Security Plan), including REVIEW of documents annually to ENSURE documents are current.

REVIEW Action Requests in order to identify any that directly affect the content of the Agreements.

Action Requests that directly affect the content of the Agreements should be shared with the affected agency during the annual review of the Agreement and documented on Attachment 5.

Document the review on Attachment 5.

6.1.3.6 The EPM or designee shall REVIEW Emergency Response Directory quarterly to ENSURE information for ERO (names and numbers), support personnel and applicable offsite organizations is maintained current.

Document the review on Attachment 6.

6.1.3.7 The EPM or designee shall REVIEW distribution lists for IOEP-1 and the MOEE annually to VERIFY distribution information is maintained current.

Document the review on Attachment 7.

6.1.3.8 The EPM or designee shall REVIEW EP PDE against accomplished objectives frequently enough to ENSURE all required objectives have been accomplished or scheduled within their periodicity (recommend review completed by second quarter).

Document the review on Attachment 8.

6.1.3.9 The EPM or designee shall COMPLETE EP PDE during the fourth quarter.

Document the completion on Attachment 8.

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EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 20 of 89 6.1.4 Emergency Equipment Inspections 6.1.4.1 The ISS or designee shall PERFORM inventory of the items in EP EKIL quarterly, or within 7 days after each use, and forward a copy of the inventory to Emergency Preparedness.

Document the inventory on Attachment 9.

6.1.4.2 The EPM or designee shall PERFORM an inventory of supplies maintained at hospitals annually, or within 7 days after each use.

Document the inventory on EP HIL.

Document the completion of the inventory on Attachment 12.

6.1.5 Emergency Communication Tests 6.1.5.1 The ISS or designee shall PERFORM communications test of Emergency Response Facility Emergency Kit portable radios, cellular phones and satellite phones quarterly.

Document the test on Attachment 10.

6.1.6 Alert Media 6.1.6.1 The ISS or designee shall PERFORM a test of Alert Media quarterly.

Document the test on Attachment 17.

6.1.7 Identifying Emergency Equipment 6.1.7.1 Emergency equipment may be identified by checking the list contained in Attachment 1.

6.1.7.2 Personnel discovering emergency equipment NOT listed in Attachment 1 should INITIATE appropriate deficiency tracking documents (e.g., Trouble Ticket, IT request, Action Request, Condition Report).

6.1.8 Discovery of Degraded or Nonfunctional Emergency Equipment 6.1.8.1 Personnel discovering problems with emergency equipment should:

INITIATE appropriate deficiency tracking documents (e.g., Trouble Ticket, IT request, Action Request, Condition Report).

NOTIFY the ISS.

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EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 21 of 89 6.1.8.2 WHEN notified of nonfunctional or degraded emergency equipment, THEN the ISS shall IDENTIFY compensatory measures by referring to Attachment 1.

6.1.8.3 VERIFY compensatory measures are available:

IMPLEMENT compensatory measures (if action is required) immediately following emergency equipment loss or facility functional failure.

6.1.8.4 IF compensatory measures are NOT available, OR Attachment 1 only states repair or replacement, THEN:

The ISS shall COMPLETE Attachment 11 to identify and evaluate the appropriate use of interim compensatory measures.

The ISS may COORDINATE with the EPM or other subject matter experts when developing and approving interim compensatory measures in Attachment 11.

IF an appropriate reviewer is NOT available, THEN the ISS may sign Attachment 11 as the reviewer.

6.1.8.5 The ISS shall NOTIFY the EPM of the nonfunctional or degraded emergency equipment and compensatory measures used.

6.1.8.6 The ISS shall PRIORITIZE emergency equipment restoration in a timely manner.

6.1.8.7 The ISS shall ADD nonfunctional or degraded emergency equipment that require compensatory actions to the ISS shift turnover process, along with compensatory measures being used.

6.1.9 Planned Maintenance Affecting Emergency Equipment NOTE Personnel identifying emergency equipment that will be degraded or rendered nonfunctional as the result of planned maintenance should coordinate with the ISS to identify compensatory measures.

6.1.9.1 lE notified by personnel of emergency equipment that will be degraded OR rendered nonfunctional as the result of planned maintenance, THEN the ISS shall:

VERIFY compensatory measures listed in Attachment 1 are available.

ENSURE compensatory measures are established prior to starting work.

REFERENCE USE

EPP-2 REVISION 2 Emergency Preparedness Program Maintenance Page 22 of 89 6.1.9.2 IF compensatory measures are NOT available, OR Attachment 1 only states repair or replacement, THEN:

The ISS may permit emergency equipment to be removed from service for maintenance or surveillance testing IF:

Personnel removing the emergency equipment from service remain in the immediate area AND

The emergency equipment can be restored to service immediately when notified by the ISS or designee.

6.1.9.3 !Ethe conditions of Step 6.1.9.2 CANNOT be met, THEN the ISS may implement interim compensatory measures according to Attachment 11.

COMPLETE Attachment 11.

ENSURE interim compensatory measures from Attachment 11 are established prior to starting work.

6.1.9.4 The ISS shall NOTIFY the EPM of the nonfunctional or degraded IOEP equipment and associated compensatory measures being implemented.

6.1.9.5 The ISS shall ADD nonfunctional or degraded emergency equipment that require compensatory actions to the ISS shift turnover process along with compensatory measures being implemented.

6.1.10 Restoration of Emergency Equipment 6.1.10.1 Emergency equipment and facilities should be returned to service with a priority commensurate with the significance of the associated emergency response function.

6.1.10.2 Personnel should NOTIFY the ISS of any work on emergency equipment that is over-schedule or at risk.

The ISS shall NOTIFY the EPM.

6.1.10.3 The individual(s) completing the work should NOTIFY the ISS when work is complete AND the emergency equipment is returned to service.

The ISS shall NOTIFY the EPM.

The ISS shall REMOVE the emergency equipment and compensatory measures from the ISS shift turnover documentation.

REFERENCE USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 23 of 89

6. 1.11 Emergency Preparedness Program Review 6.1.11.1 To meet the requirements of 10 CFR 50.54(t), SONGS coordinates an independent review of the emergency preparedness program to examine conformance with applicable portions of 10 CFR 50.47, 10 CFR 50.54, 10 CFR 72.32, 10 CFR 72.44, and 10 CFR 50 Appendix E. Included in the review are the following:

The IOEP and associated Implementing Procedures.

The emergency preparedness training including drills and exercises as well as any activation of the IOEP since the last program review.

The readiness of the station Emergency Response Organization to perform its function.

The readiness of the Emergency Response Facility and equipment to perform as outlined in the IOEP and Implementing Procedures.

The interfaces between SONGS and local agencies pertaining to the overall emergency preparedness program.

6.1.11.2 The EPM or designee shall ENSURE a review is conducted within 12 months of the prior review, and with the proper scope to meet the requirements of 10 CFR 50.54(t)

Document the completion of the review on Attachment 16.

REFERENCE USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 24 of 89 6.2 10 CFR 50.54(g) and 10 CFR 72.44(0 Screenings and Evaluations 6.2.1 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening NOTE The purpose of the 10 CFR 50.54(q) and 10 CFR 72.44(f) screening is to determine whether a 10 CFR 50.54(q) and 10 CFR 72.44(f) evaluation is required, not to determine if an activity reduces the effectiveness of the emergency preparedness program.

6.2.1.1 PERFORM a 10 CFR 50.54(q) and 10 CFR 72.44(f) screening for any activity that may impact the emergency preparedness program to determine and document whether 10 CFR 50.54(q) and 10 CFR 72.44(f) Evaluation is needed.

6.2.1.1.1 COMPLETE 10 CFR 50.54(q) and 10 CFR 72.44(f) screening on EP QSC, 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening Form, using the guidelines in Attachment 13.

A 10 CFR 50.54(q) and 10 CFR 72.44(f) screening may be skipped for activities that will be taken directly to a 10 CFR 50.54(q) and 10 CFR 72.44(f) evaluation.

Multiple activities may be considered on a single screening so long as all proposed activities are identified and screened.

An activity may involve a specific change that results in an impact to a single item or it may involve a much broader change to an area of the emergency preparedness program.

6.2.1.1.2 Screen each activity separately unless it involves any of the following:

Editorial or typographical changes such as formatting, paragraph numbering, spelling, grammar, punctuation, or title changes that do NOT change the intent.

Conforming changes (e.g., activities that implement a change associated with regulation, order, or NRC approved license amendments that specifically address the impact on the SONGS emergency preparedness program).

Repetitive identical changes such as a single activity that changes several sections of the IOEP or EPIPs.

Two or more changes that are interdependent (e.g., an activity where one change compensates for another change, such as changes to the ERO staffing, changing equipment used for multiple functions, major program changes in a particular area, etc.).

REFERENCE USE

~ - SONGS Emergency Preparedness Program Maintenance EPP-2 REVISION 2 Page 25 of 89 6.2.1.1.3 IF the activity is subject to one or more change processes outside of 10 CFR 50.54(q) and 10 CFR 72.44(f) [such as 10 CFR 50.59, 10 CFR 50.90, 10 CFR 50.54(a) or 10 CFR 50.54(p)], THEN comply with the other applicable change processes.

6.2.2 10 CFR 50.54(q) and 10 CFR 72.44(f) Evaluation NOTES

1. The NRC expects 10 CFR 50.54(q) and 10 CFR 72.44(f) evaluations to be of a level of rigor and thoroughness consistent with the scope of the proposed changes with particular emphasis placed on the Risk-Significant Planning Standards [10 CFR 50.47(b)(4), (5), (9), and (10)], as exempted.

2. The NRC would consider enforcement action for any 10 CFR 50.54(q) and 10 CFR 72.44(f) evaluation that is of inadequate scope and extent to reasonably assess the impact of the proposed change on the effectiveness of the Emergency Plan.

6.2.2.1 PERFORM a 10 CFR 50.54(q) and 10 CFR 72.44(f) evaluation for any activity that affects an area of the emergency preparedness program as determined in the 10 CFR 50.54(q) and 10 CFR 72.44(f) screening or by self-evidence (i.e., the proposed activity was taken directly to an evaluation without a screening).

6.2.2.1.1 COMPLETE EP QEV, 10 CFR 50.54(q) and 10 CFR 72.44(f) Evaluation Form, using the guidelines in Attachment 14.

6.2.2.1.2 IF the activity is subject to one or more change processes outside of 10 CFR 50.54(q) and 10 CFR 72.44(f) [such as 10 CFR 50.59, 10 CFR 50.90, 10 CFR 50.54(a) or 10 CFR 50.54(p)], THEN comply with the other applicable change processes as well.

REFERENCE USE

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Emergency Preparedness Program Maintenance REVISION 2

~s Page 26 of 89 6.2.3 Approval for Changes that Reduce Effectiveness NOTE The regulation 10 CFR 50.54(q)(4) requires the licensee to submit a license amendment application per 10 CFR 50.90 for prior NRG approval of a change that it believes will reduce the effectiveness of its Emergency Plan.

6.2.3.1 In addition to the filing requirements in 10 CFR 50.90, the application shall include:

6.2.3.1.1 All Emergency Plan pages affected by the change.

6.2.3.1.2 A forwarding letter identifying the change(s), the reason for the change(s),

and the licensee's basis for concluding that its Emergency Plan, as modified, continues to meet the planning standards in 10 CFR 50.4 7(b) and the requirements in Appendix E to 10 CFR 50, as exempted.

6.2.4 Determining Acceptability of a Previously Performed 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening or Evaluation 6.2.4.1 !Ethe acceptability of a previously performed 10 CFR 50.54(q) and 10 CFR 72.44(f) screening or evaluation is in question, THEN compare it to the regulation that was applicable at the time the 10 CFR 50.54(q) and 10 CFR 72.44(f) screening or evaluation was prepared.

6.2.4.2 IF a previously performed 10 CFR 50.54(q) and 10 CFR 72.44(f) screening or evaluation is determined to be unacceptable, THEN document the determination in CAP.

6.2.4.3 A subsequent 10 CFR 50.54(q) and 10 CFR 72.44(f) screening or evaluation may also be required to correct an error or omission in an approved screening or evaluation.

6.2.4.3.1 The subsequent 10 CFR 50.54(q) and 10 CFR 72.44(f) screening or evaluation should clearly consider and describe how the previously approved 10 CFR 50.54(q) and 10 CFR 72.44(f) screening or evaluation is affected, and shall be completely re-performed as a stand-alone document.

6.2.4.3.2 The subsequent 10 CFR 50.54(q) and 10 CFR 72.44(f) screening or evaluation shall reference the previously performed 10 CFR 50.54(q) and 10 CFR 72.44(f) screening or evaluation and state whether it supersedes or supplements it.

REFERENCE USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 27 of 89 6.3 Emergency Preparedness Training Program 6.3.1 SONGS ERO Training Program Structure NOTE SONGS ERO Personnel Training consists of Initial Training and Continuing Training.

6.3.1.1 SONGS ERO Training Program Objectives

To instruct each SONGS ERO member in the topics relevant to the function of the ERO positions.

To instruct each SONGS ERO member in the duties and responsibilities specific to their ERO position according to EPP-1.

To provide a means of evaluating ISS/ED and Resource Manager qualification by use of a PQS.

6.3.1.2 SONGS ERO Training Program Overview

The training for SONGS ERO personnel is developed from the position-specific responsibilities as defined in the IOEP. Members of the SONGS ERO receive initial training and annual retraining. They also receive recurring Emergency Plan-related training annually through ISFSI Plant Access Training and position specific training based upon their specific ERO position.

IF training requirements are revised, THEN ENSURE the Learning Management System qualification program matches the new requirements.

Attachment 18 describes the Emergency Preparedness Training Program Curriculum for SONGS ERO positions.

REFERENCE USE

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Emergency Preparedness Program Maintenance REVISION 2

~=-- SONGS Page 28 of 89 6.3.1.3 Personnel Selection 6.3.1.3.1 SONGS ERO personnel are selected based on input from SONGS ISFSI management.

6.3.1.3.2 WHEN a candidate is selected for a SONGS ERO position, THEN INITIATE an Action Request to assign the ERO position to the candidate.

6.3.1.3.3 In the Action Request Description field, INCLUDE "ERO Position Qualification".

6.3.1.3.4 CREATE an Action Request Assignment for the candidate that contains sufficient information to support the qualification completion, such as:

SONGS ERO position name.

Required training to be completed for the SONGS ERO position per Attachment 18.

Date training is due to be completed.

Initiation of EP ERPA.

Completion of applicable sections of EP ERPA and forwarding of form to the EPM.

6.3.1.3.5 WHEN a SONGS ERO candidate has completed the required ERO position training, THEN the EPM or designee shall COMPLETE the applicable section of EP ERPA.

DOCUMENT completion of EP ERPA in a separate assignment under the AR created in Step 6.3.1.3.2.

REFERENCE USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 29 of 89 NOTE

1. EPM or designee may delegate Subject Matter Experts (SMEs) to perform ERO training and evaluation activities.

2. SMEs are selected based on the following criteria:

Documented technical expertise on the specific tasks for which trainees will be trained and evaluated. Documented technical expertise can be validated using the applicable training program database e.g., ShareKnowledge, SOS Learning Management System, etc.

Overall job knowledge.

High standards of performance and commitment to quality.

Professionalism and judgment.

Conservative approach to nuclear safety and industrial safety.

6.3.2 SONGS ERO Position Initial Training 6.3.2.1 Knowledge-Based Training 6.3.2.1.1 Personnel assigned to SONGS ERO positions receive an initial overview course that familiarizes them with the basic IOEP information in the following areas:

Planning Basis.

Emergency Classification.

ERO and Responsibilities.

Augmentation of SONGS ERO.

Emergency Response Facility.

Position-specific Duties.

6.3.2.1.2 Planning Basis:

An introduction to emergency preparedness and regulatory requirements.

A summary of the role of off-site radiological emergency support groups with emphasis on related emergency plans.

A summary of the role of the ERO during an emergency.

REFERENCE USE

EPP-2 REVISION 2

~ Emergency Preparedness Program Maintenance

~~ SONGS Page 30 of 89 6.3.2.1.3 Emergency Classification:

Review of SONGS ISFSI emergency classification scheme based on NEI 99-01 Rev. 6, provided in IOEP-2.

Use of EAL Matrix Table in IOEP-2.

Assessment of conditions following an off-normal, natural phenomenon, or accident event.

Classification of an event and declaration of an emergency.

6.3.2.1.4 ERO and Responsibilities:

Review of EPP-1, Section for Responsibilities.

Review of the ERO structure and chain of command.

ISS/ED delegable and non delegable responsibilities.

6.3.2.1.5 Augmentation of SONGS ERO:

Emergency Response Directory.

Personnel required to be contacted and associated time limits.

Courtesy Notification process.

Communication Equipment.

6.3.2.1.6 Emergency Response Facility:

ERF location and layout.

ERF access control.

Location and use of assessment equipment.

Location and use of ERO notebook and communications equipment.

Location and contents of Emergency Kit.

6.3.2.1.7 Position-specific Duties:

ISS/ED.

Security.

RM.

REFERENCE USE

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~ - SONGS Page 31 of 89 6.3.2.2 Performance-Based Training NOTE It is preferred that performance based training is completed in a drill/exercise setting, such that a trainee can perform their SONGS ERO position tasks under the control of a qualified SONGS ERO position holder.

6.3.2.2.1 Personnel assigned to SONGS ERO positions receive performance-based training using observations, instructional walkthrough, AND/OR drill participation upon completion of the knowledge based training requirements.

6.3.2.2.2 Performance requirements are designed to provide a practical element to the SONGS ERO Training Program AND a familiarization with the conduct of operations associated with the assigned SONGS ERO position.

Observations are designed to provide the trainee with an opportunity to observe their prospective SONGS ERO position "in action" during a drill or exercise.

Instructional walkthroughs are designed to provide one-on-one or small group training sessions in an interactive lecture-type environment by the EPM or a qualified SONGS ERO position holder. The walkthrough usually takes place where the position is assigned and covers the equipment, communications, procedures and activities necessary to fulfill the responsibilities and actions of that position.

Drills are designed to provide training sessions through interactive scenarios.

Drills are conducted as part of the overall training program for the broader ERO and may sometimes be used to demonstrate periodically required objectives. Participation in a drill for purposes of training will not include an evaluation of an EP objective specific to that position, as this is designed to be a guided instructional period for the trainee, in which they may receive coaching and mentoring.

6.3.2.2.3 The SONGS ERO function may permit a training exemption based on previous experience in a similar position. COMPLETE AD 412 to approve an Exemption or a Waiver.

6.3.2.2.4 !E an individual is re-qualifying for the same SONGS ERO position, THEN the EPM or designee EVALUATES the differences between the initial and continuing training qualifications and how long the individual has been out of the position, AND the individual COMPLETES the differences.

REFERENCE USE

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Emergency Preparedness Program Maintenance EPP-2 REVISION 2 Page 32 of 89 6.3.3 SONGS ERO Position Evaluation 6.3.3.1 AFTER completion of Knowledge-Based (Section 6.3.2.1) AND Performance-Based (Section 6.3.2.2) training, the SONGS ERO position trainee completes evaluation requirements of the PQS during discussions, observations, instructional walkthrough, and/or drill participation.

6.3.3.2 Evaluation elements are OBSERVED AND ASSESSED by evaluators who are qualified in the SONGS ERO position.

6.3.3.3 Performance-Based evaluation involves practical demonstrations of the ability to perform the assigned duties and responsibilities for the SONGS ERO position.

6.3.3.3.1 The evaluation process includes generic tasks AND position-specific tasks for the SONGS ERO position.

6.3.3.3.2 Trainee proficiency may be demonstrated by successfully performing or simulating the task.

6.3.3.3.3 The criteria for satisfactory demonstration of the SONGS ERO trainee's capability to perform their SONGS ERO position duties and responsibilities are determined by the evaluator(s) in accordance with the PQS and applicable instructions and tasks.

6.3.3.3.4 The evaluator's initials and signature on the PQS verifies the trainee has demonstrated the knowledge and skills to independently perform the SONGS ERO position tasks.

6.3.3.3.5 The SONGS ERO position candidate provides the completed PQS to the EPM or designee for approval.

6.3.4 Remediation NOTE Unsatisfactory exercise or drill performance or failure to satisfactorily complete a portion of a training program may require some form of remediation.

6.3.4.1 IF remediation is required, THEN the EPM or designee PREPARES a remedial action plan on a case by case basis.

REFERENCE USE

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SONGS Emergency Preparedness Program Maintenance REVISION 2 Page 33 of 89 6.3.5 Annual Retraining 6.3.5.1 The annual retraining provides an overview of SONGS IOEP AND position specific responsibilities.

6.3.5.2 This training is accomplished via completion of required training or demonstrating proficiency of the position during drills.

6.3.5.3 An individual who does NOT complete annual retraining is REMOVED from their ERO position in LMS.

6.3.6 SONGS Supplemental Personnel (With Unescorted PA Access) Training 6.3.6.1 SONGS personnel with unescorted PA access receive ISFSI Plant Access Training in accordance with ADM-30, Attachment for Initial and Requal Training, which includes general IOEP overview. Personnel requiring badges for unescorted PA access receive initial and annual refresher training on general station procedures and policy. This training includes required actions to be taken if an actual emergency is declared at the SONGS ISFSI.

6.3.6.1.1 Transport of Contaminated Injured Persons is performed in accordance with SDS-RP1-PCD-1004, Survey and Release of Personnel, AND demonstrated during the annual medical emergency drill with EP support.

6.3.7 Other Supplemental Personnel (Without Unescorted PA Access) Training 6.3.7.1 Personnel assigned to work at the station who do NOT require unescorted ISFSI PA access, including visitors, receive information on the actions to be taken if an emergency is declared at the SONGS ISFSI.

6.3.7.2 SONGS or Non-SONGS personnel who are brought in to assist with response, mitigating or recovery actions who have NOT received emergency planning training will receive Just-In-Time training prior to performing response actions. This includes training on radiological hazards and Visitor/Escort responsibilities for personnel who are not badged for unescorted ISFSI PA Access.

Personnel names and a summary of brief/training provided will be logged in accordance with EPP-1 instructions REFERENCE USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 34 of 89 6.3.8 EPM Training 6.3.8.1 The individual assigned as the EPM should MAINTAIN an adequate knowledge of regulations, planning techniques, and the latest applications of emergency equipment and supplies. Training may include:

6.3.8.1.1 Courses specific or related to emergency preparedness.

6.3.8.1.2 Observation of, or participation in, drills and/or exercises at other stations.

6.3.8.1.3 Participation in industry review and evaluation programs.

6.3.8.1.4 Participation in regional or national emergency preparedness seminars, committees, workshops, or forums.

6.3.8.1.5 10 CFR 50.54(q) and 10 CFR 72.44(f) Evaluation Qualification.

6.3.8.2 EPM or designee shall USE IOEPQM, ISFSI Only Emergency Planning Qualification Manual, to complete qualifications for EP Program administrative support activities.

6.3.8.2.1 Personnel performing 10 CFR 50.54(q) and 10 CFR 72.44(f) screenings and evaluations shall have completed training per qualification IOEPQM. In addition,

Personnel performing 10 CFR 50.54(q) and 10 CFR 72.44(f) screenings and evaluations should have adequate expertise in technical or administrative matters related to the activity being addressed.

!Ethe scope of 10 CFR 50.54(q) and 10 CFR 72.44(f) screening or evaluation extends beyond expertise of preparer or reviewer, THEN assistance by a subject matter expert should be requested via the EPM.

Continuing training on a calendar two-year frequency for personnel retaining 10 CFR 50.54(q) and 10 CFR 72.44(f) program qualifications is required (Encode 5054SE). Training frequency and content should be augmented in response to degrading performance in order to maintain an effective 10 CFR 50.54(q) and 10 CFR 72.44(f) program.

6.3.8.2.2 Waivers/ exemptions may be granted to contractors or SONGS staff that possess the necessary experience to complete the 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening and Evaluations. COMPLETE AD 412 to approve an Exemption or a Waiver.

6.3.8.2.3 Continuing training course work selection and professional development for emergency preparedness should be REVIEWED AND UPDATED by the EPM (or designee).

REFERENCE USE

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~ 5 Emergency Preparedness Program Maintenance REVISION 2 Page 35 of 89 6.3.9 Support Organizations Training 6.3.9.1 Training is made available to support organizations that may be called upon to provide assistance in the event of an emergency. The following outlines the training provided to these organizations:

6.3.9.1.1 Non-SONGS organizations that may provide specialized services during an emergency (i.e., law enforcement, firefighting, rescue, medical services and transport of injured personnel) are provided or offered site-specific emergency response training, annually.

6.3.9.1.2 The training made available is designed to acquaint the participants with the special problems potentially encountered during an ISFSI emergency (including basic radiation protection and the effects of radiation exposures and radiological contamination), notification procedures and their expected roles. Organizations that must enter the site are instructed as to the identity (by position and title) of those persons in the onsite organization who will control their support activities.

6.3.9.1.3 Records for training offered and/or provided for the offsite responders are to be DOCUMENTED AND MAINTAINED.

6.3.9.2 Support for training of Offsite Emergency Response Organizations may be provided by SONGS when requested.

6.3.9.3 SONGS or Non-SONGS personnel who are brought in to assist with mitigating or recovery actions who have NOT received emergency planning training will receive Just-in-Time training prior to performing response actions. This includes training on radiological hazards and Visitor/Escort responsibilities for personnel who are not badged for unescorted ISFSI PA access.

Personnel names and a summary of brief/training provided will be logged in accordance with EPP-1 instructions REFERENCE USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 36 of 89 6.4 Drill and Exercise Program NOTES

1. Equipment and proficiency drills may be performed as part of the Biennial Exercise, alternate year Integrated Drill, or as an independent drill. A drill may be a component of an exercise. Drills are supervised and evaluated by qualified personnel.

2. SONGS will invite Federal, State, and local government agencies to participate or observe scheduled exercises.

6.4.1 Drill/Exercise Schedule 6.4.1.1 DEVELOP and MAINTAIN a Drill and Exercise Schedule that allows demonstration of all major portions of the IOEP over a six-year period, and supports achievement of the minimum drill frequencies and types listed as specified below:

6.4.1.1.1 Biennial (2Y)

Exercise - tests the adequacy of timing and content of implementing procedures and methods; tests emergency equipment and communication networks; ensures emergency personnel are familiar with their duties.

May be evaluated by Federal evaluators.

Alternate year Integrated Drill - Conducted for the purpose of testing, developing, and maintaining the proficiency of emergency responders.

6.4.1.1.2 Annual (1Y)

Communications drill with State and local government agencies, and NRC Headquarters is conducted annually. Communication drills include the aspect of understanding the content of messages.

Medical Emergency Drill, involving a simulated contaminated individual, which contains provisions for participation by local support services organizations (i.e., ambulance and support hospital) is conducted annually.

The offsite portions of the medical drill may be performed as part of the required Biennial Exercise or alternate year Integrated Drill.

Radiation Protection drill is conducted annually.

Unannounced augmentation drill is conducted annually. This drill involves implementation of the ERO call-out procedure and documentation of the estimated response time for each responder. This drill demonstrates the capability to augment the ED after an emergency is declared.

6.4.1.1.3 Other

Fire drill is conducted in accordance with SONGS Fire Protection Program.

REFERENCE USE

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~s Page 37 of 89 6.4.1.2 Demonstrate the following principal functional areas in Biennial Exercises and alternate year Integrated Drills during the six year calendar cycle in accordance with the frequency specified in EP PDE:

Management and coordination of emergency response.

Accident assessment.

Event classification.

Notification of offsite agencies

Assessment of onsite impact of radiological releases.

Mitigative action development and implementation.

Emergency Termination and Recovery.

6.4.1.3 The EPM or designee shall DEVELOP an Annual Drill and Exercise Schedule for the coming year before the end of the current year.

COORDINATE drill dates with affected offsite agencies when establishing the drill schedule.

CONFIRM any changes to the Drill and Exercise Schedule with all affected internal and external organizations, and ENSURE changes are approved by the EPM.

6.4.2 Selection of Drill/Exercise Objectives 6.4.2.1 The EPM or designee shall IDENTIFY which drill objectives will be evaluated prior to the drill.

6.4.2.2 The selection of objectives shall be based upon:

Corrective Actions/Inspection Reports/Drill Critiques/Industry Lessons Learned.

Revisions to the IOEP.

Six-year schedule and objective demonstration tracking based on EP PDE.

Verification of the effectiveness of corrective actions initiated from previous drills.

REFERENCE USE

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_;jt~ Emergency Preparedness Program Maintenance C *=-- Page 38 of 89

~ - - : - SONGS 6.4.3 Scenario Development NOTES

1. EP DCL may be used to develop the Biennial Exercise and alternate year Integrated Drill.

2. Exercise and drill scenarios, as appropriate, emphasize coordination among Onsite and Offsite Response Organizations.

3. Notifications to ANI during a drill or exercise will be performed in accordance with the latest ANI Information Bulletin 11-01 as described in EPP-1, Emergency Response.

6.4.3.1 ASSEMBLE appropriate resources based on the type and scope of the scenario.

6.4.3.2 COORDINATE any required resources with the SONGS Manager, ISFSI.

6.4.3.3 DEVELOP the scenario to provide reasonable assurance that anticipatory responses will NOT result from pre-conditioning of participants.

6.4.3.4 VARY the scenario from year to year such that all major elements of the plans AND preparedness organizations are tested.

6.4.3.5 The scenario shall provide the necessary information and guidance to achieve the identified objectives.

6.4.3.6 The scenario should CONSIDER free play for participant decision making.

6.4.3.7 DEVELOP the scope of the drill or exercise to indicate:

Participants.

Extent of responses by the ERO including extent of notifications and degree of simulation.

Offsite participation.

REFERENCE USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 39 of 89 6.4.4 Scenario Manual 6.4.4.1 The scenarios for use in exercises and drills include, at a minimum, the following:

The basic objective(s) of each drill/exercise and appropriate evaluation criteria.

The date(s), time period, place(s), and participating organizations.

The simulated events.

A time schedule of real and simulated initiating events.

A narrative summary describing the conduct of the exercises or drills to include such things as simulated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing.

A description of the arrangements for and advance materials to be provided to official observers.

6.4.5 Scenario Confidentiality 6.4.5.1 Scenario confidentiality shall be maintained for drill/exercise evaluated objectives and unannounced drills.

6.4.5.2 Each individual, except Federal, State, and local governmental agency representatives, knowledgeable of the scenario shall sign a confidentiality agreement.

6.4.6 Conduct of Drill and Exercises NOTE EP DCL may be used to conduct drill/exercise readiness checks.

6.4.6.1 Before the drill/exercise starts:

6.4.6.1.1 NOTIFY participants and drill/exercise controllers and evaluators of their participation and CONDUCT briefs.

6.4.6.1.2 ENSURE controllers establish drill control communications at predetermined time.

6.4.6.1.3 NOTIFY offsite agencies and/or offsite controllers of the start of the drill/exercise.

6.4.6.1.4 NOTIFY the Emergency Response Facility of the drill/exercise and start time and any extent of play that may or may not involve the actual staff.

6.4.6.1.5 ANNOUNCE the drill/exercise start and instructions for nonparticipants.

REFERENCE USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 40 of 89 6.4.6.2 During the drill/exercise:

6.4.6.2.1 START the drill/exercise at the scheduled time.

6.4.6.2.2 ALLOW free play for decision making.

6.4.6.2.3 Controllers ENSURE the events are running according to the scenario timeline.

6.4.6.2.4 The Lead Controller may DETERMINE the need for modification of scenario information, OR the suspension OR termination of the drill/exercise based upon changing site conditions or ERP response.

6.4.6.2.5 Controllers may RESOLVE discrepancies in data or field information with concurrence of the Lead Controller.

6.4.6.2.6 Controllers shall DISTRIBUTE messages and cues as scheduled in the scenario with concurrence of the Lead Controller.

6.4.6.2.7 Controllers shall INFORM the Lead Controller of problems encountered that impact the timeline and completion of major events.

6.4.6.2.8 Evaluators and controllers shall MAINTAIN a chronological record of sequence of events and participant responses in sufficient detail in their assigned area to provide an accurate record of activities.

6.4.6.3 Termination of the drill/exercise:

6.4.6.3.1 The Lead Controller shall OBTAIN concurrence from the other controllers that all applicable objectives were demonstrated and evaluated.

6.4.6.3.2 The Lead Controller shall NOTIFY the Emergency Response Facility that the exercise or drill is terminated.

6.4.6.3.3 ANNOUNCE the drill/exercise termination.

6.4.6.3.4 The Lead Controller shall ENSURE participating Federal, State or local agencies, and any Federal or State agency controllers/evaluators are notified that the drill/exercise is terminated.

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EPP-2 Emergency Preparedness Program Maintenance REVISION 2

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SONGS Page 41 of 89 6.4.6.3.5 The Lead Controller shall COORDINATE the following activities:

VERIFY all participants, controllers, and evaluators have signed an attendance sheet and COLLECT all the sheets.

ENSURE all drill/exercise paperwork is collected from each participant.

ENSURE participants restore or restock emergency supplies and equipment, including forms and procedures.

CREATE a Repetitive Order assignment under AR 0820-76580 and NOTIFY the ISS or designee to perform inventory of the items in EP EKIL within 7 days after use.

6.4.7 Drill and Exercise Evaluation 6.4.7.1 Post-Drill/Exercise Participant Critique 6.4.7.1.1 A Participant Critique shall be conducted with the ERO at the conclusion of the drill/exercise.

6.4.7.1.2 Participants unable to attend the post-drill critique shall be provided an opportunity to provide feedback using the drill/exercise critique or feedback sheets.

6.4.7.1.3 Immediately after the drill or exercise, the controllers shall DISTRIBUTE drill/exercise critique or feedback sheets to participants.

6.4.7.1.4 Participants shall COMPLETE the critique which will provide the opportunity to self-identify errors and performance-based issues.

6.4.7.1.5 Participants should document facility, equipment, process, or procedure issues identified during the drill/exercise in CAP.

6.4.7.1.6 The controllers should PROVIDE additional observations and evaluations.

6.4.7.1.7 At the conclusion of the Participant Critique, the Lead Controller shall COLLECT completed Participant Critique documentation.

6.4. 7 .2 Post-Drill/Exercise Controller/Evaluator Debrief 6.4.7.2.1 COORDINATE a Controller Debrief to discuss the preliminary findings.

6.4.7.2.2 EVALUATE drills and exercises against criteria identified by the specific, objectives using EP ODC.

6.4.7.2.3 ENSURE the Controller Debrief remains focused on evaluation of objectives, NOT the development of corrective action plans.

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,:'"'rt Emergency Preparedness Program Maintenance REVISION 2

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. ~ - SONGS Page 42 of 89 6.4.7.2.4 DETERMINE whether the items in the preliminary findings are deficiencies, weaknesses, or other issues.

6.4.7.2.5 ASSEMBLE Objective Evidence to support evaluation of RSPS objectives.

6.4.7.2.6 DIRECT the cognizant controllers to document evaluated objectives NOT met, and any facility, equipment, process, or procedure issues identified during the drill/exercise, if not already documented by participants, in CAP.

6.4.7.2.7 The Lead Controller shall ASSEMBLE the information from the evaluation forms, response records, drill data, drill/exercise critique, feedback sheets, participant comments, and other drill records.

6.4.7.2.8 The EPM or designee should PERFORM an update to the active EP PDE following each drill/exercise.

6.4.7.3 SONGS ISFSI Management Critique Meeting 6.4.7.3.1 A SONGS ISFSI Management Critique Meeting shall be completed for the Biennial Exercise and the alternate year Integrated Drill.

6.4.7.3.2 The EPM or designee shall CONDUCT the SONGS ISFSI Management Critique Meeting.

6.4.7.3.3 The purpose of the Critique Meeting is to give organizational visibility to the drill and exercise program and provide an independent check on the preliminary significance evaluation of ERO performance and drill objectives. Focus should be on drill performance issues associated with weaknesses or items that require corrective action, not minor drill critique items.

6.4.7.3.4 The Managers are expected to challenge the EPM/evaluator's conclusion related to potential drill performance weaknesses.

6.4.7.3.5 The critique process is considered complete when all draft conclusions related to the identified weaknesses have been presented by the EPM to senior management, and any management questions or comments have been documented in the draft exercise/drill critique report.

6.4.7.3.6 IF the NRC was onsite to conduct an evaluation, THEN the Management Critique Meeting for the Biennial Exercise should be completed prior to the agreed upon NRC exit meeting.

REFERENCE USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 43 of 89 6.4.7.4 Critique Report 6.4.7.4.1 A critique report incorporating comments from the SONGS ISFSI Management Critique Meeting shall be completed for the Biennial Exercise and the alternate year Integrated Drill.

6.4.7.4.2 The formal evaluation in the form of a written critique report shall be approved by the EPM and made available to the ERO and the SONGS ISFSI Management.

6.4.7.4.3 The critique report for the Biennial Exercise and the alternate year Integrated Drill shall address each of the following elements that were included for the drill/exercise scenario:

Executive Summary

Drill/Exercise Description

Introduction

Participation Summary

Sequence of Events / Drill Summary

Drill/Exercise Evaluation Results

Drill/Exercise Objectives Evaluation

Strengths, deficiencies, weaknesses and other issues

Corrective Action Summary

ERF Evaluation

Facility and Equipment Issues

Procedure Issues

Demonstration Criteria (DC) results

Participant, Controller and Evaluator Lists

Drill Control Issues

Scenario Design Issues 6.4.7.4.4 An abbreviated written critique report including Drill Objectives Evaluation and Corrective Actions shall be completed for other drills involving the evaluation of designated objectives.

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~~ SONGS Page 44 of 89 6.4.8 Corrective Actions NOTE Risk Significant Planning Standards (RSPS) are 10 CFR 50.47(b)(4),

10 CFR 50.47(b)(5), 10 CFR 50.47(b)(9), and 10 CFR 50.47(b)(10), as exempted. All other 10 CFR 50.47(b) planning standards are not risk significant.

6.4.8.1 Document evaluated objectives NOT met, facility, equipment, process, or procedure issues identified during the drill and exercise in CAP.

6.4.8.1.1 Document each problem separately. For each problem:

IDENTIFY if the problem is related to an applicable RSPS, by stating "Risk Significant Planning Standard" in the Action Request description.

IDENTIFY if it is a deficiency, weakness, or other issue.

IDENTIFY the person responsible for resolution.

6.4.8.2 EVALUATE observations made during drills and exercises in relation to applicable federal regulations and the SONGS IOEP.

6.4.8.3 ENSURE Corrective Actions for issues related to 10 CFR 50.47(b) planning standards, as exempted, are documented in CAP.

6.4.9 Actual Emergency Events 6.4.9.1 EVALUATE Actual Emergency Events incorporating applicable elements of Section 6.4.7.

6.4.9.2 EVALUATE AND CORRECT problems identified during actual Emergency Events incorporating applicable elements of Section 6.4.8.

6.4.9.3 IF Emergency Kit was used, THEN NOTIFY the ISS or designee to perform inventory of the items in EP EKIL within 7 days after use.

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~ Emergency Preparedness Program Maintenance REVISION 2

~ - . SONGS Page 45 of 89 INFORMATION USE 7.0 ACCEPTANCE CRITERIA 7.1 None 8.0 RETENTION OF RECORDS 8.1 IOEP Maintenance 8.1.1 A history file for revised IOEP-1, IOEP-2, EPIPs (Appendix B of IOEP-1), and the MOEE shall be retained in eDMRM for three years after the date of each change (Reference AR 0217-13273).

8.1.2 A record of each change to the SONGS Emergency Plan (Unit 1, Units 2&3, and ISFSI -

Operating, Permanently Defueled and ISFSI-Only), made without prior NRC approval in accordance with 10 CFR 50.54(q) shall be retained in eDMRM for three years from the date of each change. A report of each such change, including *a summary of its analysis, shall be submitted within 30 days after the change is put in effect [Reference 10 CFR 50.54(q)(5) and AR 0217-13273].

8.1.3 The original SONGS Emergency Plan (Unit 1 - Operating) and records of each change to the plan, (Unit 1, Units 2&3, and ISFSI - Operating, Permanently Defueled and ISFSI-Only) including IOEP-1, IOEP-2, or EPIPs (Appendix B of IOEP-1), for which prior NRC approval was obtained pursuant to 10 CFR 50.54(q)(4) shall be retained in eDMRM until the Commission terminates the license for the nuclear power reactor (References 10 CFR 50.54(q)(6) and AR 0217-13273).

8.1.4 SCAN Completed Attachments for quarterly reviews and inspections into eDMRM quarterly, prior to the end of the following quarter in accordance with RPA 99-0119E.

8.1.5 SCAN Completed Attachments for annual reviews and inspections into eDMRM annually, prior to the end of the first quarter of the following calendar year in accordance with RPA 99-0119E.

8.1.6 Completed copies of Attachments used in this procedure may be retained in EP files for at least two years to facilitate reviews and inspections.

8.2 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening and Evaluation 8.2.1 SCAN 10 CFR 50.54(q) and 10 CFR 72.44(f) screening and evaluation documentation into eDMRM in accordance with RPA 92-0010E.

INFORMATION USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 46 of 89 8.3 Training 8.3.1 The Personnel Qualification Standards (PQSs) of individuals participating in the Emergency Preparedness Training Program shall be maintained in the training records database and scanned into eDMRM in accordance with RPA 92-0011 E.

8.3.2 IOEPQM, ISFSI Only Emergency Planning Qualification Manual, shall be maintained in the training records database.

8.3.3 SCAN IOEPQM, ISFSI Only Emergency Planning Qualification Manual, into eDMRM in accordance with RPA 92-0011 E.

8.4 Drills and Exercises 8.4.1 Drill and Exercise records shall be maintained in EP files for a period of six years in accordance with the exercise cycle.

8.4.2 Scenarios used to conduct EP drills and exercises in accordance with Periodic Drill and Exercise Requirements shall be maintained in EP files for a period of six years.

8.4.3 SCAN the final critique report into eDMRM within three months of the date it is signed in accordance with RPA 02-0084E.

8.4.4 A copy of the critique report may be kept in EP files for a period of two years to facilitate reviews and inspections.

8.5 Emergency Preparedness Program Review 8.5.1 SCAN the independent review of the Emergency Preparedness Program performed in accordance with 10 CFR 50.54(t) per Section 6.1.11 into eDMRM in accordance with RPA 20-0002E.

9.0 REFERENCES

/ COMMITMENTS 9.1 Implementing References 9.1.1 Procedures 9.1.1.1 ADM-3, Human Performance Program 9.1.1.2 ADM-5, Corrective Action Program 9.1.1.3 ADM-8, Decommissioning Agent (DA) Records Management 9.1.1.4 ADM-10, Processing Procedures, Instructions, and Forms 9.1.1.5 ADM-30, ISFSI Training Program Description INFORMATION USE

EPP-2 Emergency* Preparedness Program Maintenance REVISION 2 Page 47 of 89 9.1.1.6 ENG-15, Operability Determinations and Functionality Assessments 9.1.1.7 EPP-1, Emergency Response 9.1.1.8 SDS-EP1-PLN-0001, Emergency Preparedness and Response Support Plan 9.1.1.9 SDS-PM1-PLN-0008, SOS Site Communication and Reportability Plan 9.1.1.1 O SDS-RP1-PCD-1004, Survey and Release of Personnel 9.1.1.11 SDS-TN1-PCD-0007, General Employee Training 9.1.1.12 SDS-TN1-PGM-0001, SOS Conduct of Training 9.1.1.13 SEC-15, Notification, Reporting and Loggable Events 9.1.2 Other 9.1.2.1 IOEPQM, ISFSI Only Emergency Planning Qualification Manual 9.1.2.2 SCE-HR-EECONDUCT-PL-303, SCE Corporate Fitness for Duty Policy 9.1.2.3 7101 PQS, ISFSI Shift Supervisor/ Emergency Director or Resource Manager 9.1.3 Forms 9.1.3.1 AD 412, Exemption or Waiver 9.1.3.2 EP 54T, SONGS Emergency Preparedness Program Review 9.1.3.3 EP DCL, Drill Checklist 9.1.3.4 EP EKIL, Emergency Kit Inventory List 9.1.3.5 EP ERPA, Emergency Response Personnel Assignment 9.1.3.6 EP HIL, Hospital Inventory List 9.1.3.7 EP ODC, Objectives Demonstration Criteria 9.1.3.8 EP PDE, Matrix of Periodic Drill and Exercises Objectives 9.1.3.9 EP QEV, 10 CFR 50.54(q) and 10 CFR 72.44(f) Evaluation Form 9.1.3.10 EP QSC, 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening Form 9.1.3.11 EP SNF, SONGS Notification Form 9.1.3.12 EP SOA, SONGS IOEP/EPIP Change Report and Analysis Summary INFORMATION USE

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Emergency Preparedness Program Maintenance

~~ SONGS Page48 of 89 9.2 Developmental References 9.2.1 Commitments 9.2.1.1 IOEP-1, SONGS ISFSI-Only Emergency Plan 9.2.1.2 IOEP-2, SONGS ISFSI-Only Emergency Plan EAL Technical Bases Manual 9.2.1.3 SONGS Technical Specifications 9.2.1.4 10 CFR 50.47(b) (as exempted) 9.2.1.5 10 CFR 50.54(q) 9.2.1.6 10 CFR 50 Appendix E (as exempted) 9.2.1. 7 10 CFR 72.44(f) 9.2.1.8 SO123-ODCM, SONGS Offsite Dose Calculation Manual (ODCM) 9.2.1.9 San Onofre 2 & 3 UFSAR (DSAR) Section 2.1.2, Exclusion Area Authority and Control 9.2.1.10 San Onofre 2 & 3 UFSAR (DSAR) Figure 2.1-5 9.2.2 Procedures 9.2.2.1 SDS-RP4-PCD-1006, Calibration of Common Portable Dose Rate Meters 9.2.3 Other 9.2.3.1 AR 0217-13273, Emergency Plan Record Retention Requirements 9.2.3.2 NEI 10-05, Assessment of On Shift Emergency Response Organization Staffing and Capabilities 9.2.3.3 NEI 11-03, Guidelines for Evaluating Emergency Plan Changes Under 10 CFR 50.54(q) 9.2.3.4 NSIR/DPR-ISG-02, Interim Staff Guidance Emergency Planning Exemption Requests For Decommissioning Nuclear Power Plants 9.2.3.5 NUREG 0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 9.2.3.6 Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors INFORMATION USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 49 of 89 9.2.3.7 ANI Information Bulletin 11-01 (Rev. 1), February 18, 2021 INFORMATION USE

EPP-2 Emergency Preparedness Program Maintenance REVISION 2

~~ .SONGS Page 50 of 89 Emergency Equipment I Attachment 1 Compensatory Measures (See Emergency Description / Function Procedure Sections 6.1.8, 6.1.9, Reference Equipment and 6.1.10)

Protected Area System that provides Timely (90 days) repair of IOEP-1: 10.0 Access Control accountability of site equipment. Use manual tracking and Personnel personnel, visitors, and of personnel inside Protected Accountability contract personnel inside the Area.

System Protected Area.

Emergency Location from which the ERO TBD at time of event. IOEP-1: 8.1 Response Facility can assess conditions, (ERF) evaluate potential consequences, initiate action, and perform notifications.

Cellular Phones Communications between Timely (90 days) repair of IOEP-1: 6.0, ERF and Federal, State, and emergency equipment. Use 8.2, App. A local government agencies; commercial landline telephone MCBCP, ERO; Hospitals; system, satellite phones and/or Field Teams, and others. portable radios.

Voice, text, messaging, email capabilities.

Satellite Phones Backup communications Timely (90 days) repair of IOEP-1: 5.0, between ERF and Federal, emergency equipment. Use 5.0, 8.2, App. A State, and local government commercial landline telephone agencies; MCBCP, ERO; system, cellular phones and/or Hospitals; Field Teams, and portable radios.

others. Voice capabilities.

Commercial Communications between Timely (90 days) repair of IOEP-1: 5.0, Landline ERF and Federal, State, and emergency equipment. Use 6.0, 8.2 Telephone System local government agencies; cellular phones, satellite phones, MCBCP; ERO; Hospitals; and/or portable radios.

Field Teams and others.

Voice capabilities.

Radio System Communications between Timely (180 days) repair of IOEP-1: 5.0, ERF and ERO; Field Teams; emergency equipment. 6.0, 8.2, 10.0, site personnel. Voice Use cellular phones and/or App.A capabilities. satellite phones.

Alert Media Communications between Timely (180 day) repair of IOEP-1: 10.0 ERF and site personnel. emergency equipment.

Use compensatory measures listed in SDS-PM1-PLN-0008.

Emergency Kit IOEP-1, IOEP-2 Emergency Timely (90 days) replacement of IOEP-1: 8.2, Procedures / Response Directory (ERO) material. Use alternate materials App.A Reference Material EPIPs. available onsite.

REFERENCE USE Attachment 1 Page 1 of 3

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 51 of89 Emergency Equipment I Attachment 1 Compensatory Measures (See Emergency Description / Function Procedure Sections 6.1.8, 6.1.9, Reference Equipment and 6.1.10)

Emergency Kit Communications equipment Timely (90 days) repair or IOEP-1: 8.2, Equipment/ (portable radios, cellular replacement of emergency App.A Supplies phone, satellite phone), equipment/ supplies. Use similar portable radiation monitoring equipment available onsite.

equipment to measure gamma, beta, and neutron radioactivity in mR/hr, portable emergency lighting, medical emergency response bag, dosimeters capable of measuring dose and dose rate, Contamination control supplies, decontamination control supplies, protective clothino.

Computers with Emergency notifications, Timely (180 days) repair or N/A network access meteorological information. replacement of emergency equipment. Use commercial landline telephone system, cellular phones, and/or satellite phones.

Holtec Confinement boundary for the IF performing evolutions that IOEP-2: E-HU1 .2 Multi-Purpose contained radioactive require VVM lid removal, THEN:

Canister materials 1. PERFORM dose rate survey prior to removing the lid and after reinstalling it.

2. PERFORM an initial dose rate survey after removing the lid to establish a baseline.

3. MAINTAIN continuous RP coverage while the lid is removed.

4. !E area radiation monitor reading OR survey indicates an UNPLANNED rise of 25 mR/hr over baseline level, THEN the intent of E-HU1 .2 has been met. Based on judgement a declaration of Unusual Event PD-HU3.1 should be made.

REFERENCE USE Attachment 1 Page 2 of 3

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 52 of 89 Emergency Equipment I Attachment 1 Compensatory Measures (See Emergency Description / Function Procedure Sections 6.1.8, 6.1.9, Reference Equipment and 6.1.10)

Trans nuclear Confinement boundary for the IF performing evolutions that IOEP-2: E-HU1 .1 Canister with contained radioactive require AHSM door removal, Spent Fuel materials THEN:

1. PERFORM dose rate survey prior to removing the door and after reinstalling it.

2. PERFORM an initial dose rate survey after removing the door to establish a baseline.

3. MAINTAIN continuous RP coverage while the door is removed.

4. !E area radiation monitor reading, OR survey indicates an UNPLANNED rise of 25 mR/hr over baseline level, THEN the intent of E-HU1 .1 has been met. Based on judgement a declaration of Unusual Event PD-HU3.1 should be made.

APB-LPL-001 and Power Distribution Panels for Timely (90 days) restoration of IOEP-1: 8.1, 8.2 APB-LPL-002 ISFSI power. Use other available resources (e.g., portable batteries, unaffected electrical outlets and equipment, flashlights, use of electronic copies vs printing, etc.)

120V M30 Lighting Power Distribution Panel for Timely (90 days) restoration of IOEP-1: 8.1, 8.2 Panel the sdaorg network power. Use other available resources (e.g., personal hotspot, MiFi jet pack, hardcopy documentation)

REFERENCE USE Attachment 1 Page 3 of 3

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Emergency Preparedness Program Maintenance EPP-2 REVISION 2

~~ SONGS Page 53 of 89 IOEP-1, IOEP-2, and MOEE Review Attachment 2 1.0 REVIEW IOEP-1 annually to ENSURE document is current (refer to Step 6.1.3.1).

1.1 ENSURE the review includes changes identified during the 10CFR50.54(t) reviews, assessments, training, drills, and exercises.

1.2 ENSURE required changes have been incorporated or are being tracked for incorporation.

Comments:

2.0 REVIEW IOEP-2 and the MOEE to ENSURE documents are current (refer to Step 6.1.3.2).

Comments:

PERFORMED BY: Date: _ _ _ _ __

Emergency Preparedness Manager or designee APPROVED BY: Date: _ _ _ _ __

~ONGS Manager, ISFSI REFERENCE USE Attachment 2 Page 1 of 1

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~ - SONGS Page 54 of 89 Security Plan and Emergency Plan Coordination Attachment 3 1.0 REVIEW IOEP-1 requirements relative to the ISFSI-Only Security Plan (refer to Step 6.1.3.3).

2.0 IDENTIFY changes to IOEP-1 and ISFSI-Only Security Plan since the last review.

3.0 CONFIRM review of changes to IOEP-1 by Security Management.

4.0 CONFIRM review of changes to ISFSI-Only Security Plan by EPM or designee.

5.0 IF any changes have NOT been reviewed by appropriate management, THEN INITIATE review for impact and document results in CAP (create a new Action Request).

5.1 RECORD Action Request number OR ENTER N/A: _ _ _ _ _ _ _ _ _ _ __

Comments: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

PERFORMED BY: Date: _ _ _ _ __

Emergency Preparedness Manager or designee APPROVED BY: Date: _ _ _ _ __

SONGS Manager, ISFSI REFERENCE USE Attachment 3 Page 1 of 1

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~ - SONGS Page 55 of 89 Annual EAL Review I Attachment 4 1.0 REVIEW EALs with State and local government agencies and MCBCP annually (refer to Step 6.1.3.4).

Comments (include how review/task was performed):

PERFORMED BY: Date: _ _ _ _ __

Emergency Preparedness Manager or designee APPROVED BY: Date: _ _ _ _ __

SONGS Manager, ISFSI REFERENCE USE Attachment 4 Page 1 of 1

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 56 of 89 Letters or Memoranda of Agreement Review Attachment 5 1.0 REVIEW the following letters or memoranda of agreement annually (refer to Step 6.1.3.5).

1.1 MCBCP Agreements for fire response, rescue operations, prompt ambulance transport of personnel on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day basis.

Comments (include how review/task was performed):

PERFORMED BY: Date: - - - - - -

Emergency Preparedness Manager or designee 1.2 Mission Hospital Regional Medical Center Agreement for hospital and medical services, including receiving and treating contaminated and/or injured persons requiring immediate hospital care.

Comments (include how review/task was performed):

PERFORMED BY: Date: - - - - - - -

Emergency Preparedness Manager or designee 1.3 Tri-City Medical Center Agreement for hospital and medical services, including receiving and treating contaminated and/or injured persons requiring immediate hospital care.

Comments (include how review/task was performed):

PERFORMED BY: Date: - - - - - -

Emergency Preparedness Manager or designee REFERENCE USE Attachment 5 Page 1 of 2

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~~ SONGS Page 57 of 89 Letters or Memoranda of Agreement Review Attachment 5 1.4 FBI and local public entities Agreement(s) for law enforcement support per the Security Plan.

Comments (include how review/task was performed):

PERFORMED BY: Date, _ _ _ _ _ __

Emergency Preparedness Manager or designee 2.0 All Letters or Memoranda of Agreement have been reviewed. Problems identified have been corrected or documented in CAP (create a new Action Request).

Comments:

PERFORMED BY: Date: _ _ _ _ __

Emergency Preparedness Manager or designee APPROVED BY: Date: _ _ _ _ _ __

SONGS Manager, ISFSI REFERENCE USE Attachment 5 Page 2 of 2

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~ ~ SONGS Emergency Preparedness Program Maintenance REVISION 2 Page 58 of 89 Emergency Response Directory Review Attachment 6 1.0 REVIEW Emergency Response Directory quarterly to ENSURE ERO recall information (names and numbers), support personnel, and applicable offsite organizations is maintained current (refer to Step 6.1.3.6).

2.0 REPLACE outdated Emergency Response Directories per the distribution list (last page of EP ERO).

Comments:

PERFORMED BY: Date: ------

Emergency Preparedness Manager or designee APPROVED BY: Date: _ _ _ _ __

SONGS Manager, ISFSI REFERENCE USE Attachment 6 Page 1 of 1

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 59 of 89 IOEP-1 and MOEE Distribution Review Attachment 7 1.0 REVIEW distribution lists for IOEP-1 and MOEE annually to VERIFY distribution information is current (refer to Step 6.1.3. 7).

Comments (include how review/task was performed):

PERFORMED BY: Date: _ _ _ _ __

Emergency Preparedness Manager or designee APPROVED BY: Date: _ _ _ _ __

SONGS Manager, ISFSI REFERENCE USE Attachment 7 Page 1 of 1

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 60 of 89 Matrix of Periodic Drill and Exercise Objectives Review Attachment 8 1.0 REVIEW EP PDE against accomplished objectives frequently enough to ENSURE all required objectives have been accomplished or scheduled within their periodicity (recommend review completed by second quarter) (refer to Step 6.1.3.8).

Comments:

PERFORMED BY: Date: - - - - - -

Emergency Preparedness Manager or designee 2.0 COMPLETE EP PDE during the fourth quarter to ENSURE all required objectives for the year have been accomplished. ATTACH EP PDE to this review.

Comments PERFORMED BY: Date: _ _ _ _ __

Emergency Preparedness Manager or designee APPROVED BY: Date: _ _ _ _ __

SONGS Manager, ISFSI REFERENCE USE Attachment 8 Page 1 of 1

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 61 of 89 Emergency Equipment and Supplies Inspection Attachment 9 1.0 ISS or designee has inventoried Emergency Kit procedures, materials, equipment, and supplies per EP EKIL (refer to Step 6.1.4.1).

INVENTORY ITEM TRACKING NUMBER DATE COMPLETED PERFORMED BY ERF KIT 1 2.0 The emergency equipment and supplies quarterly inspections have been completed. Problems identified have been corrected or documented in CAP (create a new Action Request).

Comments:

REVIEWED BY: Date: _ _ _ _ __

lSFSI Shift Supervisor or designee APPROVED BY: Date: _ _ _ _ __

SONGS Manager, ISFSl REFERENCE USE Attachment 9 Page 1 of 1

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SONGS Emergency Preparedness Program Maintenance EPP-2 REVISION 2 Page 62 of 89 Emergency Communications Quarterly Test Attachment 10 NOTE Performance of drill requirements specified in IOEP-1 Part II, Section 14 satisfies the testing frequency for equipment that is documented as used during the drill.

1.0 Emergency Kit Portable Radios Test (refer to Step 6.1.5.1).

1.1 TURN ON two Emergency Kit portable radios AND SELECT a specific channel for the test.

1.2 OPERATE Emergency Kit portable radios AND VERIFY clear and audible communications for both transmission and reception.

1.3 TURN OFF Emergency Kit portable radios.

1.4 RECORD test results on the table below.

1.5 REPEAT Steps 1.1 through 1.4 until all Emergency Kit portable radios are tested.

1.6 !E equipment or communication problems were encountered, THEN NOTIFY the ISS to arrange for repairs. DOCUMENT problems in CAP (create a new Action Request). RECORD Action Request number(s) on table below; otherwise N/A.

Emergency Kit Portable Radio Test SAT Action PERFORMED BY Date Serial Number Request Number y N y N y N y N 2.0 Emergency Kit Cellular Phones Test (refer to Step 6.1.5.1 ).

2.1 TURN ON Emergency Kit cellular phone.

2.2 CALL a nearby phone AND VERIFY clear and audible communications for both transmission and reception.

2.3 REQUEST a return phone call.

2.4 VERIFY return call clear and audible communications for both transmission and reception.

2.5 TURN OFF Emergency Kit cellular phone.

REFERENCE USE Attachment 1O Page 1 of 3

ff}EDISON_

EPP-2

\*/!:~ Emergency Preparedness Program Maintenance REVISION 2

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. ~ - SONGS Page 63 of 89 Emergency Communications Quarterly Test Attachment 10 2.6 RECORD test results on the table below.

2.7 REPEAT Steps 2.1 through 2.6 until all Emergency Kit cellular pho nes are tested.

2.8 !E equipment or communication problems were encountered, THE N NOTIFY the ISS to arrange for repairs. DOCUMENT problems in CAP (create a new Action Req uest). RECORD Action Request I number(s) on table below; otherwise N/A.

Emergency Kit Cellular Test SAT Action Request PERFO RMED BY Date Phone Number ERD Number y N y N y N y N NOTE Emergency Response Directory contains Emergency Kit sa tellite phone dialing instructions.

3.0 Emergency Kit Satellite Phones Test (refer to Step 6.1.5.1 ).

3.1 TURN ON both Emergency Kit satellite phones.

3.2 CALL one Emergency Kit satellite phone with the other Emergency Kit satellite phone AND VERIFY clear and audible communications for both transmis sion and reception.

3.3 REQUEST a return phone call.

3.4 VERIFY return call clear and audible communications for both tran smission and reception.

3.5 RECORD test results on the table below.

3.6 TURN OFF both Emergency Kit satellite phones ..

3.7 IF equipment or communication problems were encountered, THE N NOTIFY the ISS to arrange for repairs. DOCUMENT problems in CAP (create a new Action Requ est). RECORD Action Request I number(s) on table below; otherwise N/A.

Emergency Kit Test SAT Action Request PERFO RMED BY Date Satellite Phone Number Number ERD y N y N REFERENCE USE Attachment 1O Page 2 of 3

~ E] ~-~t?.9.~- EPP-2 rt~t*

~s Emergency Preparedness Program Maintenance REVISION 2 Page 64 of 89 Emergency Communications Quarterly Test Attachment 10 4.0 Quarterly communications test has been completed. Problems identified have been corrected or documented in CAP (create a new Action Request).

Comments:

REVIEWED BY: Date: _ _ _ _ __

ISFSI Shift Supervisor or designee APPROVED BY: Date: _ _ _ _ __

SONGS Manager, ISFSI REFERENCE USE Attachment 10 Page 3 of 3

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~ ~ SONGS Emergency Preparedness Program Maintenance REVISION 2 Page 65 of 89 Emergency Equipment - Compensatory Attachment 11 Equipment Description / Function ERF / Location Action Request Number 1.0 IDENTIFY the Emergency Plan Function /

Reference:

1.1 Category

CHECK the appropriate box Equipment used to assess an Emergency Action Level Threshold.

Means of fulfilling an emergency response function other than above.

NOTE Temporary compensatory measures that are put in place while the affected emergency equipment is being restored to full functionality are not considered changes to the IOEP. However, an evaluation should address the capability of function and the timeliness of compensatory measures compared to the intended function of the degraded emergency equipment.

1.2 IDENTIFY compensatory measures used:

1.3 IDENTIFY the time period approved for compensatory measures (e.g., 90 days for RSPS-related equipment and 180 days for PS-related equipment).

2.0 Do compensatory measures fully maintain the emergency response function?

YES D NO D Basis:

REFERENCE USE Attachment 11 Page 1 of 2

~

Emergency Preparedness Program Maintenance EPP-2 REVISION 2

~ - SONGS Page 66 of 89 Emergency Equipment - Compensatory Attachment 11 3.0 Documentation 3.1 For planned or unplanned maintenance activities expected to result in the emergency equipment being unavailable for more than 30 days, CREATE an Assignment to the EPM for evaluation of compensatory measures under 10 CFR 50.54(q) and 10 CFR 72.44(f).

3.1.1 Planned maintenance SHALL NOT proceed until the Assignment is approved.

3.1.2 Unplanned maintenance activity compensatory measures should be used immediately in the case of unplanned maintenance without waiting for the Assignment to be created.

3.2 NOTIFY the ERO as soon as practical.

3.3 Document compensatory measures in CAP for EP tracking.

3.4 REVIEW SEC-15 for reportability requirements and actions 4.0 Review/ Approval 4.1 Compensatory Measures Acceptance Criteria 4.1.1 The Reviewer completes the following evaluation:

SAT COMPENSATORY MEASURE EVALUATION CRITERIA Compensatory measures orovide soecific, clear, and actionable auidance.

Alternate indications/ components include specifics such as the person or position assigned responsibility for actions associated with compensatory measures, actions required by compensatory measures, and periodicity for compensatory actions, as well as review and approval authoritv.

Compensatory measures are the best available means to maintain the emergency preparedness function.

PREPARED BY: __________________ Date: _ _ _ _ __

Print Name I Signature (ISFSI Shift Supervisor/designee)

REVIEWED BY: Date: _ _ _ _ __

Print Name I Signature (ISFSI Shift Supervisor/designee)

\

APP~OVED BY: Date: _ _ _ _ __

Print Name I Signature (EPM/designeE;l or SONGS Manager, ISFSl/designee)

REFERENCE USE Attachment 11 Page 2 of 2

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 67 of 89 Hospital Supplies Inspection Attachment 12 1.0 EPM or designee has inventoried supplies maintained at the hospitals (refer to Step 6.1.4.2):

1.1 Mission Hospital Regional Medical Center DATE COMPLETED PERFORMED BY Radiological Emergency Supplies 1.2 Tri-City Medical Center DATE COMPLETED PERFORMED BY Radiological Emergency Supplies 2.0 The hospital supplies inspections have been completed. Problems identified have been documented in CAP (create a new Action Request).

Comments:

PERFORMED BY: Date: _ _ _ _ __

Emergency Preparedness Manager or designee APPROVED BY: Date: - - - - - -

SONGS Manager, ISFSI REFERENCE USE Attachment 12 Page 1 of 1

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 68 of 89 Completing EP QSC, 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening Form I Attachment 13 1.0 Section 1, Activity Description and References 1.1 Multiple activities may be considered on a single screening so long as all proposed activities are identified and screened.

1.2 RECORD the tracking number on the form (Action Request/Assignment number).

1.3 RECORD a description of the activity.

1.3.1 The description does not need to include the reason for the activity. Typically, the reason for the activity is associated with the screening of the change and should be documented in the applicable section.

1.3.2 A reference to an attached procedure, table or other form of description may be used in addition to the activity description.

1.3.3 For an activity that results in changes to multiple documents or sections in a document, developing a comparison table of the current content to the changed content may be used to support the description.

1.4 RECORD the references related to the activity (e.g., additional corrective action, engineering change package, procedure change request, calculation number, prior approval ADAMS accession number, license amendment number, etc.).

REFERENCE USE Attachment 13 Page 1 of 6

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 69 of 89 Completing EP QSC, 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening Form I Attachment 13 2.0 Section 2, 1st Tier Screening 2.1 CHECK the appropriate box or boxes that define the type of change associated with the activity.

2.1.1 CHECK the "physical change" box for an activity that involves a change such as organizational structure or staffing, site layout or boundaries, material changes of supplies or equipment, etc.

NOTE An activity may involve both a physical change and a process change, although it may not be known if a physical change will also result in a process change at this time.

2.1.2 CHECK the "process change" box for an activity that involves a change such as altering the method or steps to perform a task, performing with more or fewer individuals, overlapping with other activities, etc.

2.1.3 CHECK the "value change" box for an activity that involves a change such as set-points, thresholds, time durations, indicators, standards, etc.

2.1.4 CHECK the "editorial change" box for an activity that only involves a change such as typographical, formatting, paragraph numbering, spelling, grammar, punctuation or title changes that do NOT alter intent, value, capability or timeliness.

2.1.5 An activity that is an editorial-only change should NOT be any other type of change; physical change, process change, value change, or conforming change.

REFERENCE USE Attachment 13 Page 2 of 6

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 70 of 89 Completing EP QSC, 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening Form I Attachment 13 NOTES

1. Activities that have been ordered by the regulator or have been previously submitted to and approved by the NRC or FEMA through other formal change processes are considered conforming changes that do not require a 10 CFR 50.54(q) and 10 CFR 72.44(f) effectiveness evaluation provided the related change to the emergency preparedness program is specifically and fully addressed in that order or docketed approval transmittal (such as ISFSI design, equipment, EALs, etc.).

2. Approved LARs, such as for ISFSI modifications, DSAR, FSAR, or security changes, that do not include specific consideration and approval of the activity's change to the emergency preparedness program are not considered conforming changes.

3. Changes to regulations or new regulations issued to the industry at large are not typically considered conforming changes.

2.1.6 !Ethe change is a conforming change, THEN CHECK the "conforming change" box.

2.2 !Ethe activities are strictly an editorial or conforming change, THEN GO TO Step 5.0, Section 5, Screening Results.

REFERENCE USE Attachment 13 Page 3 of 6

EPP-2

~ Emergency Preparedness Program Maintenance REVISION 2

-::=-- Page 71 of 89

~~ SONGS Completing EP QSC, 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening Form Attachment 13 3.0 Section 3, 2nd Tier Screening 3.1 Document the association of the activity with the emergency preparedness program as follows:

3.1.1 CHECK the applicable planning standard or 10 CFR 50 Appendix E requirement box or boxes that are associated with the activity.

Most EP Program commitments are associated with a planning standard and are identified above. However, site-specific commitments associated with other regulations, orders, ASLB, NRC/FEMA correspondence, etc., that do not fall under one of the sixteen planning standards may exist as an EP Program commitment.

3.1.2 !Ethe activity is NOT associated with any of the planning standards or 10 CFR 50 Appendix E requirements, THEN PERFORM the following:

3.1.2.1 PERFORM a search to identify any SONGS site-specific emergency preparedness program commitments made since the NRC originally approved the IOEP, not related to a planning standard, that are associated with the activity, using the following resources:

Certrec

NRC Correspondence 3.1.2.2 Document the scope of the search (such as key words).

3.1.2.3 Transcribe the wording and IDENTIFY the source of any applicable SONGS site-specific Emergency Preparedness program commitment associated with the activity.

3.2 !Ethe activity is associated with any of the planning standards, OR is associated with a SONGS site-specific emergency preparedness commitment, THEN GO TO Step 4.0, Section 4, 3rd Tier Screening.

3.3 !Ethe activity is NOT associated with a planning standard, AND is NOT associated with a SONGS site-specific emergency preparedness commitment, THEN GO TO Step 5.0, Section 5, Screening Results.

REFERENCE USE Attachment 13 Page 4 of 6

~ - SONGS Emergency Preparedness Program Maintenance EPP-2 REVISION 2 Page 72 of 89 Completing EP QSC, 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening Form J Attachment 13 4.0 Section 4, 3rd Tier Screening 4.1 For each planning standard or 10 CFR 50 Appendix E requirement checked in Section 3, 2nd Tier Screening, IDENTIFY the applicable function(s) element(s) and site-specific commitment(s) associated with the activity.

NOTE

1. Regulatory Guide 1.219 Section 4 and NEI 10-05 Appendix C provide lists of EP Program functions which are the basis for Attachment 15.

2. Refer to the above documents for additional guidance when performing Screenings.

4.1.1 Using Attachment 15 as a reference, IDENTIFY the applicable function(s) associated with the activity.

4.1.2 Using 10 CFR 50 Appendix E and NSIR/DPR-ISG-02 Attachment 1, as exempted, as references, IDENTIFY the applicable element(s) that are associated with the activity.

4.1.3 IDENTIFY each SONGS site-specific emergency preparedness program commitment associated with the activity.

Reference:

NRC letter dated 06/04/15, San Onofre Nuclear Generating Station, Units 1, 2, and 3 and Independent Spent Fuel Storage Installation -Exemptions from Certain Emergency Planning Requirements and Related Safety Evaluation (TAC NOS.

MF3835, MF3836, AND MF3837). (ADAMS Accession Nos: Letter ML15082A204; Exemption: ML15082A143).

NRC letter dated November 30, 2017, San Onofre Nuclear Generating Station, Units 1, 2, and 3 - Issuance of Amendments to Revise the Permanently Defueled Emergency Plan (CAC NOS. L53160, L53161, and L53162), Enclosure 4, Safety Evaluation. (ADAMS Accession No: ML17310B482) 4.2 IDENTIFY the current IOEP content that describes how the function(s), element(s) and commitment(s) are met.

4.3 Document whether the activity does or does not affect how the current IOEP meets the listed function(s), element(s) and commitment(s).

4.4 GO TO Step 5.0, Section 5, Screening Results.

REFERENCE USE Attachment 13 Page 5 of 6

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 73 of 89 Completing EP QSC, 10 CFR 50.54(q) and 10 CFR 72.44(f) Screening Form Attachment 13 5.0 Section 5, Screening Results 5.1 CHECK the box that indicates the activity may be implemented without performing a 10 CFR 50.54(q) and 10 CFR 72.44(f) evaluation provided any of the following conditions are met:

5.1.1 The change was identified as only editorial.

5.1.2 The change was identified as only conforming (i.e., an activity given prior approval by the NRC or FEMA).

5.1.3 The activity does NOT affect how the current IOEP meets all of the following:

A planning standard function.

A program element.

A SONGS site-specific emergency preparedness program commitment.

5.2 CHECK the box that indicates the activity should NOT be implemented without performing a 10 CFR 50.54(q) and 10 CFR 72.44(f) evaluation provided any of the following conditions are met:

5.2.1 The activity does affect how the current IOEP meets a planning standard function.

5.2.2 The activity does affect how the current IOEP meets a program element.

5.2.3 The activity does affect how the current IOEP meets a site-specific EP program commitment.

6.0 Sign Off Sections 6.1 Prior to signing, the preparer and reviewer shall ENSURE all included information* is finalized and correct.

6.2 RECORD name, signature, and date for the preparer.

6.3 RECORD name, signature, and date for the reviewer.

6.4 RECORD name, signature, and date for the approver.

REFERENCE USE Attachment 13 Page 6 of 6

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 74 of 89 Completing EP QEV, 10 CFR 50.54(q) Evaluation Form Attachment 14 1.0 Section 1, Activity Description and References 1.1 Multiple activities may be considered on a single evaluation so long as all proposed activities are identified and evaluated.

1.2 RECORD the tracking number on the form (Action Request number).

1.2.1 !Ea screening evaluation was previously performed, THEN USE the same Action Request number.

1.3 RECORD a description of the activity.

1.3.1 Activities determined as strictly editorial or conforming during the 10 CFR 50.54(q) and 10 CFR 72.44(f) screen do not need to be recorded for the evaluation.

1.3.2 The description does not need to include the reason for the activity. Typically, the reason for the activity is associated with the evaluation of the change and should be documented in the applicable section.

1.3.3 A reference to an attached procedure, table, or other form of description may be used in addition to the activity description.

1.3.4 For an activity that results in changes to multiple documents or sections in a document, developing a comparison table of the current content to the changed content may be used to support the description.

1.4 RECORD the references related to the activity (e.g., additional correction actions, engineering change package, procedure change request, calculation number, prior approval ADAMS accession number, license amendment number, etc.).

2.0 Section 2, Impact and Licensing Basis Determination 2.1 The below steps are performed successively for each individual planning standard or applicable regulation when more than one planning standard or regulation is associated with the activity.

2.2 IDENTIFY the specific 10 CFR 50.47(b) planning standard(s), as exempted, and other applicable regulation associated with the activity.

REFERENCE USE Attachment 14 Page 1 of 7

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~~

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' Emergency Preparedness Program Maintenance REVISION 2 Page 75 of 89 Completing EP QEV, 10 CFR 50.54(q) Evaluation Form Attachment 14 NOTES

1. Regulatory Guide 1.219 Section 4 and NEI 10-05 Appendix C provide lists of EP Program and ERO Performance functions which are the basis for Attachment 15.

2. The above documents are available for additional guidance when performing evaluations.

2.2.1 Using Attachment 15 as a reference, IDENTIFY the applicable function(s) associated with the activity by planning standard.

2.2.2 Using 10 CFR 50 Appendix E and NSIR/DPR-ISG-02 Attachment 1, as exempted, as references, IDENTIFY the applicable element(s) associated with the activity by planning standard.

2.2.3 IDENTIFY any SONGS site-specific emergency preparedness program commitments associated with the activity, using the following resources:

Certrec.

NRC Emergency Plan related SERs.

Reference:

NRC letter dated 06/04/15, San Onofre Nuclear Generating Station, Units 1, 2, and 3 and Independent Spent Fuel Storage Installation -Exemptions from Certain Emergency Planning Requirements and Related Safety Evaluation (TAC NOS.

MF3835, MF3836, AND MF3837). (ADAMS Accession Nos: Letter ML15082A204; Exemption: ML15082A143).

NRC letter dated November 30, 2017, San Onofre Nuclear Generating Station, Units 1, 2, and 3 - Issuance of Amendments to Revise the Permanently Defueled Emergency Plan (CAC NOS. L53160, L53161, and L53162), Enclosure 4, Safety Evaluation. (ADAMS Accession No: ML17310B482) 2.2.4 Document the scope of the search (such as key words).

2.2.5 IDENTIFY the wording and the source of any applicable SONGS site-specific Emergency Preparedness program commitment associated with the activity.

REFERENCE USE Attachment 14 Page 2 of 7

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~ =-- SONGS Emergency Preparedness Program Maintenance REVISION 2 Page 76 of 89 Completing EP QEV, 10 CFR 50.54(q) Evaluation Form Attachment 14 NOTES

1. The approved means to meet a particular planning standard function, program element or site-specific commitment is documented in the approved version of the IOEP.

2. The approved version of the IOEP may itself be the licensing basis for how a particular planning standard function, program element, or site-specific commitment is met, or the licensing basis may be provided in other documents that led to the approval of the IOEP content (and subsequent revisions), such as in SERs, Supplemental SERs, licensing hearing transcripts or docketed inspection finding commitments, etc.

3. The licensing basis is used to evaluate whether an activity will result in a regulatory non-compliance or RIE.

2.3 DETERMINE and document the IOEP content that describes how the listed functions, elements, and commitments are met, and any additional licensing basis information not part of the IOEP content itself.

2.3.1 !Ethe approved licensing basis is different from the basis contained in the current IOEP, THEN document the reason for the difference.

2.3.2 IDENTIFY the source of licensing basis information if it is not the current IOEP content (for example; Safety Evaluation Report, IOEP, EPIP, etc.).

3.0 Section 3, Compliance Evaluation and Conclusion 3.1 The below steps are performed successively for each individual planning standard or applicable regulation when more than one planning standard or regulation is associated with the activity.

3.2 REVIEW the regulatory requirements (i.e., licensing basis) to ENSURE the basis of the existing program elements and why the elements were incorporated in the IOEP is understood.

3.2.1 In consideration of each function, element, and commitment listed in the impact determination above (Section 2, Impact and Licensing Basis Determination), document:

3.2.1.1 How the activity does or does not alter the IOEP content.

3.2.1.2 How the activity does or does not alter the licensing basis with regards to meeting the regulatory requirements.

REFERENCE USE Attachment 14 Page 3 of 7

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 77 of 89 Completing EP QEV, 10 CFR 50.54(q) Evaluation Form Attachment 14 3.2.1.3 ENSURE the specific 10 CFR 50.47(b) and 10 CFR 50 Appendix E, as exempted, and 10 CFR 72.32(c) requirements associated with the activity are included in the evaluation.

3.3 CHECK the appropriate box for whether the activity continues to provide compliance with the requirements of 10 CFR 50.47{b) and 10 CFR 50 Appendix E, as exempted, and 10 CFR 72.32(c) in the conclusion.

3.4 !Ethe activity does NOT continue to provide compliance with the regulatory requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E, as exempted, and 10 CFR 72.32(c),

THEN it shall be either:

3.4.1 Rejected.

3.4.2 Revised to achieve compliance.

3.4.3 Formally submitted to the NRC for an exemption to the regulatory requirement per 10 CFR 50.12.

3.5 !Ethe evaluation concludes the activity does NOT continue to provide compliance with the regulatory requirements, THEN GO TO Step 5.0, Section 5, Evaluation Results.

4.0 Section 4, Reduction in Effectiveness Evaluation and Conclusion 4.1 An RIE is usually based on a change to a planning standard function.

4.1.1 A change to one or more program elements may not always reduce the effectiveness of the associated planning standard function.

4.2 An RIE typically occurs if there is a reduction in the capability or timeliness for performing or fulfilling a function, element, or commitment without activities to compensate for the reduction in capability or timeliness.

4.2.1 In some cases, licensees may have committed to particular program elements in response to site-specific considerations.

4.3 An activity may impact more than one function, element, or commitment under different planning standards.

4.4 REVIEW Regulatory Guide 1.219 Section 4 for examples of changes that may or may not require prior NRC approval.

REFERENCE USE Attachment 14 Page 4 of 7

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 78 of 89 Completing EP QEV, 10 CFR 50.54(q) Evaluation Form Attachment 14 4.5 The below steps are performed successively for each individual planning standard or applicable regulation when more than one planning standard or regulation is associated with the activity.

4.5.1 Unless an activity results in repetitive identical changes or multiple activities result in interdependent changes, document the evaluation for RIE for each activity/change separately 4.6 In consideration of each function, element, and commitment listed in the impact determination above (Step 2.0) document how:

4.6.1 The activity does or does NOT alter the IOEP content.

4.6.2 The activity does or does not alter the licensing basis with regards to an RIE, with specific evaluation of the following attributes:

4.6.2.1 Continued capability to meet or perform the planning standard function, program element, or commitment.

4.6.2.2 Continued timeliness of the planning standard function, program element, or commitment.

4.6.3 IF there are any differences in how the IOEP will meet one of the listed functions, elements, or commitments, THEN PERFORM the following:

4.6.3.1 Document a clear explanation for the difference (e.g., special circumstances that require the difference in order to effectively perform the function, as a matter of convenience, or as an operating philosophy).

4.6.3.2 Qualify the difference as improving, sustaining, or reducing the effectiveness of the planning standard function, element, or commitment.

4.7 !E multiple activities create interdependent changes, THEN EVALUATE and document the overall impact on the effectiveness of the IOEP or its implementation in a summary at the end of the section.

4.8 CHECK the appropriate box for whether the activity constitutes an RIE in the conclusion.

REFERENCE USE Attachment 14 Page 5 of 7

EPP-2.

~-r Emergency Preparedness Program Maintenance REVISION 2

~ - SONGS Page 79 of 89 Completing EP QEV, 10 CFR 50.54(q) Evaluation Form Attachment 14 5.0 Section 5, Evaluation Results NOTE In the case where it is uncertain whether the activity constitutes a reduction in effectiveness, the NRG suggests a pre-application conference call be arranged with the NRG Headquarters staff to discuss the proposed change and to ask the staff to clarify the regulatory positions in Regulatory Guide 1.219.

5.1 RECORD the evaluation results.

5.1.1 CHECK the appropriate box that indicates the activity may be implemented without prior NRG approval provided both of the following conditions are met:

5.1.1.1 The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E, as exempted, and 10 CFR 72.32(c).

5.1.1.2 The activity does NOT constitute an RIE.

5.1.2 CHECK the appropriate box that indicates that the activity shall NOT be implemented without prior NRC approval provided either of the following conditions is met:

5.1.2.1 The activity does NOT continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50 Appendix E, as exempted, and 10 CFR 72.32(c).

5.1.2.2 The activity constitutes an RIE.

5.1.3 Take one of the following actions for any activity that reduces the effectiveness of the IOEP.

5.1.3.1 Reject the activity.

5.1.3.2 Revise the activity so that it maintains the effectiveness of the IOEP.

5.1.3.3 Formally submit the activity to the NRC for prior approval per 10 CFR 50.90.

REFERENCE USE Attachment 14 Page 6 of 7

........__ ii..1~9.l~gr:/. EPP-2

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~ ~ SONGS Emergency Preparedness Program Maintenance REVISION 2

. Page 80 of 89 Completing EP QEV, 10 CFR 50.54(q) Evaluation Form Attachment 14 6.0 Sign Off Sections 6.1 Prior to signing, the preparer and reviewer shall ENSURE all included information is finalized and correct.

6.2 RECORD name, signature, and date for the preparer.

6.3 RECORD name, signature, and date for the reviewer.

6.4 RECORD name, signature, and date for the approver.

REFERENCE USE Attachment 14 Page 7 of 7

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 81 of 89 Planning Standard Functions List Attachment 15 In accordance with10 CFR 72.32(c), the following satisfies the requirements of 10 CFR 72.32.

1.0 Assignment of Responsibility (Organization Control): 10 CFR 50.47(b)(1) 1.1 Planning Standard Functions 1.1.1 Responsibility for emergency response is assigned.

1.1.2 The response organization has the staff to respond and augment on a continuing basis (24/7 staffing) per the IOEP.

2.0 Onsite Emergency Organization: 10 CFR 50.47(b)(2) 2.1 Planning Standard Functions 2.1.1 The process ensures on shift emergency response responsibilities are staffed and assigned.

2.1.2 The process for timely augmentation of on shift staff is established and maintained.

3.0 Emergency Response Support and Resources: 10 CFR 50.47(b)(3) 3.1 Planning Standard Functions 3.1.1 Arrangements for requesting and using offsite assistance have been made.

4.0 Emergency Classification System: 10 CFR 50.47(b)(4) 4.1 Planning Standard Functions 4.1.1 A standard scheme of emergency classification and action levels is in use.

5.0 Notification Methods and Procedures: 10 CFR 50.47(b)(5) 5.1 Planning Standard Functions 5.1.1 Procedures for notification of State and local governmental agencies and MCBCP are capable of alerting them of the declared emergency within 60 minutes after declaration of an emergency and providing follow up notifications.

5.1.2 Administrative and physical means have been established for alerting and providing prompt instructions to the public within the EAB.

REFERENCE USE Attachment 15 Page 1 of 3

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~s Emergency Preparedness Program Maintenance REVISION 2 Page 82 of 89 Planning Standard Functions List Attachment 15 6.0 Emergency Communications: 10 CFR 50.47(b)(6) 6.1 Planning Standard Functions 6.1.1 Systems are established for prompt communication among principal emergency response organizations.

6.1.2 Systems are established for prompt communication to emergency response personnel.

7.0 Public Education and Information: 10 CFR 50.47(b)(7) 7.1 Planning Standard Functions 7.1.1 Coordinated dissemination of public information during emergencies is established.

8.0 Emergency Facility and Equipment: 10 CFR 50.47(b)(8) 8.1 Planning Standard Functions 8.1.1 Adequate facilities are maintained to support emergency response.

8.1.2 Adequate equipment is maintained to support emergency response.

9.0 Accident Assessment: 10 CFR 50.47(b)(9) 9.1 Planning Standard Functions 9.1.1 Methods, systems, and equipment for assessment of radioactive releases are in use.

10.0 Protective Response: 10 CFR 50.47(b)(10) 10.1 Planning Standard Functions 10.1.1 A range of Protective Actions is available for implementation during emergencies.

10.1.2 A range of protective actions is available for emergency workers during emergencies, including hostile action events.

11.0 Radiological Exposure Control: 10 CFR 50.47(b)(11) 11.1 Planning Standard Functions 11.1.1 The resources for controlling radiological exposures for emergency workers are established.

REFERENCE USE Attachment 15 Page 2 of 3

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~ ~ SONGS Emergency Preparedness Program Maintenance REVISION 2 Page.83 of 89 Planning Standard Functions List Attachment 15 12.0 Medical and Public Health Support: 10 CFR 50.47(b)(12) 12.1 Planning Standard Functions 12.1.1 Arrangements are made for medical services for contaminated, injured individuals.

13.0 Recovery Planning and Post-accident Operations: 10 CFR 50.47(b)(13) 13.1 Planning Standard Functions 13.1.1 Plans for recovery are developed.

14.0 Drills and Exercises: 10 CFR 50.47(b)(14) 14.1 Planning Standard Functions 14.1.1 A drill and exercise program (including, for example, radiological, medical, health physics) is established.

14.1.2 All exercises, drills, and training that provide performance opportunities to develop, maintain, and demonstrate key skills are assessed via a formal critique process to identify weaknesses.

14.1.3 Identified weaknesses are corrected.

15.0 Emergency Responder Training: 10 CFR 50.47(b)(15) 15.1 Planning Standard Functions 15.1.1 Training is provided to ERO personnel.

16.0 IOEP Maintenance: 10 CFR 50.47(b)(16) 16.1 Planning Standard Functions 16.1.1 Responsibility for IOEP development and review is established.

16.1.2 lndividual(s) responsible for IOEP development and maintenance are properly trained.

REFERENCE USE Attachment 15 Page 3 of 3

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SONGS Emergency Preparedness Program Maintenance REVISION 2 Page 84 of 89 Emergency Preparedness Program Review Attachment 16 1.0 REVIEW all program elements of the SONGS ISFSI Emergency Preparedness Program in accordance with 10 CFR 50.54(t) (refer to Step 6.1.11 ).

1.1 PERFORM the review using EP 54T or equivalent document.

2.0 PROVIDE a report with the results of the review, along with recommendations for improvement, to corporate (Chief Nuclear Officer and VP Decommissioning) and plant management (ISFSI Manager).

3.0 MAKE AVAILABLE to the state, local government agencies and Marine Corps Base Camp Pendleton the part of the review involving the evaluation for adequacy of interface with State and local governments.

4.0 ATTACH the completed Form EP 54T or equivalent document.

Comments:

PERFORMED BY: Date: _ _ _ _ __

Emergency Preparedness Manager or designee APPROVED BY: Date: - - - - - -

SONGS Manager, ISFSI REFERENCE USE Attachment 16 Page 1 of 1

..___ 2:,1 !J?.l~R~- EPP-2

~ Emergency Preparedness Program Maintenance REVISION 2

-~ =-

SONGS Page 85 of 89 Alert Media Test I Attachment 17 1.0 LOG INTO Alert Media.

2.0 SEND at test notification message to the SCE test group via text, phone call, AND email, requesting a return acknowledgement text.

3.0 VERIFY notification was sent and return texts were received.

4.0 LOG OUT of Alert Media.

5.0 ATTACH test report documentation to this attachment.

6.0 IF problems are encountered, THEN NOTIFY SOS to arrange for repairs.

6.1 DOCUMENT problems in CAP (create a new Action Request), AND RECORD Action Request number(s) in Comments section Comments:

PERFORMED BY: Date: - - - - - -

ISFSI Shift Supervisor or designee APPROVED BY: Date: - - - - - -

SONGS Manager, ISFSI REFERENCE USE Attachment 17 Page 1 of 1

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 86 of 89 Emergency Preparedness Training Program Curricu lum Attachment 18

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!:Q ISFS I Shift Onshift ERO 101 Supervisor/Emergency Director 7I01PQS X X X X X 4

Onshift ERO 102 On-Shift Securit Personnel X X X X Au mented ERO 103 Resource Mana er 7I01PQS X X X X X Onshift ERO 104 Non-lSS Erner enc Director 5 7I01PQS X X X X X SONGS Supplemental Supplemental X X Personnel Su X X

IOEPQM X X X LEGEND Calendar Lifetime 24 Months 12 Months Two-Year Notes:

[1] Personnel with unescorted access to SONGS ISFSI PA receive Plant Access Trai ning in accordance with ADM-30, Attachment for Initial and Requal Training , which includes general IOEP overview.

[2] Selected station personnel receive basic training in first aid (encode MT8216).

[3] SONGS or Non-SONGS Personnel who are brought in to assist with response , mitigating, or recovery actions, who have NOT received emergency planning training will receive Just-In-Time Traini ng, including training on radiologica l hazards, and Visitor/Escort responsibilities for personnel who are not badged for unescorted ISFSI PA access .

[4] Personnel qual ified for ERP 101 must meet ISFSI Shift Supervisor qualifications in accordance with ADM-30.

[5] Personnel qualified for EP 104 must also attain encode qualifications ISFONO, ISFSFP/ISFSFP1/ISFSFP2, and RPRT02/ISFRPT/RPTPQS in accordance with ADM-30.

INFORMATION USE Attachment 18 Page 1 of 1

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 87 of 89 Ownership of ERO Training Elements Attachment 19 PROGRAM OWNER: SDS [1]

ENCODE / QUALIFICATION DESCRIPTION SDS-TN1-RWT-0001 (SOS LMS) SONGS-Radiation Worker Training-CST [3]

and SDS-TN1-RWT-0001 _EXAM (SOS LMS) SONGS-Radiation Worker Training-EXAM [3]

and SDS-TN1-RWT-0001_EXAMACK (SOS LMS) SONGS-Radiation Worker Training-EXAM and ACKNOWLEDGEMENT [3]

SDS-TN1-RWT-0002 (SOS LMS) SONGS-Radiation Worker-PRACTICAL FACTORS r31 SDS-RP1-LPN-0001 (SOS LMS) Radiological Survey/Confinement Boundary Assessment and SDS-RP1-TPE-0012 (SOS LMS) Radioloqical Survey/Confinement Boundary Assessment SDS-TN1 -PAT-0001 (SOS LMS) SONGS-Plant Access Training-CST [3]

and SDS-TN1-PAT-0001_EXAM (SOS LMS) SONGS -Plant Access Training-EXAM [3]

and SDS-TN1-PAT-0001_EXAMACK (SOS LMS) SONGS -Plant Access Training-EXAM ACKNOWLEDGEMENTr31 PROGRAM OWNER: EMERGENCY PREPAREDNESS (SCE)

ENCODE DESCRIPTION 7101PQS ISFSI Shift Supervisor/Emergency Director/Resource Manager IEPERO ERO Responder N/A r41 General IOEP Overview (module of ISFSI Plant Access Traininq)

IOEPQM ISFSI Only Emerqency Planninq Qualification Manual 5054SE Performing Effective 50.54(q) I 72.44(f) Evaluations PROGRAM OWNER: SECURITY SCE)

ENCODE DESCRIPTION ISFSI Plant Access Training ISFSI Plant Access Training Encodes [2]

MT8216 Adult/Infant/Child CPR/AED/First Aid Note:

[1] Refer to SDS-TN1-PGM-0001, SOS Conduct of Training.

[2] Refer to ADM-30 , Attachment for Initial and Requal Train ing , for ISFSI Plant Access Training encodes.

(3) Refer to SDS-TN1-PCD-0007, General Employee Training

[4] General IOEP Overview is included in ISFSI Plant Access Training INFORMATION USE Attachment 19 Page 1 of 1

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 88 of 89 Summary of Changes I Attachment 20 Author: Lucia Sischo/Frank Grovich AR Tracking 50.54(q): _0_12_1_-9_3_2_23_ _ _ _ __

Reviewer(s) Step, Section, Reason Description of Change (by title or Attachment or division) Page 0221-71312 Added TransNuclear AHSM Confinement boundary 52 Compensatory measures.

0321-31454 Added that free play of participants should be considered during 38 scenario development.

Betterment Deleted EAB as example of a commitment to a particular program element in response to a site specific consideration . 77 0321-51851 Updated Attachments 18 and 19 to change ISFRAD to the SOS training designations 86, 87 Betterment Deleted reference to SCE LMS modules under SOS Radiation Worker and Site Access Training and Updated SOS training 87 designation 0821-68718 Updated called out RPA number. 46 0621-46955 Update Emergency Preparedness Manager Responsibilities to Section 2.2 match IOEP-1 0621-36110 Remove bullet for using sealed containers in place of itemized 20 inventory Remove column for sealed containers 61 0621-59239 Revise direction for Just In Time Training All 33, 35, 86 0621-26894 Add instruction to perform inventory of EP EKIL within 7 days of 41 , 44 use.

0621-68372 Clarify instructions for critique reports 43 0421-16247 Add APB-LPL-001, APB-LPL-002 , and 120V M30 Lighting Panel 52 to Emergency Equipment 0621-70963 Add line items for review 53 0621-48898 Clarify documenting in CAP to create new AR Attachment 3, 5, 9, 10, 12, 17 0621-70993 Add references to NRC letters for Emergency Plan exemptions 72, 75 and safety evaluations 0621-15902 Add instructions to EP Program Review 84 0121-93223 Add ERP 104 86 0721-74769 Add note for notifications to ANI during drill/exercise, and 38, 49 reference ANI Bulletin 1021-25662 Change SOS Training Matrix to SOS Learning Management 29 System Betterment Change cognizant supervisor to EPM 43 INFORMATION USE Attachment 20 Page 1 of 2

EPP-2 Emergency Preparedness Program Maintenance REVISION 2 Page 89 of 89 Summary of Changes I Attachment 20 Required Reviewers Name Emergency Plan 50.54(q) APPLIES Lucia Sischo Physical Security Plan 50.54(p) DNA Fire Protection 50.48(f) DNA 50.59 DNA 72.48 DNA Cyber Security DNA Nuclear Oversight DNA Procedure Owner or designee Lucia Sischo Other Reviewers Third Party 50.54(q) Reviewer Complete per L. Sischo Security Lucas Waldeck NRA Mark Morgan EP Manager Kelli Gallion-Sholler Approvers:

Cognizant Supervisor N/A for Revision CFDM / Designee Final Kelli Gallion-Sholler INFORMATION USE Attachment 20 Page 2 of 2

Enclosure 5 EPIP Summaries of Changes and Analysis

Reference:

EPP-2 SAN ONOFRE NUCLEAR GENERATING STATION REPORT AND ANALYSIS

SUMMARY

10 CFR 50.54(q)(5) / 10 CFR 72.44(f)

Document Number: EPP-1, Revision 2

Title:

Emergency Response Action Request #: 0121-93223 Change Description Analysis Summary The 10CFR50.54(q) evaluation for EPP-1 Revision 2 The changes do not contradict the licensing basis or the is covered under AR 0121-93223 assignment 4. emergency plan content. The changes do not modify the licensing This revision includes: basis with regards to a reduction in effectiveness.

Update of instructions for the Security Shift Notifications to ANI will be performed in accordance with the Supervisor to maintain control of access to current requirements, ANI Information Bulletin 11-01 (Rev.1),

include parking lots entrances. February 18, 2021, ensuring that the procedures for notification to

Update of information to reflect that American support organizations are properly described .

Nuclear Insurers (ANI) notifications are performed in accordance with their current The eastern portion of the Site Boundary is clearly identified as requirements. along Old Highway 101. This ensures the use of adequate

Clarification of the location of the Site Boundary methods for assessing and monitoring actual or potential offsite where additional radiological assessment at the consequences of a radiological emergency condition.

Exclusion Area Boundary (EAB) may be needed based on measured dose rates. Instructions for Security Shift Supervisor updated to ensure

Addition of a step to perform injury response per access to the site is controlled at the Site Boundary to include the form SE 911. fences, gates, and parking lot entrances, as directed by the

Addition of instruction to notify the hospital when Emergency Director. This ensures the ability to maintain a range contaminated injured individuals are not of protective actions for emergency workers and the public.

transported by Camp Pendleton Fire Department ambulance. Direction expanded to Marine Corps Base Camp Pendleton to notify the public located in the beach walkway along with already

Addition of direction for Marine Corps Base referenced protective actions beyond the SONGS Site Boundary, Camp Pendleton to notify the public located in the beach walkway in the event of an emergency but within the EAB. This ensures the ability to maintain a range of if protective actions are required. protective actions for the public.

Clarification of step to ensure just in time training References to ONO-1, Off-Normal Operations and SE 911, 911 is conducted for SONGS and Non-SONGS personnel brought in to assist with response, Emergency Response were included to protective action mitigation or recovery actions that have not response. This ensures the ability to maintain a range of received prior emergency planning training. protective actions for emergency workers and the public.

Addition of references to SE 911, Emergency Reference to SE 911, 911 Emergency Response, and direction to Response, ONO-1, Off-Normal Operations, and contact the hospital when contaminated injured individuals are not applicable security procedures for response transported by Camp Pendleton Fire Department were included in actions.

contaminated injury response. This ensures arrangements made

Addition of reference to ERP 104 position .

for medical services for contaminated injured individuals are

Addition of a step to notify other organizations maintained.

that may be providing on-site support of emergency termination and recovery initiation.

Adding the notification to other organizations that may be

Other editorial changes . providing on-site support of emergen~y termination and recovery initiation ensures general plans for emergency recovery and reentry are maintained.

Clarifying step to ensure training is conducted for SONGS and Non-SONGS personnel brought in to assist with response, mitigation or recovery actions that have not received prior emergency planning training and adding reference to ERP 104 position ensures that radioloqical emerqencv response traininq is EP SOA Rev O 08/20 Page 1 of 2

provided to those who may be called on to assist in an emergency.

The Emergency Plan continues to meet the regulatory requirements of 10CFR50.47(b) and 10CFR50 Appendix E, as exempted.

The changes do not modify the licensing basis with regards to a reduction in effectiveness. The procedure for notification, by the licensee, of emergency personnel by all organizations is in place.

Methods, systems, and equipment for assessment of radioactive releases have not changed. Protective actions developed for emergency workers and the public remain in place. Arrangements for medical services for contaminated injured individuals have not changed. General plans for recovery and reentry are in place.

Radiological emergency response training is provided to emergency responders. The capability and timeliness of the applicable functions are not altered by the changes. The capability and timeliness to perform the associated elements are also maintained.

The chanQes can be implemented without prior NRC aooroval.

PREPARED BY: Michael Kish/Lucia Sischo REVIEWED BY: Kelli Sholler DATE: 02-07-2022 DATE: 02-08-2022 EP SOA Rev 0 08/20 Page 2 of 2

Reference:

EPP-2 SAN ONOFRE NUCLEAR GENERATING STATION REPORT AND ANALYSIS

SUMMARY

10 CFR 50.54(q)(5) / 10 CFR 72.44(f)

Document Number: EPP-2, Revision 2

Title:

Emergency Preparedness Program Maintenance Action Request#: 0121-93223 Chanae Description Analysis Summarv The 10CFR50.54(q) evaluation for EPP-2 Revision 2 The changes do not contradict the licensing basis or the is covered under AR 0121-93223 assignment 3. This emergency plan content. The changes do not modify the revision includes: licensing basis with regards to a reduction in effectiveness.

Clarification of the responsibilities of the The Emergency Preparedness Manager responsibilities listed in Emergency Preparedness Manager. the procedure aligns with the language of the Emergency Plan.

Removal of system of sealed container usage vs.

actual performance of item-by-item inventory. The system of sealed containers was removed because it is not

Update of instructions on training for personnel used for the Emergency Kit.

brought in to assist with mitigating or recovery actions who have not received emergency Instructions on training clarify general statements regarding Just planning training. in Time training and the language aligns with the Emergency

Addition of note indicating that notifications to ANI Plan.

during drills and exercises will be performed in accordance with ANI Information Bulletin 11-01. The change to ANI notifications account for revisions to the

Addition for drill scenarios to consider free play for information bulletin and ensure that ANI requirements are met.

participant decision making.

Addition of notifications to ISS or designee to Addition of free play verbiage enhances the procedure to ensure perform EP EKIL inventory within 7 days of use. the appropriate level of realism is met for drill participation.

Relocation of the instructions for the critique report The changes to notify the ISS or designee to perform inventories to one section; clarification of the content of ensure required inventories are not inadvertently missed.

critique reports for the Biennial Exercise and the alternate year Integrated Drill; addition of The changes to the critique process enhance and eliminate instructions for abbreviate written critique reports ambiguity to the overall process. These changes ensure that drill for other drills involving the evaluation of related requirements are addressed and completed properly.

designated objectives; replacement of instruction to complete a draft critique report with instruction to complete a Management Critique Meeting prior The addition of Transnuclear Canisters ensures appropriate compensatory measures are taken when work that requires to the NRC exit meeting; removal of instructions ASHM door removal occurs. The compensatory measures in for review of the findings by Nuclear Oversight.

place will continue to meet the applicable regulatory requirements

Addition of Transnuclear canisters as Emergency of 10 CFR 50.47(b)(4), 10CFR50 Appendix E Sections IV.B.1 Equipment, including compensatory measures if and IV.B.2. The activities will render one EAL E-HU1 .1 evolutions are performed that require removal of a component unavailable for a period of time for that specific Transnuclear Advance Horizontal Storage Module canister, but the compensatory measures taken will ensure that door.

the intent of the EAL basis is sustained during the time and that

Addition of equipment and compensatory the licensing basis with regards to meeting the regulatory measures regarding Power Distribution Panels requirements is maintained.

associated with non-essential power in the ISFSI and power to ISFSI internet resources.

Addition of Distribution Panels ensure that the equipment is

Clarification of the annual Emergency Plan review considered, and compensatory measures are put in place when it by adding steps to ensure changes identified becomes nonfunctional.

during 10CFR50.54(t) reviews, assessments,'

training, drills, and exercises are documented, The changes to the annual Emergency Plan review ensure the incorporated or are being tracked for proper implementation of the Emergency Plan by providing incorporation. detailed instructions of what is expected during the annual

Addition of references to NRC Letters. review.

Removal of example discussing the employment of an EAB to satisfy the 10 CFR 72.106 reauirement for a 100-meter minimum distance EP SOA Rev 0 08/20 Page 1 of 2

from the spent fuel in the ISFSI to the Site Referencing NRC Approved Exemption letters enhance the Boundary. procedure, as they can be used during the identification of site-

Clarification of how the requirements of specific commitments.

10CFR50.54(t) reviews are met in regard to making the review available to senior SCE Removing the example regarding the 10 CFR 72.106 Management as well as associated outside requirement aligns with the latest revision to 10 CFR 72.212 agencies evaluations, since the 10 CFR 72.106 requirement is now related

Addition of training requirements for on-shift ERO to the 100-meter minimum distance from the spent fuel in the non-lSS Emergency Director position. ISFSI to the Site Boundary.

Update and clarify training encodes and description as training is being provided by The change to the 10CFR50.54(t) reviews ensures regulatory SONGS Decommissioning Solutions (SOS). requirements are met.

Other editorial changes.

Addition of new ERO position is in accordance with the Emergency Plan, as it states that if the ISS is unavailable or incapacitated, another on-shift person qualified as ED will assume the ED duties. This change does not contradict the current emergency preparedness training program curriculum and acts as an enhancement to the current curriculum.

Training encodes and description changed to align with SOS verbiage, but training content has not changed.

The Emergency Plan continues to meet the regulatory requirements of 10CFR50.47(b) and 1 0CFR50 Appendix E, as exempted.

The changes do not modify the licensing basis with regards to a reduction in effectiveness. The standard scheme of emergency classification and action levels is in use and has not changed.

Adequate facilities and equipment to support emergency response have not changed. Methods, systems, and equipment for assessment of radioactive releases have not changed. The drill and exercise program (including radiological, medical, health physics, or other program areas) is established and has not changed. All exercises, drills, and training that provide performance opportunities to develop, maintain, and demonstrate key skills continue to be assessed via a formal critique process to identify weaknesses. Training is provided to emergency responders. The responsibility for emergency plan development and review is established. The capability and timeliness of the applicable functions are not altered by the changes. The capability and timeliness to perform the associated elements are also maintained.

The chancies can be imolemented without orior NRC approval.

PREPARED BY: Michael Kish/Lucia Sischo REVIEWED BY: Kelli Sholler DATE: 02-07-2022 DATE: 02-08-2022 EP SOA Rev 0 08/20 Page 2 of 2

ML22066B023

Contents

Text

1.0 INTRODUCTION

SUMMARY

3.0 REFERENCES

1.0 INTRODUCTION

SUMMARY

3.0 REFERENCES

RESPONSE

1.0 INTRODUCTION

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9.0 REFERENCES

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9.0 REFERENCES

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1.1 Category

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SUMMARY

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