ML23353A174

ISFSI, Emergency Plan, Revision 23-04

ML23353A174
Person / Time
Site:	Indian Point
Issue date:	12/19/2023
From:	Noval W Holtec Decommissioning International
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
HDI-IPEC-23-049
Download: ML23353A174 (1)

Text

HENNE Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

HDI-IPEC-23-049 10 CFR 50.4(b)(5)

December 19, 2023

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Indian Point Unit Nos. 1, 2, 3 and ISFSI Provisional Operating License No. DPR-5 Renewed Facility License Nos. DPR-26, and DPR-64 Docket No.50-003, 50-247, 50-286 and 72-051

Subject:

Indian Point Energy Center Emergency Plan, Revision 23-04

In accordance with Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Section 50.4(b)(5), Emergency plan and related submissions, Holtec Decommissioning International, LLC (HDI), is submitting Revision 23-04 to the Indian Point Energy Center (IPEC)

ISFSI-Only Emergency Plan.

The Emergency Plan was updated because of changes associated with implementing the Indian Point Energy Center (IPEC) ISFSI-Only Emergency Plan. The changes were evaluated as required by 10 CFR 50.54(q) and do not decrease the effectiveness of the Emergency Plan.

The evaluation and the Indian Point Energy Center ISFSI-Only Emergency Plan Revision 23-04 are provided in the enclosure. This letter and the enclosed evaluation constitute the summary of analysis required to be submitted by 10 CFR 50.54(q)(5).

This letter contains no new regulatory commitments.

If you have any questions or need further information, please contact Mr. Walter Wittich, IPEC Licensing at 914-254-7212.

Sincerely,

William Noval Director, Regulatory Affairs Holtec Decommissioning International

Enclosure:

Indian Point Energy Center ISFSI-Only Emergency Plan Revision 23-04 and 10 CFR 50.54(q) Evaluation

HENNEHENNEHOLTECHOLTECHOLTECINTERNATIONALINTERNATIONALINTERNATIONALDECOMMISSIONINGDECOMMISSIONINGDECOMMISSIONING HENNE Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

cc: NRC Region I Regional Administrator NRC Senior RegionalInspector NRC Project Manager, NMSS DUWP RDB New York State Department of Public Service President and CEO, NYSERDA

HENNEHENNEHOLTECHOLTECHOLTECINTERNATIONALINTERNATIONALINTERNATIONALDECOMMISSIONINGDECOMMISSIONINGDECOMMISSIONING HENNE Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909

Enclosure to HDI-IPEC-23-049

Indian Point Energy CenterISFSI-OnlyEmergency Plan Revision 23-04

and

10 CFR 50.54(q)Evaluation

HENNEHENNEHOLTECHOLTECHOLTECINTERNATIONALINTERNATIONALINTERNATIONALDECOMMISSIONINGDECOMMISSIONINGDECOMMISSIONING NON-QUALITY RELATED IPEC-EP Rev. 35NON-QUALITY RELATED IPEC-EP Rev. 35NON-QUALITY RELATED IPEC-EP Rev. 35 IPEC Emergency Plan DOCUMENTIPEC Emergency Plan DOCUMENTIPEC Emergency Plan DOCUMENT

[SN INFORMATIONAL USE 23-04INFORMATIONAL USE 23-04INFORMATIONAL USE 23-04

Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center

ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Prepared by: Robert Suneson CL) jefe /Z%Prepared by: Robert Suneson LX) v2A /75%Prepared by: Robert Suneson LX) _ velo /753 Print Name Signature Date Print Name Signature DatePrint Name Signature Date

Approval: Matthew Johnson A / A/.z3Approval: Matthew Johnson EP /zpA /.z3Approval: Matthew Johnson = p. / wy 5 Print Name Signature DatePrint Name Signature DatePrint Name Signature Date

Effective Date: ¢hfEffective Date: _¢Alex

Effective Date: 7Ls ES Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Table of ContentsTable of Contents Table of Contents PagePagePage Partl: INTRODUCTIONPartl: INTRODUCTIONPartl: INTRODUCTION Section A: PUIPOSE......ccociinnneriissnntiscsessasessenssrsessestsnassssssnssasssensssnsisssnstnnssssassassesesans 1Section A: PUIPOSE.......cccciiriinmenintiiniissssensasssssssasesisssnsansasisanssssssssssnsassassasssssssssanassasnes 1Section A: PUIPOSE.........occ irc crcreissseastase tis sss se sant earners sess tn satan sans ane sna a ramen 1 Section B: Background...........cccueinnnenemmininniinsesisssnsnesenessssssssssnsssnnnmsessssssssssssssnsrresresss 1Section B: BacKgroUNd......cceeeeciiniimiiernmmensensiaisisninianianmsesssiamiseimsissressssssasssronensnnsrssnee 1 Section B: Background.........ccccueerecscnsmniereensssensensenninmssssssssssssassessansssssnsansensinsensessases 1 Section C: SCOPE....cicciiiiccrcemeeriniiireiisisissnneeneersesssssssnsnsesiesssossssssassanstssasasssssssssnnsassanes 2Section C: SCOPE....icciimimieiiiimmicrerrirniininniserisenses seersisssssasssssessssssssasassasssnsssssasanessssassansas 2Section C: SCOPE....oiciiriemremrarrenrenrenrentennemressesnmenmsnmarantasnnssasrassasssasssssatssesassassasssssnesnesns 2 Section D: Planning Basis.......ccccccvrvirrircnnnscesnissssssscessastasssasssssesssssstnsasasssassensaansassenas 2Section D: Planning Basis.......ccccccmrrerrreriisinnneniniicsccssssnssesssnsnensssssssssssassessnssssssasssnnas 2SectionD: Planning Basis.....cccccomirirmciicircmeie nineteen nie sesssseen n anesenas2 Partll: PLANNING STANDARDS AND CRITERIAPartll: PLANNING STANDARDS AND CRITERIAPart ll: PLANNING STANDARDS AND CRITERIA Section A: Assignment of Responsibility........c.orceerrsrsnneinnsccsnnressrenssnssscsnasessesen A-1Section A: Assignment of Responsibility........ccceicrccnneriressssninscessnectasescancsaniesennease A-1Section A: Assignment of Responsibility.......c.cccccciiiirirsccninreisimsirnsssnseserennnesenses A-1

1. IPEC Emergency Response and Responsibilities...........ccccceeeeeeeeeeeeeeeicvieeenennn. A-11. IPEC Emergency Response and Responsibilities.........cccccceerereeverrnnnrneeneieeiennens A-11. lIPEC Emergency Response and Responsibilities.........cc.crvercurerrvnnericrrenioniannens A-1

2. Offsite Response Organizations............ccuieiiiiiiiiiiiieiieeeiieeneeeeeeeeeceseeeeeeeesseseennens A-22, Offsite Response Organizations..........c.coceveueiriierierieeeerieerennaeereeeeeeesianiaaaseenes A-22. Offsite Response Organizations..........cccccviiieeriniiiiiniieeeeieneeeseeeeeeeeneessssessssnsssens A-2 Section B: Emergency Response Organization..........cccceuecccmsincisacncnreisessncasnncanns B-1Section B: Emergency Response Organization.........ccceressecsecansasseneansascisossennsensens B-1Section B: Emergency Response Organization..........eemmeeneeceneesreeerereecncanns B-1

1. IPEC Emergency Response Organization.............cccccceeverreeereccriineneeeeeesaesaenanns B-11. IPEC Emergency Response Organization.........cc..cocoieeiviiieuiiiienineeeniennnninenenns B-1

1. IPEC Emergency Response Organization.........c.cceeveeiceriiiiiiiniciiconinncnicnncnnennn B-1 1.1 On-Shift POSItIONS........ccooeiiriiieeeeircrcciiereereesies ssernnresresaeeseesessnressesssssas B-1 1.1 On-Shift POSItIONS.......euueueeruurrrererrriinurnusranrerramerrermerrerrermerm...... B-11.1 ON-Shift POSITIONS........ceeeereririeeiierie ieee cere eeeer aeatessaeaeeaeeaees B-1 1.2 Augmenting ERO......ocuuuiiiiiiiiiiiiriiernnieerieriereareesearereereesemsemsmereeesensennsnsenne B-21.2 AugmentingERO.......cooiiiirrieiiiincicnereneeeiesreesessnaneeresssssossssssarasnessssssases B-21.2 Augmenting ERO o.oo eae B-2

2. Offsite Emergency ASSIStANCE..........cvveiviiiiieiiiiieiieeeeeeeeeeee reer eeeeeeeeeasessessesee aera B-32. Offsite Emergency ASSISTANCE.......ccoceveeruirriiitiniiiiininniercrsissesisossnmsresessniesiesens B-32. Offsite Emergency ASSIStANCEe.......c..coverurirrieiieiieicrirrereere eres revareere sees sessessnnenns B-3 Section C: Emergency Response Support and Resources.......c.coevevmeinnirnrininan: C-1Section C: Emergency Response Support and ReSOUrces.........ccceureeserrecsnnnsaes C-1 Section C: Emergency Response Support and ReSOUICES..........cccseseesrisensseseans C-1

1. Support Provided by Local Organizations...........c.cccccvevinvveinnnennennennnene see eeeeeeas C-11. Support Provided by Local Organizations........ccccccevveveieiieeeiineiinneeeeeenneneeenneneenn, C11. Support Provided by Local Organizations.........ccccceeeveeieiieiieniinienienneneeeneeeeeneenen C-1 1.1 Law Enforcement...........eueeiriiireetnstansinsessaenaetasnesseeresronsannssrans C-11.1 Law Enforcement... eeeieieeiiereieetrereereereeeeererere eer ereerenteeeenenre ansaseaneC1I TO OF Y= {oo= 011-01 SEE C1 1.2 AMDUIANCE SEIVICE.....cevvvernneiieiiiiirerttisieeeeeieerrrrenrannessesseseesranmesnossessans C-11.2 AMDUIANCE SEIVICE.....coevvierieieierieereriiereeranseerereereerressnsneseesesesssnssnnnnnenees C-11.2 AmDbUIBNCE SEIVICE.....cccoiiiiiiiiiiiie eres ee eeveeseen eesae sane ean amnenaes C-1 1.3 HOSPIAL cocci cree ssrereerenreere seers seer eee sre sree ese nee nessa essen ens C-11.3 HOSDIAL....coe iirc cree caer esse rser ae seesaa reese erases sees rans aesans C-1JRCTN[oo] l OO SSPRRPUPR C-1 Ti Friis secre sees ae tesserae essere eee se senna esses sna aeeaas C-1Tid BIB. ete essere essen senna ee saa nessa reese re seer anne sane ean C-1Tid FEE eres sree sees sess ra ba nee re ee ene ean C-1

2. State and County (Local) Government RESPONSE........ccceereeeeeerrrmeriereerereeeresnens C-12. State and County (Local) Government Response..........ccccccevvivevreeniceinnceneeneenn, C-12. State and County (Local) Government RESPONSE..........cceeieereeiceicneereirenieenennens C-1

3. Federal Response Support and ReSOUICeS........ccvvvveveevieiieiieee cece, C-23. Federal Response Support and RESOUICES.........cccevveerrireeiriererreeneenieneininnennennen, C-2

3. Federal Response Support and RESOUICES........cccccviiriiiiiiieeieeneeneenenneeneenenneenens C-2

4. Letters Of AQreemEN.......ccccoiiiiiiiiiii erence rss ree re errr see ae seessense reneens C-2

4. Letters of AQrEeCMENT.......ccoovievieiiiiiciiiii iieererterenrneererereererrersssnnneresreeesnassnnnnnnnens C-24. Letters of AQreemeENnt..........ccccoveriiiiiieiiiiirirreer cericisseraereetesisessrsnrennessessassessnnans C-2 Section D: Emergency Classification System......cccccceireeeiisssncnnnnnnnienisssssscesennens D-1Section D: Emergency Classification System........cccccvcenrencernssennarmessseneemmereennnnens D-1

1. Emergency Classification System..........ccoouvrrirriiiiiiiiiniiiiieiicciieceeerneeeeereeeeeeeeen, D-11. Emergency Classification SysStem..........cocoiiiiiiiiiiiiiiiiiiiiiicniccrcnrecieereereeree reereenens D-1 1.1 UNUSUAL EVEL... cirri cence rrr seers sece sere sameness smraas es naas D-1OO 1(N= = l US D-1 Fi2 ALBIeects resets ete e sear a essa eae esas ese ae eee snae ees aneeanD-2T.2 AIH... resets ress nr esses sates assesssaneassessant asians D-2

2. Emergency Action Levels and Postulated Accidents..........ccccoeeeveriniieieenienennnn. D-22. Emergency Action Levels and Postulated Accidents........c.coccevcriieieniieicenceens D-2

3. State and Local Governmental AULRONLIES..........ccceeeeereereeeeeeeeeneeeeeeeereeeereereeeeee D-33. State and Local Governmental AUthOTItIES..........ceeveeieerenreerenieereerereenreeneeneereeeens D-3 Section E: Notification Methods and Procedures................. 4eeecasmansessansennannnnnnanne D-1Section E: Notification Methods and Procedures..............ccceeeiemneniesencinencarncannenss D-1

1. Basis for NOIfICAtION.........euvvvieiiiriiiiiiierieriririirerererreereerereeereeeerseneeesreeeressensseensens D-1

1. Basis for NOLIfICAtION..........ceviieeriiiiiieiieieiiinieiiirreereereereereereerrereeresreereeresrseressessens D-1 1.1 Initial NOtFICAtION......ccceeereereeee nrcccrereererecerceerrre esse esses ennnenee esses snnes D-1 1.1 Initial NOtifiCatiON.......ccoeerrmrireeriricccrrrrerr rere rerrreere reer ress rarer reese reeeees D-1

ii 23-04

1. Emergency Classification SYStemM..........cooovviviiriieiieiieiiee rere D-11. Basis for NOIfICAtiON...........eeeeneecririetrerrrrerrerrerrerrerreI TO 1 = 1 To (1 oz1Uo PUPP POP D-1I EO VETF l = 0) US D-1Section E: Notification Methods and Procedures.............c.cccamsansannaesearcssenrnesannes D-13. State and Local Governmental AULhONLIES..........ccciviiieriiiieriririirieriiceeens D-3Section D: Emergency Classification System........cccccciciienneeneciecinnnnnnnnsenccnnnnnee. D-12. Emergency Action Levels and Postulated Accidents.........c..cccooviierierieiiniccinnns D-2AZ ABH.oer retreat sae east e een r amenaaaa e eeennennnnn D-2arsesererretrseres rearereeas D-1 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

1.2 FOlOW-UD MESSAUES.....euuvuremrrmnnereermrmmemeeeeeterereeerereeeeseseesasessssessssnsrasssnns D-2 1.2 FOlOW-UD MESSAGES.......ccevveereerieiierieriniieeieeereierreeraeeeseesserertannaeseesaesssnes D-21.2 FOlOW-UD MESSAGES.....coccovurrieeecrnnrerierranteeeneisneeseesssseesessssseneesessssnansasses D-2

2. Notification Of the NRC.........oeeereeiiieireeeereieeirrrrireseserrerasressssssssssssesossrasasasssnes D-22. Notification of the NRC.........eeeiieirieicecrrcrrereerreeeecrennreeee er ereesessssstssesreasesssanen D-22. Notification of the NRC............o eerie teres teeaeeae sensenenneennes D-2

3. Notification of the IPEC ERO.........cocicvirierniirieecrenneesnereenneseseeeseseseeseseeseneesns D-23. Notification of the IPEC ERO..........oooiiiieeeeeee eee eeeeevee eee aan D-23. Notification of the IPEC ERO...........cuvuerieeieeiemierieerrrersrereereseesssersmsmmsesesssesssssseses D-2 Section F: Emergency Communications.......ccccrirercarnersassanessssssansssssssnersessnsssssse F-1Section F: Emergency Communications.......ccccceieereremmcrirnrcrerssssmsmnemrnsesssssessennes F-1Section F: Emergency Communications.........ccccusseneans sesessasessssnnsaesssssensenes F-1 Section G: Public Education and Information............ GreressresAreEIANSRLSS ISLES TER ER LER SEESG-1Section G: Public Education and Information.........ccccccciiniincnncnnnmnonmese G-1Section G: Public Education and Information.........ccccececcccnmmunnnnnecssccsssennaannennecnes G-1 Section H: Emergency Facilities and EQUIPMENL..........cccieerrrsrensassneessansassenneseans H-1Section H: Emergency Facilities andEquipment.........c..cccieciiinninemmrnnnnennessansennne H-1 Section H: Emergency Facilities and Equipment............cccoccerererscnncreccssncereessonnes H-1

1. Emergency Response Facility.........cccceeeeeeeeeeiiieeeeeeeceereee1. Emergency Response FacCility..........ccooovviimiirerriiiccceceerreeecee cerrereee eee snrenneeee H-1

1. Emergency Response Facility..........cccc.ooveoiiiiiie eee H-1ees eeesernnnneeeeeseeseenenns H-1

2. Emergency Equipment and SUPPLIES.......cocervviieiruirmruieiinivieenieteessinesiereesseesnne H-12. Emergency Equipment and SUPPIES........ccccerereeiiierrciiiinrrereeereseceeeeaveeeeeeseenenes H-12. Emergency Equipment and Supplies..........cooooeeeieiiieiiiieeeeeea H-1 2.1 Portable Radiation and Contamination Monitoring Instruments............. H-12.1 Portable Radiation and Contamination Monitoring Instruments............. H-12.1 Portable Radiation and Contamination Monitoring Instruments............. H-1 2.2 Communication SYSEMS.......cccieiiiiireeiieireririeerecreates ees seermeenesses seseaanaeH-12.2 Communication SYSTEMS.......uceiiieieiiieiecee cece eerie seers eer re serena H-12.2 Communication SYSIEMS.......ccoieeeciicerieeeereeeccrrereeeesee sesreernrereeeeeseeas H-1 2.3 First Aid FaCility......coovvmviiiiiiieiien iene eer H-12.3 First Aid FACIlity........cccouureerreemeeeereneeerermresseereseeeesseeesesseeeeesmmmeessseereesmmsnnes H-12.3 First Aid FaGility.....cocceerereirnnirrimrereereeiennonreneenesieeensnesessssssssnnnsensesessosssene H-1 2.4 Emergency SUPPHES......ccuuuiviieiireeierreeieiiieiesieeeeseieseereesesssnsisnsesssessessens H-22.4 Emergency SUPDIES........ccuuiieieereeerrmeeriiiitiieeetieeeereeeeseeeeererereseessesseesenene H-22.4 Emergency SUPPES........ocoouiiiiiiei eee H-2 Section I: Accident ASSESSMENL........cccuicnnriscrcrnsinssssrnsasssssassssssasssasssnssasessassassssnes1-1Section I: Accident ASSesSSment............cccciiinnniniscsnnresssessnsssesssssssessssassssssssossanessI-1Section I: Accident Assessment............ccccimiiiiiciinieenener 1-1 Section J: Protective ACtions.......ccvmiiertiiriiicsccsnnnnicisassscnnnnsnsesssssssassssresssssasensannesJ-1Section J: Protective ACLiONS........ccccveicrrccriisisssnnnisssssssssnesssssansssssssnsessessssssssssssnaseJ-1 Section J: Protective ACtIONS......c..coucireiimrimreccriremer ser ser ser ses sss sense assassin narra nerar aennJ-1

1. Notification of On-Site PEersSONNeL............ueueevereerermreereireriereeeeereeenereereerensesseesaeronns J-11. Notification of On-site Personnel...............oocoiiieiieieee eee eee J-11. Notification of On-site Personnel...............couorieiiiiiiiiiiiiiiniiniieieeneeeeneeeeesneerreeneenen J-1

2. ACCOUNLADIILY......cceeeririeiieeieiiiieeAR.Yololo1] l £=]<<1 14S J-12. ACCOUNEADINIEY..... cee ieee eee eaes J-1ie ereererrine eer eereenr seer eerasnasesenrassnraeserannnsseerennsnnns J-1

3. Personnel and Visitors Located outside of the ISFSI Protected Area................ J-13. Personnel and Visitors Located outside of the ISFSI Protected Area................. J-13. Personnel and Visitors Located outside of the ISESI Protected Area................ J-1 Section K: Radiological Exposure Control.....c..cccceuuccererrnccsesssenanssescassaessssonsascene K-1Section K: Radiological Exposure Control.........ccccccsieeeecisicscnnsnnerssnassssssascossassssnae K-1Section K: Radiological Exposure Control..........ccccieniiamnnnnnnannnnnensennee. K-1

1. Emergency EXpPOosure GUIAEINES..........uuueemrmmemerrerereeeimierimiaeeeiesianassssessseesesensnnes K-1

1. Emergency Exposure GUIdEliNES.............ceoririeeiiieiieiiierieeeerrerieneeseee ener K-11. Emergency Exposure GUIdeliNgS.............eeeeermrererreeeemeceemmmeeeermeceersmnimmseesmmmmmmmnne. K-1

2. Radiation ProteClioN..........ecuuerrirerereeriarenmerrseressreereerererrnnnnnnnsssssssrsereseerennnnsnnenss K-22. Radiation Protection...c.count eee eer K-22. Radiation Prot@Clion..........cccevritruuieirieieerrereemmnierieeasrerrsansosessssseassssensansessssssssanse K-2

3. ACCESS CONIIOL......cceiieiieiiiiiiriiiiieertiererenree eerneareeeeeeranneressetntansaseseennsnnsssennnnnn K-2

3. ACCESS CONIIOL. eure etree eee essere eee nea K-23. ACCESS CONMIOL.....ccceeiiiiiiiiiiieiiicierierirrereereeterereereseeseeteeseareeeeereerearerreareaneenseneanenes K-2

4. Personnel EXposure MONIOMNG.........ccccecevririerimimnrrnereiernereseerecesseeceressssessssassans K-24. Personnel EXposure MONItOTING.......cooiveviviieiireruiieeierieiesees esseaesereennasseeranns K-2

4. Personnel EXposure MONIOMNG.........cccccivueereeeeeeerensrinreseereeseesaesssssssensesssssanssnne K-2

5. Personnel Contamination Control......eeereteetsreerteeeeeeeeeerastettteatettniroenssssesarsrtrrnnne K-25. Personnel Contamination CONtrol...........eeueeeeeeeeeeeeemeerieimreeeeeeeeeeneereeeeermessereeneen K-25. Personnel Contamination Control............coieiieriirierieiiciie ricerca eee eee K-2 Section L: Medical and Public Health SUPPOTrt........c.cceivnemerrirecniscnnnrnsinecesssnnnnn L-1Section L: Medical and Public Health SUPPOTt........ccccceceiscnniressacnnsiessannanessssannne L-1Section L: Medical and Public Health Support..........cccocimiiiiimmmrtiniieanine L-1

1. ONSItE FirSt Aid.......eevvveererrerrrrerierieeieereereeeeeteseesmrmeeereessssteseesrsssesrsrsmssssesssessssssnes L-11. ONSIte First Aid.......uuuiiiiirieeeeiiereierrerereereeeeeeteeeeeeeesesseesessessssssssssssnsnnsssnnnnnnnes L-11. OnSite FIrSL AIL <<....ooeniieiiiiier ieee erie reer isetaaraeraa esas arses arraen veraneann sae rnnn ns L-1

2. Medical Transporation............ccocciieiieeeiicrerecrrrrerrrereerreneveeseseseseeessssnsrassssaones L-12. Medical Transportation.........coeeivuiieiiiiiie irene erreieese er restr ess rer sree recnesreeransL-1

2. Medical Transporation............ceeeeeeeeereererereenerrrmrmeerermeesrreresereeeermmessmmreeesrsessssssess L-1

3. Offsite Medical SUPPOH.........cooieiiiereieereirrernernneenennrennrrresrersesreerseressesassasesaenes L-13. Offsite Medical SUPPOR.........ccueererrreremrerrereenrereenmereeeeeeeeeesmeeseercesssresmmeresmrereerseressL-13. Offsite Medical SUPPOH......c..cooii ieee eer ee recreate reer eee ree ceer casas cas sacnans L-1 Section M: Re-Entry and Recovery Planning.......cc.cccierisvinneninsrmsssasencansmmemesssssnsennsM-1Section M: Re-Entry and Recovery Planning........cccecesereesesnsnncnesccnnassassnnassecsennsesM-1

1. RECOVEIY OPEIAtIONS.......uuuvverirrireirrnrnennenssnnnnneeeeateareeeeeeeesiesrssesasssssessersnssasnsnnee M-11. Recovery Operations........cccccvvuvruieirieieireereenenrreerierseseessnsansssssesesrenssssanssnressenses M-1 Section N: Drill and Exercise Program........cccccceressssesssssssnsssensnannansensnnenssmsnasnsnsnns N-1 Section N: Drill and Exercise Program........ccueecseeessecnsnsccscssrssssssssssonssssassassssssasas N-1 A. EXEICISES ener cece renters erence reser bases a seas e sass aa seer r anne N-1 J. EXEICISES eects sss ce sees enananessseaeeseesasusensssssssssseanrananersssessenes N-1

2. DIS...coo ii cereeeeecteererecrerrecsres ee sesitee ese sesstes ens nn neersrama e eee s bees asesbesaasssras as reves asasase N-12. DIS....evveereerereeiecrireeeeeiriteeeecrrtee sess ser esasssne eee ssernnreesssssetassssraneasassannesasssrartens N-1 2.1 Equipment and Proficiency DIillS.........ccocceevreverriiniirenniinnenenreresreneenneens N-22.1 Equipment and Proficiency Drills.........ccccoviererririnnicncreericrnnercrseneessennenee N-2

iii 23-04iii 23-04

1. Recovery Operations..........oooiiiiiiiii iii eee eee eee easeee eee ener ete ee eee eee enesnananM-1l SPR N-1iii 23-04Section M: Re-Entry and Recovery Planning........cccoeeeeieiimimennmiiniinnissnenisiinnn M-1Section N: Drill and Exercise Program.......c.cccccsessemssersenseseensensiesensessanssesansansansan N-12.1 Equipment and Proficiency DrillS..........cccoociiiiiiiiniiiiiiiniiineena N-2A. EXBTCISES <<cen ieee eect eee eer teeta teen arte a rar at etna ea araan N-1 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency Plan ISFSI-Only Emergency PlanISFSI-Only Emergency Plan

3. Critique and Evaluation.............ccevvvvievieiieiieiieeieiieeeeiierierieeesesesrerseeessmsnssescesersesn N-33. Critique and EVAIUALION.............cooirieiiiierieerrr rere rrrareee aaa ee eeeraemranne eaneaes N-3

3. Critique and Evaluation..........ceeeeeereeeerieeieeieeieeeeereeerereneeeneeseessessssssessressssssssssssens N-3 Section O: Emergency Response Training......cccecreienmmmmsnmeicsineasesssnserssssssnsarsosanns 0-1Section O: Emergency Response Training......ccccceraernearsnsnnccsssansessancescssssssssneeseess 0-1Section O: Emergency Response Training.......ccccccicirairerninnensessassrsnnnernmsnmsesinsrennns 0-1

1. Emergency Response Training........cocovuiiiiuoiierieeeciieecaiae ees ee een eecans ennaneemnaneenns 0-1

1. Emergency Response TraiMiNg........cccocereerimrmmmureerarreeraniaeeenisesseesessesasssssaseeseenes 0-11. Emergency Response TraiNiNg........ccccceverereeeeremrereanmasmesensrensmssessonnsssnsnssssnsessenns 0-1 1.1 ERO Training (ISFSI Shift Supervisor/ Emergency Director and Resource1.1 ERO Training (ISFSl Shift Supervisor / Emergency Director and Resource 1.1 ERO Training (ISFSI Shift Supervisor/Emergency Director and Resource MANGE)...eeireeeeiieieeieciireeeerer esessrsreeeeessessessesssssssassassessessessasssnnasaessassassssnnnne 0-1MANAGET)..... cei eee eee reese estes trata ar aera ears tiburon aaeeesersararansnasnsassareans 0-1MANAGE)......eeeirieeiiiieecerirrtrrreeeresreeresttsesessessessssssssassssneseessesssssassssnssasssasansesssnnes 0-1

2. Support Organization Training..........ccccccevreerereereererrrrererrrrrresrsssssressessessees essen0-22. Support Organization Training........cccceeeeeierirrrirrerieeierecrerrrererreeereseessssssssssseessess 0-22. Support Organization TTaINING.........cc.euvrereiiriieiireieereiieireirarreire.. 0-2

3. Training RECOTAS.......coiiiireiieieeiiceieeieereerettnsieieesessesrassnsisssessessesessnnsnseresseerensanas 0-33. Training RECOMAS........cccoeeeeeeereiererieenreeeerrenessrenersresersrenssnseersnssnnsnnnnnnnsnsssnsnnsssnnns 0-33. Training RECOIAS...... uci ieee tease ae eeee eres ban ena easananns 0-3 Section P: Responsibility for the Maintenance of the Planning Effort............... P-1Section P: Responsibility for the Maintenance of the Planning Effort............... P-1Section P: Responsibility for the Maintenance of the Planning Effort............... P-1

1. Responsibility for Development and Maintenance of the Plan.......................... P-1

1. Responsibility for Development and Maintenance of the Plan.......................... P-11. Responsibility for Development and Maintenance of the Plan........................... P-1 1.1 Overall Authority and Responsibility.........ccccocooerirririciiiiiciieereeeeen, P-1 1.1 Overall Authority and Responsibility...........ccccevveereireererreereerecrecreenenrenneen P-11.1 Overall Authority and Responsibility..........cccccceeeeiererinrvnnneeeeceeeecerennnnenne P-1 1.2 Maintaining the Emergency Preparedness Program.............cccccueeueennane P-11.2 Maintaining the Emergency Preparedness Program...........cccccocceeeeenen. P-1 1.2 Maintaining the Emergency Preparedness Program..........ccccceeevcvunnnnenes P-1

2. Review and Update of the IOEP........cueeeeereeremmienrereerenrenensreeresnnnnnnnnnsnnsnnnnmsnnsnne P-22. Review and Update of the OEP..........eeeeereeeierieriirierieiiiirrenneseessssasssssesnnns P-22. Review and Update of the IOEP............oooiiiriee eevee areas eens P-2

3. Review and Update of the IOEP..........uuvvureirierienieiieteniierieriernineessessanssssiosmenaen P-23. Review and Update of the OEP..........ueueereemieremrenriciecessenesesenneennns P-23. Review and Update of the IOEP..........oooeemieeeeeeeeee eevee P-2

4. Letters of Agreement............ccocvververerreerenrensenreneennnnnes eetastessssrtasenssnsnnssnsensnnsanns P-24. Letters of AQreement............eeveereriiereereereniererereeererensrersessrssssnnsnssssssssssssssssaanns P-24. Letters of AQremENt........ooooiiiii reece ese rressee serene P-2

5. Cross-Reference to Planning Criteria..........cooovviee iii eee P-2

5. Cross-Reference to Planning Criteria.........ccceecenuirnrivcrivnrceicceerinnne reereenennann P-25. Cross-Reference to Planning Criteria.........cccccceieeeeeiciinnnneereeenineeececnneeeeeerenscens P-2

6. Inventory and Maintenance of Emergency Equipment and Supplies................ P-26. Inventory and Maintenance of Emergency Equipment and Supplies................ P-2

6. Inventory and Maintenance of Emergency Equipment and Supplies................ P-2 Part Ill: APPENDICESPart lll: APPENDICES Part lll: APPENDICES Appendix 1: Letters of Agreement............oo rier Appendix-1-1Appendix 1: Letters of Agreement........c.ccccceviiiiiicinceneneninnecnenssssenssanennens Appendix-1-1Appendix 1: Letters of Agreement.........ceeeeeieecrcirenssccennannnniensssssssenness Appendix-1-1 Appendix 2: Cross-Reference Sections of the IOEP to EPIPs.............. Appendix-2-1Appendix 2: Cross-Reference Sections of the IOEP to EPIPs.............. Appendix-2-1Appendix 2: Cross-Reference Sections of the IOEP to EPIPs.............. Appendix-2-1 Appendix 3 Abbreviations and Definitions..........ccocviiiimnierininiiicinannns Appendix-3-1Appendix 3 Abbreviations and Definitions........cccccccvvvrrerierennienrenennen... Appendix-3-1Appendix 3 Abbreviations and Definitions............ccocvccmmrreerericircssennnnes Appendix-3-1 Abbreviations........coocovei ieee, Appendix-3-1Abbreviations..........cocoiiiiiiiiiiiccreeere eeeAppendix-3-1 DefiNitioNS.....cocccieriiicciriirccrereecerns creer eseeene sees nnensAppendix-3-2DefinitioNS..ccceiieieicerrrrre rrr rrr eensAppendix-3-2

iv 23-04 DEfiNItIONS veut eee eee Appendix-3-2iv 23-04ADDIEeVIAtIONS.....oiiirrrrrranree reer aAppendix-3-1 Indian Point Energy CenterIndian Point Energy Center Indian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Partl: INTRODUCTIONPart I: INTRODUCTION Part I: INTRODUCTION Section A: PurposeSection A: PurposeSection A: Purpose The purpose of the Independent Spent Fuel Storage Installation (ISFSI)-OnlyThe purpose of the Independent Spent Fuel Storage Installation (ISFSI)-OnlyThe purpose of the Independent Spent Fuel Storage Installation (ISFSI)-Only Emergency Plan (IOEP) is to ensure an adequate level of preparedness to cope withEmergency Plan (IOEP) is to ensure an adequate level of preparedness to cope with the spectrum of emergencies that could be postulated to occur with all spent fuel storedthe spectrum of emergencies that could be postulated to occur with all spent fuel storedthe spectrum of emergencies that could be postulated to occur with all spent fuel stored in the ISFSI. This plan integrates the necessary elements to provide effective in the ISFSI. This plan integrates the necessary elements to provide effectivein the ISFSI. This plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizationsemergency response considering cooperation and coordination of organizationsemergency response considering cooperation and coordination of organizations expected to respond to potential emergencies.expected to respond to potential emergencies.expected to respond to potential emergencies.

Section B: BackgroundSection B: BackgroundSection B: Background Description of the Indian Point Energy CenterDescription of the Indian Point Energy CenterDescription of the Indian Point Energy Center Indian Point Nuclear Generating Units 1, 2, and 3 (IP1, IP2, and IP3, collectivelyIndian Point Nuclear Generating Units 1, 2, and 3 (IP1, IP2, and IP3, collectivelyIndian Point Nuclear Generating Units 1, 2, and 3 (IP1, IP2, and IP3, collectively referred to as Indian Point Energy Center (IPEC)) are located on the east side of thereferred to as Indian Point Energy Center (IPEC)) are located on the east side of thereferred to as Indian Point Energy Center (IPEC)) are located on the east side of the Hudson River on approximately 239 acres of land. IPEC is about 24 miles north of theHudson River on approximately 239 acres of land. IPEC is about 24 miles north of theHudson River on approximately 239 acres of land. IPEC is about 24 miles north of the New York City boundary line, at Indian Point, Village of Buchanan, in upperNew York City boundary line, at Indian Point, Village of Buchanan, in upper New York City boundary line, at Indian Point, Village of Buchanan, in upper Westchester County, New York State. IPEC is about 2.5 miles southwest of the City ofWestchester County, New York State. IPEC is about 2.5 miles southwest of the City ofWestchester County, New York State. IPEC is about 2.5 miles southwest of the City of Peekskill; 8.3 miles south of West Point; 1.5 miles northeast of the Lovett GeneratingPeekskill; 8.3 miles south of West Point; 1.5 miles northeast of the Lovett GeneratingPeekskill; 8.3 miles south of West Point; 1.5 miles northeast of the Lovett Generating Station site; 4.6 miles north of the Bowline Point Generating Station site; and 2.3 milesStation site; 4.6 miles north of the Bowline Point Generating Station site; and 2.3 milesStation site; 4.6 miles north of the Bowline Point Generating Station site; and 2.3 miles north of Montrose Point. Rockland County is located west of IPEC, across the Hudsonnorth of Montrose Point. Rockland County is located west of IPEC, across the Hudsonnorth of Montrose Point. Rockland County is located west of IPEC, across the Hudson River.River.

River.

By letter dated December 11, 2008, IPEC notified the NRC that all spent fuelBy letter dated December 11, 2008, IPEC notified the NRC that all spent fuelBy letter dated December 11, 2008, IPEC notified the NRC that all spent fuel assemblies had been removed from the IP1 spent fuel pool (SFP). By letter dated Mayassemblies had been removed from the IP1 spent fuel pool (SFP). By letter dated Mayassemblies had been removed from the IP1 spent fuel pool (SFP). By letter dated May 12, 2020, Entergy submitted certifications for permanent cessation of reactor operations12, 2020, Entergy submitted certifications for permanent cessation of reactor operations12, 2020, Entergy submitted certifications for permanent cessation of reactor operations at IP2 and permanent removal of fuel from the reactor vessel pursuant to 10 CFRat IP2 and permanent removal of fuel from the reactor vessel pursuant to 10 CFRat IP2 and permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1). By letter dated May 11, 2021, Entergy submitted certifications for50.82(a)(1). By letter dated May 11, 2021, Entergy submitted certifications for 50.82(a)(1). By letter dated May 11, 2021, Entergy submitted certifications for permanent cessation of reactor operations at IP3 and permanent removal of fuel frompermanent cessation of reactor operations at IP3 and permanent removal of fuel frompermanent cessation of reactor operations at IP3 and permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82(a)(1). Subsequently, all spent fuel hasthe reactor vessel pursuant to 10 CFR 50.82(a)(1). Subsequently, all spent fuel has been transferred to the on-site ISFSI.been transferred to the on-site ISFSI.

The IOEP describes the plan for responding to emergencies that may arise at the ISFSI.The IOEP describes the plan for responding to emergencies that may arise at the ISFSI.

In this condition, no reactor operations can take place and all irradiated fuel has beenIn this condition, no reactor operations can take place and all irradiated fuel has been removed from the SFPs. This IOEP adequately addresses the risks associated withremoved from the SFPs. This IOEP adequately addresses the risks associated with IPEC's current conditions.IPEC's current conditions.

The Holtec International (Holtec) Final Safety Analysis Report (FSAR) for the HI-The Holtec International (Holtec) Final Safety Analysis Report (FSAR) for the HI-STORM 100 Cask System describes the Design Basis Accidents (DBAs) applicable toSTORM 100 Cask System describes the Design Basis Accidents (DBAs) applicable to the IPEC ISFSI along with the radiological dose calculation results. As provided in thethe IPEC ISFSI along with the radiological dose calculation results. As provided in the Holtec FSAR, the analyses of the potential radiological impacts of postulated off-normal,Holtec FSAR, the analyses of the potential radiological impacts of postulated off-normal, natural phenomena, and accident events involving the ISFSI indicate that any releasesnatural phenomena, and accident events involving the ISFSI indicate that any releases would result in a dose to the public below the radiation limits established in 10 CFRwould result in a dose to the public below the radiation limits established in 10 CFR 72.106(b).72.106(b).

1 23-041 23-04 1 23-04IPEC's current conditions.In this condition, no reactor operations can take place and all irradiated fuel has beenHoltec FSAR, the analyses of the potential radiological impacts of postulated off-normal,natural phenomena, and accident events involving the ISFSI indicate that any releasesbeen transferred to the on-site ISFSI.removed from the SFPs. This IOEP adequately addresses the risks associated with72.106(b).STORM 100 Cask System describes the Design Basis Accidents (DBAs) applicable toThe Holtec International (Holtec) Final Safety Analysis Report (FSAR) for the HI-The IOEP describes the plan for responding to emergencies that may arise at the ISFSI.the reactor vessel pursuant to 10 CFR 50.82(a)(1). Subsequently, all spent fuel hasthe IPEC ISFSI along with the radiological dose calculation results. As provided in thewould result in a dose to the public below the radiation limits established in 10 CFR Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

The analyses of the potential radiological impact of DBAs indicate that any releases The analyses of the potential radiological impact of DBAs indicate that any releasesThe analyses of the potential radiological impact of DBAs indicate that any releases beyond the Site Boundary are below the Environmental Protection Agency (EPA)beyond the Site Boundary are below the Environmental Protection Agency (EPA)beyond the Site Boundary are below the Environmental Protection Agency (EPA)

Protective Action Guide (PAG) exposure levels, as detailed in the EPA's Protective Protective Action Guide (PAG) exposure levels, as detailed in the EPA's ProtectiveProtective Action Guide (PAG) exposure levels, as detailed in the EPA's Protective Action Guide and Planning Guidance for Radiological Incidents, dated January 2017.Action Guide and Planning Guidance for Radiological Incidents, dated January 2017.Action Guide and Planning Guidance for Radiological Incidents, dated January 2017.

Exposure levels, which warrant pre-planned response measures are limited to the ISFSIExposure levels, which warrant pre-planned response measures are limited to the ISFSIExposure levels, which warrant pre-planned response measures are limited to the ISFSI and immediate vicinity, and for this reason, radiological emergency planning is focusedand immediate vicinity, and for this reason, radiological emergency planning is focused and immediate vicinity, and for this reason, radiological emergency planning is focused on this area. The IPEC 10 CFR 72.212 Report for the HI-STORM 100 Systemon this area. The IPEC 10 CFR 72.212 Report for the HI-STORM 100 Systemon this area. The IPEC 10 CFR 72.212 Report for the HI-STORM 100 System discusses compliance with Amendments 2, 4, 6, 9 and 15 of the Holtec HI-STORM 100discusses compliance with Amendments 2, 4, 6, 9 and 15 of the Holtec HI-STORM 100discusses compliance with Amendments 2, 4, 6, 9 and 15 of the Holtec HI-STORM 100 System Certificate of Compliance (CoC) terms, conditions, and specifications.System Certificate of Compliance (CoC) terms, conditions, and specifications.System Certificate of Compliance (CoC) terms, conditions, and specifications.

Section C: ScopeSection C: ScopeSection C: Scope The IOEP has been developed to respond to potential radiological emergencies at theThe IOEP has been developed to respond to potential radiological emergencies at theThe IOEP has been developed to respond to potential radiological emergencies at the IPEC ISFSI. Because there are no postulated off-normal, natural phenomena or accidentIPEC ISFSI. Because there are no postulated off-normal, natural phenomena or accidentIPEC ISFSI. Because there are no postulated off-normal, natural phenomena or accident events that would result in dose consequences that are large enough to require offsiteevents that would result in dose consequences that are large enough to require offsiteevents that would result in dose consequences that are large enough to require offsite emergency planning, the overall scope of the IOEP details the actions necessary toemergency planning, the overall scope of the lIOEP details the actions necessary toemergency planning, the overall scope of the IOEP details the actions necessary to safeguard onsite personnel.safeguard onsite personnel.safeguard onsite personnel.

The concepts presented in this IOEP address the applicable regulations stipulated in 10The concepts presented in this IOEP address the applicable regulations stipulated in 10The concepts presented in this IOEP address the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans" and 10 CFR Part 50, Appendix E, "Emergency PlanningCFR 50.47, "Emergency Plans" and 10 CFR Part 50, Appendix E, "Emergency PlanningCFR 50.47, "Emergency Plans" and 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," as exempted.and Preparedness for Production and Utilization Facilities," as exempted.and Preparedness for Production and Utilization Facilities, as exempted.

Exemptions from selected portions of 10 CFR 50.47 and 10 CFR 50, Appendix E, wereExemptions from selected portions of 10 CFR 50.47 and 10 CFR 50, Appendix E, wereExemptions from selected portions of 10 CFR 50.47 and 10 CFR 50, Appendix E, were granted for IPEC by the NRC on November 1, 2023 (ADAMS Accession Number:granted for IPEC by the NRC on November 1, 2023 (ADAMS Accession Number:

granted for IPEC by the NRC on November 1, 2023 (ADAMS Accession Number:

ML23063A143). This plan is consistent with the remaining applicable guidelines ML23063A143). This plan is consistent with the remaining applicable guidelinesML23063A143). This plan is consistent with the remaining applicable guidelines established in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation andestablished in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation andestablished in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support ofEvaluation of Radiological Emergency Response Plans and Preparedness in Support ofEvaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Facilities" (NUREG-0654).Nuclear Power Facilities (NUREG-0654).Nuclear Power Facilities" (NUREG-0654).

Appendix 2 contains a cross reference to applicable guidance.

Appendix 2 contains a cross reference to applicable guidance.Appendix 2 contains a cross reference to applicable guidance.

Abbreviations and acronyms used in this IOEP are included in Appendix 3.Abbreviations and acronyms used in this IOEP are included in Appendix 3.

Abbreviations and acronyms used in this IOEP are included in Appendix 3.

Section D: Planning BasisSection D: Planning BasisSection D: Planning Basis In the event of an emergency at the IPEC ISFSI, actions are required to identify andIn the event of an emergency at the IPEC ISFSI, actions are required to identify andIn the event of an emergency at the IPEC ISFSI, actions are required to identify and assess the nature of the emergency and to respond in a manner that protects the healthassess the nature of the emergency and to respond in a manner that protects the healthassess 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 andand safety of the public and onsite personnel. This plan describes the organization andand safety of the public and onsite personnel. This plan describes the organization and responsibilities for implementing emergency measures and describes interfaces withresponsibilities for implementing emergency measures and describes interfaces with responsibilities for implementing emergency measures and describes interfaces with Federal, State of New York, and local organizations which may be notified in the eventFederal, State of New York, and local organizations which may be notified in the event Federal, State of New York, and local organizations which may be notified in the event of an emergency and may be requested to provide assistance.of an emergency and may be requested to provide assistance.of an emergency and may be requested to provide assistance.

Emergency services are provided by local, public, and private entities. Fire support Emergency services are provided by local, public, and private entities. Fire supportEmergency services are provided by local, public, and private entities. Fire support services are provided by the Verplanck Fire District; law enforcement support servicesservices are provided by the Verplanck Fire District; law enforcement support servicesservices are provided by the Verplanck Fire District; law enforcement support services are provided by the New York State Police, and Federal law enforcement authorities, asare provided by the New York State Police, and Federal law enforcement authorities, asare provided by the New York State Police, and Federal law enforcement authorities, as appropriate; ambulance services are provided by the Verplanck Fire District; and appropriate; ambulance services are provided by the Verplanck Fire District; andappropriate; ambulance services are provided by the Verplanck Fire District; and medical services are provided by New York-Presbyterian Hudson Valley Hospital inmedical services are provided by New York-Presbyterian Hudson Valley Hospital inmedical services are provided by New York-Presbyterian Hudson Valley Hospital in Cortland Manor.

Cortland Manor.Cortland Manor.

2 23-04 2 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Because there are no postulated events that would result in offsite dose consequencesBecause there are no postulated events that would result in offsite dose consequencesBecause there are no postulated events that would result in offsite dose consequences large enough to require pre-planned offsite radiological emergency response,large enough to require pre-planned offsite radiological emergency response,large enough to require pre-planned offsite radiological emergency response, emergencies are divided into two classifications: 1) Notification of Unusual Eventemergencies are divided into two classifications: 1) Notification of Unusual Eventemergencies are divided into two classifications: 1) Notification of Unusual Event (Unusual Event) and 2) Alert.(Unusual Event) and 2) Alert.(Unusual Event) and 2} Alert.

The emergency classification scheme, developed in accordance with NEI 99-01,The emergency classification scheme, developed in accordance with NEI 99-01,The emergency classification scheme, developed in accordance with NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors, Revision 6,"Development of Emergency Action Levels for Non-Passive Reactors", Revision 6,"Development of Emergency Action Levels for Non-Passive Reactors", Revision 6, November 2012, has been discussed and agreed upon with responsible offsiteNovember 2012, has been discussed and agreed upon with responsible offsiteNovember 2012, has been discussed and agreed upon with responsible offsite organizations. If determined appropriate by government officials, protective actions mayorganizations. If determined appropriate by government officials, protective actions mayorganizations. If determined appropriate by government officials, protective actions may be implemented to protect the public using the existing all hazards approach tobe implemented to protect the public using the existing all hazards approach tobe implemented to protect the public using the existing all hazards approach to emergency planning.emergency planning.

emergency planning.

IPEC is responsible for planning and implementing emergency measures within the siteIPEC is responsible for planning and implementing emergency measures within the site IPEC is responsible for planning and implementing emergency measures within the site boundary. The IOEP is provided to meet that responsibility. To carry out specificboundary. The IOEP is provided to meet that responsibility. To carry out specificboundary. The lIOEP is provided to meet that responsibility. To carry out specific emergency measures discussed in this IOEP, detailed emergency plan implementingemergency measures discussed in this IOEP, detailed emergency plan implementingemergency measures discussed in this IOEP, detailed emergency plan implementing procedures (EPIPs) are established and maintained. A list of EPIPs is included inprocedures (EPIPs) are established and maintained. A list of EPIPs is included inprocedures (EPIPs) are established and maintained. A list of EPIPs is included in Appendix 2.Appendix 2.Appendix 2.

In addition to the description of activities and steps that can be implemented during anIn addition to the description of activities and steps that can be implemented during anIn addition to the description of activities and steps that can be implemented during an emergency, the IOEP also provides a general description of the steps taken to recoveremergency, the IOEP also provides a general description of the steps taken to recoveremergency, the IOEP also provides a general description of the steps taken to recover from an emergency. It also describes the training, exercises and drills, planning, and from an emergency. It also describes the training, exercises and drills, planning, andfrom an emergency. It also describes the training, exercises and drills, planning, and coordination appropriate to maintain an adequate level of emergency preparedness.coordination appropriate to maintain an adequate level of emergency preparedness.coordination appropriate to maintain an adequate level of emergency preparedness.

The IOEP is activated by the ISFSI Shift Supervisor (ISS) upon identification of anThe IOEP is activated by the ISFSI Shift Supervisor (ISS) upon identification of anThe IOEP is activated by the ISFSI Shift Supervisor (ISS) upon identification of an emergency based upon the Emergency Action Level (EAL) criteria. Upon declaration ofemergency based upon the Emergency Action Level (EAL) criteria. Upon declaration ofemergency based upon the Emergency Action Level (EAL) criteria. Upon declaration of an emergency the ISS assumes the position of the Emergency Director. The emergencyan emergency the ISS assumes the position of the Emergency Director. The emergency an emergency the ISS assumes the position of the Emergency Director. The emergency measures described in the subsequent sections and EPIPs are implemented inmeasures described in the subsequent sections and EPIPs are implemented inmeasures described in the subsequent sections and EPIPs are implemented in accordance with the emergency classification and nature of the emergency, and underaccordance with the emergency classification and nature of the emergency, and underaccordance with the emergency classification and nature of the emergency, and under the direction of the Emergency Director. Regulatory authorities and offsite supportthe direction of the Emergency Director. Regulatory authorities and offsite supportthe direction of the Emergency Director. Regulatory authorities and offsite support organizations are notified in accordance with this IOEP.organizations are notified in accordance with this IOEP.organizations are notified in accordance with this IOEP.

The Emergency Director has authority and responsibility for control and mitigation of theThe Emergency Director has authority and responsibility for control and mitigation of the The Emergency Director has authority and responsibility for control and mitigation of the emergency, including emergency response resources, coordination of radiological emergency, including emergency response resources, coordination of radiologicalemergency, including emergency response resources, coordination of radiological assessment activities, and recovery implementation. The following sections of this IOEPassessment activities, and recovery implementation. The following sections of this IOEPassessment activities, and recovery implementation. The following sections of this IOEP describe the detailed plans and actions of the IPEC Emergency Response Organizationdescribe the detailed plans and actions of the IPEC Emergency Response Organizationdescribe the detailed plans and actions of the IPEC Emergency Response Organization (ERO), including interfaces with offsite support organizations.(ERO), including interfaces with offsite support organizations.(ERO), including interfaces with offsite support organizations.

This IOEP documents the methods by which the IPEC Emergency PreparednessThis IOEP documents the methods by which the IPEC Emergency Preparedness This IOEP documents the methods by which the IPEC Emergency Preparedness Program meets the criteria set forth in 10 CFR Part 50, Section 47(b), and Appendix E,Program meets the criteria set forth in 10 CFR Part 50, Section 47(b), and Appendix E,Program meets the criteria set forth in 10 CFR Part 50, Section 47(b), and Appendix E, as exempted.as exempted.as exempted.

The IOEP, Revision 0, was approved per NRC Safety Evaluation in License (ADAMSThe IQEP, Revision 0, was approved per NRC Safety Evaluation in License (ADAMSThe IOEP, Revision 0, was approved per NRC Safety Evaluation in License (ADAMS Accession Number: ML23326A132) for License Amendment No. 67 to DPR-5,Accession Number: ML23326A132) for License Amendment No. 67 to DPR-5,Accession Number: ML23326A132) for License Amendment No. 67 to DPR-5, Amendment No. 300 to DPR-26, and Amendment No. 276 to DPR-64 dated DecemberAmendment No. 300 to DPR-26, and Amendment No. 276 to DPR-64 dated DecemberAmendment No. 300 to DPR-26, and Amendment No. 276 to DPR-64 dated December 5, 2023.5, 2023.5, 2023.

3 23-04 3 23-04 Indian Point Energy Center Indian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Part li: PLANNING STANDARDS AND CRITERIAPart ll: PLANNING STANDARDS AND CRITERIAPart Il: PLANNING STANDARDS AND CRITERIA Section A: Assignment of ResponsibilitySection A: Assignment of ResponsibilitySection A: Assignment of Responsibility Primary responsibilities for emergency response have been assigned. The emergencyPrimary responsibilities for emergency response have been assigned. The emergencyPrimary responsibilities for emergency response have been assigned. The emergency responsibilities of the various supporting organizations have been specificallyresponsibilities of the various supporting organizations have been specificallyresponsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond to and toestablished, and each principal response organization has staff to respond to and toestablished, and each principal response organization has staff to respond to and to augment its initial response on a continuous basis.augment its initial response on a continuous basis.augment its initial response on a continuous basis.

1.1.IPEC Emergency Response and ResponsibilitiesIPEC Emergency Response and Responsibilities

1. IPEC Emergency Response and Responsibilities Holtec Decommissioning International, LLC (HDI) is responsible for the safe storageHoltec Decommissioning International, LLC (HDI) is responsible for the safe storage Holtec Decommissioning International, LLC (HDI} is responsible for the safe storage of spent fuel in accordance with NRC regulations. Responsibility for planning andof spent fuel in accordance with NRC regulations. Responsibility for planning andof spent fuel in accordance with NRC regulations. Responsibility for planning and implementing all emergency measures rests with HDI. The IPEC ISFSI Organizationimplementing all emergency measures rests with HDI. The IPEC ISFSI Organizationimplementing all emergency measures rests with HDI. The IPEC ISFSI Organization has complete capability at all times to perform the detection, classification, initialhas complete capability at all times to perform the detection, classification, initialhas complete capability at all times to perform the detection, classification, initial response, and notification functions required during an emergency. The organization response, and notification functions required during an emergency. The organizationresponse, and notification functions required during an emergency. The organization has an inherent emergency response and recovery function in its overallhas an inherent emergency response and recovery function in its overallhas an inherent emergency response and recovery function in its overall management and operation.management and operation.management and operation.

The ISFSI Shift Supervisor (ISS) is at IPEC ISFSI on a continuous, 24-hour-per-dayThe ISFSI Shift Supervisor (ISS) is at IPEC ISFSI on a continuous, 24-hour-per-dayThe ISFSI Shift Supervisor (ISS) is at IPEC ISFSIl on a continuous, 24-hour-per-day basis, and is the senior management position during off-hours. This position isbasis, and is the senior management position during off-hours. This position isbasis, and is the senior management position during off-hours. This position is responsible for monitoring ISFSI conditions and managing the activities at the IPECresponsible for monitoring ISFSI conditions and managing the activities at the IPEC responsible for monitoring ISFSI conditions and managing the activities at the IPEC ISFSI. The ISS has the responsibility and authority to declare an emergency andISFSI. The ISS has the responsibility and authority to declare an emergency andISFSI. The ISS has the responsibility and authority to declare an emergency and initiate appropriate actions in accordance with written procedures to mitigate the initiate appropriate actions in accordance with written procedures to mitigate theinitiate appropriate actions in accordance with written procedures to mitigate the consequences, including making the necessary notifications. When an off-normal,consequences, including making the necessary notifications. When an off-normal,consequences, including making the necessary notifications. When an off-normal, natural phenomenon, or accident event becomes apparent, the ISS shall assess thenatural phenomenon, or accident event becomes apparent, the ISS shall assess thenatural phenomenon, or accident event becomes apparent, the 1SS shall assess the condition and assume the position of Emergency Director once an emergencycondition and assume the position of Emergency Director once an emergencycondition and assume the position of Emergency Director once an emergency declaration has been made.declaration has been made.declaration has been made.

The Emergency Director is responsible for the direction of all activities at the ISFSI The Emergency Director is responsible for the direction of all activities at the ISFSIThe Emergency Director is responsible for the direction of all activities at the ISFSI site during an emergency. Should evaluation indicate the need, the Emergencysite during an emergency. Should evaluation indicate the need, the Emergencysite during an emergency. Should evaluation indicate the need, the Emergency Director has the authority to direct any or all individuals to relocate from the ISFSIDirector has the authority to direct any or all individuals to relocate from the ISFSIDirector has the authority to direct any or all individuals to relocate from the ISFSI and surrounding area and to notify all applicable agencies of the ISFSI status. Theand surrounding area and to notify all applicable agencies of the ISFSI status. Theand surrounding area and to notify all applicable agencies of the ISFSI status. The Emergency Director ensures that appropriate actions are taken, and managementEmergency Director ensures that appropriate actions are taken, and managementEmergency Director ensures that appropriate actions are taken, and management and applicable offsite supporting organizations and regulatory agencies are notified,and applicable offsite supporting organizations and regulatory agencies are notified,and applicable offsite supporting organizations and regulatory agencies are notified, as necessary. The functions associated within the Emergency Director's scope ofas necessary. The functions associated within the Emergency Director's scope ofas necessary. The functions associated within the Emergency Director's scope of responsibilities are specified on Table B-1. The Emergency Director does not haveresponsibilities are specified on Table B-1. The Emergency Director does not haveresponsibilities are specified on Table B-1. The Emergency Director does not have concurrent duties which conflict with the above responsibilities.concurrent duties which conflict with the above responsibilities.concurrent duties which conflict with the above responsibilities.

The on-shift staff positions are staffed on a 24-hour-per-day basis. The on-shift staffThe on-shift staff positions are staffed on a 24-hour-per-day basis. The on-shift staffThe on-shift staff positions are staffed on a 24-hour-per-day basis. The on-shift staff can perform all required IOEP actions. At the direction of the Emergency Director,can perform all required IOEP actions. At the direction of the Emergency Director,can perform all required IOEP actions. At the direction of the Emergency Director, additional personnel will be activated to support the on-shift staff.additional personnel will be activated to support the on-shift staff.additional personnel will be activated to support the on-shift staff.

A Resource Manager assists in assessing the situation and obtaining additionalA Resource Manager assists in assessing the situation and obtaining additionalA Resource Manager assists in assessing the situation and obtaining additional resources needed to respond to the event.resources needed to respond to the event.resources needed to respond to the event.

The functions assigned to the On-Shift and Augmenting ERO positions are specifiedThe functions assigned to the On-Shift and Augmenting ERO positions are specifiedThe functions assigned to the On-Shift and Augmenting ERO positions are specified in Section B of this IOEP. The ERO maintains the depth, qualifications, andin Section B of this IOEP. The ERO maintains the depth, qualifications, and

A-1 23-04 A-1 23-04 in Section B of this IOEP. The ERO maintains the depth, qualifications, andA-1 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

capability for continuous 24-hour coverage of the emergency response for acapability for continuous 24-hour coverage of the emergency response for acapability for continuous 24-hour coverage of the emergency response for a protracted period. The Emergency Director has the authority and is responsible forprotracted period. The Emergency Director has the authority and is responsible forprotracted period. The Emergency Director has the authority and is responsible for maintaining and ensuring the continuity of personnel and resources.maintaining and ensuring the continuity of personnel and resources.maintaining and ensuring the continuity of personnel and resources.

. Offsite Response Organizations. Offsite Response Organizations. Offsite Response Organizations Offsite Response Organizations (OROs) (local law enforcement support; medicalOffsite Response Organizations (OROs) (local law enforcement support; medicalOffsite Response Organizations (OROs} (local law enforcement support; medical and ambulance services, including hospital support; and fire/rescue support) may beand ambulance services, including hospital support; and fire/rescue support) may beand ambulance services, including hospital support; and fire/rescue support) may be requested to respond to an emergency at IPEC. The Emergency Director isrequested to respond to an emergency at IPEC. The Emergency Director isrequested to respond to an emergency at IPEC. The Emergency Director is responsible for requesting and coordinating the response provided by the OROs withresponsible for requesting and coordinating the response provided by the OROs withresponsible for requesting and coordinating the response provided by the OROs with the onsite activities. The OROs described in this IOEP are capable of 24-hour the onsite activities. The OROs described in this IOEP are capable of 24-hourthe onsite activities. The OROs described in this IOEP are capable of 24-hour emergency response. Details related to the anticipated support from each ORO areemergency response. Details related to the anticipated support from each ORO are described in Section C of this OEP.

described in Section C of this IOEP.

Letters of Agreement (LOASs) are listed in Appendix 1 and are addressed in Part 2,Letters of Agreement (LOAS) are listed in Appendix 1 and are addressed in Part 2, Section C of this IOEP.Section C of this IOEP.

A-2 23-04A-2 23-04 Letters of Agreement (LOASs) are listed in Appendix 1 and are addressed in Part 2,Section C of this IOEP.emergency response. Details related to the anticipated support from each ORO aredescribed in Section C of this IOEP.A-2 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Section B: Emergency Response Organization Section B: Emergency Response OrganizationSection B: Emergency Response Organization Key ERO positions and associated responsibilities for each position are outlined below.Key ERO positions and associated responsibilities for each position are outlined below.Key ERO positions and associated responsibilities for each position are outlined below.

The IPEC ERO provides for an initial emergency response and timely augmentation ofThe IPEC ERO provides for an initial emergency response and timely augmentation ofThe IPEC ERO provides for an initial emergency response and timely augmentation of on-shift personnel, when required. The interface between IPEC response personnel andon-shift personnel, when required. The interface between IPEC response personnel andon-shift personnel, when required. The interface between IPEC response personnel and OROs has been previously arranged.OROs has been previously arranged.OROs has been previously arranged.

1.1. IPEC Emergency Response OrganizationIPEC Emergency Response Organization

1. IPEC Emergency Response Organization Table B-1, Emergency Response Organization Minimum Staffing Requirements,Table B-1, Emergency Response Organization Minimum Staffing Requirements, Table B-1, Emergency Response Organization Minimum Staffing Requirements, outlines the minimum staffing required for emergency response. The ERO may beoutlines the minimum staffing required for emergency response. The ERO may beoutlines the minimum staffing required for emergency response. The ERO may be activated, in part or in whole, at any time at the discretion of the Emergency Director.activated, in part or in whole, at any time at the discretion of the Emergency Director.activated, in part or in whole, at any time at the discretion of the Emergency Director.

1.1 On-Shift Positions1.1 On-Shift Positions1.1 On-Shift Positions IPEC maintains on-shift personnel capable of providing the initial response to anIPEC maintains on-shift personnel capable of providing the initial response to anIPEC maintains on-shift personnel capable of providing the initial response tc an off-normal, natural phenomenon, or accident event on a 24-hour per day basis.off-normal, natural phenomenon, or accident event on a 24-hour per day basis.

off-normal, natural phenomenon, or accident event on a 24-hour per day basis.

Members of the on-shift organization are trained on their responsibilities and dutiesMembers of the on-shift organization are trained on their responsibilities and dutiesMembers of the on-shift organization are trained on their responsibilities and duties in the event of a declared emergency and are capable of performing all necessaryin the event of a declared emergency and are capable of performing all necessaryin the event of a declared emergency and are capable of performing all necessary response actions until any necessary augmenting staff arrives, or the event isresponse actions until any necessary augmenting staff arrives, or the event isresponse actions until any necessary augmenting staff arrives, or the event is terminated. The on-shift staffing assignments include the roles and responsibilitiesterminated. The on-shift staffing assignments include the roles and responsibilitiesterminated. The on-shift staffing assignments include the roles and responsibilities for their emergency response function:for their emergency response function:for their emergency response function:

(1) ISFSI Shift Supervisor/ Emergency Director(1) ISESI Shift Supervisor/ Emergency Director (1) ISFSI Shift Supervisor/ Emergency Director The ISS is at the IPEC ISFSI on a 24-hour per day basis and is the seniorThe ISS is at the IPEC ISFSI on a 24-hour per day basis and is the seniorThe ISS is at the IPEC ISFSI on a 24-hour per day basis and is the senior management position during off-hours. This position is responsible formanagement position during off-hours. This position is responsible formanagement position during off-hours. This position is responsible for monitoring conditions and approving all onsite activities and has the requisitemonitoring conditions and approving all onsite activities and has the requisitemonitoring conditions and approving all onsite activities and has the requisite authority, management ability, technical knowledge, and staff to manage theauthority, management ability, technical knowledge, and staff to manage theauthority, management ability, technical knowledge, and staff to manage the site, emergency response, and recovery organizations.site, emergency response, and recovery organizations.site, emergency response, and recovery organizations.

The ISS has the responsibility and authority to declare an emergency and toThe ISS has the responsibility and authority to declare an emergency and toThe ISS has the responsibility and authority to declare an emergency and to initiate appropriate actions to mitigate the consequences of the emergency ininitiate appropriate actions to mitigate the consequences of the emergency in initiate appropriate actions to mitigate the consequences of the emergency in accordance with written procedures. The ISS assumes the position ofaccordance with written procedures. The ISS assumes the position ofaccordance with written procedures. The ISS assumes the position of Emergency Director with overall command and control once an emergencyEmergency Director with overall command and control once an emergencyEmergency Director with overall command and control once an emergency classification has been made. The Emergency Director is responsible for theclassification has been made. The Emergency Director is responsible for theclassification has been made. The Emergency Director is responsible for the direction of the total emergency response effort and has the companydirection of the total emergency response effort and has the companydirection of the total emergency response effort and has the company authority to accomplish this responsibility.

authority to accomplish this responsibility.authority to accomplish this responsibility.

Other responsibilities assumed by the Emergency Director associated withOther responsibilities assumed by the Emergency Director associated withOther responsibilities assumed by the Emergency Director associated with the functions listed in Table B-1 include:the functions listed in Table B-1 include:the functions listed in Table B-1 include:

+ Notification of the emergency classification to the State of New York,+ Notification of the emergency classification to the State of New York,¢ Notification of the emergency classification to the State of New York, Westchester and Rockland Counties, and the NRC;Westchester and Rockland Counties, and the NRC;Westchester and Rockland Counties, and the NRC; Management of available station resources; Management of available station resources;Management of available station resources; Initiation of mitigative, corrective, and onsite protective actions;Initiation of mitigative, corrective, and onsite protective actions;Initiation of mitigative, corrective, and onsite protective actions; Decision to call for law enforcement, fire, or ambulance assistance;Decision to call for law enforcement, fire, or ambulance assistance; Decision to call for law enforcement, fire, or ambulance assistance; Augmentation of the emergency staff, as deemed necessary;Augmentation of the emergency staff, as deemed necessary;Augmentation of the emergency staff, as deemed necessary;

B-1 23-04B-1 23-04 B-1 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Coordination of security activities;Coordination of security activities;Coordination of security activities; Termination of the emergency condition when appropriate;Termination of the emergency condition when appropriate;Termination of the emergency condition when appropriate; Performance of initial radiological assessment;Performance of initial radiological assessment;Performance of initial radiological assessment; Maintaining a record of event activities; andMaintaining a record of event activities; andMaintaining a record of event activities; and Suspending security measures.

Suspending security measures.Suspending security measures,

The Emergency Director cannot delegate the following responsibilities:The Emergency Director cannot delegate the following responsibilities:

e Classification of an eventClassification of an event o Classification of an event

<< Approval of emergency notifications to the State of New York,Approval of emergency notifications to the State of New York,Approval of emergency notifications to the State of New York, Westchester and Rockland Counties, and the NRC (although the taskWestchester and Rockland Counties, and the NRC (although the taskWestchester and Rockland Counties, and the NRC (although the task of making notifications may be delegated)of making notifications may be delegated)of making notifications may be delegated)

<< Authorization of radiation exposures in excess of 10 CFR Part 20 limits+ Authorization of radiation exposures in excess of 10 CFR Part 20 limitse Authorization of radiation exposures in excess of 10 CFR Part 20 limits

The Emergency Director is responsible for assuring that appropriateThe Emergency Director is responsible for assuring that appropriateThe Emergency Director is responsible for assuring that appropriate corrective and protective actions are taken to mobilize emergency responsecorrective and protective actions are taken to mobilize emergency responsecorrective and protective actions are taken to mobilize emergency response personnel and for notifying management, OROs, and regulatory agencies,personnel and for notifying management, OROs, and regulatory agencies,personnel and for notifying management, OROs, and regulatory agencies, as necessary.as necessary.as necessary.

(2) Security(2) Security(2) Security Security is maintained in accordance with the ISFSI Physical Security Plan.Security is maintained in accordance with the ISFSI Physical Security Plan.Security is maintained in accordance with the ISFSI Physical Security Plan.

Security performs accountability as directed by the ISS or EmergencySecurity performs accountability as directed by the ISS or EmergencySecurity performs accountability as directed by the ISS or Emergency Director.Director.Director.

1.21.2Augmenting EROAugmentingERO 1.2 Augmenting ERO IPEC maintains the necessary personnel and resources to support the IPEC ISFSIIPEC maintains the necessary personnel and resources to support the IPEC ISFSIIPEC maintains the necessary personnel and resources to support the IPEC ISFSI Emergency Director in responding to an emergency. Personnel designated toEmergency Director in responding to an emergency. Personnel designated toEmergency Director in responding to an emergency. Personnel designated to augment the on-shift ERO are part of the Augmenting ERO. The Augmenting EROaugment the on-shift ERO are part of the Augmenting ERO. The Augmenting EROaugment the on-shift ERO are part of the Augmenting ERO. The Augmenting ERO is established to assure that a sufficient number of appropriately qualifiedis established to assure that a sufficient number of appropriately qualifiedis established to assure that a sufficient number of appropriately qualified personnel are available on a 24-hour-per-day, 7-day-per-week basis to respond to personnel are available on a 24-hour-per-day, 7-day-per-week basis to respond topersonnel are available on a 24-hour-per-day, 7-day-per-week basis to respond to emergency situations.emergency situations.

emergency situations.

During an emergency at IPEC, the initial phase of the response is managed by theDuring an emergency at IPEC, the initial phase of the response is managed by theDuring an emergency at IPEC, the initial phase of the response is managed by the On-Shift ERO. Following an Alert emergency declaration, or at the discretion of theOn-Shift ERO. Following an Alert emergency declaration, or at the discretion of theOn-Shift ERO. Following an Alert emergency declaration, or at the discretion of the Emergency Director, the Augmenting ERO is notified using a callout process,Emergency Director, the Augmenting ERO is notified using a callout process,Emergency Director, the Augmenting ERO is notified using a callout process, including onsite public address announcements.including onsite public address announcements.including onsite public address announcements.

A partial or complete activation of the Augmenting ERO may be implemented at anA partial or complete activation of the Augmenting ERO may be implemented at an Unusual Event classification (refer to Section D of this IOEP), at the discretion ofUnusual Event classification (refer to Section D of this IOEP), at the discretion of the Emergency Director.the Emergency Director.

The Augmenting ERO consists of the following positions:The Augmenting ERO consists of the following positions:

B-2 23-04B-2 23-04 Unusual Event classification (refer to Section D of this IOEP), at the discretion ofB-2 23-04The Augmenting ERO consists of the following positions:the Emergency Director.A partial or complete activation of the Augmenting ERO may be implemented at an Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

(1) Resource Manager(1) Resource Manager(1) Resource Manager The Resource Manager will be in contact with the Emergency DirectorThe Resource Manager will be in contact with the Emergency Director The Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration. The Resource Managerwithin two (2) hours of an emergency declaration. The Resource Managerwithin two (2) hours of an emergency declaration. The Resource Manager will augment the Emergency Director by assisting in the assessment of thewill augment the Emergency Director by assisting in the assessment of thewill augment the Emergency Director by assisting in the assessment of the emergency condition and coordinating any required resources, includingemergency condition and coordinating any required resources, includingemergency condition and coordinating any required resources, including serving as the public information interface. The Resource Manager does notserving as the public information interface. The Resource Manager does notserving as the public information interface. The Resource Manager does not need to physically report to IPEC to perform the assigned responsibilities.

need to physically report to IPEC to perform the assigned responsibilities.need to physically report to IPEC to perform the assigned responsibilities.

Supplemental personnel shall report at the discretion of the Emergency Supplemental personnel shall report at the discretion of the EmergencySupplemental personnel shall report at the discretion of the Emergency Director and/or the Resource Manager.Director and/or the Resource Manager.

Director and/or the Resource Manager.

(2) Augmented Responder(2) Augmented Responder(2) Augmented Responder For a declared emergency involving radiological consequences, a minimumFor a declared emergency involving radiological consequences, a minimumFor a declared emergency involving radiclogical consequences, a minimum of one person trained in radiological monitoring and assessment will reportof one person trained in radiological monitoring and assessment will reportof one person trained in radiological monitoring and assessment will report to the IPEC ISFSI within four (4) hours of the emergency declaration.to the IPEC ISFSI within four (4) hours of the emergency declaration.to the IPEC ISFSI within four (4) hours of the emergency declaration.

In addition to the resources listed above, supplemental personnel resources mayIn addition to the resources listed above, supplemental personnel resources mayIn addition to the resources listed above, supplemental personnel resources may be directed to report to the IPEC ISFSI by the Emergency Director to providebe directed to report to the IPEC ISFSI by the Emergency Directorto providebe directed to report to the IPEC ISFSI by the Emergency Director to provide additional support as needed to assess radiological conditions, supportadditional support as needed to assess radiological conditions, supportadditional support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans,maintenance and repair activities, develop and implement corrective action plans,maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available fromand assist with recovery actions. The augmentation personnel are available fromand assist with recovery actions. The augmentation personnel are available from IPEC staff and can be requested from various contractors.

IPEC staff and can be requested from various contractors.IPEC staff and can be requested from various contractors.

2. Offsite Emergency Assistance2. Offsite Emergency Assistance

2. Offsite Emergency Assistance Offsite organizations may respond to a declared emergency at the IPEC ISFSI. EachOffsite organizations may respond to a declared emergency at the IPEC ISFSI. Each of these organizations are capable of 24-hour-per-day, 7-day-per-week responseof these organizations are capable of 24-hour-per-day, 7-day-per-week response and operation. The details of their responsibilities are described in Part 2, Section C,and operation. The details of their responsibilities are described in Part 2, Section C, of this IOEP and are contained in their respective LOAs, listed in Appendix 1.

of this IOEP and are contained in their respective LOAs, listed in Appendix 1.

B-3 23-04 B-3 23-04Offsite organizations may respond to a declared emergency at the IPEC ISFSI. Eachand operation. The details of their responsibilities are described in Part 2, Section C,of this IOEP and are contained in their respective LOAs, listed in Appendix 1.of these organizations are capable of 24-hour-per-day, 7-day-per-week response Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Table B-1Table B-1Table B-1 Emergency Response Organization Minimum Staffing RequirementsEmergency Response Organization Minimum Staffing RequirementsEmergency Response Organization Minimum Staffing Requirements MAJOR FUNCTIONAL AUGMENTINGMAJOR FUNCTIONAL AUGMENTING MAJOR FUNCTIONAL AUGMENTINGAREA LOCATION POSITION CAPABILITYAREA LOCATION POSITION CAPABILITY AREA LOCATION POSITION CAPABILITY Assessment of Condition Emergency Emergency ResourceAssessment of Condition Emergency Emergency ResourceAssessment of Condition Emergency Emergency Resource (Emergency Declaration) Response Facility Director Manager*(Emergency Declaration) Response Facility Director Manager*(Emergency Declaration) Response Facility Director Manager Emergency Direction and Emergency Emergency Emergency Direction and Emergency Emergency --Emergency Direction and Emergency Emergency Control Response Facility DirectorControl Response Facility Director Control Response Facility Director Notifications / Emergency Emergency ---Notifications / Emergency Emergency Notifications / Emergency Emergency --

Communications Response Facility DirectorCommunications Response Facility DirectorCommunications Response Facility Director Radiological Accident Emergency Emergency ResourceRadiological Accident Emergency Emergency ResourceRadiological Accident Emergency Emergency Resource Assessment and Protective Response Facility/ Director Manager*Assessment and Protective Response Facility/ Director Manager*Assessment and Protective Response Facility/ Director Manager*

Actions On SceneActions On Scene Actions On Scene AugmentedAugmentedAugmented ResponderResponder'*

Responder**

Corrective Actions Emergency Emergency Corrective Actions Emergency Emergency ---Corrective Actions Emergency Emergency -

Response Facility/ DirectorResponse Facility/ DirectorResponse Facility / Director On Scene On SceneOn Scene Fire Fighting On Scene Per Fire Protection l OffsiteFire Fighting On Scene Per Fire Protection l OffsiteFire Fighting On Scene Per Fe Protection l Offsite Plan ResponsePlan ResponsePlan Response OrganizationOrganization Organization Rescue and First Aid On Scene hid OffsiteRescue and First Aid On Scene bale OffsiteRescue and First Aid On Scene a Offsite Treatment ResponseTreatment ResponseTreatment Response OrganizationOrganization Organization Site Access Control and Security Station Per ISFSIl Physical l Site Access Control and Security Station Per ISFSI Physical l ---Site Access Control and Security Station Per ISFSI Physical l Accountability Security PlanAccountability Security Plan Accountability Security Plan

• As described in Part 2, Section B.1.2(1)* As described in Part 2, Section B.1.2(1)* As described in Part 2, Section B.1.2(1)

• • As described in Part 2, Section B.1.2(2)* As described in Part 2, Section B.1.2(2)

• • • Provided by on-shift personnel assigned other functions.*** Provided by on-shift personnel assigned other functions.

B-4 23-04B-4 23-04 B-4 23-04bd Provided by on-shift personnel assigned other functions.x As described in Part 2, Section B.1.2(2)

Indian Point Energy CenterIndian Point Energy Center Indian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency Plan ISFSI-Only Emergency Plan

Section C: Emergency Response Support and ResourcesSection C: Emergency Response Support and ResourcesSection C: Emergency Response Support and Resources Arrangements for requesting and effectively using resources have been made and otherArrangements for requesting and effectively using resources have been made and other Arrangements for requesting and effectively using resources have been made and other organizations capable of augmenting the planned response have been identified. LOAsorganizations capable of augmenting the planned response have been identified. LOAsorganizations capable of augmenting the planned response have been identified. LOAs are in place for those local agencies (local law enforcement support; medical andare in place for those local agencies (local law enforcement support; medical andare in place for those local agencies (local law enforcement support; medical and amambulance services, including hospital support; and fire/rescue support) identifiedambulance services, including hospital support; and fire/rescue support) identifiedbulance services, including hospital support; and fire/rescue support) identified below, that will respond to an emergency at the IPEC ISFSI.below, that will respond to an emergency at the IPEC ISFSI.below, that will respond to an emergency at the IPEC ISFSI.

1.

1. Support Provided by Local Organizations1.Support Provided by Local OrganizationsSupport Provided by Local Organizations The availability of local support services to assist with the emergency response hasThe availability of local support services to assist with the emergency response hasThe availability of local support services to assist with the emergency response has been ascertained and LOAs from each organization described below have been been ascertained and LOAs from each organization described below have beenbeen ascertained and LOAs from each organization described below have been obtained. All support is provided utilizing the National Incident Management Systemobtained. All support is provided utilizing the National Incident Management System obtained. All support is provided utilizing the National Incident Management System (NIMS) and the Incident Command System (ICS).(NIMS) and the Incident Command System (ICS).(NIMS) and the Incident Command System (ICS).

1.1 Law Enforcement1.11.1Law EnforcementLaw Enforcement When notified that assistance is required, IPEC will notify the New York StateWhen notified that assistance is required, IPEC will notify the New York StateWhen notified that assistance is required, IPEC will notify the New York State Police, which is the lead Local Law Enforcement Agency (LLEA). The handling ofPolice, which is the lead Local Law Enforcement Agency (LLEA). The handling ofPolice, which is the lead Local Law Enforcement Agency (LLEA). The handling of security matters is addressed in the ISFSI Physical Security Plan and Incidentsecurity matters is addressed in the ISFSI Physical Security Plan and Incidentsecurity matters is addressed in the ISFSI Physical Security Plan and Incident Response Plan.Response Plan.Response Plan.

1.21.2 Ambulance ServiceAmbulance Service 1.2 Ambulance Service Ambulance service is provided by the Verplanck Fire District in accordance withAmbulance service is provided by the Verplanck Fire District in accordance with Ambulance service is provided by the Verplanck Fire District in accordance with our LOA with the Verplanck Fire District. The Verplanck Fire District will coordinateour LOA with the Verpianck Fire District. The Verplanck Fire District will coordinate our LOA with the Verplanck Fire District. The Verplanck Fire District will coordinate with other responding agencies, as necessary. This service is available on a 24-with other responding agencies, as necessary. This service is available on a 24-with other responding agencies, as necessary. This service is available on a 24-hour-per-day basis. Onsite procedures contain instructions that cover the call forhour-per-day basis. Onsite procedures contain instructions that cover the call forhour-per-day basis. Onsite procedures contain instructions that cover the call for assistance and the handling of the ambulance service personnel.assistance and the handling of the ambulance service personnel.assistance and the handling of the ambulance service personnel.

1.3 Hospital1.31.3HospitalHospital The New York-Presbyterian Hudson Valley Hospital in Cortland Manor has agreedThe New York-Presbyterian Hudson Valley Hospital in Cortland Manor has agreedThe New York-Presbyterian Hudson Valley Hospital in Cortland Manor has agreed to accept patients from IPEC who have been injured, contaminated, or irradiated.to accept patients from IPEC who have been injured, contaminated, or irradiated.

to accept patients from IPEC who have been injured, contaminated, or irradiated.

The hospital provides facilities such as an emergency room, a laboratory, a The hospital provides facilities such as an emergency room, a laboratory, aThe hospital provides facilities such as an emergency room, a laboratory, a radiology department, and a nuclear medicine department.radiology department, and a nuclear medicine department.

radiology department, and a nuclear medicine department.

141.4 Fire1.4FireFire Offsite firefighting and rescue support are provided by the Verplanck Fire District inOffsite firefighting and rescue support are provided by the Verplanck Fire District inOffsite firefighting and rescue support are provided by the Verplanck Fire District in accordance with our LOA with the Verplanck Fire District. The Verplanck Fireaccordance with our LOA with the Verplanck Fire District. The Verplanck Fireaccordance with our LOA with the Verplanck Fire District. The Verplanck Fire District will coordinate with other responding agencies, as necessary.

District will coordinate with other responding agencies, as necessary.District will coordinate with other responding agencies, as necessary.

2.2. State and County (Local) Government Response2. State and County (Local) Government ResponseState and County (Local) Government Response Except for emergency notifications described in Part 2, Section E of this IOEP, andExcept for emergency notifications described in Part 2, Section E of this lIOEP, andExcept for emergency notifications described in Part 2, Section E of this IOEP, and the services described in Part 2, Section C, Paragraph 1, of this IOEP, no specific the services described in Part 2, Section C, Paragraph 1, of this IOEP, no specificthe services described in Part 2, Section C, Paragraph 1, of this IOEP, no specific coordination with the State of New York or the counties surrounding IPEC iscoordination with the State of New York or the counties surrounding IPEC iscoordination with the State of New York or the counties surrounding IPEC is required. State and local response to an emergency will be performed in accordancerequired. State and local response to an emergency will be performed in accordancerequired. State and local response to an emergency will be performed in accordance with each organization's plans and procedures.with each organization's plans and procedures.with each organization's plans and procedures.

C1 23-04 C-1 23-04 C1 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

3. Federal Response Support and Resources

3. Federal Response Support and Resources3. Federal Response Support and Resources In the event of an emergency at the IPEC ISFSI, the NRC Operations Center inIn the event of an emergency at the IPEC ISFSI, the NRC Operations Center inIn the event of an emergency at the IPEC ISFSI, the NRC Operations Center in Rockville, Maryland will be notified immediately after notification of the State of NewRockville, Maryland will be notified immediately after notification of the State of NewRockville, Maryland will be notified immediately after notification of the State of New York and local governments and not later than 60 minutes after an emergencyYork and local governments and not later than 60 minutes after an emergencyYork and local governments and not later than 60 minutes after an emergency declaration or change in classification. Classification and radiological information aredeclaration or change in classification. Classification and radiological information aredeclaration or change in classification. Classification and radiological information are communicated to this office over the commercial telephone line or via a wirelesscommunicated to this office over the commercial telephone line or via a wirelesscommunicated to this office over the commercial telephone line or via a wireless system from the IPEC ISFSI Emergency Response Facility (ERF).

system from the IPEC ISFSI Emergency Response Facility (ERF).

The NRC is the primary Federal agency providing coordination and support to theThe NRC is the primary Federal agency providing coordination and support to the licensee in the event of an emergency at the IPEC ISFSI. NRC responsibilities arelicensee in the event of an emergency at the IPEC ISFSI. NRC responsibilities are directed toward a coordination of Federal efforts to assist the licensee and State anddirected toward a coordination of Federal efforts to assist the licensee and State and local governments in their planning and implementation of emergency preparednesslocal governments in their planning and implementation of emergency preparedness procedures.

procedures.

The NRC response must be regarded primarily as supportive of, and not a substituteThe NRC response must be regarded primarily as supportive of, and not a substitute for, responsible action by IPEC and other key response organizations. The NRC for, responsible action by IPEC and other key response organizations. The NRC must be continually informed of status and possible radiological consequences andmust be continually informed of status and possible radiological consequences and be frequently updated on plans for emergency and recovery actions and needs forbe frequently updated on plans for emergency and recovery actions and needs for assistance.assistance.

4. Letters of Agreement4. Letters of Agreement HDI has entered into agreements with the OROs identified above that will provideHDI has entered into agreements with the OROs identified above that will provide support (local law enforcement support; medical and ambulance services, includingsupport (local law enforcement support; medical and ambulance services, including hospital support; and fire/rescue support) in the event of an emergency at the IPEChospital support; and fire/rescue support) in the event of an emergency at the IPEC ISFSI.

ISFSI.

The agreements are listed in Appendix 1 and are maintained on file. These The agreements are listed in Appendix 1 and are maintained on file. These agreements identify the emergency measures to be provided, the mutually acceptedagreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for the exchange of information.criteria for implementation, and the arrangements for the exchange of information.

C-2 23-04C-2 23-04 ISFSI.HDI has entered into agreements with the OROs identified above that will providemust be continually informed of status and possible radiological consequences andhospital support; and fire/rescue support) in the event of an emergency at the IPECbe frequently updated on plans for emergency and recovery actions and needs forprocedures.licensee in the event of an emergency at the IPEC ISFSI. NRC responsibilities arelocal governments in their planning and implementation of emergency preparednessC-2 23-04criteria for implementation, and the arrangements for the exchange of information.directed toward a coordination of Federal efforts to assist the licensee and State andassistance.agreements identify the emergency measures to be provided, the mutually acceptedsystem from the IPEC ISFSI Emergency Response Facility (ERF).support (local law enforcement support; medical and ambulance services, includingThe NRC is the primary Federal agency providing coordination and support to theThe NRC response must be regarded primarily as supportive of, and not a substituteThe agreements are listed in Appendix 1 and are maintained on file. These4. Letters of Agreementfor, responsible action by IPEC and other key response organizations. The NRC Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Section D: Emergency Classification SystemSection D: Emergency Classification SystemSection D: Emergency Classification System A standard emergency classification and emergency action level (EAL) scheme is inA standard emergency classification and emergency action level (EAL) scheme is in A standard emergency classification and emergency action level (EAL) scheme is in use. This section describes emergency classifications, Initiating Conditions (ICs), EALS,use. This section describes emergency classifications, Initiating Conditions (ICs), EALSs,use. This section describes emergency classifications, Initiating Conditions (ICs), EALs, and postulated emergency situations.and postulated emergency situations.and postulated emergency situations.

This section describes the emergency classification and EAL scheme used to determineThis section describes the emergency classification and EAL scheme used to determineThis section describes the emergency classification and EAL scheme used to determine the minimum response to an abnormal event at the IPEC ISFSI.the minimum response to an abnormal event at the IPEC ISFSI.the minimum response to an abnormal event at the IPEC ISFSI.

1. Emergency Classification System1. Emergency Classification System1.Emergency Classification System The emergency classification system addresses possible or anticipated events andThe emergency classification system addresses possible or anticipated events andThe emergency classification system addresses possible or anticipated events and radiological and non-radiological emergencies at the IPEC ISFSI. The emergencyradiological and non-radiological emergencies at the IPEC ISFSI. The emergencyradiological and non-radiological emergencies at the PEC ISFSI. The emergency classification system categorizes accidents and/or emergency situations into one ofclassification system categorizes accidents and/or emergency situations into one ofclassification system categorizes accidents and/or emergency situations into one of two emergency classification levels depending on emergency conditions at the timetwo emergency classification levels depending on emergency conditions at the timetwo emergency classification levels depending on emergency conditions at the time of the incident: 1) Unusual Event and 2) Alert. Each of these emergency classificationsof the incident: 1) Unusual Event and 2) Alert. Each of these emergency classificationsof the incident: 1) Unusual Event and 2) Alert. Each of these emergency classifications require notification of the IPEC ERO, the State of New York, Westchester andrequire notification of the IPEC ERO, the State of New York, Westchester and require notification of the IPEC ERO, the State of New York, Westchester and Rockland Counties, and the NRC.Rockland Counties, and the NRC.Rockland Counties, and the NRC.

The emergency classification system is based on NEI 99-01, "Development ofThe emergency classification system is based on NEI 99-01, "Development ofThe emergency classification system is based on NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors, Revision 6. The classificationEmergency Action Levels for Non-Passive Reactors", Revision 6. The classificationEmergency Action Levels for Non-Passive Reactors, Revision 6. The classification system referenced in NEI 99-01, Revision 6 has been endorsed by the NRC andsystem referenced in NEI 99-01, Revision 6 has been endorsed by the NRC and system referenced in NEI 99-01, Revision 6 has been endorsed by the NRC and provides a standard method for classifying emergencies.provides a standard method for classifying emergencies.

provides a standard method for classifying emergencies.

Once indications are available that an EAL is met, the event is classified, and theOnce indications are available that an EAL is met, the event is classified, and the Once indications are available that an EAL is met, the event is classified, and the corresponding emergency classification level is promptly declared. Refer to the ISFSIcorresponding emergency classification level is promptly declared. Refer to the ISFSI corresponding emergency classification level is promptly declared. Refer to the ISFSI EAL Technical Bases Document for actual parameter values, and status used toEAL Technical Bases Document for actual parameter values, and status used toEAL Technical Bases Document for actual parameter values, and status used to classify emergencies.classify emergencies.classify emergencies.

Incidents may initially be classified as an Unusual Event and then escalated to an AlertIncidents may initially be classified as an Unusual Event and then escalated to an Alert Incidents may initially be classified as an Unusual Event and then escalated to an Alert if the situation deteriorates. The following Sections outline the actions at eachif the situation deteriorates. The following Sections outline the actions at each if the situation deteriorates. The following Sections outline the actions at each emergency classification level.emergency classification level.emergency classification level.

HDI maintains the capability to assess, classify, and declare an emergency conditionHDI maintains the capability to assess, classify, and declare an emergency conditionHDI maintains the capability to assess, classify, and declare an emergency condition within 30 minutes after the availability of indications to plant personnel that an EALwithin 30 minutes after the availability of indications to plant personnel that an EALwithin 30 minutes after the availability of indications to plant personnel that an EAL threshold has been exceeded. The ISS promptly declares the emergency conditionthreshold has been exceeded. The ISS promptly declares the emergency conditionthreshold has been exceeded. The ISS promptly declares the emergency condition as soon as possible following identification of the appropriate ECL.as soon as possible following identification of the appropriate ECL.

as soon as possible following identification of the appropriate ECL.

1.1 Unusual Event1.1 Unusual Event1.1 Unusual Event An Unusual Event classification indicates events are in progress or have occurredAn Unusual Event classification indicates events are in progress or have occurredAn Unusual Event classification indicates events are in progress or have occurred which indicate a potential degradation of the level of safety of the ISFSI or indicatewhich 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 radioactivea security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected.material requiring offsite response or monitoring are expected.

D-1 23-04 D-1 23-04 D-1 23-04material requiring offsite response or monitoring are expected.a security threat to facility protection has been initiated. No releases of radioactivewhich indicate a potential degradation of the level of safety of the ISFSI or indicate Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

The purpose of the Unusual Event declaration is to: 1) provide for an increasedThe purpose of the Unusual Event declaration is to: 1) provide for an increased The purpose of the Unusual Event declaration is to: 1) provide for an increased awareness of abnormal conditions; 2) provide for systematic handling ofawareness of abnormal conditions; 2) provide for systematic handling ofawareness of abnormal conditions; 2) provide for systematic handling of information and decision-making, and 3) augment on-shift personnel, if deemed information and decision-making, and 3) augment on-shift personnel, if deemedinformation and decision-making, and 3) augment on-shift personnel, if deemed necessary by the Resource Manager.

necessary by the Resource Manager.necessary by the Resource Manager.

Upon declaration of an Unusual Event, offsite authorities shall be informed of theUpon declaration of an Unusual Event, offsite authorities shall be informed of theUpon declaration of an Unusual Event, offsite authorities shall be informed of the emergency declaration and the necessary documentation will be completed asemergency declaration and the necessary documentation will be completed asemergency declaration and the necessary documentation will be completed as specified in the EPIPs. The classification shall be maintained until the emergencyspecified in the EPIPs. The classification shall be maintained until the emergencyspecified in the EPIPs. The classification shall be maintained until the emergency is terminated or the emergency escalates to an Alert. If an escalation to an Alertis terminated or the emergency escalates to an Alert. If an escalation to an Alertis terminated or the emergency escalates to an Alert. if an escalation to an Alert occurs, offsite authorities will be informed of the change within 60 minutes of theoccurs, offsite authorities will be informed of the change within 60 minutes of the occurs, offsite authorities will be informed of the change within 60 minutes of the change in classification.change in classification.change in classification.

1.2 Alert 1.2 Alert1.2Alert An Alert classification indicates events are in progress or have occurred whichAn Alert classification indicates events are in progress or have occurred whichAn Alert classification indicates events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of theinvolve an actual or potential substantial degradation of the level of safety of theinvolve an actual or potential substantial degradation of the level of safety of the facility or a security event that involves probable life-threatening risk to site facility or a security event that involves probable life-threatening risk to sitefacility or a security event that involves probable life-threatening risk to site personnel or damage to site equipment because of Hostile Action. Any releasespersonnel or damage to site equipment because of Hostile Action. Any releasespersonnel or damage to site equipment because of Hostile Action. Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.are expected to be limited to small fractions of the EPA PAG exposure levels.are expected to be limited to small fractions of the EPA PAG exposure levels.

The purpose of the Alert declaration is to: 1) perform event mitigation and radiationThe purpose of the Alert declaration is to: 1) perform event mitigation and radiationThe purpose of the Alert declaration is to: 1) perform event mitigation and radiation monitoring, if required, and 2) ensure that all necessary resources are beingmonitoring, if required, and 2) ensure that all necessary resources are being monitoring, if required, and 2) ensure that all necessary resources are being applied to accident mitigation.applied to accident mitigation.applied to accident mitigation.

Upon classification of an Alert, offsite authorities will be informed of the emergencyUpon classification of an Alert, offsite authorities will be informed of the emergencyUpon classification of an Alert, offsite authorities will be informed of the emergency and the necessary documentation will be completed as specified in the EPIPs. Theand the necessary documentation will be completed as specified in the EPIPs. Theand the necessary documentation will be completed as specified in the EPIPs. The classification shall be maintained until the emergency is terminated. IPEC mayclassification shall be maintained until the emergency is terminated. IPEC may classification shall be maintained until the emergency is terminated. IPEC may enter Recovery operations while in the Alert classification.enter Recovery operations while in the Alert classification.enter Recovery operations while in the Alert classification.

2. Emergency Action Levels and Postulated Accidents 2.2. Emergency Action Levels and Postulated AccidentsEmergency Action Levels and Postulated Accidents Both emergency classifications are characterized by EALs consisting of specificBoth emergency classifications are characterized by EALs consisting of specific Both emergency classifications are characterized by EALs consisting of specific instrument readings and/or observations which indicate to the ISS that an IC hasinstrument readings and/or observations which indicate to the ISS that an IC has instrument readings and/or observations which indicate to the ISS that an IC has been met. These EALs are used to ensure that the initial classification ofbeen met. These EALs are used to ensure that the initial classification ofbeen met. These EALSs are used to ensure that the initial classification of emergencies can be accomplished rapidly, allowing for the prompt identification ofemergencies can be accomplished rapidly, allowing for the prompt identification ofemergencies can be accomplished rapidly, allowing for the prompt identification of the necessary mitigating actions.the necessary mitigating actions.the necessary mitigating actions.

EALs and ICs are provided under the following categories:EALs and ICs are provided under the following categories:EALs and ICs are provided under the following categories:

o lISFSI malfunctione lISFSI malfunction+ lSFSI malfunction

>> Hazards and other conditionseo Hazards and other conditionseo Hazards and other conditions

The Holtec HI-STORM FSAR describes the DBAs applicable to the IPEC ISFSI andThe Holtec HI-STORM FSAR describes the DBAs applicable to the IPEC ISFSI andThe Holtec HI-STORM FSAR describes the DBAs applicable to the IPEC ISFSIl and the radiological dose calculation results. Specific guidance for classifyingthe radiological dose calculation results. Specific guidance for classifying emergencies is found in EPIPs and the ISFSl EAL Technical Bases Document.emergencies is found in EPIPs and the ISFSI EAL Technical Bases Document.

D-2 23-04D-2 23-04 D-2 23-04emergencies is found in EPIPs and the ISFSI EAL Technical Bases Document.the radiological dose calculation results. Specific guidance for classifying Indian Point Energy Center Indian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

3. State and Local Governmental Authorities3. State and Local Governmental Authorities The EALs have been discussed with the State of New York and local governments The EALs have been discussed with the State of New York and local governments (Westchester and Rockland Counties). Further, State and local governmental(Westchester and Rockland Counties). Further, State and local governmental authorities are provided the opportunity to review the ISFSI EALs annually.authorities are provided the opportunity to review the ISFSI EALs annually.

D-3 23-04D-3 23-04 D-3 23-04(Westchester and Rockland Counties). Further, State and local governmentalauthorities are provided the opportunity to review the ISFSl EALs annually.3. State and Local Governmental AuthoritiesThe EALs have been discussed with the State of New York and local governments Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Section E: Notification Methods and Procedures Section E: Notification Methods and ProceduresSection E: Notification Methods and Procedures Procedures are established for notification to the State of New York and local responseProcedures are established for notification to the State of New York and local responseProcedures are established for notification to the State of New York and local response organizations {Westchester and Rockland Counties) and IPEC ERO personnel. Theorganizations (Westchester and Rockland Counties) and IPEC ERO personnel. Theorganizations (Westchester and Rockland Counties) and IPEC ERO personnel. The content of initial and follow-up messages to these organizations has been established.content of initial and follow-up messages to these organizations has been established.content of initial and follow-up messages to these organizations has been established.

1.1. Basis for NotificationBasis for Notification

1. Basis for Notification The notification of personnel and emergency response organizations isThe notification of personnel and emergency response organizations is The notification of personnel and emergency response organizations is commensurate with the hazard posed by the emergency. The emergency commensurate with the hazard posed by the emergency. The emergencycommensurate with the hazard posed by the emergency. The emergency classification system described in Part 2, Section D of this IOEP is the primary basesclassification system described in Part 2, Section D of this IOEP is the primary basesclassification system described in Part 2, Section D of this IOEP is the primary bases for notification and has been mutually agreed upon by applicable State and Federalfor notification and has been mutually agreed upon by applicable State and Federalfor notification and has been mutually agreed upon by applicable State and Federal organizations.organizations.organizations.

The ISS is responsible for identifying the appropriate emergency classification,The ISS is responsible for identifying the appropriate emergency classification, The ISS is responsible for identifying the appropriate emergency classification, declaring the emergency and initiating emergency notifications.declaring the emergency and initiating emergency notifications.

declaring the emergency and initiating emergency notifications.

Notification of an emergency declaration to is required within 60 minutes ofNotification of an emergency declaration to is required within 60 minutes ofNotification of an emergency declaration to is required within 60 minutes of emergency declaration, escalation, or change in radiological release status.emergency declaration, escalation, or change in radiological release status.emergency declaration, escalation, or change in radiological release status.

The following will receive notification of an emergency declaration:The following will receive notification of an emergency declaration:The following will receive notification of an emergency declaration:

e State of New Yorke State of New York o State of New York eo Westchester Countyeo Westchester Countyeo Westchester County e Rockland County¢ Rockland County¢ Rockland County

IPEC, in cooperation with State and local authorities, has established mutuallyIPEC, in cooperation with State and local authorities, has established mutuallyIPEC, in cooperation with State and local authorities, has established mutually agreeable methods for notification. Notification methods to offsite agencies include aagreeable methods for notification. Notification methods to offsite agencies include a agreeable methods for notification. Notification methods to offsite agencies include a means of verification or authentication. Notification of an emergency declaration ismeans of verification or authentication. Notification of an emergency declaration ismeans of verification or authentication. Notification of an emergency declaration is the responsibility of the Emergency Director.the responsibility of the Emergency Director.the responsibility of the Emergency Director.

1.1 Initial Notification1.1 Initial Notification1.1 For all classified events, Initial Notification shall be provided to the State of NewFor all classified events, Initial Notification shall be provided to the State of New York, Westchester County, and Rockland County promptly following theYork, Westchester County, and Rockland County promptly following the declaration of the emergency, but within 60 minutes of the emergency declaration.declaration of the emergency, but within 60 minutes of the emergency declaration.

The format and content of the initial message is specified in EPIPs and has beenThe format and content of the initial message is specified in EPIPs and has been established with the review and agreement of responsible state authorities. Theestablished with the review and agreement of responsible state authorities. The initial notification contains the following information, as available:initial notification contains the following information, as available:

1) Authenticity, i.e. "This is NOT an Exercise (Drill)" or "This is an Exercise1) Authenticity, i.e. "This is NOT an Exercise (Drill)" or "This is an Exercise (Drill)";(Drill);

2) Location of incident and the name and telephone number (or other applicable

2) Location of incident and the name and telephone number (or other applicable contact information) of the individual providing the notification;contact information) of the individual providing the notification;

3) Date and time of the incident;3) Date and time of the incident;

4) Emergency classification and EAL,4) Emergency classification and EAL;

5) Emergency response actions underway;5) Emergency response actions underway;

E-1 23-04E-1 23-04

1) Authenticity, i.e. "This is NOT an Exercise (Drill)" or "This is an ExerciseFor all classified events, Initial Notification shall be provided to the State of NewInitial NotificationE-1 23-04initial notification contains the following information, as available:(Drill)',5) Emergency response actions underway;3) Date and time of the incident;contact information) of the individual providing the notification;established with the review and agreement of responsible state authorities. Thedeclaration of the emergency, but within 60 minutes of the emergency declaration.2) Location of incident and the name and telephone number {or other applicableThe format and content of the initial message is specified in EPIPs and has been4) Emergency classification and EAL;York, Westchester County, and Rockland County promptly following the Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

6) Whether a release has occurred, is occurring, or is anticipated to occur;6) Whether a release has occurred, is occurring, or is anticipated to occur;6) Whether a release has occurred, is occurring, or is anticipated to occur;

7) Actual or projected dose rates at the site boundary;7) Actual or projected dose rates at the site boundary;7) Actual or projected dose rates at the site boundary;

8) Any request for on-site support from OROs.8) Any request for on-site support from OROs.8) Any request for on-site support from OROs.

1.2 Follow-up Messages1.2 Follow-up Messages1.2 Follow-up Messages Follow-up messages will be provided to the State of New York, WestchesterFollow-up messages will be provided to the State of New York, WestchesterFollow-up messages will be provided to the State of New York, Westchester County, and Rockland County as needed or on agreed upon intervals establishedCounty, and Rockland County as needed or on agreed upon intervals establishedCounty, and Rockland County as needed or on agreed upon intervals established with the offsite authorities. The content of follow-up messages is consistent withwith the offsite authorities. The content of follow-up messages is consistent with with the offsite authorities. The content of follow-up messages is consistent with that provided for initial notifications described above, as known and appropriate.that provided for initial notifications described above, as known and appropriate.that provided for initial notifications described above, as known and appropriate.

2. Notification of the NRC2. Notification of the NRC2. Notification of the NRC The NRC is notified immediately following notification of the State of New York andThe NRC is notified immediately following notification of the State of New York andThe NRC is notified immediately following notification of the State of New York and local governments, and not later than 60 minutes after the time of initial emergencylocal governments, and not later than 60 minutes after the time of initial emergencylocal governments, and not later than 60 minutes after the time of initial emergency declaration, escalation, termination, or entry into recovery phase. NRC notifications declaration, escalation, termination, or entry into recovery phase. NRC notificationsdeclaration, escalation, termination, or entry into recovery phase. NRC notifications will be performed utilizing the commercial phone system. Notification to the NRC is will be performed utilizing the commercial phone system. Notification to the NRC iswill be performed utilizing the commercial phone system. Notification to the NRC is the responsibility of the Emergency Director.

the responsibility of the Emergency Director.the responsibility of the Emergency Director.

3. Notification of the IPEC ERO3. Notification of the IPEC ERO3. Notification of the IPEC ERO The Resource Manager is notified of an emergency declaration by an onsiteThe Resource Manager is notified of an emergency declaration by an onsiteThe Resource Manager is notified of an emergency declaration by an onsite announcement and the commercial telephone system, or other commercial meansannouncement and the commercial telephone system, or other commercial meansannouncement and the commercial telephone system, or other commercial means which may include land line and/or wireless devices. The Emergency Director iswhich may include land line and/or wireless devices. The Emergency Director iswhich may include land line and/or wireless devices. The Emergency Director is responsible for the notification to the Resource Manager.

responsible for the notification to the Resource Manager.responsible for the notification to the Resource Manager.

As described in Part 2, Section B of this IOEP, the on-shift staff positions are staffedAs described in Part 2, Section B of this IOEP, the on-shift staff positions are staffed As described in Part 2, Section B of this IOEP, the on-shift staff positions are staffed on a 24-hour-per-day basis and can perform all required actions to implement thison a 24-hour-per-day basis and can perform all required actions to implement thison a 24-hour-per-day basis and can perform all required actions to implement this IOEP.IOEP.IOEP.

As described in Part 2, Section B of this IOEP, the Resource Manager will be inAs described in Part 2, Section B of this IOEP, the Resource Manager will be in As described in Part 2, Section B of this IOEP, the Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergencycontact with the Emergency Director within two (2) hours of an emergencycontact with the Emergency Director within two (2) hours of an emergency declaration. Additionally, an Augmented Responder will be contacted for an eventdeclaration. Additionally, an Augmented Responder will be contacted for an eventdeclaration. Additionally, an Augmented Responder will be contacted for an event requiring radiological accident assessment. At the direction of the Emergencyrequiring radiological accident assessment. At the direction of the Emergencyrequiring radiological accident assessment. At the direction of the Emergency Director, additional personnel will be activated to augment the on-shift staff.Director, additional personnel will be activated to augment the on-shift staff.Director, additional personnel will be activated to augment the on-shift staff.

All onsite personnel are notified of the emergency declaration, escalation, orAll onsite personnel are notified of the emergency declaration, escalation, or All onsite personnel are notified of the emergency declaration, escalation, or termination of an emergency by an announcement over the IPEC Public Addresstermination of an emergency by an announcement over the IPEC Public Addresstermination of an emergency by an announcement over the IPEC Public Address System.System.

E-2 23-04E-2 23-04 E-2 23-04System.

Indian Point Energy CenterIndian Point Energy Center Indian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Section F: Emergency Communications Section F: Emergency CommunicationsSection F: Emergency Communications Provisions exist for prompt communications between principal response organizationsProvisions exist for prompt communications between principal response organizationsProvisions exist for prompt communications between principal response organizations and emergency response personnel. The communication systems listed in Table F-1and emergency response personnel. The communication systems listed in Table F-1and emergency response personnel. The communication systems listed in Table F-1 provide the capability for 24-hour-per-day onsite and offsite communications. In the provide the capability for 24-hour-per-day onsite and offsite communications. In theprovide the capability for 24-hour-per-day onsite and offsite communications. In the event of an emergency declaration, these communications systems provide theevent of an emergency declaration, these communications systems provide the event of an emergency declaration, these communications systems provide the appropriate means for alerting or activating emergency response personnel in eachappropriate means for alerting or activating emergency response personnel in eachappropriate means for alerting or activating emergency response personnel in each response organization and allow continuous means of contact throughout theresponse organization and allow continuous means of contact throughout theresponse organization and allow continuous means of contact throughout the emergency.emergency.

emergency.

Communication systems are tested to verify proper operation at the testing frequencyCommunication systems are tested to verify proper operation at the testing frequencyCommunication systems are tested to verify proper operation at the testing frequency specified in Table F-1. A testing frequency of Frequent Use indicates that thespecified in Table F-1. A testing frequency of Frequent Use indicates that thespecified in Table F-1. A testing frequency of Frequent Use" indicates that the associated equipment is normally used at a sufficiently high regularity (e.g., multipleassociated equipment is normally used at a sufficiently high regularity (e.g., multipleassociated equipment is normally used at a sufficiently high regularity (e.g., multiple times each day), such that separate additional testing is not needed. Functionality istimes each day), such that separate additional testing is not needed. Functionality istimes each day), such that separate additional testing is not needed. Functionality is verified through normal (frequent) use of the system.verified through normal (frequent) use of the system.

verified through normal (frequent) use of the system.

Table F-1Table F-1 Table F-1 Emergency Communications SystemsEmergency Communications SystemsEmergency Communications Systems Communication System Testing FrequencyCommunication System Testing Frequency Communication System Testing Frequency Commercial Telephone System Frequent UseCommercial Telephone System Frequent UseCommercial Telephone System Frequent Use Portable Radios Frequent UsePortable Radios Frequent UsePortable Radios Frequent Use Wireless Communications Frequent UseWireless Communications Frequent Use Wireless Communications Frequent Use

Communications equipment is operationally checked in accordance with Part 2, SectionCommunications equipment is operationally checked in accordance with Part 2, SectionCommunications equipment is operationally checked in accordance with Part 2, Section H of this IOEP to ensure reliable operation. The commercial telephone system isH of this IOEP to ensure reliable operation. The commercial telephone system isH of this IOEP to ensure reliable operation. The commercial telephone system is available at the IPEC ISFSI. The commercial telephone system is used for onsite andavailable at the IPEC ISFSI. The commercial telephone system is used for onsite andavailable at the IPEC ISFSI. The commercial telephone system is used for onsite and offsite communications; including the means for requesting medical, law enforcementoffsite communications; including the means for requesting medical, law enforcementoffsite communications; including the means for requesting medical, law enforcement and fire/rescue services via 911; and as the primary means of notifying and activatingand fire/rescue services via 911; and as the primary means of notifying and activatingand fire/rescue services via 911; and as the primary means of notifying and activating the IPEC ERO.the IPEC ERO.

the IPEC ERO.

Commercial telephones serve as the primary means of providing emergencyCommercial telephones serve as the primary means of providing emergencyCommercial telephones serve as the primary means of providing emergency notifications to the State of New York, Westchester and Rockland Counties, and thenotifications to the State of New York, Westchester and Rockland Counties, and thenotifications to the State of New York, Westchester and Rockland Counties, and the NRC and is used to provide initial and follow-up notifications and for general informationNRC and is used to provide initial and follow-up notifications and for general informationNRC and is used to provide initial and follow-up notifications and for general information flow between these agencies.flow between these agencies.flow between these agencies.

In the event the commercial telephone systems are unavailable, wirelessIn the event the commercial telephone systems are unavailable, wirelessIn the event the commercial telephone systems are unavailable, wireless communications can be used as a backup means to make emergency notifications andcommunications can be used as a backup means to make emergency notifications and maintain continuous communications with the state and counties and can serve as amaintain continuous communications with the state and counties and can serve as a backup means of notifying and activating the IPEC ERO.backup means of notifying and activating the IPEC ERO.

F-1 23-04 F-1 23-04maintain continuous communications with the state and counties and can serve as abackup means of notifying and activating the IPEC ERO.communications can be used as a backup means to make emergency notifications and Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Section G: Public Education and InformationSection G: Public Education and InformationSection G: Public Education and Information The principal points of contact with the news media for dissemination of informationThe principal points of contact with the news media for dissemination of informationThe principal points of contact with the news media for dissemination of information during an emergency are established in advance, and procedures for coordinatedduring an emergency are established in advance, and procedures for coordinatedduring an emergency are established in advance, and procedures for coordinated dissemination of information to the public are established.dissemination of information to the public are established.dissemination of information to the public are established.

The Emergency Director or Resource Manager will notify Communications personnel ofThe Emergency Director or Resource Manager will notify Communications personnel of The Emergency Director or Resource Manager will notify Communications personnel of an emergency declaration. Communications personnel and will serve as spokespersonan emergency declaration. Communications personnel and will serve as spokespersonan emergency declaration. Communications personnel and will serve as spokesperson and will monitor media activity and coordinate with senior management to addressand will monitor media activity and coordinate with senior management to addressand will monitor media activity and coordinate with senior management to address rumors and disseminate information to the public.rumors and disseminate information to the public.rumors and disseminate information to the public.

To ensure timely dissemination of information to the public, news conferences can beTo ensure timely dissemination of information to the public, news conferences can be To ensure timely dissemination of information to the public, news conferences can be conducted onsite or at other locations, as necessary. Communications personnel, orconducted onsite or at other locations, as necessary. Communications personnel, or conducted onsite or at other locations, as necessary. Communications personnel, or senior IPEC or HDI management will represent the facility as the companysenior IPEC or HDI management will represent the facility as the companysenior IPEC or HDI management will represent the facility as the company spokesperson.spokesperson.spokesperson.

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Section H: Emergency Facilities and EquipmentSection H: Emergency Facilities and EquipmentSection H: Emergency Facilities and Equipment Adequate emergency facilities and equipment to support the emergency response areAdequate emergency facilities and equipment to support the emergency response areAdequate emergency facilities and equipment to support the emergency response are provided and maintained. This section of the IOEP identifies and describes the ERF,provided and maintained. This section of the IOEP identifies and describes the ERF,provided and maintained. This section of the IOEP identifies and describes the ERF, assessment equipment, the first aid and medical facilities, and protective equipment andassessment equipment, the first aid and medical facilities, and protective equipment andassessment equipment, the first aid and medical facilities, and protective equipment and supplies that can be utilized during an emergency.

supplies that can be utilized during an emergency.supplies that can be utilized during an emergency.

This section of the IOEP also describes the surveillance programs used to monitor andThis section of the IOEP also describes the surveillance programs used to monitor andThis section of the IOEP also describes the surveillance programs used to monitor and ensure that facilities and equipment are maintained in a high degree of constantensure that facilities and equipment are maintained in a high degree of constantensure that facilities and equipment are maintained in a high degree of constant readiness.readiness.readiness.

1.1.1.Emergency Response FacilityEmergency Response FacilityEmergency Response Facility During an emergency, command and control functions are managed within the ERF.During an emergency, command and control functions are managed within the ERF.During an emergency, command and control functions are managed within the ERF.

From this location, the Emergency Director (or other personnel, as directed) canFrom this location, the Emergency Director (or other personnel, as directed) canFrom this location, the Emergency Director (or other personnel, as directed) can assess ISFSI conditions; evaluate the magnitude and potential consequences ofassess ISFSI conditions; evaluate the magnitude and potential consequences ofassess ISFSI conditions; evaluate the magnitude and potential consequences of abnormal conditions; initiate preventative and corrective actions; and performabnormal conditions; initiate preventative and corrective actions; and performabnormal conditions; initiate preventative and corrective actions; and perform emergency notifications.emergency notifications.emergency notifications.

The ERF is staffed in accordance with Part 2, Section B of this IOEP. The facility The EREF is staffed in accordance with Part 2, Section B of this IOEP. The facilityThe ERF is staffed in accordance with Part 2, Section B of this IOEP. The facility provides sufficient space to accommodate anticipated response personnel andprovides sufficient space to accommodate anticipated response personnel andprovides sufficient space to accommodate anticipated response personnel and provides 24-hour availability of the communications systems specified in Part 2,provides 24-hour availability of the communications systems specified in Part 2,provides 24-hour availability of the communications systems specified in Part 2, Section F of this IOEP. Radiological conditions resulting from the DBAs specified inSection F of this IOEP. Radiological conditions resulting from the DBAs specified inSection F of this IOEP. Radiological conditions resulting from the DBAs specified in the Holtec HI-STORM FSAR do not inhibit staffing of the ERF.the Holtec HI-STORM FSAR do not inhibit staffing of the ERF.the Holtec HI-STORM FSAR do not inhibit staffing of the ERF.

Emergency Equipment and Supplies

. Emergency Equipment and SuppliesEmergency Equipment and Supplies This section describes the monitoring instruments used to initiate emergencyThis section describes the monitoring instruments used to initiate emergencyThis section describes the monitoring instruments used to initiate emergency measures and provide continuing assessment of conditions throughout the course ofmeasures and provide continuing assessment of conditions throughout the course ofmeasures and provide continuing assessment of conditions throughout the course of an emergency.an emergency.an emergency.

2.1 Portable Radiation and Contamination Monitoring Instruments 212.1Portable Radiation and Contamination Monitoring InstrumentsPortable Radiation and Contamination Monitoring Instruments IPEC maintains portable radiation and contamination monitoring equipment IPEC maintains portable radiation and contamination monitoring equipmentIPEC maintains portable radiation and contamination monitoring equipment necessary for monitoring the conditions of the ISFSI. These instruments are necessary for monitoring the conditions of the ISFSI. These instruments arenecessary for monitoring the conditions of the ISFSI. These instruments are normally utilized and maintained by radiation monitoring personnel and arenormally utilized and maintained by radiation monitoring personnel and arenormally utilized and maintained by radiation monitoring personnel and are available for emergency use.available for emergency use.available for emergency use.

2.2 Communication Systems 2.22.2Communication SystemsCommunication Systems Communications systems providing for 24-hour per day onsite and offsite Communications systems providing for 24-hour per day onsite and offsiteCommunications systems providing for 24-hour per day onsite and offsite communications capabilities are identified and tested as described in Part 2, communications capabilities are identified and tested as described in Part 2,communications capabilities are identified and tested as described in Part 2, Section F of this IOEP.Section F of this IOEP.Section F of this (OEP.

2.3 First Aid Facility2.32.3First Aid FacilityFirst Aid Facility First aid supplies and equipment are located at the ERF. Qualified personnel areFirst aid supplies and equipment are located at the ERF. Qualified personnel areFirst aid supplies and equipment are located at the ERF. Qualified personnel are available on a 24-hour-per-day basis to provide medical treatment as referenced in available on a 24-hour-per-day basis to provide medical treatment as referenced inavailable on a 24-hour-per-day basis to provide medical treatment as referenced in Part Il, Section L of this IOEP.Part Il, Section L of this IOEP.Part Il, Section L of this IOEP.

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2.4 Emergency Supplies2.4 Emergency Supplies 2.4 Emergency Supplies Emergency equipment and supplies necessary to carry out the provisions of theEmergency equipment and supplies necessary to carry out the provisions of theEmergency equipment and supplies necessary to carry out the provisions of the IOEP and EPIPs are maintained at the ERF. Emergency kits are maintained inIOEP and EPIPs are maintained at the ERF. Emergency kits are maintained inIOEP and EPIPs are maintained at the ERF. Emergency kits are maintained in accordance with the EPIPs and contain self-reading dosimeters. Sufficient accordance with the EPIPs and contain self-reading dosimeters. Sufficientaccordance with the EPIPs and contain self-reading dosimeters. Sufficient reserves of instruments/equipment are provided to replace those which arereserves of instruments/equipment are provided to replace those which are reserves of instruments/equipment are provided to replace those which are removed from emergency kits for calibration or repair. Calibration of instrumentsremoved from emergency kits for calibration or repair. Calibration of instrumentsremoved from emergency kits for calibration or repair. Calibration of instruments has been established at intervals recommended by instrument suppliers, or ashas been established at intervals recommended by instrument suppliers, or ashas been established at intervals recommended by instrument suppliers, or as required by Federal regulations.required by Federal regulations.required by Federal regulations.

Table H-1 lists equipment, supplies, and reference materials that are to beTable H-1 lists equipment, supplies, and reference materials that are to beTable H-1 lists equipment, supplies, and reference materials that are to be maintained in the ERF and other onsite locations. Emergency equipment andmaintained in the ERF and other onsite locations. Emergency equipment and maintained in the ERF and other onsite locations. Emergency equipment and supplies are stored at various locations throughout the site for immediate use bysupplies are stored at various locations throughout the site for immediate use bysupplies are stored at various locations throughout the site for immediate use by emergency forces.emergency forces.emergency forces.

TABLE H-1TABLE H-1TABLE H-1 Typical Emergency EquipmentTypical Emergency EquipmentTypical Emergency Equipment Emergency equipment and supplies are stored at various locations throughout the site Emergency equipment and supplies are stored at various locations throughout the siteEmergency equipment and supplies are stored at various locations throughout the site for immediate use by emergency personnel. The following is a listing of the types offor immediate use by emergency personnel. The following is a listing of the types of for immediate use by emergency personnel. The following is a listing of the types of equipment and supplies stored at various locations:equipment and supplies stored at various locations:equipment and supplies stored at various locations:

Emergency Response Facility Emergency Response FacilityEmergency Response Facility Procedures / Reference Materials IOEPProcedures / Reference Materials IOEPProcedures / Reference Materials IOEP ISFSI EAL Technical Bases DocumentISFSI EAL Technical Bases DocumentISFSI EAL Technical Bases Document Emergency Telephone DirectoryEmergency Telephone DirectoryEmergency Telephone Directory EPIPsEPIPsEPIPs

Equipment: Portable radiation monitoring instrumentsEquipment: Portable radiation monitoring instrumentsEquipment: Portable radiation monitoring instruments Portable emergency lightingPortable emergency lightingPortable emergency lighting Medical emergency response kitMedical emergency response kitMedical emergency response Kit Onsite LocationsOnsite LocationsOnsite Locations Equipment / Emergency Supplies: Portable radiation and contamination monitoringEquipment / Emergency Supplies: Portable radiation and contamination monitoringEquipment/ Emergency Supplies: Portable radiation and contamination monitoring instrumentsinstrumentsinstruments Contamination control suppliesContamination control suppliesContamination control supplies Decontamination suppliesDecontamination suppliesDecontamination supplies Protective clothingProtective clothing DosimetersDosimeters Radiological postings and barricadesRadiological postings and barricades

H-2 23-04H-2 23-04 H-2 23-04Radiological postings and barricadesProtective clothingDosimeters Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Section: Accident AssessmentSection l: Accident AssessmentSection: Accident Assessment Effective response to a potential emergency requires assessment to determine theEffective response to a potential emergency requires assessment to determine theEffective response to a potential emergency requires assessment to determine the nature of the emergency and its actual and potential consequences. IPEC hasnature of the emergency and its actual and potential consequences. IPEC hasnature of the emergency and its actual and potential consequences. IPEC has established various methods to evaluate and monitor the effects of a potentialestablished various methods to evaluate and monitor the effects of a potential emergency and has the appropriate means to ensure adequate assessment.emergency and has the appropriate means to ensure adequate assessment.

The assessment activities required to evaluate a particular emergency depend on theThe assessment activities required to evaluate a particular emergency depend on the specific nature and classification of the emergency. The Emergency Director isspecific nature and classification of the emergency. The Emergency Director is responsible for the initial measurement of ISFSI dose rates after off-normal, naturalresponsible for the initial measurement of ISFSI dose rates after off-normal, natural phenomena, or accident events. The EALs identify the parameter values to determinephenomena, or accident events. The EALs identify the parameter values to determine the emergency condition. Classification of events is performed by the Emergencythe emergency condition. Classification of events is performed by the Emergency Director in accordance with the EAL scheme.Director in accordance with the EAL scheme.

If the measured ISFSI dose rates exceed the EAL threshold, the Emergency DirectorIf the measured ISFSI dose rates exceed the EAL threshold, the Emergency Director ensures a radioactive release assessment in the vicinity of the affected storage moduleensures a radioactive release assessment in the vicinity of the affected storage module or cask is performed. After the assessment is complete, the Emergency Directoror cask is performed. After the assessment is complete, the Emergency Director contacts the Resource Manager for assistance in interpreting the results of thecontacts the Resource Manager for assistance in interpreting the results of the radioactive release assessment.

radioactive release assessment.

Notification of the radiological release assessment is performed in accordance with PartNotification of the radiological release assessment is performed in accordance with Part 2, Section E of this lOEP.2, Section E of this IOEP.

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[-1 23-04 1-1 23-04If the measured ISFSI dose rates exceed the EAL threshold, the Emergency DirectorNotification of the radiological release assessment is performed in accordance with PartDirector in accordance with the EAL scheme.phenomena, or accident events. The EALs identify the parameter values to determineresponsible for the initial measurement of ISFSl dose rates after off-normal, naturalradioactive release assessment.contacts the Resource Manager for assistance in interpreting the results of theestablished various methods to evaluate and monitor the effects of a potentialensures a radioactive release assessment in the vicinity of the affected storage moduleemergency and has the appropriate means to ensure adequate assessment.specific nature and classification of the emergency. The Emergency Director isor cask is performed. After the assessment is complete, the Emergency Director2, Section E of this IOEP.The assessment activities required to evaluate a particular emergency depend on thethe emergency condition. Classification of events is performed by the Emergency Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Section J: Protective ActionsSection J: Protective ActionsSection J: Protective Actions Protective actions for onsite personnel are provided for their health and safety.Protective actions for onsite personnel are provided for their health and safety.Protective actions for onsite personnel are provided for their health and safety.

Implementation guidelines for onsite protective actions are provided in EPIPs.

Implementation guidelines for onsite protective actions are provided in EPIPs.Implementation guidelines for onsite protective actions are provided in EPIPs.

Additionally, implementing procedures provide for a range of protective actions to Additionally, implementing procedures provide for a range of protective actions toAdditionally, implementing procedures provide for a range of protective actions to protect onsite personnel during security events.protect onsite personnel during security events.

protect onsite personnel during security events.

1.1.1. Notification of On-site PersonnelNotification of On-site PersonnelNotification of On-site Personnel Facility personnel, contractors, and visitors are notified of an emergency using the Facility personnel, contractors, and visitors are notified of an emergency using theFacility personnel, contractors, and visitors are notified of an emergency using the IPEC Public Address System. Announcements include response actions to be takenIPEC Public Address System. Announcements include response actions to be takenIPEC Public Address System. Announcements include response actions to be taken by onsite and contractor personnel. Additionally, the announcements describe anyby onsite and contractor personnel. Additionally, the announcements describe anyby onsite and contractor personnel. Additionally, the announcements describe any necessary actions for visitors.necessary actions for visitors.

necessary actions for visitors.

The Security Force will ensure that individuals in the Owner Controlled Area areThe Security Force will ensure that individuals in the Owner Controlled Area areThe Security Force will ensure that individuals in the Owner Controlled Area are notified as necessary of any emergency and the response actions to be taken.notified as necessary of any emergency and the response actions to be taken.notified as necessary of any emergency and the response actions to be taken.

2. AccountabilityAccountabilityAccountability The Emergency Director has the authority to initiate personnel accountability.The Emergency Director has the authority to initiate personnel accountability.The Emergency Director has the authority to initiate personnel accountability.

Accountability should be considered and used as a protective action whenever a riskAccountability should be considered and used as a protective action whenever a riskAccountability should be considered and used as a protective action whenever a risk to health or safety exists, or at the discretion of the Emergency Director. If personnelto health or safety exists, or at the discretion of the Emergency Director. If personnelto health or safety exists, or at the discretion of the Emergency Director. If personnel accountability is required, at the direction of the Emergency Director, all individualsaccountability is required, at the direction of the Emergency Director, all individualsaccountability is required, at the direction of the Emergency Director, all individuals at the facility (including employees without emergency assignments, visitors, andat the facility (including employees without emergency assignments, visitors, andat the facility (including employees without emergency assignments, visitors, and contractor personnel) shall be notified of the emergency and provided with contractor personnel) shall be notified of the emergency and provided withcontractor personnel) shall be notified of the emergency and provided with instructions.instructions.instructions.

Accountability of all personnel inside the ISFSI Protected Area should beAccountability of all personnel inside the ISFSI Protected Area should beAccountability of all personnel inside the ISFSI Protected Area should be accomplished within 60 minutes after event declaration and maintained thereafter ataccomplished within 60 minutes after event declaration and maintained thereafter ataccomplished within 60 minutes after event declaration and maintained thereafter at the discretion of the Emergency Director. Following announcement of an emergencythe discretion of the Emergency Director. Following announcement of an emergencythe discretion of the Emergency Director. Following announcement of an emergency declaration, onsite personnel are responsible for reporting to designated areas anddeclaration, onsite personnel are responsible for reporting to designated areas and declaration, onsite personnel are responsible for reporting to designated areas and aiding the accountability process. If personnel are not accounted for, the Emergencyaiding the accountability process. If personnel are not accounted for, the Emergencyaiding the accountability process. If personnel are not accounted for, the Emergency Director is notified, and onsite announcements are made. If personnel are stillDirector is notified, and onsite announcements are made. If personnel are stillDirector is notified, and onsite announcements are made. If personnel are still unaccounted for following the onsite announcements, Security will initiate sweeps tounaccounted for following the onsite announcements, Security will initiate sweeps tounaccounted for following the onsite announcements, Security will initiate sweeps to locate the missing individual(s).locate the missing individual(s).locate the missing individual(s).

Accountability may be suspended or delayed if movement of personnel would placeAccountability may be suspended or delayed if movement of personnel would placeAccountability may be suspended or delayed if movement of personnel would place them in more danger than leaving them in place, such as outside weather conditionsthem in more danger than leaving them in place, such as outside weather conditionsthem in more danger than leaving them in place, such as outside weather conditions or security events.or security events.or security events.

Accountability of persons located within the Site Boundary but outside the ISFSlAccountability of persons located within the Site Boundary but outside the ISFSIAccountability of persons located within the Site Boundary but outside the ISFSI Protected Area is not required.Protected Area is not required.Protected Area is not required.

3. Personnel and Visitors Located outside of the ISFSI Protected AreaPersonnel and Visitors Located outside of the ISFSI Protected AreaPersonnel and Visitors Located outside of the ISFS] Protected Area Other areas within the Site Boundary may be affected by the need to relocateOther areas within the Site Boundary may be affected by the need to relocateOther areas within the Site Boundary may be affected by the need to relocate personnel. If required, the Emergency Director will determine the specific areaspersonnel. If required, the Emergency Director will determine the specific areaspersonnel. If required, the Emergency Director will determine the specific areas requiring protective actions. Personnel and visitors located outside of the ISFSIrequiring protective actions. Personnel and visitors located outside of the ISFSI

J-1 23-04J-1 23-04 requiring protective actions. Personnel and visitors located outside of the [SFSIJ-1 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Protected Area but within the Site Boundary, will be directed to report to anProtected Area but within the Site Boundary, will be directed to report to anProtected Area but within the Site Boundary, will be directed to report to an assembly area or exit the site as appropriate, in accordance with EPIPs.

assembly area or exit the site as appropriate, in accordance with EPIPs.assembly area or exit the site as appropriate, in accordance with EPIPs.

In the event of a suspected radiological release, personnel are monitored forIn the event of a suspected radiological release, personnel are monitored for In the event of a suspected radiological release, personnel are monitored for radioactive contamination prior to leaving the facility. Portable radiation surveyradioactive contamination prior to leaving the facility. Portable radiation surveyradioactive contamination prior to leaving the facility. Portable radiation survey meters are available to monitor for potential contamination.meters are available to monitor for potential contamination.meters are available to monitor for potential contamination.

The Emergency Director is responsible for controlling access to the site when the The Emergency Director is responsible for controlling access to the site when theThe Emergency Director is responsible for controlling access to the site when the IOEP is activated.

IOEP is activated.

J-2 23-04J-2 23-04 IOEP is activated.J-2 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency Plan ISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Section K: Radiological Exposure ControlSection K: Radiological Exposure ControlSection K: Radiological Exposure Control The means for controlling radiological exposures during an emergency are establishedThe means for controlling radiological exposures during an emergency are establishedThe means for controlling radiological exposures during an emergency are established for emergency workers. Exposure guidelines in this section are consistent with the EPAfor emergency workers. Exposure guidelines in this section are consistent with the EPAfor emergency workers. Exposure guidelines in this section are consistent with the EPA PAG Manual (EPA-400/R-17/001).

PAG Manual (EPA-400/R-17/001).PAG Manual (EPA-400/R-17/001).

The general guideline for emergency personnel exposure will be to keep it as low asThe general guideline for emergency personnel exposure will be to keep it as low asThe general guideline for emergency personnel exposure will be to keep it as low as reasonably achievable (ALARA). All reasonable measures shall be taken to control thereasonably achievable (ALARA). All reasonable measures shall be taken to control thereasonably achievable (ALARA). All reasonable measures shall be taken to control the radiation exposure to emergency response personnel providing rescue, first aid,radiation exposure to emergency response personnel providing rescue, first aid,radiation exposure to emergency response personnel providing rescue, first aid, decontamination, emergency transportation, medical treatment services, or corrective ordecontamination, emergency transportation, medical treatment services, or corrective ordecontamination, emergency transportation, medical treatment services, or corrective or assessment actions within applicable limits specified in 10 CFR Part 20.assessment actions within applicable limits specified in 10 CFR Part 20.assessment actions within applicable limits specified in 10 CFR Part 20.

1. Emergency Exposure Guidelines1. Emergency Exposure Guidelines1. Emergency Exposure Guidelines Radiation exposure in an emergency is controlled taking every reasonable effort toRadiation exposure in an emergency is controlled taking every reasonable effort toRadiation exposure in an emergency is controlled taking every reasonable effort to minimize exposure. However, circumstances may warrant exposure in excess of 10minimize exposure. However, circumstances may warrant exposure in excess of 10minimize exposure. However, circumstances may warrant exposure in excess of 10 CFR Part 20 limits. Saving a life, measures to circumvent substantial exposurestoCFR Part 20 limits. Saving a life, measures to circumvent substantial exposurestoCFR Part 20 limits. Saving a life, measures to circumvent substantial exposuresto the general public, or the prevention of damage to critical equipment may bethe general public, or the prevention of damage to critical equipment may bethe general public, or the prevention of damage to critical equipment may be sufficient cause for above normal exposures. The Emergency Director is responsiblesufficient cause for above normal exposures. The Emergency Director is responsible sufficient cause for above normal exposures. The Emergency Director is responsible for authorizing personnel to receive doses in excess of 10 CFR Part 20limits, iffor authorizing personnel to receive doses in excess of 10 CFR Part 20limits, iffor authorizing personnel to receive doses in excess of 10 CFR Part 20limits, if necessary. Table K-1 identifies the exposure guidelines for emergency activities.necessary. Table K-1 identifies the exposure guidelines for emergency activities.necessary. Table K-1 identifies the exposure guidelines for emergency activities.

Table K-1Table K-1Table K-1 Emergency Exposure CriteriaEmergency Exposure CriteriaEmergency Exposure Criteria (Refer to Note 1)(Refer to Note 1)(Refer to Note 1)

Guideline Activity Condition Guideline Activity ConditionGuideline Activity Condition

. All reasonably achievable actionsAll reasonably achievable actions 5 rem All occupational exposures have been taken to minimize dose.5 rem All occupational exposures have been taken to minimize dose.

Exceeding 5 rem is unavoidable andExceeding 5 rem is unavoidable and 10 rem Protecting critical infrastructure necessary l all appropriate actions have been10 rem Protecting critical infrastructure necessary l all appropriate actions have been for public welfare taken to reduce dose. Monitoringfor public welfare taken to reduce dose. Monitoring available to project or measure dose.available to project or measure dose.

Exceeding 5 rem is unavoidable andExceeding 5 rem is unavoidable and 25 rem(e) Lifesaving or Protection of Large all appropriate actions have been25 rem(Xo) Lifesaving or Protection of Large all appropriate actions have been Population taken to reduce dose. MonitoringPopulation taken to reduce dose. Monitoring available to project or measure dose.available to project or measure dose.

... All conditions above and only for,.. All conditions above and only for

>25 rem(ble) Lifesaving or protection of large people fully aware of the risks>25 rem(bXe) Lifesaving or protection of large people fully aware of the riskspopulations involved.

pop involved.

NOTES:NOTES:

1. Reference for this table is Table 3-1 of the EPA PAG Manual.1. Reference for this table is Table 3-1 of the EPA PAG Manual.

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

(b) In the case of a very large incident, consider the need to raise the property and lifesaving(b) In the case of a very large incident, consider the need to raise the property and lifesaving Response Worker Guideline to prevent further loss.Response Worker Guideline to prevent further loss.

(c) Only on a voluntary basis. Response actions that could cause exposures in excess of 25 rem(c) Only on a voluntary basis. Response actions that could cause exposures in excess of 25 rem should only be undertaken with an understanding of the potential acute effects of radiation to theshould only be undertaken with an understanding of the potential acute effects of radiation to the exposed responder and only when the benefits of the action clearly exceed the associated risks.exposed responder and only when the benefits of the action clearly exceed the associated risks.

K-1 23-04K-1 23-04

1. Reference for this table is Table 3-1 of the EPA PAG Manual.10 rem(@ Protecting critical infrastructure necessary l all appropriate actions have been... All conditions above and only forK-1 23-04Exceeding 5 rem is unavoidable andPopulation taken to reduce dose. MonitoringNOTES:Exceeding 5 rem is unavoidable andResponse Worker Guideline to prevent further loss.populations involved.(a) For potential doses > 5 rem, medical monitoring programs should be considered.(b) In the case of a very large incident, consider the need to raise the property and lifesaving(c) Only on a voluntary basis. Response actions that could cause exposures in excess of 25 rem>25 remibte} Lifesaving or protection of large people fully aware of the riska5 rem All occupational exposures have been taken to minimize dose.exposed responder and only when the benefits of the action clearly exceed the associated risks.available to project or measure dose.available to project or measure dose.should only be undertaken with an understanding of the potential acute effects of radiation to the25 rem) Lifesaving or Protection of Large all appropriate actions have beenfor public welfare taken to reduce dose. MonitoringAll reasonably achievable actions Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Onily Emergency Plan

2. Radiation Protection2. Radiation Protection2. Radiation Protection IPEC maintains a radiological exposure control program to ensure that protectionIPEC maintains a radiological exposure control program to ensure that protectionIPEC maintains a radiological exposure control program to ensure that protection against radiological exposure, as set forth in 10 CFR Part 20, is provided. Exposureagainst radiological exposure, as set forth in 10 CFR Part 20, is provided. Exposureagainst radiological exposure, as set forth in 10 CFR Part 20, is provided. Exposure to individuals providing emergency functions will be consistent with the limits to individuals providing emergency functions will be consistent with the limitsto individuals providing emergency functions will be consistent with the limits specified in Table K-1 with every attempt, made to keep exposures As Low Asspecified in Table K-1 with every attempt, made to keep exposures As Low Asspecified in Table K-1 with every attempt, made to keep exposures As Low As Reasonably Achievable (ALARA).Reasonably Achievable (ALARA).Reasonably Achievable (ALARA).

3. Access Control3. Access Control3. Access Control During a classified emergency, radiological surveys of the ISFSI and its immediateDuring a classified emergency, radiological surveys of the ISFSI and its immediateDuring a classified emergency, radiological surveys of the ISFSI and its immediate vicinity will be performed to determine the extent of the radiological concern. Thevicinity will be performed to determine the extent of the radiological concern. Thevicinity will be performed to determine the extent of the radiological concern. The Emergency Director will ensure Radiological Control Areas (RCAs) and accessEmergency Director will ensure Radiological Control Areas (RCAs) and access Emergency Director will ensure Radiological Control Areas (RCAs) and access controls are established to prevent personnel from entering the area. Recovery and controls are established to prevent personnel from entering the area. Recovery andcontrols are established to prevent personnel from entering the area. Recovery and corrective actions will be planned and executed in a manner that minimizescorrective actions will be planned and executed in a manner that minimizescorrective actions will be planned and executed in a manner that minimizes personnel exposure.personnel exposure.personnel exposure.

4. Personnel Exposure Monitoring4. Personnel Exposure Monitoring4. Personnel Exposure Monitoring Personal dosimeters are utilized to monitor the exposure of personnel during normalPersonal dosimeters are utilized to monitor the exposure of personnel during normalPersonal dosimeters are utilized to monitor the exposure of personnel during normai or emergency conditions. Adequate supplies of dosimeters are maintained for useor emergency conditions. Adequate supplies of dosimeters are maintained for useor emergency conditions. Adequate supplies of dosimeters are maintained for use during an emergency. Procedures describe the types of personal dosimeter devices, during an emergency. Procedures describe the types of personal dosimeter devices,during an emergency. Procedures describe the types of personal dosimeter devices, the manner in which they are to be used, who is to wear them, and how they are tothe manner in which they are to be used, who is to wear them, and how they are to the manner in which they are to be used, who is to wear them, and how they are to be cared for.be cared for.

be cared for.

Emergency worker dose records are maintained in accordance with RadiationEmergency worker dose records are maintained in accordance with RadiationEmergency worker dose records are maintained in accordance with Radiation Protection procedures.Protection procedures.Protection procedures.

5. Personnel Contamination Control5. Personnel Contamination Control5. Personnel Contamination Control Various contamination control measures are utilized. These include access controlVarious contamination control measures are utilized. These include access control Various contamination control measures are utilized. These include access control measures and the means for the decontamination of personnel, areas, andmeasures and the means for the decontamination of personnel, areas, andmeasures and the means for the decontamination of personnel, areas, and equipment. These activities are addressed in facility procedures and are brieflyequipment. These activities are addressed in facility procedures and are brieflyequipment. These activities are addressed in facility procedures and are briefly described below.described below.described below.

All personnel are monitored for radioactive contamination prior to leaving the site.

All personnel are monitored for radioactive contamination prior to leaving the site.All personnel are monitored for radioactive contamination prior to leaving the site.

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

During normal or emergency conditions, contamination should be removed from anyDuring normal or emergency conditions, contamination should be removed from anyDuring normal or emergency conditions, contamination should be removed from any part of a person's body prior to leaving the RCA. All personnel decontamination,part of a person's body prior to leaving the RCA. All personnel decontamination,part of a person's body prior to leaving the RCA. All personnel decontamination, including during an emergency, will be performed under the supervision of personnelincluding during an emergency, will be performed under the supervision of personnelincluding during an emergency, will be performed under the supervision of personnel trained in radiological monitoring and assessment and in accordance withtrained in radiological monitoring and assessment and in accordance withtrained in radiological monitoring and assessment and in accordance with established procedures.established procedures.established procedures.

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

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Documentation of surveys, contamination, and decontamination activities shall be maintained in accordance with facility procedures.

Indian Point Energy CenterISFSI-Only Emergency PlanISFSI-Only Emergency PlanIndian Point Energy CenterK-3 23-04K-3 23-04K-3 23-04Documentation of surveys, contamination, and decontamination activities shall beDocumentation of surveys, contamination, and decontamination activities shall bemaintained in accordance with facility procedures.maintained in accordance with facility procedures.

Indian Peint Energy Center Indian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Section L: Medical and Public Health SupportSection L: Medical and Public Health SupportSection L: Medical and Public Health Support Arrangements are made for medical services for contaminated injured individuals. On-Arrangements are made for medical services for contaminated injured individuals. On-Arrangements are made for medical services for contaminated injured individuals. On-shift personnel and equipment are available to provide first aid for personnel working atshift personnel and equipment are available to provide first aid for personnel working atshift personnel and equipment are available to provide first aid for personnel working at the site. Medical emergency supplies are located at various locations onsite.the site. Medical emergency supplies are located at various locations onsite.the site. Medical emergency supplies are located at various locations onsite.

If urgent professional medical help is needed, local ambulance services are available to If urgent professional medical help is needed, local ambulance services are available toIf urgent professional medical help is needed, local ambulance services are available to transport seriously ill, injured, or radioactively contaminated injured personnel.transport seriously ill, injured, or radioactively contaminated injured personnel.transport seriously ill, injured, or radioactively contaminated injured personnel.

1. Onsite First Aid1. Onsite First Aid1. Onsite First Aid First aid assistance at the IPEC ISFSI is designed to address a wide range of commonFirst aid assistance at the IPEC ISFSI is designed to address a wide range of commonFirst aid assistance at the IPEC ISFSI is designed to address a wide range of common injuries. This task is accomplished by on-site individuals trained in basic first aid.injuries. This task is accomplished by on-site individuals trained in basic first aid.injuries. This task is accomplished by on-site individuals trained in basic first aid.

2. Medical Transportation2. Medical Transportation2. Medical Transportation Arrangements have been made for transporting injured, contaminated, and irradiatedArrangements have been made for transporting injured, contaminated, and irradiated Arrangements have been made for transporting injured, contaminated, and irradiated personnel to the hospital via the Verplanck Fire District. These services are available onpersonnel to the hospital via the Verplanck Fire District. These services are available onpersonnel to the hospital via the Verplanck Fire District. These services are available on a 24-hour-per-day basis. Transportation is also available via IPEC vehicles or privatea 24-hour-per-day basis. Transportation is also available via IPEC vehicles or privatea 24-hour-per-day basis. Transportation is also available via IPEC vehicles or private vehicles, if necessary.vehicles, if necessary.vehicles, if necessary.

When personnel are transported to the hospital in a contaminated condition, personnelWhen personnel are transported to the hospital in a contaminated condition, personnelWhen personnel are transported to the hospital in a contaminated condition, personnel trained in radiological monitoring will be dispatched to monitor and maintain radiologicaltrained in radiological monitoring will be dispatched to monitor and maintain radiologicaltrained in radiological monitoring will be dispatched to monitor and maintain radiological controls.controls.controls.

3. Offsite Medical Support3. Offsite Medical Support3. Offsite Medical Support An agreement is in place with New York-Presbyterian Hudson Valley Hospital forAn agreement is in place with New York-Presbyterian Hudson Valley Hospital for An agreement is in place with New York-Presbyterian Hudson Valley Hospital for medical treatment of patients from IPEC who have injuries complicated by radioactivemedical treatment of patients from IPEC who have injuries complicated by radioactive medical treatment of patients from IPEC who have injuries complicated by radioactive contamination. The hospital has trained personnel for handling radioactivelycontamination. The hospital has trained personnel for handling radioactivelycontamination. The hospital has trained personnel for handling radioactively contaminated patients from IPEC. These services and facilities are available on a 24-contaminated patients from IPEC. These services and facilities are available on a 24-contaminated patients from IPEC. These services and facilities are available on a 24-hour-per-day basis.

hour-per-day basis.hour-per-day basis.

Part 2, Section C of this IOEP contains details of the ambulance and hospitalPart 2, Section C of this IOEP contains details of the ambulance and hospitalPart 2, Section C of this IOEP contains details of the ambulance and hospital arrangements and capabilities.arrangements and capabilities.arrangements and capabilities.

L-1 23-04 L-1 23-04 L-1 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Section M: Re-Entry and Recovery PlanningSection M: Re-Entry and Recovery PlanningSection M: Re-Entry and Recovery Planning IPEC has established general plans described in the following sections to addressIPEC has established general plans described in the following sections to address IPEC has established general plans described in the following sections to address recovery from potential emergencies at the IPEC ISFSI. The recovery organization willrecovery from potential emergencies at the IPEC ISFSI. The recovery organization will recovery from potential emergencies at the IPEC ISFSI. The recovery organization will be based on the normal IPEC ISFSI organization.be based on the normal IPEC ISFSI organization.be based on the normal IPEC ISFSI organization.

The senior management position directs the recovery organization and is responsibleThe senior management position directs the recovery organization and is responsibleThe senior management position directs the recovery organization and is responsible for:for:

e Ensuring the IPEC ISFSI is maintained in a safe condition;o Ensuring the IPEC ISFSI is maintained in a safe condition;o Ensuring the IPEC ISFSI is maintained in a safe condition;

• Managing onsite recovery activities during the initial recovery phase;e Managing onsite recovery activities during the initial recovery phase;e Managing onsite recovery activities during the initial recovery phase; o Keeping corporate support apprised of IPEC ISFSI activities and requirements.e Keeping corporate support apprised of IPEC ISFSI activities and requirements.o Keeping corporate support apprised of IPEC ISFSI activities and requirements.

1. Recovery Operations1. Recovery Operations1. Recovery Operations IPEC is responsible for recovery measures and restoring the ISFSI to a stable IPEC is responsible for recovery measures and restoring the ISFSI to a stableIPEC is responsible for recovery measures and restoring the ISFSI to a stable condition. In an emergency event, immediate response actions are directed towardscondition. In an emergency event, immediate response actions are directed towards condition. In an emergency event, immediate response actions are directed towards limiting the consequences of the emergency in a manner that will afford maximumlimiting the consequences of the emergency in a manner that will afford maximum limiting the consequences of the emergency in a manner that will afford maximum protection to onsite personnel. Once the immediate assessment and protectiveprotection to onsite personnel. Once the immediate assessment and protective protection to onsite personnel. Once the immediate assessment and protective actions have been implemented, the restoration and recovery measures can beactions have been implemented, the restoration and recovery measures can beactions have been implemented, the restoration and recovery measures can be initiated.initiated.initiated.

The extent and nature of the corrective and protective actions and the extent ofThe extent and nature of the corrective and protective actions and the extent ofThe extent and nature of the corrective and protective actions and the extent of recovery will depend on the emergency conditions and the status of the ISFSI. The recovery will depend on the emergency conditions and the status of the ISFSI. Therecovery will depend on the emergency conditions and the status of the ISFSI. The general goals for recovery include:general goals for recovery include:general goals for recovery include:

e An orderly evaluation of the cause and effect of the emergency andAn orderly evaluation of the cause and effect of the emergency andAn orderly evaluation of the cause and effect of the emergency and implementation of solutions to prevent immediate recurrence of the incident;implementation of solutions to prevent immediate recurrence of the incident;implementation of solutions to prevent immediate recurrence of the incident;

¢ A planned approach for returning the ISFSI to a stable condition by obtainingA planned approach for returning the ISFSI to a stable condition by obtainingA planned approach for returning the ISFSI to a stable condition by obtaining the appropriate resources, materials, and equipment; the appropriate resources, materials, and equipment;the appropriate resources, materials, and equipment;

¢ A planned approach to coordinate with offsite authorities to identify andA planned approach to coordinate with offsite authorities to identify and resolve situations that may impact the public;resolve situations that may impact the public; e An evaluation of the radiation exposure records for all onsite emergencyAn evaluation of the radiation exposure records for all onsite emergency response personnel involved in the incident; response personnel involved in the incident; e A planned approach to ensure that radiation exposures and contaminationA planned approach to ensure that radiation exposures and contamination controls are consistent with the ALARA program.controls are consistent with the ALARA program.

ISFSI recovery activities shall be in accordance with the ISFSI TechnicalISFSI recovery activities shall be in accordance with the ISFSI Technical Specifications and other licensee documents. During ISFSI recovery, the radiationSpecifications and other licensee documents. During ISFSI recovery, the radiation exposure limits of 10 CFR Part 20 shall apply.exposure limits of 10 CFR Part 20 shall apply.

If, during recovery operations, an emergency situation occurs, recovery efforts willif, during recovery operations, an emergency situation occurs, recovery efforts will be suspended until the emergency condition is resolved. The Emergency Directorbe suspended until the emergency condition is resolved. The Emergency Director will re-evaluate ISFSI conditions prior to resuming recovery.will re-evaluate ISFSI conditions prior to resuming recovery.

The recovery operations will be terminated by IPEC's senior management positionThe recovery operations will be terminated by IPEC's senior management position directing the recovery organization after the ISFSI is returned to a stable condition.

directing the recovery organization after the ISFSI is returned to a stable condition.

M-1 23-04M-1 23-04 ISFSI recovery activities shall be in accordance with the ISFSI TechnicalIf, during recovery operations, an emergency situation occurs, recovery efforts willM-1 23-04be suspended until the emergency condition is resolved. The Emergency Directorresolve situations that may impact the public;response personnel involved in the incident;Specifications and other licensee documents. During ISFSI recovery, the radiationcontrols are consistent with the ALARA program.exposure limits of 10 CFR Part 20 shall apply.directing the recovery organization after the ISFSI is returned to a stable condition.The recovery operations will be terminated by IPEC's senior management positionwill re-evaluate ISFSI conditions prior to resuming recovery.A planned approach to coordinate with offsite authorities to identify andAn evaluation of the radiation exposure records for all onsite emergencyA planned approach to ensure that radiation exposures and contamination Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Section N: Drill and Exercise ProgramSection N: Drill and Exercise ProgramSection N: Drill and Exercise Program Periodic exercises are conducted to evaluate major portions of emergency responsePeriodic exercises are conducted to evaluate major portions of emergency response Periodic exercises are conducted to evaluate major portions of emergency response capabilities. Periodic drills are conducted to develop and maintain key emergencycapabilities. Periodic drills are conducted to develop and maintain key emergencycapabilities. Periodic drills are conducted to develop and maintain key emergency response skills. Deficiencies resulting from exercises or drills are identified andresponse skills. Deficiencies resulting from exercises or drills are identified andresponse skills. Deficiencies resulting from exercises or drills are identified and corrected.corrected.corrected.

An exercise tests the execution of the overall emergency preparedness and theAn exercise tests the execution of the overall emergency preparedness and theAn exercise tests the execution of the overall emergency preparedness and the integration of this preparedness. A drill is a supervised instruction period aimed atintegration of this preparedness. A drill is a supervised instruction period aimed atintegration of this preparedness. A drill is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular response function. A summarytesting, developing, and maintaining skills in a particular response function. A summarytesting, developing, and maintaining skills in a particular response function. A summary of exercises and drills, including the associated elements for each, is outlined below.of exercises and drills, including the associated elements for each, is outlined below.of exercises and drills, including the associated elements for each, is outlined below.

Exercise and Drill scenarios will include, at a minimum, the following:Exercise and Drill scenarios will include, at a minimum, the following:

Exercise and Drill scenarios will include, at a minimum, the following:

The basic objective(s) of the exercise/drillThe basic objective(s) of the exercise/drillThe basic objective(s) of the exercise/drill The date(s), time period, place(s), and participating organization(s)

The date(s), time period, place(s), and participating organization(s)The date(s), time period, place(s), and participating organization(s)

A time schedule of real and simulated eventsA time schedule of real and simulated eventsA time schedule of real and simulated events A narrative summary describing the conduct of the drill to include such items as:A narrative summary describing the conduct of the drill to include such items as:A narrative summary describing the conduct of the drill to include such items as:

Simulated casualtiesSimulated casualtiesSimulated casualties Offsite fire assistance Offsite fire assistanceOffsite fire assistance Rescue of personnelRescue of personnelRescue of personnel Use of protective clothingUse of protective clothingUse of protective clothing

The scenarios will be varied from year to year such that all major elements of the plansThe scenarios will be varied from year to year such that all major elements of the plansThe scenarios will be varied from year tc year such that all major elements of the plans and preparedness organizations are tested.and preparedness organizations are tested.and preparedness organizations are tested.

The scenarios are designed to allow free play in exercising the decision-making processThe scenarios are designed to allow free play in exercising the decision-making processThe scenarios are designed to aliow free play in exercising the decision-making process associated with such emergency response actions as exposure control, emergencyassociated with such emergency response actions as exposure control, emergency associated with such emergency response actions as exposure control, emergency classification, and the ERO and additional staff augmentation process. Starting timesclassification, and the ERO and additional staff augmentation process. Starting times classification, and the ERO and additional staff augmentation process. Starting times and pre-notification for exercises are coordinated with and agreed upon by alland pre-notification for exercises are coordinated with and agreed upon by alland pre-notification for exercises are coordinated with and agreed upon by all participating organizations.participating organizations.participating organizations.

1. Exercises1. Exercises1. Exercises A Biennial Exercise is conducted for the purposes of testing: 1) the adequacy ofA Biennial Exercise is conducted for the purposes of testing: 1) the adequacy ofA Biennial Exercise is conducted for the purposes of testing: 1) the adequacy of timing and content of implementing procedures and methods; 2) emergencytiming and content of implementing procedures and methods; 2) emergencytiming and content of implementing procedures and methods; 2) emergency equipment and communication networks, and 3) to ensure that emergency equipment and communication networks, and 3) to ensure that emergencyequipment and communication networks, and 3) to ensure that emergency personnel are familiar with their duties.

personnel are familiar with their duties.personnel are familiar with their duties.

Offsite organizations are invited and offered the opportunity to participate to theOffsite organizations are invited and offered the opportunity to participate to theOffsite organizations are invited and offered the opportunity to participate to the extent assistance would be expected during an emergency declaration. However,extent assistance would be expected during an emergency declaration. However,extent assistance would be expected during an emergency declaration. However, participation by offsite organizations is not required, nor are offsite response participation by offsite organizations is not required, nor are offsite responseparticipation by offsite organizations is not required, nor are offsite response organizations evaluated.organizations evaluated.organizations evaluated.

2. Drills2. Drills

2. Drills Drills are conducted for the purpose of training, developing, and maintaining theDrills are conducted for the purpose of training, developing, and maintaining the proficiency of emergency responders. At least one drill involving a combination ofproficiency of emergency responders. At least one drill involving a combination of

N-1 23-04N-1 23-04 Drills are conducted for the purpose of training, developing, and maintaining theN-1 23-04proficiency of emergency responders. At least one drill involving a combination of Indian Point Energy CenterIndian Point Energy Center Indian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

some of the principal functional areas of emergency response shall be conducted insome of the principal functional areas of emergency response shall be conducted insome of the principal functional areas of emergency response shall be conducted in the interval between Biennial Exercises for the purpose of testing, developing, andthe interval between Biennial Exercises for the purpose of testing, developing, andthe interval between Biennial Exercises for the purpose of testing, developing, and maintaining the proficiency of emergency responders.maintaining the proficiency of emergency responders.maintaining the proficiency of emergency responders.

2.12.1 Equipment and Proficiency Drills2.1 Equipment and Proficiency DrillsEquipment and Proficiency Drills Drills may be used to test and evaluate the adequacy of the ERF, equipment,Drills may be used to test and evaluate the adequacy of the ERF, equipment, Drills may be used to test and evaluate the adequacy of the ERF, equipment, procedures, communication channels, actions of emergency response personnel,procedures, communication channels, actions of emergency response personnel,procedures, communication channels, actions of emergency response personnel, and coordination between OROs and the facility.and coordination between OROs and the facility.and coordination between OROs and the facility.

Drills may be performed as part of the biennial exercise, integrated drill or as an Drills may be performed as part of the biennial exercise, integrated drill or as anDrills 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 independent drill. A drill may be a component of an exercise. Drills are supervisedindependent drill. A drill may be a component of an exercise. Drills are supervised and evaluated by qualified personnel.

and evaluated by qualified personnel.and evaluated by qualified personnel.

Drills and/or surveillance tests are conducted at IPEC for the following:Drills and/or surveillance tests are conducted at IPEC for the following:Drills and/or surveillance tests are conducted at IPEC for the following:

(1) Communication Drills or Surveillances(1) Communication Drills or Surveillances(1) Communication Drills or Surveillances To ensure that emergency communications systems described in Part 2,To ensure that emergency communications systems described in Part 2,To ensure that emergency communications systems described in Part 2, Section F of this IOEP are operable, communications tests are conductedSection F of this IOEP are operable, communications tests are conducted Section F of this [OEP are operable, communications tests are conducted as outlined below.as outlined below.as outlined below.

>> To test the capability to notify the State of New York, Westchester>> To test the capability to notify the State of New York, Westchestero To test the capability to notify the State of New York, Westchester County, and Rockland County utilizing commercial telephone system,County, and Rockland County utilizing commercial telephone system, County, and Rockland County utilizing commercial telephone system, the capability is functionally tested annually. This drill will include thethe capability is functionally tested annually. This drill will include thethe capability is functionally tested annually. This drill will include the aspect of understanding the content of the message.aspect of understanding the content of the message.aspect of understanding the content of the message.

+ To test the capability to communicate with the NRC, communicatione To test the capability to communicate with the NRC, communication+ To test the capability to communicate with the NRC, communication systems are tested annually.systems are tested annually.systems are tested annually.

+ The communication systems listed below, as detailed in Part 2,e The communication systems listed below, as detailed in Part 2,eo The communication systems listed below, as detailed in Part 2, Section F of this IOEP, are used on a frequent basis. Therefore,Section F of this IOEP, are used on a frequent basis. Therefore,Section F of this IOEP, are used on a frequent basis. Therefore, periodic testing of these capabilities is not necessary.periodic testing of these capabilities is not necessary.periodic testing of these capabilities is not necessary.

o Commercial Telephone Systemo Commercial Telephone Systemo Commercial Telephone System o Portable Radioso Portable Radioso Portable Radios o Wireless communicationso Wireless communicationsco Wireless communications

Performance of the Communication Drills satisfies the testing requirements Performance of the Communication Drills satisfies the testing requirementsPerformance of the Communication Drills satisfies the testing requirements specified in Part 2, Section F of this IOEP.specified in Part 2, Section F of this OEP.specified in Part 2, Section F of this lIOEP.

(2) Fire Drills(2) Fire Drills(2) Fire Drills Fire Drills are conducted in accordance with the Fire Protection Plan.Fire Drills are conducted in accordance with the Fire Protection Plan.Fire Drills are conducted in accordance with the Fire Protection Plan.

(3) Medical Drills(3) Medical Drills(3) Medical Drills To evaluate the training of medical response personnel, a medical drill isTo evaluate the training of medical response personnel, a medical drill isTo evaluate the training of medical response personnel, a medical drill is conducted annually involving a simulated contaminated-injured individualconducted annually involving a simulated contaminated-injured individualconducted annually involving a simulated contaminated-injured individual and may also contain provisions for participation by local fire departmentand may also contain provisions for participation by local fire department

N-2 23-04 N-2 23-04 N-2 23-04and may also contain provisions for participation by local fire department Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

and hospital. This drill may be performed separately or as part of theand hospital. This drill may be performed separately or as part of the and hospital. This drill may be performed separately or as part of the Biennial Exercise. The Verplanck Fire District and New York-Presbyterian Biennial Exercise. The Verplanck Fire District and New York-PresbyterianBiennial Exercise. The Verplanck Fire District and New York-Presbyterian Hudson Valley Hospital are invited to participate to demonstrate andHudson Valley Hospital are invited to participate to demonstrate and Hudson Valley Hospital are invited to participate to demonstrate and practice the receipt and treatment of contaminated patients.practice the receipt and treatment of contaminated patients.

practice the receipt and treatment of contaminated patients.

(4) Radiation Protection Drills(4) Radiation Protection Drills(4) Radiation Protection Drills Radiological monitoring drills are conducted annually. These drillsRadiological monitoring drills are conducted annually. These drillsRadiological monitoring drills are conducted annually. These drills demonstrate the ability to perform radiological survey and assessment anddemonstrate the ability to perform radiological survey and assessment and demonstrate the ability to perform radiological survey and assessment and can be performed separately or as part of an Emergency Plan exercise or can be performed separately or as part of an Emergency Plan exercise orcan be performed separately or as part of an Emergency Plan exercise or drill.drill.

drill.

3. Critique and Evaluation3. Critique and Evaluation3. Critique and Evaluation Critiques are used to evaluate the performance of participating personnel and theCritiques are used to evaluate the performance of participating personnel and theCritiques are used to evaluate the performance of participating personnel and the adequacy of the ERF, equipment, and procedures. The ability of emergency adequacy of the ERF, equipment, and procedures. The ability of emergencyadequacy of the ERF, equipment, and procedures. The ability of emergency response personnel to self-evaluate weaknesses and identify areas for improvementresponse personnel to self-evaluate weaknesses and identify areas for improvement response personnel to self-evaluate weaknesses and identify areas for improvement is key to successful exercise or drill conduct.is key to successful exercise or drill conduct.

is key to successful exercise or drill conduct.

Exercise and drill performance objectives are evaluated against measurableExercise and drill performance objectives are evaluated against measurableExercise and drill performance objectives are evaluated against measurable demonstration criteria. As soon as possible following the conclusion of each exercisedemonstration criteria. As soon as possible following the conclusion of each exercisedemonstration criteria. As soon as possible following the conclusion of each exercise or drill, a critique, including participants and evaluators, is conducted to evaluate theor drill, a critique, including participants and evaluators, is conducted to evaluate theor drill, a critique, including participants and evaluators, is conducted to evaluate the ability of the ERO to implement the IOEP and associated procedures. Deficienciesability of the ERO to implement the IOEP and associated procedures. Deficiencies ability of the ERO to implement the IOEP and associated procedures. Deficiencies identified during exercises or drills are entered into the corrective actions program.identified during exercises or drills are entered into the corrective actions program.identified during exercises or drills are entered into the corrective actions program.

A written report is prepared following an exercise or drill involving the evaluation ofA written report is prepared following an exercise or drill involving the evaluation ofA written report is prepared following an exercise or drill involving the evaluation of designated objectives. The report evaluates and documents the ability of the ERO todesignated objectives. The report evaluates and documents the ability of the ERO todesignated objectives. The report evaluates and documents the ability of the ERO to respond to a simulated emergency. The report will also contain references torespond to a simulated emergency. The report will also contain references to corrective actions and recommendations for revisions to the IOEP, EPIPs and/or the corrective actions and recommendations for revisions to the IOEP, EPIPs and/or the upgrade of emergency equipment and supplies resulting from the exercise or drill.

upgrade of emergency equipment and supplies resulting from the exercise or drill.

N-3 23-04N-3 23-04 N-3 23-04respond to a simulated emergency. The report will also contain references toupgrade of emergency equipment and supplies resulting from the exercise or drill.corrective actions and recommendations for revisions to the IOEP, EPIPs and/or the Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency Plan ISFSI-Only Emergency Plan

Section O: Emergency Response TrainingSection O: Emergency Response TrainingSection O: Emergency Response Training Radiological emergency response training is provided to those who may be called on toRadiological emergency response training is provided to those who may be called on toRadiological emergency response training is provided to those who may be called on to assist in an emergency. All personnel at the IPEC ISFSI who fill required positions in theassist in an emergency. All personnel at the IPEC ISFSI who fill required positions in the assist in an emergency. All personnel at the IPEC ISFSI who fill required positions in the ERO will take part in a training program to ensure adequate preparedness to assist inERO will take part in a training program to ensure adequate preparedness to assist inERO will take part in a training program to ensure adequate preparedness to assist in an emergency. OROs that may be called upon for emergency assistance will also bean emergency. OROs that may be called upon for emergency assistance will also bean emergency. OROs that may be called upon for emergency assistance will also be invited to participate in appropriate training programs.

invited to participate in appropriate training programs.invited to participate in appropriate training programs.

1. Emergency Response Training1.1. Emergency Response TrainingEmergency Response Training Requirements for emergency preparedness training are specified in the EmergencyRequirements for emergency preparedness training are specified in the EmergencyRequirements for emergency preparedness training are specified in the Emergency Preparedness Training Program. This program identifies the level and the depth toPreparedness Training Program. This program identifies the level and the depth toPreparedness Training Program. This program identifies the level and the depth to which individuals are to be trained. The training program for emergency responsewhich individuals are to be trained. The training program for emergency responsewhich individuals are to be trained. The training program for emergency response personnel is based on position-specific responsibilities as defined in the IOEP.personnel is based on position-specific responsibilities as defined in the IOEP.personnel is based on position-specific responsibilities as defined in the IOEP.

Emergency response personnel in the following categories receive initial training andEmergency response personnel in the following categories receive initial training and Emergency response personnel in the following categories receive initial training and annual retraining.annual retraining.

annual retraining.

1.1 ERO Training (ISFSI Shift Supervisor / Emergency Director and Resource1.1 ERO Training (ISFSI Shift Supervisor/ Emergency Director and Resource1.1 ERO Training (ISFSI Shift Supervisor/ Emergency Director and Resource Manager)

Manager)Manager)

The ISS / Emergency Directors and Resource Managers shall have trainingThe ISS / Emergency Directors and Resource Managers shall have training The ISS / Emergency Directors and Resource Managers shall have training conducted such that proficiency is maintained on the topics listed below. Theseconducted such that proficiency is maintained on the topics listed below. These conducted such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.subjects shall be covered as a minimum on an annual basis.subjects shall be covered as a minimum on an annual basis.

EAL ClassificationEAL ClassificationEAL Classification Offsite Notification ProceduresOffsite Notification ProceduresOffsite Notification Procedures ERO ActivationERO ActivationERO Activation Dose Rate Meter OperationDose Rate Meter OperationDose Rate Meter Operation Radioactive Release AssessmentRadioactive Release AssessmentRadioactive Release Assessment Emergency Exposure ControlEmergency Exposure ControlEmergency Exposure Control Protective Actions for Onsite PersonnelProtective Actions for Onsite PersonnelProtective Actions for Onsite Personnel ISFSI DBAsISFSl DBAsISFSI DBAs Review of Applicable Drill/Exercise-ldentified Deficiencies Review of Applicable Drill/Exercise-ldentified DeficienciesReview of Applicable Drill/Exercise-ldentified Deficiencies

Personnel available during declared emergencies who may be called upon toPersonnel available during declared emergencies who may be called upon toPersonnel available during declared emergencies who may be called upon to perform emergency response activities as an extension of their normal dutiesperform emergency response activities as an extension of their normal dutiesperform emergency response activities as an extension of their normal duties receive duty-specific training. Additional emergency preparedness training isreceive duty-specific training. Additional emergency preparedness training isreceive duty-specific training. Additional emergency preparedness training is provided as part of annual access training as delineated in the sections below:

provided as part of annual access training as delineated in the sections below:provided as part of annual access training as delineated in the sections below:

(1) First Aid Response(1) First Aid Response (1) First Aid Response First Aid training is provided to personnel assigned on-shift in accordanceFirst Aid training is provided to personnel assigned on-shift in accordance with site training and qualification plan.with site training and qualification plan.

(2) Fire Response(2) Fire Response Fire Training is conducted in accordance with the Fire Protection Plan.Fire Training is conducted in accordance with the Fire Protection Plan.

0-1 23-040-1 23-04 First Aid training is provided to personnel assigned on-shift in accordanceFire Training is conducted in accordance with the Fire Protection Plan.(2) Fire Response0-1 23-04with site training and qualification plan.

Indian Point Energy CenterIndian Point Energy Centerindian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

(3) Radiation Monitoring Personnel(3) Radiation Monitoring Personnel(3) Radiation Monitoring Personnel Radiation monitoring personnel shall have training conducted such thatRadiation monitoring personnel shall have training conducted such thatRadiation monitoring personnel shall have training conducted such that proficiency is maintained on the topics listed below. These subjects shall be proficiency is maintained on the topics listed below. These subjects shall beproficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.covered as a minimum on an annual basis.covered as a minimum on an annual basis.

Use of Radiation Protection ProceduresUse of Radiation Protection ProceduresUse of Radiation Protection Procedures Use of Emergency Survey EquipmentUse of Emergency Survey Equipment Use of Emergency Survey Equipment CommunicationsCommunicationsCommunications Field SurveysField SurveysField Surveys Role of Dose Assessment in an EmergencyRole of Dose Assessment in an Emergency Role of Dose Assessment in an Emergency Monitoring of Radioactive ReleasesMonitoring of Radioactive ReleasesMonitoring of Radioactive Releases Protective Actions for Onsite PersonnelProtective Actions for Onsite Personnel Protective Actions for Onsite Personnel Review of Applicable Drill/Exercise-ldentified DeficienciesReview of Applicable Dril/Exercise-ldentified DeficienciesReview of Applicable Drill/Exercise-ldentified Deficiencies

(4) Security(4) Security(4) Security Security Response is based upon a normal daily security function that is toSecurity Response is based upon a normal daily security function that is toSecurity Response is based upon a normal daily security function that is to safeguard the site. Security personnel receive specialized training in thesafeguard the site. Security personnel receive specialized training in thesafeguard the site. Security personnel receive specialized training in the following areas:following areas:following areas:

s Assembly / Accountabilitye Assembly / Accountability oe Assembly / Accountability

>> Site Evacuation+ Site Evacuation>> Site Evacuation eo Search and Rescueeo Search and Rescuee Search and Rescue

Personnel Badged for Unescorted AccessPersonnel Badged for Unescorted Access Personnel Badged for Unescorted Access Personnel who are badged for unescorted access receive access trainingPersonnel who are badged for unescorted access receive access trainingPersonnel who are badged for unescorted access receive access training annually. Information pertaining to their safety and the safety of visitorsannually. Information pertaining to their safety and the safety of visitorsannually. Information pertaining to their safety and the safety of visitors under escort during a classified emergency is included in this training.under escort during a classified emergency is included in this training.under escort during a classified emergency is included in this training.

Access training shall include the following emergency preparedness topics:

Access training shall include the following emergency preparedness topics:Access training shall include the following emergency preparedness topics:

Basic Emergency Plan and Implementing Preparedness TopicsBasic Emergency Plan and Implementing Preparedness TopicsBasic Emergency Plan and Implementing Preparedness Topics Emergency Classification LevelsEmergency Classification LevelsEmergency Classification Levels Call-out of Personnel During an EmergencyCall-out of Personnel During an Emergency Call-out of Personnel During an Emergency Personnel Accountability ProceduresPersonnel Accountability ProceduresPersonnel Accountability Procedures

Personnel assigned to work at IPEC receive initial and periodic refresher Personnel assigned to work at IPEC receive initial and periodic refresherPersonnel assigned to work at IPEC receive initial and periodic refresher training on general station procedures and policy. This training includestraining on general station procedures and policy. This training includestraining on general station procedures and policy. This training includes required actions to be taken if an emergency is declared.required actions to be taken if an emergency is declared.required actions to be taken if an emergency is declared.

2. Support Organization Training2. Support Organization Training

2. Support Organization Training Training is offered annually to support organizations (fire, ambulance, medical, andTraining is offered annually to support organizations (fire, ambulance, medical, andTraining is offered annually to support organizations (fire, ambulance, medical, and law enforcement agencies) that may be called upon to provide assistance in thelaw enforcement agencies) that may be called upon to provide assistance in the law enforcement agencies) that may be called upon to provide assistance in the event of an emergency. The training shall be structured to meet the needs of thatevent of an emergency. The training shall be structured to meet the needs of that

0-2 23-04 0-2 23-04 0-2 23-04event of an emergency. The training shall be structured to meet the needs of that Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

organization with respect to the nature of their support. Topics of event notification,organization with respect to the nature of their support. Topics of event notification,organization with respect to the nature of their support. Topics of event notification, site access and orientation, basic radiation protection, and interface activities are site access and orientation, basic radiation protection, and interface activities aresite access and orientation, basic radiation protection, and interface activities are included in the training.included in the training.

included in the training.

3. Training Records3. Training Records. Training Records Records associated with training of IPEC personnel are documented and maintainedRecords associated with training of IPEC personnel are documented and maintainedRecords associated with training of IPEC personnel are documented and maintained in accordance with facility procedures. Records associated with training offered in accordance with facility procedures. Records associated with training offeredin accordance with facility procedures. Records associated with training offered and/or provided to OROs is documented and maintained in accordance with facilityand/or provided to OROs is documented and maintained in accordance with facility and/or provided to OROs is documented and maintained in accordance with facility procedures.procedures.

procedures.

0-3 23-040-3 23-04 0-3 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency Plan ISFSI-Only Emergency Plan

Section P: Responsibility for the Maintenance of the Planning EffortSection P: Responsibility for the Maintenance of the Planning Effort Section P: Responsibility for the Maintenance of the Planning Effort Responsibilities for development, review, and distribution of the IOEP and actions thatResponsibilities for development, review, and distribution of the IOEP and actions thatResponsibilities for development, review, and distribution of the IOEP and actions that must be performed to maintain the IOEP are established, and personnel who performmust be performed to maintain the IOEP are established, and personnel who performmust be performed to maintain the IOEP are established, and personnel who perform the planning are properly trained.the planning are properly trained.the planning are properly trained.

1. Responsibility for Development and Maintenance of the Plan1. Responsibility for Development and Maintenance of the Plan1. Responsibility for Development and Maintenance of the Plan 1.1 Overall Authority and Responsibility1.1 Overall Authority and Responsibility1.1 Overall Authority and Responsibility A member of IPEC's senior management has the overall authority andA member of IPEC's senior management has the overall authority andA member of IPEC's senior management has the overall authority and responsibility for emergency response planning and implementation of the IOEP.responsibility for emergency response planning and implementation of the IOEP.responsibility for emergency response planning and implementation of the OEP.

This responsibility includes ensuring that the emergency preparedness program isThis responsibility includes ensuring that the emergency preparedness program isThis responsibility includes ensuring that the emergency preparedness program is maintained and implemented as described in the IOEP, and that applicablemaintained and implemented as described in the IOEP, and that applicablemaintained and implemented as described in the IOEP, and that applicable requirements and regulations are met.requirements and regulations are met.requirements and regulations are met.

1.2 Maintaining the Emergency Preparedness Program1.2 Maintaining the Emergency Preparedness Program1.2 Maintaining the Emergency Preparedness Program The IPEC ISFSI senior management position is responsible for maintaining anThe IPEC ISFSI senior management position is responsible for maintaining anThe IPEC ISFSI senior management position is responsible for maintaining an adequate knowledge of emergency preparedness regulations, emergency planningadequate knowledge of emergency preparedness regulations, emergency planningadequate knowledge of emergency preparedness regulations, emergency planning techniques, and the latest applications of emergency equipment and supplies. Thetechniques, and the latest applications of emergency equipment and supplies. The techniques, and the latest applications of emergency equipment and supplies. The position is responsible for the following tasks:position is responsible for the following tasks:position is responsible for the following tasks:

e Development, maintenance, and revision of the IOEP and EPIPs areDevelopment, maintenance, and revision of the IOEP and EPIPs areDevelopment, maintenance, and revision of the IOEP and EPIPs are accomplished in accordance with applicable regulations and industryaccomplished in accordance with applicable regulations and industryaccomplished in accordance with applicable regulations and industry standards.standards.standards.

e LOAs listed in Appendix 1 are reviewed biannually and updated, asLOAs listed in Appendix 1 are reviewed biannually and updated, asLOAs listed in Appendix 1 are reviewed biannually and updated, as necessary.necessary.

necessary.

¢ Review and approve the IOEP and Emergency Planning Procedures prior toReview and approve the IOEP and Emergency Planning Procedures prior toReview and approve the IOEP and Emergency Planning Procedures prior to implementation.implementation.implementation.

o Development and maintenance of 10 CFR 50.54(q) evaluations of programDevelopment and maintenance of 10 CFR 50.54(q) evaluations of program Development and maintenance of 10 CFR 50.54(q) evaluations of program changes.changes.changes.

Adequate support is provided to ensure the training program for offsite e Adequate support is provided to ensure the training program for offsiteAdequate support is provided to ensure the training program for offsite response personnel is in place and maintained.response personnel is in place and maintained.response personnel is in place and maintained.

Development and maintenance of a working relationship with OROs.Development and maintenance of a working relationship with OROs.Development and maintenance of a working relationship with OROs.

¢ Oversee Emergency Preparedness Training Program and ensuring thatOversee Emergency Preparedness Training Program and ensuring thatOversee Emergency Preparedness Training Program and ensuring that proper records are maintained to document training and retraining of theproper records are maintained to document training and retraining of the proper records are maintained to document training and retraining of the ERO.ERO.ERO.

e Preparation for and conduct of the EP drill and exercise program.Preparation for and conduct of the EP drill and exercise program.Preparation for and conduct of the EP drill and exercise program.

e¢ Documenting the activities of the Emergency Preparedness Program asDocumenting the activities of the Emergency Preparedness Program asDocumenting the activities of the Emergency Preparedness Program as required by law and regulations.required by law and regulations.required by law and regulations.

e Corrective actions identified during the conduct of exercises, drills, training,Corrective actions identified during the conduct of exercises, drills, training,Corrective actions identified during the conduct of exercises, drills, training, audits, and inspections are tracked in the Corrective Action Program.audits, and inspections are tracked in the Corrective Action Program.audits, and inspections are tracked in the Corrective Action Program.

¢ Ensuring an independent review of the Emergency Preparedness Program isEnsuring an independent review of the Emergency Preparedness Program isEnsuring an independent review of the Emergency Preparedness Program is conducted to meet the requirements of 10 CFR 50.54(t).conducted to meet the requirements of 10 CFR 50.54(t).

Individuals assigned the duties of maintaining the IOEP are required to maintain anIndividuals assigned the duties of maintaining the IOEP are required to maintain an adequate knowledge of regulations, planning techniques, and the latestadequate knowledge of regulations, planning techniques, and the latest

P-1 23-04P-1 23-04 Individuals assigned the duties of maintaining the IOEP are required to maintain anP-1 23-04adequate knowledge of regulations, planning techniques, and the latestconducted to meet the requirements of 10 CFR 50.54(t).

Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency Plan ISFSI-Only Emergency Plan

applications of emergency equipment and supplies. Training for these individualsapplications of emergency equipment and supplies. Training for these individualsapplications of emergency equipment and supplies. Training for these individuals includes 10 CFR 50.54(q) Evaluation Qualification.includes 10 CFR 50.54(q) Evaiuation Qualification.

includes 10 CFR 50.54(q) Evaluation Qualification.

2. Review and Update of the IOEP. Review and Update of the IOEP. Review and Update of the IOEP The IOEP, the associated EPIPs, and the ISFSl EAL Technical Bases Document areThe IOEP, the associated EPIPs, and the ISFSI EAL Technical Bases Document areThe IOEP, the associated EPIPs, and the ISFSI EAL Technical Bases Document are reviewed at least annually, and updated as needed, in accordance with the reviewed at least annually, and updated as needed, in accordance with thereviewed at least annually, and updated as needed, in accordance with the requirements of 10 CFR 50.54(q). The review shall encompass the need forrequirements of 10 CFR 50.54(q). The review shall encompass the need for requirements of 10 CFR 50.54(q). The review shall encompass the need for changes based upon the following:changes based upon the following:changes based upon the following:

Written critiques and evaluations of drills and exercises Written critiques and evaluations of drills and exercisesWritten critiques and evaluations of drills and exercises Changes in the organizational structureChanges in the organizational structure Changes in the organizational structure Changes in the functions and capabilities of supporting agenciesChanges in the functions and capabilities of supporting agenciesChanges in the functions and capabilities of supporting agencies Changes in regulations Changes in regulationsChanges in regulations Modifications to the facility which would affect emergency planningModifications to the facility which would affect emergency planningModifications to the facility which would affect emergency planning Recommendations or agreement changes received from other organizations Recommendations or agreement changes received from other organizationsRecommendations or agreement changes received from other organizations

Any changes shall be incorporated in the IOEP, EPIPs, and the ISFSI EAL TechnicalAny changes shall be incorporated in the IOEP, EPIPs, and the ISFSI EAL Technical Any changes shall be incorporated in the IOEP, EPIPs, and the ISFSI EAL Technical Bases Document. Proposed activities that may impact the IOEP must be evaluatedBases Document. Proposed activities that may impact the IOEP must be evaluatedBases Document. Proposed activities that may impact the IOEP must be evaluated per 10 CFR 50.54(q) and 10 CFR 72.44(f).per 10 CFR 50.54(q) and 10 CFR 72.44(f).per 10 CFR 50.54(q) and 10 CFR 72.44(f).

The IOEP and EPIPs are distributed on a controlled basis.The IOEP and EPIPs are distributed on a controlled basis.

The IOEP and EPIPs are distributed on a controlled basis.

3. Review and Update of the IOEP. Review and Update of the IOEP. Review and Update of the IOEP A phone list contains telephone numbers used by the IPEC ERO during anA phone list contains telephone numbers used by the IPEC ERO during anA phone list contains telephone numbers used by the IPEC ERO during an emergency. This directory contains names and phone numbers of the IPEC ERO,emergency. This directory contains names and phone numbers of the IPEC ERO,emergency. This directory contains names and phone numbers of the IPEC ERO, support personnel, and applicable offsite organizations. These numbers are verifiedsupport personnel, and applicable offsite organizations. These numbers are verifiedsupport personnel, and applicable offsite organizations. These numbers are verified at least annually and updated, as necessary.

at least annually and updated, as necessary.at least annually and updated, as necessary.

4. Letters of Agreement. Letters of Agreement. Letters of Agreement Appendix 1 of this IOEP contains a listing of LOAs with support agencies. Every twoAppendix 1 of this IOEP contains a listing of LOAs with support agencies. Every twoAppendix 1 of this IOEP contains a listing of LOAs with support agencies. Every two years, each Agreement is reviewed and verified current in order to assure theyears, each Agreement is reviewed and verified current in order to assure theyears, each Agreement is reviewed and verified current in order to assure the availability of assistance from each supporting organization.availability of assistance from each supporting organization.availability of assistance from each supporting organization.

5. Cross-Reference to Planning Criteria. Cross-Reference to Planning Criteria

. Cross-Reference to Planning Criteria The IOEP is formatted in the same manner as Attachment 1 of 1ISG-02, as detailedThe IOEP is formatted in the same manner as Attachment 1 of ISG-02, as detailedThe IOEP is formatted in the same manner as Attachment 1 of ISG-02, as detailed in Appendix 2. This allows for ease in auditing evaluation criteria.in Appendix 2. This allows for ease in auditing evaluation criteria.in Appendix 2. This allows for ease in auditing evaluation criteria.

6. Inventory and Maintenance of Emergency Equipment and Supplies. Inventory and Maintenance of Emergency Equipment and Supplies. Inventory and Maintenance of Emergency Equipment and Supplies Periodic inventory, testing, and calibration of emergency equipment and supplies arePeriodic inventory, testing, and calibration of emergency equipment and supplies arePeriodic inventory, testing, and calibration of emergency equipment and supplies are conducted in accordance with approved procedures. This equipment includes, but isconducted in accordance with approved procedures. This equipment includes, but isconducted in accordance with approved procedures. This equipment includes, but is not limited to:not limited to:not limited to:

o Portable radiation monitoring equipmento Portable radiation monitoring equipments Portable radiation monitoring equipment

P-2 23-04P-2 23-04 P-2 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

e Emergency medical response equipmenteo Emergency medical response equipment¢ Emergency medical response equipment eo Dosimeters>> Dosimeterseo Dosimeters

>> Portable Radios e Portable Radioses Portable Radios

Emergency equipment and instrumentation {refer to Part 2, Section H of this IOEP)Emergency equipment and instrumentation (refer to Part 2, Section H of this IOEP)

Emergency equipment and instrumentation (refer to Part 2, Section H of this IOEP) shall be inventoried, inspected, and operationally checked periodically as indicatedshall be inventoried, inspected, and operationally checked periodically as indicatedshall be inventoried, inspected, and operationally checked periodically as indicated by the procedure and after each use. Sufficient reserves of equipment andby the procedure and after each use. Sufficient reserves of equipment andby the procedure and after each use. Sufficient reserves of equipment and instrumentation are stocked to replace emergency equipment and instrumentationinstrumentation are stocked to replace emergency equipment and instrumentationinstrumentation are stocked to replace emergency equipment and instrumentation removed from service for calibration and/or repair.removed from service for calibration and/or repair.

P-3 23-04P-3 23-04 P-3 23-04removed from service for calibration and/or repair.

Indian Point Energy CenterIndian Point Energy Centerindian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Part li: APPENDICES Part lil: APPENDICES

23-04 23-04 ISFSI-Only Emergency PlanPart lil: APPENDICES23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency Plan ISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Appendix 1 Letters of AgreementAppendix 1 Letters of AgreementAppendix 1 Letters of Agreement Copies of LOAs for the offsite emergency response supporting organizations listedCopies of LOAs for the offsite emergency response supporting organizations listedCopies of LOAs for the offsite emergency response supporting organizations listed below are maintained in the Emergency Planning Department files.below are maintained in the Emergency Planning Department files.below are maintained in the Emergency Planning Department files.

1. Verplanck Fire District (Fire/Ambulance)

1. Verplanck Fire District (Fire/Ambulance)1. Verplanck Fire District (Fire/Ambulance)

2. New York-Presbyterian Hudson Valley Hospital2. New York-Presbyterian Hudson Valley Hospital2. New York-Presbyterian Hudson Valley Hospital

3. New York State Police3. New York State Police3. New York State Police

Per Section P, the LOAs with outside support organizations and government agenciesPer Section P, the LOAs with outside support organizations and government agenciesPer Section P, the LOAs with outside support organizations and government agencies are reviewed and confirmed every two years. These letters are updated as needed.are reviewed and confirmed every two years. These letters are updated as needed.are reviewed and confirmed every two years. These letters are updated as needed.

Letters with no specific end date remain in effect until terminated in writing by eitherLetters with no specific end date remain in effect until terminated in writing by eitherLetters with no specific end date remain in effect until terminated in writing by either party. This has been agreed to by the applicable supporting agencies.party. This has been agreed to by the applicable supporting agencies.party. This has been agreed to by the applicable supporting agencies.

Appendix-1-1 23-04 Appendix-1-1 23-04 Appendix-1-1 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency Plan ISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Appendix2 Cross-Reference Sections of the IOEP to Emergency PlanningAppendix2 Cross-Reference Sections of the IOEP to Emergency PlanningAppendix2 Cross-Reference Sections of the IOEP to Emergency Planning ProceduresProcedures Procedures Cross reference table of regulations and guidance documents to the IOEP and EPIPs.Cross reference table of regulations and guidance documents to the IOEP and EPIPs.

Cross reference table of regulations and guidance documents to the IOEP and EPIPs.

Emergency Planning Planning ISG-02, AttachmentEmergency Planning Planning 1SG-02, Attachment Emergency Planning Planning ISG-02, Attachment Plan Standard Requirement 1 Evaluation ProcedurePlan Standard Requirement 1 Evaluation ProcedurePlan Standard Requirement 1 Evaluation Procedure Section 10 CFR 50.47**l Appendix E.IV*'* Criteria Section 10 CFR 50.47**l Appendix E.IV** CriteriaSection 10 CFR 50.47**l Appendix E.IV** Criteria A (b}1) A1,2,4,7 A IP-EN-EP-801A (b)1) A1,2,4,7 A IP-EN-EP-801A (b)(1) A112 4,7 A IP-EN-EP-801 B (b)(2) A1,2,4,CAH B IP-EN-EP-801B (b)(2) A1,2,4;CA B IP-EN-EP-8018 (b)(2) A1,2 4;,CAH B IP-EN-EP-801. IP-EP-240. IP-EP-240} IP-EP-240

Cc (b)(3) AB, 7 Cc IP-EP-AD1c (bX3) A, 7 C IP-EP-AD1(b)(3) AB, 7 Cc IP-EP-AD1IP-EN-EP-801IP-EN-EP-801IP-EN-EP-801

D (b)4) 8.1,2,CA1,2 D IP-EP-120D {b)}(4) 8.1,2,C.1,2 D IP-EP-120(b)(4) 81,2,CH1,2 IP-EP-120 AB,7,C.1;D1,3 IP-EP-115AG6,7;C1;,D1, 3; IP-EP-115 E (b)(5) E E IP-EP-AD1A6,7,C.1;D.1, 3; IP-EP-115 E (XS) E IP-EP-AD1E (b)(5) E E IP-EP-AD1

. } IP-EP-115 F (b)(6) C.1;D.1, 3. E F IP-EP-AD1F (b)(6) C.1;D.A, 3;E F IP-EP-AD1F (b)(6) C1,D1,3E F IP-EP-AD1.. IP-EP-115IP-EP-115

G (bX?) Exempt G IP-EN-EP-801G (b)}7) Exempt G IP-EN-EP-801IP-EN-EP-613IP-EN-EP-613IP-EN-EP-613

© (b)7) Exempt G IP-EN-EP-801 H (b)(8) E:G H IP-EP-AD1(b)(8) E.G IP-EP-AD1. IP-EP-115. IP-EP-115IP-EP-115 H (0X8) E.G H IP-EP-AD1

Cad. IP-EN-EP-613

.24.- C0 IP-EN-EP-613R1-IP-EN-EP-613 I {b)(9) A4;81,C2,E l IP-EP-120l (b)(9) A4;81,C2E ( IP-EP-120(b)(9) Ad4:81,C2 E I IP-EP-120 J (b)(10) C1,E J IP-EP-240J (b)(10) CAE J IP-EP-240J (b}10) C1 E J IP-EP-240 K (b)(11) E K IP-EP-115K (b}11) E K IP-EP-115 K (b)(11) E K IP-EP-1156 L (b)(12) A6, 7. E L IP-EP-AD1L (b)}12) AB, 7, E L IP-EP-AD1L (b}12) AB, 7, E L IP-EP-AD1 M (b)(13) H M IP-EN-EP-613M (b)(13) H M IP-EN-EP-613M (b}13) H M IP-EN-EP-613 N (b)(14) EY; F M IP-EN-EP-306N (b)(14) EQ; F M IP-EN-EP-306N (b)(14) EQ; F M IP-EN-EP-306 0 {b)(15) F 0 DSP-TRO01o] (b)(15) F 0 DSP-TRO01

0) (b)(15) F 0 DSP-TR001 P (b)(16) G P IP-EP-AD1P (b)(16) G P IP-EP-AD1P (b)(16) G P IP-EP-AD1

• • Refer to the IPEC exemptions from portions of 10 CFR 50.47 and Appendix E for** Refer to the IPEC exemptions from portions of 10 CFR 50.47 and Appendix E for** Refer to the IPEC exemptions from portions of 10 CFR 50.47 and Appendix E for applicability.applicability.

APPENDIX-2-1 APPENDIX-2-1 23-0423-04 applicability.23-04APPENDIX-2-1 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Appendix 3 Abbreviations and DefinitionsAppendix 3 Abbreviations and DefinitionsAppendix 3 Abbreviations and Definitions AbbreviationsAbbreviationsAbbreviations Any abbreviation followed by a lower case "s denotes the plural form of the term.

Any abbreviation followed by a lower case "s denotes the plural form of the term.Any abbreviation followed by a lower case "s denotes the plural form of the term.

ALARA......cooeirirreeiecrtrterscrsntassessraseesesssenresesssarens anesAs Low As Reasonably AchievableALARA.......oooeeeeeeeeieeeeneerenntenennesresssssssstsrssssssssssssssssssens As Low As Reasonably AchievableALARA... areas As Low As Reasonably Achievable CFR etter crrererree assessssvanrne sees sess sessonsannnns Code of Federal RegulationsCFR ceteris rere reernraseressssretsrensessensess erase ranassrsnnans Code of Federal Regulations0= Code of Federal Regulations O01© 2S EOUPS RSP Certificate of Compliance 1070lOJUU eer ae etrereerrereinrrraees Certificate of Compliance0 oT OOS Certificate of Compliance DBA cere s eres seer ee seers sense senna Design Basis AccidentI] = 7 SRST Design Basis AccidentDBA cert st senate nana aren Design Basis Accident EAL cece sree reser neers Emergency Action Levell Emergency Action LevelBAL eee eee aera easter arr s Emergency Action Level

= SOO PUPUOURIRt Emergency Classification Level=O PROPOR Emergency Classification Level0 RN Emergency Classification Level EPA rena U.S. Environmental Protection Agency l U.S. Environmental Protection Agency= U.S. Environmental Protection Agency EPIP eer enna nnn nanaEmergency Plan Implementing ProcedureEPIP coer eres ebenEmergency Plan Implementing Procedure EPIP....eeeeeeeecreeeree erences Emergency Plan Implementing Procedure BRE Lerten reese reese eee esasEmergency Response FacilityERE eerste sasssesesssnnsnnnnnnsnsnnrennnnnnnnnnn Emergency Response FacilityERE eee eee eee teeta ree naasEmergency Response Facility ERO... erect rrccretrrree sess svereeeeae eases ese anns Emergency Response OrganizationERO...rerrerrrrrernrrrreeer eraser eseneneneree ses sesassrannes Emergency Response OrganizationERO. eet eee eet eee eee arena Emergency Response Organization FS AR coe as Final Safety Analysis Report

[SY Final Safety Analysis ReportFSAR.....eeeeeeeeceeerccrrieeeereresesssssernssnseressessesesssrasnnneressas sens Final Safety Analysis Report l EUR Holtec Decommissioning International, LLCHDI... eres eee errr sees esaannes Holtec Decommissioning International, LLCHDI ceases ennnnes Holtec Decommissioning International, LLC IC a, et eeesetreeesttsetesteeieteeetertertaniaateteetertantarinnserieeteraes Initiating Condition[© USO SUTP Initiating ConditionLC ieee eee eee eee ea eater eraee aerate batter aaeaaenteria Initiating Condition ICS.rere eeereeresrenrreeraraer ar eararrarearranrarte Incident Command System[03FO OOS SSS SPPPR Incident Command System[0 OTP PRURROT Incident Command System l POURS UPOPPERSIndian Point Unit 1l EPR PO POUPPP RRPPPPRIndian Point Unit 1ot POPP PURERIndian Point Unit 1 DP cece sess sees senna nanannnanIndian Point Unit 2US Indian Point Unit 2l POOR UR PPPS Indian Point Unit 2 l Indian Point Unit 3l a OR SRSUURRRRRPRIndian Point Unit 3SRO UEPPPUPPRIIndian Point Unit 3 18]= = SPOTS RSURPRPIN ISFSI-Only Emergency PlanOEP cette errr erences anaes sess re esses nae sees snnnaees ISFSI-Only Emergency Plan[0 3 = UO ISFSI-Only Emergency Plan l od= OSE Indian Point Energy CenterIPEC.. cere reese rtrer ces rnree tesserae sess ne eases anne eases Indian Point Energy Centerod= OS OPUS REPRR Indian Point Energy Center 1S] JSPR Independent Spent Fuel Storage Installation15] 21 FO Independent Spent Fuel Storage Installation[1S]= Independent Spent Fuel Storage Installation ISG rere reeset ree essa ese br tare ees s sennanaaeres Interim Staff GuidanceISG eee eee essere essere reese esse ae eee eran eraser nae s een nnnes Interim Staff GuidanceLS GS eee tnuta_tatnutatnnntinnnnnnrnnnnnnes Interim Staff Guidance LS Serer eer eee sees sees ar aera ae ee sees ra rnnnesISFSI Shift SupervisorLS Scere rata eaenaan aa nnareasISFSI Shift SupervisorLS SS reeset eres serra reas aera baarbreeaeeesISFSI Shift Supervisor l I SOTO Local Law Enforcement AgencyLLEA. erect crreeeree eters sss eerarase see eee sessnnranans Local Law Enforcement AgencyLLEA eerste bn bss nnnLocal Law Enforcement Agency LOA... eeebeteeeeereereeneerantterra_..ehenhenRLnrLtheantanannennannrannnntnrennnns Letter of AgreementLDA eee eee eer aera a aes aarp anaaee ter eaate Letter of Agreement0J SSSR Letter of Agreement MREM ccc nee sees rater esse sete essessenreess ene milli-Roentgen Equivalent ManMREM citer cerrccrreeree ree sesrssrnraneresesesesssssssnneneeens milli-Roentgen Equivalent ManMREM eee eee eer rere e seer aera milli-Roentgen Equivalent Man 11151EUSP UURUPTUUU PU millisievertIMIS iiiiieeccieerree tet eeeesrerrarae teat eeesasassast astra saesasaasasssssntes ane sasseesnsnsnasesesessensrsrnenes millisievertTTESV Le eieiteiitieereeeneeneea enna nranna ne aanaaasnrannnanaansannnnsansansansansannansansann anna nasens ens annnnnnnnnns millisievert NIMS... reece rerrerrestos sere ennenns National Incident Management SystemNIMS creer cence ee ses aeree casesaeaesanans National Incident Management SystemNIMS eerste reese es National Incident Management System NRC eee eee eee rere eee ree U.S. Nuclear Regulatory Commission NRC... sreereese reeseessere nsensU.S. Nuclear Regulatory CommissionNRC rere ccctrrtrte recesses sennnnnnnaeeneresenns U.S. Nuclear Regulatory Commission ORO...oeiiiiiccetteeecninieeteeireeser cerse esses ane esasessne eee ee nena eesanenn Offsite Response Organization

[0]2 {© JOSS TURRRR Offsite Response OrganizationORO cere rere Offsite Response Organization PAG... errs esree s assessessess serena errs nnnns Protective Action GuidePAG... oo oeiieeieirieererrettee eerste eeesssnses ee sesssrsneesassnrneessessnsaesessnnses Protective Action GuidePAG..coeeeeiitiriieter terete uahaab sr bar bbb bbb b babe bbe bo bob bet rabbit tbr anes Protective Action Guide RCA errata bbe bana bebe trate bratreas Radiologically Controlled Area RCA otters cereeette nesses esssaneenee eee seesssssnnsansaens Radiologically Controlled Area{OF NOR Radiologically Controlled Area SFPeete eres eerste bere e tesserae brea ase aa sen snstne eae ae sannan Spent Fuel Pool ES]= SOP POTS OPOURUUSOUPPR PUPPPPRRPP Spent Fuel PoolSFP cea Spent Fuel Pool

APPENDIX-3-1 23-04APPENDIX-3-1 23-04 APPENDIX-3-1 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency Plan ISFSI-Only Emergency PlanISFSI-Only Emergency Plan

DefinitionsDefinitionsDefinitions Accountability - The process used by the IPEC ERO to identify potentially missingAccountability - The process used by the IPEC ERO to identify potentially missingAccountability - The process used by the IPEC ERO to identify potentially missing and/or injured personnel within the ISFSI Protected Area during an emergency.and/or injured personnel within the ISFSI Protected Area during an emergency.and/or injured personnel within the ISFSI Protected Area during an emergency.

Annual Frequency of occurrence equal to once per calendar year, between JanuaryAnnual Frequency of occurrence equal to once per calendar year, between JanuaryAnnual Frequency of occurrence equal to once per calendar year, between January 1st and December 31st,1st and December 31%,1st and December 31%,

Assessment Actions - Those actions taken during or after an accident to obtain andAssessment Actions - Those actions taken during or after an accident to obtain andAssessment Actions - Those actions taken during or after an accident to obtain and process information that is necessary to make decisions to implement specific process information that is necessary to make decisions to implement specificprocess information that is necessary to make decisions to implement specific emergency measures.

emergency measures.emergency measures.

Biennial Frequency of occurrence equal to once per two calendar years.Biennial Frequency of occurrence equal to once per two calendar years.Biennial Frequency of occurrence equal to once per two calendar years.

Classification - The classification of emergencies is divided into TWO (2) categories or Classification - The classification of emergencies is divided into TWO (2) categories orClassification - The classification of emergencies is divided into TWO (2) categories or conditions, covering the postulated spectrum of emergency situations. Each emergencyconditions, covering the postulated spectrum of emergency situations. Each emergencyconditions, covering the postulated spectrum of emergency situations. Each emergency classification is characterized by Emergency Action Levels (EALs) or event initiatingclassification is characterized by Emergency Action Levels (EALs) or event initiatingclassification is characterized by Emergency Action Levels (EALs) or event initiating conditions. The two classifications address emergencies of increasing severity.conditions. The two classifications address emergencies of increasing severity.conditions. The two classifications address emergencies of increasing severity.

Corrective Actions - Those emergency measures taken to ameliorate or terminate anCorrective Actions - Those emergency measures taken to ameliorate or terminate an Corrective Actions - Those emergency measures taken to ameliorate or terminate an emergency situation at or near its source.emergency situation at or near its source.emergency situation at or near its source.

Drill - A supervised instruction period aimed at testing, developing, and maintaining skill Drill - A supervised instruction period aimed at testing, developing, and maintaining skillDrill - A supervised instruction period aimed at testing, developing, and maintaining skill in a particular operation.in a particular operation.

in a particular operation.

Emergency Action Level (EAL) - A predetermined, site-specific, observable thresholdEmergency Action Level (EAL) - A predetermined, site-specific, observable thresholdEmergency Action Level (EAL) - A predetermined, site-specific, observable threshold for a plant Initiating Condition that places the plant in a given emergency class.for a plant Initiating Condition that places the plant in a given emergency class.for a plant Initiating Condition that places the plant in a given emergency class.

Emergency Director - A previously designated and trained individual who assumesEmergency Director - A previously designated and trained individual who assumesEmergency Director - A previously designated and trained individual who assumes total responsibility for directing all licensee activities related to an emergency at the site.total responsibility for directing all licensee activities related to an emergency at the site.total responsibility for directing all licensee activities related to an emergency at the site.

Emergency Plan Implementing Procedures Procedures that provide detailedEmergency Plan Implementing Procedures Procedures that provide detailedEmergency Plan Implementing Procedures Procedures that provide detailed information necessary to maintain the Emergency Planning Program and implementinformation necessary to maintain the Emergency Planning Program and implementinformation necessary to maintain the Emergency Planning Program and implement required tasks during an emergency.required tasks during an emergency.required tasks during an emergency.

Indian Point Energy Center (IPEC) - The combined areas immediately surroundingIndian Point Energy Center (IPEC) - The combined areas immediately surroundingIndian Point Energy Center (IPEC) - The combined areas immediately surrounding IP1, IP2, and IP3, and the ISFSI that are owned and operated by the licensee.IP1, IP2, and IP3, and the ISFSI that are owned and operated by the licensee.

ISFSI Protected Area The area surrounding the IPEC ISFSI encompassed byISESI Protected Area The area surrounding the IPEC ISFSI encompassed by physical barriers and to which access is controlled.physical barriers and to which access is controlled.

Offsite - Locations outside of the Indian Point Energy Center Site boundary.Offsite - Locations outside of the Indian Point Energy Center Site boundary.

On-site - The area within the Indian Point Energy Center Site boundary.On-site - The area within the Indian Point Energy Center Site boundary.

Owner Controlled Area - The fenced area containing licensee property.

Owner Controlled Area - The fenced area containing licensee property.

APPENDIX-3-2 23-04APPENDIX-3-2 23-04 IP1, IP2, and IP3, and the ISFSI that are owned and operated by the licensee.ISFS1 Protected Area The area surrounding the IPEC ISFSI encompassed byphysical barriers and to which access is controlled.Owner Controlled Area-The fenced area containing licensee property.Offsite - Locations outside of the Indian Point Energy Center Site boundary.On-site - The area within the Indian Point Energy Center Site boundary.APPENDIX-3-2 23-04 Indian Point Energy CenterIndian Point Energy CenterIndian Point Energy Center ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan

Protective Action Guide (PAG) - Projected radiological dose values to individuals in Protective Action Guide (PAG) - Projected radiological dose values to individuals inProtective Action Guide (PAG) - Projected radiological dose values to individuals in the general population who warrant protective action. Protective Action Guides containthe general population who warrant protective action. Protective Action Guides containthe general population who warrant protective action. Protective Action Guides contain criteria used to determine whether the general population needs protective actioncriteria used to determine whether the general population needs protective actioncriteria used to determine whether the general population needs protective action regarding projected radiological doses, or from actual committed (measured) dose regarding projected radiological doses, or from actual committed (measured) doseregarding projected radiological doses, or from actual committed (measured) dose values.values.values.

Radiologically Controlled Area Any area within plant buildings or on plant propertyRadiologically Controlled Area Any area within plant buildings or on plant propertyRadiologically Controlled Area Any area within plant buildings or on plant property where access is restricted and monitored for the purpose of radiation protection.where access is restricted and monitored for the purpose of radiation protection.where access is restricted and monitored for the purpose of radiation protection.

Recovery Actions - Those actions taken after the emergency to restore the plant asRecovery Actions - Those actions taken after the emergency to restore the plant as nearly as possible to its pre-emergency condition.nearly as possible to its pre-emergency condition.

Site Boundary - That line beyond which the land is neither owned, leased, norSite Boundary - That line beyond which the land is neither owned, leased, nor otherwise controlled by the site licensee. For dose assessment purposes the Siteotherwise controlled by the site licensee. For dose assessment purposes the Site Boundary is the closest distance at which members of the public would be exposed to aBoundary is the closest distance at which members of the public would be exposed to a radioactive release.

radioactive release.

APPENDIX-3-3 23-04APPENDIX-3-3 23-04 Recovery Actions - Those actions taken after the emergency to restore the plant asBoundary is the closest distance at which members of the public would be exposed to anearly as possible to its pre-emergency condition.radioactive release.Site Boundary - That line beyond which the land is neither owned, leased, norotherwise controlled by the site licensee. For dose assessment purposes the SiteAPPENDIX-3-3 23-04 IP-EN-EP-305 Rev. 9 HlIP-EN-EP-305 l Rev. 9 l IP-EN-EP-305 Rev. 9 l Emergency Planning 10CFR50.54(q) Review ProgramEmergency Planning 10CFR50.54(q) Review Program Emergency Planning 10CFR50.54(q) Review Program

Attachment 2 Page 1 of 3Attachment 2 Page 1 of 3Attachment 2 Page 1 of 3 10CFR50.54(Q)(3) Screening 10CFR50.54(Q)(3) Screening10CFR50.54(Q)(3) Screening

Procedure/Document Number: IPECProcedure/Document Number: IPEC Revision: 23-04Procedure/Document Number: IPEC Revision: 23-04Revision: 23-04 ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan Equipment/Facility/Other: Indian Point Energy Center (IPEC)Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Title:

Indian Point Energy Center ISFSI-Only Emergency PlanTitle: Indian Point Energy Center ISFSI-Only Emergency PlanTitle: Indian Point Energy Center ISFSI-Only Emergency Plan Part I. Description of Activity Being Reviewed (This is generally changes to the emergency plan, EALs,Part l. Description of Activity Being Reviewed (This is generally changes to the emergency plan, EALs,Part I. Description of Activity Being Reviewed (This Is generally changes to the emergency plan, EALs, EAL bases, etc. refer to Seclion 3.0 Step 6):

EAL bases, etc. refer to Section 3.0 Step 6):EAL bases, etc. refer to Section 3.0 Step 6):

This activity being reviewed is to include the reference procedures into Appendix 2 Cross-Reference Sections of theThis activity being reviewed is to include the reference procedures into Appendix 2 Cross-Reference Sections of theThis activity being reviewed Is to include the reference procedures into Appendix 2 Cross-Reference Sections of the IOEP to Emergency Planning Procedures of the NRC approved ISFSI-Only Emergency Plan (I0EP).IOEP to Emergency Planning Procedures of the NRC approved ISFSI-Only Emergency Plan (IOEP).IOEP to Emergency Planning Procedures of the NRC approved ISFSI-Only Emergency Plan (IOEP).

This activity also includes adding the NRC approved dates, ADAMS Accession Number, and NRC Safety Evaluation inThis activity also includes adding the NRC approved dates, ADAMS Accession Number, and NRC Safety Evaluation inThis activity also includes adding the NRC approved dates, ADAMS Accession Number, and NRC Safety Evaluation In License Amendment number shown on Part 1: Introduction, Section C: Scope and Section D: Planning Basis of theLicense Amendment number shown on Part 1: Introduction, Section C: Scope and Section D: Planning Basis of theLicense Amendment number shown on Part 1: Introduction, Section C. Scope and Section D: Planning Basis of the PDEP.PDEP.PDEP.

Lastly, this activity removes the Staff Augmentation Drills stated Section N: Drills and Exercise Program as previouslyLastly, this activity removes the Staff Augmentation Drills stated Section N: Drills and Exercise Program as previouslyLastly, this activity removes the Staff Augmentation Drills stated Section N; Drills and Exercise Program as previously approved and correctly stated in the Permanently Defueled Emergency Plan. The Staff Augmentation Drills wasapproved and correctly stated in the Permanently Defueled Emergency Plan. The Staff Augmentation Drills wasapproved and correctly stated In the Permanently Defueled Emergency Plan. The Staff Augmentation Drills was inadvertently reinstated in the OEP in error.inadvertently reinstated in the IOEP in error.inadvertently reinstated in the IOEP In error.

Part Il. Activity Previously Reviewed? ree) Be toPart Il. Activity Previously Reviewed? es NO toPart ll. Activity Previously Reviewed? Ee "no. to_.. YES NOYES NOYES NO Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or NOT requred, next pd. oo. Evaluation i xt part... luation i-Evaluation i t part :

Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or NOT required. reneeIs this activity fully bounded by an NRC approved 10CFR50.90 submittal or NOT aquired next pat Alert and Notification System Design Report? EnterAlert and Notification System Design Report? Enter Alert and Notification System Design Report? Enter Justificationjustification justification If YES, identify bounding source document number/approval reference and po2nd,artIf YES, identtfy bounding source document number/approval reference and below and If YES, identify bounding source document number/approval reference and podand

i complete Part ensure the basis for concluding the source document fully bounds the VI.ensure the basis for concluding the source document fully bounds the VI.ensure the basis for concluding the source document fully bounds the VI, proposed change is documented below:proposed change is documented below:

proposed change is documented below:

Justification: [] Bounding document attached (optional)Justification: [] Bounding document attached (optional)

Justification: [] Bounding document attached (optional)

Part lil. Applicability of Other Regulatory Change Control ProcessesPart lll. Applicability of Other Regulatory Change Control Processes Part lll. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity. (Refer to EN-LI-100)Check if any other regulatory change processes control the proposed activity. (Refer to EN-LI-100)Check if any other regulatory change processes control the proposed acthity. (Refer to EN-LI-100)

APPLICABILITY CONCLUSIONAPPLICABILITY CONCLUSIONAPPLICABILITY CONCLUSION Bd if there are no other controlling change processes. continue the 10CFR50.54(q)(3) Screening.If there are no other controlling change processes, continue the 10CFR50.54(q)(3) Screening.

i If there are no other controlling change processes, continue the 10CFR50.54(q)(3) Screening.

[J One or more controlling change processes are selected, however, some portion of the activity involves the[J One or more controlling change processes are selected, however, some portion of the activity involves the[J One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 10CFR50.54(q)(3) Screening for thatemergency plan or affects the implementation of the emergency plan; continue the 10CFR50.54(g)(3) Screening for thatemergency plan or affects the implementation of the emergency plan; continue the 10CFR50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below, portion of the activity. Identify the applicable controlling change processes below.portion of the activity. Identify the applicable controlling change processes below.

[J One or more controlling change processes are selected and fully bounds all aspects of the activity. 10CFR50.54(q)(3)((] One or more controlling change processes are selected and fully bounds all aspects of the activity. 10CFRS50.54(q)(3)[J] One or more controlling change processes are selected and fully bounds all aspects of the activity. 10CFRS50.54(q)(3)

Evaluation is NOT required. Identify controling change processes below and complete Part VI.Evaluation is NOT required. Identify controlling change processes below and complete Part VI.Evaluahion Is NOT required. Ident¥y controlling change processes below and complete Part V1.

CONTROLLING CHANGE PROCESSESCONTROLLING CHANGE PROCESSESCONTROLLING CHANGE PROCESSES l

ce. LIYES [J NOCIYES ONO Part IV. Editorial ChangePart IV. Editorial ChangePart IV. Editorial Change §0.54(0)(3) Continue toCJYESONO 50.54(q)(3) Continue toContinue to Is this activity an editorial or typographical change such as formatting, paragraphIs thts actvRy an editortal or typographical change such as formatting, paragraph Evaluation is next partEvaluation isEvaluation is50.54(q)(3)next partnext part Is this activity an editoriat or typographical change such as formatting, paragraph numbering, spelling, or punctuation that does not change intent?numbering, spelling, or punctuation that does not change intent?numbering, spelling, or punctuation that does not change Intent? NOT required.NOT required.NOT required.

oC ? Enter Justification:Justification:Justification: justificationEnterEnter justificationjustification and continueand continueand continue to next part orto next part or complete Partcomplete Part Vl asVl as applicable.applicable.

applicable.complete Partto next part orVl as IP-EN-EP-305 l Rev. 9 lIP-EN-EP-305 l Rev. 9 IP-EN-EP-305 l Rev. 9 l Emergency Planning 10CFR50.54(q) Review Program Emergency Planning10CFR50.54(q) Review ProgramEmergency Planning10CFR50.54(q) Review Program

Attachment 2 Page 2 of 3Attachment 2 Page 2 of 3Attachment 2 Page 2 of 3 10CFR50.54(Q)(3) Screening 10CFR50.54(Q)(3) Screening10CFR50.54(Q)(3) Screening

Procedure/Document Number: IPEC Revision: 23-04Procedure/Document Number: IPEC Revision: 23-04Procedure/Document Number: IPEC Revision: 23-04 ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan Equipment/Facility/Other: Indian Point Energy Center (IPEC}Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Equipment/Facility/Other: Indian Point Energy Center (IPEC)

l

Title:

Indian Point Energy Center ISFSI-Only Emergency PlanTitle: Indian Point Energy Center ISFSI-Only Emergency PlanTitle: Indian Point Energy Center ISFSI-Only Emergency Plan Part V. Emergency Planning Element/Function Screen (Associated 10CFR50.47(b) planning standard functionPart V. Emergency Planning Element/Function Screen {Assoclated 10CFR50.47(b) planning standard functionPart V. Emergency Planning Element/Function Screen (Associated 10CFR50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-identified in brackets) Does this activity affect any of the following, Including program elements from NUREG-identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section 11?0654/FEMA REP-1 Section 11?0654/FEMA REP-1 Section 11?

1. Responsibillty for emergency response is assigned, [1] []

1. Responsibility for emergency response is assigned. [1] ]1. Responsibility for emergency response is assigned. [1]

2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 M2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 J2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 staffing) in accordance with the emergency plan. [1]staffing) in accordance with the emergency plan. [1]

staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] [13. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] [1The process ensures that on shift emergency response responsibilities are staffed and assigned. [2]

4. The process for timely augmentation of onshift staff is established and maintained. [2] OC]4, The process for timely augmentation of onghift staff is established and maintained. [2] []The process for timely augmentation of onshift staff is established and maintained. [2]

5. Arrangements for requesting and using off site assistance have been made. [3] []5. Arrangements for requesting and using off site assistance have been made. [3] ]Arrangements for requesting and using off site assistance have been made. [3]

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] J6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] [J]State and local staff can be accommodated at the EQF in accordance with the emergency plan. [3]

7. A standard scheme of emergency classification and action levels is in use. [4] []

7. A standard scheme of emergency classification and action levels is in use. [4] 1A standard scheme of emergency classification and action levels is in use. [4]

8. Procedures for notification of State and local governmental agencies are capable of alerting them of ]8. Procedures for notification of State and local governmental agencies are capabie of alerting them of JProcedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes after declaration of an emergency and providing follow-the declared emergency within 15 minutes after declaratton of an emergency and providing follow-the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]up notffications. [5]up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt Hl8, Administrative and physical means have been established for alerting and providing prompt []9. Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway. [5]instructions to the public within the plume exposure pathway. [5]instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and ]10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and ]10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuciear Power Plants, or complies with the licensee's FEMA-approved ANSNotification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANSNotffication Systems for Nuclear Power Plants, or complles wih the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

design report and supporting FEMA approval letter. [5]design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response Ol]11. Systems are established for prompt communication among principal emergency response CJ11. Systems are established for prompt communication among principal emergency response organizations. [6]organizations. [6]organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6] Ll]12. Systems are established for prompt communication to emergency response personnel. [6] L]12. Systems are established for prompt communication to emergency response personnel. [6]

13. Emergency preparedness information is made available to the public on a periodic basis within the Cl13. Emergency preparedness information is made available to the public on a perlodie basis within the []13. Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway emergency planning zone (EPZ). [7]plume exposure pathway emergency planning zone (EPZ). [7]plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. [7] LJ14. Coordinated dissemination of public information during emergencies is established. [7] ]14. Coordinated dissemination of public information during emergencies is established. [7]

15. Adequate facilities are maintained to support emergency response. [8] Ol]15. Adequate facilities are maintained to support emergency response. [8]

16. Adequate equipment is maintained to support emergency response. [8] []16. Adequate equipment is maintained to support emergency response. [8]

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] OJ17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9]

18. A range of public PARs is available for implementation during emergencies. [10] LJ18. A range of public PARs is available for implementation during emergencies. [10]

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are OJ18. Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local available to support the formulation of PARs and have been provided to State and local governmental authorities. [10]

governmental authorities. [10]

20. A range of protective actions is available for plant emergency workers during emergencies, including []20. A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.[10]those for hostile action events.[10]

15. Adequate facilities are maintained to support emergency response. [8] ]16. Adequate equipment is maintained to support emergency response. [8] J17. Methods, systems, and equipment for assessment of radioactive releases are In use, [9] ]18. A range of public PARs is available for implementation during emergencies. [10] UJ19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are ]available to support the formulation of PARs and have been provided to State and iocalgovernmental authonties. [10]20. A range of protective actions is available for plant emergency workers during emergencles, Including []those for hostile action events,[10]

IP-EN-EP-305 l Rev. 9 l IP-EN-EP-305 l Rev. 9IP-EN-EP-305 Rev. 9 l Emergency Planning 10CFR50.54(q) Review Program Emergency Planning 10CFR50.54(q) Review ProgramEmergency Planning 10CFR50.54(q) Review Program

Attachment 2 Page 3 of 3Attachment 2 Page 3 of 3Attachment 2 Page 3 of 3 10CFR50.54(Q)(3) Screening10CFR50.54(Q)(3) Screening 10CFR50.54(Q)(3) Screening

Procedure/Document Number: IPEC Revision: 23-04Procedure/Document Number: IPEC Revision: 23-04 Procedure/Document Number: IPEC Revision: 23-04 ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan i Equipment/Facility/Other: Indian Point Energy Center (IPEC)Equipment/Facility/Other: Indian Point Energy Center (IPEC)Equipment/Facility/Other: Indian Point Energy Center {IPEC)

Title:

Indian Point Energy Center ISFS1-Only Emergency PlanTitle: Indian Point Energy Center ISFSI-Only Emergency PlanTitle: Indian Point Energy Center ISFSI-Only Emergency Plan

21. The resources for controlling radiological exposures for emergency workers are established. [11]

21. The resources for controlling radiological exposures for emergency workers are established. [11]21. The resources for controlling radiological exposures for emergency workers are established. [11]

22. Arrangements are made for medical services for contaminated, injured individuals. [12]22. Arrangements are made for medical services for contaminated, injured individuals. [12]22. Arrangements are made for medical services for contaminated, injured individuals. [12]

23. Plans for recovery and reentry are developed. [13]23. Plans for recovery and reentry are developed. [13]23. Plans for recovery and reentry are developed. [13]

24. A drill and exercise program (including radiological, medical, health physics and other program24. A dnll and exercise program {Including radiological, medical, health physics and other program

24. A drill and exercise program (including radiological, medical, health physics and other program areas) is established. [14]

areas) is established. [14]areas) is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop,25. Drills, exercises, and training evolutions that provide performance opportunities to develop,25. Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skllls are assessed via a formal critique process In order to identifymaintain, and demonstrate key skills are assessed via a formal critique process in order to identifymaintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]weaknesses, [14]weaknesses. [14]

26. Identified weaknesses are corrected. [14]26. Identified weaknesses are corrected. [14]26. Identified weaknesses are corrected. [14]

27. Training is provided to emergency responders. [15]27. Training is provided to emergency responders. [15]27. Training is provided to emergency responders. [15]

28. Responsibility for emergency plan development and review is established. [16]28. Responsibility for emergency plan development and review is established. [16]28. Responsibility for emergency plan development and review is established. [16]

29. Planners responsible for emergency plan development and maintenance are properly trained. [16]29. Planners responsible foremergency plandevelopment andmaintenance areproperly trained.[16]28. Planners responsible for emergency plan development and maintenance are properly trained. [16]

APPLICABILITY CONCLUSIONAPPLICABILITY CONCLUSIONAPPLICABILITY CONCLUSION Q If no Part V criteria are checked, a 10CFR50.54(q)(3) Evaluation is NOT required; document the basis for conclusionJ If no Part V criteria are checked, a 10CFR50.54(q)}(3) Evaluation is NOT required; document the basis for conclusionQOIfnoPartVcriteriaarechecked, a10CFR50.54(q)(3) EvaluationisNOTrequired;documentthebasisforconclusion below and complete Part VI.below and complete Part VI.

below andcomplete PartVI.

X If any Part V criteria are checked, complete Part VI and perform a 10CFR50.54(q){(3) Evaluation.X If any Part V criteria are checked, complete Part VI and perform a 10CFR50.54(q)(3) Evaluation.XIfanyPart Vcriteriaarechecked,completePartViandperforma10CFR50.54(q)(3)Evaluation.

BASIS FOR CONCLUSIONBASIS FORCONCLUSIONBASIS FOR CONCLUSION A review of this activity in accordance with 10 CFR 50.54(q)(3) screen has been completed and determined that theA reviewofthisactivityinaccordancewith10CFR50.54(q)(3) screenhasbeencompletedanddetermined thattheA review of this activity in accordance with 10 CFR 50.54(q}(3) screen has been completed and determined that the effectiveness of the Independent Spent Fuel Storage Installathon (ISFS1) Only Emergency Plan (IOEP) is maintained foreffectiveness of the Independent Spent Fuel Storage Installation (ISFSI) Only Emergency Plan (IOEP) is maintained foreffectivenessoftheIndependent Spent FuelStorageInstallation (ISFSI)OnlyEmergencyPlan(IOEP)ismaintainedfor the noted editortal changes. The editortal changes described are In line with the editorial change checklist defined in EN-the noted editorial changes. The editorial changes described are in line with the editorial change checklist defined in EN-thenotededitorialchanges.Theeditorialchangesdescribedareinline withtheeditorialchangechecklist definedinEN-AD-101 Procedure Process which defines editorial changes and referenced in EN-EP-305 Emergency Planning AD-101"ProcedureProcesswhich defines editorialchanges andreferencedinEN-EP-305EmergencyPlanningAD-101 Procedure Process which defines editorial changes and referenced in EN-EP-305 "Emergency Planning 10CFR50.54(q) Review Program.10CFR50.54(q) Review Program.10CFR50.54(q)ReviewProgram.

This Independent Spent Fuel Storage Installation (ISFSI) Only Emergency Plan (IOEP) revises the NRC approvedThis Independent Spent Fuel Storage Installation (ISFSI) Only Emergency Plan (IOEP) revises the NRC approved ThisIndependentSpentFuelStorageInstallation(ISFSI) Only EmergencyPlan(IOEP)revisestheNRCapproved Independent Spent Fuel Storage Installation (ISFSI) Only Emergency Plan (IOEP) with the correct procedure references Independent Spent Fuel Storage Installation (ISFSI) Only Emergency Plan (IOEP) with the correct procedure referencesIndependent SpentFuelStorageInstallation (ISFSI)Only Emergency Plan(IOEP) withthecorrectprocedure references In Appendix 2 and also adds the NRC dated matertal which was unavailable until NRC approval was obtained. Howeverin Appendix 2 and also adds the NRC dated material which was unavailable until NRC approval was obtained. HoweverinAppendix2andalsoaddstheNRCdatedmaterial whichwasunavailableuntilNRCapprovalwasobtained. However in Section N, the paragraph on Staff Augmentation Drills was added in error after it was deleted in the approved DPEPin Section N, the paragraph on Staff Augmentation Drills was added in error after it was deleted in the approved DPEP inSectionN,theparagraphonStaff Augmentation DrillswasaddedinerrorafteritwasdeletedintheapprovedDPEP EPLAN. This activity will be further evaluated under 10 CFR 50.54(q)(3).EPLAN.This activitywillbefurther evaluatedunder10CFR 50.54(q)(3).EPLAN. This activity will be further evaluated under 10 CFR 50.54(q)(3).

For reference, the ISFSI-Only Emergency Plan (I0OEP) was submitted to the NRC per Letter HDI-IPEC-22-080 datedFor reference, the ISFSI-Only Emergency Plan (IOEP) was submitied to the NRC per Letter HDI-IPEC-22-080 datedForreference,theISFSI-OnlyEmergencyPlan(OEP) wassubmittedtotheNRCperLetterHDI-IPEC-22-080dated November 17, 2022 (ADAMS Accession No. ML22321A148). Letter HDI-IPEC-22-080 requested a license amendmentNovember 17, 2022 (ADAMS Accession No. ML22321A148), Letter HDI-IPEC-22-080 requested a license amendmentNovember 17,2022 (ADAMS Accession No.ML22321A148). Letter HDI-IPEC-22-080 requested alicense amendment to revise the IPEC Emergency Plan and associated Emergency Action Level (EAL) scheme for a facility: configuration torevisetheIPECEmergencyPlanandassociated Emergency Action Level(EAL)schemeforafacilityconfigurationto revise the IPEC Emergency Plan and assoctated Emergency Action Level (EAL) scheme for a facility configuralion with all spent fuel in dry storage within an independent Spent Fuel Storage Installation Facility (ISFSI).withallspentfuelindrystoragewithinanIndependentSpentFuelStorageInstallationFacility(ISFSI).with all spent fuel in dry storage within an Independent Spent Fuel Storage Installation Facility (ISFSI).

Part VI. Signatures:Part VI. Signatures:Part VI.Signatures:

Preparer Name (Print) Prepar ignature Date!PreparerName (Print) Preparer Signature Date:Preparer Name (Print) Prepar ignature Date:

Antonio Iraola / Zvi VL 2¢Antonio Iraola J Utef 2%AntonioIraola1Ue] 2¢

l l Reviewer Name (Print) ewgL Signature Date:Reviewer Name (Print) ERE Date: j'

• ReviewerName(Print) ews Signature Date: ;* /

Craig Delamater / L [, [5 CraigDelamater /14{,A )Cralg Delamater, /ILL Approver Name (Print) Approfar Signature Date: CoApprover Name (Print) Approler Signature Date:ApproverName(Print) Approffer Signature Date:Co Matthew Johnson 12/le)2023 MatthewJohnson /2y//.023 Manager, NuclearManager,Nuclear

& [v4[2 [v4 Matthew Johnson AH 12fef202 3Manager, Nuclear J[v4 IP-EN-EP-305 l Rev. 9 l IP-EN-EP-305 l Rev. 9IP-EN-EP-305 Rev. 9 Emergency Planning 10CFR50.54(q) Review ProgramEmergency Planning 10CFR50.54(q) Review ProgramEmergency Planning 10CFR50.54(q) Review Program

Attachment 3 Page 1 of 2Attachment 3 Page 1 of 2 Attachment 3 Page 1 of 2 10CFR50.54(Q)(3) Evaluation10CFR50.54(Q)(3) Evaluation10CFR50.54(Q)(3) Evaluation

Procedure/Document Number: IPEC Revision: 23-04Procedure/Document Number: IPEC Revision: 23-04 Procedure/Document Number: IPEC Revision: 23-04 ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Equipment/Facility/Other: Indian Point Energy Center (IPEC)Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Title:

Indian Point Energy Center ISFSI-Only Emergency PlanTitle: Indian Point Energy Center ISFSI-Only Emergency PlanTitle: Indian Point Energy Center ISFSI-Only Emergency Plan

Part I. Description of Proposed Change: The ISFSI-Only Emergency Plan (IOEP) was submitted to the NRCPart l. Description of Proposed Change: The ISFSI-Only Emergency Plan (IOEP) was submited to the NRCPart I. Description of Proposed Change: The ISFSI-Only Emergency Plan (IOEP) was submitted to the NRC per Letter HDI-IPEC-22-080 dated November 17, 2022 (ADAMS Accession No. ML22321A148) and approved howeverper Letter HDI-IPEC-22-080 dated November 17, 2022 (ADAMS Accession No. ML22321A148) and approved however per Letter HDI-IPEC-22-080 dated November 17, 2022 (ADAMS Accession No. ML22321A148) and approved however in Section N, the paragraph on Staff Augmentation Drills was added in error after it was deleted in the approved DPEPin Section N, the paragraph on Staff Augmentation Drills was added in error after it was deleted in the approved DPEPin Section N, the paragraph on Staff Augmentation Drills was added in error after it was deleted in the approved DPEP EPLAN which was submitted to the NRC per Letter HDI-IPEC-21-016 dated December 22, 2021 (ADAMS Accession No.EPLAN which was submitied to the NRC per Letter HDI-IPEC-21-016 dated December 22, 2021 (ADAMS Accession No, EPLAN which was submitted to the NRC per Letter HDI-IPEC-21-016 dated December 22, 2021 (ADAMS Accession No. ML213568704) and Letter HDI-IPEC-22-018 dated February 4, 2022 (ADAMS Accession No, ML22035A121).ML21356B704) and Letter HDI-IPEC-22-018 dated February 4, 2022 (ADAMS Accession No. ML22035A121).ML213568704) and Letter HDI-IPEC-22-018 dated February 4, 2022 (ADAMS Accession No. ML22035A121).

Part Il. Description and Review of Licensing Basis Affected by the Proposed Change:Part Il. Description and Review of Licensing Basis Affected by the Proposed Change:Part ll. Description and Review of Licensing Basis Affected by the Proposed Change:

The ISFSI-Only Emergency Plan has been reviewed through the Process Applicablity Determination (PAD) in The ISFSI-Only Emergency Plan has been reviewed through the Process Applicability Determination (PAD) inThe ISFSI-Only Emergency Plan has been reviewed through the Process Applicability Determination (PAD) in accordance with Lhe criteria described in NEI 11-03 and IP-EN-LI-100. This proposed change does not (1) change theaccordance with the criteria described in NEI 11-03 and IP-EN-LI-100. This proposed change does not (1) change theaccordance with the criteria described in NEI 11-03 and IP-EN-LI-100. This proposed change does not (1) change the facility or procedures as described in the DSAR or (2) create a test or equipment not described in the DSAR and isfacility or procedures as described in the DSAR or (2) create a test or equipment not described in the DSAR and isfacility or procedures as described in the DSAR or (2) create a test or equipment not described in the DSAR and is governed under the Emergency Plan 10 CFR 50.54(q) screening process in accordance with EN-EP-305. Thesegovemed under the Emergency Plan 10 CFR 50.54(q) screening process in accordance with EN-EP-305. Thesegoverned under the Emergency Plan 10 CFR 50.54(q) screening process in accordance with EN-EP-305. These proposed changes do not involve structures, systems or components controlled by 10 CFR 50.59 or 72.48 and do notproposed changes do not involve structures, systems or components controlled by 10 CFR 50.58 or 72.48 and do not proposed changes do not involve structures, systems or components controlled by 10 CFR 50.59 or 72.48 and do not have the potential to impact on any of the License Basis Documents (LBDs) on the PAD form, except for the Emergencyhave the potential to impact on any of the License Basis Documents (LBDs) on the PAD form. except for the Emergencyhave the potential to impact on any of the License Basis Documents (LBDs) on the PAD form, except for the Emergency Plan. All responses to the questions contained in sections Ill and IV of the PAD form were determined to be no impact.Plan. All responses to ihe questions contained in sections Ill and IV of the PAD form were determined to be no impact.Plan. All responses to the questions contained in sections Ili and IV of the PAD form were determined to be no impact.

Since these proposed changes do not contain any requirements that could affect any LBDs other than the EmergencySince these proposed changes do not contain any requirements that could affect any LBDs other than the Emergency Since these proposed changes do not contain any requirements that could affect any LBDs other than the Emergency Plan, & is determined to be fully governed under 10 CFR 50.54(qg). In addition to those reviewed for the PAD, both the Plan, it is determined to be fully governed under 10 CFR 50.54(q). In addition to those reviewed for the PAD, both thePlan, it is determined to be fully governed under 10 CFR 50.54(q). In addition to those reviewed for the PAD, both the DPEP and the IOEP EPLANS were reviewed and no additional relevant or affected plan content was identified.DPEP and the IOEP EPLANS were reviewed and no additional retevant or affected plan content was Identified.DPEP and the IOEP EPLANS were reviewed and no additional relevant or affected plan content was identified.

Part lll. Describe How the Proposed Change Complies with Relevant EmergencyPart lll. Describe How the Proposed Change Complies with Relevant EmergencyPart lll. Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:

10 CFR 50.47(b)(14)Drills and Exercise Program10 CFR 50.47(b)(14)Drills and Exercise Program10 CFR 50.47(b){14)Drllis and Exercise Program Site Compliance: The requirement for Staff Augmentation Drills was removed, as no longer being via the NRC approvalSite Compliance: The requirement for Staff Augmentation Drills was removed, as no longer being via the NRC approval Site Compliance: The requirement for Staff Augmentation Drills was removed, as no longer being via the NRC approval of the PDEP EPLAN. However, it was inadvertently added back, in error, with the submittal to the NRC for the ISFSI-of the PDEP EPLAN. However, it was inadvertently added back, in error, with the submittal to the NRC for the ISFSI-of the PDEP EPLAN. However, it was inadvertently added back, in error, with the submittal to the NRC for the ISFSI-Only Emergency Plan (IOEP).Only Emergency Plan (IOEP).Only Emergency Plan (IOEP).

Previous NRC Commitments During the Process Applicability Determination (PAD) review, the Licensing ResearchPrevious NRC Commitments During the Process Applicability Determination (PAD) review, the Licensing ResearchPrevious NRC Commitments During the Process Applicability Determination (PAD) review, the Licensing Research System and the NRC Orders were reviewed for potential NRC Commitment changes because of this revision.System and the NRC Orders were reviewed for potential NRC Commitment changes because of this revision.System and the NRC Orders were reviewed for potenttal NRC CommKment changes because of this revision.

A review of U2/U3 Post Defuel Technical Specifications, U2/U3 DSAR, U2/ U3 Technical Requirements Manual, NRCA review of U2/U3 Post Defuel Technical Specifications, U2/1U3 DSAR. U2/ U3 Technical Requirements Manual, NRCA review of U2/U3 Post Defuel Technical Specifications, U2/U3 DSAR, U2/ U3 Technical Requirements Manual, NRC Orders/Commitments, and the indian Point PDEP and ISFS!-Only Emergency Plans were all conducted.Orders/Commitments, and the Indian Point PDEP and ISFSI-Only Emergency Plans were all conducted.

Orders/Commitments, and the Indian Point PDEP and ISFSI-Only Emergency Plans were all conducted.

Part IV. Description of Emergency Plan Planning Standards, Functions and ProgramPart IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change:Elements Affected by the Proposed Change:

10 CFR 50.47(b)(14)Drills and Exercise Program10 CFR 50.47(b){(14)Drills and Exercise Program

10 CFR 50.47(b)(14)Dnils and Exercise ProgramPart IV. Description of Emergency Plan Planning Standards, Functions and ProgramElements Affected by the Proposed Change:

IP-EN-EP-305 l Rev. 9IP-EN-EP-305 Rev. 9IP-EN-EP-305 Rev. 9 Emergency Planning 10CFR50.54(q) Review ProgramEmergency Planning 10CFR50.54(q) Review ProgramEmergency Planning 10CFR50.54(q) Review Program

Part V. Description of Impact of the Proposed Change on the Effectiveness of EmergencyPart V. Description of Impact of the Proposed Change on the Effectiveness of EmergencyPart V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:Plan Functions:Plan Functions:

This change removes from Section N of the ISFSI-Only EPLAN (IOEP) the need to conduct Staff Augmentation Drills asThis change removes from Section N of the ISFSI-Only EPLAN (IOEP) the need to conduct Staff Augmentation Drills as This change removes from Section N of the ISFSI-Only EPLAN (IOEP) the need to conduct Staff Augmentation Drills as previously reviewed and approved by the NRC during the approval of the Permanently Defueled Emergency Plan previously reviewed and approved by the NRC during the approval of the Permanently Defueled Emergency Planpreviously reviewed and approved by the NRC during the approval of the Permanently Defueled Emergency Plan (PDEP).

(PDEP).(PDEP).

The change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planning The change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planningThe change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planning standard 10 CFR 50.47(b)(14) and 10CFR50 Appendix E and can be incorporated without prior NRC approval as it wasstandard 10 CFR 50.47(b)(14) and 10CFR50 Appendix E and can be incorporated without prior NRC approval as it wasstandard 10 CFR 50.47(b){14) and 10CFR50 Appendix E and can be incorporated without prior NRC approval as it was previously approved and because there is no reduction in the ability of the Emergency Response Organization to declarepreviously approved and because there is no reduction in the ability of the Emergency Response Organization to declarepreviously approved and because there 1s no reduction in the ability of the Emergency Response Organizatten to declare or respond to an emergency in a timely manner.

or respond to an emergency in a timely manner.or respond to an emergency in a timely manner.

Conclusion Regarding Impact:Conclusion Regarding Impact:Conclusion Regarding Impact:

This change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planningThis change does nat represent a reduction in the effectiveness of the emergency plan, continues to meet planningThis change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planning standard 10 CFR 50.47(b)(14) and 10CFR50 Appendix E and can be incorporated without prior NRC approval becausestandard 10 CFR 50.47(b)(14) and 10CFR50 Appendix E and can be incorporated without prior NRC approval becausestandard 10 CFR 50.47(b)(14) and 10CFR50 Appendix E and can be hcorporated without prior NRC approval because the effectiveness of the emergency plan is not reduced. This change can be incorporated without prior NRC approval.the effectiveness of the emergency plan is not reduced. This change can be incorporated without prior NRC approval.

the effectiveness of the emergency plan is not reduced. This change can be incorporated without prior NRC approval.

IP-EN-EP-305IP-EN-EP-305 IP-EN-EP-305 l Rev. 9Rev. 9Rev. 9 Emergency Planning 10CFR50.54(q) Review Program Emergency Planning 10CFR50.54(q) Review ProgramEmergency Planning 10CFR50.54(q) Review Program

Attachment 3Attachment 3Attachment 3 Page 2 of 2 Page 2 of 2Page 2 of 2 10CFR50.54(Q)(3) Evaluation10CFR50.54(Q)(3) Evaluation10CFR50.54(Q)(3) Evaluation Procedure/Document Number: IPECProcedure/Document Number: IPECProcedure/Document Number: IPECRevision: 23-04Revision: 23-04 Revision: 23-04 ISFSI-Only Emergency PlanISFSI-Only Emergency PlanISFSI-Only Emergency Plan Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Equipment/Facility/Other: Indian Point Energy Center (IPEC)Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Title:

Indian Point Energy Center ISFSI-Only Emergency PlanTitle: Indian Point Energy Center ISFSI-Only Emergency PlanTitle: Indian Point Energy Center ISFSI-Only Emergency Plan Part VI. Evaluation ConclusionPart VI. Evaluation ConclusionPart VI. Evaluation Conclusion Answer the following questions about the proposed change.Answer the following questions about the proposed change.

Answer the following questions about the proposed change.

l. Does the proposed change comply with 10CFR50.47(b) and 10CFR50

1. Does the proposed change comply with 10CFRE50.47(b) and 10CFR501. Does the proposed change comply with 10CFR50.47(b) and 10CFR50YES [JNOXYES [INO Appendix E?Appendix E? YES [INO Appendix E?

2. Does the proposed change maintain the effectiveness of the emergency plan2. Does the proposed change maintain the effectiveness of the emergency planDoes the proposed change maintain the effectiveness of the emergency planXIyes J NO (i.e., no reduction in effectiveness)?(1.e., no reduction in effectiveness)?BAYES [INOYES (OJ NO (i.e., no reduction in effectiveness)?

3. Does the proposed change constitute an emergency action level scheme3. Does the proposed change constitute an emergency action level schemeDoes the proposed change constitute an emergency action level schemeOves XI NOOves XI NO change?change?change? Oves KI NO

If questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change,if questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, If questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRC approval undermodify the proposed change and perform a new evaluation or obtain prior NRC approval undermodX¥y the proposed change and perform a new evaluation or obtain prior NRC approval under provisions of 10CFR50.90. If questions 1 and 2 are answered YES, and question 3 answered NO,provisions of 10CFR50.90. If questions 1 and 2 are answered YES, and question 3 answered NO,provistons of 10CFR50.90. If questions 1 and 2 are answered YES, and question 3 answered NO, implement applicable change process(es). Refer to Section 6.7 Step 8.implement applicable change process(es). Refer to Section 6.7 Step 8.implement applicable change process(es). Refer to Section 6.7 Step 8.

Part VII. Signatures Part VII. SignaturesPart Vil. Signatures Preparer Name (Print)Preparer Name (Print)Preparer Name (Print)Prepagér SignaturePrepager Signaturerepager Signature Date:Date:Date:

Antonio IraolaAntonio Iraola Antonio Iraola / LL.1/ thls

Reviewer Name (Print) Reyjewal Signature Date:

Reviewer Name (Print) Regie Signature Date:Reviewer Name (Print) Rexjewag Signature Date:

Craig Delamater CN yy A A (4Craig Delamater ON /2 /IA 4Craig DelamaterA s2felrx addl v 7 Approver Name (Print) Approver Signature Date:

Approver Name (Print) Approver Signature Date:Approver Name (Print) Approver Signature Date:

Matthew JohnsonMatthew Johnson Af /2//.20273Matthew Johnson Af /2/e/.ol 3 Manager, NuclearManager, NuclearManager, Nuclear

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