SBK-L-18168, Radiological Emergency Plan (Ssrep), Revision 74

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Radiological Emergency Plan (Ssrep), Revision 74
ML18275A213
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 10/02/2018
From: Browne K
NextEra Energy Seabrook
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
SBK-L-18168
Download: ML18275A213 (33)


Text

NEXTera ENERGY ~

SEABROOK October 2, 2018 Docket No. 50-443 Docket No. 72-63 SBK-L-18168 United States Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001 Seabrook Station Radiological Emergency Plan (SSREP), Revision 74 In accordance with the requirements of 10 CFR 50, Appendix E; 10 CFR 50.4, and 10 CFR 72.44(£), enclosed is Revision 74 to the Seabrook Station Radiological Emergency Plan (SSREP).

The revision does not reduce the effectiveness of the SSREP, and the SSREP continues to meet the standards of 10 CFR 50.47(b) and 10 CFR 50, Appendix E. The Resident Inspector copy is provided directly through the NextEra Energy Seabrook, LLC records management system. provides a summary of changes to the SSREP. Enclosure 2 provides a summary of the change analysis required by 10 CFR 50.54(q)(5), and Enclosure 3 provides a copy of the revised manual sections.

Should you have any questions regarding the enclosed revisions, please contact me at (603) 773-7932.

Sincerely,

, LLC vH.l.l'-':!J,AJ.ro Licensing Manager NextEra Energy Seabrook, LLC PO Box 300, Seabrook, NH 03874

United States Nuclear Regulatory Commission SBK-L-18168 I Page 2 cc (with enclosures):

J.P. DeBoer, Region I, Division of Reactor Safety cc (without Enclosure 3):

ATTN: Document Control Desk Director, Spent Fuel Storage and Transportation, Office of Nuclear Material Safety and Safeguards Nuclear Regulatory Commission Washington, DC 20555-0001 J. Poole, NRC Project Manager, Project Directorate I-2 cc (without enclosures):

D. H. Dorman, NRC Region I Administrator P. Cataldo, NRC Senior Resident Inspector

Enclosure 1 to SBK-L-18168 Summary of Changes Radiological Emergency Plan (SSREP), Revision 74

  • Revised sections 2, 10, and Appendix D to support relocating remote monitoring area from Portsmouth, NH to onsite.

Enclosure 1, Page 1 of 1

Enclosure 2 to SBK-L-18168 Change Analysis Summary Radiological Emergency Plan (SSREP), Revision 74 The Seabrook Station Radiological Emergency Plan (S,SREP), Revision 74, was revised to support relocating the Remote Monitoring Area (RMA) from the Frank Jones Center in Portsmouth NH to an onsite location because Portsmouth Land Acquisition sold the property that the RMA is located on. This change impacted sections 2 and 10 of Chapter 1, as well as Appendix D of the SSREP.

The functions of providing facilities, equipment, protective actions and controlling radiological exposures are maintained because relocating the Remote Monitoring Area (RMA) operations to an on-site location near the Security Firing Range (West Sector) enhances our ability to quickly establish monitoring and decontamination of station staff. The new RMA location minimizes the travel time for decontamination support originating from the site, and will continue to be available to emergency workers. The Radiological Assistant at the EOF will continue to be notified of RMA contamination results and facilities will continue to maintain the supplies necessary to support decontamination efforts. Based on a review of the current year and the previous 10 year Wind Rose information, the predominant wind directions for the site are from the West North West and West sectors with an approximate 5% wind direction originating from the East North East and East sectors. The Firing Range location has been evaluated as a Special Receptor location in the Offsite Dose Calculation Manual (ODCM) and has atmospheric dispersion factors that are lower than the Site Boundary diffusion and deposition factors. The RMA physical location is outside the established RMA activation criteria (90 - 180 degrees from the site). There is no timing associated with these functions.

The above changes do not reduce the effectiveness of the emergency plan and the emergency plan as changed continues to meet the planning standards of 10 CFR 50.47 (b) and the requirements of 10 CFR 50, Appendix E.

Enclosure 2, Page 1 of 1 to SBK-L-18168 RMD Controlled Copy _ _ __

SEABROOK STATION PROGRAM MANUAL Seabrook Station Radiological Emergency Plan SSREP Manual Owner:

Rev. 74 D. Currier

SEABROOK STATION RADIOLOGICAL EMERGENCY PLAN (SSREP)

TABLE OF CONTENTS CONTENT PAGE

1.0 INTRODUCTION

1-1.l 2.0 DEFINITIONS 1-2.1 3.0 RADIOLOGICAL EMERGENCY PLAN

SUMMARY

1-3.1 3.1 Introduction 1-3.l 3.2 Station Emergency Response 1-3.l 3.3 Local and State Government Responses 1-3.3 3.4 Federal Government Response 1-3.3 Figure 3.1 Notification Plan Figure 3.2 Relationship of the Seabrook Station ERO to Offsite Organizations 4.0 THE AREA 1-4.l 4.1 The Site 1-4.1 4.2 Area Characteristics, Land Use and Demography 1-4.1 4.2.l Area Characteristics 1-4.l 4.2.2 Uses of Adjacent Lands and Waters 1-4.2 4.2.3 Population Distribution 1-4.2 4.3 Emergency Planning Zones 1-4.2 Table 4.1 Summary of Peak Population Estimates of Communities within 0 to 10 Miles of the Site Table 4.4 Communities Within the Seabrook Station Plume Exposure Pathway Emergency Planning Zone Figure 4.1 Site Boundaries Figure 4.2 Major Routes in 10 Mile Study Figure 4.3 Site Layout Figure 4.4 2010 Resident Population Distribution within a 0-10 Mile Radius of Seabrook Station Figure 4.6 Estimate Peak Transient Population (0-10 Miles)

Figure 4.7 Seabrook Station "Plume Exposure" Emergency Planning Zone Figure 4.8 Seabrook Station "Ingestion Exposure" Emergency Planning Zone (County Designations)

Page 1 SSREP Rev. 74

CONTENT PAGE 5.0 EMERGENCY CLASSIFICATION SYSTEM 1-5.1 5.1 Regulatory Context 1-5.l 5.2 Definitions Used in Developing EAL Methodology 1-5.2 5.3 Recognition Categories 1-5.3 5.4 Emergency Class Descriptions 1-5.5 5.5 Emergency Class Thresholds 1-5.7 5.6 Emergency Action Levels 1-5.8 5.7 Treatment of Multiple Events and Emergency Class Upgrading 1-5.9 5.8 Emergency Class Downgrading 1-5.10 5.9 Classifying Transient Events 1-5.10 5.10 Cold Shutdown/Refueling IC/EALs 1-5.11 5.11 ISFSI IC/EALs 1-5.11 Figure 5.6 Emergency Initiating Condition Matrix - Modes 1, 2, 3 and 4 Figure 5.7 Emergency Initiating Condition Matrix-Modes 5, 6 and Defueled Figure 5.8 Fission Product Barrier Degradation Matrix - Modes 1, 2, 3 and 4 6.0 EMERGENCY FACILITIES AND EQUIPMENT 1-6.l 6.1 Emergency Centers 1-6.l 6.1.1 Technical Support Center 1-6.l 6.1.2 Operational Support Center 1-6.1 6.1.3 Emergency Operations Facility 1-6.2 6.1.4 Support for Radiological Analysis of Environmental Samples 1-6.3 6.1.5 Joint Information Center 1-6.3 6.1.6 Federal Radiological Monitoring and Assessment Center 1-6.3 6.2 Assessment Capability 1-6.4 6.2.1 Process Monitors 1-6.4 6.2.2 Radiation Data Management System 1-6.4 6.2.3 Geophysical Phenomena Monitors 1-6.5 6.2.4 Fire Detection Systems 1-6.6 6.2.5 Facilities and Equipment for Offsite Monitoring 1-6.6 Figure 6.1 Location of Emergency Operation Centers Around the Seabrook Station Site Page2 SSREP Rev. 74

CONTENT Figure 6.2 Relative Location of Technical Support within the 75' Elevation Level of the Control Building Figure 6.5 Operational Support Center Layout Figure 6.6 EOF Layout 7.0 COMMUNICATIONS 1-7.l 7.1 Nuclear Alert System 1-7.l 7.2 NRC Communications Channels 1-7.l 7.3 Telephone System 1-7.2 7.4 Commercial Pager Service 1-7.2 7.5 Station Radio System 1-7.2 7.5.l Offsite Monitoring Team Radio Network 1-7.2 7 .5 .2 UHF Radio System 1-7.3 7.6 Station Paging System 1-7.4 7.7 Sound-Powered Telephone System 1-7.4 Figure 7.1 Emergency Notification Figure 7.2 Coordination Channels with States Figure 7.3 Offsite Monitoring Team Radio Communications Figure 7.4 Telephone Communication Systems Overview Figure 7.5 UHF Radio Communication Systems Overview 8.0 ORGANIZATION 1-8.l 8.1 Introduction 1-8.l 8.2 Emergency Response Organization 1-8.1 8.2.1 On-Shift Emergency Response Organization 1-8.l 8.2.2 Augmented Emergency Response Organization 1-8.2 8.3 Emergency Public Information Organization 1-8.3 8.4 Seabrook Station Corporate Support 1-8.3 8.5 Recovery Organization 1-8.4 8.6 Extensions of Seabrook Station Emergency Response Organization 1-8.4 8.6.l Local Services 1-8.4 8.6.2 Federal Government Support 1-8.5 8.6.3 Private Organization Support 1-8.5 Page 3 SSREP Rev. 74

CONTENT PAGE 8.7 Coordination with State Government Authorities 1-8.5 Figure 8.1 On-Shift Emergency Response Organization Figure 8.2 Augmented Emergency Response Organization for Unusual Event Figure 8.3 Augmented Emergency Response Organization for Alert, Site Area Emergency, and General Emergency Figure 8.4 Emergency Operations Facility Staff Figure 8.5 Operational Support Center Staff Figure 8.6 Technical Support Center (TSC) Staff Figure 8.7 Canceled Figure 8.9 Joint Information Center Staff Figure 8.12 On-Shift Emergency Response Organization Actions Figure 8.13 Summary of the Radiological Emergency Responsibilities and Functions of the Massachusetts State Authorities Figure 8.14 Summary of the Radiological Emergency Responsibilities and Functions of the New Hampshire State Authorities Figure 8.15 Comparison of NUREG-0654 Emergency Response Staffing Goals with the Seabrook Station Emergency Response Organization (ERO)

Figure 8.16 Seabrook Station News Services Staff 9.0 EMERGENCY RESPONSE OUTLINE 1-9.1 9.1 Initiation 1-9.1 9.2 Activation of the Emergency Organization 1-9.1 9 .2.1 Unusual Event Response 1-9.1 9.2.2 Alert Response 1-9.2 9.2.3 Site Area Emergency Response 1-9.4 9.2.4 General Emergency Response 1-9.5 9.3 Emergency De-escalation, Termination and Recovery 1-9.5 Figure 9.1 Method of Notification and Reporting Instructions for Onsite Personnel 10.0 EMERGENCY MEASURES 1-10.l 10.l Radiological Accident Assessment Systems and Techniques 1-10.1 10.1.1 Estimation of Offsite Dose Rates 1-10.2 10.1.2 Evaluation of Field Environmental Samples 1-10.3 10.1.3 Evaluation of Post Accident Samples 1-10.4 10.1.4 Severe Accident Management Guidance 1-10.4 10.2 Protective Action Recommendation Criteria 1-10.4 10.3 Radiological Exposure Control 1-10.5 Page4 SSREP Rev. 74

CONTENT PAGE 10.4 Protective Measures 1-10.6 10.4.1 Personnel Accountability 1-10.6 10.4.2 Station Access/Egress Control Methods 1-10.6 10.4.3 Protective Measures for Hostile Action Based Events 1-10.7 10.4.4 Decontamination Capability 1-10.8 10.4.5 Use of Onsite Protective Equipment and Supplies 1-10.8 10.4.6 Radiation Guideline Action Levels 1-10.8 10.5 Aid to Affected Personnel 1-10.9 10.5.l Medical Treatment 1-10.9 10.5.2 Medical Transportation 1-10.9 Table 10.1 EPA Protective Action Guidelines 1-10.10 Table 10.2 Emergency Dose Limits 1-10.11 Table 10.3 Emergency Center Protection 1-10.12 Figure 10.l Emergency Center Protection Figure 10.2 Seabrook Station Evacuation Routes 11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION 1-11.1 11.1 Emergency Notification 1-11.1 11.2 Public Notification 1-11.1 11.3 Public Information 1-11.1 12.0 MAINTAINING EMERGENCY PREPAREDNESS 1-12.1 12.1 Drills and Exercises 1-12.l 12.1.1 Radiological Emergency Plan Exercises 1-12.l 12.1.2 Emergency Plan Drills 1-12.l 12.1.3 Drill and Exercise Scenarios 1-12.3 12.1.4 Evaluation of Exercises 1-12.4 12.1.5 Credit for Response to an Actual Emergency 1-12.4 12.2 Emergency Plan Training 1-12.5 12.2.1 Emergency Response Organization (ERO) 1-12.5 12.2.2 Support Groups 1-12.6 12.2.3 Station Personnel with No ERO Assignment 1-12.6 12.2.4 Emergency Preparedness Department Personnel 1-12.6 12.2.5 Records 1-12.6 12.3 Review and Updating of Plan and Procedures 1-12.7 12.4 Maintenance and Inventory of Emergency Equipment and Supplies 1-12.7 Page 5 SSREP Rev. 74

CONTENT PAGE 12.5 Emergency Preparedness Manager 1-12.7 12.6 Technical Training Supervisor 1-12.8 12.7 Operations Support Manager 1-12.8 13.0

SUMMARY

OF CHANGES 1-13.l APPENDICES Appendix A Emergency Response Organization Position Definitions A-1 AppendixB Canceled B-1 Appendix C Evacuation Time Estimates C-1 AppendixD Letters of Agreement with Emergency Response Organizations D-1 AppendixE Seabrook Station Public Alert and Notification System E-1 AppendixF Emergency Equipment F-1 Appendix G Seabrook Station Supporting Emergency Plans and Procedures Listing G-1 AppendixH NUREG-0654/Seabrook Station Radiological Emergency Plan Cross Reference H-1 Page 6 SSREP Rev. 74

LIST OF EFFECTIVE PAGES PAGE REV. PAGE REV.

Cover 74 Figure 8.5 59 Figure 8.6 58 TOC 1 - 6 74 Figure 8.7 Canceled Figure 8.9 64 LOEP 1 - 2 74 Figure 8.12 50 1-1.1and1-1.2 56 Figure 8.13 13 Figure 8.14 52 1-2.1thru1-2.4 73 Figure 8.15 Sheet 1 55 1-3.1thru1-3.4 66 Sheet 2 55 Figure 3.1 64 Sheet 3 55 Figure 3.2 55 Sheet 4 55 Sheet 5 55 1-4.1thru1-4.5 66 Sheet 6 55 Figure 4.1 56 Figure 8.16 32 Figure 4.2 20 Figure 4.3 58 1-9.1thru1-9.7 66 Figure 4.4 66 Figure 9.1 66 Figure 4.6 66 Figure 4.7 5 1-10.1thru1-10.12 73 Figure 4.8 Undated Figure 10.1 30 Figure 10.2 48 1-5.1thru1-5.12 71 Figure 5.6 57 1-11.1thru1-11.3 64 Figure 5.7 57 1-12.1thru1-12.8 71 Figure 5.8 57 1-13.1 73 1-6.1thru1-6.7 70 Figure 6.1 56 Appendix A Figure 6.2 42 Cover Page 64 Figure 6.5 47 Index 64 Figure 6.6 64 A-1 thru A-25 64 1-7.1thru1-7.4 64 Appendix B cancellation sheet 42 Figure 7.1 64 Figure 7.2 64 Appendix C Figure 7.3 64 Cover Page 49 Figure 7.4 64 C-1 thru C-5 49 Figure 7.5 64 Appendix D 1-8.1thru1-8.6 70 Cover Page 63 Figure 8.1 70 Table of Contents 63 Figure 8.2 60 D-1 58 Figure 8.3 60 D-la 58 Figure 8.4 66 D-lb 58 D-2 63 Page 1 SSREP Rev. 74

LIST OF EFFECTIVE PAGES PAGE REV. PAGE REV.

D-3 thru D-3b 46 D-4 61 D-5 thru D-5c 57 D-6 61 D-7 59 D-8 thru D-8e 59 D-9 thru D-9b 60 D-10 63 Appendix E Cover Page 57 E-1 thru E-5 57 Appendix F 33 Appendix G G-1 thru G-7 55 Appendix H Cover Page 47 H-1 thru H-7 47 Page2 SSREP Rev. 74

13.0

SUMMARY

OF CHANGES Rev. 73: (PCR 02276102 September 2018)

Revised sections 2 and 10 to support relocating remote monitoring area from Portsmouth to onsite.

Rev. 72: (PCR 2217534 August 2017)

Section 5 - Corrected footers on EAL charts. Corrected typographical error on Figure 5.7 (Category A to Category R) (AR 2217534).

Section 12 -Replaced validation, exemption, and deferral are discussed in the ERO Training Program Description with training requirements are discussed in the ERO Training Program Description (AR 2194476).

Appendix D - Updated Letter of Agreement with the State of New Hampshire and Commonwealth of Massachusetts.

Rev. 71: (PCR 2191568 and PCR 2211605 July 2017)

Section 5 - Editorial Change to correct footer in Figures 5.6, 5.7, and 5.8.

Section 9 -Replaced Site Vice President title with Plant General Manager. Corrected typographical errors in Figure 9.1.

Section 5 - Revised EAL description to match new NRC approved EAL scheme (AR 2101091 ).

Editorial change to replace reference from NARC to LI-AA-102-1001 with regard to regulatory reporting.

1-13.1

  • SSREP Rev. 73

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

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

Alternative Operational Support Center - An area within the EOF where OSC personnel assemble for hostile action based events or other catastrophic events that prevent site access.

Alternative Technical Support Center - An area within the EOF where TSC personnel assemble for hostile action based events or other catastrophic events that prevent site access.

Assembly Area - The Assembly Area for backup response personnel and maintenance technicians is located in the Seabrook Station Conference Center at the rear of Warehouse # 1.

Personnel reporting to this facility include White Team ERO secondary responders and maintenance technicians. This facility would be activated only during the period from 0700 to 1630, Monday through Friday, except during planned outages when it would be opened on any shift. Activation is required at an Alert or higher emergency classification level.

Assessment Actions - Actions which are taken to effectively define the emergency situation necessary for decisions on specific emergency measures.

Automated Telephone Notification Service -A commercial, computer-based call-out service used to notify Primary, Subject-to- Call and Secondary Responders during back-shifts, weekends and holidays of an Alert or higher emergency classification.

Backup Responders - Personnel who do not initially report to an emergency response facility but are available for subsequent staffing duties (e.g., second shift). They include all White Team personnel. During a daytime plan activation, these personnel report to the Assembly Area.

Committed Dose Equivalent (CDE) - The dose equivalent to an organ from an intake of radioactive material during the 50 year period following the intake.

Committed Effective Dose Equivalent (CEDE) -The sum of the products of the weighting factors applicable to each of the body organs that are irradiated and the CDE to these organs.

Corrective Actions - Emergency measures taken to ameliorate or terminate an emergency situation.

Deep Dose Equivalent (DDE) - The external dose equivalent to the whole body at a tissue depth of 1 cm.

Dose - A general term referring to the quantity of absorbed energy in tissue. In the SSREP, dose is used for irradiation of the whole body, unless otherwise indicated.

Dose Equivalent (DE) - The product of absorbed dose in tissue and the quality factor.

Emergency Action Level (EAL) - A pre-determined, site-specific, observable threshold for an Initiating Condition that places the Station in a given emergency class.

1-2.1 SSREP Rev. 73

Emergency Classifications - One of a minimum set of names or titles, established by the Nuclear Regulatory Commission (NRC), for grouping off-normal nuclear power plant conditions according to (1) their relative radiological seriousness, and (2) the time-sensitive onsite and off-site radiological emergency preparedness actions necessary to respond to such conditions.

The radiological emergency classes, in ascending order of seriousness, are as follows:

  • Unusual Event
  • Alert
  • Site Area Emergency
  • General Emergency Emergency Operating Centers (EOCs) - Areas designated by the State and local authorities as Emergency Plan facilities for their respective staffs.

Emergency Operating Procedures - The outline of specific corrective actions to be taken by Station operators in response to abnormal operating conditions.

Emergency Operations Facility (EOF) - A center established beyond ten miles from the Seabrook Station site where Seabrook Station emergency management directs the actions of the emergency response organization, coordinates the evaluation of offsite radiological conditions with offsite authorities, arrives at protective action recommendations, and establishes a recovery organization.

Emergency Planning Zones (EPZ) - The areas for which planning is recommended to assure that prompt and effective actions can be taken to protect the public in the event of an accident.

The two zones are the plume exposure pathway zone (about 10 miles in radius) and the ingestion exposure pathway zone (about 50 miles in radius).

Emergency Response Organization (ERO) - The Seabrook Station personnel assigned and trained to implement this emergency plan.

Emergency Response Procedures - Procedures that outline specific actions to be taken by the Seabrook Station ERO to activate and implement this emergency plan. These procedures are contained in the Station Emergency Response Manual (SSER).

GEL Laboratories - A contracted service for emergency environmental sample analysis.

General Emergency - Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

1-2.2 SSREP Rev. 73

HOSTILE ACTION - An act toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the nuclear power plant.

Non-terrorism-based EALs should be used to address such activities (e.g., violent acts between individuals in the owner controlled area).

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

Ingestion Exposure Pathway - The pathway in which individuals receive a radiation dose due to internal deposition of radioactive materials from ingestion of contaminated water, foods, or milk.

Initiating Condition - One of a predetermined subset of nuclear power plant conditions where either the potential exists for a radiological emergency or such an emergency has occurred.

Joint Information Center (JIC) - A facility where news media representatives can obtain emergency news information.

NextEra Energy Seabrook, LLC- Managing agent of Seabrook Station.

Non-essential Personnel - Onsite personnel who are not assigned to the Seabrook Station ERO.

These personnel are evacuated from the site at an Alert or higher emergency classification.

Operational Support Center - An emergency center established for the assembly and dispatch of available skilled emergency personnel (e.g., additional Station operations and support personnel) in support of onsite emergency operations.

Plume Exposure Pathway - The pathway in which individuals receive a radiation dose due to (a) whole body external exposure due to gamma radiation from the plume and from deposited material, and (b) inhalation exposure from the passing radioactive plume.

Primary Responders - The eight ERO positions that are staffed on a rotating duty basis. These positions are notified by pager, respond to any emergency, and include the Site Emergency Director, Operations Technician, Technical Services Coordinator, Health Physics Coordinator, Response Manager, EOF Coordinator, ERO Technical Liaison and Emergency News Manager.

Primary Responders are also notified by the automated telephone notification service during back-shifts, weekends and holidays of an Alert or higher emergency classification level.

Projected Dose - The amount of radiation dose estimated at the onset of the accident. It includes all the dose an individual would receive for the duration of the accident assuming no protective measures were undertaken.

Protective Actions - Emergency measures to be taken by the public to mitigate the consequences of an accident by minimizing the radiological doses that may occur if such actions were not undertaken. Protective actions would be warranted provided the reduction in the individual dose is not offset by excessive risks to individual safety in implementing such actions.

1-2.3 SSREP Rev. 73

Protective Action Guides (PAG) - Pre-established radiological dose values to the public which warrant protective actions following an uncontrolled release ofradioactive material.

Recovery Actions - Actions taken once the emergency condition has been controlled in order to restore stable Station conditions.

Red Team - The pre-assigned group of responders who initially report for emergency response duties.

Remote Monitoring and Decontamination Area - This area is located onsite. It will be activated in the event that a radiological release occurs prior to the evacuation of site personnel, and that the prevailing wind conditions at the time make it possible for site evacuees to be contaminated.

Secondary Responders - ERO positions that are not staffed on a rotating duty basis. These positions are activated at an Alert or higher emergency classification. Secondary responders are notified by pager and, during back-shifts, weekends and holidays, by the automated telephone notification service of an Alert or higher emergency classification level.

Site - Seabrook Station property situated on a 900-acre tract of land on the western shore of Hampton Harbor in Rockingham County.

Site Area Emergency -Events are in process or have occurred that involve actual or likely major failures in plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) prevent effective access to , equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed the EPA Protective Action Guideline exposure levels beyond the site boundary.

Station Emergency Response Manual (SSER) - The manual containing all Emergency Response Procedures.

Subject-to-Call Responders - ERO positions that are not staffed on a rotating basis.

Subject-to-Call Responders are expected to report on an all-call basis to activate emergency facilities at an Alert or higher emergency classification level. Subject-to-Call Responders are notified by pager and, during back-shifts, weekends and holidays, by the automated telephone notification service of an Alert or higher emergency classification level.

Technical Support Center (TSC) - An in-station emergency center established in close proximity to the Control Room that has the capability to acquire parameters for post-accident evaluation by technical and recovery assistance personnel. Onsite emergency response activities are directed from the TSC.

Total Effective Dose Equivalent (TEDE) -The sum of the deep dose equivalent (DDE) for external exposures and the committed effective dose equivalent (CEDE) for internal exposures.

Unusual Event -Events are in process or have occurred which indicate a potential degradation in the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

White Team - The pre-assigned group ofresponders that are available for second shift duties or to fill staffing deficiencies in the Red Team.

1-2.4 SSREP Rev. 73

10.0 EMERGENCY MEASURES 10.1 Radiological Accident Assessment Systems and Techniques The two monitored effluent pathways for accidental releases of radioactive material at Seabrook Station are the plant vent stack and the main steam lines (through the lifting of the safety relief valves or the throttling of the atmospheric steam dump valves). Each of these effluent pathways contains a monitor. The monitor responses can be correlated to the effluent radioactivity concentration. In addition to these monitored pathways, high-range containment area monitors are capable of measuring the exposure rate within the containment, which can be correlated to the radioactivity concentration within the structure. Each of the above systems may be considered as separate release pathways which can be assessed with its associated monitor.

Containment leakage is also considered as a possible effluent pathway for dose assessment.

The containment monitoring system consists of redundant ionization chambers and instrumentation channels with a range of I0° to I0 8 RJhr (gamma). The system is Class IE qualified. A time-dependent conversion factor has been calculated which will enable conversion of the monitor's response (RJhr) to the total noble gas concentration (µCi/cc) in the containment building at a given time after shutdown assuming that the concentration within the containment is uniform. This conversion factor is calculated based on the assumption that a core equilibrium mixture of fission products exists at t=O. It should be noted, however, that the intent of this system is not to correlate this monitor response to core conditions or damage but to estimate the concentration in the containment building. The only relationship that can be readily made from this monitor to core conditions is a minimum core damage level since the amount of diluted or undiluted primary coolant leakage into the containment building may be a major unknown variable. If available, the minimum core damage level indicated by this monitor will be used as an indication of the type of fission product mixture being released through the effluent pathways.

The Wide Range Gas Monitor (WRGM) is used to continuously monitor the gaseous activity released to the environment through the plant vent stack. Its monitoring range is large enough to encompass low level releases using a beta scintillation detector with a range of 4.0E-8 to I .OE-I

µCi/cc and two mid to high range solid-state beta/gamma detectors of 7.0E-5 to 1.0E+3 µCi/cc and 2.0E-2 to 1.0E+5 µCi/cc, respectively. The WRGM was designed and installed to minimize personnel exposure while obtaining particulate and iodine grab samples. The WRGM also calculates a release activity in µCi/sec in the range of 1.0E+2 to I.OE+ I4 µCi/sec.

A backup monitor is available in the event of a WRGM failure. This monitor consists of an ionization chamber type detector, viewing a prescribed geometrical container in which the stack exit gas flows. The detector and associated remote universal digital rate meter are capable of monitoring dose rates from O. I mR/hr to I 0,000 RJhr.

The main steam line monitors consist of a G-M detector placed adjacent to each of the four (4) main steam lines (several inches) with remote readout modules. This monitor response (mRJhr) is used to estimate offsite doses.

1-I O. I SSREP Rev. 73

10.1.1 Estimation of Offsite Dose Rates Seabrook Station maintains a computerized dose projection system, utilized in the Control Room, TSC and EOF, which is capable of providing real time and forecast offsite dose estimates for actual meteorological and radiological accident conditions. The system is referred to as Raddose-V.

Raddose-V uses a variable trajectory, puff advection model of dispersion to predict the position of the radioactive plume. A ground level plume is modeled. The model uses a finite cloud technique to estimate external exposure received from the plume, while the standard concentration x/Q methodology is used to estimate doses received from inhalation of radioisotopes and external exposure over a four day period from material deposited on the ground. In addition, the model incorporates routines for computing deposition, as well as the current dose rate from radioactive material deposited on the ground, out to 50 miles.

The Raddose-V calculation considers source term and plume decay, as well as the effects of wet and dry deposition of iodines and particulates. The model also includes predefined protective action recommendations to alert users of the program to any exceedances of the EPA-400 Protective Action Guides (PAGs). The EPA-400 PAGs used are 1 Rem TEDE and 5 Rem CDE-Thyroid.

The six main tasks of the Raddose-V program are:

1. Determine the source term (release rates) of airborne radioactive material, based on current, plant-specific accident data.
2. Model the atmospheric transport and diffusion of the released material, based current, local meteorological conditions.
3. To calculate TEDE, estimate the sum of exposure from the plume, inhalation of radioisotopes, and four day exposure from material deposited on the ground.
4. Calculate committed dose equivalent (CDE) to the thyroid.
5. Estimate integrated deposition of radioactive material and corresponding dose rates from deposited material.
6. Provide dose and deposition results for both real-time and forecast periods.

Raddose-V performs all calculations in discrete 15-minute "advection time steps'. The model allows up to 200 advection steps (50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />) to be modeled. The model requires relevant meteorological and radiological information for each time step. The program data input screens allow for direct entry of Main Plant Computer System (MPCS) meteorological and radiological parameters, or the user can enter this data manually.

Raddose-V then calculates plume position, and dose and deposition information, for each step, according to the meteorological and radiological data entered. New real-time calculations are conducted every 15 minutes, based on the new position of the plume at the end of the 15 minute advection step.

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Once calculations are completed, users of the program are given the opportunity to print results following each 15 minute step.

For each time step, Raddose-V calculates dose rates and integrated doses at 80 radial-grid positions within the Plume Exposure Pathway Emergency Planning Zone (EPZ). Results are also provided at 77 predetermined receptor locations. Maximum dose rates by distance, based on plume position at the end of each advection time step, are calculated for each reporting location. The model also has the ability to calculate dose rates at any user-defined receptor location by entering the position's distance and bearing from the plant.

Further, the model calculates ground deposition at the 144 radial-grid receptors in the 50 mile Ingestion Pathway EPZ. These receptor locations include the same locations for which dose rates and doses are calculated in the Plume Exposure Pathway EPZ, plus receptors located at 20, 30, 40 and 50 miles at each of the sixteen (16) compass directions. TEDE and CDE-Thyroid doses are also given out to 50 miles.

Raddose-V also provides the ability to project doses (using a standard 4-hour default release duration) for the present incident without affecting the calculation results of real-time doses. Forecast results are based on "avoided" dose consistent with EPA-400 philosophy. Output reports available for real-time dose assessment are also available for the forecast calculations.

10.1.2 Evaluation of Field Environmental Samples When Seabrook Station monitoring teams have determined the approximate plume centerline (i.e., maximum radiation level) in the field, they will take air samples at various intervals downwind from the station. These samples will be analyzed on a gross (beta, gamma) basis in the field and, if elevated levels are observed, returned to the EOF.

At the EOF they will be referred to an appropriate laboratory facility to be analyzed to determine radionuclide concentrations.

Particular attention will be directed to observed iodine concentrations. The air samples will be analyzed in a two-step process. The first step involves a field analysis of the sample which measures the gross radioactivity collected on the silver zeolite cartridge and filter paper samples using a Pancake G-M detector. Field monitoring instrumentation can detect and measure radioidine concentration in the air as low as 10-7 Ci/cc. If the sample analysis shows a relatively high amount of radioactivity, a second analysis will be performed at an appropriate laboratory facility. The sample will be delivered to a laboratory facility for gamma spectroscopic analysis with greater sensitivity. Procedure ER 5.2, Site Perimeter and Offsite Monitoring and Environmental Sampling, also describes air sampling methods. Projected thyroid committed dose equivalent (CDE) will be determined from measured I-131 concentrations by multiplying by an estimate of the duration of the exposure and a dose conversion factor.

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In addition to the measurement and evaluation of offsite direct dose rates and air samples for radioiodine, the offsite radiological impact assessment will include the identification of all principal radionuclides potentially released from the accident in all potentially significant exposure pathways. This will be accomplished through an offsite monitoring and sampling program in which environmental samples of media (water, air, soil, etc., as appropriate) will be collected and subjected to detailed radionuclide analysis. This analysis can be performed by the GEL Laboratories, Charleston, South Carolina. The radionuclide results of any such analysis would be interpreted in terms of radiation exposure to the public by the use of the comprehensive dose calculation programs available at the EOF. The results of environmental sample analyses will be evaluated in relation to US Environmental Protection Agency dose guidelines for relocation and to the US Food and Drug Administration (FDA) derived intervention levels for the radionuclides identified in FDA guidance for limiting consumption of radioactively contaminated foods.

10 .1.3 Evaluation of Post Accident Samples When an emergency condition results in core damage, an in-station (e.g., containment) source term that could be subsequently released, or a release, station emergency response personnel will obtain and analyze various post accident samples. Potential sampling points include containment atmosphere, gas spaces in other plant areas, and the plant vent stack. Per the Seabrook Station Post Accident Assessment Program, archive samples of the reactor coolant system and containment sump can also be obtained and analyzed.

Source-term components, including radioiodine, would be quantified and evaluated in terms of actual or potential impact.

10 .1.4 Severe Accident Management Guidance Guidance for responding to severe accident conditions has been established and appropriate improvements have been implemented in accordance with Chapter 5 of NEI 91-04, Revision 1, Severe Accident Issue Closure Guidelines. Appropriate Severe Accident Management (SAM) references have been incorporated into applicable Seabrook Station emergency response (SSER) procedures. Severe accident management training requirements for TSC personnel are documented in the Emergency Preparedness Training Program Description. The Operations Training Department tracks SAM Implementor Training for Operations personnel.

10.2 Protective Action Recommendation Criteria Seabrook Station will issue protective action recommendations (P ARs) based on the emergency class and several factors which vary with each emergency class. No protective actions will be recommended at the Unusual Event or Alert emergency classes. At a Site Area Emergency, PARs for beach areas may be issued based on the time of year and selected plant status indicators. At a General Emergency, P ARs will be issued based on selected plant status indicators, dose projections and field monitoring results.

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Protective action recommendations have been developed using the guidance of NUREG-0654, Supplement 3, which provides an acceptable method to comply with 10CFR50, Appendix E, Section IV, paragraph 3 in the use of evacuation time estimates in the formulation of PARs for the plume exposure pathway emergency planning zone, and provides guidance for meeting planning standard 10CFR50.47(b)(10) in the development of a range of protective actions.

The protective action recommendations have been coordinated with responsible State of New Hampshire and Commonwealth of Massachusetts authorities.

For a General Emergency, other than a General Emergency based on a Hostile Action, Seabrook Station will at a minimum recommend (1) evacuation of towns within 2 miles of the Station, (2) evacuation of towns 5 miles downwind of the Station, (3) sheltering of the remaining towns within the EPZ, (4) evacuation of Hampton and Seabrook Beaches and (5) closure of Massachusetts beach areas. For a General Emergency based on a Hostile Action, the initial PAR will be to shelter for all EPZ towns. P ARs may be expanded based on further assessments of plant and radiological conditions.

For accidents that result in airborne radioactivity releases, projected dose and dose rate estimates at the site boundary and distances out to 10 miles will be issued to those offsite authorities responsible for protective action decision making. Based on offsite field monitoring results and dose projections, Seabrook Station will recommend protective actions in accordance with the criteria set forth in the EPA Protective Action Guidelines, Table 10.1.

Seabrook Station will also perform ingestion pathway sampling and analysis, and assist offsite authorities in determining protective actions for the ingestion exposure pathway Emergency Planning Zone.

10.3 Radiological Exposure Control During a Station emergency, abnormally high levels ofradiation and/or radioactivity may be encountered. These levels may range from slightly above those experienced during normal station operation to life-endangering levels of several hundred rem in a short period of time.

Under all situations, whether it is immediate action to regain control of the emergency or for life-saving purposes, measures will be taken to minimize personnel doses from external and/or internal sources of radiation.

Specific dose guidelines for entry or re-entry into areas in order to (1) remove injured persons, and (2) undertake corrective actions, are defined in Table 10.2 of the plan. The Site Emergency Director will authorize, with Health Physics Coordinator or Radiological Controls Coordinator concurrence, emergency dose guidelines consistent with these or more restrictive guidelines dependent upon emergency conditions. The Radiological Controls Coordinator will discuss the hazards involved in rescue procedures with the members of the response team prior to undertaking any health-threatening mission.

Considerations to be made prior to allowing personnel to accept risks associated with rescue operations are defined in Table 10.2, Emergency Dose Limits.

Dose to individuals providing other emergency functions will be consistent with the limits specified in Table 10.2 with every attempt being made to keep personnel dose as low as reasonably achievable (ALARA).

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The Health Physics Coordinator, or a designated alternate, is responsible for maintaining the emergency radiological protection programs developed for station staff and support personnel. A supply of self-reading dosimeters will be stored at the Health Physics Control Point for distribution and assignment to the Technical Support Center. An emergency tote of self-reading dosimeters is stored at the EOF to ensure immediate deployment of offsite monitoring teams with dosimetry and to support entry of offsite personnel to the site. Self-reading dosimetry readers and program software have been added to the EOF inventory to ensure dosimetry activation.

Each emergency response organization member reporting to the site will be provided a Dosimeter of Legal Record (DLR) badge and a self-reading dosimeter. Dose records based upon the results of these dosimeters will be maintained at each center. This information will be cross-referenced with and replaced by DLR badge data when available. Should the station exhaust its supply of DLR badges, the station DLR vendor, Mirian Technologies (GDS) will supply DLR badges. Offsite authorities responding onsite will be provided dosimetry.

10.4 Protective Measures 10.4.1 Personnel Accountability The determination of station personnel accountability is facilitated by the use of a computer-assisted accountability system. The goal of this system is to generate an initial list of missing individuals within 30 minutes of the declaration of an Alert or higher emergency classification level.

Upon declaration of an emergency and activation of station emergency alarms, station personnel assigned specific emergency responsibilities will proceed to their designated emergency center location. If an Alert or higher emergency classification level is declared, non-assigned personnel (e.g., station visitors, contractor and other station personnel) will return their dosimetry to the designated normal storage racks, if appropriate, and leave the protected area through the Guard Island. There, non-assigned personnel will receive instructions concerning station egress measures. Security will generate computer reports of personnel entering and evacuating through Guard Island.

All emergency response personnel reporting to emergency centers will log in on card readers and accountability rosters associated with each center.

Station security personnel will be responsible for reviewing computer results and reporting these results to the Security Shift Supervisor who, in tum, will make the final determination of station personnel accountability and report the results to the STED or Site Emergency Director. Search and rescue procedures will be implemented if any persons have been identified as missing.

10.4.2 Station Access/Egress Control Methods Under all Station emergency conditions, public address announcements, made by control room personnel, will provide emergency notification and instruction to those personnel within the Protected Area. Individuals in the balance of the owner-controlled area will be alerted by an onsite siren. Visitors or those in transit within the owner-controlled area will be advised by the most appropriate means. The complete warning and advisement process will be accomplished in a rapid manner to ensure personnel safety.

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When an Alert, Site Area Emergency or a General Emergency has been declared, all non-assigned station personnel will be directed to proceed to either the remote monitoring area for monitoring and decontamination or directly home (except during outages when the station is in Mode 5 or 6- see Chapter 3, section 3.2). Unless directed otherwise, non-assigned personnel will use their personal vehicles to leave the site.

In the event that station conditions may produce or have produced a release, traffic control measures will be established to direct unassigned personnel off site via the most appropriate exit (the North Access Road or the South Access Road). The Security Shift Supervisor will be informed by the Short Term Emergency Director or by the Site Emergency Director which access road to use for site evacuation traffic in order to minimize the potential for radiation exposure or contamination by radioactive material.

If a radioactive release has occurred which might result in the contamination of Station evacuees, personnel trained in contamination monitoring techniques will proceed to the remote monitoring area to perform contamination monitoring of evacuated vehicles and personnel. All evacuating personnel will be instructed to report to the remote monitoring area to be surveyed for contamination levels. If contamination is detected, actions will be implemented that appropriately correspond to the type and degree of contamination and that are consistent with the priorities of the emergency actions and conditions underway.

The Health Physics Coordinator will contact the Radiological Assistant at the EOF and report Remote Monitoring Area contamination survey results. Appropriate personnel and vehicle decontamination techniques will be used as necessary.

Upon being released, station evacuees will be advised of area evacuation routes by security. Site evacuation routes are noted in Figure 10.2, Seabrook Station Evacuation Routes. Appendix C provides evacuation time estimates of the public within the plume exposure pathway EPZ and also summarizes the major evacuation routes which will be utilized if necessary.

The Security Coordinator will make arrangements for station badging necessary to support incoming emergency response personnel. All incoming responders will be directed to report to the EOF where they will be briefed and provided with the necessary equipment.

10.4.3 Protective Measures for Hostile Action Based Events Operations Department Abnormal Operating Procedures (AOPs) contain specific instructions for onsite personnel within the Protected Area for hostile action based events.

The AOPs are referenced in Appendix G,Section VII. The content of the instructions are specific to land based or airborne events. The protective measures prescribed by the AOPs conform to the requirements of 10 CFR 50 Appendix E, Section IV, 1.

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10.4.4 Decontamination Capability Station decontamination facilities are located in the Operational Support Center, specifically at the Radiologically Controlled Area HP Control Point. The RCA shower is available for personnel decontamination purposes. Soap, brushes, etc., are available to aid in decontamination efforts. Survey instrumentation for personnel monitoring is available here. If necessary, internal contamination can be assessed with the use of whole body count equipment (FAS TS CAN) or its backup. All waste generated through the use of the decontamination facilities is collected and processed by the station liquid radwaste system.

Decontamination capability exists at the EOF and at the remote monitoring area. At the remote monitoring area, initial decontamination methods will involve the use mild soap and water in conjunction with a soft brush. All radwaste generated as a result of this procedure will be disposed of by normal radwaste procedures. All personnel with detectable skin contamination will be detained for decontamination purposes; otherwise, they will be released. Radiation Protection Department procedures for personnel surveys and decontamination techniques prescribe progressive techniques for skin decontamination, including techniques applicable to removal of radioiodine contamination. The procedures and supplies for implementing them are maintained at the EOF and remote monitoring area. At both locations, personnel decontamination can be accomplished with the use of a shower station, with wash water collected into a tank and pumped to 55-gallon drums that shall be transferred for processing onsite. If required, vehicle decontamination will be accomplished via dry decontamination methods.

10.4.5 Use of Onsite Protective Equipment and Supplies The station supplies of personnel radiation protection equipment will be used as necessary to support the emergency response effort. Respiratory protection equipment, protective clothing, and potassium iodide will be assigned to the onsite emergency response organization members in accordance with Procedure ER 4.3, Radiation Protection During Emergency Conditions. Respiratory protection qualifications for personnel assigned to OSC positions, Offsite Monitoring Team positions, On-shift Electricians, On-shift Mechanics, and On-shift I&C Technicians will be tracked by Emergency Preparedness. Respiratory protection qualifications for Plant Engineering engineers who could be assigned to corrective action teams will be tracked by Plant Engineering. Radiological monitoring equipment will be stocked and available for use at established emergency centers. Seabrook Station documents containing detailed lists of dedicated equipment available to support radiological emergency response efforts are referenced in Appendix F.

10.4.6 Radiation Guideline Action Levels Radiation guideline action levels for emergency center habitability are shown on Tables 10.l and 10.3. These tables describe the actions of station staff in response to a range of station radiological conditions.

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10.5 Aid to Affected Personnel 10.5.1 Medical Treatment Station medical facilities are provided in the first aid station located in proximity to the Radiologically Controlled Area HP Control Point. Seabrook Station also maintains a site medical office located in the Operations Support Building. The first aid station and medical office are equipped and supplied to implement the requirements of the Medical Program. (Protected: Ref. NRC IR 85-32[10])

Specific station personnel have been trained as Emergency Medical Technicians (EMTs).

One Emergency Medical Technician, supplemented by at least one additional individual trained in first aid and cardio-pulmonary resuscitation, will be on site at any one time to provide 24-hour emergency response coverage.

10.5.2 Medical Transportation Arrangements have been made with Exeter Hospital to provide care for contaminated injured patients. In addition, Wentworth-Douglass Hospital located in Dover, NH, will provide care for these individuals on a backup basis. Both hospitals participate in medical emergency drills as a portion of emergency plan training.

The Seabrook Fire Department ambulance will be used for medical transportation of injured and contaminated personnel. The ambulance is capable of radio communications with the hospital while en route with a patient. (Protected: Ref. NRC IR 85-32[12])

Ambulance personnel are provided with specific training by Seabrook Station staff on the radiation protection considerations associated with radiologically contaminated personnel.

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Table 10.1 EPA Protective Action Guidelines Applicable to Seabrook Station Protective Action Recommendation Procedures PAG PROTECTIVE ACTION I COMMENTS I

1 rem TEDEa Evacuation Evacuation of the general public should be initiated at 1 rem.

5 rem CDEb - thyroid Evacuation Evacuation of the general public should be initiated at 5 rem.

Potential State Considerations PAG PROTECTIVE ACTION COMMENTS 5 rem TEDE Evacuation Special situations include severe weather, competing disasters, evacuation impediments or institutionalized persons not readily mobile.

25 rem CDE - thyroid Evacuation Special situations include severe weather, competing disasters, evacuation impediments or institutionalized persons not i

readily mobile.

I>25 rem CDE - thyroid Administer Kl I Offsite Emergency workers and institutionalized persons.

a Total Effective Dose Equivalent - see Definitions b Committed Dose Equivalent - see Definitions 1-10.10 SSREP Rev. 73

Table 10.2 Emergency Dose Limits Dose Limit3 b (rem) Activity Condition 5 All activities I 10 I Protecting valuable property Lower dose not practicable 25 I Lifesaving or protection of large Lower dose not practicable populat10ns I

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

a TEDE to non-pregnant emergency workers.

b Emergency dose limits for the lens of the eye and for any other organ (including skin and extremities) are three and ten times listed values, respectively.

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Table 10.3 Emergency Center Protection

1. Center habitability actions shall be as indicated on Figure 10.1.
2. The need to dispense potassium iodide (KI) tablets to emergency response personnel is based upon a projected or actual thyroid committed dose equivalent (CDE) :::=:: 5 rem 1. Administering KI after an uptake may limit thyroid CDE depending on time after exposure.
3. Protective clothing (lab coats, shoe covers, cotton gloves) will be required when indicated by RP survey results.

1 Based on most limiting FDA recommended threshold for pregnant and lactating women per "Guidance, Potassium Iodide as a Thyroid Blocking Agent in Radiation Emergencies,"

U.S. Department of Health and Human Services, Food and Drug Administration, Center for Drug Evaluation and Research (CDER), November 2001.

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APPENDIXD LETTERS OF AGREEMENT TABLE OF CONTENTS Date of Agreement

1. Exeter Hospital January 2012
2. [Deleted AR 02276102 September 2018] [Deleted]
3. Wentworth-Douglass Hospital February 2004
4. Seabrook Fire Department June 2016
5. State of New Hampshire and Commonwealth of Massachusetts July 2017
6. Institute of Nuclear Power Operations See NOTE 1
7. Portsmouth Police Department May2013
8. Pease Development Authority (EOF) May 2013
9. Alternate EOF location for beyond Design Basis Events April 2014 (Protected: Ref. NRC IR 85-32[7])

(Protected: Ref. NRC IR 85-32[12])

(Protected: Ref. FPL Common Letter L-2005-214)

NOTE 1: The INPO.emergency assistance agreement is initiated by INPO with its member utilities.

The agreement is certified to remain in effect annually by INPO by letter of agreement to its member utilities. The current letter of certification is posted annually by INPO on the INPO website under emergency preparedness. For that reason, the current INPO letter of agreement is not maintained in the SSREP.

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SUMMARY

OF CHANGES Rev. 63: (PCR 02276102 September 2018)

Deleted letter of agreement with the Portsmouth Land Acquisition because the property that the Remote Monitoring Area is located on has been sold.

Rev. 62: (PCR2217534 August2017)

Updated Appendix D with the revised letter of agreement between the site and the State of New Hampshire and Commonwealth of Massachusetts.

Rev. 61:

In Appendix D updated agreements for Portsmouth Land Acquisition (Remote Monitoring Area),

Seabrook Fire Department, and Institute of Nuclear Power Operations.

Rev. 60:

In Appendix D added agreement for alternative EOF for beyond design basis events.

Rev. 59:

In Appendix D removed PSNH Newington Station and Newington Police Department. Added Portsmouth Police Department and Pease Development Authority. Changed Jask Realty to Portsmouth Land Acquisition. (AR#l 721945)

Rev. 58:

Added new lease agreement for relocated remote monitoring area and updated letters of agreement for Exeter Hospital and Seabrook Fire Department.

Rev. 57:

Inserted most recent Institute of Nuclear Power Operations emergency assistance agreement.

Rev. 56:

Updated letter of agreement with the Commonwealth of Massachusetts and the State of New Hampshire.

Updated lease agreements with Public Service New Hampshire for the Emergency Operations Facility at Newington Station and for the remote monitoring/decontamination facility at Schiller Station.

Rev. 55:

Updated the letter of agreement with the Seabrook Fire Department with agreement dated August 2007.

Rev. 54:

This appendix was unaffected by this revision to the manual.

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