TMI-22-028, Radiological Emergency Plan Document Revisions

Radiological Emergency Plan Document Revisions

ML22270A010
Person / Time
Site:	Three Mile Island
Issue date:	09/27/2022
From:	David Helker Constellation Energy Generation
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TMI-22-028
Download: ML22270A010 (76)

Text

200 Exelo n Way Kennett Square, PA 19348 www.ConstellationEnergy.com

10 CFR 50.4 10 CFR 50.54(q)(5) 10 CFR 72.44(f)

TMI-22-028

September 27, 2022

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

Three Mile Island Nuclear Station, Unit 1 Renewed Facility License No. DPR-50 NRC Docket No. 50-289

Three Mile Island Nuclear Station, Unit 2 Facility Possession-Only License No. DPR -73 NRC Docket No. 50-320

Subject:

Exelo n Nuclear Radiological Emergency Plan Do cument R evisions

In accordance with 10 CFR 50.4(b)(5), "Emergency Plan and related submissions,"

Constellation Energy Generation, LLC ( CEG) is submitting the Emergency Plan document revisions listed in the table belo w for the Three Mile Island Nuclear St ation (TMI).

Document Revision Title EP-TM-1002 0 Constellation Three Mile Island ISFSI Only Emergency Plan (IOEP)

EP-TM-100 2, Addendum 1 0 Constellation Three Mile Island ISFSI Only Emergency Action Levels and Technical Bases Superseded Deleted Emergenc y Plan Documents EP-TM -1001 1 Three Mile Island Permanently Defueled Emergency Plan (PDEP)

EP-TM -1001, Addendum 1 0 Three Mile Island Station Permanently Defueled Emergency Action Levels and Technical Bases

The changes to the Emergency Plan documents noted in the table above were evaluated under the requirements of 10 CFR 50.54(q) and w ere determined not to result in a reduction in the effectiveness of the Emergency Plan for TMI. The changes are considered "conforming changes" in support of implementing Amendment No. 303 issued by the NRC as documented in a letter and supp orting Safety Evaluation Report dated April, 2022. T his notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50.5 4(q)(5).

The changes continue to meet the applicable emergenc y Planning Standards establi shed in 1 0 CFR 50.4 (b), 10 CFR 50, Appendi[ E, and the Program Ele ment guidance in N8REG -0 54.

U.S. Nuclear Regul atory C ommission Emergency Plan Do cument Revisions Docket Nos. 50-289 and 50-320 September 27, 2022 Page 2

In addition, a s required by 10 CFR 50.54(q)(5), Attachment 1 of this submittal includes a summary analysis of the changes to the noted Emergenc y Plan documents. This submittal also satisfies the reporting requirement s associated with 10 CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee shall submit a report containi ng a de scription of the cha nges to the Director, Division of F uel Management, Office of Nu clear Material Safety and Safeguar ds.

A copy of the applicable Emergency Plan documents and supporting change summary analys is are included in the attachments to this letter. The Emergency Plan documents noted as being superseded/d eleted are not attached.

There are no regulatory commitments in this submittal.

If you have any questions or require addi tional informati on, please contac t Richard Gropp at (610) 765-5557.

Respectfully,

David P. H elker Sr. Manager, Licensing Constellation Energy Generation, LLC

Attachments: 1) 10 CFR 50.54(q)(5) Procedure Change Summary Analysis

2) EP-TM-1002, Revision 0, "Constellation Three Mile Island ISFSI O nly Emergency Plan (IOEP )"

3) EP-TM-1002, Addendum 1, R evision 0, "Constellation Three Mile Island ISFSI Only Emergency Action Levels and T echnical Bases"

cc: w/ Attachment 1 only Regional Administrator - NR C Region I Director, NRC Division of Spent Fuel Management, ONMSS NRC Project Manager, NMSS -Three Mile Island Nuclear Station W. DeHaas, PA DEP, Bureau of Radiation P rotection

Attachment 1

10 CFR 50.54(q)(5) Procedure Change Summary Analysis

Attachm ent 1 Summary of Changes Page 1 of 3

Attachment 1

10 CFR 50.54(q)(5) Procedure Change Summary Analysis

I. Procedures/Titles

Constellation Energy Generation, LLC ( CEG) has iss ued the Emerge ncy Plan document revisions for the Three Mile Island Nuclear Station (TMI) as noted be low.

• EP-TM-1002, Revision 0, "Constellation Three Mile Island ISF SI Only Emergency Plan (IOEP )"

• EP-TM-1002, Addendum 1, R evision 0, "Constellation Three Mile Island ISFSI Only Emergency Action Levels and T echnical Bases"

The following previously approved procedures for TMI hav e been superseded/ deleted:

• EP-TM -1001, Revision 1, "Three Mile Island Permanently Defueled Emergency Plan (PDEP)"

• EP-TM -1001, Addendum 1, Revision 0, "Three Mile Island Station Permanently Defueled Emergency Action Levels and Technical Bases "

II. Description of Procedures

Background

By letter dated March 4, 2021, as supplemented, Exelon Generation Company LLC (now CEG) submitted a license amendment request to revise the TMI Emergency Plan and associated Emergency Action Level (EAL) scheme for the permanently defueled condition after all irradiated fuel has been transferred from the Spent Fuel Pools (SFPs) to the Independent Spent Fuel Storage Installation (ISFSI). By letter dated April 7, 2022, a long with the supporting Safety Evaluation Report (SER), the U.S. Nuclear Regulatory Commission (NRC) issued Amendm ent No. 303 to Renewed Facility License DPR-50 approving the TMI ISFSI-only E mergency Plan (IOEP).

The documents noted above (i.e., EP-TM -1002 and EP-TM -1002, A ddendum 1) implement the IOEP at TMI and describe the facility's plan for responding to emergencies that may arise following implementation of Amendment No. 303. The IOEP encompasses bo th TMI -1 and TMI-2 and establ ishes the emergency planning requirements after all spent fuel has been transferred from the TMI -1 SFPs to dry cask storage within the onsite TMI -1 ISFSI. CEG maintains the emergency planning responsibilities for TMI-2, which is owned by TMI-2 Solutions (subsidiary of Energy Solutions), through a service agreement.

Summary of Chang es Page 2 of 3

EP-TM -1002

This document is applicable after T MI-1 has pl aced all spent fu el previously maintained in the TMI -1 SPFs into dry cask storage on the TMI-1 ISFSI. The changes are consistent with TMI -1 Ame ndment No. 303 as approved by the NRC. The IOEP describes the plan for responding to emergencies that ma y arise at the TMI-1 ISFSI and encompasses both TMI-1 and TMI-2. The purpose of the IOEP is to ensurethat an adequate lev el of prepa redness to cope with a spectrum of emergencies that could be postu lated to occur, including the means to minimize radiation exposure to facility personnel, is provided. The IOEP plan inte grates the necessary elements to provide effective emergency response cons idering cooperation and coordination of off-site organizations expected to respond to potential emergencies.

EP-TM -1002, Addendum 1

This document provides the detailed setof EALs and associated Technical Bases applicable to TMI using the EAL development methodology guidance described in NEI 99- 01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6, for a permanently defueled f acility. The changes are consistent with TMI-1 Amendment No. 303 as approved by the NRC. TMI will use the Recognition C ategory "PD" (Permanently Defueled) to provide the site-specific emergency classification scheme including a set of Initiating Conditions (ICs) and EALs associated with the perman ently defueled condition and Recognition Category "E" IC/EAL for t he ISFSI.

III. Description of Changes

EP-TM -1002 and EP-AA-1002, Addendum 1

These documents implement the IOEP a t TMI and describe the facility's plan for responding to emergencies that may arise and encompass both TMI -1 and TMI-2 following the implementation of Amendment No. 303 to Renewed Facility License DPR-50 for TMI-1. The changes are commensurate with the reduced spectrum of credible accidents for a permanently shut down and defueled power reactor facility with all TM 1-1 spent fuel removed from the SFPs and transferred to the ISFSI. The c hanges are c onsidered "conforming changes" in support of implementing Amendment No. 303 as approved by the NRC. The NRC's SER addresses the acceptability of the proposed TMI IOEP and associated EAL scheme and supporting Technical Bases. The I OEP replaces the previously approved TMI Permanently Defueled Emergency Plan (PD EP) and associated Permanently Defueled EALs after all spent fuel has been transferred from the TMI -1 SFPs to dry cask storage within the onsite TMI -1 ISFSI.

As noted above, and as a result of implementin g the IOEP, the following TMI Emergency Plan documents are no longer applicable and have been superseded/dele ted:

• EP-TM -1001, Revision 1

• EP-TM -1001, Addendum 1, Revision 0 Summary of Chang es Page 3 of 3

IV. Description of H ow the Changes Sti ll Comply w ith Regulati ons

EP-TM -100 2 and EP-AA -1002, Addendum 1

The im plementation of the noted procedures addresses changes in supp ort of impleme nting the TMI IOEP as approved by the NRC on April 7, 2022, under Amendment No. 303 to Renewed Facility License DPR -50 for TMI -1. The changes were evalu ated in accordance with the requirements of 10 CFR 50.54(q) and were determined not to require prior NRC approval. The changes described reflect the changes as approved by the NRC. The changes are considered "conforming changes" and prior NRC approval is not required to support implementation since the NRC has already approved the changes. NRC Regulatory Guide (RG) 1.129, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," states the following regarding "conforming changes":

The licensee should screen all proposed changes to t he emergency plan to determine whether a 10 CFR 50.54(q) evaluation is necessary and to determine whether another formal change process is applicable. The purpose of this screening is not to decide which proposed changes could reduce effectiveness but inst ead whether a 10 CFR 50.54(q) change evaluation is necessary. The licensee should screen each proposed change separately and reserve the treatment of changes collectively f or (1) repetitive identical changes, (2) editorial or typographical changes such as formatting, paragraph numbering, spelling, or punctuation that do not change intent, (3) conforming changes, or (4) two or more elements that are interdependent (e.g., a change to one element compensates for a change to another element). The licensee shoul d document this screening if it concludes that a 10 CFR 50.54(q) evaluation is not necessary.

The implemtation of the proc edures does not alter the meaning or intent of the basis of the NRC-approved IOEP for TMI. Existing requirements and capabilities for the TMI Emergency Plan have not been deleted or reduced as a result of the changes described. A review of existing regulatory commitments was made to ensure any applic able existing commitments continue to be met. The changes described for the TMI IOEP meet applicable regulatory requirements established in 10 CFR 50.47, 10 CFR 50, Appendix E, and the Pro gram Element guidance of NUREG-0654 for a permanently defueled faci lity where the spent fuel has removed from the TMI-1 SFPs and transferred to dry cask storage within the onsite TMI -

1 ISFSI.

V. Description of Wh y the Ch anges are Not a Reduction in Effective ness (RIE )

EP-TM -1002 and EP-AA -1002, Addendum 1

Based on the ch anges described in Sections III and IV above for the IOEP d ocumentation for TMI, emergenc y response c apabilities are maintai ned and are not adversely impacted by the changes. The changes were previously approved by the NRC under Amend ment No.

303 and evaluated pursua nt t o 10 CFR 50.54(q) and are considered "conforming changes" consistent with the guidance specified in RG 1.219 and, therefore, prior NRC approval is not required. Applicable regulatory commitments to the NRC are not changed or reduced.

Emergency preparedness requi rements establishe d in 10 CFR 50.47, 10 CFR 50, Appen dix E, and the Pro gram Element guida nce of NUREG-0654 continue to be met. Therefore, the changes described do not constitute a reduction in effectivenes s in support of impl ementing the IOEP for TMI.

Attachment 2

Emergency Plan Revision

EP-TM -100 2, Revision 0, "Constellation Three Mile Island ISFSI Only Emergency Plan (IOEP )"

EP-TM-1002 Revision 0

CONSTELLATION

THREE MILE ISLAND

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) ONLY EMERGENCY PLAN (IOEP)

Three Mile Island IOEP Constellation

REVISION HISTORY

REVISION EFFECTIVE DATE REVISION EFFECTIVE DATE 0 August 30, 2022

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TABLE OF CONTENTS

Section Page

PART I....................................................................................................................................... 1

1.0 INTRODUCTION

............................................................................................................ 1

1.1 PURPOSE...................................................................................................................... 1 1.2 SCOPE........................................................................................................................... 1

2.0 DISCUSSION................................................................................................................. 3

2.1 OVERVIEW OF ISFSI ONLY EMERGENCY PLAN (IOEP)........................................... 3 2.2 FACILITY DESCRIPTION.............................................................................................. 3 2.3

SUMMARY

OF EMERGENCY ACTIONS...................................................................... 4

3.0 REFERENCES

............................................................................................................... 5

4.0 DEFINITIONS AND ABBREVIATIONS......................................................................... 7

4.1 DEFINITIONS................................................................................................................. 7 4.2 ACRONYMS................................................................................................................. 10

PART II..................................................................................................................................... 11

1.0 ASSIGNMENT OF RESPONSIBILITY (ORGANIZATION CONTROL)....................... 11

1.1 EMERGENCY RESPONSE AND RESPONSIBILITIES............................................... 11 1.2 OFFSITE RESPONSE ORGANIZATIONS (ORO)....................................................... 11

2.0 EMERGENCY RESPONSE ORGANIZATION (ERO).................................................. 13

2.1 ON-SHIFT POSITIONS................................................................................................ 13 2.2 SECURITY................................................................................................................... 14 2.3 AUGMENTED POSITION............................................................................................ 14 2.4 SUPPLEMENTAL PERSONNEL.................................................................................. 14 2.5 FUNCTIONAL RESPONSIBILITIES............................................................................. 15

3.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES....................................... 16

3.1 LOCAL SERVICES....................................................................................................... 16 3.2 FEDERAL GOVERNMENT SUPPORT........................................................................ 16 3.3 ADDITIONAL SUPPORT.............................................................................................. 16

4.0 EMERGENCY CLASSIFICATION SYSTEM................................................................ 17

4.1 UNUSUAL EVENT....................................................................................................... 17

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4.2 ALERT.......................................................................................................................... 17 4.3 EMERGENCY ACTION LEVELS AND POSTULATED ACCIDENTS.......................... 18

5.0 NOTIFICATION METHODS AND PROCEDURES...................................................... 19

5.1 NOTIFICATION AND MOBILIZATION OF TMI EMERGENCY RESPONSE PERSONNEL............................................................................................................... 19 5.2 BASES FOR NOTIFICATION OF OFFSITE AGENCIES............................................. 19 5.3 EMERGENCY MESSAGES......................................................................................... 19 5.4 NRC EVENT NOTIFICATION....................................................................................... 20 5.5 SUPPORT ORGANIZATIONS...................................................................................... 20

6.0 EMERGENCY COMMUNICATIONS............................................................................ 21

7.0 PUBLIC INFORMATION.............................................................................................. 22

8.0 EMERGENCY FACILITY AND EQUIPMENT.............................................................. 23

8.1 EMERGENCY RESPONSE FACILITY......................................................................... 23 8.2 EMERGENCY EQUIPMENT........................................................................................ 23

9.0 ACCIDENT ASSESSMENT......................................................................................... 25

10.0 PROTECTIVE ACTIONS............................................................................................. 26

10.1 SITE EGRESS CONTROL METHODS........................................................................ 26 10.2 FIRE FIGHTING........................................................................................................... 26 10.3 ACCOUNTABILITY...................................................................................................... 26

11.0 RADIOLOGICAL EXPOSURE CONTROL.................................................................. 27

11.1 EXPOSURE GUIDELINES........................................................................................... 27 11.2 RADIATION PROTECTION.......................................................................................... 27 11.3 ACCESS CONTROL.................................................................................................... 27 11.4 PERSONNEL EXPOSURE MONITORING.................................................................. 27 11.5 CONTAMINATION CONTROL..................................................................................... 28

12.0 MEDICAL AND HEALTH SUPPORT........................................................................... 30

12.1 ONSITE FIRST AID...................................................................................................... 30 12.2 MEDICAL TRANSPORTATION.................................................................................... 30 12.3 OFFSITE MEDICAL SUPPORT................................................................................... 30

13.0 EMERGENCY TERMINATION AND RECOVERY....................................................... 31

13.1 EMERGENCY TERMINATION AND NOTIFICATION.................................................. 31 13.2 RECOVERY OPERATIONS......................................................................................... 31

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14.0 EXERCISE AND DRILLS............................................................................................. 32

14.1 EXERCISE AND DRILL................................................................................................ 32 14.2 EQUIPMENT AND PROFICIENCY DRILLS................................................................. 33

15.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING........................................... 35

15.1 EMERGENCY RESPONSE PERSONNEL TRAINING................................................ 35 15.2 EMERGENCY PREPAREDNESS TRAINING PROGRAM.......................................... 35 15.3 SUPPORT ORGANIZATIONS TRAINING.................................................................... 36

16.0 MAINTAINING EMERGENCY PREPAREDNESS....................................................... 37

16.1 EMERGENCY PREPAREDNESS RESPONSIBILITIES.............................................. 37 16.2 REVIEW AND UPDATING OF THE IOEP AND SUPPORTING PROCEDURES........ 38 16.3 MAINTENANCE AND INVENTORY OF EMERGENCY EQ UIPMENT AND SUPPLIES

..................................................................................................................................... 38

PART III..................................................................................................................................... 39

APPENDIX B................................................................................................................................ 40

APPENDIX C................................................................................................................................ 41

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PART I

1.0 INTRODUCTION

The INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) Only Emergency Plan (IOEP) describes the plan for responding to emergencies that may arise at the Three Mile Island Nuclear Station (TMI) ISFSI. The Emergency Plan encompasses both Three Mile Island Unit 1 (TMI-1) and Three Mile Island Unit 2 (TMI-2).

This plan is applicable after the TMI-1 has placed all spent fuel previously maintained in the stations Spent Fuel Pool into dry cask storage on the TMI-1 ISFSI. In this condition, no reactor operations can take place and all irradiated fuel is removed from the Spent Fuel Pools (SFPs).

Constellation maintains the emergency planning responsibilities for TMI-2, which is owned by TMI-2 Solutions (subsidiary of Energy Solutions), through a service agreement.

This IOEP adequately addresses the risks associated with TMI's current conditions.

As provided in the ISFSI storage system Final Safety Analysis (FSAR), the analysis of the potential radiological impacts of postulated off-normal, natural phenomenon, and accident events in an ISFSI only condition indicates that any releases would result in a DOSE to the public below the radiation limits established in 10 CFR 72.106(b). Exposure levels, which warrant pre-planned response measures, are generally limited to the ISFSI pad and nearby vicinity, and for this reason radiological emergency planning is focused on this area.

1.1 PURPOSE

The purpose of the IOEP is to assure an adequate level of preparedness to cope with a spectrum of emergencies that could be postulated to occur, including the means to minimize radiation exposure to facility personnel. This plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of off-site organizations expected to respond to potential emergencies.

1.2 SCOPE

The IOEP has been developed to respond to potential radiological emergencies at TMI. Because there are no postulated accidents that would result in DOSE consequences that are large enough to require OFFSITE emergency planning, the overall scope of this plan delineates the actions necessary to safeguard ONSITE personnel and minimize damage to property. If determined appropriate by government officials, PROTECTIVE ACTIONS may be implemented to protect the public using an all-hazards approach to emergency planning.

The concepts presented in this plan address the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans" and 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," as exempted. Exemptions to selected portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and 10 CFR Part 50, Appendix E were previously approved by the NRC on December 1, 2020 (ADAMS Accession Number:

ML20244A292 and ML20244A293). The plan is consistent with the remaining applicable

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guidelines established in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Facilities" (NUREG-0654). Appendix 3 contains a cross-reference to the applicable guidance in NUREG-0654.

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2.0 DISCUSSION

2.1 OVERVIEW OF ISFSI ONLY EMERGENCY PLAN (IOEP)

In the event of an emergency at TMI, actions are required to identify and assess the nature of the emergency and to bring it under control in a manner that protects the health and safety of the public and facility personnel.

This plan describes the organization and responsibilities for implementing emergency measures. It describes interfaces with Federal, Commonwealth of Pennsylvania, and local organizations that may be notified in the event of an emergency and may be requested to provide assistance.

Emergency services are provided by local public and private entities as provided in Part II, Section 1.

Law enforcement support services are provided by local, state, and federal law enforcement authorities, as appropriate. Ambulance service is provided by Londonderry Volunteer Fire Company.

Because there are no postulated accidents that would result in off-site DOSE consequences that are large enough to require off-site emergency planning, emergencies are divided into two CLASSIFICATIONS: 1) Notification of UNUSUAL EVENT (UNUSUAL EVENT) and 2) ALERT.

The CLASSIFICATION scheme, developed in accordance with Nuclear Energy Institute (NEI) 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6, November 2012 (NEI 99-01), has been discussed and agreed upon with responsible OFFSITE organizations and is compatible with their respective emergency plans. If determined appropriate by government officials, PROTECTIVE ACTIONS may be implemented to protect the public using the existing all hazards emergency planning (i.e., Comprehensive Emergency Management Plan (CEMP)).

Constellation is responsible for planning and implementing emergency measures associated with the TMI site. This plan is provided to meet this responsibility. To carry out specific emergency measures discussed in this plan, detailed EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIP) are established and maintained. A list of EPIPs is included in Appendix B.

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

2.2 FACILITY DESCRIPTION

The TMI site is located in an area of low population density about 12 miles southeast of Harrisburg, Pennsylvania. The area is in Londonderry Township, Dauphin County, about 2.5 miles from the southern tip of Dauphin County, where the county is coterminous with York and Lancaster Counties.

TMI-1 is owned by Constellation. TMI-1 formerly consisted of a single unit Babcock and Wilcox (B&W) Company (Currently AREVA) pressurized water reactor (PWR). TMI-1 ceased power operations in September 2019 and certified that fuel had been permanently removed from

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the reactor vessel. The 10 CFR Part 50 license for TMI-1 no longer authorize operation of the reactor, emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2). All spent fuel has been transferred to the TMI-1 ISFSI which is located to the south of the TMI-1 facility. The TMI-1 ISFSI is a robust and high integrity facility for the spent fuel storage system. The ISFSI is designed to prevent the release of radioactivity in the event of accidents, including environmental phenomena (e.g., earthquake).

TMI-2 is owned by TMI-2 Solutions. The TMI-2 reactor was damaged during an accident in 1979 and is currently defueled and the plant maintained in long-term monitored storage. Monitoring of this facility is performed by Constellation through a service agreement with TMI-2 Solutions.

The TMI site is part of an 814-acre tract consisting of TMI and several adjacent islands, which were purchased by a predecessor. The island, which is situated about 900 feet from the east bank and approximately one mile from the west bank of the Susquehanna River, is elongated parallel to the flow of the river with its longest axis oriented approximately due north and south. The north and south ends of the island have access bridges, which connect the island to State Highway Route 441. The north access bridge is used daily. Route 441 is a two-lane highway, which runs parallel to TMI on the east bank of the Susquehanna River and is more than 2,000 feet from the TMI reactors at the closest point. The EXCLUSION AREA for TMI is a 2,000 -foot radius, and for the purposes of Emergency Planning, the EXCLUSION AREA and the site boundary are considered the same.

A Norfolk Southern one-track line runs adjacent and parallel to Route 441 on the east bank of the river. On the west bank of the river, there is a multi-track Norfolk Southern line at the river's edge about 1.25 miles west of the site and a black top, two lane road that runs parallel to it. There is a one-track railroad spur across the bridge on the north end of the island, which is used for site-related activities.

2.3

SUMMARY

OF EMERGENCY ACTIONS

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

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3.0 REFERENCES

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

3.1. 10 CFR 20, Standards for Protection Against Radiation

3.2. 10 CFR 50.47, "Emergency plans"

3.3. 10 CFR 50.72, "Immediate notification requirements for operating nuclear power reactors"

3.4. 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities"

3.5. 10 CFR 72.13, "Applicability"

3.6. 10 CFR 72.32, "Emergency Plan"

3.7. 10 CFR 72.44, "License conditions"

3.8. 10 CFR 72.75, "Reporting requirements for specific events and conditions"

3.9. 10 CFR 72.106, "Controlled area of an ISFSI or MRS"

3.10. NUREG-1140, Final Report published January 1988, "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees

3.11. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities

3.12. NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (November 1980)

3.13. NUREG-0728, "Report to Congress, NRC Incident Response Plan"

3.14. NUREG-1567, "Standard Review Plan for Spent Fuel Dry Storage Facilities"

3.15. US NRC Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors", Revision 4, July 2003

3.16. NRC Information Notice No. 85-44, "Emergency Communication System Monthly Test"

3.17. NRC Information Notice No. 90-08, "KR-85 Hazards from Decayed Fuel"

3.18. EPA-400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," October 1991 (reprinted May 1992)

3.19. American Nuclear Insurers Bulletin #5B (1981), "Accident Notification Procedures for Liability Insured"

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3.20. Letter from U.S. Nuclear Regulatory Commission to, Bryan C. Hanson (Exelon Generation Company, LLC) "Three Mile Island Nuclear Station, Units 1 and 2 -

Exemptions from Certain Emergency Planning Requirements and Related Safety Evaluation (EPID L-2019-LLE-0016)," dated December 1, 2020 (ML20244A292 and ML20244A293)

3.21. TMI -1 Defueled Safety Analysis Report (DSAR)

3.22. TMI-2 Post Defueled Monitored Storage Safety Analysis Report (PDMS SAR)

3.23. MAGNASTOR Cask System, Certificate of Compliance No. 1031, Final Safety Analysis Report, and Technical Specifications

3.24. NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non -Passive Reactors

3.25. Environmental Protection Agency, Protective Action Guide and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment (March 2013)

3.26. 10 CFR 72.3, Definitions

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4.0 DEFINITIONS AND ABBREVIATIONS

4.1 DEFINITIONS

This section provides definitions that are used in this document. Terms capitalized in the text of the definitions indicate that they are defined elsewhere in this section.

ACCIDENT ASSESSMENT - consists of a variety of actions taken to determine the nature, effects, and severity of an accident.

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

ALERT - See definition in Part II, Section 4.2.

ANNUAL - Frequency of occurrence equal to once per calendar year, January 1 to December 31.

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

BIENNIAL - Frequency of occurrence equal to once per two calendar year periods.

CLASSIFICATION - The comparison of conditions, indications, and reports associated with an off-normal, natural phenomenon, or accident event to the approved emergency classification system to determine the most accurate EMERGENCY ACTION LEVEL. The classification of emergencies is divided into two (2) categories or conditions, in ascending order of severity they are (1) UNUSUAL EVENT and (2) ALERT.

COMMAND AND CONTROL - When in COMMAND AND CONTROL of the event, the designated individual has overall responsibility for the TMI emergency response efforts.

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

DECLARATION - Official determination by the EMERGENCY DIRECTOR that conditions at the ISFSI meet the criteria for an EMERGENCY ACTION LEVEL warranting CLASSIFICATION of an emergency at the UNUSUAL EVENT or ALERT CLASSIFICATION.

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

DESIGN BASIS ACCIDENT (DBA) - Credible accident events as analyzed in the ISFSI storage system Final Safety Analysis Reports (FSARs).

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

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

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

EMERGENCY CLASSIFICATION LEVEL (ECL) - One of a set of names or titles established by the Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to potential or actual effects or consequences, and the resulting response actions. The EMERGENCY CLASSIFICATION LEVELS applicable to TMI, in ascending order of severity, are:

UNUSUAL EVENT ALERT

EMERGENCY DIRECTOR (ED) - The Director of the facility in COMMAND AND CONTROL of the event. The ISFSI Shift Supervisor fills the role of ED throughout an event.

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPS) - Specific procedures describing actions needed to implement the IOEP and describing the methods established to maintain and monitor the IOEP.

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

EMERGENCY RESPONSE ORGANIZATION (ERO) - Organization of personnel who may be called upon during an emergency to perform duties to mitigate accident conditions at TMI.

EMERGENCY RESPONSE PERSONNEL - Personnel who may be called upon during an emergency to perform duties to mitigate accident conditions at TMI.

ESSENTIAL PERSONNEL - TMI-1 personnel that either have assigned emergency response duties, are security personnel, are required for maintaining the safe operation of the ISFSI, or are personnel either identified as essential by the ISS/ED or performing critical tasks under the direction of the ISS/ED.

EXCLUSION AREA/EXCLUSION AREA BOUNDARY (EAB) - The EXCLUSION AREA for TMI is a 2,000-foot radius, and for the purposes of Emergency Planning, the EXCLUSION AREA and the site boundary are considered the same.

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EXERCISE - An event that tests the integrated capability of a major portion of the basic elements existing within emergency preparedness plan and organization.

HOSTAGE - See definition in Addendum 1.

HOSTILE ACTION - See definition in Addendum 1.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) - A complex designed and constructed for the interim storage of spent nuclear fuel, solid reactor-related Greater Than Class C (GTCC) waste, and other radioactive materials associated with spent fuel and reactor-related GTCC waste storage.

INITIATING CONDITION - An event or condition that aligns with the definition of one of the ECLs by virtue of the potential or actual effects or consequences.

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

LEAD AGENCY - Pennsylvania Emergency Management Agency (PEMA)

LOCAL GOVERNMENT AGENCIES - Dauphin and Lancaster Counties

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

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

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

RADIOLOGICALLY CONTROLLED AREA (RCA) - An area within the restricted area posted in accordance with procedure for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.

TOTAL EFFECTIVE DOSE EQUIVALENT (TEDE) - The sum of the effective DOSE equivalent (for external exposure) and the committed effective DOSE equivalent (for internal exposure).

UNUSUAL EVENT (UE) - See definition in Part II, Section 4.1.

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4.2 ACRONYMS

BRP Bureau of Radiation Protection (Pennsylvania)

CFR Code of Federal Regulations

DBA DESIGN BASIS ACCIDENT

DLR Dosimeter of Legal Record

DSAR Defueled Safety Analysis Report

EAB EXCLUSION AREA BOUNDARY

EAL EMERGENCY ACTION LEVEL

ECL EMERGENCY CLASSIFICATION LEVEL

ED EMERGENCY DIRECTOR

EP Emergency Preparedness

ENS Emergency Notification System (NRC)

EPIPS EMERGENCY PLAN IMPLEMENTING PROCEDURES

ERF EMERGENCY RESPONSE FACILITY

ERO EMERGENCY RESPONSE ORGANIZATION

HMC Hershey Medical Center

ISFSI INDEPENDENT SPENT FUEL STORAGE INSTALLATION

ISS ISFSI Shift Supervisor

IOEP ISFSI-Only Emergency Plan

NRC United States Nuclear Regulatory Commission

PA Protected Area

PEMA Pennsylvania Emergency Management Agency

RCA RADIOLOGICALLY CONTROLLED AREA

TEDE TOTAL EFFECTIVE DOSE EQUIVALENT

UE UNUSUAL EVENT

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PART II

1.0 ASSIGNMENT OF RESPONSIBILITY (ORGANIZATION CONTROL)

Planning Standard 50.47(b)(1) (as exempted in Reference 3.20) - Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

1.1 EMERGENCY RESPONSE AND RESPONSIBILITIES

The ISFSI Shift Supervisor (ISS) is at the station 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and is the senior management position at the station during off-hours. This position is responsible for monitoring TMI-1 ISFSI conditions, managing TMI-1 ISFSI activities, and monitoring TMI-2 conditions.

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

The on-shift personnel, as described in Part II, Section 2.1, are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. The on-shift personnel are capable of performing all required response actions, including manning of communications, until individuals arrive to augment shift personnel. The ERO maintains the depth and capability for continuous 24-hour coverage of the emergency response for a protracted period.

1.2 OFFSITE RESPONSE ORGANIZATIONS (ORO)

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

a) Fire protection, b) Rescue operations, c) Ambulance services, d) Medical and hospital services, and e) Law enforcement.

Pennsylvania Emergency Management Agency (PEMA)

PEMA is the LEAD AGENCY and is required to be notified within 30 minutes after declaring an emergency. PEMA is available on a 24 -hour basis to receive emergency communications from

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TMI staff and will implement/coordinate the Commonwealths response as part of the Comprehensive Emergency Management Plan.

County Support Dauphin and Lancaster Counties Emergency Management Agencies will be notified within 30 minutes after declaring an emergency. The Counties will aid in supplying emergency management support (fire, medical support).

Pennsylvania State Police

Local Law Enforcement Agency to provide emergency assistance per the Site Security Plan. The Letter of Agreement is maintained by the Site Security Department).

Londonderry Volunteer Fire Department

Arrangements have been made with the Londonderry Volunteer Fire Department to provide the primary response for fire and emergency medical services(ambulance). The Londonderry Fire Department is approximately 5 m iles from the TMI facility, which allows for timely response from the initial notification.

Hershey Medical Center

Hospital personnel have been trained and hospitals are equipped to handle contaminated, or radiation injured individuals. Specifically, training of medical support personnel at the agreement hospitals will include basic training on the nature of radiological emergencies, diagnosis and treatment, and follow-up medical care. Facility personnel are available to assist medical personnel with DECONTAMINATION, radiation exposure and contamination control.

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2.0 EMERGENCY RESPONSE ORGANIZATION (ERO)

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

2.1 ON-SHIFT POSITIONS

TMI-1 has personnel on-shift at all times that provide the initial response to an event. Members of the on-shift organization are trained on their responsibilities and duties in the event of an emergency and are capable of performing all necessary response actions until the augmentation personnel arrive or the event is terminated. The normal shift staffing assignments include the roles and responsibilities for their emergency response functions.

2.1.1 ISFSI SHIFT SUPERVISOR (ISS)/EMERGENCY DIR ECTOR (ED)

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

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

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

Event CLASSIFICATION and emergency DECLARATION Authorization of radiation exposure in excess of 10 CFR 20 limits

Key delegable responsibilities of the ED include the following:

Notification of OFFSITE agencies (federal, state, and local)

Management of available station resources Initiation of assessment and mitigative/CORRECTIVE ACTIONS

Initiation of ONSITE PROTECTIVE ACTIONS Decision to call for OFFSITE law enforcement, firefighting or ambulance assistance

Augmentation of the EMERGENCY RESPONSE ORGANIZATION as deemed necessary Coordination or suspension of Security activities

Termination of the emergency condition when appropriate Performance of initial radiological assessment

Maintain a record of event activities

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2.2 SECURITY

Station Security is administered by the Security Plan and Security personnel report to the ED when implementing the IOEP. Security personnel assist the ED as directed.

2.3 AUGMENTED POSITION

The ERO is responsible for implementing the actions described in this Plan. The ERO is made up of on-shift personnel (described in Part II, Section 2.1), augmented by the Resource Manager, and Radiological Assessment Personnel (if required). Supplemental personnel are contacted as needed.

2.3.1 RESOURCE MANAGER

The Resource Manager will be in contact with the ED within two (2) hours of CLASSIFICATION.

The Resource Manager will augment the ED by assisting in assessment of the emergency conditions (refer to Table 2-1) and coordinating required resources, including public information interface. The Resource Manager does not need to physically report to TMI to perform their responsibilities. Supplemental personnel shall report at the discretion of the ED and/or the Resource Manager.

2.3.2 RADIOLOGICAL ASSESSMENT PERSONNEL

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

2.4 SUPPLEMENTAL PERSONNEL

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

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2.5 FUNCTIONAL RESPONSIBILITIES

Table 2-1 below lists the functional responsibilities of on-shift and augmented positions that fulfill emergency staffing capabilities.

TABLE 2-1 EMERGENCY RESPONSE ORGANIZATION STAFFING AND RESPONSIBILITY

AUGMENTED FUNCTIONAL AREA LOCATION SHIFT STAFFING OFFSITE

RESPONSE

Assessment of EMERGENCY EMERGENCY Condition RESPONSE DIRECTOR (a) Resource Manager FACILITY EMERGENCY Emergency Direction EMERGENCY and Control RESPONSE DIRECTOR (a) ---

FACILITY EMERGENCY Notifications / EMERGENCY Communications RESPONSE DIRECTOR (a) ---

FACILITY

Radiological Resource Manager ACCIDENT EMERGENCY EMERGENCY (b)

ASSESSMENT and RESPONSE DIRECTOR (a)

PROTECTIVE FACILITY / On Scene RP Support (c)

ACTIONS EMERGENCY Resource Manager CORRECTIVE RESPONSE EMERGENCY (b) / Supplemental /

ACTIONS FACILITY / On Scene DIRECTOR (a) Support Personnel

Per Fire Protection OFFSITE Response Firefighting On Scene Program Plan Organization Rescue and First Aid OFFSITE Response Treatment On Scene (d) Organization

Security Per Security Plan Per Security Plan ---

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

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

(c) For a declared emergency involving radiological consequences (E-HU1), a minimum of one person trained in radiological monitoring and assessment will report to the TMI-1 ISFSI within four (4) hours of the emergency DECLARATION.

(d) Provided by on-shift personnel who may be assigned other functions.

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3.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES

Planning Standard 50.47(b)(3) (as exempted in Reference 3.20) - Arrangements for requesting and effectively using assistance resources have been made, and other organizations capable of augmenting the planned response have been identified.

3.1 LOCAL SERVICES

Arrangements have been made for the extension of the ERO's capability to address emergencies.

Arrangements are in place through letters of agreement for ambulance services, treatment of contaminated and injured patients, fire support services, and law enforcement response as requested by the facility Evidence of agreements with participating local services is listed in Appendix C.

3.2 FEDERAL GOVERNMENT SUPPORT

Resources of federal agencies appropriate to an emergency condition are made available in accordance with the National Response Framework. This plan and the resources behind it are activated through the facility notification of the NRC.

3.3 ADDITIONAL SUPPORT

Dependent upon the emergency condition and response needs, the TMI ERO can be augmented by personnel and equipment support from the remainder of the Constellation organization. This support capability is outlined in the EMERGENCY PLAN IMPLEMENTING PROCEDURES referenced in Appendix B.

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4.0 EMERGENCY CLASSIFICATION SYSTEM

Planning Standard 50.47(b)(4) (as exempted in Reference 3.20) - A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee.

TMI utilizes NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors as its basis for classifying emergencies. The CLASSIFICATION system referenced in NEI 99-01, Rev. 6 has been endorsed by the NRC and offers a standard method for classifying emergencies. Addendum 1 provides the site and ISFSI Only EALs.

This Plan addresses two (2) CLASSIFICATIONS of emergencies (UNUSUAL EVENT and ALERT), which represent a hierarchy of emergencies based on potential accidents that could occur at TMI. Once indications are available that an EAL is met, the event is assessed and classified, and the corresponding EMERGENCY CLASSIFICATION LEVEL is promptly declared as soon as possible.

4.1 UNUSUAL EVENT

EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INDICATE A POTENTIAL DEGRADATION OF THE LEVEL OF SAFETY AT TMI OR INDICATE A SECURITY THREAT TO FACILITY PROTECTION HAS BEEN INITIATED. NO RELEASES OF RADIOACTIVE MATERIAL REQUIRING OFFSITE RESPONSE OR MONITORING ARE EXPECTED. STATE AND LOCAL GOVERNMENT AGENCIES, AND THE NRC ARE NOTIFIED OF AN UNUSUAL EVENT.

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

4.2 ALERT

EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVE AN ACTUAL OR POTENTIAL SUBSTANTIAL DEGRADATION OF THE LEVEL OF SAFETY AT TMI OR A SECURITY EVENT THAT INVOLVES PROBABLE LIFE-THREATENING RISK TO SITE PERSONNEL OR DAMAGE TO ISFSI EQUIPMENT BECAUSE OF A HOSTILE ACTION. ANY RELEASES ARE EXPECTED TO BE LIMITED TO SMALL FRACTIONS OF THE EPA PAG EXPOSURE LEVELS.

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

On-shift staffing will be supplemented by the augmented ERO at the ALERT Level.

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4.3 EMERGENCY ACTION LEVELS AND POSTULATED ACCIDENTS

Both EMERGENCY CLASSIFICATION LEVELS are characterized by EALs consisting of specific instrument readings and/or observations which are used to tell the TMI-1 ISS that an INITIATING CONDITION has been met. These EALs are used to assure that the initial CLASSIFICATION of emergencies can be accomplished rapidly, allowing for the prompt identification of the nature of mitigating activities needed.

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

• Hazards and Other Conditions

• ISFSI Malfunction

Specific guidance for classifying emergencies is found in EPIPs and Addendum 1, TMI ISFSI Only Emergency Action Levels and Technical Bases.

EALs shall be reviewed with State and LOCAL GOVERNMENT AGENCIES on an ANNUAL basis.

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5.0 NOTIFICATION METHODS AND PROCEDURES

Planning Standard 50.47(b)(5) (as exempted in Reference 3.20) - Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow-up messages to response organizations has been established.

5.1 NOTIFICATION AND MOBILIZATION OF TMI EMERGENCY RESPONSE PERSONNEL

The EPIPs provide direction for alerting and notifying ONSITE EMERGENCY RESPONSE PERSONNEL of the initial CLASSIFICATION or any escalation of an emergency by verbal announcement over portable radios. Each emergency CLASSIFICATION may result in augmentation personnel being notified to respond. EPIPs provide direction for augmentation should it be deemed appropriate.

5.2 BASES FOR NOTIFICATION OF OFFSITE AGENCIES

The notification of personnel and EMERGENCY RESPONSE ORGANIZATIONS is commensurate with the hazard posed by the emergency. The EMERGENCY CLASSIFICATION SYSTEM described in Part II, Section 4.0 is the primary bases for notification and has been mutually agreed upon by applicable state and federal response organizations.

The ED is responsible for identifying the appropriate emergency CLASSIFICATION, declaring the emergency and initiating emergency notifications.

Notification to the LEAD AGENCY and LOCAL GOVERNMENT AGENCIES is required within 30 minutes of emergency DECLARATION, escalation, or change in radiological release status.

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

PEMA Dauphin County Lancaster County

5.3 EMERGENCY MESSAGES

Notification of an emergency is provided verbally to the State and LOCAL GOVERNMENT providing them with applicable information utilizing an established message format that describes the accident status. The content of the initial notification and follow-up message form has been established in conjunction with the Commonwealth of Pennsylvania and includes the date and time of the incident, the class of emergency, and the EAL. Appropriate identification of the caller and time of the notification are also provided.

Follow-up messages will be provided as directed by EPIPs.

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5.4 NRC EVENT NOTIFICATION

The NRC Operations Center will be notified immediately following notification of the appropriate state and LOCAL GOVERNMENT AGENCIES, and not later than 60 minutes after the time of initial emergency DECLARATION, escalation, termination or entry into the recovery phase via the Event Notification System (ENS). Notification to the NRC is the responsibility of the ED.

5.5 SUPPORT ORGANIZATIONS

Medical, local law enforcement agency, and firefighting support services are notified for assistance via the public 9-1-1 system, using the commercial telephone, as the situation dictates.

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

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6.0 EMERGENCY COMMUNICATIONS

Planning Standard 50.47(b)(6) (as exempted in Reference 3.20) - Provisions exist for prompt communications among principal response organizations to emergency personnel.

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

TABLE 6-1 Communication Systems

Communication System Testing Frequency

Commercial telephone system Frequent Use

Portable radios Frequent Use

NRC FTS Network (ENS) Monthly

Mobile communications devices (cellular or satellite phones) Quarterly*

• Performance of drill requirements specified in Part II, Section 14, satisfies the testing frequency

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7.0 PUBLIC INFORMATION

Planning Standard 50.47(b)(7) (as exempted in Reference 3.20) - The principal points of contact with the news media for dissemination of information during an emergency are established in advance, and procedures for coordinated dissemination of information to the public are established.

As the principle point of contact for the dissemination of information during an event at the TMI, Constellation Corporate Communications Department personnel will be notified of a declared emergency. Corporate Communications Department will monitor media activity and coordinate with senior management disseminating public information per communication protocols. As necessary, news conference(s) can be conducted at the site or other coordinated location.

Corporate Communications Department personnel, or senior TMI management will represent the facility as the spokesperson. If an event occurs at the TMI, information will be disseminated to the public in a timely manner.

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

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8.0 EMERGENCY FACILITY AND EQUIPMENT

Planning Standard 50.47(b)(8) - Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

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

8.1 EMERGENCY RESPONSE FACILITY

EMERGENCY RESPONSE FACILITY (ERF) is staffed in accordance with Part II, Section 2.0, and provides availability of communications systems as specified in Part II, Section 6.0. The ERF is open on a continuous basis. There is no activation needed.

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

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

8.2 EMERGENCY EQUIPMENT

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

8.2.1 PORTABLE RADIATION AND CONTAMINATION MONITORING INSTRUMENTS Portable radiation and contamination monitoring instruments and sampling equipment normally utilized and maintained by the radiation protection personnel and are available for emergency use.

8.2.2 COMMUNICATION SYSTEMS

Communication systems are identified and tested as described in Part II, Section 6.

8.2.3 EMERGENCY SUPPLIES

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

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8.2.4 FIRST AID FACILITIES

First aid supplies and equipment are located at the TMI ERF. Qualified personnel are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day to provide medical treatment as referenced in Part II, Section 12.

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9.0 ACCIDENT ASSESSMENT

Planning Standard 50.47(b)(9) (as exempted in Reference 3.20) - Adequate methods, systems, and equipment for assessing and monitoring actual or potential consequences of a radiological emergency condition are in use.

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

The EALs identify the parameter value to determine the emergen cy condition. CLASSIFICATION of events is performed by the ED in accordance with the EAL sche me.

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

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

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10.0 PROTECTIVE ACTIONS

Planning Standard 50.47(b)(10) (as exempted in Reference 3.20) - A range of protective actions has been developed for emergency workers and the publi c.

PROTECTIVE ACTIONS for O NSITE personnel are provided for their health and safety.

Implementation guidelines for O NSITE PROTECTIVE ACTIONS are provid ed in EPIPs.

Additionally, the EPIPs provide for a range of PROTECTIVE ACTIONS (e.g. re location of personnel and personnel take cov er) to protect ONSITE personnel during HOSTILE AC TIONS.

10.1 SITE EGRESS CONTROL METHODS

All non-ESSENTIAL PERSONNEL are evacuated from the facility at the discretion of the ED. In the event of a suspected radiological release, personnel are monitored for radioactive contamination prior to leaving the facility. Portable radiation survey meters are available to monitor for potential contamination.

10.2 FIRE FIGHTING

Strategies have been developed for firefighting and fire protection in specific critical areas of the facility. The Fire Protection Program describes the fire protection organization and individual responsibilities.

10.3 ACCOUNTABILITY

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

ACCOUNTABILITY of all personnel inside the ISFSI PROTECTED AREA (PA) should be accomplished within 60 m inutes of the ACCOUNTABILITY announcement (provided ACCOUNTABILITY is still determined to be necessary). If personnel are unaccounted for, teams shall be dispatched to locate the personnel. ACCOUNTABILITY may be modified or suspended if the safety of personnel may be jeopardized by a Security event or other event hazardous to personnel.

Non-ESSENTIAL PERSONNEL located outside of the ISFSI PA but within the SITE BOUNDARY will be directed to report to an assembly area or exit the site, as appropriate.

The ED is responsible for controlling access to the site when the IOEP is activated.

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11.0 RADIOLOGICAL EXPOSURE CONTROL

Planning Standard 50.47(b)(11) - Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

11.1 EXPOSURE GUIDELINES

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

Means for controlling radiological exposures in an emergency are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesavi ng Activity Protective Action Guides in EPA-400-R92-001 (EPA-400).

During an emergency, DOSES above normal occupational radiation exposure limits may be authorized by the ED (non-delegable responsibility) for activities such as saving a life, preservation of valuable equipment or controlling exposure. Table 11-1 contains the guidelines for emergency exposure criteria, which is consistent with the EPA-400 Table 2-2, Guidance on Dose Limits for Workers Performing Emergency Services.

11.2 RADIATION PROTECTION

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

11.3 ACCESS CONTROL

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

11.4 PERSONNEL EXPOSURE MONITORING

Personal dosimeters are utilized to monitor the exposure of personnel during normal or emergency conditions. Emergency workers will receive Dosimeter of Legal Record (DLR) badges and personal self-reading dosimeters capable of measuring expected exposures on a real time basis. Adequate supplies of dosimeters are maintained for use during an emergency. Procedures

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

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

11.5 CONTAMINATION CONTROL

Various contamination control measures are utilized. These include access control measures and means for the DECONTAMINATION of personnel, areas, and equipment. These activities are addressed in facility procedures and are briefly described below.

All personnel are monitored for radioactive contamination prior to leaving the RCA. During normal or emergency conditions, contamination should be removed from any part of a person's body prior to their leaving the RCA. All personnel DECONTAMINATION, even during an emergency, will be performed under the supervision of personnel trained in radiological monitoring and assessment and in accordance with established procedures.

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

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

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Table 11-1 Emergency Worker Guidelines

Guideline DOSE Limit Activity Condition (Rem TEDE) 5 All Personnel should be kept within normal 10 CFR 20 limits during bona fide emergencies, except as authorized for activities as indicated below.

10 Protecting valuable property Lower DOSE not practicable.

25 Lifesaving or protection of Lower DOSE not practicable.

large populations

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

Limit DOSE to the lens of the eye to 3 times the above values and DOSES to any other organ (including skin and body extremities) to 10 times the above values.

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12.0 MEDICAL AND HEALTH SUPPORT

Planning Standard 50.47(b)(12) - Arrangements are made for medical services for contaminated injured individuals.

Medical assistance is available ONSITE and OFFSITE for treatment of TMI personnel. Various means of transportation are available to transport individuals for radiological and non-radiological injuries.

The individuals and organizations providing emergency medical assistance as identified in this section either have the capability for evaluation of radiation exposure and uptake or they are provided this capability from Constellation in the form of personnel and/or equipment.

Constellation assures that persons providing these services are adequately prepared to handle contaminated individuals through detailed training classes, drills and EXERCISES. Letters of Agreement with OFFSITE organizations and individuals for medical support are listed in Appendix C.

12.1 ONSITE FIRST AID

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

12.2 MEDICAL TRANSPORTATION

Transportation of injured personnel is available via local emergency medical services, TMI vehicles, or private vehicles. When personnel are transported to the Hershey Medical Center (HMC) while in a contaminated condition, a person trained in radiological monitoring will be dispatched to monitor and maintain radiological controls.

12.3 OFFSITE MEDICAL SUPPORT

HMC have medical facilities capable of handling various types of injuries. HMC are capable of treating patients with injuries of a non-radiological or radiological nature. When personnel are transported to OFFSITE medical facility while in a contaminated condition, a person trained in radiological monitoring will be dispatched to monitor and maintain radiological controls.

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13.0 EMERGENCY TERMINATION AND RECOVERY

Planning Standard 50.47(b)(13) - General plans for recovery and reentry are developed.

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

13.1 EMERGENCY TERMINATION AND NOTIFICATION

Termination of an emergency status is the responsibility of the ED. The ED is also responsible for providing notification of the emergency termination and initiation of recovery operations to the NRC, State and LOCAL GOVERNMENT AGENCIES, the TMI ERO and other organizations that may be providing ONSITE support.

13.2 RECOVERY OPERATIONS

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

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

The ISFSI recovery will be terminated by the TMI senior management position after the ISFSI has been returned to a stable condition.

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14.0 EXERCISE AND DRILLS

Planning Standard 50.47(b)(14) - Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

14.1 EXERCISE AND DRILL

BIENNIAL EXERCISES shall be conducted to test the timing and content of implementing procedures and methods; to test emergency equipment and communication networks; and to ensure that emergency personn el are familiar with their duties. TMI offers the following organizations the opportunity to participate to the extent assistance would be expected during an emergency DECLARATION; however, participation is not required:

1. Commonwealth of Pennsylvania

2. Local Hospitals

3. Local Fire Departments

4. Law Enforcement

5. Ambulance Service

At least one drill involving a combination of some of the principal functional areas of emergency response shall be conducted in the interval between BIENNIAL EXERCISES.

Communication checks with OFFSITE agencies, fire drills, medical drills, radiological monitoring drills and health physics drills are performed as indicated in the following sections.

EXERCISE and drill scenarios are developed to provide reasonable assurance that anticipatory responses will not result from preconditioning of participants. EXERCISE and drill scenarios, as appropriate, emphasize coordina tion among ONSITE and OFFSITE response organizations. The scenarios for use in EXERCISES and drills include, at a minimum, the following:

• Basic objective(s) and appropriate evaluation criteria,

• Date(s), time period, place(s), and participating organizations,

• Simulation lists,

• Time schedule of real and simulated initiating events,

• Narrative summary describing the conduct of the EXERCISES or drills to include such things as simulated casualties, OFFSITE fire department assistance, search and rescue of personnel, use of protective clothing, and

• List of controllers and participants.

In accordance with applicable portions to Section IV.G to NSIR/DPR-ISG-01, the scenario will vary from year to year.

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The scenarios are designed to allow free play in exercising the decision-making process associated with such emergency response actions as exposure control, emergency CLASSIFICATION, and the ERO and additional staff augmentation process.

Starting times and pre-notification for EXERCISES are coordinated with and agreed upon by all participating organizations.

14.2 EQUIPMENT AND PROFICIENCY DRILLS

Drills are conducted to provide supervised instruction, training and practice opportunities for ERO members. Drills may be performed as part of the BIENNIAL EXERCISE, INTEGRATED DRILL or as an independent drill. A drill may be a component of an EXERCISE. Drills are supervised and evaluated by qualified personnel. Drills are conducted, in addition to the EXERCISE at the frequencies indicated below:

14.2.1 COMMUNICATION DRILLS

A communications drill with State and LOCAL GOVERNMENT AGENCIES is conducted ANNUALLY. A communications drill with NRC Headquarters is conducted ANNUALLY.

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

14.2.2 FIRE DRILLS

Fire drills are conducted in accordance with TMI Fire Protection Program.

14.2.3 SECURITY DRILLS

Security drills will be conducted in accordance with the TMI Security Plan.

14.2.4 MEDICAL EMERGENCY DRILLS

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

14.2.5 RADIATION PROTECTION DRILLS

A Radiation Protection drill to demonstrate radiation monitoring personnel to demonstrate ability to perform radiological survey and assessment will be conducted ANNUALLY.

14.2.6 AUGMENTATION DRILLS

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

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14.2.7 CRITIQUE AND EVALUATION

A critique will be performed as soon as practicable after drills and EXERCISES to evaluate the ability of the participating organizations to respond as indicated in this IOEP. The ability of EMERGENCY RESPONSE PERSONNEL to self-evaluate weaknesses and identify areas for improvement is the key to successful EXERCISE / drill conduct.

EXERCISE and drill objectives are evaluated against measurable demonstration criteria.

Following the conclusion of each EXERCISE or drill, a critique, including participants and evaluators, is conducted to evaluate the ability of the ERO to implement the IOEP and its implementing procedures.

A formal evaluation in the form of a written critique report is prepared following an EXERCISE or drill involving the evaluation of designated objectives. The report evaluates and documents the ability of the ERO to respond to a simulated emergency situation. The report will also contain reference to corrective action program documents and recommendations. The Emergency Preparedness Specialist is responsible for ensuring that items identified in the critique are correctly dispositioned, appropriate assignment of responsibility is made, and that corrective actions are implemented in accordance with the corrective action program.

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15.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING

Planning Standard 50.47(b)(15) - Radiological emergency response training is provided to those who may be called on to assist in an emergency.

15.1 EMERGENCY RESPONSE PERSONNEL TRAINING

Requirements for EMERGENCY PREPAREDNESS training are specified in the EMERGENCY PREPAREDNESS Training Program. This program identifies the level and the depth to which individuals are to be trained.

15.2 EMERGENCY PREPAREDNESS TRAINING PROGRAM

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

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

15.2.1 ISS/EMERGENCY DIRECTORS AND RESOURCE MANAGERS

Trained such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum initially and on an ANNUAL basis.

• Emergency CLASSIFICATION

• State and LOCAL GOVERNMENT AGENCIES, and NRC notifications

• ERO activation

• DOSE RATE meter operation

• Radiological release assessment

• Emergency exposure control

• PROTECTIVE ACTIONS for ONSITE personnel

• ISFSI DBAs and Accident Assessment

• Review of applicable drill identified deficiencies and Human Performance Concerns

15.2.2 RADIOLOGICAL ASSESSMENT PERSONNEL

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

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15.2.3 MEDICAL SUPPORT PERSONNEL

HMC personnel are invited to receive training, as outlined in Part II, Section 15.3.

15.2.4 SECURITY AND LAW ENFORCEMENT PERSONNEL

Station Security personnel are trained in accordance with the Security Plan. Local Law Enforcement Agency support personnel are invited to receive training, as outlined in Part II, Section 15.3.

15.2.5 FIRST AID AND RESCUE TEAMS

Selected individuals assigned on-shift ERO responsibility receive first aid training equivalent to Red Cross Adult First Aid/CPR/AED). Station personnel are trained to report any injury or medical emergency to the ISS, then provide first aid treatment within their level of competency.

Responding support personnel are invited to receive training as outlined in Part II, Section 15.3.

15.2.6 OTHER PERSONNEL

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

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

15.3 SUPPORT ORGANIZATIONS TRAINING

Annual training is made available to non-TMI support organizations, that may be called upon to provide assistance in the event of an emergency (e.g. firefighting, medical services, transport of injured, etc.).

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

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16.0 MAINTAINING EMERGENCY PREPAREDNESS

Planning Standard 50.47(b)(16) - Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

16.1 EMERGENCY PREPAREDNESS RESPONSIBILITIES

16.1.1 ISFSI SENIOR MANAGEMENT POSITION

Constellation is responsible for the maintenance of TMI EMERGENCY PREPAREDNESS Program. The issuance and control of this Plan and the activities associated with EMERGENCY PREPAREDNESS at TMI shall be the overall responsibility of the TMI-1 ISFSI senior management position.

16.1.2 EMERGENCY PREPAREDNESS SPECIALIST POSITION

The overall Emergency Plan is ma intained by Corporate Emergency Preparedness.

The specific responsibilities include, but are not limited to, the following:

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

• Overseeing the EMERGENCY PREPAREDNESS Training Program and ensuring that proper records are maintained to document training of the ERO, and ensuring that the ERO is notified of updates to the IOEP or EPIPs

• Overseeing and documenting the EMERGENCY PREPAREDNESS drill and EXERCISE Program

• Documenting and maintaining the EMERGENCY PREPAREDNESS facilities and equipment

• Documenting and maintaining the EMERGENCY PREPAREDNESS interfaces with OFFSITE agencies by (a) ensuring that all the Letters and Memoranda of Agreement with support organizations are reviewed ANNUALLY and updated as needed; and (b) ensuring that the OFFSITE Response Organizations are notified of updates to the IOEP

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

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

Individuals assigned the duties of maintaining the IOEP maintain an adequate knowledge of regulations, planning techniques, and the latest applications of emergency equipment and supplies. All recommendations for changes to this document or associated implementing procedures are reviewed in accordance with 10 CFR 50.54(q) and 72.44(f), by individuals trained in performing such evaluations.

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16.2 REVIEW AND UPDATING OF THE IOEP AND SUPPORTING PROCEDURES

It is important that a state of EMERGENCY PREPAREDNESS be maintained at all times. The IOEP is reviewed ANNUALLY and updated, as needed. The ANNUAL IOEP review/update includes required changes identified during 10 CFR 50.54(t) reviews, assessments, training, drills, and EXERCISES.

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

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

16.2.1 EALS STATE AND LOCAL GOVERNMENT AGENCY REVIEW

The EALs shall be made available for review with State and LOCAL GOVERNMENT AGENCIES ANNUALLY.

16.2.2 EMERGENCY RESPONSE DIRECTORY

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

16.2.3 LETTERS AND MEMORANDA OF AGREEMENT

Every two years, each Letter or Memorandum of Agreement with support organizations is reviewed and verified current in order to assure the availability of assistance from each supporting organization.

16.3 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT AND SUPPLIES

Periodic inventory, testing, and calibration of emergency equipment and supplies are conducted in accordance with EPIPs. This equipment includes, but is not limited to:

Portable radiation monitoring equipment

Emergency medical response equipment

Dosimeters

Portable radios

Emergency equipment and instrumentation shall be inventoried, inspected and operationally checked periodically as indicated by the EPIPs and after each use. Sufficient reserves of equipment and instrumentation are stocked to replace emergency equipment and instrumentation removed from service for calibration and/or repair.

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PART III

APPENDIX A

CROSS REFERENCE IOEP SECTION TO PLANNING STANDARDS / REQUIREMENTS / CRITERIA AND PROCEDURES

NUREG-IOEP Planning Planning 0654, Section Part II Standard Requirement II Evaluation Procedure Section (10 CFR 50.47) (Appendix E.IV)** Criteria

1.0 (b)(1)* A.1*, 2, 4*, 7* A EP-TM-112 2.0 (b)(2) A.1*, 2, 4*; C.1* B EP-TM-112 3.0 (b)(3)* A.6, 7* C EP-TM-112 B.1*, 2; C.1*, 2* EP-TM-1002 Add. 1 4.0 (b)(4)* D EP-TM-111

A.6, 7*; C.1*; EP-TM-114 5.0 (b)(5)* D.1*,3*; E* E

6.0 (b)(6)* C.1*; D.1*, 3*; E* F EP-AA-121, EP-AA-124 7.0 (b)(7)* Exempted* G EP-TM-112 8.0 (b)(8) E*; G H EP-AA-121, EP-AA-124 A.4*; B.1*; C.2*; EP-AA-110 9.0 (b)(9)* E* I

10.0 (b)(10)* C.1*; E* J EP-TM-113 11.0 (b)(11) E* K EP-TM-113 12.0 (b)(12) A.6, 7*; E* L EP-TM-112 13.0 (b)(13) H M EP-TM-115 14.0 (b)(14) E9*; F* N EP-TM-122 15.0 (b)(15) F* O TQ-TM-113 16.0 (b)(16) G P EP-AA-120, EP-AA-124

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

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APPENDIX B

INDEX OF EMERGENCY PLAN IMPLEMENTING PROCEDURES

Document Document Title

INDEPENDENT SPENT FUEL STORAGE INSTALLATION EP-TM-1002 Addendum 1 (ISFSI) ONLY EMERGENCY ACTION LEVELS AND TECHNICAL BASES EP-AA-110 ASSESSMENT OF EMERGENCIES EP-TM-111 EMERGENCY CLASSIFICATION EMERGENCY RESPONSE ORGANIZATION EP-TM-112 ACTIVATION AND OPERATION

EP-TM-113 PERSONNEL PROTECTIVE ACTIONS EP-TM-114 NOTIFICATIONS EP-TM-115 TERMINATION AND RECOVERY EP-AA-120 EMERGENCY PLAN ADMINISTRATION EMERGENCY RESPONSE FACILITIES AND EP-AA-121 EQUIPMENT READINESS

EP-TM-122 DRILLS AND EXERCISE PROGRAM EP-AA-123 COMPUTER PROGRAMS EP-AA-124 INVENTORIES AND SURVEILLANCES TRAINING AND QUALIFICATION FOR TQ-TM-113 DECOMMISSIONING THREE MILE ISLAND ERO

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APPENDIX C

LETTERS of AGREEMENT

Letters with Corporate Constellation:

Organization/Agreement Type

Department of Energy (DOE) Radiation Emergency Assistance Center/Training Site, REAC/TS (Letter on File)

Medical Consultant

Environmental, Inc. (P.O.)

Radiological Environmental Monitoring

Landauer, Inc. (P.O.)

Emergency Dosimetry

Teledyne Brown Engineering (P.O.)

Bioassay Analysis/Radiochemical Analysis

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Three Mile Island Specific Letters of Agreement

The following is a listing of letters of agreement, memorandum of understanding, and contracts specific to emergency response activities in support of the TMI Station.

NOTE: While this list reflects letters of agreement currently in effect, it is possible that the list may change for a number of reasons. The EP Specialist will consider the impact that a loss of an agency will have on the emergency response process.

1. Medical Support Organizations and Personnel

• Londonderry Volunteer Fire Company (fire and ambulance service)

• South Central Emergency Medical Services Inc. (ambulance)

• Hershey Medical Center

2. Firefighting Organizations

NOTE: These are supplemented by Mutual Aid agreements with other firefighting as organizations.

• Bainbridge Volunteer Fire Company (Lancaster Co.)

• Middletown Volunteer Fire Department

• Londonderry Volunteer Fire Company (Primary)

• Elizabethtown Fire Department

• Lower Swatara Volunteer Fire Department

• Susquehanna Area Regional Airport Authority (SARAA)

3. Law Enforcement Agencies

• Pennsylvania State Police (letter of agreement maintained by Security)

4. Local County Response Agencies

• Pennsylvania Emergency Manage ment Agency Memorandum of Under standing (MOU)

(letter on file)

NOTE: Documentation of agree ment for, Dauphin, and Lancaster, counties are contained as part of the agreement with PEMA.

5. Other Agencies

• Norfolk Southern Railway Company

• Harrisburg Area Community College

• Londonderry Volunteer Fire Department (staging area)

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Attachment 3

Emergency Plan Revision

EP-TM-1002, Addendum 1, R evision 0, "Constellation Three Mile Isla nd ISFSI Only Emergency Action Levels and T echnical Bases"

EP-TM-1002 Addendum 1 Revision 0

CONSTELLATION

THREE MILE ISLAND NUCLEAR STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) ONLY

EMERGENCY ACTION LEVELS AND TECHNICAL BASES Three Mile Island IOEP Constellation

REVISION HISTORY

Rev. 0, AUGUST 2022

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TABLE OF CONTENTS

PURPOSE............................................................................................................ 1

DISCUSSION....................................................................................................... 1

2.1 Permanently Defueled Facility.............................................................................. 1

2.2 Independent Spent Fuel Storage Installation........................................................ 2

KEY TERMINOLOGY USED................................................................................ 2

3.1 Emergency Classification Levels (ECLs).............................................................. 2

3.2 Initiating Condition (IC)......................................................................................... 3

3.3 Emergency Action Level (EAL)............................................................................. 3

GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS............................ 3

4.1 General Considerations........................................................................................ 3

4.2 Classification Methodology................................................................................... 4

4.3 Classification of Multiple Events and Conditions.................................................. 4

4.4 Classification of Imminent Conditions................................................................... 4

4.5 Emergency Classification Level Upgrading and Termination................................ 5

4.6 Classification of Short-Lived Events..................................................................... 5

4.7 Classification of Transient Conditions................................................................... 5

4.8 After-the-Fact Discovery of an Emergency Event or Condition............................ 5

4.9 Retraction of an Emergency Declaration.............................................................. 5

4.10Response to a TMI-2 Emergency......................................................................... 5

REFERENCES..................................................................................................... 7

5.1 Developmental...................................................................................................... 7

5.2 Implementing........................................................................................................ 7

5.3 Commitments....................................................................................................... 7

ACRONYMS & DEFINITIONS.............................................................................. 8

6.1 Acronyms............................................................................................................. 8

6.2 Definitions............................................................................................................. 8

ATTACHMENTS................................................................................................... 9

Attachment 1: EAL Matrices........................................................................................ 9

Attachment 2: EAL Bases............................................................................................ 9

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PURPOSE

This document provides the detailed set of EMERGENCY ACTION LEVELS (EALs) applicable to the Three Mile Island Nuclear Station (TMI) and the associated Technical Bases using the EAL development methodology found in NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (NEI 99-01, Rev. 6). As a permanently defueled facility, TMI will use the Recognition Category "PD" (Permanently Defueled) to provide a site-specific emergency classification scheme including a set of Initiating Conditions (ICs) and EALs associated with the permanently defueled condition and a Recognition Category "E" IC/EAL for the INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI). Permanently defueled station ICs and EALs are addressed in Appendix C of NEI 99-01, Rev. 6. All recommendations for changes to this document or associated implementing procedures are reviewed in accordance with 10 CFR 50.54(q).

This document should be used to facilitate review of the TMI EALs, provide historical documentation for future reference, and serve as a resource for training. Individuals responsible for the classification of events will refer to the ICs and EALs contained in the matrix of this document. They may use the information in the associated "Basis" and "Notes" sections as a reference in support of EAL interpretation. An EAL matrix may be provided as a user aid.

Emergency classifications are to be made as soon as conditions are present and recognizable for the classification in accordance with the applicable EALs; but within 30 minutes in all cases after the availability of indications to operators that an EAL threshold has been reached. Use of this document for assistance is not intended to delay the emergency classification.

DISCUSSION

2.1 Permanently Defueled Facility

NEI 99-01, Appendix C, Rev. 6, provides guidance for an emergency classification scheme applicable to a permanently defueled facility. This is a facility that generated spent fuel under a 10 CFR Part 50 license, has permanently ceased operations, has removed all irradiated fuel from the Spent Fuel Pool (SFP), and will store the spent fuel onsite for an extended period of time in an ISFSI. The EMERGENCY CLASSIFICATION LEVELS applicable to permanently defueled facility are consistent with the requirements of 10 CFR Part 50 and NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1" (NUREG-0654).

In order to relax the emergency plan requirements applicable to an operating station, the owner of a permanently defueled station must demonstrate that no credible event can result in a significant radiological release beyond the site boundary. Exelon has confirmed that the source term and motive force available in the permanently defueled condition are insufficient to warrant classifications of a Site Area Emergency or General Emergency.

Therefore, the generic ICs and EALs applicable to a permanently defueled facility may only result in either a Notification of UNUSUAL EVENT (UNUSUAL EVENT) or ALERT classification.

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2.2 Independent Spent Fuel Storage Installation

Selected guidance in NEI 99-01, Rev. 6, is applicable to licensees electing to use their 10 CFR Part 50 emergency plan to fulfill the requirements of 10 CFR 72.32 for a stand-alone INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI). The EMERGENCY CLASSIFICATION LEVELS applicable to an ISFSI are consistent with the requirements of 10 CFR Part 50. The initiating conditions germane to a 10 CFR 72.32 emergency plan (as described in NUREG-1567, "Spent Fuel Dry Storage Facilities") are subsumed within the classification scheme for a 10 CFR 50.47 emergency plan.

The analysis of potential onsite and offsite consequences of accidental releases associated with the operation of an ISFSI is contained in NUREG-1140, "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees" (NUREG-1140). NUREG-1140 concluded that the postulated worst-case accident involving an ISFSI has insignificant consequences to public health and safety.

This evaluation shows that the maximum offsite dose to a member of the public due to an accidental release of radioactive materials would not exceed 1 Rem Total Effective Dose Equivalent (TEDE).

Regarding the above information, the expectations for an offsite response to an ALERT classified under a 10 CFR 72.32 emergency plan are generally consistent with those for an UNUSUAL EVENT in a 10 CFR 50.47 emergency plan (e.g., to provide assistance if requested). Also, the licensee's Emergency Response Organization (ERO) required for 10 CFR 72.32 emergency plan is different from that prescribed for a 10 CFR 50.47 emergency plan (e.g., there is no emergency technical support function required).

KEY TERMINOLOGY USED

There are several key terms that appear throughout the NEI 99-01, Rev. 6, methodology.

These terms are introduced in this section to support understanding of subsequent material.

3.1 Emergency Classification Levels (ECLs)

One of a set of names or titles established by the U.S. Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The ECLs that remain applicable to TMI, in ascending order of severity, are:

3.1.1 UNUSUAL EVENT (UE)

EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INDICATE A POTENTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE FACILITY OR INDICATE A SECURITY THREAT TO FACILITY PROTECTION HAS BEEN INITIATED. NO RELEASES OF RADIOACTIVE MATERIAL REQUIRING OFFSITE RESPONSE OR MONITORING ARE EXPECTED UNLESS FURTHER DEGRADATION OF SAFETY SYSTEMS OCCURS.

Purpose:

The purpose of this classification is to assure that the first step in future response has been carried out, to bring the operations staff to a state of readiness, and to provide systematic handling of UNUSUAL EVENT information and decision-making.

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3.1.2 ALERT

EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVE AN ACTUAL OR POTENTIAL SUBSTANT IAL DEGRADATION OF THE LEVEL OF SAFETY OF THE FACILITY OR A SECURITY EVENT THAT INVOLVES PROBABLE LIFE-THREATENING RISK TO SITE PERSONNEL OR DAMAGE TO SITE EQUIPMENT BECAUSE OF A HOSTILE ACTION. ANY RELEASES ARE EXPECTED TO BE LIMITED TO SMALL FRACTIONS OF THE ENVIRONMENTAL PROTECTION AGENCY (EPA) PROTECTIVE ACTION GUIDES (PAG) EXPOSURE LEVELS.

Purpose:

The purpose of this classification is to assure that emergency personnel are readily available to respond or to perform confirmatory radiation monitoring, if deemed necessary, and provide offsite authorities current information on facility status and parameters.

3.2 Initiating Condition (IC)

An event or condition that aligns with the definition of one of the two ECLs by virtue of the potential or actual effects or consequences.

Discussion: An IC describes an event or condition, the severity or consequences of which meets the definition of an ECL. An IC can be expressed as a continuous, measurable parameter (e.g., radiation monitor readings) or an event (e.g., a SECURITY CONDITION).

NUREG-0654 states that the ICs form the basis for establishment by a licensee of the specific facility instrumentation readings (as applicable) which, if exceeded, would initiate the emergency classification. Thus, it is the specific instrument readings that would be the EALs.

3.3 Emergency Action Level (EAL)

A pre-determined, site-specific, observable threshold for an IC that, when met or exceeded, places the facility in a given ECL.

Discussion: EAL statements may utilize a variety of criteria including instrument readings and status indications, observable events, results of calculations and analyses, entry into particular procedures, and the occurrence of natural phenomena.

GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS

4.1 General Considerations

When making an emergency classification, the Emergency Director (ED) must consider all information having a bearing on the proper assessment of an IC. This includes the EAL, plus Notes, and the informing Basis information.

All emergency classification assessments should be based upon valid indications, reports, or conditions. A valid indication, report, or condition is one that has been verified through appropriate means such that there is no doubt regarding the indicator's

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operability, the condition's existence, or the report's accuracy. For example, validation could be accomplished through a response on related or redundant indicators or direct observation by personnel. The validation of indications should be completed in a manner that supports timely emergency declaration.

A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that 1) the activity proceeds as planned and 2) the conditions remains within the limits imposed by the license. Such activities include planned work to test, manipulate, repair, maintain, or modify a system or component. In these cases, the controls associated with the planning, preparation, and execution of the work will ensure that compliance is maintained with all aspects of the license provided that the activity proceeds and concludes as expected.

Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72.

While the EALs have been developed to address possible or anticipated events and conditions which may warrant emergency classification, a provision for classification based on the EDs experience and judgment is still necessary. The NEI 99-01, Rev. 6, scheme provides the Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the ECL definitions (refer to PD-HU3 and PD-HA3). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.

4.2 Classification Methodology

To make an emergency classification, the user will compare an event or condition (i.e.,

the relevant facility indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL(s) must be consistent with the related Notes. If an EAL has been met or exceeded, then the IC is considered met and the associated ECL is declared in accordance with facility procedures.

4.3 Classification of Multiple Events and Conditions

When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared.

For example:

If an UNUSUAL EVENT EAL and an ALERT EAL are met, an ALERT should be declared.

There is no "additive" effect from multiple EALs meeting the same ECL. For example:

• If two UNUSUAL EVENT EALs are met, an UNUSUAL EVENT should be declared.

Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, "Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events."

4.4 Classification of Imminent Conditions

Although EALs provide specific thresholds, the Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively

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short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met.

4.5 Emergency Classification Level Upgrading and Termination

An ECL may be terminated when the event or condition that meets the IC and EAL no longer exists. Events will not be downgraded.

As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02.

4.6 Classification of Short-Lived Events

Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Example of such events would be a SECURITY CONDITION.

4.7 Classification of Transient Conditions

It is important to stress that the emergency classification assessment period is not a "grace period" during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event; emergency classification assessments must be deliberate and timely, with no undue delays.

4.8 After-the-Fact Discovery of an Emergency Event or Condition

In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.

In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022, "Event Report Guidelines 10 CFR 50.72 and 50.73," is applicable.

Specifically, the event should be reported to the NRC in accordance with 10 CFR 50.72 within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

4.9 Retraction of an Emergency Declaration

Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022.

4.10 Response to a TMI-2 Emergency

TMI-2 alarms will be monitored on a 24-hour a day basis remotely from Emergency Response Facility (ERF) or by another appropriate location in the event of a failure of the

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remote monitoring system. For failures of specific local alarm capabilities, local conditions will be monitored in accordance with the applicable procedures.

A TMI-2 related emergency will be reported to the ISFSI Shift Supervisor (ISS). The ISS will assess and evaluate the situation; classify the event as required based on impact to the site per the EALs; and provide the appropriate response.

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REFERENCES

5.1 Developmental

5.1.1 NEI 99-01 Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012

5.1.2 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities

5.1.3 RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2007

5.1.4 NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73

5.1.5 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors

5.1.6 NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants

5.1.7 10 CFR 72.32, Emergency Plan

5.1.8 NUREG-1567, Spent Fuel Dry Storage Facilities

5.1.9 10 CFR 50.47, Emergency Plans

5.1.10 NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees

5.1.11 NSIR/ISG-02, Interim Staff Guidance, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants

5.2 Implementing

5.2.1 EP-TM-1002, Independent Spent Fuel Installation Emergency Plan

5.2.2 EP-TM-1002, Addendum 1, Emergency Action Levels and Technical Bases

5.3 Commitments

None

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ACRONYMS & DEFINITIONS

6.1 Acronyms

CFR..................................................................................... Code of Federal Regulations DSAR............................................................................. Defueled Safety Analysis Report EAL.................................................................................. EMERGENCY ACTION LEVEL ECL.................................................................. EMERGENCY CLASSIFICATION LEVEL EPA.............................................................................. Environmental Protection Agency FEMA.............................................................. Federal Emergency Management Agency ISFSI.................................... INDEPENDENT SPENT FUEL STORAGE INSTALLATION IC.......................................................................................................... Initiating Condition NEI.............................................................................................. Nuclear Energy Institute NRC............................................................................... Nuclear Regulatory Commission ODCM........................................................................... Off-site Dose Calculation Manual PAG............................................................................................. Protective Action Guide PD.................................................................................................. Permanently Defueled Rem.......................................................................................... Roentgen Equivalent Man TEDE............................................................................... Total Effective Dose Equivalent

6.2 Definitions

NOTE: Selected terms used in IC and EAL statements are set in all capital letters (e.g., ALL CAPS).

ALERT: Refer to Section 3.1.2.

CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.

EMERGENCY ACTION LEVEL (EAL): Refer to Section 3.3.

EMERGENCY CLASSIFICATION LEVEL (ECL): Refer to Section 3.1.

INITIATING CONDITION (IC): Refer to Section 3.2.

HOSTAGE: Person(s) held as leverage against the station to ensure that demands will be met by the facility owner.

HOSTILE ACTION: An act toward TMI-1 ISFSI or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the TMI-1 ISFSI. Non-terrorism-based EALs should be used to address such activities.

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

IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): See definition in IOEP,Section I.

PROJECTILE: An object directed toward the TMI-1 ISFSI that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

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

UNUSUAL EVENT (UE): Refer to Section 3.1.1

ATTACHMENTS Attachment 1: EAL Matrices Attachment 2: EAL Bases

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Attachment 1 - EALs Matrices

Table PD-1: Recognition Category "PD" Initiating Condition Matrix

UNUSUAL EVENT ALERT

PD-HU1 Confirmed SECURITY CONDITION PD-HA1 HOSTILE ACTION within the TMI-1 or threat. ISFSI is occurring or has occurred.

PD-HU3 Other conditions exist which in the PD-HA3 Other conditions exist which in the judgment of the Emergency Director warrant judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT. declaration of an ALERT.

Table E-1: Recognition Category "E" Initiating Condition Matrix

UNUSUAL EVENT

E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

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Attachment 1 - EALs Matrices

ALERT UNUSUAL EVENT

Hazards and Other Conditions Affecting Facility Safety

PD-HA1 HOSTILE ACTION within the TMI-1 ISFSI is PD-HU1 Confirmed SECURITY CONDITION or threat.

occurring or has occurred.

Emergency Action Level (EAL): Emergency Action Level (EAL):

Notification by the Security Force that a HOSTILE 1. Notification of a credible security threat directed ACTION is occurring or has occurred within theTMI-1 at the site as determined per SY-AA-101-132, ISFSI. Security Assessment and Response to Unusual Activities.

OR

2. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.

ALERT UNUSUAL EVENT

Hazards and Other Conditions Affecting Facility Safety

PD-HA3 Other conditions exist which in the judgment PD-HU3 Other conditions exist which in the judgment of the Emergency Director warrant of the Emergency Director warrant declaration of an ALERT. declaration of an UNUSUAL EVENT.

Emergency Action Level (EAL): Emergency Action Level (EAL):

Other conditions exist which, in the judgment of the Other conditions exist which in the judgment of the Emergency Director, indicate that events are in Emergency Director indicate that events are in progress progress or have occurred which involve an actual or or have occurred which indicate a potential degradation potential substantial degradation of the level of safety of the level of safety of the facility or indicate a security of the facility or a security event that involves probable threat to facility protection has been initiated. No life-threatening risk to site personnel or damage to site releases of radioactive material requiring offsite equipment because of a HOSTILE ACTION. Any response or monitoring are expected unless further releases are expected to be limited to small fractions degradation of conditions occur.

of the EPA Protective Action Guideline exposure levels.

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Attachment 1 - EALs Matrices

ALERT UNUSUAL EVENT

ISFSI Malfunction

E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

Emergency Action Level (EAL):

Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading > 2 times the ISFSI Technical Specification allowable levels.

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Attachment 2 - EAL Bases

Recognition Category PD EAL Basis

Recognition Category PD provides a stand-alone set of ICs/EALs for a Permanently Defueled nuclear facility to consider for use in developing a site-specific emergency classification scheme. For development, it was assumed that the plant had operated under a 10 CFR Part 50 license and that the operating company has permanently ceased plant operations. Further, the company intends to store the spent fuel on the ISFSI pad until the Department of Energy takes possession of the spent fuel.

When in a permanently defueled condition, the plant licensee typically receives approval from the NRC for exemption from specific emergency planning requirements. These exemptions reflect the lowered radiological source term and risks associated with spent fuel pool storage relative to reactor at-power operation. Source terms and accident analyses associated with plausible accidents are documented in the station's Defueled Safety Analysis Report (DSAR), as updated. As a result, each licensee will need to develop a site-specific emergency classification scheme using the NRC-approved exemptions, revised source terms, and revised accident analyses as documented in the station's DSAR.

The Permanently Defueled (PD) Recognition Category uses the same ECLs as operating reactors; however, the source term and accident analyses limit the ECLs to an UNUSUAL EVENT and ALERT. The UNUSUAL EVENT ICs provide for an increased awareness of abnormal conditions while the ALERT ICs are specific to actual or potential impacts to spent fuel. The source terms and release motive forces associated with a permanently defueled facility would not be sufficient to require declaration of a Site Area Emergency or General Emergency.

In NEI 99-01, Rev. 6, appropriate ICs and EALs from Recognition Categories A [R], C, F, H, and S [M] were modified and included in Recognition Category PD to address a spectrum of the events that may affect a spent fuel pool. Once all of the irradiated fuel has been removed from the spent fuel pool the spectrum of potential emergency events that may occur are again grea tly reduced. Based on industry precedence, some of Hazard Recognition Category (PD -H) ICs and EALs, as reflected in this document, are being maintained.

Table PD-1: Recognition Category "PD" Initiating Condition Matrix, provides a summary of initiating conditions associated with Recognition Category PD.

Recognition Category E EAL Basis

Recognition Category E provides an IC/EAL for an ISFSI. A significant amount of the radioactive material contained within a cask must escape its packaging and enter the atmosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel. Formal offsite planning is not required because the postulated worst-case accident involving an ISFSI has insignificant consequences to the public health and safety.

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Attachment 2 - EAL Bases

PD-HA1

Initiating Condition:

HOSTILE ACTION within the TMI-1 ISFSI is occurring or has occurred.

Emergency Action Level (EAL):

Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the TMI-1 ISFSI.

Basis:

This IC addresses an occurrence of a HOSTILE ACTION within the TMI-1 ISFSI. Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

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

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small ai rcraft, shots from hunters, phy sical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

This EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in theTMI-1 ISFSI.

Basis Reference(s):

1. NEI 99-01 Rev 6, PD-HA1

2. Station Security Plan

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Attachment 2 - EAL Bases

PD-HU1

Initiating Condition:

Confirmed SECURITY CONDITION or threat.

Emergency Action Level (EAL):

1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.

OR

2. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.

Basis:

This IC addresses events that pose a threat to facility personnel and thus represent a potential degradation in the level of facility safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs PD-HA1.

Classification of these events will initiate appropriate threat-related notifications to facility personnel and OROs.

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

EAL #1 Basis:

Addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-101-132.

EAL #2 Basis:

References Security Force because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.

Escalation of the EMERGENCY CLASSIFICATION LEVEL would be via IC PD-HA1.

Basis Reference(s):

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

2. Station Security Plan

3. SY-AA-101-132, Security Assessment and Response to Unusual Activities

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Attachment 2 - EAL Bases

PD-HA3

Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT.

Emergency Action Level (EAL):

Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the facility or a security event that involves probable life-threatening risk to site personnel or damage to facility equipment because of a HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the EMERGENCY CLASSIFICATION LEVEL description for an ALERT.

Basis Reference(s):

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

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Attachment 2 - EAL Bases

PD-HU3

Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT.

Emergency Action Level (EAL):

Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the facility or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of equipment required for spent fuel storage occurs.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the EMERGENCY CLASSIFICATION LEVEL description for an UNUSUAL EVENT.

Basis Reference(s):

1. NEI 99-01, Rev 6, PD-HU3

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Attachment 2 - EAL Bases

E-HU1

Initiating Condition

Damage to a loaded cask CONFINEMENT BOUNDARY.

Emergency Action Level (EAL):

Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading > 2 times the ISFSI Technical Specification allowable levels.

Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The word cask, as used in this EAL, refers to the storage container in use at the site for dry storage of irradiated fuel. The issues of concern are the creation of a potential or actual release path to the environment, degradation of any fuel assemblies' due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

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

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

Basis Reference(s):

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

2. Certificate of Compliance 1031 NAC MAGNASTOR Canister

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