ZS-2016-0063, Response to Request for Additional Information for Proposed Revision to Defueled Station Emergency Plan

Response to Request for Additional Information for Proposed Revision to Defueled Station Emergency Plan

ML16176A208
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/22/2016
From:	Gerard van Noordennen ZionSolutions
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
ZS-2016-0063
Download: ML16176A208 (56)

Text

An EnergySo/utions Company 10 CFR 50.4 10 CFR 50.54 10 CFR50.90 June 22, 2016 ZS-2016-0063 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304

Subject:

Response to Request for Additional Information for Proposed Revision to Zion Nuclear Power Station Defueled Station Emergency Plan

References:

1) Letter from U.S. Nuclear Regulatory Commission to John Sauger, ZionSolutions, LLC, "Request for Additional Information Related to the Proposed Revision to the Defueled Station Emergency Plan for Zion Nuclear Power Station, Units 1 and 2 (TAC NOS. L53 l l 4 and L53115)," dated June 3, 2016

2) Letter from Gerard van Noordennen, ZionSolutions, LLC, to U.S. Nuclear Regulatory Commission, "License Amendment Request for Proposed Revision to Zion Nuclear Power Station Defueled Station Emergency Plan,"

dated January 7, 2016 ZionSolutions, LLC (ZS) is herewith submitting the attached response to the NRC's Request for Additional Information (RAI) (Reference 1) on ZS' Lic.ense Amendment Request for a Proposed Revision to Zion Nuclear Power Station (ZNPS) Defueled Station Emergency Plan (Reference 2). Attachment I documents ZS' responses to the RAis; Attachment 2 provides the revised Emergency Plan reflecting the RAI responses; and Attachment 3 provides the revised Emergency Action Level Basis Document reflecting the RAI responses.

ZS has determined that the changes incorporated do not affect the previously provided Significant Hazards Consideration (SHC) (Reference 2).

ZS requests approval of the revised Emergency Plan by January 1, 20 I 7 consistent with our initial submittal.

Should you have any questions concerning this submittal, please contact me at (224) 789-4025.

I declare under penalty of perjury that the foregoing is true and correct.

101 Shiloh Boulevard, Zion

• IL 60099 (224) 789-4016

• Fax: (224) 789-4008

• www.zionsolutionscompany.com

ZionSolutions, LLC ZS-2016-0063 Page 2 of2 Respectfully, G~'lrl--~

Gerard van Noordennen Vice President Regulatory Affairs Attachments:

1. Response to Request for Additional Information

2. Revised Proposed ISFSI Emergency Plan

3. Revised ISFSI Emergency Plan Emergency Action Level Basis Document cc: Jolm Hickman, U.S. NRC Senior Project Manager Service List

Zion Nuclear Power Station, Unit 1and2 License Transfer Service List cc:

Ken Robuck Alwyn C. Settles Group President Disposal and

• Section Head, Nuclear Facility Inspection Decommissioning Bureau of Nuclear Facility Safety EnergySolutions Illinois Emergency Management Agency 299 South Main Street, Suite 1700 1011 North St., PO Box 250 Salt Lake City, UT 84111 Mazon, IL 60444 John Sauger Kelly F. Grahn Executive VP & General Manager Senior Health Physicist, Unit Supervisor ZionSolutions, LLC Bureau of Radiation Safety, Environmental 101 Shiloh Boulevard Management Zion, IL 60099 Illlnois Emergency Management Agency 245 W Roosevelt Road, Building 8, Suite 55 Gerard van Noordennen West Chicago, IL 60185 VP Regulatory Affairs ZionSolutions, LLC Kent McKenzie

• 101 Shiloh Boulevard Emergency Management Coordinator Zion, IL 60099 Lake County Emergency Management Agency 1303 N. Milwaukee Avenue Anthony Orawiec Libertyville, IL 60048-1308 Decommissioning Plant Manager ZionSolutions, LLC Regional Administrator 101 Shiloh Boulevard U.S. NRC,.Region III Zion, IL 60099 2443 Warrenville Road Lisle, IL 60532-4352 Dan Shrum Senior VP Regulatory Affairs

• John E. Matthews EnergySolutions Morgan, Lewis & Bockius LLP 299 South Main Street, Suite 1700 1111 Pennsylvania Avenue, NW Salt Lake City, UT 84111 Washington, DC 20004 Russ Workman General Counsel EnergySolutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111

ATTACHMENT 1 Response to Request for Additional Information

ZionSolutions, LLC ZS-2016-0063: Attachment 1 Page 1of6 RAI-ZS-1 NRC Question:

Jlttachment 2 (Zion Station ISFSI Emergency Plan, Revision 0 DRAFT), Section 5. 4, Radiological Assessment, states: "The !SS [ISFSI Shift Supervisor] will ensure an assessment of ISFSI dose rates is performed after any natural phenomena event or accident condition. "

Please describe the process used to determine if the EAL threshold values for E-HUJ are

.reached, including: (1) a description ofhow the surveys are to be conducted; (2) the type and availability ofsurvey instrument(s) to be.used, and (3) how the '!SS is prompted to initiate the surveys..

ZS Response:

The surveys will be conducted by trained ISFSI personnel. The ISS/ED has the responsibility to determine the level of monitoring required, and to have radiation dose rate measurements taken as necessary. On-shift personnel will perform radiation dose rate measurements, as necessary.

The typical instrumen¥tion to be available and utilized at the ISFSI is the Ludlum Model 12-4 Survey Meter withthe HE-3 Neutron Detector and the Fluke 451P Ion Chamber Survey Meter.

Any event at the site where there is visible damage to a storage cask and which the ISS believes could have the abilify to jeopardize the integrity of the Transportable Storage Canister confinement boundary would prompt the initiation of surveys.

Section 5 .4 has been replaced with the following text:

"Section 5.4 Radiological Assessment Radiological assessment may be initiated upon classification of an emergency. However, the only significant radiological consequences associated with the accident analyses in Chapter 12 of the NAC MAGNASTOR. FSAR are associated with elevated dose rates caused by:

• A hypothetical VCC tip-over exposing the bottom of the cask that has limited shielding.

• vcc damage resulting from a design basis tornado induced missile that causes concrete to be removed frorri a small area on the VCC.

None of the NAC MAGNASTOR postulated accidents result in a loss of container confinement boundary, so a radiological release is not expected. Even if the confinement boundary was affected, the consequences to the public health and safety would be insignificant, as there is no driving force for a release of radioactive material.

As a result, radiological assessment and protective actions would be limited to the determination of dose rates in the area of an affected VCC, the establishment of controls to prevent personnel from entering the area, and to ensure that any recovery or repair activities are planned and executed in a manner that minimizes exposure.

ZionSolutions, LLC ZS-2016-0063: Attachment 1 Page 2of6 5 .4.1, Radiological Monitoring The level of monitoring activity will depend on the severity of the accident. The ISS/ED has the responsibility to determine the level of monitoring required, and to have radiation dose rate measurements taken as necessary. On-shift personnel will perform radiation dose rate measurements as necessary.

Exposure of individuals performing emergency functions is consistent with the limits specified in facility procedures. Every attempt will be made to keep personnel exposure As Low As Reasonably Achievable (ALARA).

5.4.2 Radiological Exposure Control The ISS/ED is responsible for emergency radiological protection activities for facility staff and support personnel. The ISS/ED approves personnel exposure limits. When required by RP procedures or the ED, all emergency response personnel are issued a Thermoluminescent Dosimeter (TLD) subject to provisions contained in Emergency Operating Procedures.

Emergency response personnel dose records will be based upon the results of TLD data, as soon as the TLDs can be processed.

During an incident, higher than normal levels of radiation may be encountered. Under all situations, steps will be taken to minimize radiation exposure. Specific exposure guidelines for entry or re-entry into areas in order to remove injured persons (rescue operations) or undertake corrective actions will be in accordance with the guidance set forth in facility procedures. The ISS/ED will authorize emergency exposure limits or more restrictive limits, dependent upon incident conditions. Medical responders and the ISS/ED will discuss the hazards involved in rescue operations prior to undertaking a rescue mission ofthis nature. The ISS/ED will administer emergency radiation exposure control. Authorization to allow emergency response personnel to receive doses in excess of 10 CFR 20 limits shall be made only by the ISS/ED and only during declared emergencies. Considerations to be made prior to allowing personnel to accept risks associated with rescue operations or high dose missions are defined in facility procedures."

ZionSolutions, LLC .

ZS-2016-0063: Attachment 1 Page 3of6 RAI-ZS-2 NRC Question: , Section 5. 5. 2, Decontamination Capabilities, states in part, " ... contamination of individuals at the ISFSI, injured or not, is not a credible event." However,Section IV.E.3, Emergency Facilities and Equipment, to Appendix E of Title 10 ofthe Code ofFederal Regulations (10 CFR) Part 50, requires the following, in part:

"Adequate provisions shall be made and described for emergency facilities and equipment, including:

• 3. Facilities and supplies at the site for decontamination of onsite individuals; Please describe how the Zion Station ISFSI Emergency Plan meets the regulatory requirement cited above. [Note: Staff consideration for the elimination of this requirement would require the licensee's submittal ofan exemption request under 10 CFR 5 0.12 seeking specific relieffrom the cited Appendix E requirement.]

ZS Response:

Section 5.5.2 is revised as shown below to address this question. Decontamination equipment will be added to the First Aid kit located at the ISFSI and any decontamination would take place within the ISFSI Monitoring Building.

"5.5.2 Decontamination Capabilities Survey instrumentation for personnel frisking is available. Personnel contamination identified during the initial survey will require the contaminated individual to remove apparel, re-survey, and, if skin contamination is identified, perform decontamination as specified in Emergency Operating Procedures.

• In the event that accident conditions result in a contaminated injured individual, the victim's rescue and medical treatment take precedence over the victim's radiation exposure due to bodily contamination. Gross decontamination of the victim (generally limited to the removal of contaminated articles of clothing) will be accomplished to the extent that the health of the patient is not affected. Decontamination measures associated with wounds will be performed by the appropriately trained medical staff at the hospital under the supervision of the attending physician."

ZionSolutions, LLC ZS-2016-0063: Attachment 1 Page 4of6 RAI-ZS-3 NRC Question:

Section IV.E6 to Appendix E of 10 CFR) Part 50 requires the following, in part:

"Adequate provisions shall be made and described for emergency facilities and equipment, including:

• 6. Arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary; , Section 5. 6, First Aid and Medical, states: "Both the Vista Medical Center and the City ofZion Fire and Rescue Department have personnel trained in radiation protection measures." Please clarify the extent of training for the City ofZion Fire and Rescue Department as to whether: (1) training for the City ofZion Fire and Rescue Department covers the transportation of contaminated injured individuals from the site to the Vista Medical Center, and (2) training for the Vista Medical Center addresses the treatment ofradiologically contaminated injuries.

ZS Response:

(1) Annual training is provided to the City of Zion Fire and Rescue Department that encompasses transport of contaminated injured persons to the Vista Medical Center, including covering the individual to minimize further spread of contamination.

(2) Annual training is provided to the Vista Medical Center emergency room personnel with respect to minimizing the spread of contamination, establishment of a special area for treatment of the individual and dosimetry for emergency room personnel. Decontamination of an injury would be performed by the medical staff under the direction of the attending physician. Further assistance with decontamination of the treatment room, transport vehicle and equipment/

materials would be provided by augmented ERO RP personnel.

The following text is inserted in Section 5.6 before the last sentence:

"Annual training is provided to:

• The City of Zion Fire and Rescue Department that encompasses transport of contaminated injured persons to the Vista Medical Center, including covering the individual to minimize further spread of contamination; and

• The Vista Medical Center emergency room personnel with respect to minimizing the spread of contamination, establishment of a special area for treatment of the individual and dosimetry for emergency room personnel. Decontamination of an injury would be performed by the medical staff under the direction of the attending physician. Further assistance with decontamination of the treatment room, transport vehicle and equipment/ materials would be provided by augmented ERO RP personnel."

ZionSolutions, LLC ZS-2016-0063: Attachment 1 Page 5of6 RAI-ZS-4 NRC Question: , Section 5. 3, Emergency Response Organization Actions, lists separate bullets for:

ED [Emergency Director] deactivates Augmented ERO [emergency response organization], and ED deactivates ERO. Please clarifY if these are intended to be separate actions o~ unintentional duplication.

ZS Response:

These actions are intended to be separate actions.

RAI-ZS-5 NRC Question:

ZNPS DSEP (Revision 18), Section 7.2.2, Augmented DERO [Defueled Emergency Response Organization], states: "The Radiation Protection Director is the only member of the Augmented DERO that is on call. The remainder of the Augmented DERO will be developed by the ED using guidance and contact information provided in EPIP E0-03, Emergency Preparedness Administration. " , Section 7. 2. 2, Augmented ERO, states: "For an Emergency Classification of ALERT involving radiological consequences or at the discretion of ED, On-call support personnel can be activated. "

• Please describe, in the event that a declaration is made under initiating condition (IC) E-HU-1, at what time would health physics expertise be available on site to perform the follow up radiological surveys to determine the magnitude of the release and radiological conditions due to the event.

ZS Response:

Augmented ERO RP personnel will be available to respond and provide support within four hours of being contacted as described in Section 7 .2.2 of the Emergency Plan.

ZionSolutions, LLC ZS-2016-0063: Attachment 1 Page 6of6 RAI-ZS-6 NRC Question: (Zion ISFSI Emergency Action Level Basis Document, Revision 0 DRAFT),

IC E-HUl states, in part: "The technical specification multiple of '2 times,' which is also used in Recognition Category A, IC AUl, is used here to distinguish between non-emergency and emergency conditions." However, Recognition Category A, IC AUl, is not included in the proposed emergency action level (EAL) scheme. Please remove this statement or explain how it is applicable.

ZS Response:

The statement "which is also used in Recognition Category A, IC AUl" will be removed in E-HUl since it is not applicable.

In addition, in Table 4.1 on Page 4-2 of the ISFSI Emergency Plan, in the Emergency Action Level Threshold Values column, "spent fuel cask" was replaced with "Vertical Concrete Cask" to align the wording with the NAC CoC and the EAL Basis wording. '

RAI-ZS-7 NRC Question: , IC PD-HUI, lists Emergency Action Level Threshold Values: (1 or 2 or 3).

However, there are only 2 threshold values listed, neither of which are numbered. Please revise accordingly to address inconsistency.

ZS Response:

"Emergency Action Level Threshold Values: (1or2 or 3)" will be changed to "Emergency Action Level Threshold Values: (1or2)"; and the two threshold values listed will be numbered 1 and 2, respectively.

ATTACHMENT 2 Revised Proposed Independent Spent Fuel Installation (ISFSI)

Emergency Plan

ZIONSOLUTIONSLLC An EnergySo/utions Company Zion Station Independent Spent Fuel Storage Installation (ISFSI)

Emergency Plan Revision 0 DRAFT

Zion Station ISFSI Emergency Plan Revision 0 DRAFT TABLE OF CONTENTS

1.0 INTRODUCTION

.......................................................................................................... 1-1 2.0 FACILITY DESCRIPTION .......................................................................................... 2-1 2.1 SITE ........ ,........*.............................................. ,...................................... ,................... 2-1 2.2 SURROUNDINGAREA ........................................................................................... 2-1 2.3 INDEPENDENT SPENT FUEL STORAGE INSTALLATION ............................... 2-2 3.0 ISFSI OFF-NORMAL EVENTS AND ACCIDENTS .......................................... ;..... 3-1 3.1 ISFSIOff-NormalEvents .......................................................................................... 3-1 3.2 ISFSI Accidents ......................................................................................................... 3-1 4.0 CLASSIFICATION********~******************************: ............................................................... 4-1 4.1 CLASSIFICATION OF ACCIDENTS ...................................................................... 4-1 4.2 EMERGENCY ACTION LEVELS (EALS) ............................................................. 4-1 5.0 RESPONSE .................................................................................................................... 5-1 5.1 RECOGNITION AND CLASSIFICATION .............................................................. 5-1 5.2 NOTIFICATION AND ACTIVATION ...................................................................... 5-1 5.3 EMERGENCY RESPONSE ORGANIZATION ACTIONS ..................................... 5-2 5.4 RADIOLOGICAL ASSESSMENT ........................................................................... 5-3 5.5 PROTECTIVE MEASURES ..................................................................................... 5-4 5.6 FIRST AID AND MEDICAL .................................................................................... 5-5 5.7 FIREFIGHTING ..................................*...................................................................... 5-6 5.8 TERMINATION ........................................................................................................ 5-6 5.9 RECOVERY .............................................................................................................. 5-6 6.0 FACILITIES AND EQUIPMENT ................................................................................ 6-1 6.1 EMERGENCY FACILITIES ............................................................... *...................... 6-1 6.2 SYSTEMS, EQUIPMENT, AND ADVISORY SERVICES ...................................... 6-1 6.3 COMMUNICATIONS ............................................................................................... 6-2 7.0 ORGANIZATION AND RESPONSIBILITIES .......................................................... 7-1 7.1 NORMAL ORGANIZATION ................................................................................... 7-1 7.2 EMERGENCY RESPONSE ORGANIZATION (ERO) ........................................... 7-1 7.3 ON-SITE RESPONSIBILITIES ................................................................................ 7-2 7.4 CORPORATE SUPPORT .......................................................................................... 7-3 7.5 LOCAL OFFSITE SUPPORT ................................................................................... 7-4 7.6 STATE AND FEDERAL GOVERNMENT ............................................................... 7-4 1

Zion Station ISFSI Emergency Plan Revision 0 DRAFT 8.0 MAINTAINING EMERGENCY PREPAREDNESS ................................................. 8-1 8.1 RESPONSIBILITIES ................................................................................................ 8-1 8.2 TRAINING ................................................................................................................ 8-1 8.3 DRILLS AND EXERCISES ...................................................................................... 8-2 8.4 REVIEW AND UPDATE OF EMERGENCY PLAN, EAL BASIS DOCUMENT, AND EMERGENCY OPERATION PROCEDURES ....................... 8-3 8.5 PERIODIC SURVEILLANCE .................................................................................. 8-3 8.6 INDEPENDENT REVIEW ....................................................................................... 8-4 APPENDIX A DEFINITIONS, ABBREVIATIONS AND ACRONYMS ....................... A-1 APPENDIXB LETTERS OF AGREEMENT .................................................................... B-1 APPENDIXC EMERGENCY PLAN PROCEDURES ..................................................... C-1 ii

Zion Station ISFSI Emergency Plan Revision 0 DRAFT

1.0 INTRODUCTION

This document describes the Licensee's plan for responding to emergencies that may arise at the Zion Station Independent Spent Fuel Storage Installation (ISFSI).

The emergencies addressed in this plan are related to the dry storage of spent nuclear fuel and Greater Than Class C (GTCC) waste at the ISFSI, and include off-normal, accident, natural phenomena, and hypothetical events and consequences as presented in the NAC International, Inc. (NAC) Modular Advanced Generation Nuclear All-purpose Storage (MAGNASTOR) Final Safety Analysis Report (FSAR).

All of the Zion Station spent fuel and GTCC waste have been relocated to the ISFSI, therefore, only those off-normal events and accidents that apply to ISFSI storage conditions are addressed in this Emergency Plan.

The analyses of the radiological impact of potential accidents at the ISFSI site conclude that any releases beyond the ISFSI Controlled Area Boundary are less than the Environmental Protection Agency (EPA) Protective Action Guide (P AG) exposure levels, as detailed in EPA-400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." The Controlled Area, as defined in 10 CFR 72.3, means the area immediately surrounding an ISFSI for which the licensee exercises authority over its use and within which ISFSI operations are perfmmed. The Licensee shall exclude access to the ISFSI Controlled Area if adverse radiological conditions require.

If an emergency condition develops, the ISFSI Shift Supervisor (ISS) is responsible for recognizing the event and assuming the role of the Emergency Director (ED). The ED is responsible for declaring the emergency and implementing the ISFSI Emergency Plan.

The On-Shift Emergency Response Organization (On-Shift ERO) is responsible for perfo1ming emergency response activities and may be augmented with additional emergency response personnel at the discretion of the ED. Notification is made to State agencies and the Nuclear Regulatory Commission. Conditions are assessed and c01Tective actions are implemented to restore the facility to a normal safe condition.

The Zion Station ISFSI Emergency Plan is based on applicable regulations, industry guidelines, and the NAC MA GNAS TOR FSAR accident analyses for the dry cask storage system.

1-1

Zion Station ISFSI Emergency Plan Revision 0 DRAFT 2.0 FACILITY DESCRIPTION 2.1 SITE The Zion Station ISFSI is sited on a tract ofland of approximately 250 acres in the extreme eastern portion of the city of Zion, Lake County, Illinois, on the west shore of Lake Michigan. The site is approximately 6 miles NNE of the center of the city of Waukegan, Illinois and 8 miles south of the center of the city of Kenosha, Wisconsin.

2.2 SURROUNDING AREA In the vicinity of the site (approximate 1 mile radius) is the extreme western portion of the City of Zion which encompasses the Zion Metra Train Station, a small public park (Edina Park), a portion of a light industrial region , including a warehouse facility, and a small number of residences. There are no schools, hospitals or prisons within a 1 mile radius of the site. The site is bordered on the north and south by the Illinois Beach State Park.

The centers of the closest communities of Zion and Winthrop Harbor are located approximately 1.6 miles and 2.5 miles away respectively. In addition to Shiloh Boulevard providing access to the site, there are three other highways or major roads (Illinois Route 173, 29th Street and Wadsworth Road) that intersect the 1 mile radius and extend westward to other principal north-south roads that are outside of the boundary. Additionally, part of the Chicago and Northwestern Railroad track system passes though the boundary (approximately 0.8 miles to the west) and is used for commuter and freight traffic.

The site is bounded on the east by Lake Michigan on which surface vessels and over which aircraft operate. Commercial barge and ship traffic does not ordinaiily operate within five miles of the site.

2-1

Zion Station ISFSI Emergency Plan Revision 0 DRAFT 2.3 INDEPENDENT SPENT FUEL STORAGE INSTALLATION All of the Zion Station spent nuclear fuel and Greater Than Class C (GTCC) waste is in dry cask storage at the ISFSI located south of the ComEd switchyard (see Figure 2-

1) within the Owner Controlled Boundary, as shown in Figure 2-2.

The cask storage pads are two 36 inch thick reinforced concrete slabs that ate 689-feet wide by 148-feet long. They are independent structures separated by a reinforced concrete apron located between the two pads. In total, the cask storage pads are designed to accommodate 72 Vertical Concrete Casks (VCCs) (9 rows with 4 VCCs per row on each pad). Sixty-one (61) VCCs are used for the storage of spent fuel; and four (4) VCCs are used for the storage of GTCC waste.

The ISFSI pads are surrounded by the Protected Area (PA) fence. A second fence surrounds the PA fence and establishes an isolation zone between the two fences.

The ISFSI is also located within the Radiological Restricted Area Boundary which provides an additional fenced perimeter. Both the ISFSI and the Radiological Restricted Area are inside the Site Boundary.

The ISFSI monitoring building provides for normal ISFSI access control and ISFSI monitoring. The Central Alarm Station is the portion of the ISFSI Monitoring Building where ISFSI monitoring is conducted. During an emergency, the ISFSI Monitoring Building becomes the Emergency Response Facility (ERP) and is the location where emergency events will be initially assessed, classified, and managed.

The ISFSI is designed for interim storage of spent fuel in a contained shielded system. The MAGNASTOR dry cask storage system is used under the provisions of 10 CPR 72 Pait K, "General License for Storage of Spent Fuel at Power Reactor Sites." A general license is granted under 10 CPR 72.210,for storage of spent nuclear fuel in an ISFSI at power reactor sites to persons that are authorized to possess or operate nuclear power reactors under 10 CPR 50. ZS is authorized by the NRC to store and possess spent nuclear fuel at the Zion Station by Facility Operating Licenses (DPR-39 and DPR-48) pursuant to the provisions of 10 CPR 50.

The NAC MAGNAS TOR system is a sealed canister based system for the storage and transportation of spent nuclear fuel. The primary components of the MAGNASTOR system consist of the Transportable Storage Canister and the Vertical Concrete Cask (VCC). The VCC provides radiation shielding and contains internal airflow paths that allow decay heat generated by the spent nuclear fuel stored within the Transportable Storage Canister to be removed by natural air circulation around the canister wall. For additional information on the MAGNASTOR system, refer to the MAGNASTOR FSAR, Certificate of Compliance No. 1031 and the Zion Nuclear Power Station Independent Spent Fuel Storage Installation (ISFSI), 10 CPR 72.212 Evaluation Report.

2-2

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 3.0 ISFSI OFF-NORMAL EVENTS AND ACCIDENTS The following is a description of off-normal events and accident conditions described in Chapter 12 of the MAGNASTOR FSAR that are applicable with all spent fuel located at the ISFSI for long term storage. The analyses demonstrate that the MAGNASTOR storage system satisfies the requirements of 10 CPR 72.24 and 10 CPR 72.122 for off-normal events and accident conditions. The design of the concrete cask and storage canister preclude the release of contamination from the contents during use of the storage system. Evaluations show that for off-normal events and accident conditions, there is no mechanistic failure of the confinement boundary of the storage canister. The storage canister maintains its structural integrity during off-normal events and accident conditions without release of radioactive material or excessive radiation exposure to workers or the general public. The storage canister has no credible leakage, and therefore, there is no release of radioactive material during off-normal events and accident conditions of storage.

Accidents and off-normal events that are analyzed for the ISFSI, including some events considered to be non-credible, have been reviewed. All spent fuel has been relocated to the ISFSI, therefore, only those off-normal events and accidents that apply to storage conditions are addressed. This plan classifies events based on predetermined Emergency Action Levels (EALs). This approach establishes clear, predetermined actions to an emergency event or accident, allowing a coordinated response to the eventual mitigation of the emergency condition and the restoration of the facility to a safe status.

3.1 ISFSI Off-Nonnal Events The MAGNASTOR FSAR presents evaluations of postulated off-nonnal events that could occur once during any calendar year of operation.

• Severe Ambient Temperature Events (> 106° F or < -40° F)

• Blockage of One-Half of the Air Inlets

• Small Releases of Radioactive Particulate from the Transportable Storage Canister exterior.

These off-normal events result in no serious radiological consequences.

3 .2 ISFSI Accidents The MAGNASTOR FSAR presents results of analyses of design basis and hypothetical accident conditions evaluated for the MAGNASTOR system. In addition to design basis accidents, the MAGNASTOR FSAR also addresses low-probability events including natural phenomena that might occur once over the lifetime of the ISFSI or have consequences that may result in maximum potential effect on the immediate environment. The analyses show that the MAGNASTOR system has a substantial design margin of safety and the system provides protection to the public and to site personnel. The following accidents have been evaluated.

3-1

Zion Station ISFSI Emergency Plan Revision 0 DRAFT 3 .2.1 Accident Pressurization.

This is a hypothetical event that assumes the failure of all fuel rods in a canister.

No normal storage conditions are expected to lead to the rupture of all the fuel rods. Pressurization of the canister is caused by release of fission products and helium fill gas from the fuel rods. Analysis shows that the maximum Transportable Storage Canister pressure resulting from this accident is less than the Transportable Storage Canister design pressure.

There are no radiological consequences for this accident and there are no adverse consequences as a result of the maximum accident internal pressure.

Failure of fuel rods is unlikely to be detected by any measurement or inspection that could normally be undertaken from the exterior of the Transportable Storage Canister or VCC.

There are no corrective actions required.

3.2.2 Earthquake The analysis shows that the design basis earthquake does not affect the MAGNAS TOR concrete cask performance. The loaded concrete cask does not tip over for the design basis earthquake defined as a horizontal acceleration load of 0.37g at the top surface of the ISFSI pad. The maximum horizontal acceleration at the ZNPS ISFSI has been determined to be 0.19g. Maximum sliding distance of a concrete cask due to the horizontal acceleration is approximately 6.2 inches. With a minimum 16 feet center-to-center spacing of the casks there is sufficient clear space in between adjacent casks. Sliding due to the design basis earthquake will not cause adjacent concrete casks to impact one another, nor will it cause a concrete cask to slide off the ISFSI pad.

There are no radiological consequences for this accident.

An earthquake would be detected by ISFSI personnel feeling the movement of the area.

Corrective action consists of inspecting the VCCs following the event.

3-2

Zion Station ISFSI Emergency Plan Revision 0 DRAFT 3 .2.3 Explosion An explosion is unlikely because administrative controls exclude explosive substances in the vicinity of the ISFSI. The closest explosive sources were evaluated and it was determined that MAGNASTOR design basis values were not exceeded.

There are no radiological consequences for this accident.

An explosion would be detected by visual or audible observation.

Inspection of the storage casks is required to ensure that the air inlets and outlets are free of debris. There are no recovery actions or corrective actions required for this accident event.

3.2.4 Failure of All Fuel Rods with a Subsequent Ground Level Breach of the Canister Because no mechanistic failure of the Transportable Storage Canister was identified with the Failure of All Fuel Rods and since the Transp01iable Storage Canister is leak tight, this potential accident is not evaluated in the MAGNASTOR FSAR.

3.2.5 Fire A fire is a very unlikely occurrence since there are no flammable materials stored in the area of the ISFSI pad. However, controls are in place limiting flammable materials to less than the 50 gallons in the direct vicinity of a VCC assumed in the hypothetical fire accident. The hypothetical fire accident is assumed to involve 50 gallons of fuel in the cask transport vehicle with the fire totally engulfing the entire base of a concrete cask. The duration of the analyzed fire is 8 minutes.

There are no significant radiological consequences for this accident. There may be local spalling of concrete during the fire event, which could lead to some minor reduction in shielding effectiveness and an insignificant increase in radiation dose rates on the cask surface.

Fires will be detected by visual observation or possibly by odor.

Following the fire, the concrete cask should be inspected for general deterioration of the concrete, loss of shielding (spalling of concrete), exposed reinforcing bar, and surface discoloration that could affect heat rejection. This inspection will determine the repair activities necessary to return the concrete storage cask to its design basis configuration.

3-3

Zion Station ISFSI Emergency Plan Revision 0 DRAFT 3.2.6 Flood The MAGNASTOR system is not adversely affected by a design basis flood having a depth of water of 50 feet and a flow velocity of 15 feet per second.

The ISFSI is bounded by this accident since the ISFSI pads are constructed above Probable Maximum Surge and Sieche levels.

There are no radiological consequences for this accident.

Flooding will be detected by visual observation. Should water overflow the ISFSI pad, inspection of the concrete casks would be perfonned to ensure that the air inlets and outlets are free of debris.

3 .2. 7 Full Blockage of Air Inlets The likely cause of complete cask air inlet blockage is the covering of the base of the cask with snow, water or earth in a catastrophic event that is beyond the design basis earthquake. This hypothetical event is a bounding accident and is not considered credible. The evaluation of the accident demonstrates that there are no adverse consequences providing at least two of the air inlets are cleared of obstruction within 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> of event initiation. The remaining air inlets should be cleared of obstructions as soon as possible after that. The blockage of the air inlets would be detected by a Technical Specification Surveillance required to be performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to ensure that all inlet and outlet screens are free of blockage or in response to natural phenomena.

There are no radiological consequences for this accident with exception of the dose received in clearing the air inlets. For the MAGNASTOR system, the estimated extremity dose is 448 mrem for clearing the 4 air inlets of a VCC.

The whole body dose would be slightly less.

Blocked air inlets would be detected by visual observation. If observed, air

/vent obstructions will be cleared.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 3.2.8 Lightning A lightning strike is a random weather related event. Since the MA GNAS TOR storage cask is located on an unsheltered pad, the storage cask may be subject to a lightning strike. A lightning strike on a concrete cask may be visually detected at the time of the strike, or by visible surface discoloration at the point of entry or exit of the current flow. The analysis shows that the only area affected will be the surface of the VCC and that the increase VCC bulk temperature due to Joulean heating is not significant.

There are no radiological consequences for this accident.

Lightning strikes will be detected by visual observation.

The array of VCCs will be visually inspected for any damage following the lightning event and if damage is discovered, appropriate actions will be taken.

3.2.9 Maximum Anticipated Heat Load (133° F Ambient Temperature)

The cause of this condition is a weather event that causes the MAGNASTOR system to be subject to a 133° F ambient temperature with complete inlet flow blockage. The maximum component temperatures are less than the allowable temperatures for accident conditions and are also less than the temperature limits for normal conditions of storage. Available info1mation from the U.S.

National Oceanic and Atmospheric Administration for Chicago, Illinois indicates that the maximum temperature reached in the area has been 105° F.

There are no radiological consequences for this accident.

High ambient temperature would be detected by individual senses and monitored using thennometers or weather reports.

While the MAGNASTOR FSAR does not require recovery or c01Tective actions for this accident, ZS has surveillance requirements that would detect and correct air inlet flow blockages.

3-5

Zion Station ISFSI Emergency Plan Revision 0 DRAFT 3 .2.10 Tip-Over of the Concrete Cask A hypothetical non-credible accident condition has been postulated involving the non-mechanistic tip over of a concrete storage cask. No design basis accidents will cause the concrete cask to tip over. An earthquake having a magnitude greatly exceeding the design basis earthquake would be required to tip over the concrete cask. Functionally, the concrete cask is not expected to suffer significant adverse effects due to this event. The concrete cask and canister are expected to continue to provide design basis shielding, geometry control of contents, contents confinement performance, and spent fuel cooling.

There is a radiological consequence due to the hypothetical tip over event since the bottom end of the concrete cask has significantly less shielding than the sides and top of the concrete cask. High dose rates can be expected at the exposed concrete cask bottom following the tip over event and would dictate the use of supplemental shielding until the concrete cask can be up- righted.

Stringent access controls must be applied to ensure that personnel do not enter the area of radiation shine from the exposed bottom of the tipped over concrete cask. Following a tip over event, supplemental shielding should be used until the concrete cask can be up-righted. Surface and top and bottom edges of the concrete cask are expected to exhibit cracking and possible loss of concrete down to the layer of reinforcing bar.

The increased dose rate due to this cracking is not expected to be significant.

Tip-over casks will be detected by visual observation.

Recovery and con-ective actions are described in the MAGNASTOR FSAR. As previously noted, tip over is not a credible event.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 3.2.11 Tornado and Tornado Driven Missiles A tornado is a random weather event having a higher probability of occurrence at certain times of the year and geographical locations. The postulated tornado wind loading and tornado missile impacts are not capable of overturning the cask, or penetrating the boundary established by the concrete cask. There is little potential for significant damage to the concrete cask, which provides radiation shielding. The worst tornado missile impact for a MAGNASTOR concrete cask at the ISFSI pad could cause a penetration of approximately 6 inches into the concrete shield. The loss of shielding would result in a local surface radiation dose rate of less than 600 mrem/hr at the point of penetration.

The presence of a tornado will be detected by weather reports or visual observation. Any subsequent damage will be detected by visual observation.

A tornado event is not expected to result in the need to take any corrective actions other than an inspection of the ISFSI. This inspection would be directed at ensuring the concrete cask inlets and outlets had not become blocked by wind-blown debris, and at checking for obvious surface damage to the concrete cask. In the worst case, a tornado missile could dislodge concrete to a depth of approximately 6 inches which would require repair of the damage by grouting.

3.2.12 24-Inch Cask Drop The concrete cask may be lifted and moved by a transport frame. The transport frame raises the cask using a lifting attachment that connects to the two lifting lugs. The failure of one or more of the lifting lugs, or the failure of the lifting frame could result in a drop of the cask.

A drop of a cask would be visually observed at the time of the drop.

The detailed analysis is provided in Section 3 of the MAGNASTOR FSAR.

The analysis indicates that damage occurs to the air inlet system; however, the damage and impact to cooling are bounded by the loss of one half of the air inlet evaluation. The analyses also show that stress placed on the structural components of the Transpmiable Storage Canister is within safety limits and that buckling of the canister will not occur. The analyses also indicate that the fuel baskets are structurally adequate to withstand a 24 inch drop.

Administrative controls are in place to ensure the height of the cask does not exceed 24 inches and nominally less than 12 inches during transport.

Although the concrete cask remains functional following this event and no immediate corrective actions are required, the Transportable Storage Canister should be inspected and transferred to an undamaged concrete cask as soon as practicable. The damaged cask should be inspected and repaired as required prior to continued use. Prior to transferring the Transportable Storage Canister from the damaged concrete cask, inlet and outlet screen inspection frequencies should be evaluated for an increase based on the damaged cask's air flow path restrictions.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 4.0 CLASSIFICATION 4.1 CLASSIFICATION OF ACCIDENTS The Zion Station ISFSI Emergency Plan provides an emergency classification system based on Nuclear Energy Institute (NEI) 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors." Consistent with NRC guidance for an away-from-reactor ISFSI, accidents and off-nonnal events that rise to the level of an emergency at the ZNPS ISFSI are given the emergency classification of an ALERT. Classification of ISFSI emergencies at this level meet the intent for emergency planning in 10 CFR 72.32.

Accidents and off-normal events that are analyzed for the ISFSI, including some events considered to be non-credible, have been reviewed and where appropriate, have been assigned the emergency classification level of ALERT.

4.1.1 ALERT The emergency classification level of ALERT signifies that events are in progress or have occuned which involve an actual or potential substantial degradation of the level of safety of the ISFSI.

The ALERT classification includes emergency situations which are not expected to threaten the public, but for which notification of the States of Illinois, Wisconsin and the NRC is required.

The purpose of the ALERT classification is to assure that the ERO is available to respond to perform event mitigation, radiation monitoring if required, and to provide the States of Illinois and Wisconsin; and the NRC with cunent infomrntion on status .

. 4.2 EMERGENCY ACTION LEVELS (EALS)

An event is classified using Procedure E0-4, "Emergency Preparedness Implementation." This procedure is based, in part, on the infonnation contained in Table 4.1, "ISFSI Emergency Events"; and the Emergency Action Level Basis Document. The tables and supplemental information provided in the Emergency Action Level Basis Document identify possible Initiating Conditions, Recognition Category Codes, Emergency Action Level (EAL) Threshold Values, and the Emergency Classification associated with each Initiating Condition. EAL Threshold Values include predetermined values or conditions and are used to detennine that the severity of an event has progressed to that which wan-ants being given the designated Emergency Classification.

During an event, recognition of the emergency condition is the responsibility of the ISS. When conditions described in a specific Emergency Action Level (EAL) are reached, the ISS assumes the position of Emergency Director and classifies the emergency. Upon classification of an ALERT the ED activates the ERO.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT TABLE 4.1 ISFSI EMERGENCY EVENTS Recognition Emergency Event Type Category Emergency Action Level Threshold Values Classification Level Code Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on contact radiation reading greater than two times the NAC Certificate of Compliance, Appendix A, Technical Specification limits ofLCO 3.3.1 on the surface of the Vertical Concrete Cask Calculated Values Damage to a loaded cask Confinement E-HUl ALERT (Two times the NAC Certificate of Compliance, Appendix Boundary A, Technical Specification limits of LCO 3 .3 .1)

> 190 mrem/hr gamma on vertical surface OR

> 10 mrem/hr neutron on vertical surface OR

>900 mrem/hr (neutron+ gamma) on the top 4-2

Zion Station ISFSI Emergency Plan Revision 0 DRAFT Recognition Emergency Event Type Category Emergency Action Level Threshold Values Classification Level Code Confinned ISFSI Physical Security Plan security contingency event that results in the LLEA being requested to respond to the ISFSI.

-OR-Security Condition PD-HUI ALERT Notification of a credible threat to the site, reported by the NRC or other recognized offsite agency, that presents a risk to site personnel, a potential degradation to the level of safety at the site or a security threat to the ISFSI.

Other conditions exist which in the judgment Other conditions exist which in the judgment of the of the Emergency Emergency Director indicate that events are in progress or PD-HU3 ALERT Director warrant have occmTed which indicate a potential degradation of the declaration of an level of safety at the ISFSI.

ALERT 4-3

Zion Station ISFSI Emergency Plan Revision 0 DRAFT 5.0 RESPONSE 5.1 RECOGNITION AND CLASSIFICATION Recognition of the emergency condition is the responsibility of the ISS. When conditions described in a specific Emergency Action Level (EAL) are reached, the ISS assumes the position of Emergency Director and classifies the emergency. A classification of Recovery is made when repairs are being made as required to return to an acceptable condition and parameters are stable or improving. Termination is declared when no EAL Threshold Values are exceeded and the ERO is no longer needed.

5.2 NOTIFICATION AND ACTIVATION The ED will notify designated management and determine the level of effort required to mitigate the event.

Upon declaration of an emergency, the ED will assure notifications of the emergency have been given to the Illinois Emergency Management Agency (IEMA), Wisconsin Emergency Management, and the NRC Operations Center. The ED may delegate making the notification to others. Notification will be made to IEMA within 30 minutes and the NRC within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of declaring an emergency. Notification to IEMA should be made via the commercial telephone system. NRC notification should be accomplished using the NRC Event Notification System (ENS).

Wisconsin Emergency Management should be notified using commercial lines after notification is made to IEMA. However, this notification should not interfere with notifying the NRC. This notification may be made after the NRC is notified.

A designated member of management will be responsible for coordinating all public and corporate communications associated with a declared emergency.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 5.3 EMERGENCY RESPONSE ORGANIZATION ACTIONS The following is a general summary of the actions taken in response to an emergency:

• ISS recognizes off-normal condition, assesses its significance and assumes the role of ED.

• ED classifies the event and declares an ALERT.

• ED communicates the initiating conditions to On-Shift personnel.

• ED assesses danger to personnel and provides protective action guidance.

Establishes access controls to affected areas if radiological conditions require.

• On-site personnel respond as directed by ED.

• Required notification to IEMA is completed within 30 minutes of the declaration of emergency.

• Required notification to the NRC is completed within one hour of the declaration of emergency.

• ZionSolutions management is notified. The Augmented support is activated as detennined by the ED.

• Recovery actions are determined in accordance with E0-4, "Emergency Preparedness Implementation."

• ED deactivates Augmented ERO.

• The event is tenninated in accordance with E0-4, "Emergency Preparedness Implementation."

• ED deactivates ERO

• ED position is deactivated.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 5.4 RADIOLOGICALASSESSMENT Radiological assessment may be initiated upon classification of an emergency.

However, the only significant radiological consequences associated with the accident analyses in Chapter 12 of the NAC MAGNASTOR FSAR are associated with elevated dose rates caused by:

• A hypothetical VCC tip-over exposing the bottom of the cask that has limited shielding.

• VCC damage resulting from a design basis tornado induced missile that causes concrete to be removed from a small area on the VCC.

None of the NAC MAGNASTOR postulated accidents result in a loss of container confinement boundary, so a radiological release is not expected. Even if the confinement boundary was affected, the consequences to the public health and safety would be insignificant, as there is no driving force for a release of radioactive material.

As a result, radiological assessment and protective actions would be limited to the determination of dose rates in the area of an affected VCC, the establishment of controls to prevent personnel from entering the area, and to ensure that any recovery or repair activities are planned and executed in a manner that minimizes exposure.

5.4.1 Radiological Monitoring The level of monitoring activity will depend on the severity of the accident.

The ISS/ED has the responsibility to detennine the level of monitoring required, and to have radiation dose rate measurements taken as necessary. On-shift personnel will perforn1 radiation dose rate measurements as necessary.

Exposure of individuals performing emergency functions is consistent with the limits specified in facility procedures. Every attempt will be made to keep personnel exposure As Low As Reasonably Achievable (ALARA).

5.4.2 Radiological Exposure Control The ISS/ED is responsible for emergency radiological protection activities for facility staff and support personnel. The ISS/ED approves personnel exposure limits. When required by RP procedures or the ED, all emergency response personnel are issued a Thennoluminescent Dosimeter (TLD) subject to provisions contained in Emergency Operating Procedures. Emergency response personnel dose records will be based upon the results of TLD data, as soon as the TLDs can be processed.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT During an incident, higher than normal levels of radiation may be encountered.

Under all situations, steps will be taken to minimize radiation exposure.

Specific exposure guidelines for entry or re-entry into areas in order to remove injured persons (rescue operations) or undertake corrective actions will be in accordance with the guidance set forth in facility procedures. The ISS/ED will authorize emergency exposure limits or more restrictive limits, dependent upon incident conditions. Medical r.esponders and the ISS/ED will discuss the hazards involved in rescue operations prior to undertaking a rescue mission of this nature. The ISS/ED will administer emergency radiation exposure control.

Authorization to allow emergency response personnel to receive doses in excess of 10 CFR 20 limits shall be made only by the ISS/ED and only during declared emergencies. Considerations to be made prior to allowing personnel to accept risks associated with rescue operations or high dose missions are defined in facility procedures.

5.5 PROTECTIVE MEASURES 5 .5 .1 Accountability/Evacuation If determined to be necessary, the ED will initiate accountability of personnel.

All reports of initial and continuous accountability of personnel shall be provided to the ED.

In the unlikely event that the ED decides that an evacuation is needed, the ED will notify personnel of the need to evacuate. Individuals leaving the site and/or ISFSI area will go to the assembly area designated by the ED. Appropriate steps will be taken to locate any persons not accounted for.

Personnel remaining on-site or arriving on-site following an evacuation shall report to the ERF (ISFSI Monitoring Building), or alternate location as directed.

Accountability and evacuation are controlled by Procedure E0-4, "Emergency Preparedness Implementation."

5.5.2 Decontamination Capabilities Survey instrumentation for personnel frisking is available. Personnel contamination identified during the initial survey will require the contaminated individual to remove apparel, re-survey, and, if skin contamination is identified, perform decontamination as specified in Emergency Operating Procedures.

In the event that accident conditions result in a contaminated injured individual, the victim's rescue and medical treatment take precedence over the victim's radiation exposure due to bodily contamination. Gross decontamination of the victim (generally limited to the removal of contaminated articles of clothing) will be accomplished to the extent that the health of the patient is not affected..

Decontamination measures associated with wounds will be performed by the appropriately trained medical staff at the hospital under the supervision of the attending physician.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 5.5.3 Access Control Access control to the site and ISFSI area will be established at a location designated by the ED in an emergency.

5.5.4 Protective Equipment and Supplies Radiation dose survey and personnel contamination survey equipment is available. Surveys will be conducted as necessary to ensure that personnel responding to an emergency are provided appropriate protection. Recovery actions will not be performed until a comprehensive radiation survey, if required, is conducted.

2.1.1 Protective Equipment and Supplies Radiation dose survey and personnel contamination survey equipment is available. Surveys will be conducted as necessary to ensure that personnel responding to an emergency are provided appropriate protection. Recovery actions will not be performed until a comprehensive radiation survey, if required, is conducted.

5.6 FIRST AID AND MEDICAL Individuals trained in first aid will be available. Medical supplies are available at the ISFSI. The medical supplies are specified in E0-3, "Emergency Preparedness Administration" and accompanying job aids.

Injured persons requiring offsite medical care will be transported to the Vista Medical Center East for treatment. An-angements have been made with the City of Zion Fire and Rescue Department to provide emergency transportation for personnel requiring offsite medical treatment. Both the Vista Medical Center East and the City of Zion Fire and Rescue Department have personnel trained in radiation protection measures.

Personnel requiring offsite treatment may be transported to the hospital by ambulance or LLEA vehicle. Annual training is provided to:

• The City of Zion Fire and Rescue Depaiiment that encompasses transport of contaminated injured persons to the Vista Medical Center, including covering the individual to minimize fmiher spread of contamination; and

• The Vista Medical Center emergency room personnel with respect to minimizing the spread of contamination, establishment of a special area for treatment of the individual and dosimetry for emergency room personnel.

Decontamination of an injury would be performed by the medical staff under the direction of the attending physician. Further assistance with decontamination of the treatment room, transport vehicle and

• equipment/materials would be provided by augmented ERO RP personnel.

All actions of offsite responders will be coordinated by the ED.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 5.7 FIREFIGHTING Designated personnel will coordinate on-site activities with the Zion Fire and Rescue Department. Firefighting is implemented in accordance with the ISFSI Fire Protection Program.

5.8 TERMINATION In any emergency event, immediate response actions are directed toward limiting the consequences of the emergency in a manner that will afford maximum protection to on-site personnel. Once the immediate corrective and on-site protective actions have been implemented, and a stable and safe condition is established, deactivation of the emergency support personnel may be initiated. The ED will terminate the event and provide notification to on-site personnel and appropriate offsite authorities.

5.9 RECOVERY Additional corrective actions may be necessary to complete the recovery and return to normal activities. All re-ently and recovery actions will be preplanned and will be documented. Radiological or other hazard areas will be posted with warning signs indicating radiation levels or other hazards. Efforts shall be made to limit radiation exposure.

The ED has the authority and responsibility to initiate the re-entry and recovery actions. Once re-entry is initiated, a designated member of Management assumes control and directs recovery and corrective actions. The ED is then deactivated.

The decision to initiate re-entry shall be made by the ED, and the following prerequisites shall be considered:

• Personnel monitoring requirements are detern1ined.

• Portable radiation monitoring instruments are available, if needed.

• Communications are available.

• Radiological conditions are dete1111ined and are documented prior to entry.

• Habitability of evacuated areas is confirmed.

The designated member of Management will coordinate the restoration of the facility and has the authority to take the necessary actions to ensure the facility is returned to a safe condition. Recovery responsibilities include but are not limited to:

• Developing the recovery plan.

• Maintaining comprehensive hazard assessment of the facility.

• Prioritizing clean-up of affected areas and equipment.

• Isolating and repairing damaged equipment or systems.

• Documenting corrective actions taken related to recovery and the return to normal activities.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 6.0 FACILITIES AND EQUIPMENT 6.1 EMERGENCY FACILITIES 6.1.1 Emergency Response Facility (ERF)

During an emergency the ISFSI Monitoring Building is designated as the Emergency Response Facility (ERF). Emergency conditions are normally managed by the ED at this location. The ERF provides sufficient space to accommodate personnel and has communications systems and other necessary equipment available.

6.1.2 Assembly Areas Should an evacuation be necessary, personnel will be directed to report to a safe assembly area designated by the ED.

6.1.3 First Aid Supplies Emergency first aid equipment and supplies are located in the ERF and other locations specified in E0-3, "Emergency Preparedness Administration."

6.2 SYSTEMS, EQUIPMENT, AND ADVISORY SERVICES 6.2.1 Equipment Dedicated emergency equipment is located as designated in E0-3, "Emergency Preparedness Administration." Hospital emergency supplies are maintained at Vista Medical Center East.

Controlled copies of appropriate facility documents (drawings, procedures, Technical Specifications, FSAR, etc.) are available at the ERF.

6.2.2 Fire Detection and Protection The ISFSI Monit01ing Building is equipped with general occupancy smoke detectors, sprinklers, and p01iable fire extinguishers. Fires that cannot be extinguished by the installed sprinklers or by using portable fire extinguishers will be addressed by the City of Zion Fire and Rescue Department.

6.2.3 Meteorological Information General meteorological (wind speed and wind direction) information needed to deal with an emergency can be obtained using the internet.

The meteorological data from the nearby Waukegan National Airport is available on the internet and is representative of the site conditions.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 6.2.4 Offsite Advisories LLEA frequency radio can be monitored for local information and advisories.

NRC security advisories can be received at the ISFSI utilizing available communications systems.

6.3 COMMUNICATIONS 6.3.1 Commercial Telephone System The commercial telephone system is used to notify support personnel. It is also used as the primary method of alerting State entities of an emergency, and is the backup method to notify the NRC.

6.3.2 Portable Radios Two-way portable radios are available for communications on-site.

6.3.3 LLEA Frequency Radio The ISFSI is equipped with City of Zion Police Depaiiment Radios operating on the LLEA frequency. These radios maintain a direct and continuous communications capability between the ISFSI and the LLEA.

6.3.4 Illinois Emergency Management Agency (IEMA).

The commercial phone system is nonnally used to communicate with IEMA.

6.3.5 NRC Emergency Notification System (ENS)

The ENS is a dedicated telephone system used to notify the NRC Operations Center. The NRC will be notified immediately after State notifications and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of event classification or change in classification. In the event of failure of the ENS, commercial phone lines would be used to notify the NRC.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 7.0 ORGANIZATION AND RESPONSIBILITIES 7 .1 NORMAL ORGANIZATION The Zion Station ISFSI organization is directed by the ISFSI Manager, who is responsible for overall management of the Emergency Preparedness Program. On-Shift supervision is provided by an ISFSI Shift Supervisor (ISS), who manages the activities of the ISFSI Security staff, and reports to the ISFSI Manager. The ISFSI Manager is not nonnally part of the On-Shift ERO.

7.2 EMERGENCY RESPONSE ORGANIZATION (ERO)

The ERO consists of an On-Shift ERO and an Augmented ERO. The On-Shift ERO is the ED. The ED may elect to utilize any employees or contract personnel that may be on site at the time of the emergency. ISFSI personnel shall respond to emergencies per the requirements of the Security Plan and the needs of the emergency. Personnel not specifically trained as a member of the ERO will be given specific direction prior to being assigned any task.

The ED can utilize other resources and offsite support organizations (Fire Department, LLEA, and Medical Facilities) as needed to support the emergency response and recovery actions. The ED will provide personnel with appropriate instructions and assignments to ensure that assistance resources are used effectively.

Additional resources are expected to respond in a timely manner when contacted.

7.2.l On-Shift ERO Detection and recognition of conditions that wan:ant declaration of an emergency is the responsibility of the ISS. Upon declaration of an emergency, the ISS assumes the position of ED, assumes emergency response duties and implements the Emergency Plan.

The ED may delegate administrative duties to available personnel not otherwise involved with the emergency, including notifications to State, and Federal entities and ZionSolutions management. The ED has overall responsibility for the coordination of emergency response activities of the On-Shift and Augmented ERO.

The ED is responsible for directing all aspects of the response to an emergency.

Depending on the situation, the ED may either remain in the ERF or perform designated activities from another location.

At the direction of the ED, employees and contract personnel on site at the time of the emergency may be used to conduct actions to bring the facility to a stable condition. On-Shift ISFSI personnel are excluded unless the emergency involves an ISFSI Security Contingency Event which, by the ISFSI Security Plan, requires their action.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 7.2.2 Augmented ERO For an Emergency Classification of ALERT involving radiological consequences or at the discretion of ED, On-call support personnel can be activated. The goal of the On-call support personnel is to provide specialized technical or other support within four hours of being activated. The size and composition is determined by the ED. The On-call support personnel may provide suppo1i to the ED to assess radiological conditions, provide technical support, support maintenance and repair activities, develop plans to implement corrective actions, and assist with recovery actions.

Personnel may be assigned to perform activities such as the following, if required:

• Assessing the extent of damaged equipment.

• Identifying short and-long-term repair needs.

• Establishing repair priorities and deploying repair teams.

• Coordinating available resources to restore equipment and systems.

• Coordinating logistical needs.

• Performing radiological surveys and assessments.

• Coordinating news announcements with the EnergySolutions Corporate Communications.

• Facilitating communications with the NRC, IEMA, and other organizations.

• Assisting with recovery actions.

7.3 ON-SITE RESPONSIBILITIES 7 .3 .1 ISFSI Shift Supervisor (ISS)

The ISS is responsible for the detection and recognition of conditions that waiTant declaration of an emergency. Upon identification of an emergency, the ISS assumes the position of ED, assumes emergency response duties, declares the emergency and implements the Emergency Plan.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 7.3.2 Emergency Director (ED)

Actions the ED cannot delegate are:

• Classification of emergency.

• Authorization of radiation exposure in excess of 10 CFR 20 limits.

• Initiation of re-entry/recovery operations.

• Authorization of State and NRC notifications.

• Tennination of the event.

The primary responsibilities of the ED are:

• Direction of emergency response actions.

• Command and control of the ERO.

• Classification and notification.

• Assessment of radiological conditions.

• Authorization of on-site protective actions.

• Dete1mination of need for and requesting assistance.

• Implementation of Emergency Operation Procedures.

• Prioritization of emergency response actions.

• Periodic updates to State, and Federal entities.

• Mitigation of event.

• Interface with offsite agencies.

• Access control.

• Deactivation of emergency response personnel.

Although the On-Shift ISS will initially assume the position of ED, any ED qualified individual may be utilized to fulfill the positions duties and responsibilities.

7.4 CORPORATE SUPPORT Corporate support may be provided by the Licensee's corporate organization.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 7.5 LOCAL OFFSITE SUPPORT Arrangements have been made with local organizations to provide:

• LLEA support for security events.

• Firefighting and rescue services.

• Transportation of contaminated injured personnel.

• Hospital services for medical treatment of contaminated injured personnel.

Letters of Agreement for each organization, for local offsite support, are maintained on file and are listed in Appendix B.

7.6 STATE AND FEDERAL GOVERNMENT State and Federal government response is expected to be limited to documenting the notification of the emergency, periodically receiving updated information on the emergency, and coordinating public information news releases if necessary.

Investigations or inquiries may be commenced by State or Federal officials following an event.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT FIGURE 7.1 EMERGENCY RESPONSE ORGANIZATION Emergency Director ERO r--------- ---------,

I I I Local I Offsite Support I I I Augmented

• LLEA I I

ERO I I

• Fire Dep artment  :

I

• Ambulance I I

I

• Hospital 1 1 1------------------~

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 8.0 MAINTAINING EMERGENCY PREPAREDNESS 8.1 RESPONSIBILITIES The ISFSI Manager has overall responsibility for maintaining emergency preparedness and is responsible for ensuring adequate resources. The ISFSI Manager or designee is responsible for ensuring the following tasks and functions are completed:

• Maintenance of readiness of the ERF and equipment.

• Development and maintenance of the Emergency Plan.

• Development and maintenance of the implementing procedures.

• Training and qualification of ERO personnel.

• Conduct of drills and exercises.

• Monitoring effectiveness of and providing input to emergency preparedness training.

• Maintaining agreements with local offsite support services.

• Reviewing EALs with state and local government authorities on an annual basis.

in accordance with 10 CFR 50, Appendix E (IV)(B).

8.2 TRAINING Training will be implemented to provide the skills and knowledge necessary to maintain staff proficiency. Training will focus on non-routine and specialized activities that are particular to the individual functions and overall emergency response actions. Training may consist of, but not be limited to, classroom lecture, self-study, practical demonstrations, and facility drills.

8.2.1 Emergency Staff Training Each person specifically charged with ERO responsibilities will be provided initial and continuing training. This continuing training will be conducted during the calendar year. Continuing training addresses general changes to the Emergency Plan, facilities, equipment, regulations, policies, and specific changes to their responsibilities (which are not considered part of their routine duties). This training will also address problem areas identified during audits, drills, or exercises.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 8.2.2 Offsite Assistance Training Organizations which may be called upon to render assistance on-site will be offered general facility familiarization sessions on an annual basis. These sessions may include a walk down of the facility, safety, building layout, access protocol, communications capabilities, and security requirements.

8.3 DRILLS AND EXERCISES In addition to the training described earlier, the ISFSI staff will conduct drills to enhance skills and knowledge of the practical implementation of the Emergency plan and demonstrate the adequacy of emergency facilities, equipment, and implementing procedures. Drills allow interaction between evaluators and ERO personnel to reinforce requirements and overall process implementation. Drills will be scheduled with various objectives to demonstrate these capabilities. Some drills will focus on specific functions while others will involve a broader scope of the Emergency Plan.

Offsite support organizations (e.g., ambulance service, fire department, and LLEA) may be invited to participate in drills.

8.3.1 Drills In addition to training drills discussed above, the following drills will be conducted annually:

• Radiation Monitoring Drill - demonstrating conduct of general area surveys.

• Medical Emergency Drill - demonstrating the capability for transporting a contaminated injured worker offsite.

• Fire Drill - conducted in accordance with the Fire Protection Program.

8.3.2 Exercise An exercise will be conducted biennially to demonstrate the capability to implement the Emergency Plan. Objectives will be developed to ensure major elements of the Emergency Plan are perfomrnd and evaluated to ensure the appropriate level of preparedness is being maintained. -

Offsite response organizations must be invited to participate in or observe the exercise.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT 8.3.3 Drill and Exercise Evaluation Facility staff will evaluate the exercise and drills. Expectations for evaluators will be discussed with each evaluator prior to the drill/exercise. Evaluators should be assigned to evaluate functions or areas consistent with their expertise.

Following the drill/exercise a critique of the evolution will be conducted and any identified deficiencies will be corrected through retraining, remedial drills, or by other means. Comment resolution will be assigned to responsible personnel for final implementation.

8.4 REVIEW AND UPDATE OF EMERGENCY PLAN, EAL BASIS DOCUMENT, AND EMERGENCY OPERATION PROCEDURES 8.4.1 Emergency Plan This plan, including written agreements between the site and other organizations, will be reviewed annually. Approved changes to the plan will be incorporated into the appropriate implementing procedures along with the plan changes. Letters of Agreement will be reviewed annually and verified to be in effect at the time of the plan review. This may be accomplished via written communication or documented telephone conversation.

This is a controlled document to ensure changes are incorporated into distributed copies. Plan changes will be approved by the ISFSI Manager.

8.4.2 EAL Basis Document The EAL Basis Document will be reviewed annually. The controls associated with the maintenance of this document are the same as established for EOs.

8.4.3 Emergency Operation Procedures (EOs)

Procedures which implement the Emergency Plan will be reviewed, revised and distributed in accordance with procedure and document control requirements.

Revisions will be made whenever a plan change is made that affects the procedure, or other circumstances dictate a revision is necessary. EOs will be approved by the ISFSI Manager.

8.5 PERIODIC SURVEILLANCE Facilities and equipment will be maintained in accordance with E0-3, "Emergency Preparedness Administration." Inventories of Emergency Plan kits and supplies will be conducted on a semi-annual basis and after Emergency Plan implementation (either by actual event or drill activity).

A list of telephone numbers that are important to emergency notification is verified on a semi-annual basis.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT Commercial communication lines with IEMA will be verified semiannually. The dedicated NRC ENS system will be tested monthly.

8.6 INDEPENDENT REVIEW All Emergency Plan program elements shall be reviewed by persons having no direct responsibility for the implementation of the Emergency Plan at least once every 12 months to satisfy the requirements of 10 CFR 50.54(t). An independent audit covering all program elements satisfies this requirement.

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Zion Station ISFSI Emergency Plan Revision 0 DRAFT APPENDIX A DEFINITIONS, ABBREVIATIONS AND ACRONYMS 1.0 DEFINITIONS Actions

• Assessment Actions - Actions taken during or after an incident to obtain and process information that is necessary to make decisions to implement specific emergency measures.

• Corrective Actions -Actions taken to make improvements.

• Emergency Actions - Actions taken to improve or terminate an emergency situation.

• Protective Actions -Actions taken to avoid or reduce radiological exposure to personnel.

• Recovery Actions - Actions taken after an emergency to restore the facility to pre-emergency condition.

• Airborne Radioactivity -Any particulate radioactive material dispersed in the air.

• Alert - Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the ISFSI.

• Confinement Boundary - The confinement boundary of the canister consists of the Transpmiable Storage Canister cylindrical shell, bottom plate, closure lid, and vent and drain port covers.

• Contamination (Radioactive) - Radioactive material in any place where it is unwanted (e.g., on persons, places, or things).

• Controlled Area - The area, as defined in 10 CFR 72.3, which immediately smTounds the ISFSI for which the license exercises authority over its use and within which ISFSI operations are perfonned. The Licensee shall exclude access to the ISFSI Controlled Area if adverse radiological conditions require.

• Decontamination - The reduction or removal of contaminating radioactive material from a person, area, or object by cleaning or washing.

• Emergency Action Level (EAL) -A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the site in a given emergency classification level. 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.

APPENDIX A-1

Zion Station ISFSI Emergency Plan Revision 0 DRAFT

• Emergency Response Organization (ERO) - The organization responsible under emergency conditions.

• Emergency Director (ED) -The person in charge during an emergency.

• Initiating Condition - An event where either the potential exists for a radiological or security emergency, or an event where such an emergency has occurred.

• Independent Spent Fuel Storage Installation (ISFSI) - The facility designed and constructed to provide on-site dry storage of spent fuel.

• MAGNASTOR System - The NAC International, Inc. Modular Advanced Generation Nuclear All-purpose Storage system which is being used for dry cask storage of spent fuel and GTCC waste at the ISFSI.

• Normal Levels - Nonnal levels can be considered as the highest reading in the past twenty- four hours excluding the current peak value.

• ODCM/RETS -This te1m is used to identify the specific section (RETS) of the controlling document (ODCM). RETS is Chapter 12 of the ODCM and contains values necessary to quantify limits set within certain Emergency Action Level Threshold Values.

• Protective Action Guides (PA Gs) - Guidelines provided by the EPA regarding projected absorbed dose to individuals in the general population, which warrant protective action.

• Radiological Restricted Area (RRA) - An area, access to which is limited for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.

• Site Boundary - The line beyond which the land is not owned, leased, or otherwise controlled by the licensee.

• Transportable Storage Canister - The stainless steel canister that provides containment for the spent fuel. The loaded Transportable Storage Canisters are placed inside of the VCCs for on-site dry storage.

• Unplanned - A parameter change or an event that is not the result of an intended evolution and requires corrective or mitigative actions.

• Valid - An indication, repo1i or condition, is considered to be Valid when it is verified by (1) an instrument response check, or (2) indications on related or redundant indicators, or (3) by direct observation by site personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed.

Implicit in this definition is the need for timely assessment.

• Vertical Concrete Cask (VCC) - The cask positioned on the ISFSI pad that contains the Transportable Storage Canister used to store spent fuel.

APPENDIX A-2

Zion Station ISFSI Emergency Plan Revision 0 DRAFT 2.0 ABBREVIATIONS AND ACRONYMS ALARA As Low As Reasonably Achievable CFR Code of Federal Regulations EAL Emergency Action Level ED Emergency Director ERF Emergency Response Facility ERO Emergency Response Organization IEMA Illinois Emergency Management Agency ISFSI Independent Spent Fuel Storage Installation ISS ISFSI Shift Supervisor LLEA Local Law Enforcement Agency mrem/hr millirem (1/1000 rem) per hour NRC Nuclear Regulatory Commission ODCM/RETs Offsite Dose Calculation Manual/Radiological Effluent Technical Standards Rem Roentgen Equivalent Man - A measure of biological damage caused by radiation exposure TLD The1mo Luminescent Dosimeter VCC Vertical Concrete Cask ZS ZionSolutions, LLC APPENDIX A-3

Zion Station ISFSI Emergency Plan Revision 0 DRAFT APPENDIXB LETTERS OF AGREEMENT This appendix lists the letters of agreement in effect between ZionSolutions and offsite authorities and support organizations. These agreements are reviewed annually. Signed copies of these agreements are maintained by the ISFSI Manager and are available upon request.

Organizations City of Zion

• Fire and Rescue Department

• Police Department Vista Medical Center East APPENDIX B-1

Zion Station ISFSI Emergency Plan Revision 0 DRAFT APPENDIXC EMERGENCY PLAN PROCEDURES The following Emergency Plan Procedures implement the requirements specified in this plan.

EONo.

E0-1 Response to Analyzed Events at the ISFSI E0-2 Handling Medical Situations and Spills at the ISFSI E0-3 Emergency Preparedness Administration E0-4 Emergency Preparedness Implementation E0-7 NRC Notification Requirements APPENDIX C-1

ATTACHMENT 3 Revised ISFSI E,mergency Plan Emergency Action Level Basis Document

ISFSI Emergency Plan Emergency Action Level Basis Document Revision 0 DRAFT E-HUl (ISFSI)

ECL: ALERT Initiating Condition (IC): Damage to a loaded cask CONFINEMENT BOUNDARY.

Emergency Action Level Threshold Values:

(1) Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than two times the NAC Certificate of Compliance, Appendix A, Technical Specification limits ofLCO 3.3.1 on the surface of the Vertical Concrete Cask.

Basis:

This Initiating Condition (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 issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

Calculated Values (Two times the NAC Certificate of Compliance, Appendix A, Technical Specification limits of LCO 3 .3 .1)

> 190 mrem/hr gamma on vertical surface

-OR-

> 10 mrem/hr neutron on vertical surface

-OR-

> 900 mrem/hr (neutron + gamma) on the top Changes to these values will not be considered a reduction in effectiveness if the NAC C of C Technical Specification limits have been changed.

The existence of "damage" is determined by radiological survey. The 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 IC PD-HUl (ALERT).

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ISFSI Emergency Plan Emergency Action Level Basis Document Revision 0 DRAFT PD-HUl (ISFSI)

ECL:ALERT Initiating Condition: Confirmed SECURITY CONDITION or threat.

Emergency Action Level Threshold Values: (I or 2)

(1) Confirmed ISFSI Physical Security Plan SECURITY CONTINGENCY EVENT that results in the LLEA being requested to respond to the ISFSI.

(2) Notification of a credible threat to the site, reported by the NRC or other recognized off site agency, that presents a risk to site personnel, a potential degradation to the level of safety at the site or a security threat to the ISFSI.

Basis:

This IC addresses events that pose a threat to site personnel or the ISFSI, and thus represents a potential degradation in the level of safety.

Security events which do not meet one of these EALs are adequately addressed by the requirements of IO CFR § 73.7I or IO CFR § 50.72.

Classification of these events will initiate appropriate threat-related notifications to site and ISFSI personnel and offsite organizations.

Security plans and terminology are based on the guidance provided by NEI 03-I2, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

EAL #I addresses threats to the ISFSI requiring assistance from the LLEA. These threats are discussed in detail in the ISFSI Physical Security Plan.

EAL #2 addresses the receipt of a credible threat that presents a risk to personnel or degradation of safety at the site. The threat is assumed to be credible if rep01ied by the NRC or other recognized off site organization. ZionSolutions has chosen to use the EAL Threshold Values that would normally be associated with Recognition Category Code PD-HUI, Unusual Event to initiate an Emergency Classification of ALERT. This is consistent with the requirement set forth in IO CFR 72.32(a)(3), Classification of accidents, to have a classification system for classifying accidents as "alerts." This change in classification of PD-HUI provides the site, State and NRC with conservative notification of actions and/or activities that could have a security related impact on the ISFSI. This use of PD-HU3 makes it unnecessary to have a Recognition Category Code of PD-HA3 for the ISFSI since other requirements specify that if any of the Security Contingency Event conditions in the ISFSI Physical Security Plan were to escalate, the proper notifications to State and Federal Agencies would be made.

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ISFSI Emergency Plan Emergency Action Level Basis Document Revision 0 DRAFT Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan.

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ISFSI Emergency Plan Emergency Action Level Basis Document Revision 0 DRAFT PD-HU3 (ISFSI)

ECL: ALERT Although the use of Recognition Category Code PD-HU3 is associated with Unusual Event, ZionSolutions is also using it and the associate EAL Threshold Values in Table 4.2, "ISFSI Emergency Events", to designate ECL of ALERT for the ISFSI. Refer to the Basis for the explanation and justification Initiating Condition: Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT at the ISFSI.

Emergency Action Level Threshold Values:

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 at the site or ISFSI. No releases ofradioactive material requiring offsite response or monitoring are expected.

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.

ZionSolutions has chosen to use the EAL Threshold Values that would normally be associated with Recognition Category Code PD-HU3, Unusual Event to initiate an Emergency Classification of ALERT. This is consistent with the requirement set forth in 10 CFR 72.32(a)(3), Classification of accidents, to have a classification system for classifying accidents as "alerts." This use of PD-HU3 makes it unnecessary to have a Recognition Category Code of PD-HA3 for the ISFSI.

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