View source for M200031, GEH - NRC Request for Additional Information License Amendment Request for the Vnc Radiological Emergency Plan

{{Adams
| number = ML20058G800
| issue date = 02/27/2020
| title = GEH - NRC Request for Additional Information License Amendment Request for the Vnc Radiological Emergency Plan
| author name = 
| author affiliation = GE-Hitachi Nuclear Energy Americas, LLC
| addressee name = 
| addressee affiliation = NRC/NMSS, NRC/NRR
| docket = 05000018, 05000073, 05000183
| license number = DPR-001, DR-10, R-033, TR-1
| contact person = 
| case reference number = EPID L-2019-LLA-0159, M200031
| package number = ML20058G787
| document type = Response to Request for Additional Information (RAI)
| page count = 62
| project = EPID:L-2019-LLA-0159
| stage = Request
}}

=Text=
{{#Wiki_filter:US NRC February 27, 2020                          Security and Proprietary Related Information M200031                              Withhold from Public Disclosure Pursuant to 10 CFR 2.390 Page 1 of 7 Attachment 4 NRC Request for Additional Information RE:
License Amendment Request for the VNC Radiological Emergency Plan (EPID L-2019-LLA-0159)
GEH Responses Dated 02/27/20 GEH RAI-1 Section 3.3, Off-Site Support Organization Descriptions, of Attachment 2, Reduction in Effectiveness Evaluation, of the application states, in part, The proposed REP describes the off-site support organizations VNC maintains written agreements with, but does not specify the name or the location of those off-site support organizations. It further states, The removal of specific names of organizations will require fewer changes when the agreements are changed.
RG 2.6, Revisions 1 and 2, states, The plan should not incorporate details that may routinely change (e.g., names and telephone numbers, specific items of equipment and supplies, inventory lists, and step-by-step procedures or checklists that may be altered as a result of experience or test exercises). These details are useful, but are better maintained in the facilitys implementing emergency procedures.
However, RG 2.6, Revision 1, states, Supporting organizations that would augment the licensees emergency organization, e.g., fire department, hospitals, and security organizations, should be specified.
Update the GEH REP to specify the supporting organizations that would augment the licensees emergency organization or provide a justification why the specific facilities do not need to be specified.
GEH RAI-1 Response The GEH REP has been updated to specify the supporting organizations that provide response services to VNC as follows:
Submitted Emergency Plan                               February 2020 VNC Emergency Plan 3.3 Off-Site Support Organizations                     3.3 Off-Site Support Organizations Certain supporting services that may be needed         Certain supporting services that may be needed during or after a radiological emergency are           during or after a radiological emergency are available from local off-site organizations.           available from local off-site organizations.
These services are described below.                    These services are described below. Refer to Section 10.2.2, Review and Update, for a current list of MOUs with off-site support organizations.

US NRC February 27, 2020                        Security and Proprietary Related Information M200031                           Withhold from Public Disclosure Pursuant to 10 CFR 2.390 Page 2 of 7 Submitted Emergency Plan                              February 2020 VNC Emergency Plan 10.2.2 Review and Update                              10.2.2 Review and Update
[paragraph 2]                                         [paragraph 2]
Agreements with supporting organizations will be      Agreements with supporting organizations will be reviewed on a biennial basis, and updated if          reviewed on a biennial basis, and updated if necessary. Changes to agreements may be               necessary. Changes to agreements may be coordinated with the biennial review of the           coordinated with the biennial review of the Emergency Plan.                                       Emergency Plan. VNC maintains the following support agreements:
: 1. ((                              )) - Applicable to Sections 3.3.1, First Aid Assistance, and 3.3.3, Ambulance Service
: 2. [
                                                             ]-Pleasanton Areas - Applicable to Section 3.3.2, Medical Treatment Facilities
: 3. ((                                        )) -
Applicable to Section 3.3.4, Firefighting Assistance
: 4. ((                                      )) -
Applicable to Section 3.3.5, Police Assistance LAR Attachment 2 has been revised to delete content related to Reduction in Effectiveness (RIE) #3 requesting approval to remove names and locations of off-site support organizations VNC maintains written agreements with.
GEH RAI-2 By application dated July 17, 2019, GEH requested an exemption from the requirement of Appendix E.IV.D.3 to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, regarding the 15-minute notification of state agencies.
The NRC staff finds that an exemption is not required because in this specific section of the regulations, the intent is not applicable to non-power reactors. As provided in the statements of consideration for the revision to the emergency planning regulations, the purpose of the 15-minute notification is to ensure prompt notification of the public within the plume exposure pathway emergency planning zone for power reactors (see 44 Federal Register (FR) 75173; December 19, 1979 and 45 FR 55407; August 19, 1980).
There are no other specific time requirements in Appendix E to 10 CFR Part 50 for notification of the NRC, State and local agencies. The one-hour notification is acceptable to the NRC staff for the GEH Nuclear Test Reactor and is consistent with other regulations for other NRC non-power reactor licensees that are required to have emergency plans.
Update the LAR to rescind (or omit) the requested exemption or further explain why GEH still requests an exemption to Appendix E.IV.D.3 to 10 CFR Part 50.

US NRC February 27, 2020                          Security and Proprietary Related Information M200031                            Withhold from Public Disclosure Pursuant to 10 CFR 2.390 Page 3 of 7 GEH RAI-2 Response LAR Attachment 2 has been revised to delete content Reduction in Effectiveness (RIE) #5 requesting exemption to Appendix E.IV.D.3 to 10 CFR Part 50 related to the 15 minute state and local agency notification requirement.
GEH RAI-3 Section 7.4.4, Emergency Exposure Control and Guidelines, of the proposed Vallecitos Nuclear Center (VNC) REP references an earlier version of the EPA PAG Manual. The latest version of the EPA PAG Manual is U.S. Environmental Protection Agency, EPA 400/R-17/001, PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents, January-2017 (ADAMS Accession No. ML17044A073).
Update the VNC REP to reflect the latest version of the EPA PAG Manual or explain why referencing the current version of the EPA PAG manual is not necessary.
GEH RAI-3 Response The VNC REP Section 7.4.4 reference and information regarding emergency exposure guidelines for emergency workers has been updated to EPA 400-R-17-001 as follows:
Emergency exposure guidelines for emergency workers, consistent with EPA 400-R         001, PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents, Table 3-1, "Emergency Worker Guidelines," have been established as follows:
Guideline                       Activity                                 Condition 5 rem       All occupational exposures                 All reasonably achievable actions have been taken to minimize dose.
10 rema       Protecting critical infrastructure         Exceeding 5 rem unavoidable and all necessary for public welfare (e.g., a      appropriate actions taken to reduce power plant)                               dose.
Monitoring available to project or measure dose.
25 rem       Lifesaving or protection of large          Exceeding 5 rem unavoidable and all populations                                appropriate actions taken to reduce dose.
Monitoring available to project or measure dose.
            >25 rem       Lifesaving or protection of large          All conditions above and only for populations                                people fully aware of the risks involved.
a   For potential doses >5 rem (50 mSv), medical monitoring programs should be considered.
Additional Changes to the VNC REP Change #1 Submitted Emergency Plan                                 February 2020 VNC Emergency Plan 3.3.1   First Aid Assistance                             3.3.1  First Aid Assistance First aid assistance is available through the           First aid assistance is available through the Alameda County Office of Emergency                      Alameda County Emergency Services I                   -     -_
Services Ddispatcher (911).                             Dispatch (911).

US NRC February 27, 2020                            Security and Proprietary Related Information M200031                              Withhold from Public Disclosure Pursuant to 10 CFR 2.390 Page 4 of 7 Submitted Emergency Plan                                  February 2020 VNC Emergency Plan 3.3.3 Ambulance Service                                  3.3.3 Ambulance Service Ambulance service is available through                  Ambulance service is available through the Alameda County Office of Emergency                  the Alameda County Emergency Services Services Ddispatcher (911).                             Dispatch (911).
3.3.4    Firefighting Assistance                         3.3.4   Firefighting Assistance When needed, a request for firefighting                 When needed, a request for firefighting assistance will be made through the                     assistance will be made through the Alameda County Office of Emergency                      Alameda County Emergency Services Services Ddispatcher (911).                             Dispatch (911).
The proposed changes correct wording in the emergency plan that no longer reflects the name of the off-site response organization which is the public safety answering point for the region.
Change #2 Submitted Emergency Plan                                  February 2020 VNC Emergency Plan 3.3.4 Firefighting Assistance                             3.3.4 Firefighting Assistance
[paragraph 2]                                           [paragraph 2]
Assistance for VNC is provided by the                   The first arriving responders at VNC may participants in the California Fire Service             come from the closest fire station in Sunol.
and Rescue Emergency Mutual Aid Plan.                   If additional assistance is needed, the fire Typically, the primary response will be from            incident commander will make the request Alameda County Fire Services. If additional             for additional resources through ACFD.
assistance beyond the county capability is needed, personnel and equipment are requested through the California Department of Forestry & Fire Protection (CDF).
The proposed change revises the description of the off-site firefighting organization process.
While performing a review of off-site assistance agencies described in the VNC REP, it was recognized that the depiction of the relationships of the off-site organizations involved in firefighting assistance was not consistent with the current state at the organizations. No actual change in fire support response is made with this description revision. Support capability and response timeliness has not changed.
Change #3 Submitted Emergency Plan                                  February 2020 VNC Emergency Plan 5.1 Unusual Event                                         5.1 Unusual Event RU3                                                      RU3 Radiological effluent level (Ci/cc) meet any of         Radiological effluent level (Ci/cc) meet any of the following:                                           the following for greater than 60 minutes:
      > 2.4E-8 NTR Noble Gas Stack Monitor                    > 2.4E-5 NTR Noble Gas Stack Monitor

US NRC February 27, 2020                          Security and Proprietary Related Information M200031                             Withhold from Public Disclosure Pursuant to 10 CFR 2.390 Page 5 of 7 Submitted Emergency Plan                                February 2020 VNC Emergency Plan 5.2 Alert                                               5.2 Alert RA3                                                    RA3 Radiological effluent level (Ci/cc) meet any of       Radiological effluent level (Ci/cc) meet any of the following:                                         the following for greater than 60 minutes:
      > 1.2E-7 NTR Noble Gas Stack Monitor                  > 1.2E-4 NTR Noble Gas Stack Monitor Appendix 3 - EAL Technical Bases for Effluent           Appendix 3 - EAL Technical Bases for Effluent Releases                                                Releases
[Calculation table 10 CFR 20 limit for unknown          [Calculation table 10 CFR 20 limit for unknown activity 1E-15 Ci/cc]                                  activity 1E-12 Ci/cc]
The proposed change uses a different 10 CFR 20 limit as the underlying basis for the NTR effluent monitor EAL threshold and specifies the duration required for the indication to meet the emergency classification level.
10 CFR 20 Appendix B Table 2, Effluent Concentrations, provides three column 1 air limits for unknown (unlisted) nuclide activity.
The submitted emergency plan NTR Noble Gas Stack Monitor EAL thresholds were developed using the most conservative of the three 10 CFR 20 Appendix B Table 2 limits, which represents an unknown (unlisted) radionuclide that decays by alpha emission or spontaneous fission (1E-15 Ci/cc). The most conservative of the three limits was selected based on the SAR Section 13.6, Experiment Design Basis Accident, using Pu-239 as the experiment material.
While an experiment using Pu-239 is the most radiologically severe of the NTR design basis accidents, it uses extremely conservative assumptions to demonstrate that a worse case accident remains below federal design limits. These types of experiments are no longer conducted at NTR. Use of the unknown (unlisted) radionuclide limit for this type of event is overly conservative and results in threshold values significantly below the operational alarm setpoint for Offsite Dose Calculation Manual (OCDM) releases. The operational noble gas alarm setpoint is based on the 10 CFR 20 Appendix B Table 2 Ar-41 limit, and is currently set to 9.5E-5 Ci/cc.
This change proposes to update the NTR Noble Gas Stack Monitor EAL threshold basis using the 10 CFR 20 Appendix B Table 2 limit for a radionuclide with decay mode other than alpha emission or spontaneous fission and with radioactive half-life greater than 2 hours (1E-12 Ci/cc). Using the middle value of the 10 CFR 20 Appendix B Table 2 unknown (unlisted) radionuclide limits is more representative of a wide spectrum of NTR accident events and results in EAL thresholds near the current alarm setpoint for ODCM operational releases.
The 10 CFR 20 Appendix B Table 2 Ar-41 limit was not used as a basis for the NTR Noble Gas Stack Monitor EAL thresholds as it does not represent of a wide spectrum of NTR accident events.
The proposed EAL threshold wording was also clarified to specify that the release occur for greater than 60 minutes as the calculated concentration must be present for that period of time to meet the 10 CFR 20 annual dose exposure limit. This clarification will prevent misclassification of emergencies when a momentary or short duration release occurs, but remains within ODCM limits or technical specifications.

US NRC February 27, 2020                            Security and Proprietary Related Information M200031                                Withhold from Public Disclosure Pursuant to 10 CFR 2.390 Page 6 of 7 Change #4 Submitted Emergency Plan                                  February 2020 VNC Emergency Plan 5.1.3    RU3 Technical Basis                              5.1.3    RU3 Technical Basis NTR Vent Stack Noble Gas Monitor                          NTR Vent Stack Noble Gas Monitor instrument range is 2E-11 to 2E-04                        instrument range is 1E-06 to 1E+01 NTR Vent Stack Particulate Monitor                        NTR Vent Stack Particulate Monitor instrument range is 1E-07 to 1E+01                        instrument range is 2E-11 to 2E-04 5.2.3    RA3 Technical Basis                              5.2.3    RA3 Technical Basis NTR Vent Stack Noble Gas Monitor                          NTR Vent Stack Noble Gas Monitor instrument range is 2E-11 to 2E-04                        instrument range is 1E-06 to 1E+01 NTR Vent Stack Particulate Monitor                        NTR Vent Stack Particulate Monitor instrument range is 1E-07 to 1E+01                        instrument range is 2E-11 to 2E-04 This proposed change corrects a transposition error of the NTR monitor instrument ranges and a value error for the lower range value of the gas monitor.
The corrections are editorial as the information is provided to document that the NTR vent stack monitor EAL threshold values are within the observable range of their associated instruments, not for other decision making or commitment related purposes.
Change #5 Submitted Emergency Plan                                  February 2020 VNC Emergency Plan 8.2 Assessment Facilities                                 8.2 Assessment Facilities Other monitoring devices are utilized to identify         Other monitoring devices are utilized to identify off-normal conditions, such as smoke detectors,           off-normal conditions, such as smoke detectors, criticality, fire and flood alarms, and onsite and        fire and flood alarms, and on-site and off-site offsite seismic and meteorological indicators.            seismic and meteorological indicators. Several Several of these devices activate alarms locally          of these devices activate alarms locally and/or and/or in the ((           )) for immediate               in the ((        )) for immediate response and response and assessment.                                  assessment.
The proposed change removes criticality from the monitoring devices.
While performing a review of equipment and facilities described in the VNC REP, it was recognized that the criticality alarm is no longer applicable. SNM-960 safety condition S-5(b) allows for an exemption to the VNC criticality monitoring system requirements if an evaluation has determined the risk of a criticality is very low. NRC staff discussed this exemption in Section 5.2.3 of their renewal safety evaluation dated August 9, 2017. As a result, there is no need to maintain a VNC criticality accident alarm system (CAAS). CAAS accident alarm requirements in 10 CFR 70.24 do not apply to the NTR.
Change #6

US NRC February 27, 2020                           Security and Proprietary Related Information M200031                              Withhold from Public Disclosure Pursuant to 10 CFR 2.390 Page 7 of 7 Submitted Emergency Plan                                February 2020 VNC Emergency Plan 8.2 Assessment Facilities                               8.2 Assessment Facilities Portable survey and personnel monitoring                Portable survey and personnel monitoring instruments are maintained throughout the site          instruments are maintained throughout the site and are available for use during an emergency.          and are available for use during an emergency.
Sampling equipment and counting laboratories            Sampling equipment and a counting laboratory are available on site for specific radionuclide         are available on site and off site for specific identification and analysis.                            radionuclide identification and analysis.
The proposed change corrects wording in the emergency plan that describes both on site and off site lab capabilities.
While performing a review of equipment and facilities described in the VNC REP, it was recognized that there is only one counting laboratory on site. The REP statement appears to be in error in that no documents could be found to indicate that a count laboratory other than the one in Building 103 was maintained on site.
As needed, VNC utilizes off site laboratories capable of performing specific radionuclide identification and analysis of gas and particulate samples.
Change #7 Submitted Emergency Plan                                February 2020 VNC Emergency Plan 8.3 First Aid and Medical Facilities                    8.3 First Aid and Decontamination Equipment The site contains numerous areas where                  The site contains numerous areas where radioactive materials are used. Consequently,           radioactive materials are used. Consequently, there are numerous areas where contaminated             there are numerous areas where contaminated injured individuals may be relocated for first aid      injured individuals may be relocated for first aid administration and decontamination. On site             administration and decontamination. On site company vehicles are available for                      company vehicles are available for transportation.                                         transportation.
First aid supplies, stretchers, and industrial          First aid supplies, stretchers, industrial showers showers are located around the site.                    and AEDs are available at the site.
The proposed change of Section 8.3 accurately reflects the medical equipment and decontamination capability at the site and clarifies there is no formal medical facility.
Change #8 Added the list of emergency plan implementing procedures to Appendix 2.
The list of emergency plan implementing procedures, which is not available at the time of initial submittal, has been determined and added to Appendix 2 of the VNC REP.

Attachment 5 Reduction in Effectiveness Evaluation Page 1 of 9 Reduction in Effectiveness Evaluation 1.0    

==SUMMARY==
DESCRIPTION Pursuant to 10 CFR 50.90 and 10 CFR 50.54(q), GE Hitachi (GEH) Vallecitos Nuclear Center (VNC) requests an amendment to the license for the Nuclear Test Reactor (NTR)
R-33. Specifically, the changes would revise the test reactor's license in order to adopt the proposed Radiological Emergency Plan (REP) updated to conform to the current guidance contained in Regulatory Guide 2.6. The proposed REP establishes an updated licensing basis for the NTR (that covers the SAFSTOR reactor facilities that utilize the NTR REP), and complies with current NRC regulations in 10 CFR 50.34(b)(6)(v), 10 CFR 50 Appendix E, 10 CFR 50.54(q), and the guidance in the NRC-endorsed ANSI/ANS-15.16-2015, with several exceptions.
VNC has developed a REP based specifically upon ANSI/ANS-15.16-2015 planning standards, and organized such that each criterion (also called a planning element) is explicitly stated, followed by a description of how the VNC emergency preparedness program will address that criterion.
The proposed REP provides the basis for response actions that would be implemented in an emergency and the requirements for maintenance and administration of the VNC emergency preparedness program.
In addition to the alignment of the REP to the most current requirements and guidance, this update of the REP will provide program improvements to the classification and notification functions and clarification of emergency response organization (ERO) response requirements.
2.0    DETAILED DESCRIPTION 2.1    Proposed Changes The proposed REP was developed based upon the latest requirements and guidance contained in 10 CFR 50 Appendix E, ANSI/ANS-15.16-2015 and the existing commitments within the NTR REP as approved by the NRC, with several exceptions.
Additionally, this change involves the removal of the Site Area Emergency classification level and revision of the Emergency Action Levels (EALs), by adoption of the current ANSI/ANS-15.16-2015 EAL scheme into site specific thresholds, and documentation of their technical bases.
Changes in the proposed REP that could be considered a reduction in effectiveness from ANSI/ANS-15.16-2015 or the current REP have been identified in this document as RIE. Detailed justification is provided for these RIEs in Section 3, Technical Evaluation, to demonstrate that the proposed REP continues to provide for an adequate response to radiological emergencies.
Page 2 of 9 Reduction in Effectiveness Evaluation 2.2    Proposed Radiological Emergency Plan Deviations Summary The results of the comparison between; (1) the proposed REP and the current REP, and (2) the proposed REP and NUREG-0849 criterion, revealed the following changes that could be considered reductions in effectiveness, and therefore are evaluated in detail in Section 3.0.
[RIE 1] VNC Non-Part 50 Special Nuclear Material (SNM) Section 3.1 facilities have been removed from the scope of the proposed REP.
[RIE 2] The Emergency Director is no longer required to          Section 3.2 be on site 24/7 in the proposed REP.
[RIE 3] The Site Area Emergency classification level has         Section 3.3 been removed from the proposed REP.
2.3    Reason for the Proposed Changes The REP was originally based upon ANSI/ANS-15.16-1982. ANSI/ANS-15.16-2008 was issued to align with changes to 10 CFR 20, Standards for Protection Against Radiation.
In 2014, ANSI/ANS-15.16-2008 was revised to incorporate security-related events into the emergency plan in a risk-informed way. Because of the low inventory of radioactive material, most research and test reactors do not meet the threshold levels that initiate either a General Emergency or a Site Area Emergency. In fact, many do not meet the threshold for an Alert classification. As such, the revisions to ANSI/ANS-15.16 ensured that security-related events were incorporated into emergency plans without creating emergency classifications that did not or would not otherwise exist.
The reasons for the revision to the VNC REP are as follows:
(1) Update the REP to the current format and planning standards contained in ANSI/ANS-15.16-2015, to the level of detail specified in the NUREG-0849 standard review plan.
(2) Relax the requirement for an on-site Emergency Director to allow their absence when NTR and SAFSTOR reactor facility operations are not in progress.
(3) Revise the REP EALs to conform to the initiating conditions contained in ANSI/ANS-15.16-2015 and develop a site specific technical basis for each threshold indication, which removes the Site Area Emergency classification level at VNC.
(4) Specify the state notification requirement as 60 minutes. The REP currently does not specify a notification time requirement.
By updating the REP, VNC will restore alignment to the most current NRC requirements and guidance. Additionally, it will provide relief from current staffing, response and administrative commitments in closer alignment with the needs of a low power test reactor facility.
Page 3 of 9 Reduction in Effectiveness Evaluation 2.4    NTR Radiological Emergency Plan Background 2.4.1  September 1984: First NRC approved NTR REP implemented at VNC.
2.4.2  August 1992: NRC approves January 1992 revision of NTR REP that removes references to SNM-960 non-reactor and SAFSTOR reactor facilities.
2.4.3  April 2001: As part of NTR Amendment No 21 (2001 License Renewal) the NRC reviewed the REP dated March 1996 and concluded that it maintained acceptable compliance with applicable portions of Appendix E to 10 CFR Part 50 and that it provides acceptable assurance that the licensee continues to be prepared to assess and respond to emergency events.
This revision is considered the latest NRC approved NTR REP (supersedes the 1984 approved version and the subsequent changes made prior the March 1996 revision).
2.4.4  January 2013: The availability of the Emergency Operations Coordinator (EOC), now titled Emergency Director, was changed from a three-shift-per-day, seven-day-per-week schedule statement to a five-day-per-week schedule, but added The on-duty Secondary Response EOC will assume Initial Response EOC responsibilities during off-hours. Changes made in this revision were not submitted for prior NRC approval.
2.4.5  November 2013: SNM-960 licensed facilities were added back into the NTR REP with regards to EPZs (operational boundaries) and applicable emergency classification level thresholds. Changes made in this revision were not submitted for prior NRC approval.
Page 4 of 9 Reduction in Effectiveness Evaluation

==3.0    TECHNICAL EVALUATION==

3.1    VNC Non-Part 50 SNM Facilities The NRC approved VNC REP scope was limited to the reactor facilities on site (NTR, VBWR, EVESR, and GETR). The current VNC REP includes non-reactor radiological facilities licensed for special nuclear materials (SNM-960 and CA 0017-01). The scope of the reactor facilities REP was expanded in the November 2013 revision to include the VNC non-reactor radiological facilities. Change evaluation documentation is not retrievable for the November 2013 revision, however no submittal for prior NRC approval was made at that time; therefore, the change was not considered a reduction in effectiveness in adding the non-reactor radiological SNM-960 licensed facilities into the REP.
VNC is a large site with facilities that fall under multiple NRC and California State licenses. The October 1982 VNC emergency plan was written for the entire site. The scope of that site emergency plan was continued until relief was approved by the NRC in 1990.
GE Nuclear Energy requested the renewal of the SNM-960 license in April 1989. As part of that request for renewal, VNC asked that License Condition 12 be deleted. SNM-960 License Condition 12 required VNC to follow the provisions of the radiological contingency plan submitted to the NRC in October 1982, and subsequent revisions. The subsequent emergency preparedness regulations for fuel cycle facilities (54 FR 14051) offered an option to demonstrate that a plan was not needed. VNC evaluated potential accidents and their effects on the surroundings and concluded that a radiological contingency plan was not necessary for the SNM-960 licensed facilities. The NRC approved the deletion of Condition 12 from the SNM-960 license in a letter dated 20 December 1990.
The re-institution of the SNM-960 licensed facilities into the November 2013 REP was inappropriate and not based on physical, operational or administrative changes to those facilities (regulatory, radiological or otherwise). There were no changes or new regulations/guidance related to research and test reactors or the SAFSTOR facilities that warranted the inclusion of the SNM-960 licensed facilities back into the REP.
The proposed revision removes the SNM-960 licensed facilities from under the governance of the REP, consistent with the SMN-960 and CA-0017-01 licenses and the 1996 NRC approved version of the REP.
The change to the scope of the proposed REP, which removes the SNM-960 licensed facilities, continues to meet all aspects of 10 CFR 50 Appendix E and Regulatory Guide 2.6 applicable to the NTR and continues to cover the SAFSTOR reactor facilities.
The removal of the SNM-960 licensed facilities is considered a reduction in effectiveness based on it being a commitment documented in the current version of the REP. There are no regulatory, licensing or site specific reasons for the SNM-960 licensed facilities to be included in the scope of the VNC reactor facilities REP.
Page 5 of 9 Reduction in Effectiveness Evaluation VNC requests NRC approval to remove the applicability of the SNM-960 licensed facilities from the current REP, which restore alignment with the NRC approved version of the REP, restores conformance with the SNM licenses, and removes potential emergency declaration of events that do not warrant it.
VNC continues to maintain response and notification procedures as required by the regulations governing the SNM-960 licensed facilities. The structure and processes used by the VNC ERO and other response personnel will continue to be used during off-normal events at those facilities.
3.2    Emergency Director Continuous Coverage The NRC approved REP specifies that the Emergency Operations Coordinator (now titled Emergency Director) acting as the initial response EOC, be present on-site to provide continuous coverage on a three-shift, seven-day-per-week basis. The current REP specifies that the continuous coverage will be provided during normal working hours, or off-hours, as required.
The change relaxing the Emergency Director continuous coverage site specific requirement was made in the January 2013 revision of the REP without being submitted for prior NRC approval.
10 CFR 50 Appendix E and Regulatory Guide 2.6 do not provide requirements or guidance regarding continuous coverage of the facility by ERO personnel at test and research reactors. ANSI/ANS-15.16-2015 Section 3.3.5 and NUREG-0849 element 3.1.e specifies that the emergency plan should describe the organizational considerations for the capability of the ERO to function around-the-clock for a protracted period of time following the initiation of emergencies that have or could have radiological consequences requiring around the clock emergency response. However, NUREG-0849 specifies that this element is only applicable to research and test reactors > 2 MW (not applicable to NTR). Thus, no regulation or guidance document requires a low power research and test reactor to maintain a qualified ERO member continuously on site. The January 2013 change to the REP did not violate a regulatory or guidance requirement.
NTR Technical Specifications (TS) Section 6.1.3 requires the following when the reactor is not secured:
: a. A licensed operator in the control room.
: b. A second person present at the site familiar with NTR Emergency Procedures and capable of carrying out facility written procedures.
: c. A licensed Senior Reactor Operator shall be present at the NTR Facility or readily available on call.
Additionally, TS require the presence of a licensed Senior Reactor Operator present at the NTR Facility during the following events:
: a. During the recovery from an unscheduled shutdown.
: b. During reactor fuel loading or reactor fuel movement.
c    During any experiment or facility changes with a reactivity worth greater than one dollar.
Page 6 of 9 Reduction in Effectiveness Evaluation There is no NTR TS requirement for a licensed operator or an ERO member to be present on site when the reactor is secured.
The VNC REP requirement for an ERO member to be present on site at all times can be traced back to the original emergency plan and was carried forward until January 2013.
The requirement to maintain an ERO member present on site at all times was a site specific REP commitment. The change to remove the requirement to maintain an ERO member to be present on site at all times was made in conjunction with site operational and staffing reductions. Although the change did not violate regulation, guidance or TS requirements, it did reduce the effectiveness of the NRC approved REP and was implemented without obtaining prior NRC approval.
VNC maintains a process to ensure there is an identified individual on duty as the Emergency Director at all times. ((
                                                                                   )) If an off-normal event occurs an officer will make the appropriate announcements and notify the Emergency Director. Notification means include ((
                                           )).
The VNC process for staffing the Emergency Director position is equivalent to other research and test reactors. For example:
Purdue University PUR-1 reactor (10 kW) E-Plan does not require an Emergency Director on-site during off-hours. Campus police are responsible for contacting the Emergency Director when they are not on site.
NC State University PULSTAR reactor (2 MW) E-Plan does not require an Emergency Director on-site during off-hours. Campus police are responsible for contacting the Emergency Director when they are not on site.
UMASS Lowell research reactor (1 MW) E-Plan does not require an Emergency Director on-site during off-hours. Campus police are responsible for contacting the Emergency Director when they are not on site.
The removal of the requirement to maintain an Emergency Director on-site 24/7 is considered a reduction in effectiveness based on it being a site specific commitment contained in the NRC approved version of the REP.
There are no regulatory or licensing based reasons to require the on-site presence of the Emergency Director 24/7.
VNC requests NRC approval to reduce the requirements for Emergency Director presence on-site to whenever NTR is operational or entries into EVESR, GETR, or VBWR are in progress. This change will make VNC ERO staffing consistent with other research and test reactor sites. There is no other site specific consideration at VNC which would warrant the need for 24/7 on-site staffing of the Emergency Director position.
Page 7 of 9 Reduction in Effectiveness Evaluation 3.3    Site Area Emergency Classification Level and EALs The NRC approved REP EAL set is based on ANSI/ANS-15.16-1982 initiating conditions. The current REP EAL set is based the ANSI standard and a set of thresholds developed to encompass all VNC SNM areas licensed for radioactive materials.
Additional thresholds are also contained in the site emergency implementing procedures.
SNM-960 licensed facilities do not require an emergency plan and are not within the scope of the REP (refer to Section 3.1 for effectiveness evaluation of the SNM-960 licensed facilities). The current EAL set does not have a documented technical basis.
This change to the REP EALs is a complete revision to conform to the criteria in ANSI/ANS-15.16-2015, including the development of a technical basis for each site specific EAL threshold. This change also removes site specific EAL thresholds that apply only to the SNM-960 licensed facilities and modifies EAL thresholds such that they will not apply to SNM-960 licensed facilities (leaving them applicable to only the reactor facilities). Specifically, the proposed EAL thresholds are limited to events involving NTR or the SAFSTOR reactor facilities, or events that affect the NTR or the SAFSTOR reactor facilities.
The new EAL scheme develops site specific indications and parameters and uses site specific terminology. It is considered a scheme change based on the significance of the threshold changes being made. In accordance with 10 CFR 50 Appendix E.IV.B.2, a licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. The new EAL scheme and its technical bases are documented in Sections 4 and 5 of the proposed REP (refer to Attachment 3 of this submittal).
In the development of a technical basis for the site specific EAL threshold values it was determined that the radiological conditions that define a Site Area Emergency classification level were not possible at VNC. NTR is the most significant source term at VNC, which is licensed to operate at power levels not in excess of 100 kW (thermal).
The NTR Safety Analysis Report (SAR) states that even if catastrophic non-mechanistic failure of the NTR is assumed, there are no potential consequences more severe than those associated with the accidents analyzed in Chapter 13. SAR Table 13-3 provides dose summaries for site boundary exposure to the NTR Design Basis Accident (DBA),
that result in a Total Body 2 hour submersion dose of 4.54E-3 Rem (4.5 mRem) and CDE Thyroid of 1.61E-1 Rem (161 mRem). These values are significantly below the ANSI/ANS-15.16-2015 24 hour and 1 hour thresholds required for a Site Area Emergency. Thus, the Site Area Emergency classification level is not applicable at VNC.
The change to the EAL classification scheme complies with and continues to meet all aspects of 10 CFR 50 Appendix E and Regulatory Guide 2.6 applicable to the NTR.
Page 8 of 9 Reduction in Effectiveness Evaluation The removal of the Site Area Emergency classification level may be considered a reduction in effectiveness based on it being a requirement in the NRC approved and current versions of the REP. There is no technical basis or regulatory requirement for a Site Area Emergency classification level for the VNC NTR or SAFSTOR facilities. Thus, maintaining site specific EALs and response procedure actions for a Site Area Emergency classification level provides no benefit or added safety capability, because an event can never reach that level at VNC.
The change to the EAL classification scheme is an improvement in the capability to perform the classification emergency planning function, and therefore is not a Reduction in Effectiveness. However, the scope of the EAL scheme change requires NRC approval prior to implementation.
3.4    State Event Notification Time Requirement The NRC approved and current versions of the REP do not specify timeliness criteria for notification of the California Office of Emergency Services (OES) or the NRC following declaration of an emergency. VNC site emergency procedures (SEPs) implementing the process for Cal OES and NRC notification do not specify timeliness criteria. No commitment is made in the NRC approved and current versions of the REP to notify local agencies of a declared event at VNC.
10 CFR 50 Appendix E.IV.D.3 states; a licensee shall have the capability to notify responsible state and local governmental agencies within 15 minutes after declaring an emergency. The purpose of the 15-minute notification is to ensure prompt notification of the public within the plume exposure pathway emergency planning zone for power reactors, thus the intent is not applicable to non-power reactors like NTR. Because NTR is not a power reactor no other specific time requirements in Appendix E to 10 CFR Part 50 for notification of the NRC, state and local agencies apply. Therefore, the one-hour notification is acceptable for NTR and is consistent with other regulations for other NRC non-power reactor licensees that are required to have emergency plans.
VNC has also included specific wording in the proposed REP that the NRC be notified immediately after notification of California Office of Emergency Services (Cal OES) and
((                               )) after event declaration (initial or an escalation).
3.5    Impact of Proposed Changes on State Emergency Plan VNC discussed the REP with the Cal OES Radiological Preparedness Unit to inform them of proposed changes including removal of the Site Area Emergency classification level. Cal OES had no additional comments.
Page 9 of 9 Reduction in Effectiveness Evaluation

==4.0    REFERENCES==

4.1    10 CFR 20, Standards for Protection Against Radiation 4.2    10 CFR 50.34(b)(6)(v), Contents of applications; Technical Information, Final Safety Analysis Report, Emergency Plans 4.3    10 CFR 50.54, Conditions of Licenses 4.4    10 CFR 50 Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities 4.5    Regulatory Guide 2.6, Emergency Planning for Research and Test Reactors, Revision 2 4.6    ANSI/ANS-15.16-2015, Emergency Planning for Research Reactors 4.7    NUREG-0849, Standard Review Plan for the Review and Evaluation of Emergency Plans for Research and Test Reactors, October 1983 4.8    SNM-960, Amendment No.0, August 9, 2017 4.9    SNM-960, Amendment No.5, December 20, 1990 4.10   Technical Specifications for the Nuclear Test Reactor Facility License R-33, Amendment 23 4.11   NTR Safety Analysis Report, June 2000 4.12   VNC Reactor Facilities Radiological Emergency Plan, March 1996 [NRC approved plan]
4.13   VNC Reactor and Radiological Facilities Radiological Emergency Plan, January 2018
[current plan]

VNC Radiological Emergency Plan                    February 2020
* HITACHI VALLECITOS NUCLEAR CENTER REACTOR FACILITIES RADIOLOGICAL EMERGENCY PLAN Revised & Approved February 2020 pg. i

VNC Radiological Emergency Plan                                                                                           February 2020 TABLE OF CONTENTS 1 INTRODUCTION .................................................................................................................... 1 1.1  Objective .......................................................................................................................... 1 1.2  Scope and Regulatory Basis............................................................................................. 1 1.2.1 Scope ....................................................................................................................... 1 1.2.2 NTR Regulatory Basis ............................................................................................ 2 1.3  Location ........................................................................................................................... 4 1.4  Reactor Description ......................................................................................................... 5 2 DEFINITIONS.......................................................................................................................... 7 3 ORGANIZATION AND RESPONSIBILITIES ...................................................................... 9 3.1  VNC Emergency Response Organization (ERO) ............................................................ 9 3.1.1 Emergency Director .............................................................................................. 10 3.1.2 ((                                                                                )) .......................................... 11 3.1.3 ((                                                                       )) .................................................. 11 3.1.4 ((                                   )) ...................................................................................... 11 3.1.5 ((
                           )) .............................................................................................................. 11 3.1.6 ((
                 )) ........................................................................................................................ 11 3.1.7 ((                             )) ............................................................................................. 12 3.2  Off-Site Agencies........................................................................................................... 12 3.2.1 Federal Agencies ................................................................................................... 12 3.2.2 State Agencies ....................................................................................................... 12 3.3  Off-Site Support Organizations ..................................................................................... 13 3.3.1 First Aid Assistance .............................................................................................. 13 3.3.2 Medical Treatment Facilities ................................................................................ 13 3.3.3 Ambulance Service ............................................................................................... 13 3.3.4 Firefighting Assistance ......................................................................................... 13 3.3.5 Police Assistance .................................................................................................. 14 4 EMERGENCY CLASSIFICATION SYSTEM ..................................................................... 15 4.1  Unusual Event ................................................................................................................ 15 4.2  Alert ............................................................................................................................... 16 pg. ii

VNC Radiological Emergency Plan                                                                                           February 2020 4.3  Site Area Emergency ..................................................................................................... 16 4.4  General Emergency ........................................................................................................ 17 5 EMERGENCY ACTION LEVELS........................................................................................ 18 5.1  Unusual Event ................................................................................................................ 19 5.1.1 RU1 Technical Basis............................................................................................. 20 5.1.2 RU2 Technical Basis............................................................................................. 20 5.1.3 RU3 Technical Basis............................................................................................. 20 5.1.4 SU1 Technical Basis ............................................................................................. 20 5.1.5 SU2 Technical Basis ............................................................................................. 21 5.1.6 HU1 Technical Basis ............................................................................................ 21 5.1.7 HU2 Technical Basis ............................................................................................ 21 5.2  Alert ............................................................................................................................... 23 5.2.1 RA1 Technical Basis............................................................................................. 23 5.2.2 RA2 Technical Basis............................................................................................. 23 5.2.3 RA3 Technical Basis............................................................................................. 24 5.2.4 SA1 Technical Basis ............................................................................................. 24 6 EMERGENCY PLANNING ZONEs (EPZs) ......................................................................... 25 6.1  NTR EPZ ....................................................................................................................... 25 6.2  GETR, VBWR, and EVESR EPZs ................................................................................ 25 7 EMERGENCY RESPONSE................................................................................................... 26 7.1  Activation of Emergency Organizations ........................................................................ 26 7.1.1 Notification of Onsite Personnel and Mobilization of the ERO ........................... 26 7.1.2 ((
                 )) ........................................................................................................................ 26 7.1.3((                                                     ..  )) .................................................................. 26 7.2  Assessment Actions ....................................................................................................... 27 7.2.1 Plant Parameters and Corresponding Emergency Classification .......................... 27 7.2.2 Onsite Accident Assessment Capabilities ............................................................. 27 7.3  Corrective Actions ......................................................................................................... 27 7.4  Protective Actions .......................................................................................................... 27 7.4.1 Personnel Evacuation from Immediate Area ........................................................ 28 7.4.2 Contamination Control Measures ......................................................................... 28 pg. iii

VNC Radiological Emergency Plan                                                                                          February 2020 7.4.3 Personnel Decontamination/First Aid ................................................................... 28 7.4.4 Emergency Exposure Control and Guidelines ...................................................... 29 8  EMERGENCY FACILITIES AND EQUIPMENT................................................................ 30 8.1  Emergency Control Center (ECC) ................................................................................. 30 8.2  Assessment Facilities ..................................................................................................... 30 8.3  First Aid and Decontamination Equipment ................................................................... 30 8.4  Communications Equipment.......................................................................................... 31 8.4.1 ((                                  --  )) .................................................................................. 31 8.4.2 ((                          )) .............................................................................................. 31 8.4.3 ((                               )) ......................................................................................... 31 8.4.4 ((                             )) .......................................................................................... 31 8.4.5 ((                                                    )).................................................................... 31 8.4.6 ((                                                                                   )) ..................................... 31 8.5  Contingency Planning .................................................................................................... 31 9  RECOVERY ........................................................................................................................... 32 9.1  Reentry ........................................................................................................................... 32 9.2  Recovery ........................................................................................................................ 32 10 MAINTAINING EMERGENCY PREPAREDNESS ............................................................ 34 10.1 Training and Drills ......................................................................................................... 34 10.1.1   Training ........................................................................................................... 34 10.1.2   Conduct of Drills ............................................................................................. 35 10.1.3   Critique of Drills.............................................................................................. 36 10.2 Plan Review and Update ................................................................................................ 36 10.2.1   Responsibility for the Plan .............................................................................. 36 10.2.2   Review and Update.......................................................................................... 36 10.3 Maintenance and Inventory of Emergency Equipment, Instrumentation, and Supplies 37 Appendix 1, References .................................................................................................................38 Appendix 2, Emergency Plan Implementing Procedures ..............................................................39 Appendix 3, EAL Technical Bases for Effluent Releases .............................................................40 pg. iv

VNC Radiological Emergency Plan                                                        February 2020 DOCUMENT REVIEW This document is required to be reviewed Biennially.
Reviews finding technical or procedural errors will require immediate correction by revision.
The first (original) review of any revision will be located on the front cover of this plan. Reviews finding administrative/format errors may be noted in the comments and corrected as time permits.
Electronic Signatures are authorized for review and approval.
Date                   Reviewer                             Comments (if necessary) pg. v

VNC Radiological Emergency Plan                                                        February 2020 1    INTRODUCTION Planning Standard (ANSI/ANS-15.16 Section 3.1 & NUREG-0849 Section 1.0)
The plan shall briefly introduce the type of reactor, the reactors purpose, where it is located, and the purposes of the emergency plan.
The purpose of the introduction is to provide a general orientation and common understanding about the reactor and the objectives of the plan for those members of the reactor organization, the public, and local, county, state, and federal agencies that will read and study the plan.
1.1     Objective This emergency plan contains security related information and describes the approach used to identify, communicate, respond to and minimize the consequences of classified emergencies; it documents regulatory compliance and site specific commitments; and provides a basis for the response and maintenance implementing procedure instructions.
This plan will be provided to external stakeholders as appropriate.
1.2     Scope and Regulatory Basis 1.2.1   Scope There are four reactor facilities at the Vallecitos Nuclear Center (VNC) that are licensed by the NRC under 10 CFR 50 requirements; the Nuclear Test Reactor (NTR), which has a current operating license, and the other three reactor facilities which are in a shutdown SAFSTOR decommissioning mode with possess only licenses:
Vallecitos Boiling Water Reactor (VBWR) DPR-1 ESADA Vallecitos Experimental Superheat Reactor (EVESR) DR-10 GE Test Reactor (GETR) TR-1 This emergency plan has been developed for the NTR, license R-33, in accordance with the applicable regulations, guidance and information documents. Per NRC letter dated 03/19/13 and DRK-2013-14 response the NTR emergency plan and implementing procedures are sufficient to meet the emergency planning requirements for the three shutdown defueled reactors (spent fuel for the SAFSTOR facilities is no longer maintained or stored on site).
Other VNC facilities which are governed under Special Nuclear Material (SNM) federal and state licenses do not contain sufficient radioactive materials to require an emergency plan (NRC Letter SNM-960 Amendment 5 12/20/90 and GEH 03/08/18 Memo, Evaluation that a VNC Radiological Emergency Plan is not Required for Radioactive Material Authorized by the State of California).
Page 1 of 40

VNC Radiological Emergency Plan                                                       February 2020 Building 102 contains administrative offices and shielded facilities (hotcells) for experiments, sealed source manufacture, and examination of irradiated materials. The building also includes radiological equipment repair and refurbishment shop areas, the storage pool and dry pit storage as well as a radiochemistry laboratory equipped with standard chemical and radiochemical apparatus.
Building 103 consists of administrative offices and laboratories equipped and designed to handle small amounts of radioactive materials in the performance of research, development, and analytical chemistry and metallurgical services.
Building 105 contains laboratory areas with equipment for research and special measurement that involves minimal amounts of radioactive material used in conjunction with spectrometric equipment.
Building 106 houses support facilities (e.g., electrical shop, instrument shop, radiological instrument calibration facilities, etc.), an x-ray room, and offices.
Building 349 contains the site low-level liquid waste evaporator.
400 and 401 Areas consists of offices and spaces that may contain laboratory quantities of radioactive material.
Hillside Storage Area is used to store Low Level Radwaste. Irradiated fuel segments and hardware are stored in the above ((                           )).
The VNC Emergency Response Organization (ERO) may be used to address events occurring at those facilities outside of a declared emergency. Event response involving SNM facilities are primarily controlled through site industrial / hazards procedures that are outside the scope of this emergency plan.
1.2.2 NTR Regulatory Basis NRC Regulatory Guide 2.6, Emergency Planning for Research and Test Reactors, provides test and research reactor licensees with a method that the NRC considers acceptable for use in complying with the following regulations on the content of their emergency plans:
10 CFR 50.34(b)(6)(v) requires that each application for a Part 50 license to operate a facility include a final safety analysis report that contains, along with other information, the applicants plans for coping with emergencies, including the items specified in Appendix E to 10 CFR 50.
Note - NTR is the only facility at VNC that is required to maintain a safety analysis report.
10 CFR 50.54(q) requires Part 50 licensees to follow and maintain the effectiveness of emergency plans that meet the requirements of 10 CFR 50 Appendix E.
Page 2 of 40

VNC Radiological Emergency Plan                                                     February 2020 10 CFR 50 Appendix E identifies the minimum requirements for emergency plans. It also indicates that because operation of test reactors involve distinct considerations, the size of the emergency preparedness zone (EPZ) and degree of compliance with requirements in Appendix E, sections I through V, as necessary, will be determined on a case-by-case basis using this regulatory guide for research and test reactor, and other non-power production and utilization facility emergency response plans.
Regulatory Guide 2.6 Revision 2 endorses the consensus standard ANSI/ANS-15.16-2015, stating that it provides specific acceptance criteria that; (1) comply with the applicable requirements contained in the above listed regulations, and (2) supply a basis to develop acceptable emergency response plans and improve emergency preparedness.
Consistent with ANSI/ANS-15.16, NUREG-0849 provides areas of review, planning standards, and items for NRC staff to evaluate a licensees compliance with the applicable emergency planning requirements. NUREG-0849 is used as a basis for the level of planning detail included in this document.
Page 3 of 40

VNC Radiological Emergency Plan                                                                                    February 2020 1.3   Location VNC, owned and operated by General Electric Hitachi (GEH), is located in the west-central portion of the State of California about 15 miles east of the southern end of San Francisco Bay, approximately 35 air miles east-southeast of San Francisco and 20 air miles north of San Jose. It lies on the north side of the Vallecitos Valley. The nearest sizeable towns are Pleasanton, located 4.1 miles to the north-northwest and Livermore, located 6.2 miles to the northeast.
The site is on the north side of Vallecitos Road (State Route 84), which is a two and four-lane paved highway. The majority of the site is undeveloped with hills ranging in elevation from 600 to 900 feet above mean sea level. Access to Vallecitos Road from the south-west is via Interstate Highway 680, and from the north-east via Stanley Boulevard or Interstate Highway 580.
HA lBOR/1.llY ISU                                                  San Ramon Canp Village    Parks San Leandro                                               Mifilary Reservation LA   MANOR Dublin                           Ulmar Castro San orenzo Valley Hayward San Franctsco Bay Foster City Alameda Creek              Union City A RDENWOO Farwell 6705 Vallecitos Rd, Sunol, CA 94586 Fremont Newar 101 Bcir elmont         tsl<Di Figure 1 VNC Bay Area Map Page 4 of 40

VNC Radiological Emergency Plan                                                   February 2020 1.4  Reactor Description The NTR, located in Building 105, is a heterogeneous enriched-uranium graphite-moderated and -reflected light-water-cooled thermal reactor. The reactor is a variable level neutron source used in the research, development, analytical and commercial programs of GEH and its customers. The NTR is primarily engaged in neutron radiography non-destructive material imaging. Per the General Electric Nuclear Test Reactor Safety Analysis Report Section 1.1, the NTR is licensed to operate at power levels not in excess of 100 kW (thermal).
GETR and related structures are located in the 200 Area. VBWR and EVESR and related structures are located in the 300 Area. These facilities are not occupied. Only relatively minor activities associated with inspection and maintenance of the deactivated facilities are currently performed. No fuel assemblies from these reactors remain on-site. Radiation and contamination levels in all of the SAFSTOR facilities are significantly reduced since shut-down several decades ago and well below values typical of operating research & test reactors.
Those and other areas regulated under separate licenses at VNC that contain radioactive material are illustrated Figure 1-2.
Page 5 of 40

VNC Radiological Emergency Plan                                                                                         June 2019 D           0,               0 0           0                0 D           in               0 I()
w           w                w 8                                                                      8 g                                                                      t2 w                                                                      w N3000r------F=-+---=-=----"\ic=-!'7"'-----+-- - - - - - - I I - - - - - - - ,
BLDG O*
g      0
                                ,o w
Figure 1 VNC Site Layout Page 6 of 40

VNC Radiological Emergency Plan                                                             June 2019 2   DEFINITIONS Planning Standard (& ANSI/ANS-15.16 Section 3.2 & NUREG-0849 Section 2.0)
Terms unique to the reactor facility or that have a special meaning when used in the plan shall be defined in the plan.
Assessment Actions - Those actions taken during or after an emergency to obtain and process information necessary to make decisions to implement corrective, protective and recovery actions.
Corrective Actions - Those actions taken to arrest and terminate an emergency.
Direct - Directing involves obtaining data and recommendations, processing this input, and then ensuring the performance of one or more actions or activities such as additional assessment, protective or corrective actions. The performance of actions or activities is generally through responsible intermediaries.
Emergency Action Level (EAL) - A pre-determined, site-specific, observable threshold for an initiating condition that, when met or exceeded, result in actions such as (a) establishing emergency classes and (b) initiating appropriate emergency measures.
Emergency Classification Level (ECL) - One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:
Unusual Event (UE)
Alert Site Area Emergency (SAE)
General Emergency (GE)
Emergency Control Center (ECC) - The primary base of VNC emergency operations during a declared event to facilitate the management and coordination of overall emergency response.
Emergency Planning Zone (EPZ) - Area for which off-site emergency planning is performed to assure that prompt and effective actions can be taken to protect the public in the event of an accident. The EPZ size is dependent on reactor power level and the distance beyond the site boundary at which the protective action guides could be exceeded.
Refer to Section 6 for the VNC facility specific EPZs.
Fire - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.
Holding Statement - A statement reviewed and approved for accuracy prior to issuance, that provides prepared information to distribute in response to rumors or inquiries from news or social media outlets, community officials, regulatory agencies, or other interested parties.
Page 7 of 40

VNC Radiological Emergency Plan                                                           June 2019 Off-Normal Condition - A situation or event, other than those addressed by site personnel on a routine basis, which are evaluated for emergency plan entry by the Emergency Director.
Off-Site - The geographical area that is beyond the site boundary.
On-Site - The geographical area that is within the site boundary.
Operations Boundary - The area within the site boundary such as the reactor building (or the nearest physical personnel barrier in cases where the reactor building is not a principal physical personnel barrier) where GEH has direct authority over all activities. The area within this boundary shall have prearranged evacuation procedures known to personnel frequenting the area.
Refer to Section 6 for the site specific reactor facility operational boundaries.
Protective Actions - Those actions taken to mitigate the consequences of an emergency.
Recovery Actions - Those actions taken after an emergency to restore the area to the pre-emergency condition.
Site Boundary - The site boundary is a boundary that does not necessarily have restrictive barriers and surrounds the operations boundary wherein GEH may directly initiate emergency activities. The area within the site boundary may be frequented by people unacquainted with the reactor operations.
For purposes of this plan, the site boundary is the GEH property fence designated as the Vallecitos Nuclear Center.
Page 8 of 40

VNC Radiological Emergency Plan                                                                June 2019 3   ORGANIZATION AND RESPONSIBILITIES Planning Standard (ANSI/ANS-15.16 Section 3.3 & NUREG-0849 Section 3.0)
Responsibility for planning and implementing all emergency measures within the site boundary rests with the owner/operator of the reactor facility. The plan shall describe the emergency organization that would be activated to cope with radiological emergencies that includes the on-site emergency organization and any augmentation from off-site groups. Persons or groups that will fill positions in the emergency organization should be identified by their normal everyday title.
3.1      VNC Emergency Response Organization (ERO)
VNC emergency preparedness response adapts the normal site organization into an ERO that is activated upon declaration of an emergency classification level. The VNC ERO is shown below.
Emergency Director Offsite Incident GEH Headquarters Command Offsite Response Support J                                 Emergency Response Support Nuclear/ Licensing / Rad Safety/ EHS Support Communications/ Media Support Bldg Emergency         Fire Chief & Fire Facilities Manager        RC & EHS Manager Coordinator               Team L       Maintenance and Craft Personnel L     Nuclear/ Licensing /
Rad Safety/ Security
                                              / EHS Personnel L    Bldg Emergency Team I Assembly Area Leader Figure 3 VNC Emergency Response Organization and Support Interface An off-normal condition is initially evaluated by the Emergency Director. An Emergency Director is present on site whenever the reactor (NTR) is operational or entries into EVESR, GETR, or VBWR are in progress. Otherwise, the Emergency Director may be offsite.
Page 9 of 40

VNC Radiological Emergency Plan                                                          June 2019 When the Emergency Director is on site, they are typically made aware of an off-normal condition ((
                               )). When the Emergency Director is not on site they will be contacted by [
              )).
Following evaluation of the event, the Emergency Director will determine whether an emergency declaration is warranted, staff the appropriate ERO positions and notify Federal and State agencies.
Responsibilities and authority of members of the ERO, management, and support specialists include those listed below. Additional responsibilities and duties may be assigned in implementing procedures.
3.1.1 Emergency Director As part of overall command and control of the event, the Emergency Director coordinates the collection and evaluation of information from the event location, prioritizes response and mitigating activities of dispatched personnel, and manages the Emergency Control Center (ECC) and ERO in order to provide continuous assessment of the situation regarding the magnitude of the emergency, projected consequences, and effectiveness of the response measures taken.
Specifically, the Emergency Director has the overall responsibility and authority for VNC emergency response activities, including:
Classifying and declaring emergencies Designating a location for the ECC, ((                             ))
Ensuring notification of the VNC ERO and augmenting as necessary Ensuring notification of the appropriate offsite agencies Mobilizing corporate and other support resources as necessary Coordinating response activities (including off-site assistance if requested) to mitigate the consequences of the event Directing on-site protective actions to prevent or minimize personnel hazard and injury Authorizing reentry into facilities or areas that may have been evacuated during the emergency Authorizing volunteer emergency workers to incur radiation exposures in excess of normal occupational limits Escalating the emergency classification level or terminating the event These responsibilities can only be delegated to other personnel qualified as an Emergency Director.
Page 10 of 40

VNC Radiological Emergency Plan                                                                June 2019 The Emergency Director is also responsible for providing holding statement information about the emergency to the corporate communications and public relations function for release to the news media and the public.
3.1.2   ((
            ))[
                                                                           ))
((
                           )).
3.1.3    ((                                               ))
((
                                                                               )). This includes dose assessments and recommendation of on-site protective actions as appropriate.
3.1.4   ((
            )) ((                                                    )) repair/damage control teams associated with accident mitigation. The ((                           )) assesses the personnel resources and technical skill levels required to mitigate the emergency situation and requests augmentation of the ERO staff as appropriate.
3.1.4.1 ((                                           ))
((
                               )) to emergencies during normal working hours and may be called in during off-hours to assist in emergencies.
3.1.5   ((
            ))((                              )), is responsible for supporting assessment of the emergency and directing assessment, corrective, and protective activities concerning criticality safety and radiation protection.
3.1.6   ((
            ))((                              )), who will respond to an emergency during normal working hours, communicate conditions and take local corrective and protective actions.
If needed, the BET may be called in during off-hours. The BET includes personnel trained to perform emergency response activities which may include first aid, radiation monitoring, and equipment operation and maintenance particular to their facility.
Page 11 of 40

VNC Radiological Emergency                                                                   June 2019 Plan 3.1.6.1 ((
           ))[
                )). They are responsible for communicating with the BEC and for accounting for all personnel who work in the evacuated area.
3.1.7  ((
           ))((                                                  )) when onsite and may be called in during off-hours. They are [
                                                                                         ]
((
                                                                                          )) Fires which have progressed or threaten to progress to the interior structural fire stage or during off-hours will be handled by off-site assistance.
3.2    Off-Site Agencies Federal, state and local agency response assistance is not anticipated since no radiological event at VNC is capable of reaching a level requiring protection of the public (local source term resulting in a release of radioactivity is not sufficient to result in exposure which exceed EPA PAG levels beyond the site boundary).
Offsite agencies are notified of declared emergencies as described in Section 7.
3.2.1  Federal Agencies Control, responsibility and interface of federal organizations is governed by the National Response Framework (NRF) and the Nuclear/Radiological Incident Annex to the NRF when they are notified of an event at a nuclear research or test reactor facility.
The NRC acts as the lead federal agency with regard to technical matters during a nuclear incident including radiological assistance. The NRC maintains an Incident Response Plan (IRP). The IRP objectives are to provide for protection of the public health and safety, property, and the environment, from the effects of radiological incidents that may occur at licensed facilities. The objectives of the agency plan set forth the organizational and management concepts and responsibilities needed to assure that NRC has an effective emergency response program.
Department of Homeland Security (DHS) may provide leadership capabilities in the event there are incidents related to security.
3.2.2  State Agencies The California Office of Emergency Services (OES) is the state authority for coordination of all state response. Cal OES is also the primary state response agency that coordinates the state's response to requests for assistance from local jurisdictions.
Page 12 of 40

VNC Radiological Emergency Plan                                                          June 2019 If an event is of significant magnitude to require establishment of a near site Incident Command Post (ICP), it will be established through Cal OES and the Emergency Director will communicate with and potentially provide a liaison to the ICP to assist in coordinating response efforts.
3.3   Off-Site Support Organizations Certain supporting services that may be needed during or after a radiological emergency are available from local off-site organizations. These services are described below. Refer to Section 10.2.2, Review and Update, for a current list of MOUs with off-site support organizations.
3.3.1 First Aid Assistance First aid assistance is available through the Alameda County Emergency Services Dispatch (911). Typically, local fire Emergency Medical Service (EMS) units are sent to respond for first aid related issues. However, other trained personal, such as from local law enforcement, may be dispatched for first aid service as determined by the county dispatch process.
A written agreement is maintained with local emergency medical services for assistance that would be requested to come on-site.
3.3.2 Medical Treatment Facilities Access to local area medical facilities and professional care for radiation-exposed or contaminated individuals requiring medical treatment is provided through written agreement with a private professional organization.
3.3.3 Ambulance Service Ambulance service is available through the Alameda County Emergency Services Dispatch (911). If the nature of the emergency or injury warrants, 911 is called and injured personnel are transported via ambulance to one of several local area medical facilities.
A written agreement is maintained with a local private ambulance service company regarding transport of injured or ill personnel to an offsite medical treatment facility, who may be contaminated.
3.3.4 Firefighting Assistance When needed, a request for firefighting assistance will be made through the Alameda County Emergency Services Dispatch (911).
The first arriving responders at VNC may come from the closest fire station in Sunol. If additional assistance is needed, the fire incident commander will make the request for additional resources through ACFD.
Page 13 of 40

VNC Radiological Emergency Plan                                                           June 2019 A written agreement is maintained with local fire services for assistance that would be requested to come on-site.
3.3.5 Police Assistance Police assistance is available for law enforcement activities and off-site traffic and/or crowd control from county and state law enforcement agencies with jurisdiction over the areas and roadway surrounding VNC.
A written agreement is maintained with local law enforcement for assistance that would be requested to come on-site.
Page 14 of 40

VNC Radiological Emergency Plan                                                           June 2019 4    EMERGENCY CLASSIFICATION SYSTEM Planning Standard (ANSI/ANS-15.16 Section 3.4 & NUREG-0849 Section 4.0)
The emergency plan shall describe several classes of emergency situations covering the spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the emergency organization. To provide for improved communications between the licensee or owner/operator and federal, state, and local agencies and organizations, the most severe accidents are standardized in four classes of emergency conditions that group the accidents according to the severity of off-site radiological consequences. Each emergency plan shall include only those standard classes appropriate for dealing with accident consequences determined to be credible for the specific facility.
Each class of emergency should be associated with particular emergency action levels and with particular immediate actions to provide appropriate graded response.
This plan is based on the classification system described in ANSI/ANS-15.16-2015. Events are standardized in four classes of emergency conditions which group them according to the severity of off-site radiological consequences. These classes in order of increasing severity are:
Unusual Event Alert Site Area Emergency General Emergency All four classes are included in this section of the emergency plan for completeness even though credible radiological accident consequences for NTR are covered by the first two classes.
4.1     Unusual Event Unusual Events may be initiated by either man-made events or natural phenomena that can be recognized as creating a significant hazard potential that was previously nonexistent. There is usually time available to take precautionary and corrective steps to prevent the escalation of the accident or to mitigate the consequences should it occur. No releases of radioactive material requiring off-site responses are expected.
Although the situation may not have caused damage to the reactor, it may warrant an immediate shutdown of the reactor or interruption of nonessential routine functions.
The ED ERO position will be activated, with other ERO positions potentially notified to increase the state of readiness as warranted by the circumstances.
Actions taken in response to this emergency class are:
: 1. Notify State and NRC of Unusual Event emergency declaration per Section 7.1.2
: 2. Augment ERO resources if needed
: 3. Assess and respond Page 15 of 40

VNC Radiological Emergency Plan                                                          June 2019
: 4. Escalate to a more severe class, if appropriate or Terminate the emergency with verbal summary to offsite authorities 4.2  Alert Events leading to an Alert would be of such radiological significance as to require notification of the GE and off-site emergency organizations and their response as appropriate for the specific emergency situation. Under this class, it is unlikely that off-site response or monitoring would be necessary. Reactor shutdown is a highly probable response action. Protective evacuations or isolation of certain areas within the operations boundary or within the site boundary may be necessary.
Actions taken in response to this emergency class are:
: 1. Notify State and NRC of Alert emergency declaration per Section 7.1.2
: 2. Augment ERO resources and staff the ECC
: 3. Dispatch on-site monitoring teams
: 4. Assess and respond
: 5. Make staff available for consultation with NRC and State on a periodic basis
: 6. Escalate to a more severe class, if appropriate or Terminate the emergency with verbal summary to offsite authorities 4.3  Site Area Emergency A site area emergency may be initiated when events such as major damage of fuel or cladding and actual or imminent failure of other physical barriers containing fission products in reactor fuel or fueled experiments have occurred, and projected off-site radiological consequences exceed action levels in section 5.0. Monitoring at the site boundary should be conducted to assess the need for off-site protective actions.
Protective measures on-site may be necessary.
The results of NTR Safety Analysis Report (SAR) Section 13 accident analyses show that there are no credible events that could cause fuel melt or a significant release of fission products from the fuel. Even if catastrophic non-mechanistic failure of the NTR facilities is assumed, there are no potential consequences more severe than those associated with the accidents analyzed in SAR Chapter 13.
SAR Section 13.5.3.1 provides radiological consequence analysis of accidental explosions. Assuming a 1% release and stable atmospheric conditions (inversion),
maximum site boundary doses are less than 20 mRem to the thyroid and 1 mRem to the whole body under this combination of circumstances.
SAR Table 13-3 provides dose summaries for site boundary exposure to the NTR Design Basis Accident (DBA), which is an experiment accident event. Total Body 2 hour submersion dose is 4.54E-3 Rem (4.5 mRem) and CDE Thyroid is 1.61E-1 Rem (161 mRem).
Page 16 of 40

VNC Radiological Emergency Plan                                                          June 2019 The limiting EAL exposure threshold is for 1 hour. ((
                                 ]
4.4  General Emergency A general emergency may be initiated by accidents that result in an uncontrolled release of radioactive material into the air, water, or ground to the extent that protective actions off-site may be necessary. This class of accident is not credible for most research reactors. Therefore, most research reactors would not include this class as part of their emergency plans.
Refer to the technical basis in Section 4.3, Site Area Emergency, documenting that the NTR radiological source term is insufficient to meet the level of Site Area Emergency or General Emergency classification levels.
Page 17 of 40

VNC Radiological Emergency Plan                                                            June 2019 5     EMERGENCY ACTION LEVELS Planning Standard (ANSI/ANS-15.16 Section 3.5 & NUREG-0849 Section 5.0)
Because of the wide diversity of research reactors (power level, engineered safety features, site environment, etc.), those conditions that might initiate or signal a radiological incident having particular off-site consequences will vary widely among facilities. Action levels should be established in terms of effluent monitors or other plant parameters from which the dose rates and radiological effluent releases at the site boundary can be projected.
To establish effluent action levels, facilities that have meteorological information available may base the action levels on actual meteorological conditions; otherwise, the criteria to be used for downwind concentration should be taken from ANSI/ANS-15.7-1977; R1986 (withdrawn),
Research Reactor Site Evaluation, Sec. 4, Criteria for Downwind Concentration [3]. Each emergency plan shall establish EALs appropriate for the specific facility and consistent with Table 1.
The emergency plan shall include EALs to initiate protective actions for members of the general public and facility staff on-site.
Page 18 of 40

VNC Radiological Emergency Plan                                                                       June 2019 5.1  Unusual Event ANSI/ANS-15.16 Table 1 Initiating Condition                     VNC Emergency Action Level(s)
Abnormal Radiological Conditions Actual or projected radiological effluent at the     RU1 site boundary that is calculated (or measured)       Actual or projected dose at the site boundary:
to result in either of the following conditions,      * .:::. 15 mrem DDE over a 24-hour period both ofwhich are based on an exposure of24 hours or less:                                        * .:::. 15 mrem CEDE over a 24-hour period (1) A deep dose equivalent of 0.15 mSv (15            RU2 mrem)                                           Actual or projected dose rates at the site OR                                               boundary:
(2) A committed effective dose equivalent of          * .:::. 4 mrem/hr DDE 0.15mSv (15 mrem) based on the following         * .:::. 20 mrem COE thyroid for 1 hour of considerations:                                     inhalation
* 100 EC X 24 hours = 2.4 X10 3 EC-hour          RU3
              ~0.15 mSv (15 mrem) (for radionuclides        Radiological effluent level (&#xb5;Ci/cc) meet any of other than noble gases)                     the following for greater than 60 minutes:
* 50 EC X 24 hours= 1.2 X10 3 EC-hour            * .:::. 2.4E-5 NTR Noble Gas Stack Monitor
              ~0.15 mSv [15 mrem] (for noble gases)
                                                            * .:::. 2.4E-5 NTR Particulate Stack Monitor
                                                            * .:::. 2.4E-1 from any reactor facility effluent Noble Gas sample
                                                            * .:::. 4.7E-3 from any reactor facility effluent Halogen sample
                                                            * .:::. 2.4E-7 from any reactor facility effluent a Particulate sample
                                                            * .:::. 2.4E-5 from any reactor facility effluent 13 Particulate sample Security Conditions Credible security threat affecting the reactor       SU1 facility                                              Credible security threat affecting a reactor facility Receipt of bomb threat affecting the reactor         SU2 facility                                              Credible bomb threat affecting a reactor facility Hazardous Conditions Report or observation of a severe natural             HU1 phenomenon affecting the reactor site                 Report or observation of any of the following severe natural phenomenon affecting the NTR:
* Tornado strike within the site boundary
                                                            * > 75 mph winds for> 1 minute
* NTR Seismic Alarm and felt by onsite personnel Fire within the reactor facility not extinguished    HU2 within 15 minutes                                     Fire within a reactor facility not extinguished within 15 minutes of detection Page 19 of 40

VNC Radiological Emergency Plan                                                        June 2019 5.1.1 RU1 Technical Basis The RU1 threshold values are directly related to the ANSI/ANS-15.16-2015 initiating condition values.
For the purpose of event declaration, direct measurement by survey instrument adjusted for exposure period is considered equivalent to an isotopic sample and analysis (where the determination of actual DDE and CEDE would not be timely).
5.1.2 RU2 Technical Basis Per ANSI/ANS-15.16, if the exposure time is < 24 hours, the EC multiplier can be increased proportionately, provided that the values of 2.4x103 and 1.2x103 EC-hour are used to declare an Unusual Event; the proportional increases are 5 for an alert and 25 for a site area emergency.
Using this relationship, the RU2 threshold values are one fifth the RA2 threshold values.
Direct measurement by survey instrument is considered equivalent for purposed of event declaration as isotopic sample and analysis to determine actual DDE would not be timely.
CDE thyroid is determined by portable air sample and gross count adjustment for I-131 source term assumptions.
5.1.3 RU3 Technical Basis Per ANSI/ANS-15.16, it is expected that licensees will determine the relationship of the EAL dose levels at the site boundary to instrumentation readings and/or safety analysis accident conditions for their specific facilities.
NTR Vent Stack Noble Gas Monitor instrument range is 1E-06 to 1E+01 NTR Vent Stack Particulate Monitor instrument range is 2E-11 to 2E-04 Refer to Appendix 3 for the calculations supporting the threshold values for RU3.
5.1.4 SU1 Technical Basis Per ANSI/ANS-15.16, the situation that may lead to an emergency class described in the subsections of NUREG-0849, Sec. 4.0 may be referenced as EALs appropriate to the emergency class.
Per NUREG-0849, situations that may lead to this class include: (1) threats to or breaches of security such as bomb threats or civil disturbances directed toward the reactor.
The SU1 security threat threshold is based on the ANSI/ANS-15.16-2015 initiating condition wording.
Page 20 of 40

VNC Radiological Emergency Plan                                                          June 2019 A civil disturbance alone would not meet the definition of an unusual event as conditions for this description could be as low as a single protester staging at the entrance to the site access road. However, a civil disturbance level consistent with the Unusual Event definition would be a credible security threat and declared per SU1.
5.1.5 SU2 Technical Basis Per ANSI/ANS-15.16, the situation that may lead to an emergency class described in the subsections of NUREG-0849, Sec. 4.0 may be referenced as EALs appropriate to the emergency class.
Per NUREG-0849, situations that may lead to this class include: (1) threats to or breaches of security such as bomb threats or civil disturbances directed toward the reactor.
The SU2 bomb threat threshold is based on the ANSI/ANS-15.16-2015 initiating condition wording clarified that the it be a credible threat for consistency with the SU1 security threat wording.
5.1.6 HU1 Technical Basis Per ANSI/ANS-15.16, the situation that may lead to an emergency class described in the subsections of NUREG-0849, Section 4.0 may be referenced as EALs appropriate to the emergency class.
Per NUREG-0849, situations that may lead to this class include: (2) natural phenomena, such as tornados in the immediate vicinity of the reactor, hurricanes, or earthquakes felt in the facility.
Tornado in the immediate vicinity of the reactor is defined as a tornado strike within the site boundary. Tornado EF rating is not a consideration as EF-0 winds are projected as 65 - 85 mph, which meets the intent of the initiating condition. Strike means that the tornado touched down.
Hurricanes have not historically been experienced at VNC. A threshold of sustained winds > 75 mph measured on site will be used to meet the intent of the initiating condition. Sustained means a period of at least 1 minute.
The combination of NTR Seismic Alarm and felt by personnel considered equivalent to an earthquake of Magnitude 4 at the site. Richter Scale Magnitude 4 earthquakes correlate to a level IV Modified Mercalli Scale identified as being felt indoors by many, by few outside, where dishes and windows rattle.
5.1.7 HU2 Technical Basis Per ANSI/ANS-15.16, the situation that may lead to an emergency class described in the subsections of NUREG-0849, Section 4.0 may be referenced as EALs appropriate to the emergency class.
Per NUREG-0849, situations that may lead to this class include: (3) facility emergencies, such as prolonged fires, fuel damage indicated by high coolant fission product activity, or high offgas activity.
Page 21 of 40

VNC Radiological Emergency Plan                                                     June 2019 The HU2 fire threshold is related to the ANSI/ANS-15.16-2015 initiating condition wording with the additional specification that the 15 minute time period begins when the fire is detected (by fire alarm or direct observation).
Coolant activity at VNC is monitored on a monthly basis and is not suitable as an EAL threshold.
Thresholds for abnormal radiological conditions, which include high gaseous activity are provided in the RUx series EALs.
Page 22 of 40

VNC Radiological Emergency Plan                                                                      June 2019 5.2   Alert ANSI/ANS-15.16 Table 1                            VNC Emergency Action Levels Abnormal Radiological Conditions Actual or projected radiological effluent at the    RA1 site boundary that is calculated (or measured)      Actual or projected dose at the site boundary:
to result in either of the following conditions,    * .:::. 75 mrem TEDE over a 24-hour period both ofwhich are based on an exposure of24 hours or less:                                      * .:::. 75 mrem CEDE over a 24-hour period (1) A deep dose equivalent of 0.75 mSv              RA2 (75 mrem)                                      Actual or projected dose rates at the site OR                                             boundary:
(2) A committed effective dose equivalent of        * .:::. 20 mrem/hr TEDE 0.75mSv (75 mrem) based on the following       * .:::. 100 mrem COE thyroid for 1 hour of considerations:                                   inhalation
* 500 EC X 24 hours = 1.2 X10 4 EC-hour        RA3
              ~0.75 mSv (75 mrem) (for radionuclides       Radiological effluent level (&#xb5;Ci/cc) meet any of other than noble gases)                      the following for greater than 60 minutes:
* 250 EC X 24 hours =6.0 X10 3 EC-hour         * .:::. 1.2E-4 NTR Noble Gas Stack Monitor
              ~0.75 mSv [75 mrem] (for noble gases)
                                                           * .:::. 1.2E-4 NTR Particulate Stack Monitor Actual or projected radiation levels at the site    * .:::. 1.2E-0 from any reactor facility effluent boundary of 0.2 mSv/hour deep dose                     Noble Gas sample equivalent (20 mrem/hour) for 1 hour or 1.0 mSv (100 mrem) to the thyroid (committed            * .:::. 2.4E-2 from any reactor facility effluent dose equivalent)                                       Halogen sample
                                                           * .:::. 1.2E-6 from any reactor facility effluent a Particulate sample
                                                           * .:::. 1.2E-4 from any reactor facility effluent 13 Particulate sample Security Conditions Security breach affecting the reactor facility      SA1 Security breach affecting a reactor facility 5.2.1 RAl Technical Basis The RAl threshold values are directly related to the ANSI/ANS-15.16-2015 initiating condition values.
For the purpose of event declaration, direct measurement by survey instrument adjusted for exposure period is considered equivalent to an isotopic sample and analysis (where the determination of actual DDE and CEDE would not be timely).
5.2.2 RA2 Technical Basis The RA2 threshold values are directly related to the ANSI/ANS-15.16-2015 initiating condition values.
For the purpose of event declaration, direct measurement by survey instrument adjusted for exposure period is considered equivalent to an isotopic sample and analysis (where the determination of actual DDE would not be timely).
Page 23 of 40

VNC Radiological Emergency Plan                                                       June 2019 CDE thyroid is determined by portable air sample and gross count adjustment for I-131 source term assumptions.
5.2.3 RA3 Technical Basis Per ANSI/ANS-15.16, it is expected that licensees will determine the relationship of the EAL dose levels at the site boundary to instrumentation readings and/or safety analysis accident conditions for their specific facilities.
NTR Vent Stack Noble Gas Monitor instrument range is 1E-06 to 1E+01 NTR Vent Stack Particulate Monitor instrument range is 2E-11 to 2E-04 Refer to Appendix 3 for the calculations supporting the threshold values for RA3.
5.2.4 SA1 Technical Basis The SA1 security breach threshold is based on the ANSI/ANS-15.16-2015 initiating condition wording and includes physical attacks and verification of bomb placement or sabotage directly affecting a reactor facility.
Page 24 of 40

VNC Radiological Emergency Plan                                                          June 2019 6    EMERGENCY PLANNING ZONEs (EPZs)
Planning Standard (ANSI/ANS-15.16 Section 3.6 & NUREG-0849 Section 6.0)
As part of emergency planning, the reactor licensee or owner/operator of a facility that identifies radiological emergencies that result in off-site plume exposures exceeding 10 mSv deep dose (1 rem whole body) or 50 mSv (5 rem) thyroid shall identify an EPZ.
The postulated radioactive releases from credible accidents provide the basis for determining the need for an EPZ. The EPZ size depends on the distance at which the protective actions are calculated to be warranted. As an alternative to performing such calculations, the EPZ sizes in Table 2 may be adopted according to the power level. Table 2 is based upon highly conservative dose calculations that are generically applicable to research reactors.
6.1     NTR EPZ Per the NTR Safety Analysis Report Section 1.1, the NTR is licensed to operate at power levels not in excess of 100 kW (thermal).
Thus, based upon ANSI/ANS-15.16-2015 Section 3.6 and Table 2, the applicable EPZ for NTR is the operations boundary for the reactor facility.
The NTR operations boundary is established as ((                  )).
6.2     GETR, VBWR, and EVESR EPZs The other three reactor facilities are in a defueled SAFSTOR status with the spent fuel no longer remaining on site.
Since the emergency planning requirements for these facilities are deferred to this VNC Regulatory Guide 2.6 emergency plan, their EPZ is based on the same specification as the NTR.
GETR, VBWR, and EVESR operations boundaries are established as their respective reactor containment enclosure.
Page 25 of 40

VNC Radiological Emergency Plan                                                             June 2019 7   EMERGENCY RESPONSE Planning Standard (ANSI/ANS-15.16 Section 3.7 & NUREG-0849 Section 7.0)
Emergency response measures shall be identified for each emergency. These response measures should be related to the emergency class and action levels that specify what measures are to be implemented.
7.1    Activation of Emergency Organizations Site Emergency Procedures (SEPs) are established for notification and mobilization of emergency response personnel.
7.1.1  Notification of Onsite Personnel and Mobilization of the ERO Notification of onsite personnel occurs each time an emergency classification level is declared by the Emergency Director (initial event declaration and any escalation) via
((
                                                                                      ] Provisions are made to alert personnel in high noise areas and outbuildings as applicable.
Notification and mobilization of the VNC ERO is described in section 3.1.
7.1.2 ((
          ))((                                              )) is declared or upgraded, initial notifications are made to continually ((                                    ))
((
                                                                                                )).
: 1. State Agencies (Cal OES)
Cal OES is notified ((                    )) of an event declaration (initial or an escalation).
: 2. Nuclear Regulatory Commission (NRC)
The NRC is notified immediately after notification of Cal OES ((
                           )) after event declaration (initial or an escalation).
7.1.3 ((
          ))((
Page 26 of 40

VNC Radiological Emergency Plan                                                         June 2019
                                                         ))
((
                  )).
7.2   Assessment Actions 7.2.1 Plant Parameters and Corresponding Emergency Classification Recognizable EAL thresholds have been developed in accordance with Regulatory Guide 2.6 and the NRC endorsed methodology in ANSI/ANS-15.16-2015 (refer to section 5).
EAL technical bases document the VNC site specific indications and parameters used to determine the thresholds that correlate to a particular emergency classification level (refer to section 5).
7.2.2 Onsite Accident Assessment Capabilities On-site capabilities and resources are available to provide information for accident assessment throughout the course of an event. Data will be obtained from in-place radiation monitors, portable instrumentation, and from observation and measurement by specific emergency teams.
Radiological instrumentation readings and sampling are used to project dose rates at the Site Boundary, and to determine the integrated dose received for events involving a release of radioactivity. Site emergency procedures address calculating accumulated or projected dose.
7.3   Corrective Actions VNC has strategies for mitigation of designated emergencies (such as radiological, fire, security threat, and other hazards) and has equipment available to be used in those strategies/mitigative actions.
The Emergency Director is responsible for assessing the need for and directing mitigation activities such as deactivation of process systems or restoration of disabled equipment needed to mitigate the consequences of an emergency. Additional assistance may be provided by other ERO positions upon arrival or via remote communications.
7.4   Protective Actions Preventive measures are implemented, to the extent practical, to prevent exposure of on-site personnel to radiological hazards; and in the event that prevention techniques fail, protective measures are in place to minimize the effects of such emergencies.
Page 27 of 40

VNC Radiological Emergency Plan                                                          June 2019 Protective measures are taken by ERO personnel and any support organization personnel called to the site. Initial actions to protect non-emergency team personnel may involve evacuation from facilities followed by search for and rescue of missing persons, medical treatment, decontamination, and other actions judged appropriate by the Emergency Director dependent on existing conditions.
7.4.1 Personnel Evacuation from Immediate Area Personnel may be evacuated from an area affected by an emergency or moved to areas controlled for safety purposes. The evacuation is initiated by ((
                                         ))
Typically, personnel evacuate their facility by following established routes to a pre-designated assembly area, which is posted in each facility. Alternate routes and/or alternate assembly areas may be determined and directed by the Building Emergency Coordinator if travel to or conditions at the designated assembly area are hazardous. The Building Emergency Teams will assist in the orderly evacuation of facilities. Additional instructions may be relayed by the Emergency Director [
                                                                                              ))
The Assembly Area Leader from the Building Emergency Team will conduct personnel accountability at the assembly area to determine whether there missing employees; security personnel will identify visitors that were expected to be at that location. Reports of missing persons are relayed to the Emergency Director for appropriate search and rescue action.
7.4.2 Contamination Control Measures In response to an emergency involving a potential release of radioactive material, it is assumed that a release has occurred. The ERO establishes access controls to the area (such as rope/tape barriers, building access points, postings, control point watches, periodic announcements, etc.), determines whether radioactive contamination is present by survey, and takes appropriate steps to limit personnel exposure to and the spread of radioactive contamination. Area contamination information is provided to the Emergency Director and tracked by the ERO.
Emergency workers are protected from contamination by protective clothing available in emergency supply lockers. In order to protect emergency workers in areas of radioactive airborne contamination, self-contained breathing apparatuses (SCBA) or filtered respirators are available for use as appropriate.
Contaminated individuals are treated and decontaminated in isolated areas.
7.4.3 Personnel Decontamination/First Aid Individuals are surveyed and then decontaminated as necessary. If an individual is contaminated and injured, the order of decontamination/first aid administration is dependent on the severity of the contamination and injury. The criteria for deciding the order is that which is least detrimental to the overall health of the individual.
Page 28 of 40

VNC Radiological Emergency Plan                                                            June 2019 7.4.4 Emergency Exposure Control and Guidelines Identification and control of radiation areas is performed the same as described in Section 7.4.2 for radioactive contamination. Measures and criteria for radiation, high radiation and locked high radiation areas encountered during a declared emergency are established the same as those used during normal operations as much as possible.
Direct exposures of emergency workers are monitored by remote area monitoring (RAM) devices, portable survey instruments, and by the individuals own personal monitoring devices (such as electronic dosimeters). A supply of electronic dosimeters that can be set to alarm for dose and dose rate values are maintained on site for emergency worker use.
Personnel exposure information is provided to the Emergency Director and tracked by the ERO.
Emergency exposure guidelines for emergency workers, consistent with EPA 400-R       001, PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents, Table 3-1, "Emergency Worker Guidelines," have been established as follows:
Guideline                      Activity                            Condition 5 rem       All occupational exposures            All reasonably achievable actions have been taken to minimize dose.
10 rema      Protecting critical infrastructure    Exceeding 5 rem unavoidable and all necessary for public welfare (e.g., a appropriate actions taken to reduce power plant)                          dose.
Monitoring available to project or measure dose.
25 rem      Lifesaving or protection of large     Exceeding 5 rem unavoidable and all populations                           appropriate actions taken to reduce dose.
Monitoring available to project or measure dose.
          >25 rem      Lifesaving or protection of large     All conditions above and only for populations                           people fully aware of the risks involved.
a   For potential doses >5 rem (50 mSv), medical monitoring programs should be considered.
Page 29 of 40

VNC Radiological Emergency Plan                                                            June 2019 8    EMERGENCY FACILITIES AND EQUIPMENT Planning Standard (ANSI/ANS-15.16 Section 3.8 & NUREG-0849 Section 8.0)
The emergency plan should briefly describe the emergency facilities, types of equipment and their location.
8.1     Emergency Control Center (ECC)
During an emergency [
                                                          ]
((
                              ].
8.2     Assessment Facilities The reactor facilities are monitored by area radiation monitors (ARMs) and effluent radiation (stack) monitors as required by their technical specifications. Radiation monitors with remote readouts permit continuous assessment in some areas.
Other monitoring devices are utilized to identify off-normal conditions, such as smoke detectors, fire and flood alarms, and onsite and offsite seismic and meteorological indicators. Several of these devices activate alarms locally and((                    )) for immediate response and assessment.
Portable survey and personnel monitoring instruments are maintained throughout the site and are available for use during an emergency.
Sampling equipment and a counting laboratory are available on site and offsite for specific radionuclide identification and analysis. Company vehicles are available for use by emergency response personnel. Communication from the area experiencing the emergency is possible ((
                                                                                            ))
8.3     First Aid and Decontamination Equipment The site contains numerous areas where radioactive materials are used. Consequently, there are numerous areas where contaminated injured individuals may be relocated for first aid administration and decontamination. On site company vehicles are available for transportation.
First aid supplies, stretchers, industrial showers, and AEDs are available at the site.
GEH will provide a radiation monitor to assist in the control and cleanup of contamination of ambulance and offsite medical facilities used when treating contaminated injured personal transported from the site as necessary.
Page 30 of 40

VNC Radiological Emergency Plan                                                          June 2019 8.4   Communications Equipment 8.4.1 ((
         ))((
                                                                                  )).
8.4.2 ((
         ))[
                                   )).
8.4.3 ((
         ))((
                              )).
8.4.4 ((
         ))[
                                                           )).
8.4.5 ((
         ))((
                                                                                        )).
8.4.6 ((
         ))[
                      ].
8.5   Contingency Planning Procedures include instructions for consideration in case the emergency renders the ECC or equipment employed during the response unusable. The VNC site contains several facilities that can be designated response locations should the ECC be unavailable. First-aid, personnel protective clothing, radiological, fire-fighting, etc. equipment and resources are maintained throughout the site such that access restrictions to a particular area would not likely result in the inability to perform necessary response activities.
Mutual aid agreements between offsite support agencies provides assurance that fire, medical and law enforcement resources would be available when called upon.
Page 31 of 40

VNC Radiological Emergency Plan                                                              June 2019 9    RECOVERY Planning Standard (ANSI/ANS-15.16 Section 3.9 & NUREG-0849 Section 9.0)
This element of the emergency plan should describe the criteria for restoring the reactor facility to a safe status including reentry into the reactor building or portions of the facility that-may have been evacuated because of the accident. The operations to recover from most severe accidents will.be complex and depend on the actual conditions at the facility. It is not practicable to plan detailed recovery actions for all conceivable situations.
9.1     Reentry During an emergency, immediate actions are directed toward limiting the consequences of the accident to afford maximum protection to personnel onsite. Once corrective measures have been taken and effective control of the facility has been reestablished, a more methodical approach to reentry is taken. Reentry into two separate categories:
Reentry during the emergency phase of an accident is performed to save a life, control a release of radioactive material, prevent further damage to or restore equipment. If necessary, this category of reentry may be performed using emergency exposure limits. Briefings, rather than written procedures, may be used when making these reentries.
All reentry activities conducted during the emergency are authorized by the Emergency Director and coordinated by Incident Command.
Reentry during the recovery phase of an accident is performed using normal occupational exposure limits. Either normal procedures or procedures developed specifically for each reentry are used to control post-emergency activities.
Reentry activities during the recovery phase are authorized by a Recovery Director or the VNC Manager, and coordinated by the recovery personnel directing and performing the reentry.
9.2     Recovery During a declared emergency, a point will be reached when the facility will be restored to a stable condition. The Emergency Director will determine when there is no longer a need to keep the ERO activated and the site can return to a normal organization for control.
The extent and nature of the corrective and protective measures and the extent of facility recovery will depend on the remaining conditions, if any, and the status of site areas and equipment. The general goals for recovery are:
An orderly evaluation of the cause and effect of the event and the implementing of actions to prevent recurrence of the incident.
A planned approach for maintaining the facility in a stable condition by obtaining the appropriate manpower, materials, and equipment needed to accomplish that end.
Page 32 of 40

VNC Radiological Emergency Plan                                                     June 2019 An evaluation of the emergency radiation exposure records for all on-site emergency response personnel involved in the incident.
A planned approach to ensure that further radiation exposures and contamination control are restored under 10 CFR 20 requirements and are in keeping with the ALARA program.
Procedures have been developed for the systematic transition from the declared state of emergency to recovery and termination.
Page 33 of 40

VNC Radiological Emergency Plan                                                           June 2019 10 MAINTAINING EMERGENCY PREPAREDNESS Planning Standard (ANSI/ANS-15.16 Section 3.10 & NUREG-0849 Section 10.0)
The emergency plan shall describe the elements necessary for maintaining an acceptable state of emergency preparedness. A description shall be provided of how the effectiveness of the emergency plan will be maintained, including training, review, and update of the emergency plan and associated implementing procedures along with maintenance and inventory of equipment and supplies that would be used in emergencies. Frequent coordination with emergency support organizations should also be maintained to ensure the necessary training and the efficient use of their capabilities.
10.1    Training and Drills 10.1.1 Training ERO personnel receive the appropriate level of site access, radiological, communications systems, facility evacuation, and position specific training. The training for ERO personnel is primarily developed from the position specific responsibilities and tasks as defined in this plan and the site emergency procedures.
Emergency response and other personnel in the following categories receive knowledge and/or performance based training initially and annual retraining thereafter:
: 1. Emergency Directors This position receives training to maintain proficiency on the topics listed below:
Event Classification / Emergency Action Levels Event Notification and Communications Accident Assessment and Mitigation Protective Actions / Emergency Exposure Control
: 2. Accident Assessment Personnel Accident assessment activities are performed by Emergency Directors, Facilities Managers (as applicable), and GEH operations, radiological, security and maintenance managers as a function of their areas of expertise and ERO roles.
: 3. Radiological Monitoring and Analysis Teams Radiological monitoring personnel will receive training for the actions they will be expected to perform during an emergency as part of their training. The following general topics will be included in the training:
Equipment and Equipment Checks Emergency Communications Radiological Release Surveys and Sampling Page 34 of 40

VNC Radiological Emergency Plan                                                               June 2019 Emergency Exposure Control
: 4. First Aid and Rescue Personnel A number of site employees are trained in first aid.
Basic search and rescue activities may be performed by ERO personnel as part of event response.
: 5. Medical Support Personnel VNC does not maintain medical support personnel, such as a site nurse on staff.
: 6. Police, Security, Ambulance and Fire-Fighting and Other Personnel a) Training of site security personnel is controlled by the VNC Security Plan.
b) Building Emergency Team members receive initial training and annual reviews in respiratory protection, radiological protection, first aid, fire protection and emergency support as appropriate for their assigned responsibilities.
c) The Site Fire Chief is responsible for fire protection training of designated personnel assigned to the site fire team, which is controlled outside this emergency plan as defined by the site fire protection program.
d) Training is offered to the offsite support organizations that may be called upon to provide assistance in the event of an emergency (i.e., local law enforcement, fire-fighting, rescue, medical services, ambulance).
The training made available is designed to acquaint the participants with the special characteristics of VNC (e.g. potential radiation and radiological contamination areas), notification procedures, and their expected roles. Organizations that must enter the site also receive instructions as to the identity (by position and title) of those VNC persons who will control their support activities.
e) Badged site personnel who are not part of the ERO are instructed in reporting and responding to alarms.
10.1.2 Conduct of Drills Drills are conducted annually to provide supervised instruction, training and practice opportunities for ERO members and are executed as realistically as is reasonably possible.
Written scenarios, prepared in advance, govern the conduct of annual drill and include the following as applicable:
General Information - A section containing the scope of the scenario, time period, place(s), and participating organizations.
Timeline - A section containing the time schedule of initiating events.
Page 35 of 40

VNC Radiological Emergency Plan                                                           June 2019 Messages - A section for plant data, injects, messages, and symptomology cards.
Onsite Radiological Data - A section for area radiation maps and display system snapshots, if warranted by the scenario events.
Objectives - A section containing a table of performance objectives expected to be demonstrated during the scenario.
Participant/Controller/Evaluator/Observer Instructions - as applicable to the drill.
Smaller response proficiency drills, such as evacuation drills, may be performed in addition to the larger scope annual drill in each occupied building at VNC.
At least every two years, a drill shall be offered that contains provisions for coordination with off-site emergency personnel and should test, at a minimum, the communication links and notification procedures with those off-site agencies and support organizations.
10.1.3 Critique of Drills Following the observation of drills, a critique is conducted to evaluate areas such as personnel performance, response procedure processes, and facility and equipment adequacy and identify issues. Specifically, the critique is performed as soon as possible following the conclusion of a drill using preselected performance objectives that are evaluated against measurable demonstration criteria.
A written critique report is prepared a drill to document whether the objectives were successfully demonstrated. Failed or degraded performance objectives are entered into the corrective action program (CAP). Failed or degraded demonstration criteria, improvement items and recommendations are dispositioned within the report and may be entered into the CAP.
10.2   Plan Review and Update 10.2.1 Responsibility for the Plan The Manager, VNC is the senior GEH employee on site with overall authority for site operations. This authority includes the responsibility for overall emergency preparedness activities at VNC.
The Manager, RC & EHS, is responsible for administering the program by coordinating and planning radiological emergency preparedness, updating the emergency plan, and coordinating plans with other appropriate organizations.
10.2.2 Review and Update The Emergency Plan will be reviewed to be current on a biennial basis, and updated if necessary. Any changes due to regulatory revisions, issues identified by drills and exercises, or other updates will be incorporated into the Emergency Plan.
Page 36 of 40

VNC Radiological Emergency Plan                                                       June 2019 Agreements with supporting organizations will be reviewed on a biennial basis, and updated if necessary. Changes to agreements may be coordinated with the biennial review of the Emergency Plan. VNC maintains the following support agreements:
: 1. Faulk Northern California - Applicable to Sections 3.3.1, First Aid Assistance, and 3.3.3, Ambulance Service
: 2. The Hospital Committee for the Livermore-Pleasanton Areas - Applicable to Section 3.3.2, Medical Treatment Facilities
: 3. Alameda County Fire Department - Applicable to Section 3.3.4, Firefighting Assistance
: 4. Alameda County Sheriff's Office - Applicable to Section 3.3.5, Police Assistance Emergency plan implementing and administrative procedures are reviewed biennially or when revised as needed.
Changes will be processed in accordance with 10 CFR 50.54(q) requirements and distributed per site procedures.
10.3 Maintenance and Inventory of Emergency Equipment, Instrumentation, and Supplies In addition to supplies of normal use equipment and instruments, emergency kits are maintained at VNC. Annual inventories and quarterly surveillances are performed to verify supplies and kit contents, and inspect and operationally check emergency use equipment/instruments. The inventories will utilize the corrective action program to document follow-up action items that correct any deficiencies discovered. Sufficient reserves of instruments and equipment are maintained to replace those removed from emergency kits or lockers for calibration or repair.
Requirements to operationally check emergency equipment and instruments prior to use, if needed, are contained in site procedures.
Requirements to calibrate emergency equipment and instruments are specified in site procedures.
Portable radiation monitoring instruments are calibrated upon initial acquisition, after major maintenance and at least annually. Radiation Protection is responsible for the maintenance and storage of radiological equipment and instruments.
Page 37 of 40

VNC Radiological Emergency Plan                                                   June 2019 Appendix 1 - Regulatory and Developmental References
: 1. 10 CFR 20, Standards for Protection Against Radiation
: 2. 10 CFR 50.54, Conditions of Licenses
: 3. 10 CFR 50 Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities
: 4. Regulatory Guide 2.6, Emergency Planning for Research and Test Reactors, Revision 2
: 5. ANSI/ANS-15.16-2015, Emergency Planning for Research Reactors
: 6. NUREG-0849, Standard Review Plan for the Review and Evaluation of Emergency Plans for Research and Test Reactors, October 1983
: 7. EPA 400/R-17/001, PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents, January 2017
: 8. General Electric Nuclear Test Reactor Safety Analysis Report, June 2000
: 9. NRC Letter SNM-960 Amendment 5, 12/20/90
: 10. GEH Memo, Evaluation that a VNC Radiological Emergency Plan is not Required for Radioactive Material Authorized by the State of California, 03/08/18 Page 38 of 40

VNC Radiological Emergency Plan                         June 2019 Appendix 2 - Emergency Plan Implementing Procedures Response Procedures REP 1.1, ECC Activation and Operation REP 1.2, REP Emergency Classification and Notifications REP 1.3, REP Protective Actions REP 1.4, REP Response Actions Maintenance and Administrative Procedures REP 2.1, Maintenance and Review of REP Documents REP 2.2, Equipment Important to Emergency Response REP 2.3, REP Training and Qualification CP-28-116, REP Drills and Exercises Page 39 of 40

VNC Radiological Emergency Plan                                                                                                 June 2019 Appendix 3 - EAL Technical Bases for Effluent Releases Method: 10 CFR 20 effluent concentration limits, representative of a 50 mrem/yr dose, are adjusted to an equivalent concentration limit for the EAL site boundary threshold value in mr/hr.
The site boundary EAL concentration limit is back-calculated to an effluent stack release rate using the limiting SAR X/Q dispersion factor and stack flow rate.
RU3 Site Boundary                       RU3 NTR Stack 10 CFR 20 RU3 NTR Stack Release Concentration                   Release Concentration Concentration Limit Release Rate
(&#xb5;Ci/cc)              (&#xb5;Ci/cc)                (&#xb5;Ci/sec)       (&#xb5;Ci/cc) 10 CFR 20 Unknown*                 1.00E-12               7.01E-10                2.02E+01        2.37E-05 Noble Gas**         Ar-41 1.00E-08                7.01E-06                2.02E+05        2.37E-01 Halogen**          I-131 2.00E-10               1.40E-07                4.03E+03        4.74E-03 Alpha Particulate**      Np-237 1.00E-14                7.01E-12                2.02E-01        2.37E-07 Beta-Gamma Particulate**               1.00E-12               7.01E-10                2.02E+01        2.37E-05 RA3 Site Boundary                       RA3 NTR Stack 10 CFR 20 RA3 NTR Stack Release Concentration                   Release Concentration Concentration Limit Release Rate
(&#xb5;Ci/cc)              (&#xb5;Ci/cc)                (&#xb5;Ci/sec)       (&#xb5;Ci/cc) 10 CFR 20 Unknown*                 1.00E-12               3.51E-09                1.01E+02 1.19E-04 Noble Gas**         Ar-41 1.00E-08                3.51E-05                1.01E+06 1.19E+00 Halogen**          I-131 2.00E-10               7.01E-07                2.02E+04 2.37E-02 Alpha Particulate**      Np-237 1.00E-14                3.51E-11                1.01E+00 1.19E-06 Beta-Gamma Particulate**               1.00E-12               3.51E-09                1.01E+02 1.19E-04 Calculation Constants 10 CFR 20 Effluent Concentration Dose Basis (mrem/yr):    50 10 CFR 20 Effluent Concentration Dose Basis (mrem/hr): 5.70E-03 EAL RU3 Limit (mr/hr):                          4 EAL RA3 Limit (mr/hr):                          20 Limiting X/Q* (sec/cc): 3.48E-11 NTR Bldg 105 Stack Flow Rate* (cfm):     1800 Conversion Factor (cc/sec per cfm): 471.95 NTR Bldg 105 Stack Flow Rate (cc/sec): 8.50E+05
* 10 CFR 20 limit for unlisted (unknown) radionuclide with decay mode other than alpha emission or spontaneous fission and with radioactive half-life greater than 2 hours.
  ** Values taken from NTR SAR Section 6.4 Page 40 of 40}}