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{{#Wiki_filter:MAINE YANKEE321 Old Ferry Road, Wiscasset, Maine 04578December 15, 2015OMY- 15-055Re: 10 CFR 50.54(q)(5)10 CFR 72.44(f)10 CFR 50.4(b)(5)10 CFR 72.4ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-000 1Maine Yankee Atomic Power CompanyMaine Yankee Independent Spent Fuel Storage InstallationNRC License No. DPR-36 (NRC Docket No. 50-309)
 
==Subject:==
Revision 7 to Maine Yankee ISFSI Emergency PlanIn accordance with 10 CFR 50.54(q)(5), 10 CFR 72.44(f), 10 CFR 50.4(b)(5), and 10 CFR 72.4,Maine Yankee Atomic Power Company (Maine Yankee) is providing Revision 7 of the MaineYankee Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan, and a summary ofthe analysis that determined that the changes do not constitute a reduction in commitment, nor adecrease in effectiveness of the Maine Yankee ISFSI Emergency Plan.Attachment 1 provides a summary of the evaluation that provides the basis for concluding theMaine Yankee ISFSI Emergency Plan, as changed, continues to meet the standards of 10 CFR50.47(b) and the requirements of Appendix B to Part 50 as modified by the existing exemptionsfor the Maine Yankee ISFSI.Enclosure 1 provides a copy of Revision 7 of the Maine Yankee ISFSI Emergency Plan. It waseffective on December 15, 2015.This letter contains no commitments.If you have any questions regarding this submittal, please do not hesitate to contact me at(207) 882-1303.Respectfully,~Stanley PBEISFSI Manager Maine Yankee Atomic Power CompanyOMY- 15-055/December 15, 201 5/Page 2Attachments and EnclosuresAttachment 1 -Summary of 10 CFR 50.54(q) Evaluation for Changes to the Maine Yankee ISESIEmergency PlanEnclosure 1 -Maine Yankee ISFSI Emergency Plan, Revision 7cc: D. Dorman, NRC Region I AdministratorM. S. Ferdas, Chief, Decommissioning Branch, NRC, Region IM. Lombard, Director, Division of Spent Fuel Management, NM4SSJ. Goshen, NRC Project ManagerP. J. Dostie, SNSI, State of MaineJ. Hyland, State of Maine  to OMY-15-055Summary of 10 CFR 50.54(q) Evaluation for Changes to theMaine Yankee ISFSJ Emergency PlanSection /Table Description of Proposed Change Justification of Proposed ChangeThrough-out Changed title Emergency This is a change to standardize to thethe Emergency Coordinator to Emergency same title at all three Yankee sites.Plan Director or EC to ED.Through-out The Emergency Plan has been These changes are editorial and clericalthe Emergency reformatted and renumbered as in nature and have no impact on thePlan. needed to support this change. intent of the Emergency Plan.Table 4-1 Deleted a reviewer's note that was This is an administrative change.incorporated into revision 6inappropriately.Section 5.3.3 This section has been revised to This is a change to permit the Radiationclarify that if personnel become Protection personnel to determine wherecontaminated they will be the monitoring and decontaminationmonitored by Radiation Protection will be performed.Personnel. It also eliminates therequirement to perform this_____________activity at a specific point.Section This section has been revised to This is a clarification of duties andadd that Protective Clothing (PCs) responsibilities making the Radiationwill be provided by the Radiation Protection contractor responsible toProtection contractor, supply PCs.Section 8.1.2 Changed title from General This is a clarification to identify theEmployee Training (GET) to current title of the site training program.ISFSJ Access Training.Chapter 11, Added reference to NRC RIS This is an administrative, change thatReferences 2015-14 "Issuance of Enforcement adds a new guidance document.Guidance Memorandum -Emergency Plan and EmergencyPlan Implementing ProcedureUpdates", issued 10/30/15.Appendix II Updated FP-1 title and updated This is a clarification and administrativePhysical Security Plan full title. change.Page 1 of 2  to OMY-15-055Summary of 10 CFR 50.54(q) Evaluation for Changes to theMaine Yankee ISFSI Emergency PlanSection /Table Description of Proposed ChangeJustification of Proposed ChangeAppendix III,EmergencyPlanImplementingProceduresDeleted EO-6, Non-EmergencyEvent Assessment as anEmergency Plan ImplementingProcedure.Deleted EO-3 and EO-4 asEmergency Plan ImplementingProcedures because their contentwas relocated into EO-2.EO-2 was renamed. The originalcontent of EO-2 was moved toOP-1, because it was not requiredto implement the Emergency Plan.EO-6 never implemented theEmergency Plan. A self-assessmentestablished that the actions in EO-6 didnot meet the intent or definition of animplementing procedure.The self-assessment identified thefollowing procedures as EmergencyPlan Implementing Procedures inaccordance with Appendix E to Part 50:EO-l -Emergency PlanImplementationEO-2 -Response to Accident andNatural Phenomena EventsEO-5 -Emergency Plan AdministrationThese procedures contai-n-the followingas required by Appendix E of Part 50:* Organization (Emergency)* Assessment Actions* Activation of the EmergencyOrganization* Notification Procedures* Emergency Facilities andEquipment* Training* Maintaining EmergencyPreparedness* RecoveryThe current EO-2 off normal actionshave been incorporated into OP-ibecause it did not implement theEmergency Plan. EO-2 has been revisedto incorporate EO-3 and EO-4 into thenew EO-2, titled "Response to Accidentand Natural Phenomena Events". EO-3and EO-4 have been cancelled.Page 2 of 2 ENCLOSURE 1 TO OMY-.15-055MAINE YANKEE ISFSI EMERGENCY PLAN, REVISION 7 MAINE YANKEEIN DEPENDENT SPENT FUELSTORAGE INSTALLATION(ISFSI)EMERGENCY PLANREVISION 7Effective Date: December 15, 2015 TABLE OF CONTENTSSection PageTABLE OF CONTENTS iiAPPENDICES iLIST OF TABLES vLIST OF FIGURES viDEFINITIONS vii
 
==1.0 INTRODUCTION==
1:12.0 FACILITY DESCRIPTION2.1 Maine Yankee Site 2.12.2 General Area 2.12.3 Independent Spent Fuel Storage Installation 2.23.0 ISFSI ACCIIDENT TYPES, DETECTION AND CONSEQUENCES3.1 Radiological Events 3.13.2 Non-radiological Events 3.14.0 CLASSIFICATION OF ACCIDENTS4.1 Definitions 4.14.2 Categories of Events 4.15.0 EMERGENCY RESPONSE5.1 Notification and Activation 5.15.1.1 Maine Yankee Emergency Support Staff 5.15.1.2 Offsite Organizations 5.15.1.3 Information to be Communicated 5.25.2 Radiological Assessment 5.25.3 Protective Actions 5.25.4 Coordination with Offsite Agencies 5.56.0 FACILITIES AND EQUIPMENT6.1 Control Center 6.16.2 Radiation Controls Checkpoint 6.16.3 Assembly Areas 6.16.4 Equipment 6.16.5 Communications 6.26.6 Fire Suppression 6.2REV 7 TABLE OF CONTENTS(Continued)Section Page7.0 RESPONSIBILITIES7.1 On-shift Organization 7.17.2 Augmented Organization 7.28.0 MAJINTAINING EMIERGENCY PREPAREDNESS8.1 Training 8.18.2 Review and Updating of the ISFSI Emergency PlanAnd Implementing Procedures 8.28.3 Drills and Exercises 8.38.4 Independent Program Review 8.39.0 RECOVERY 9.1*10.0 OFIFSITE ASSISTANCE 10.1
 
==11.0 REFERENCES==
11.1i11REV 7 APPENDICESAPPENDIX I -Assistance Agreements I-1APPENDIX II -Supporting Plans and Documents 11-1APPENDIX Ill -Emergency Plan Implementing Procedures III-i1ivREV 7 LIST OF TABLESNumber Title4-1 Emergency Action Levels5-1 Guidance on Dose Limits for Emergency Workers(EPA-400-R-92-00 1)Page4.35.4REV"7 LIST OF FIGURESNumber Titl.__e Tawe2-1 Maine Yankee Site -General Area 2.32-2 Maine Yankee Site -Facility Layout 2.45-1 Maine Yankee Initial Notification and Activation Process 5.67-1 Maine Yankee On-Shift Organization 7.3REV 7 DEFINITIONSASSEMBLY AREAS -Designated locations where personnel may be directed to congregate mnthe event of the need to evacuate all or portions of the facility.ASSESSMENT ACTIONS -Actions taken during or after an emergency event or accident toobtain and process information necessary to implement specific emergency measures.CONFINEMENT BOUNDARY -The confinement boundary of the canister consists of thecanister shell, bottom plate, shield lid, structural lid, the two port covers, and the welds that jointhese components.CONTROL CENTER (CC) -During an emergency the lunch/conference room or otherdesignated area in the security/operations building functions as the emergency Control Center(CC) operating under the direction of the Emergency Coordinator. It is the primary point atwhich 1SF SI conditions are tracked and corrective actions are taken to mitigate any abnormalconditions.CONTROLLED AREA -The designated area outside of the Protected Area (PA), extending atleast 300 meters from the spent fuel storage pads, over which control is exercised duringemergency events pursuant to 10 CFR 72.106(b).CORRECTIVE ACTIONS -Measures to reduce the severity of (or terminate) an emergencysituation.EMERGENCY ACTION LEVEL (rEAL) -Conditions that, if met or exceeded, warrantclassification and declaration of an emergency.EMERGENCY DIRECTOR (ED) -The ED is responsible for the overall coordination anddirection of the company response to an emergency condition at the ISFSI.EMERGENCY SUPPORT STAFF -A group of trained staff designated to respond to a'declared emergency, if necessary.GREATER THTAN CLASS C WASTE (GTCC) -Radioactive waste material that is notgenerally acceptable for near surface disposal is waste for which form and disposal methods mustbe different, and in general more stringent, than those specified for Class C waste. The MaineYankee Core Shroud Assembly and Core Support Plate are considered GTCC waste and will bestored at the ISFSI.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) -A spent fuel storagefacility owned and operated by Maine Yankee, comprised of a Protected Area (PA) containingsixteen storage pads having 64 cask locations for dry storage of spent fuel and GTCC waste, asecurity/operations building and an earthen berm partially surrounding the site.INITIATING CONDITION (IC) -ISFSI parameters, equipment status and/or personalobservations that comprise the individual EALs.LOCAL ORGANIZATIONS -Those organizations that provide specific services underemergency conditions (i.e. police, ambulance and fire department).viiREV 7 DEFINITIONS(Continued)UNUSUAL EVENT (UIE) -Events are in progress or have occurred which indicate a potentialdegradation of the level of safety of the facility. No release of radioactive material requiringoffsite response or monitoring is expected.PROTECTED AREA (PA) -The area, encompassed by physical barriers, within the secured,controlled access boundary of the ISFSI.ISFSI SHIFT SUPERVISOR (ISS) -The senior ISFSl representative on-shift. The ISSassumes the position of IS S/ED upon classification and declaration of an unusual event.REV 7
 
==1.0 INTRODUCTION==
This document describes the Maine Yankee Atomic Power Company's (MYAPC) planfor responding to emergencies that may arise at the Maine Yankee Independent SpentFuel Storage Installation (ISFSI). The overall purpose of the plan is to delineate theactions necessary to safeguard ISFSI personnel and minimize damage to site property inthe event of an incident at the ISFSI. Analyses of the possible design basis events andconsequences are presented in the Safety Analysis Report for the UMS UniversalStorage System (NAC UMS SAR) used at the ISFSI for dry spent fuiel storage.The analyses of the potential radiological impact of an accident at the Maine Yankee siteindicates that any releases beyond the ISESI Controlled Area boundary are expected to beless than the U.S. Environmental Protection Agency (EPA) protective action guide (PAG)exposure levels, as detailed in EPA-400-R-92-001, Manual of Protective Action Guidesand Protective Actions for Nuclear Incidents. Exposure levels which may warrant pre-planned response measures are generally limited to the Controlled Area. For this reason,radiological emergency planning is focused on the Controlled Area.1.1REV 7 2.0 FACILITY DESCRIPTION2.1 Maine Yankee Site2.1.1 OverviewThe Maine Yankee site is located in the town of Wiscasset, Lincoln County, Maine. Sitecoordinates are approximately 43 degrees 57 minutes 5 seconds north latitude and 69degrees 41 minutes 45 seconds west longitude. The site is bounded by the Back River onthe east, mainland on the north and Bailey Cove on the west. The ISFSI is located on apeninsula known as Bailey Point, which extends south to Montsweag Bay (Figure 2-1).The ISFSI facility is depicted on Figure 2-2. Spent nuclear fuel is in interim storagewithin the specified secure fuel storage area and will be monitored by the ISFSJ staff.2.2 General AreaWithin 5 miles of the site, land use is largely rural residential, small businesses, summerhouses, idle farmland and forest. Housing is scattered along principal roads and isconcentrated only in the center of Wiscasset.The waters of the Back River, Montsweag Bay and associated tributaries are tidal andopen to boating, both commercial and recreational. Regulation of boating is theresponsibility of the U.S. Coast Guard and the State of Maine. The primary type ofboating in the Mon._tswe~ag B~ay -Back River is shallow draft Pleasure boats. With nocommercial traffic in the area, there is essentially no hazard to the site from potentialaccidents with commercial barges or boats carrying hazardous, toxic or explosivematerials.Industrial activity within the general area of the JSFSJ is minimal. The largest industrialfacility is the Bath Iron Works, a shipbuilding facility located on the Kennebec Riverapproximately 7 miles southwest in the city of Bath.The Wiscasset Municipal Airport is the nearest airport to the site and is locatedapproximately one .mile northwest of the site. It consists of one runway (approximately3,400 feet long by 75 feet wide). This runway is aligned such that takeoffs and landingsare on headings of either 070 or 250 (the predominant heading is 250). The majorities ofaircraft that are serviced by this facility are privately owned and are similar to the PiperColt, Cherokee, and Cessna 150 and 172 type craft. The largest aircraftthat typically usethe facility are similar to the Lear 25, Citation II and Rockwell Commander type craft.2.1REV 7 2.3 Independent Spent Fuel Storage Installation (ISFSI)The ISFSI is designed for interim storage of fuel for a minimum of 50 years in acontained shielded system. The ISFSI utilizes the Universal MPC System (UMSTM)developed by NAC International. The UMSTM is a canister-based multi-purpose canister(MPG) system designed for both storage and transportation of spent nuclear fuel. Thecanister-based spent fuel storage system is a passive system which utilizes an outerconcrete cylinder called a Vertical Concrete Cask (VCC) to protect and shield the innersealed metal canister. The VCC is vented for natural convection cooling and has nomoving parts. Decay heat from the loaded fuel storage canister in the VCC is dissipatedto the surrounding air by a once through buoyancy driven airflow. The VCC providesradiation shielding, as well as protection from tornado missiles and earthquakes.The ISFST site consists of a Protected Area (PA) for fuel storage and aSecurity/Operations Building. The ISFSI has a Controlled Area that extends at least 300meters from the nuclear fuel storage area.The PA has sixteen concrete storage pads, and is surrounded by a security fence and anuisance fence with an isolation zone between the two fences. A partial earthen berm isprovided around the facility to reduce the visual impact of the facility. The ISFSI containsa total of 64 storage casks, with one sealed fuel canister per VCC. The types of canistersstored in the storage casks include 60 casks for spent fuel and 4 casks for Greater ThanClass C (GTCC) waste. Sixteen storage pads of equal size are provided for uniformity,which allows for storage of 4 casks per storage pad. The ISFSI site is arranged to providemaneuvering room around the storage pads for access with a cask heavy haul tractor-trailer.The Security/Operations Building provides offices and work space for the operating andmaintenance personnel, including the Radiation Controls Checkpoint lunch/conferencerooms, restrooms, locker rooms, document control room, spare parts storage, and a dieselgenerator for emergency power. The Security/Operations Building also houses the ISFSJsecurity staff, security equipment, and communications equipment. Access to the ISFSIprotected area is controlled and monitored by the security staff.The ISFSI operates under the provisions of a general license utilizing the UJMSTM spentfuel storage/transportation system. The UMSTM system is licensed under a Certificate ofCompliance issued by the U.S. Nuclear Regulatory Commission (NRC) in accordancewith 10 CFR Part 72, "Licensing Requirements for the Independent Storage of SpentNuclear Fuel and High-Level Radioactive Waste".2.2REV 7 FIGURE 2-1MAINE YANKEE SITEGENERAL AREAII fI;.so~cE- USGS OUAD~AM.- WEST--:',:' I. iSWJESS AE/90..1 "" eifSZALE'" Fa2.3oREV 7 FIGURE MAINE YANKEE SITE* 4,*BERMl2.4REV 7 3.0 ISFSI ACCIDENT TYPES. DETECTION AND CONSEQUENCES3.1 Radiological EventsThere are no postulated credible ISFSI accident conditions that would impose aradiological hazard to personnel beyond the ISFSI Controlled Area boundary. There areno credible design basis accidents that would exceed the EPA PAGs at the ISESIControlled Area boundary. In the event of an ISFSI accident condition, the associatedradiological hazards are limited to personnel onsite at the time of the event.The postulated ISFSI accident conditions are described in Chapter 11 of the SafetyAnalysis Report for the UMS Universal Storage System developed by NAC International(Reference 4).3.2 Non-Radiological EventsThe spectrum ofIJSFSI non-radiological events that could necessitate implementation ofthis Emergency Plan is limited. These events fall into the category of general industrialincidents (e.g. fire, explosion, toxic material release, etc.), natural and destructivephenomena (hurricane, tornado, etc.) or security events. These events are furtherdescribed in Chapter 11 of the Safety Analysis Report for the UMS Universal StorageSystem. The determination of which, events are included is based on the probability ofoccurrence, the potential severity and the potential impact on the facility of the event.3.2.1 Tip-Over of Vertical Concrete CaskA hypothetical non-credible accident condition has been postulated involving the non-mechanistic tip-over of a vertical concrete storage cask. Functionally, the cask is notexpected to suffer significant adverse consequences due to this event. The concrete caskand canister are expected to continue providing design basis shielding, geometry controlof contents, and contents confinement performance. The tipped-over configuration of theconcrete cask will be obvious during a Site inspection following the initiating event.There is an adverse localized radiological consequence due to the hypothetical tip-overevent since the bottom end of the concrete cask has significantly less shielding than thesides and top of these same components. The estimated dose rate from the-bottom of atipped-over cask is calculated to be approximately 34 rem/hr at 1 meter, 4 rem/hr at 4meters, and < 10Omrem/hr at 100 meters (NAC-SAR). Following a tip-over event,supplemental shielding should be used until the concrete cask can be up-righted. Surfaceand top and bottom edges of the concrete cask are expected to exhibit cracking andpossible loss of concrete down to the layer of reinforcing bar. The increased dose ratedue to this cracking is not expected to be significant. There are no credible eventsexpected to result in a cask tip-over.3.1REV 7 3.2.2 Tornado and Tornado Driven MissilesIt is not expected that the performance of the UMS storage cask will be significantlyaffected by a tornado event. It is not anticipated that postulated tornado wind loading andmissile impacts are capable of overturning a cask, or penetrating the cask concreteboundary and affecting the fuel storage canister. A tornado event can be visuallyobserved. Advanced warning of a tornado and of tornado sightings may be received fromthe National Weather Service, local radio and television stations, local law enforcementpersonnel, and site personnel. An inspection of the cask exterior surface following atornado event is required. The inspection should be directed at ensuring the inlets andoutlets have not become blocked by wind-blown debris and checking for obviousconcrete surface damage. Damage to the vertical concrete cask after a design basistornado is not anticipated to result in radiation exposure at the Controlled Area boundarythat would exceed the EPA PAGs exposure guidelines. The penetrating missile impact isestimated to reduce the concrete shielding thickness, locally at the point of impact, byapproximately 6 inches. Localized cask surface dose rates for the removal of 6 inches ofconcrete are estimated to be less than 250 rnrem/hr (NAC SAR Section 11.2.11).3.2.3 Explosions.An explosion affecting the Universal Storage System may be caused by industrialaccidents or the presence of explosive substances in the vicinity of the ISFSI. It is notanticipated that explosive substances will be stored or used at the JSFSJ. An explosion inthe vicinity of the ISFSI would be sensed by on-duty ISFSJ personnel. In the event of anearby explosion, an inspection of the concrete casks may be required to check caskintegrity, to ensure that the air inlets and outlets are free of debris, and to ensure that themonitoring system and screens are intact. There are no anticipated off-site radiologicalconsequences for this event.3.2.4 Seismic EventThe earthquake evaluation shows that the loaded or empty vertical concrete casks are notexpected to tip over or slide in the event of an earthquake. Significant earthquakes wouldbe detected by ground motion. Inspection of the vertical concrete casks is requiredfollowing an earthquake event. The proper positioning of the Concrete casks should beverified to ensure they maintain the established spacing requirements. The temperaturemonitoring system should be checked for operation. There are no anticipated off-siteradiological consequences for earthquake events.3.2REV 7 3.2.5 FiresThere are no flammable materials routinely present in the ISFSI cask storage area. A"combustible liquid control zone" shall be established for the ISFSI itself, which shall bea minimum of 10 feet from the outside perimeter of the VCC. The total liquidcombustibles allowed within the zone cannot exceed 50 gallons and must be in directsupport of ISFSI operations or maintenance. A fire in the vicinity of the ISFSI will bedetected by observation of the fire or smoke. Upon detection of a fire, appropriate actionsshould be taken by site personnel to report andlor extinguish the fire. The concrete caskshould be inspected for general deterioration of the concrete, loss of shielding (spalling ofconcrete), exposed reinforcing bar, and surface discoloration that could affect heatrejection. This inspection serves as the basis for the determination of any repair activitiesnecessary to return the concrete cask to its design basis configuration. There may be localspalling of concrete during the fire event, which could lead to some minor reduction inshielding effectiveness. The principal effect would be local increases in radiation doserates on the cask surface. There are no off-site radiological consequences anticipated forthis event.3.2.6 Abnormal Cask Outlet Temperature ShiftThis event involves an abnormal outlet temperature shift caused by a partial or fullblockage of the vertical concrete cask air inlets and outlets that could result in the heat upof the fuel cladding, the fuel basket and the concrete, with the temperature potentiallyreaching the design basis limiting temperature. Full blockage could result in thesetemperature limits potentially being exceeded after 24 hours. Blockage of the cask airinlets and outlets will be detected by the Cask outlet temperature monitoring system. Anyobstruction blocking the air inlets and outlets must be manually removed. There are nosignificant radiological consequences for this event at the Controlled Area boundary, asthe vertical concrete cask is expected to retain its shielding performance (NAC SARL11.2.13).3.2.7 Other Conditions3.2.7.1 Off-Normal Canister Handling EventsThese events would involve off-normal occurrences during the handling or transfer of aloaded transportable storage canister (TSC), i.e., during the installation or removal of thecanister in or from the vertical concrete cask (VCC), or the transfer cask (TFR).Unintended loads could be applied to the canister due to misalignment or faulty craneoperation, or due to inattention of the operator. The event is expected to be obvious tothe operators at the time of occurrence. There is no anticipated deterioration of thecanister or fuel basket performance due to this event. There are no anticipated off-siteradiological consequences associated with this off-normal event.3.3REV 7 3.2.7.2 Drop of Vertical Concrete CaskThis event involves dropping a loaded vertical concrete cask during routine handlingoperations. This event may be due to the failure of one or more of the cask lifting jacksor of the air pad system. The maximum lift height shall be limited to less than 24 inchesby administrative controls. The event would be detected by the operators as it occurs.The damaged cask should be inspected and repaired prior to continued use. There are noanticipated off-site radiological consequences for this event.3.2.7.3 Flood EventThe UMS storage system vertical concrete casks have been evaluated for a design basisflood condition having a 50-foot depth of water and a water velocity of 15 feet persecond. This flood depth would frully submerge the vertical concrete casks. The analysisshows that the vertical concrete casks are not expected to slide or overturn during thedesign basis flood. Small floods may lead to blockage of the concrete cask air inlet vents.Partial and full blockage of air inlets is described in Section 3.2.6 of this plan. Floodingconditions would be detected by the ISFSI staff or personnel working in the vicinity ofthe ISFSI. A potential exists for collection of debris or accumulation of silt at the base ofothe cask, which could clog or obstruct the air inlet vents. Operation of the temperaturemonitoring system should be verified, as flood conditions may have impaired operation. There are no anticipated off-site radiological consequences associated with thedesign basis flood event.3.2.7.4 Lightning Strike EventSince the vertical concrete casks are located on an unsheltered pad, the casks may besubject to a lightning strike. A lightning strike on a concrete cask may be visuallydetected at the time of the strike, or by visible surface discoloration at the point of entryor exit of the current flow. There are no anticipated off-site radiological consequencesdue to the lightning event.3.3 Security EventEvents that impact the security of the ISFSI are discussed in the ISESI Security Plan.These events represent a threat to the level of safety of the ISFSI due to unauthorizedaccess, the introduction of threatening materials, or the use of hostile force in designatedsecurity areas. Security event detection and response is described in the Maine YankeeIndependent Spent Fuel Storage Installation Physical Security Plan. The Emergency Planmay be implemented if necessary in response to a security event.Events that fall into these areas will be categorized under the appropriate category in theclassification process discussed in Section 4, CLASSIFICATION OF ACCIDENTS.3.4REV 7 4.0 CLASSIFICATION OF ACCIDENTSBased on NUJREG-l1140,"Regulatory Analysis of Emergency Preparedness for Fuel Cycleand Other Radioactive Material Licensees", the NRC has determined that there are nocredible design basis accidents that would exceed the EPA PAGs at an ISFSI ControlledArea boundary. Emergency classification guidance in Appendix F of Nuclear EnergyInstitute document NEI 99-01 (Final Rev. 4), "Methodology for Development ofEmergency Action Levels," states, "The expectations of offsite response to an 'alert'classified under a 10 CFR 72.32 emergency plan are generally consistent with those for anotification of unusual event in a 10 CFR 50.47 emergency plan, i.e., to provideassistance if requested." The NEI 99-01 guidance is utilized in this plan to classify MaineYankee ISFSI emergency events. The NRC Regulatory Analysis for Rev. 4 of Reg Guide1.101 (Reference 5) to accept NET199-01 determined that the guidance in NE1 99-01 isappropriate for developing site specific EALs, to meet the intent of 10 CFR 50.47(b) (4 )and Appendix F to Part 50.Accidents and off-normal events that are analyzed for the ISFSI, including some eventsconsidered to be non-credible, have been reviewed and assigned a classification. Thereare no credible design basis accidents that would exceed the EPA PAGs at the ISFSIControlled Area boundary. Table 4-1 summarizes events that are classified as an UnusualEvent.This plan classifies events based on predetermined Emergency Action Levels (EALs).This approach provides a simple, predetermined response to an emergency event oraccident, allowing a coordinated and phased approach to the eventual mitigation of theconditions and restoring the facility to a safe status.4.1 Definitions4.1.1 Unusual Event (U-E)Events are in process or have occurred which indicate a potential degradation of the levelof safety of the facility. No release of radioactive material requiring offsite response ormonitoring is expected.4.2 Categories of EventsPer the Emergency Action Levels (EALs) guidance in NE1 99-01 (Reference 2), there aretwo categories of ISFSI events that can lead to an accident being classified as an UnusualEvent (UF). The ISS/ED has the discretion to classify events based on the classificationlevel definition. This discretion should be used when conditions or events are observedand no specific Initiating Condition (IC) / Emergency Action Level (EAL) is apparent.The UBE classification will heighten awareness of the abnormal condition. Table 4-1 liststhe initiating conditions, associated emergency action levels, and the applicable NRCemergency classification levels.4.1REV 7 4.2.1 Damage to a Loaded Vertical Concrete Cask That May Damage the Fuel or GTCCConfinement Boundary UEA UE classification for these IC/EALs is warranted on the basis of the occurrence of anevent of sufficient magnitude that a loaded VCC is severely damaged, which may beindicative of potential damage to a cask confinement boundary. This classificationincludes events involving loss of a loaded fuel storage cask confinement boundary,leading to degradation of the fuel during storage or posing an operational safety problemwith respect to removal of the degraded fuel confinement boundary from storage. Naturalphenomena events and accident conditions in which a loaded VCC is damaged areclassified at the UPE level. Cask seal integrity issues discovered during leakage testingassociated with normal canister processing would be addressed in accordance with NACtechnical specifications, or required actions, therefore, classification should not bemade based on loss of seal integrity by itself. However, loss or potential loss of sealintegrity coincident with an accident condition or natural phenomena that clearly affectsthe cask would justify a UPE classification. The 1SF SI vertical concrete storage casks areroutinely monitored by site personnel such that any degradation would be detected.Increases in radiation levels may be indicative of degradation of a storage cask.4.2.2 Confirmed Security Event with Potential Loss of Level of Safety of the ISFSI LYEThese IC/EALs provide a UE cl!assification for security events involving a potential lossof the level of safety of the ISFSI based on the Maine Yankee Independent Spent FuelStorage Installation Physical Security Plan.4.2REV 7 TABLE 4-1 EMERGENCY ACTION LEVELSInitiating Conditions Emergency Action Levels NRC EmergencyClassification LevelHU1 -DAMAGE TO A 1. Natural Phenomena UNUSUAL EVENTLOADED VERTICAL events affecting a loadedCONCRETE CASK (VCC) GTCC or spent fuel caskTHAT MAY DAMAGE confinement boundary.THlE FUEL OR GTCC 2. Accident conditionsCONFINEMENT affecting a loaded GTCCBOUNDARY or spent fuel caskconfinement boundary._________________3. ISS/ED judgment.HiU2 -CONFIRMED 1. Ongoing security UNUSUAL EVENTSECURITY EVENT WITH compromise or attemptedPOTENTIAL LOSS OF entry which may result inLEVEL OF SAFETY OF the potential loss ofTHE ISFSI control of the facility.4.3REV 7 5.0 EMERGENCY RESPONSEEmergency Response OverviewIn the event of an accident at the facility, actions will be taken by facility staff to reportthe event to the ISFSI Shift Supervisor (ISS) and to minimize the impact of the event. Theprimary objective of the initial responders is to assess the situation and minimize the riskimposed on workers and the general public. This involves initiation of required actions tomitigate a particular hazard. Subsequent actions include notifications, staffaccountability, staff augmentation, and implementation of onsite corrective actions asnecessary. The ISFSI Shift Supervisor becomes the Emergency Director (IS S/ED) uponclassification and declaration of an unusual event.5.1 Notification and ActivationWhen an emergency condition is recognized, the event is classified and declared by theISS/ED and mitigating actions are taken to minimize the progression of the event. Theseactions are initiated by available resources. The IS S/ED will request any offsite assistancethat may be necessary due to the nature of the event. Following initial notifications, theMaine State Police (MSP) and the Nuclear Regulatory Commission (NRC) will benotified of the event and mitigating actions in progress or that have been completed.Figure 5-1 depicts the initial .notification and activation process.5.1.1 Maine Yankee Emergency Support StaffThe ISS/ED or designee will direct ISFSI shift personnel to notify the ISFSI Support Staffof an event, if necessary. This will be accomplished by the commercial telephone system(i.e., land based, cell based, satellite based service). In the event the initiating conditionsconstitute a Security Event, these notifications will be made by the IS S/ED or designee. [Notifications to supplement support positions should be completed within one hour of theevent declaration.5.1.2 Offsite OrganizationsFollowing notification of the Maine Yankee ISFSI Support Staff, the Maine State Police(MSP) will be contacted and provided pertinent information regarding the event, actionstaken to mitigate the event and notification of any assistance which may be necessaryfrom local organizations (i.e. fire, ambulance, police response). Notification to the MSPshall be comPleted within one hour of event declaration. Depending on the need forimmediate outside assistance, these notifications may be initiated in an acceleratedmanner (i.e. immediate need for fire fighting capabilities or medical assistance). TheMSP Headquarters Communications Center is staffed 24 hours a day, 7 days a week. TheMSP have the capability to contact State and county emergency response personnel, ifneeded.The MSP will initiate notification to appropriate State Officials in the Maine EmergencyManagement Agency (MEMA), Division of Environmental Health (D)EH) and others asdesignated in the State's notification protocol, based on the event.The NRC will be notified after the notification of the MSP and no later than one hourafter the emergency was declared.5.1REV 7 5.1.3 Information to be CommunicatedA pre-scripted format is used to ensure consistent information is provided to the MSP andthe NRC.At a minimum, the following information will be provided during the initial notificationof the event:Event Classification;Date/Time of Classification;Reason or events causing the condition;General description of damage to major structures/areas;Personal injuries;Status of offsite assistance (fire/medical/other);Name of person making notification;Date and Time of notification.The information will be verified, via repeat-back, to ensure it was accuratelycommunicated.5.2 Radiological AssessmentInitial response to an event will be to ascertain the cause, mitigate furter progression anddetermine the potential impact to ISFSI personnel and the general public. Initialassessment will normally consist of an area dose assessment if warranted. Initial doseassessment activities will be directed by the ISS/ED and performed by qualifiedpersonnel.As soon as practical, facility staff should initiate general area radiation surveys todetermine the actual extent of any radiological concern. Results of the surveys will' beanalyzed by facility staff to formulate an action plan to mitigate the event and restore thefacility to a safe condition. Survey data will also be used, as appropriate, in any on-sitedose assessment techniques.Following the termination of the event, environmental surveys (including, but not limitedto water, soil, vegetation, etc.) may be required to determine the long-term impact of theevent.5.3 Protective Actions5.3.1 Relocation and AccountabilityIn an UNUSUAL EVENT declaration, personnel not directly involved with the responsemay be directed to relocate to an assembly area. Staff will be notified using the on-sitepaging system or other means. An assembly area may be established, based on the natureof the event, at a location determined by the ISS/ED. The ISFSI shift staff will maintainaccountability of personnel and report any missing persons to the ISS/ED. Search andrescue efforts may be performed by shift personnel or local response personnel asnecessary.5.2REV 7 5.3.2 First Aid/Medical ResponseOff-site emergency medical responders will be requested to report to the scene andinitiate first aid treatment to stabilize the patient and prepare for transport to a medicalfacility. One or more First Aid kits are located in the facility. Injuries may becomplicated by the presence of radiation and/or a contaminating substance (chemical orradiological). Given the design of the fuel/GTCC storage canisters, radiologicalcontamination is unlikely, but should be evaluated. The patient will be assessed to*determine if a life-threatening condition exists and appropriate actions taken to eithercontain or remove the contamination. In addition, environmental factors will be takeninto account regarding the need to stabilize the patient in place or remove to a safer area(i.e. lower radiation levels, etc.). Maine Yankee maintains a Letter of Agreement with theWiscasset Ambulance Service for transporting injured/contaminated workers from thesite to a receiving hospital. In addition, agreements have been made with the MidcoastHospital (Brunswick) for treating personnel with various types of injuries/conditions.5.3.3 Personnel MonitoringPersonnel working in known radiation areas will be issued dosimetry in accordance withexisting radiation protection procedures. During emergency conditions, they normallyretain their dosimetry and report to either their assigned emergency station or theassembly area, if a person suspects they may be contaminated, they will be monitored byRadiation Protection personnel.Emergency support staff will be issued dosirnetry as required for assigned tasks.Exposure control will be maintained in accordance with the site Radiation Protection andALARA programs. Dose extensions may be granted in excess of the limits of 10OCFR20for special circumstances. These extensions will be in accordance with EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents.Extensions above the I0CFR_20 limits must be approved by the IS S/ED. The anticipatedemergency exposures are well within the limits specified in Table 5-1.5.3REV 7 TABLE 5-1 GUIDANCE ON DOSE LIMITS FOR EMERGENCY WORKERS (a)Type of Activity TEDE (b) ConditionAll 5 Remn Maintain ALARA and to the extent practicable___________________________limit emergency workers to these limitsProtecting Valuable Property 10 Remn Lower dose not practicable.Life Saving or Protection of Large 25 Rem Lower dose not practicable.Populations>25 Rem Only on a voluntary basis to persons fully aware ofthe risks involved, including the numerical levelsof dose at which acute effects of radiation will beincurred and numerical estimates of delayedeffects.(a) From EPA-400-R-92-00l, Manual of Protective Action Guides and Protective Actions forNuclear Incidents(b) Sum of the deep dose equivalent from the external sources and the comimitted dose.equivalent from the internal exposures to non-pregnant adults from exposure and intakeduring an emergency situation. Dose limits to the eye should be 3 times the listed value.Dose limits to any other organ (including skin and body extremities) should be 10 times thelisted value.5.3.4 Decontamination CapabilitiesSurvey instrumentation for personnel frisking is available. Personnel contaminationidentified during the initial survey will require the contaminated individual to removeprotective apparel, re-survey, and if skin contamination levels are identified, performdecontamination as directed by radiation protection personnel.In the event that accident conditions result in a contaminated injured individual, thevictim's rescue and medical treatment take precedence over the Victim's radiationexposure due to bodily contamination. Gross decontamination of the victim (generallylimited to the removal of contaminated articles of clothing) will be accomplished to theextent that the health of the patient is not affected. Decontamination measures associatedwith wounds will be performed under the joint supervision of the attending physician atthe hospital and the responding radiation protection representative.5.3.5 Contamination and Hazard Exposure ControlSurveys will be conducted to determine which areas contain contamination of either aradiological nature or a hazardous substance. These areas will be identified by eithermarking with boundary rope or tape and access will be limited and controlled accordinglyby the radiation protection personnel. Monitoring of the area will be conducted usingappropriate equipment, based on the type of contamination. All personnel required towork in the area will be provided appropriate personnel protective equipment (coveralls,booties, gloves, etc.) by the Radiation Protection contractor. The level of protection willbe determined by the IS S/ED or other designated personnel.5.4REV"7 5.3.6 Emergency ActionThis plan permits emergency response personnel to take reasonable action that departsfrom a license condition or a technical specification in an emergency when this action isilmmediately needed to protect the public health and safety and no action consistent withlicense conditions and technical specifications can provide adequate or equivalentprotection is immediately apparent.5.4 Coordination with Offsite AgenciesThere is no response required from State agencies. State government response isexpected to be limited to recording the notification of the emergency, periodicallyreceiving updated information on the emergency, and coordinating public informationnews releases. Upon request, Local government agencies (i.e. fire, police, ambulance)will respond to the ISFSJ during an emergency, if necessary.If needed, provisions exist for limiting traffic on roads leading to the Maine Yankee site.These actions would be coordinated through the Maine State Police or the LincolnCounty Sheriffs Office, Wiscasset, Maine.5.5REV 7 FIGURE 5-1MAINE YANKEE INITIAL NOTIFICATION AND ACTIVATION PROCESS' IS S/EDISFS.I SHIFT NRC MAINE STATESPECIALIST POLICE (MSP)MAINE YANKEE .MAINE EMERGENCISFSI SUPPORT MANAGEMENTSTAFF AGENCY (EOC)(If needed)5.6.;YREV 7 6.0 FACILITIES AND EQUIPMENT6.1 Control CenterThe Control Center in the Security/Operations Building is the primary facility whereISFSI conditions are monitored and corrective actions are developed to mitigate anyabnormal occurrence. Emergency conditions classified as UEs are managed by theISS/ED from the Control Center or other appropriate location.The Control Center provides space for the designated members of the ISFSI Emergencysupport staff to conduct analysis and support functions in response to the event. TheControl Center may be activated for other reasons at the discretion of the ISSiED. Thefollowing functions are coordinated from the Control Center: emergency management,offsite notifications and communication, and facility restoration planning.The Control Center is sized to accommodate personnel performing communications,radiological assessment, general engineering and analysis tasks. Communication systemsare available to allow interaction with offsite organizations, as necessary. Variousequipment has been assembled and stored in or near the Control Center for use by supportstaff, including personal protective equipment, and radiation monitoring equipment. TheControl Center has nearby office space to accommodate any required offsite personnel.6.2 Radiation Controls CheckpointThe Radiation Controls (RC) Checkpoint is located in the Security/Operations Building.Personnel dosimetry is issued at this point and a radiological emergency kit is available.6.3 Assembly .AreaPersonnel directed to evacuate the PA will be directed to report to an assembly areadesignated by the ISS/ED.6.4 EquipmentAppropriate equipment is maintained for emergency response activities in the ISFSISecurity/Operations Building. Required supplies are inventoried to ensure operabilityand availability at all times.Controlled copies of facility documents (drawings, procedures, Technical Specifications,SARs, etc.) are maintained in, or in the areas adjacent to the Control Center. Thisinformation is readily available for support staff use.6.1REV 7 6.5 Communications6.5.1 Onsite Communication Systems6.5.1.1 Commercial Telephone SystemThe commercial telephone system is the primary means of onsite communicationduring an emergency. This system has an independent backup power configuration,which incorporates a combination of batteries and an emergency diesel generator toensure uninterrupted operation on a loss of normal power to the ISFSI telephonesystem.6.5.1.2 Paging SystemA general voice paging system is available with speakers on the interior and exteriorof the Security/Operations Building.6.5.1.3 Radio SystemISFSI staff will be equipped with portable radios for onsite communications. One ormore licensed frequencies will be used for routine communications, and one or morestate police frequencies will be used for offsite routine and emergencycommunications.6.5.2 Offsite Communications Systems6.5.2.1 Telephone to the Maine State PoliceCommercial telephones are used to establish communications between the MaineYankee JSFSI Control Center and the Maine State Police (MSP). This is the primarymethod of informing State of Maine personnel of a declared emergency at the MaineYankee ISFSL. Both organizations have telephones in a location that is staffed 24hours a day, '7 days a week.6.5.2.2 Maine State Police RadioIn the event the commercial telephone circuits fail, the MSP can be contacted viaradio from the Control Center and from the ISFSI Security Offices using either of twoState Police frequencies installed on these radios (State Police -Zone 2 and state-widecar-to-car (SWCC). SWCC frequency can also be used to communicate with theLincoln County Sheriffs Office. The ISFSI radio system is powered from the normalpower company service grid. Back up power is provided by a UPS system.6.5.2.3 NRC Emergency NotificationIn the event of an emergency at the Maine Yankee ISFSI, the NRC will be notifiedwithin one hour using the ENS telephone system in accordance with 10 CFR 50.72(a).This line is not anticipated to be established continuously, but used primarily toprovide periodic informational updates to the NRC.6.6 Fire SuppressionFire extinguishers located at the ISFSI are used to help extinguish or contain a fire tothe area of origin and minimize involvement of adjacent areas until the Wiscasset FireDepartment responds to the scene. A fire hydrant is located near the ISFSI for use bythe Wiscasset Fire Department.6.2REV 7 7.0 RESPONSIBILITIESThe Emergency Organization is comprised of on-shift ISFSI personnel. Detection andrecognition of conditions that warrant declaration of an emergency, in accordance withthe EALs, is the responsibility of the ISFSI Shift Supervisor (ISS). Upon declaration of anemergency, the on-shift organization assumes their emergency response duties andimplements this plan. The minimum on-shift staff required for initial emergencyresponse consists of the ISS/ED (Fig. 7-1).The IS S/ED may call in support staff in numbers and disciplines necessary to support theresponse and recovery actions required for the event. Radiation Protection support isavailable on a call-in basis if not present on-site at the onset of an emergency.7.1 On-shift Organization7.1.1 LSFSI Shift Supervisor /Emergency DirectorThe ISS is the qualified emergency representative on-shift. The 1SS assumes the positionof ISS/ED. The IS S/ED executes any actions deemed necessary to mitigate theconsequences of the emergency condition and restore the facility to a safe and stableconfiguration.The primary responsibilities of the IS S/ED include:* Classification and emergency declaration of the incident* Notification and request for assistance from local response agency, including medicalassistance as necessary* Notification and interface with offsite agencies* Notification of ISFSI support staff,* Direction and control of available personnel* Initiation of immediate corrective actions, if any* Direction, control, communications and public information* Authorization of onsite protective actions* Establish priorities for the Control Center staff* Provide periodic updates to the NRC* Determine the need for offsite/contractor assistance* Mitigation and recoveryThe ISS/ED is responsible for maintaining the integrity of the ISFSI and all operationalactivities in the facility. The ISS/ED may be relieved by another qualified ED) ifconditions warrant.7.1.2 Shift SpecialistThe ISFSI Shift Specialist is responsible for maintaining facility security in accordancewith the ISFSI Security Plan.The primary responsibilities of the Shift Specialist during an emergency is:* Maintaining site security and access control from the Central Alarm Station (CAS)* Personnel Accountability in the ISFSI Protected Area (PA)* Notification of the support staff as requested by the iS S/ED* Notification of offsite Agencies as requested by the IS S/ED* Search and Rescue coordination, as necessaryoFire response coordination, as necessary.7.1REV 7 7.2 Augmented OrganizationThe need for an augmented response by support staff is determined by the ISS/ED on acase by case basis for the Unusual Event (UE) classification. If needed, the augmentedsupport staff is expected to be in place to support emergency response activities withinapproximately 2 hours. Augmented response personnel may be provided by a contractedservice.7.2.1 Support StaffAvailable facility staff and/or emergency services contractors will be called in asnecessary to assist in the response, including:* Perform spent fuel storage condition assessments, if necessary* Assess the extent of damaged equipment* Identify short and long-term repair needs* Establish initial repair priorities and deploy repair teams* Coordinate available resources to restore equipment and systems based on thedirection of the ISS/ED* Handle logistical needs* Perform radiological and environmental surveys as necessary.* Developing public information materials for release to the news media as necessary,and maintaining liaison with news media and State of Maine information staff.7.2REV 7 FIGURE 7-1MAINE YANKEE ISFSIMINIMUM ON-SHIFT EMERGENCY ORGANIZATIONISFSI SHIFT SUPERVISOR!/EMERGENCY DIRECTOR (ISS/ED)SHIFT SPECIALIST7.3REV 7 8.0 MAINTAINING EMERGENCY PREPAREDNESSThe ISFSI Manager or designee is responsible for ensuring the availability ofadequate emergency support staff and for approval of the ISFSI Emergency Planand Implementing Procedures (IEPIPs).The JSFSI Manager is also responsible for ensuring the following tasks andfunctions are completed:* The maintenance of readiness of the on-site emergency response facilities andequipment;* Development and maintenance of the ISFSI Emergency Plan;o Development and maintenance of the associated implementing procedures;* Preparation of scenarios for training drills and exercises;* Conduct of drills and exercises;* Provision of input to emergency preparedness training of the support staff;* Returning emergency equipment and supplies used during a drill, exercise oractual emergency to a state of readiness following the termination of the drill,exercise or emergency;* Providing support for the annual radiation monitoring drill and medicalemergency drill.*Reviewing ISFSJ EALS with state and local government authorities on anannual basis in accordance with 10 CFR 50 Appendix E (TV)(B).8.1 TrainingThe Maine Yankee ISFSIi Emergency Plan Training Program consists of lessonplans designed to provide the skills and knowledge necessary to maintain staffproficiency. Each IEPIP will be reviewed to identify activities that are notconsidered to be a part of the assigned individuals day-to-day routine function (i.e.use of telephones, general communication protocol, etc.). Lessons will focus onnon-routine and specialized activities that are particular to the assigned functionand overall emergency response actions. Training may consist of, but not belimited to, classroom lecture, self-study, practical demonstrations (wherenecessary, as specified in the lesson plan), and facility drills.8.1.1 Emergency Staff TrainingEach individual selected for assignment to the on site staff or the support staff willbe provided training designed to familiarize the person with their duties,responsibilities and expected actions in the event of a condition that requires thesupport staff to be mobilized. This initial training will be completed prior to theindividual assuming the emergency response duty.Each on shift and support staff member will be provided continuing training fortheir assigned duties. This training will be conducted annually. Continuingtraining addresses general changes to the ISFSJ Emergency Plan, facilities,equipment, regulations, policies and specific changes to their responsibilities(which are not considered part of their routine duties). It also addresses problemareas identified during audits, drills or exercises.8.1REV 7 8.1.2 ISFSI Access TrainingThe ISFSI Access Training program provides employees and contractors routinely onsitethe basic elements of the ISFSI Emergency Plan and expected actions during anemergency. Information is reviewed annually as part of site access training.8.1.3 Offsite Assistance TrainingOrganizations which may be called upon to render assistance onsite will be offeredgeneral facility familiarization sessions on an annual basis. These sessions may include awalk down of the general facility, safety, building layout, access protocol,communications capabilities and security requirements. Radiological orientation trainingwill also be offered annually.8.2 Review and Updating of the ISFSI Emergency Plan and Implementing Procedures8.2.1 ISFSI Emergency Plan (JEP) ReviewThis plan, including all written agreements between Maine Yankee and other parties, willbe reviewed annually. Approved changes to the plan will be incorporated into theappropriate implementing procedures along with the plan changes. Letters of Agreementwill be reviewed annually and verified to be in effect at the time of the plan review. Thismay be accomplished via written correspondence or documented telephone conversation.This plan is a controlled document to ensure changes are incorporated into distributedcopies. Plan changes will be subject to management review and approval. Plan changeswill be issued as an entire revision with changes identified on the affected pages.8.2.2 Emergency Plan Implementing Procedure ReviewISFSI Emergency Plan Implementing Procedures (JEPIiPs) will be reviewed and revised inaccordance with plant procedure control guidelines, and as necessary. Periodic revisionswill be incorporated whenever a plan change is made that affects the procedure or othercircumstances dictate a revision is necessary. IEPIPs will be subject to managementreview and approval.8.2.3 Periodic Surveillance ProgramFacilities and equipment will be maintained in accordance with surveillance procedures.Inventories of emergency plan equipment will be conducted on a semi-annual basis andafter facility activation (actual event or drill activity). A walkdown of the Control Centerwill be conducted on a quarterly basis to ensure facility readiness is maintained.Telephone numbers that are important to emergency notification and are contained in theJEPI~s will be verified on a quarterly basis.8.2.4 Communications Systems ChecksTelephones, radios and paging systems used for on-site and off-site emergencycommunications will be tested quarterly per communications surveillance procedures.8.2REV 7 8.3 Drills and ExercisesIn addition to the emergency plan training described earlier, the facility staff will conductperiodic drills to enhance skills and knowledge of the practical implementation of theIEP. Periodic drills will be scheduled with various objectives to demonstrate theseCapabilities. Some drills will focus on singular functions (such as communicationscapabilities) while others will involve the activation of the support staff. Theseevolutions serve as an extension of the training program, allowing interaction betweenevaluators and responders to reinforce procedural requirements and overall processimplementation.8.3.1 DrillsIn addition to training drills discussed above, the following drills will be conductedannually;-Support Staff Drill -involving a combination of some of the principal functionalareas of emergency response capabilities. The biennial exercise satisfies the annualsupport staff drill requirements.-Radiological Monitoring Drill.- demonstrating conducting general area surveys.-Medical Emergency Drill -demonstrating the capability to transport an injured workeroffsite.-Fire Drill -conducted in accordance with the Fire Protection Program.8.3.2 ExercisesAn exercise will be conducted once every two years to demonstrate the capability toimplement the ISFSI Emergency Plan. Objectives will be developed to ensure majorelements of the emergency plan are demonstrated and evaluated to ensure the appropriatelevel of preparedness is being maintained.Offsite response organizations will be invited to participate in biennial exercises.8.3.3 Driln and Exercise EvaluationFacility staff will evaluate the exercise and drills. Expectations for evaluators will bediscussed with each evaluator prior to the drill. Whenever possible, evaluators shouldhave present or recent ISFSI emergency responsibilities and be assigned to evaluatefunctions/areas consistent with their emergency assignment. Following the drill/exercisea critique of the evolution will be conducted. Comments will be evaluated anddispositioned by Maine Yankee and deficiencies will be corrected through retraining,remedial drills, or by other means. Comment resolution will be assigned to appropriatepersonnel for final implementation.8.3REV 7 8.4 Independent Program ReviewAn independent program review of the ISFSI emergency preparedness program will beconducted once every 12 months in accordance with 10 CFR 50.54(t) or as necessary,based on the assessment against performance indicators, and as soon as reasonablypractical after a change occurs with personnel, procedures, equipment or facilities thatpotentially could adversely affect emergency preparedness, but no longer than 12 monthsafter the change. Items to be reviewed should include, but not be limited to, adequacy ofinterfaces with State and local government agencies, implementing procedures, drills,exercises and capabilities.8.4REV 7 9.0 RECOVERYThe primary objective of the facility staff is to mitigate the consequences of an emergencyand restore the facility to a safe condition. Restoration of the facility effectively beginswith the first action taken in response to the event and terminates when the facilityresumes normal operations.When conditionshave. stabilized and a full assessment of the event has been conducted,the facility staff will focus on establishing a plan to verify' operability of allsystems/components necessary to maintain and monitor the integrity of the spent fuel.The ISESI Manager or designee will coordinate the restoration of the facility and has theauthority to take the necessary actions to ensure the facility is returned to a safe condition.Recovery responsibilities, of the JSFSI Manager include, but are not limited to:Development of the site recovery plan.* Maintain comprehensive hazard assessment of the facility.* Prioritize clean-up of affected areas/equipment.* Isolate and repair damaged equipment/systems.* Document all actions taken related to the recovery operations.9.1REV 7 10.0 OFFSITE ASSISTANCEResponse from organizations that are not associated with Maine Yankee are not expectedto be necessary, except for fire, medical emergencies or hazardous materials incidents.Letters of Agreement exist with organizations that may be called upon, on an as-neededbasis, to provide assistance.The Wiscasset Fire Department and Wiscasset Ambulance Service have standingagreements to assist Maine Yankee in the event of a fire, hazardous materials incident ormedical emergency.Maine Yankee maintains a Letter of Agreement with the MidCoast Hospital in Brunswickfor treatment of radiologically contaminated and injured workers.Response from the State of Maine will be limited to acknowledging notification of theevent. No mitigating actions are anticipated to be necessary in response to an event at.Maine Yankee. Precautionary actions are anticipated to be similar to those taken inresponses to preparations for severe weather, etc.Other agreements exist for specialized services that can be called upon as needed.10.1Rev 7
 
==11.0 REFERENCES==
: 1. Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-400-R-92-001, May 1992.2. NEI 99-0 1 Final Rev. 4 "Methodology for Development of Emergency Action Levels,"January 2003.3. NIJREG-1 140, "Regulatory Analysis on Emergency Preparedness for Fuel Cycle and OtherRadioactive Material Licensees."4. NAC Safety Analysis Report, UMS Universal Storage System, Docket 72-10 15, October1999.5. NRC Regulatory Guide 1.10 1, Rev. 4, "Emergency Planning for Nuclear Power Plants.", July2003.6. NRC Regulatory Issue Summary 20 15-14, "Issuance of Enforcement Guidance Memorandum-Emergency Plan and Emergency Plan Implementing Procedure Updates", October 30, 2015.11.1Rev 7 APPENDIX I -ASSISTANCE AGREEMENTSORGANIZATIONMid-Coast HospitalWiscasset Fire DepartmentWiscasset Ambulance ServiceI-1IREV 7 APPENDIX II -SUPPORTING PLANS AN]) DOCUMENTSDefueled Safety Analysis Report (DSAR)FP-.1, Fire Protection ProgramMaine Yankee Independent Spent Fuel Storage Installation Physical Security Plan andSupporting Security ProceduresIi-1REV 7 APPENDIX Ill -EMERGENCY PLAN IMPLEMENTING PROCEDURES1. Emergency Plan Implementing Proceduresa. EQ -1, Emergency Planning Administrationb. EQ -2, Response to Accident and Natural Phenomena Eventsc. EQ -5, Emergency Plan Implementation'IlI-REV 7 MAINE YANKEE321 Old Ferry Road, Wiscasset, Maine 04578December 15, 2015OMY- 15-055Re: 10 CFR 50.54(q)(5)10 CFR 72.44(f)10 CFR 50.4(b)(5)10 CFR 72.4ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-000 1Maine Yankee Atomic Power CompanyMaine Yankee Independent Spent Fuel Storage InstallationNRC License No. DPR-36 (NRC Docket No. 50-309)
 
==Subject:==
Revision 7 to Maine Yankee ISFSI Emergency PlanIn accordance with 10 CFR 50.54(q)(5), 10 CFR 72.44(f), 10 CFR 50.4(b)(5), and 10 CFR 72.4,Maine Yankee Atomic Power Company (Maine Yankee) is providing Revision 7 of the MaineYankee Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan, and a summary ofthe analysis that determined that the changes do not constitute a reduction in commitment, nor adecrease in effectiveness of the Maine Yankee ISFSI Emergency Plan.Attachment 1 provides a summary of the evaluation that provides the basis for concluding theMaine Yankee ISFSI Emergency Plan, as changed, continues to meet the standards of 10 CFR50.47(b) and the requirements of Appendix B to Part 50 as modified by the existing exemptionsfor the Maine Yankee ISFSI.Enclosure 1 provides a copy of Revision 7 of the Maine Yankee ISFSI Emergency Plan. It waseffective on December 15, 2015.This letter contains no commitments.If you have any questions regarding this submittal, please do not hesitate to contact me at(207) 882-1303.Respectfully,~Stanley PBEISFSI Manager Maine Yankee Atomic Power CompanyOMY- 15-055/December 15, 201 5/Page 2Attachments and EnclosuresAttachment 1 -Summary of 10 CFR 50.54(q) Evaluation for Changes to the Maine Yankee ISESIEmergency PlanEnclosure 1 -Maine Yankee ISFSI Emergency Plan, Revision 7cc: D. Dorman, NRC Region I AdministratorM. S. Ferdas, Chief, Decommissioning Branch, NRC, Region IM. Lombard, Director, Division of Spent Fuel Management, NM4SSJ. Goshen, NRC Project ManagerP. J. Dostie, SNSI, State of MaineJ. Hyland, State of Maine  to OMY-15-055Summary of 10 CFR 50.54(q) Evaluation for Changes to theMaine Yankee ISFSJ Emergency PlanSection /Table Description of Proposed Change Justification of Proposed ChangeThrough-out Changed title Emergency This is a change to standardize to thethe Emergency Coordinator to Emergency same title at all three Yankee sites.Plan Director or EC to ED.Through-out The Emergency Plan has been These changes are editorial and clericalthe Emergency reformatted and renumbered as in nature and have no impact on thePlan. needed to support this change. intent of the Emergency Plan.Table 4-1 Deleted a reviewer's note that was This is an administrative change.incorporated into revision 6inappropriately.Section 5.3.3 This section has been revised to This is a change to permit the Radiationclarify that if personnel become Protection personnel to determine wherecontaminated they will be the monitoring and decontaminationmonitored by Radiation Protection will be performed.Personnel. It also eliminates therequirement to perform this_____________activity at a specific point.Section This section has been revised to This is a clarification of duties andadd that Protective Clothing (PCs) responsibilities making the Radiationwill be provided by the Radiation Protection contractor responsible toProtection contractor, supply PCs.Section 8.1.2 Changed title from General This is a clarification to identify theEmployee Training (GET) to current title of the site training program.ISFSJ Access Training.Chapter 11, Added reference to NRC RIS This is an administrative, change thatReferences 2015-14 "Issuance of Enforcement adds a new guidance document.Guidance Memorandum -Emergency Plan and EmergencyPlan Implementing ProcedureUpdates", issued 10/30/15.Appendix II Updated FP-1 title and updated This is a clarification and administrativePhysical Security Plan full title. change.Page 1 of 2  to OMY-15-055Summary of 10 CFR 50.54(q) Evaluation for Changes to theMaine Yankee ISFSI Emergency PlanSection /Table Description of Proposed ChangeJustification of Proposed ChangeAppendix III,EmergencyPlanImplementingProceduresDeleted EO-6, Non-EmergencyEvent Assessment as anEmergency Plan ImplementingProcedure.Deleted EO-3 and EO-4 asEmergency Plan ImplementingProcedures because their contentwas relocated into EO-2.EO-2 was renamed. The originalcontent of EO-2 was moved toOP-1, because it was not requiredto implement the Emergency Plan.EO-6 never implemented theEmergency Plan. A self-assessmentestablished that the actions in EO-6 didnot meet the intent or definition of animplementing procedure.The self-assessment identified thefollowing procedures as EmergencyPlan Implementing Procedures inaccordance with Appendix E to Part 50:EO-l -Emergency PlanImplementationEO-2 -Response to Accident andNatural Phenomena EventsEO-5 -Emergency Plan AdministrationThese procedures contai-n-the followingas required by Appendix E of Part 50:* Organization (Emergency)* Assessment Actions* Activation of the EmergencyOrganization* Notification Procedures* Emergency Facilities andEquipment* Training* Maintaining EmergencyPreparedness* RecoveryThe current EO-2 off normal actionshave been incorporated into OP-ibecause it did not implement theEmergency Plan. EO-2 has been revisedto incorporate EO-3 and EO-4 into thenew EO-2, titled "Response to Accidentand Natural Phenomena Events". EO-3and EO-4 have been cancelled.Page 2 of 2 ENCLOSURE 1 TO OMY-.15-055MAINE YANKEE ISFSI EMERGENCY PLAN, REVISION 7 MAINE YANKEEIN DEPENDENT SPENT FUELSTORAGE INSTALLATION(ISFSI)EMERGENCY PLANREVISION 7Effective Date: December 15, 2015 TABLE OF CONTENTSSection PageTABLE OF CONTENTS iiAPPENDICES iLIST OF TABLES vLIST OF FIGURES viDEFINITIONS vii
 
==1.0 INTRODUCTION==
1:12.0 FACILITY DESCRIPTION2.1 Maine Yankee Site 2.12.2 General Area 2.12.3 Independent Spent Fuel Storage Installation 2.23.0 ISFSI ACCIIDENT TYPES, DETECTION AND CONSEQUENCES3.1 Radiological Events 3.13.2 Non-radiological Events 3.14.0 CLASSIFICATION OF ACCIDENTS4.1 Definitions 4.14.2 Categories of Events 4.15.0 EMERGENCY RESPONSE5.1 Notification and Activation 5.15.1.1 Maine Yankee Emergency Support Staff 5.15.1.2 Offsite Organizations 5.15.1.3 Information to be Communicated 5.25.2 Radiological Assessment 5.25.3 Protective Actions 5.25.4 Coordination with Offsite Agencies 5.56.0 FACILITIES AND EQUIPMENT6.1 Control Center 6.16.2 Radiation Controls Checkpoint 6.16.3 Assembly Areas 6.16.4 Equipment 6.16.5 Communications 6.26.6 Fire Suppression 6.2REV 7 TABLE OF CONTENTS(Continued)Section Page7.0 RESPONSIBILITIES7.1 On-shift Organization 7.17.2 Augmented Organization 7.28.0 MAJINTAINING EMIERGENCY PREPAREDNESS8.1 Training 8.18.2 Review and Updating of the ISFSI Emergency PlanAnd Implementing Procedures 8.28.3 Drills and Exercises 8.38.4 Independent Program Review 8.39.0 RECOVERY 9.1*10.0 OFIFSITE ASSISTANCE 10.1
 
==11.0 REFERENCES==
11.1i11REV 7 APPENDICESAPPENDIX I -Assistance Agreements I-1APPENDIX II -Supporting Plans and Documents 11-1APPENDIX Ill -Emergency Plan Implementing Procedures III-i1ivREV 7 LIST OF TABLESNumber Title4-1 Emergency Action Levels5-1 Guidance on Dose Limits for Emergency Workers(EPA-400-R-92-00 1)Page4.35.4REV"7 LIST OF FIGURESNumber Titl.__e Tawe2-1 Maine Yankee Site -General Area 2.32-2 Maine Yankee Site -Facility Layout 2.45-1 Maine Yankee Initial Notification and Activation Process 5.67-1 Maine Yankee On-Shift Organization 7.3REV 7 DEFINITIONSASSEMBLY AREAS -Designated locations where personnel may be directed to congregate mnthe event of the need to evacuate all or portions of the facility.ASSESSMENT ACTIONS -Actions taken during or after an emergency event or accident toobtain and process information necessary to implement specific emergency measures.CONFINEMENT BOUNDARY -The confinement boundary of the canister consists of thecanister shell, bottom plate, shield lid, structural lid, the two port covers, and the welds that jointhese components.CONTROL CENTER (CC) -During an emergency the lunch/conference room or otherdesignated area in the security/operations building functions as the emergency Control Center(CC) operating under the direction of the Emergency Coordinator. It is the primary point atwhich 1SF SI conditions are tracked and corrective actions are taken to mitigate any abnormalconditions.CONTROLLED AREA -The designated area outside of the Protected Area (PA), extending atleast 300 meters from the spent fuel storage pads, over which control is exercised duringemergency events pursuant to 10 CFR 72.106(b).CORRECTIVE ACTIONS -Measures to reduce the severity of (or terminate) an emergencysituation.EMERGENCY ACTION LEVEL (rEAL) -Conditions that, if met or exceeded, warrantclassification and declaration of an emergency.EMERGENCY DIRECTOR (ED) -The ED is responsible for the overall coordination anddirection of the company response to an emergency condition at the ISFSI.EMERGENCY SUPPORT STAFF -A group of trained staff designated to respond to a'declared emergency, if necessary.GREATER THTAN CLASS C WASTE (GTCC) -Radioactive waste material that is notgenerally acceptable for near surface disposal is waste for which form and disposal methods mustbe different, and in general more stringent, than those specified for Class C waste. The MaineYankee Core Shroud Assembly and Core Support Plate are considered GTCC waste and will bestored at the ISFSI.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) -A spent fuel storagefacility owned and operated by Maine Yankee, comprised of a Protected Area (PA) containingsixteen storage pads having 64 cask locations for dry storage of spent fuel and GTCC waste, asecurity/operations building and an earthen berm partially surrounding the site.INITIATING CONDITION (IC) -ISFSI parameters, equipment status and/or personalobservations that comprise the individual EALs.LOCAL ORGANIZATIONS -Those organizations that provide specific services underemergency conditions (i.e. police, ambulance and fire department).viiREV 7 DEFINITIONS(Continued)UNUSUAL EVENT (UIE) -Events are in progress or have occurred which indicate a potentialdegradation of the level of safety of the facility. No release of radioactive material requiringoffsite response or monitoring is expected.PROTECTED AREA (PA) -The area, encompassed by physical barriers, within the secured,controlled access boundary of the ISFSI.ISFSI SHIFT SUPERVISOR (ISS) -The senior ISFSl representative on-shift. The ISSassumes the position of IS S/ED upon classification and declaration of an unusual event.REV 7
 
==1.0 INTRODUCTION==
This document describes the Maine Yankee Atomic Power Company's (MYAPC) planfor responding to emergencies that may arise at the Maine Yankee Independent SpentFuel Storage Installation (ISFSI). The overall purpose of the plan is to delineate theactions necessary to safeguard ISFSI personnel and minimize damage to site property inthe event of an incident at the ISFSI. Analyses of the possible design basis events andconsequences are presented in the Safety Analysis Report for the UMS UniversalStorage System (NAC UMS SAR) used at the ISFSI for dry spent fuiel storage.The analyses of the potential radiological impact of an accident at the Maine Yankee siteindicates that any releases beyond the ISESI Controlled Area boundary are expected to beless than the U.S. Environmental Protection Agency (EPA) protective action guide (PAG)exposure levels, as detailed in EPA-400-R-92-001, Manual of Protective Action Guidesand Protective Actions for Nuclear Incidents. Exposure levels which may warrant pre-planned response measures are generally limited to the Controlled Area. For this reason,radiological emergency planning is focused on the Controlled Area.1.1REV 7 2.0 FACILITY DESCRIPTION2.1 Maine Yankee Site2.1.1 OverviewThe Maine Yankee site is located in the town of Wiscasset, Lincoln County, Maine. Sitecoordinates are approximately 43 degrees 57 minutes 5 seconds north latitude and 69degrees 41 minutes 45 seconds west longitude. The site is bounded by the Back River onthe east, mainland on the north and Bailey Cove on the west. The ISFSI is located on apeninsula known as Bailey Point, which extends south to Montsweag Bay (Figure 2-1).The ISFSI facility is depicted on Figure 2-2. Spent nuclear fuel is in interim storagewithin the specified secure fuel storage area and will be monitored by the ISFSJ staff.2.2 General AreaWithin 5 miles of the site, land use is largely rural residential, small businesses, summerhouses, idle farmland and forest. Housing is scattered along principal roads and isconcentrated only in the center of Wiscasset.The waters of the Back River, Montsweag Bay and associated tributaries are tidal andopen to boating, both commercial and recreational. Regulation of boating is theresponsibility of the U.S. Coast Guard and the State of Maine. The primary type ofboating in the Mon._tswe~ag B~ay -Back River is shallow draft Pleasure boats. With nocommercial traffic in the area, there is essentially no hazard to the site from potentialaccidents with commercial barges or boats carrying hazardous, toxic or explosivematerials.Industrial activity within the general area of the JSFSJ is minimal. The largest industrialfacility is the Bath Iron Works, a shipbuilding facility located on the Kennebec Riverapproximately 7 miles southwest in the city of Bath.The Wiscasset Municipal Airport is the nearest airport to the site and is locatedapproximately one .mile northwest of the site. It consists of one runway (approximately3,400 feet long by 75 feet wide). This runway is aligned such that takeoffs and landingsare on headings of either 070 or 250 (the predominant heading is 250). The majorities ofaircraft that are serviced by this facility are privately owned and are similar to the PiperColt, Cherokee, and Cessna 150 and 172 type craft. The largest aircraftthat typically usethe facility are similar to the Lear 25, Citation II and Rockwell Commander type craft.2.1REV 7 2.3 Independent Spent Fuel Storage Installation (ISFSI)The ISFSI is designed for interim storage of fuel for a minimum of 50 years in acontained shielded system. The ISFSI utilizes the Universal MPC System (UMSTM)developed by NAC International. The UMSTM is a canister-based multi-purpose canister(MPG) system designed for both storage and transportation of spent nuclear fuel. Thecanister-based spent fuel storage system is a passive system which utilizes an outerconcrete cylinder called a Vertical Concrete Cask (VCC) to protect and shield the innersealed metal canister. The VCC is vented for natural convection cooling and has nomoving parts. Decay heat from the loaded fuel storage canister in the VCC is dissipatedto the surrounding air by a once through buoyancy driven airflow. The VCC providesradiation shielding, as well as protection from tornado missiles and earthquakes.The ISFST site consists of a Protected Area (PA) for fuel storage and aSecurity/Operations Building. The ISFSI has a Controlled Area that extends at least 300meters from the nuclear fuel storage area.The PA has sixteen concrete storage pads, and is surrounded by a security fence and anuisance fence with an isolation zone between the two fences. A partial earthen berm isprovided around the facility to reduce the visual impact of the facility. The ISFSI containsa total of 64 storage casks, with one sealed fuel canister per VCC. The types of canistersstored in the storage casks include 60 casks for spent fuel and 4 casks for Greater ThanClass C (GTCC) waste. Sixteen storage pads of equal size are provided for uniformity,which allows for storage of 4 casks per storage pad. The ISFSI site is arranged to providemaneuvering room around the storage pads for access with a cask heavy haul tractor-trailer.The Security/Operations Building provides offices and work space for the operating andmaintenance personnel, including the Radiation Controls Checkpoint lunch/conferencerooms, restrooms, locker rooms, document control room, spare parts storage, and a dieselgenerator for emergency power. The Security/Operations Building also houses the ISFSJsecurity staff, security equipment, and communications equipment. Access to the ISFSIprotected area is controlled and monitored by the security staff.The ISFSI operates under the provisions of a general license utilizing the UJMSTM spentfuel storage/transportation system. The UMSTM system is licensed under a Certificate ofCompliance issued by the U.S. Nuclear Regulatory Commission (NRC) in accordancewith 10 CFR Part 72, "Licensing Requirements for the Independent Storage of SpentNuclear Fuel and High-Level Radioactive Waste".2.2REV 7 FIGURE 2-1MAINE YANKEE SITEGENERAL AREAII fI;.so~cE- USGS OUAD~AM.- WEST--:',:' I. iSWJESS AE/90..1 "" eifSZALE'" Fa2.3oREV 7 FIGURE MAINE YANKEE SITE* 4,*BERMl2.4REV 7 3.0 ISFSI ACCIDENT TYPES. DETECTION AND CONSEQUENCES3.1 Radiological EventsThere are no postulated credible ISFSI accident conditions that would impose aradiological hazard to personnel beyond the ISFSI Controlled Area boundary. There areno credible design basis accidents that would exceed the EPA PAGs at the ISESIControlled Area boundary. In the event of an ISFSI accident condition, the associatedradiological hazards are limited to personnel onsite at the time of the event.The postulated ISFSI accident conditions are described in Chapter 11 of the SafetyAnalysis Report for the UMS Universal Storage System developed by NAC International(Reference 4).3.2 Non-Radiological EventsThe spectrum ofIJSFSI non-radiological events that could necessitate implementation ofthis Emergency Plan is limited. These events fall into the category of general industrialincidents (e.g. fire, explosion, toxic material release, etc.), natural and destructivephenomena (hurricane, tornado, etc.) or security events. These events are furtherdescribed in Chapter 11 of the Safety Analysis Report for the UMS Universal StorageSystem. The determination of which, events are included is based on the probability ofoccurrence, the potential severity and the potential impact on the facility of the event.3.2.1 Tip-Over of Vertical Concrete CaskA hypothetical non-credible accident condition has been postulated involving the non-mechanistic tip-over of a vertical concrete storage cask. Functionally, the cask is notexpected to suffer significant adverse consequences due to this event. The concrete caskand canister are expected to continue providing design basis shielding, geometry controlof contents, and contents confinement performance. The tipped-over configuration of theconcrete cask will be obvious during a Site inspection following the initiating event.There is an adverse localized radiological consequence due to the hypothetical tip-overevent since the bottom end of the concrete cask has significantly less shielding than thesides and top of these same components. The estimated dose rate from the-bottom of atipped-over cask is calculated to be approximately 34 rem/hr at 1 meter, 4 rem/hr at 4meters, and < 10Omrem/hr at 100 meters (NAC-SAR). Following a tip-over event,supplemental shielding should be used until the concrete cask can be up-righted. Surfaceand top and bottom edges of the concrete cask are expected to exhibit cracking andpossible loss of concrete down to the layer of reinforcing bar. The increased dose ratedue to this cracking is not expected to be significant. There are no credible eventsexpected to result in a cask tip-over.3.1REV 7 3.2.2 Tornado and Tornado Driven MissilesIt is not expected that the performance of the UMS storage cask will be significantlyaffected by a tornado event. It is not anticipated that postulated tornado wind loading andmissile impacts are capable of overturning a cask, or penetrating the cask concreteboundary and affecting the fuel storage canister. A tornado event can be visuallyobserved. Advanced warning of a tornado and of tornado sightings may be received fromthe National Weather Service, local radio and television stations, local law enforcementpersonnel, and site personnel. An inspection of the cask exterior surface following atornado event is required. The inspection should be directed at ensuring the inlets andoutlets have not become blocked by wind-blown debris and checking for obviousconcrete surface damage. Damage to the vertical concrete cask after a design basistornado is not anticipated to result in radiation exposure at the Controlled Area boundarythat would exceed the EPA PAGs exposure guidelines. The penetrating missile impact isestimated to reduce the concrete shielding thickness, locally at the point of impact, byapproximately 6 inches. Localized cask surface dose rates for the removal of 6 inches ofconcrete are estimated to be less than 250 rnrem/hr (NAC SAR Section 11.2.11).3.2.3 Explosions.An explosion affecting the Universal Storage System may be caused by industrialaccidents or the presence of explosive substances in the vicinity of the ISFSI. It is notanticipated that explosive substances will be stored or used at the JSFSJ. An explosion inthe vicinity of the ISFSI would be sensed by on-duty ISFSJ personnel. In the event of anearby explosion, an inspection of the concrete casks may be required to check caskintegrity, to ensure that the air inlets and outlets are free of debris, and to ensure that themonitoring system and screens are intact. There are no anticipated off-site radiologicalconsequences for this event.3.2.4 Seismic EventThe earthquake evaluation shows that the loaded or empty vertical concrete casks are notexpected to tip over or slide in the event of an earthquake. Significant earthquakes wouldbe detected by ground motion. Inspection of the vertical concrete casks is requiredfollowing an earthquake event. The proper positioning of the Concrete casks should beverified to ensure they maintain the established spacing requirements. The temperaturemonitoring system should be checked for operation. There are no anticipated off-siteradiological consequences for earthquake events.3.2REV 7 3.2.5 FiresThere are no flammable materials routinely present in the ISFSI cask storage area. A"combustible liquid control zone" shall be established for the ISFSI itself, which shall bea minimum of 10 feet from the outside perimeter of the VCC. The total liquidcombustibles allowed within the zone cannot exceed 50 gallons and must be in directsupport of ISFSI operations or maintenance. A fire in the vicinity of the ISFSI will bedetected by observation of the fire or smoke. Upon detection of a fire, appropriate actionsshould be taken by site personnel to report andlor extinguish the fire. The concrete caskshould be inspected for general deterioration of the concrete, loss of shielding (spalling ofconcrete), exposed reinforcing bar, and surface discoloration that could affect heatrejection. This inspection serves as the basis for the determination of any repair activitiesnecessary to return the concrete cask to its design basis configuration. There may be localspalling of concrete during the fire event, which could lead to some minor reduction inshielding effectiveness. The principal effect would be local increases in radiation doserates on the cask surface. There are no off-site radiological consequences anticipated forthis event.3.2.6 Abnormal Cask Outlet Temperature ShiftThis event involves an abnormal outlet temperature shift caused by a partial or fullblockage of the vertical concrete cask air inlets and outlets that could result in the heat upof the fuel cladding, the fuel basket and the concrete, with the temperature potentiallyreaching the design basis limiting temperature. Full blockage could result in thesetemperature limits potentially being exceeded after 24 hours. Blockage of the cask airinlets and outlets will be detected by the Cask outlet temperature monitoring system. Anyobstruction blocking the air inlets and outlets must be manually removed. There are nosignificant radiological consequences for this event at the Controlled Area boundary, asthe vertical concrete cask is expected to retain its shielding performance (NAC SARL11.2.13).3.2.7 Other Conditions3.2.7.1 Off-Normal Canister Handling EventsThese events would involve off-normal occurrences during the handling or transfer of aloaded transportable storage canister (TSC), i.e., during the installation or removal of thecanister in or from the vertical concrete cask (VCC), or the transfer cask (TFR).Unintended loads could be applied to the canister due to misalignment or faulty craneoperation, or due to inattention of the operator. The event is expected to be obvious tothe operators at the time of occurrence. There is no anticipated deterioration of thecanister or fuel basket performance due to this event. There are no anticipated off-siteradiological consequences associated with this off-normal event.3.3REV 7 3.2.7.2 Drop of Vertical Concrete CaskThis event involves dropping a loaded vertical concrete cask during routine handlingoperations. This event may be due to the failure of one or more of the cask lifting jacksor of the air pad system. The maximum lift height shall be limited to less than 24 inchesby administrative controls. The event would be detected by the operators as it occurs.The damaged cask should be inspected and repaired prior to continued use. There are noanticipated off-site radiological consequences for this event.3.2.7.3 Flood EventThe UMS storage system vertical concrete casks have been evaluated for a design basisflood condition having a 50-foot depth of water and a water velocity of 15 feet persecond. This flood depth would frully submerge the vertical concrete casks. The analysisshows that the vertical concrete casks are not expected to slide or overturn during thedesign basis flood. Small floods may lead to blockage of the concrete cask air inlet vents.Partial and full blockage of air inlets is described in Section 3.2.6 of this plan. Floodingconditions would be detected by the ISFSI staff or personnel working in the vicinity ofthe ISFSI. A potential exists for collection of debris or accumulation of silt at the base ofothe cask, which could clog or obstruct the air inlet vents. Operation of the temperaturemonitoring system should be verified, as flood conditions may have impaired operation. There are no anticipated off-site radiological consequences associated with thedesign basis flood event.3.2.7.4 Lightning Strike EventSince the vertical concrete casks are located on an unsheltered pad, the casks may besubject to a lightning strike. A lightning strike on a concrete cask may be visuallydetected at the time of the strike, or by visible surface discoloration at the point of entryor exit of the current flow. There are no anticipated off-site radiological consequencesdue to the lightning event.3.3 Security EventEvents that impact the security of the ISFSI are discussed in the ISESI Security Plan.These events represent a threat to the level of safety of the ISFSI due to unauthorizedaccess, the introduction of threatening materials, or the use of hostile force in designatedsecurity areas. Security event detection and response is described in the Maine YankeeIndependent Spent Fuel Storage Installation Physical Security Plan. The Emergency Planmay be implemented if necessary in response to a security event.Events that fall into these areas will be categorized under the appropriate category in theclassification process discussed in Section 4, CLASSIFICATION OF ACCIDENTS.3.4REV 7 4.0 CLASSIFICATION OF ACCIDENTSBased on NUJREG-l1140,"Regulatory Analysis of Emergency Preparedness for Fuel Cycleand Other Radioactive Material Licensees", the NRC has determined that there are nocredible design basis accidents that would exceed the EPA PAGs at an ISFSI ControlledArea boundary. Emergency classification guidance in Appendix F of Nuclear EnergyInstitute document NEI 99-01 (Final Rev. 4), "Methodology for Development ofEmergency Action Levels," states, "The expectations of offsite response to an 'alert'classified under a 10 CFR 72.32 emergency plan are generally consistent with those for anotification of unusual event in a 10 CFR 50.47 emergency plan, i.e., to provideassistance if requested." The NEI 99-01 guidance is utilized in this plan to classify MaineYankee ISFSI emergency events. The NRC Regulatory Analysis for Rev. 4 of Reg Guide1.101 (Reference 5) to accept NET199-01 determined that the guidance in NE1 99-01 isappropriate for developing site specific EALs, to meet the intent of 10 CFR 50.47(b) (4 )and Appendix F to Part 50.Accidents and off-normal events that are analyzed for the ISFSI, including some eventsconsidered to be non-credible, have been reviewed and assigned a classification. Thereare no credible design basis accidents that would exceed the EPA PAGs at the ISFSIControlled Area boundary. Table 4-1 summarizes events that are classified as an UnusualEvent.This plan classifies events based on predetermined Emergency Action Levels (EALs).This approach provides a simple, predetermined response to an emergency event oraccident, allowing a coordinated and phased approach to the eventual mitigation of theconditions and restoring the facility to a safe status.4.1 Definitions4.1.1 Unusual Event (U-E)Events are in process or have occurred which indicate a potential degradation of the levelof safety of the facility. No release of radioactive material requiring offsite response ormonitoring is expected.4.2 Categories of EventsPer the Emergency Action Levels (EALs) guidance in NE1 99-01 (Reference 2), there aretwo categories of ISFSI events that can lead to an accident being classified as an UnusualEvent (UF). The ISS/ED has the discretion to classify events based on the classificationlevel definition. This discretion should be used when conditions or events are observedand no specific Initiating Condition (IC) / Emergency Action Level (EAL) is apparent.The UBE classification will heighten awareness of the abnormal condition. Table 4-1 liststhe initiating conditions, associated emergency action levels, and the applicable NRCemergency classification levels.4.1REV 7 4.2.1 Damage to a Loaded Vertical Concrete Cask That May Damage the Fuel or GTCCConfinement Boundary UEA UE classification for these IC/EALs is warranted on the basis of the occurrence of anevent of sufficient magnitude that a loaded VCC is severely damaged, which may beindicative of potential damage to a cask confinement boundary. This classificationincludes events involving loss of a loaded fuel storage cask confinement boundary,leading to degradation of the fuel during storage or posing an operational safety problemwith respect to removal of the degraded fuel confinement boundary from storage. Naturalphenomena events and accident conditions in which a loaded VCC is damaged areclassified at the UPE level. Cask seal integrity issues discovered during leakage testingassociated with normal canister processing would be addressed in accordance with NACtechnical specifications, or required actions, therefore, classification should not bemade based on loss of seal integrity by itself. However, loss or potential loss of sealintegrity coincident with an accident condition or natural phenomena that clearly affectsthe cask would justify a UPE classification. The 1SF SI vertical concrete storage casks areroutinely monitored by site personnel such that any degradation would be detected.Increases in radiation levels may be indicative of degradation of a storage cask.4.2.2 Confirmed Security Event with Potential Loss of Level of Safety of the ISFSI LYEThese IC/EALs provide a UE cl!assification for security events involving a potential lossof the level of safety of the ISFSI based on the Maine Yankee Independent Spent FuelStorage Installation Physical Security Plan.4.2REV 7 TABLE 4-1 EMERGENCY ACTION LEVELSInitiating Conditions Emergency Action Levels NRC EmergencyClassification LevelHU1 -DAMAGE TO A 1. Natural Phenomena UNUSUAL EVENTLOADED VERTICAL events affecting a loadedCONCRETE CASK (VCC) GTCC or spent fuel caskTHAT MAY DAMAGE confinement boundary.THlE FUEL OR GTCC 2. Accident conditionsCONFINEMENT affecting a loaded GTCCBOUNDARY or spent fuel caskconfinement boundary._________________3. ISS/ED judgment.HiU2 -CONFIRMED 1. Ongoing security UNUSUAL EVENTSECURITY EVENT WITH compromise or attemptedPOTENTIAL LOSS OF entry which may result inLEVEL OF SAFETY OF the potential loss ofTHE ISFSI control of the facility.4.3REV 7 5.0 EMERGENCY RESPONSEEmergency Response OverviewIn the event of an accident at the facility, actions will be taken by facility staff to reportthe event to the ISFSI Shift Supervisor (ISS) and to minimize the impact of the event. Theprimary objective of the initial responders is to assess the situation and minimize the riskimposed on workers and the general public. This involves initiation of required actions tomitigate a particular hazard. Subsequent actions include notifications, staffaccountability, staff augmentation, and implementation of onsite corrective actions asnecessary. The ISFSI Shift Supervisor becomes the Emergency Director (IS S/ED) uponclassification and declaration of an unusual event.5.1 Notification and ActivationWhen an emergency condition is recognized, the event is classified and declared by theISS/ED and mitigating actions are taken to minimize the progression of the event. Theseactions are initiated by available resources. The IS S/ED will request any offsite assistancethat may be necessary due to the nature of the event. Following initial notifications, theMaine State Police (MSP) and the Nuclear Regulatory Commission (NRC) will benotified of the event and mitigating actions in progress or that have been completed.Figure 5-1 depicts the initial .notification and activation process.5.1.1 Maine Yankee Emergency Support StaffThe ISS/ED or designee will direct ISFSI shift personnel to notify the ISFSI Support Staffof an event, if necessary. This will be accomplished by the commercial telephone system(i.e., land based, cell based, satellite based service). In the event the initiating conditionsconstitute a Security Event, these notifications will be made by the IS S/ED or designee. [Notifications to supplement support positions should be completed within one hour of theevent declaration.5.1.2 Offsite OrganizationsFollowing notification of the Maine Yankee ISFSI Support Staff, the Maine State Police(MSP) will be contacted and provided pertinent information regarding the event, actionstaken to mitigate the event and notification of any assistance which may be necessaryfrom local organizations (i.e. fire, ambulance, police response). Notification to the MSPshall be comPleted within one hour of event declaration. Depending on the need forimmediate outside assistance, these notifications may be initiated in an acceleratedmanner (i.e. immediate need for fire fighting capabilities or medical assistance). TheMSP Headquarters Communications Center is staffed 24 hours a day, 7 days a week. TheMSP have the capability to contact State and county emergency response personnel, ifneeded.The MSP will initiate notification to appropriate State Officials in the Maine EmergencyManagement Agency (MEMA), Division of Environmental Health (D)EH) and others asdesignated in the State's notification protocol, based on the event.The NRC will be notified after the notification of the MSP and no later than one hourafter the emergency was declared.5.1REV 7 5.1.3 Information to be CommunicatedA pre-scripted format is used to ensure consistent information is provided to the MSP andthe NRC.At a minimum, the following information will be provided during the initial notificationof the event:Event Classification;Date/Time of Classification;Reason or events causing the condition;General description of damage to major structures/areas;Personal injuries;Status of offsite assistance (fire/medical/other);Name of person making notification;Date and Time of notification.The information will be verified, via repeat-back, to ensure it was accuratelycommunicated.5.2 Radiological AssessmentInitial response to an event will be to ascertain the cause, mitigate furter progression anddetermine the potential impact to ISFSI personnel and the general public. Initialassessment will normally consist of an area dose assessment if warranted. Initial doseassessment activities will be directed by the ISS/ED and performed by qualifiedpersonnel.As soon as practical, facility staff should initiate general area radiation surveys todetermine the actual extent of any radiological concern. Results of the surveys will' beanalyzed by facility staff to formulate an action plan to mitigate the event and restore thefacility to a safe condition. Survey data will also be used, as appropriate, in any on-sitedose assessment techniques.Following the termination of the event, environmental surveys (including, but not limitedto water, soil, vegetation, etc.) may be required to determine the long-term impact of theevent.5.3 Protective Actions5.3.1 Relocation and AccountabilityIn an UNUSUAL EVENT declaration, personnel not directly involved with the responsemay be directed to relocate to an assembly area. Staff will be notified using the on-sitepaging system or other means. An assembly area may be established, based on the natureof the event, at a location determined by the ISS/ED. The ISFSI shift staff will maintainaccountability of personnel and report any missing persons to the ISS/ED. Search andrescue efforts may be performed by shift personnel or local response personnel asnecessary.5.2REV 7 5.3.2 First Aid/Medical ResponseOff-site emergency medical responders will be requested to report to the scene andinitiate first aid treatment to stabilize the patient and prepare for transport to a medicalfacility. One or more First Aid kits are located in the facility. Injuries may becomplicated by the presence of radiation and/or a contaminating substance (chemical orradiological). Given the design of the fuel/GTCC storage canisters, radiologicalcontamination is unlikely, but should be evaluated. The patient will be assessed to*determine if a life-threatening condition exists and appropriate actions taken to eithercontain or remove the contamination. In addition, environmental factors will be takeninto account regarding the need to stabilize the patient in place or remove to a safer area(i.e. lower radiation levels, etc.). Maine Yankee maintains a Letter of Agreement with theWiscasset Ambulance Service for transporting injured/contaminated workers from thesite to a receiving hospital. In addition, agreements have been made with the MidcoastHospital (Brunswick) for treating personnel with various types of injuries/conditions.5.3.3 Personnel MonitoringPersonnel working in known radiation areas will be issued dosimetry in accordance withexisting radiation protection procedures. During emergency conditions, they normallyretain their dosimetry and report to either their assigned emergency station or theassembly area, if a person suspects they may be contaminated, they will be monitored byRadiation Protection personnel.Emergency support staff will be issued dosirnetry as required for assigned tasks.Exposure control will be maintained in accordance with the site Radiation Protection andALARA programs. Dose extensions may be granted in excess of the limits of 10OCFR20for special circumstances. These extensions will be in accordance with EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents.Extensions above the I0CFR_20 limits must be approved by the IS S/ED. The anticipatedemergency exposures are well within the limits specified in Table 5-1.5.3REV 7 TABLE 5-1 GUIDANCE ON DOSE LIMITS FOR EMERGENCY WORKERS (a)Type of Activity TEDE (b) ConditionAll 5 Remn Maintain ALARA and to the extent practicable___________________________limit emergency workers to these limitsProtecting Valuable Property 10 Remn Lower dose not practicable.Life Saving or Protection of Large 25 Rem Lower dose not practicable.Populations>25 Rem Only on a voluntary basis to persons fully aware ofthe risks involved, including the numerical levelsof dose at which acute effects of radiation will beincurred and numerical estimates of delayedeffects.(a) From EPA-400-R-92-00l, Manual of Protective Action Guides and Protective Actions forNuclear Incidents(b) Sum of the deep dose equivalent from the external sources and the comimitted dose.equivalent from the internal exposures to non-pregnant adults from exposure and intakeduring an emergency situation. Dose limits to the eye should be 3 times the listed value.Dose limits to any other organ (including skin and body extremities) should be 10 times thelisted value.5.3.4 Decontamination CapabilitiesSurvey instrumentation for personnel frisking is available. Personnel contaminationidentified during the initial survey will require the contaminated individual to removeprotective apparel, re-survey, and if skin contamination levels are identified, performdecontamination as directed by radiation protection personnel.In the event that accident conditions result in a contaminated injured individual, thevictim's rescue and medical treatment take precedence over the Victim's radiationexposure due to bodily contamination. Gross decontamination of the victim (generallylimited to the removal of contaminated articles of clothing) will be accomplished to theextent that the health of the patient is not affected. Decontamination measures associatedwith wounds will be performed under the joint supervision of the attending physician atthe hospital and the responding radiation protection representative.5.3.5 Contamination and Hazard Exposure ControlSurveys will be conducted to determine which areas contain contamination of either aradiological nature or a hazardous substance. These areas will be identified by eithermarking with boundary rope or tape and access will be limited and controlled accordinglyby the radiation protection personnel. Monitoring of the area will be conducted usingappropriate equipment, based on the type of contamination. All personnel required towork in the area will be provided appropriate personnel protective equipment (coveralls,booties, gloves, etc.) by the Radiation Protection contractor. The level of protection willbe determined by the IS S/ED or other designated personnel.5.4REV"7 5.3.6 Emergency ActionThis plan permits emergency response personnel to take reasonable action that departsfrom a license condition or a technical specification in an emergency when this action isilmmediately needed to protect the public health and safety and no action consistent withlicense conditions and technical specifications can provide adequate or equivalentprotection is immediately apparent.5.4 Coordination with Offsite AgenciesThere is no response required from State agencies. State government response isexpected to be limited to recording the notification of the emergency, periodicallyreceiving updated information on the emergency, and coordinating public informationnews releases. Upon request, Local government agencies (i.e. fire, police, ambulance)will respond to the ISFSJ during an emergency, if necessary.If needed, provisions exist for limiting traffic on roads leading to the Maine Yankee site.These actions would be coordinated through the Maine State Police or the LincolnCounty Sheriffs Office, Wiscasset, Maine.5.5REV 7 FIGURE 5-1MAINE YANKEE INITIAL NOTIFICATION AND ACTIVATION PROCESS' IS S/EDISFS.I SHIFT NRC MAINE STATESPECIALIST POLICE (MSP)MAINE YANKEE .MAINE EMERGENCISFSI SUPPORT MANAGEMENTSTAFF AGENCY (EOC)(If needed)5.6.;YREV 7 6.0 FACILITIES AND EQUIPMENT6.1 Control CenterThe Control Center in the Security/Operations Building is the primary facility whereISFSI conditions are monitored and corrective actions are developed to mitigate anyabnormal occurrence. Emergency conditions classified as UEs are managed by theISS/ED from the Control Center or other appropriate location.The Control Center provides space for the designated members of the ISFSI Emergencysupport staff to conduct analysis and support functions in response to the event. TheControl Center may be activated for other reasons at the discretion of the ISSiED. Thefollowing functions are coordinated from the Control Center: emergency management,offsite notifications and communication, and facility restoration planning.The Control Center is sized to accommodate personnel performing communications,radiological assessment, general engineering and analysis tasks. Communication systemsare available to allow interaction with offsite organizations, as necessary. Variousequipment has been assembled and stored in or near the Control Center for use by supportstaff, including personal protective equipment, and radiation monitoring equipment. TheControl Center has nearby office space to accommodate any required offsite personnel.6.2 Radiation Controls CheckpointThe Radiation Controls (RC) Checkpoint is located in the Security/Operations Building.Personnel dosimetry is issued at this point and a radiological emergency kit is available.6.3 Assembly .AreaPersonnel directed to evacuate the PA will be directed to report to an assembly areadesignated by the ISS/ED.6.4 EquipmentAppropriate equipment is maintained for emergency response activities in the ISFSISecurity/Operations Building. Required supplies are inventoried to ensure operabilityand availability at all times.Controlled copies of facility documents (drawings, procedures, Technical Specifications,SARs, etc.) are maintained in, or in the areas adjacent to the Control Center. Thisinformation is readily available for support staff use.6.1REV 7 6.5 Communications6.5.1 Onsite Communication Systems6.5.1.1 Commercial Telephone SystemThe commercial telephone system is the primary means of onsite communicationduring an emergency. This system has an independent backup power configuration,which incorporates a combination of batteries and an emergency diesel generator toensure uninterrupted operation on a loss of normal power to the ISFSI telephonesystem.6.5.1.2 Paging SystemA general voice paging system is available with speakers on the interior and exteriorof the Security/Operations Building.6.5.1.3 Radio SystemISFSI staff will be equipped with portable radios for onsite communications. One ormore licensed frequencies will be used for routine communications, and one or morestate police frequencies will be used for offsite routine and emergencycommunications.6.5.2 Offsite Communications Systems6.5.2.1 Telephone to the Maine State PoliceCommercial telephones are used to establish communications between the MaineYankee JSFSI Control Center and the Maine State Police (MSP). This is the primarymethod of informing State of Maine personnel of a declared emergency at the MaineYankee ISFSL. Both organizations have telephones in a location that is staffed 24hours a day, '7 days a week.6.5.2.2 Maine State Police RadioIn the event the commercial telephone circuits fail, the MSP can be contacted viaradio from the Control Center and from the ISFSI Security Offices using either of twoState Police frequencies installed on these radios (State Police -Zone 2 and state-widecar-to-car (SWCC). SWCC frequency can also be used to communicate with theLincoln County Sheriffs Office. The ISFSI radio system is powered from the normalpower company service grid. Back up power is provided by a UPS system.6.5.2.3 NRC Emergency NotificationIn the event of an emergency at the Maine Yankee ISFSI, the NRC will be notifiedwithin one hour using the ENS telephone system in accordance with 10 CFR 50.72(a).This line is not anticipated to be established continuously, but used primarily toprovide periodic informational updates to the NRC.6.6 Fire SuppressionFire extinguishers located at the ISFSI are used to help extinguish or contain a fire tothe area of origin and minimize involvement of adjacent areas until the Wiscasset FireDepartment responds to the scene. A fire hydrant is located near the ISFSI for use bythe Wiscasset Fire Department.6.2REV 7 7.0 RESPONSIBILITIESThe Emergency Organization is comprised of on-shift ISFSI personnel. Detection andrecognition of conditions that warrant declaration of an emergency, in accordance withthe EALs, is the responsibility of the ISFSI Shift Supervisor (ISS). Upon declaration of anemergency, the on-shift organization assumes their emergency response duties andimplements this plan. The minimum on-shift staff required for initial emergencyresponse consists of the ISS/ED (Fig. 7-1).The IS S/ED may call in support staff in numbers and disciplines necessary to support theresponse and recovery actions required for the event. Radiation Protection support isavailable on a call-in basis if not present on-site at the onset of an emergency.7.1 On-shift Organization7.1.1 LSFSI Shift Supervisor /Emergency DirectorThe ISS is the qualified emergency representative on-shift. The 1SS assumes the positionof ISS/ED. The IS S/ED executes any actions deemed necessary to mitigate theconsequences of the emergency condition and restore the facility to a safe and stableconfiguration.The primary responsibilities of the IS S/ED include:* Classification and emergency declaration of the incident* Notification and request for assistance from local response agency, including medicalassistance as necessary* Notification and interface with offsite agencies* Notification of ISFSI support staff,* Direction and control of available personnel* Initiation of immediate corrective actions, if any* Direction, control, communications and public information* Authorization of onsite protective actions* Establish priorities for the Control Center staff* Provide periodic updates to the NRC* Determine the need for offsite/contractor assistance* Mitigation and recoveryThe ISS/ED is responsible for maintaining the integrity of the ISFSI and all operationalactivities in the facility. The ISS/ED may be relieved by another qualified ED) ifconditions warrant.7.1.2 Shift SpecialistThe ISFSI Shift Specialist is responsible for maintaining facility security in accordancewith the ISFSI Security Plan.The primary responsibilities of the Shift Specialist during an emergency is:* Maintaining site security and access control from the Central Alarm Station (CAS)* Personnel Accountability in the ISFSI Protected Area (PA)* Notification of the support staff as requested by the iS S/ED* Notification of offsite Agencies as requested by the IS S/ED* Search and Rescue coordination, as necessaryoFire response coordination, as necessary.7.1REV 7 7.2 Augmented OrganizationThe need for an augmented response by support staff is determined by the ISS/ED on acase by case basis for the Unusual Event (UE) classification. If needed, the augmentedsupport staff is expected to be in place to support emergency response activities withinapproximately 2 hours. Augmented response personnel may be provided by a contractedservice.7.2.1 Support StaffAvailable facility staff and/or emergency services contractors will be called in asnecessary to assist in the response, including:* Perform spent fuel storage condition assessments, if necessary* Assess the extent of damaged equipment* Identify short and long-term repair needs* Establish initial repair priorities and deploy repair teams* Coordinate available resources to restore equipment and systems based on thedirection of the ISS/ED* Handle logistical needs* Perform radiological and environmental surveys as necessary.* Developing public information materials for release to the news media as necessary,and maintaining liaison with news media and State of Maine information staff.7.2REV 7 FIGURE 7-1MAINE YANKEE ISFSIMINIMUM ON-SHIFT EMERGENCY ORGANIZATIONISFSI SHIFT SUPERVISOR!/EMERGENCY DIRECTOR (ISS/ED)SHIFT SPECIALIST7.3REV 7 8.0 MAINTAINING EMERGENCY PREPAREDNESSThe ISFSI Manager or designee is responsible for ensuring the availability ofadequate emergency support staff and for approval of the ISFSI Emergency Planand Implementing Procedures (IEPIPs).The JSFSI Manager is also responsible for ensuring the following tasks andfunctions are completed:* The maintenance of readiness of the on-site emergency response facilities andequipment;* Development and maintenance of the ISFSI Emergency Plan;o Development and maintenance of the associated implementing procedures;* Preparation of scenarios for training drills and exercises;* Conduct of drills and exercises;* Provision of input to emergency preparedness training of the support staff;* Returning emergency equipment and supplies used during a drill, exercise oractual emergency to a state of readiness following the termination of the drill,exercise or emergency;* Providing support for the annual radiation monitoring drill and medicalemergency drill.*Reviewing ISFSJ EALS with state and local government authorities on anannual basis in accordance with 10 CFR 50 Appendix E (TV)(B).8.1 TrainingThe Maine Yankee ISFSIi Emergency Plan Training Program consists of lessonplans designed to provide the skills and knowledge necessary to maintain staffproficiency. Each IEPIP will be reviewed to identify activities that are notconsidered to be a part of the assigned individuals day-to-day routine function (i.e.use of telephones, general communication protocol, etc.). Lessons will focus onnon-routine and specialized activities that are particular to the assigned functionand overall emergency response actions. Training may consist of, but not belimited to, classroom lecture, self-study, practical demonstrations (wherenecessary, as specified in the lesson plan), and facility drills.8.1.1 Emergency Staff TrainingEach individual selected for assignment to the on site staff or the support staff willbe provided training designed to familiarize the person with their duties,responsibilities and expected actions in the event of a condition that requires thesupport staff to be mobilized. This initial training will be completed prior to theindividual assuming the emergency response duty.Each on shift and support staff member will be provided continuing training fortheir assigned duties. This training will be conducted annually. Continuingtraining addresses general changes to the ISFSJ Emergency Plan, facilities,equipment, regulations, policies and specific changes to their responsibilities(which are not considered part of their routine duties). It also addresses problemareas identified during audits, drills or exercises.8.1REV 7 8.1.2 ISFSI Access TrainingThe ISFSI Access Training program provides employees and contractors routinely onsitethe basic elements of the ISFSI Emergency Plan and expected actions during anemergency. Information is reviewed annually as part of site access training.8.1.3 Offsite Assistance TrainingOrganizations which may be called upon to render assistance onsite will be offeredgeneral facility familiarization sessions on an annual basis. These sessions may include awalk down of the general facility, safety, building layout, access protocol,communications capabilities and security requirements. Radiological orientation trainingwill also be offered annually.8.2 Review and Updating of the ISFSI Emergency Plan and Implementing Procedures8.2.1 ISFSI Emergency Plan (JEP) ReviewThis plan, including all written agreements between Maine Yankee and other parties, willbe reviewed annually. Approved changes to the plan will be incorporated into theappropriate implementing procedures along with the plan changes. Letters of Agreementwill be reviewed annually and verified to be in effect at the time of the plan review. Thismay be accomplished via written correspondence or documented telephone conversation.This plan is a controlled document to ensure changes are incorporated into distributedcopies. Plan changes will be subject to management review and approval. Plan changeswill be issued as an entire revision with changes identified on the affected pages.8.2.2 Emergency Plan Implementing Procedure ReviewISFSI Emergency Plan Implementing Procedures (JEPIiPs) will be reviewed and revised inaccordance with plant procedure control guidelines, and as necessary. Periodic revisionswill be incorporated whenever a plan change is made that affects the procedure or othercircumstances dictate a revision is necessary. IEPIPs will be subject to managementreview and approval.8.2.3 Periodic Surveillance ProgramFacilities and equipment will be maintained in accordance with surveillance procedures.Inventories of emergency plan equipment will be conducted on a semi-annual basis andafter facility activation (actual event or drill activity). A walkdown of the Control Centerwill be conducted on a quarterly basis to ensure facility readiness is maintained.Telephone numbers that are important to emergency notification and are contained in theJEPI~s will be verified on a quarterly basis.8.2.4 Communications Systems ChecksTelephones, radios and paging systems used for on-site and off-site emergencycommunications will be tested quarterly per communications surveillance procedures.8.2REV 7 8.3 Drills and ExercisesIn addition to the emergency plan training described earlier, the facility staff will conductperiodic drills to enhance skills and knowledge of the practical implementation of theIEP. Periodic drills will be scheduled with various objectives to demonstrate theseCapabilities. Some drills will focus on singular functions (such as communicationscapabilities) while others will involve the activation of the support staff. Theseevolutions serve as an extension of the training program, allowing interaction betweenevaluators and responders to reinforce procedural requirements and overall processimplementation.8.3.1 DrillsIn addition to training drills discussed above, the following drills will be conductedannually;-Support Staff Drill -involving a combination of some of the principal functionalareas of emergency response capabilities. The biennial exercise satisfies the annualsupport staff drill requirements.-Radiological Monitoring Drill.- demonstrating conducting general area surveys.-Medical Emergency Drill -demonstrating the capability to transport an injured workeroffsite.-Fire Drill -conducted in accordance with the Fire Protection Program.8.3.2 ExercisesAn exercise will be conducted once every two years to demonstrate the capability toimplement the ISFSI Emergency Plan. Objectives will be developed to ensure majorelements of the emergency plan are demonstrated and evaluated to ensure the appropriatelevel of preparedness is being maintained.Offsite response organizations will be invited to participate in biennial exercises.8.3.3 Driln and Exercise EvaluationFacility staff will evaluate the exercise and drills. Expectations for evaluators will bediscussed with each evaluator prior to the drill. Whenever possible, evaluators shouldhave present or recent ISFSI emergency responsibilities and be assigned to evaluatefunctions/areas consistent with their emergency assignment. Following the drill/exercisea critique of the evolution will be conducted. Comments will be evaluated anddispositioned by Maine Yankee and deficiencies will be corrected through retraining,remedial drills, or by other means. Comment resolution will be assigned to appropriatepersonnel for final implementation.8.3REV 7 8.4 Independent Program ReviewAn independent program review of the ISFSI emergency preparedness program will beconducted once every 12 months in accordance with 10 CFR 50.54(t) or as necessary,based on the assessment against performance indicators, and as soon as reasonablypractical after a change occurs with personnel, procedures, equipment or facilities thatpotentially could adversely affect emergency preparedness, but no longer than 12 monthsafter the change. Items to be reviewed should include, but not be limited to, adequacy ofinterfaces with State and local government agencies, implementing procedures, drills,exercises and capabilities.8.4REV 7 9.0 RECOVERYThe primary objective of the facility staff is to mitigate the consequences of an emergencyand restore the facility to a safe condition. Restoration of the facility effectively beginswith the first action taken in response to the event and terminates when the facilityresumes normal operations.When conditionshave. stabilized and a full assessment of the event has been conducted,the facility staff will focus on establishing a plan to verify' operability of allsystems/components necessary to maintain and monitor the integrity of the spent fuel.The ISESI Manager or designee will coordinate the restoration of the facility and has theauthority to take the necessary actions to ensure the facility is returned to a safe condition.Recovery responsibilities, of the JSFSI Manager include, but are not limited to:Development of the site recovery plan.* Maintain comprehensive hazard assessment of the facility.* Prioritize clean-up of affected areas/equipment.* Isolate and repair damaged equipment/systems.* Document all actions taken related to the recovery operations.9.1REV 7 10.0 OFFSITE ASSISTANCEResponse from organizations that are not associated with Maine Yankee are not expectedto be necessary, except for fire, medical emergencies or hazardous materials incidents.Letters of Agreement exist with organizations that may be called upon, on an as-neededbasis, to provide assistance.The Wiscasset Fire Department and Wiscasset Ambulance Service have standingagreements to assist Maine Yankee in the event of a fire, hazardous materials incident ormedical emergency.Maine Yankee maintains a Letter of Agreement with the MidCoast Hospital in Brunswickfor treatment of radiologically contaminated and injured workers.Response from the State of Maine will be limited to acknowledging notification of theevent. No mitigating actions are anticipated to be necessary in response to an event at.Maine Yankee. Precautionary actions are anticipated to be similar to those taken inresponses to preparations for severe weather, etc.Other agreements exist for specialized services that can be called upon as needed.10.1Rev 7
 
==11.0 REFERENCES==
: 1. Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-400-R-92-001, May 1992.2. NEI 99-0 1 Final Rev. 4 "Methodology for Development of Emergency Action Levels,"January 2003.3. NIJREG-1 140, "Regulatory Analysis on Emergency Preparedness for Fuel Cycle and OtherRadioactive Material Licensees."4. NAC Safety Analysis Report, UMS Universal Storage System, Docket 72-10 15, October1999.5. NRC Regulatory Guide 1.10 1, Rev. 4, "Emergency Planning for Nuclear Power Plants.", July2003.6. NRC Regulatory Issue Summary 20 15-14, "Issuance of Enforcement Guidance Memorandum-Emergency Plan and Emergency Plan Implementing Procedure Updates", October 30, 2015.11.1Rev 7 APPENDIX I -ASSISTANCE AGREEMENTSORGANIZATIONMid-Coast HospitalWiscasset Fire DepartmentWiscasset Ambulance ServiceI-1IREV 7 APPENDIX II -SUPPORTING PLANS AN]) DOCUMENTSDefueled Safety Analysis Report (DSAR)FP-.1, Fire Protection ProgramMaine Yankee Independent Spent Fuel Storage Installation Physical Security Plan andSupporting Security ProceduresIi-1REV 7 APPENDIX Ill -EMERGENCY PLAN IMPLEMENTING PROCEDURES1. Emergency Plan Implementing Proceduresa. EQ -1, Emergency Planning Administrationb. EQ -2, Response to Accident and Natural Phenomena Eventsc. EQ -5, Emergency Plan Implementation'IlI-REV 7}}

Revision as of 18:05, 30 May 2018

Maine Yankee ISFSI - Revision 7 to the Emergency Plan
ML16014A136
Person / Time
Site: Maine Yankee
Issue date: 12/15/2015
From: Brown J S
Maine Yankee Atomic Power Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
OMY-15-055
Download: ML16014A136 (46)


Text

MAINE YANKEE321 Old Ferry Road, Wiscasset, Maine 04578December 15, 2015OMY- 15-055Re: 10 CFR 50.54(q)(5)10 CFR 72.44(f)10 CFR 50.4(b)(5)10 CFR 72.4ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-000 1Maine Yankee Atomic Power CompanyMaine Yankee Independent Spent Fuel Storage InstallationNRC License No. DPR-36 (NRC Docket No. 50-309)

Subject:

Revision 7 to Maine Yankee ISFSI Emergency PlanIn accordance with 10 CFR 50.54(q)(5), 10 CFR 72.44(f), 10 CFR 50.4(b)(5), and 10 CFR 72.4,Maine Yankee Atomic Power Company (Maine Yankee) is providing Revision 7 of the MaineYankee Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan, and a summary ofthe analysis that determined that the changes do not constitute a reduction in commitment, nor adecrease in effectiveness of the Maine Yankee ISFSI Emergency Plan.Attachment 1 provides a summary of the evaluation that provides the basis for concluding theMaine Yankee ISFSI Emergency Plan, as changed, continues to meet the standards of 10 CFR50.47(b) and the requirements of Appendix B to Part 50 as modified by the existing exemptionsfor the Maine Yankee ISFSI.Enclosure 1 provides a copy of Revision 7 of the Maine Yankee ISFSI Emergency Plan. It waseffective on December 15, 2015.This letter contains no commitments.If you have any questions regarding this submittal, please do not hesitate to contact me at(207) 882-1303.Respectfully,~Stanley PBEISFSI Manager Maine Yankee Atomic Power CompanyOMY- 15-055/December 15, 201 5/Page 2Attachments and EnclosuresAttachment 1 -Summary of 10 CFR 50.54(q) Evaluation for Changes to the Maine Yankee ISESIEmergency PlanEnclosure 1 -Maine Yankee ISFSI Emergency Plan, Revision 7cc: D. Dorman, NRC Region I AdministratorM. S. Ferdas, Chief, Decommissioning Branch, NRC, Region IM. Lombard, Director, Division of Spent Fuel Management, NM4SSJ. Goshen, NRC Project ManagerP. J. Dostie, SNSI, State of MaineJ. Hyland, State of Maine to OMY-15-055Summary of 10 CFR 50.54(q) Evaluation for Changes to theMaine Yankee ISFSJ Emergency PlanSection /Table Description of Proposed Change Justification of Proposed ChangeThrough-out Changed title Emergency This is a change to standardize to thethe Emergency Coordinator to Emergency same title at all three Yankee sites.Plan Director or EC to ED.Through-out The Emergency Plan has been These changes are editorial and clericalthe Emergency reformatted and renumbered as in nature and have no impact on thePlan. needed to support this change. intent of the Emergency Plan.Table 4-1 Deleted a reviewer's note that was This is an administrative change.incorporated into revision 6inappropriately.Section 5.3.3 This section has been revised to This is a change to permit the Radiationclarify that if personnel become Protection personnel to determine wherecontaminated they will be the monitoring and decontaminationmonitored by Radiation Protection will be performed.Personnel. It also eliminates therequirement to perform this_____________activity at a specific point.Section This section has been revised to This is a clarification of duties andadd that Protective Clothing (PCs) responsibilities making the Radiationwill be provided by the Radiation Protection contractor responsible toProtection contractor, supply PCs.Section 8.1.2 Changed title from General This is a clarification to identify theEmployee Training (GET) to current title of the site training program.ISFSJ Access Training.Chapter 11, Added reference to NRC RIS This is an administrative, change thatReferences 2015-14 "Issuance of Enforcement adds a new guidance document.Guidance Memorandum -Emergency Plan and EmergencyPlan Implementing ProcedureUpdates", issued 10/30/15.Appendix II Updated FP-1 title and updated This is a clarification and administrativePhysical Security Plan full title. change.Page 1 of 2 to OMY-15-055Summary of 10 CFR 50.54(q) Evaluation for Changes to theMaine Yankee ISFSI Emergency PlanSection /Table Description of Proposed ChangeJustification of Proposed ChangeAppendix III,EmergencyPlanImplementingProceduresDeleted EO-6, Non-EmergencyEvent Assessment as anEmergency Plan ImplementingProcedure.Deleted EO-3 and EO-4 asEmergency Plan ImplementingProcedures because their contentwas relocated into EO-2.EO-2 was renamed. The originalcontent of EO-2 was moved toOP-1, because it was not requiredto implement the Emergency Plan.EO-6 never implemented theEmergency Plan. A self-assessmentestablished that the actions in EO-6 didnot meet the intent or definition of animplementing procedure.The self-assessment identified thefollowing procedures as EmergencyPlan Implementing Procedures inaccordance with Appendix E to Part 50:EO-l -Emergency PlanImplementationEO-2 -Response to Accident andNatural Phenomena EventsEO-5 -Emergency Plan AdministrationThese procedures contai-n-the followingas required by Appendix E of Part 50:* Organization (Emergency)* Assessment Actions* Activation of the EmergencyOrganization* Notification Procedures* Emergency Facilities andEquipment* Training* Maintaining EmergencyPreparedness* RecoveryThe current EO-2 off normal actionshave been incorporated into OP-ibecause it did not implement theEmergency Plan. EO-2 has been revisedto incorporate EO-3 and EO-4 into thenew EO-2, titled "Response to Accidentand Natural Phenomena Events". EO-3and EO-4 have been cancelled.Page 2 of 2 ENCLOSURE 1 TO OMY-.15-055MAINE YANKEE ISFSI EMERGENCY PLAN, REVISION 7 MAINE YANKEEIN DEPENDENT SPENT FUELSTORAGE INSTALLATION(ISFSI)EMERGENCY PLANREVISION 7Effective Date: December 15, 2015 TABLE OF CONTENTSSection PageTABLE OF CONTENTS iiAPPENDICES iLIST OF TABLES vLIST OF FIGURES viDEFINITIONS vii

1.0 INTRODUCTION

1:12.0 FACILITY DESCRIPTION2.1 Maine Yankee Site 2.12.2 General Area 2.12.3 Independent Spent Fuel Storage Installation 2.23.0 ISFSI ACCIIDENT TYPES, DETECTION AND CONSEQUENCES3.1 Radiological Events 3.13.2 Non-radiological Events 3.14.0 CLASSIFICATION OF ACCIDENTS4.1 Definitions 4.14.2 Categories of Events 4.15.0 EMERGENCY RESPONSE5.1 Notification and Activation 5.15.1.1 Maine Yankee Emergency Support Staff 5.15.1.2 Offsite Organizations 5.15.1.3 Information to be Communicated 5.25.2 Radiological Assessment 5.25.3 Protective Actions 5.25.4 Coordination with Offsite Agencies 5.56.0 FACILITIES AND EQUIPMENT6.1 Control Center 6.16.2 Radiation Controls Checkpoint 6.16.3 Assembly Areas 6.16.4 Equipment 6.16.5 Communications 6.26.6 Fire Suppression 6.2REV 7 TABLE OF CONTENTS(Continued)Section Page7.0 RESPONSIBILITIES7.1 On-shift Organization 7.17.2 Augmented Organization 7.28.0 MAJINTAINING EMIERGENCY PREPAREDNESS8.1 Training 8.18.2 Review and Updating of the ISFSI Emergency PlanAnd Implementing Procedures 8.28.3 Drills and Exercises 8.38.4 Independent Program Review 8.39.0 RECOVERY 9.1*10.0 OFIFSITE ASSISTANCE 10.1

11.0 REFERENCES

11.1i11REV 7 APPENDICESAPPENDIX I -Assistance Agreements I-1APPENDIX II -Supporting Plans and Documents 11-1APPENDIX Ill -Emergency Plan Implementing Procedures III-i1ivREV 7 LIST OF TABLESNumber Title4-1 Emergency Action Levels5-1 Guidance on Dose Limits for Emergency Workers(EPA-400-R-92-00 1)Page4.35.4REV"7 LIST OF FIGURESNumber Titl.__e Tawe2-1 Maine Yankee Site -General Area 2.32-2 Maine Yankee Site -Facility Layout 2.45-1 Maine Yankee Initial Notification and Activation Process 5.67-1 Maine Yankee On-Shift Organization 7.3REV 7 DEFINITIONSASSEMBLY AREAS -Designated locations where personnel may be directed to congregate mnthe event of the need to evacuate all or portions of the facility.ASSESSMENT ACTIONS -Actions taken during or after an emergency event or accident toobtain and process information necessary to implement specific emergency measures.CONFINEMENT BOUNDARY -The confinement boundary of the canister consists of thecanister shell, bottom plate, shield lid, structural lid, the two port covers, and the welds that jointhese components.CONTROL CENTER (CC) -During an emergency the lunch/conference room or otherdesignated area in the security/operations building functions as the emergency Control Center(CC) operating under the direction of the Emergency Coordinator. It is the primary point atwhich 1SF SI conditions are tracked and corrective actions are taken to mitigate any abnormalconditions.CONTROLLED AREA -The designated area outside of the Protected Area (PA), extending atleast 300 meters from the spent fuel storage pads, over which control is exercised duringemergency events pursuant to 10 CFR 72.106(b).CORRECTIVE ACTIONS -Measures to reduce the severity of (or terminate) an emergencysituation.EMERGENCY ACTION LEVEL (rEAL) -Conditions that, if met or exceeded, warrantclassification and declaration of an emergency.EMERGENCY DIRECTOR (ED) -The ED is responsible for the overall coordination anddirection of the company response to an emergency condition at the ISFSI.EMERGENCY SUPPORT STAFF -A group of trained staff designated to respond to a'declared emergency, if necessary.GREATER THTAN CLASS C WASTE (GTCC) -Radioactive waste material that is notgenerally acceptable for near surface disposal is waste for which form and disposal methods mustbe different, and in general more stringent, than those specified for Class C waste. The MaineYankee Core Shroud Assembly and Core Support Plate are considered GTCC waste and will bestored at the ISFSI.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) -A spent fuel storagefacility owned and operated by Maine Yankee, comprised of a Protected Area (PA) containingsixteen storage pads having 64 cask locations for dry storage of spent fuel and GTCC waste, asecurity/operations building and an earthen berm partially surrounding the site.INITIATING CONDITION (IC) -ISFSI parameters, equipment status and/or personalobservations that comprise the individual EALs.LOCAL ORGANIZATIONS -Those organizations that provide specific services underemergency conditions (i.e. police, ambulance and fire department).viiREV 7 DEFINITIONS(Continued)UNUSUAL EVENT (UIE) -Events are in progress or have occurred which indicate a potentialdegradation of the level of safety of the facility. No release of radioactive material requiringoffsite response or monitoring is expected.PROTECTED AREA (PA) -The area, encompassed by physical barriers, within the secured,controlled access boundary of the ISFSI.ISFSI SHIFT SUPERVISOR (ISS) -The senior ISFSl representative on-shift. The ISSassumes the position of IS S/ED upon classification and declaration of an unusual event.REV 7

1.0 INTRODUCTION

This document describes the Maine Yankee Atomic Power Company's (MYAPC) planfor responding to emergencies that may arise at the Maine Yankee Independent SpentFuel Storage Installation (ISFSI). The overall purpose of the plan is to delineate theactions necessary to safeguard ISFSI personnel and minimize damage to site property inthe event of an incident at the ISFSI. Analyses of the possible design basis events andconsequences are presented in the Safety Analysis Report for the UMS UniversalStorage System (NAC UMS SAR) used at the ISFSI for dry spent fuiel storage.The analyses of the potential radiological impact of an accident at the Maine Yankee siteindicates that any releases beyond the ISESI Controlled Area boundary are expected to beless than the U.S. Environmental Protection Agency (EPA) protective action guide (PAG)exposure levels, as detailed in EPA-400-R-92-001, Manual of Protective Action Guidesand Protective Actions for Nuclear Incidents. Exposure levels which may warrant pre-planned response measures are generally limited to the Controlled Area. For this reason,radiological emergency planning is focused on the Controlled Area.1.1REV 7 2.0 FACILITY DESCRIPTION2.1 Maine Yankee Site2.1.1 OverviewThe Maine Yankee site is located in the town of Wiscasset, Lincoln County, Maine. Sitecoordinates are approximately 43 degrees 57 minutes 5 seconds north latitude and 69degrees 41 minutes 45 seconds west longitude. The site is bounded by the Back River onthe east, mainland on the north and Bailey Cove on the west. The ISFSI is located on apeninsula known as Bailey Point, which extends south to Montsweag Bay (Figure 2-1).The ISFSI facility is depicted on Figure 2-2. Spent nuclear fuel is in interim storagewithin the specified secure fuel storage area and will be monitored by the ISFSJ staff.2.2 General AreaWithin 5 miles of the site, land use is largely rural residential, small businesses, summerhouses, idle farmland and forest. Housing is scattered along principal roads and isconcentrated only in the center of Wiscasset.The waters of the Back River, Montsweag Bay and associated tributaries are tidal andopen to boating, both commercial and recreational. Regulation of boating is theresponsibility of the U.S. Coast Guard and the State of Maine. The primary type ofboating in the Mon._tswe~ag B~ay -Back River is shallow draft Pleasure boats. With nocommercial traffic in the area, there is essentially no hazard to the site from potentialaccidents with commercial barges or boats carrying hazardous, toxic or explosivematerials.Industrial activity within the general area of the JSFSJ is minimal. The largest industrialfacility is the Bath Iron Works, a shipbuilding facility located on the Kennebec Riverapproximately 7 miles southwest in the city of Bath.The Wiscasset Municipal Airport is the nearest airport to the site and is locatedapproximately one .mile northwest of the site. It consists of one runway (approximately3,400 feet long by 75 feet wide). This runway is aligned such that takeoffs and landingsare on headings of either 070 or 250 (the predominant heading is 250). The majorities ofaircraft that are serviced by this facility are privately owned and are similar to the PiperColt, Cherokee, and Cessna 150 and 172 type craft. The largest aircraftthat typically usethe facility are similar to the Lear 25, Citation II and Rockwell Commander type craft.2.1REV 7 2.3 Independent Spent Fuel Storage Installation (ISFSI)The ISFSI is designed for interim storage of fuel for a minimum of 50 years in acontained shielded system. The ISFSI utilizes the Universal MPC System (UMSTM)developed by NAC International. The UMSTM is a canister-based multi-purpose canister(MPG) system designed for both storage and transportation of spent nuclear fuel. Thecanister-based spent fuel storage system is a passive system which utilizes an outerconcrete cylinder called a Vertical Concrete Cask (VCC) to protect and shield the innersealed metal canister. The VCC is vented for natural convection cooling and has nomoving parts. Decay heat from the loaded fuel storage canister in the VCC is dissipatedto the surrounding air by a once through buoyancy driven airflow. The VCC providesradiation shielding, as well as protection from tornado missiles and earthquakes.The ISFST site consists of a Protected Area (PA) for fuel storage and aSecurity/Operations Building. The ISFSI has a Controlled Area that extends at least 300meters from the nuclear fuel storage area.The PA has sixteen concrete storage pads, and is surrounded by a security fence and anuisance fence with an isolation zone between the two fences. A partial earthen berm isprovided around the facility to reduce the visual impact of the facility. The ISFSI containsa total of 64 storage casks, with one sealed fuel canister per VCC. The types of canistersstored in the storage casks include 60 casks for spent fuel and 4 casks for Greater ThanClass C (GTCC) waste. Sixteen storage pads of equal size are provided for uniformity,which allows for storage of 4 casks per storage pad. The ISFSI site is arranged to providemaneuvering room around the storage pads for access with a cask heavy haul tractor-trailer.The Security/Operations Building provides offices and work space for the operating andmaintenance personnel, including the Radiation Controls Checkpoint lunch/conferencerooms, restrooms, locker rooms, document control room, spare parts storage, and a dieselgenerator for emergency power. The Security/Operations Building also houses the ISFSJsecurity staff, security equipment, and communications equipment. Access to the ISFSIprotected area is controlled and monitored by the security staff.The ISFSI operates under the provisions of a general license utilizing the UJMSTM spentfuel storage/transportation system. The UMSTM system is licensed under a Certificate ofCompliance issued by the U.S. Nuclear Regulatory Commission (NRC) in accordancewith 10 CFR Part 72, "Licensing Requirements for the Independent Storage of SpentNuclear Fuel and High-Level Radioactive Waste".2.2REV 7 FIGURE 2-1MAINE YANKEE SITEGENERAL AREAII fI;.so~cE- USGS OUAD~AM.- WEST--:',:' I. iSWJESS AE/90..1 "" eifSZALE'" Fa2.3oREV 7 FIGURE MAINE YANKEE SITE* 4,*BERMl2.4REV 7 3.0 ISFSI ACCIDENT TYPES. DETECTION AND CONSEQUENCES3.1 Radiological EventsThere are no postulated credible ISFSI accident conditions that would impose aradiological hazard to personnel beyond the ISFSI Controlled Area boundary. There areno credible design basis accidents that would exceed the EPA PAGs at the ISESIControlled Area boundary. In the event of an ISFSI accident condition, the associatedradiological hazards are limited to personnel onsite at the time of the event.The postulated ISFSI accident conditions are described in Chapter 11 of the SafetyAnalysis Report for the UMS Universal Storage System developed by NAC International(Reference 4).3.2 Non-Radiological EventsThe spectrum ofIJSFSI non-radiological events that could necessitate implementation ofthis Emergency Plan is limited. These events fall into the category of general industrialincidents (e.g. fire, explosion, toxic material release, etc.), natural and destructivephenomena (hurricane, tornado, etc.) or security events. These events are furtherdescribed in Chapter 11 of the Safety Analysis Report for the UMS Universal StorageSystem. The determination of which, events are included is based on the probability ofoccurrence, the potential severity and the potential impact on the facility of the event.3.2.1 Tip-Over of Vertical Concrete CaskA hypothetical non-credible accident condition has been postulated involving the non-mechanistic tip-over of a vertical concrete storage cask. Functionally, the cask is notexpected to suffer significant adverse consequences due to this event. The concrete caskand canister are expected to continue providing design basis shielding, geometry controlof contents, and contents confinement performance. The tipped-over configuration of theconcrete cask will be obvious during a Site inspection following the initiating event.There is an adverse localized radiological consequence due to the hypothetical tip-overevent since the bottom end of the concrete cask has significantly less shielding than thesides and top of these same components. The estimated dose rate from the-bottom of atipped-over cask is calculated to be approximately 34 rem/hr at 1 meter, 4 rem/hr at 4meters, and < 10Omrem/hr at 100 meters (NAC-SAR). Following a tip-over event,supplemental shielding should be used until the concrete cask can be up-righted. Surfaceand top and bottom edges of the concrete cask are expected to exhibit cracking andpossible loss of concrete down to the layer of reinforcing bar. The increased dose ratedue to this cracking is not expected to be significant. There are no credible eventsexpected to result in a cask tip-over.3.1REV 7 3.2.2 Tornado and Tornado Driven MissilesIt is not expected that the performance of the UMS storage cask will be significantlyaffected by a tornado event. It is not anticipated that postulated tornado wind loading andmissile impacts are capable of overturning a cask, or penetrating the cask concreteboundary and affecting the fuel storage canister. A tornado event can be visuallyobserved. Advanced warning of a tornado and of tornado sightings may be received fromthe National Weather Service, local radio and television stations, local law enforcementpersonnel, and site personnel. An inspection of the cask exterior surface following atornado event is required. The inspection should be directed at ensuring the inlets andoutlets have not become blocked by wind-blown debris and checking for obviousconcrete surface damage. Damage to the vertical concrete cask after a design basistornado is not anticipated to result in radiation exposure at the Controlled Area boundarythat would exceed the EPA PAGs exposure guidelines. The penetrating missile impact isestimated to reduce the concrete shielding thickness, locally at the point of impact, byapproximately 6 inches. Localized cask surface dose rates for the removal of 6 inches ofconcrete are estimated to be less than 250 rnrem/hr (NAC SAR Section 11.2.11).3.2.3 Explosions.An explosion affecting the Universal Storage System may be caused by industrialaccidents or the presence of explosive substances in the vicinity of the ISFSI. It is notanticipated that explosive substances will be stored or used at the JSFSJ. An explosion inthe vicinity of the ISFSI would be sensed by on-duty ISFSJ personnel. In the event of anearby explosion, an inspection of the concrete casks may be required to check caskintegrity, to ensure that the air inlets and outlets are free of debris, and to ensure that themonitoring system and screens are intact. There are no anticipated off-site radiologicalconsequences for this event.3.2.4 Seismic EventThe earthquake evaluation shows that the loaded or empty vertical concrete casks are notexpected to tip over or slide in the event of an earthquake. Significant earthquakes wouldbe detected by ground motion. Inspection of the vertical concrete casks is requiredfollowing an earthquake event. The proper positioning of the Concrete casks should beverified to ensure they maintain the established spacing requirements. The temperaturemonitoring system should be checked for operation. There are no anticipated off-siteradiological consequences for earthquake events.3.2REV 7 3.2.5 FiresThere are no flammable materials routinely present in the ISFSI cask storage area. A"combustible liquid control zone" shall be established for the ISFSI itself, which shall bea minimum of 10 feet from the outside perimeter of the VCC. The total liquidcombustibles allowed within the zone cannot exceed 50 gallons and must be in directsupport of ISFSI operations or maintenance. A fire in the vicinity of the ISFSI will bedetected by observation of the fire or smoke. Upon detection of a fire, appropriate actionsshould be taken by site personnel to report andlor extinguish the fire. The concrete caskshould be inspected for general deterioration of the concrete, loss of shielding (spalling ofconcrete), exposed reinforcing bar, and surface discoloration that could affect heatrejection. This inspection serves as the basis for the determination of any repair activitiesnecessary to return the concrete cask to its design basis configuration. There may be localspalling of concrete during the fire event, which could lead to some minor reduction inshielding effectiveness. The principal effect would be local increases in radiation doserates on the cask surface. There are no off-site radiological consequences anticipated forthis event.3.2.6 Abnormal Cask Outlet Temperature ShiftThis event involves an abnormal outlet temperature shift caused by a partial or fullblockage of the vertical concrete cask air inlets and outlets that could result in the heat upof the fuel cladding, the fuel basket and the concrete, with the temperature potentiallyreaching the design basis limiting temperature. Full blockage could result in thesetemperature limits potentially being exceeded after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Blockage of the cask airinlets and outlets will be detected by the Cask outlet temperature monitoring system. Anyobstruction blocking the air inlets and outlets must be manually removed. There are nosignificant radiological consequences for this event at the Controlled Area boundary, asthe vertical concrete cask is expected to retain its shielding performance (NAC SARL11.2.13).3.2.7 Other Conditions3.2.7.1 Off-Normal Canister Handling EventsThese events would involve off-normal occurrences during the handling or transfer of aloaded transportable storage canister (TSC), i.e., during the installation or removal of thecanister in or from the vertical concrete cask (VCC), or the transfer cask (TFR).Unintended loads could be applied to the canister due to misalignment or faulty craneoperation, or due to inattention of the operator. The event is expected to be obvious tothe operators at the time of occurrence. There is no anticipated deterioration of thecanister or fuel basket performance due to this event. There are no anticipated off-siteradiological consequences associated with this off-normal event.3.3REV 7 3.2.7.2 Drop of Vertical Concrete CaskThis event involves dropping a loaded vertical concrete cask during routine handlingoperations. This event may be due to the failure of one or more of the cask lifting jacksor of the air pad system. The maximum lift height shall be limited to less than 24 inchesby administrative controls. The event would be detected by the operators as it occurs.The damaged cask should be inspected and repaired prior to continued use. There are noanticipated off-site radiological consequences for this event.3.2.7.3 Flood EventThe UMS storage system vertical concrete casks have been evaluated for a design basisflood condition having a 50-foot depth of water and a water velocity of 15 feet persecond. This flood depth would frully submerge the vertical concrete casks. The analysisshows that the vertical concrete casks are not expected to slide or overturn during thedesign basis flood. Small floods may lead to blockage of the concrete cask air inlet vents.Partial and full blockage of air inlets is described in Section 3.2.6 of this plan. Floodingconditions would be detected by the ISFSI staff or personnel working in the vicinity ofthe ISFSI. A potential exists for collection of debris or accumulation of silt at the base ofothe cask, which could clog or obstruct the air inlet vents. Operation of the temperaturemonitoring system should be verified, as flood conditions may have impaired operation. There are no anticipated off-site radiological consequences associated with thedesign basis flood event.3.2.7.4 Lightning Strike EventSince the vertical concrete casks are located on an unsheltered pad, the casks may besubject to a lightning strike. A lightning strike on a concrete cask may be visuallydetected at the time of the strike, or by visible surface discoloration at the point of entryor exit of the current flow. There are no anticipated off-site radiological consequencesdue to the lightning event.3.3 Security EventEvents that impact the security of the ISFSI are discussed in the ISESI Security Plan.These events represent a threat to the level of safety of the ISFSI due to unauthorizedaccess, the introduction of threatening materials, or the use of hostile force in designatedsecurity areas. Security event detection and response is described in the Maine YankeeIndependent Spent Fuel Storage Installation Physical Security Plan. The Emergency Planmay be implemented if necessary in response to a security event.Events that fall into these areas will be categorized under the appropriate category in theclassification process discussed in Section 4, CLASSIFICATION OF ACCIDENTS.3.4REV 7 4.0 CLASSIFICATION OF ACCIDENTSBased on NUJREG-l1140,"Regulatory Analysis of Emergency Preparedness for Fuel Cycleand Other Radioactive Material Licensees", the NRC has determined that there are nocredible design basis accidents that would exceed the EPA PAGs at an ISFSI ControlledArea boundary. Emergency classification guidance in Appendix F of Nuclear EnergyInstitute document NEI 99-01 (Final Rev. 4), "Methodology for Development ofEmergency Action Levels," states, "The expectations of offsite response to an 'alert'classified under a 10 CFR 72.32 emergency plan are generally consistent with those for anotification of unusual event in a 10 CFR 50.47 emergency plan, i.e., to provideassistance if requested." The NEI 99-01 guidance is utilized in this plan to classify MaineYankee ISFSI emergency events. The NRC Regulatory Analysis for Rev. 4 of Reg Guide1.101 (Reference 5) to accept NET199-01 determined that the guidance in NE1 99-01 isappropriate for developing site specific EALs, to meet the intent of 10 CFR 50.47(b) (4 )and Appendix F to Part 50.Accidents and off-normal events that are analyzed for the ISFSI, including some eventsconsidered to be non-credible, have been reviewed and assigned a classification. Thereare no credible design basis accidents that would exceed the EPA PAGs at the ISFSIControlled Area boundary. Table 4-1 summarizes events that are classified as an UnusualEvent.This plan classifies events based on predetermined Emergency Action Levels (EALs).This approach provides a simple, predetermined response to an emergency event oraccident, allowing a coordinated and phased approach to the eventual mitigation of theconditions and restoring the facility to a safe status.4.1 Definitions4.1.1 Unusual Event (U-E)Events are in process or have occurred which indicate a potential degradation of the levelof safety of the facility. No release of radioactive material requiring offsite response ormonitoring is expected.4.2 Categories of EventsPer the Emergency Action Levels (EALs) guidance in NE1 99-01 (Reference 2), there aretwo categories of ISFSI events that can lead to an accident being classified as an UnusualEvent (UF). The ISS/ED has the discretion to classify events based on the classificationlevel definition. This discretion should be used when conditions or events are observedand no specific Initiating Condition (IC) / Emergency Action Level (EAL) is apparent.The UBE classification will heighten awareness of the abnormal condition. Table 4-1 liststhe initiating conditions, associated emergency action levels, and the applicable NRCemergency classification levels.4.1REV 7 4.2.1 Damage to a Loaded Vertical Concrete Cask That May Damage the Fuel or GTCCConfinement Boundary UEA UE classification for these IC/EALs is warranted on the basis of the occurrence of anevent of sufficient magnitude that a loaded VCC is severely damaged, which may beindicative of potential damage to a cask confinement boundary. This classificationincludes events involving loss of a loaded fuel storage cask confinement boundary,leading to degradation of the fuel during storage or posing an operational safety problemwith respect to removal of the degraded fuel confinement boundary from storage. Naturalphenomena events and accident conditions in which a loaded VCC is damaged areclassified at the UPE level. Cask seal integrity issues discovered during leakage testingassociated with normal canister processing would be addressed in accordance with NACtechnical specifications, or required actions, therefore, classification should not bemade based on loss of seal integrity by itself. However, loss or potential loss of sealintegrity coincident with an accident condition or natural phenomena that clearly affectsthe cask would justify a UPE classification. The 1SF SI vertical concrete storage casks areroutinely monitored by site personnel such that any degradation would be detected.Increases in radiation levels may be indicative of degradation of a storage cask.4.2.2 Confirmed Security Event with Potential Loss of Level of Safety of the ISFSI LYEThese IC/EALs provide a UE cl!assification for security events involving a potential lossof the level of safety of the ISFSI based on the Maine Yankee Independent Spent FuelStorage Installation Physical Security Plan.4.2REV 7 TABLE 4-1 EMERGENCY ACTION LEVELSInitiating Conditions Emergency Action Levels NRC EmergencyClassification LevelHU1 -DAMAGE TO A 1. Natural Phenomena UNUSUAL EVENTLOADED VERTICAL events affecting a loadedCONCRETE CASK (VCC) GTCC or spent fuel caskTHAT MAY DAMAGE confinement boundary.THlE FUEL OR GTCC 2. Accident conditionsCONFINEMENT affecting a loaded GTCCBOUNDARY or spent fuel caskconfinement boundary._________________3. ISS/ED judgment.HiU2 -CONFIRMED 1. Ongoing security UNUSUAL EVENTSECURITY EVENT WITH compromise or attemptedPOTENTIAL LOSS OF entry which may result inLEVEL OF SAFETY OF the potential loss ofTHE ISFSI control of the facility.4.3REV 7 5.0 EMERGENCY RESPONSEEmergency Response OverviewIn the event of an accident at the facility, actions will be taken by facility staff to reportthe event to the ISFSI Shift Supervisor (ISS) and to minimize the impact of the event. Theprimary objective of the initial responders is to assess the situation and minimize the riskimposed on workers and the general public. This involves initiation of required actions tomitigate a particular hazard. Subsequent actions include notifications, staffaccountability, staff augmentation, and implementation of onsite corrective actions asnecessary. The ISFSI Shift Supervisor becomes the Emergency Director (IS S/ED) uponclassification and declaration of an unusual event.5.1 Notification and ActivationWhen an emergency condition is recognized, the event is classified and declared by theISS/ED and mitigating actions are taken to minimize the progression of the event. Theseactions are initiated by available resources. The IS S/ED will request any offsite assistancethat may be necessary due to the nature of the event. Following initial notifications, theMaine State Police (MSP) and the Nuclear Regulatory Commission (NRC) will benotified of the event and mitigating actions in progress or that have been completed.Figure 5-1 depicts the initial .notification and activation process.5.1.1 Maine Yankee Emergency Support StaffThe ISS/ED or designee will direct ISFSI shift personnel to notify the ISFSI Support Staffof an event, if necessary. This will be accomplished by the commercial telephone system(i.e., land based, cell based, satellite based service). In the event the initiating conditionsconstitute a Security Event, these notifications will be made by the IS S/ED or designee. [Notifications to supplement support positions should be completed within one hour of theevent declaration.5.1.2 Offsite OrganizationsFollowing notification of the Maine Yankee ISFSI Support Staff, the Maine State Police(MSP) will be contacted and provided pertinent information regarding the event, actionstaken to mitigate the event and notification of any assistance which may be necessaryfrom local organizations (i.e. fire, ambulance, police response). Notification to the MSPshall be comPleted within one hour of event declaration. Depending on the need forimmediate outside assistance, these notifications may be initiated in an acceleratedmanner (i.e. immediate need for fire fighting capabilities or medical assistance). TheMSP Headquarters Communications Center is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week. TheMSP have the capability to contact State and county emergency response personnel, ifneeded.The MSP will initiate notification to appropriate State Officials in the Maine EmergencyManagement Agency (MEMA), Division of Environmental Health (D)EH) and others asdesignated in the State's notification protocol, based on the event.The NRC will be notified after the notification of the MSP and no later than one hourafter the emergency was declared.5.1REV 7 5.1.3 Information to be CommunicatedA pre-scripted format is used to ensure consistent information is provided to the MSP andthe NRC.At a minimum, the following information will be provided during the initial notificationof the event:Event Classification;Date/Time of Classification;Reason or events causing the condition;General description of damage to major structures/areas;Personal injuries;Status of offsite assistance (fire/medical/other);Name of person making notification;Date and Time of notification.The information will be verified, via repeat-back, to ensure it was accuratelycommunicated.5.2 Radiological AssessmentInitial response to an event will be to ascertain the cause, mitigate furter progression anddetermine the potential impact to ISFSI personnel and the general public. Initialassessment will normally consist of an area dose assessment if warranted. Initial doseassessment activities will be directed by the ISS/ED and performed by qualifiedpersonnel.As soon as practical, facility staff should initiate general area radiation surveys todetermine the actual extent of any radiological concern. Results of the surveys will' beanalyzed by facility staff to formulate an action plan to mitigate the event and restore thefacility to a safe condition. Survey data will also be used, as appropriate, in any on-sitedose assessment techniques.Following the termination of the event, environmental surveys (including, but not limitedto water, soil, vegetation, etc.) may be required to determine the long-term impact of theevent.5.3 Protective Actions5.3.1 Relocation and AccountabilityIn an UNUSUAL EVENT declaration, personnel not directly involved with the responsemay be directed to relocate to an assembly area. Staff will be notified using the on-sitepaging system or other means. An assembly area may be established, based on the natureof the event, at a location determined by the ISS/ED. The ISFSI shift staff will maintainaccountability of personnel and report any missing persons to the ISS/ED. Search andrescue efforts may be performed by shift personnel or local response personnel asnecessary.5.2REV 7 5.3.2 First Aid/Medical ResponseOff-site emergency medical responders will be requested to report to the scene andinitiate first aid treatment to stabilize the patient and prepare for transport to a medicalfacility. One or more First Aid kits are located in the facility. Injuries may becomplicated by the presence of radiation and/or a contaminating substance (chemical orradiological). Given the design of the fuel/GTCC storage canisters, radiologicalcontamination is unlikely, but should be evaluated. The patient will be assessed to*determine if a life-threatening condition exists and appropriate actions taken to eithercontain or remove the contamination. In addition, environmental factors will be takeninto account regarding the need to stabilize the patient in place or remove to a safer area(i.e. lower radiation levels, etc.). Maine Yankee maintains a Letter of Agreement with theWiscasset Ambulance Service for transporting injured/contaminated workers from thesite to a receiving hospital. In addition, agreements have been made with the MidcoastHospital (Brunswick) for treating personnel with various types of injuries/conditions.5.3.3 Personnel MonitoringPersonnel working in known radiation areas will be issued dosimetry in accordance withexisting radiation protection procedures. During emergency conditions, they normallyretain their dosimetry and report to either their assigned emergency station or theassembly area, if a person suspects they may be contaminated, they will be monitored byRadiation Protection personnel.Emergency support staff will be issued dosirnetry as required for assigned tasks.Exposure control will be maintained in accordance with the site Radiation Protection andALARA programs. Dose extensions may be granted in excess of the limits of 10OCFR20for special circumstances. These extensions will be in accordance with EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents.Extensions above the I0CFR_20 limits must be approved by the IS S/ED. The anticipatedemergency exposures are well within the limits specified in Table 5-1.5.3REV 7 TABLE 5-1 GUIDANCE ON DOSE LIMITS FOR EMERGENCY WORKERS (a)Type of Activity TEDE (b) ConditionAll 5 Remn Maintain ALARA and to the extent practicable___________________________limit emergency workers to these limitsProtecting Valuable Property 10 Remn Lower dose not practicable.Life Saving or Protection of Large 25 Rem Lower dose not practicable.Populations>25 Rem Only on a voluntary basis to persons fully aware ofthe risks involved, including the numerical levelsof dose at which acute effects of radiation will beincurred and numerical estimates of delayedeffects.(a) From EPA-400-R-92-00l, Manual of Protective Action Guides and Protective Actions forNuclear Incidents(b) Sum of the deep dose equivalent from the external sources and the comimitted dose.equivalent from the internal exposures to non-pregnant adults from exposure and intakeduring an emergency situation. Dose limits to the eye should be 3 times the listed value.Dose limits to any other organ (including skin and body extremities) should be 10 times thelisted value.5.3.4 Decontamination CapabilitiesSurvey instrumentation for personnel frisking is available. Personnel contaminationidentified during the initial survey will require the contaminated individual to removeprotective apparel, re-survey, and if skin contamination levels are identified, performdecontamination as directed by radiation protection personnel.In the event that accident conditions result in a contaminated injured individual, thevictim's rescue and medical treatment take precedence over the Victim's radiationexposure due to bodily contamination. Gross decontamination of the victim (generallylimited to the removal of contaminated articles of clothing) will be accomplished to theextent that the health of the patient is not affected. Decontamination measures associatedwith wounds will be performed under the joint supervision of the attending physician atthe hospital and the responding radiation protection representative.5.3.5 Contamination and Hazard Exposure ControlSurveys will be conducted to determine which areas contain contamination of either aradiological nature or a hazardous substance. These areas will be identified by eithermarking with boundary rope or tape and access will be limited and controlled accordinglyby the radiation protection personnel. Monitoring of the area will be conducted usingappropriate equipment, based on the type of contamination. All personnel required towork in the area will be provided appropriate personnel protective equipment (coveralls,booties, gloves, etc.) by the Radiation Protection contractor. The level of protection willbe determined by the IS S/ED or other designated personnel.5.4REV"7 5.3.6 Emergency ActionThis plan permits emergency response personnel to take reasonable action that departsfrom a license condition or a technical specification in an emergency when this action isilmmediately needed to protect the public health and safety and no action consistent withlicense conditions and technical specifications can provide adequate or equivalentprotection is immediately apparent.5.4 Coordination with Offsite AgenciesThere is no response required from State agencies. State government response isexpected to be limited to recording the notification of the emergency, periodicallyreceiving updated information on the emergency, and coordinating public informationnews releases. Upon request, Local government agencies (i.e. fire, police, ambulance)will respond to the ISFSJ during an emergency, if necessary.If needed, provisions exist for limiting traffic on roads leading to the Maine Yankee site.These actions would be coordinated through the Maine State Police or the LincolnCounty Sheriffs Office, Wiscasset, Maine.5.5REV 7 FIGURE 5-1MAINE YANKEE INITIAL NOTIFICATION AND ACTIVATION PROCESS' IS S/EDISFS.I SHIFT NRC MAINE STATESPECIALIST POLICE (MSP)MAINE YANKEE .MAINE EMERGENCISFSI SUPPORT MANAGEMENTSTAFF AGENCY (EOC)(If needed)5.6.;YREV 7 6.0 FACILITIES AND EQUIPMENT6.1 Control CenterThe Control Center in the Security/Operations Building is the primary facility whereISFSI conditions are monitored and corrective actions are developed to mitigate anyabnormal occurrence. Emergency conditions classified as UEs are managed by theISS/ED from the Control Center or other appropriate location.The Control Center provides space for the designated members of the ISFSI Emergencysupport staff to conduct analysis and support functions in response to the event. TheControl Center may be activated for other reasons at the discretion of the ISSiED. Thefollowing functions are coordinated from the Control Center: emergency management,offsite notifications and communication, and facility restoration planning.The Control Center is sized to accommodate personnel performing communications,radiological assessment, general engineering and analysis tasks. Communication systemsare available to allow interaction with offsite organizations, as necessary. Variousequipment has been assembled and stored in or near the Control Center for use by supportstaff, including personal protective equipment, and radiation monitoring equipment. TheControl Center has nearby office space to accommodate any required offsite personnel.6.2 Radiation Controls CheckpointThe Radiation Controls (RC) Checkpoint is located in the Security/Operations Building.Personnel dosimetry is issued at this point and a radiological emergency kit is available.6.3 Assembly .AreaPersonnel directed to evacuate the PA will be directed to report to an assembly areadesignated by the ISS/ED.6.4 EquipmentAppropriate equipment is maintained for emergency response activities in the ISFSISecurity/Operations Building. Required supplies are inventoried to ensure operabilityand availability at all times.Controlled copies of facility documents (drawings, procedures, Technical Specifications,SARs, etc.) are maintained in, or in the areas adjacent to the Control Center. Thisinformation is readily available for support staff use.6.1REV 7 6.5 Communications6.5.1 Onsite Communication Systems6.5.1.1 Commercial Telephone SystemThe commercial telephone system is the primary means of onsite communicationduring an emergency. This system has an independent backup power configuration,which incorporates a combination of batteries and an emergency diesel generator toensure uninterrupted operation on a loss of normal power to the ISFSI telephonesystem.6.5.1.2 Paging SystemA general voice paging system is available with speakers on the interior and exteriorof the Security/Operations Building.6.5.1.3 Radio SystemISFSI staff will be equipped with portable radios for onsite communications. One ormore licensed frequencies will be used for routine communications, and one or morestate police frequencies will be used for offsite routine and emergencycommunications.6.5.2 Offsite Communications Systems6.5.2.1 Telephone to the Maine State PoliceCommercial telephones are used to establish communications between the MaineYankee JSFSI Control Center and the Maine State Police (MSP). This is the primarymethod of informing State of Maine personnel of a declared emergency at the MaineYankee ISFSL. Both organizations have telephones in a location that is staffed 24hours a day, '7 days a week.6.5.2.2 Maine State Police RadioIn the event the commercial telephone circuits fail, the MSP can be contacted viaradio from the Control Center and from the ISFSI Security Offices using either of twoState Police frequencies installed on these radios (State Police -Zone 2 and state-widecar-to-car (SWCC). SWCC frequency can also be used to communicate with theLincoln County Sheriffs Office. The ISFSI radio system is powered from the normalpower company service grid. Back up power is provided by a UPS system.6.5.2.3 NRC Emergency NotificationIn the event of an emergency at the Maine Yankee ISFSI, the NRC will be notifiedwithin one hour using the ENS telephone system in accordance with 10 CFR 50.72(a).This line is not anticipated to be established continuously, but used primarily toprovide periodic informational updates to the NRC.6.6 Fire SuppressionFire extinguishers located at the ISFSI are used to help extinguish or contain a fire tothe area of origin and minimize involvement of adjacent areas until the Wiscasset FireDepartment responds to the scene. A fire hydrant is located near the ISFSI for use bythe Wiscasset Fire Department.6.2REV 7 7.0 RESPONSIBILITIESThe Emergency Organization is comprised of on-shift ISFSI personnel. Detection andrecognition of conditions that warrant declaration of an emergency, in accordance withthe EALs, is the responsibility of the ISFSI Shift Supervisor (ISS). Upon declaration of anemergency, the on-shift organization assumes their emergency response duties andimplements this plan. The minimum on-shift staff required for initial emergencyresponse consists of the ISS/ED (Fig. 7-1).The IS S/ED may call in support staff in numbers and disciplines necessary to support theresponse and recovery actions required for the event. Radiation Protection support isavailable on a call-in basis if not present on-site at the onset of an emergency.7.1 On-shift Organization7.1.1 LSFSI Shift Supervisor /Emergency DirectorThe ISS is the qualified emergency representative on-shift. The 1SS assumes the positionof ISS/ED. The IS S/ED executes any actions deemed necessary to mitigate theconsequences of the emergency condition and restore the facility to a safe and stableconfiguration.The primary responsibilities of the IS S/ED include:* Classification and emergency declaration of the incident* Notification and request for assistance from local response agency, including medicalassistance as necessary* Notification and interface with offsite agencies* Notification of ISFSI support staff,* Direction and control of available personnel* Initiation of immediate corrective actions, if any* Direction, control, communications and public information* Authorization of onsite protective actions* Establish priorities for the Control Center staff* Provide periodic updates to the NRC* Determine the need for offsite/contractor assistance* Mitigation and recoveryThe ISS/ED is responsible for maintaining the integrity of the ISFSI and all operationalactivities in the facility. The ISS/ED may be relieved by another qualified ED) ifconditions warrant.7.1.2 Shift SpecialistThe ISFSI Shift Specialist is responsible for maintaining facility security in accordancewith the ISFSI Security Plan.The primary responsibilities of the Shift Specialist during an emergency is:* Maintaining site security and access control from the Central Alarm Station (CAS)* Personnel Accountability in the ISFSI Protected Area (PA)* Notification of the support staff as requested by the iS S/ED* Notification of offsite Agencies as requested by the IS S/ED* Search and Rescue coordination, as necessaryoFire response coordination, as necessary.7.1REV 7 7.2 Augmented OrganizationThe need for an augmented response by support staff is determined by the ISS/ED on acase by case basis for the Unusual Event (UE) classification. If needed, the augmentedsupport staff is expected to be in place to support emergency response activities withinapproximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Augmented response personnel may be provided by a contractedservice.7.2.1 Support StaffAvailable facility staff and/or emergency services contractors will be called in asnecessary to assist in the response, including:* Perform spent fuel storage condition assessments, if necessary* Assess the extent of damaged equipment* Identify short and long-term repair needs* Establish initial repair priorities and deploy repair teams* Coordinate available resources to restore equipment and systems based on thedirection of the ISS/ED* Handle logistical needs* Perform radiological and environmental surveys as necessary.* Developing public information materials for release to the news media as necessary,and maintaining liaison with news media and State of Maine information staff.7.2REV 7 FIGURE 7-1MAINE YANKEE ISFSIMINIMUM ON-SHIFT EMERGENCY ORGANIZATIONISFSI SHIFT SUPERVISOR!/EMERGENCY DIRECTOR (ISS/ED)SHIFT SPECIALIST7.3REV 7 8.0 MAINTAINING EMERGENCY PREPAREDNESSThe ISFSI Manager or designee is responsible for ensuring the availability ofadequate emergency support staff and for approval of the ISFSI Emergency Planand Implementing Procedures (IEPIPs).The JSFSI Manager is also responsible for ensuring the following tasks andfunctions are completed:* The maintenance of readiness of the on-site emergency response facilities andequipment;* Development and maintenance of the ISFSI Emergency Plan;o Development and maintenance of the associated implementing procedures;* Preparation of scenarios for training drills and exercises;* Conduct of drills and exercises;* Provision of input to emergency preparedness training of the support staff;* Returning emergency equipment and supplies used during a drill, exercise oractual emergency to a state of readiness following the termination of the drill,exercise or emergency;* Providing support for the annual radiation monitoring drill and medicalemergency drill.*Reviewing ISFSJ EALS with state and local government authorities on anannual basis in accordance with 10 CFR 50 Appendix E (TV)(B).8.1 TrainingThe Maine Yankee ISFSIi Emergency Plan Training Program consists of lessonplans designed to provide the skills and knowledge necessary to maintain staffproficiency. Each IEPIP will be reviewed to identify activities that are notconsidered to be a part of the assigned individuals day-to-day routine function (i.e.use of telephones, general communication protocol, etc.). Lessons will focus onnon-routine and specialized activities that are particular to the assigned functionand overall emergency response actions. Training may consist of, but not belimited to, classroom lecture, self-study, practical demonstrations (wherenecessary, as specified in the lesson plan), and facility drills.8.1.1 Emergency Staff TrainingEach individual selected for assignment to the on site staff or the support staff willbe provided training designed to familiarize the person with their duties,responsibilities and expected actions in the event of a condition that requires thesupport staff to be mobilized. This initial training will be completed prior to theindividual assuming the emergency response duty.Each on shift and support staff member will be provided continuing training fortheir assigned duties. This training will be conducted annually. Continuingtraining addresses general changes to the ISFSJ Emergency Plan, facilities,equipment, regulations, policies and specific changes to their responsibilities(which are not considered part of their routine duties). It also addresses problemareas identified during audits, drills or exercises.8.1REV 7 8.1.2 ISFSI Access TrainingThe ISFSI Access Training program provides employees and contractors routinely onsitethe basic elements of the ISFSI Emergency Plan and expected actions during anemergency. Information is reviewed annually as part of site access training.8.1.3 Offsite Assistance TrainingOrganizations which may be called upon to render assistance onsite will be offeredgeneral facility familiarization sessions on an annual basis. These sessions may include awalk down of the general facility, safety, building layout, access protocol,communications capabilities and security requirements. Radiological orientation trainingwill also be offered annually.8.2 Review and Updating of the ISFSI Emergency Plan and Implementing Procedures8.2.1 ISFSI Emergency Plan (JEP) ReviewThis plan, including all written agreements between Maine Yankee and other parties, willbe reviewed annually. Approved changes to the plan will be incorporated into theappropriate implementing procedures along with the plan changes. Letters of Agreementwill be reviewed annually and verified to be in effect at the time of the plan review. Thismay be accomplished via written correspondence or documented telephone conversation.This plan is a controlled document to ensure changes are incorporated into distributedcopies. Plan changes will be subject to management review and approval. Plan changeswill be issued as an entire revision with changes identified on the affected pages.8.2.2 Emergency Plan Implementing Procedure ReviewISFSI Emergency Plan Implementing Procedures (JEPIiPs) will be reviewed and revised inaccordance with plant procedure control guidelines, and as necessary. Periodic revisionswill be incorporated whenever a plan change is made that affects the procedure or othercircumstances dictate a revision is necessary. IEPIPs will be subject to managementreview and approval.8.2.3 Periodic Surveillance ProgramFacilities and equipment will be maintained in accordance with surveillance procedures.Inventories of emergency plan equipment will be conducted on a semi-annual basis andafter facility activation (actual event or drill activity). A walkdown of the Control Centerwill be conducted on a quarterly basis to ensure facility readiness is maintained.Telephone numbers that are important to emergency notification and are contained in theJEPI~s will be verified on a quarterly basis.8.2.4 Communications Systems ChecksTelephones, radios and paging systems used for on-site and off-site emergencycommunications will be tested quarterly per communications surveillance procedures.8.2REV 7 8.3 Drills and ExercisesIn addition to the emergency plan training described earlier, the facility staff will conductperiodic drills to enhance skills and knowledge of the practical implementation of theIEP. Periodic drills will be scheduled with various objectives to demonstrate theseCapabilities. Some drills will focus on singular functions (such as communicationscapabilities) while others will involve the activation of the support staff. Theseevolutions serve as an extension of the training program, allowing interaction betweenevaluators and responders to reinforce procedural requirements and overall processimplementation.8.3.1 DrillsIn addition to training drills discussed above, the following drills will be conductedannually;-Support Staff Drill -involving a combination of some of the principal functionalareas of emergency response capabilities. The biennial exercise satisfies the annualsupport staff drill requirements.-Radiological Monitoring Drill.- demonstrating conducting general area surveys.-Medical Emergency Drill -demonstrating the capability to transport an injured workeroffsite.-Fire Drill -conducted in accordance with the Fire Protection Program.8.3.2 ExercisesAn exercise will be conducted once every two years to demonstrate the capability toimplement the ISFSI Emergency Plan. Objectives will be developed to ensure majorelements of the emergency plan are demonstrated and evaluated to ensure the appropriatelevel of preparedness is being maintained.Offsite response organizations will be invited to participate in biennial exercises.8.3.3 Driln and Exercise EvaluationFacility staff will evaluate the exercise and drills. Expectations for evaluators will bediscussed with each evaluator prior to the drill. Whenever possible, evaluators shouldhave present or recent ISFSI emergency responsibilities and be assigned to evaluatefunctions/areas consistent with their emergency assignment. Following the drill/exercisea critique of the evolution will be conducted. Comments will be evaluated anddispositioned by Maine Yankee and deficiencies will be corrected through retraining,remedial drills, or by other means. Comment resolution will be assigned to appropriatepersonnel for final implementation.8.3REV 7 8.4 Independent Program ReviewAn independent program review of the ISFSI emergency preparedness program will beconducted once every 12 months in accordance with 10 CFR 50.54(t) or as necessary,based on the assessment against performance indicators, and as soon as reasonablypractical after a change occurs with personnel, procedures, equipment or facilities thatpotentially could adversely affect emergency preparedness, but no longer than 12 monthsafter the change. Items to be reviewed should include, but not be limited to, adequacy ofinterfaces with State and local government agencies, implementing procedures, drills,exercises and capabilities.8.4REV 7 9.0 RECOVERYThe primary objective of the facility staff is to mitigate the consequences of an emergencyand restore the facility to a safe condition. Restoration of the facility effectively beginswith the first action taken in response to the event and terminates when the facilityresumes normal operations.When conditionshave. stabilized and a full assessment of the event has been conducted,the facility staff will focus on establishing a plan to verify' operability of allsystems/components necessary to maintain and monitor the integrity of the spent fuel.The ISESI Manager or designee will coordinate the restoration of the facility and has theauthority to take the necessary actions to ensure the facility is returned to a safe condition.Recovery responsibilities, of the JSFSI Manager include, but are not limited to:Development of the site recovery plan.* Maintain comprehensive hazard assessment of the facility.* Prioritize clean-up of affected areas/equipment.* Isolate and repair damaged equipment/systems.* Document all actions taken related to the recovery operations.9.1REV 7 10.0 OFFSITE ASSISTANCEResponse from organizations that are not associated with Maine Yankee are not expectedto be necessary, except for fire, medical emergencies or hazardous materials incidents.Letters of Agreement exist with organizations that may be called upon, on an as-neededbasis, to provide assistance.The Wiscasset Fire Department and Wiscasset Ambulance Service have standingagreements to assist Maine Yankee in the event of a fire, hazardous materials incident ormedical emergency.Maine Yankee maintains a Letter of Agreement with the MidCoast Hospital in Brunswickfor treatment of radiologically contaminated and injured workers.Response from the State of Maine will be limited to acknowledging notification of theevent. No mitigating actions are anticipated to be necessary in response to an event at.Maine Yankee. Precautionary actions are anticipated to be similar to those taken inresponses to preparations for severe weather, etc.Other agreements exist for specialized services that can be called upon as needed.10.1Rev 7

11.0 REFERENCES

1. Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-400-R-92-001, May 1992.2. NEI 99-0 1 Final Rev. 4 "Methodology for Development of Emergency Action Levels,"January 2003.3. NIJREG-1 140, "Regulatory Analysis on Emergency Preparedness for Fuel Cycle and OtherRadioactive Material Licensees."4. NAC Safety Analysis Report, UMS Universal Storage System, Docket 72-10 15, October1999.5. NRC Regulatory Guide 1.10 1, Rev. 4, "Emergency Planning for Nuclear Power Plants.", July2003.6. NRC Regulatory Issue Summary 20 15-14, "Issuance of Enforcement Guidance Memorandum-Emergency Plan and Emergency Plan Implementing Procedure Updates", October 30, 2015.11.1Rev 7 APPENDIX I -ASSISTANCE AGREEMENTSORGANIZATIONMid-Coast HospitalWiscasset Fire DepartmentWiscasset Ambulance ServiceI-1IREV 7 APPENDIX II -SUPPORTING PLANS AN]) DOCUMENTSDefueled Safety Analysis Report (DSAR)FP-.1, Fire Protection ProgramMaine Yankee Independent Spent Fuel Storage Installation Physical Security Plan andSupporting Security ProceduresIi-1REV 7 APPENDIX Ill -EMERGENCY PLAN IMPLEMENTING PROCEDURES1. Emergency Plan Implementing Proceduresa. EQ -1, Emergency Planning Administrationb. EQ -2, Response to Accident and Natural Phenomena Eventsc. EQ -5, Emergency Plan Implementation'IlI-REV 7 MAINE YANKEE321 Old Ferry Road, Wiscasset, Maine 04578December 15, 2015OMY- 15-055Re: 10 CFR 50.54(q)(5)10 CFR 72.44(f)10 CFR 50.4(b)(5)10 CFR 72.4ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-000 1Maine Yankee Atomic Power CompanyMaine Yankee Independent Spent Fuel Storage InstallationNRC License No. DPR-36 (NRC Docket No. 50-309)

Subject:

Revision 7 to Maine Yankee ISFSI Emergency PlanIn accordance with 10 CFR 50.54(q)(5), 10 CFR 72.44(f), 10 CFR 50.4(b)(5), and 10 CFR 72.4,Maine Yankee Atomic Power Company (Maine Yankee) is providing Revision 7 of the MaineYankee Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan, and a summary ofthe analysis that determined that the changes do not constitute a reduction in commitment, nor adecrease in effectiveness of the Maine Yankee ISFSI Emergency Plan.Attachment 1 provides a summary of the evaluation that provides the basis for concluding theMaine Yankee ISFSI Emergency Plan, as changed, continues to meet the standards of 10 CFR50.47(b) and the requirements of Appendix B to Part 50 as modified by the existing exemptionsfor the Maine Yankee ISFSI.Enclosure 1 provides a copy of Revision 7 of the Maine Yankee ISFSI Emergency Plan. It waseffective on December 15, 2015.This letter contains no commitments.If you have any questions regarding this submittal, please do not hesitate to contact me at(207) 882-1303.Respectfully,~Stanley PBEISFSI Manager Maine Yankee Atomic Power CompanyOMY- 15-055/December 15, 201 5/Page 2Attachments and EnclosuresAttachment 1 -Summary of 10 CFR 50.54(q) Evaluation for Changes to the Maine Yankee ISESIEmergency PlanEnclosure 1 -Maine Yankee ISFSI Emergency Plan, Revision 7cc: D. Dorman, NRC Region I AdministratorM. S. Ferdas, Chief, Decommissioning Branch, NRC, Region IM. Lombard, Director, Division of Spent Fuel Management, NM4SSJ. Goshen, NRC Project ManagerP. J. Dostie, SNSI, State of MaineJ. Hyland, State of Maine to OMY-15-055Summary of 10 CFR 50.54(q) Evaluation for Changes to theMaine Yankee ISFSJ Emergency PlanSection /Table Description of Proposed Change Justification of Proposed ChangeThrough-out Changed title Emergency This is a change to standardize to thethe Emergency Coordinator to Emergency same title at all three Yankee sites.Plan Director or EC to ED.Through-out The Emergency Plan has been These changes are editorial and clericalthe Emergency reformatted and renumbered as in nature and have no impact on thePlan. needed to support this change. intent of the Emergency Plan.Table 4-1 Deleted a reviewer's note that was This is an administrative change.incorporated into revision 6inappropriately.Section 5.3.3 This section has been revised to This is a change to permit the Radiationclarify that if personnel become Protection personnel to determine wherecontaminated they will be the monitoring and decontaminationmonitored by Radiation Protection will be performed.Personnel. It also eliminates therequirement to perform this_____________activity at a specific point.Section This section has been revised to This is a clarification of duties andadd that Protective Clothing (PCs) responsibilities making the Radiationwill be provided by the Radiation Protection contractor responsible toProtection contractor, supply PCs.Section 8.1.2 Changed title from General This is a clarification to identify theEmployee Training (GET) to current title of the site training program.ISFSJ Access Training.Chapter 11, Added reference to NRC RIS This is an administrative, change thatReferences 2015-14 "Issuance of Enforcement adds a new guidance document.Guidance Memorandum -Emergency Plan and EmergencyPlan Implementing ProcedureUpdates", issued 10/30/15.Appendix II Updated FP-1 title and updated This is a clarification and administrativePhysical Security Plan full title. change.Page 1 of 2 to OMY-15-055Summary of 10 CFR 50.54(q) Evaluation for Changes to theMaine Yankee ISFSI Emergency PlanSection /Table Description of Proposed ChangeJustification of Proposed ChangeAppendix III,EmergencyPlanImplementingProceduresDeleted EO-6, Non-EmergencyEvent Assessment as anEmergency Plan ImplementingProcedure.Deleted EO-3 and EO-4 asEmergency Plan ImplementingProcedures because their contentwas relocated into EO-2.EO-2 was renamed. The originalcontent of EO-2 was moved toOP-1, because it was not requiredto implement the Emergency Plan.EO-6 never implemented theEmergency Plan. A self-assessmentestablished that the actions in EO-6 didnot meet the intent or definition of animplementing procedure.The self-assessment identified thefollowing procedures as EmergencyPlan Implementing Procedures inaccordance with Appendix E to Part 50:EO-l -Emergency PlanImplementationEO-2 -Response to Accident andNatural Phenomena EventsEO-5 -Emergency Plan AdministrationThese procedures contai-n-the followingas required by Appendix E of Part 50:* Organization (Emergency)* Assessment Actions* Activation of the EmergencyOrganization* Notification Procedures* Emergency Facilities andEquipment* Training* Maintaining EmergencyPreparedness* RecoveryThe current EO-2 off normal actionshave been incorporated into OP-ibecause it did not implement theEmergency Plan. EO-2 has been revisedto incorporate EO-3 and EO-4 into thenew EO-2, titled "Response to Accidentand Natural Phenomena Events". EO-3and EO-4 have been cancelled.Page 2 of 2 ENCLOSURE 1 TO OMY-.15-055MAINE YANKEE ISFSI EMERGENCY PLAN, REVISION 7 MAINE YANKEEIN DEPENDENT SPENT FUELSTORAGE INSTALLATION(ISFSI)EMERGENCY PLANREVISION 7Effective Date: December 15, 2015 TABLE OF CONTENTSSection PageTABLE OF CONTENTS iiAPPENDICES iLIST OF TABLES vLIST OF FIGURES viDEFINITIONS vii

1.0 INTRODUCTION

1:12.0 FACILITY DESCRIPTION2.1 Maine Yankee Site 2.12.2 General Area 2.12.3 Independent Spent Fuel Storage Installation 2.23.0 ISFSI ACCIIDENT TYPES, DETECTION AND CONSEQUENCES3.1 Radiological Events 3.13.2 Non-radiological Events 3.14.0 CLASSIFICATION OF ACCIDENTS4.1 Definitions 4.14.2 Categories of Events 4.15.0 EMERGENCY RESPONSE5.1 Notification and Activation 5.15.1.1 Maine Yankee Emergency Support Staff 5.15.1.2 Offsite Organizations 5.15.1.3 Information to be Communicated 5.25.2 Radiological Assessment 5.25.3 Protective Actions 5.25.4 Coordination with Offsite Agencies 5.56.0 FACILITIES AND EQUIPMENT6.1 Control Center 6.16.2 Radiation Controls Checkpoint 6.16.3 Assembly Areas 6.16.4 Equipment 6.16.5 Communications 6.26.6 Fire Suppression 6.2REV 7 TABLE OF CONTENTS(Continued)Section Page7.0 RESPONSIBILITIES7.1 On-shift Organization 7.17.2 Augmented Organization 7.28.0 MAJINTAINING EMIERGENCY PREPAREDNESS8.1 Training 8.18.2 Review and Updating of the ISFSI Emergency PlanAnd Implementing Procedures 8.28.3 Drills and Exercises 8.38.4 Independent Program Review 8.39.0 RECOVERY 9.1*10.0 OFIFSITE ASSISTANCE 10.1

11.0 REFERENCES

11.1i11REV 7 APPENDICESAPPENDIX I -Assistance Agreements I-1APPENDIX II -Supporting Plans and Documents 11-1APPENDIX Ill -Emergency Plan Implementing Procedures III-i1ivREV 7 LIST OF TABLESNumber Title4-1 Emergency Action Levels5-1 Guidance on Dose Limits for Emergency Workers(EPA-400-R-92-00 1)Page4.35.4REV"7 LIST OF FIGURESNumber Titl.__e Tawe2-1 Maine Yankee Site -General Area 2.32-2 Maine Yankee Site -Facility Layout 2.45-1 Maine Yankee Initial Notification and Activation Process 5.67-1 Maine Yankee On-Shift Organization 7.3REV 7 DEFINITIONSASSEMBLY AREAS -Designated locations where personnel may be directed to congregate mnthe event of the need to evacuate all or portions of the facility.ASSESSMENT ACTIONS -Actions taken during or after an emergency event or accident toobtain and process information necessary to implement specific emergency measures.CONFINEMENT BOUNDARY -The confinement boundary of the canister consists of thecanister shell, bottom plate, shield lid, structural lid, the two port covers, and the welds that jointhese components.CONTROL CENTER (CC) -During an emergency the lunch/conference room or otherdesignated area in the security/operations building functions as the emergency Control Center(CC) operating under the direction of the Emergency Coordinator. It is the primary point atwhich 1SF SI conditions are tracked and corrective actions are taken to mitigate any abnormalconditions.CONTROLLED AREA -The designated area outside of the Protected Area (PA), extending atleast 300 meters from the spent fuel storage pads, over which control is exercised duringemergency events pursuant to 10 CFR 72.106(b).CORRECTIVE ACTIONS -Measures to reduce the severity of (or terminate) an emergencysituation.EMERGENCY ACTION LEVEL (rEAL) -Conditions that, if met or exceeded, warrantclassification and declaration of an emergency.EMERGENCY DIRECTOR (ED) -The ED is responsible for the overall coordination anddirection of the company response to an emergency condition at the ISFSI.EMERGENCY SUPPORT STAFF -A group of trained staff designated to respond to a'declared emergency, if necessary.GREATER THTAN CLASS C WASTE (GTCC) -Radioactive waste material that is notgenerally acceptable for near surface disposal is waste for which form and disposal methods mustbe different, and in general more stringent, than those specified for Class C waste. The MaineYankee Core Shroud Assembly and Core Support Plate are considered GTCC waste and will bestored at the ISFSI.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) -A spent fuel storagefacility owned and operated by Maine Yankee, comprised of a Protected Area (PA) containingsixteen storage pads having 64 cask locations for dry storage of spent fuel and GTCC waste, asecurity/operations building and an earthen berm partially surrounding the site.INITIATING CONDITION (IC) -ISFSI parameters, equipment status and/or personalobservations that comprise the individual EALs.LOCAL ORGANIZATIONS -Those organizations that provide specific services underemergency conditions (i.e. police, ambulance and fire department).viiREV 7 DEFINITIONS(Continued)UNUSUAL EVENT (UIE) -Events are in progress or have occurred which indicate a potentialdegradation of the level of safety of the facility. No release of radioactive material requiringoffsite response or monitoring is expected.PROTECTED AREA (PA) -The area, encompassed by physical barriers, within the secured,controlled access boundary of the ISFSI.ISFSI SHIFT SUPERVISOR (ISS) -The senior ISFSl representative on-shift. The ISSassumes the position of IS S/ED upon classification and declaration of an unusual event.REV 7

1.0 INTRODUCTION

This document describes the Maine Yankee Atomic Power Company's (MYAPC) planfor responding to emergencies that may arise at the Maine Yankee Independent SpentFuel Storage Installation (ISFSI). The overall purpose of the plan is to delineate theactions necessary to safeguard ISFSI personnel and minimize damage to site property inthe event of an incident at the ISFSI. Analyses of the possible design basis events andconsequences are presented in the Safety Analysis Report for the UMS UniversalStorage System (NAC UMS SAR) used at the ISFSI for dry spent fuiel storage.The analyses of the potential radiological impact of an accident at the Maine Yankee siteindicates that any releases beyond the ISESI Controlled Area boundary are expected to beless than the U.S. Environmental Protection Agency (EPA) protective action guide (PAG)exposure levels, as detailed in EPA-400-R-92-001, Manual of Protective Action Guidesand Protective Actions for Nuclear Incidents. Exposure levels which may warrant pre-planned response measures are generally limited to the Controlled Area. For this reason,radiological emergency planning is focused on the Controlled Area.1.1REV 7 2.0 FACILITY DESCRIPTION2.1 Maine Yankee Site2.1.1 OverviewThe Maine Yankee site is located in the town of Wiscasset, Lincoln County, Maine. Sitecoordinates are approximately 43 degrees 57 minutes 5 seconds north latitude and 69degrees 41 minutes 45 seconds west longitude. The site is bounded by the Back River onthe east, mainland on the north and Bailey Cove on the west. The ISFSI is located on apeninsula known as Bailey Point, which extends south to Montsweag Bay (Figure 2-1).The ISFSI facility is depicted on Figure 2-2. Spent nuclear fuel is in interim storagewithin the specified secure fuel storage area and will be monitored by the ISFSJ staff.2.2 General AreaWithin 5 miles of the site, land use is largely rural residential, small businesses, summerhouses, idle farmland and forest. Housing is scattered along principal roads and isconcentrated only in the center of Wiscasset.The waters of the Back River, Montsweag Bay and associated tributaries are tidal andopen to boating, both commercial and recreational. Regulation of boating is theresponsibility of the U.S. Coast Guard and the State of Maine. The primary type ofboating in the Mon._tswe~ag B~ay -Back River is shallow draft Pleasure boats. With nocommercial traffic in the area, there is essentially no hazard to the site from potentialaccidents with commercial barges or boats carrying hazardous, toxic or explosivematerials.Industrial activity within the general area of the JSFSJ is minimal. The largest industrialfacility is the Bath Iron Works, a shipbuilding facility located on the Kennebec Riverapproximately 7 miles southwest in the city of Bath.The Wiscasset Municipal Airport is the nearest airport to the site and is locatedapproximately one .mile northwest of the site. It consists of one runway (approximately3,400 feet long by 75 feet wide). This runway is aligned such that takeoffs and landingsare on headings of either 070 or 250 (the predominant heading is 250). The majorities ofaircraft that are serviced by this facility are privately owned and are similar to the PiperColt, Cherokee, and Cessna 150 and 172 type craft. The largest aircraftthat typically usethe facility are similar to the Lear 25, Citation II and Rockwell Commander type craft.2.1REV 7 2.3 Independent Spent Fuel Storage Installation (ISFSI)The ISFSI is designed for interim storage of fuel for a minimum of 50 years in acontained shielded system. The ISFSI utilizes the Universal MPC System (UMSTM)developed by NAC International. The UMSTM is a canister-based multi-purpose canister(MPG) system designed for both storage and transportation of spent nuclear fuel. Thecanister-based spent fuel storage system is a passive system which utilizes an outerconcrete cylinder called a Vertical Concrete Cask (VCC) to protect and shield the innersealed metal canister. The VCC is vented for natural convection cooling and has nomoving parts. Decay heat from the loaded fuel storage canister in the VCC is dissipatedto the surrounding air by a once through buoyancy driven airflow. The VCC providesradiation shielding, as well as protection from tornado missiles and earthquakes.The ISFST site consists of a Protected Area (PA) for fuel storage and aSecurity/Operations Building. The ISFSI has a Controlled Area that extends at least 300meters from the nuclear fuel storage area.The PA has sixteen concrete storage pads, and is surrounded by a security fence and anuisance fence with an isolation zone between the two fences. A partial earthen berm isprovided around the facility to reduce the visual impact of the facility. The ISFSI containsa total of 64 storage casks, with one sealed fuel canister per VCC. The types of canistersstored in the storage casks include 60 casks for spent fuel and 4 casks for Greater ThanClass C (GTCC) waste. Sixteen storage pads of equal size are provided for uniformity,which allows for storage of 4 casks per storage pad. The ISFSI site is arranged to providemaneuvering room around the storage pads for access with a cask heavy haul tractor-trailer.The Security/Operations Building provides offices and work space for the operating andmaintenance personnel, including the Radiation Controls Checkpoint lunch/conferencerooms, restrooms, locker rooms, document control room, spare parts storage, and a dieselgenerator for emergency power. The Security/Operations Building also houses the ISFSJsecurity staff, security equipment, and communications equipment. Access to the ISFSIprotected area is controlled and monitored by the security staff.The ISFSI operates under the provisions of a general license utilizing the UJMSTM spentfuel storage/transportation system. The UMSTM system is licensed under a Certificate ofCompliance issued by the U.S. Nuclear Regulatory Commission (NRC) in accordancewith 10 CFR Part 72, "Licensing Requirements for the Independent Storage of SpentNuclear Fuel and High-Level Radioactive Waste".2.2REV 7 FIGURE 2-1MAINE YANKEE SITEGENERAL AREAII fI;.so~cE- USGS OUAD~AM.- WEST--:',:' I. iSWJESS AE/90..1 "" eifSZALE'" Fa2.3oREV 7 FIGURE MAINE YANKEE SITE* 4,*BERMl2.4REV 7 3.0 ISFSI ACCIDENT TYPES. DETECTION AND CONSEQUENCES3.1 Radiological EventsThere are no postulated credible ISFSI accident conditions that would impose aradiological hazard to personnel beyond the ISFSI Controlled Area boundary. There areno credible design basis accidents that would exceed the EPA PAGs at the ISESIControlled Area boundary. In the event of an ISFSI accident condition, the associatedradiological hazards are limited to personnel onsite at the time of the event.The postulated ISFSI accident conditions are described in Chapter 11 of the SafetyAnalysis Report for the UMS Universal Storage System developed by NAC International(Reference 4).3.2 Non-Radiological EventsThe spectrum ofIJSFSI non-radiological events that could necessitate implementation ofthis Emergency Plan is limited. These events fall into the category of general industrialincidents (e.g. fire, explosion, toxic material release, etc.), natural and destructivephenomena (hurricane, tornado, etc.) or security events. These events are furtherdescribed in Chapter 11 of the Safety Analysis Report for the UMS Universal StorageSystem. The determination of which, events are included is based on the probability ofoccurrence, the potential severity and the potential impact on the facility of the event.3.2.1 Tip-Over of Vertical Concrete CaskA hypothetical non-credible accident condition has been postulated involving the non-mechanistic tip-over of a vertical concrete storage cask. Functionally, the cask is notexpected to suffer significant adverse consequences due to this event. The concrete caskand canister are expected to continue providing design basis shielding, geometry controlof contents, and contents confinement performance. The tipped-over configuration of theconcrete cask will be obvious during a Site inspection following the initiating event.There is an adverse localized radiological consequence due to the hypothetical tip-overevent since the bottom end of the concrete cask has significantly less shielding than thesides and top of these same components. The estimated dose rate from the-bottom of atipped-over cask is calculated to be approximately 34 rem/hr at 1 meter, 4 rem/hr at 4meters, and < 10Omrem/hr at 100 meters (NAC-SAR). Following a tip-over event,supplemental shielding should be used until the concrete cask can be up-righted. Surfaceand top and bottom edges of the concrete cask are expected to exhibit cracking andpossible loss of concrete down to the layer of reinforcing bar. The increased dose ratedue to this cracking is not expected to be significant. There are no credible eventsexpected to result in a cask tip-over.3.1REV 7 3.2.2 Tornado and Tornado Driven MissilesIt is not expected that the performance of the UMS storage cask will be significantlyaffected by a tornado event. It is not anticipated that postulated tornado wind loading andmissile impacts are capable of overturning a cask, or penetrating the cask concreteboundary and affecting the fuel storage canister. A tornado event can be visuallyobserved. Advanced warning of a tornado and of tornado sightings may be received fromthe National Weather Service, local radio and television stations, local law enforcementpersonnel, and site personnel. An inspection of the cask exterior surface following atornado event is required. The inspection should be directed at ensuring the inlets andoutlets have not become blocked by wind-blown debris and checking for obviousconcrete surface damage. Damage to the vertical concrete cask after a design basistornado is not anticipated to result in radiation exposure at the Controlled Area boundarythat would exceed the EPA PAGs exposure guidelines. The penetrating missile impact isestimated to reduce the concrete shielding thickness, locally at the point of impact, byapproximately 6 inches. Localized cask surface dose rates for the removal of 6 inches ofconcrete are estimated to be less than 250 rnrem/hr (NAC SAR Section 11.2.11).3.2.3 Explosions.An explosion affecting the Universal Storage System may be caused by industrialaccidents or the presence of explosive substances in the vicinity of the ISFSI. It is notanticipated that explosive substances will be stored or used at the JSFSJ. An explosion inthe vicinity of the ISFSI would be sensed by on-duty ISFSJ personnel. In the event of anearby explosion, an inspection of the concrete casks may be required to check caskintegrity, to ensure that the air inlets and outlets are free of debris, and to ensure that themonitoring system and screens are intact. There are no anticipated off-site radiologicalconsequences for this event.3.2.4 Seismic EventThe earthquake evaluation shows that the loaded or empty vertical concrete casks are notexpected to tip over or slide in the event of an earthquake. Significant earthquakes wouldbe detected by ground motion. Inspection of the vertical concrete casks is requiredfollowing an earthquake event. The proper positioning of the Concrete casks should beverified to ensure they maintain the established spacing requirements. The temperaturemonitoring system should be checked for operation. There are no anticipated off-siteradiological consequences for earthquake events.3.2REV 7 3.2.5 FiresThere are no flammable materials routinely present in the ISFSI cask storage area. A"combustible liquid control zone" shall be established for the ISFSI itself, which shall bea minimum of 10 feet from the outside perimeter of the VCC. The total liquidcombustibles allowed within the zone cannot exceed 50 gallons and must be in directsupport of ISFSI operations or maintenance. A fire in the vicinity of the ISFSI will bedetected by observation of the fire or smoke. Upon detection of a fire, appropriate actionsshould be taken by site personnel to report andlor extinguish the fire. The concrete caskshould be inspected for general deterioration of the concrete, loss of shielding (spalling ofconcrete), exposed reinforcing bar, and surface discoloration that could affect heatrejection. This inspection serves as the basis for the determination of any repair activitiesnecessary to return the concrete cask to its design basis configuration. There may be localspalling of concrete during the fire event, which could lead to some minor reduction inshielding effectiveness. The principal effect would be local increases in radiation doserates on the cask surface. There are no off-site radiological consequences anticipated forthis event.3.2.6 Abnormal Cask Outlet Temperature ShiftThis event involves an abnormal outlet temperature shift caused by a partial or fullblockage of the vertical concrete cask air inlets and outlets that could result in the heat upof the fuel cladding, the fuel basket and the concrete, with the temperature potentiallyreaching the design basis limiting temperature. Full blockage could result in thesetemperature limits potentially being exceeded after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Blockage of the cask airinlets and outlets will be detected by the Cask outlet temperature monitoring system. Anyobstruction blocking the air inlets and outlets must be manually removed. There are nosignificant radiological consequences for this event at the Controlled Area boundary, asthe vertical concrete cask is expected to retain its shielding performance (NAC SARL11.2.13).3.2.7 Other Conditions3.2.7.1 Off-Normal Canister Handling EventsThese events would involve off-normal occurrences during the handling or transfer of aloaded transportable storage canister (TSC), i.e., during the installation or removal of thecanister in or from the vertical concrete cask (VCC), or the transfer cask (TFR).Unintended loads could be applied to the canister due to misalignment or faulty craneoperation, or due to inattention of the operator. The event is expected to be obvious tothe operators at the time of occurrence. There is no anticipated deterioration of thecanister or fuel basket performance due to this event. There are no anticipated off-siteradiological consequences associated with this off-normal event.3.3REV 7 3.2.7.2 Drop of Vertical Concrete CaskThis event involves dropping a loaded vertical concrete cask during routine handlingoperations. This event may be due to the failure of one or more of the cask lifting jacksor of the air pad system. The maximum lift height shall be limited to less than 24 inchesby administrative controls. The event would be detected by the operators as it occurs.The damaged cask should be inspected and repaired prior to continued use. There are noanticipated off-site radiological consequences for this event.3.2.7.3 Flood EventThe UMS storage system vertical concrete casks have been evaluated for a design basisflood condition having a 50-foot depth of water and a water velocity of 15 feet persecond. This flood depth would frully submerge the vertical concrete casks. The analysisshows that the vertical concrete casks are not expected to slide or overturn during thedesign basis flood. Small floods may lead to blockage of the concrete cask air inlet vents.Partial and full blockage of air inlets is described in Section 3.2.6 of this plan. Floodingconditions would be detected by the ISFSI staff or personnel working in the vicinity ofthe ISFSI. A potential exists for collection of debris or accumulation of silt at the base ofothe cask, which could clog or obstruct the air inlet vents. Operation of the temperaturemonitoring system should be verified, as flood conditions may have impaired operation. There are no anticipated off-site radiological consequences associated with thedesign basis flood event.3.2.7.4 Lightning Strike EventSince the vertical concrete casks are located on an unsheltered pad, the casks may besubject to a lightning strike. A lightning strike on a concrete cask may be visuallydetected at the time of the strike, or by visible surface discoloration at the point of entryor exit of the current flow. There are no anticipated off-site radiological consequencesdue to the lightning event.3.3 Security EventEvents that impact the security of the ISFSI are discussed in the ISESI Security Plan.These events represent a threat to the level of safety of the ISFSI due to unauthorizedaccess, the introduction of threatening materials, or the use of hostile force in designatedsecurity areas. Security event detection and response is described in the Maine YankeeIndependent Spent Fuel Storage Installation Physical Security Plan. The Emergency Planmay be implemented if necessary in response to a security event.Events that fall into these areas will be categorized under the appropriate category in theclassification process discussed in Section 4, CLASSIFICATION OF ACCIDENTS.3.4REV 7 4.0 CLASSIFICATION OF ACCIDENTSBased on NUJREG-l1140,"Regulatory Analysis of Emergency Preparedness for Fuel Cycleand Other Radioactive Material Licensees", the NRC has determined that there are nocredible design basis accidents that would exceed the EPA PAGs at an ISFSI ControlledArea boundary. Emergency classification guidance in Appendix F of Nuclear EnergyInstitute document NEI 99-01 (Final Rev. 4), "Methodology for Development ofEmergency Action Levels," states, "The expectations of offsite response to an 'alert'classified under a 10 CFR 72.32 emergency plan are generally consistent with those for anotification of unusual event in a 10 CFR 50.47 emergency plan, i.e., to provideassistance if requested." The NEI 99-01 guidance is utilized in this plan to classify MaineYankee ISFSI emergency events. The NRC Regulatory Analysis for Rev. 4 of Reg Guide1.101 (Reference 5) to accept NET199-01 determined that the guidance in NE1 99-01 isappropriate for developing site specific EALs, to meet the intent of 10 CFR 50.47(b) (4 )and Appendix F to Part 50.Accidents and off-normal events that are analyzed for the ISFSI, including some eventsconsidered to be non-credible, have been reviewed and assigned a classification. Thereare no credible design basis accidents that would exceed the EPA PAGs at the ISFSIControlled Area boundary. Table 4-1 summarizes events that are classified as an UnusualEvent.This plan classifies events based on predetermined Emergency Action Levels (EALs).This approach provides a simple, predetermined response to an emergency event oraccident, allowing a coordinated and phased approach to the eventual mitigation of theconditions and restoring the facility to a safe status.4.1 Definitions4.1.1 Unusual Event (U-E)Events are in process or have occurred which indicate a potential degradation of the levelof safety of the facility. No release of radioactive material requiring offsite response ormonitoring is expected.4.2 Categories of EventsPer the Emergency Action Levels (EALs) guidance in NE1 99-01 (Reference 2), there aretwo categories of ISFSI events that can lead to an accident being classified as an UnusualEvent (UF). The ISS/ED has the discretion to classify events based on the classificationlevel definition. This discretion should be used when conditions or events are observedand no specific Initiating Condition (IC) / Emergency Action Level (EAL) is apparent.The UBE classification will heighten awareness of the abnormal condition. Table 4-1 liststhe initiating conditions, associated emergency action levels, and the applicable NRCemergency classification levels.4.1REV 7 4.2.1 Damage to a Loaded Vertical Concrete Cask That May Damage the Fuel or GTCCConfinement Boundary UEA UE classification for these IC/EALs is warranted on the basis of the occurrence of anevent of sufficient magnitude that a loaded VCC is severely damaged, which may beindicative of potential damage to a cask confinement boundary. This classificationincludes events involving loss of a loaded fuel storage cask confinement boundary,leading to degradation of the fuel during storage or posing an operational safety problemwith respect to removal of the degraded fuel confinement boundary from storage. Naturalphenomena events and accident conditions in which a loaded VCC is damaged areclassified at the UPE level. Cask seal integrity issues discovered during leakage testingassociated with normal canister processing would be addressed in accordance with NACtechnical specifications, or required actions, therefore, classification should not bemade based on loss of seal integrity by itself. However, loss or potential loss of sealintegrity coincident with an accident condition or natural phenomena that clearly affectsthe cask would justify a UPE classification. The 1SF SI vertical concrete storage casks areroutinely monitored by site personnel such that any degradation would be detected.Increases in radiation levels may be indicative of degradation of a storage cask.4.2.2 Confirmed Security Event with Potential Loss of Level of Safety of the ISFSI LYEThese IC/EALs provide a UE cl!assification for security events involving a potential lossof the level of safety of the ISFSI based on the Maine Yankee Independent Spent FuelStorage Installation Physical Security Plan.4.2REV 7 TABLE 4-1 EMERGENCY ACTION LEVELSInitiating Conditions Emergency Action Levels NRC EmergencyClassification LevelHU1 -DAMAGE TO A 1. Natural Phenomena UNUSUAL EVENTLOADED VERTICAL events affecting a loadedCONCRETE CASK (VCC) GTCC or spent fuel caskTHAT MAY DAMAGE confinement boundary.THlE FUEL OR GTCC 2. Accident conditionsCONFINEMENT affecting a loaded GTCCBOUNDARY or spent fuel caskconfinement boundary._________________3. ISS/ED judgment.HiU2 -CONFIRMED 1. Ongoing security UNUSUAL EVENTSECURITY EVENT WITH compromise or attemptedPOTENTIAL LOSS OF entry which may result inLEVEL OF SAFETY OF the potential loss ofTHE ISFSI control of the facility.4.3REV 7 5.0 EMERGENCY RESPONSEEmergency Response OverviewIn the event of an accident at the facility, actions will be taken by facility staff to reportthe event to the ISFSI Shift Supervisor (ISS) and to minimize the impact of the event. Theprimary objective of the initial responders is to assess the situation and minimize the riskimposed on workers and the general public. This involves initiation of required actions tomitigate a particular hazard. Subsequent actions include notifications, staffaccountability, staff augmentation, and implementation of onsite corrective actions asnecessary. The ISFSI Shift Supervisor becomes the Emergency Director (IS S/ED) uponclassification and declaration of an unusual event.5.1 Notification and ActivationWhen an emergency condition is recognized, the event is classified and declared by theISS/ED and mitigating actions are taken to minimize the progression of the event. Theseactions are initiated by available resources. The IS S/ED will request any offsite assistancethat may be necessary due to the nature of the event. Following initial notifications, theMaine State Police (MSP) and the Nuclear Regulatory Commission (NRC) will benotified of the event and mitigating actions in progress or that have been completed.Figure 5-1 depicts the initial .notification and activation process.5.1.1 Maine Yankee Emergency Support StaffThe ISS/ED or designee will direct ISFSI shift personnel to notify the ISFSI Support Staffof an event, if necessary. This will be accomplished by the commercial telephone system(i.e., land based, cell based, satellite based service). In the event the initiating conditionsconstitute a Security Event, these notifications will be made by the IS S/ED or designee. [Notifications to supplement support positions should be completed within one hour of theevent declaration.5.1.2 Offsite OrganizationsFollowing notification of the Maine Yankee ISFSI Support Staff, the Maine State Police(MSP) will be contacted and provided pertinent information regarding the event, actionstaken to mitigate the event and notification of any assistance which may be necessaryfrom local organizations (i.e. fire, ambulance, police response). Notification to the MSPshall be comPleted within one hour of event declaration. Depending on the need forimmediate outside assistance, these notifications may be initiated in an acceleratedmanner (i.e. immediate need for fire fighting capabilities or medical assistance). TheMSP Headquarters Communications Center is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week. TheMSP have the capability to contact State and county emergency response personnel, ifneeded.The MSP will initiate notification to appropriate State Officials in the Maine EmergencyManagement Agency (MEMA), Division of Environmental Health (D)EH) and others asdesignated in the State's notification protocol, based on the event.The NRC will be notified after the notification of the MSP and no later than one hourafter the emergency was declared.5.1REV 7 5.1.3 Information to be CommunicatedA pre-scripted format is used to ensure consistent information is provided to the MSP andthe NRC.At a minimum, the following information will be provided during the initial notificationof the event:Event Classification;Date/Time of Classification;Reason or events causing the condition;General description of damage to major structures/areas;Personal injuries;Status of offsite assistance (fire/medical/other);Name of person making notification;Date and Time of notification.The information will be verified, via repeat-back, to ensure it was accuratelycommunicated.5.2 Radiological AssessmentInitial response to an event will be to ascertain the cause, mitigate furter progression anddetermine the potential impact to ISFSI personnel and the general public. Initialassessment will normally consist of an area dose assessment if warranted. Initial doseassessment activities will be directed by the ISS/ED and performed by qualifiedpersonnel.As soon as practical, facility staff should initiate general area radiation surveys todetermine the actual extent of any radiological concern. Results of the surveys will' beanalyzed by facility staff to formulate an action plan to mitigate the event and restore thefacility to a safe condition. Survey data will also be used, as appropriate, in any on-sitedose assessment techniques.Following the termination of the event, environmental surveys (including, but not limitedto water, soil, vegetation, etc.) may be required to determine the long-term impact of theevent.5.3 Protective Actions5.3.1 Relocation and AccountabilityIn an UNUSUAL EVENT declaration, personnel not directly involved with the responsemay be directed to relocate to an assembly area. Staff will be notified using the on-sitepaging system or other means. An assembly area may be established, based on the natureof the event, at a location determined by the ISS/ED. The ISFSI shift staff will maintainaccountability of personnel and report any missing persons to the ISS/ED. Search andrescue efforts may be performed by shift personnel or local response personnel asnecessary.5.2REV 7 5.3.2 First Aid/Medical ResponseOff-site emergency medical responders will be requested to report to the scene andinitiate first aid treatment to stabilize the patient and prepare for transport to a medicalfacility. One or more First Aid kits are located in the facility. Injuries may becomplicated by the presence of radiation and/or a contaminating substance (chemical orradiological). Given the design of the fuel/GTCC storage canisters, radiologicalcontamination is unlikely, but should be evaluated. The patient will be assessed to*determine if a life-threatening condition exists and appropriate actions taken to eithercontain or remove the contamination. In addition, environmental factors will be takeninto account regarding the need to stabilize the patient in place or remove to a safer area(i.e. lower radiation levels, etc.). Maine Yankee maintains a Letter of Agreement with theWiscasset Ambulance Service for transporting injured/contaminated workers from thesite to a receiving hospital. In addition, agreements have been made with the MidcoastHospital (Brunswick) for treating personnel with various types of injuries/conditions.5.3.3 Personnel MonitoringPersonnel working in known radiation areas will be issued dosimetry in accordance withexisting radiation protection procedures. During emergency conditions, they normallyretain their dosimetry and report to either their assigned emergency station or theassembly area, if a person suspects they may be contaminated, they will be monitored byRadiation Protection personnel.Emergency support staff will be issued dosirnetry as required for assigned tasks.Exposure control will be maintained in accordance with the site Radiation Protection andALARA programs. Dose extensions may be granted in excess of the limits of 10OCFR20for special circumstances. These extensions will be in accordance with EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents.Extensions above the I0CFR_20 limits must be approved by the IS S/ED. The anticipatedemergency exposures are well within the limits specified in Table 5-1.5.3REV 7 TABLE 5-1 GUIDANCE ON DOSE LIMITS FOR EMERGENCY WORKERS (a)Type of Activity TEDE (b) ConditionAll 5 Remn Maintain ALARA and to the extent practicable___________________________limit emergency workers to these limitsProtecting Valuable Property 10 Remn Lower dose not practicable.Life Saving or Protection of Large 25 Rem Lower dose not practicable.Populations>25 Rem Only on a voluntary basis to persons fully aware ofthe risks involved, including the numerical levelsof dose at which acute effects of radiation will beincurred and numerical estimates of delayedeffects.(a) From EPA-400-R-92-00l, Manual of Protective Action Guides and Protective Actions forNuclear Incidents(b) Sum of the deep dose equivalent from the external sources and the comimitted dose.equivalent from the internal exposures to non-pregnant adults from exposure and intakeduring an emergency situation. Dose limits to the eye should be 3 times the listed value.Dose limits to any other organ (including skin and body extremities) should be 10 times thelisted value.5.3.4 Decontamination CapabilitiesSurvey instrumentation for personnel frisking is available. Personnel contaminationidentified during the initial survey will require the contaminated individual to removeprotective apparel, re-survey, and if skin contamination levels are identified, performdecontamination as directed by radiation protection personnel.In the event that accident conditions result in a contaminated injured individual, thevictim's rescue and medical treatment take precedence over the Victim's radiationexposure due to bodily contamination. Gross decontamination of the victim (generallylimited to the removal of contaminated articles of clothing) will be accomplished to theextent that the health of the patient is not affected. Decontamination measures associatedwith wounds will be performed under the joint supervision of the attending physician atthe hospital and the responding radiation protection representative.5.3.5 Contamination and Hazard Exposure ControlSurveys will be conducted to determine which areas contain contamination of either aradiological nature or a hazardous substance. These areas will be identified by eithermarking with boundary rope or tape and access will be limited and controlled accordinglyby the radiation protection personnel. Monitoring of the area will be conducted usingappropriate equipment, based on the type of contamination. All personnel required towork in the area will be provided appropriate personnel protective equipment (coveralls,booties, gloves, etc.) by the Radiation Protection contractor. The level of protection willbe determined by the IS S/ED or other designated personnel.5.4REV"7 5.3.6 Emergency ActionThis plan permits emergency response personnel to take reasonable action that departsfrom a license condition or a technical specification in an emergency when this action isilmmediately needed to protect the public health and safety and no action consistent withlicense conditions and technical specifications can provide adequate or equivalentprotection is immediately apparent.5.4 Coordination with Offsite AgenciesThere is no response required from State agencies. State government response isexpected to be limited to recording the notification of the emergency, periodicallyreceiving updated information on the emergency, and coordinating public informationnews releases. Upon request, Local government agencies (i.e. fire, police, ambulance)will respond to the ISFSJ during an emergency, if necessary.If needed, provisions exist for limiting traffic on roads leading to the Maine Yankee site.These actions would be coordinated through the Maine State Police or the LincolnCounty Sheriffs Office, Wiscasset, Maine.5.5REV 7 FIGURE 5-1MAINE YANKEE INITIAL NOTIFICATION AND ACTIVATION PROCESS' IS S/EDISFS.I SHIFT NRC MAINE STATESPECIALIST POLICE (MSP)MAINE YANKEE .MAINE EMERGENCISFSI SUPPORT MANAGEMENTSTAFF AGENCY (EOC)(If needed)5.6.;YREV 7 6.0 FACILITIES AND EQUIPMENT6.1 Control CenterThe Control Center in the Security/Operations Building is the primary facility whereISFSI conditions are monitored and corrective actions are developed to mitigate anyabnormal occurrence. Emergency conditions classified as UEs are managed by theISS/ED from the Control Center or other appropriate location.The Control Center provides space for the designated members of the ISFSI Emergencysupport staff to conduct analysis and support functions in response to the event. TheControl Center may be activated for other reasons at the discretion of the ISSiED. Thefollowing functions are coordinated from the Control Center: emergency management,offsite notifications and communication, and facility restoration planning.The Control Center is sized to accommodate personnel performing communications,radiological assessment, general engineering and analysis tasks. Communication systemsare available to allow interaction with offsite organizations, as necessary. Variousequipment has been assembled and stored in or near the Control Center for use by supportstaff, including personal protective equipment, and radiation monitoring equipment. TheControl Center has nearby office space to accommodate any required offsite personnel.6.2 Radiation Controls CheckpointThe Radiation Controls (RC) Checkpoint is located in the Security/Operations Building.Personnel dosimetry is issued at this point and a radiological emergency kit is available.6.3 Assembly .AreaPersonnel directed to evacuate the PA will be directed to report to an assembly areadesignated by the ISS/ED.6.4 EquipmentAppropriate equipment is maintained for emergency response activities in the ISFSISecurity/Operations Building. Required supplies are inventoried to ensure operabilityand availability at all times.Controlled copies of facility documents (drawings, procedures, Technical Specifications,SARs, etc.) are maintained in, or in the areas adjacent to the Control Center. Thisinformation is readily available for support staff use.6.1REV 7 6.5 Communications6.5.1 Onsite Communication Systems6.5.1.1 Commercial Telephone SystemThe commercial telephone system is the primary means of onsite communicationduring an emergency. This system has an independent backup power configuration,which incorporates a combination of batteries and an emergency diesel generator toensure uninterrupted operation on a loss of normal power to the ISFSI telephonesystem.6.5.1.2 Paging SystemA general voice paging system is available with speakers on the interior and exteriorof the Security/Operations Building.6.5.1.3 Radio SystemISFSI staff will be equipped with portable radios for onsite communications. One ormore licensed frequencies will be used for routine communications, and one or morestate police frequencies will be used for offsite routine and emergencycommunications.6.5.2 Offsite Communications Systems6.5.2.1 Telephone to the Maine State PoliceCommercial telephones are used to establish communications between the MaineYankee JSFSI Control Center and the Maine State Police (MSP). This is the primarymethod of informing State of Maine personnel of a declared emergency at the MaineYankee ISFSL. Both organizations have telephones in a location that is staffed 24hours a day, '7 days a week.6.5.2.2 Maine State Police RadioIn the event the commercial telephone circuits fail, the MSP can be contacted viaradio from the Control Center and from the ISFSI Security Offices using either of twoState Police frequencies installed on these radios (State Police -Zone 2 and state-widecar-to-car (SWCC). SWCC frequency can also be used to communicate with theLincoln County Sheriffs Office. The ISFSI radio system is powered from the normalpower company service grid. Back up power is provided by a UPS system.6.5.2.3 NRC Emergency NotificationIn the event of an emergency at the Maine Yankee ISFSI, the NRC will be notifiedwithin one hour using the ENS telephone system in accordance with 10 CFR 50.72(a).This line is not anticipated to be established continuously, but used primarily toprovide periodic informational updates to the NRC.6.6 Fire SuppressionFire extinguishers located at the ISFSI are used to help extinguish or contain a fire tothe area of origin and minimize involvement of adjacent areas until the Wiscasset FireDepartment responds to the scene. A fire hydrant is located near the ISFSI for use bythe Wiscasset Fire Department.6.2REV 7 7.0 RESPONSIBILITIESThe Emergency Organization is comprised of on-shift ISFSI personnel. Detection andrecognition of conditions that warrant declaration of an emergency, in accordance withthe EALs, is the responsibility of the ISFSI Shift Supervisor (ISS). Upon declaration of anemergency, the on-shift organization assumes their emergency response duties andimplements this plan. The minimum on-shift staff required for initial emergencyresponse consists of the ISS/ED (Fig. 7-1).The IS S/ED may call in support staff in numbers and disciplines necessary to support theresponse and recovery actions required for the event. Radiation Protection support isavailable on a call-in basis if not present on-site at the onset of an emergency.7.1 On-shift Organization7.1.1 LSFSI Shift Supervisor /Emergency DirectorThe ISS is the qualified emergency representative on-shift. The 1SS assumes the positionof ISS/ED. The IS S/ED executes any actions deemed necessary to mitigate theconsequences of the emergency condition and restore the facility to a safe and stableconfiguration.The primary responsibilities of the IS S/ED include:* Classification and emergency declaration of the incident* Notification and request for assistance from local response agency, including medicalassistance as necessary* Notification and interface with offsite agencies* Notification of ISFSI support staff,* Direction and control of available personnel* Initiation of immediate corrective actions, if any* Direction, control, communications and public information* Authorization of onsite protective actions* Establish priorities for the Control Center staff* Provide periodic updates to the NRC* Determine the need for offsite/contractor assistance* Mitigation and recoveryThe ISS/ED is responsible for maintaining the integrity of the ISFSI and all operationalactivities in the facility. The ISS/ED may be relieved by another qualified ED) ifconditions warrant.7.1.2 Shift SpecialistThe ISFSI Shift Specialist is responsible for maintaining facility security in accordancewith the ISFSI Security Plan.The primary responsibilities of the Shift Specialist during an emergency is:* Maintaining site security and access control from the Central Alarm Station (CAS)* Personnel Accountability in the ISFSI Protected Area (PA)* Notification of the support staff as requested by the iS S/ED* Notification of offsite Agencies as requested by the IS S/ED* Search and Rescue coordination, as necessaryoFire response coordination, as necessary.7.1REV 7 7.2 Augmented OrganizationThe need for an augmented response by support staff is determined by the ISS/ED on acase by case basis for the Unusual Event (UE) classification. If needed, the augmentedsupport staff is expected to be in place to support emergency response activities withinapproximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Augmented response personnel may be provided by a contractedservice.7.2.1 Support StaffAvailable facility staff and/or emergency services contractors will be called in asnecessary to assist in the response, including:* Perform spent fuel storage condition assessments, if necessary* Assess the extent of damaged equipment* Identify short and long-term repair needs* Establish initial repair priorities and deploy repair teams* Coordinate available resources to restore equipment and systems based on thedirection of the ISS/ED* Handle logistical needs* Perform radiological and environmental surveys as necessary.* Developing public information materials for release to the news media as necessary,and maintaining liaison with news media and State of Maine information staff.7.2REV 7 FIGURE 7-1MAINE YANKEE ISFSIMINIMUM ON-SHIFT EMERGENCY ORGANIZATIONISFSI SHIFT SUPERVISOR!/EMERGENCY DIRECTOR (ISS/ED)SHIFT SPECIALIST7.3REV 7 8.0 MAINTAINING EMERGENCY PREPAREDNESSThe ISFSI Manager or designee is responsible for ensuring the availability ofadequate emergency support staff and for approval of the ISFSI Emergency Planand Implementing Procedures (IEPIPs).The JSFSI Manager is also responsible for ensuring the following tasks andfunctions are completed:* The maintenance of readiness of the on-site emergency response facilities andequipment;* Development and maintenance of the ISFSI Emergency Plan;o Development and maintenance of the associated implementing procedures;* Preparation of scenarios for training drills and exercises;* Conduct of drills and exercises;* Provision of input to emergency preparedness training of the support staff;* Returning emergency equipment and supplies used during a drill, exercise oractual emergency to a state of readiness following the termination of the drill,exercise or emergency;* Providing support for the annual radiation monitoring drill and medicalemergency drill.*Reviewing ISFSJ EALS with state and local government authorities on anannual basis in accordance with 10 CFR 50 Appendix E (TV)(B).8.1 TrainingThe Maine Yankee ISFSIi Emergency Plan Training Program consists of lessonplans designed to provide the skills and knowledge necessary to maintain staffproficiency. Each IEPIP will be reviewed to identify activities that are notconsidered to be a part of the assigned individuals day-to-day routine function (i.e.use of telephones, general communication protocol, etc.). Lessons will focus onnon-routine and specialized activities that are particular to the assigned functionand overall emergency response actions. Training may consist of, but not belimited to, classroom lecture, self-study, practical demonstrations (wherenecessary, as specified in the lesson plan), and facility drills.8.1.1 Emergency Staff TrainingEach individual selected for assignment to the on site staff or the support staff willbe provided training designed to familiarize the person with their duties,responsibilities and expected actions in the event of a condition that requires thesupport staff to be mobilized. This initial training will be completed prior to theindividual assuming the emergency response duty.Each on shift and support staff member will be provided continuing training fortheir assigned duties. This training will be conducted annually. Continuingtraining addresses general changes to the ISFSJ Emergency Plan, facilities,equipment, regulations, policies and specific changes to their responsibilities(which are not considered part of their routine duties). It also addresses problemareas identified during audits, drills or exercises.8.1REV 7 8.1.2 ISFSI Access TrainingThe ISFSI Access Training program provides employees and contractors routinely onsitethe basic elements of the ISFSI Emergency Plan and expected actions during anemergency. Information is reviewed annually as part of site access training.8.1.3 Offsite Assistance TrainingOrganizations which may be called upon to render assistance onsite will be offeredgeneral facility familiarization sessions on an annual basis. These sessions may include awalk down of the general facility, safety, building layout, access protocol,communications capabilities and security requirements. Radiological orientation trainingwill also be offered annually.8.2 Review and Updating of the ISFSI Emergency Plan and Implementing Procedures8.2.1 ISFSI Emergency Plan (JEP) ReviewThis plan, including all written agreements between Maine Yankee and other parties, willbe reviewed annually. Approved changes to the plan will be incorporated into theappropriate implementing procedures along with the plan changes. Letters of Agreementwill be reviewed annually and verified to be in effect at the time of the plan review. Thismay be accomplished via written correspondence or documented telephone conversation.This plan is a controlled document to ensure changes are incorporated into distributedcopies. Plan changes will be subject to management review and approval. Plan changeswill be issued as an entire revision with changes identified on the affected pages.8.2.2 Emergency Plan Implementing Procedure ReviewISFSI Emergency Plan Implementing Procedures (JEPIiPs) will be reviewed and revised inaccordance with plant procedure control guidelines, and as necessary. Periodic revisionswill be incorporated whenever a plan change is made that affects the procedure or othercircumstances dictate a revision is necessary. IEPIPs will be subject to managementreview and approval.8.2.3 Periodic Surveillance ProgramFacilities and equipment will be maintained in accordance with surveillance procedures.Inventories of emergency plan equipment will be conducted on a semi-annual basis andafter facility activation (actual event or drill activity). A walkdown of the Control Centerwill be conducted on a quarterly basis to ensure facility readiness is maintained.Telephone numbers that are important to emergency notification and are contained in theJEPI~s will be verified on a quarterly basis.8.2.4 Communications Systems ChecksTelephones, radios and paging systems used for on-site and off-site emergencycommunications will be tested quarterly per communications surveillance procedures.8.2REV 7 8.3 Drills and ExercisesIn addition to the emergency plan training described earlier, the facility staff will conductperiodic drills to enhance skills and knowledge of the practical implementation of theIEP. Periodic drills will be scheduled with various objectives to demonstrate theseCapabilities. Some drills will focus on singular functions (such as communicationscapabilities) while others will involve the activation of the support staff. Theseevolutions serve as an extension of the training program, allowing interaction betweenevaluators and responders to reinforce procedural requirements and overall processimplementation.8.3.1 DrillsIn addition to training drills discussed above, the following drills will be conductedannually;-Support Staff Drill -involving a combination of some of the principal functionalareas of emergency response capabilities. The biennial exercise satisfies the annualsupport staff drill requirements.-Radiological Monitoring Drill.- demonstrating conducting general area surveys.-Medical Emergency Drill -demonstrating the capability to transport an injured workeroffsite.-Fire Drill -conducted in accordance with the Fire Protection Program.8.3.2 ExercisesAn exercise will be conducted once every two years to demonstrate the capability toimplement the ISFSI Emergency Plan. Objectives will be developed to ensure majorelements of the emergency plan are demonstrated and evaluated to ensure the appropriatelevel of preparedness is being maintained.Offsite response organizations will be invited to participate in biennial exercises.8.3.3 Driln and Exercise EvaluationFacility staff will evaluate the exercise and drills. Expectations for evaluators will bediscussed with each evaluator prior to the drill. Whenever possible, evaluators shouldhave present or recent ISFSI emergency responsibilities and be assigned to evaluatefunctions/areas consistent with their emergency assignment. Following the drill/exercisea critique of the evolution will be conducted. Comments will be evaluated anddispositioned by Maine Yankee and deficiencies will be corrected through retraining,remedial drills, or by other means. Comment resolution will be assigned to appropriatepersonnel for final implementation.8.3REV 7 8.4 Independent Program ReviewAn independent program review of the ISFSI emergency preparedness program will beconducted once every 12 months in accordance with 10 CFR 50.54(t) or as necessary,based on the assessment against performance indicators, and as soon as reasonablypractical after a change occurs with personnel, procedures, equipment or facilities thatpotentially could adversely affect emergency preparedness, but no longer than 12 monthsafter the change. Items to be reviewed should include, but not be limited to, adequacy ofinterfaces with State and local government agencies, implementing procedures, drills,exercises and capabilities.8.4REV 7 9.0 RECOVERYThe primary objective of the facility staff is to mitigate the consequences of an emergencyand restore the facility to a safe condition. Restoration of the facility effectively beginswith the first action taken in response to the event and terminates when the facilityresumes normal operations.When conditionshave. stabilized and a full assessment of the event has been conducted,the facility staff will focus on establishing a plan to verify' operability of allsystems/components necessary to maintain and monitor the integrity of the spent fuel.The ISESI Manager or designee will coordinate the restoration of the facility and has theauthority to take the necessary actions to ensure the facility is returned to a safe condition.Recovery responsibilities, of the JSFSI Manager include, but are not limited to:Development of the site recovery plan.* Maintain comprehensive hazard assessment of the facility.* Prioritize clean-up of affected areas/equipment.* Isolate and repair damaged equipment/systems.* Document all actions taken related to the recovery operations.9.1REV 7 10.0 OFFSITE ASSISTANCEResponse from organizations that are not associated with Maine Yankee are not expectedto be necessary, except for fire, medical emergencies or hazardous materials incidents.Letters of Agreement exist with organizations that may be called upon, on an as-neededbasis, to provide assistance.The Wiscasset Fire Department and Wiscasset Ambulance Service have standingagreements to assist Maine Yankee in the event of a fire, hazardous materials incident ormedical emergency.Maine Yankee maintains a Letter of Agreement with the MidCoast Hospital in Brunswickfor treatment of radiologically contaminated and injured workers.Response from the State of Maine will be limited to acknowledging notification of theevent. No mitigating actions are anticipated to be necessary in response to an event at.Maine Yankee. Precautionary actions are anticipated to be similar to those taken inresponses to preparations for severe weather, etc.Other agreements exist for specialized services that can be called upon as needed.10.1Rev 7

11.0 REFERENCES

1. Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-400-R-92-001, May 1992.2. NEI 99-0 1 Final Rev. 4 "Methodology for Development of Emergency Action Levels,"January 2003.3. NIJREG-1 140, "Regulatory Analysis on Emergency Preparedness for Fuel Cycle and OtherRadioactive Material Licensees."4. NAC Safety Analysis Report, UMS Universal Storage System, Docket 72-10 15, October1999.5. NRC Regulatory Guide 1.10 1, Rev. 4, "Emergency Planning for Nuclear Power Plants.", July2003.6. NRC Regulatory Issue Summary 20 15-14, "Issuance of Enforcement Guidance Memorandum-Emergency Plan and Emergency Plan Implementing Procedure Updates", October 30, 2015.11.1Rev 7 APPENDIX I -ASSISTANCE AGREEMENTSORGANIZATIONMid-Coast HospitalWiscasset Fire DepartmentWiscasset Ambulance ServiceI-1IREV 7 APPENDIX II -SUPPORTING PLANS AN]) DOCUMENTSDefueled Safety Analysis Report (DSAR)FP-.1, Fire Protection ProgramMaine Yankee Independent Spent Fuel Storage Installation Physical Security Plan andSupporting Security ProceduresIi-1REV 7 APPENDIX Ill -EMERGENCY PLAN IMPLEMENTING PROCEDURES1. Emergency Plan Implementing Proceduresa. EQ -1, Emergency Planning Administrationb. EQ -2, Response to Accident and Natural Phenomena Eventsc. EQ -5, Emergency Plan Implementation'IlI-REV 7