ML21120A110

Response to Request for Additional Information (RAI) - License Amendment Request to Approve the Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan

ML21120A110
Person / Time
Site:	Oyster Creek
Issue date:	04/30/2021
From:	Sterdis A Holtec Decommissioning International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML21120A110 (23)

Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 50.90 10 CFR 50.54(q)(4)

April 30, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Docket No. 50-219 and 72-15

Subject:

Response to Request for Additional Information (RAI) - License Amendment Request to Approve the Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan

References:

1. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, License Amendment Request to Approve the Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan, February 23, 2021 (ML21054A321)

2. US NRC Electronic Mail Request to Andrea Sterdis (HDI) OCNGS - Draft Request for Additional Information Regarding Request to Revise ISFSI Only Emergency Plan April 5, 2021

3. US NRC Electronic Mail Request to Andrea Sterdis (HDI) Request for Additional Information Related to Request for Approval of Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan, April 8, 2021 (ML21099A038, ML21099A044)

By letter dated February 23, 2021 (Reference 1) Holtec Decommissioning International, LLC, (HDI) submitted a License Amendment Request (LAR) for Oyster Creek Nuclear Generating Station (OCNGS). The proposed amendment would revise the site emergency plan for the Independent Site Fuel Storage Installation (ISFSI) Only condition.

Subsequently, in an electronic mail request dated April 5, 2021 (Reference 2), the NRC issued a Draft Request for Additional Information (RAI) indicating that it had reviewed the information submitted in Reference 1 and additional information was needed to support its continued review.

The Draft RAI in Reference 2 was discussed during a teleconference on April 8, 2021, between HDI and NRC representatives. As a result of the discussions, it was determined that no modification to the Draft RAI was needed and the NRC issued a formal RAI on April 8, 2021 (Reference 3) and requested a response within 30 days.

HDI-OC-21-033 Page 1 of 2

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 to this letter provides HDIs response to the NRCs RAI. Attachment 2 provides updated clean pages of the ISFSI Only Emergency Plan and ISFSI Only EALS. HDI has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Reference 1. The additional information provided in this submittal does not affect the previously stated bases in Reference 1 for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4).

There are no regulatory commitments contained in this submittal.

If you have any questions or require additional information, please contact me at (856) 797-0900, ext. 3813 or a.sterdis@holtec.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 30, 2021.

Sincerely, Digitally signed by Andrea Sterdis Andrea DN: cn=Andrea Sterdis, c=US, o=Holtec Decommissioning International, ou=HDI, Sterdis email=a.sterdis@holtec.com Date: 2021.04.30 10:47:23 -04'00' Andrea L. Sterdis HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC . Response to NRCs Request for Additional Information Updated (clean) pages of the Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan (IOEP) and Oyster Creek ISFSI Only Emergency Actions Levels and technical Bases (IOEAL) cc:

USNRC Regional Administrator, Region I USNRC Project Manager, NMSS - Oyster Creek Nuclear Generating Station Assistant Commissioner, Air Quality, Energy and Sustainability, NJ DEP Assistant Director Radiation Protection Element, NJ Bureau of Nuclear Engineering HDI-OC-21-033 Page 2 of 2

Attachment 1 Response to NRCs Request for Additional Information HDI-OC-21-033 Page 1 of 11

SUMMARY

By letter dated February 23, 2021 (ML21054A321) (Reference 1), Holtec Decommissioning International, LLC (HDI) submitted a license amendment request for review and approval of the Oyster Creek Nuclear Generating Station (OCNGS) Independent Spent Fuel Storage Installation Facility (ISFSI) Only Emergency Plan and its associated Emergency Action Level scheme. The proposed changes are being submitted to the U.S. Nuclear Regulatory Commission (NRC) for approval prior to implementation, as required under Paragraph 50.54(q)(4) of Title 10 of the Code of Federal Regulations (10 CFR).

Subsequently, in an electronic mail request dated April 5, 2021 (Reference 2), the NRC issued a Draft Request for Additional Information (RAI) indicating that it had reviewed the information submitted in Reference 1 and additional information was needed to support its continued review. The Draft RAI in Reference 2 was discussed during a teleconference on April 8, 2021, between HDI and NRC representatives. As a result of the discussions, it was determined that no modification to the Draft RAI was needed and the NRC issued a formal RAI on April 8, 2021 (Reference 3) and requested a response within 30 days.

Accordingly, this attachment provides HDIs response to the NRCs RAI contained in the Reference 3 electronic mail request. Each specific question is followed by HDIs response.

Changes made to the previously submitted ISFSI Only Emergency Plan and EALs are shown as markups at the end of the RAI response as necessary. Attachment 2 contains clean corrected pages for replacement.

RESPONSE TO RAI QUESTIONS

RAI-1

Requirement:

• 10 CFR 50.47(b)(12), requires that arrangements are made for medical services for contaminated injured individuals.

• 10 CFR Part 50, Appendix E.IV.E.6 requires arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary.

• Associated guidance in NUREG-0654,Section II.B, Evaluation Criterion L.4 states that each licensee shall arrange for transporting victims of radiological accidents to medical facilities.

Issue: Section 5.2.2, Ambulance Service, of Enclosure 1 Attachment 1, Oyster Creek ISFSI Only Emergency Plan, states, Arrangements are made for prompt ambulance transport of persons with injuries involving radioactivity to designated hospitals. Such service is available on a 24-hour per day basis and is confirmed by letter of agreement.

However, previously Section 7.2.3.1, Local Services, of Attachment 3, Clean Copy -

Permanently Defueled Emergency Plan (PDEP), in letter dated February 13, 2018 (ADAMS Accession No. ML18044A214), states, HDI-OC-21-033 Page 2 of 11

1. Transportation of injured personnel using an ambulance service (Lacey Township, Lanoka Harbor, and Waretown First Aid Squads)

In letter dated October 17, 2018 (ADAMS Accession No. ML18221A400), the NRC issued the amendment approving the proposed permanently defueled emergency plan The SER stated, Therefore, the NRC staff concludes that the licensee's proposed Oyster Creek PDEP, as provided in Attachment 3 to the licensees letter dated February 13, 2018, is acceptable.

The current text in IOEP Section 5.2.2 does not identify what ambulance services are available.

Request: Clarify what ambulance service(s) are confirmed by letter(s) of agreement with the OCNGS ISFSI.

HDIs Response to RAI 1 Letters of Agreement will be maintained with Lacey Emergency Medical Service (EMS) and Lanoka Harbor EMS for the ISFSI Only Emergency Plan. Maintaining two ambulance services provides redundancy for this off-site service. DPP-OC-EP-001 (IOEP) Section 5.2.2 Ambulance Service on page 19 has been changed to:

Such service is available on a 24-hour per day basis and is confirmed by letters of agreement with Lacey Emergency Medical Service (EMS) and Lanoka Harbor EMS.

RAI-2

Requirements:

• 10 CFR 50.47(b)(1), as exempted, requires that each principal response organization has staff to respond and augment its initial response on a continues basis.

• 10 CFR 50.47(b)(2), as exempted, requires on-shift facility licensee responsibilities for emergency response are unambiguously de"ned, adequate staf"ng to provide initial facility accident response in key functional areas is maintained at all times.

• 10 CFR Part 50, Appendix E.lV.A.1, as exempted, requires a description of the normal plant organization. Additionally, Appendix E.lV.A.2, as exempted, requires a description of the onsite emergency response organization (ERO).

• Associated guidance in NUREG-0654,Section II, Evaluation Criterion A.4, states each licensee shall be capable of continuous (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) operation. Evaluation Criteria B.1, states that each licensee shall specify the on-site emergency organization of the plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement. Evaluation Criteria 35 states each licensee shall specify the position or title and major tasks to be performed by persons to be assigned to the functional areas of emergency activities.

Issue: Section 6.1 On-site Positions" of the IOEP only identi"es the ISFSI Shift Manager/Security Operations Supervisor (ISS) position. Table 61 only identifies the Emergency Director as the on-shift staff to "ll all functional areas.

HDI-OC-21-033 Page 3 of 11

Request: Identify other on-shift positions and types of staff that are available to "ll emergency response functions at OCNGS ISFSI. Identify who would assume Emergency Director duties at OCNGS ISFSI if the ISS is incapacitated or somehow unavailable during a shift.

HDIs Response to RAI 2 The submitted IOEP says:

3.3.1 Emergency Director This position is the highest level of authority for the OCNGS Emergency Response Organization (ERO) and on-site emergency activities. This position is held by the ISFSI Shift Supervisor (ISS) or designated alternate. The ISS in the IOEP is equivalent to the Lead Security Shift Supervisor (LSSS) as defined in the ISFSI Only Security Plan.

On-shift positions are listed on in table 6-1 in the IOEP. As listed, the NRC approved Security Plan dictates the number of security personnel on shift. The submitted IO PSP requires a minimum of: a Security Supervisor (ISS) and a Security Officer. The Security Officer would succeed the ISS if incapacitated until on call replacements are achieved. The Security Officer is trained to perform call outs and off-site notifications. This succession is covered in EPIPs/Security procedures.

RAI-3

Requirement:

• 10 CFR 50.47(b)(7), as exempted, requires the principal points of contact with news media for dissemination of information during and emergency are established in advance, and procedures for coordinated dissemination of information to the public are established.

• Associated guidance in NUREG-0654, Section ll.G, Evaluation Criterion 3.a, states each principal organization shall designate the points of contact and physical location for use by news media during an emergency. Also, Evaluation Criteria 4.a states each licensee shall designate a spokesperson who should have access to all necessary information.

Evaluation Criteria 4.b states each licensee shall establish arrangements for timely exchange of information among designated spokespersons. Evaluation Criteria 4.c states each licensee shall establish coordinated arrangements for dealing with rumors.

Issue: In IOEP Section 6.2.1, the Resource Manager is identi"ed as serving as the public information interface. In Section 11.0 Public information," corporate public affairs personnel are identified to represent the facility as the company spokesperson, and to disseminate information to the public.

Request: Clarify the apparent duplication of responsibilities between the Resource Manager and corporate public affairs personnel for the OCNGS ISFSI.

HDI-OC-21-033 Page 4 of 11

HDIs Response to RAI 3 The Resource Manager may be the initial liaison to the public. They will provide information to Corporate Public Affairs and coordinates with Corporate Public Affairs who becomes the lead on dissemination of information to the public. Section 6.2.1 Resource Manager functions are being updated as shown below. Corporate Public Affairs becomes the lead for this function. DPP-OC-EP-001 (IOEP) section 6.2.1 Resource Manager on page 22 following sentence change as follows:

The Resource Manager will augment the Emergency Director by assisting in the assessment of the emergency condition and coordinating any required resources, including serving as the public information interface (until turnover to Corporate Public Affairs occurs).

RAI 4

Requirement:

• 10 CFR 50.47(b)(5), as exempted, requires procedures have been established for noti"cation, by the licensee, of State and local response organizations...

• 10 CFR Part 50, Appendix E.lV.D.3, as exempted, requires a licensee to have the capability to notify responsible State and local governmental agencies after declaring an emergency.

• Associated guidance in NUREG-0654, Section E. Evaluation Criterion E.1. states that each licensee shall establish procedures which describe mutually agreeable bases for notification of response organizations consistent with the emergency classi"cation and action level scheme.

Issue: Section 9.0, Notification Methods and Procedures, of Enclosure 1 Attachment 1, states, in part:

Procedures are established for the prompt noti"cation to NJ OEM [New Jersey-Of"ce of Emergency Management] and local organizations. . ..

However, previously the response to request for additional information (RAI) OC-03 in , Response to Request for Additional Information, in letter dated February 13, 2018 states, Local organization EOCs [Emergency Operations Centers]: Ocean County, Lacey Township, and Ocean Township are noti"ed by the State of New Jersey, as necessary, when an Unusual Event, Alert, or other State EOC noti"cation has been made by the OC Shift Manager. The local county and townships have established this process for the current operating plant and will continue to support this method during this decommissioning period. The Local Warning Points/EOC block on Figure 6.1 [Exelon HDI-OC-21-033 Page 5 of 11

Noti"cation Scheme] has been revised to indicate the three local EOCs that will be contacted by the State EOC in the attached revised PDEP.

The current text in IOEP Section 9.3.1 does not detail how the local governmental organizations will be notified.

Request: Clarify how the local governmental organizations will be noti"ed of an emergency at the OCNGS ISFSI.

HDIs Response to RAI 4 The New Jersey Office of Emergency Management (OEM) is the state point of contact for UE or ALERT declarations (as in the current PDEP). The OEM coordinates and communicates with local EOCs in accordance with the states protocol. This protocol is a state process that is not controlled by OC/HDI.

RAI-5

Requirement:

• 10 CFR 50.47(b)(8), as exempted, requires that adequate emergency facilities and equipment to support the emergency response are provided and maintained.

• 10 CFR Part 50, Appendix E.lV.E., as exempted, requires each licensee to describe emergency facilities.

• Associated guidance in NUREG-0654, Section ll.H, Evaluation Criterion H.2, states each licensee shall establish an emergency facility from which evaluation and coordination of all licensee activities related to an emergency is to be carried out, and from which the licensee shall provide information to federal, State, and local authorities responding to emergencies. Also, in Evaluation Criteria H.6, each licensee shall make provisions to acquire data from or for emergency access to offsite monitoring and analysis equipment including geophysical phenomena monitors, (e.g., meteorological, and seismic).

Issue: IOEP Section 12.1, Emergency Response Facilities, identifies the Emergency Response Facility (ERF) as the facility from which command and control functions are managed. However, the IOEP does not identify the location of the ERF. The IOEP does not include information on the availability of, or access to geophysical phenomena monitors.

Request: Provide the location of the ERF for the OCNGS ISFSI. Provide information on the availability of or access to geophysical phenomena monitors for the OCNGS ISFSI.

HDIs Response to RAI-5 The onsite ERF is the office area within the main warehouse just adjacent to the ISFSI facility and is where the ISFSI Security Supervisors Office is located. The Security Supervisors Office HDI-OC-21-033 Page 6 of 11

has been added to the DPP-OC-EP-001 (IOEP) page 11, ERF definition 3.1.12 is changed as follows:

The ISFSI Security Supervisors Office is the fFacility that containing contains the communications equipment necessary for emergency conditions.

Geophysical information is available to the ISFSI Security Supervisor as described in EPIPs by the following means:

The National Weather Service (NWS) Mt. Holly, NJ office provides meteorological information (e.g., wind speed, temperature, and wind direction) from several locations in the vicinity of OCNGS. This information is available by telephone or the internet.

Seismic information can be obtained from the U.S. Geological Surveys (USGS) National Earthquake Center by telephone or internet.

RAI-6

Requirement:

• 10 CFR 50.47(b)(10), as exempted, requires that a range of protective actions has been developed for emergency workers.

• Associated guidance in NUREG-0654,Section II.J, Evaluation Criterion J.2, states each licensee shall make provisions for evacuation routes and transportation for onsite individuals. Also, Evaluation Criteria J.3 states each licensee shall provide for radiological monitoring of people evacuated from the site. Further, Evaluation Criteria J.6 states licensees shall make provisions for the use of individual respiratory protection.

Issue: The IOEP does not address evacuation routes or transportation for onsite individuals, radiological monitoring of site evacuees, or the provision of respiratory protective equipment.

Request: Provide information on evacuation routes, monitoring of people evacuated from the site, and provision of respiratory protective equipment for the OCNGS ISFSI.

HDIs Response to RAI-6 Details of Evacuation routes and Radiation monitoring are covered in Emergency Plan Implementing Procedures (EPIPS) and Site radiation control procedures. Primary evacuation is to off site. Medical evacuation is to one of the two listed Hospitals in the IOEP.

The protective equipment for OC ISFSI is listed in Appendix A page 46 of DPP-OC-EP-001 (IOEP) has the following change:

• Protective clothing, including respiratory protection HDI-OC-21-033 Page 7 of 11

RAI-7

Requirement:

• 10 CFR 50.47(b)(15), requires radiological emergency response training is provided to those who may be called on to assist in an emergency.

• 10 CFR Part 50, Appendix E.IV.F.1 requires description of specialized initial training and periodic retraining of categories of emergency personnel, including first aid and rescue teams.

• Associated guidance in NUREG-0654,Section II.B, Evaluation Criterion O.3, as modified by Attachment 1 to NSIR/DPR-ISG-02, "Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants" (ADAMS Accession No. ML14106A057),

states that each licensee shall arrange for transporting victims of radiological accidents to medical facilities.

Issue: Section 19.1.2, First Aid Personnel, of Enclosure 1 Attachment 1, states, First Aid training is provided to personnel assigned on-shift in accordance with site training and qualification plan.

However, previously Section 11.2.2, Emergency Response Organization Training, of , in letter dated February 13, 2018 (ADAMS Accession No. ML18044A214), states, Personnel assigned the responsibility of first aid response will be trained with courses equivalent to Red Cross First Aid, CPR, or AED for Lay Responders or equivalent.

The current text of Section 19.1.2 First Aid Personnel does not provide information on the level of training provided.

Request: Clarify what level/type of training first aid personnel receive at the OCNGS ISFSI.

HDIs Response to RAI 7 The following sentence has been added to Section 19.1.2 on page 41 of DPP-OC-EP-001 (IOEP):

Personnel assigned the responsibility of first aid response will be trained with courses equivalent to Red Cross First Aid, CPR, or AED for Lay Responders or equivalent

RAI-8

Requirement:

• 10 CFR 50.47(b)(16), as exempted, requires that responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

HDI-OC-21-033 Page 8 of 11

• Associated guidance in NUREG-0654,Section II.P, Evaluation Criterion P.7, states each plan shall contain a listing, by title, procedures required to implement the plan. The listing shall include the section(s) of the plan to be implemented by each procedure.

Issue: The IOEP includes an Appendix B, which has a column to identify appropriate procedures. However, the column only indicates TBD for all procedures.

Request: Provide an appropriate listing, by title, of the procedures required to implement the IOEP for the OCNGS ISFSI.

HDIs Response to RAI 8 EPIPs will follow similar level of detail as provided for the PDEP for emergency preparedness actions that are required by the IOEP. The EPIP titles will be updated prior to implementation of the IOEP.

RAI-9

Requirement:

• 10 CFR 50.47(b)(4), as exempted, requires a standard emergency classification and action level scheme.

• 10 CFR Part 50, Appendix E.IV.B.1, as exempted, requires a description of the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification.

• Associated guidance in NUREG-0654,Section II.D, Evaluation Criterion D.1, states that an emergency classification and emergency action level scheme must be established by the licensee.

Issue: PD-HA1, Hostile Action is occurring or has occurred, of Enclosure 1, Attachment 2, EAL Bases, states, This IC [Initiating Condition] addresses the notification of an aircraft attack threat or an occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA.

However, the EAL itself does not state the location in the Emergency Action Level.

Request: Revise the Emergency Action Level to include the location discussed in Enclosure 1, , EAL Bases.

HDIs Response to RAI 9 within the OWNER CONTROLLED AREA has been added to the EAL PD-HA1 and repeated in the bases document. See Attachment 2, DPP-OC-EP-002 (IO EAL) pages 16 and 20.

1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor.

HDI-OC-21-033 Page 9 of 11

RAI-10

Requirement:

• 10 CFR 50.47(b)(4), as exempted, requires a standard emergency classification and action level scheme.

• 10 CFR Part 50, Appendix E.IV.B.1, as exempted, requires a description of the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification.

• Associated guidance in NUREG-0654,Section II.B, Evaluation Criterion D.1, states that an emergency classification and emergency action level scheme must be established by the licensee.

Issue: Definitions section, of Enclosure 1 Attachment 2, EAL Bases, does not have a definition for the following terms:

• Emergency Action Level (EAL)

• Emergency Classification Level (ECL)

• Initiating Condition (IC)

Request: Revise the definition section to include the definitions for Emergency Action Level (EAL), Emergency Classification Level (ECL), and Initiating Condition (IC).

HDIs Response to RAI 10 Reference paragraphs have been added to DPP-OC-EP-002 (IO EAL) page 13 as follows:

Emergency Action Level (EAL): Refer to Section Error! Reference source not found. 3.3.

Emergency Classification Level (ECL): Refer to Section Error! Reference source not found. 3.1.

Initiating Condition (IC): Refer to Section Error! Reference source not found. 3.2.

RAI-11

Requirement:

• 10 CFR 50.47(b)(4), as exempted, requires a standard emergency classification and action level scheme.

• 10 CFR Part 50, Appendix E.IV.B.1, as exempted, requires a description of the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification.

HDI-OC-21-033 Page 10 of 11

• Associated guidance in NUREG-0654,Section II.B, Evaluation Criterion D.1, states that an emergency classification and emergency action level scheme must be established by the licensee.

Issue: The Definitions section of Enclosure 1 Attachment 2, EAL Bases, has the following terms that are not used in the EAL Bases:

• Normal Level

• Unplanned Request: Revise the Definitions section to exclude the definitions for Normal Level and Unplanned.

HDIs Response to RAI 11 Definitions have been removed from DPP-OC-EP-002 (IO EAL) pages 13 and 14.

NORMAL LEVELS: As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.

UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

References:

1. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, License Amendment Request to Approve the Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan, February 23, 2021 (ML21054A321)

2. US NRC Electronic Mail Request to Andrea Sterdis (HDI) OCNGS - Draft Request for Additional Information Regarding Request to Revise ISFSI Only Emergency Plan April 5, 2021

3. US NRC Electronic Mail Request to Andrea Sterdis (HDI) Request for Additional Information Related to Request for Approval of Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan, April 8, 2021 HDI-OC-21-033 Page 11 of 11

Attachment 2 Updated Pages to the ISFSI Only Emergency Plan and Emergency Action Levels.

HDI-OC-21-033 (10 pages follow)

Procedure Number: Revision:

OYSTER CREEK ISFSI ONLY DPP-OC-EP-001 0 Use Category:

EMERGENCY PLAN (IOEP)

Reference Use Page 11 of 48 This position is the highest level of authority for the OCNGS Emergency Response Organization (ERO) and on-site emergency activities. This position is held by the ISFSI Shift Supervisor (ISS) or designated alternate. The ISS in the IOEP is equivalent to the Lead Security Shift Supervisor (LSSS) as defined in the ISFSI Only Security Plan.

3.1.11 Emergency Plan Implementing Procedure (EPIP)

Specific procedures describing actions taken by plant staff to activate and implement the IOEP.

3.1.12 Emergency Response Facility (ERF)

The ISFSI Security Supervisors Office is the facility that contains the communications equipment necessary for emergency conditions. It is operated under the direction of the Emergency Director and serves as the primary location for classification of the emergency, notification of the emergency to offsite agencies, assessment actions, and emergency action direction.

3.1.13 Emergency Response Organization (ERO)

Organization comprised of assigned individuals who would respond and assist during a classified emergency.

3.1.14 Fire Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires.

Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

3.1.15 Frequency That unit of time specified (monthly, quarterly, etc.) plus or minus 25 percent, unless otherwise specifically stated. This definition does not apply to "Annual" when it is related to the conduct of the Biennial Exercise. Biennial Exercises are performed within the calendar year.

3.1.16 Hostile Action An act toward the ISFSI or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land or water using guns, explosives, Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

Procedure Number: Revision:

OYSTER CREEK ISFSI ONLY DPP-OC-EP-001 0 Use Category:

EMERGENCY PLAN (IOEP)

Reference Use Page 19 of 48 5.2.1 Fire Department The primary fire response and support is from the Forked River Volunteer Fire Department (FRVFD). The fire department is located approximately 2 miles from OCNGS, allowing for a timely response. Three additional fire departments located within 7 miles of the facility can provide additional support as necessary. New Jersey requires Mutual Aid Plans to be in place for coordinated fire support within Ocean County.

5.2.2 Ambulance Service Arrangements are made for prompt ambulance transport of persons with injuries involving radioactivity to designated hospitals. Such service is available on a 24-hour per day basis and is confirmed by letter of agreements with Lacey Emergency Medical Service (EMS) and Lanoka Harbor EMS. Radiation monitoring services shall be provided by Oyster Creek whenever it becomes necessary to use the ambulance service for the transportation of contaminated persons.

5.2.3 Hospitals OCNGS establishes communications with Southern Ocean Medical Center or Community Medical Center via commercial telephone. An agreement is in place with both Southern Ocean Medical Center and Community Medical Center for medical treatment of patients from OCNGS who have Injuries complicated by radioactive contamination. The hospitals have trained personnel and detailed procedures for handling radioactively contaminated patients from OCNGS.

5.2.4 Law Enforcement Agencies Law enforcement support services are provided by the local law enforcement agency (LLEA), State, and Federal law enforcement authorities, as appropriate.

5.2.5 Nuclear Regulatory Commission In the event of an emergency at the OCNGS ISFSI, the NRC Operations Center in Rockville, Maryland will be notified immediately after notification of NJ OEM and other local responders and not later than 60 minutes after an emergency declaration or change in classification. Classification and radiological information are communicated to this office over a commercial phone line or via a wireless system from the OCNGS ISFSI Emergency Response Facility (ERF).

The NRC is the primary Federal agency providing coordination and support to the licensee in the event of an emergency at the OCNGS ISFSI. NRC responsibilities are directed toward a coordination of Federal efforts to provide assistance to the licensee and State and local governments in their planning and implementation of emergency preparedness procedures.

Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

Procedure Number: Revision:

OYSTER CREEK ISFSI ONLY DPP-OC-EP-001 0 Use Category:

EMERGENCY PLAN (IOEP)

Reference Use Page 22 of 48 In addition to the resources listed below, additional personnel resources may be directed to report to the OCNGS ISFSI by the Emergency Director to provide additional support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available from OCNGS staff and can be requested from various contractors.

6.2.1 Resource Manager The Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration. The Resource Manager will augment the Emergency Director by assisting in the assessment of the emergency condition and coordinating any required resources, including serving as the public information interface (until turnover to Corporate Public Affairs occurs). The Resource Manager does not need to physically report to OCNGS to perform the assigned responsibilities.

6.2.2 Augmented Responder For a declared emergency involving radiological consequences, a minimum of one person trained in radiological monitoring and assessment will report to the OCNGS ISFSI within four (4) hours of the emergency declaration.

6.2.3 Offsite Response Organizations Additional support is available from OROs, as described in Section 5.2 of this Plan.

6.3 Functional Responsibilities Table 6-1 lists the functional responsibilities that fulfill emergency staffing capabilities.

Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

Procedure Number: Revision:

OYSTER CREEK ISFSI ONLY DPP-OC-EP-001 0 Use Category:

EMERGENCY PLAN (IOEP)

Reference Use Page 41 of 48 ISFSI DBAs Review of applicable drill and exercise-identified deficiencies Personnel available during declared emergencies who may be called upon to perform emergency response activities as an extension of their normal duties receive duty-specific training. Additional emergency preparedness training is provided as part of annual access training.

19.1.2 First Aid Personnel First Aid training is provided to personnel assigned on-shift in accordance with site training and qualification plan. Personnel assigned the responsibility of first aid response will be trained with courses equivalent to Red Cross First Aid, CPR, or AED for Lay Responders or equivalent 19.1.2 Radiation Monitoring Personnel Radiation monitoring personnel shall have training conducted such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.

Use of Radiation Protection procedures Use of emergency survey equipment Communications Field Surveys Role of dose assessment in an emergency Monitoring of radioactive releases Protective actions for onsite personnel Review of applicable drill and exercise-identified deficiencies 19.1.4 Personnel Badged for Unescorted Access Personnel who are badged for unescorted access receive access training annually. Information pertaining to their safety and the safety of visitors under escort during a classified emergency is included in this training.

Access training shall include the following emergency preparedness topics:

Basic Emergency Plan and implementing preparedness topics Emergency classification levels Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

Procedure Number: Revision:

OYSTER CREEK ISFSI ONLY DPP-OC-EP-001 0 Use Category:

EMERGENCY PLAN (IOEP)

Reference Use Page 46 of 48 APPENDIX A EMERGENCY EQUIPMENT, SUPPLIES AND REFERENCE MATERIALS EMERGENCY RESPONSE FACILITY Procedures / Reference Materials ISFSI Only Emergency Plan ISFSI Only EAL Technical Bases Document Emergency Telephone Directory EPIPs Equipment Portable radiation monitoring instrument Portable emergency lighting Medical emergency response kit ONSITE LOCATIONS Equipment / Supplies Portable radiation and contamination monitoring instruments Contamination control supplies Decontamination control supplies Protective clothing, including respiratory protection Dosimeters Radiological postings and barricades Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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OYSTER CREEK ISFSI ONLY DPP-OC-EP-002 0 EMERGENCY ACTION LEVELS Use Category:

AND TECHNICAL BASES (IO EAL) Reference Use Page 13 of 25 CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.

Emergency Action Level (EAL): Refer to Section 3.3.

Emergency Classification Level (ECL): Refer to Section 3.1.

Initiating Condition (IC): Refer to Section 3.2.

HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) or its personnel that includes the use of violent force to destroy equipment, take Hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

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

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

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business.

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

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

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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OYSTER CREEK ISFSI ONLY DPP-OC-EP-002 0 EMERGENCY ACTION LEVELS Use Category:

AND TECHNICAL BASES (IO EAL) Reference Use Page 14 of 25 7.0 ATTACHMENTS Attachment 1: EAL Matrices Attachment 2: EAL Bases Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

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OYSTER CREEK ISFSI ONLY DPP-OC-EP-002 0 EMERGENCY ACTION LEVELS Use Category:

AND TECHNICAL BASES (IO EAL) Reference Use Page 16 of 25 Attachment 1 - EALs Matrices ALERT UNUSUAL EVENT Hazards and Other Conditions Affecting Facility Safety PD-HA1 HOSTILE ACTION is occurring or has PD-HU1 Confirmed SECURITY CONDITION or threat.

occurred.

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

1. A HOSTILE ACTION is occurring or has 1. Notification of a credible security threat directed occurred within the OWNER CONTROLLED at the site.

AREA as reported by the Security Shift OR Supervisor.

2. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.

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

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

Other conditions exist which, in the judgment of the Other conditions exist which in the judgment of the Emergency Director, indicate that events are in Emergency Director indicate that events are in progress or have occurred which involve an actual or progress or have occurred which indicate a potential substantial degradation of the level of safety potential degradation of the level of safety of the of the facility or a security event that involves probable facility or indicate a security threat to facility life-threatening risk to site personnel or damage to site protection has been initiated. No releases of equipment because of HOSTILE ACTION. Any radioactive material requiring offsite response or releases are expected to be limited to small fractions of monitoring are expected unless further degradation E mergen cy Di rector Jud gmen t the EPA Protective Action Guideline exposure levels. of equipment required for spent fuel cooling occurs.

Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful

Procedure Number: Revision:

OYSTER CREEK ISFSI ONLY DPP-OC-EP-002 0 EMERGENCY ACTION LEVELS Use Category:

AND TECHNICAL BASES (IO EAL) Reference Use Page 20 of 25 Attachment 2 - EAL Bases PD-HA1 Initiating Condition:

HOSTILE ACTION is occurring or has occurred.

Emergency Action Level (EAL):

1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor.

Basis:

This IC addresses the notification of an aircraft attack threat or an occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the facility and staff for a potential aircraft impact.

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

As time and conditions allow, these events require a heightened state of readiness by the facility staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The ALERT declaration will also heighten the awareness of Offsite Response Organizations (ORO),

allowing them to be better prepared should it be necessary to consider further actions.

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

§ 50.72.

EAL #1 Basis This EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the facility PROTECTED AREA.

Basis Reference(s):

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

2. Station Security Plan Attachment 2 - EAL Bases Holtec International Intellectual Property Contains Copyrighted Material - Unauthorized Use Is Unlawful