Text

Transmittal of Donald C. Cook Nuclear Plant, Emergency Plan, Revision 47
	ML22214A113
Person / Time
Site:	Cook
Issue date:	08/02/2022
From:	Scarpello M; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	AEP-NRC-2022-47
	Download: ML22214A113 (228)
	v • d • e

m INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant POWER"' One Cook Place Bridgman, Ml 49106 A unit ofAmerican Electric Power lndianaMichiganPower.com August 2, 2022 AEP-NRC-2022-4 7 10 CFR 50.54(q)(5) 10 CFR 50.4 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 Transmittal of Donald C. Cook Nuclear Plant, Emergency Plan Revision 47 Pursuant to 10 CFR 50.54(q)(5), Indiana Michigan Power Company, the licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, is providing, as the enclosure to this letter, Revision 47 of the CNP Emergency Plan, implemented on July 6, 2022.

There are no new or revised commitments in this letter. Should you have any questions, please contact me at (269) 466-2649.

Sincerely, h.{b1pL Michael K. Scarpello Regulatory Affairs Director KMH/rdw

Enclosure:

Donald C. Cook Nuclear Plant, Emergency Plan, Revision 47 c: R. J. Ancona - MPSC, w/o enclosure EGLE - RMD/RPS, w/o enclosure J. B. Giessner- NRC Region Ill NRC Resident Inspector, w/o enclosure R. M. Sistevaris - AEP Ft. Wayne, w/o enclosure J. E. Walcutt - AEP Ft. Wayne, w/o enclosure S. P. Wall - NRC, Washington D.C., w/o enclosure A J. Williamson - AEP Ft. Wayne, w/o enclosure

Enclosure to AEP-NRC-2022-47 DONALD C. COOK NUCLEAR PLANT EMERGENCY PLAN Revision 47

Page 1 of 226 0 DONALD C. COOK NUCLEAR PLANT EMERGENCY PLAN REVISION 47 UNITS 1 & 2 DOCKET NOS. 50-315 & 50-316 LICENSE NOS. DPR-58 & DPR-74 50.54(q):

--.::::: ____/ Date: 6-2. 22 Performed By - Michael Rennhack Date: i,/.2.i.../:2.0.21..

Date: G\8'd\t>\}

Emergency Preparedness Manager- Kevin Simpson Date: e-,{2,z/2,z Plant Operations Review Committee:

Approved: Kelly Ferneau / 4866 Date: 6/29/2022 PORC Chair Meeting Number Effective Date: 7/6/2022 CEP Rev47

Page 2 of 226 Page Intentionally Left Blank CEP Rev 47

Page 3 of 226 TABLE OF CONTENTS INTRODUCTION PAGE A. Purpose ......................................................................................................................... 11 B. Objective ....................................................................................................................... 11 C. Scope ............................................................................................................................ 11 D. Organization of the Emergency Plan ............................................................................. 11 E. Definitions ..................................................................................................................... 12 PLANNING STANDARDS PAGE A. ORGANIZATIONAL CONTROL 15 A.1 Organizational Control ....................................................................................... 16 A.2 Not Applicable .................................................................................................... 17 A.3 Agreements ....................................................................................................... 17 A.4 Continuous Protracted Operations ..................................................................... 17 B. EMERGENCY RESPONSE ORGANIZATION 19 B.1 Normal On-Site Operating Organization ............................................................. 20 B.2 On-Shift Emergency Coordination ...................................................................... 23 B.3 Emergency Coordination Line of Succession ..................................................... 23 B.4 Non-delegable Emergency Coordinator Duties .................................................. 23 B.5 Emergency Response Organization ................................................................... 24 B.5.a Technical Support Center ....................................................................... 24 B.5.b Operations Support Center ..................................................................... 28 B.5.c Emergency Operations Facility ............................................................... 30 B.5.d Emergency News Center/Joint Information Center ................................. 34 B.5.e Liaisons .................................................................................................. 36 B.6 Overall Organization and Communication .......................................................... 36 B.7 Plant Staff Augmentation ................................................................................... 36 B.8 Offsite Agencies and Organizations ................................................................... 37 B.9 Offsite Groups.................................................................................................... 38 C. EMERGENCY RESPONSE SUPPORT AND RESOURCES 53 C.1 Federal Radiological Assistance ........................................................................ 54 C.2 Liaisons ............................................................................................................. 55 C.3 Radiological Laboratories................................................................................... 56 C.4 Offsite Agencies and Organizations (non Governmental) ................................... 56 D. EMERGENCY CLASSIFICATION SYSTEM 58 D.1 Emergency Action Levels................................................................................... 59 D.2 Initiating Conditions............................................................................................ 60 CEP Rev 47

Page 4 of 226 E. NOTIFICATION METHODS AND PROCEDURES 78 E.1 Notification of Offsite Response Organizations .................................................. 79 E.2 ERO Alert, Notification and Mobilization ............................................................. 80 E.2.a Onsite (Plant Staff) ................................................................................. 80 E.2.b Offsite (Plant Staff) ................................................................................. 81 E.3 Content of Initial Emergency Messages ............................................................. 82 E.4 Content of Follow-up Emergency Messages ...................................................... 82 E.5 Not Applicable (State and Local Public Information System) .............................. 82 E.6 Public Notification .............................................................................................. 82 E.7 Public Information Messages ............................................................................. 83 F. EMERGENCY COMMUNICATIONS 87 F.1 Licensee, Local, State, and NRC Emergency Communications ......................... 88 F.2 Medical Support Communications ...................................................................... 91 F.3 Communications Systems Testing ..................................................................... 91 G. PUBLIC EDUCATION AND INFORMATION 93 G.1 Public Information .............................................................................................. 94 G.2 Distribution of Public Information ........................................................................ 94 G.3 Emergency News Center/Joint Information Center............................................. 95 G.4 ENC/JIC Spokespersons and Public Inquiry ...................................................... 95 G.5 Annual Media Briefing ........................................................................................ 95 H. EMERGENCY FACILITIES AND EQUIPMENT 96 H.1 Technical Support Center (TSC) ........................................................................ 97 H.2 Emergency Operations Facility (EOF) .............................................................. 100 H.3 Operations Support Center (OSC) ................................................................... 102 H.4 AEP Emergency Organization Staffing and Activation ..................................... 103 H.5 Emergency Detection ....................................................................................... 104 H.6 Offsite Monitoring and Analysis Equipment ...................................................... 108 H.7 Radiological Environmental Monitoring ............................................................ 109 H.8 Meteorological System ..................................................................................... 109 I. ACCIDENT ASSESSMENT 114 I.1 Release Identification and Event Classification ................................................ 115 I.2 Radiation Monitoring System ........................................................................... 115 I.3 Release Source Term and Magnitude Determination ....................................... 115 I.4 Dose Assessment Evaluation .......................................................................... 116 I.5 Meteorological Assessment ............................................................................. 117 I.6 Not Addressed ................................................................................................. 117 I.7 Radiological Field Monitoring ........................................................................... 117 I.8 Liquid and Gaseous Release Assessment ....................................................... 117 I.9 Off-site Radioiodine Monitoring ........................................................................ 117 I.10 Not Addressed ................................................................................................. 117 CEP Rev 47

Page 5 of 226 J. PROTECTIVE RESPONSE 118 J.1 Owner Controlled Area Warning and Advisement ......................................... 119 J.2 Evacuation Routes ........................................................................................... 119 J.3 Evacuee Monitoring ......................................................................................... 120 J.4 Evacuee Decontamination ............................................................................... 120 J.5 Personnel Accountability .................................................................................. 120 J.6 Protective Measures for Those Remaining, or Reporting to the Site ................ 121 J.7 Off-Site Protective Actions ............................................................................... 122 J.8 Evacuation Times ............................................................................................ 122 J.9 Not Applicable .................................................................................................. 122 J.10 Plume Exposure Pathway Protective Measures Implementation ...................... 123 K. RADIOLOGICAL EXPOSURE CONTROL 125 K.1 Emergency Exposure ....................................................................................... 127 K.2 Emergency Exposure Authorization and Control .............................................. 127 K.3 Emergency Personnel Dosimetry ..................................................................... 127 K.4 Not Applicable .................................................................................................. 128 K.5 Decontamination .............................................................................................. 128 K.6 Contamination Control ..................................................................................... 128 K.7 Decontamination of Relocated Onsite Personnel ............................................. 129 L. MEDICAL AND PUBLIC HEALTH SUPPORT 131 L.1 Offsite Medical Support .................................................................................... 132 L.2 Onsite Medical Support .................................................................................... 133 L.3 Not Applicable .................................................................................................. 133 L.4 Victim Transport ............................................................................................... 133 M. RECOVERY AND RE-ENTRY PLANNING AND POST ACCIDENT OPERATIONS 134 M.1 Reentry and Recovery ..................................................................................... 135 M.2 Not Addressed ................................................................................................. 136 M.3 Recovery Initiation Notification ......................................................................... 136 M.4 Not Addressed ................................................................................................. 136 N. EXERCISES AND DRILLS 137 N.1 Exercises ......................................................................................................... 138 N.2 Drills................................................................................................................. 138 N.3 Drill and Exercise Execution ............................................................................ 139 N.4 Official Observation and Critique...................................................................... 140 N.5 Results Evaluation and Corrective Actions ....................................................... 140 O. RADIOLOGICAL EMERGENCY RESPONSE TRAINING 141 O.1 Organization Training ....................................................................................... 142 O.2 Onsite ERO Training ........................................................................................ 142 O.3 First Aid Team Training .................................................................................... 142 O.4 ERO Training and Qualification ........................................................................ 142 O.5 Initial and Annual Retraining ............................................................................ 144 CEP Rev 47

Page 6 of 226 P. RESPONSIBILITY FOR PLANNING EFFORT 145 P.1 Emergency Planner Training ............................................................................ 146 P.2 Emergency Plans Administration Responsibility ............................................... 146 P.3 Emergency Planning Coordinator Designation (Not Addressed) ...................... 146 P.4 Periodic Reviews, Updates, and Audits............................................................ 146 P.5 Emergency Plan Change Communication ........................................................ 146 P.6 Emergency Response Organization Support Plans.......................................... 147 P.7 Implementing Procedures ................................................................................ 147 P.8 Table of Contents & Cross-reference ............................................................... 147 P.9 Independent Emergency Program Review ....................................................... 147 P.10 ERO Telephone Number Updates ................................................................... 147 CEP Rev 47

Page 7 of 226 APPENDICES A. 1. Index of Emergency Plan Implementing Procedures ........................................ 149

2. Cross Reference CEP and Emergency Plan Implementing Procedures ........... 150 B. Agreements with Off-Site Support Agencies ................................................................ 156 C. Emergency Kits and Equipment Locations .................................................................. 179 D. Emergency Preparedness Brochure ............................................................................ 181 E. Description of Federal Radiological Assistance ........................................................... 195 F. Berrien County Road Map ........................................................................................... 203 G. Population Distribution ................................................................................................ 205 H. Radiological Response Support Service Capabilities................................................... 207 I. Notification of American Nuclear Insurers .................................................................... 209 J. Eight Year Plan Matrix ................................................................................................. 213 K. Agreements with Off-Site Agencies, Hazardous Material Spills ................................... 216 CEP Rev 47

Page 8 of 226 LIST OF FIGURES Figure TITLE Section Page

1. Michigan Nuclear Accident Response Organization A 18

2. Management Structure of the Nuclear Generation Group B 44

3. Site Operations B 45

4. On Shift Emergency Response Organization B 46

5. TSC Organization B 47

6. OSC Organization B 48

7. EOF Organization B 49

8. CNP Emergency News Center/

Joint Information Center Organization B 50

9. Nuclear Incident Initial Notification Process E 85

10. CNP Emergency Response Communications Flow E 86

11. Locations of Emergency Response Centers H 111

12. CNP Emergency Response Center Locations H 112

13. Primary Evacuation Routes J 124

14. Accident Notification Procedures for ANI Insurers Appendix I 212 CEP Rev 47

Page 9 of 226 LIST OF TABLES Table TITLE Section Page

1. Cook Nuclear Plant Minimum Staffing for Nuclear Power Plant Emergencies B 51

2. EAL Initiating Conditions - Mode 1-4 D 61

3. EAL Initiating Conditions, Mode 1-6 & Defueled D 66

4. EAL Initiating Conditions, Modes 5-6 & Defueled D 73

5. Critical NUREG 0737 Parameters H 113

6. Maximum Allowable Contamination Limits for On Site Facilities Used by the Public K 130 CEP Rev 47

Page 10 of 226 INTRODUCTION Introduction CEP Rev 47

Page 11 of 226 INTRODUCTION A. Purpose The purpose of the Cook Nuclear Plant Emergency Plan is to fulfill the requirements as set forth in 10 CFR 50, Appendix E, and the planning objectives set forth in NUREG-0654/FEMA-REP-1.

B. Objective The Cook Nuclear Plant Emergency Plan has the fundamental objective of protecting the health and safety of the general public, persons temporarily visiting or assigned to the reactor facility, and employees of the plant.

C. Scope The specific details for the implementation of this emergency plan are incorporated in the Cook Nuclear Plant Emergency Plan Procedures pursuant to the requirements specified in Purpose, above. The Cook Nuclear Plant Emergency Plan applies to both of the nuclear units and the on-site Independent Spent Fuel Storage Installation (ISFSI). The Emergency Plan procedures include or reference procedures developed for plant operating, radiological, security, and administrative functions as necessary to ensure that all requirements are adequately defined. Appendix A to this Plan contains a list of Plant Emergency Plan Procedures. This plan is primarily concerned with an accidental release of radioactive material, but it is also concerned with major non-nuclear accidents which could prove hazardous to the safe operation of the plant. This includes supplementing our procedures for responding to hazardous material spills to meet Michigan Hazardous Waste Operations and Emergency Response (HAZWOPER) and hazardous waste regulations.

D. Organization of the Emergency Plan The information describing the D.C. Cook Nuclear Power Plant Emergency Plan follows the numerology of NUREG-0654/FEMA-REP-1.

The organization of NUREG-0654/FEMA-REP-1, sequences evaluation criteria by subject. Some criteria apply to licensee only, and some apply to offsite organizations only.

The result is that there would be gaps in the Emergency Plan numbering if the licensee only criteria were listed. When this occurs the NUREG numbering is maintained by listing the criteria number and labeling it as Not Applicable.

Some criteria in the Emergency Plan are not addressed. Again, to maintain the NUREG numbering the criteria is listed but is labeled as Not Addressed.

Introduction CEP Rev 47

Page 12 of 226 E. Definitions

1. Berrien County Emergency Operations Center (BCEOC) This facility provides an area to coordinate efforts of local agencies and organizations involved in the emergency response. It is a center established and controlled by the Berrien County Sheriffs Department and is located in Benton Harbor, Michigan.

2. Civil Disturbance One or more persons violently protesting plant operations or activities at the site.

3. Confinement Boundary The barrier(s) between areas containing radioactive substances and the environment.

4. Control Rooms Control and monitoring functions for Units 1 and 2 are provided for in separate Control Rooms. Each Control Room has a controlled access entrance located off the turbine building main operating floor at Elevation 633. Personnel assigned to the Control Room during the emergency will be as indicated in Figure 4 (until the Technical Support Center is activated).

Should conditions require the presence, in the Control Room, of personnel other than those listed in Figure 4, approval must be obtained from the Shift Manager or his alternate.

5. Cook Nuclear Plant Procedures Documents defining the details necessary to specify manipulation of controls and equipment to place the facility in a safe condition and to prescribe other appropriate protective measures to be taken by employees of the licensee.

6. Emergency Action Levels Radiation dose rates; specific levels of airborne, waterborne, or surface-deposited concentrations of radioactive materials; or specific instrument indications (including their rates of change) that may be used as thresholds for designating the appropriate class of emergency.

7. Emergency News Center (ENC) The Emergency News Center is located in the Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the Plant in Buchanan, Michigan. This facility will provide for dissemination of emergency information to the news media prior to activation of the Joint Information Center.

8. Emergency Operations Facility (EOF) This facility is in the Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the Plant in Buchanan, Michigan. This facility is activated at the declaration of an Alert, or higher, emergency classification. The EOF houses the support personnel whose primary responsibilities are to assist in offsite dose assessment and protective action recommendations, communication with offsite agencies, exposure control, technical support of plant operations and other related activities. Representatives from various support agencies and groups may use this facility as a working space to prepare short and long term plans and procedures to mitigate the incident.

9. Emergency Plan Implementing Procedures (EPIPs) The specific procedures that provide instructions, identify responsibilities, and implement the emergency plan.

A list of Emergency Plan Procedures is contained in Appendix A.

Introduction CEP Rev 47

Page 13 of 226

10. HAZMAT Team The hazardous material spill response team (HAZMAT Team) is a group of plant personnel designated to respond to emergencies involving hazardous materials. They are trained as required by Michigan Hazardous Waste Operations and Emergency Response (HAZWOPER) rules and respond to emergencies using spill pre-plan procedures. The Shift Manager, or a qualified Incident Commander, will act as the Incident Commander in charge of the plant spill response. A designated HAZMAT Team Safety Officer will have responsibility for the on-scene safety of response personnel.

11. Hostile Action An act toward a Nuclear Power Plant (NPP) or its personnel that includes the use of violent force to destroy equipment, takes 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 or ISFSI. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area.)

12. Hostile Force One or more individuals who are engaged in determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

13. 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.

14. Joint Information Center (JIC) This facility is operated by AEP personnel for the purpose of disseminating information to the news media, conducting press briefing and as an area where the representatives from various emergency response organizations can meet, review, and release material to the press. The JIC uses the same facilities as the Emergency News Center (ENC).

15. NRC Licensed Personnel Those plant personnel holding current operators or senior operators licenses from the United States Nuclear Regulatory Commission as defined in 10 CFR Part 55.

16. Off-Site means outside the area which is under the control of Cook Nuclear Plant.

17. Off-Site Survey Teams These are teams of personnel assigned to monitor radiological parameters anywhere outside of the plant protected area or the ISFSI protected area. At least one member of the team shall be trained in radiation protection.

18. On-Site defined as the owner controlled area inclusive of the protected area and all property outside the plant protected and ISFSI protected areas but under the control of Cook Nuclear Plant.

19. Operations Support Center (OSC) This area is located in the basement/shelter area of the plants lakeside office building. The OSC is the area that will house the operations support personnel for assignment to respond to Control Room and Technical Support Center requests. Communication links are established as needed with the Control Rooms, Technical Support Center and the Emergency Operations Facility.

Introduction CEP Rev 47

Page 14 of 226

20. Protected Area The area encompassed by physical barriers to control access to the plant and to the ISFSI.

21. Protective Action Guides (PAG) The projected dose to an individual from an unplanned release of radioactive material at which a specific protective action to reduce or avoid that dose is recommended. Protective actions would be warranted provided the reduction in individual dose expected to be achieved by carrying out the protective action is not offset by excessive risks to individual safety in taking the protective action. The PAG does not include the dose that has unavoidably occurred prior to the initiation of a protective action.

22. State Emergency Operations Center (SEOC) This facility provides a central location from which the emergency functions of state government may be carried out in response to emergency conditions. The primary State EOC is located at 7150 Harris Drive, Dimondale, MI 48821.

23. State Field Team Center (FTC) This facility provides the operational working area for State representatives assigned to coordinate the dispatch of field teams to monitor for radioactive contamination. The facility will be directed by a Field Team Center Coordinator assigned by the Michigan Department of State Police/Emergency Management and Homeland Security Division. A representative of the Department of Environmental Quality/Drinking Water and Radiological Protection Division will be assigned to this facility as the Radiological Monitoring Team Leader. The location for the FTC is the Michigan Department of Transportations Coloma garage at the intersection of Red Arrow Highway and I-196.

24. Technical Support Center (TSC) This facility is located in the northeast corner of the protected area boundary. This center is physically separated from both Control Rooms. This facility has communication links to each Control Room, to the Emergency Operations Facility, Emergency News Center/Joint Information Center, Operations Support Center and offsite emergency operations centers established by State/County authorities. This area contains access to instrumentation and necessary reference material for plant management and support personnel.

The primary function of the TSC is to provide an area in close proximity to the Control Room from which plant operators can receive technical support and assistance from personnel who have the experience and expertise in nuclear plant operations, maintenance, safety and design. Their function is to mitigate the cause(s) of a nuclear incident and act as a data gathering center for plant parameters.

Access to the TSC will typically be limited immediately to those individuals listed in Figure 5, TSC Organization and as the situation demands, those individuals required by the SED or alternate.

Introduction CEP Rev 47

Page 15 of 226 PLANNING STANDARD A ORGANIZATION CONTROL Planning Standard A CEP Rev 47

Page 16 of 226 A. ORGANIZATIONAL CONTROL A.1. Organizational Control In order for any emergency plan to be effective it is necessary to ensure that every organization that provides support services has prepared in advance an emergency plan and/or procedures.

These plans and/or procedures should define the individual responsibilities for coordinating and directing support effort and the level of response each organization is prepared to make to meet its defined response capability on a continuous basis.

Assistance from private organizations having nuclear industry affiliations can also be expected and are identified in Section C.4.

A.1.a. Response Organizations Descriptions of the primary response organizations and their operational roles are outlined in Section B. The state column of Figure 1 shows the Primary Response Agencies and Support Response Agencies that comprise the State of Michigan's nuclear accident response organization. The Primary Response Agencies and their duties are performed at the State Emergency Operations Center (SEOC). The Support Response Agencies are the resources available to the SEOC for implementing actions in response to an emergency.

A.1.b. Concept of Operations In the event of an emergency situation, the Shift Manager (or Senior NRC licensed individual) will call upon any additional members of the plant organization as needed. These additional individuals form, along with the on-duty operating shift, the plant Emergency Response Organization. The initiation of any aspects of this emergency plan allows for the use of the total plant organization, at the discretion of the Shift Manager.

The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan Organization are delineated in Table 1.

The extent to which the Emergency Response Organization is staffed will be dependent upon the emergency classification and the discretion of the Site Emergency Director (SED). For an Unusual Event, only the Control Room will be staffed. For an Alert, Site Area Emergency, and General Emergency the TSC, OSC, ENC/JIC, and EOF will be activated and staffed.

Senior plant management and technical personnel representing the licensee and the NRC are located in the TSC. TSC personnel will provide support to the Control Room operating personnel in the management of abnormal conditions and in accident mitigation. During recovery operations the TSC provides plant systems support for the management personnel located in the EOF. The TSC functions as the primary information source to the EOF and to the NRC on plant status.

The Operations Support Center (OSC) is an onsite assembly area separate from the Control Room and the TSC where licensee operations support personnel report in an emergency. This is an assembly area for personnel to report for instructions from the OSC Manager. Communications are provided to the Control Room, TSC, and EOF on bridge lines. Teams are dispatched from the OSC to provide for Damage Control, Rescue, and Surveys.

Planning Standard A CEP Rev 47

Page 17 of 226 The EOF will provide current information on conditions potentially affecting the public to the NRC, state and county emergency response agencies. Radiological assessment, determination of recommended public protective actions and coordination of offsite response will be transferred to the EOF once the EOF is activated. EOF personnel coordinate the offsite radiological monitoring during nuclear emergencies and recovery operations. The EOF will function as the post-accident recovery management center for both onsite and offsite activities.

The CNP Emergency Public Information Organization is structured to provide a correct and consistent flow of information to the public and the news media throughout an emergency at CNP.

During the initial phases of any emergency, all public information relating to the emergency will be released via the Emergency News Center. The ENC becomes the JIC when the State of Michigan declares the JIC operational.

A.1.c. Organization Interrelationships The relationships between Cook Nuclear Plant normal operating and Emergency Response Organizations are presented in numbered Figures 1 through 8. The figures are referenced throughout this Emergency Plan, and in Planning Section B, the Onsite Emergency Organization.

A.1.d. Persons in Charge The Emergency Director (ED) is responsible for control and coordination of all Cook Nuclear Plant emergency and recovery operations.

A.1.e. 24 Hour Response The CNP Emergency Response Organization (ERO) is capable of continuous 24-hour operations for a protracted period.

A.2. Not applicable A.3. Agreements The CNP Emergency Plan provides for agreements with various offsite support organizations that are part of the overall response organization within the Plume Exposure Pathway Emergency Planning Zone. These agreements are listed in Appendix B to this plan.

In addition to the offsite support agencies listed in Appendix B, it is assumed that assistance will be provided, as necessary, by those State, County and Federal agencies that are mandated by their charter, public law or regulations to protect the public health and safety, i.e., the NRC and FEMA. It is not expected that letters of agreement are required with these agencies.

A.4. Continuous Protracted Operations The CNP Emergency Response Organization (ERO) is capable of continuous 24-hour operations for a protracted period.

Planning Standard A CEP Rev 47

Page 18 of 226 FIGURE 1 MICHIGAN NUCLEAR ACCIDENT RESPONSE ORGANIZATION FEDERAL STATE Federal Emergency Management PRIMARY RESPONSE AGENCIES Agency Nuclear Regulatory Commission State Police Environmental Quality Department of Energy Direction, Control & Monitoring & Sampling Federal Coordination Coordination Technical Advice Resource Support Evacuation Authority Decontamination Advice Technical Advice Warning/Notification Occupational Health Security Medical & Health Support PLANT OWNER/OPERATOR Damage Assessment Accident & Dose Site Emergency Response Organization Public Information Assessment Notification In-place Shelter Radiological Exposure Onsite Control Local Plans Control Terrorist Activities Protective Actions LOCAL Federal Liaison Ground Water Military Weapon Accident Municipal Water Supplies Public Works Health Fire Berrien County SUPPORT RESPONSE AGENCIES Social Services Sheriffs Department Agriculture Licensing and Reg Affairs Warning Food Contamination Public Utilities Liaison Evacuation Food Supply Energy Disruption Sheltering Sampling Blockading Corrections Education Public Information Re-entry Temporary Housing Housing Transportation Assist. Mass Transportation Feeding and Clothing Support Community Health Military Affairs Crisis Counseling Transportation Temporary Housing Security Aerial & Ground Monitoring Support Natural Resources Human Services Environmental Impact Housing/Registration Fish/Game Contamination Feeding and Clothing Sampling Assistance Centers Warning Support Volunteer Agency Support Meteorological Analysis Surface Water Transportation Transportation - Railroads - Air Traffic Traffic Regulations Blockade Planning Standard A CEP Rev 47

Page 19 of 226 PLANNING STANDARD B EMERGENCY RESPONSE ORGANIZATION Planning Standard B CEP Rev 47

Page 20 of 226 B. EMERGENCY RESPONSE ORGANIZATION The purpose of this section is to describe the CNP organization during normal operations and during emergencies. Figure 2 shows the management structure for the Nuclear Generation Group (NGG). The Senior Vice President is the primary interface with local and state officials in matters concerning emergency preparedness.

B.1 Normal On-Site Operating Organization The normal on-site operating organization chart for the CNP is shown in Figure 3.

B.1.a. Vice Presidents The Chief Nuclear Officer (CNO) is responsible for implementing all activities at the CNP in accordance with all applicable laws, regulations, AEP and NGG policies while meeting the business needs of AEPNGG.

The Site Vice President (SVP) has the full authority and responsibility for operating, maintaining, and modifying the plant within established parameters and procedures. These responsibilities include ensuring effective implementation of the radiation protection program, directing the production, safety, work control and outage activities and Site Protective Services, and organizational/administrative activities at the plant. Additionally, the SVP is responsible for oversight of the Security Plan, Emergency Plan, and is responsible for integration of the emergency response and security functions.

B.1.b. Plant Manager The Plant Manager is accountable to the Site Vice President for the operations, maintenance, radiation protection, chemistry and environmental functional areas of plant production. The primary responsibility for the Plant Manager is the safe operation of the nuclear facility in accordance with applicable corporate policies, laws, regulations, licenses, and technical requirements, to ensure that public health and safety, including that of employees, is protected from undue nuclear and industrial safety risks.

B.1.c. Maintenance Manager The Maintenance Manager reports to the Plant Manager and is accountable for managing and directing the activities related to the maintenance of all site equipment, structures, grounds and yards, and fire protection program. Managers that report to the Maintenance Manager provide the tools and support services necessary to optimize the safe, environmentally sound, cost effective efforts of the plant production organizations.

B.1.d. Emergency Preparedness Manager The Emergency Preparedness Manager ensures that the on-site and off-site emergency preparedness programs can protect the health and safety of the general public and site personnel while minimizing damage to the property and the environment in the event of an emergency. The Emergency Preparedness Manager is accountable to the Site Vice President.

B.1.e. Nuclear Regulatory Compliance and Licensing Director The Nuclear Regulatory Compliance and Licensing Director is accountable to the Site Vice President and is responsible for developing and directing the access authorization and fitness for duty programs.

Planning Standard B CEP Rev 47

Page 21 of 226 B.1.f. Security Manager The Security Manager is accountable to the Site Vice President and is responsible for developing and directing the nuclear security program.

B.1.g. Training Manager The Training Manager reports to the Site Vice President and is accountable for the maintenance of INPO accreditation for eligible training programs, as well as non-accredited programs. This includes managing the development and presentation of training materials; maintenance of training materials, inclusive of the plant simulator and training aids; maintenance of training records and methods for assessing training effectiveness.

B.1.h. Operations Manager The Operations Manager reports to the Plant Manager and is accountable for operating the nuclear generating units in a safe, environmentally sound, cost effective, reliable and efficient manner in accordance with applicable corporate policies, laws, regulations, licenses, and technical requirements. The primary responsibility of the Operations Manager is the safe operation of the generation units to ensure that the public health and safety, including those of employees, is protected from undue industrial and nuclear safety risks.

B.1.i. Chemistry Manager The Chemistry Manager reports to the Plant Manager and is accountable for all activities related to plant system chemistry sampling, analysis, and control operations at CNP by optimizing fission product barrier effectiveness, maximize the life of plant equipment, and protect the health and safety of the public.

B.1.j. Radiation Protection Manager The Radiation Protection Manager, who is accountable to the Plant Manager, serves as the regulatory Radiation Protection Manager. The Radiation Protection Manager is responsible for the implementation and maintenance of the radiation protection programs. As such, the function of the Radiation Protection Manager is to establish and maintain the highest level of radiological safety attainable for the protection of plant employees, the public, and the environment.

B.1.k. On-Shift Operations Personnel The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan Organization are delineated in Table 1, CNP Staffing for Radiological Emergencies. Figure 4 is the chart for the On-shift Response Organization.

The Shift Manager, acting as the SED, has overall responsibility for directing and implementing emergency and abnormal procedures to bring the unit to a safe condition. The Shift Manager retains the Emergency Direction and Control functions until relieved by a qualified Site Emergency Director (SED) or Emergency Director (ED). This position is the Table 1 on-shift column Shift Manager position for the Emergency Direction and Control functional area and plant operations functional area.

One of the two Unit Supervisors on shift aids and assists the Shift Manager. This position is the Table 1, CNP Staffing for Radiological Emergencies, on-shift plant operations functional area Unit Supervisor.

Planning Standard B CEP Rev 47

Page 22 of 226 The Work Control SRO reports to the Control Room in the event of an emergency to assist the Operations shift. The Work Control SRO provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, On-shift plant operations functional area Assistant Shift Manager/WCC-SRO.

One of the Reactor Operators provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area On-Shift Offsite Dose Assessment until relieved of that responsibility by the EOF.

Two of the Auxiliary Equipment Operators (AEOs) provide staffing of the Table 1, CNP Staffing for Radiological Emergencies, Notification/Communication functional area until relieved of that responsibility by the EOF. An additional AEO performs the plant system engineering, repair and corrective actions functional area repair and corrective actions Rad Waste Operator as part of the normal AEO duties.

The on-duty Shift Technical Advisor (STA) reports to the Control Room in the event of an emergency. The STA function is monitoring the Critical Safety Function Status Trees and recommending necessary procedure transitions. The Core/Thermal Hydraulic conditions are monitored by the Critical Safety Function Status Trees. The STA provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Plant System Engineering, Repair and Corrective Actions functional area On-Shift Core/Thermal Hydraulics and STA Technical Support. The STA reports to the SM and acts in an advisory capacity. Other STAs called in will report to the TSC, as needed.

B.1.l. On Shift non-Operations (Supplemental) Personnel The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan Organization are delineated in Table 1, CNP Staffing for Radiological Emergencies. Figure 4 is the chart for the On-shift Response Organization.

Three RP Technicians (RPT) are assigned to each shift to provide the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area On-Shift Offsite, Onsite, and In-plant surveys. They also provide Protective Actions functional area On-Shift Radiation Protection coverage. The on-shift RP Technician staffing is augmented with an on-shift Chemistry Technician and ten (10) RP Technicians called in for 60 minute supplemental staffing.

Two Chemistry Technicians are assigned to each shift to provide the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area On-Shift Chemistry positions making expertise immediately available to address chemistry issues.

The on-shift Chemistry staffing is augmented with one (1) Chemistry technician called in for 60 minute supplemental staffing.

The I & C Technician assignment along with an AEO ensures the plant system engineering repair and corrective actions functional area On-Shift Repair and Corrective Actions maintenance disciplines expertise are immediately available to address maintenance issues. The on-shift Maintenance staffing is augmented with a combination of the following: I&C Technician/Electrician, additional Electricians, and Mechanics called in for 60 minute supplemental staffing.

Planning Standard B CEP Rev 47

Page 23 of 226 The Fire Brigade provides the staffing for the On-Shift Fire Protection Functional Area and the Rescue and First Aid functional area. The brigade shift staffing is maintained as specified in the Technical Requirements Manual. Staffing for sixty minute response is provided by supporting local fire departments.

The Security force provides the staffing for the On-Shift and 60 minute Access Control and Accountability Functional Area. Security staffing is maintained as specified in the Security Plan.

B.2. On-Shift Emergency Coordination The Shift Manager, acting as the SED, has overall responsibility for directing and implementing emergency and abnormal procedures to bring the unit to a safe condition.

B.3. Emergency Coordination Line of Succession The authority for initiation of the Emergency Plan is delegated to the senior supervisor of the on-duty operating shift (e.g., the Shift Manager).

Upon the classification of an emergency event, the Shift Manager (SM) assumes the position of Site Emergency Director (SED). The Shift Manager retains the Emergency Direction and Control functions until relieved by a qualified Site Emergency Director (SED) or Emergency Director (ED).

Upon arrival at the appropriate emergency response facility, the SED and/or ED reviews the emergency situation with the Shift Manager, assumes the responsibilities for overall management of plant and emergency response functions, and assures that proper actions are being taken to mitigate the event. The SED or ED ensures that the proper State/County authorities, NRC and AEP officials are notified.

The SED will function as acting Emergency Director until such responsibilities are assumed at the EOF.

Upon activation of the EOF the Emergency Director reviews the emergency situation with the SED and assumes responsibility for control and co-ordination of all emergency and recovery operations from the SED.

B.4. Non-delegable Emergency Coordinator Duties During the initial phase of a nuclear incident prior to activation of the EOF, the SED has the non-delegable responsibility to make Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures.

Upon activation of the EOF the Emergency Director assumes the non-delegable responsibility for making Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures.

Planning Standard B CEP Rev 47

Page 24 of 226 B.5 Emergency Response Organization The CNP Emergency Response Organization is presented in Figures 4 through 8.

Every effort is made to match professional skills with those needed in the ERO positions listed on Figures 4 through 8. However, there may be some instances where, in actual assignments, the professional skill description may not match those listed with their respective position. In such cases, the individual in question has been determined to effectively fulfill the requirements of the position through training and qualification for the ERO staff position or because of similar current, or past professional experiences or duties.

All positions are assigned common administrative responsibilities such as event response and maintaining adequate documentation of the event tasks. Individual tasks for each ERO position are as follows:

B.5.a. Technical Support Center (TSC)

The TSC Emergency Response Organization is presented in Figure 5.

B.5.a.1. Site Emergency Director (SED)

The SED is assigned the following responsibilities:

Coordinate response activities with offsite response agencies Coordinate ERO/facility shift turnover Assume/maintain command and control Transfer command and control Manage all onsite emergency response activities Request and coordinate emergency activities with law enforcement agencies Coordinate information and activities with offsite agency personnel in the facility Develop requests for external assistance (technical, craft, admin, etc.)

Approve material, personnel and logistics expenditures necessary for response to the event Classify and declare emergencies Approve and direct offsite emergency notifications to state and local authorities Direct notifications and ENS communications with the NRC Ensure flow of information within and between the emergency response facilities Perform or direct emergency PA announcements Direct preparations and brief personnel prior to facility activation Direct relocation of site emergency response facilities Establish plant/station response priorities Determine and direct the actions for mitigation strategies and contingency plans Coordinate between CR, OSC and TSC to set OSC Team task priorities Direct site assembly, accountability and search & rescue activities Direct local and site evacuation Coordinate site evacuation Approve use of KI Approve Protective Action Recommendations to offsite authorities Approve emergency exposures Terminate the emergency event Develop recovery plans Planning Standard B CEP Rev 47

Page 25 of 226 Authorize and direct extreme measures (FLEX, EDMG, SAMG, §50.54(x) or suspend security controls)

Conduct facility briefs and updates In addition to these immediate duties noted above, the SED also has the authority to make policy decisions and expend funds necessary to cope with the event.

B.5.a.2. TSC Manager The TSC Manager is assigned the following responsibilities; Coordinate ERO/facility shift turnover Manage facility emergency response activities Manage assigned group emergency response activities Coordinate information and activities with offsite agency personnel in the facility Coordinate integration of the NRC site team Develop requests for external assistance (technical, craft, admin, etc.)

Assist with emergency classification Ensure flow of information within and between the emergency response facilities Perform or direct emergency PA announcements Direct preparations and brief personnel prior to facility activation Ensure minimum staff is available and prepared to activate the facility Activate the facility Determine current/projected staff needs Support coordination of site emergency facility relocation Establish plant/station response priorities Coordinate between CR, OSC and TSC to set OSC Team task priorities Establish and maintain facility accountability Coordinate site evacuation Develop recovery plans Conduct facility briefs and updates B.5.a.3. ENS Communicator The ENS Communicator is assigned the following responsibility; Provide event data and plant information to the NRC via the ENS B.5.a.4. TSC Communicator The TSC Communicator is assigned the following responsibilities; Communicate on assigned communication line and provide key information to facility staff Provide operations or radiological data to ERO members (loss of PPC/PSS)

Maintain status and information boards B.5.a.5. CR Communicator (located in the CR)

The CR Communicator is assigned the following responsibilities; Communicate on assigned communication line and provide key information to facility staff Provide operations or radiological data to ERO members (loss of PPC/PSS)

Planning Standard B CEP Rev 47

Page 26 of 226 B.5.a.6. Plant Evaluation Team The Plant Evaluation Team (PET) is made up of individuals from; Engineering - Nuclear Fuels Group Engineering - Electrical or Instrumentation and Control Engineering - Mechanical Operations or Operations Training The PET are assigned the following responsibilities:

PET -

Operations PET -

Reactor PET -

Electrical PET -

Mechanical Monitor status of the Emergency Operations Procedures X Assist with emergency classification X Support completion of the Emergency Notification Form to state and X

local authorities Provide event data and plant information to the NRC via the ENS X Provide operations or radiological data to ERO members (loss of X

PPC/PSS)

Communicate with ICP to provide information and coordination X Provide support for development of mitigation strategies and X X X X contingency plans Provide support for accident detection, assessment and response X X X X priorities Provide analysis of core damage and fission product release potential X X Coordinate between CR, OSC and TSC to set OSC Team task X

priorities Evaluate conditions and provide recommendations for PARs X Analyze and develop extreme measures actions (FLEX, EDMG, X X X X SAMG, §50.54(x))

B.5.a.7. Maintenance Coordinator The Maintenance Coordinator is assigned the following responsibilities; Ensure flow of information within and between the emergency response facilities Provide support for development of mitigation strategies and contingency plans Coordinate between CR, OSC and TSC to set OSC Team task priorities Participate with OSC Team dispatch and control B.5.a.8. Radiological Assessment Coordinator (RAC)

The RAC is assigned the following responsibilities:

Manage assigned group emergency response activities Assist with emergency classification Provide operations or radiological data to ERO members (loss of PPC/PSS)

Communicate with ICP to provide information and coordination Determine current/projected staff needs Support coordination of site emergency facility relocation Provide support for development of mitigation strategies and contingency plans Planning Standard B CEP Rev 47

Page 27 of 226 Provide support for accident detection, assessment and response priorities Monitor, evaluate and communicate conditions involving any release of radioactivity Record/review radiological sampling and survey data Provide support and logistics for site assembly activities Provide support and logistics for site evacuation activities Evaluate the need for and ensure proper use of KI Evaluate conditions and provide recommendations for PARs Ensure approved emergency exposure controls are issued Ensure radiological conditions are known for occupied areas Track emergency worker exposure and evaluate the need for dose extensions Coordinate the monitoring of site evacuees Direct personnel monitoring and decontamination activities Ensure habitability is established and maintained for occupied onsite areas Establish contamination controls for occupied areas B.5.a.9. Security Coordinator The Security Coordinator is assigned the following responsibilities:

Manage assigned group emergency response activities Request and coordinate emergency activities with law enforcement agencies Assist with emergency classification Communicate with ICP to provide information and coordination Provide support for development of mitigation strategies and contingency plans Establish and maintain accountability for security personnel Provide support and logistics for site assembly activities Participate in search and rescue activities Coordinate site evacuation Direct site access controls activities Provide support and logistics for site evacuation activities Ensure radiological conditions are known for occupied areas Coordinate ERO response to a security event B.5.a.10 ICP Liaison The ICP Liaison is staffed during a security or other type event where the offsite agencies establish an incident command post near the station. Additional personnel from Security, Radiation Protection, Fire Brigade, and/or Operations may be dispatched to assist.

The ICP Liaison is assigned the following responsibility; Communicate with ICP to provide information and coordination B.5.a.11. Administrative Coordinator The Administrative Coordinator is assigned the following responsibilities:

Complete facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list Coordinate facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing lists for the site Manage assigned group emergency response activities Provide admin/logistics needs for facility operation Planning Standard B CEP Rev 47

Page 28 of 226 B.5.a.12. Administrative Specialist The Administrative Specialist is assigned the following responsibilities:

Provide admin/logistics needs for facility operation Distribute forms, reports, etc. as needed B.5.a.13 Computer Analyst The Computer Analyst is assigned the following responsibility; Ensure availability of facility information/communication/display systems B.5.b. Operations Support Center (OSC)

The OSC Emergency Response Organization is presented in Figure 6.

B.5.b.1. Operations Support Center Manager The Operations Support Center Manager is assigned the following responsibilities; Complete facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list Coordinate ERO/facility shift turnover Manage facility emergency response activities Manage assigned group emergency response activities Coordinate integration of the NRC site team Develop requests for external assistance (technical, craft, admin, etc.)

Ensure flow of information within and between the emergency response facilities Direct preparations and brief personnel prior to facility activation Ensure minimum staff is available and prepared to activate the facility Activate the facility Determine current/projected staff needs Support coordination of site emergency facility relocation Coordinate between CR, OSC and TSC to set OSC Team task priorities Participate with OSC Team dispatch and control Establish and maintain facility accountability Provide support and logistics for site evacuation activities Coordinate the monitoring of site evacuees Direct personnel monitoring and decontamination activities Develop recovery plans Conduct facility briefs and updates B.5.b.2. OSC Communicator The OSC Communicator is assigned the following responsibilities; Communicate on assigned communication line and provide key information to facility staff Provide operations or radiological data to ERO members (loss of PPC/PSS)

Maintain status and information boards Distribute forms, reports, etc. as needed Planning Standard B CEP Rev 47

Page 29 of 226 B.5.b.3. Team Coordinator The Team Coordinator is assigned the following responsibilities; Maintain status and information boards Coordinate between CR, OSC and TSC to set OSC Team task priorities Participate with OSC Team dispatch and control B.5.b.4. RP Supervisor The RP Supervisor is assigned the following responsibilities; Manage assigned group emergency response activities Determine current/projected staff needs Brief and dispatch the onsite/offsite radiation monitoring teams Record/review radiological sampling and survey data Participate with OSC Team dispatch and control Provide radiation protection coverage for emergency teams Evaluate the need for and ensure proper use of KI Ensure use of Personnel Protective Equipment (protective clothing, respirators, etc.)

Ensure approved emergency exposure controls are issued Ensure radiological conditions are known for occupied areas Track emergency worker exposure and evaluate the need for dose extensions Coordinate the monitoring of site evacuees Direct personnel monitoring and decontamination activities Ensure habitability is established and maintained for occupied onsite areas Establish contamination controls for occupied areas B.5.b.5. Mechanical Supervisor The Mechanical Supervisor is assigned the following responsibilities; Manage assigned group emergency response activities Determine current/projected staff needs Participate with OSC Team dispatch and control Ensure use of Personnel Protective Equipment (protective clothing, respirators, etc.)

B.5.b.6. Electrical/I&C Supervisor The Electrical/I&C Supervisor is assigned the following responsibilities; Manage assigned group emergency response activities Determine current/projected staff needs Participate with OSC Team dispatch and control Ensure use of Personnel Protective Equipment (protective clothing, respirators, etc.)

B.5.b.7. Chemistry Supervisor The Chemistry Supervisor is assigned the following responsibilities; Manage assigned group emergency response activities Determine current/projected staff needs Record/review chemical sampling and analysis Participate with OSC Team dispatch and control Planning Standard B CEP Rev 47

Page 30 of 226 Ensure use of Personnel Protective Equipment (protective clothing, respirators, etc.)

B.5.b.8. Damage Control Team The Damage Control Team reports directly to the OSC Manager and is responsible for the repair and restoration of damaged plant systems, equipment, or components.

Members of the Damage Control Team will be selected based on the type of damage that must be dealt with at the time.

B.5.b.9. Rescue Team Rescue Teams are used for rescue of injured and trapped personnel.

Rescue Teams shall be made up of at least two people, one person qualified in radiation protection and at least one other person.

B.5.b.10. In-Plant/On-Site Survey Team In-Plant/On-Site Survey Teams are used for radiological survey during reentry of site facilities as well as support of other emergency teams which must gain access for decontamination, repair, and other activities that support event mitigation or recovery operations.

B.5.c. Emergency Operations Facility (EOF)

The EOF Emergency Response Organization is presented in Figure 7.

B.5.c.1. Emergency Director The Emergency Director is assigned the following responsibilities:

Coordinate response activities with offsite response agencies Coordinate ERO/facility shift turnover Assume/maintain command and control Transfer command and control Request and coordinate emergency activities with law enforcement agencies Coordinate information and activities with offsite agency personnel in the facility Coordinate information with government officials/agencies and EOCs Prioritize and authorize requests for external assistance (technical, craft, admin, etc.)

Approve material, personnel and logistics expenditures necessary for response to the event Request Federal support and resources Classify and declare emergencies Approve and direct offsite emergency notifications to state and local authorities Direct notifications and ENS communications with the NRC Ensure flow of information within and between the emergency response facilities Maintain communications with AEP corporate and coordinate activities Review news releases Direct preparations and brief personnel prior to facility activation Support coordination of site emergency facility relocation Approve Protective Action Recommendations to offsite authorities Terminate the emergency event Develop recovery plans Planning Standard B CEP Rev 47

Page 31 of 226 Authorize and direct extreme measures (FLEX, EDMG, SAMG, §50.54(x) or suspend security controls)

Conduct facility briefs and updates B.5.c.2. EOF Manager The EOF Manager is assigned the following responsibilities:

Coordinate response activities with offsite response agencies (EM, ICP, Field Mon, etc.)

Coordinate ERO/facility shift turnover Manage facility emergency response activities Manage assigned group emergency response activities Coordinate information and activities with offsite agency personnel in the facility Coordinate integration of the NRC site team Develop requests for external assistance (technical, craft, admin, etc.)

Assist with emergency classification Ensure flow of information within and between the emergency response facilities Direct preparations and brief personnel prior to facility activation Ensure minimum staff is available and prepared to activate the facility Activate the facility Determine current/projected staff needs Develop recovery plans Conduct facility briefs and updates B.5.c.3. Operations Advisor The Operations Advisor is assigned the following responsibilities:

Monitor status of the Emergency Operations Procedures Assist with emergency classification Support completion of the Emergency Notification Form to state and local authorities Provide support for development of mitigation strategies and contingency plans Evaluate conditions and provide recommendations for PARs Analyze and develop extreme measures actions (FLEX, EDMG, SAMG, §50.54(x))

B.5.c.4. State Communicator The State & County Communicators are assigned the following responsibility:

Perform offsite emergency notifications to state and local authorities Distribute forms, reports, etc. as needed B.5.c.5. County Communicator The State & County Communicators are assigned the following responsibility:

Perform offsite emergency notifications to state and local authorities B.5.c.6. HPN Communicator The HPN Communicators are assigned the following responsibility:

Provide event data and plant information to the NRC via the HPN Planning Standard B CEP Rev 47

Page 32 of 226 B.5.c.7. EOF Communicator The EOF Communicator is assigned the following responsibilities:

Communicate on assigned communication line and provide key information to facility staff Provide operations or radiological data to ERO members (loss of PPC/PSS)

Maintain status and information boards B.5.c.8. Public Information Communicator The Public Information is assigned the following responsibilities:

Provide emergency response information to the ENC Provide technical assistance for the development of news releases and statements B.5.c.9. Offsite Liaison Coordinator Offsite Liaison Coordinator is assigned the following responsibilities:

Manage assigned group emergency response activities Support State/County EOC Liaisons Coordinate information with government officials/agencies and EOCs B.5.c.10. Offsite Liaison The Offsite Liaison is assigned the following responsibilities:

Coordinate information with government officials/agencies and EOCs Report status of state and county emergency response activities to EOF B.5.c.11. Industry & Reg Affairs Liaison The Industry & Reg Affairs Liaison is assigned the following responsibilities:

Coordinate information and activities with offsite agency personnel in the facility Coordinate integration of the NRC site team Coordinate external assistance (industry, commercial, contractor)

Provide event notification/information to industry groups (INPO, ANI, etc.)

Provide guidance for licensed-based decisions B.5.c.12. Environmental Assessment Coordinator The EOF the Environmental Assessment Coordinator is assigned the following responsibilities:

Coordinate response activities with offsite response agencies (EM, ICP, Field Mon, etc.)

Manage assigned group emergency response activities Assist with emergency classification Support completion of the Emergency Notification Form to state and local authorities Determine current/projected staff needs Monitor, evaluate and communicate conditions involving any release of radioactivity Review and analyze dose assessment results Direct/perform dose assessment Record/review radiological sampling and survey data Evaluate the need for and ensure proper use of KI Evaluate conditions and provide recommendations for PARs Planning Standard B CEP Rev 47

Page 33 of 226 Ensure approved emergency exposure controls are issued Track emergency worker exposure and evaluate the need for dose extensions Coordinate the monitoring of site evacuees Direct personnel monitoring and decontamination activities Direct post-accident environmental sampling and exposure activities B.5.c.13. Dose Assessor The Dose Assessors are assigned the following responsibilities:

Support completion of the Emergency Notification Form to state and local authorities Monitor, evaluate and communicate conditions involving any release of radioactivity Review and analyze dose assessment results Direct/perform dose assessment Record/review radiological sampling and survey data B.5.c.14. Field Monitoring Team Communicator The Field Monitoring Team Communicator is assigned the following responsibilities:

Communicate on assigned communication line and provide key information to facility staff Brief and dispatch the onsite/offsite radiation monitoring teams Record/review radiological sampling and survey data Track emergency worker exposure and evaluate the need for dose extensions B.5.c.15. Field Monitoring Team Member The Field Monitoring Team Members are assigned the following responsibilities:

Perform radiological sampling and surveys Record/review radiological sampling and survey data Offsite Radiation Monitoring is performed by survey teams assembled in the OSC. Upon leaving the OSC the Offsite Survey Team(s) report to the Environmental Assessment Coordinator in the EOF via the Field Monitoring Team Communicator to receive briefing and instructions.

The off-site Survey Team Driver is normally filled by non-RPT personnel. Qualified RP Technicians fill the position for persons performing the survey.

B.5.c.16. Logistics Coordinator The Logistics Coordinator is assigned the following responsibilities:

Manage assigned group emergency response activities Coordinate external assistance (industry, commercial, contractor)

Arrange logistics support for event response Support coordination of site emergency facility relocation Serve as primary point of contact for SAFER and FLEX support Complete facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list B.5.c.17. IT Specialist The IT Specialist is assigned the following responsibility:

Ensure availability of facility information/communication/display systems Planning Standard B CEP Rev 47

Page 34 of 226 B.5.c.18. Administrative Coordinator The Administrative Coordinator is assigned the following responsibilities:

Manage assigned group emergency response activities Provide admin/logistics needs for facility operation B.5.c.19. Administrative Specialist The Administrative Specialist is assigned the following responsibilities:

Provide admin/logistics needs for facility operation Distribute forms, reports, etc. as needed B.5.d. Emergency News Center/Joint Information Center (ENC/JIC)

The ENC, located at the Nuclear Generation Group Headquarters Building, approximately 14 miles southeast of CNP in Buchanan, Michigan, will be staffed by individuals from the Energy Information Center, CNP, and Corporate Communications - Generation. The ENC will be under the direction of the Emergency News Center Manager. Throughout the operation of the ENC, the Emergency News Center Manager maintains constant communication with AEP Corporate Communications - Generation. See Figure 8 for an organization chart illustrating staffing and information flow for the ENC/JIC. Figure 5 illustrates ENC/JIC functional relationship to the remainder of the Emergency Response Organization.

When the Governor of the State of Michigan declares a State of Disaster or Emergency the ENC becomes the Joint Information Center at the governors declaration. See Figure 8 for an organization chart illustrating staffing and information flow for the ENC/JIC.

B.5.d.1. Utility Spokesperson The Utility Spokesperson is the single utility spokesperson when dealing with the news media.

The Utility Spokesperson is assigned the following responsibilities:

Coordinate information and activities with offsite agency personnel in the facility Approve/review news releases Direct the development of news releases Ensure press releases are prepared and issued prior to the JIC becoming operational Perform media briefings and interviews Address rumors in media briefings Develop recovery plans B.5.d.2. Technical Communicator The Technical Communicator is assigned the following responsibilities:

Communicate on assigned communication line and provide key information to facility staff Provide operations or radiological data to ERO members (loss of PPC/PSS)

Provide emergency response information to the ENC Provide technical assistance for the development of news releases and statements Assist the Spokesperson in gathering technical information for media briefings and interviews Planning Standard B CEP Rev 47

Page 35 of 226 B.5.d.3. Emergency News Center Manager The Emergency News Center Manager is assigned the following responsibilities:

Complete facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list Coordinate ERO/facility shift turnover Manage facility emergency response activities Manage assigned group emergency response activities Coordinate information and activities with offsite agency personnel in the facility Develop requests for external assistance (technical, craft, admin, etc.)

Ensure flow of information within and between the emergency response facilities Maintain communications with AEP corporate and coordinate activities Direct the development of news releases Ensure press releases are prepared and issued prior to the JIC becoming operational Coordinate the conduct of media briefings Direct preparations and brief personnel prior to facility activation Ensure minimum staff is available and prepared to activate the facility Activate the facility Determine current/projected staff needs Conduct facility briefs and updates B.5.d.4. Media Area Coordinator The Media Area Coordinator is assigned the following responsibilities:

Manage assigned group emergency response activities Maintain status and information boards Coordinate the conduct of media briefings Coordinate accommodation of news media personnel Provide media with prepared media information and media briefing start times Provide admin/logistics needs for facility operation Distribute forms, reports, etc. as needed B.5.d.5. Audio/Visual Specialist The Audio/Visual Specialist is assigned the following responsibilities:

Support the setup of electronics and communications equipment Ensure availability of facility information/communication/display systems B.5.d.6. Receptionist The Receptionist is assigned the following responsibilities:

Coordinate ENC security and media badging Register personnel at the assigned location Provide admin/logistics needs for facility operation B.5.d.7. Briefing Statement Writer The Briefing Statement Writer is assigned the following responsibilities:

Planning Standard B CEP Rev 47

Page 36 of 226 Develop technical news releases Coordinate distribution of news releases B.5.d.8. Rumor Control/Media Monitoring Coordinator The Rumor Control/Media Monitoring Coordinator is assigned the following responsibilities:

Manage assigned group emergency response activities Monitor media outlets for event related information Perform rumor control activities Set up the facility Determine current/projected staff needs B.5.d.9. Rumor Control/Media Monitoring Specialist The Rumor Control/Media Monitoring Specialist is assigned the following responsibilities:

Monitor media outlets for event related information Perform rumor control activities B.5.d.10. Support Office Coordinator The Support Office Coordinator is assigned the following responsibilities:

Provide admin/logistics needs for facility operation Manage assigned group emergency response activities Determine current/projected staff needs B.5.d.11. Support Office Admin Specialist The Support Office Admin Specialist is assigned the following responsibility:

Complete facility 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months staffing list Provide admin/logistics needs for facility operation B.6. Overall Organization and Communication The communication links between various emergency centers established as a result of implementing the Emergency Plan are delineated by Functional Organization Charts in Figures 9 and 10.

Initial notification flow sequence is shown in Figure 9.

Figure 10 shows the relationship between various emergency centers and organizations after the incident has occurred and all channels of communication have been established.

B.7. Plant Staff Augmentation B.7.a. Logistics Support Emergency Director directs the development of recovery plans and procedures.

The Administrative Coordinator serves as a support resource for the ED in the areas of planning, scheduling and expediting of recovery operations. The Administrative Coordinator is assigned to the EOF and reports to the EOF Manager.

Planning Standard B CEP Rev 47

Page 37 of 226 B.7.b. Reentry/Recovery Technical Support The Plant Evaluation Team (PET), operating out of the TSC develops corrective action recommendations. When the corrective action plans are decided upon, the TSC Manager coordinates the design and construction activities of the utility, NSSS supplier, and other outside vendors to support the corrective actions for recovery.

B.7.c. Management Level Interface with Government During an event the Emergency Director is responsible for control and coordination of all emergency and recovery operations including communications with offsite organizations, and interface with governmental authorities.

B.7.d. Releases to Media The Emergency News Center Manager coordinates all information at the ENC/JIC with counterparts from the county, state, federal agencies, and others involved with the emergency.

The Utility Spokesperson is the single utility spokesperson when dealing with the news media.

B.8. Offsite Agencies and Organizations Appendix B, Agreements with Off-Site Support Agencies, identifies the primary response agencies that can be relied upon in an emergency to provide assistance. In addition various nuclear industry organizations can be called upon to provide technical assistance as needed.

Procedures have been developed and are in place that assures the ability to notify and request assistance from those agencies identified in Appendix B. These procedures also provide the ability to notify and request assistance from other nuclear industry organizations. These include, but are not limited to:

1. NSSS Supplier.

2. Consultants on radiological and radwaste requirements.

3. Nuclear Fuel Supplier.

B.8.a. Notification of American Nuclear Insurers The American Nuclear Insurers notification criteria for nuclear emergencies has been brought into alignment with the emergency classification (EAL) system described in Section D and also identifies methods for follow-up communications.

American Nuclear Insurers requires notification in the event of an Alert, Site Area Emergency or General Emergency.

A representative of the NGG shall notify American Nuclear Insurers via the American Nuclear Insurers emergency notification number.

American Nuclear Insurers requires that periodic updates be supplied of releases of radioactive material from the plant, plant status and impending protective action for members of the public.

These updates are the responsibility of the Industry Support Communicator in the EOF.

Appendix I, Notification of American Nuclear Insurers, and Figure 13 show the ANI notification procedure.

Planning Standard B CEP Rev 47

Page 38 of 226 B.9. Offsite Groups Although many offsite groups may be used in the event of an emergency, there are three offsite groups that have agreed to serve in the capacities outlined in this plan should an incident occur.

These groups are the Berrien County Sheriffs Department, the State of Michigan, and the Federal Government. The responsibilities and authorities of the County, State and Federal Governments and their interrelationship with this emergency plan are outlined in the following paragraphs.

Written agreements with various offsite agencies that are part of the overall response organization within the Plume Exposure Pathway Emergency Planning Zone are listed in Appendix B of this plan.

B.9.a. Berrien County Sheriffs Department The Berrien County Sheriffs Department, which is the lead agency in implementing the Berrien County Radiological Emergency Plan, has established an Emergency Operating Center (BCEOC) in accordance with the Berrien County Emergency Plan. This center is located in Benton Harbor, Michigan about 14 miles from the plant. It is equipped with the appropriate communications equipment to coordinate all the local offsite protective actions.

The Berrien County Sheriff has the responsibility and authority for coordination of all local resources in the event of a hostile threat or a radiological emergency, including establishing an Incident Command Post when applicable.

The Sheriffs Department also has a marine division within its organization for the control of water traffic should it be necessary. Although the Sheriffs Department is primarily responsible for coping with an emergency using its own resources, the County Sheriff will call upon state resources to supplement the local resources when the local resources are clearly insufficient to cope with the emergency.

Once the Governor of Michigan has declared a State of Disaster under Act 390, the Berrien County Sheriffs Department will implement the Governors Orders and will perform the following:

1. Contact other local agencies as needed for assistance.

2. Control offsite vehicular traffic.

3. Initiate the warning system and issue clear instructions of what protective action is required for the populace.

4. Take other appropriate action, if so advised by the Michigan Department of Environment, Great Lakes, and Energy (EGLE) or upon notification by the SED or ED that conditions requiring immediate offsite protective action have been reached. (For further details see the Berrien County Plan - Warning Annex.)

B.9.b. State of Michigan The State of Michigan has developed the Michigan Emergency Management Plan. In the event that offsite protective action is required due to a hostile threat or a radiological emergency at CNP, this Michigan Emergency Management Plan can also be placed into effect to assist the Berrien County Sheriffs Department. A brief outline follows of the plans provisions for nuclear facility emergencies.

Planning Standard B CEP Rev 47

Page 39 of 226 Under the Michigan Emergency Management Plan, the Department of State Police will provide guidance for the development of state and local nuclear incident emergency plans for dealing with peacetime radiological incidents. These are defined as situations in which normal control over radioactive materials is accidentally lost, with resulting hazard to the health and safety of the general public.

The State Director of Emergency Management and Homeland Security is responsible for planning and coordinating the Disaster Relief Forces and their activities for the state. The Nuclear Power Plant Project Coordinator, Emergency Management and Homeland Security Division, State Police is designated as the Emergency Planning Coordinator for the States radiological emergency response planning portion of the plan.

The State Police, Emergency Management and Homeland Security Division, at the direction of the Governor, will coordinate all organizations in the State for nuclear incident activities, maintaining liaison with all levels of government.

The primary State Emergency Operations Center (SEOC), acting in support of the BCEOC, will perform all state governmental functions. This SEOC is located at 7150 Harris Drive, Dimondale, MI 48821.

Alternate sites to the primary State EOC will be located in one of the State Police District Headquarters as indicated in the Michigan Emergency Management Plan.

The basic responsibilities and duties of the State Government agencies that provide support during a nuclear incident are outlined below.

B.9.b.1. The Primary State Response Agencies and a summary of their responsibilities are:

B.9.b.1.a. The Department of Michigan State Police (MSP)

Receives notification of nuclear incidents from the utility and alerts state agencies and warns affected local governments (adjacent states and adjacent counties are also alerted);

Operates the State Emergency Operations Center, and the field team centers; Provides overall direction and control of all activated state and local disaster relief forces; Provides notification to local jurisdictions based on technical advice by EGLE to evacuate and/or shelter in-place.

Assists local jurisdictions to establish security around restricted area; Collects and compiles damage assessment information; Prepares and coordinates emergency public information releases and advises the news media; Assists local jurisdictions with any transportation accidents; Establishes procedures to handle terrorist activities at nuclear power plants; and Provides liaison to various federal organizations and agencies.

Planning Standard B CEP Rev 47

Page 40 of 226 B.9.b.1.b. The Department of Environment, Great Lakes, and Energy (EGLE)

Monitors the environment, State of Michigan personnel, and equipment in support of emergency operations; In coordination with the Michigan Department of Health and Human Services, Evaluates the public health and medical aspects of radiological effects; Recommends measures and establishes limits to mitigate radiological effects on public health; Recommends measures to control the spread of radioactivity; Establishes radiological safety criteria for recovery, re-occupancy, and rehabilitation of affected areas; Provides technical advice and assistance for offsite decontamination activities and support.

Sample surface water.

Conduct other monitoring as requested.

Monitor areas for contamination of the environment and recommend suitable countermeasures to reduce the impact of contamination of the environment.

Analyzes and projects radiological release hazards; coordinates technical analysis with other technical resources (including stat, federal, local, and private sector).

Leads the Technical Support Unit at the Michigan State Emergency Operations Center.

B.9.b.2. The State Support Response Agencies and a summary of their responsibilities are:

B.9.b.2.a. Department of Agriculture Responsible for sampling agriculture areas for food contamination and recommending appropriate counter measures in conjunction with the Department of Public Health.

Responsible for taking appropriate actions to prohibit contaminated foods from entering the market.

B.9.b.2.b. Licensing and Regulatory Affairs Provide liaison to the public utility companies.

Provide recommendations for handling energy disruptions resulting from a shutdown due to a nuclear incident.

Provide advice and guidance to affected persons regarding insurance claims and adjustments.

B.9.b.2.c. Department of Corrections Provide for mass care, feeding, clothing and sheltering.

Provide mass transportation assistance for affected persons and disaster relief workers.

B.9.b.2.d. Department of Education Planning Standard B CEP Rev 47

Page 41 of 226 Provide support for mass care, feeding and housing.

Provide mass transportation assistance.

B.9.b.2.e. Department of Community Health Provide crisis counseling and intervention center assistance to affected persons.

Provides coordination of medical and emergency medical services to affected areas.

B.9.b.2.f. Department of Military Affairs Provide transportation and manpower support for evacuation counter measures.

Provide security support to local law enforcement operations, including control of access to restricted or evacuated areas within the Emergency Planning Zone (EPZ).

B.9.b.2.g. Department of Natural Resources Monitor areas accessible by fish and game.

Take action to prevent or minimize contamination of fish and game.

Take samples of fish and game, which may have been exposed or contaminated.

Assist local authorities to warn and evacuate occupants of state parks, beaches, and other recreational areas if necessary.

B.9.b.2.h. Human Services Assist with sheltering and housing evacuated population; Provide feeding and clothing if required to persons affected.

Establish assistance centers for affected individuals and families to receive advice and assistance.

Coordinate assistance made available by volunteer relief agencies and the American Red Cross.

B.9.b.2.i. Department of Transportation Provide for mass transportation assistance to local jurisdictions if required.

Provide advice and assistance support regarding barricades and security measures around an evacuated or restricted area.

Provide advice on traffic regulation and control for the evacuation of designated areas.

Provide assistance for the rescue of entrapped workers and persons.

Planning Standard B CEP Rev 47

Page 42 of 226 The Michigan Department of State Police is notified of an emergency condition in the manner described in Section E by the SED or designee. The State Police will set up a command post at the SEOC at 7150 Harris Drive, Dimondale, MI 48821. The State Police will also set up a Field Team Center (FTC) to coordinate the dispatch of field teams to monitor for radiological contamination. The FTC will be established at the Michigan Department of Transportation Coloma Service Garage on Red Arrow Highway at I-196. The State Police will coordinate their efforts with the BCEOC and with the EOF, as needed. After notification has been given, the Michigan Department of State Police will assist Berrien County and perform the actions listed in Section B.9.b.

B.9.c. Federal Government The Federal Government has established the Nuclear/Radiological Incident Annex under the National Response Plan to coordinate Federal radiological assistance. The Nuclear/Radiological Incident Annex establishes:

A means of requesting and providing Federal radiological assistance from existing Federal resources, and An operational framework for coordinating the radiological monitoring and assessment activities of Federal agencies during radiological emergencies occurring within the United States and its territories.

The Nuclear Regulatory Commission (NRC) as the Coordinating Agency is responsible for coordinating the response of all other federal agencies in accordance with the National Response Plan.

The Department of Energy (DOE) Chicago Operations Office, located at Argonne National Laboratory, has radiation monitoring capability available. It will, as requested by NGG Management or any of the indicated offsite groups (Sheriff, State Police or EGLE), assist in the offsite emergency program.

The Chicago Operations Office will, upon request by NGG Management or any of the indicated offsite groups, participate in the monitoring of the offsite areas affected and in the analysis of field data and will recommend measures to be taken offsite for protecting the public. It will also advise the ED of the recommendations.

The DOE Operations Office will, to the extent they are available during the protection and recovery stage, continue to advise the Emergency Management and Homeland Security Division of the Michigan Department of State Police and provide monitoring and analytical capability as requested.

B.9.d. Fire Department CNP maintains an onsite fire fighting brigade; this capability is expected to be sufficient for all fires onsite. In the event offsite assistance is desired or needed, local fire departments may be called upon. The Fire Protection Shift Supervisor is responsible for fire fighting activity onsite as well as notifying offsite departments when assistance is needed.

The primary fire departments that will respond to a fire emergency at CNP are:

Lake Township Fire Department Bridgman Fire Department Planning Standard B CEP Rev 47

Page 43 of 226 Letters of agreement to provide firefighting assistance to CNP can be found in Appendix B of this Plan.

B.9.e. HAZMAT Team CNP maintains an onsite hazardous material spill response team that is capable of responding to most emergency spill events. If there is insufficient manpower or material available, assistance from the Berrien County HAZMAT Team will be requested. A letter of agreement offering their services can be found in Appendix K of this plan.

AEP has also contracted with environmental firms to provide emergency spill response assistance. These contractors are listed in the Spill Prevention Control and Countermeasures (SPCC) Plan and Pollution Incident Prevention (PIP) Plan, copies of which are located in the Shift Managers office.

Planning Standard B CEP Rev 47

Page 44 of 226 Figure 2 Management Structure of the Nuclear Generation Group

~*

Chief Nuclear Officer I I I I Director Director Manager Managing Director Manager Nuclear Nuclear Business Site Vice President Employee Of Engineering Policy Oversight Services Concerns Communication

~ Nuclear Projects Nuclear IT Manager Plant Manager - Director Director Nuclear Regulatory Emergency Compliance and Preparedness Licensing Manager Training Manager Security Manager Continuous Improvement

- Manager Planning Standard B CEP Rev 47

Page 45 of 226 Figure 3 Site Operations Site Vice President

~~

Plant Manager

~~

I Operations Maintenance Nuclear Outage Work Control Director Director Manager Manager

~Is I I Site Procedure Chemistry Radiation Protection Safety Group/Nuclear Manager Manager Manager Document Management Manager Planning Standard B CEP Rev 47

Page 46 of 226 On Sh ift Response Or g,m iza1io 11 Sit e Emergen cy DIrecto r (Sh ift Man ager) f-----i._ r----------

r t'lt'r:i.l/.",-r.i1't /

.!I I nrt1I A?f"n'j,."

i S hirl T.,.d 111ic.:al Rl'ld illt i nn Prn i'l"r.it°ln T,-c-h niri!ln\

Chem 1strf lechnilCIOA$

l n$t rum e '1t <.:ont n:::I lechnmitn S1::1.u fil\' Sl1ifl Ad\-.sot S U!-'1=1.,i W I

.ccurt :v U- 2 S.u :ie rvi sor fo rce

~nd a.-,d conuol Roo m Ccm hul Rt:u m

<trt'r:i.r n--; Operators.

W C.CSP. O ln dtit"n t C'A'l m m11,ri Pu:.. Li* i:.un A UIClllary .111U ll'4 1;i ')I A uAilidlf'( Auxd t.- .ry lAEO Operator Opera tor 0 µ:1:1l'-" O ('lf" fflM f Phone Talhrs Planning Standard B CEP Rev 47

Page 47 of 226 Figure 5 - TSC Organization Site Emergency Director (60 min)

Control Room OSC TSC Manager (60 min)

ENS Communicator TSC Communicator (60 min)

CR Communicator

[Located in CR]

Rad Assessment Plant Evaluation Maintenance Coordinator Administrative Security Coordinator Team Coordinator Coordinator (60 min)

PET - Reactor PET - Electrical ICP Liaison TSC Admin Specialist (60 min) (60 min) [event based]

PET - Mechanical PET - Operations Computer Analyst (60 min) (60 min)

Planning Standard B CEP Rev 47

Page 48 of 226 Figure 6 - OSC Organization 2x: Chemistry OSC Manager Technician (60 min)

(from shift)

OSC Communicator Team Coordinator OPs Spervisor RP Supervisor Mechanical Supervisor Elect/I&C Supervisor Chemistry Supervisor (from shift) 2x: RPT - In Plant Radwaste Operator Mechanic Electrician Chemistry Technician Survey (60 min) (60 min) (60 min) (60 min)

(60 min)

Mechanic 2x: Chemistry 5x: Fire Brigade RPT - Onsite Survey Electrician Technician Member (60 min) (60 min) (60 min) (from shift) (from shift) 4x: RPT - Protective Electrician OR I&C 6x: AEO Actions Tech (from shift)

(60 min) (60 min) 3x: RPT I&C Tech (from shift) (from shift)

Planning Standard B CEP Rev 47

Page 49 of 226 Figure 7 - EOF Organization Emergency Director (60 min)

Station Emergency News Center Operations Advisor (60 min)

EOF Manager (60 min)

State Communicator Public Information (60 min) Communicator County Communicator EOF Communicator (60 min)

Env Assessment Coord Offsite Liaison Coordinator Logistics Coordinator Administrative Coordinator (60 min)

EOF Admin HPN Communicator 2x: Offsite Liaison IT Specialist Specialist Industry & Reg Dose Assessor Affairs Liaison FMT Communicator 4x: FMT Member (60 min)

Planning Standard B CEP Rev 47

Page 50 of 226 Figure 8 - CNP ENC/JIC Organization Utility Spokesperson Technical Communicator Corporate Communications ENC Manager Briefing Statement Writer Rumor Control / Media Media Area Coordinator Support Office Coordinator Monitoring Coordinator 4x: Rumor Control / Media Support Office Admin Receptionist Monitoring Specialist Specialist AV Specialist Planning Standard B CEP Rev 47

Page 51 of 226 Table 1 CNP Staffing for Nuclear Power Plant Emergencies On HAB Shift 60 Functional Area Major Tasks ERO Position Title Min Full Staff

1. Plant Ops and Response and Shift Manager (CR) 1 Assessment of Accident Assistant Shift Manager/WCC-SRO (CR) 1 Operational Mitigation Unit Supervisor (CR) 2 Aspects Control Room Operator (CR) 4 Auxiliary Equipment Operator (CR) 4

2. Direction and Command and Shift Manager (CR) 1(a)

Control Control Site Emergency Director (TSC) 1 Facility and Group TSC Manager (TSC) 1 Control OSC Manager (OSC) 1 EOF Manager (EOF) 1 ENC Manager (ENC) 1(d)

3. Notification & Emergency Licensee - Reactor Operator (CR) 1(a)

Comm. Communications Local/State - Qualified Operator (CR) 1 Federal - Qualified Operator (CR) 1 State & County Communicator (EOF) 2 ENS Communicator (TSC) 1 HPN Communicator (EOF) 1 Plant Status & CR Communicator (CR) 1 Technical TSC Communicator (TSC) 1 Activities OSC Communicator (OSC) 1 EOF Communicator (EOF) 1 Public Info Communicator (EOF) 1 Governmental Offsite Liaison Coordinator (EOF) 1 Offsite Liaison (EOF) 2 ICP Liaison (TSC) 1(b)

Industry & Reg Affairs Liaison (EOF) 1

4. Radiological EOF Director Emergency Director (EOF) 1 Assessment and Support of Dose Assessment Reactor Operator (CR) 1(a)

Operational Dose Assessor (EOF) 1 Accident Offsite Surveys RP Technician (OSC) 1 Assessment FMT Communicator (EOF) 1 FMT Member (EOF) 4 Onsite Surveys RP Technician (OSC) 1 RP Technician (OSC) 1 In-plant Surveys RP Technician (OSC) 1 RP Technician (OSC) 2 RP Supervisory Rad Assessment Coordinator (TSC) 1 Environmental Assmt Coordinator (EOF) 1 RP Supervisor (OSC) 1 Chemistry / Chemistry Technician (OSC) 2 Radiochemistry Chemistry Technician (OSC) 1 Chemistry Chemistry Supervisor (OSC) 1 Supervisory Planning Standard B CEP Rev 47

Page 52 of 226 On HAB Shift 60 Functional Area Major Tasks ERO Position Title Min Full Staff

5. Plant System Technical Support Shift Technical Advisor (CR) 1 Engineering, / Accident Core Damage: PET - Reactor (TSC) 1(a) 1 Repair, and Analysis Thermal Hydraulics: PET - Ops (TSC) 1(a) 1 Corrective Electrical: PET - Electrical/I&C (TSC) 1 Actions Mechanical: PET - Mechanical (TSC) 1 Operations Advisor (EOF) 1 Repair and Mechanic (OSC) 2 Corrective Actions Electrician (OSC) 2 I&C Technician (OSC) 1 Electrician OR I&C Technician (OSC) 1 Maintenance Coordinator (TSC) 1 Team Coordinator (OSC) 1 Mechanical Supervisor (OSC) 1 Radwaste Operator (OSC) 1 Elect/I&C Supervisor (OSC) 1

6. In-Plant PAs Radiation RP Technician (OSC) 2(a)

Protection RP Technician (OSC) 4

7. Fire Protection Fire Brigade (OSC) 5 Local Support

8. Rescue / 1st Aid Fire Brigade (OSC) 2(a) Local Support

9. Access Control Security & Shift Security Supervisor (Plant) 1 Accountability Security Personnel (Plant) (c)

Security Coordinator (TSC) 1

10. Resource Administration Administrative Coordinator (TSC) 1 Allocation and TSC Administrative Specialist (TSC) 1 Admin Administrative Coordinator (EOF) 1 EOF Administrative Specialist (EOF) 1 Media Area Coordinator (ENC) 1 Receptionist (ENC) 1 Facility Operations Computer Analyst (TSC) 1 Logistics Coordinator (EOF) 1 IT Specialist (EOF) 1 AV Specialist (ENC) 1 Support Office Coordinator (ENC) 1 Support Office Admin Specialist (ENC) 1

11. Public Public Information Utility Spokesperson (ENC) 1(d)

Information Technical Communicator (ENC) 1 Briefing Statement Writer (ENC) 1 Rumor Control/Media Mon Coord (ENC) 1 Rumor Control/Media Mon Spec (ENC) 4 Totals: 27 33 40 1 The augmentation times presented in this table are goals developed from the guidance of Table B-1 in NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."

a. May be provided by shift or other personnel assigned from other functions. Not included in the total.

b. The ICP Liaison is a situational position. For all HAB events a 2nd TSC Security Coordinator assumes the position of ICP Liaison and responds to the ICP.

c. Per Security Plan

d. Utility Spokesperson and Emergency News Center Manager are minimum staffing positions required for facility activation, but they do not have a required response time.

Planning Standard B CEP Rev 47

Page 53 of 226 PLANNING STANDARD C EMERGENCY RESPONSE SUPPORT AND RESOURCES Planning Standard C CEP Rev 47

Page 54 of 226 C. EMERGENCY RESPONSE SUPPORT AND RESOURCES C.1. Federal Radiological Assistance C.1.a. Requesting Federal Assistance The Emergency Director (ED) or the Site Emergency Director (SED) has the authority to request federal radiological assistance.

A request for federal radiological assistance should be made through the Department of Energys (DOE) Chicago Operations Office located at 9800 S. Cass Avenue, Argonne, Illinois 60439. The Chicago Operations Office is designated to provide the primary assistance following a radiological incident in the Radiological Assessment Program (RAP) Region 5.

When a request for RAP assistance is made, the following information should be provided:

1. Nature of the incident.

2. Name, title, location and telephone number of person requesting assistance.

3. Time of the incident.

4. Location of the incident.

5. Accessibility of location.

6. Whether a fire is involved.

7. Relative seriousness of incident.

8. Weather conditions.

9. Personnel involved (injuries, contamination, etc.).

10. Local/state/federal agencies that have been notified.

11. Whether the news media is aware of the incident; whether false or exaggerated reports are known to have circulated.

C.1.b. Federal Resources The immediate objective of the DOEs Chicago Operations Office is to dispatch a team of specialists to the incident site where the team will:

1. Evaluate the hazard.

2. Take or recommend action to counteract and control any acute hazard offsite from the licensees site.

3. Establish communication with State and local authorities and the press.

If the Chicago Operations Office determines a need for additional assistance beyond its own capabilities, it may initiate the Nuclear/Radiological Incident Annex.

Planning Standard C CEP Rev 47

Page 55 of 226 The Nuclear/Radiological Incident Annex has been established by the federal government to coordinate federal radiological assistance. The Nuclear/Radiological Incident Annex establishes:

A means of requesting and providing Federal radiological assistance from existing federal resources, and An operational framework for coordinating the radiological monitoring and assessment activities of Federal agencies during radiological emergencies occurring within the United States and its territories.

Through the Nuclear/Radiological Incident Annex the DOEs Chicago Operations Office has the capability to call upon resources located throughout the United States and will provide this assistance where necessary or when requested. Some of the immediate resources that can be provided are (but not limited to):

1. Provide team(s) of RAP personnel to assist in offsite monitoring.

2. Provide portable direct reading radiological measuring instruments.

3. Provide counting equipment.

4. Provide aerial surveillance and measurement.

5. Provide analytical capability to augment the licensee and states capability.

6. Provide resources as may be available at the Argonne National Laboratory.

7. Provide health physics assistance.

8. Provide environmental control assistance.

9. Provide remote handling equipment on an as needed basis.

Additional information pertaining to federal radiological assistance can be found in Appendix E, Description of Federal Radiological Assistance, to this plan. Appendix E is divided into three sections.Section I is a brief introduction to the federal radiological assistance.Section II describes typical capabilities and expected mobilization and travel times for some of the Region 5 radiological assistance resources available within Region 5 of the DOEs radiological assistance program.Section III describes additional DOE capabilities that can be activated dependent on the assistance needed and how it is activated.

C.1.c. Federal Response Support Resources Appendix E contains information on the local resources required to support the RAP.

C.2. Liaisons C.2.a. Liaisons to CNP Not applicable Planning Standard C CEP Rev 47

Page 56 of 226 C.2.b. Liaisons from CNP Sections B.5.a.10 and B.5.c.10. detail the liaisons provided to the Berrien County EOC, Incident Command Post and the Michigan SEOC.

C.3. Radiological Laboratories Section H.6.c Offsite Laboratory Facilities discusses offsite laboratory availability.

C.4. Offsite Agencies and Organizations Appendix B identifies the primary response agencies that can be relied upon in an emergency to provide assistance. In addition various nuclear industry organizations can be called upon to provide technical assistance as needed. Procedures have been developed and are in place that assures the ability to notify and request assistance from those agencies identified in Appendix B.

These procedures also provide the ability to notify and request assistance from other nuclear industry organizations. These include, but are not limited to:

1. NSSS Supplier.

2. Consultants on radiological and radwaste requirements.

3. Nuclear Fuel Supplier.

C.4.a. American Nuclear Insurers The American Nuclear Insurers notification criteria for nuclear emergencies has been brought into alignment with the emergency classification (EAL) system described in Section D and also identifies methods for follow-up communications.

American Nuclear Insurers requires notification in the event of an Alert, Site Area Emergency or General Emergency.

A representative of the NGG shall notify American Nuclear Insurers via the American Nuclear Insurers emergency notification number.

American Nuclear Insurers requires that periodic updates be supplied of releases of radioactive material from the plant, plant status and impending protective action for members of the public.

These updates are the responsibility of the Industry and Reg. Affairs Liaison in the EOF.

Appendix I and Figure 13 show the ANI notification procedure.

C.4.b. Nuclear Transportation Accidents A Voluntary Assistance Agreement has been entered into between electric utilities involved in the transportation of source material, special nuclear material and by-product material received, possessed, used or transferred. This agreement sets forth the understanding and agreement with respect to the mutual undertaking to each other in the situation where an emergency occurs by reason of a nuclear materials transportation accident and assistance is provided by one utility to another. A copy of this agreement can be found in Appendix B.

Planning Standard C CEP Rev 47

Page 57 of 226 C.4.c. Nuclear Power Plant Accidents A voluntary assistance agreement has been entered into between electric utilities involved in the operation of nuclear power plants. This agreement sets forth the understanding and agreement with respect to their mutual undertaking to each other in a situation where an emergency occurs at a nuclear power plant and assistance is provided by one utility to another. A copy of this agreement can be found in Appendix B, and contact information is contained in the Emergency Plan Procedures.

Planning Standard C CEP Rev 47

Page 58 of 226 PLANNING STANDARD D EMERGENCY CLASSIFICATION SYSTEM Planning Standard D CEP Rev 47

Page 59 of 226 D. EMERGENCY CLASSIFICATION SYSTEM In general, Initiating Conditions (ICs) describe conditions that require implementation of emergency actions. Emergency Action Levels (EALs) are, where possible, pre-designated, non-subjective thresholds for entry into a particular Emergency Classification Level (ECL). The action to be taken by the operating shift depends on the severity of the incident, its effects and type.

The SED or ED will exercise subjective judgment to ensure all incidents are classified at the highest appropriate ECL based on the following criteria:

Conditions warrant a declaration of an Unusual Event when events are in process or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Conditions warrant a declaration of an Alert when events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of Hostile Action. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Conditions warrant a declaration of a Site Area Emergency when events are in process or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or Hostile Action that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Conditions warrant a declaration of a General Emergency when events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or Hostile Action that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

The ICs/EALs were created following the methodology of NEI-99-01, Revision 6. The ICs/EALs will classify an event or condition into one of four Emergency Classification Levels (ECLs) if an emergency classification is appropriate.

D.1. Emergency Action Levels Emergency Action Levels are pre-determined, site specific, observable thresholds for plant Initiating Conditions that place the plant in a given emergency class. An EAL can be an instrument reading; an equipment status indicator, a measurable parameter (onsite or offsite); a discrete, observable event; results of analyses; entry into specific emergency operating procedure; or another phenomenon which, if it occurs, indicates entry into a particular emergency class.

Planning Standard D CEP Rev 47

Page 60 of 226 The severity of the emergency classification may change over time with the emergency being upgraded from one classification level to another. Incidents will typically be classified in a lower emergency classification at first and then escalated to a higher classification if the situation deteriorates. Each of the four emergency classification levels has characteristic Emergency Action Levels for various parameters.

Table 2 is the EAL Initiating Conditions for modes 1 through 4. Table 3 describes the EAL Initiating Conditions for the various Emergency Condition Categories (ECCs) for Modes 1 through 6 and defueled. Table 4 describes the Initiating Conditions for Modes 5 and 6 and defueled condition (shutdown).

D.2. Initiating Conditions Initiating Condition - One of a predetermined subset of nuclear power plant conditions where either the potential exists for a radiological emergency or such an emergency has occurred.

Some of the initiating conditions and events are directly identifiable by their existence, such as operation of a safety system or a fire, while others require observation of process or radiation monitoring instrumentation.

Station procedures contain the specific instrumentation, equipment status, and non-process conditions and events that are used to establish the emergency classification.

Table 2 is the EAL Initiating Conditions for modes 1 through 4. Table 3 describes the EAL Initiating Conditions for the various Emergency Condition Categories (ECCs) for Modes 1 through 6 and defueled. Table 4 describes the Initiating Conditions for Modes 5 and 6 and defueled condition (shutdown).

D.2.1 Emergency Declaration Timeliness Station procedures contain instructions to declare an emergency within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.

Planning Standard D CEP Rev 47

Page 61 of 226 Table 2 EAL INITIATING CONDITIONS - Mode 1-4 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SG1 Prolonged loss of all offsite and all SS1 Loss of all offsite and all onsite AC SA1 Loss of all but one AC power SU1 Loss of all offsite AC power onsite AC power to emergency buses power to emergency buses for 15 source to emergency buses for 15 capability to emergency buses for 15 minutes or longer minutes or longer minutes or longer 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 SG1.1 SS1.1 SA1.1 SU1.1 Loss of Loss of all offsite and all onsite AC Loss of all offsite and all onsite AC AC power capability, Table S-1, to Loss of all offsite AC power capability, Emerg power to emergency 4.16KV buses T11A power to emergency 4.16KV buses T11A emergency 4.16KV buses T11A (T21A) Table S-1, to emergency 4.16KV buses AC (T21A) and T11D (T21D) (T21A) and T11D (T21D) for 15 min. and T11D (T21D) reduced to a single T11A (T21A) and T11D (T21D)

Power AND EITHER: (Note 1) power for 15 min. (Note 1)

Restoration of at least one essential bus source for 15 min. (Note 1) in < 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is not likely (Note 1) AND

CSFST Core Cooling RED PATH (F- Any additional single power source 0.2) conditions met failure will result in loss of all AC power S to SAFETY SYSTEMS System SG2 Loss of all emergency AC and vital SS2 Loss of all vital DC power for 15 Table S-1 AC Power Sources Malfunct. DC power sources for 15 minutes or minutes or longer Offsite:

longer

Unit Auxiliary Xmr TR1AB (TR2AB)

Unit Auxiliary Xmr TR1CD (TR2CD) 1 2 3 4 1 2 3 4

Reserve Auxiliary Xmr TR101AB 2 SG2.1 SS2.1 (TR201AB)

Loss of Loss of all offsite and all onsite AC Loss of all 250 VDC power based on bus None

Reserve Auxiliary Xmr TR101CD Vital power to emergency 4.16KV buses T11A voltage indications < 215 VDC on all vital (TR201CD)

DC (T21A) and T11D (T21D) for 15 min. DC buses 1CD (2CD) (Train A) and

69/4.16 kV Alternate Xfr TR12EP-1 Power AND 1AB (2AB) (Train B) for 15 min. Onsite:

Loss of all 250 VDC power based on bus (Note 1)

EDG 1AB (2AB) voltage indications < 215 VDC on all vital

EDG 1CD (2CD)

DC buses 1CD (2CD) (Train A) and 1AB (2AB) (Train B) for 15 min.

(Note 1)

Planning Standard D CEP Rev 47

Page 62 of 226 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SA3 UNPLANNED loss of Control Room SU3 UNPLANNED loss of Control Room indications for 15 minutes or longer with indications for 15 minutes or longer a significant transient in progress 1 2 3 4 1 2 3 4 Table S-3 Significant Transients 3

Reactor trip SA3.1 SU3.1 Loss of None An UNPLANNED event results in the An UNPLANNED event results in the CR

Runback > 25% thermal power inability to monitor one or more Table S- inability to monitor one or more Table S-Indications

Electrical load rejection > 25% of 2 parameters from within the Control 2 parameters from within the Control full electrical load Room Room for 15 min. (Note 1) for 15 min. (Note 1)

ECCS actuation AND Any significant transient is in progress, Table S-3 SU4 RCS activity greater than Technical Table S-2 Safety System Specification allowable limits S 4 Parameters 1 2 3 4 System RCS None Malfunct. Activity None

Reactor power SU4.1

RCS level Sample analysis indicates RCS activity >

Technical Specification 3.4.16 limits

RCS pressure SU5 RCS leakage for 15 minutes or

Core Exit TC temperature longer

Level in at least one S/G 1 2 3 4

Auxiliary feed flow in at least one SU5.1 SG RCS unidentified or pressure boundary 5 leakage > 10 gpm for 15 min.

RCS None None OR Leakage RCS identified leakage > 25 gpm for 15 min. (Note 1)

OR None Leakage from the RCS to a location outside containment > 25 gpm for 15 min.

Planning Standard D CEP Rev 47

Page 63 of 226 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SS6 Inability to shut down the reactor SA6 Automatic or manual trip fails to shut SU6 Automatic or manual trip fails to shut causing a challenge to core cooling down the reactor and subsequent manual down the reactor or RCS heat removal actions taken at the reactor control console are not successful in shutting down the reactor I 1 I 1 I 1 SS6.1 SA6.1 SU6.1 An automatic or manual trip fails to An automatic or manual trip fails to shut An automatic trip did not shut down the shut down the reactor as indicated by down the reactor as indicated by reactor reactor as indicated by reactor power 5%

reactor power 5% power 5% after any RPS setpoint is exceeded AND AND AND 6 All actions to shut down the reactor Manual trip actions taken at the reactor A subsequent automatic trip or manual trip RPS None are not successful as indicated by control console (reactor trip switches) are action taken at the reactor control console Failure reactor power 5% not successful in shutting down the (reactor trip switches) is successful in AND EITHER: reactor as indicated by reactor power 5% shutting down the reactor as indicated by

Core Cooling RED PATH (F-0.2) (Note 8) reactor power< 5% (Note 8) conditions met

Heat Sink RED PATH (F-0.3) SU6.2 S conditions met A manual trip did not shut down the reactor System as indicated by reactor power 5% after Malfunct. any manual trip action was initiated Table S-4 Communication Methods AND A subsequent automatic trip or manual trip System Onsite ORO NRC action taken at the reactor control console Plant Page X (reactor trip switches) is successful in Plant Radios X X shutting down the reactor as indicated by Plant X X X reactor power < 5% (Note 8)

Telephone SU7 Loss of all onsite or offsite communications capabilities ENS Line X X Commercial X X I 1 I 2 I 3 I 4 Telephone SU7.1 7 Microwave X X Loss of all Table S-4 onsite communication Loss of None None Transmission methods Comm. OR Loss of all Table S-4 ORO communication methods OR Loss of all Table S-4 NRC communication methods Planning Standard D CEP Rev 47

Page 64 of 226 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SU8 Failure to isolate containment or loss None of containment pressure control 1 2 3 4 SU8.1 8 Any penetration is not isolated within 15 CNMT None None min. of a VALID containment isolation Failur signal OR Containment pressure > 2.8 psig with < one full train of containment depressurization equipment operating per design for 15 min. (Note 9) (Note 1)

Table S-5 Hazardous Events SA9 Hazardous event affecting SAFETY SYSTEMS needed for the current operating

Seismic event (earthquake) mode S

Internal or external FLOODING event 1 2 3 4 System

High winds or tornado strike Malfunct. SA9.1

FIRE The occurrence of any Table S-5

EXPLOSION hazardous event AND 9

Other events with similar hazard Event damage has caused indications of Hazardous degraded performance on one train of a characteristics as determined by the SAFETY SYSTEM needed for the current None Event None SED operating mode Affecting Safety AND EITHER:

Systems

Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode

Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 11, 12)

Table F-2 Containment Radiation R/hr 1 2 3 4 1 2 3 4 1 2 3 4 VRA-1310 (2310) / 1410 (2410)

FC RCS CNMT F FG1.1 FS1.1 FA1.1 Monitor Loss Loss Potential Fission Product Loss of any two barriers AND Loss or potential loss of any two barriers Any loss or any potential loss of EITHER Loss Barriers Loss or potential loss of third barrier (Table F-1) Fuel Clad OR RCS (Table F-1) VRA 1310 1,000 200 9,100 (Table F-1) (2310)

VRA-1410 700 140 6,300 (2410)

Planning Standard D CEP Rev 47

Page 65 of 226 Fission Product Barrier Threshold Matrix Fuel Clad (FC) Barrier Reactor Coolant System (RCS) Barrier Containment (CNMT) Barrier Loss Potential Loss Loss Potential Loss Loss Potential Loss A. 1. An automatic or manual 1. Operation of a standby 1. A leaking or RUPTURED RCS or SG ECCS (SI) actuation required charging pump is required by SG is FAULTED outside of Tube by EITHER: EITHER: containment Leakage

UNISOLABLE RCS

UNISOLABLE RCS None None leakage leakage None

SG tube RUPTURE

SG tube leakage

2. CSFST Integrity-RED PATH (F-0.4) conditions met B. 1. CSFST Core Cooling-RED 1. CSFST Core Cooling- 1. CSFST Heat Sink-RED 1. CSFST Core Cooling-RED Inadequate PATH (F-0.2) conditions met ORANGE PATH (F-0.2) PATH (F-0.3) conditions met PATH (F-0.2) conditions met Heat conditions met AND AND Removal 2. CSFST Heat Sink-RED None Heat Sink is required None Restoration procedures not PATH (F-0.3) conditions effective within 15 min. (Note met AND 1)

Heat Sink is required C. CNMT 1. Containment radiation > 1. Containment radiation > 1. Containment radiation >

Radiation/ Table F-2 column FC Loss Table F-2 Table F-2 column CNMT None None None RCS Activity 2. Dose equivalent I-131 column RCS Loss Potential Loss coolant activity > 300 Ci/gm D. CNMT 1. Containment isolation is 1. CSFST Containment-RED Integrity or required AND EITHER PATH (F-0.5) conditions met Bypass

Containment integrity has been lost based on SED 2. Containment hydrogen judgment concentration 4%

None None None None

UNISOLABLE pathway 3. Containment pressure >

from Containment to the 2.8 psig with < one full train environment exists of depressurization

2. Indications of RCS equipment operating per leakage outside of design for 15 min. (Notes Containment 1, 9)

E. SEC 1. Any condition in the 1. Any condition in the 1. Any condition in the 1. Any condition in the 1. Any condition in the 1. Any condition in the Judgement opinion of the SED that opinion of the SED that opinion of the SED that opinion of the SED that opinion of the SED that opinion of the SED that indicates loss of the Fuel indicates potential loss of indicates loss of the RCS indicates potential loss of the indicates loss of the indicates potential loss of the Clad barrier the Fuel Clad barrier barrier RCS barrier Containment barrier Containment barrier Planning Standard D CEP Rev 47

Page 66 of 226 Table 3 EAL INITIATING CONDITIONS - Mode 1-6 & Defueled GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT RG1 Release of gaseous radioactivity RS1 Release of gaseous radioactivity RA1 Release of gaseous or liquid RU1 Release of gaseous or liquid resulting in offsite dose greater than resulting in offsite dose greater than 100 radioactivity resulting in offsite dose radioactivity greater than 2 times the 1,000 mrem TEDE or 5,000 mrem thyroid mrem TEDE or 500 mrem thyroid CDE greater than 10 mrem TEDE or 50 mrem ODCM limits for 60 minutes or longer CDE thyroid CDE 1 2 3 4 5 6 D 1 2 3 4 5 6 D 1 2 3 4 5 6 D 1 2 3 4 5 6 D RG1.1 RS1.1 RA1.1 RU1.1 Reading on any Table R-1 effluent Reading on any Table R-1 effluent Reading on any Table R-1 effluent Reading on any Table R-1 effluent radiation monitor > column GE for 15 radiation monitor > column SAE for 15 radiation monitor > column ALERT for radiation monitor > column UE for 60 min. (Notes 1, 2, 3, 4) min. (Notes 1, 2, 3, 4) 15 min. (Notes 1, 2, 3, 4) min. (Notes 1, 2, 3)

RG1.2 RS1.2 RA1.2 RU1.2 Dose assessment using actual Dose assessment using actual Dose assessment using actual Sample analysis for a gaseous or liquid meteorology indicates doses > 1000 meteorology indicates doses > 100 mrem meteorology indicates doses > 10 mrem release indicates a concentration or R mrem TEDE or 5000 mrem thyroid CDE TEDE or 500 mrem thyroid CDE at or TEDE or 50 mrem thyroid CDE at or release rate > 2 x ODCM limits for 60 Abnorm. at or beyond beyond the site boundary (Note 4) beyond the site boundary (Note 4) min.

Rad 1 the site boundary (Note 4) RS1.3 RA1.3 (Notes 1, 2)

Rad RG1.3 Field survey results indicate EITHER of Levels / Analysis of a liquid effluent sample Effluent Field survey results indicate EITHER of the following at or beyond the site indicates a concentration or release rate Rad Effluent the following at or beyond the site boundary: that would result in doses > 10 mrem boundary:

Closed window dose rates > 100 mR/hr TEDE or

Closed window dose rates > 1000 expected to continue for 60 min. 50 mrem thyroid CDE at or beyond the mR/hr expected to continue for 60 min.

Analyses of field survey samples site boundary for 60 min. of exposure

Analyses of field survey samples indicate thyroid CDE > 500 mrem for 60 (Notes 1, 2) indicate thyroid CDE > 5000 mrem for 60 min. of inhalation. RA1.4 Field survey results indicate min. of inhalation. (Notes 1, 2) EITHER of the following at or beyond the (Notes 1, 2) site boundary:

Closed window dose rates > 10 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CD > 50 mrem for 60 min. of inhalation.

(Notes 1, 2)

Planning Standard D CEP Rev 47

Page 67 of 226 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT RG2 Spent fuel pool level cannot be RS2 Spent fuel pool level at the top of the RA2 Significant lowering of water level RU2 UNPLANNED loss of water level restored to at least the top of the fuel racks fuel racks above, or damage to, irradiated fuel above irradiated fuel for 60 minutes or longer I 1 I 2 I 3 I 4 I 5 I 6 I D I I 1 I 2 I 3 I 4 I 5 I 6 I D I I 1 I 2 I 3 I 4 I 5 I 6 I D I I 1 I 2 I 3 I 4 I 5 I 6 I D I RG2.1 RS2.1 RA2.1 RU2.1 Spent fuel pool level cannot be restored to Lowering of spent fuel pool level to 1.54 ft. Uncovery of irradiated fuel in the UNPLANNED water level drop in the at least 1.54 ft. on 1(2)-RLI-502-CRI Spent on REFUELING PATHWAY REFUELING PATHWAY as indicated by low Fuel Pit Level Indication for 60 min. 1(2)-RLI-502-CRI Spent Fuel Pit Level RA2.2 water level alarm or indication 2 (Note 1) Indication Damage to irradiated fuel resulting in a AND Irradiated release of radioactivity from the fuel as UNPLANNED rise in corresponding area Fuel Table R-1 Effluent Monitor Classification Thresholds indicated by High alarm on any of the radiation levels as indicated by any of the Event following radiation monitors: following radiation monitors:

Release Monitor GE SAE Alert UE

VRS-1101/1201, Unit 1 Upper

VRS-1101/1201, Unit 1 Upper Point Containment Containment Unit Vent VRS-1500 3.3E+00 3.3E-01 3.3E-02 4.2E-03

VRS-2101/2201, Unit 2 Upper

VRS-2101/2201, Unit 2 Upper Noble (2500) Ci/cc Ci/cc Ci/cc Ci/cc Containment Containment R

Gaseous Gas

RRC-330-A/B Spent Fuel Area

RRC-330-A/B Spent Fuel Area Abnorm. Gland SRA-1800 1.6E+02 1.6E+01 1.6E+00 1.4E-01 RA2.3 Rad Seal (2800) Ci/cc Ci/cc Ci/cc Ci/cc Lowering of spent fuel pool level to 10.58 ft.

Levels / Leakoff on 1(2)-RLI-502-CRI Spent Fuel Pit Level Rad Steam Jet SRA-1900 1.5E+04 1.5E+03 1.5E+02 1.3E+01 Indication Effluent Air Ejector (2900) Ci/cc Ci/cc Ci/cc Ci/cc RA3 Radiation levels that IMPEDE access Radwaste RRS-1000 8.8E-03 to equipment necessary for normal plant Table R-2 Safe Operation & Shutdown

------- ------- operations, cooldown or shutdown Rooms/Areas Effluent Ci/cc Room / Area Mode(s)

SG 4.4E-03 I 1 I 2 I 3 I 4 I 5 I 6 I D I Liquid DRA-300 ------- ------- -------

Auxiliary Building '573 Blowdown Ci/cc 3, 4, 5 SG 3.6E-02 RA3.1 BART Area Blowdown DRA-353 ------- ------- ------- Ci/cc Dose rates > 15 mR/hr in any of the

Auxiliary Building 587' 3 Treatment following areas: Boric Acid Storage Area Rad 3, 4, 5

Unit 1 Control Room (ERS-7401) Tank Room, Nuclear Levels

Unit 2 Control Room (ERS-8401) Sampling Room

Central Alarm Station (by survey)

Auxiliary Building 609' RA3.2 4KV Room (Mezzanine An UNPLANNED event results in Area), Boric Acid Batch 3, 4, 5 radiation levels that prohibit or IMPEDE Tank Area, Chemistry access to any Table R-2 rooms or areas Hot Lab, RHR Hx (Note 5) Room Planning Standard D CEP Rev 47

Page 68 of 226 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HS1 HOSTILE ACTION within the plant HA1 Hostile action within the OWNER HU1 Confirmed SECURITY CONDITION PROTECTED AREA CONTROLLED AREA or airborne attack or threat threat within 30 minutes 1 2 3 4 5 6 D 1 2 3 4 5 6 D 1 2 3 4 5 6 D HS1.1 HA1.1 HU1.1 A HOSTILE ACTION is occurring or has A HOSTILE ACTION is occurring or has A SECURITY CONDITION that does not 1 None occurred within the plant PROTECTED occurred within the OWNER involve a HOSTILE ACTION as reported Security AREA as reported by the Security Shift CONTROLLED AREA as reported by the by the Security Shift Supervisor Supervisor Security Shift Supervisor OR OR Notification of a credible security threat A validated notification from NRC of an directed at the site H aircraft attack threat within 30 min. of the OR Hazards site A validated notification from the NRC providing information of an aircraft threat HU2 Seismic event greater than OBE levels 1 2 3 4 5 6 D 2 HU2.1 Seismic None None None Control Room personnel feel an actual or Event potential seismic event AND The occurrence of a seismic event is confirmed in manner deemed appropriate by the Shift Manager Planning Standard D CEP Rev 47

Page 69 of 226 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HU3 Natural or Technological Hazard 1 2 3 4 5 6 D HU3.1 A tornado strike within the PROTECTED AREA HU3.2 Internal room or area FLOODING of a magnitude sufficient to require manual or automatic electrical isolation of a 3 SAFETY SYSTEM component needed H Natural or None None None for the current Hazards Technological operating mode Hazard HU3.3 Movement of personnel within the plant PROTECTED AREA is IMPEDED due to an event external to the PROTECTED AREA involving hazardous materials (e.g., an offsite chemical spill or toxic gas release)

HU3.4 A hazardous event that results in onsite conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7)

Planning Standard D CEP Rev 47

Page 70 of 226 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HU4 FIRE potentially degrading the level of safety of the plant 1 2 3 4 5 6 D HU4.1 A FIRE is not extinguished within 15 min. of any of the following FIRE detection indications (Note 1):

Report from the field (i.e., visual observation)

Table H-1 Fire Areas

Receipt of multiple (more than 1) fire alarms

Control Room or indications

Containment

Field verification of a single fire alarm

Auxiliary Building AND The FIRE is located within any Table H-1 4

Switchgear Areas area.

Fire

Diesel Generator Rooms HU4.2

ESW System Enclosures Receipt of a single fire alarm (i.e., no other None None

AFW Pump Rooms indications of a FIRE) AND The fire alarm is

Refueling Water Storage Tank indicating a FIRE within any Table H-1 area

Condensate Storage Tank AND The existence of a FIRE is not verified within 30 min. of alarm receipt (Note 1)

H HU4.3 A FIRE within the plant or ISFSI PROTECTED Hazards AREA not extinguished within 60 min. of the initial report, alarm or indication (Note 1)

HU4.4 A FIRE within the plant or ISFSI PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish Table H-2 Safe Operation & Shutdown Rooms/Areas HA5 Gaseous release IMPEDING access to equipment necessary for normal plant Room / Area Mode(s) operations, cooldown or shutdown

Auxiliary Building '573 3, 4, 5 BART Area 1 2 3 4 5 6 D

Auxiliary Building 587' 5 Boric Acid Storage Tank Hazardous None 3, 4, 5 None Room, Nuclear Sampling HA5.1 Gases Room Release of a toxic, corrosive, asphyxiant or

Auxiliary Building 609' flammable gas into any Table H-2 rooms or 4KV Room (Mezzanine areas AND Area), Boric Acid Batch 3, 4, 5 Entry into the room or area is prohibited or Tank Area, Chemistry IMPEDED (Note 5)

Hot Lab, RHR Hx Room Planning Standard D CEP Rev 47

Page 71 of 226 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HS6 Inability to control a key safety HA6 Control Room evacuation resulting function from outside the Control Room in transfer of plant control to alternate locations 1 2 3 4 5 6 D 1 2 3 4 5 6 D HS6.1 HA6.1 An event has resulted in plant control An event has resulted in plant control 6 being transferred from the Control Room being transferred from the Control Room Control None None to the Local Shutdown Instrumentation to the Local Shutdown Instrumentation Room AND Evacuation Control of any of the following key safety functions is not reestablished within 15 min. (Note 1):

Reactivity control (modes 1, 2 and 3 only)

Core cooling

RCS heat removal HG7 Other conditions exist which in the HS7 Other conditions existing that in the HA7 Other conditions exist that in the HU7 Other conditions existing that in the judgment of the Site Emergency Director judgment of the Site Emergency Director judgment of the Site Emergency Director judgment of the Site Emergency Director H warrant declaration of a GENERAL warrant declaration of a SITE AREA warrant declaration of an ALERT warrant declaration of a UE Hazards EMERGENCY EMERGENCY 1 2 3 4 5 6 D 1 2 3 4 5 6 D 1 2 3 4 5 6 D 1 2 3 4 5 6 D HG7.1 HS7.1 HA7.1 HU7.1 Other conditions exist which in the Other conditions exist which in the Other conditions exist which, in the Other conditions exist which in the judgment of the SED indicate that events judgment of the SED indicate that events judgment of the SED, indicate that judgment of the SED indicate that events are in progress or have occurred which are in progress or have occurred which events are in progress or have occurred are in progress or have occurred which 7 involve actual or IMMINENT substantial involve actual or likely major failures of which involve an actual or potential indicate a potential degradation of the SED core degradation or melting with plant functions needed for protection of substantial degradation of the level of level of safety of the plant or indicate a Judgement potential for loss of containment integrity the public or HOSTILE ACTION that safety of the plant or a security event security threat to facility protection has or HOSTILE ACTION that results in an results in intentional damage or that involves probable life threatening been initiated. No releases of radioactive actual loss of physical control of the malicious acts, (1) toward site personnel risk to site personnel or damage to site material requiring offsite response or facility. Releases can be reasonably or equipment that could lead to the likely equipment because of HOSTILE monitoring are expected unless further expected to exceed EPA Protective failure of or, (2) that prevent effective ACTION. Any releases are expected to degradation of SAFETY SYSTEMS Action Guideline exposure levels access to equipment needed for the be limited to small fractions of the EPA occurs.

offsite for more than the immediate site protection of the public. Any releases are Protective Action Guideline exposure area not expected to result in exposure levels levels.

which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Planning Standard D CEP Rev 47

Page 72 of 226 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT EU1 Damage to a loaded cask CONFINEMENT BOUNDARY 1 2 3 4 5 6 D EU1.1 E Damage to a loaded cask None None None CONFINEMENT BOUNDARY as ISFSI indicated by an on-contact radiation reading:

> 60 mrem/hr (gamma + neutron) on the top of the overpack

> 600 mrem/hr (gamma + neutron) on the side of the overpack excluding inlet and outlet ducts Planning Standard D CEP Rev 47

Page 73 of 226 Table 4 EAL INITIATING CONDITIONS - Mode 5-6 & Defueled GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT CG1 Loss of RCS inventory affecting CS1 Loss of RCS inventory affecting CA1 Significant loss of RCS inventory CU1 UNPLANNED loss of RCS fuel clad integrity with containment core decay heat removal capacity inventory challenged 5 6 5 6 5 6 5 6 CG1.1 CS1.1 CA1.1 CU1.1 RCS level cannot be monitored for RCS level cannot be monitored for 30 Loss of RCS inventory as indicated by UNPLANNED loss of reactor coolant 30 min. (Note 1) min. (Note 1) RCS level < 614.0 ft. results in RCS water level less than a AND AND CA1.2 required lower limit for 15 min. (Note Core uncovery is indicated by any of Core uncovery is indicated by any of RCS water level cannot be monitored 1) 1 the following: the following: for 15 min. (Note 1) CU1.2 RCS

UNPLANNED increase in any Table

UNPLANNED increase in any Table AND EITHER RCS water level cannot be monitored Level

UNPLANNED increase in any Table AND EITHER C-1 sump/tank level of sufficient C-1 sump/tank level of sufficient magnitude to indicate core uncovery magnitude to indicate core uncovery C-1 sump/tank level due to a loss of

UNPLANNED increase in any Table

High alarm on Containment radiation

High alarm on Containment radiation RCS inventory C-1 monitor VRA-1310 (2310) or VRA- monitor VRA-1310 (2310) or VRA-

Visual observation of UNISOLABLE sump/tank level due to loss of RCS C 1410(2410) 1410(2410) RCS leakage inventory Cold

Erratic Source Range Monitor

Erratic Source Range Monitor

Visual observation of unisolable RCS SD/Refuel indication indication leakage System AND Malfunct. Any Containment Challenge indication, Table C-2 CA2 Loss of all offsite and all onsite CU2 Loss of all but one AC power AC power to emergency buses for 15 source to emergency buses for 15 minutes or longer minutes or longer 5 6 D 5 6 D 2 CA2.1 CU2.1 Loss of Loss of all offsite and all onsite AC AC power capability, Table C-3, to Emerg None None power to emergency 4.16KV buses emergency 4.16 kV buses T11A AC T11A (T21A) and T11D (T21D) for (T21A) and T11D (T21D) reduced to a Power 15 min. (Note 1) single power source for 15 min. (Note 1)

AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Planning Standard D CEP Rev 47

Page 74 of 226 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT CA3 Inability to maintain plant in cold CU3 UNPLANNED increase in RCS shutdown temperature 5 6 5 6 CA3.1 CU3.1 3 UNPLANNED increase in RCS UNPLANNED increase in RCS RCS None None temperature to > 200°F for > Table C-4 temperature to > 200°F (Note 10)

Temp. duration CU3.2 C (Note 1, 10) Loss of all RCS temperature and RCS Cold OR level indication for 15 min. (Note 1)

SD/Refuel UNPLANNED RCS pressure increase System > 10 psig (This EAL does not apply Malfunct during water-solid plant conditions).

CU4 Loss of Vital DC power for 15 minutes or longer 4

Loss of 5 6 Vital None None None CU4.1 DC

< 215 VDC bus voltage indications on Power Technical Specification required 250 VDC vital buses for 15 min. (Note 1)

Planning Standard D CEP Rev 47

Page 75 of 226 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT CU5 Loss of all onsite or offsite communications capabilities 5 6 D CU5.1 5 Loss of all Table C-5 onsite Loss of None None None communication methods Comm. OR Loss of all Table C-5 ORO communication methods OR Loss of all Table C-5 NRC communication methods CA6 Hazardous event affecting SAFETY SYSTEMS needed for the C current operating mode Cold 5 6 SD/Refuel System CA6.1 Malfunct The occurrence of any Table C-6 hazardous event AND 6 Event damage has caused indications Hazardous of degraded performance on one train Event None None None of a SAFETY SYSTEM needed for the Affecting current operating mode AND EITHER:

Safety

Event damage has caused Systems indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode

Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 11, 12)

Planning Standard D CEP Rev 47

Page 76 of 226 Table C-1 Sumps / Tanks Table C-2 Containment Challenge Indications Table C-3 AC Power Sources Offsite:

Reserve Auxiliary Xmr TR101AB (TR201AB)

Reserve Auxiliary Xmr TR101CD (TR201CD)

Containment Sumps

CONTAINMENT CLOSURE not established (Note 6)

69/4.16 kV Alternate Xmr TR12EP-1

Auxiliary Building Sumps

Containment hydrogen concentration 4%

Main Xmr TR1 (TR2) backfeed (only if already

RWST

UNPLANNED rise in Containment pressure aligned)

RCDT Onsite:

EDG 1AB (2AB)

EDG 1CD (2CD)

Table C-4 RCS Reheat Duration Thresholds Table C-6 Hazardous Events Containment Heat-Up RCS Status

Seismic event (earthquake)

Closure Status Duration

Internal or external FLOODING INTACT (but not N/A 60 min.* event REDUCED INVENTORY)

High winds or tornado strike Not INTACT established 20 min.*

FIRE OR

EXPLOSION REDUCED INVENTORY not established 0 min.

Other events with similar hazard characteristics as determined by the

If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not SED applicable Table C-5 Communication Method System Onsite ORO NRC Plant Page X Plant Radios X X Plant Telephone X X X ENS Line X X Commercial Telephone X X Microwave Transmission X X Notes Note 1: The SED should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Planning Standard D CEP Rev 47

Page 77 of 226 Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer VALID for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Note 5: If the equipment in the listed room or area was already inoperable or out-of-service before the event occurred, then no emergency classification is warranted.

Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a GENERAL EMERGENCY is not required.

Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

Note 8: A manual trip action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

Note 9: One Containment Spray System train and one Containment Air Recirculation Fan comprise one full train of depressurization equipment.

Note 10: Begin monitoring hot condition EALs concurrently for any new event or condition not related to the loss of decay heat removal.

Note 11: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.

Note 12: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted 1 2 3 4 5 6 D Modes: Power Startup Hot Standby Hot Shutdown Cold Shutdown Refueling Defueled Operation Planning Standard D CEP Rev 47

Page 78 of 226 PLANNING STANDARD E NOTIFICATION METHODS AND PROCEDURES Planning Standard E CEP Rev 47

Page 79 of 226 E. NOTIFICATION OF EMERGENCY RESPONSE PERSONNEL AND ORGANIZATIONS E.1. Notification of Offsite Response Organizations During an emergency condition, control of offsite actions rests with the appropriate government authorities with technical assistance provided by various members of the plant staff. This technical assistance is provided through the use of the plants communication system.

A current list of all key support agencies with their telephone numbers is maintained in the Shift Managers office so that they may be notified of any emergency condition. This call list is incorporated into the plant Emergency Plan Procedures and is checked quarterly to verify that all phone numbers on the list are correct. It is the responsibility of the SM, acting as the SED early in an event, the SED, or the ED, once the EOF is operational, to ensure that these offsite response organizations are notified. Notification shall include the message authentication in order to permit further action by the Sheriffs Department.

Notification is given to the Berrien County Sheriffs Department and to the Michigan State Police Operations Office in Lansing, Michigan within 15 minutes following the recognition and verification of an Unusual Event, Alert, Site Area Emergency, or General Emergency condition.

Any incident that requires initiation of the Nuclear Emergency Alarm requires notification of the NRC and notification of the appropriate offsite groups.

Upon notification with authentication, the Berrien County Emergency Operations Plan will be implemented.

The Berrien County Sheriffs Department has established a county Emergency Operating Center (EOC) in Benton Harbor, Michigan, which will be the focal point for immediate offsite county agency actions when notified of an emergency condition. The Berrien County Sheriff is the Berrien County Administrator of the Office of Emergency Management/Homeland Security and is responsible for coordinating all local resources when notified of an emergency condition. An offsite liaison is sent to the Berrien County EOC at the emergency classification of Alert or higher classification. The liaison assists in the interpretation of incoming plant reports, and acts as the liaison between the Plant and the Berrien County Sheriffs Department.

The organization of the Department of State Police is such that initial notification is made to the Michigan Intelligence Operations Center (MIOC) in Lansing, Michigan. The Michigan State Police will then set up an EOC at 7150 Harris Drive; Dimondale, MI 48821. An offsite liaison will also be sent to the State EOC upon activation by the State Police to perform a function similar to that of the person at the Berrien County EOC. Plant status updates will be provided to the State and County using separate lines. All communications, where practical, to the State and County will be via the offsite liaison at their respective EOCs.

Immediately following the initial notification of the Berrien County Sheriffs Department and the Michigan State Police, the SM/SED/ED shall also notify the Nuclear Regulatory Commissions Operations Center, and the appropriate senior AEPNGG management.

The decision to evacuate offsite individuals or to take other protective action rests with the appropriate civil authorities. The SED or ED is responsible for notifying the appropriate State/County authorities that the conditions for offsite protective actions have been reached.

Figure 8 shows the initial notification process for nuclear incidents. A current list of all appropriate company officials and county, state and federal authorities with their telephone numbers is maintained as part of the plant ERO Phone Directory. A listing of offsite support groups is attached as Appendix B.

Planning Standard E CEP Rev 47

Page 80 of 226 E.1.a Notification of Nuclear Transportation Accidents Incidents involving nuclear material that result from transportation accidents offsite as specified in Section C.4.b and within the service territory of AEP shall be reported to the applicable state government. The appropriate information required in Sections E.3 and E.4 and other pertinent information shall be provided as necessary. If the Plant has been requested to respond to a transportation accident involving nuclear material by another utility under the Voluntary Assistance Agreement, the Plant shall inform the state and Berrien County government of the request, nature and location of the accident, expected response and recommended precautions to be taken by the responsible offsite authorities. The response team shall keep the on-scene government representatives and the Plant informed on the status of the accident.

E.2 ERO Alert, Notification and Mobilization E.2.a Onsite (Plant Staff)

If an emergency condition should arise that would affect individuals on or offsite, this emergency plan will be initiated. There are two plant emergency alarms: A Fire Alarm and a Nuclear Emergency Alarm. Each audible signal is unique and easily distinguishable so that no confusion as to its purpose will develop.

If the incident or condition is a fire, the Fire Alarm is sounded.

The Nuclear Emergency Alarm is a horn designed to produce a distinct sound different from any other alarms in the plant. It may be activated manually from either the Unit 1 Control Room or Unit 2 Control Room. The senior supervisor of the on-duty shift (e.g., the Shift Manager) has the authority to activate the Nuclear Emergency Alarm. In the absence of the Shift Manager, the senior NRC licensed operator assigned in the Control Room has the authority to activate the Nuclear Emergency Alarm. An announcement over the Plant Public Address System (PA) identifying the incident will be made including a brief description of the incident, and the appropriate alarm for the determined condition will be sounded throughout the plant and at the switchyards. In addition, in certain areas where the PA system and/or the Nuclear Emergency Alarm are not audible, strobe lights are installed to provide a visual warning signal.

In the case of some Security events, the Nuclear Emergency Alarm would not be sounded.

Persons responding to the NEA could become targets of opportunity. Instructions to onsite personnel would be made using the Plant PA system.

Immediate sounding of the Nuclear Emergency Alarm is required for incidents which, in the judgment of the Shift Manager, result in:

release of radioactivity that could cause conditions for excessive exposure to plant personnel, or plant conditions that could cause conditions for excessive exposure to plant personnel, or a Site Area Emergency, or General Emergency, except where harm to personnel is possible (e.g. Security event driving the SAE or GE).

Planning Standard E CEP Rev 47

Page 81 of 226 The sounding of the Nuclear Emergency Alarm dictates an immediate evacuation of all plant personnel and plant visitors to the onsite assembly areas identified in Section J.1. with the exceptions that:

1. The operators on duty for each unit report to their respective Control Room.

2. Personnel designated as part of the plant Emergency Response Organization report to their assigned facilities. (i.e. TSC, OSC, EOF, ENC/JIC)

3. Individuals in outlying areas of the plant are informed by Site Protective Services of the emergency classification in effect and the action to be taken.

4. Security personnel will remain on post unless otherwise directed.

5. Initiation of the procedures for evacuation of all employees and visitors within the Cook Energy Information Center.

Immediately after initiation of the Nuclear Emergency Alarm, the emergency call list is initiated, if not already initiated, and measures are taken by the Shift Manager and Shift Technical Advisor to evaluate conditions on the site.

The decision to take onsite protective actions, beyond sounding of the Nuclear Emergency Alarm is the responsibility of the SED. Any Emergency Plan incident other than routine tests that requires initiation of the Nuclear Emergency Alarm requires notification of the NRC by the SED or ED and notification of appropriate offsite groups as determined by the SED or ED.

E.2.b Offsite (Plant Staff)

An Emergency Plan Procedure for notification of plant personnel and an ERO Phone Directory have been developed to provide the information that is necessary to summon plant personnel during emergency conditions to staff the Emergency Response Facilities. This procedure may be implemented anytime the SED determines that it is necessary to augment on duty emergency personnel with off-duty plant personnel.

A current list of all key personnel with their telephone numbers is maintained in the Shift Managers office so that they may be notified. This call list is incorporated into the ERO Phone Directory and is checked quarterly to verify that all phone numbers on the list are correct. When the Nuclear Emergency Alarm is sounded, notification of the Site Vice President (or Alternate),

and Operations Director is the responsibility of the Shift Manager or designee. Calls made by on-shift personnel initiate the ERO call out to staff the Emergency Response Facilities. If the automated ERO Notification System (ERONS) fails, a backup manual call out procedure is initiated.

Personnel that are called out, or are on call, report to their assigned Emergency Response Facility immediately upon receiving notification to respond at an Alert or higher emergency classification.

In the event of security related event the notification alerts the emergency response personnel, who normally report to on-site facilities, to report to an alternate location such as the Buchanan Office Building.

Once the Nuclear Emergency Alarm has sounded, only authorized personnel are permitted to enter the Owner Controlled Area. This access control is a function of the Plant Security Force which may be further augmented by the Berrien County Sheriff and/or the Michigan State Police.

Planning Standard E CEP Rev 47

Page 82 of 226 E.3. Content of Initial Emergency Messages Initial emergency messages sent from the Plant to appropriate offsite response organizations shall contain the information listed below, as it becomes available.

1. Class of Emergency.

2. Date and time of classification.

3. Indicate if a release is occurring or has occurred.

4. Protective Measures recommended (if known) based on magnitude or severity of an actual release and current meteorological conditions, or the condition of the core/containment.

5. Potentially affected population areas.

6. Plant name

7. Verification to confirm authenticity of communication.

E.4 Content of Follow-up Emergency Messages Follow-up messages sent from the Plant to appropriate offsite response organizations should contain the following information, as it becomes available:

1. Location of incident, name and telephone number (or communication channel identification) of caller.

2. Type and description of release (airborne, waterborne, surface spill) and estimated duration/impact times (actual or projected).

3. An estimate of the quantity of radioactive material released or being released and the release point.

4. Physical form of released material, including estimates of the relative quantities of noble gases, iodines and particulates.

5. Meteorological conditions (wind speed, direction, atmospheric stability, or precipitation, if any).

6. Projected dose rate at site boundary, integrated dose from time of message to projected end of release at site boundary.

7. Projected dose rate and integrated dose for 2, 5 and 10 miles.

8. Prognosis for worsening or terminating the event based on plant information.

E.5 Not Applicable E.6. Public Notification The Berrien County Sheriff is responsible for overall supervision of the warning function for offsite actions.

Planning Standard E CEP Rev 47

Page 83 of 226 The Berrien County Emergency Operations Plan-Nuclear Power Plant Incident Procedures contain the time estimated for adverse and favorable conditions for various sectors in the 10 mile EPZ for 2 mile, 5 mile, and 10 mile radii. The time estimates include the times required for:

Notification Public Preparation Movement Total Evacuation Confirmation Evacuation & Confirmation Special Considerations to include or consider in each sector The Berrien County Plan includes provisions for:

1. Alerting local radio, television stations and, local news media to be prepared to transmit Emergency Public Information.

2. Coordination with other law enforcement and fire services to extend public notification of the appropriate Emergency Plan areas utilizing public address systems on emergency vehicles.

3. Warning of the Warren Dunes park (recreation) area populace of the emergency and action to be taken.

4. Activation and use of the Integrated Public Alert Warning System (IPAWS).

Activation of this system is controlled solely by the Berrien County Sheriff and is based upon recommendations made by the appropriate authority.

Berrien County has overall responsibility for testing, maintenance, and repair of the Integrated Public Alert Warning Systems (IPAWS).

IPAWS is the primary method for alerting and notifying the population within the plume exposure EPZ. Backup ANS for the EPZ is achieved through Route Alerting which is contained within the Alert and Notification System (ANS) Design Report and the State of Michigan and Berrien County Radiological Emergency Response Plans. Refer to Appendix B for FEMA letter describing the provisions for ANS.

A description of the warning system is in the emergency preparedness brochure/calendar provided in Appendix D, Emergency Preparedness Brochure.

E.7. Public Information Messages The State of Michigan and Berrien County have developed and incorporated in their respective emergency plans sample messages for release of information to the public.

These messages will utilize supporting information obtained directly from the Plant or from the plant liaison persons located at the Berrien County EOC, State EOC and at the JIC (when operational).

Planning Standard E CEP Rev 47

Page 84 of 226 Using the information gathered from various sources, the message(s) will contain pertinent information to the public for the declared emergency classification. The message(s) describe the warning, sheltering, evacuation and other protective measures deemed necessary by the appropriate County and/or State officials.

Additionally, Berrien County has prepared sample Public Information Bulletins to provide pertinent information on protective actions that may be taken in the event of a nuclear incident. These bulletins are shown in the Berrien County Emergency Plan.

Planning Standard E CEP Rev 47

Page 85 of 226 Figure 9 Nuclear Incident Initial Notification Process Incident Discovered Nuclear Control Emergency Room or Fire Alarm Berrien SM or

~

County Alternate Senior Vice President -

~ State Police ~

Nuclear Generation

,-- NRC Site Vice President 7

,-- Security ENC/ JIC

~ Ambulance*

NRC

>-- Resident Inspector

~

Fire Departm ent5" Emergency

>-- Pre pa redness Coordinators

Selectivelynotifiedfor support Planning Standard E CEP Rev 47

Page 86 of 226 Figure Figure 109 CNP Emergency Response Communications Flow CNP Emergency Response Communications Flow TECHNICAL CONTROL SUPPORT ROOM CENTER EMERGENCY NEWS CENTER/ /

/

OPERATIONS JOINT INFORMATION / / /

SUPPORT CENTER /

/

CENTER /

/

STATE

/

COMMUNICATIONS

/

COORDINATOR

/

NEWS EMERGENCY MEDIA &

NRC OPERATIONS PUBLIC FACILITY GOVERNOR NSSS/FUEL PROVIDER(S)

ICP I

I CONSULTANTS 1- STATE EOC 1 AMERICAN NUCLEAR I_ BERRIEN INSURERS COUNTY EOC INPO LOCAL SUPPORT SERVICES COOK NUCLEAR PLANT EMERGENCY RESPONSE FEMA COMMUNICATIONS FLOW DOE SHORT-TERM FLOW OTHER LOCAL/STATE/

FEDERAL GOVERNMENT LONG-TERM FLOW AGENCIES Planning Standard E CEP Rev 47

Page 87 of 226 PLANNING STANDARD F EMERGENCY COMMUNICATIONS Planning Standard F CEP Rev 47

Page 88 of 226 F. EMERGENCY COMMUNICATIONS F.1. Licensee, Local, State, and NRC Emergency Communications Implementation procedures for the use of communication networks to notify all parts of the emergency organization are outlined in the CNP Emergency Plan Procedures that are available in each of the emergency response facilities. The communications network consists of communications systems that are available on a 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day basis to communicate with AEP personnel, State, County, and the NRC during emergency conditions.

F.1.a. State and Local Communications The Berrien County Sheriffs Department and the Michigan State Police dispatch are continuously staffed so capability exists for 24-hour radio and telephone communication with the Plant. The telephone and radio links to the Berrien County Sheriffs Department dispatchers also accesses the county emergency response organizations. The 911 system is an alternate method to access the county emergency response organizations.

The primary means of notification to the Sheriffs Department is by telephone. As an alternate, notification of an emergency to the Sheriffs Department in Berrien County is made with a transmitter and receiver combination device from the Unit 1 Control Room. This device is operated with a frequency and a license maintained by the State of Michigan. Controls for the device are also available on the Plant Security consoles. This establishes a communication link between the Control Room and the Sheriffs Department in Berrien County.

The primary means of notification to the State Police Operations Center in Lansing is by telephone. A back-up radio system is maintained between CNP and the Michigan Department of State Police in Niles, Michigan. In this system, a radio transceiver maintained at the CNP is set at a frequency used by the State Police. These radios are equipped such that the State Police are assured that any transmissions to them originated at the Cook Plant.

Communications between CNP and the local fire departments are by means of telephone calls.

The fire departments would respond immediately upon notification of an emergency at CNP.

Radio Radio communication capability is provided to contact the Berrien County Sheriffs Department and the Michigan Department of State Police Post 53 (in Niles) from the Unit 1 Control Room, Central Alarm Station (CAS), and the Secondary Alarm Station (SAS) in the event of failure of telephone company circuits. Suitable normal and back-up power supplies are also provided.

Bridgman Local Telephone Service Local commercial telephone service provides circuits between Bridgman and the CNP.

F.1.b. Communications with Contiguous Governments in the EPZs Notifying the State of Indiana and the Michigan counties within a 50 mile radius of CNP of the incident classification, protective actions recommended, etc. is the responsibility of the Berrien County Sheriffs Department and the Michigan Department of State Police. Berrien County and Michigan is the only county and state within a 10 mile radius of CNP.

Planning Standard F CEP Rev 47

Page 89 of 226 F.1.c. Communications with Federal Emergency Response Organizations The Communications section of Appendix E, Description of Federal Radiological Assistance, outlines communication with the DOE Radiological Assistance Plan responders.

F.1.d Offsite Communications The communications system at CNP provides the versatility required in the event of a nuclear incident. The system operation utilizes private telephone lines, dedicated microwave links (OPX),

2-way radio, the normal in-plant communication system (PABX), and the capability to reach outside extensions through various system company switchboards. The emergency response centers will have the following communications capability:

PABX/ OPX Private Fire/Emer. Offsite ENS HPN Microwave Lines Radio Radios Control Room X X2 X X X TSC (SS) X X X X X X OSC X X X EOF X1 X X X X X Plant Mgrs Office X ENC/JIC X X 1 The EOF utilizes the Buchanan Office Building PABX and has access to a local commercial provider and AEP microwave capability.

2 Two telephone lines in each Control Room automatically bypass the plant PABX if it fails.

Communications between CNP and the Offsite Survey Team(s) are made by portable radios.

These radios are maintained in the dedicated survey vehicles, emergency facilities, and are assigned for use to plant operating departments.

AEP Microwave/Fiber Optics System This system allows direct communication to major media stations and AEP offices. It provides fast and reliable support for the plant in the event of an emergency. The CNP switchboard has tie trunks to Buchanan, Michigan and Fort Wayne, Indiana. Direct, dedicated microwave channels are established 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day between Cook Plant, and both Fort Wayne, Indiana and Buchanan, Michigan.

The microwave facilities at CNP are powered by their own battery that is constantly serviced by a trickle charger, powered from an AC station auxiliary. In the event of a failure in this AC line, an emergency generator automatically takes over the supply of power to the charger. The battery alone is capable of operating the microwave facilities for approximately 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

F.1.e. Alerting and Activating Emergency Response Organization and Personnel Plant Public Address System The Plant Public Address (PA) System is powered by the Critical Control Room Power Supply and is automatically switched to a backup supply from the diesel generator in the event that the normal power supply is lost.

Planning Standard F CEP Rev 47

Page 90 of 226 The Plant PA System provides paging to all major buildings of the plant including the office and service building. This system includes a five-party channel system for two-way communications.

It should be noted that this system cannot be used to notify offsite persons of an incident.

Other systems are available for this use.

Plant Private Automatic Branch Exchange Plant Telephone System The Private Automatic Branch Exchange Plant Telephone System (PABX) is powered by its own battery on a trickle charger. PABX System installations are located in areas most frequently occupied by plant personnel, including the plants emergency response organization.

Security Radio A portable radio system is installed for security communications. This system uses dual transmitters to provide a dual frequency capability. Radio coverage includes all general areas onsite. If necessary, this system can be used as a back-up means of communication onsite in the event of an emergency.

Fire and Emergency Radio A portable radio system is installed for fire and emergency communications. This system is powered from a non-emergency bus and provided with backup battery power. The fire and emergency radio coverage includes all general areas onsite, excluding containment.

This system is also utilized for medical emergencies, field team communications, etc.

F.1.f Emergency Communications with the NRC Communications with the NRC Headquarters is by dedicated telephone lines from the Control Rooms, TSC, and EOF. The Federal Telecommunications System (FTS) is used to communicate with NRC Headquarters, in White Flint, Maryland. Communications with Region III headquarters, located in Lisle, Illinois, is by commercial telephone lines and the FTS.

Health Physics Network (HPN)

A FTS telephone line has been installed between the Plant and the NRC, which is primarily intended for use during an emergency and will function as the Health Physics Network (HPN) dedicated line. A total of three extensions are located at AEP facilities in:

NRC Resident Inspectors Office TSC EOF This line will be utilized to provide specific information to the NRC regarding significant radiological events at the Plant. Information transmitted to the NRC, excluding that originating from the Resident Inspectors Office, must be approved by the appropriate emergency response management personnel prior to its transmittal.

The HPN telephones will be staffed by the licensee.

Planning Standard F CEP Rev 47

Page 91 of 226 Emergency Notification System (ENS)

The Emergency Notification System (ENS) is intended for use as the primary means for the Plant to report emergencies and other significant events to the NRC. This FTS line will serve as a dedicated line to provide operational data to the NRC during a declared emergency.

A total of five extensions are located at AEP facilities in:

TSC Control Rooms NRC Resident Inspectors Office EOF Communications over the ENS telephone will be initiated by Control Room personnel if a nuclear emergency occurs at CNP. Licensee personnel will staff the ENS telephone at the TSC when the TSC is activated.

Emergency Response Data System (ERDS)

The Emergency Response Data System (ERDS) is a direct electronic data link between CNP computer systems and the NRC Operations Center. Types of data transmitted include information on the plants primary and secondary coolant systems, safety injection system, and radiation monitoring systems. Data is updated at approximately 5-second intervals.

F.2 Medical Support Communications Communications between CNP and the offsite medical facilities are made by telephone calls and are authenticated for contaminated patients only.

F.3 Communications Systems Testing Communication links between the NRC Operations Centers and the CNP TSC and EOF via the Emergency Notification System (red phone) are tested monthly for operability. In addition, the Control Room communication link with the NRC Operations Centers is tested for operability on a daily basis.

Communication links between the Plant and Berrien County Sheriffs Department, and the Michigan Department of State Police have been established and are tested monthly at a minimum.

Communications with Offsite Survey Teams will be tested at least annually to ensure an understanding of the content of the messages in the drills.

Planning Standard F CEP Rev 47

Page 92 of 226 The majority of the communications systems are tested on a daily basis through normal use. The radio communications to the Berrien County Sheriffs Department and Michigan Department of State Police are tested daily. An annual drill is conducted with the offsite emergency response personnel including those of State and County agencies if these authorities desire to participate.

As a minimum, each annual drill (exercise) tests the communication links and notification procedures with State and County agencies to ensure the proper flow of information in the event of a nuclear incident.

Planning Standard F CEP Rev 47

Page 93 of 226 PLANNING STANDARD G PUBLIC EDUCATION AND INFORMATION Planning Standard G CEP Rev 47

Page 94 of 226 G. PUBLIC EDUCATION AND INFORMATION The utility industrys experience has consistently shown that offsite public reaction is more favorable when information originates with the utility, and that notification of appropriate county, state and federal agencies is made prior to any public announcement to ensure that the information presented is fully understood by all parties and does not conflict with news reports and information transmitted to any agencies by other sources. Press briefings will be arranged in conjunction with appropriate agency officials to permit a consistent and timely exchange of information.

The ENC/JIC personnel manage information release on the incident by:

Gathering information on the incident, preparing, and approving information releases to the media.

Providing a single location for use by the media for obtaining information about the incident.

Monitoring the broadcast media for discrepancies between approved media releases and broadcast information.

Answering questions posed by callers to the Public Inquiry telephone lines.

The ENC/JIC facility shall be activated for any Alert, Site Area Emergency, or General Emergency. The goal is to have ENC/JIC staffed approximately 90 minutes after declaration of an Alert, Site Area Emergency, or General Emergency.

G.1. Public Information American Electric Power (AEP) annually distributes emergency educational information to the public within the Emergency Planning Zone (EPZ) in conjunction with Berrien County and the Michigan Department of State Police - Emergency Management and Homeland Security Division.

Such information includes the warning methodology used in notification of the public, educational information on radiation, personnel or agencies to contact for additional information, and sheltering and evacuation procedures used in the event of a nuclear incident. Appendix D is an example of the emergency educational information material that is distributed annually.

G.2 Distribution of Public Information The above emergency educational information was distributed to the public initially and is updated annually. This information is sent to all Berrien County residences and businesses, as well as Niles and other locations served by municipal power. This mailing includes those living and working both inside and near the 10 mile EPZ. New electric service customers are sent a copy of the emergency educational information and are added to the annual mailing.

The brochure is also distributed to Warren Dunes State Park, local motels, hotels, nursing homes, marinas, and apartment complexes. Selected camping and recreational areas that are part of the 10 mile EPZ most frequently used by large segments of the transient population will also be provided with similar information. The Cook Energy Information Center Manager is responsible for the annual distribution of emergency educational information to the public within the 10 mile EPZ.

Planning Standard G CEP Rev 47

Page 95 of 226 G.3. Emergency News Center/Joint Information Center (ENC/JIC)

The Emergency News Center/Joint Information Center (ENC/JIC) provides a single location for issuing information on incidents and Company response about incidents to the news media.

The Emergency News Center/Joint Information Center (ENC/JIC) is located in the Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the plant site in Buchanan, Michigan. The ENC/JIC shares the first floor of the building with the EOF.

Media access is allowed to an auditorium area, media work area, and lobby area of the building through a guarded main entranceway. Access to all other areas and entrances to the building are locked, barricaded, or guarded to prevent media intrusion into the EOF, corporate offices, or the ERO staffed portion of the ENC/JIC.

The auditorium provides the location for briefings by the utility Spokesperson and representatives of any other agencies responding to the incident. Space and electrical power are provided for media cameras to be set up for broadcasting briefings. An area adjacent to but separate from the auditorium is set up as a media work area with desks, chairs, and phones for media use, as well as distribution of press kits and copies of releases.

A Support Staff area is set up adjacent to, but separate from the auditorium and areas accessible to the media, for communicators, statement writers and others working to support ENC/JIC operation. Fax machines, telephone lines and computers are set up to support obtaining current information and preparing press statements.

G.4. ENC/JIC Spokespersons and Public Inquiry G.4.a. Spokesperson Information Later in the event as off-site agencies activate, the ENC/JIC becomes the single location for coordinated response to the news media by the spokespersons of the Company, local and state government, the NRC, and any other agencies responding to the incident. The ENC/JIC does not become a Joint Information Center until after the declaration of a Site Area Emergency and when a representative from the state is present and declares the JIC operational.

G.4.b Spokesperson Information Exchange The ENC/JIC is staffed to provide for media release preparation and presentation, media monitoring, and public inquiry. The ENC/JIC staff also provides for support of off-site agency responders to the facility as well as support for the media representatives that use the facility.

G.4.c. Public Inquiry A Media Monitoring and Public Inquiry area is set up equipment for Media Monitors to review broadcast media reports for any inaccurate information. Rumor Control/Media Monitoring Specialists record and respond to any questions called in to the Public Inquiry extensions.

G.5 Annual Media Briefing Information is sent annually to the local news media to explain the emergency preparedness plans of the State, County, and utility. This is sent just prior to the annual Cook Emergency Plan exercise and invites the media to participate in the exercise. The role of the media in providing emergency information to the public is also explained.

Planning Standard G CEP Rev 47

Page 96 of 226 PLANNING STANDARD H EMERGENCY FACILITIES AND EQUIPMENT Planning Standard H CEP Rev 47

Page 97 of 226 H. EMERGENCY FACILITIES AND EQUIPMENT Plant personnel who are needed and are not onsite will be notified of the existing plant condition and will be directed to report to one of the following locations:

1 TSC 2 EOF 3 OSC 4 Or an alternate location in the event of unsafe plant conditions.

H.1. Technical Support Center H.1.a. TSC Functions The onsite Technical Support Center (TSC) provides plant management and technical support to plant operations personnel during emergency conditions from a location outside the Control Room.

During the short-term emergency conditions, the TSC is capable of serving the following purposes until all required response centers both on and offsite have been activated.

Providing technical support to operations personnel as requested.

Directing the activities of site personnel.

Evaluating offsite agency requests and recommendations to ensure compatibility with emergency response objectives.

The TSC shall be activated for any Alert, Site Area Emergency or General Emergency.

The TSC, combined with the Control Room, can perform the functions of the EOF until the EOF is activated.

Sufficient data to determine the plant steady state and dynamic behavior prior to and throughout the course of an accident is available for analysis in the TSC. TSC personnel shall have ready access to plant records and procedures to support detailed technical analysis and evaluation of plant conditions.

The TSC facilities may be used by plant personnel for normal daily operations as well as for training and emergency drills provided that these activities do not interfere with the immediate activation of the TSC or the continuing TSC operations in the event of an accident.

The primary NRC role in the TSC will be supportive, advisory, and observational.

H.1.b. TSC Location The TSC is located in the northeast corner of the protected area boundary and is within close walking distance should face-to-face interaction between Control Room and TSC personnel become necessary. (See Figures 10 and 11)

Planning Standard H CEP Rev 47

Page 98 of 226 An alternate location for the TSC is the Buchanan Office Building in the event of unsafe conditions at the plant.

H.1.c. TSC Staffing The TSC is staffed to provide technical support to the Control Room operating staff during accidents. The number and type of personnel assigned to the TSC and their time of arrival in the TSC may vary according to the emergency class. The TSC staff assignments are contained in Section B. The SED, or in the absence of the SED, the TSC Manager shall coordinate activities in the TSC and interface with the Control Room and the EOF.

H.1.d. TSC Design The CNP TSC is located in the northeast corner of the protected area boundary and is within close walking distance should face-to-face interaction between Control Room and TSC personnel become necessary. Because of the proximity of the TSC in the protected area, it will normally take approximately 6 minutes to travel from the TSC to the Control Rooms. The TSC houses the Plant Evaluation Team area which contains the computer workstations, communications area and equipment, and a separate office with sufficient working space for at least five NRC representatives. The TSC has been constructed to provide the same degree of radiological habitability as the Control Room under accident conditions. Concrete shielding has been provided to significantly reduce the effects of containment building radiation shine during an accident.

Radiation monitoring is provided to indicate radiation dose rates as well as airborne radioactivity levels.

The CNP TSC has been designed to:

1. Provide technical support to plant operations personnel during emergency conditions.

2. Relieve the reactor operators of peripheral duties not directly related to reactor system manipulation.

3. Prevent congestion in the Control Room.

4. If necessary, perform EOF functions for an Alert, Site Area Emergency or General Emergency until the EOF is fully functional.

The following communication systems have been provided in the TSC:

Offsite emergency radio to communicate with the Offsite Survey Teams as well as with in-plant teams, and EOF.

Dedicated line on the NRC Health Physics Network (HPN) and two dedicated lines on the NRC Emergency Notification System (ENS).

Plant intercom/PA System.

Dedicated communication circuit to the Control Room, OSC and EOF.

Fax capability.

2 private lines off the CNP PBX are dedicated for NRC use with outside capability.

Planning Standard H CEP Rev 47

Page 99 of 226 Additional telephones to be used as needed.

The TSC will not contain, but will have ready access to plant records, drawings and other documentation as required. The concept of operation of the AEP Emergency Response Organization is described in Section A.1.b.

H.1.e. TSC Data Availability Personal Computers and printers are available in the TSC that allow access to the plant LAN, stand-alone programs, and access to Plant Process Computer information.

H.1.e.1. Plant Process Computer (PPC)

The CNP Plant Process Computer (PPC) System has been developed and designed using the guidelines of NUREG-0696 and NUREG-0737, Supplement 1 to provide the plant operating and technical support personnel with the pertinent plant information to facilitate the emergency response to an accident in a timely manner and to assess the status of the critical safety functions.

This system can also be used during normal plant operations for other functions such as plant performance analysis and personnel training.

The PPC network is a data gathering, analysis, and display system that interfaces with multiple computer systems. This system consists of two similar computerized data acquisition, processing and display systems, one for each unit. The Unit 1 and Unit 2 PPCs acquire, validate, and convert analog, digital, pulse, and sequence of events inputs from process instruments into engineering units. In addition, data is acquired from the RMS, MIDAS, and from various recorders located throughout the plant. The Unit 1, Unit 2, and Simulator PPCs and the Plant System Server (PSS) computers are part of a computer network. The PPC network is used to send emergency response data to the NRC via ERDS. The Safety Parameter Display System (SPDS) is also a function that is performed by the PPC network.

The PPC system information is accessed with personal computers that access the PPC through the Plant System Server (PSS) system and the information so obtained is usually referred to as PPC data. PCs that have access to the PPC in this fashion are available in the Control Rooms, TSC, OSC, ENC/JIC, and the EOF.

H.1.e.2. Emergency Response Data System Emergency Response Data System (ERDS) is a direct electronic data link between CNP PPC system and the NRC Operations Center. Types of data transmitted include information on the plant primary and secondary coolant systems, safety injection system, and radiation monitoring systems.

H.1.e.3. Dose Assessment Program (DAP)

A Dose Assessment Program (DAP) is available in the TSC, EOF, and the Control Room. DAP is discussed in section I.4.

H.1.e.4. MIDAS Access to meteorological information via the Meteorological Information and Dispersion Assessment (MIDAS) System display is available on any of the computers in the Control Rooms, OSC, TSC, and EOF that have access to the PPC. The meteorological information is used for offsite dose assessment purposes.

Planning Standard H CEP Rev 47

Page 100 of 226 H.1.e.5. Radiation Monitoring System RMS data is available for viewing on all Emergency Response Facility LAN workstations. RMS viewing and control functions are available in the Unit 1 and Unit 2 Control Rooms.

H.2. Emergency Operations Facility H.2.a. EOF Functions The EOF provides coordination and evaluation of licensee activities during an emergency. The EOF shall be activated during an Alert, Site Area Emergency and General Emergency.

Once fully activated and staffed, the function of the EOF shall provide for:

Management of overall licensee emergency response, Coordination of radiological and environmental assessment, Determination of recommended public protective actions, Coordination of emergency response activities with federal, state, and local agencies, and Recovery functions.

To accomplish these functions, personnel shall be provided in the EOF for communications with offsite agencies and the evaluation of pertinent radiological, meteorological, and plant system data.

Once the Emergency Response Organization (ERO) has been established in the EOF, the TSC Manager will work with the Logistics Coordinator to coordinate communications with the engineering support personnel as needed to respond to the emergency.

The EOF personnel shall coordinate the emergency response activities with those of county, state and federal emergency response organizations, including the NRC and FEMA.

H.2.b. EOF Location The EOF is located on the first floor in the NGG Headquarters building in Buchanan, Michigan, which is approximately 14 miles from CNP. The EOF shares the first floor of the building with the ENC/JIC, but the media is segregated from all but a lobby area and auditorium where briefings occur and do not have access to the EOF or the EOF staff. (See Figure 11)

H.2.c. EOF Staffing The EOF shall be staffed to provide overall management of the plant resources and evaluation and coordination of plant activities during and after an accident. The EOF staff will include personnel to perform radiological evaluations, interface with offsite, and manage offsite resources.

The EOF staff assignments are contained in Section B. The ED shall be in charge of all activities in the EOF.

Planning Standard H CEP Rev 47

Page 101 of 226 H.2.d. EOF Design The EOF is located in the NGG Headquarters building in Buchanan, Michigan, which is approximately 14 miles from CNP. It occupies approximately 6400 square feet of the first floor of the building, approximately 2500 square feet of which is reserved for use by NRC personnel.

The EOF contains an operations room which includes the crisis management team, communicators, the NRC office, the dose assessors and the data display terminals. The communications are to the:

ENC/JIC State and local representatives in their respective Emergency Operation Centers NRC Emergency Operations Center (ENS and HPN telephones have been installed)

TSC and Control Room Licensee Offsite Survey Teams The EOF Manager will be in charge of all the Emergency Operations Facility communicators and status displays.

The following communication systems have been provided in the EOF:

Offsite emergency radio to communicate with the Offsite Survey Teams, TSC, and OSC.

Dedicated line on the NRC Health Physics Network (HPN) and on the NRC Emergency Notification System (ENS).

Dedicated communication circuit to the Control Room, TSC, and OSC.

Fax capability.

3 private lines dedicated for NRC use with outside capability.

Additional telephones to be used as needed.

The design of the EOF structure and organization ensures its ability to perform the following functions:

Management of overall licensee emergency response.

Coordination of radiological and environmental assessment.

Determination of recommended public protective actions.

Coordination of emergency response activities with federal, state and local agencies.

Planning Standard H CEP Rev 47

Page 102 of 226 The EOF was designed for occupancy by approximately 70 persons. The approximate occupancy, by function, is as follows:

ERO Managers and Coordinators 6 NRC Personnel 23 FEMA, State and County Personnel 3 Communicators 6 Clerical and Extra Staff 5 Assessment Staff 2 45 Ample parking spaces exist outside the EOF in the NGG Headquarters Building parking lot for the number of vehicles that can be expected during an emergency as well as space for mobile vans that will be brought in by offsite support agencies. In addition, space exists near the building that can be used for landing a helicopter should the need arise.

H.2.e. EOF Data Availability The same computer capability (PC, PPC, LAN, DAP, etc.) described for the TSC in H.1.e. is available in the EOF.

H.3. Operations Support Center (OSC)

H.3.a OSC Functions The Operations Support Center (OSC) is an onsite assembly area separate from the Control Room and the TSC where licensee operations support personnel report in an emergency.

The OSC:

Provides a location where plant logistic support can be coordinated during an emergency, and Restricts Control Room access to those support personnel specifically requested by the shift manager.

The OSC shall be activated for any Alert, Site Area Emergency, or General Emergency.

This is an assembly area for personnel to report for instructions from the OSC Manager.

Communications are provided to the Control Room, TSC, and EOF on bridge lines.

Communications are provided to Damage Control, Rescue, and Survey Teams with portable radios.

H.3.b. OSC Location The OSC is located in the basement of the Lakeside Office Building on the plant site. The classrooms, storage rooms, and offices on the north end of the basement comprise the area where the staff assigned to the OSC stage and perform their function. The remainder of the office building complex is used for assembly of the remainder of the plant staff when accountability is performed. (See Figures 10 and 11)

Planning Standard H CEP Rev 47

Page 103 of 226 The OSC will normally be located in the basement area of the Lakeside Office Building; however, this area is not intended to be fixed and may be re-located to other areas of the plant that will permit the orderly progression of work to restore the plant/unit to operational status. Any area that is used as an OSC shall be approved by the SED after the RP Department surveys the area and it is found to be radiologically acceptable.

An alternate location for the OSC is the Buchanan Office Building in the event of unsafe conditions at the plant H.3.c, OSC Staffing The OSC staff assignments are contained in Section B. The OSC Manager shall be in charge of all activities in the OSC.

H.3.d. OSC Design The OSC is located in the basement of the plants lakeside office building. Classroom space is available for assembling, briefing, and de-briefing response teams, as well as storage space for emergency response equipment such as anti-contamination clothing and survey equipment.

There shall be direct communications between the OSC and the Control Room and between the OSC and the TSC so that the personnel reporting to the OSC can be assigned to duties in support of emergency operations.

Means for analyzing air samples and environmental samples are located in the OSC. Offsite Survey Teams can return samples to the OSC for analysis. If the OSC is unavailable or inaccessible samples can be counted at Palisades Nuclear Plant (about 25 miles from CNP) or other of the contingency Offsite Laboratory Facilities.

The following communication systems have been provided in the OSC:

Offsite emergency radio to communicate with the Offsite Survey Teams, TSC, and EOF.

Dedicated communication circuits to the Control Room, TSC, and EOF.

Fax capability.

Additional telephones to be used as needed.

H.3.e. OSC Data Availability The same computer capability (PC, PPC, LAN, etc.) described for the TSC, with the exception of DAP, is available in the OSC. In addition the OSC has access capability to the Radiation Protection Dose Tracking and Control System.

H.4. AEP Emergency Organization Staffing and Activation The concept employed by AEP is to support the plant operating staff in an emergency by activating all of the Emergency Response Facilities when the operating shift determines that additional resources are necessary to respond to an event.

Planning Standard H CEP Rev 47

Page 104 of 226 At the plant, the TSC would be activated upon an Alert, or higher emergency classification and would perform its functions to support Control Room operation within the goal of 60 minutes.

These functions are to provide plant management and technical support to operations personnel; relieve the Control Room personnel of peripheral duties not directly related to plant operation; prevent congestion in the Control Room, and perform EOF functions until the EOF is activated.

The EOF will be activated for any Alert, Site Area Emergency or General Emergency and for any lesser classification as determined by the SED. The goal is to activate the EOF within 60 minutes of an Alert, or higher emergency classification. Pre-designated members of the NGG staff will report to the EOF to provide management and operations support.

When ERO members arrive at the EOF, the EOF functions are transferred from the TSC or the Control Room to the EOF. These functions are: management of overall licensee emergency response, coordination of radiological and environmental assessment, including determination of protective action recommendations for the public (when the Emergency Director position is activated), and coordination of emergency response activities with federal, state and local agencies. During this time, the EOF is in communication with the TSC.

The ENC/JIC facility will be activated at the Alert level, and becomes the JIC at a Site Area Emergency and when declared as the JIC by the State of Michigan. The goal is to activate the ENC/JIC within 90 minutes of an Alert, or higher emergency classification. The EOF will be in communication with the ENC/JIC as well as with the state and county emergency operations center. Press releases will be coordinated with the NRC, state, local and AEP ERO.

Long Term Recovery. At the plant, the TSC is providing support to the Control Room and plant operations staff. The ED is responsible for the entire recovery operation and is located in the EOF.

The EOF staff obtains its information on the plant status from the PPC terminals located in the EOF. The dose assessment and communication with the licensees Offsite Survey Teams and all other communications with offsite parties continues to be performed at the EOF. The Engineering, Design and Site Services Manager is responsible for obtaining supplementary assistance, if needed, from the other NGG personnel.

H.5. Emergency Detection CNP has nuclear and process instrumentation to detect abnormal situations. This instrumentation will provide warning to the operators so that action can be taken to avoid or mitigate the consequences of plant incidents. Detection capability is provided in the following areas:

1. Instrumentation for detecting seismic activity on the plant site and meteorological towers for monitoring and recording weather data.

2. A system for monitoring of radiation levels in selected areas of the plant, radioactivity of process streams in the plant, and liquid and gaseous discharges from the plant.

3. Instrumentation to measure tank levels in various plant systems and the pressures, temperatures, and flows of process streams.

4. Instrumentation for detecting fires in the plant and security events.

Specifically the instrumentation available to assist in determining the severity of a nuclear incident inside the containment is listed in Table 5, Critical NUREG-0737 Parameters.

Planning Standard H CEP Rev 47

Page 105 of 226 Events that do not have a potential for radiological releases but which may have a public interest are detected through the plants monitoring instrumentation, the plant computer system, audio-visual, alarm/trip indications, fire protection system, and seismic monitoring system.

H.5.a. Seismic Monitoring The seismic monitoring system consists of two forms of monitoring instrumentation, the strong motion triaxial accelerometers and the peak recording accelerometers.

The strong motion triaxial system is composed of seismic triggers, control panel, recorder, panels, accelerometers, and power supply. These components provide a means of recording the time history of a seismic event. The power supply to the system, excluding the playback instrument, is designed to provide power from a battery backup source should the AC input supply be lost.

The seismic monitoring system includes a digital computer with an uninterruptable power supply. The system has real-time analysis capability. The accelerometers for these two systems have been placed in various locations throughout the plant in such positions as to minimize inadvertent system activations.

H.5.b Radiation Monitoring System The instrumentation for determining the extent and magnitude of accidental releases of radioactive materials offsite includes the Radiation Monitoring System and meteorological instrumentation. Information from each of these sources is available in the Unit 1 and Unit 2 Control Rooms, as well as any PC with access to the Plant System Server (PSS). The RMS and Meteorological System data is available to the EOF, TSC, ENC/JIC and OSC from the PPC through the Plant System Server.

Alarms are provided for high radiation, RMS malfunctions and, where applicable, loss of sample flow on the local indication and control panel, and at the main Control Room display console via the RMS communications system.

A release can be determined from either in-plant RMS, or portable radiation instrumentation dispatched from the plant when it is possible that there has been an accidental gas release which could not be monitored by the plant RMS. Information from readings of this portable instrumentation may then be used to determine the extent of the release.

For accidents where there has been no significant release to the environs, but readings on Control Room instruments indicate a release within the containment, samples can be taken to determine the level of radioactivity therein. Tables relating the radiation levels in the containment for various accident conditions as a function of time and power history are used for comparison with actual data as an aid in determining the possible type of and severity of the accident and are contained in the Emergency Plan Procedures.

The major source of liquid effluent from the plant is through the circulating water discharge.

Identified potential sources of radioactive releases to the circulating water system are monitored by the process monitors of the Radiation Monitoring System.

For long-term events which may have some impact on the environment, additional REMP sampling stations may be provided as necessary.

The Radiation Monitoring System instrumentation is divided into analog and digital systems.

Planning Standard H CEP Rev 47

Page 106 of 226 Additional information on the monitor functions and range can be found in the UFSAR, Offsite Dose Calculation Manual, OP Drawings, and Technical Specifications Bases sections.

H.5.b.1. Analog System Four Containment High Range Radiation Monitors (CHRRM) are installed (two per containment, 1(2)-VRA-1310/1410(2310/2410) to provide dose rate indications for each Units upper and lower containment volume. CHRRM dose rate values are displayed on the PPC and inputs to DAP.

H.5.b.2. Digital System The digital RMS consists of a number and variety of radiation detectors, computer servers, local processors, flow & pressure switches, relays, controllers, local & remote displays and control terminals in addition to audible and visual status indicators. Local processing units gather, store and transmit data, perform calculations and operability verifications, provide a means for calibration, retain channel parameter information and history files, determine operation & alarm status and communicate with system servers.

Each reactor unit at CNP is equipped with an RMS server. These two servers are functionally identical. One server communicates with all field monitors to obtain, process and log operational status and data. This server relays user commands initiated from either of the two, RMS touchscreens located in each Control Room or from the RP Tech Spec Technician workstation. User commands to change alarm or operational set points, start/stop sample pumps, initiate or terminate check source operations may be initiated remotely or performed locally. The second server operates in Standby, collecting data, ready to assume control of system functions in the event of a server failure or outage.

a. RMS Process Monitors provide local and remote radiation level indication, alarm annunciation, monitor status and process flow isolation, where necessary. Monitor information is available locally, in both Control Rooms and at the RP Tech Spec Technicians workstation. A common high radiation alarm is annunciated and the initiating device(s) identity is printed or logged at the control terminals.

b. Area Radiation Monitors are located in most filter cubicles, pump rooms and hallways of the Auxiliary Building. Select areas inside each containment are equipped with radiation monitors. A number of area radiation monitors initiate trip functions upon high alarm. Radiation data is processed locally, transmitted to RMS servers and available at each RMS workstation.

A complete listing of the RMS monitors, their identification number, type of monitor, location and range is available via computer or in the Reference Section of facility binders containing the Emergency Plan Implementing Procedures issued for use.

H.5.b.3. Release Assessment Dose Assessment software is available in each Control Room, the TSC, and the EOF that calculates:

1. The site boundary dose as a function of time, meteorological conditions and release rate,

2. The dose rate as a function of distance from the plant for site boundary and beyond, and meteorological conditions.

Planning Standard H CEP Rev 47

Page 107 of 226 The above DAP software is only applicable to gaseous releases which are directly measurable from plant effluent and containment area monitors, or Offsite Survey Team measurements of plume dose rate.

In addition to the instrumentation which is immediately used by the plant personnel in detecting a radiation release from the plant, a Radiological Environmental Monitoring Program is available from which samples can be taken and analyzed.

The Radiological Environmental Monitoring Program (REMP) monitors the environment surrounding the plant. The stations from which sampling of airborne particulate, airborne I-131, lake water, well water, external radiation, etc. are located in the Plants surrounding environs and are identified in appropriate plant procedures.

With the existing instrumentation available to plant personnel, the evaluation of the release and the estimation of the resultant radiation levels at distances from the site boundary can be made without the need to use the Radiological Environmental Monitoring Program sample stations.

For long-term events which may have some impact on the environment, additional REMP sampling stations may be established.

H.5.c. Process Monitoring Plant operating parameters including pressures, temperatures, volumes, and flowrates for systems, as well as RMS and meteorology are available throughout the ERO facilities on PCs that access the PPC information through the Plant System Server (PSS).

H.5.d Fire Protection The fire protection detection system is comprised of two general types of detectors. They are thermal detectors and products of combustion detectors. The thermal detectors are designed to detect thermal energy output (i.e., heat from a fire). The products of combustion detectors are designed to detect particles, smoke, or infrared radiation.

The fire detection systems provide an alarm and/or actuate fire suppression systems. Alarm functions generally include:

Annunciation in the Control Rooms, Audible overall plant fire horns for those suppression systems which are actuated by detection systems, Audible and/or visual alarms for gaseous suppression systems actuated by detection systems.

H.5.d.1. Types of thermal detectors in use at the plant are as follow:

Thermistor A thermistor is a continuous line heat detector. When an over heat condition occurs anywhere along the thermistor, the resistance drops which is sensed by the control panel.

The control panel activates an alarm and/or automatic fire suppression systems.

Planning Standard H CEP Rev 47

Page 108 of 226 Fusible Entity Detector/Actuators Fusible Entity Detectors are used to activate sprinkler systems by melting at predetermined temperatures allowing water to be released from the sprinkler heads. The types of plant sprinkler systems employing this type of detector/actuators are:

Wet Pipe Sprinkler System The piping is always full of water under pressure, so that, if exposed to fire, the sprinkler head is activated and water will instantly flow from the open head onto the fire, and at the same time provides an alarm of such activation and water flow.

Preaction Sprinkler System These systems are used in areas subject to freezing temperatures or where there is a possibility of water damage from accidental operation or a break in the piping system.

In these systems, there are two piping systems one for air (pilot) and one for water.

Sprinklers (pilot heads) with a lower temperature rating are installed in the air (pilot) piping system as compared to those installed in the water piping system. The air pressure in the pilot piping keeps a control valve closed. When the pilot heads operate from a fire, the air in the pilot piping is vented and the control valve opens allowing water to fill the water piping. At this point, the system operates the same as a wet pipe sprinkler system.

H.5.d.2. Types of products of combustion detectors in use at the plant are as follow:

Ionization Type Responds to an abnormally high concentration of invisible particles of combustion products that are ionized by a radioactive source located in the detector chamber.

Photoelectric Type Responds to visible smoke in the detector chamber which causes a light source in the detector to be refracted and reflected into a photoelectric cell.

Infrared Flame Detector Responds directly to the presence of the infrared radiation emanating from flames, which flicker between the frequencies of 5 to 30 C.P.S.

H.6 Offsite Monitoring and Analysis Equipment H.6.a. Geophysical (Meteorological, hydrologic, seismic)

A contract is maintained with a commercial weather service for meteorological forecast services, and for an alternate source of meteorological data if the plant site meteorological system is unavailable. As a back-up for the contract service the NOAA Weather Service Forecast broadcasts are accessed through a plant phone extension, as well as being available from weather radios.

Phone numbers for the National Earthquake Information Center are maintained PMP-2080-EPP-101, Emergency Classification. The center can be contacted for confirmation of, or information on seismic events.

Planning Standard H CEP Rev 47

Page 109 of 226 H.6.b. Radiological Monitoring Emergency Plan Procedures establish the means of assuring that adequate emergency equipment is stocked at designated points for use in emergencies dealing with radiological hazards. The emergency equipment includes, but is not limited to:

Air samplers with assorted cartridges Ion chambers Geiger counters Respirators Personal dosimetry Plant procedures identify the requirement for emergency equipment to be inventoried and checked at specified times to ensure that the supplies and equipment are properly maintained and available for use. Emergency equipment is kept at some offsite locations see Appendix C, Emergency Kits and Equipment Locations, for locations.

Appendix B contains agreements with offsite support agencies including agreements with other utilities for assistance during emergencies at nuclear power stations.

Appendix E contains information about assistance and resources, including instrumentation, available through the DOE Radiological Assistance Plan.

H.6.c Offsite Laboratory Facilities In the event that it becomes necessary to use offsite laboratories for analysis of samples the following facilities may be contacted and the analysis performed depending on the type of samples (See Appendix H, Radiological Response Support Service Capabilities):

Teledyne Isotopes Inc.

Argonne Laboratory (DOE)

There is also a Reciprocal Laboratory Use Agreement with Palisades Nuclear Plant (see Appendix B).

H.7. Radiological Environmental Monitoring The CNP uses a pressurized water reactor with a radwaste holdup and treatment system that has been designed to keep radioactive releases to as low as practical levels. However, small quantities of noble gases and other radionuclides that are released to the environment are expected to be minuscule and insignificant as a source of potential exposure to flora and fauna in the area. However, direct radiation exposure to the public and radionuclide accumulations in various components of food chains to man is carefully monitored through the REMP. Further information on the REMP can be found in the Offsite Dose Calculation Manual (ODCM).

H.8 Meteorological System The systems meteorological towers are located inside the thermal internal boundary layer and have the ability to measure unmodified onshore airflow to detect the presence of a lake breeze.

Planning Standard H CEP Rev 47

Page 110 of 226 The meteorological system consists of monitoring information located on three towers. The primary and backup towers are located about 1-mile inland from the plant site to provide a representative determination of the meteorological conditions for emergency planning purposes.

The primary tower has instruments at the 10 and 60-meter elevations. Each elevation has a measurement of wind speed and direction. Temperature is measured at both elevations and is used to determine a delta temperature (delta T). This delta T is used in dose assessment to determine atmospheric stability. A precipitation gauge is located near the primary tower site.

The backup tower has wind speed and wind direction instrumentation located at the 10-meter elevation. Separate communication lines are provided for the main and backup towers.

The shoreline tower also has wind speed and wind direction instrumentation at the 10-meter elevation. Temperature detectors are located at the 2-meter and 10 meter elevations of the tower.

The shoreline tower is located just northwest of the plant on the shore of Lake Michigan.

The three towers are controlled by a central computer located at CNP site. The towers are polled every 15 minutes for meteorological data. The data are stored in the central computer.

Meteorological data are available from any PC with access to the PPC data.

Daily checks of the digital data are performed to ensure reliability. Erroneous data are flagged on these displays and triggers the issuance of a Work Order (WO). The WO system is used to notify the appropriate department of the problem and provides notification of the resolution to the problem. An adequate spare parts inventory is maintained at the primary tower site. Calibration of the system is performed semi-annually and is documented by the plant Instrumentation and Control Section.

Meteorological information can be obtained directly from the primary tower site using a keypad if communications with the central computer are lost. Backup meteorological information can also be obtained from a consulting firm. Forecasting information is available from the consulting firm as well as a plant extension that continuously plays NOAA weather information, and Weather Service radio.

Planning Standard H CEP Rev 47

Page 111 of 226 Figure 11 LOCATIONS OF EMERGENCY RESPONSE CENTERS

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Planning Standard H CEP Rev 47

Page 112 of 226 FIGURE 12 CNP EMERGENCY RESPONSE CENTER LOCATIONS Control Room Entry at Elev. 633 Turbine Building Technical Support Center (TSC) In the northeast corner of the Protected Area Boundary.

Operations Support Center (OSC) Plant Offices - Basement Shelter Elev. 587 Emergency Operations Facility (EOF) In Nuclear Generation Group Headquarters Buchanan -

Approximately 14 miles Southeast of CNP Emergency News Center/Joint Information Center (ENC/JIC) In Nuclear Generation Group Headquarters Buchanan -

Approximately 14 miles Southeast of CNP Planning Standard H CEP Rev 47

Page 113 of 226 TABLE 5 CRITICAL NUREG 0737 PARAMETERS PARAMETER INSTRUMENTATION Neutron Flux (Gammametrics) NRI-21, NRI-23 Reactor Coolant Pressure (Wide Range) NPS-110, NPS-111, MR-13 Reactor Coolant Outlet Temperature Thot (Wide Range) NTR-110, 120, 130 140 Reactor Coolant Inlet Temperature Tcold (Wide Range) NTR-210, 220, 230 240 Incore Thermocouples (Core Exit Thermocouples) T/C 1-65 Reactor Coolant System Subcooling Margin Monitor QR-110-3 Reactor Coolant Inventory System (Reactor Vessel Level Indication) NLI-110, 111, 120, 121, 130, 131 Pressurizer Water Level NLP-151, 152, 153 Charging Pump Flow IFI-51, 52, 53, 54 Charging Pump Breaker Status 1E, 1W, 2E, 2W Control Room Position Indicating Lights for Breakers Safety Injection Pump Breaker Status 1N, 1S, 2N, 2S Control Room Position Indicating Lights for Breakers Safety Injection Flow IFI-260, 266 Refueling Water Storage Tank Water Level ILS-950, 951 Containment Water Level NLI-320, 321, 330, 331, 340, 341 Containment Recirculation Sump Water Level NLI-300, NLI-301 Containment Pressure (Wide Range) PPA-310, 312 Containment Pressure (Narrow Range) PPP-300, 301, 302, 303 Containment Hydrogen Monitoring ESR-1 thru 9, PAS-H2-A-CR1, PAS-H2-B-CR1 Containment Isolation Valve Position Monitoring Control Room Position Indicating Lights Containment Area Radiation Monitors (High Range) Unit 1 VRA-1310, 1410, Unit 2 VRA-2310, 2410 Steam Line Pressure MPP-210, 211, 212, 220, 221, 222, 230, 231, 232, 240, 241, 242 Steam Generator Water Level (Wide Range) BLI-110, 120, 130, 140 Steam Generator Water Level (Narrow Range) BLP-110, 111, 112, 120, 121, 122, 130, 131, 132, 140, 141, 142 Auxiliary Feedwater Flow Rate FFI-210, 220, 230, 240 CCW Flow to ESF System, CCW Pump Breaker Status PP-10E, PP-10W Reactivity Control, Control Rod Position CA1-8(U1), CB1-4(U1), CA1-4(U2), CB1-8(U2), CC1-8, CD1-9, SA1-8, SB1-8, SC1-4, SD1-4 Condensate Storage Tank Level CLI-113, CLI-114 Planning Standard H CEP Rev 47

Page 114 of 226 PLANNING STANDARD I ACCIDENT ASSESSMENT Planning Standard I CEP Rev 47

Page 115 of 226 I. ACCIDENT ASSESSMENT The purpose of this section is to describe the systems, equipment, and methods for monitoring and assessing offsite consequences of actual or potential radiological emergencies.

I.1. Release Identification and Event Classification The Emergency Plan Procedures contain the information used to establish the emergency classification category based on plant system and effluent parameter values. Those initiating conditions are identified in NUMARC/NESP-007. Section D contains the plant specific EALs and initiating conditions in the Emergency Classification System tables.

I.2. Radiation Monitoring System The RMS monitors area radiation levels in most rooms and passageways of the Auxiliary Building and each containment. Effluent and process flows are monitored for radioactive material. The monitors and channels of most interest for monitoring and evaluating events for radiological impact are:

Containment Radio Gas monitors ....................................................................... 2 per unit Condenser Air Ejector Radio Gas monitors ........................................................ 1 per unit Unit Vent Radio Gas Monitors ............................................................................ 1 per unit Gland Steam Leak Off Monitors.......................................................................... 1 per unit Steam Generator Power Operated Relief Valve (PORV) Monitors...................... 4 per unit Containment High Range Area Radiation Monitors............................................. 2 per unit Process Monitors Component Cooling Loops A and B Liquid Waste Disposal Steam Generator Blowdown Sampling Essential Service Water Waste Gas Decay Tanks Waste Liquid Off-Gas Steam Generator Blowdown Treatment A complete listing of the RMS monitors, their identification number, type of monitor, location, and range is available via computer or in the Reference Section of facility binders containing the Emergency Plan Implementing Procedures issued for use. Section H.5.b contains the description of the RMS system.

1.3. Release Source Term and Magnitude Determination I.3.a. Release Source Term Calculations correcting containment dose rates as a function of time and reactor power history are contained in the plant core damage assessment procedure. Tables use the corrected containment dose rate results to provide estimates of core damage.

Estimates of core damage are used to select the source term used in the Dose Assessment Program for assessing releases.

Planning Standard I CEP Rev 47

Page 116 of 226 The Dose Assessment Program for assessing releases of radioactive material can use the source term for a release after core damage, a release of a waste gas decay tank (WGDT), a release from the spent fuel pit (SFP) or a release from the Independent Spent Fuel Storage Installation (ISFSI) to estimate dose rates.

I.3.b. Release Magnitude Effluent monitor radiation readings and effluent pathway flow rates are used to calculate the magnitude of releases.

When it is possible that there has been an accidental gas release which could not be monitored by the plant RMS survey teams dispatched from the plant perform surveys offsite with portable radiation instrumentation. Information from readings of this portable instrumentation may be used to determine the extent of the release.

I.4 Dose Assessment Evaluation A dose assessment program to quickly relate measured release rates and containment dose rates to dose and dose rates at the site boundary and beyond are maintained in the Control Rooms, TSC, and the EOF. The determination of the meteorological stability class to perform offsite dose calculations is described in the Plant Emergency Plan Procedures. Once the meteorological stability class is determined, the offsite radiation dose and dose rates at the site boundary can be estimated using the information obtained from the plant radiation monitoring instruments and/or measured offsite radiation dose rates and the dose assessment program.

A dose assessment computer program, DAP, provides a method of calculating conservative estimates of dose and dose rates at the offsite area most probably affected by a gaseous release to assist in emergency classification and Protective Action Recommendations (PAR). The Dose Assessment Program allows evaluation of several types of release scenarios with the flexibility for meteorological and radiological inputs to perform alternate evaluations to best characterize an event and the resulting protective measures. The program also allows calculations based on offsite survey results for cross comparison purposes, or a means for evaluating unmonitored releases.

In order to calculate a dose/dose rate, the program requires data on:

the radiological effluent.

containment area monitor dose rates, or offsite dose rate measurement results.

This information can be obtained from the plants RMS or from Offsite Survey Teams.

Other features included in the program are as follows:

Variable Trajectory Plume Segment Model Radioactive decay after reactor shutdown Decay and daughter in-growth during transit Ground level release Finite cloud correction Option to input offsite field survey data.

NuReg - 1228 Event Tree Modeling for Source Term Multi Accident Assessment Capability The program is run on personal computers.

Planning Standard I CEP Rev 47

Page 117 of 226 The DAP program will be used as the primary means of performing a dose assessment.

Dose Assessment Program (DAP) is a PC computer program that calculates conservative estimates of Total Effective Dose Equivalent (TEDE) and Thyroid Committed Dose Equivalent (CDE) dose rates and total projected dose, based on a radiological release, at the plant boundary and at 2, 5, and 10 mile distances. The program also uses the information to determine the Emergency Classification Level (ECL) associated with the release.

I.5 Meteorological Assessment The systems meteorological towers are located inside the thermal internal boundary layer and have the ability to measure unmodified onshore airflow to detect the presence of a lake breeze.

Meteorological data are available from any PPC capable computer. Section H.8 contains a description of the Meteorological System.

Meteorological data from the onsite meteorological tower is input into the dose assessment program. The data is used to calculate the atmospheric diffusion factor, X/Q, to determine atmospheric dispersion of radioactive material as part of the Dose Assessment Program for calculating off site doses and dose rates. Weather forecast information is also used to project changes in plume dispersion and location, which can cause changes to Protective Action Recommendations.

I.6. Not Addressed.

I.7 Radiological Field Monitoring As part of the response to any Alert, Site Area Emergency or General Emergency, one or more offsite survey teams are formed, as per plant procedures, and dispatched for sampling under radio contact. The off-site survey team driver position is normally filled by non-RPT personnel.

Qualified RP Technicians fill the position for persons performing the survey. If adequate RP and other personnel are not available onsite, personnel to staff offsite survey team(s) would be summoned per Emergency Plan procedures.

I.8. Liquid and Gaseous Release Assessment A minimum of two vehicles dedicated to Emergency Plan offsite surveys is available 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day. Additionally, keys for all normally available plant vehicles are available in the OSC in the Office Building Basement. Offsite survey team(s) deployed from onsite would have such vehicles available for use.

Each of the two dedicated offsite survey vehicles, the office building basement, and the EOF have air sampling equipment, dose rate, and count rate instrumentation in addition to radio equipment for communication with the plant.

Previous experience indicates that deployment of personnel from onsite to offsite areas takes approximately 30 minutes from the time of notification.

I.9. Off-site Radioiodine Monitoring Measurements of radio-iodine yielding sensitivity to the range of 10-8 Ci/cc can be obtained by returning the sample to the regular counting facility or to the counting area independent of the regular counting facility located in the basement area of the Office Building.

I.10. Not Addressed.

Planning Standard I CEP Rev 47

Page 118 of 226 PLANNING STANDARD J PROTECTIVE RESPONSE Planning Standard J CEP Rev 47

Page 119 of 226 J. PROTECTIVE RESPONSE J.1. Owner Controlled Area Warning and Advisement Since the PA system within the plant is extensive, an announcement of the nature of the emergency can be made to most personnel immediately.

Upon sounding of the Nuclear Emergency Alarm personnel in the outlying areas of the plant site are notified using the methods described in section E.2.a of this plan.

J.1.a. Non ERO Employees Plant employees without ERO duties and personnel temporarily assigned to the plant for training or other purposes, are required to know the location and routes to the assembly areas and be familiar with the emergency alarm procedure. Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm.

J.1.b. Visitors Groups on tour are escorted to an assembly area by their tour guide, should the Nuclear Emergency Alarm be sounded. Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm.

J.1.c. Contractors and Construction Contractors, supervisors, and/or foremen (i.e., outside labor) are provided with instructions, prior to beginning work as to the emergency alarm procedure and as to their responsibility for assembling the people under their supervision in the area designated by the SED or designated alternate. Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm.

J.1.d Others The decision to commence evacuation of the Cook Energy Information Center is made by the SED on the basis of the evaluation of the condition of the plant and the extent of the emergency.

The Manager of the Cook Energy Information Center or designee is responsible for the accountability of all Energy Information Center employees and all visitors of the Center should the Nuclear Emergency Alarm be sounded.

When State Police and National Guard are assigned to the plant their disposition will be determined by the nature of the emergency. If the plant is under attack the MSP and National Guard are considered essential personnel and become Emergency Workers for the event. If the emergency does not involve attack of the plant the MSP and National Guard are considered non-essential personnel and evacuated from site upon evacuation of non-essential personnel.

J.2. Evacuation Routes If the SED deems evacuation of personnel from the plant site necessary, the evacuation route to be taken is determined by the nature of the incident. Personnel evacuate the plant and site as directed by the SED. Evacuation of individuals shall not commence until it is determined that personnel exposure for such evacuation is within the limits of 10 CFR Part 20, or if this is not practical due to the nature of the emergency, the most expeditious and non-hazardous evacuation route shall be used.

Planning Standard J CEP Rev 47

Page 120 of 226 The SED designates the evacuation route. One of the below designated routes is utilized (see Figure 12)

1. North East along main access road to the Red Arrow Highway.

2. North along Lake Michigan beach area to Rosemary Road.

3. South along Lake Michigan beach area to Livingston Road.

4. North East (for Energy Information Center only) to the Red Arrow Highway.

The Security Coordinator (or alternate) is responsible for the accountability of evacuated personnel from the plant site and reports any missing persons to the SED.

J.3. Evacuee Monitoring If evacuation is initiated a personnel monitoring station is established for those evacuated by a person trained in radiation protection. The Radiation Protection Plan specifies the acceptable limits for contamination to the body and clothing for exiting the plant. Suitable equipment intended for such personnel monitoring stations will be stored in the OSC and Survey Vehicles.

Other equipment is available from the Radiation Protection Access Control (RPAC), if access to that area is feasible.

J.4 Evacuee Decontamination If any of the evacuated personnel are contaminated, the OSC Manager will institute the necessary steps for movement of these personnel to decontamination facilities and initiate surveys of the surrounding areas.

J.5 Personnel Accountability Control of all personnel entering, leaving and at various locations throughout the plant is a function of the plant security force. The accountability of all personnel in the protected area of the plant is maintained via the security computer system. The security computer records provide the primary means of assuring the accountability of all persons of the site. Use of this computer will enable the accountability to be performed rapidly with a stated goal of achieving completion of personnel accountability within 30 minutes.

During some postulated events, assembly and accountability may pose a greater danger to plant personnel than directing a rapid egress of personnel from the Protected Area, or directing personnel to remain at their work areas. SM/SED discretion, with input from the Security Coordinator (or Security if facilities are not yet activated) should be used when deciding to perform accountability and/or evacuation under these conditions.

Once the Nuclear Emergency Alarm has been sounded all personnel onsite shall report to their pre-assigned assembly areas. The SED will notify personnel via the PA system of any changes in the areas to be used due to the release or expected release of radiological effluents from the plant.

Personnel reporting to their assembly area onsite will be accounted for using the plant security access list and security computer. This list provides an up-to-date listing of all personnel onsite by area location. The results of the accountability process will be transmitted to the individual in charge of personnel accountability.

Planning Standard J CEP Rev 47

Page 121 of 226 If personnel are unaccounted for, the security computer will be queried to determine the individuals last known location. The individual(s) will be paged on the PA system, the individuals supervisor will be notified and if required, the SED will initiate search and rescue operations.

J.6 Protective Measures for Those Remaining, or Reporting to the Site Personnel remaining onsite after the sounding of the Nuclear Emergency Alarm will be required to assemble in an area that is free from ionizing radiation and contamination, or presents the minimum exposure to personnel engaged in emergency operations. Surveys of the assembly area(s) will be conducted to ensure continued habitability.

Personnel remaining onsite who are engaged in emergency operations where there is an actual or potential radiological hazard, shall upon the direction of the RP Supervisor, wear the required protective clothing and respiratory protection. The RP Department shall perform the required surveys and establish the type and quantity of clothing, and other protective measures required.

The Plant Security Force will control access to the Owner Controlled Area at the I-94 Gatehouse as directed by the SED.

Personnel arriving at the plant to assist in the emergency will be allowed access to the plant via minimal exposure routes as identified by the Plant RP Department and approved by the SED.

The RP Department will establish a Controlled Area Access Point for personnel arriving at (and departing from) the plant from offsite if the access route exceeds the criteria for Clean Areas as identified in the Radiation Protection Plan. The amount of exposure personnel receive in reporting to the plant will be included in the individuals dose records.

Additionally, other precautions, such as decontamination, will be taken as necessary prior to entering the plant and reporting to the assigned assembly area. Equipment decontamination and controls are described in detail in the Radiation Protection Plan.

J.6.a. Respiratory Protection The Radiation Protection Plan and Radiation Protection Procedures identify the instructions and requirements pertaining to respiratory protection requirements and respiratory protection equipment usage.

J.6.b. Protective Clothing The Radiation Protection Plan and Radiation Protection Procedures identify the instructions and requirements pertaining to protective clothing requirements and protective clothing usage.

J.6.c. Radio-protective Drugs The procedures and precautions for the issuance and use of thyroid prophylaxis, e.g., individual thyroid protection, by emergency workers will be based on existing conditions. The provisions for stockpiling, inventory, storage and use are included in Emergency Plan Procedures. However, since the medical aftereffects of the agent cannot be determined, wholesale (wide) distribution cannot be incorporated as a responsible protective measure for personnel onsite.

Planning Standard J CEP Rev 47

Page 122 of 226 J.7 Off-site Protective Actions For incidents that fall under the ECLs as defined herein, the SED or ED will notify the Michigan State Police, the Berrien County Sheriffs Department, the NRC, and the AEP Emergency Response Organization described in this plan that such an incident has occurred.

It is the responsibility of the Governor of Michigan, or authorized representative, to issue Protective Action Orders (PAOs) such as sheltering, evacuation, administration of thyroid blocking agents, etc. These decisions are based upon the protective action guides in Annex S of the Michigan Emergency Management Plan (MEMP). Since copies of the MEMP are maintained and readily available at the various Emergency Response Facilities, the protective action guides and their bases will not be reproduced here.

For incidents involving actual or imminent releases of radioactive material to the atmosphere the Control Room or EOF protective action recommendation procedures, as appropriate, will be used as the basis for recommendations for protective actions to the public. These procedures are based on the current issue of the Manual for Protective Action Guides and Protection Action for Nuclear Incidents (EPA 400-R-92-001). The EPA Guide provides Protective Action Guides (PAGs) for whole body external gamma radiation and for inhalation of radioactive material in an airborne plume.

The most effective actions to be recommended to the public are evacuation, sheltering, and access control. Evacuation potentially provides the greatest margin of protection. On the other hand, because sheltering may be implemented in less time than evacuation, it may be the protective action of choice if rapid evacuation is impeded for any reason. Also, since sheltering is less disruptive than evacuation, it may be the protective action of choice when the dose reduction factor associated with shelter is adequate to reduce the projected dose to less than PAG levels.

Access control is an effective action to avoid exposure of personnel who might otherwise enter areas of high exposure unnecessarily.

Emergency Plan Procedures have been established to provide the mechanism and criteria for recommending protective actions to state and local government.

Additionally the protective action guides for emergency workers and those engaged in lifesaving activities exposed to airborne radioactive materials are listed in Section K.1., Emergency Exposure, and in the Plant Radiation Protection Plan.

J.8. Evacuation Times Evacuation time estimates and informational county maps are contained in the Berrien County Emergency Operations Plan submitted to the Nuclear Regulatory Commission (NRC).

Evacuation time estimates are performed within 365 days after the availability of the most recent decennial census data. Yearly reviews of the Evacuation time estimates are performed to estimate the Emergency Planning Zone permanent resident population changes.

J.9. Not Applicable Planning Standard J CEP Rev 47

Page 123 of 226 J.10 Plume Exposure Pathway Protective Measures Implementation J.10.a. Route and Facility Location Maps Maps for the 10 and 50 mile EPZ, developed by the Michigan State Police are provided for use at the following locations:

Control Rooms TSC OSC EOF ENC/JIC Berrien County EOC Cook Energy Information Center These maps show information such as sector designations, emergency center locations topographical information, and when used in conjunction with Berrien County plan indicates preferred evacuation routes.

J.10.b. Population Distribution Maps Evacuation time estimates and informational county maps are contained in the Berrien County Emergency Operations Plan submitted to the Nuclear Regulatory Commission (NRC).

J.10.c. Population Notification The Berrien County Plan includes provisions for alerting local radio and television stations and, local news media to be prepared to transmit Emergency Public Information. Section E.6 addresses Public Notification J.10.d. Protective Action Basis The Dose Assessment Program and off-site survey team results, as well as plant system and equipment status, are the basis for Protective Action Recommendations. DAP and off-site surveys are addressed in sections I.4 and I.5.

Planning Standard J CEP Rev 47

Page 124 of 226 Figure 13 Cook Nuclear Plant Primary Evacuation Routes Evacuation Route D Evacuation Route A Protected Area Evacuation Route B Primary Evacuation Routes A Northeast along Main Access

/, Road to Red Arrow Highway B South along Lake Michigan Beach area to Livingston Road C North Along Lake Michigan Beach area to Rosemary Road D (For Energy Information Center)

Northeast on Visitor Center Road to Red Arrow Highway Planning Standard J CEP Rev 47

Page 125 of 226 PLANNING STANDARD K RADIOLOGICAL EXPOSURE CONTROL Planning Standard K CEP Rev 47

Page 126 of 226 K. RADIOLOGICAL EXPOSURE CONTROL The CNP Radiation Protection Plan (PMI-6010) specifies the base criteria for the implementation of the Radiation Protection (RP) program and the methods to be used to control the exposure to radiation and radioactive materials. The standards listed in PMI-6010 and the programs to be followed consist of:

1. RP Training and Qualifications

2. ALARA Program

3. Radiation Work Permits

4. Dosimetry Program

5. Area Postings

6. Contamination Control

7. Internal Exposure Control

8. Radioactive Material Control Program

9. Survey Program

10. Instrumentation Program

11. Radiological Environmental Monitoring Program

12. Offsite Dose Calculation Manual

13. Review and Surveillance Program Related sub-tier RP procedures have been developed to provide a detailed and comprehensive method of performing the daily and emergency assignments. The procedures cover the following areas:

1. Exposure Monitoring and Control

2. Respiratory Protection

3. Contamination Control

4. Radiological Controls

5. Instrumentation

6. Instrumentation Calibration

7. Radioactive Effluent Control

8. Abnormal Condition Response

9. RMS Instrumentation Planning Standard K CEP Rev 47

Page 127 of 226

10. RMS Instrumentation Calibration

11. RMS Alarm Response K.1. Emergency Exposure It is possible that emergency situations may arise which transcend the normal requirements for limiting dose.

Dose to penetrating radiation during emergency response or response to accidents may be up to 10 rem Total Effective Dose Equivalent (TEDE), 100 rem Committed Dose Equivalent (CDE) to the thyroid for non-life-saving actions.

Life saving doses may be up to 25 rem TEDE or 250 rem CDE to the thyroid. However, in all situations, every reasonable effort shall be made to minimize dose.

In no case shall this type of dose be permitted unless rescue personnel are wearing monitoring devices capable of monitoring these doses.

Situations may also rarely occur in which a dose in excess of 25 rem, for emergency exposure, would be unavoidable in order to carry out a lifesaving operation, to avoid extensive exposure of large populations, to perform assessment actions, provide first aid or other medical treatment services, to perform personnel decontamination or provide ambulance services for personnel onsite. (Onsite medical support is described in Planning Standard L, L.2) However, persons undertaking any emergency operation in which the dose will exceed 25 rem to the whole body should do so only on a voluntary basis and with full awareness of the risks involved, including the numerical levels of dose at which acute effects of radiation will be incurred and numerical estimates of the risk of delayed effects.

K.2. Emergency Exposure Authorization and Control Doses in excess of 10 CFR 20 limits may be authorized by the SED in order to prevent serious property damage, serious bodily injury, or for life saving measures.

The assessment and recording of radiation exposures will be the assigned duty and responsibility of the person so designated by the RP Supervisor. The SED shall be made aware of any changes in cumulative exposures which would affect emergency team assignments.

The exposure of personnel who were in the immediate area of a radiation incident must be determined before they are assigned to any emergency or recovery team. Self-reading dosimeters, electronic dosimeters, area monitor records, or thermoluminescent dosimeters will be used to establish accumulated exposure for each individual.

K.3. Emergency Personnel Dosimetry K.3.a Dose Determination Radiation Exposure Records for exposed personnel will be maintained by the plant and will be available for review by the State of Michigan Department of Environment, Great Lakes, and Energy (EGLE).

K.3.b. Dosimetry Use and Dose Records Planning Standard K CEP Rev 47

Page 128 of 226 RMT-2080-OSC-001 identifies criteria and methods for reading, recording and maintaining dose records.

K.4. State and Local Emergency Exposure Authorization Not Applicable.

K.5. Decontamination K.5.a. Decontamination Criteria RMT-2080-OSC-001 identifies the criteria for decontamination of personnel, personnel wounds, and equipment.

Survey data and records of data taken by the licensee resulting from a nuclear incident at the licensees plant will be made available to the State for review upon written request to plant management by the EGLE or other designated State agency.

K.5.b. Decontamination Methods RMT-2080-OSC-001 identify the means and methods for decontamination of personnel, personnel wounds, and equipment.

There are two separate decontamination facilities which may be used during an emergency. The main facility is located in the Radiation Protection Access Control (RPAC) on the 609 elevation east of the auxiliary building. The other facility is located in the Auxiliary Building access at the Turbine Radiation Protection Access Control (TRPAC) on the 609 elevation of the Unit 1Turbine Building.

The decontamination facility associated with the RPAC consists of a decontamination area and a personnel shower. Additional space available in the area may also be used. Personnel protective clothing and equipment are also available in the RPAC.

Both decontamination facilities have adequate water supplies for both showers and wash basins.

All floor and sink drains in the adjoining areas drain either into the laundry and hot shower drain tank or other contaminated liquid tanks for complete control of potentially contaminated wastes.

Information on equipment and inventory of supplies as well as detailed written procedures and standing orders, are found in the Administrative Procedures and the Emergency Plan Procedures, as well as the RP Plan and the RP Procedures. A list of Emergency Kit Locations is shown in Appendix C. Inventory procedures are specified in the RP procedure indicated in the plant procedure column in Appendix A.

K.6. Contamination Control K.6.a. Area Access Control RMT-2080-OSC-001 and RMT-2080-TSC-001 identifies the means and methods for area access for control of contamination.

K.6.b. Water and Food Contamination Control Not addressed.

Planning Standard K CEP Rev 47

Page 129 of 226 K.6.c. Returning Items and Areas to Normal Use RMT-2080- EPI-109 identify the means and methods for decontaminating and returning areas and items to normal use.

The public will be restricted from areas within the Owner Controlled Area normally open to the public (i.e., Energy Information Center) which have been contaminated with radioactive material in excess of the limits defined in Table 6, Maximum Allowable Contamination Limits for On-Site Facilities Used by the Public. Prior to the release of these areas for public use, the plant will notify EGLE and provide the required data for review at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in advance of release of these areas to the public.

K.7. Decontamination of Relocated Onsite Personnel Personnel evacuated from onsite will be decontaminated as required by the plant RP procedures and Emergency Plan Procedures. If necessary and where possible, suitable protective clothing will be used during the evacuation.

Planning Standard K CEP Rev 47

Page 130 of 226 Table 6 MAXIMUM ALLOWABLE CONTAMINATION LIMITS FOR ON-SITE FACILITIES USED BY THE PUBLIC*

Beta-Gamma Counts per Minute (cpm)1 Skin, Personal Clothing, and Items < 2 X Background2 Directly Associated With the Human Body Material or Facilities Not Directly < 2 X Background2 Associated With the Human Body 1

Measured with GM and side window probe with beta shield opened or with thin window pancake probe.

2 Use background readings in cpm as measured pursuant to footnote 1. Gamma background must be 0.2 mR/hr, or less, as measured with a GM and a side window probe with the beta shield closed.

Ref. Michigan Emergency Management Plan Planning Standard K CEP Rev 47

Page 131 of 226 PLANNING STANDARD L MEDICAL AND PUBLIC HEALTH SUPPORT Planning Standard L CEP Rev 47

Page 132 of 226 L. MEDICAL AND PUBLIC HEALTH SUPPORT L.1. Offsite Medical Support Spectrum Health Lakeland Medical Center, in St. Joseph, Michigan has an emergency room which is open 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day year round and arrangements have been made with them for the care of contaminated persons. There is a physician constantly on duty at the hospital. Spectrum Health Lakeland Medical Center is the primary site for the handling of contaminated patients from CNP. The hospital is approximately 9.5 miles from the plant site.

In addition, Spectrum Health Lakeland Niles Hospital, located in Niles, Michigan, about 19 miles from the plant site, has facilities and staff for the handling of contaminated patients from CNP.

This facility is the back-up site for Spectrum Health Lakeland Medical Center.

The Radiation Emergency Area (REA) at Spectrum Health Lakeland Medical Center, lends itself well to controlling the access of non-essential personnel. The REA at both St. Joseph and Niles is located in a section of the hospital remote from any other treatment facilities. A contaminated or potentially contaminated patient is wrapped and placed on a clean gurney when taken from the ambulance before being taken into the facility to avoid the spread of contamination.

The REA facility in both hospitals consists of a room designed for easy decontamination, should this be required. Adequate water is supplied for any necessary personnel or equipment decontamination. The facilities include a fiberglass table with a special drain to allow control of liquids for later removal from the hospital. If the injury does not require special handling because of contamination levels or high radiation levels, the facilities of the emergency room and other parts of the hospital are available.

In addition to that equipment normally found in hospital emergency facilities for routine non-nuclear emergencies, other specialized equipment includes such items as plastic and absorbent paper for contamination control, protective clothing, equipment for the control of liquid and solid wastes and their removal from the hospital to the plant for treatment and/or disposal, and assorted signs, barriers, and supplies. Also available at the hospital are such items as survey instruments, dosimeters, samplers, and associated equipment.

There are no limitations with regard to duration of admissions of casualties or contaminated patients. Special rooms have been arranged so the patients can be kept as long as necessary before being transferred to a different facility or until released.

Onsite decontamination of the injured person, as well as the design of the REA with respect to the rest of the hospital, negates any limitations on the availability of the offsite medical facilities with respect to contamination levels. The only limitation due to direct radiation levels from a contaminated injured person is to the people directly concerned with treatment of the contaminated injured person because the REA is located in a part of the building remote from the patients and staff in most conditions. The limitation on the exposure of the physician or hospital staff remains a medical judgment made by the physician for individual cases. This judgment will be made using data obtained from portable radiation monitoring equipment.

Detailed procedures have been developed for activation of the hospital assistance plan. A comprehensive training program has been conducted for the hospital staff and employees who would be involved as a part of the offsite medical support. This program includes training in the principles of radiation protection, basic radiation protection procedures, applicable parts of the emergency plan and emergency procedures, and an exercise simulating radiological and physical injury. This training program shall be periodically reviewed and repeated at least once each year.

Planning Standard L CEP Rev 47

Page 133 of 226 Plant personnel will monitor all persons leaving the treatment room after removal of protective clothing. The treatment room, all equipment used in the room and during patient treatment is surveyed by plant personnel for contamination. Any contaminated equipment or areas will be decontaminated by plant personnel to the Plant RP Protection Plan Clean Area specifications.

All radioactive waste is sealed and transported to the plant for disposal in accordance with current DOT and State regulations.

Subsequent therapy for individuals who have been exposed or contaminated is provided in the kind and extent which is required under the direction of the hospital physician. Additionally, consultation service is available from the Department of Energys Radiation Emergency Assistance Center/Training Site on radiation related injuries.

L.2. Onsite Medical Support In the event of serious injury, medical treatment must always take precedence over decontamination of the individual. First Aid training is provided within several plant departments, providing emergency medical expertise within the plant. All plant personnel are trained in the proper response to a medical emergency. No physicians or nurses are located on-site.

The CNP has the necessary facilities and supplies at the site for decontamination and monitoring of personnel as well as the facilities and necessary medical supplies for appropriate emergency first aid treatment.

L.3. State Medical Support Listing Not Applicable.

L.4. Victim Transport Medic-1 Ambulance Service is located approximately 4 miles from the plant and provides the primary emergency medical services for the Plant. As a backup a plant emergency vehicle is available.

Planning Standard L CEP Rev 47

Page 134 of 226 PLANNING STANDARD M RECOVERY AND RE-ENTY PLANNING AND POST ACCIDENT OPERATIONS Planning Standard M CEP Rev 47

Page 135 of 226 M. RECOVERY AND RE-ENTRY PLANNING AND POST ACCIDENT OPERATIONS M.1. Reentry and Recovery The exact nature and details of a specific emergency determine the procedures that are used for the resumption of normal plant activities. The procedures formulated to regain the services of plant systems lost through such an incident follow the practices of good engineering judgment.

After the Emergency Plan has been activated, the plant personnel initiate a survey of plant damage and contamination. The plant systems or components involved in the incident are evaluated by any number of the following methods:

1. Radiation Surveys

2. Process instrumentation

3. Visual inspections (where possible)

4. Reactor Protection System Instrumentation

5. Reactor Control System Instrumentation

6. Out of core and in core nuclear instrumentation

7. Engineering safety features instrumentation

8. Radiation monitoring system

9. Post Accident Sampling Capability (where possible)

Re-Entry Survey or personnel monitoring teams are sent out to gather information prior to re-entry and report such findings to the individuals designated in the Emergency Plan Procedures in the TSC and/or the EOF.

The RP Supervisor is responsible for protecting plant personnel re-entering the plant. The RP Supervisor is responsible for ensuring that radiation doses are under Federal limits for a radiation worker involved in plant re-entry before resuming normal plant operation.

Survey teams will measure radiation levels on and around the site and re-entry will be made when radiation hazards are reduced to permissible levels. The SED will approve re-entry procedures based on existing and potential conditions of the plant.

Recovery Operations Where control of the incident has been attained and there is no further danger to personnel, the emergency phase shall be at an end. Restoration and recovery operations shall continue, but not under the same criteria as the emergency operation. During restoration and recovery operations, activity levels and personnel exposures will be based on 10 CFR 20 limits.

Planning Standard M CEP Rev 47

Page 136 of 226 The recovery procedures that must be developed following a radiological incident will vary, but in general they will include the following activities:

1. Damage evaluation

2. Decontamination measures

3. Repair procedures

4. Disposal procedures

5. Ensure adequate offsite response readiness

6. Test and start-up procedures M.2. Recovery Organization The Recovery Organization is addressed in the Emergency Plan Procedures. See Appendix A for cross-reference.

M.3. Recovery Initiation Notification Normal communications channels will be utilized to notify State, County and other response organizations of the start of recovery operations and any changes occurring within the plans, procedures and response organization. Recovery operations affecting or interfacing with offsite responsibilities will be reviewed and approved by the appropriate response manager.

M.4. Estimating Population Total Exposure Not addressed.

Planning Standard M CEP Rev 47

Page 137 of 226 PLANNING STANDARD N EXERCISES AND DRILLS Planning Standard N CEP Rev 47

Page 138 of 226 N. EXERCISES AND DRILLS N.1. Exercises N.1.a. Exercise Content Each exercise will be conducted in accordance with a unique scenario developed for that exercise. Each exercise tests portions of emergency preparedness plans within the AEP system, State and County. The plant will also participate in joint exercises initiated and coordinated by the NRC and FEMA to test the effectiveness of the emergency plan(s) at all levels.

The ultimate criteria against which the results of exercises are to be measured will be effective implementation of the plants and participating response organization emergency response plans to a simulated event, and the manner in which all agencies, public and private, interface their plans to assure that the public health and safety is protected.

N.1.b. Exercise Scheduling An annual emergency exercise is conducted at CNP to test various basic elements of the emergency preparedness program. Biennially, this exercise is conducted with participation of offsite emergency personnel, including those of State and County agencies.

Off-hours shift augmentation drills ensure that the goals of Table 1, CNP Staffing for Radiological Emergencies, are being met. These drills are to be conducted semi-annually. One of these drills per calendar year will include the contacted personnel reporting to their assigned emergency facilities and activating the facility. Credit can be taken for normal shift personnel above that indicated for On-shift to meet the augmentation goals.

Scenarios will be varied from year to year such that all major elements of the Emergency Plan, Emergency Plan Procedures and Emergency Response Organizations are tested within an 8 year period (see Appendix J, Eight Year Plan Matrix, for 8 year plan).

N.2. Drills N.2.a. Communication Drills Communications is a part of each drill and exercise. Links are established between the off-site agencies and the Cook ERO, or plant personnel playing the part of the off-site agencies communicate with the ERO communicators.

Communication links between the plant emergency facilities are established as a part of each drill or exercise. Anytime Offsite Survey Teams are dispatched for drill or exercises communication and control with the teams is established.

N.2.b. Fire Drills Quarterly fire drills are conducted to ensure participation biannually by site fire brigade members.

An annual fire drill is held that includes participation of an offsite fire department.

N.2.c. Medical Emergency Drills An exercise simulating radiological and physical injury shall be conducted with the offsite medical personnel annually.

Planning Standard N CEP Rev 47

Page 139 of 226 N.2.d. Radiological Monitoring Drills Drills involving response to, and analysis of, simulated airborne, liquid, and environmental (vegetation, snow, soil, etc.) samples and direct radiation measurements in the environment shall be conducted semi-annually.

N.2.e. Health Physics Drills N.2.e.1. Environmental Monitoring Drills involving response to, and analysis of, simulated airborne, liquid, and environmental (vegetation, snow, soil, etc.) samples and direct radiation measurements in the environment shall be conducted semi-annually.

N.2.e.2. Plant Liquid Monitoring PASS removed by Operating License change #261 and 244 for U1 and 2 respectively delete requirements for Post Accident Sampling System.

N.2.f. Other drills N.2.f.1. Hostile Action Based Drills Drills involving response to 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. (NRC Commitment 8373.)

N.2.f.2. Fast Breaking Drills Drills involving an initial classification of, or rapid escalation to, a Site Area Emergency or General Emergency.

N.2.f.3. No radiological release or minimal release.

Drills involving declaration of a Site Area Emergency but not a General Emergency that involve no radiological release or an unplanned minimal radiological release.

N.3. Drill and Exercise Execution Each scenario shall be jointly developed by appropriate response agencies participating in the exercise and shall include:

N.3.a. Basic objective(s) of the exercise N.3.b. Date, time and place and participating response agencies, and the extent to which participating agencies will respond.

N.3.c. Simulated events, which may include offsite radiological releases.

N.3.d. Time Line of real and simulated events.

N.3.e. Narrative summary describing the conduct of the exercise.

Planning Standard N CEP Rev 47

Page 140 of 226 N.3.f. Arrangements for official observers, and advance materials to official observers.

N.4. Official Observation and Critique After the drill or exercise, a critique shall be conducted involving participants, controllers and observers. The critique should be held as soon as practicable after completion of the drill or exercise.

N.5. Results Evaluation and Corrective Actions A formal evaluation of exercises, with lessons learned, shall be prepared and submitted through the Corrective Action Program. The Emergency Preparedness Manager (or alternate) shall review and assign action items to upgrade those areas where deficiencies were noted. These action items will be assigned, tracked and closed using the plant corrective action program.

Planning Standard N CEP Rev 47

Page 141 of 226 PLANNING STANDARD O RADIOLOGICAL EMERGENCY RESPONSE TRAINING Planning Standard O CEP Rev 47

Page 142 of 226 O. RADIOLOGICAL EMERGENCY RESPONSE TRAINING O.1 Organization Training Cook Nuclear Plant provides training to agencies or organizations that provide onsite assistance to the plant. Types of organizations provided this training are as follows:

Local Law Enforcement Ambulance Service Fire Departments Hospitals Training should be offered annually. Should any of these agencies request additional training, either in scope or schedule, every possible action should be taken to facilitate the request.

The training of Berrien County and State of Michigan emergency response personnel is the responsibility of the Michigan State Police Emergency Management and Homeland Security Division. The Cook Nuclear Plant is committed to assist in the endeavor upon request.

O.2. Onsite ERO Training The plant training program is the responsibility of the Training Manager.

A general employee training program provides initial orientation training and annual (every 12 months) retraining to CNP employees in the general emergency plan response. They are familiarized with the sounding of the Nuclear Emergency Alarm, assembly areas and routes to take to these assembly areas. This training also includes general aspects of the Emergency Plan.

ERO position specific training and qualification is administered through TPD-600-EPT Emergency Preparedness Training Program Description. Position specific Job Familiarization Guides are used for on-the-job training and qualification of the ERO responders.

O.3. First Aid Team Training Personnel who respond to medical emergencies at the Cook Nuclear Plant receive either first-aid training or are qualified as Medical Emergency Response Team members (MERT).

O.4 ERO Training and Qualification To the maximum extent practicable, emergency plan training and qualification should be incorporated into functional training and qualification programs.

Specialized initial training and retraining programs will be provided as outlined below for the following categories of emergency personnel.

O.4.a. Directors and Key Personnel Initial specialized training in emergency plan and procedures implementation is provided to the directors and coordinators of the response organizations including emergency plan drill participation and annual reviews of the same. Training for execution of the emergency plan is provided by completion of senior licensed operator training, or equivalent training that applies to emergency plan execution.

Planning Standard O CEP Rev 47

Page 143 of 226 O.4.b. Personnel Responsible for Accident Assessment Initial specialized training in emergency plant operations, emergency plan and procedures implementation is provided including an annual review of the same. Further training includes participation in emergency plan drills.

O.4.c. Radiological Monitoring Teams Radiation Protection personnel receive Emergency Plan training as part of their Initial RP Technician training. Continuing Training and drill participation requirements addressed in TPD-600-EPT, Emergency Preparedness Training Program Description.

O.4.d. Security & Fire Brigade Fire Brigade staff receive Initial and annual retraining in firefighting techniques and first aid.

The Plant Security Force is considered the Emergency Security Team. All actions required during emergencies are included in security officer training.

O.4.e. Onsite Repair & Damage Control The Damage Control Team is responsible for the repair and restoration of damaged plant systems, equipment, or components. Training, exercises and drills involving the Damage Control Team will be conducted in a manner consistent with established Emergency Plan Procedures.

O.4.f. First Aid & Rescue Teams The first-aid training program is administered by the Training Department.

The MERT program is administered by an accredited offsite institution.

O.4.g. Local Service Personnel (Offsite Fire Department Personnel and Local Sheriff)

The local Fire Departments receive familiarization in specific plant access and control procedures and participate annually in plant fire drills.

Sheriffs department receives annual Emergency Alert System (EAS) training and participates in the annual plant emergency exercise.

O.4.h. Medical Support Personnel An exercise simulating radiological and physical injury shall be conducted with the offsite medical personnel annually.

O.4.i. Licensee Headquarters Support AEPs Enterprise Resilience organization maintains an Emergency Management Plan that outlines roles, responsibilities and organization to support D.C. Cook during an emergency. This plan is governed by the Enterprise Resilience Policy and appropriate subsequent Standards. A training activity, which includes integration of this AEP Emergency Management plan with D.C.

Cooks Emergency Plan, will occur at least once during the eight year drill and exercise cycle.

Planning Standard O CEP Rev 47

Page 144 of 226 O.4.j. Personnel Transmitting Emergency Information and Instructions ERO Communicators receive ERO initial training and position specific Job Familiarization Guides for their specific communication duties.

O.5. Initial and Periodic Retraining Initial training and job familiarization, as well as periodic training for personnel with emergency response responsibilities are in TPD-600-EPT, Emergency Preparedness Training Program Description.

Initial training and job familiarization completed prior to assignment to the ERO.

Planning Standard O CEP Rev 47

Page 145 of 226 PLANNING STANDARD P RESPONSIBILITY FOR PLANNING EFFORT Planning Standard P CEP Rev 47

Page 146 of 226 P. RESPONSIBILITY FOR PLANNING EFFORT P.1 Emergency Planner Training Emergency Preparedness Coordinator position specific training and qualification is administered through TPD-600-EPC Emergency Preparedness Coordinator Training Program Description.

Position specific training and qualification card are used for training and qualification of Emergency Preparedness Coordinators.

P.2 Emergency Plan Administration Responsibility The Chief Nuclear Officer shall have overall authority and responsibility for radiological emergency response planning. In this effort he has the authority to delegate responsibility in the planning effort to enhance the overall readiness and ensure that the plan is updated as necessary.

Normally plan updating and review will be the responsibility of the Site Vice President. The training of individuals in the CNP Emergency Response Organization (ERO) in the Emergency Plan shall be the responsibility of the Training Manager.

P.3 Emergency Planning Coordinator Designation The Emergency Preparedness Coordinator position has the responsibility for the development and updating of the Cook Emergency Plan and coordination of this plan with other response organizations.

P.4. Periodic Reviews Updates and Audits The responsibilities of the individuals, groups, agencies, the Emergency Plan, and implementation procedures to be followed during an emergency condition are reviewed at a minimum, on an annual basis and updated as required. All written agreements with offsite support groups are reviewed and updated if necessary, on a two year basis. This review will take into account changes identified by drills and exercises. The plant maintains up-to-date approved emergency response plans from the state and county. Changes to these offsite plans are reviewed to maintain an effective interface with the Cook Emergency Plan.

The Plant Operations Review Committee is responsible for the review of changes to the Emergency Plan. The Plant Operations Review Committee is also responsible for the review of changes, other than editorial corrections, to the Emergency Plan Implementing Procedures. The Senior Vice President - Nuclear Generation Group, or designee, shall approve changes to the Emergency Plan. All reviews shall be documented. The Senior Vice President-Nuclear Generation Group shall be sent copies of the changes. NRC approval shall be obtained as appropriate.

P.5. Emergency Plan Change Communication Approved Emergency Plan revisions and/or applicable procedural changes will be promptly forwarded to appropriate offsite emergency support organizations.

A list of changes to the Emergency Plan shall be submitted with each plan revision. Changes to the Plants Emergency Plan Procedures shall be made in accordance with plant practice for revising procedures.

Planning Standard P CEP Rev 47

Page 147 of 226 P.6 Emergency Response Organization Support Plans Plan Source Emergency Operations Plan Berrien County Sheriffs Office Michigan Emergency Management Plan State of Michigan Regional Plan Handbook - RAP Department of Energy Region V INPO Emergency Response Manual Institute of Nuclear Power Operations National Response Plan, Department of Homeland Security with Nuclear/Radiological Incident Annex NRC as Coordinating Agency P.7. Implementing Procedures Detailed procedures for implementing and providing additional information on the Emergency Plan are available in the Emergency Plan Procedures. The written procedures indicated in Appendix A cover the following but are not limited to:

1. Authority and responsibility for completing specific tasks.

2. Action levels requiring implementation of protective measures outlined.

3. Medical treatment procedures and handling of contaminated individuals.

4. Necessary equipment for medical treatment, radiation detection, and rescue operations.

5. Identification of emergency communications equipment.

6. Emergency center description and operation.

7. Restoration procedures from emergency to normal conditions.

8. Communications P.8 Table of Contents & Cross-reference Table of Contents and Appendix A fulfill this requirement.

P.9. Independent Emergency Program Review Audits of the Emergency Plan and implementing procedures are performed as delineated in 10 CFR 50.54(t)(1). These audits shall be performed by the Plant Performance Assurance Department and may include items relating to training, readiness testing, equipment, State/local plant interfaces, medical arrangements, etc.

Audit findings shall be reported, evaluated and recommendations completed as described in the Audit Program Policy. The results of the audit, along with the recommendations for improvements shall be documented and reported to plant management and retained for a period of five years.

Reviews involving the adequacy of interface with State/local agencies shall be available to the appropriate agency.

P.10. ERO Telephone Number Updates Appendix J fulfils this requirement.

Planning Standard P CEP Rev 47

Page 148 of 226 APPENDIX A

1. INDEX OF EMERGENCY PLAN IMPLEMENTING DOCUMENTS

2. CROSS REFERENCE CEP AND EMERGENCY PLAN IMPLEMENTING DOCUMENTS Appendix A CEP Rev 47

Page 149 of 226 DONALD C. COOK NUCLEAR PLANT EMERGENCY PLAN IMPLEMENTING DOCUMENTS IDENTIFICATION NUMBER TITLE RMA-2080-EPA-008 EMERGENCY PLAN MANAGEMENT PMP-2080-EPP-100 EMERGENCY RESPONSE PMP-2080-EPP-101 EMERGENCY CLASSIFICATION PMP-2080-EPP-108 INITIAL DOSE ASSESSMENT RMT-2080-EPI-109 TERMINATION AND RECOVERY PMP 2080-EPP-200 INITIATING CHANGES TO THE EMERGENCY PLAN OR EMERGENCY PLAN IMPLEMENTING PROCEDURES PMP-2081-EPP-105 CORE DAMAGE ASSESSMENT RMT-2080-EPP-500 DRILL & EXERCISE SCHEDULING, DEVELOPMENT, CONDUCT &EVALUATION RMT-2080-EOF-001 ACTIVATION AND OPERATION OF THE EOF RMT-2080-ENC-001 ACTIVATION AND OPERATION OF THE ENC/JIC RMT-2080-OSC-001 ACTIVATION AND OPERATION OF THE OSC RMT-2080-TSC-001 ACTIVATION AND OPERATION OF THE TSC SPP-2060-SFI-216 PLANT RESPONSE TO A VALIDATED SECURITY THREAT EPP-2080-ERO-001 EMERGENCY RESPONSE RESOURCE READINESS RMT-2080-PPA-001 EMERGENCY PREPAREDNESS PERIODIC PROGRAM ACTIVITIES TPD-600-EPC EMERGENCY PREPAREDNESS COORDINATOR TRAINING PROGRAM DESCRIPTION TPD-600-EPT EMERGENCY PREPAREDNESS TRAINING PROGRAM DESCRIPTION Spectrum Health Lakeland Emergency Radiation Exposure Intake Procedure ERO ON-SHIFT STAFFING ANALYSIS REPORT Appendix A CEP Rev 47

Page 150 of 226 NUREG-0654 - EMERGENCY PLAN - PROCEDURE CROSS REFERENCE At Cook Nuclear Plant, NUREG-0654 is applied as guidance in plan and procedure development with consideration to plant organization, administrative policies and operating procedures.

NUREG-0654 EMERGENCY (Sect II Planning Standards PLANT PROCEDURE PLAN SECTION and Evaluation Criteria)

A.1.a A.1.a Not applicable B.8 B.9 A.1.b A.1.b Not applicable A.1.c A.1.c Not applicable Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figure 8 Figure 9 Figure 10 A.1.d A.1.d PMP-2080-EPP-100 RMT-2080-EOF-001 A.1.e A.1.e RMT-2080-EOF-001 Table 1 A.2. Not applicable Not applicable A.3 A.3 PMP-2080-EPP-200 Appendix B A.4 A.4 RMT-2080-EOF-001 RMT-2080-OSC-001 RMT-2080-TSC-001 B.1 B.1 Not applicable Figure 3 Figure 4 B.2 B.2 PMP-2080-EPP-100 B.1.j.

B.5.a.1 B.5.c.1 B.3 B.3 PMP-2080-EPP-100 RMT-2080-TSC-001 RMT-2080-EOF-001 B.4 B.4 PMP-2080-EPP-100 RMT-2080-EOF-001 Appendix A CEP Rev 47

Page 151 of 226 NUREG-0654 EMERGENCY (Sect II Planning Standards PLANT PROCEDURE PLAN SECTION and Evaluation Criteria)

B.5 B,5 RMT-2080-OSC-001 Table 1 RMT-2080-TSC-001 Figure 5 RMT-2080-EOF-001 Figure 6 RMT-2080-ENC-001 Figure 7 ERO On-Shift Staffing Figure 8 Analysis Report B.6 B.6 Not applicable Figure 8 B.7 B.5 ERO On-Shift Staffing Table 1 Analysis Report B.7.a B.7.a RMT-2080-EOF-001 B.5.c.9 B.7.b B.7.b RMT-2080-TSC-001 B.5.c.8 B.7.c B.7.c RMT-2080-EOF-001 B.5.c.1 B.7.d B.7.d RMT-2080-ENC-001 B.5.d.1 B.8 B.8 Not applicable C.4 Appendix B B.9 B.9 Not applicable L.1 Appendix B C.1.a C.1.a Not applicable C.1.b C.1.b Not applicable Appendix E C.1.c Appendix E Not applicable C.2.a Not applicable Not applicable C.2.b B.5.e.1 RMT-2080-EOF-001 C.3 H.6.c RMT-2080-EOF-001 Appendix B Appendix H C.4 C.4 RMT-2080-EOF-001 B.8 Appendix B Appendix H D.1 D.1 PMP-2080-EPP-101 Table 2 Table 3 Table 4 D.2 D.2 PMP-2080-EPP-101 Table 2 Table 3 Table 4 D.3 Not applicable Not applicable D.4 Not applicable Not applicable Appendix A CEP Rev 47

Page 152 of 226 NUREG-0654 EMERGENCY (Sect II Planning Standards PLANT PROCEDURE PLAN SECTION and Evaluation Criteria)

E.1 E.1 PMP-2080-EPP-100 E.2 E.2 PMP-2080-EPP-100 SPP-2060-SFI-216 E.3 E.3 PMP-2080-EPP-100 E.4 E.4 PMP-2080-EPP-100 RMT-2080-EOF-001 E.5 Not applicable Not applicable E.6 E.6 Not applicable Appendix D E.7 E.7 PMP-2080-EPP-100 RMT-2080-EOF-001 F.1.a F.1.a PMP-2080-EPP-100 F.1.b F.1.b RMT-2080-EOF-001 F.1.c F.1.c. RMT-2080-EOF-001 Appendix E F.1.d F.1.d RMT-2080-EOF-001 F.1.e F.1.e PMP 2080-EPP-100 F.1.f F.1.f RMT-2080-EOF-001 F.2 F.2 Not applicable F.3 F.3 EPP-2080-ERO-001 G.1 G.1 Not applicable Appendix D G.2 G.2 Not applicable G.3.a G.3. RMT-2080-ENC-001 G.3.b Not addressed Not applicable G.4.a G.4.a RMT-2080-ENC-001 G.4.b G.4.b. RMT-2080-ENC-001 G.4.c G.4.c. RMT-2080-ENC-001 G.5 G.5. Not applicable H.1 H.1 (TSC) RMT-2080-TSC-001 H.3 (OSC) RMT-2080-OSC-001 H.2 H.2 RMT-2080-EOF-001 H.3 Not applicable Not applicable (SEOC/CEOC)

H.4 H.4. PMP-2080-EPP-100 H.5 H.5 RMT-2080-TSC-001 H.5.a H.5.a RMT-2080-EOF-001 RMT-2080-OSC-001 H.5.b H.5.b RMT-2080-TSC-001 H.5.c H.5.c RMT-2080-TSC-001 H.5.d H.5.d Not applicable H.6 H.6 RMT-2080-EOF-001 H.6.a H.6.a RMT-2080-EOF-001 H.6.b H.6.b RMT-2080-EOF-001 EPP-2080-ERO-001 H.6.c H.6.c RMT-2080-EOF-001 H.7 H.7 EPP-2080-ERO-001 Appendix A CEP Rev 47

Page 153 of 226 NUREG-0654 EMERGENCY (Sect II Planning Standards PLANT PROCEDURE PLAN SECTION and Evaluation Criteria)

H.8 H.8. RMT-2080-EOF-001 H.9 H.3 RMT-2080-OSC-001 H.10 Appendix J EPP-2080-ERO-001 H.11 Appendix C EPP-2080-ERO-001 H.12 H.3.d. RMT-2080-EOF-001 I.1 I.1. PMP-2080-EPP-101 Table 2 Table 3 Table 4 I.2 I.2 RMT-2080-EOF-001 I.3.a I.3.a. RMT-2080-EOF-001 I.3.b I.3.b. RMT-2080-EOF-001 I.4 I.4 RMT-2080-EOF-001 I.5 I.5 RMT-2080-EOF-001 I.6 Not addressed Not applicable I.7 I.7 RMT-2080-EOF-001 I.8 I.8 RMT-2080-EOF-001 I.9 I.9 RMT-2080-EOF-001 I.10 Not addressed RMT-2080-EOF-001 I.11 Not applicable RMT-2080-EOF-001 J.1.a J.1.a RMT-2080-TSC-001 J.1.b. J.1.b. RMT-2080-TSC-001 J.1.c. J.1.c. RMT-2080-TSC-001 J.1.d. J.1.d. RMT-2080-TSC-001 J.2 J.2 RMT-2080-TSC-001 Figure 14 J.3 J.3 RMT-2080-TSC-001 J.4 J.4 RMT-2080-TSC-001 J.5 J.5 RMT-2080-TSC-001 J.6.a J.6.a. RMT-2080-EOF-001 J.6.b J.6.b. RMT-2080-EOF-001 J.6.c J.6.c. RMT-2080-EOF-001 J.7 J.7 RMT-2080-EOF-001 J.8. J.8, PMP-2080-EPP-100 Berrien County Emergency RMT-2080-EOF-001 Operations Plan J.9. Not Applicable Not Applicable J.10.a. J.10.a. Not applicable J.10.b J.10.b. Not Applicable J.10.c. J.10.c. Not Applicable E.6.

J.10.m. J.10.d. PMP-2080-EPP-100 I.4. RMT-2080-EOF-001 I.5.

K.1 a - g K.1 RMT-2080-OSC-001 K.2 K.2 RMT-2080-TSC-001 RMT-2080-OSC-001 Appendix A CEP Rev 47

Page 154 of 226 NUREG-0654 EMERGENCY (Sect II Planning Standards PLANT PROCEDURE PLAN SECTION and Evaluation Criteria)

K.3.a K.3.a. RMT-2080-TSC-001 RMT-2080-OSC-001 K.3.b K.3.b. RMT-2080-OSC-001 K.4 Not Applicable Not Applicable K.5.a K.5.a. RMT-2080-OSC-001 K.5.b K.5.b RMT-2080-OSC-001 K.6.a. K.6.a. RMT-2080-TSC-001 RMT-2080-OSC-001 K.6.b. Not Addressed K.6.c. K.6.c. RMT-2080-EPI-109 K.7 K.7 RMT-2080-OSC-001 L.1 L.1. Spectrum Health Lakeland Emergency Radiation Exposure Intake Procedure L.2 L.2. Not applicable L.3. Not Applicable Not applicable L.4 L.4 Not applicable M.1 M.1 RMT-2080-OSC-001 M.2 M.2 RMT-2080- EPI-109 M.3 M.3 RMT-2080- EPI-109 M.4 Not addressed Not applicable N.1.a N.1.a RMT-2080-EPP-500 RMT-2080-PPA-001 N.1.b. N.1.b. RMT-2080-EPP-500 Appendix J RMT-2080-PPA-001 N.2.a N.2.a. RMT-2080-EPP-500 RMT-2080-PPA-001 N.2.b Tech. Spec. RMT-2080-EPP-500 RMT-2080-PPA-001 N.2.c N.2.c. RMT-2080-EPP-500 Appendix J RMT-2080-PPA-001 N.2.d N.2.d. RMT-2080-EPP-500 N.2.e N.2.e RMT-2080-EPP-500 N.3 N.3 RMT-2080-EPP-500 N.4 N.4 RMT-2080-EPP-500 N.5 N.5 RMT-2080-EPP-500 O.1 O.1 TPD-600-EPT O.1.a. O.1 TPD-600-EPT O.1.b. Not applicable Not applicable O.2 O.2 TPD-600-EPT O.3 O.3 TPD-600-EPT O.4.a O.4.a. TPD-600-EPT O.4.b O.4.b. TPD-600-EPT O.4.c. O.4.c. TPD-600-EPT O.4.d. O.4.d. TPD-600-EPT O.4.e. O.4.e. TPD-600-EPT O.4.f. O.4.f. TPD-600-EPT Appendix A CEP Rev 47

Page 155 of 226 NUREG-0654 EMERGENCY (Sect II Planning Standards PLANT PROCEDURE PLAN SECTION and Evaluation Criteria)

O.4.g. O.4.g. TPD-600-EPT O.4.h. O.4.h. RMT-2080-EPP-500 O.4.i. O.4.i. TPD-600-EPT O.4.j. O.4.j. TPD-600-EPT O.5 O.5. TPD-600-EPT P.1 P.1 TPD-600-EPC P.2 P.2 PMI-2080 P.3 P.3 f---------------f-----------1 PMP-2080-EPP-200 I P.4 P.4. PMI-2080 P.5 P.5 PMP-2080-EPP-200 P.6 P.6 Not applicable P.7 Appendix A Not applicable P.8 Table of Contents Not applicable Appendix A P.9 P.9 Not applicable P.10 Appendix J RMT-2080-PPA-001 Appendix A CEP Rev 47

Page 156 of 226 APPENDIX B AGREEMENTS WITH OFF-SITE SUPPORT AGENCIES Appendix B CEP Rev 47

Page 157 of 226 APPENDIX B Agreements with Off-Site Support Agencies

1. Sheriff Department, Berrien County, Michigan 1 page January 5, 2018

2. Lakeland Health 1 page January 18, 2018

3. Lake Township Fire Department 1 page January 5, 2018

4. City of Bridgman Fire Department 1 page January 16, 2018

5. Medic 1 Community Emergency Service 2 pages December 20, 2017

6. Reciprocal Laboratory Use Agreement 2 pages August 28, 2017

7. Mutual Assistance Agreement Between Detroit Edison 6 pages October 13, 2019 Company, Entergy Nuclear Palisades and Indiana Michigan Power Co.

8. Institute of Nuclear Power Operations Emergency 1 page November 2, 2017 Resources

9. FEMA Alert and Notification (ANS) Design Report letter 6 pages April 13, 2021 Appendix B CEP Rev 47

Page 158 of 226 Sheriff Department, Berrien County, Michigan 1 page BERRIEN COUNTY EMERGENCY MANAGEMENT DIVISION OF BERRIEN COUNTY SHERIFF'S OFFICE JON HINKELMAN 2100 E. Empire Avenue, Benton Harbor, Michigan 49022 CHAIRMAN BOARD OF COMMl SSIONERS Telephone (269) 983-7141

Fax: (269) 983-5726 L. PAUL BAILEY SHERIFF CAPT. ROCKEY ADAMS COORDINATOR 1/5/2018 Mr. Ronald J. Sieber Cook Nuclear Plant One Cook Place Bridgman, Ml 49106

Dear Mr. Sieber:

We wish to reaffirm the willingness of the Berrien County Sheriff's Department to respond upon request to any emergency which could occur at the D.C. Cook facility. Berrien County Emergency Management/Office of Homeland Security has the obligation to respond upon notification that an emergency exists. Berrien County will implement their Nuclear Accident Proced_ures (Appendix 1) of the Emergency Operations Plan and take appropriate actions as outlined therein.

In addition, the Sheriff's Department has basic patrol and investigative services and currently has a fourteen member Hazardous Materials Response Team who are trained to Technician Level. Four of the fourteen Haz-Mat team members are cross-trained as bomb technicians, and of whom have successfully completed the FBI Hazardous Device School at Redstone Arsenal in Redstone, Alabama . Our Tactical Unit consists of 20 personnel who conduct training monthly.

The Berrien County Sheriff's Department will be available to you upon request, in any area within the jurisdiction of this agency.

Sincerely, 1~~

Sheriff/Director, Emergency Management Appendix B CEP Rev 47

Page 159 of 226 Lakeland Health 1 page

~ Lakeland Health January 18, 2018 Mr. Joel Gebbie Sr. Vice President & ChiefNuclear Officer Cook Nuclear Plant One Cook Place Bridgman, MI 49106

Dear Mr. Gebbie:

This letter is to confirm that Lakeland Health remains able to provide care for the injured radioactively-contaminated patients at the St. Joseph and Niles Emergency Department sites.

This would include Donald C. Cook personnel exposed on-site and members oftbe public exposed off-site who may require services.

Mutually agreed upon annual training and drills will be conducted to assure staff competency in caring for this patient population, with evaluation by FEMA when required. A policy and procedure manual is available at each site and updated regularly to incorporate changes in patient management. An identified Radiation Emergency Area (REA) is available at each site that allows for stabilization, treatment, and management of the radioactive component of the emergency. I understand that the training for hospital personnel, equipment, and stocking of the disaster cart will continue to be provided by Donald C. Cook Nuclear Plant.

This agreement shall remain in effect from the date of signing until either party, upon ninety (90) days prior written notice to the other party, terminates the agreement.

Please contact Kathy Effa, Manager of Emergency Services, at 269.983 .8670 for any assistance 0_\_ // ?

that you require.

/

- ~ erely, _

I ------ I I _,

.* 1/>" .

L.---,-Loren B. Hamel, MD President & CEO Lakeland Health LBH:sd Legal Review Completed J...\ A-P I l 1'8 II~

1234 Napier Avenue , St . Joseph , Ml 49085 ( 269 ) 983 - 8300 www . I a kel and h ea Ith . o rg Appendix B CEP Rev 47

Page 160 of 226 Lake Township Fire Department 1 page LAI(E TOWNSI-IIP FIRE AND RESCUE P.O. BOX 8 18 3 169 SHAWNEE ROAD BRIDGMAN, MICHIGAN 49106 269-465-6351 Emergency Preparedness Agreement Between Lake Charter Township Fire Department and Donald C. Cook Nuclear Plant Upon receipt of a request for assistance from the Cook Nuclear Plant, Lake Charter Township Fire Department agrees to respond by sending personnel and an NFPA 1901 compliant Pwnper Fire Apparatus with the required minimum equipment to the Cook nuclear Plant Site.

The Cook Nuclear Plant agrees to lead Lake Charter Township Fire Department responders from the Security Control Center to the scene and agrees to provide escorts for Lake Charter Township Fire Fighting vehicles and personnel while in the Protected Area, or other owner controlled areas.

The Cook Nuclear Plant and Lake Charter Township Fire Department agree that for all fires in the Plant Protected Areas, the Plant Fire Brigade Leader will be responsible for fire extinguishment with the assistance of Lake Charter Township Fire Department personnel and advice and counsel of the Lake Charter Township Fire Chief or his designee.

For fires outside the Plant Protected Area, the Lake Charter Township Fire Chief shall be responsible for fire extinguishment with the advice and counsel of the Plant Fire Brigade Leader or designee if they are present.

The Cook Nuclear Plant agrees to provide and Lake Charter Township Fire Department agrees to participate in annual site specific training and drills conducted at the Cook Nuclear Plant site, This agreement shall remain in effect from the date of signing unless the agreement is terminated.

Any party upon ninety (90) days prior written notice to the other party may terminate this agreement.

As an indication of your agreement to the above statements concerning our mutual responsibilities, please sign below, Sincerely,

~~-tice President John ast *

/ok Nuclear Plant Supeh,isor

///_~/ ~L~

Lake Charter Township Harold Heyn - 17 Fire Chief Lake Charter Township Fire Department Appendix B CEP Rev 47

Page 161 of 226 City of Bridgman Fire Department 1 page BRIDGMAN FIRE RESCUE P.O. BOX 366 4234 VINE STREET BRIDGMAN MICHIGAN 49106 (269) 465-3803 (269) 465-5144 FAX (269) 465-4269 EMERGENCY 911 Emergency Preparedness Agreement between Bridgman City Fire Department and Donald C. Cook Nuclear Plant.

Upon receipt of a request for assistance from the Cook Nuclear Plant, Bridgman City Fire Department agrees to respond by sending personnel, apparatus, and equipment to the Cook Nuclear Plant site.

The Cook Nuclear Plant agrees to lead Bridgman City Fire Department responders from the Security Control Center to the scene and agrees to provide escorts for Bridgman City Fire Department Apparatus and personnel while in the protected area, or other owner controlled areas.

The Cook Nuclear Plant and Bridgman City Fire Department agree that for all fires in the Plant Protected Areas, the Plant Fire Brigade Leader will be responsible for the fire extinguishment with the assistance of Bridgman City Fire Department personnel and the advice and counsel of the Bridgman City Fire Chief or his designee.

For fires outside the Plant Protected Area, the Lake Charter Township Fire Chief shall be responsible for fire extinguishment with the assistance of Bridgman City Fire Department personnel and advice of the Bridgman City Fire Chief or designee and counsel of the Plant Fire Brigade Leader or designee if they are present.

The Cook Nuclear Plant agrees to provide and Bridgman City Fire Department agrees to participate in annual site specific training and drills conducted at the Cook Nuclear Plant site.

This agreement shall remain in effect from the date of signing unless the agreement is terminated.

Any party upon ninety (90) days prior written notice to the other party may terminate this agreement.

As an indication of your agreement to the above statements concerning our mutual responsibilities, please sign below.

Sincerely, Accepted and agreed to this

. , fl,_ D f -

_I_<.::>__ ay °, Jo,1 V i , 1-,.) , 2018

~.A:J!- -

Joel Buist ite Vice President Fire Chief Cook Nuclear Plant Bridgman City Fire Department Appendix B CEP Rev 47

Page 162 of 226 Medic 1 Community Emergency Service 2 pages

MEDI£ Jl A.DIIB"'CJ"LA.:N"CE Emergency Pla1111i11g Agreement Betwee11 Medic 1 A111b11/a11ce aud Doua/d C. Cook Nuclear Plaut The purpose of this letter is to establish an agreement between Indiana and Michigan Electric Company's Donald C. Cook Nuclear Plant and Medic I Ambulance. ln the event of an emergency al the Cook Nuclear Plant involving an i1tjury, Medic 1 Ambulance agrees to provide medical care whether the victim bas been iltjured as the result of an accident involving radioactive contamination, hazardous waste, or a regu lar work accident.

Upon receipt of a request for an EMS vehicle from the Cook Nuclear Plant Control Room, Medic 1 Ambulance agrees to respond by sending personnel, apparatus, and equipment to the Plant site.

Cook Nuclear Plant agrees to provide an escort for EMS vehicles and personnel while in the protected area.

Cook Nuclear Plant agrees to provide the necessary health physics suppo1t to Medic 1 Ambulance staff during the treatment of victims who are injured in an accident involving radioactive contamination.

In the event of an iltjury involving a hazardous waste, specific chem ical information will be provided to Medic I Ambulance staff.

The communication link between Medic 1 Ambulance and Cook Nuclear Plant will be provided via telephone communication through the Berrien County dispatch radio.

Cook Nuclear Plant agrees to provide traini ng for emergency room and EMS perso1mel in order to prepare them for handling of radiologically contaminated victims. Such train ing will consist of, but not be limited to, a discussion of types of radiation, types of contamination, methods of decontamination, and methods of controlling the spread of contamination.

Cook Nuclear Plant agrees to conduct and Medic I Ambulance agrees to participate injoinl drills that include plant perso1mel, EMS personnel, and emergency room personnel. These drills will meet Joint Commission on Accredited Hospitals (JCAH) requi rements.

Cook Nuclear Plant agrees to decontaminate all Medic 1 Ambulance equipment and facilities incl uding EMS vehicles that have become contaminated as a result of treatment ofa victim in a timely fashion and to dispose of the associated waste.

Cook Nuclear Plant agrees to provide emergency kits for the emergency room and the ambulance.

Appendix B CEP Rev 47

Page 163 of 226 Medic I Ambulance agrees that medical care provided under this agreement includes any assistance rendered through existing mutual aid agreements entered into by Medic I Ambulance.

Any *party, upon ninety (90) days prior notice to the other party, may terminate this agreement:

As indication of your agreement to the above statement concerning our mutual responsibility, please sign below.

Site Vice President 2Ja7.si:,Jr.* ~

Executive Director Cook Nuclear Plant Medic I Ambulance Dated: \ 2-. / 2...o/l 7 Dated: --~D=e=c~e=m=b~e~r~l~9~,2=0~1~7_ __

P.O. Box 1563 / Benton Harbor, MI 49023 / Phone (269) 925-2141 Appendix B CEP Rev 47

Page 164 of 226 Reciprocal Laboratory Use Agreement 2 pages RECIPROCAL LABORATORY USE AGREEMENT WITNESS ETH THAT WHEREAS, INDIANA MICHIGAN POWER, (hereinafter called IMP) and ENTERGY NUCLEAR PALISADES, L.L.C., (hereinafter called "ENTERGY") have chemical and radiochemical analytical laboratories at their Donald C Cook Nuclear Plant and Palisades Nuclear Plant, respectively, which laboratory facilities are suitable for performing chemical analyses following a nuclear-related accident (NRA), and WHEREAS, IMP and Entergy each desire to provide the temporary use of their respective existing laboratory facilities and personnel to perform chemical analyses for the other in the event the other has lost use of its laboratory facilities due to a NRA, NOW, THEREFORE, the parties hereto do hereby mutually agree as follows:

1. In the event either party hereto is unable to use its laboratory facilities due to a NRA, the other party agrees to temporarily use its existing laboratory facilities and personnel , to the extent practical , to analyze without charge, samples delivered to it by the party which suffered the NRA. Each party agrees, in connection with such sampling, handling and analyses, to comply with the requirements of NUREG-0578 and NUREG.-0737 and such other requirements as may be specified by the Nuclear Regulatory Commission in regard to past-accident sample analysis.

2. Each party agrees, in performing analyses for the other, to provide a high standard of professional service, provided, however, that neither party shall have any obligation or liability for damages, including, but not limited to, consequential damages, arising out of or in connection with the others use of, or reliance on, the results of such analyses.

3. This agreement shall be effective on the date hereof and shall continue until terminated as hereinafter set forth. Either party hereto may terminate this agreement at any time hereafter upon sixty (60) days written notice of termination to the other party.

Appendix B CEP Rev 47

Page 165 of 226 INDIANA MICHIGAN POWER BY: 0 ~ ) La, r;J/ 2,g/,7

~ane Lies Date

/re Vice President - Cook Nuclear Plant ENTERGY NUCLEAR PALISADES, L.L.C.

BY:

Charles F. Arnone Date Site Vice President - Palisades Appendix B CEP Rev 47

Page 166 of 226 Mutual Assistance Agreement Between Detroit Edison Company, Entergy Nuclear Palisades and Indiana Michigan Power Co. 6 pages MUTUAL ASSISTANCE AGREEMENT BETWEEN DTE ENERGY ELECTRIC COMPANY, ENTERGY NUCLEAR PALISADES, L.L.C.

AND INDIANA MICHIGAN POWER Appendix B CEP Rev 47

Page 167 of 226 0.1 Emcrnv f\*uclcm Pr.lii::ac1Ai$l;, I .LC., i>TF. F1,arg;r t:]eclrlc Cornp~.r1~* ~nd Jndiana Michigan Povrer, WITNESS ETH 0.2 WHERF.AS, Frit*rgy N,1clear Palisados, (LLC). DTE Enorgy Electric Compony md ln::ian.:i. ri.1llch ga1, Powe, own elect1'jc ft,:ilities, ir.ctudin~J n.1clear generalion stations and are 9ngag~:.i In lhe g~1,aralio** or el~:f.ric power in Mich.gan; ar,d 0.3 WHEREAS, t11* r,~rtios d~s ra :(, help 8$St1r0 11*,~ ~val:,,tiillly of adaqual0ly IraI11.,;J ar;J experien~d emerg&ncy perwrnel i.1 t!l~ Aveni c.f .:tr Ar.Horg~ncy s*Lur11 m, .-11 ahy *:)f lh.+i*

nu:lear gcn~ro.ting s1ation!.;

0/ MOW. THEREFORE, in oorside,ation o: tt.e p*omises a,:1 iru:ual covenants herein set fort,, the :a11ies agree as fellows~

ARTICLE I DEFINITIONS 1.1 "Alcrr sh.JI be dofincc a:. a ~itt.ni::m in wt.ich c'Jcnm mo 'n pror.c.:.~ o* havC> or,..'"'... mnd w.1i:h i1wolves an act.1al or pot&ntial substantial c*e;rada,:on of tl~e l~vel oJ safe:y Qf t111::1

~l*nl.

1-~ **~rnerQenc~" shall be defi.1ec. cons!stent with the detin;ticn ot lsite area emer~ency a!:

~Er. k:.r~*1 iu NUREG. 0654 aS ttsituatior1 in which e,*tmts: 1:t*e ir: proc~sor haveoc.-curred

- - hi::I: irn:ol*,e r.lt:tutd or likely mtt~)r fE'.i!ures of plant funcikm$ rie,:U.1e*j for protecticr. of tt.e r,ul,li*:::,

I *.J Rcquo:;ting p;:rl'/' :;t-,,1II ho d~finod a!=I an,r p.1rry tr. thi$1 Afim~mont \'lltlo, ur.or ~h<-1 occurrer.ce of an einer9enc,; at one o* tts nucloar *~or.e:-ati19 stations, se.aks errerge!'lcy

~'I.Ssistancc, purouiJnt t:i this Agrccrrcnt. frcm ono or moro of ihc po:-tics hereto.

1.'I "Hesponding part,"' o, respondi.,i:, parties shad be ~ef ned as any par1y or partie& to 111:s Agreement who are pre:sent~ ,.;,*itt1 a re:,1ues~ lar emergency a~s.i&.1anc~ pursuant to this Agr#en1e11t.

Appendix B CEP Rev 47

Page 168 of 226 ARTICLE 11 REQUESTS FOR EMERGENCY ASSISTANCE 2.1 In the event of an Alert at one of its nuclear generating stations, any party to this .

Agreement may notify any or all of the other parties that an Alert exists and that their emergency assistance may be required.

2.2 In the event of an emergency at one of its nuclear generating stations, any party to the Agreement may request emergency assistance from any or all of the other parties.

2.3 Requests for emergency assistance shall be made between and among the following party personnel:

Entergy Nuclear Palisades, L.L.C. Site Vice President - Palisades Nuclear Plant DTE Energy Electric Company Site Vice President - Fermi Nuclear Plant Indiana Michigan Power Site Vice President - Cook Nuclear Plant ARTICLE 111 EXCUSED FAILURE TO RESPOND 3.1 Failure to respond to a request for emergency assistance pursuant to this Agreement shall be excused if, in order to respond, the requested party or parties would be forced in its or their sole judgment or judgments to:

3.1.1 Violate its duties relating to the care and staffing at its own nuclear generating stations; or 3.1.2 Jeopardize the public health or safety at a location other than the location of the requesting party emergency.

ARTICLE IV SCOPE OF ASSISTANCE 4.1 If requested under this Agreement, the responding party or parties will provide trained and experienced personnel to perform off-site radiation protection activities to the requesting party. All equipment intended for use by the responding personnel, except personal dosimeters and certification documents (such as certifications of Health Physics training, instrument training and dose exposure records), shall be the responsibility of the requesting party to provide. The responding party or parties may use their own equipment if agreeable to the requesting party. However, use by the responding party or parties of their own equipment sh all in no way alter the duties and obligations imposed upon the parties by this Agreement.

4.2 Emergency assistance provided by the responding party or parties shall continue until their personnel are dismissed by the requesting party, or are recalled by the responding party to support operations at its own facilities.

Appendix B CEP Rev 47

Page 169 of 226 4.3 Responding party or parties' personnel exposure shall be limited to off-site radiation, and such exposure shall not exceed federal requirements as set forth in 10CFR20.

4.4 Wages, hours and other terms and conditions of employment applicable to loaned personnel shall be those of the party providing such personnel.

4.5 Personnel provided by responding party or parties shall, at all lime during the period in which emergency assistance is being provided, continue to be employees of the responding party or parties. The responding party, and not the requesting party, shall be liable to loaned personnel for any wages, salaries, cost and expenses associated with the provision of emergency assistance.

ARTICLE V REIMBURSEMENT FOR EMERGENCY ASSISTANCE RENDERED 5.1 The requesting party shall reimburse each responding party for all costs and expenses incurred by each responding party in providing emergency assistance hereunder. Such costs and expenses shall include:

5.1. 1 Salaries and wages paid to loaned personnel (in cluding supervisors) for paid time spent in the requesting party service area, and paid time for travel to and from such service area; 5.1 .2 A percentage of the total of such wages and salaries, as determined by the responding party, rellecting expenses incurred for:

5.1.2.1 Compliance with Worker Compensation laws; 5.1.2.2 Payroll taxes; 5.1.2.3 Hospitalization, surgical and medical coverage; 5.1.2.4 Pensions and life insurance; 5.1.2.5 Vacation, holiday and sick pay;

5. 1.2.6 Travel accident insurance; 5.1.3 Transportation to and from the requesting party service area, including the cost of travel accident insurance purchased expressly for coverage during such transportation; 5.1 .4 Food and lodging; 5.1 .5 Personal expenses specifically agreed to between the requesting and responding parties; 5.1.6 Charges, at the rates internally used by the responding party, for the use of transportation equipment and other equipment requested; and 5.1 .7 Any further costs specifically agreed to between the requesting and responding parties.

Appendix B CEP Rev 47

Page 170 of 226 5.2 All time sheets and work records pertaining to loa ned personnel shall be maintained by the responding party.

5.3 All charges shall be paid by the requesting party to each responding party within ten (10) days after receipt of an invoice, itemized to the satisfaction of the requesting party.

ARTICLE VI INDEMNIFICATION 6.1 The requesting party shall indemnify and hold harm less each responding party irom and against any and all liability for loss, damage, cost or expense which the responding party shall incur by reason of bodily injury, including death, to any person or persons, or by reason of damage to or destruction of any property, including the loss of use thereof, arising out of or in any manner connected with the giving of emergency assistance to the requesting party.

6.2 In the event of bodily injury, including death, to any employee of the responding party, or in the event of damage to or destruction of any property of the responding party, the requesting party shall indemnify the responding party for such loss in the following manner:

6 .2.1 If such loss is covered by an insurance policy purchased by the responding party from a third party carrier, the requesting party shall make reimbursement to the extent such losses increase the responding party insurance costs; 6.2.2 If such loss is not covered by an insurance policy purchased by the responding party or exceeds such coverage, the req uesting party shall make reimbursement to the extent of the claims or benefits actually paid or the losses sustained by the responding party.

ARTICLE VII MODIFICATION 7.1 At any time after the date of this Agreement any party, by giving not less than thirty days wri1ten notice to the othe r parties, may from time to time call for reconsideration of the terms and conqitions of this Agreement. If such reconsideration is called for, the authorized representatives of the parties shall meet as promptly as convenient and discuss any of the terms and conditions of the Agreement. No party shall be under any obligation to agree to any modification or supplement not satisfactory to it. Any agreement modifying or supplementing such terms and conditions shall be in writing, signed by all parties, and shall specify the date such modification or supplement shall become effective.

ARTICLE VIII PLAN EXERCISING 8.1 The parties agree to provide, at their own expense, personnel to observe or assist in demonstrating the effectiveness of a nuclear generating station emergency plan as may be required by that nuclear generating station NRG approved emergency plan.

Appendix B CEP Rev 47

Page 171 of 226 ARTICLE IX TERM OF AGREEMENT 9.1 This Agreement shall continue indefinitely from the date of signing unless and until terminated as provided for in Section 9.2 below.

9.2 Any party, upon sixty (60) days prior written notice to all other parties, may terminate this Agreement.

IN WITNESS WHEREOF, the parties hereto cause this Agreement to be executed by their duly authorized officers on duplicate original pages attached hereto and made a part hereof.

ENTERGY NUCLl:.: zlS~DES, L.L.C.

2rN ~-- oilo/;9 Darrell W. Corbin Date Site Vice President - Palisades DTE ENERGY ELECTRIC COMPANY Paul Fessler 1 Date Senior Vice President - Fermi INDIANA MICHIGAN POWER

<t . l)i: r'1 Q. Sh Lies Date Sile ice President - D. C. Cook Nuclear Plant Appendix B CEP Rev 47

Page 172 of 226 Institute of Nuclear Power Operations Emergency Resources 1 page INPD Institute of Nuclear Power Operations Suite 100 700 Galleria Parkway, SE Atlanta, GA 30339-5943 770-644-8000 FAX 770-644-8549 November 2, 2017

Dear Ladies and Gentlemen:

This letter certifies that the Nuclear Power Plant Emergency Response Assistance Agreement dated November 8, 2013 remains in effect. INPO will assist you as described in the agreement and in revision 1 of the United States Industry Event Response Framework.

A copy of the agreement and the counterpart signatures can be found on the INPO integrated response member website. This agreement will remain in effect until amended or terminated in accordance with the guidance described in paragraphs 14 and 15 of the agreement.

Should you have any questions, please call me at (770) 644-8882 or email at williamsdr@inpo.org Sincerely, Dane R. Williams Manager, Emergency Managament DRW:oa Appendix B CEP Rev 47

Page 173 of 226 FEMA ANS Design Report Letter 6 pages Approva l of .C. Cook uclear Po ~er Pa t Alert aml o if r;atinn Sys 1 Plan Memo DATE: April 13, 2021 MEMORANDUM FOR:

FROM:

SUBJECT:

Approval and Acceptance of Updated D.C. Cook Nuclear Power Plant Alert and Notification System Changes The Federal Emergency Management Agency (FEMA) eadq arters Radiological Emergency Prepa redness Program has oompleted its evalu lion o the upda ed D.C Cook uclear Plant {C P), Berrien COunty and the State of Michigan Design Report and Alert and No f1cat on Systom (ANS) Plan. In accordance with 44 CFR 350.14 , FEMA approved the pdated A. S Evafua *on Report (A.~S Plan and Design Report) and forwarded the ANS Evaluation Report lo the U.S.

uctear Regulatory Comm1 sion ( RC) for appropnate act,oo on March 9, 2021.

As noted in the updated Design Report for CNP, Berrien County selected the Integrated Pubhc Alert and Warmng System Wlr fess Emerg ncy ert (IPAWS-WEA) net e lntegrat!MI Public Alert and Warning System Emergency Alert System (IPAWS*EAS) as t e IJ{irnary alerting an<f notification method for residents and t ransients within the 0-mlle Emergency Plannmg Zone (EPZ). Rou te Alerting vii remain as t.he cu rrent (pre Is ng). back-up ert and nolifica ion method. Additional y, Ber *en Co nty a Jld CNP will be implementing 8 -WAR , an Emergency Notification System {ENSI to supp!(! ent tert and notification capabihlies abo11 and be)IO(ld the required primary and back-up design objectives. The proposed changes are suitable for a reasonable assurance determination of public safety for he population in the CNP plume e,cposure pathway EPZ..

RC accepted FEMA's ndmgs that the updated CNP, Bcrnen County, and State of Michigan A S Plan and Design Rep0rt mee the applicable reQul rements in 10 CFR 50, Appendix E, Section IV.D.3 and enabled the RC to make a f inding of reasonab e assurance for pubhc health and safety.

Enclosed are copies of the FE A's approva l and he NRC's acceptance memorandums and a draft letter for Region V to notify the State of lchlgan and begin planning for implementation of tile P(ial d NS.

FEMA Appendix B CEP Rev 47

Page 174 of 226 Approval of O.C. Cook Nuclear Power Plant Alett aoo Notification System Pla.n Page 2 If you have any questions regarding this matter, please contact Bruce Foreman, Chief, Polk:y and Doctrine Branch, Technological ttazards DiVlslon or Michael Boney, Chief, Engineering and Technology Section, Technological Hazards Division at 202-304-5399 or 202-322- 6266 respectivety.

Cc: Michael Chesney, Federal Preparedness Coordinator, FEMA Region V sean O'Leary, Chief, Technological Hazards Branch, F£MA Region v

Enclosures:

F£MA Approval Letter to NRC, March 5, 2021 NRC Response Acceptance Letter to FEMA. March 29, 2021 Draft Notification of Approval Letter from Region V to the Stale of Michigan Appendix B CEP Rev 47

Page 175 of 226 U.S. Dtputmeat ofHomelud s<<:orify tVashingroll. DC 20472 FEMA March 5, 2021 Kathryn Brock, Director, Division of Preparedness and Response Office ofNuclea, Security and Incident Response U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dear Ms. Brock The Federal Emergency Management Agency (FEMA) received the updated State of Michigan, Berrien County, and DC Cook Nuclear Plant (CNP) Alert and Notification Sysrem Evaluation Report (ANS Plan and Design Report) . In aocordance with 44 CFR Part 350, FEMA reviews and approves significant plan changes; this plan change constitutes a significant change. FEMA has reviewed and approved the ANS Plan and Design Report I am fonvarding the report with FEMA approval to you for appropriate action.

As noted in the updated report, the State of Michigan, Berrien County and CNP selected the Integrated Public Alerts Warning System Wireless Emergency Alert (!PAWS-WEA) and the Integrated Public Alerts and Warning System Emergency Alert System (IPAWS-EAS) as the primary alerting and notification methods for residents and transients within the 10-mile Emergency Planning Zone. Additionally, the State of Michigan, Benien County, and CNP selected Route Alerting as the independent backup alerting method. Please note the report also identifies the use of a sttppleruentary system called the Berrien Warning and Regional Notification System or "B-WARN!". a subscnOer-based mass notification system. We assess the proposed changes to be approved for a reasonable assurance determination of public safety for the population in the CNP plume exposure pathway emergency planning zone.

If you have any questions or concerns, please contact Bruce C. Fore man, Branch Chief, Policy and Doctrine Branch, Technological Hazards Division at 202-646-3567.

Sincerely, SCOTTH KELBEJ>G Scott Kelberg Aeting D eputy A ssistant Administrator N ational Preparedness D ired orate Enc.losures: DC Cook Alert and Notification System (ANS) Evaluation Report Appendix B CEP Rev 47

Page 176 of 226 UNITED STATES NUCLEAR REGULATORY COMMISSION WA$HINC TON, o.c. :zosu . 0001 March 29. 202 1 Scott Kelberg Acting Deputy Assistant Administrator National Prepar edness Directorate Federal Emergency Management Agency 400 C Street, South West Washington, DC 20024

SUBJECT:

RE: STATE OF MICHIGAN, BERRIEN COUNTY, AND DC COOK NUCLEAR PLANT ALERT AND NOTIFICATIO N SYST EM EVALUATION REPORT

Dear Mr. Kelberg:

On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated Mar ch 5, 2021 which provided the Federal Emergency Management Agency (FEMA) approval of Revision 2 of the State of Michigan, Berrien County, and Donald C. Cook Nuclear Plant (CNP) Alert and Notification System Evaluation Report (ANS Plan and Design Report) dated January 1, 20211

As noted in Revision 2 of the CNP ANS Plan and Design Report, Berrien County proposes to replace sirens and use an Integrated Public A lert and W arning Sy stem (IPA W S) - W irele ss Emergency A lert and IPA W S - E mergency A lert S ystem concurrently as lhe primary ANS for the CNP 10-mile emergency planning zone. The revised CNP ANS Plan and Design Report further stipulates that route alerting will remain the back-up ANS.

Per Section 111, Paragraph 2 of the "Memorandum of Understanding (MOU) between the Department of Homeland Security/federal Emergency Management Agency and the Nuclear Regulatory Commission Regarding Radiological Emergencies , Planning, and Preparedness,*

which was signed on November 19, 20152:

FEMA coordinates all Federal planning for offsite impact of radiological emergencies and takes the lead for assessing offsite radiological emergency response plans and prepar edness, makes findings and determinations as to the adequacy and capability of

' NRC's Agencywicle Documents Access .llld Manageme.nt System (ADAMS) Accession No. Ml2 1083A256

" ADAMS Accession No. ML t 5344A37 1 Appendix B CEP Rev 47

Page 177 of 226 S. Kelberg 2 implementing offsite p la ns and commu nicat es those findings a nd determinations to the NRC. The NRC reviews FEMA's find ing s and d e termin atio ns in conj un ction w ith the NRC onste find ino s for the ou roose of m akino de termin ations on the o,,erall st ate of emergen cy p re pa redness. These ove rall find ing s and d et ermina tio ns are u sed by the NRC to make radio logical health an d safety decisio ns in the issuan ce of licenses an d the co ntinued o peration of lice nsed utilization facility to include ta king en forcement a ctio ns su ch a s no tices o f vio latio ns, civil penalties, o rders, or sh utdown of o pe*ating reactors.

This delineation of responsib ilities avo id s d up lica tive efforts by the NRC in prepared ness ma tters.*

Consiste nt w ith ti e ro les of each respective a ge ncy a s set forth in the aforeme, tion ed MOU, the NRC condu cted a review of the FEMA find ings. To a id it s review , the NRC utilized the FEMA eva luation criteria and samp le tem plate for ANS ch anges a nd use of IPAWS3* The N RC review focused o n the applicab le req uirem en ts in Title 10 of the Code of Federal R eg,1/ations ( 10 CFR)

S ection SO, Ap pendix E, S ection IV.D.3. 10 C FR SO, Append ix E ,Section IV.0.3.

Addition alty, the NRC evaluat ed the revised CNP ANS P lan a nd Desig n Report d ated Ja nua ry 1, 2021 a nd fo und that it cont ained su fficien t information t o be considered a n adeq uate sub mittal fo r NRC t o condu ct its review. At th is time , the NRC d id no t iden tify ~ny lice nsing b asis issues.

In con clusio n, the NRC a ccep ts the findings of FEMA tha t Revision 2 o f the State of Mich igan ,

Berrie n County, and C NP ANS Plan and Design Report meets the ap plicab le req uirements in 10 C FR SO, Ap pendix E, S ection IV.D.3 , and, en ables the NRC to mainta in its i nd ing of rea so n ab le a ssu*ance for p ublic heatth an d safety.

Please feel free lo con ta ct my st aff, Robert K ahler, Chie f, Policy a nd Oversigh t B ranch a t 30 1-287-3756 o r at Robert.Kahle r@nrc.g ov, if yo u have q uestions.

Sin ce re ly,

lr'IJhr -pi, /'itKK Signed b)' Brock. Kathryn on 03/29.'21 K ath ryn M . Brock, Dire cto r Divisio n of Pre pa red ness a nd Response Office of Nuclear Security an d Incident Response

1 ADAMS Accession No. ML 19339GS62 Appendix B CEP Rev 47

..* ML21083A256* ltr ML21083A259 OFFICE NSIR/DPR/POB NSIR/DPR NAME CRosales-Cooper C/i RKahler R~ KBrock KB DATE Mar 26, 2021 Mar 26, 2021 Mar 29, 2021 Page 179 of 226 APPENDIX C EMERGENCY KITS AND EQUIPMENT LOCATION Appendix C CEP Rev 47

Page 180 of 226 Emergency Kits and Equipment Location KIT LOCATION Radiation Protection Emergency Kit Operations Support Center (OSC)

Emergency Operations Facility (EOF)

Survey Vehicles (1 in each of the 2 dedicated Survey Vehicles)

First Aid - Decon Equipment Radiation Protection Access Control (RPAC)

Anti-C Equipment for Ambulance Security Control Center In-Plant/On-Site Driver to Hospital Vehicle Search Portal Emergency Anti-C Equipment and Technical Support Center (TSC)

Respirators Operations Support Center Area Emergency Operations Facility (EOF)

Each Control Room Control Room Emergency Cabinet Survey Vehicle Hospital Emergency Cabinet Spectrum Health Lakeland Medical Center Spectrum Health Lakeland Niles Hospital Shift Supervisor Office Radiation 633 Turbine Deck outside the Shift Managers Protection Emergency Locker Office by the west wall SCBAs 17 - Auxiliary Building 10 - RPAC 10 - Basement Assembly Area (OSC) 10 - 633 Turbine Deck outside the Shift Managers Office by the west wall 2 - Each Control Room 10 - 609 Turbine Bldg. (for Turbine Building use only)

Stretcher Lockers 10 - Locations in Plant Appendix C CEP Rev 47

Page 181 of 226 APPENDIX D EMERGENCY PREPAREDNESS BROCHURE Appendix D CEP Rev 47

Page 182 of 226 Applicable Portions from the Annual Emergency Information Calendar for Berrien County INTEGRATED PUBLIC ALERT & WARNING SYSTEM {IPAWS) & B-WARN!

On February 5, 2021, the Berrien County Sheriff If your wireless carrier participates in the WEA system you (floods, earthquakes, forest fires); chemical spills or Department's Emergency Management and will receive emergency alerts automatically. There is no releases, nuclear power plant emergencies and national Homeland Security Division will use two alert systems need to download an app. To find out if your phone can emergencies (terrorist attacks).

simultaneously, !PAWS and B-WARN!. Together, they receive Wireless Emergency Alerts, contact your wireless Boaters, if you receive an emergency alert, immediately will inform the majority of people in Berrien County provider. All the major providers participate in WEA tune to the marine channel 16 ( 156.8 MHz) or an area of any emergencies or hazards. Messages will be sent voluntarily. There is no charge to your wireless data plan radio or TV station listed on page 3. You will be told the to residents, workers, visitors, boaters, campers and when you receive WEA messages. location of safe waterways and docking areas. Marine travelers in the County. patrol boats will also warn boaters on Lake Michigan if MAKE SURE YOU CAN RECEIVE WEA AND TEST IPAWS GETS YOUR ATTENTION ON THE VARIOUS ALERTS ON YOUR CELL PHONE. there is a serious emergency.

COMMUN ICATION DEVICES YOU USE SO YOU CAN To ensure that you receive WEA as w ell as test alerts B-WARN! SEN D S ALERTS TO MORETHAN YOUR TAKE ACTION FASTER IN AN EMERGENCY. at 3 p.m. on the first Friday of the month {starting WIRELESS DEVICES. SIGN UP ONLINETODAY.

The Integrated Public Alert & Warning System (IPAWSJ February 5, 202 1): B-WARN1is an ' Opt-In" notification service that allows is FEMA's national system for local alerting. It delivers consistent, authenticated emergency and life-saving

Contact your cell phone provider to see if they the Berrien County Sheriff's Office to alert you during an emergency. When you sign up you choose how you want participate in WEA.

information to you and the public through mobile

Turn off your "airplane mode" setting. to be notified. This includes receiving voice messages on

inCheck phones using Wireless Emergency Alerts {WEA), to your landline phone, text messages on your cell phone as radio and television via the Emergency Alert System your notification settings menu. Turn on "opt- well as pager, email and fax messages. When you sign up

{EASJ, and on the National Oceanic and Atmospheric to receive alerts" setting.

you also can designate the locations where you want the Administration'sWeather Radio (NOAA). IPAWS messages If your cell phone provider does not participate in WEA, County to send the B-WARN! messages.

will tell you where to seek more information so you can make sure to sign up for Berrien County's B-WARN!. It's act quickly. easy. See the instructions on this page.

IPAWS is tested on the first Friday of each month EAS MESSAGES ARE SENTTHROUGH at 3 p.m. starting in February. TV AND RADIO STATIONS.

All of the 24-hour TV and radio stations listed on page 3 To receive the test alerts, you likely will ned to change are part of the EAS. Some of the stations may experience Sign upat www.bcsheriff.org.

the settings on your cell or mobile phone. See the a delay in getting emergency information out due On the site's homepage:

instructions in the Wireless Emergency Alerts (WEA) to computerized programming or limited broadcast

1. Click on the Divisions tab and select Emergency section on this page. sched uling. Check all of the listed stations until you find Management & Homeland Security Division from one that is broadcasti ng emergency information.

the sidebar.

WEA - MAKE SURE THE SETTING TO RECEIVE LOCAL EMERGENCY ALERTS ON YOUR CELL PHONE IS NATIONAL OCEANIC AND ATMOSPHERIC 2. Click the B-WARN! Button.

TURNED ON. ADMINISTRATION'SWEATHER RADIO (NOAA) 3. Click t he Sign Up Today but ton.

Wireless Emergency Alerts {WEA) are short, text-l ike This is a nationwide network of radio stations

4. Create an account.

emergency messages that come from aut horized broadcasti ng continuous, 24-hours per day, weather information directly from the nearest National Weather 5. Fill out the online form and submit it.

federal, state, local, tribal and territorial public alerting authorities. These alerts are broadcast from cell towers Service {NWS) office. {Our station is in Northern Indiana.)

to any WEA-enabled mobile device in a locally targeted NOAA Weather Radio can send out warnings and post- If you believe, for whatever reason, the above area. WEA have a unique tone and vibration, both event information for all types of hazards including methods will not be able to alert you, please see repeated twice. weather (tornadoes, blizzards); natural disasters the Functional Needs card on page 17.

Appendix D CEP Rev 47

Page 183 of 226 WHAT TO DO IF YOU ARE TOLD TO SEEK SHELTER WHAT TO DO IF YOU ARE TOLD TO EVACUATE OR STAY INDOORS

Only call 9 11 i f you are experiencing an emergency. If you have a For most emergencies, it is safer to stay indoors. The wind will blow any toxic or general question or need advice, use the Cook Nuclear Public Inquiry Hotline: 866-362-3105.

Listen to the radio or TV (see page for instructions. They will give you poisonous fumes and gases away in a short time. During a severe weather emergency, buildings offer the best protection, especially basements. While indoors, do the following: 3)

Keep ca lm . Panic is your worst enemy in any emergency. evacuation rout es and directions to open Public Reception Centers.

Go d irectly to a Public Reception Center and register. Follow the broadcasted

Close all windows and doors and bring pets inside.

Turn off all air-intake systems such as fans and air conditioners. Turn down the evacuation rout e instructions to the nea rest open Public Reception Cent er. Please register when you arrive so family and friends w ill know where you are. After you furnace thermost at. Close fireplace dampers.

If your building has a basement, take a radio and go there.

have registered you may go to stay with friends or family who live outside the danger area. If you prefer, you will be assigned to a safe, nearby gathering place.

Do not go outside until you are told i t is safe to go out or are told to Stay ca lm. You and others w ith you should have time to get ready to leave saf ely.

evacuate. If you must go outdoors briefly to warn someone during a nuclear emergency, cover your nose and mouth with a cloth towel or scarf.

Take only essential items. Pack as if you were going on a trip for only a few days.

Do not use the telephone or the internet unless it is absolutely necessary. It's Use the list on page 17 as a guide.

Do not take firearms, alcoholic beverages o r illegal drugs.

important t o keep t elephone lines open for emergency use.

Stay out of your ca r or vehicle in a weather emergency. Seek shelter in the

If you have functional needs and have sent in a postcard, you w ill receive the necessary assistance. If you need help, list en to a local TV or rad io station listed basement of a nearby building or a ditch until the weather emergency passes. on page 3 for the telephone number you can call.

Do not pick up children from schools or day ca re centers. School staff and child

Have a plan for your pets. Public Reception Centers will only accept pet s if they caregivers w ill keep children in school until it is safe t o go out again. Listen for are service animal s. Make arrangement s t o st ay w ith relatives, friends or at a pet -

directions on TV or radio st ations (see page 3) about where and when they can be friendly hotel out side of the area. Bring pet supplies with you. Animal Control will picked up.

Do not worry i f you o r family members are in a hospital or other special-care be at Public Reception Centers to provide additional options and advice. For more information, go t o ready.gov/ caring-animals, PetTravel.com and Pets Welcome.com.

faci lity, as they also have emergency procedures.

Turn off small appliances, lightsand water faucets. However, leave your PLAN AHEAD FOR SHELTERING-IN-PLACE refrigerat or and freezer on.

Have ready access to:

Turn off all air-intake systems such as fans and air cond itioning. Turn down the furnace thermostat. Close fireplace dampers.

D A battery-operated radio and flashlight plus extra batteries.

D Seven- to t en-days' supply of your and your household members' prescriptions

Close and lock all w indows and doors. The evacuated area w ill be secured and you will not be allowed to return until it is safe.

and med ications.

D Three-days' supply of non-perishable food and beverages for your household

Check on neighbors. Make sure they know how to evacuat e and that they have transportation.

and pets.

ANYONE WITH FUNCTIONAL NEEDS: If you might need special help in an IMPORTANT: Do not pick up your children from schools o r child care emergency, fill out the card on page 17 and mail it right away. You can also centers. If necessary, they w ill be taken to shelters outside fill it out online at www.bcsheriff.org. the danger zone. Listen for directions on TV or radio stations (see page 3) about where and when they can be picked up. Do not worry if you or family members are in a hospi tal or other special-care facility, as they also have emergency procedures.

Appendix D CEP Rev 47

Page 184 of 226 WHAT TO DO IFYOU RECEIVE AN EMERGENCY ALERT In Berrien County, we use !PAWS wireless emergency alerts, 8-WARN! alerts and alerts VACATIONERS AND VISITORS:

over TV or radio broadcasts to let you know a .serious emergency is happening. Such If you receive an emergency alert while vacationing or visiting in the area, seek emergencies include a nuclear accident, chemical spill, severe weather or other possible shelter indoors.Tune to one of the TV or radio stations listed on thispage. Follow all dangerous condition in our county that requires you to take action for safety. Learn d irections given by park officials, sheriff and police officers. If possible, during a weather more about IPAWS onli ne by visiting the Emergency Management Division webpage at emergency do not stay in your vehicle. It is not s.afe!

www.bcsheriff.org and look for the public warning system section.

BOATERSAND CAMPERS:

If you receive an alert, tune to any TV station or radio station listed in this If you receive an emergency alert while boat.i ng, d o not wait for further warning.

section, or check your cell phone or another wireless communication device Tune to the marine channel 16 (156.8 MHz) or to an area AM/FM radio station listed for emergency messages. below for emergency information. Mariners are encouraged to keep their radios tu ned to channel 16 when on Lake Michigan to receive emergency information. Marine patrol boats will also warn boaters on Lake Michigan if there isa serious emergency. You will IPAWS is FEMA's national alert warning system that delivers messages via WEA, EAS and be told the location of safe waterways and docking areas.

NOAA weather radio. You need to sign up for t he other alert system the county uses called 8-WARN! More details are on page 16. If you receive an emergency alert while camping, hiking, swimming or visit.i ng area parks, follow all emergen,y inmu,tions,from park officials. At Warren Dunes Cell phones and other wireless devices r eceive IPAWSWireless Emergency and Grand Mere state parks, officials will use the public address system or mobile alert Alerts (WEA). These are text-like alerts that loudly alert your phone if the setting to units to let you know what to do. At other local parks, immediately tu ne to an area radio receive local emergency alerts is turned on. If your wireless carrier participates in the st ation listed below and follow instructions.

WEA system you will receive emergency alerts automatically. WEA messages are not charged to your wireless data plan. You may need to turn on thisfeature to receive the alerts and you may need to separately turn on the ability to receive a test alert. !PAWS is tested on the first Friday of each month at 3 p.m.

Contact your phone provider or store for assistance on how to turn these settings on.

Emergency Alert System (EAS) messages are sent through TV and radio stations. Emergency Alert System (EAS) area radio and TV stations All of the TV and radio stations listed here are part of the EAS. Some of the stations Tune to one of these radio or TV stations for emergency information. All call letters are may experience a delay in getting emergency information out d ue to computerized accurate at the time of printing. All stations are on the air 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Check your cable or programming or limited broadcast scheduli ng. Check all of the listed stations until s.atellite provider for your channel lineup.

you find one that is broadcasting emergency information.

NOAA Weat her Radios will also alert and broadcast emergency information when the National Weather Service Forecast Office in Northern Indiana activates AM FM them at the request of County officials.

WHFB- 1060 WAUS- 90.7 WEFM-9S:.9 8-WARN! is a system you sign up for. It allows you to enter land line phone numbers, WQLQ - 99.9 WCSY- 103.7 cell numbers, text message numbers, pagers, email, and fax numbers tobe alerted in WNIL- 1290 WSJM - 94.9 WYTZ - 97.5 WAOR- 102.7 WIRX - 107.1 an emergency. Thissystem also allows you to enter add resses for places you want to WSJM - 1400 WTRC - 95.3 WCXT - 98..3 be alerted even if you are not there, such as a child'sschool or your home while you are away. Learn more and sign up at www.bcsheriff.org. Look for the section marked "Sign up for emergency alerts" on the Emergency Management & Homeland Security WNDU- NBC 16 WNDU - 16.2 WSBT - CBS 22.1 WBND - ABC 57 Division page. Or fill out and mail the Functional Needs card on page 17. WNDU -NBC 16.1 WSBT - FOX 22.2 If you believe, for whatever reason, the above methods will not be able to FOLLOW ALL BROADCAST INSTRUCTIONS PROMPTLY.

alert you, please see the Functional Needs card on page 17. The radio or TV announcer will tell you what actions you should take, if any.

Appendix D CEP Rev 47

Page 185 of 226 COOK NUCLEAR WHATTO BRING WITH YOU D Basics: this calendar, cash, PLANT EMERGENCY portable radio, flashl ight, PLANNING ZONE extra batteries, keys, tool kit, credit/debit cards, The circled area of the map is a checkbook, wallet, purse, AWROU.WESCALEfl NILES 10-mile radius su rrounding Cook cell phone and charger Nuclear Plant in Bridgman known D Bedding: blankets, pillows, as the Emergency Planning Zone sleeping bags (EPZ). The emergency warning system for Berrien County alerts D Toiletries: soap, towels, people county-wide which includes toothpaste, toothbrushes, those living within the EPZ and razors, sanitary suppl ies those who are not. When necessary, D Special items: special-diet area TV and radio stations (see page foods, baby formula and

3) will alert people living inside the bottles, diapers, favorite EPZ when there is an emergency.

Inside the EPZ are the Protective toys or games D Health supplies: medicines, 7

Action Areas for the Cook Nuclear glasses, dentures, hearing Plant. During an emergency, these aids, first-aid kit, areas will be identified by the prescription information numbers shown on the map. For D Identification: d river's example, the TV or radio station license, credit cards, may say, "Protective Action Area important papers 1 must evacuate," or, "Protective Action Area 2 must take shelter." D Pet supplies: food, water, Know which Protective Action Area medicines, leashes, tags you live, work or are boating in so ONCE YOU ARE IN you can respond promptly YOURVEH ICLE to instructions.

Drive carefully. There is During an emergency, listen to no need to speed. Follow area TV or radio stations for official directions of all sheriff, instructions on evacuating to the police and traffic officers.

Public Reception Center you are Close all windows and to use.

vent.s. Shut off heating PUBLIC RECEPTION CENTERS and air conditioning.

The locations ofthe fou r Public listen to the radio (see Reception Centers are listed below page 3). Follow emergency the map. Listen to an area radio instructions broadcast on or TV station (see page 3) to learn your car or portable radio. A. COLOMA HIGH SOUlOL B. WATERVLIET HIGHSCHOOL C. BRANDYWINEHIGH SCHOOL 0. NEW BUFFALO HIGHSCHOOL which Public Reception Centers You will be told when it is 300 W.St. JosephSl, Coloma 410 E. St. Joseph St., Watervliet 1700 Bell Rd., Nil~ 1112 E. Clay St., NewBuffalo are open. safe to return. (Red Arrow Highway) (Red Arrow Highway) (Southof Nil~ & East of M-S1) (Southof US-12)

Appendix D CEP Rev 47

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CUT ALONG THIS LINE Appendix D 2021 FUNCTIONAL NEEDS EMERGENCY INFORMATION If you have functional needs, please fill in thi scard, fold, sealitwith tape and mail it today! You may also fill tllisoutonlineat www.baheriff.org. You must send in anew cardor fill out theonline form every year to keep our files up-ID-date.

IIAME OF PERSOII IIEEDIIIGHELP:

STREET /IDDRESS:

OIY: ZIP: H(\\IE PHONE: (

CELLPHOII~ ( EMAIL:

If there arespecial directionsto your home, please con tact BerrienCounty Emergency Management at 269-983-7111, Ext. 4915.

IFYOUAREA PART-Tr.IE RESIDENT, PLIASECIRCLETHEMONTH SYOU STAY N BERRl&l COUNTY:

JAN FEB MAR APR MAY JUN JUL N.JG SEPT OCT NOV DEC YOUR FUNCTIONALNEED (CIRCLEAll THATAPPLY):

VISION*IMPAIRED HEARING/SPEECH*IMPAIRED WHEELCHAIR WALKER/CANE BEDRIOOEN VENTILATOR OXYCIN CEP Rev 47 OTHER (PLEASE DESCRIBE):

/"\ ALERT/NOTIFKATION INFORMATION (CIRCLE ONE ANSWER FOR EACHQU ESTION): /"\

C C

..... IPAWS: lntegra11!d Public Alert &Warning Sys !em .....

l> Are)l)uable to receive IPAWS wireless emergencyaler~? YES NO l>

5 z Are)l)uable to receive B-WARN' emergency alerts? ye; 110 B-WARN!: Berrien Warning Alertand Regimal Notifications 5 z

":c..... ":c.....

NOAA: Natimal Oceanicand Almosphenc Administratim Are)l)Uable to receive NOAA Weather Radioemeigency aler~? YES NO vi vi

,.... TRANSPORTATION IN FORMATION (CIRCLE ONE*. ,....

zm YES NO POS9BLY zm Could a family member or friend give youtransportation if youwere askedto evacuate in an emergency?

PET INFORMATION :

If you would requiretransportltion help to evacuate, do you have pets at home that will requireattention if youareaskedto evacuate in an emergency? If so, indicate the numberof each:

CAlS: OOGS: SERVICE D(X;S: 0THER (DESCRIBE):

EMERGENCY CONTACTS:

PRIMAAY(NMIE): REL AT IONSHI P: PHONE:

PJ.TERNATE(NAME): REL AT IONSHIP: PHONE:

Page 186 of 226

Page 187 of 226 CUT ALONG THIS LINE r-----------------------

For anyone who might need special help in an emergency

Please fill out the other side of thi s card, cut it out along the dashed line, fold and seal it, then d rop it into the mail. No postage i s required.

If you prefer, you c:an fill out the Functional Needs information at www.bcsheriff.o rg.

Your functional needs information will be kept confidential.

Each person needing assi st ance, even if l iving together at the same add ress, w a:

should fill out a card or the w J:

online form t o noti fy us of each a person's needs.

The Berrien County Health 0

u.

~

Department w ill keep your functional needs information on file for one year. Please fill out a new card and mail it in as soon as you receive your new calendar.

functional If you know someone with a need, volunteer to help them in an emergency.

Thi s i s especially important if that person lives w ithin the 10-mile Emergency Planning Zone (see the map on page 17).

If this i s not p ractical, please d iscuss and/or assi st them in filling out the Functional Needs Emergency Information Card or the online form.

CUT ALONG THIS LINE Appendix D CEP Rev 47

Page 188 of 226 IMPORTANT NUCLEAR EMERGENCY TERMS AND RADIATION FACTS Nuclear Emergency Terms 4. GENERAL EMERGENCY: t he most serious sit uation possi ble at the Cook Nuclear Plant. It could result i n t he release of a large amount of radioact ive material outside In the unlikely event that t here is an emergency at the Cook Nuclear Plant, fou r terms t he plant bound ary. Al l federal, state and county officials wi ll provide hel p as needed.

will be used to describe each situation. Those four terms are explai ned below. They are Prot ective measures may be requi red to ensu re t he safety of t he publ ic as far as 10 listed in order of least serious {1) to most serious {4).

m iles from t he plant. The wi reless emergency alerts, IPAWS, B-WARN! and NOAA Because of the many safeguards and highly skilled people operat ing t he Cook Nuclear marine radios direct you t o t une i nto area TV and rad io st at ions {see page 3) if shelt er or Plant , it is very unl ikely that a serious event wi ll ever occu r there. Chances of you having evacuat ion is necessary.

to seek shelt er or evacuate because of a nuclear emergency are very remote. In most TWO OTHER KEYTERMS: RADIATION AND CONTAMINATION

Radiation refers to t he part icles and waves given off by radioact ive mat erial. It is cases, evacuation is ordered as a safety measu re before any danger can come t o you or your family. Federal law, however, requi res that the public be told wlhat t o do i n case of a significant release of radioactive material from the Cook Nuclear Plant. Please keep t his a form of energy that occurs nat urally and art ificially. We are exposed to it every Emergency Information Calendar handy and become familiar w it h its content s. day. However, radiation could be harmful to your healt h and safety if t he level s are high enough and t he exposure l asts long enough.

Somet i mes you wi ll hear news about a drill or an exercise i nvolvi ng t he Cook Nuclear Plant . That is because federal, state, county and plant officials are required by law Contami nation i s when rad ioact ive mat erial is where it i s not supposed to be.

to participat e regularl y i n dri lls and exercises so they are prepared i n case of an Food, water or ai r i s considered contaminated if it contai ns more or different types emergency. of radioactive m aterial than would be normally present. Our bod ies, for example, cont ain very small amount s of t he radioact ive elements potassi um-40, carbon-14 Remember, you Wlill receive an emergency alert if sheltering or evacuation is and t rit i um. We are not considered to be contami nated because these elements necessary. See page 16. exist w it hin u s naturally. However, t he presence o f stront ium-90 (a possi ble by-product of a nuclear power plant emergency) in food, ai r or water can indicate cont ami nat ion.

If you receive an emergency alert, l isten to an area TV or radio station for emergency Facts About Radiation i nformat ion {see l ist on page 3) and follow instruct ions.

1. UNUSUAL EVENT: a minor problem at the Cook Nuclear Plant th.at varies from RA DIATION IS A N ATURA L FACT OF LIFE normal or routine operations. No release of radioactive material is expect ed. Cook Plant Radiation i s a form of energy li ke light or sunshi ne. There is radiat ion .all around us. We officials wi ll not ify federal, state and county official s. You wi ll not have to do anythi ng. are exposed to small amounts of rad ioactive materi als every moment of our lives.

2. ALERT: an abnorm al plant condit ion that could result in a small release of radioact ive H OW WE MEASURE RA DIATION mat erial inside t he plant This i s still considered a m inor event. Cook Plant officials w ill You cannot see, taste, lhear or smell ionizing radiat ion. But we can measu re it w ith not ify federal, st at e and county offici als t o stand by. It is not likely t hat you w ill have to special i nstruments. We use a unit called a millirem (mRem) t o measure ionizi ng do anything.

radiation.

3. SITE AREA EMERGENCY: a more serious situat ion that could result i n a release of On average, a person living in the U.S. receives about 620 mRem per year from all radioactive mat erial around the plant sit e. All federal; state and courntyofficials w ill radiation sources. A person livi ng withi n 10 miles of the Cook Nuclear Plant receives be ready t o help if needed. Protective measures may be requi red to ensu re t he safety about 485 mRem because we live at a low elevat ion t hat is not near any radioactive rock of t he public in a lim ited area near t he plant sit e boundary. If so, you will receive an formations. About 310 mRem of the total we receive comes from man-made sources, emergency alert. Tune i n immediately t o an area TV or radio station (see page 3) t o learn primarily medical test ing. Only a t iny fract ion of one percent of t he m an-made radiat ion whether you will need to seek shelt er or evacuate.

would come from t he Cook Plant .

Appendix D CEP Rev 47

Page 189 of 226 IMPORTANT NUCLEAR EMERGENCY TERMS AND RADIATION FACTS CONTINUED NATURAL BACKGROUND RADIATION IS IN THE AIR WE BREATHE have to be exposed to radiation doses over 20,000 mRem within a day to produce The sun covers our planet with cosmic rad iation. Some rocks and minerals give off small effects measurable by a trained doctor. Very large doses of 50,000 to 100,000 mRem are amounts of radiation. One source you may be fami liar with is radon gas. Many building req uired before you would feel any ill effects.

materials contain radiation. In fact, radioactive partic.les are in the air we breathe, the The amount of exposure from radiation depends on:

food we eat and the water we drink. Even ou r bodies are slightly radioactive. These Length of time you are exposed.

sources of radiation are called natural background rad iation.

How far you are from the source of radiation.

Which part of your body isexposed.

How much material you inhale or take into your body.

Your health or physical condition can affect your reaction to radiation exposure. For Food & water: 40 Building materials: 7 example, you should be aware that unborn babies and very young children are more likely to be harmed by radiat.ion exposure.

WE MAKE AND USE RADIOACTIVE SOURCES EVERY DAY The less radiation you are exposed to, the less chance you have of receiving any harmful Besides naturally occurring radiation, there is also artificial (man-made) radiation. effects. That is why it is so important to have an emergency plan in place near a nuclear Radioactive materials are used in medical and dental X-rays. They are used to help power plant. We need to treat radiation with both caution and common sense.

diagnose and treat diseases such as cancer. Science and ind ustry use radioactive Cook Nuclear Plant workers regularly check radiation levels both inside and outside the materials for research and to do such things as X-ray welds. Other sources of radioactive plant. In the unlikely event of a serious nuclear accident at the plant, state and federal materials are TVs, smoke detectors, some lumi nous-dial watches and clocks. Very small health experts would be called in to take radiation readings beyond the plant site amounts of radiation come from generating electricity with n uclea r power.

boundary. These readings would determi ne what steps, if any, you, your family and co-workers would need to take to p rotect yourselves.

State of Michigan Potassium Iodide Distribution Viewing TV 1 hour/day: 1 Living by the Cook Plant: < 1 Radioactive iodine (radioiodine) is one of the products that could be released in the unlikely event of a serious nuclear power plant accident. Potassium iodide (Kl) is a non-radioactive form of iodine that may be taken to reduce the amount of rad ioactive iodine Types of Radiation absorbed by the body's thyroid gland. Kl offers protection only to the thyroid gland and Radiation includes such things as light, heat and radio waves. However, when we speak its use would be to supplement evacuation and in-place sheltering. Evacuation and in-of radiation we usually mean "ionizing" radiation. This rad iation can produce high- place sheltering are the primary means of protection in a radiological emergency.

energy, charged particles called "ions" in the materials it strikes.

State and county officials will use the Emergency Alert System (EAS) to notify the public THE MAIN TYPES OF ION IZING RADIATION ARE: ofthe need to evacuate, to seek shelter in place, or to take Kl. Kl is available to persons within 10 miles of the Cook Nuclear Plant through the Michigan Department of Health Alpha particles, which can be stopped by a sheet of paper.

and Human Services (MDHHS). Detailed instructions on the MDHHS distribut.ion of Beta particles, which can be stopped by a thin sheet of metal.

Kl can be found on page 21 of this calendar or www.michigan.gov/KI. It is necessary Gamma rays, which can be stopped almost completely by three feet of concrete. to pick up your Kl prior to an emergency situation at the plant. Complete your voucher Neutron particles, which can be stopped by water, concrete and metal. and pick up your Kl at a participating pharmacy at your earliest convenience. You will NOT be able to get Kl f rom the pharmacy during a nuclear plant emergency.

Effects of Radiation People who are allergic to iodine should not use Kl. In the event of an allergic reaction, Just as too much exposu re to the sun can cause painful sunburn, too much exposu re contact a doctor.

to certain levels and types of radiation can have harmful effects. You would, however, Appendix D CEP Rev 47

Page 190 of 226 NOTICE TO FARMERS, FOOD PROCESSORS AND DISTRIBUTORS HOW YOU WILL BE NOTIFIED IN A NUCLEAR EMERGENCY PROTECTING THE FOOD SUPPLY DURING A NUCLEAR EMERGENCY The State of Michigan will evaluate the seriousness of a nuclear accident It will order Following a nuclear emergency, the public could be exposed to radioactive material actions to protect the public and the food supply. in several ways. At first, particles and gases releas.ed into the air could be ingested

If you live w it hin 10 miles of the Cook Nuclea r Plant, your first warning may be or inhaled directly. Additional exposu re could result from eating or drinking food or milk contaminated by traces of radioactive material. Farmers, food processors and an IPAWS Wireless Emergency Alert or a 8-WARN! alert. If you receive an alert, tune distributors will be req uired to take steps to protect the food supply. Every step will be to a radio o r TV station listed on page 3 fo r emergency information.

If you live farther than 10 miles from the plant, you will be notified by area taken to minimize or avoid contamination. Please read this page and the next to learn how to protect the food supply in the event of a n uclear emergency.

radio and TV stations (see page 3). The news report will let you know if you need to take protective action, or a Cooperative Extension Service official will contact SAMPLES WILL BE COLLECTED TO DETERMINE PROTECTIVE ACTION you. Please follow the emergency instruct ions right away. In the event of an accidental release of radioactive material, State of Michigan

IfMichigan you have questions about a rea l or potential emergency, please contact the Department of Agriculture and Rural Development at 800-292-3939 emergency workers will determine what protective steps you will need to take.

Emergency workers will collect samples of ai r, water and soil to see whether there is during business hours (8 a.m.-5 p.m.). After hours, call 517-373-0440. radioactive contamination, where it is located and the amount. Samples of mi lk, forage, crops and processed foods also may be taken. Field data and other factors will be used WHATTO DO IF YOU ARE TOLD TO SEEK SHELTER by the state to determine the best course of action to protect the public and the food During a nuclear emergency, it is very important to limit you r outdoor activit ies as much supply.

as possible. Please stay indoors and follow the instructions provided in radio and TV Samples may be taken from as far away as 50 miles from the plant site. State of messages (see page 3).

Michigan emergency workers will give farmers, food processors and d istributors outside WHATTO DO IF YOU ARE ORDERED TO EVACUATE YOUR FARM of the 10-mile radius of the Cook Nuclear Plant sp ec.ific instructions on how to collect If you live within 10 mi les of the Cook Nuclear Plant, you may be told to evacuate. You and test samples.

maybe permitted, with directions from the state and county, to reenter the evacuated SAMPLES ARE BEING TAKEN NOW TO GIVE US A BASELINE area temporarily to tend to the needs of your farm. You will receive instructions Radioactive materials occu r naturally in the environment. So Indiana Michigan Power on where to check in, what routes to use, safety precautions and decontamination and State of Michigan emergency workers contirnually take samples of the air, water, procedures.

milk, vegetation and animal life near the Cook Nuclear Plant This gives them a "natural" Your Cooperative Extension Service agent can provide animal health and feeding baseli ne for comparison in the event of a nuclear emergency.

guidelines.

HOW TO PROTECT YOUR WATER SUPPLY IN A NUCLEAR EMERGENCY IMPORTANT: Do not delay when notified to evacuate. Instructions on how Store as much water as you can for your livestock. Cover open wells, tanks and other to safely return to care for livestock will be given when it is storage containers. Close off the intakes from contaminated ponds, streams or cisterns.

safe to do so. In general, water from wells and water heaters should be safe to use.

Radioactive contaminants deposited on the ground usually will travel very slowly HOW CAN A NUCLEAR EMERGENCY CONTAMINATE FOOD? into the soil. If contaminants fall onto the surface of lakes and rivers, the radioactive materials may get into the ground water supplies. It takes j ust a few hours for streams During a nuclear emergency, dust-sized, radio.active materials can fall onto fruits, and lakes to carry the contaminants many miles.

vegetables or g rains. This food could enter the food supply and be eaten by the public.

For example: Cows could eat grass covered with radioactive iodine-131. Traces of the iodine could be passed through to the milk and then to people who drink it lodine-131 has the potential to concentrate in the human thyroid gland where it could cause thyroid cancer.

Appendix D CEP Rev 47

Page 191 of 226 NOTICE TO FARMERS, FOOD PROCESSORS AND DISTRIBUTORS CONTINUED HOW TO PROTECT YOUR LIVESTOCK OR POULTRY IN A NUCLEAR EMERGENCY WHO PAYS FOR LOST OR DESTROYED FARM PRODUCTS?

The first priority is to protect dairy animals because radioactive materials can quickly Farmers, food processors and distributors could face serious financial losses following enter the food chain through milk and other dairy products. If sheltering is required, a nuclear emergency. Under federal law, you will be reimbursed for any of these losses.

shelter your dairy animals first. The Price-Anderson Act, enacted by Congress in 1957, requires the operators of nuclear Shelter livestock in covered barns or sheds unless the weather is extremely hot or other power plants and certain other nuclear facilit ies to purchase nuclear liability insurance factors make sheltering impossible. Provide your animals with stored feed such as hay, policies for the protection of the public. As a result, no-fault insurance pools are in place silage and bagged grain. Whenever possible, draw water for y-ou r animals from a well. to pay claims promptly without lengthy court hearings. Claimants need only prove Avoid using water from ponds, rivers and c.reeks. This will help to minimize the amount that the inj ury or property damage resulted from the nuclear emergency. Commercial of radioactive material ingested by you r animals. insurance policies exclude coverage for nuclear emergencies because the Price-Anderson Act makes coverage unnecessary.

Poultry are more resistant to radioactive contamination than other farm animals. Keep them in you r enclosed faci lity and continue to give them stored feed and well water. If WHATTO DO WITH FOOD AND PRODUCTS CONTAMINATED your poultry are normally kept outdoors, bring them inside if possible. IN A NUCLEAR EMERGENCY After an event, there may be additional guidance from government officials on food, IMPORTANT: Do not destroy any animals, crops, milk o r feed supplies fruits and vegetables, feed and animal health.

unless directed by authorities to do so. Crops in the field let your standing crops grow to maturity. The level of radiation exposure they may receive should not affect their g rowth. Most contaminants will be washed off in the DO NOT DESTROY YOUR AN IMALS rain. Or, over time, the crops will return to safe levels as they grow. If special harvesting Destroy you r animals only if you get orders from state or federal authorities. Do not procedures are required, your Cooperative Extension Service agent will give you slaughter any animals except for immediate food needs. Generally, animalsthat are instructions. Government officiaIs may restrict the movement of cropsand agricultural exposed to radioactive contaminants and radioactive rainwater will survive. Many will products and wit hhold them from the marketplace if they are suspected to be be marketable and safe for humans to eat. However, do not al low animals to graze in contaminated, unti l they are assessed to be safe.

open fields unless the State of Michigan, your Cooperative Extension Service agent or another government official gives you permission. Roots and tubers Potatoes, carrots and plants that mature under the ground generally are safe to eat WHATTO DO IF FEED IS RADIOACTIVELY CONTAMINATED Make sure to thoroughly wash and peel these products to remove soil particles and Only in extreme emergencies may you feed your livestock contaminated grain or contaminants.

hay. If you must use the contaminated feed, you may be able to reduce the level of contamination. For example, if the feed is stored outside, the contamination may Fruits and vegetables in the fi eld be g reater at or near the surface of the feed pile. You may be able to reduce the Unprotected plants may have particles of radioactive contamination on their surfaces.

contamination level significantly by removing the top portion. Government officials Before eating them, wash thoroughly. Then brush, sc.rub or peel the outer layers. Some may restrict the movement of feed products and withhold them from the marketplace leafy vegetables may be eaten after you remove the outer layers.

if they are suspected to be contaminated, until they are assessed to be safe. If your crops do not need to be h arvested immed iately; leave them in the field or on the Do not dispose of contaminated feed or hay unless spoilage has made it inedible. trees. They should be able to be harvested once your area is declared safe again.

Generally, contaminated products may be salvageable after adequate time passes and You may lose some ripe fruits and vegetables to spoilage. Contamination levels in your they are properly processed. Please keep contaminated feed supplies separate from area may be too high for field workers to harvest your crop in a timely manner. You other feed so the contamination does not spread. Your Cooperative Extension Service will be reimbursed for crop losses. Government officials may restrict the movement of agent can provide you with specific information. crops and agricultural products and wit hhold them from the marketplace if they are suspected to be contaminated, unti l they are assessed to be safe.

Appendix D CEP Rev 47

Page 192 of 226 Honey and apiary pr oducts In less severe situations, fiber crops may be planted instead of fruits and vegetables.

Following a nuclear emergency; State of Michigan emergency workers will need to take Deep plowing may be used to keep the radioactive contaminants below the root zone samples and analyze honey and beehives in the Protective Action Areas. Contact your until the radioactivity decays to safe levels over time. Liming may also be used to limit Cooperative Extension Service agent for guidance. the absorption of specific radioactive elements by crops.

Fa rm products Farmers will receive guidance from the United States Department of Agriculture's Natural Resources Con servation Service on how to restore valuable soils to productive If radioactive particles or material are present in large amounts, you may be advised use.

not to use, eat or sell garden produce or animal products until samples are taken and analyzed. State of Micihigan emergency workers will conduct the sample tests and WHAT SHOULD FOOD PROCESSORS AND DISTR IBUTORS DO analysis. Please follow their orders to protect the public's and your safety. IN A NUCLEAR EMERGENCY?

Milk After a nuclear emergency, government officials may restrict the movement of Milk contaminated at low levels of iodine-131 may be converted to powdered milk or contaminated food products or withhold them from the marketplace. These products cheese. Then it will be stored until the iodine's radioactivity d iminishes to safe levels. It should not be released until they are considered safe for consumption or a decision is may also be used in animal feed. made to d ispose of them. State of Michigan emergency workers will instruct you on how to safely handle and dispose of contaminated food products.

Wildlife and p lants The envi ronmental damage caused by a nuclear reaction may be short-l ived. Steps can After a nuclear emergency, wild game such as deer, rabbit, squirrel, pheasant and be taken to make a full recovery.

partridge may eat food and water contaminated with rad ioactive particles. State of Michigan emergency workers may advise you not to eat wild game until it has been sampled and assessed to be safe. Wild edible plants, such as native herbs, mushrooms, dandelion greens, spearmint, peppermint or wintergreen may have particles of contamination on their surfaces, too. Before eating, be sure to wash, brush, scrub or peel to minimize contamination. For more information, contact:

HOW SOON WILL THE RADIOACTIVITY REACH SAFE LEVELS? MSU- BERRIEN COUNTY COOPERATIVE EXTENSION S!ERVICE The speed that radioactivity d iminishes depends on several things. Inert gases released 269-944-41 26 from a nuclear power plant lose their radioactivity within minutes. Wind or heavy rain tend to remove radioactive material from plants very quickly. In some cases, however, a 1737 Hillandale Road hard rain after a nuclear emergency may splash contaminated soil onto plant surfaces. Benton Harbor, Ml 49022 This will increase the amount of radioactive material on low-standing plants. www.canr.msu.edu/berrien/

WHAT STEPS CAN BE TAKEN TO RESTORE CONTAMINATED SOI LS?

There are several step:s that can be taken to restore soils contaminated in a nuclear If you have questions about a real or potential emergency, emergency. One is not to use the soil for a period of ti me. In a worst-case situation, you may al so contact:

heavily contaminated soil may need to be removed and sent to an approved radioactive waste disposal facility. Such d rastic action may not be possible for la rge fields, but may MICHIGAN DEPARTMENT OF AGRICULTURE be used for small plots or areas such as walkways near buildings where people come in AND RURAL DEVELOPMENT close contact with it. 800-292-3939 www.michigan.gov/mdard Appendix D CEP Rev 47

Page 193 of 226 Potassium Iodide (Kl) Facts Use the information in this chart to take the correct amount for one dose.

MffDHHS What Is Kl? AGE WEIGHT DOSE Kl (the chemical name for the drug is *potassillll Two (2) 65 mg tablets iodide") is a non-prescription iodine pill. Iodine is 18+ years Any weight Including pregnant or breastfeeding women an element that is found in nature and is also a,1 important part of your diet. Because iodide is S>l 12-18years 150 lbs. or more Two (2) 65 mg tablets important to your health, tt is added to table salt.

12-18years Less than 150 lbs. One (1) 65 mg tablet Potassium iodide (Kl) is available Table salt cannot be used as a replacement for Kl.

at no cost to people who live or How does Kl work? 3-12 years Any weight One (1) 65 mg tablet work within 10 miles of the Cook In the unlikely event of a serious accident at Nuclear Plant in Berrien County, Half (1/2) 65 mg tablet, crushed into a liquid.

a nuctear power plant, one form of radiation, I month-3 years Any weight Instructions forcrushing and mixing will be provided by Michigan. This insert explains radioactive iodine, could be released into the air. the pharmacy and can be found at www.michigangov/ki What Kl is used for and how you This type of radiation can be stored in your thyroid can get it . To get your Kl t ablets, gland. This can cause thyroid cancer or other Quarter (1/4) 65 mg tablet crushed into a liquid.

please read the inf ormation in this thyroid problems over time. Children are most at Birth-I month Any weight Instructions forcrushing and mixing will be provided by calendar, complet e the voucher on risk of thyroid injury from exposure to radioacti*,e the pharmacy and can be found at www.michigangov/ki the next page and take it to one of iodine. Kl protects your thyroid by filling it up the participating pharmacies listed. with a safe fonm of iodine so that it can~ take in Please get your tablets now so you radioactive iodine. You should only take Kl tt the announcements Who should NOT take Kl?

Keeping your thyroid gland healthy is important say that the power plant has declared a ' General You should not take Kl If:

are ready if you are ever asked t o because it produces honmones that manage yo<Jr Emergency," the most serious type of plant take them. You w ill NOT be able to

You are allergic to iodine. A shellfish allergy may heart rate, blood pressure, temperature and other emergency. If you are told to evacuat e and don't get Kl from the pharmacy during a not mean that you are allergic to iodine. Talk to essential body functions. It is important to know have your Kl readily available, don~ waste time nuclear plant emergency. your doctor if you have a shellfish allerg7 and that Kl does not protect your whole body from searching for it. Evacuating or sheltering-in-place are unsure tt you should take Kl.

If you already have Kl tablets from radioactive material - it only protects the thyroid. is the best way to protect yourself from harm due to radiation.

You have dermatitis herpetiformis (DH) or this program, check the expiration How can I get Kl? hypocomplementemic urticaria! vasculit s (HUY) dat e on the box. If it has expired, How much Kl should I take?

Take the enclosed voucher to one of the syndrome, two very rare skin conditions.

go t o one of the pharmacies listed One dose protects the thyroid for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . You oarticioatino Ollarmacies. The oharmacv will oi*,e r.hAr.lc with your l'lnr.tor if you aln:iarty ht1VP. ;:i on the next page to replace your Kl you the amount of Kl that you need. Place it in a should be safely evacuated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . thyroid condition or you are unsure Whether or not w ith a new supply. safe, dry location and keep it in its foil packet. You Taking more than the recommended dose will not to take Kl.

should keep tt on hand as part of your emergency help you and may increase the risk of side effects.

supply kit. Be sure to get your Kl now. You will See the chart above for dose guidelines. How does this program apply to not be able to get it from the phanmaey during a businesses?

The Michigan Department of What side effects could I have from Businesses with more than 200 employees, nuclear power plant emergency. taking Kl?

Heahh and Human Services clients or patients should contact MDHHSto (MDHHS) runs the Kl program. When should I take Kl? Kl can cause minor side effects. You could have arrange for delivery of Kl. If your business Take Kl only If a "General Emergency* has an upset stomach or swelling in your mouth. If you chooses to participate in the program, it is For more information, contact:

been declared at the Cook Nuclear Plant. tt )OU have a serious reaction such as fever, joint pain, responsible for having a dispensing plan ttrat receive an emergency alert, follow the instructions swelling of the face or body or trouble breathing, complies with these instructions. If your b.JSiness Phone: 517-335-8150 get medical help right away.

and tune to your local radio or TV station (see chooses not to participate or has less than 200 (8 a.m. to 5 p.m.) page 3) for more detailed infonmation. Follow the employees, clients, or patients, you can provide Email: mdhhs-ki@michigan.gov instructions given by emergency officials. You may a copy of this fact sheet to your employees to Online: www.m ichigan.gov/ki be instructed to shelter-in-place or evacuate. obtain their personal supply of Kl at one of the designated pharmacies.

Appendix D CEP Rev 47

Page 194 of 226 Read this information before signing the Kl voucher.

2021 Potassium Iodide (Kl) Voucher Signing the voucher means that you understand and agree to the following: By signing this fonm, I agree that I have read the Kl info:rmation provided and that I am obtaining I UNDERSTAND THAT: Kl for people who live or work witllin 10 miles of the Cook Nuclear Plant.

Kl is an over-tile-counter, non-prescription drug. PLEASE COMPLETE SECTION 1 OR 2

Kl is to be tal<en only when a "General Emergency" has been dedared at the Cook Nudear Plant.

Kl is NOT a substitute for evacuation or sheltering-in place.

1. REQUESTING Kl FOR HOUSEHOLDUSE

Kl only protects tile tllyroid gland from radioactive i'odine. It does not protect the rest of the body. NAME:

In a nuclear power plant emergency, tllere could be health risks from otller forms of radiation.

Although taking Kl is usually safe, it can cause problems in people who have thyroid disease or STREET AOORESS:

are allergic to iodine. People who have denmati1is herpetifonmis (DH) or hypocomplementemic urticaria! vasculitis (HUV), two very rare skin diseases, should talk to their doctor before CITY: ZIP:

taking Kl.

COUNTY: PHONE:(

I AGREE THAT:

I have read the potassium iodide (Kl) fact sheet and will follow all instructions on how to use Kl. NUMBER Of PEOPLE LIVING ATTHIS AOORESS:

I will follow tile instructions of emergency officials. AGES Of PEOPLE LIVINGATTHISAOORESS:

I will hold tile phanmacy hanmless from all liability, claims, suits or actions related to the use, delivery, labeling and packaging of Kl.

2. REQUESTING Kl FOR BUSINESS USE Additional agreements for businesses

I own or represent the business/institution named on the voucher. NAME Of BUSlllE5S:

This business/institution will provide information on dosing and medical contraindications to all CONTACT NAME:

employees/clients prior to distributing Kl. This information is provided in each box of Kl and on the MO HHS website at www.michigan.gov/ki. STREET AOORESS:

To qualify to receive Kl tablets for your household or business, you must:

CITY: ZIP:

live or work within 10 miles of tile Cook Nudear Plant.

Be 18 years or older. COUNTY: PHONE:(

Present a government-issued photo ID.

NUMBER Of EMPLOYEES/PATIENTS/RESIDENTS/CLIENTSATTHISkDORESS:

SIGNATURE: DATE:

Participating Pharmacies YOU MAY PICK UP YOUR Kl TABLETS AT THE FOLLOWING PHARMACIES: PHARMACY USE ONLY

MelJer Pharmacy 1920 Pipestone Rd., Benton Harbor, Ml IOF BOXES DATE DISPENSED: LOH : DISPENSED:

MelJer Pharmacy 5019 Red Arrow Hwy., Stevensvllle, Ml PHARMACY

MelJer Pharmacy 5150 s. Franklin St., Michigan City, IN NAME: PHARMACY I:

MelJer Pharmacy 1223 Phoenix st., south Haven, Ml CITY:

Appendix D CEP Rev 47

Page 195 of 226 APPENDIX E DESCRIPTION OF FEDERAL RADIOLOGICAL ASSISTANCE Appendix E CEP Rev 47

Page 196 of 226 FEDERAL RADIOLOGICAL ASSISTANCE DESCRIPTION I. Introduction This document summarizes the DOE radiological assistance capabilities that can be provided to the Donald C. Cook Nuclear Plant (CNP).

Section II describes typical capabilities and expected mobilization and travel times for some of the Region 5 of the DOEs radiological assistance program.

Section III describes additional DOE capabilities that can be activated dependent on the assistance needed and how it is activated.

Based on its extensive capabilities, the Chicago Operations Office (CH) will augment the resources of CNP. CH typical capabilities and mobilization and travel times are based on discussions with the CH Regional Coordinating Office representative on the Region 5 Radiological Assistance Plan (Reference 1).

The mobilization time, which is defined as the time required to load equipment and initiate travel, is usually about one hour. Travel times in this attachment are specific to CNP and pertain to arrival at some appropriate location near the station. These are best estimate mobilization and travel based on a normal situation.

II. Region 5 Typical Capabilities and Mobilization and Travel Times The DOE radiological assistance resources are drawn from the major DOE contractor laboratories and facilities. The personnel involved with these response have routine radiological-related duties on a daily basis at leading nuclear facilities thereby ensuring not only continuing experience and training, but also providing the conditions for keeping equipment operable and calibrated.

The Radiological Assistance Plan (RAP) provides assistance only. Although this is a federal government agency with highly developed expertise, this agency will not assume the responsibility of the Utility or State for protection of the health and welfare of Michigan citizens and plant personnel. CNP would request DOE-RAP assistance only if it was determined that the plant radiological resources needed augmentation. If requested, a RAP representative from the CH will report to the plant/EOF and the CNP ERO in accident assessment and radiological exposure control function. CH can provide support to CNP to accomplish the following goals:

Alpha, beta, gamma radiation surveys Radiation monitoring of air, food, water, milk, and personnel Gamma spectrometry and radionuclide identification of air, food, water, milk, soil and vegetation Airborne radioiodine sampling and analysis of concentrations as low as 5E-07 Ci/cc Radiological control advice Laboratory analysis Mobile laboratories Communications Appendix E CEP Rev 47

Page 197 of 226 Mobile laboratories from RAP contain high and low-range alpha, beta, and gamma radiation survey equipment as well as alpha-gamma spectrometry analysis equipment.

Estimated times of arrival for the CH resources within the region will vary depending on where the resources are drawn from. The number of personnel and equipment dispatched will also vary depending on the accident conditions and the requests presented by the Utility and/or State.

Table F-1 lists the DOE manpower located at Argonne National Laboratory (ANL) that could be provided in response to an incident. The table also provides an estimate for time of arrival to CNP area assuming a half hour to a 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months assemble or mobilization time.

It should be noted that ANL team is a major team and therefore has a larger spectrum of monitoring equipment and number of personnel to respond to an accident. The available resources include a mobile laboratory equipped with a multichannel analyzer. The other teams listed in the table would complement this ANL resource capability.

All of the above resources can be activated with one phone call to CH. That phone number is given in Appendix H. If the call comes in to the off-hours duty officer, arrangements will be made for 3-way communication or re contact with a radiological expert. The phone call may be made from the Technical Support Center by the Radiological Assessment Coordinator (RAC). The RAC would be able to describe the suspected radiological consequences of the accident and the resources and assistance which might be required of DOE RAP.

III. Additional DOE RAP Capabilities Specialized and unique resources exist for various other DOE activities. These resources can be activated and mobilized when needed. Included in this capability are resources available throughout all the other DOE radiological assistance regions as well as the resources of the Nuclear Emergency Search Team (NEST), Aerial Measuring System (AMS), and the Atmospheric Release Advisory Capability (ARAC).

Response Equipment The DOE response network is organized to include the deployment of those personnel and equipment that are immediately required. If the situation is of major proportion, equipment in the following categories may be needed and available.

Airborne Systems Helicopters and fixed-wing aircraft are equipped with gamma and neutron detection equipment. Gamma spectral data is recorded with position information derived from measurements of several exposure rates and principal isotope identification on the ground. This is plotted as isopleths on maps or aerial photographs for immediate use by the responsible authorities.

Aerial photography is performed with large format cameras. A twelve channel Daedalus Scanner is available for very sensitive thermal mapping, assessment applications or similar diagnostic.

Appendix E CEP Rev 47

Page 198 of 226 Standard Health Physics Instruments Packages of standard health physics instruments are available with current calibrations.

Team scientists select the appropriate instruments for the predominant isotopes. A TLD reader and 250 TLDs are included. A variety of alarming dosimeters are carried by personnel working close to the incident site. Also, included are air samplers, portable counting equipment, battery powered analyzers, and source handling equipment. Anti-contamination clothing and breathing apparatus are also available.

Communications An extensive communications system is deployed with the special team. A memorandum of understanding between DOE at AT&T assures rapid telephone response for the communications system connection. The switching hardware for a twelve line telephone system and radios for HF and VHF transmissions are installed in an airline cargo pod. In addition, the system contains a portable microwave system to provide video, data, audio, telephone, and control communication between a field command post and an incident site which may be up to 50 miles apart. Telephone with HF backup is the primary longer distance communication system. On-scene communication is assured with VHF radio, repeaters and pagers. Included in the communication array are all the basic support elements to establish a field command post.

This includes typewriters, telecopiers, copy machines, status boards, etc. All of the equipment and systems described above are packaged for deployment within two hours of a request. Existing airlift agreements between DOE and the Military Airlift Command assure rapid response. Most of the equipment can also be flown on commercial wide-body aircraft and trucked the final distance to a site if time so dictates.

Backup Support There are many specialized systems located throughout DOE National Laboratories which could be made available for specialized needs or extreme emergency situations. The members of the special DOE field team and the DOE Headquarters Emergency Action Coordinating Team are prepared to locate special equipment, arrange transportation and logistically support the equipment on site if risk to the public and national priorities so require.

ARAC The ARAC system located at LLL, is a system for computer based atmospheric modeling system which is real-time linked to the National Weather Service and the USAF Global Weather System. To insure accurate modeling for small areas around a fixed site meteorological data from the site is required. In addition, topographic data is added for the site environs. Many calculational models are available to the field team. Source terms may be discrete (explosion), continuous plume, or patterns if particulates are present. Software is available to make dose assessments and to accumulate these if the release is continuing over a period of time. ARAC can also predict plume patterns which may be extremely valuable for evacuation planning, locations where air monitoring should be emphasized, or planning releases which are under limited control. Finally, aerial teams can continuously compare and update ARAC data with actual in-plume measurements to assist in improving source term estimates. Communication with ARAC is via telecopier.

Because of its relatively long deployment time of approximately 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , ARAC could only be sued as a backup to offsite dose projection calculations done by the utility state and local agencies.

Appendix E CEP Rev 47

Page 199 of 226 The request for the above resources is made to CH who will request their activation by calling the DOE Headquarters at the Emergency Operation Center in Germantown, Maryland.

If CH decides resources other than those within DOE RAP, are needed, CH would activate the appropriate Federal agencies within the Interagency Radiological Assistance Program by calling the appropriate agency, or agencies, directly.

Additional Monitoring Teams Ames, Iowa Miamisburg, Ohio Cincinnati, Ohio Monitoring teams from the above locations are available for assistance. Deployment time is eight (8) hours or longer.

Appendix E CEP Rev 47

Page 200 of 226 Resource Information Required by RAP A. Command Centers State of Michigan State of Michigan EOC 7150 Harris Drive Dimondale, MI 48821 517-284-3862 Field Team Center Michigan Department of Transportation Coloma Garage Red Arrow Highway Benton Harbor, MI 49022 269-840-2811 Berrien County BC EOC 2100 East Empire Ave.

Benton Harbor, MI 49022 269-934-9023 Donald C. Cook Nuclear Plant Emergency Operations Facility 500 Circle Drive Buchanan, MI 49107 B. Nearest Airport Primary - Benton Harbor Southwest Michigan Regional Airport Telephone: 269-927-3194 Frequency: Standard FAA frequency Services: Fixed Base Operator; AVGAS and Jet A fuel available; Major engine and repair capability Tower Hours of Operation: Tower closed; South Bend controls Alternate - South Bend Michiana Regional Airport Telephone: 574-233-2185 Frequency: Standard FAA frequency Services: Refueling: 2 fixed based operators; AVGAS and Jet A fuel available; Major engine and avionics repair capability Tower Hours of Operation: 7:00 am to midnight C. Lodging Holiday Inn Express - Benton Harbor 269-927-4599 Ramada Inn - Benton Harbor 269-927-1172 Courtyard by Marriott - Benton Harbor 269-925-3000 D. Transportation Avis 269-926-2151 E. Police Escorts If required Coordinate requirement with County and/or State Police Appendix E CEP Rev 47

Page 201 of 226 F. Police Vehicles for Communication Augmentation Coordinate specific requirements and request with Berrien County and/or State Police as available.

State Police Frequency 800 MHz County Sheriff 800 MHz G. Travel Routes (From Chicago Operations Office)

Take I-294 South for 23.0 miles At I-80 Toll Exit 160B, continue (east) on I-294 [I-80] for 0.6 mile Continue (East) on I-80/I-94 for 52 miles At I-94 Exit 4, turn Right (East) onto US-12 for 18.2 miles toward Niles At Red Bud Trail turn Left (North) onto Red Bud Trail for about 2 miles to Elizabeth Street.

At Buchanan, turn Left (West) onto Elizabeth Street for 1/4 mile to 500 Circle Drive H. Medical Facility Location Spectrum Health Lakeland Medical 1234 Napier Avenue Center Saint Joseph, MI 269-983-8300 Spectrum Health Lakeland Niles 3100 N. St. Joseph Hospital Niles, MI 269-683-5510 I. Maps of Sampling Points Provide as required.

REFERENCES

1. Radiological Assistant Plan - Region 5, August 25, 1978, U.S. Department of Energy, Chicago Operations Office, Argonne, Illinois.

Appendix E CEP Rev 47

Page 202 of 226 DOE Radiological Assistance Laboratories at ANL Mobilization**

Number of Radiologically And travel time to Laboratory Location trained persons for first the CNP Area response Hours Argonne National Lab Argonne, Illinois

a. Response by private charter 5-6* 3 aircraft

b. Mobile Laboratory 5-6** 4

This number includes one or two DOE personnel to coordinate the Federal radiological monitoring effort with the Utility and/or State.

- This includes 30-90 minutes mobilization time based on motor vehicle/land transportation under ideal weather and traffic conditions.

Appendix E CEP Rev 47

Page 203 of 226 APPENDIX F BERRIEN COUNTY ROAD MAP Appendix F CEP Rev 47

Page 204 of 226 Berrien County Geographical Information System (GIS)

Follow web browser link:

https://www.berriencounty.org/406/Municipality-Maps Appendix F CEP Rev 47

Page 205 of 226 APPENDIX G POPULATION DISTRIBUTION Appendix G CEP Rev 47

Page 206 of 226 2010 POPULATION DISTRIBUTION Sector Direction 0-10 Miles A N 0 B NNE 12,425 C NE 26,677 D ENE 5,852 E E 7,674 F ESE 4,728 G SE 1,485 H SSE 2,418 J S 3,340 K SSW 2,993 L SW 266 M WSW 0 N W 0 P WNW 0 Q NW 0 R NNW 0 Total 67,858 Appendix G CEP Rev 47

Page 207 of 226 APPENDIX H RADIOLOGICAL RESPONSE SUPPORT SERVICES CAPABILITIES Appendix H CEP Rev 47

Page 208 of 226 ARGONNE LABORATORY (DOE)

The following is a description of resources available from the Department of Energy (DOE) per the regional implementation of DOE Radiological Assistance Program (RAP). This description of available resources is taken from the DOE Region V Radiological Assistance Plan,Section III, dated January 1984. This description of available resources is consistent with the DOE Letter of Agreement found in Appendix B to the Donald C. Cook Plan.

DOE Region V radiological assistance resources are drawn from the major DOE contractor laboratories and facilities located in the geographical region. The personnel involved with these responses have routine radiological related duties on a daily basis at leading nuclear facilities, thereby, ensuring not only continuing experience and training, but also providing the conditions for keeping state-of-the-art equipment operable and calibrated. It should be noted that Argonne National Laboratories is a major resource and, therefore, has a larger spectrum of monitoring equipment and personnel for emergency response than the other laboratories in the region.

DOE provides assistance only. Although this is a Federal agency with highly developed expertise, this agency will not assume the responsibility of the utility, the State, or local resource group for protection of the health and welfare of the local population and nuclear station personnel. A request for DOE assistance would be made only if it was concluded that utility and State radiological resources needed augmentation. If requested, a RAP representative from DOE Chicago Operations Office (CH) will report to the utilitys emergency operations facility (EOF) and/or the State EOC and assist the emergency organization in the accident assessment and radiological exposure control functions. CH can provide support to accomplish the following goals:

Alpha, beta, and gamma radiation surveys; Radiation monitoring of air, food, water, milk, and personnel; Gamma spectrometry and radionuclide identification of air, food, water, milk, soil, and vegetation samples; Airborne radioiodine sampling and analysis of concentrations as low as 1E-08 microcuries per cubic centimeter; Radiological control advice; Laboratory analysis; Mobile laboratories; and Communications Mobile laboratories from CH contain high and low range alpha, beta, and gamma radiation survey equipment as well as sodium iodine scintillation spectrometry analysis equipment.

Estimated times of arrival for the CH resources within the region will vary depending on where the resources are drawn from. The number of personnel and equipment dispatched will also vary depending on the accident conditions and the nature of the request.

The request for any of the DOE resources listed in this section can be activated by a single incoming telephone call. Once the CH Duty Officer receives the request for assistance, he will make the necessary calls to activate the specific resources requested. That incoming number is (630) 252-4800 (24 hrs.).

Appendix H CEP Rev 47

Page 209 of 226 APPENDIX I NOTIFICATION OF AMERICAN NUCLEAR INSURERS Appendix I CEP Rev 47

Page 210 of 226 NUCLEAR EMERGENCIES ANI/MAELU EMERGENCY ASSISTANCE (GENERAL)

The provisions of the Price-Anderson Law facilitate ANI and MAELU (the pools) providing prompt assistance to members of the public who may be adversely affected in the event a nuclear incident were to occur at an ANI/MAELU/NRC indemnified facility. This arrangement is intended to alleviate the immediate financial burden which may be incurred by members of the public due, for example, to evacuation and relocation activities initiated as a consequence of a nuclear occurrence.

In providing emergency assistance to members of the public, the pools will promptly dispatch their representatives to commence the distribution of emergency assistance funds.

ANI/MAELU EMERGENCY ASSISTANCE (CLAIMS HANDLING PROCEDURES)

The pools emergency assistance arrangements contemplate the mobilization and dispatch of emergency claims teams to directly dispense emergency assistance funds to affected members of the public.

Following notification of a nuclear incident potentially involving bodily injury, evacuation of offsite personnel or damage to offsite property, the ANI staff will alert claims personnel of member companies. The information provided to us by the insured will be utilized to recommend appropriate emergency response actions. If the magnitude of the incident requires immediate financial assistance to members of the general population, pool representatives will be directed to establish an emergency assistance office at a convenient location. It is contemplated that establishment of such an office would be coordinated with the insured and local or state government authorities.

Applicants for emergency assistance will be required to fill out a simple form giving their name, address, and names of additional persons to be assisted. The application contains two basic provisions:

1. That the disbursement of emergency assistance funds does not constitute an admission of liability on the part of the insured; and

2. That the acceptance of emergency funds does not constitute a release on the part of the applicant.

The procedures outlined above are specifically directed towards immediate payment to members of the public for out-of pocket transportation, living and other reasonable expenses incurred shortly after a nuclear incident. Subsequent to such immediate relief being provided, the pools will service bodily injury and property damage claims which may be presented. Should the incident be declared an extraordinary nuclear occurrence by the NRC, virtually all legal defenses are waived by the insured and the pools which makes adjusting the claims much simpler.

CRITERIA FOR EMERGENCY NOTIFICATION Under what circumstances should the pools be notified in order to activate the type of emergency assistance response described above?

Appendix I CEP Rev 47

Page 211 of 226 Condition 5, Notice of Occurrence, Claim or Suit, of the Nuclear Energy Liability Policy (facility form) delineates the notification commitment of the insured to the insurer; however, the provisions of Condition 5 do not specifically describe the type of immediate financial assistance discussed above. Almost by definition, emergency financial assistance must be provided in a timely fashion.

Timely assistance of course, implies timely notification:

The pools should be notified in the event of a nuclear emergency requiring notification of State or Federal governmental agencies, or if the insured believes that offsite persons may be affected and financial assistance of a nature discussed (under Emergency Assistance above) may be required. In these instances we would expect notification as soon as possible after the initiation of the emergency.

Recent efforts by the Nuclear Regulatory Commission have led to the standardization of the system used by power reactor licensees to categorize emergencies as published in NUREG 0654

, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans Other types of nuclear facilities are using similar terms to describe emergency conditions which could develop at their sites. To be consistent with industry classification systems, the insureds emergency plans and/or emergency plan implementing procedures should be written to require notification of the pools in the event of an ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY as soon as possible. Even if it appears to be remote that offsite persons will be affected, the pool should be notified in order that response plans can be initiated to the point of alerting teams of adjusters to stand by. Response activity can be discontinued if it proves less severe and does not require pool response.

Naturally, all nuclear occurrences of an emergency or non-emergency nature which may fall under the nuclear liability policy should be reported formally in writing as specified in Condition 5 of the facility form policy.

EMERGENCY NOTIFICATION AND FOLLOW-UP PROCEDURES In the event of an emergency, it is important to establish clear lines of communication between your facility and ANI in order to exchange all required information during a developing emergency situation.

ANI maintains 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months coverage of our emergency notification number. This number is 860-682-1301. During normal office hours (8:00 am - 4:00 p.m.) this number will be answered by our receptionist who will transfer an incoming emergency call to an appropriate individual in the office.

Outside of normal office hours this phone line is covered by an automated phone answering service. The answering service can be used to leave a message, including the affiliation and phone number of the caller. A designated ANI staff will in turn call back the facility to obtain appropriate information regarding the nuclear accident.

The TMI incident, as well as other incidents, clearly demonstrated the need for follow-up communication since the information transmitted in the initial notification may be incomplete. As discussed above, an important purpose of emergency notification to the pools is to allow them to gauge financial assistance to member of the public as they did during the TMI incident.

Additionally, members companies with assets at risk require accurate and timely information from the ANI staff when nuclear incidents occur, whether or not such incidents ultimately lead to the actuation of emergency financial assistance by the pools. In order to carry out these mandated responsibilities, it is essential that ANI receive up-to-date information from reliable technical sources regarding radioactive releases from the site, plant status, and impending protective action for members of the public.

Appendix I CEP Rev 47

Page 212 of 226 FIGURE14 FIGURE 13 ACCIDENT NOTIFICATION PROCEDURES FOR ANI INSURERS THE FACILITY'S COMMUNICATIONS DUTY OFFICER-EACH SHIFT

NUCLEAR or

- NON-NUCLEAR ACCIDENT 860-682-1301 AMERICAN NUCLEAR ANI HOME OFFICE INSURERS FARMINGTON, CT NOTIFICATION NOTES :

--- 24 HOUR TELEPHONE COVERAGE PROVIDED FOR IMMEDIATE NOTIFICATION AND OTHER SERIOUS ACCIDENTS .

--- IN ADDITION TO NOTIFICATION TO ANI , PROMPTLY NOTIFY YOUR COMPANY'S INSURANCE DEPARTMENT.

NUCLEAR

--- NOTIFY ANI AS SOON AS POSSIBLE AFTER DECLARATION OF A NUCLEAR ALERT , SITE AREA EMERGENCY,OR GENERAL EMERGENCY.

--- REFER TO ANI INFORMATION BULLETIN 5A (81) FOR DESCRIPTION OF EMERGENCY CLAIMS ASSISTANCE AND ACCIDENT REPORTING INFORMATION REQUIREMENTS .

- NON-NUCLEAR

--- REFER TO ANI INFORMATION BULLETIN 5A (81). NOTIFY ANI IMMEDIATELY IN THE EVENT OF A SERIOUS ACCIDENT INVOLVING FIRE , LIGHTING, EXPLOSION, OPERATION OF FIXED FIRE PROTECTION EQUIPMENT , WINDSTORM, VEHICULAR DAMAGE TO PLANT , DROPPING OF EQUIPMENT, EMERGENCY OR UNPLANNED IMPAIRMENT TO FIRE PROTECTION EQUIPMENT, ETC., AND SERIOUS ACCIDENTS THAT INVOLVE ELECTRICAL AND MECHANICAL EQUIPMENT AND PRESSURE SYSTEMS COMPONENTS .

--- REPORT ALL PROPERTY ACCIDENTS REGARDLESS OF DEDUCTIBLE . TRIVIAL ACCIDENTS NEED ONLY BE REPORTED TO YOUR COMPANY 'S INSURANCE DEPARTMENT FOR PROMPT WRITTEN NOTIFICATION OF ANI VIA AGENT /BROKER.

Page 1 of 1 Revision 30 Appendix I Appendix I CEP Rev 47

Page 213 of 226 APPENDIX J EIGHT YEAR PLAN MATRIX Appendix J CEP Rev 47

Page 214 of 226 EIGHT YEAR PLAN FOR EMERGENCY PREPAREDNESS ACTIVITIES Eight Year Items 2021 2022 2023 2024 2025 2026 2027 2028

1. Exercise with full State and County participation involving the ingestion X exposure pathway.

2. Exercise with State and County participation X X X X (HAB)

3. Exercise with full State and County participation X

4. Biennial Evaluated Exercise X X X X (HAB)

5. Annual Exercise (Satisfied by Biennial Evaluated Exercise) X X X X Notes: The plan presented above ensures compliance with both the NRC and FEMA periodic exercise requirements Annual Items

1. Annual Exercise (Performance date dependent on outside agency schedule) 1a. Train controllers/evaluators 1b. Conduct the exercise

2. Annual Media Mailing

3. Review Emergency Action Levels with State and County authorities

4. Verify dates of letter of agreement in the Emergency Plan

5. Review documentation to ensure Emergency Response Organization personnel have received required training in the past year.

6. Test of communications between Cook Plant, State and County EOCs and Field Assessment Teams.

7. Review of Emergency Preparedness Program pursuant to 10 CFR 50.54(t) (PA Audit)

8. Letter to State and County making interface evaluation portion of 50.54(t) review available

9. Distribution of Emergency Preparedness Public Information Brochure

10. Fire drill with off-site support participation (conducted per Fire Protection Program Manual (FPPM))

11. Training for plant, hospital, and ambulance personnel on the handling and treatment of contaminated/injured personnel

12. Medical emergency drill involving a contaminated individual (Performance date dependent on outside agency schedule)

Radiological Monitoring Drill (both on-site and off-site). Drill to include collection and analysis of water, vegetation, soil and air 13.

samples. Coordinated with the annual exercise.

14. Annually validate the reliability / availability of IPAWS The scheduling for the performance of annual items is dependent on the outside agency schedule.

Appendix J CEP Rev 47

Page 215 of 226 EIGHT YEAR PLAN FOR EMERGENCY PREPAREDNESS ACTIVITIES Semi-Annual Items

1. Semi-annual backshift augmentation drill*

Semi-annual Radiological Monitoring and Health Physics Drills involving the response to and analysis of simulated airborne and 2.

liquid samples and direct radiation measurements in the environment.*

Quarterly Items**

1. Verification of plant personnel Notification Telephone Numbers

2. Verification of Initial Notification Telephone Numbers

3. Fire Emergency Drill

4. Operability checks, per Radiation Protection Procedures

5. Inventories Monthly Items

1. State and County EC (within EPZ) communication tests

2. NRC Headquarters and Regional office communications test (CR, TSC, EOF)

The semi-annual items are conducted during any month January through June and any month during July through December.

- The quarterly items are conducted during any month within the quarter.

Appendix J CEP Rev 47

Page 216 of 226 APPENDIX K AGREEMENTS WITH OFFSITE AGENCIES FOR HAZARDOUS MATERIALS SPILLS Appendix K CEP Rev 47

Page 217 of 226 APPENDIX K Agreements With Offsite Agencies For Hazardous Materials Spills

1. Berrien County Emergency Management 1 page January 5, 2018

2. Lakeland Regional Health System 1 page January 18, 2018 Appendix K CEP Rev 47

Page 218 of 226 Berrien County Emergency Management BERRIEN COUNTY EMERGENCY MANAGEMENT DIVISION OF BERRIEN COUNTY SHERIFF'S OFFICE JON HINKELMAN 2100 E. Empire Avenue, Benton Harbor, Michigan 49022 CHAIRMAN BOARD OF COMMlSSIONERS Telephone (269) 983-7141

Fax: (269) 983-5726 L. PAUL BAILEY SHERIFF CAPT. ROCKEY ADAMS COORDINATOR 1/5/2018 Mr. Ronald J. Sieber Cook Nuclear Plant One Cook Place Bridgman, Ml 49106

Dear Mr. Sieber:

We wish to reaffirm the willingness of the Berrien County Sheriff's Department to respond upon request to any emergency which could occur at the D.C. Cook facility. Berrien County Emergency Management/Office of Homeland Security has the obligation to respond upon notification that an emergency exists. Berrien County will implement their Nuclear Accident ProcecLures (Appendix 1) of the Emergency Operations Plan and take appropriate actions as outlined therein.

In addition, the Sheriff's Department has basic patrol and investigative services and currently has a fourteen member Hazardous Materials Response Team who are trained to Technician Level. Four of the fourteen Haz-Mat team members are cross-trained as bomb technicians, and of whom have successfully completed the FBI Hazardous Device School at Redstone Arsenal in Redstone, Alabama. Our Tactical Unit consists of 20 personnel who conduct training monthly.

The Berrien County Sheriff's Department will be available to you upon request, in any area within the jurisdiction of this agency.

Sincerely, 1~~

Sheriff/Director, Emergency Management Appendix K CEP Rev 47

Page 219 of 226 Lakeland Regional Health System

~ Lakeland Health January 18, 2018 Mr. Joel Gebbie Sr. Vice President & ChiefNuclear Officer Cook Nuclear Plant One Cook Place Bridgman, MI 49106

Dear Mr. Gebbie:

This letter is to confirm that Lakeland Health remains able to provide care for the injured radioactively-contaminated patients at the St. Joseph and Niles Emergency Department sites.

This would include Donald C. Cook personnel exposed on-site and members oftbe public exposed off-site who may require services.

Mutually agreed upon annual training and drills will be conducted to assure staff competency in caring for this patient population, with evaluation by FEMA when required. A policy and procedure manual is avail.able at each site and updated regularly to incorporate changes in patient management. An identified Radiation Emergency Area (REA) is available at each site that allows for stabilization, treatment, and management oftbe radioactive component of the emergency. I understand that the training for hospital personnel, equipment, and stocking of the disaster cart will continue to be provided by Donald C. Cook Nuclear Plant.

This agreement shall remain in effect from the date of signing until either party, upon ninety (90) days prior written notice to the other party, terminates the agreement.

~ \

Please contact Kathy Effa, Manager of Emergency Services, at 269.983.8670 for any assistance that you require.

0

/

-~ cerely, _

/ ~

/ '- I I .,

.* 1/> ' .

L..,...--Loren B. Hamel, MD President & CEO Lakeland Health LBJ-I: sci Legal Review Completed I

J..i A-P I l 1'8 I '<a 1234 Napier Avenue , St . Joseph , Ml 49085 ( 269 ) 983 - 8300 www . I a ke I and h ea Ith . o rg Appendix K CEP Rev 47

Page 220 of 226 REVISION

SUMMARY

Procedure No.: CEP Rev. No.: 047

Title:

D.C. COOK NUCLEAR PLANT EMERGENCY PLAN Alteration Justification The Cook Emergency Plan is wholly controlled under 10 CFR 50.54(q) and plant procedure RMA-2080-EPA-008, Emergency Plan Management, therefore a 50.59 review is not required.

10 CFR 50.54(q) # 22-33 was performed on the proposed changes.

Page 17, A.1.b. GT 2022-1322 - 1 FROM Globally Revised from JIC activation to The ENC becomes the JIC when the State of JIC operational.

Michigan declares the JIC activated.

TO Changed to align with the terminology that The ENC becomes the JIC when the State of the State of Michigan uses to describe the Michigan declares the JIC operational. JIC at their request.

This meets editorial correction criteria per PMP-2010-PRC-002, Figure 5, Editorial Correction Criteria, Item (g) rewording which clearly does not change the methodology or intent of the step.

Page 34, B.5.d.1. GT 2022-1322 - 1 FROM Globally Revised from JIC activation to Ensure press releases are prepared and issued JIC operational.

prior to JIC activation TO Changed to align with the terminology that Ensure press releases are prepared and issued the State of Michigan uses to describe the prior to the JIC becoming operational JIC at their request.

This meets editorial correction criteria per PMP-2010-PRC-002, Figure 5, Editorial Correction Criteria, Item (g) rewording which clearly does not change the methodology or intent of the step.

CEP Rev 47

Page 221 of 226 Alteration Justification Page 35, B.5.d.3 GT 2022-1322 - 1 FROM Globally Revised from JIC activation to Ensure press releases are prepared and issued JIC operational.

prior to JIC activation TO Changed to align with the terminology that Ensure press releases are prepared and issued the State of Michigan uses to describe the prior to the JIC becoming operational JIC at their request.

This meets editorial correction criteria per PMP-2010-PRC-002, Figure 5, Editorial Correction Criteria, Item (g) rewording which clearly does not change the methodology or intent of the step.

Page 64, SU8.1 AR 2022-1094 - 2 Planning Standard D FROM Containment pressure > 2.8 psig with < one full Editorial correction.

train of containment depressurization equipment operating per design for ³ 15 min. This meets editorial correction criteria per TO PMP-2010-PRC-002, Figure 5, Editorial Containment pressure > 2.8 psig with < one full Correction Criteria, Item (g) obvious train of containment depressurization equipment incorrect symbol. The symbol is correct in operating per design for 15 min. other locations.

Page 66, RU1.2 AR 2022-1094 - 2 Planning Standard D FROM Sample analysis for a gaseous or liquid release Editorial correction.

indicates a concentration or release rate > 2 x ODCM limits for ³ 60 min. (Notes 1, 2) This meets editorial correction criteria per TO PMP-2010-PRC-002, Figure 5, Editorial Sample analysis for a gaseous or liquid release Correction Criteria, Item (g) obvious indicates a concentration or release rate > 2 x incorrect symbol. The symbol is correct in ODCM limits for 60 min. (Notes 1, 2) other locations.

Page 80, E.2.a GT 2021-6824 - 1 Planning Standard E FROM An announcement over the Plant Public Address Editorial correction. (pluralized System (PA) at the switchyard. switchyards)

TO An announcement over the Plant Public Address This meets editorial correction criteria per System (PA) at the switchyards. PMP-2010-PRC-002, Figure 5, Editorial Correction Criteria, Item (a) Grammar Correction CEP Rev 47

Page 222 of 226 Alteration Justification Page 83, E.7. GT 2022-1322 - 1 FROM Globally Revised from JIC activation to JIC (when activated) JIC operational.

TO JIC (when operational). Changed to align with the terminology that the State of Michigan uses to describe the JIC at their request.

This meets editorial correction criteria per PMP-2010-PRC-002, Figure 5, Editorial Correction Criteria, Item (g) rewording which clearly does not change the methodology or intent of the step.

Page 95, G.4.a GT 2022-1322 - 1 FROM Globally Revised from JIC activation to The ENC/JIC does not become a Joint JIC operational.

Information Center until after the declaration of a Site Area Emergency and when a representative Changed to align with the terminology that from the state is present and declares the JIC the State of Michigan uses to describe the activated. JIC at their request.

TO The ENC/JIC does not become a Joint This meets editorial correction criteria per Information Center until after the declaration of PMP-2010-PRC-002, Figure 5, Editorial a Site Area Emergency and when a representative Correction Criteria, Item (g) rewording from the state is present and declares the JIC which clearly does not change the operational. methodology or intent of the step.

Page 111, Map Map of Emergency Response Centers Updated the map of Emergency Response did not include the location of the OSC.

Centers to include the location of the OSC.

Page 120, J.3 GT 2021-6606 - 1 Planning Standard J FROM Suitable equipment intended for such personnel Remove Anti-Cs from Training Center monitoring stations will be stored in both the OSC and the Training Center. Moved the Emergency equipment from TO the Training Center to the Survey Vehicle Suitable equipment intended for such personnel as Evaluated in 50.54(q) #21-03, and monitoring stations will be stored in the OSC and approved in PORC 4835 Survey Vehicles.

CEP Rev 47

Page 223 of 226 Alteration Justification Page 132, L.1 GT 2021-6325 - 1 Planning Standard L 1st & 3rd Paragraph FROM Updated hospital names.

Lakeland Regional Medical Center, Saint Joseph TO This meets editorial correction criteria per Spectrum Health Lakeland Medical Center PMP-2010-PRC-002, Figure 5, Editorial 2nd Paragraph Correction Criteria, Item (d)

FROM Organizational Changes.

Niles Community Hospital, Niles TO Spectrum Health Lakeland Niles Hospital Page 143, O.4.i AR 2022-1317 - 4 Planning Standard - O FROM O.4.i. Licensee Headquarters Support Described AEP Headquarters Support Not addressed. Training, Reference TPD-600-EPT, TO Emergency Preparedness Training O.4.i. Licensee Headquarters Support Program Description & RMT-2080-EPP-AEPs Enterprise Resilience organization 500, Emergency Plan Drills and Exercises maintains an Emergency Management plan that outlines roles, responsibilities and organization to support D.C. Cook during an emergency. This plan is governed by the Enterprise Resilience Policy and appropriate subsequent Standards. A training activity, which includes integration of this AEP Emergency Management plan with D.C. Cooks Emergency Plan, will occur at least once during the eight year drill and exercise cycle.

Page 146, P.3 Added a description of the Emergency FROM Not Addressed Planning Coordinator Designation to TO Planning Standard P.3. This change adds The Emergency Preparedness Coordinator information that was not previously position has the responsibility for the present.

development and updating of the Cook Emergency Plan and coordination of this plan with other response organizations.

CEP Rev 47

Page 224 of 226 Alteration Justification Page 149, APPENDIX A, Index of Emergency GT 2021-6325 - 1 Planning Standard L Plan Implementing Documents; FROM Update hospital name/procedure title.

Decontamination and Treatment of the Radioactively Contaminated Patient(s) at This meets editorial correction criteria per Lakeland Regional Medical Center PMP-2010-PRC-002, Figure 5, Editorial TO Correction Criteria, Item (d)

Spectrum Health Lakeland Emergency Radiation Organizational Changes.

Exposure Intake Procedure Page 154, L.1 GT 2021-6325 - 1 Planning Standard L FROM Lakeland Hospital Contaminated Injured Person Updated hospital names.

Protocol TO This meets editorial correction criteria per Spectrum Health Lakeland Emergency Radiation PMP-2010-PRC-002, Figure 5, Editorial Exposure Intake Procedure Correction Criteria, Item (d)

Organizational Changes.

Pages 154-155, Appendix A Cross Reference AR 2022-1317 - 4 Appendix A Table Plant Procedure column was updated for Updated to reference TPD-600-EPT, Planning Standards O.3, O.4.d, O.4.f, O.4.g, Emergency Preparedness Training and O.4.i from Not Addressed to TPD-600- Program Description, in the Plant EPT. Procedure column for O.3, O.4.d, O.4.f, O.4.g, and O.4.i.

Page 155, Appendix A Cross Reference Table AR 2022-1317 - 4 Appendix A Plant Procedure column was updated for Planning Standard O.4.h from Not Addressed Updated to reference RMT-2080-EPP-to RMT-2080-EPP-500 500, Emergency Plan Drills and Exercises in the Plant Procedure column for O.4.h.

Page 155, Appendix A Cross Reference Table AR 2022-1317 - 4 Appendix A Emergency Plan Section was updated for Planning Standard O.4.i from Not Addressed to Updated to reference O.4.i as the O.4.i Emergency Plan Section for O.4.i.

Page 155, Appendix A Cross Reference Table Updated P.3 from "Not Applicable" to Emergency Plan Section was updated for "P.3 in the EMERGENCY PLAN Planning Standard P.3 from Not Addressed to SECTION column and "PMI-2080" to P.3 and Plant Procedure column was updated for PMP-2080-EPP-200 in the PLANT Planning Standard P.3 from PMI-2080 to PMP- PROCEDURE column of the NUREG-2080-EPP-200. 0654/CEP/Procedure CROSS REFERENCE table.

CEP Rev 47

Page 225 of 226 Alteration Justification Page 180, Appendix C GT 2021-6606 - 1 Appendix C Removed the Emergency Anti-C equipment from the Training Center as approved in 10 CFR Removed the Emergency Anti-C 50.54(q) #21-03 equipment from the Training Center as Evaluated in 50.54(q) #21-03, and approved in PORC 4835 Page 180, Appendix C AR 2020-6553 - 5 Appendix C FROM Both Control Rooms Changed "Both Control Rooms" to "Each TO Control Room" to align with RP-95-03, and to reduce confusion as to the intention.

Each Control Room This meets editorial correction criteria per PMP-2010-PRC-002 Figure 5 Editorial Correction Criteria, Item (q) rewording for clarification which clearly does not change the methodology or intent of the step.

Page 180, Appendix C GT 2021-6325 - 1 Planning Standard L FROM Lakeland Regional Medical Center, St. Joseph Update hospital names.

Niles Community Hospital, Niles TO This meets editorial correction criteria per Spectrum Health Lakeland Medical Center PMP-2010-PRC-002 Figure 5 Editorial Spectrum Health Lakeland Niles Hospital Correction Criteria, Item (d)

Organizational Changes.

Page 200, Item (A) Command Centers Other facility addresses were listed, Added address for EOF Added address to align.

Page 201, Item H GT 2021-6325 - 1 Planning Standard L FROM Lakeland Regional Medical Center, St. Joseph, Update hospital names.

MI Niles Community Hospital, Niles, MI This meets editorial correction criteria per TO PMP-2010-PRC-002 Figure 5 Editorial Spectrum Health Lakeland Medical Center Correction Criteria, Item (d)

Spectrum Health Lakeland Niles Hospital Organizational Changes.

Page 214, Appendix J, AR 2022-1061 - 1 Appendix J Revised the eight year cycle to reflect the current eight year cycle. Administrative Update to Eight Year Cycle CEP Rev 47

Page 226 of 226 Alteration Justification Page 214, Appendix J, Annual Item 14 GT 2022-4385 - 1 Appendix J FROM Test of the Public Notification System ANS to IPAWS per ANS design report &

TO 50.54(q) #21-02 IPAWS transition Annually validate the reliability / availability of IPAWS CEP Rev 47

AEP-NRC-2022-47, Transmittal of Donald C. Cook Nuclear Plant, Emergency Plan, Revision 47

Contents

Text

Enclosure:

Dear Mr. Sieber:

Dear Mr. Gebbie:

Dear Ladies and Gentlemen:

SUBJECT:

Enclosures:

SUBJECT:

Dear Mr. Kelberg:

Dear Mr. Sieber:

Dear Mr. Gebbie:

SUMMARY

Title:

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