JAFP-16-0104, Emergency Plan Update, Emergency Plan, Volume 2, Rev. 23 and Volume 3, Rev. 27

Emergency Plan Update, Emergency Plan, Volume 2, Rev. 23 and Volume 3, Rev. 27

ML16188A185
Person / Time
Site:	FitzPatrick
Issue date:	06/15/2016
From:	Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Office of Nuclear Reactor Regulation
References
JAFP-16-0104
Download: ML16188A185 (182)

Text

ENTERGY NUCLEAR OPERATIONS, INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURE TABLE OF CONTENTS - VOLUME 2 N/A REVISION 23 EFFECTIVE DATE:

I I

• INFORMATIONAL USE *

• QUALITY RELATED

• ADMINISTRATIVE

• c PERIODIC REVIEW DUE DATE: June 2017

TABLE OF CONTENTS - VOLUME 2 N/A REVISION

SUMMARY

SHEET REV. NO. CHANGE AND REASON FOR CHANGE 23 FULL REVISION - THESE CHANGES ARE BEING MADE TO REFLECT RECENT PROCEDURE CHANGES. PROCEDURES WERE ADDED SO THE TABLE OF CONTENTS NEEDS TO REFLECT THOSE CHANGES.

1. Add EAP-14.7 Remote Assembly Area Activation to Emergency Action Procedures (EAP)

2. Add EAP-14.8 Alternate TSC/OSC Activation and Operation to Emergency Action Procedures (EAP)

3. Update IAP-2 list of Attachments in Immediate Action Procedures (IAP}

Rev. No. ~ Page No. ~2- of ~3-

TABLE OF CONTENTS - VOLUME 2 N/A IMMEDIATE ACTION PROCEDURES (IAP)

IAP-1 Emergency Plan Implementation Checklist IAP-2 Classification of Emergency Conditions Attachment 1, Classification and Declaration Process Attachment 2, EAL Classification Matrix (posted attachment)

Attachment 3, EAL Bases Category A - Abnormal Rad Release/Rad Effluent Category C - Cold Shutdown/Refueling System Malfunction Category E - ISFSI Category H - Hazards Category s - System Malfunction Category F - Fission Product Barrier Degradation Attachment 4, Fission Product Barrier Loss I Potential Loss Matrix and Basis Attachment 5, Additional Guidance for Classification EMERGENCY ACTION PROCEDURES (EAP)

EAP - 1.1 Offsite Notifications EAP-2 Personnel Injury EAP-3 Fire EAP-4A onshift Dose Assessment EAP-4B Detailed Dose Assessment EAP-4C Protective Action Recommendations EAP-4.1 Release Rate Determination EAP-5.3 Onsite/Offsite Downwind Surveys and Environmental Monitoring EAP-6 In-Plant Emergency Survey/Entry EAP-8 Personnel Accountability EAP-9 Search and Rescue Operations EAP-10 Protected Area Evacuation EAP-11 Site Evacuation EAP-12 Dose Estimated From An Accidental Release of Radioactive Material to Lake Ontario EAP-13 Damage Control EAP-14.6 Habitability of the Emergency Facilities EAP-14.7 Remote Assembly Area Activation EAP-14.8 Alternate TSC/OSC Activation and Operation EAP-15 Emergency Radiation Exposure Criteria and Control EAP-16 Public Information Procedure EAP-16.2 Joint Information Center Operation EAP-17 Emergency Organization Staffing EAP- 1 9 Emergency Use of Potassium . Iodide (KI)

EAP-20 Post Accident Sample, Offsite Shipment and Analysis EAP-23 Emergency Access Control EAP-24 EOF Vehicle and Personnel Decontamination Rev. No. __2l_ Page No. ~3- of ~3-

EME RGENC Y PL!\ IMPLEMENTING PROCE DURES/VOLUME 3 PDATE LI ST Date of Issue: 6/ 15/201 6 Procedure Procedure Revision Date of Las t Use of Number T itle Number Review Procedure N/A TABLE OF CONTENTS REV. 27 06/16 Informatio nal EST IM AT ION OF POPULAT ION DO E WIT HIN EA P-27 REV. I3 0511 5 Refe rence IO MILE EMERGENC Y PLAN NING ZONE EOF VENT ILAT ION ISOLAT ION DU RI NG AN EA P-29 REV. 7 08/1 3 Information al EMERGE CY EMERGENC Y TE RMINAT ION AND EA P-30 REV. 4 07/ 11 In fo rmati onal TRANS IT ION TO RECOVE RY ACCE PTANCE OF E VlRO ME TAL EA P-34 SA MP LES AT THE EOF/EL DU R! GAN REV . 5 08/ 13 Informat ional EME RGENC Y EOF TL D lSSUA CE DU RI NG A EA P-35 REV. 8 08/13 Informational EME RGENC Y EAP-36 WlTHDRA WN (5116/20 16)

EA P-42 OBTA INING MET EOROLOG ICAL DATA REV . 25 04/ I4 Informational EA P-43 WITHDRAWN (3/ 10/20 16)

EA P-44 CO RE DAMAGE ESTI MAT ION REV. 8 07/ 12 Informational EME RGENCY RES PONSE DATA SYSTEM EA P-45 (E RDS CO NFIGU RAT ION CONT ROL REV. 9 04/ 15 Informat ional PROG RAM)

EA P-46 SUPPLEMENTAL ERO ACT IO S REV. 3 03/ 16 Refe rence SA P-I MA INTA INING EME RGEN CY PREPAREDNESS RE V. 25 12/ 14 ln forma tional SA P-2 EMERGENC Y EQU IPMENT INVENTO RY REV . 58 04/ 16 Reference SA P-3 EME RGENC Y COM MUN ICAT IONS TEST ING REV . 87 12/ 15 Reference PROM PT NOT IFICAT ION SYSTEM SA P-8 REV. 2 1 07/ 15 ln fo rm at iona l FA ILU RE/SIREN SYSTEM FALSE ACTIVAT ION METEO ROLOG ICA L MON ITO RI NG SYSTEM SAP-I 0 REV. 16 04/ 15 Refere nce SU RV EILLANCE EMERGENC Y RES PONSE DATA SYSTE M SA P-1 7 (ERDS) QUA RTE RLY TEST ING REV. 11 03/1 1 Informational SAP-20 EMERGENC Y PLAN TRAINING REV. 38 0311 6 l nform ational EQU IP MENT IMPORTANT TO EME RGENC Y SA P-23 REV. I 12/ 14 Informati onal PREPAREDN ESS LOSS OF EMERGENCY PREPAREDNESS SAP-24 REV. 0 12/ 15 In forma tional CA PAB ILI T IES Page 1 of 1

ENTERGY NUCLEAR OPERATIONS, INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT EMERGENCY PLAN I MPLEMENTING PROCEDURE TABLE OF CONTENTS - VOLUME 3 N/A REVISION 27 EF FECTIVE DATE: to !1s /201&

/ I

• I NFORMATIONAL USE *

• QUAL ITY RELATED *

• ADMI NISTRATIVE *

• • • • • • • • • • • • • • • • • • • • • • • • * **** LE PERIODIC REVIEW DUE DATE: June 2017

TABLE OF CONTENTS - VOLUME 3 N/A REVISION

SUMMARY

SHEET REV. NO. CHANGE AND REASON FOR CHANGE 27 FULL REVISION - THESE CHANGES ARE BEING MADE TO REFLECT RECENT PROCEDURE CHANGES. PROCEDURES WERE BEING REMOVED AND ADDED SO THE TABLE OF CONTENTS NEEDS TO REFLECT THOSE CHANGES.

1. Remove EAP-36 from Emergency Action Procedures (EAP)

2. Remove EAP-37 from Emergency Action Procedures (EAP)

3. Remove EAP-43 from Emergency Action Procedures (EAP)

4. Remove SAP-7 from Supplemental Action Procedures (SAP)

5. Add SAP-24 Equipment Important to Emergency Preparedness to Supplemental Action Procedures (SAP)

Rev. No. 27 Page No. 2 of 3

TABLE OF CONTENTS - VOLUME 3 N/A EMERGENCY ACTION PROCEDURES (EAP)

EAP-27 Estimation of Population Dose Within 10 Mile Emergency Planning Zone EAP-29 EOF Ventilation Isolation During An Emergency EAP-30 Emergency Termination and Transition To Recovery EAP-34 Acceptance of Environmental Samples at the EOF/EL During an Emergency EAP-35 EOF TLD Issuance During an Emergency EAP-42 Obtaining Meteorological Data EAP-44 Core Damage Estimation EAP-45 Emergency Response Data System (ERDS) Configuration Control Program EAP-46 Supplemental' ERO Actions SUPPLEMENTAL ACTION PROCEDURES (SAP)

SAP-1 Maintaining Emergency Preparedness SAP-2 Emergency Equipment Inventory SAP-3 Emergency Communications Testing SAP-8 Prompt Notification System Failure/Siren System False Activation *

• SAP-10 Meteorological Monitoring System Surveillance SAP-17 Emergency Response Data System (ERDS) Quarterly Testing SAP-20 Emergency Plan Training SAP-23 Equipment Important to Emergency Preparedness SAP-24 Loss of Emergency Preparedness Capabilities Rev. No. ~ Page No. 3 of 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET 1 OF3 Procedure/Document Number: Volume 1 *Table of : Revision: 32 Contents Equipment/Facility/Other: James A. Fitzpatrick

Title:

Volume 1 *Table of Contents Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result In a change to the emergency plan or affect the implementation of the emergency plan):

FULL REVISION - THESE CHANGES ARE BEING MADE TO REFLECT RECENT PROCEDURE CHANGES. SECTIONS WERE REMOVED SO THE TABLE OF CONTENTS NEEDS TO REFLECT THOSE CHANGES.

1. Remove Section 5.3.12, Public Information Liaison - reason: position is no longer listed in Section 5, was removed in the last revision

2. Remove Sections 7.2.8.1, 7.2.8.2, 7.2.8.3, and 7.2.8.4* reason: Revision 35 to Section 7 removed these items

3. Remove Section 7.4.5, Alternate Staffing Facility- reason: Revision 33 to section 7 removed this item Part II. Activity Previously Reviewed? DYES IZl NO Is this activity fully bounded by an NRC approved 10 CfR 50.90 submittal or 50.54(q)(3) Continue to Evaluation is next part Alert and Notification System Design Report? ' NOT required.

Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and complete Part proposed change is documented below: VI.

Justification:

D Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

NOTE: For example, when a design change is the proposed kctivity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

Screenina.

APPLICABILITY CONCLUSION

[8] If there are no controlling change processes, continue the 50.54(q)(3) Screening.

D One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

D One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT reauired. ldentifv controllina chanae orocesses below and comolete Part VI.

CONTROLLING CHANGE PROCESSES 10 CFR 50.54(q)

EN-EP-305 REV 3

('

ATTACHMENT9.1 1 OCFR50.54{q) SCREENING SHEET 2oF3 Procedure/Document Number: Volume 1

• Table of  ; Revision: 32 Contents *'

Equipment/Facility/Other: James A. Fitzpatrick

Title:

Volume 1 - Table of Contents Part IV. Editorial Change 1:8JYES UNO S0.54(q)(3) Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change inte~t? NOT required.

Justification:  !

Enter justification and Changes are editorial changes that do not change the intent of the Emergency Plan (or complete Pan Procedure). These changes update the Table of Contents of the Emergency Plan (or VI.

Procedure) to reflect changes that were previously made.

Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1] 0

2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 D staffing) in accordance with the emergency plan. [1) :

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] 0

4. The process for timely augmentation of onshift staff is established and maintained. [2] D

5. Arrangements for requesting and using off site assistance have been made. [3] D

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] 0

7. A standard scheme of emergency classification and action levels is in use. [4) D B. Procedures for notification of State and local governmental agencies are capable of alerting them of D the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt D instructions to the public Within the plume exposure pathway. [5) 1o. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 0 Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5)

11. Systems are established for prompt communication among principal emergency response D organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6] D

13. Emergency preparedness information is made available to the public on a periodic basis within the 0 plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. [7] D

15. Adequate facilities are maintained to support emergency response. [8) 0

16. Adequate equipment is maintained to support emergency response. {B] u

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] u 1B. A range of public PARs is avallable for implementation during emergencies. [1 O] u

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are u available to suooort the formulation of PARs and have been orovided to State and local EN-EP-305 REV 3

)

ATTACHMENT9.1 I

SHEET 30F3 Procedure/Document Number: Volume 1 -Table of Revision: 32 Contents Equipment/Facility/Other: James A. Fitzpatrick

Title:

Volume 1 - Table of Contents

20. A range of protective actions is available for plant emergency workers during emergencies, including u those for hostile action events.!10]

21. The resources for controlling radiological exposures for emergency workers are established. (11) u

22. Arrangements are made for medical services for contaminated, Injured Individuals. [12] u

23. Plans for recovery and reentry are developed. [13] u

24. A drill and exercise program (including radiological, medical, health physics and other program u areas) Is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, 0 maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. (14)

26. Identified weaknesses ate corrected. [14] u

27. Training is provided to emergency responders. !15] u

28. Responsibility for emergency plan development and review is established. [16] u

29. Planners responsible for emergency plan development and maintenance are properly trained. (16] 0 APPLICABILITY CONCLUSION

~ If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI.

I a lf any Part V criteria are checked, complete Part.VI and pei'form a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION These changes are being made to reflect recent procedure changes. Procedure sections were removed so the Table of Contents. needs to reflect those changes. The proposed changes revise the Table of Contents information only. The change does not add, delete or modify a process, meaning or intent of a *description, or change facilities or equipment. These changes do not require a change to the Emergency Plan. No further evaluation is required.

Part VI. Signatures:

Preparer Name (Print)

Mellonle Christman (Optional) Reviewer Name (Print)

('(Q~-<-

N JA v Preparer Signature

\

\0.'i 'l\O('\

Reviewer Signature v Date:

06/02/2016 Date:

Reviewer Qame~t) ~ Reviewer Signature Dale:

lP ~ (f.p U~*( ~. \P~

Nuclear EP Project ManaQer ~~

~/ure Approver Name (Print) Date:

\rO -:r-o.--e I b-/1 .. lOL' EP manager or designee

'.I II EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET 1 OF3 Procedure/Document Number: Volume 2 *Table of : Revision: 23 Contents  ;*

Equipment/Facility/Other: James A. Fitzpatrick

Title:

Volume 2 *Table of Contents Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

FULL REVISION - THESE CHANGES ARE BEING MADE TO REFLECT RECENT PROCEDURE CHANGE

S. PROCEDURE

S WERE ADDED SO THE TABLE OF CONTENTS NEEDS TO REFLECT THOSE CHANGES.

1. Add EAP-14.7 Remote Assembly Area Activation to Emergency Action Procedures (EAP)

2. Add EAP-14.8 Alternate TSC/OSC Activation and Operation to Emergency Action Procedures (EAP)

3. Update IAP-2 list of Attachments in Immediate Action Procedures (IAP)

Part II. Activity Previously Reviewed? UYES t8J NO Is this activity fully bounded by an NRC approved 1 O CFR 50.90 submittal or 50.54(q)(3) Continue to Evaluation Is next part Alert and Notification System Design Report? NOT required.

Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and complete Part proposed change is documented below: VI.

Justification:

D Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

NOTE:. For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included In this 50.54(q)(3)

Screenino.

APPLICABILITY CONCLUSION t8l If there are no controlling change processes, continue the 50.54(q)(3) Screening.

0 One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q}(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

D One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT reouired. Identify controlling change processes below and complete Part VI.

CONTROLLING CHANGE PROCESSES 10 CFR 50.54(q)

EN-EP-305 REV 3

ATTACHMENT9.1 10CFR50.54(q) SCREENING SHEET 20F3 Procedure/Document Number: Volume 2 - Table of Revision: 23 Contents Equipment/Facility/Other: James A. Fitzpatrick  ;

Title:

Volume 2 - Table of Contents Part IV. Editorial Change (gl,YES ONO 50.54(q)(3) Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.

Justification: Enter

' justification and Changes are editorial changes that do not change the intent of the Emergency Plan (or complete Part Procedure). These changes update the Table of Contents of the Emergency Plan (or VI.

Procedure) to reflect changes that were previously made.

Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG*

0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1] D

2. The response organization has the staff to respond and to augment staff on a continuing basis (240 D staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] D

4. The process for timely augmentation of onshift staff is established and maintained. (2) D

5. Arrangements for requesting and using off site assistance have been made. [3] D

6. State and local staff can be accommodated at the EOF iri accordance with the emergency plan. [3] D

7. A standard scheme of emergency classification and action levels is in use. (4) D

8. Procedures for notification of State and local governmental agencies are capable of alerting them of D the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt D instructions to the public within the plume exposure pathway. [5)

10. The public ANS meets the design requirements of FEMA*REP-1 o, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response D organizations. [6)

12. Systems are established for prompt communication to emergency response personnel. [6] D

13. Emergency preparedness information is made available to the public on a periodic basis within the D plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. [7] LJ

15. Adequate facilities are maintained to support emergency response. [8] D

16. Adequate equipment is maintained to support emergency response. [8) D

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] D

18. A range of public PARs is available for implementation during emergencies. [10} LJ

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are LJ available to support the formulation of PARs and have been provided to State and local governmental authorities. [1 OJ EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING I

SHEET 30F3 Procedure/Document Number: Volume 2 - Table of Revision: 23 Contents Equipment/Facility/Other: James A. Fitzpatrick

Title:

Volume 2 - Table of Contents ..

20. A range of protective actions is available for plant emergency workers during emergencies, including u those for hostile action events.[1 OJ

21. The resources for controlling radiological exposures for emergency workers are established. [11] D

22. Arrangements are made for medical services for contaminated, injured individuals. [12] u

23. Plans for recovery and reentry are developed. [13] u

24. A drill and exercise program (including radiological, medical, health physics and other program u areas) is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, 0 maintain, and demonstrate key skills are assessed via a formal critique process in order lo identify weaknesses. [14]

26. Identified weaknesses are corrected. [14) u

27. Training is provided to emergency responders. (15] u

28. Responsibility for emergency plan development and review is established. [16) u

29. Planners responsible for emergency plan development and maintenance are properly trained. [16) u APPLICABILITY CONCLUSION 8 If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below ancl complete Part VI.

0 If any Part V criteria are checked. complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION These changes are being made to reflect recent procedure changes. Procedures were added so the Table of Contents needs to reflect those changes. The proposed changes revise the Table of Contents information only. The change does not add, delete or modify a process, meaning or intent of a description, or change facilities or equipment. These changes do not require a change to the Emergency Plan. No further evaluation is required.

Part VI. Signatures:

Preparer Name (Print) Preparer Signature ar" Date:

Mellonie Christman .fY\ ~Ch..r"\~ 06f02/2016 (Optional) Reviewer Name (Print) Reviewer Signature Date:

NIA Reviewer Name (Print)

°"1)......,:, l 6) ~ - I o ..,._,.,._

~ Reviewer Signature Q Date:

Nuclear EP Project Manager ~°'*""- ~/-z./r" A;i;;:;~~

Approver Name (Print) Date:

J'D J'Crl'(. '

EP manager or desionee (, ""11 *d-D I"

\,

u EN-EP-305 REV 3

ATTACHMENT9.1 10CFR50.54(q) SCREENING SHEET1 OF4 Procedure/Document Number: Volume 3

• Table of Revision: 27 Contents Equipment/Facility/Other: James A. Fitzpatrick (JAF)

Title:

Volume 3 Table of Contents ,.

Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

FULL REVISION - THESE CHANGES ARE BEING MADE TO REFLECT RECENT PROCEDURE CHANGE

S. PROCEDURE

S WERE BEING REMOVED AND ADDED SO THE TABLE OF CONTENTS NEEDS TO REFLECT THOSE CHANGES.

1. Remove EAP-36 from Emergency Action Procedures (EAP)

2. Remove EAP-37 from Emergency Action Procedures (EAP)

'I

3. Remove EAP-43 from Emergency Action Procedures (EAP)

4. Remove SAP-7 from Supplemental Action Procedures (SAP)

5. Add SAP-24 Equipment Important to Emergency Preparedness to Supplemental Action Procedures (SAP)

EN-EP-305 REV 3

'f ATTACHMENT 9.1 10CFR50.54(q) SCREENING 5HEET20F4 Procedure/Document Number: Volume 3 - Table of Revision: 27 Contents Equipment/Facility/Other: James A. Fitzpatrick

Title:

Volume 3 - Table of Contents Part II. Activity Previously Reviewed? UYES 12,g NO Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3) Continue to Evaluation Is next part Alert and Notification System Design Report? NOT required.

Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and complete Part proposed change is documented below: VI.

Justification:

D Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

Screenina.

APPLICABILITY CONCLUSION

[81 If there are no controlling change processes, continue the 50.54(q}(3) Screening.

D One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3} Screening for that portion of the activit}i. Identify the applicable controlling change processes below.

D One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT required. Identify controlling change processes below and comolete Part VI.

CONTROLLING CHANGE PROCESSES i

10 CFR 50.54(q)  :

Part IV. Editorial Change [81YES ONO 50.54(q)(3) Continue to neitt Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.

Enter Justification: justification and Changes are editorial changes that do not change the intent of the Emergency Plan (or complete Part Procedure}. These changes update the Table of Contents of the Emergency Plan (or VI.

Procedure) to reflect changes that were previously made.

Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NU REG-0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1] D

2. The response organization has the staff to respond and to augment ~taff on a continuing basis (24/7 D staffing} in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] D

4. The process for timely augmentation of onshift staff is established and maintained. [2] D

5. Arrangements for requesting and using off site assistance have been made. [3] D

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] D EN-EP-305 REV 3

)

ATTACHMENT 9.1 10CFRS0.54(q) SCREENING SHEET30F4 Procedure/Document Number: Volume 3

• Table of Revision: 27 Contents Equipment/Facility/Other: James A. Fitzpatrick

Title:

Volume 3

• Table of Contents

7. A standard scheme of emergency classification and action levels Is in use. [4] D

8. Procedures for notification of State and local governmental agencies are capable of alerting them of D the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. (5]

9. Administrative and physical means have been established for alerting and providing prompt D instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response LJ organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. (6] D

13. Emergency preparedness information is made available to the public on a periodic basis within the D plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. (7] D

15. Adequate facilities are maintained to support emergency response. [8] D

16. Adequate equipment is maintained to support emergency response. [8] D

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] D

18. A range of public PARs is available for implementation during emergencies. [10] D

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are D available to support the formulation of PARs and have been provided to State and local governmental authorities. [1 O]

20. A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events.[1 O]

21. The resources for controlling radiological exposures for emergency workers are established. [11] D

22. Arrangements are made for medical services for contaminated, injured individuals. [12] D

23. Plans for recovery and reentry are developed. [13] D

24. A drill and exercise program (including radiological, medical, health physics and other program u areas) is established. (14)

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, D maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]

26. Identified weaknesses are corrected. [14] D

27. Training is provided to emergency responders. [15] D

28. Responsibility for emergency plan development and review is established. [16] D

29. Planners responsible for emergency plan development and maintenance are properly trained. [16] D EN-EP-305 REV 3

)

ATTACHMENT 9.1 10CFR50,54(q) SCREENING SHEET40F4 Procedure/Document Number: Volume 3 *Table of Contents I Revision: 27 Equipment/Facility/Other: James A. Fitzpatrick  :

Title:

Volume 3 - Table of Contents APPLICABILITY CONCLUSION g If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for condusion below and complete Part VI.

• Q Ir any Part V criteria are checked, complete Part VI and perfo~m a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION These changes are being made to reflect recent procedure changes. Procedures were removed and added so the Table of Contents needs to reflect those changes. The proposed changes revise the Table of Contents information only. The change does not add, delete or modify a process, meaning or intent of a description, or change facilities or equipment These changes do not require a change to the Emergency Plan. No further evaluation is required. '

Part VI. Si natures:

Preparer Name (Print) Preparer Signature Date:

06/02/2016 Mellonie Christman (Optional) Reviewer Name (Print) Date:

Reviewer ~ame {Print) (\ Date:

""':D-.'1 j). \(.. \ D u-n-~~aY G- - '2. -l<t-Nuclear EP Pro"ect Mana er Approver Name (Print)

\fQ~().u EP mana er or desi nee EN-EP-305 REV 3

ENTERGY NUCLEAR NORTHEAST JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCUMENT TRANSMITTAL AND RECEIPT ACKNOWLEDGEMENT FORM TO: EP Admin DEPT.: Emergency Pl a nning LOCATION: USNRC Document Control Center, Washington DC/RockvilleMD SPECIAL NOTES: JAFP Memo & EN-LI-106 form requi red.

Include 10CFR50.54(q) Screen and Eval uae i en (EN-EP-305 Attach 9.1 & 9.2)

CONTROL MANUAL NUMBER 34 FROM: KELLY SAWYER DEPT.: ADMINI STRATIVE SERVICES LOCATION: JAF DATE : June 13, 2016 APPLICABLE MANUAL: E-PLAN PROCEDURE

• • • EDITORIAL CORRECTIONS***

DOCUMENT DOCUMENT TITLE REV EFFECTIVE NUMBER DATE UPDATE LIST UPDATE LIST \TQLtJME 1 - 611512016 APPENDIX ***PAGES D-1 & D-2 ONLY***

9 N/A D ( Periodic Review Date Change)

APPENDIX ***PAGES COVER & E-1 ONLY***

10 N/A E (Periodic Review Date Change)

INSTRUCTIONS:

1. Insert the attached revised documents, and withdraw any noted WITH DRAW N documents from your controlled copy.

2. DISCARD ALL SUPERCEDED DOCUMENTS, as applicable. DISCARD THIS TRANSMITTAL.

NOTE Fail ure to incorporate these documents into your controlled manual will result in cancellation of the subject controlled documents.

ENTERGY NUCLEAR OPERATIONS, INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT EMERGENCY PLAN VOLUME 1 NEW YORK STATE PLAN AND PROCEDURES APPENDIX D EFFECTIVE DATE:

• INFORMATIONAL USE *

• QUALITY RELATED *

• ADMINISTRATIVE

• LL~

PERIODIC REVIEW DUE DATE: June 2017

~~~~~~~~~~~

Rev. No. 9 Page D-1

REVISION

SUMMARY

PAGE REV. NO CHANGE AND REASON FOR CHANGE 9 FULL REVISION

1. Revised the cover sheet signature to reflect correct Director title.

Rev. No . 9 Page D-2

ENERGY NUCLEAR OPERATIONS, INC.

JAMES A . FITZPATRICK NUCLEAR POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURE EMERGENCY PLAN VOLUME 1 OSWEGO COUNTY PLANS AND PROCEDURES APPENDIX E EFFECTIVE DATE= 9 I Zo / 2 o 1c__f

~~~~---'C....-,1~........"'--~~1'--~~-'---,f--~~~~

• INFORMATI ONAL USE *

• QUALITY RELATED

• ADMINISTRATIVE

• N PERIODIC REVIEW DUE DATE: June 2017

~~~~~~~~~~~~~~

Rev. No. 10

REVISION

SUMMARY

PAGE REV. NO CHANGE AND REASON FOR CHANGE 10 FULL REVISION

1. Revised the cover sheet signature to reflect correct Director title.

Rev. No. 10 Page E-1

ENTERGY NUCLEAR NORTHEAST JAMES A. FITZPATRICK NUCLEAR POWER PLANT '

DOCUMENT TRANSMITTAL AND RECEIPT ACKNOWLEDGEMENT FORM TO : EP Admin DEPT . : Emergency Planning LOCATION: USNRC Document Control Center, Washington DC/RockvilleMD SPECIAL NOTES: JAFP Memo & EN-LI-106 form required.

Include 10CFR50.54(q) Screen and Evaluation (EN-EP-305 Attach 9.1 & 9.2)

CONTROL MANUAL NUMBER 34 FROM: KELLY SAWYER DEPT. : ADMINISTRAT I VE SERVI CES LOCATION : JAF DATE : June 13, 2016 APPLICABLE MANUAL: E-PLAN PROCEDURE DOCUMENT DOCUMENT TITLE REV EFFECTIVE NUMBER DATE UPDATE LIST UPBA-'PE L~S!l'! - l/Q:beME ~ &: 3 - 611§12916 EMERGENCY PLAN IMPLEMENTATION IAP-1 47 6/15/2016 CHECKLIST SAP-1 MAINTAINING EMERGENCY PREPAREDNESS 25 6/15/2016 INSTRUCTIONS:

1. Insert the attached revised documents, and withdraw any noted WITHDRAWN documents from your controlled copy.

2. DISCARD ALL SUPERCEDED DOCUMENTS, as applicable. DISCARD THIS TRANSMITTAL.

NOTE Failu re to incorporate these documents into your controlled manual will resu lt in cancellation of the subject controlled documents.

ENTERGY NUCLEAR OPERATIONS , INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURE EMERGENCY PLAN IMPLEMENTATION CHECKLIST IAP-1 REVISION 47 EFFECTIVE DATE: _

1 s~h'-""--o=-<-1-=&"-----

_,l....c:.Y-r-/.:....:.1 I

• INFORMATI ONAL US E *

• QUALITY RE LATED

• ADMI NISTRATIVE

!co .OL PERIODIC REVIEW DUE DATE: J UNE 2021

EMERGENCY PLAN IMPLEMENTATION CHECKLIST IAP-1 REVISION

SUMMARY

SHEET REV. NO. CHANGE AND REASON FOR CHANGE 47 FULL REVISION

1. Attachment 2 - Section 2.2.4 . J - Add "IF in response to an emergency at either NMP or JAF, Oswego County implements Protective Actions that includes evacuation, sheltering and/or KI use, THEN implement protective actions for JAF personnel (protected area or site evacuation, accountability or KI)."

Reason: There was direction in Attachment 1 for the Control Room but not in Attachment 2 for the EOF Emergency Director, to give additional guidance for implementing protective actions during an emergency at NMP that includes evacuation, sheltering and/or KI.

Rev. No. _AL Page ~2- of ~

EMERGENCY PLAN IMPLEMENTATION CHECKLIST IAP-1 TABLE OF CONTENTS SECTION l .0 PURPOSE * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

• 4

2.0 REFERENCES

• * * * * * * * . * * . . * * * * * . * * * * . . * * * * . * * * * * * * * * * * * * *

• 4 3 *0 INITIATING EVENTS * * * * * . * * * * * * * * * * * * * * * * . * * * * * * * * * * * * * *

• 4 4.0 PROCEDURE * * * * * * * * * * * * * * * * * * * * * * * * *  ! * * * * * * * * * * * * * * * * * " *

• 5 5.0 ATTAClDJENTS ****************************************** *

• S

1. CONTROL ROOM EMERGENCY PLAN IMPLEMENTATION CHECKLIST 6

2. EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

(

' \

Rev. No. _AL Page ~3- of --1..a_

EMERGENCY PLAN IMPLEMENTATION CHECKLIST IAP-1 1.0 PURPOSE The purpose of this procedure is to provide a checklist for implementing actions and direction in the use of additional procedures for implementing the emergency plan.

2.0 REFERENCES

2.1 Performance References NONE 2.2 Developmental References 2.2.1 JAFNPP Emergency Plan, Volumes 2 & 3, Implementing Procedures.

2.2.2 NRC Bulletin 2005-02, Emergency Preparedness and Response Actions for Security-Based Events.

2.2.3 CR-JAF-2008-00923/CA-10, Determine and implement a means to reduce delays in sounding station alarms and making site announcement for accountability.

2.3 CommitJnents 2.3.1 ENOC-05-004 dated August 17, 2005, Response to NRCB-2005-04.

3.0 INITIATING EVENTS 3.1 Either an Unusual Event, Alert, Site Area Emergency or General Emergency has been declared in accordance with IAP-2, CLASSIFICATION OF EMERGENCY CONDITIONS.

Rev.* No. 31.__ Page ~4- of ~

EMERGENCY PLAN IMPLEMENTATION CHECKLIST IAP-1 4.0 PROCEDURE NOTE: Announcements should be made for all classifications and reclaspifications, .except during hostile action based events. Announcements during a Hostile Action Based event are made in accordance with AOP-70.

4.1 Shift Manager NOTE: As a quick reference tool for the implementer of this procedure, a new checklist should be completed in full at initial declaration and for each reclassification. Additionally, a review of the checklist should be conducted for significant event related occurrences.

4.1.1 WHEN an emergency classification level is declared, THEN implement Attachment 1 4.2 EOF Emergency Director 4.2.1 WHEN an emergency classification level is declared, THEN respond to the EOF AND implement Attachment 2.

5.0 ATTACHMENTS

1. CONTROL ROOM EMERGENCY PLAN IMPLEMENTATION CHECKLIST

2. EOF EMERGENCY DIRECTOR EMERGENCY- PLAN IMPLEMENTATION CHECKLIST Rev . No . __£]__ Page ~5- of ~

CONTROL ROOM EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 1 of 8 NOTE: During a Hostile Action Based event, typically any actions for personnel injury, fires, accountability, protected area and site evacuations ARE DELAYED until coordination with Security can be managed. Checkboxes have been added where appropriate to remind the ED that this step has been delayed as a result of a HAB.

Implemented Initials/

Time Actions/Procedures A. Implement EAP-1.1, OFFSITE NOTIFICATIONS, in order to D Initials notify offsite agencies.

1. Evaluate for radiological release per EAP-4.1, UE* Attachment 5 ALERT* Time 2. IF any Security EAL is recognized as met, THEN ensure SAE* status of that Security EAL is reported on all GE* notifications provided to external agencies, even if the emergency has been reclassified to a higher level as a result of non-security issues.

UcoM2.3.1 D Initials B. IF any Security EAL is ~ecognized as met, THEN:

1. Implement AOP-70, Security Threat as appropriate UE* *-

ALERT* Time 2. Ensure status of that Security EAL is reported on all SAE* notifications provided to external agencies, even if the GE* emergency has been reclassified to a higher level as a result of non-security issues.

3. IF the 4-way bridge line cannot be staffed due to restrictions on personnel movements, THEN assign any control room staff to don the 4-way bridge headset and dial into the bridge using the phone numbers in the Emergency Telephone Directory.

4. IF the event is security related, 'l'HEN an accelerated verbal NRC notification via the ENS phone or commercial phone is required within approximately 15 minutes of the recognition of a security based emergency.

The NRC expects to be provided with the following information:

i: Site name: James A. FitzPatrick ii: Emergency clas.sification: (If determined yet. l iii: Brief description of the nature of the threat (if known) including:

a) Type of attack (e.g. armed assault by land, or water) b) Attack status (i.e. imminent, in progress, or repelled.)

NRC Headquarters Operation Center Commercial Phones 301-816-5100 or 301-951-0550 C. IF a General Emergency has been declared in accordance with D Initials IAP-2, CLASSIFICATION OF EMERGENCY CONDITIONS, THEN recommend protective actions in accordance with procedure GE* EAP-4C, PROTECTIVE ACTION RECOMMENDATIONS.

Time 1. IF in response to an emergency at either NMP or JAF, Oswego County implements Protective Actions that includes evacuation, sheltering and/or KI use, THEN implement protective actions for JAF personnel {protected area or site evacuation, accountability or KI).

• IMPLEMENTATION IS REQUIRED AT THIS EMERGENCY CLASSIFICATION IAP-1 EMERGENCY PLAN ATTACHM:ENT 1 Rev. No. _A]_ IMPLEMENTATION CHECKLIST Page _6_of _fJL_

CONTROL ROOM EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 2 of 8 Implemented Initials/Time Actions/Procedures D. Per EAP-1.1, direct activation of ERONS to notify and D Initials recall the ERO as applicable.

1. ERONS should be activated at the UE, and only once UE* again a.t the ALERT or higher classification if ALERT* escalation from the UE occurs.

SAE*

GE* Time 2. All Emergency Response Facilities shall be activated at an Alert emergency classification or higher.

a. ERF activation at an Unusual Event emergency classification is at the discretion of the Shift Manager.

3. The following information is required to activate ERONs:

a. Emergency Classification: (circle)

b. None UE Alert SAE GE

c. was the Emergency declared based on a Security EAL?

YES I NO

d. What action should be taken: (select only one)

• ACTIVATE ALL EMERGENCY RESPONSE FACILITIES

• ACTIVATE TSC/OSC ONLY

• ALTERNATE REPORTING LOCATION

• NO ACTION/INFORMATION ONLY

• SECURITY EVENT

• IMPLEMENTATION IS REQUIRED AT THIS EMERGENCY CLASSIFICATION IAP-1 EMERGENCY PLAN ATTACHMENT 1 Rev. No. _fl_ IMPLEMENTATION CHECKLIST Page _7_of --2Jl_

CONTROL~ROOM EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 3 of B Implemented Initials/Time Actions/Procedures NOTE: ERDS Activation is required to be completed within D Initials 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of an Alert or higher emergency declaration.

E. :CF an Alert or higher has been declared, THEN activate ALERT* or direct activation of ERDS IAW EN-EP-311, Emergency SAE* Time Response Data System (ERDS) Activation.

GE*

F. :CMPLEMENT EAP-10, PROTECTED AREA EVACUAT:CON IF:

D Initials

• A Site Area Emergency OR General Emergency has been SAE* declared, OR

• GE*

Time * :CF any of the following are present, THEN the ED OR EPM MAY, at his discretion, implement an EAP-10, PROTECTED AREA EVACUAT:CON:

• Uncontrolled steam leak

• toxic gases

• Flarmnable gases

• Explosion

• unanticipated actual and confirmed multiple area radiation monitor alarms indicting a non-localized condition

• unanticipated actual and confirmed ventilation monitor alarms

• EAP-6 survey showing high radiation /

• non-localized high airborne activity indicated by (,

process computer alarms

• fire compromising safety systems

• IMPLEMENTATION IS REQUIRED AT THIS EMERGENCY CLASSIFICATION IAP-1 EMERGENCY PLAN ATTACHMENT 1 Rev. No. _Al_ IMPLEMENTATION CHECKLIST Page __JL_of --2JL_

CONTROL ROOM EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 4 of 8 Implemented Initials/Time Actions/Procedures G. IMPLEMENT EAP-8, PERSONNEL ACCOUNTABILITY when:

D Initials

• A Site Area Emergency or General Emergency has been HAB declared, OR 30 Minute - - - -

Limit To Time

• A Protected Area.Evacuation or Site Evacuation has Complete been completed, OR From Time Declared

• At the Emergency Director OR Emergency Plant Manager's request.

D SAE* 1. Notify Security of the time the SAE or GE was DECLARED, AND GE*

2. Direct Security to commence Accountability, AND 3 . Immediately sound the Station Alarm and make Site announcements for Accountability H. Implement EAP-11, SITE EVACUATION:

D Initials

• At a Site Area Emergency IF determined appropriate HAB by the Emergency Director or Emergency Plant Manager, OR D Time

• At a General Emergency

) SAE+

GE*

I. IF a Gaseous Radioactivity Release is suspected, D Initials imminent, underway or has occurred, THEN implement EAP-4A, CONTROL ROOM DOSE ASSESSMENT Attachment 1 ALERT* Onshift Dose Assessment Data Entry Fo:rm for each release SAE* point in alarm and provide to Chemistry Technician, in GE* Time order to determine recommendations to be given to the County and State.

J. IF a Liquid Radioactivity Release is imminent, underway D Initials or has occurred, THEN implement EAP-12, DOSE ESTIMATED FROM AN ACCJ:DENTAL RELEASE OF RADIOACTIVE MATERIAL TO LAKE ONTARJ:O, in order to determine dose projections and protective action recommendations to be given to the Time County and State.

• Evaluate the need to isolate the storm sewer discharge into Lake Ontario by closing the shuttle gate.

+' IMPLEMENTATION SHALL BE CONSIDERED AT THIS EMERGENCY CLASSIFICATION.

• IMPLEMENTATION IS REQUIRED AT THIS EMERGENCY CLASSIFICATION IAP-1 EMERGENCY PLAN ATTACHMENT 1 Rev . No * .J.1_ IMPLEMENTATION CHECKLIST Page _9_of ~

CONTROL ROOM EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 5 of 8 Implemented lnitials!Time Actions/Procedures K. IF any of the following conditions arise implement the D Initials procedure as indicated. These may be delayed until coordination with Security can be arranged during a HAE Security Threat.

D TIME Initiated Delayed :Indications Procedure Fire EAP-3 Injury/Illness EAP-2 unusual weather EN-FAP-EP-10 Damage Control EAP-13 Unaccounted for EAP-9 personnel Need for Emergency EAP-15 Exposure High Rad Area Entry EAP-6 '

or emergency surveys \

needed IAP-1 EMERGENCY PLAN ATTACHMENT 1 Rev. No. IMPLEMENTATION CHECKLIST Page -1.Q_of ....2JL...

CONTROL ROOM EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 6 of 8 Implemented Initials /Time Actions/Procedures L. XF abnormal radiological conditions are indicated in D HAB Initials the plant or environs, or, if a General Emergency has been declared, 'l'HEN implement EAP-19, EMERGENCY USE OF POTASSXUM XODXDE (KX}.

D Time GE*

M. Continuously assess plant conditions against XAP-2, D Initials CLASSXFXCATXON OF EMERGENCY CONDXTXONS, to reclassify the emergency, including after EOF has assumed command and control.

Time N. Prepare for turnover to the EOF:

D Initials 1. Complete EP-2-ALL, Essential Information Form to assist in turnover Time 2. Direct the Communications Aid to fax complete form to the TSC and EOF incoming fax lines as detailed in the Emergency Telephone Directory.

\I

/

IAP-1 EMERGENCY PLAN ATTACHM:ENT 1 Rev. No . .....!I_ IMPLEMENTATION CHECKLIST Page __11_of --2JL_

CONTROL ROOM EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 7 of 8 Initials O. ~F, after the OSC is declared operational, an D HAB operations-only task is required by an emergency procedure or off-normal procedure, or is deemed D Time immediately necessary to protect the plant, THEN operator(s) may be directly dispatched by the Control Room to complete the task:

NOTE: Shift non-licensed operators are normally stationed in the OSC once activated. They should continue to carry their radios or telephones to be contacted directly by Control Room if necessary.

1. Brief the operator(s) on the task.

2. Direct the operator(s) to report to the OSC Operations Support Lead prior to leaving the OSC so they can be properly tracked.

3. Notify OSC Operations Support of the task and the names of the operator(s) assigned.

NOTE: Designating a team task as "Urgent" moves the team to the front of the line for briefing and expedites the dispatch process. Urgent tasks require one or more of the following attributes:

• Life Saving, Search, Rescue, Medical Emergency or Fire Fighting

• Time Critical Tasks (as designated by the TSC Manager, Shift Manager, or TSC Operations Director).

4. WHEN a non-urgent task outside of the Control Room is required, THEN communicate the task requirements to the TSC Manager.

IAP-1 EMERGENCY PLAN ATTACHMENT 1 Rev. No. ~ IMPLEMENTATION CHECKLIST Page ---1.2.__of --2]_

CONTROL ROOM EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 8 of 8 P. WHEN contacted by the OSC and informed that the OSC is Initials D activated, THEN:

1. Provide the following information concerning in-Time plant teams currently dispatched into the plant:

(Operators, Fire Brigade, Maintenance Personnel, etc.)

• Known or suspected plant hazards

• Team member names

• Assignment description and expected time of return

• Team location

• Communications methods

2. Acknowledge that the OSC is now taking control of the in-plant teams as well as for all subsequent teams dispatched from the osc.

Q. Utilize EAP-30, Emergency Termination and Transition to Initials D Recovery to terminate the event OR prepare for recovery.

Time

• IMPLEMENTATION IS REQUXRED AT THIS EMERGENCY CLASSIFICATION.

Print name Signature Date Time IAP-1 EMERGENCY PLAN ATTACHMENT 1 Rev. No . __11._ IMPLEMENTATION CHECKLIST Page -1.J_of _2_a_

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 1 of 15 Implemented Actions/Procedures 1.0 INITIAL ACTIONS NOTE: The EOF must be operational AND command and control assumed within approximately 60 minutes of ERO activation.

1.1 Mobilization 1.1.1 Print your name and today's date to indicate that you are the individual performing this checklist:

Name: Date:

1.1.2 Prepare to assume your assigned duties as follows:

A. Print your name on the EOF Staffing Board.

B. Don your position nametag.

C. Obtain any other supplies needed to perform your assigned tasks.

D. Determine the time that the EOF must be declared operational AND assume command and control

1. Determine time of ERO activation

2. Add 60 minutes to the above

3. Subtract 10 minutes for challenge goal

4. Target time:

1.1.3 Initiate and maintain a position log using EP-3-ALL, Log Sheet Form, to document significant actions, decisions and communications related to your position.

NOTE: If possible, the Shift Manager will have a completed EP-2-ALL, Essential Information Form faxed to the EOF prior to completion of EOF staffing.

1.1.4 Review Plant Status Report with EOF Technical Advisor.

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No. __D_ IMPLEMENTATION CHECKLIST Page ___JA_of ~

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 2 of 15 Implemented Actions/Procedures NOTE: Consult Emergency Telephone Directory for ED Hotline Bridge number.

1.1.5 Contact the Emergency Plant Manager (EPM) and the Shift Manager on the ED Hotline (primary) or ED Hotline Bridge (back-up).

A. Provide your name and inform them you are the oncoming ED.

B. Obtain a brief update of event and onsite conditions and record details on EP-2-ALL, Essential Information Form.

C. Inquire if there are any immediate needs prior to your assuming Command and Control.

1.1.6 Provide a short update to the EOF Staff.

• Your name and title

• Brief overview of event

• Direct immediate focus on the activation of the EOF

• Expectation of the time of EOF operational and command control is assumed (from 1.1.2.D)

NOTE: The EOF Manager has the primary responsibility for staffing and activation of the EOF. They will obtain your concurrence prior to declaring the facility activated.

1.1. 7 Coordinate activation of the EOF with the EOF Manager.

A. Declare the EOF operational when:

1. The EOF is habitable

2. The EOF has sufficient staff to support EOF operations

3. The EOF has sufficient equipment and supplies to support EOF operations.

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No. ~ IMPLEMENTATION CHECKLIST Page --1..2._of _2lL_

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 3 of 15 Implemented Actions/Procedures 1.1.8 Direct the EOF Communicator to contact the Corporate Duty Manager and provide them a summary of the situation.

1.2 Assume Command and Control NOTE: The EOF must be operational AND command and control assumed within approximately 60 minutes of ERO activation.

NOTE: The EOF may assume command and control of the emergency from the Control Room without assuming the responsibilities associated with offsite notifications, dose assessment and PARS.

1.2 .1 Contact the Shift Manager (or current ED in EOF) and determine when conditions will permit turnover of Command and Control duties.

1.2 .2 WHEN conditions permit, THEN conduct a formal turnover using EP-2-ALL, Essential Information Sheet.

1. 2 .3 Verify readiness to transfer responsibility of the following:

A. Classification of emergencies (EOF Technical Advisor)

B. Dose Assessment and PARs (EOF Rad Assessment Coordinator)

c. Offsite Notifications (EOF Offsite Communicator) 1.2. 4 WHEN the EOF is operational AND the EOF has capability to classify emergencies, THEN assume command and control of the emergency.

A. Inform the Shift Manager that you have assumed command and control of the emergency.

1.2. 5 Announce to the EOF that you have assumed overall command and control at:

(time) .

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No . __j_1._ IMPLEMENTATION CHECKLIST Page --1.Q_of --2JL_

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 4 of 15

Implemented Actions/Procedures

1. 2. 6 Direct the EOF Manager to notify other Emergency Response Facilities (TSC, JIC and OSC or backup facilities or alternate facilities) and Offsite Agencies (Oswego county, New York State and NRC) that you now have command and control of the emergency for Entergy JAF.

1. 2. 7 If any of the functions listed in step 1.2.3 were not taken over, then take action to assume responsibilities for those actions.

1.3 Emergency Response Facilities (ERF) Staffing NOTE: The EOF Manager is responsible for activation of the EOF. They will confer with you prior to activation.

1. 3 .1 Confirm Emergency Response Facilities (ERF) are being properly staffed and activated.

A. Contact (or direct staff to contact)

'") \ the following for facility staffing status: ,

0 TSC(alternate or backup if necessary) (TSC Manager) 0 osc (alternate or backup if necessary) (OSC Manager) 0 JIC (JIC Manager)

• :IF there are staffing issues, THEN ensure resources are directed to facilitate staffing and activation of ERFs.

1. 3 .2 confer with the TSC Manager to determine D if 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ERO Staffing will be required.

D

• IF it is determined the event will require a shift relief, THEN establish a shift turnover time for the facilities.

D

• Inform the EOF Manager to start shift roster development and shift callouts.

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No. _il_ IMPLEMENTATION CHECKLIST Page --11._of ~

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 5 of 15 Implemented Actions /Procedures NOTE: ERONS may be activated to:

• Notify the ERO for the purpose of obtaining additional staffing

• Providing the ERO information such as emergency status updates or second shift staffing information.

NOTE: ERONS activation codes are maintained in the KI lockers in the TSC and EOF 1.3 .3 IF it is desired to activate ERONS, THEN direct the EOF Cormnunicator to do so by implementing EAP-1.1.

2.0 ONGOING ACTIONS 2.1 General Operations NOTE: In the event that a qualified ERO member is not available to fill a position, an individual considered capable of fulfilling the position's responsibilities may be assigned to the position upon approval of the Emergency Director while /

• attempts are made to obtain a qualified ERO member.

2.1.1 Consult EP-10-ALL, Filling an ERO Vacancy During Facility Activation/Operation Form, for guidance on filling ERO positions.

2.1.2 IF notified by offsite emergency management or Security that an ICP is being (or has been) established, THEN:

Verify via the EOF Lead Offsite Liaison that the JAF Operations/RP Liaison and Security Liaison have arrived at the ICP.

NOTE: The Emergency Director will, as conditions dictate, initiate an Inter-Facility Briefing (EN-14-ALL, Briefing Form) using the ED Hotline.

2.1.3 As appropriate, initiate an inter-facility briefing with the following ERO members:

• EPM

• EOF Manager

• JIC Manager

• Shift Manager

• Company Spokesperson IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No. -4.1._ IMPLEMENTATION CHECKLIST Page __JJL_of ~

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST

, Page 6 of 15 Implemented Actions/Procedures A. The topics can include the following:

• Plant status (stable, de-grading, improving)

• Current station priorities and the status of actions being taken

• Onsite protective measures (evacuation, accountability, etc.)

• Current EOF priorities and the status of actions being taken

• Offsite actions being taken and/or issues

• Public Information issues or concerns

• Need for additional resources NOTE: During a Hostile Action Based Event ensure coordination of resources with the ICP and other offsite agencies as necessary.

2.1.4 Establish and/or review EOF priorities.

NOTE: Facility briefings should be conducted as needed (or approximately every 60 minutes as determined by the Emergency Director) .

2.1.5 Conduct periodic EOF briefings using EP-14-ALL, Briefing Form.

2.1.6 Integrate the Entergy response efforts with Local, State and Federal response by:

A. Performing initial and continuing briefings with county, state and federal officials present in the EOF and ensure that the JAF representatives in the ICP are getting the information needed during a HAB event.

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No. _fl_ IMPLEMENTATION CHECKLIST Page ---1.2_of -2JL_

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 7 of 15

rmplemented Actions/Procedures B. Assigning the following contacts and inform offsite officials present in the EOF:

• Tech Assistant for plant issues

• Rad Assessment Coordinators for rad conditions and dose projections

• EOF Manager for logistical requests

c. Evaluating any request for outside agency (local, state or Federal) assistance AND coordinate such support as appropriate.

D. Direct implementation of TSG's as appropriate for the event, consider:

0 TSG-1 Parameter Assessment 0 TSG-2 System Assessment 0 TSG-3 RPV Flow Assessment and Breach 0 TSG-4 Action Timing and Prioritization 0 TSG-5 Containment Venting 0 TSG-6 Drywell Spray Injection 0 TSG-7 Torus Spray Injection 0 TSG-8 Extending Station Blackout Coping Times 0 TSG-9 Primary Containment Venting without AC Power 0 TSG-10 Mitigating a Large Scale Security Event 0 TSG-11 Additional Resources for Extreme Damage Events 0 TSG-12 B5B Extreme Damage Mitigating Strategies 2.1.7 Keep Entergy Senior Management (JAF SVP, Corporate Duty Manager) informed of emergency status either directly or through the EOF Communicator.

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No. ~ IMPLEMENTATION CHECKLIST Page --2.Q__of _.£lL_

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 8 of 15 Implemented Actions/Procedures 2.1.8 Evaluate AND approve, as appropriate the expenditure and redirection of company resources-to support emergency response.

NOTE: The EOF Manager has the primary responsibility to prepare for arrival of NRC Site Team.

2.1.9 IF the NRC Site Team will be responding, THEN ensure EOF activities are coordinated with NRC team personnel.

NOTE: The NRC Executive Team Director (NRC Chairman or designated Commissioner} may desire to speak periodically with the Licensee's senior management representative.

2.1.10 IF requested, THEN provide information regarding the event to the NRC Executive Team Director.

NOTE: Actions that depart from Technical Specifications and licensing conditions are permitted per 10 CFR 50.54(x}

provided:

• An emergency exists and such action is immediately needed to protect the health and safety of the public when no adequate or equivalent means of protection consistent with Technical Specifications or License Conditions are apparent.

• The NRC resident, NRC Operations Center and Operations Department Manager are notified of the deviation prior to the action if time permits and if not, as soon as possible but in all cases within one hour.

2.1.11 Approve extreme plant mitigating actions (outside procedural guidance} that may affect offsite areas.

2.1.12 Review and approve the technical content of News Releases.

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No . ...A.1..._ IMPLEMENTATION CHECKLIST

• Page _ILof _2_L

- ----~----------------

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 9 of 15 Implemented Actions/Procedures 2.1.13 Maintain oversight of all emergency operations by performing the following every 30 minutes OR more often if needed:

A. Current station priorities (verify appropriate, discuss top 3 in detail)

B. Status of actions to address station priorities C. Verify with offsite agencies present in the EOF that their need for information is being met.

2.2 Emergency Classification 2.2.1 Direct the Technical Advisor to continually compare kno'Wil conditions with the EALs for possible changes in emergency classification using IAP-2, Emergency Action Levels.

ALERT 2.2.2 IF escalation to an ALERT emergency classification is appropriate, THEN:

A. Validate the change in emergency classification with the Shift Manager.

B. Announce the emergency classification change to the EOF.

Record Time Classification is declared:

c. Direct EOF staff to provide Part 1 Notification fact sheet for your signature in eight minutes.

NOTE: During a HAB Event the following action may be delayed until coordination with security and offsite Law Enforcement can be achieved.

NOTE: EPM has the responsibility for implementing on site protective actions.

D. Inform the EPM and SM of the escalation in emergency classification and direct them to perform:

1. Required site protective actions in accordance with

• EAP-8, Personnel Accountability

• EAP-10, Protected Area Evacuation

2. Appropriate plant announcements for event classification escalation.

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No. --11.._ IMPLEMENTATION CHECKLIST Page ~of ~

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 10 of 15 Implemented Actions/Procedures E. Perform a briefing with the EOF Staff providing details on the emergency classification.

F. IF the triggering event is a security event, THEN verify that press releases or other media products do NOT contain sensitive HAE-related information AND media products are reviewed by Local Law Enforcement prior to issuance.

SITE AREA 2.2.3 IF escalation to an SITE AREA EMERGENCY EMERGENCY classification is appropriate, THEN:

A. Validate the change in emergency classification with the Shift Manager.

B. Announce the emergency classification change to the EOF.

Record Time Classification is declared:

C. Direct EOF staff to provide Part 1 Notification fact sheet for your signature in eight minutes.

NOTE: During a HAB Event the following 2 actions may be delayed until coordination with security and offsite Law Enforcement can be achieved.

NOTE: EPM has the responsibility for implementing on-site protective actions.

D. Inform the EPM and SM of the escalation in emergency classification and direct them to perform:

1. Required site protective actions in accordance with

• EAP-8, Personnel Accountability,

• EAP-10, Protected Area Evacuation or EAP-11, Site Evacuation.

2. Appropriate plant announcements for event classification escalation.

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No. _il_ IMPLEMENTATION CHECKLIST Page ---1.J._of ~

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 11 of 15 J:mplemented Actions/Procedures E. Perform a briefing with the EOF Staff providing details on the emergency classification.

F. IF the triggering event is a security event, THEN verify that press releases or other media products do NOT contain sensitive HAE-related information AND media products are reviewed by Local Law Enforcement prior to issuance.

GENERAL 2.2.4 J:F escalation to a GENERAL EMERGENCY EMERGENCY classification is.appropriate, THEN:

A. Validate the change in emergency classification with the Shift Manager.

B. Announce the emergency classification change to the EOF.

Record Time Classification is declared:

c. Direct EOF staff to provide Part 1 Notification fact sheet for your signature in eight minutes, including Protective Action Recommendations. .

,)

D. Direct the Rad Assessment Coordinator to develop Protective Action Reconunendations in accordance with EAP-4C, Protective Action Recommendations.

NOTE: During a HAE Event the following 2 actions may be delayed until coordination with security and offsite Law Enforcement can be achieved NOTE: EPM has the responsibility for implementing on-site protective actions.

E. Inform the EPM and SM of the escalation in emergency classification and direct them to perform:

1. Required site protective actions in accordance with

• EAP-8, Personnel Accountability,

• EAP-10, Protected Area Evacuation or EAP-11, Site Evacuation.

2 . Appropriate plant announcements for event classification escalation.

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No. _n__ IMPLEMENTATION CHECKLIST Page ---2..Lof _2.a_

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 12 of 15 Implemented Actions/Procedures F. Perform a briefing with the EOF Staff providing details on the emergency classification.

G. Approve Protective Action Recommendations when provided by the Rad Assessment Coordinator.

H. Authorize KI for use by JAF personnel on a voluntary basis, in accordance with EAP-19, Emergency Use of Potassium Iodine (KI) -

I. IF the triggering event is a security event, THEN verify that press releases or other media products do NOT contain sensitive HAE-related information AND media products are reviewed by Local Law Enforcement prior to issuance.

J. IF in response to an emergency at either NMP or JAF, Oswego County implements Protective Actions that includes evacuation, sheltering and/or KI use, THEN implement protective.

actions for JAF personnel (protected area or site evacuation, accountability or KI) .

2.3 Off site Notifications NOTE: Initial notifications to local and State agencies are required to be initiated within 15 MINUTES of an upgrade to emergency classification or Protective Action Recommendation.

2.3.l Initial Notifications A. Direct the Offsite Communicator to perform notification in accordance with EAP-1.1, Offsite Notifications.

B. Review AND approve the Part 1 Notification Fact Sheet, for transmittal to local and State agencies.

c. Confirm that notifications have been completed.

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No. _Al_ IMPLEMENTATION CHECKLIST Page ~of ....£8-_

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 13 of 15 Implemented Actions/Procedures NOTE: NRC notification should be made concurrently or immediately following state and local notifications, but no later than one hour after a change in classification.

NRC notifications will be performed by the TSC ENS Communicator once the TSC has been activated.

D. IF TSC ENS Communicator is NOT available, THEN direct the EOF Communications Liaison to notify the NRC via the ENS phone line.

2.3.2 Follow-Up Notifications NOTE: Follow-Up Notifications to local and State agencies should be made:

• Within approximately 15 minutes of a significant change in plant conditions. I j

/ '

• Within approximately 15 minutes of a change in radiological release status.

• Approximately every 30 minutes unless above listed conditions change (or as requested by State and local authorities).

A. Direct the EOF Offsite Communicator complete and transmit appropriate forms to offsite agencies.

2.4 Protective Action Recommendations NOTE: Consider the following changes as triggers to review for potential changes in PARS:

• A change in classification level to General Emergency

• A changes to any Fission Product Barriers status

• Changes in release status or magnitude of release

• Changes in dose projections IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. No. --41._ IMPLEMENTATION CHECKLIST Page __lQ__of _a]_

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 14 of 15 Implemented Actions/Procedures

• Changes in meteorological conditions (wind shift I stability class) 2 .4 .1 Determine the appropriate Protective Action Reconunendation (PAR) in accordance with Procedure EAP-4C, Protective Action Recommendations.

2.4.2 IF there is a change in PAR not related to a change in classification, THEN ensure notifications are made within 15 minutes in accordance with section 2.3 of this checklist.

2.5 Personnel Protective Measures NOTE: The EPM has responsibility for directing actions for Protected Area or Site Evacuations and ensuring accountability of all onsite personnel.

For events with significant damage to the site when no announcement has been made ref er to EAP-8 Personnel Accountability for normal and alternate means to perform.

)

NOTE: During a HAB Event the following actions may be delayed until coordination with security and offsite Law Enforcement can be achieved.

NOTE: Emergency exposures limits greater than 5 Rem TEDE may be applicable for stopping a release, saving lives and/or protecting major equipment or large populations. Ensure actions have been considered which could avoid excess exposures.

2.5.1 IF requested by the Radiological Assessment Coordinator or the TSC Radiation Coordinator to approve emergency exposures, THEN review and approve request, if appropriate in accordance with EAP-15, Emergency Radiation Exposure Criteria and Control.

2.5.2 IF requested by the Radiological Assessment Coordinator or the Radiation Protection Coordinator to approve the issuance of radioisotope blocking agents (KI) for JAF emergency response personnel, THEN review and approve the request in accordance with EAP-19, Emergency Use of Potassium Iodide (KI).

IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev.* No. -11_ IMPLEMENTATION CHECKLIST Page --2J_of _2jL_

EOF EMERGENCY DIRECTOR EMERGENCY PLAN IMPLEMENTATION CHECKLIST Page 15 of 15 Implemented Actions/Procedures 2.6 Termination and Recovery NOTE: Planning for Recovery may begin prior to actual termination, as time and resources allow, see Termination and Recovery procedure for guidance.

Support Groups may be called and formed to assist the ERO with recovery planning; 2.6.1 Direct ERO staff to identify necessary recovery actions using forms and guidance in EAP-30, Emergency Termination and Transition to Recovery.

2.6.2 WHEN conditions begin to stabilize and/or improve, THEN consider event termination in accordance with EAP-30, Emergency Termination and Transition to Recovery.

2.7 Shift Turnover 2.7.1 WHEN contacted by an oncoming ED, THEN give a time when conditions would permit the turnover process.

2.7.2 WHEN conditions permit, THEN conduct a ' 1 turnover using EP-2-ALL, Essential '

Information Sheet.

2.7.3 Log the transfer in the Emergency Response Log.

2.7.4 Review the log and documents you completed during your shift for accuracy and completeness.

3.0 SITUATIONAL ACTIONS 4.0 CLOSEOUT ACTIONS 4.1 Provide your position binder to the EOF Manager to be replenished.

4.2 Assemble and/or direct the EOF Manger to assemble and organize all Emergency Director documentation pertaining to the event.

4.3 Direct (and participate in) post event critiques I reviews.

Print Name Date Time IAP-1 EMERGENCY PLAN ATTACHMENT 2 Rev. NO . ...AL IMPLEMENTATION CHECKLIST Page _JJL_of -2ft_

ENTERGY NUCLEAR OPERATIONS, INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURE MAINTAINING EMERGENCY PREPAREDNESS SAP-1 REVISION 25 EFFECTIVE DATE:

I I

• INFORMATIONAL USE *

• QUALITY RELATED *

• ADMINISTRATIVE

• PERIODIC REVIEW DUE DATE: June 2021

MAINTAINING EMERGENCY PREPAREDNESS SAP-1 REVISION

SUMMARY

SHEET REV. NO. CHANGE AND REASON FOR CHANGE 25 FULL REVISION

1. Updated cover sheet format for consistency with current standards.

2. Added a new section 4.11 - Qualified ERO Personnel, which states "A listing of qualified ERO personnel shall be entered into Merlin on a quarterly basis."

Reason: Program enhancement Rev. No. ~ Page ~2- of _1Q__

MAINTAINING EMERGENCY PREPAREDNESS SAP-1 TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE ************************************************ 4

2.0 REFERENCES

• * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

• 4 3.0 'IN:CT:CATl:NG EVENTS * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

• 5 4.0 PROCEDURE * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

• S s.o ATTAC:ED.mNTS * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

• 9 1 . EP JOB AID LOG 10 Rev. No . --22_ Page ~3- of ......11L.

MAINTAINING EMERGENCY PREPAREDNESS SAP-1 1.0 PURPOSE This procedure details the actions to be taken to maintain emergency preparedness at the JAFNPP site. This procedure also outlines the management controls used to ensure that corrective actions are implemented.

2.0 REFERENCES

2.1 Performance References None 2.2 Developmental References 2.2.1 AP-02.01 - PROCEDURE WRITING MANUAL 2.2.2 AP-02.03 - EMERGENCY PREPAREDNESS 2.2.3 AP-02.04 - CONTROL OF PROCEDURES 2.2.4 IAP CLASSIFICATION OF EMERGENCY CONDITIONS

2. 2. 5 SAP EMERGENCY COMMUNICATIONS TESTING 2.2.6 EN-EP-306 - DRILLS AND EXERCISES 2.2.7 EN-EP-308 EMERGENCY PLANNING CRITIQUES 2.2.8 EN-TQ-107 - GENERAL EMPLOYEE TRAINING 2.2.9 EN-TQ-200 - TRAINING OVERSIGHT PROGRAM 2.2.10 EN-TQ-201 - SYSTEMATIC APPROACH TO TRAINING PROCESS 2.2.11 EN-QV-109 - AUDIT PROCESS 2.2.12 JAFNPP Emergency Plan, Volume #1 2.2.13 JAFNPP Emergency Plan Implementing Procedures, Volumes 2 and 3 2.2.14 NUREG-0654, Criteria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in support of Nuclear Power Plants 2.2.15 10CFR50.54(t) 2.2.16 volume 10 Code of Federal Regulations, Part 50

2. 2. l7 Federal Register Notice, Vol. 70, NO. 16, dated Wednesday, January 26, 2005 regarding Emergency Planning criteria for co-located Licensees Rev. No. --2..5_ Page ~4- of -1.Q_

MAINTAINING EMERGENCY PREPAREDNESS SAP-1 3.0 INITIATING EVENTS NONE 4.0 PROCEDURE 4.1 EP Department Work Activities Master List 4 .1.1 EP should maintain a master list of all activities required as follows:

A. Required by regulation or cormnitted to by the Emergency Plan, site or fleet procedures B. Activities needed to maintain EP equipment and facilities in ready condition 4 .2 Training 4.2.1 The responsibility for training is shared by the Training Manager and the Emergency Planning Manager.

4.2.2 Initial training and periodic retraining shall be conducted in accordance with; A. EN-TQ-107 - GENERAL EMPLOYEE TRAINING B. EN-TQ-200 - TRAINING OVERSIGHT PROGRAM

c. EN-TQ-201 - SYSTEMATIC APPROACH TO TRAINING PROCESS D. EN-TQ-110 - EMERGENCY RESPONSE ORGANIZATION TRAINING E. SAP EMERGENCY PLAN ASSIGNMENTS 4.2.3 Training Manager - The Training Manager is responsible for the formal classroom training of individuals who have duties in the emergency response organization. The Training Manager is also responsible for specialized training services such as fire fighting, first aid and search/rescue.

The Training Manager is responsible for all documentation of fire brigade drills.

4.2.4 The Emergency Planning Manager is responsible for cormnunications, medical emergency (contaminated injury), radiological monitoring and radiation protection drills.

Rev. No. ~ Page ~5- of -1.Q._

MAINTAINING EMERGENCY PREPAREDNESS SAP-1 4.2.5 Formal training shall be documented using a Training Report (as defined by Training procedures) .

4.2.6 The Training Manager shall be responsible for maintaining all Emergency Plan training records.

This shall include records of all formal training sessions, drills and exercises.

4.3 Drills and Exercises Responsibility for the conduct of emergency planning drills and exercises rests with Emergency Planning Manager (EPM).

4.3.1 The development, conduct and documentation of drills and exercises is detailed in EN-EP-306 -

DRILLS AND EXERCISES.

4.3.2 Drills and exercises are critiqued in accordance with EN-EP-308 - EMERGENCY PLANNING CRITIQUES.

4.3.3 The Operations Department Fire Marshall maintains responsibility for the conduct of fire drills.

4.4 Program Audits Entergy Quality Assurance (QA) shall conduct an independent review of the emergency preparedness program in accordance with 10CFR50.54(t).

4.4.1 Findings and corrective action records shall be maintained by the QA department in accordance with their procedures and EN-QV-109 - AUDIT PROCESS.

4.4.2 In accordance with 10CFR50.54(t) Emergency Planning will transmit to Oswego County and New York State the part of the review involving the evaluation for adequacy of interface with state and county governments.

4.5 EP Job Aids NOTE:

Job aids are NOT intended as a substitute for a procedure or procedure change.

4.5.1 The EPM or designee shall authorize use of all emergency preparedness job aids 4.5.2 Job aids shall be marked with the assigned job aid number, effective date and a reference to the Rev. No. __£L_ Page ~6- of _lQ_

MAINTAINING EMERGENCY PREPAREDNESS SAP-1 originating/source document including its revision number, if applicable.

4.5.3 The EPM shall ensure that the annual review of open job aids is performed. Review includes the following:

A. Assessment of open job aids for continued use.

B. Verification that active job aids are current in content.

4.5.4 Attachment 1, EP Job Aid Log may be used to satisfy step 4.5.1.

4.6 Requirements for Co-Located Licenses.

4.6.1 The EPM shall verify that the following actions are planned and performed:

A. Conduct an exercise biennially (2 years) of the onsite emergency plan.

B. Participate quadrennially in an offsite biennial full or partial participation exercise.

C. Conduct emergency preparedness activities and interactions in the years between its participation in the of fsite full OR partial participation exercise with offsite authorities, to test and maintain interface among the affected State and local authorities and the licensee.

D. Co-located licensees shall also participate in emergency preparedness activities and interaction with offsite authorities for the period between exercises E. Conduct a hostile action exercise of its onsite emergency plan in each exercise cycle F. Participate in an offsite biennial full or partial participation hostile action exercise in alternating exercise cycles.

Rev. No. __22.._ Page ~7- of _lQ_

MAINTAINING EMERGENCY PREPAREDNESS SAP-1 4.7 Training and Drill Activities for Offsite *Agencies 4.7.1 On an annual basis, training should be offered to the Oswego County and New York State emergency disaster service organizations and may include:

• Review of JAF Site Emergency Plan or implementing procedures

• Classification of Emergencies/Emergency Action Levels

• Reporting Requirements

• Assessment and Protective/Corrective Actions

• Communication Networks 4.7.2 On an annual basis, training should be offered to the following offsite support organizations:

• Fire Departments within the 10 mile emergency planning zone

• Ambulance providers within the 10 mile emergency planning zone who could be expected to provide resources

• Local law enforcement (LLEA training is provided by Nuclear Security Department)

• The onsite emergency organization including the interface with the JAF Fire Brigade 4.7.3 On an annual basis, the following training should be offered to the Oswego and University Hospitals:

• Communications systems

• The onsite emergency organization including the interface between JAF Radiation Protection personnel, the local medical support personnel, and the radiation medicine consultants

• Radiological aspects of emergency medical treatment 4.8 Assessment of Emergency Response Facilities 4.8.1 ERFs will be assessed monthly by walkdowns in accordance with SAP-2 and SAP-3 Rev. No. ~ Page ~8- of _1.Q_

MAINTAINING EMERGENCY PREPAREDNESS SAP-1 4.9 Development of an EP Work Plan 4.9.1 The EPM shall designate the following using the EP Department staff:

• Drill/Exercise Coordinator

• ERO Coordinator

• Plan and Procedures Coordinator

• Emergency Response Facilities Coordinator

• Offsite Response Organization Coordinator 4.9.2 The EPM should perform the following action annually:

A. Develop an EP work Plan whose purpose is to schedule implementation of all requirements detailed in this procedure.

1. Work Tracking items should be initiated for each task identified in the EP Work Activities Master List.

4.10 Plan and Procedure Maintenance 4.10.1 Maintenance of the JAFNPP Emergency Plan and Implementing procedures consists of document control activities including distribution control, change control, procedure review, and cross reference review. Plan and procedure maintenance is in accordance with AP-02.03 - EMERGENCY PREPARDNESS and AP-02.04 - CONTROL OF PROCEDURES.

4.11 Qualified ERO Personnel 4 .11.1 A listing of qualified ERO personnel shall be entered into Merlin on a quarterly basis.

5.0 ATTACHMENTS

1. EP JOB AID LOG Rev. No . ---2.2_ Page _9_ of _lQ_

ATTACHMENT 1 Page 1 of 1 EP JOB AID LOG

• EPM. Signature .. *

• Date

• Expiration D_ate *. .*.. Datei,:;:~f,':; ~

• ,Number ' * * *. *oate

• Description of Posted Operator Aid *.. * * *posted ..'* * .. (If as~ign~d): ... Removed:**

SAP-1 MAINTAINING EMERGENCY PREPAREDNESS ATTACHMENT 1 Rev. No. _1..2.._ Page 10 of 10

AlTACHMENT 9.1 1 OCFR50.54(q) SCREENING SHEET1 OF3 Procedure/Document Number: IAP-1 I Revision: 47 Equipment/Facility/Other: JAF

Title:

Emergency Plan Implementation Checklist Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan): - Section 2.2.4.J - Add "IF in response to an emergency at either NMP or JAF, Oswego County implements Protective Actions that includes evacuation, sheltering and/or KI use, THEN implement protective actions for JAF personnel (protected area or site evacuation, accountability or KI)."

Because there was direction in Attachment 1 for the Control Room but not in Attachment 2 for the EOF Emergency Director, to give additional guidance for implementing protective .actions during an emergency at NMP that includes evacuation, sheltering and/or KI.

Part II. Activity Previously Reviewed? DYES cg] NO Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3) Continue to Evaluation is next part Alert and Notification System Design Report? NOT required.

Enter If YES, identify bounding source document number/approval referenc~ and justification ensure the basis for concluding the source document fully bounds the below and complete Part proposed change is documented below: VI.

Justification:

0 Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN*Ll-100)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

Screening.

APPLICABILITY CONCLUSION

[81 If there are no controlling change processes, continue the 50.54(q)(3) Screening. ,

0 One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

0 One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT required. Identify controlling change processes below and complete Part VI.

EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET20F3 Procedure/Document Number: IAP-1 I Revision: 47 Equipment/Facility/Other: JAF

Title:

Emergency Plan Implementation Checklist CONTROLLING CHANGE PROCESSES 10CFR50.54(q)

Part IV. Editorial Change DYES [81 NO 50.54{q)(3) Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.

Justification: Enter justification and complete Part VI.

Part V. Emergency Planning Element/Function Screen (Associated 10CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NU REG*

0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1] D

2. The response organization has the staff to respond and to augment staff on a continuing basis (24n D staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2) D

4. The process for timely augmentation of onshift staff is established and maintained. [2] D

5. Arrangements for requesting and using off site assistance have been made. [3] D

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] D

7. A standard scheme of emergency classification and action levels is in use. [4] D

8. Procedures for notification of State and local governmental agencies are capable of alerting them of D the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt D instructions to the public within the plume exposure pathway. [5)

10. The public ANS meets the design requirements of FEMA*REP-10, Guide for Evaluation of Alert and u Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response u organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6] D

13. Emergency preparedness information is made available to the public on a periodic basis within the D plume exposure pathway emergency planning zone (EPZ}. [7)

14. Coordinated dissemination of public information during emergencies is established. [7] D

15. Adequate facilities are maintained to support emergency response. [8) D

16. Adequate equipment is maintained to support emergency response. [8) D

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] D

18. A range of public PARs is available for implementation during emergencies. [1 O] D EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET30F3 Procedure/Document Number: IAP*1 I Revision: 47 Equlpment/Facillty/Other: JAF

Title:

Emergency Plan Implementation Checklist

19. Evacuation lime estimates for the population located in the plume exposure pathway EPZ are LJ available to support the formulation of PARs and have been provided to State and local governmental authorities. [10]

20. A range of protective actions is available for plant emergency workers during emergencies, including LJ those for hostile action events.[10)

21. The resources for controlling radiological exposures for emergency workers are established. [11] LJ

22. Arrangements are made for medical services for contaminated, injured individuals. [12] u

23. Plans for recovery and reentry are developed. [13) . u

24. A drill and exercise program {including radiological, medical, health physics and other program u areas) is established. (14)

25. Drills, exercises, and training evolutions that provide performance opportunities lo develop, u maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14)

26. Identified weaknesses are corrected. (14] u

27. Training is provided to emergency responders. (15] u 2B. Responsibility for emergency plan development and review is established. [16] u

29. Planners responsible for emergency plan development and maintenance are properly trained. [16] u APPLICABILITY CONCLUSION lXI If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis lor conclusion below and complete Part VI.

0 If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION The above changes give the EOF Emergency Director additional guidance for implementing protective actions during an emergency at NMP that includes evacuation, sheltering and/or KL The Control Room has direction in their Attachment but the Emergency Director did no1 have the same guidance. This proposed change does not change the intent or purpose of the procedure, change any facilities, equipment or processes, or affect any planning standard elements. This proposed change does not require a change to the Emergency Plan. No further evaluation is required for this change.

Part VI. Signatures:

Preparer Name (Print) Preparer Signature Date:

Meflonie Christman fYn~ ~ 06/0212016 (Optional) Reviewer Name (Print) Re.Miwer Signature Date:

NJA Reviewer Name (Print) Reviewer Signature Date:

u~1/J.. (<..~~ ~~ ~-l.-/G:.

Nuclear EP Project Manager Approver Name (Print)

James D. Jones EP manager or designee AF"ra ...,

Date:

l,*ll*lO{~

EN-EP-305 REV 3

AlTACHMENT 9.1 1 OCFR50.54(q) SCREENING SHEET1 OF4 Procedure/Document Number: SAP-1 I Revision: 25 Equipment/Facility/Other: JAF

Title:

Maintaining Emergency Preparedness Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

1. Updated cover sheet format for consistency with current standards.

2. As a program enhancement, EP added a new section 4.11 - Qualified ERO Personnel, which states "A listing of qualified ERO personnel shall be entered into Merlin on a quarterly basis."

Part II. Activity Previously Reviewed? DYES 181 NO Is this activity fully bounded by an N RC approved 1 O CFR 50.90 submittal or 50.54{q)(3) Continue to Evaluation is next part Alert and Notification System Design Report? NOT required.

Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and complete Part proposed change is documented below: VI.

Justification: ..

D Boundina document attached (ootio~al)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

Screenina.

APPLICABILITY CONCLUSION 181 If there are no controlling change processes, continue the 50.54(q)(3) Screening.

D One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54( q)(3) Screening for that portion  : "

of the activity. Identify the applicable controlling change processes below.

D One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT required. Identify controlling change processes below and complete Part VI.

CONTROLLING CHANGE PROCESSES 10CFR50.54(q)

Part IV. Editorial Change DYES 181 NO 50.54(q)(3) Continue tone' Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.

Justification: Enter justification and complete Part VL EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET20F4 Procedure/Document Number: SAP-1 I Revision: 25 Equipment/Facility/Other: JAF

Title:

Maintaining Emergency Preparedness Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. (1] D

2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 staffing) in accordance with the emergency plan. [1]

D

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] D

4. The process for timely augmentation of onshift staff is established and maintained. [2] D

5. Arrangements for requesting and using off site assistance have been made. [3] D

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] D

7. A standard scheme of emergency classification and action levels is in use. (4] D

8. Procedures for notification of State and local governmental agencies are capable of alerting them of D the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt D instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response D organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6] D

13. Emergency preparedness information is made available to the public on a periodic basis within the u plume exposure pathway emergency planning zone (EPZ). (7]

14. Coordinated dissemination of public information during emergencies is established. [7] D

15. Adequate facilities are maintained to support emergency response. [8] u

16. Adequate equipment is maintained to support emergency response. [8] D

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] D

18. A range of public PARs is available for implementation during emergencies. (10] 0

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are D available to support the formulation of PARs and have been provided to State and local governmental authorities. [1 O]

20. A range of protective actions is available for plant emergency workers during emergencies, including u those for hostile action events.[10]

EN-EP-305 REV 3

ATTACHMENT 9.1 1 OCFR50.54(q) SCREENING SHEET30F4 Procedure/Document Number: SAP-1 I Revision: 25 Equipment/Facility/Other: JAF

Title:

Maintaining Emergency Preparedness

21. The resources for controlling radiological exposures for emergency workers are established. [11] D

22. Arrangements are made for medical services for contaminated, injured individuals. [12] D

23. Plans for recovery and reentry are developed. [13) D

24. A drill and exercise program (Including radiological, medical, health physics and other program D areas) is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, u maintain, and demonstrate key skills are assessed via a formal critique process In order to Identify weaknesses. [14)

26. Identified weaknesses are corrected. [14] D

27. Training is provided to emergency responders. [15] u

28. Responsibility for emergency plan development and review is established. [16) u

29. Planners responsible for emergency plan development and maintenance are properly trained. [16] D APPLICABILITY CONCLUSION

[8) If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI.

D If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION

1. Updated cover sheet format for consistency with current standards. There are no applicable Emergency Planning Element/Functions affected by this change. The change does not add, delete or modify a process, meaning or intent of a description, or change facilities or equipment. No further evaluation is required.

2. As a program enhancement, EP added a new section 4.11 - Qualified ERO Personnel, which states "A listing of qualified ERO personnel shall be entered into Merlin on a quarterly basis." This change will ensure that records are kept up to date on qualified ERO personnel in Merlin. Emergency Preparedness continues to be maintained. There are no applicable Emergency Planning Element/Functions affected by this change.

The change does not add, delete or modify a process, meaning or intent of a description, or change facilities or equipment. No further evaluation is required.

EN-EP-305 REV 3

ATTACHMENT9.1 10CFR50.54(q) SCREENING 5HEET40F4 Procedure/Document Number: SAP-1 I Revision: 25 Equipment/Facility/Other: JAF

Title:

Maintaining Emergency Preparedness Part VI. Signatures:

Preparer Name (Print)

Mellonie Christman (Optional) Reviewer Name (Print)

Y"Warer Sign~ture

}'Ch.xi~

Re,lewer Signature

. v .

J Date:

6-02-2016 Date:

~/A Reviewer Name (Print) Reviewer Signature Date:

Uo..o:>~& K. ~v.J'<'..~JV~

Nuclear EP Project Manager Wi:bo* . --- 0 &.- '2..-( Co Date:

F'"{:::;,-

Approver Name (Print)

James 0. Jones 1,-l(-Jl>lft EP manager or designee EN-EP-305 REV 3

NUCLEAR NON*QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 1OF29 OPERATIONS SUPPORT CENTER OSC) OPERATIONS Procedure Contains NMM ECH eB REFLIB Forms: YES 0 NO Procedure Revision T e: New D NON-Editorial 1:8] Editorial D TC D Cancellation D HQN Dean Burnett Mary Ann Wilson Effective Procedure Owner: Governance Owner:

Director, Emergency Director, Emergency Date

Title:

Title:

Programs Programs Site: Site:

6/14/2016 HQN HQN Site Site Procedure Champion Title ANO NA NA BRP N/A N/A CNS N/A N/A GGNS Jeffrey Seiter Manager, EP IPEC Lori Glander Manager, EP JAF James Jones Manager, EP PLP Dan Malone Manager, EP PNPS NIA NIA RBS Tim Schenk N/A VY N/A N/A W3 N/A NIA HQN Tim Garvev Proiect Manaqer, EP For site implementation dates see ECH eB REFLIB using site tree view (Navigation panel)

Site and NMM Procedures Canceled or Superseded By This Revision Process Applicability Exclusion: All Sites: D Specific Sites: ANO D BRP D GGNS D IPECl:8] JAF r8l PLP r8l PNPSO RBS r8l VY D W3 D Change Statement Revision 3:

• Deleted Palisades Commitment CMT932002114

• Corrected binder name referenced for use by the Work Control Coordinator.

• Clarified steps in the Work Control Coordinator, Mechanical and Electrical/l&C Coordinator, and the Rad/Chem Coordinator checklists regarding use of WebEOC, EP-4-ALL and EP-6-ALL.

Associated PRHQN #: PR-PRHQN-2016-00141 I Procedure Writer: T. Garvey Contains Proprietary Information: YES D NO r8l

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 20F 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS TABLE OF CONTENTS Section 1.0 PURPOSE ............................................................................................ 3

2.0 REFERENCES

..................................................................................... 3 3.0 DEFINITIONS ...............................~ ....................................................... 3 4.0 RESPONSIBILITIES ............................................................................. 3 5.0 DETAILS ............................................................................................... 3 6.0 INTERFACES ..........................................................;............................ 4 7.0 RECORDS ............................................................................................ 4 8.0 SITE SPECIFIC COMMITMENTS ........................................................ 4 9.0 ATTACHMENTS ................................................................................... 5 ATTACHMENT 9.1 OSC MANAGER .................................................................... 6 ATTACHMENT 9.2 OSC OPERATIONS SUPPORT .............................................. 13 ATTACHMENT 9.3 WORK CONTROL COORDINATOR .......................................... 16 ATTACHMENT 9.4 MECHANICAL AND ELECTRICAlil&C COORDINATORS ............ 20 ATTACHMENT 9.5 RAD/CHEM COORDINATOR ................................................. 23 ATTACHMENT 9.6 OSC LOG KEEPER .............................................................. 28

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 3 OF 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS 1.0 PURPOSE NOTE This procedure may be used for activation and operations at the backup/alternate OSC as applicable.

[1] To describe the activation and operation of the OPERATIONS SUPPORT CENTER (OSC)

2.0 REFERENCES

[1] Site Emergency Plans

[2] Site Emergency Plan Implementing Procedures 3.0 DEFINITIONS

[1] Activation - Actions taken to staff and setup an emergency response facility to make it operational. Actions include but are not limited to notification of emergency personnel, equipment setup and equipment operability testing.

[2] Operational - Status of an emergency facility declared by the appropriate facility manager upon determining that the facility is adequately staffed and equipment is setup and available to assume/perform the emergency functions assigned to that facility.

4.0 RESPONSIBILITIES

[1] The entire staff of the Operations Support Center (OSC) is responsible for activation and operation of the facility using this procedure, their position specific checklists and applicable site specific performance aides.

5.0 DETAILS NOTE The actions of this procedure may be completed in any sequence, however, the sequence presented is recommended.

[1] The OSC is required to be activated at the declaration of an Alert, Site Area Emergency and General Emergency.

[2] The OSC Manager follows the instructions outlined in Attachment 9.1, OSC Manager .

[3] The OSC Operations Support follows the instructions outlined in Attachment 9.2, Operations Support.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 40F 29 OPERATIONS SUPPORT CENTER {OSC) OPERATIONS

[4] The Work Control Coordinator follows the instructions outlined in Attachment 9.3, Work Control Coordinator.

[5] The Mechanical and Electrical/l&C Coordinators follow the instructions outlined in Attachment 9.4, Mechanical and Electrical/l&C Coordinators

[6] The Rad/Chem Coordinator follows the instructions outli.ned in Attachment 9.5, Rad/Chem Coordinator.

[7] The OSC Log Keeper follows the instructions outlined Attachment 9.6, OSC Log Keeper.

[8] Other shift personnel and additional support personnel assemble at the OSC to provide assistance as necessary.

6.0 INTERFACES

[1] EN-AD-103, Document Control & Records Management Programs

[2] EN-EP-601, Corporate Emergency Center Operations

[3] EN-Ll-102, Corrective Action Process

[4] EN-NS-102, Fitness for Duty Program

[5] EN-FAP-OM-012, Notifications of Off-Normal Situations I Corporate Duty Manager Responsibilities

[6] EN-EP-609, Emergency Operations Facility (EOF) Operations

[7] EN-EP-610, Technical Support Center (TSC) Operations 7.0 RECORDS Any logs or forms completed by members of the ERO during an actual declared emergency are permanent quality records and are maintained in accordance with EN-AD-103.

8.0 SITE SPECIFIC COMMITMENTS Commitment Number Step Site Document or Reference GGN8 GNR0-97/00113.97-15-01.ITEM1 P-33188 GGN8 GGNS Emergency Plan 7.3.2 81 P-28915 5.0 [8] GGN8 GGNS Emergency Plan 7.3.2 84 P-28916 GGNS GGNS Emergency Plan 7.3.2 86 P28917 RBS P-15578

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 50F29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS 9.0 ATTACHMENTS 9.1 OSC Manager 9.2 Operations Support 9.3 Work Control Coordinator 9.4 Mechanical and Electrical/l&C Coordinator 9.5 Rad/Chem Coordinator 9.6 OSC Log Keeper

NUCLEAR NON*QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 6 OF 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT9.1 OSCMANAGER Sheet 1 of7 OSC Manager Name: _ _ _ _ _ _ _ _ _ _ _ _~--- Date:- - - -

1.0 Initial Responsibility/Activity Notes NOTE The ERO should take appropriate actions necessary to mitigate the event regardless of facility manning or status.

1.1 Initial Orientation A. Upon arrival at the OSC:

1. Card in the accountability readers and/or sign in on EP-7-ALL, Facility Sign-In/Accountability Form

2. Sign in on the OSC staffing board

3. Obtain the OSC Manager Binder & ID Badge.

B. Review electronic displays, plant data, status boards and any other available information to become familiar with current plant conditions.

C. Obtain a briefing from the Emergency Plant Manager (EPM):

1. Plant conditions

2. Equipment Status

3. Actions being taken (any repair/Operations personnel currently in the field)

4. Team requirements for actions planned but not yet initiated.

1.2 Assume the Position of OSC Manager A. IF the OSC has NOT been declared operational, THEN :

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 7 OF 29 OPERATIONS SUPPORT CENTER {OSC) OPERATIONS ATTACHMENT9.1 OSCMANAGER Sheet 2 of 7 Initial Responsibility/Activity (cont.) Notes NOTE:

Typical minimum staffing needed to declare OSC Operational. The Site's staffing requirements may differ as needed to address site specific requirements.

• OSC Manager

• Rad/Chem Coordinator

• Maintenance (craft), RP and Chemistry personnel (the appropriate staff to perform the facilities key functional areas for the event).

NOTE:

During a Security Event only personnel and facilities necessary to mitigate the

~ -- -<',

emergency situation should be activated. The OSC may be declared operational without all key members being present. This will be determined by the most senior person in the facility.

1. Verify the minimum OSC staffing is present.

(a) IF additional personnel are needed or positions are vacant THEN direct someone to fill vacancies in accordance with EP-10-ALL, Filling an ERO Vacancy During Facility Activation I Operation Form.

2. Ensure communication is available for the dispatching of teams via verbal concurrence by the Work Control Coordinator or the Mechanical and/or the Electrical/l&C Coordinator.

3. Ensure communication is available to the Control Room via verbal concurrence by the Operation Support personnel.

4. Ensure radiological monitoring capabilities are available in the OSC via verbal concurrence by the Rad/Chem Coordinator.

5. Ensure the OSC is ready to dispatch required teams and maintain radiological onsite assessment.

6. When the OSC is ready, contact the Control Room and request a complete listing of personnel currently performing tasks from the Control Room.

7. Ensure the Control Room listing of personnel/tasks is provided to the Work Control Coordinator or the Mechanical and/or Electrical/l&C Coordinator.

NUCLEAR NON*QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 80F 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATIACHMENT9.1 QSC MANAGER Sheet3 of 7 Initial Responsibility/Activity (cont.) Notes

8. WHEN minimum staffing for the OSC is met AND Steps 2 through 7 above are complete, THEN declare the OSC operational and record in WebEOC or on EP-3-ALL, Log Sheet Form.

9. Make an announcement to the OSC and inform the CR, TSC and EOF that the OSC is operational.

10. Consider assignment and preparation of a search and rescue team to expedite dispatch if needed.

11. Perform an initial briefing for the OSC staff using EP-2-ALL, Essential Information Form.

B. IF relieving another OSC Manager THEN perform a formal turnover with the current OSC Manager.

1. Obtain the OSC Manager's position binder/badge and review any documents used.

2. Review facility log.

3. Obtain a briefing from tile acting OSC Manager on the emergency, plant conditions and any actions that have been completed or are in progress.

4. Relieve the current OSC Manager.

5. Announce to the OSC, TSC, CR, and EOF that you are now the OSC Manager.

2.0 Continuous Responsibility/Activity 2.1 Direct the activities of the OSC A. Coordinate and/or prioritize assessment and corrective actions with the TSC.

B. Ensure work task priorities are being maintained.

C. Keep OSC Coordinators updated on pending assignments.

D. IF multiple pre-assignment briefs are to occur simultaneously, THEN instruct the Coordinators to use other areas of the OSC to conduct briefings.

E. Ensure OSC staff members are following appropriate procedures.

NUCLEAR NON-QUALITY RELATED EN-EP*611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 90F29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT9.1 OSC MANAGER Sheet4 of7 Continuous Responsibility/Activity (cont.) Notes 2.2 Maintain personnel accountability in the OSC A. Ensure all ERO members reporting to the OSC swipe their Security Badge at one of the Accountability Card Readers or sign in on EP-7-ALL, Facility Sign-In/Accountability Form.

B. IF you leave the area, THEN:

1. Assign the Work Control Coordinator to fulfill your responsibility.

2. Upon your return, obtain a briefing from the Work Control Coordinator on any events that occurred while you were away.

2.3 Maintain Adequate OSC Staffing A. Ensure an adequate number of personnel are available for Repair and Corrective Action Teams.

B. Coordinate shift scheduling with EOF Admin and Logistics Coordinator.

1 With assistance from OSC Coordinators, ensure those personnel required for the second shift are available and do not have other emergency response duties.

2. Ensure second shift personnel are notified of their assignments and time of shift turnover.

C. Upon direction from the ED reduce staffing per shift schedule.

D. Continually assess the need for additional personnel.

E. Coordinate with the EOF Administration and Logistics Coordinator for call-out of additional staff as required.

2.4 Maintain a Log A. Ensure the OSC Log Keeper is maintaining a log:

1. Log when you assume the duties of the OSC Manager and OSC activation.

2. Log significant decisions and important details used to make decisions.

3. Log significant communications with other members of the ERO and offsite officials.

4. Log the dispatch of teams.

B. Periodically review log for accuracy.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 100F 29 OPERATIONS SUPPORT CENTER OSC) OPERATIONS ATIACHMENT9.1 OSCMANAGER Sheet 5 of7 Continuous Responsibility/Activity (Cont'd) Notes 2.5 Assign an individual to monitor inter-facility communications between the Control Room, TSC and EOF as necessary 2.6 Prepare and Facilitate Facility Briefings A. Coordinate with the TSC Manager, as appropriate, to schedule periodi facility briefings:

1. Briefings should be every 30-60 minutes or as conditions change.

2. Make an announcement approximately 5 minutes before the actual briefing that a briefing will be conducted, if possible.

B. Use EP-14-ALL, Briefing Form and EP-2-ALL, Essential Information Form for periodic briefs. '\

C. Direct key staff to provide information needed for the briefing, if necessary.

D. Conduct briefing and ensure information provided in the briefing is captured and appropriately documented by the OSC Log Keeper.

2. 7 Supervise the activities of the OSC Coordinators and team personnel.

A. The EPM is responsible for overall control of the onsite emergency response. Obtain EPM concurrence prior to directing any actions that may affect the operability of a plant system.

B. Coordinate activities of operations personnel in the OSC with the Operations Support and the Control Room.

C. Inform the EPM immediately of any operations teams requested to be dispatched from the OSC by the Control Room.

D. Maintain adequate personnel and material resources for the onsite response.

Assign tasks to OSC Coordinators. EP-6-ALL, Team Tracking Form, may be used to track task assignments if WebEOC is unavailable.

F. Keep the Work Control Coordinator, OSC Coordinators, and Team Members informed of the overall focus of the emergency, task priorities and existing radiological conditions.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 11OF29 OPERATIONS SUPPORT CENTER OSC) OPERATIONS ATTACHMENT 9.1 OSCMANAGER Sheet 6 of7 Continuous Responsibility/Activity (cont.) Notes G. Remind the Work Control Coordinator and OSC Coordinators to maintain an awareness of the activities and concerns of OSC team members.

H. Verify that the Work Control Coordinator is maintaining current status as new tasks are assigned, old tasks completed, and as priorities are changed.

I. Interact with the OSC Coordinators and clarify any concerns/questions regarding plant or equipment status.

J. Prioritize team dispatch with EPM.

K. Ensure the EPM/CR/EOF ED are notified when the team(s) are dispatched.

L. Coordinate development of emergency repair and corrective actions with the TSC Manager and the Ops Support personnel.

2.8 Request assistance from the EOF Administration and Logistics Coordinator for materials and supplies not available on site as required.

2.9 Obtain approval from the EPM prior to deviating from any existing plant procedure dealing with changing plant configuration or personnel safety.

2.10 Obtain approval from the EPM prior to performing an action that would normally require a procedure but no procedure exists.

2.11 Ensure timely dispatch of search and rescue teams.

A. Coordinate the search and rescue activities in accordance with site specific procedures.

B. Instruct search and rescue teams not to move an incapacitated victim without a Medical Representative or qualified First Responder unless the potential harm from radiation or ot_her hazards outweighs the potential harm of moving the victim.

2.12 Inform the EPM of changing situations in the plant based on information received from teams out in the field.

2.13 !E_conditions require an emergency radiation exposure and/or issuance of Kl, THEN obtain EPM approval prior to the emergency radiation exposure and/or issuance of Kl to OSC personnel.

A. Use EP-8-ALL, Kl Instructions/Briefing Form if required.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 12 OF 29 OPERATIONS SUPPORT CENTER (OSC} OPERATIONS ATTACHMENT9.1 QSC MANAGER Sheet 7 of 7 Continuous Responsibility/Activity (cont'd.) Notes 2.14 Additional/Long Term Emergency Response A. Support/coordinate with the Administration and Logistics Coordinator to ensure that manpower planning is being conducted to provide for response efforts over an extended period.

B. Depending upon the duration of the emergency, coordinate with the Administration and Logistics Coordinator to make arrangements for food and potable water delivery to all emergency response centers, including off-site teams.

2.15 Evacuation of OSC A. IF it becomes necessary to evacuate or relocate the OSC, THEN notify the EPM, EOF and Control Room.

B. Ensure OSC staff completes the following:

1. Bring their position books and any other required documents.

2. Bring any required equipment - radios, satellite phones, etc.

C. Refer to the applicable site specific performance aides for guidance regarding set up and operations of the backup/alternate OSC 3.0 Closeout Activity 3.1 Direct OSC personnel to return all equipment to proper storage locations.

3.2 Collect all documentation:

A. Direct OSC staff to verify that logs, forms and other documentation are complete.

B. Verify that all repairs performed by OSC Teams which deviated from normal station procedures are properly documented, so that necessary actions can be taken for continuous plant operations or plant recovery operations.

3.3 Provide all logs and records to the EP Manager upon termination of the emergency.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 13 OF 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.2 OSC OPERATIONS SUPPORT Sheet 1of3 Operations Support Name:_ _ _ _ _ _ _ _ _ _ _ _ _ __ Date: _ _ __

1.0 Initial Responsibility/Activity* Notes 1.1 Initial Orientation A. Upon arrival at the OSC:

1. Card in the accountability readers and/or sign in on EP-7-ALL, Facility Sign-In/Accountability Form

2. Sign in on the OSC staffing board

3. Obtain the Operations Support Binder & ID Badge B. Review electronic displays, plant data, status boards and any other available information to become familiar with current plant conditions.

C. Obtain a briefing from the OSC Manager:

1. Plant conditions

2. Equipment Status

3. Actions being taken (any repair/Operations personnel currently in the field)

4. Team requirement for actions planned but not yet initiated.

1.2 Assume the position of Operations Support A. Track the dispatching of the non-license operators from the Control Room until released to the OSC by establishing communications with the Control Room.

B. Report your readiness to the OSC Manager when prepared to assume the Operations Support position.

C. IF relieving another Operations Support person THEN perform a formal turnover.

1. Review current logs.

2. Obtain a briefing from the current Operations Support personnel on the emergency, radiological conditions and any actions that have been completed or are in progress.

3. Relieve current Operations Support person.

4. Inform OSC Manager and staff that you are now the Operations Support person.

NUCLEAR NON*QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 14 OF 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATIACHMENT 9.2 OSC OPERATIONS SUPPORT Sheet 2 of 3 2.0 Continuous Responsibility/Activity NOTES 2.1 Inform an OSC Coordinator and/or the OSC Manager when temporarily leaving the work area.

A. IF you are leaving the OSC THEN:

1. Inform an OSC Coordinator and/or OSC Manager when you leave, where you are going and when you expect to return.

2. Inform an OSC Coordinator and/or OSC Manager when you return.

• B. Upon return, obtain a briefing on any events, which have occurred while away.

2.2 Use WebEOC, or if unavailable, EP-3-ALL, Log Sheet Form, to maintain a log of activities.

A. Record the time you assume position of Operations Support person.

B. Record Operations Team activities undertaken with information on repairs performed and pending actions to ensure repairs are completed.

C. Record key communications received and sent and associated time.

2.3 Assist the Control Room and OSC Manager in planning and preparing for any Operations activities needed to return the plant to a safe condition.

A. Establish communications with the Control Room.

B Keep the Control Room informed of field team activities currently underway or that are planned.

C. Coordinate operations and repair activities with the Control Room.

D. Provide operational guidance to other OSC staff and in-plant teams.

2.4 Participate in Team dispatch and field operations:

A. Choose Operations personnel who are best qualified to conduct assigned task(s)

NUCLEAR NON*QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 15 OF 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.2 OSC OPERATIONS SUPPORT Sheet3 of 3 Continuous Responsibility/Activity (cont.) Notes NOTE:

For urgent Operations requirements, EP-5-ALL, Team Dispatching Form, may be completed after team dispatch.

B. Use EP-5-ALL, Team Dispatch Form, to prepare and document team assignments. Ensure each team dispatched has a copy of the Team Dispatching Form.

C. Ensure the Team is properly equipped to conduct repairs, including procedures, drawings, tools and repair parts.

D. Participate in Team briefings to ensure team members understand assigned task and understand the hazard to be encountered.

Briefings should be clear, concise, accurate and prompt.

)

E. Ensure responsibility for dispatch of Operations Teams is turned over to the OSC as soon as possible (e.g. no later than at Site Area Emergency declaration).

F. Keep the OSC Manager aware of all teams' progress.

G. Maintain communication capability (i.e. phone, radio) and work with the Work Control Coordinator while the team is in the field to answer any question that may arise concerning task.

H. Debrief Operations team members when they return and ensure actions are properly documented.

I. Report results and status of team efforts to the OSC Manager as necessary.

J. Assist the OSC Manager as necessary.

3.0 Closeout Responsibility/Activity 3.1 Assist OSC personnel to return equipment to proper storage locations.

3.2 Review all documentation the Operations Support person(s) maintained during the emergency.

A. Ensure logs, forms and other documentation are complete.

B. Ensure all repairs performed by OSC Operations Teams that deviated from normal station procedures are properly documented.

• *c~* Provide all logs and records to the OSC Manager upon termination of the emergency.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 16 OF 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.3 WORK CONTROL COORDINATOR Sheet 1of4 Work Control Coordinator Name: -~~~~~~~~~~~-

Date:- - - -

1. 0 Initial Responsibility/Activity Notes 1.1 Initial Orientation A. Upon arrival at the OSC:

1. Card in the accountability readers and/or sign in on EP-7-ALL, Facility Sign-In/Accountability Form

2. Sign in on the OSC staffing board

3. Obtain the Work Control Coordinator Binder & ID Badge B. Review electronic displays, plant data, status boards and any other available information to become familiar with current plant conditions.

C. Obtain a briefing from the OSC Manager:

1. Plant conditions

2. Equipment Status

3. Actions being taken (any repair/Operations personnel currently in the field)

4. Team requirements for actions planned but not yet initiated.

1.2 Assume the position of Work Control Coordinator A. Obtain a briefing from the OSC Manager on the status of any personnel or teams currently in the field.

B. Coordinate the formation, briefing/debriefing, of dispatched teams.

Establish communications with field personnel and establish that the OSC has now taken control of their actions.

C. Report your readiness to the OSC Manager when prepared to assume the Work Control Coordinator position.

D. IF relieving another Work Control Coordinator, THEN perform a formal turnover with the current Work Control Coordinator:

1. Review current log(s).

2. Obtain briefing from current Work Control Coordinator on the emergency and any actions that have been completed or are in progress.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 17 OF 29 OPERATIONS SUPPORT CENTER OSC) OPERATIONS ATTACHMENT 9.3 WORK CONTROL COORDINATOR Sheet 2 of 4 Initial Responsibility/Activity (cont.) Notes

3. Relieve current Work Control Coordinator.

4. Inform OSC Manager and staff that you are now the Work Control Coordinator.

2.0 Continuous Responsibility/Activity 2.1 Inform an OSC Coordinator and/or the OSC Manager when temporarily leaving the work area.

A. IF you are leaving the OSC THEN:

1. Inform an OSC Coordinator and /or OSC Manager when you leave, where you are going and when you expect to return. (For accountability purposes)

2. Inform an OSC Coordinator and/or OSC Manager when you return.

B. Upon return, obtain a briefing on any events, which have occurred while away.

2.2 Use WebEOC, or if unavailable, EP-11-ALL, Repair & Corrective Action Assignment Form, EP-3-ALL, Log Sheet Form, and EP-6-ALL, Team Tracking Form, to maintain a log of significant items/tracking of the teams, including:

A. Time you assume position of Work Control Coordinator.

B. Teams dispatched from the OSC including updates when the team status changes (i.e. priority, deployment status, task outcome).

2.3 Maintain communications with the TSC regarding team assignments and priority.

2.4 Issue radios (and headsets as needed) to OSC Coordinators and teams being dispatched.

NOTE:

The headphone would normally be used when workers are dressed in Protective Clothing and/or respirators.

A. Ensure that charged batteries are installed in portable radios.

B. Ensure communication methodology is established and the proper (radio) communications protocol is utilized.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 18 OF 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.3 WORK CONTROL COORDINATOR Sheet 3 of 4 Continuous Responsibility/Activity (cont.) Notes C. Remind personnel using radios to check operability of their radio when entering any area for which communications might be suspect. .

2.5 Ensure ongoing accountability (unless directed otherwise) for OSC personnel.

NOTE:

A computer spreadsheet may be used in place of EP-6-ALL, Team Tracking Form, and EP-4-All, Exposure Authorization Form, to keep records of teams sent into the field from the OSC.

A. Use EP-5-ALL, Team Dispatching Form, to prepare and document team assignments. Ensure each team dispatched has a copy of the Team Dispatching Form.

B. Track all individuals leaving OSC in WebEOC or on EP-6-ALL, Team Tracking Form.

1. IF the computer spreadsheet is used THEN printout copies of the spreadsheet to maintain hard copy records of team activities.

C. IF individuals are going to be receiving emergency radiation exposure THEN track radiation exposures on EP-4-ALL, Exposure Authorization Form.

D. Inform the OSC Manager immediately of any missing personnel.

E. IF anyone is unaccounted for THEN assist in search and rescue operations utilizing teams.

2.6 Monitor the activities of the team personnel in the field.

A. Keep informed on team mission priorities

1. The OSC Manager will inform you of task priorities.

2. Track and communicate assigned priorities.

3. Continually remind OSC personnel dispatched to perform task of current priorities and any changes to priorities.

B. When possible, participate in team briefings to ensure you are aware of the team's assigned tasks and expected hazards.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 19 OF 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.3 WORK CONTROL COORDINATOR Sheet4 of 4 Continuous Responsibility/Activity (cont.) Notes C. Maintain communications with teams once they are dispatched from the OSC.

D. Keep track of team radiation exposure while they are in the field using spreadsheet or manual forms. Transfer information to WebEOC, or EP-6-ALL, Team Tracking Form.when teams return.

E. When possible, participate in Team Debriefings when teams return to the OSC, to keep informed on field conditions.

F. Immediately update teams of any change in emergency classifications or changing conditions, which may affect their safety, such as the start of a release.

G. Immediately update OSC Rad/Chem Coordinator of any changing or unexpected conditions reported by teams in the field.

2.7 Direct the OSC Log-Keeper to assist you in maintaining records as necessary.

2.8 Inform the OSC Manager and other OSC Coordinators of changing situations in the plant based on information received from dispatched teams.

A. Unexpected radiation levels.

B. Unreported hazardous conditions.

C. Important equipment status.

3.0 Closeout Responsibility/Activity 3.1 Assist OSC personnel to return all equipment to proper storage locations.

3.2 Review all documentation the OSC Coordinators maintained during the emergency:

A. Ensure logs, forms and other documentation are complete B. Work with other OSC Coordinators to ensure all repairs performed by OSC Teams that deviated from normal station procedures are properly documented so that necessary actions can be taken for continuous plant operations or recovery operations.

3.3 Provide all logs and records to the OSC Manager upon termination of the emergency.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 20 OF29 OPERATIONS SUPPORT CENTER OSC) OPERATIONS ATTACHMENT 9.4 MECHANICAL AND ELECTRICAL/l&C COORDINATORS Sheet 1of3 Mechanical Coordinator Name: ~~~~~~~~~~~~~

Date: _ _ __

Electrical/l&C Coordinator Name: ~~~~~~~~~~~~

Date: _ _ __

1.0 Initial Responsibility/Activity Notes 1.1 Initial Orientation A. Upon arrival at the OSC:

1. Card in the accountability readers and/or sign in on EP-7-ALL, Facility Sign-In/Accountability Form

2. Sign in on the OSC staffing board

3. Obtain the Mechanical or Electrical/l&C Coordinator Binder & ID Badge

/ ---~-

B. Review electronic displays, plant data, status boards and any other i .

available information to become familiar with current plant conditions.

C. Obtain a briefing from the OSC Manager:

1. Plant conditions

2. Equipment Status

3. Actions being taken (any repair/Operations personnel currently in the field)

4. Team requirement for actions planned but not yet initiated.

1.2 Assume the position of Mechanical or Electrical/l&C Coordinator A. Report readiness status to the OSC Manager when prepared to assume the Mechanical or Electrical/l&C Coordinator position.

B. IF relieving another Mechanical or Electrical/l&C Coordinator, THEN perform a formal turnover with the current Mechanical or Electrical/l&C Coordinator:

1. Review current log(s).

2. Obtain briefing from current Coordinator on the emergency and any actions that have been completed or are in progress.

3. Relieve current Mechanical or Electrical/l&C Coordinator.

4. *Inform OSC Manager and staff that you are now the Mechanical or Electrical/l&C Coordinator

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT REFERENCE Use MANUAL PAGE 21OF29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.4 MECHANICAL AND ELECTRICAL/l&C COORDINATORS Sheet 2 of 3 Initial Responsibility/Activity (cont'd) Notes 2.0 Continuous Responsibility/Activities 2.1 Inform an OSC Coordinator and/or the OSC Manager when temporarily leaving the work area.

A. Request another OSC Coordinator assume the Work Control Coordinator duties while you are away.

B. IF you are leaving the OSC THEN:

1. Inform an OSC Coordinator and /or OSC Manager when you leave, where you are going and when you expect to return. (For accountability purposes)

2. Inform an OSC Coordinator and/or OSC Manager when you return.

C. Upon return, obtain a briefing on any events, which have occurred while away.

2.2 Assist OSC Manager in planning and preparing for any maintenance activities needed to return the plant to a safe condition.

2.3 Participate in team dispatch and field operations:

A. Choose maintenance personnel who are best qualified to conduct assigned task(s)

B. Use EP-5-ALL,Team Dispatching Form, to prepare and document team assignments.

C. Ensure each team dispatched has a copy of the Team Dispatching Form.

D. Ensure Team is properly equipped to conduct repairs, including procedures, drawings, tools and repair parts.

E. Participate in Team briefings to ensure team members properly understand assigned task and understand the hazards to be encountered. Briefings should be clear concise, accurate and prompt.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT REFERENCE USE MANUAL PAGE 22 OF29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.4 MECHANICAL AND ELECTRICAL/l&C COORDINATORS Sheet 3 of 3 Continuous Responsibility/Activities (cont.) Notes F. Maintain communication capability (i.e. phone, radio) and work with the Work Control Coordinator while the team is in the field to answer any questions that may arise concerning task.

G. Assist the Work Control Coordinator as required/requested with Team status and dose tracking using WebEOC or EP-6-ALL, Team Tracking Form.

NOTE:

Ensure any deviations from Quality Control work practices are logged as part of the Team debriefings.

H. Debrief team members when they return and ensure actions are properly documented.

I. Inform the OSC Manager prior to dispatching teams.

J. Report results and status of team efforts to the OSC Manager as necessary.

K. Assist with maintaining team status/results in WebEOC or applicable forms as necessary.

3.0 Closeout Responsibility/Activity 3.1 Assist OSC personnel to return all equipment to proper storage locations.

3.2 Review all documentation the OSC Coordinators maintained during the emergency:

A. Ensure logs, forms and other documentation are complete B. Work with other OSC Coordinators to ensure all repairs performed by OSC Teams that deviated from normal station procedures are properly documented so that necessary actions can be taken for continuous plant operations or recovery operations.

3.3 Provide all logs and records to the OSC Manager upon termination of the emergency,

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 23 OF29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.5 RAD/CHEM COORDINATOR Sheet 1of5 Rad/Chem Coordinator: Date:-----

---

~

1.0 Initial Responsibility/Activity Notes 1.1 Initial Orientation A. Upon arrival at the OSC:

1. Card in the accountability readers and/or sign in on EP-7-ALL, Facility Sign-In/Accountability Form.

2. Sign in on the OSC staffing board

3. Obtain the "Rad/Chem Coordinator" Binder & ID Badge.

B. Review electronic displays, plant data, status boards and any other available information to become familiar with current plant conditions.

C. Obtain status of radiation protection activities and current plant radiological conditions from shift Radiation Protection personnel.

D. Obtain a briefing from the OSC Manager:

1. Plant conditions

2. Equipment Status

3. Actions being taken (any repair/Operations personnel, currently in the field

4. Team requirement for actions planned but not yet initiated.

1.2 Assume the position of Rad/Chem Coordinator A. Contact the TSC Radiological Coordinator and receive a briefing of radiological conditions and status of any ongoing jobs.

B. Determine if any personnel are currently in the radiological controlled area (RCA) using available tools (e.g. Sentinel).

C. Obtain a copy of current employee exposure for use in ALARA considerations when assigning OSC team members.

D. Brief the OSC Manager of the information obtained from the Radiological Coordinator and/or Watch RP Tech.

E. Ascertain the ability to conduct chemistry sampling via normal as well as through PASS (if available) and provide this information to the OSC Manager.

F. Assess the need for additional Radiological or Chemistry personnel and provide any requests to the OSC Manager.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 240F29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.5 RAD/CHEM COORDINATOR Sheet 2 of 5 Initial Responsibility/Activity(cont.l Notes G. Ensure initial and subsequent provisions of habitability surveys of the OSC (if co-located include the TSC) and other occupied staging areas. Discuss any issues with the TSC Radiological Coordinator.

H. Check radiological equipment supplies for operability and inventories.

I. Obtain resultant dose and radiological information and provide to the TSC Radiological Coordinator.

J. Report readiness status to the OSC Manager when prepared to assume the OSC Rad/Chem Coordinator position.

2.0 Continuous Responsibility/Activities 2.1 IF relieving another OSC Rad/Chem Coordinator THEN perform a formal turnover:

A. Review the OSC Rad/Chem Coordinator's EP-3-ALL, Log Sheet Forms, or WebEOC.

B. Obtain a briefing on the emergency, radiological conditions and any actions that have been completed or are in progress.

C. Relieve current OSC Rad/Chem Coordinator.

D. Inform OSC Manager and staff that you are now the OSC Rad/Chem Coordinator.

2.2 Inform an OSC Coordinator and/or the OSC Manager when temporarily leaving the work area.

A. IF you are leaving the OSC THEN:

1. Inform an OSC Coordinator and/or OSC Manager when you leave, where you are going and when you expect to return.

2. Inform an OSC Coordinator and/or OSC Manager when you return.

B. Upon return, obtain a briefing on any events, which have occurred while away.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 250F29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.5 RAD/CHEM COORDINATOR Sheet 3 of 5 Continuous Responsibility/Activities (cont.) Notes 2.3 Use WebEOC or if unavailable, EP-3-ALL, Log Sheet Forms, to maintain a log of activities.

A. Record the time you assume position of Rad/Chem Coordinator.

B. Record time and details of sample requests.

C. Record radiological/chemistry activities undertaken with information on tasks performed and pending actions to ensure tasks are completed. (You need not repeat information on team briefing forms)

D. Record all communications outside the Protected Area Fence.

2.4 Assist OSC Manager in planning and preparing for any Radiological/Chemistry activities needed to return the plant to a safe

/

' condition.

2.5 Ensure adequate staffing is available and assign personnel as required (e.g. communication with TSC).

2.6 Deploy onsite radiation monitoring teams to survey radiation levels and sample for contamination.

2.7 Ensure habitability of the OSC A. Ensure appropriate radiological controls are established for the OSC (e.g. frisking, air sampling) per site procedures.

B. Ensure emergency ventilation filtration system is started per appropriate site procedures.

2.8 Ensure requests for chemistry sampling contain specific details on the type of results information that is necessary (e.g. boron concentration, activity, etc.).

2.9 Participate in team dispatch and field operations:

A. Choose personnel who are best qualified to conduct assigned task(s).

B. Use EP-5-ALL, Team Dispatching Form, to prepare and document team assignments.

C. Ensure each team dispatched has a copy of the Team Dispatching Form.

D. Prepare or have prepared RWP documentation. Review and approve the prepared form and then use or have it used.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 26 OF 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.5 RAD/CHEM COORDINATOR Sheet4 of 5 Continuous Responsibility/Activities (cont.) Notes E. Use the RWP to discuss dose limits, surveys to be performed, expected and maximum dose rates, and stay times. Advise team members to immediately contact or return to the OSC when dose rates or stay times approach the established limits.

F. Determine the need for emergency exposure limits and Kl issuance and communicate conditions to the OSC Manager and the TSC.

G. Discuss dosimetry requirements.

H. Discuss protective clothing and respiratory protection requirements.

I. Discuss travel route requirements and if there are any releases in progress.

J. Advise team members on monitoring and decontamination procedures following mission completion.

K. Advise team how they will be notified of changing conditions or classifications. Direct radiological control personnel to read dosimetry for personnel whose exposure limits are approached.

L. Participate in team briefings to ensure team members understand the assigned task and understand the hazard to be encountered.

Briefings should be clear, concise, accurate and prompt.

M. Participate in OSC team post job briefings, if needed.

• N. Maintain communication capability (i.e. phone, radio) and work with the Work Control Coordinator while the team is in the field to answer any questions that may arise concerning the task.

0. Verify the Work Control Coordinator is tracking individual exposure data in WebEOC or on EP-6-ALL, Team Tracking Form.

P. Coordinate with the OSC Manager for tasks involving injured personnel or search and rescue activities.

(a) IF potentially contaminated or highly exposed personnel require offsite medical facility attention, THEN support transport with Operations and Security.

Q. Frequently brief the OSC Manager on assigned task status.

R. Coordinate with the EOF Administration and Logistics Coordinator to obtain equipment and materials not available onsite or through previously arranged agreements. Discuss with the Radiological Coordinator.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV.3 MANAGEMENT MANUAL REFERENCE USE PAGE 27 OF29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.5 RAD/CHEM COORDINATOR Sheets of 5 Continuous Responsibility/Activities (cont.) Notes S. Ensure adequate supplies of SCBA's/Respirators are maintained to support dispatched teams.

2.10 IF there are contaminated injured personnel THEN perform the following:

A. Provide radiological support for the assessment, treatment, and transportation of contaminated injured personnel.

B. Monitor patients for contamination and decontaminate as appropriate.

C. Make arrangements to pick up Rad Protection personnel at the hospital.

D. Follow proper procedures to retrieve radioactive waste from offsite treatment locations.

E. Obtain concurrence from the Radiological Coordinator prior to releasing the hospital's Radiological Emergency Room or the ambulance, for uncontrolled use.

3.0 Closeout Responsibility/Activity 3.1 IF radiological conditions allow THEN direct Rad Protection Technicians:

A. To return emergency equipment to proper storage areas and restock supplies as needed.

B. Review radiological conditions in the plant and update postings as required.

C. Review any open RWPs to ensure conditions have not changed which may affect their use.

3.2 Provide all logs and records to the OSC Manager upon termination of the emergency.

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT REFERENCE USE MANUAL PAGE 280F 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.6 OSC LOG KEEPER Sheet 1of2 OSC Log Keeper: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Date: _ _ __

1.0 Initial Responsibility/Activity Notes 1.1 Initial Orientation A. Upon arrival at the OSC:

1. Card in the accountability readers and /or sign in on EP-7-ALL, Facility Sign-In/Accountability Form.

2. Sign in on the OSC staffing board

3. Obtain the OSC Log Keeper Binder & ID Badge B. Review electronic displays, plant data, status boards and any other available information to become familiar with current plant conditions.

C. Obtain a briefing from the OSC Manager:

1. Plant conditions

2. Equipment Status

3. Actions being taken (any repair/Operations,personnel currently in the field)

4. Team requirements for actions planned but not yet initiated.

1.2 Assume the position of OSC Log Keeper A. Log on to WebEOC B. Report readiness to the OSC Manager when prepared to assume the OSC Log Keeper position, and assist in OSC staffing 2.0 Continuous Responsibility/Activities 2.1 IF relieving another OSC Log Keeper THEN perform a formal relief turnover:

A. Review WebEOC logs and applicable Log Sheet Forms.

B. Obtain a briefing on facility status C. Inform the OSC Manager and staff that you are now the OSC Log-Keeper

NUCLEAR NON-QUALITY RELATED EN-EP-611 REV. 3 MANAGEMENT MANUAL REFERENCE USE PAGE 290F 29 OPERATIONS SUPPORT CENTER (OSC) OPERATIONS ATTACHMENT 9.6 OSC LOG KEEPER Sheet 2 of 2 Continuous Responsibility/Activities (cont'd) Notes 2.2 Inform the OSC Manager when temporarily leaving the area and upon return.

2.3 Support the Security Coordinator with Accountability, if applicable 2.4 Support the OSC in work activities needed during event e.g. log keeping, tracking personnel leaving OSC, document/drawing retrieval.

2.5 Assist with TSC activities as requested where the TSC is co-located with the OSC.

2.6 Assist the OSC Manager in second shift scheduling A. Obtain shift turnover time from the OSC Manager.

B. Assist the OSC Manager and Administration and Logistics Coordinator (EOF) with coordination of second shift coverage including contacting personnel to verify availability and informing them of turnover time.

2.7 Use WebEOC, or if unavailable, EP-3-ALL, Log Sheet Forms, to maintain a log.

A. Log when the OSC Manager assumed the duties of OSC Manager (and when the OSC was declared operational, if not previously done)

B. Log significant decisions and-important details used to make decisions.

C. Log significant communications with other ERO members and offsite officials.

2.8 Receive status updates from the OSC Manager and if directed post updates on the appropriate electronic displays.

3.0 Closeout Responsibility/Activity 3.1 Assist OSC personnel to return all equipment to proper storage locations.

3.2 Review all documentation you maintained during the emergency.

Ensure logs, forms and other documentation is complete.

3.3 Provide all logs and records to the OSC Manager upon termination of the emergency.

/'

ATTACHMENT9.1 10CFRS0.54(q) SCREENING SHEET1 OF3 Procedure/Document Number: EN-EP-611 I Revision: 003 Equipment/Facility/Other: James A. Fitzpatrick

Title:

Operations Support Center (OSC) Operations Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

1. Page 4: Deleted Palisades Commitment CMT932002114

2. Page 16: Corrected binder name referenced for use by the Work Control Coordinator

3. Page 17: Revised sub-heading to "Initial Responsibility/Activity (cont.)".

4. Page 18: Added use of WebEOC to step 2.5 B

5. Page 19: Revised step 2.6 E, to indicate that information is to be transferred to WebEOC or EP*6*ALL.

6. Page 22: Revised step 2.3 G to add use of WebEOC and delete use of EP*4*ALL.

7. Page 26: Revised step 2.9 0 to add use of EP-6-ALL and delete use of EP-4-ALL.

Part II. Activity Previously Reviewed? DYES ~NO Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54{q){3). Continue to

'f

• t" S t D

• R rt? Evaluation 1s next part Al e rt an d N o t 1 1ca ion ys em es1gn epo . NOT required.

Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and complete Part proposed change is documented below: VI.

Justification:

D Bounding document atta~hed (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

ScreeninQ.

APPLICABILITY CONCLUSION

~ If there are no controlling change processes, continue the 50.54(q)(3) Screening.

D One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

D One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54{q)(3)

Evaluation is NOT required. Identify controllinQ chani:ie processes below and complete Part VI.

CONTROLLING CHANGE PROCESSES 10 CFR 50.54 (q)

DYES ~NO Part IV. Editorial Change 50.54(q)(3) Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.

Enter Justification: justification and Changes 2 and 3 are editorial changes: complete Part 2: This change corrects the binder for use by the Work Control Coordinator from the VI.

Ops Support binder to the Work Control Coordinator binder.

3. This change corrects the sub-header from "Continuous" to "Initial" Responsibility/Activity (cont.).

EN-EP-305 REV 3 I

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET20F3 Procedure/Document Number: EN-EP-611 I Revision: 003 Equipment/Facility/Other: James A. Fitzpatrick

Title:

Operations Support Center (OSC) Operations Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1] D

2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 D staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] D

4. The process for timely augmentation of onshift staff is established and maintained. [2] D

5. Arrangements for requesting and using off site assistance have been made. [3] D

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] D

7. A standard scheme of emergency classification and action levels is in use. [4] D

8. Procedures for notification of State and local governmental agencies are capable of alerting them of D the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt D instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response D organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6] D

13. Emergency preparedness information is made available to the public on a periodic basis within the D plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. [7] D

15. Adequate facilities are maintained to support emergency response. [8] D

16. Adequate equipment is maintained to support emergency response. [8] D

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] D

18. A range of public PARs is available for implementation during emergencies. [1 O] D

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are D available to support the formulation of PARs and have been provided to State and local governmental authorities. [1 O]

20. A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events.[1 O]

EN-EP-305 REV 3

A1TACHMENT 9.1 10CFR50.54(q) SCREENING SHEET3 OF3 Procedure/Document Number: EN-EP-611 I Revision: 003 Equipment/Facility/Other: James A. Fitzpatrick

Title:

Operations Support Center (OSC) Operations

21. The resources for controlling radiological exposures for emergency workers are established. [11] u

22. Arrangements are made lor medical services for contaminated, injured individuals. [12] D

23. Plans for recovery and reentry are developed. [13] u

24. A drill and exercise program (including radiological, medical, health physics and other program u areas) Is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, u maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]

26. Identified weaknesses are corrected. [14] u

27. Training is provided to emergency responders. [15j u

28. Responsibility for emergency plan development and review is established. [16} u

29. Planners responsible for emergency plan development and maintenance are properly trained. (16] u APPLICABILITY CONCLUSION igj II no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis tor conclusion below and complete Part VI.

a It any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION

• Change 1 was evaluated and approved on Commitment Change Evaluation Form; (Palisades) Site Reg. Assurance Tracking Number 2002114.

.. Changes 2 and 3 are editorial changes

• Changes 4, 5, 6 and 7 revise referred to locations where information is to be documented, that is use of a different form or electronically in WebEOC. The change is to ensure data is recorded in the correct location(s); there is no change of intent.

These proposed changes do not affect the meaning or the intent of a description, facilities, equipment or process. These changes do not affect the Emergency Plan. No further evaluation of these changes is required.

Part VI. Signatures:

Preparer Name (Print)

MELLONIE CHRISTMAN {'f\Q Preparer Signature c\ _, ,_)Jrh -Y **(),./"', !Y Date:

5*26*2016 NI~

(Optional) Reviewer Name (Print) Reviewer Signature Date:

Reviewer Name (Print)

\lM. C1M-V~

Nuclear EP Project Mana er

- Reviewer Signature

\~ ,6 .... A Dale:

s/:> 1/ lt.:J

/ -

?~1/1"""'"ra Approver Name (Print) Date:

""J1) \rlMf ~ 5"..JI... dDlb EP manager or designee

\. \J EN*EP-305 REV 3

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 1 OF77 10CFR50.54 q Review Pro ram Procedure Contains NMM ECH eB REFLIB Forms: YES [8J NO 0 Procedure Revision T e: New D NON-Editorial [8J Editorial D TC D Cancellation HQN Dean Burnett Mary Ann Wilson Effective Procedure Owner: Governance Owner:

Director, Emergency Director, Emergency Date

Title:

Title:

Planning Planning Site: Site:

06/16/2016 HON HQN Site Site Procedure Champion Title ANO Robert Carey Manager, EP BRP N/A N/A CNS N/A N/A GGNS Jeff erv Seiter Manaaer, EP IPEC Lori Glander Manaaer, EP JAF Jim Jones Manager, EP PLP Dan Malone Manaaer, EP PNPS Donna Calabrese Manager, EP RBS Tim Schenk Manaaer, EP VY Steve Naeck Manaaer, EP W3 John Signorelli Manager, EP HQN Jack Lewis EP Project Manaaer For site implementation dates see ECH eB REFLIB using site tree view (Navigation panel). (EN-AD-101 Section 5. 7)

Site and NMM Procedures Canceled or Superseded By This Revision None Process Applicability Exclusion: All Sites: D Specific Sites: ANO D BRP D CNS D GGNS D IPECO JAF 0 PLP 0 PNPSO RBS 0 VY 0 W3 D Change Statement This is a major revision to the procedure to implement a review process for 10CFR50.54{g}{2} that differs from the review process applied to emergency plan changes made under 10CFR50~54{g}{3}.

Revision bars are not used.

This revision also:

• Eliminates the NRC submittal requirement for Emergency Plan Implementing Procedure changes to address a change in the regulations

• Clarifies training requirements as they apply to site Emergency Planning Managers

• Eliminates flow charts

• Adds tools to assist with the completion of 10CFR50.54{g}{3} screenings and evaluations and the performance of Project Manager Reviews

• Makes editorial corrections throughout procedure for formatting and consistency 1 such as changing 'Emergency Plan' to (lower case} 'emergency plan' throughout the document where applicable Associated PRHQN #: 2015-00558 I Procedure Writer: Jack Lewis Contains Proprietary Information: YES D NO l:8l

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 2 OF 77 10CFR50.54 Review Pro ram TABLE OF CONTENTS Section Section Title 1.0 PURPOSE .................................................................................. 3

2.0 REFERENCES

........................................................................... 3 3.0 DEFINITIONS ............................................................................. 4 4.0 RESPONSIBILITIES ................................,................................. 6 5.0 DETAILS ................................................................................... 7 6.0 INTERFACES ............................................................................ 26 7.0 RECORDS ................................................................................. 26 8.0 SITE SPECIFIC COMMITMENTS ............................................. 27 9.0 ATTACHMENTS ....................................................................... 27 ATTACHMENT9.1 10 CFR 50.54(a)(2) REVIEW .......................................... 28 ATTACHMENT 9.2 10 CFR 50.54(Q)(3) SCREENING .................................... 30 ATTACHMENT 9.3 10 CFR 50.54(a)(3) EVALUATION ................................... 33 ATTACHMENT 9.4 10 CFR 50.54(a) TRAINING DOCUMENTATION ................. 35 ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES ............................ 36 ATTACHMENT 9.6 ADDITIONAL REGULATORY GUIDANCE ............................. 49 ATTACHMENT9.7 PLANNING STANDARDS, APPENDIX E,FUNCTIONS AND ELEMENTS ...................................................................... 52 ATTACHMENT

9.8 BACKGROUND

INFORMATION ........................................... 56 ATTACHMENT 9.9 10 CFR 50.54(a)(3) SCREENING TEMPLATE ................... 64 ATTACHMENT 9.10 10 CFR 50.54(a)(3) EVALUATION TEMPLATE .................. 67 ATTACHMENT9.11 10 CFR 50.54(0) PROJECT MANAGER REVIEW CHECKLIST.; ................................................................... 73

A-=::=:-Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED EN-EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 30F77 Emergency Planning 10CFR50.54lal Review Program 1.0 PURPOSE The purpose of this procedure is to provide guidance for the review of proposed changes to Entergy Nuclear emergency plans, associated procedures and activities that may potentially impact Entergy Nuclear emergency plans to determine that effectiveness of the site emergency plans has been maintained or if a potential reduction in effectiveness has been identified, that appropriate NRG prior approval is obtained before implementing the proposed change.

2.0 REFERENCES

[1] 10 CFR 50.54, "Conditions of Licenses"

[2] 10 CFR 50.47, "Emergency Plans"

[3] 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities"

[4] NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants"

)

[5] NRG Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes"

[6] NRG Regulatory Issue Summary 2003-18 Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels"

[7] NEI 11-03, "Guidelines for Evaluating Emergency Plan Changes Under 10CFR50.54(q)"

[8] NRG Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors"

[9] 10CFR50.12, "Specific Exemptions"

[1 O] NRG Regulatory Issue Summary 2015-14, "Issuance of Enforcement Guidance Memorandum - Emergency Plan and Emergency Implementing Procedure Updates"

[11] Enforcement Guidance Memorandum 15-003, "Enforcement Discretion not to Cite Certain Violations of Section V of Appendix E to 10CFR Part 50 for Non-Submittal of Emergency Plan and Emergency Plan Implementing Procedure Changes by Operating Reactor Licensees, While Rulemaking Changes are Being Developed"

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 4 OF 77 10CFR50.54 Review Pro ram 3.0 DEFINITIONS

[1] Activity: An event or action, or series of events or actions that may result in a change to the emergency plan or affect the implementation of the emergency plan.

(a) An activity sets in motion the need to determine impact on certain licensing bases documents using regulatory review criteria such as 10 CFR 50.54(q)

(b) Activities may range from something as simple as making an editorial change or organization change to complicated facility modifications (c) Activities may be identified by the applicability determination process provided by 10 CFR 50.59 or through another process (d) For the purposes of 10CFR 50.54(q), activities may also originate outside of the licensee's responsibility such as permanent road closings or substantive population increases

[2] Capability: The capacity to implement the response actions identified in the emergency plan (e.g., the ability to augment onshift personnel in a timely manner, generate timely and accurate PARs, complete notific?tions within 15 minutes, and maintain a protracted response).

[3] Change: An action that results in modification or addition to, or removal from, the licensee's emergency plan. All such changes are subject to the provisions of 10 CFR 50.54(q) except in cases in which the applicable regulations establish specific criteria for accomplishing.a particular change.

[4] Conforming Change: A change made to comply with another process change, such as an underlying regulatory basis change or a new regulatory basis, a station modification, Technical Specification, etc. These changes are reviewed as required using this procedure, but may be treated collectively when multiple changes to the reviewed activity are made to conform to the other process change.

[5] Editorial Change: Editorial changes are reviewed under 10CFR50.54(q)(2) or screened under 10CFR50.54(q)(3) and do not require a 10 CFR 50.54(q)(3) evaluation. They are a specific change or revision to a procedure or document that meets the criteria defined in EN-AD-101 that define the meaning of "editorial change or non-intent change" for controlled document change purposes.

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 5 OF77 10CFR50.54 Review Pro ram

[6] Emergency Plan: The document(s) that the licensee prepared and maintains that identifies and describes its methods for maintaining emergency preparedness and responding to emergencies. An emergency plan includes the plan that was originally approved by the NRC, and all subsequent changes that the licensee made with and without prior NRC review and approval under 10 CFR 50.54(q).

For the purposes of this procedure, Entergy considers the following to be elements or parts of the emergency plan, and therefore subject to 10 CFR 50.54(q)(3) reviews, whether or not they are actually contained in the document itself:

(a) Emergency classification Initiating Conditions, Emergency Action Levels and Emergency Action Level Basis Document(s)

(b) Evacuation Time Estimate (c) ANS Design Report (d) Onshift Staffing Analysis (e) Other site-specific documents as identified by the site

[7] Emergency Planning Function: A capability or resource necessary to prepare for, and respond to, a radiological emergency, as required by Section IV of Appendix E to 10 CFR 50 and the planning standards of 10 CFR 50.47(b).

[8] Methods: The procedural means or manner of implementing the response actions identified in the emergency plan (e.g., emergency classification schemes, notification protocols, and emergency action level (EAL) threshold value bases).

[9] Planning Standard(s): The 16 standards delineated in 10 CFR 50.47(b) that onsite and offsite emergency plans must meet in order for the NRC to find reasonable assurance that adequate protective measures can and will be taken.

Corresponding sections of Appendix E to 10 CFR 50 contain additional requirements associated with the Planning Standards.

[1 O] Program Element: The items that comprise the implementation aspects of an emergency planning function. These items correspond to the evaluation criteria in NUREG-0654 (or other alternative methods for which the licensee obtained approval) that identify specific acceptable methods for complying with an emergency planning function.

[11] Regulatory Requirement: Any emergency preparedness-related requirement, including the planning standards, Appendix E to 10 CFR 50, 10 CFR 50.54(q), 10 CFR 50.54(t), commitments made in the emergency plan, Commission orders, and commitments made with regard to compensatory actions under 10 CFR 50.47(c) or 1o CFR 50.54(s)(2)(ii). "Regulatory requiremene includes a licensee s 1

self-imposed requirements necessary for demonstrating compliance with the planning standards and Appendix E to 10 CFR 50.

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• NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED INFORMATIONAL USE EN-EP-305 Emeraencv Planning 10CFR50.54(q) Review Program I

PAGE 60F77 REV.4

[12] Reduction in Effectiveness: A change in an emergency plan that results in reducing the licensee's capability to perform an emergency planning function in the event of an emergency.

[13] Resources: Personnel, procedures, equipment, communications, instrumentation, analytical equipment, transportation, supplies, and other items needed to implement the response actions identified in the emergency plan.

4.0 RESPONSIBILITIES

[1] The Manager, Regulatory Assurance (site) is responsible for processing requests to change an Entergy Operating License and coordinating the implementation of NRC approved license amendments in accordance with EN-Ll-103.

[2] The Manager, Emergency Preparedness at each site or designee is responsible for:

(a) Ensuring that applicable activities that may impact the emergency plan are reviewed to ensure the effectiveness of the emergency plan is maintained

\

in accordance with 10 CFR 50.54(q)(2) l (b) Ensuring a screening and if required an evaluation, is performed in accordance with 10 CFR 50.54(q)(3) to determine if proposed changes to the emergency plan reduce the effectiveness of the emergency plan (c) Assigning knowledgeable and qualified individuals to perform and review 10 CFR 50.54(q)(2) reviews and 10CFR50.54(q)(3) screenings and evaluations and ensuring that assigned personnel are knowledgeable of the subject being evaluated or reviewed (d) Ensuring revisions to the emergency plan are sent to the NRC within 30 days of their implementation in accordance with 10 CFR 50.4, for changes which do not require prior approval by the NRC. Changes requiring approval by NRG will be submitted in accordance with the provisions of EN-Ll-103.

[3] The preparer of the 10 CFR 50.54(q)(2) review, 10 CFR 50.54(q)(3) screening or evaluation is responsible for performing the applicable task in accordance with this procedure and verifying their qualifications are current before performing these activities.

[4] Other departments are responsible for referring changes that could impact the effectiveness of the emergency plan to the emergency preparedness organization for review under this guidance (e.g., certain changes to plant design, radiation monitor set-points, security plan, etc.). These determinations are made in accordance with EN-Ll-100. Examples include:

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4

--::::=-Entergy MANAGEMENT MANUAL INFORMATIONAL USE PAGE 7 OF 77 10CFR50.54 Review Pro ram (a) Adding security delay barriers or reducing the number of access points to the protected area that could impact activation times for onsite emergency facilities, onsite protective measures, site evacuation times/dose, etc.

(b) Adding an occupied building without public address system to communicate site evacuation (c) Changing plant vent radiation monitor that could require a change to EAL thresholds 5.0 DETAILS 5.1 PRECAUTIONS AND LIMITATIONS

[1] Proposed activities that may impact the maintenance of the emergency plan should be reviewed under 10 CFR 50.54(q)(2).

[2] Proposed activities that constitute a change to the emergency plan require review under 10 CFR 50.54(q)(3) using the screening and evaluation (if required) process.

[3] Changes related to requirements that have been removed from the emergency plan and relocated in other documents are reviewed under 10 CFR 50.54(q)(3).

Documents containing relocated requirements are considered part of the emergency plan for the purpose of reviewing the relocated requirements (e.g.,

implementing instructions or procedures). (Refer to Regulatory Guide 1.219, Regulatory Position 3.5c).

(a) Sites may perform an analysis of their emergency plan against the regulatory requirements for content of emergency plans in 10 CFR 50.47(b) and 10 CFR 50 Appendix E and the planning standards and evaluation criteria in NUREG-0654. This analysis should document the current state of the emergency plan and indicate where the programmatic description emergency plan content for emergency response is located when it is not contained in the emergency plan document itself. Such an analysis is not considered a full substitute for the location and determination of NRG-approved historical emergency plan revisions and all other emergency plan changes processed under 10 CFR 50.54(q).

[4] Changes, other than changes to the emergency plan, could adversely impact an emergency planning function. Applicable changes are reviewed under 10 CFR 50.54(q)(2) as required for maintaining the ability to implement the approved emergency plan. Other activities could affect the ability to implement the emergency plan effectively. Applicable changes to other programs, structures, systems or components are reviewed to ensure they do not impact the ability to effectively implement the emergency plan. Refer to EN-LI-100 for identification of these types of changes.

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Entergy MANAGEMENT MANUAL INFORMATIONAL USE PAGE 8 OF77 10CFR50.54 Review Pro ram

[5] Refer also to EN-Ll-100 for other regulations that may apply to proposed activities. The review of proposed activities includes review under the other applicable regulations.

[6] IF an activity modifies the emergency plan, such that the plan no longer complies with the planning standards in 10 CFR 50.47(b) or the requirements in Appendix E to 10 CFR 50, THEN an exemption request is processed under 10 CFR 50.12 "Specific Exemptions", rather than 10 CFR 50.54{q). Note that changes that may reduce the effectiveness of the plan while maintaining compliance with the regulations are processed under 10 CFR 50.90. A change requiring processing under 10 CFR 50.12 is rare. Regulatory Assurance should be consulted regarding such a submittal.

[7] As stated in R.G. 1.219, 1.6a, "The licensee cannot properly evaluate a proposed change to the emergency plan if it has not considered the basis for the staff's approval of the original plan or the basis for any subsequent change, whether it has been approved by the staff or implemented by the licensee under 10 CFR 50.54{q)." This is taken to mean that prior changes should be considered when evaluating changes to the emergency plan as well as NRC actions, if any, related to the original plan and subsequent changes.

[8] R.G. 1.219, 5.2c5 establishes the expectation for a level of rigor and thoroughness in 10 CFR 50.54{q) evaluations (reviews) consistent with the scope of the change with particular emphasis on the risk significant planning standards (10 CFR 50.47{b}{4), (5), (9), and (10)). An evaluation of inadequate scope and extent to reasonably assess the impact of the proposed change on the effectiveness of the emergency plan may be considered a violation of the 10CFR50.54{q) rule.

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 90F77 10CFR50.54 Review Pro ram

5. 2 GENERAL NOTE Attachment 9.8 contains background information regarding various aspects of conducting a review. These include such items as the role of conservatism in change evaluations, the role of Probabilistic Risk Assessment (PRA) in change evaluations, timeliness as an evaluation consideration, role of the facility licensing basis, role of margin in the evaluation process and changing Emergency Action Level (EAL) schemes. This information should be considered when performing reviews under 10CFR50.54(q).

[1] Other Regulations (a) Activities that modify the emergency plan such that the plan no longer complies with the planning standards in 10 CFR 50.47(b) or the requirements in appendix E to 10 CFR Part 50 are processed as an exemption request under 10 CFR 50.12, "Specific Exemptions," rather than under 10 CFR 50.54(q)

(b) IF other applicable regulations establish specific criteria for a proposed activity, THEN implement the other change processes in addition to the 10 CFR 50.54(q) change process

• For example, a modification of the radiation monitoring system described in the FSAR that impacts a technical specification and an EAL threshold could be subject to 10 CFR 50.59, "Changes, Tests, and Experiments,"

and 10CFR 50.54(q)

(c) Refer to EN-Ll-100 for other regulations that may apply in addition to 10 CFR 50.54(q) when reviewing an activity (d) Refer to attachment 9.6 for additional regulatory guidance with information relevant to making changes to the emergency plan

~

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~Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED EN-EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 10 OF 77 Emergencv Plannina 10CFR50.54lal Review Program

[2] Changes to the emergency plan that have previously been approved by the NRC under 10 CFR 50.90 do not require a 10 CFR 50.54(q)(3) evaluation. Such changes still require documentation in a screening as described below.

(a) License amendments that address changes to the emergency plan would screen out under 10 CFR 50.54(q)(3) provided the change to the emergency plan is specifically addressed in the license amendment (b) For license amendments that do not specifically address changes to the emergency plan, a 10 CFR 50.54(q)(2) review may be completed to determine whether or not the change to the licensing basis supports the emergency plan (c) Any aspects of an activity that have not been approved by the NRC under 10 CFR 50.90 require review under 10 CFR 50.54(q)(2) and/or 10 CFR 50.54(q)(3)

• For example, a license amendment to revise a site's Technical Specifications may not fully encompass the scope of related changes being made to emergency plan procedures. In this case, the changes to the emergency plan procedures that are not within the scope of the license amendment would require review under 10 CFR 50.54(q)(2).

[3] Any emergency plan change that the evaluation determines to be a Reduction in Effectiveness (RIE) requires NRC approval prior to implementation. Such changes are submitted under the provisions of 10 CFR 50.90. These submittals are controlled by EN-Ll-103.

[4] Prior NRC approval is required for any EAL change that potentially reduces the effectiveness of the emergency plan, changes from one EAL scheme (i.e.,

NUREG 0654 to NUMARC/NESP-007 or NEI 99-01) to another, or for plan changes that propose an alternate method for complying with the regulation.

[5] A pre-application call may be held with the appropriate NRC Headquarters staff if a licensee is unsure whether or not the proposed changes constitute an RIE.

Fleet EP assists with such calls as requested.

[6] It is acceptable for an originator to use a matrix or other method for completing Attachments 9.1, 9.2 and 9.3 of this procedure provided all content in the applicable attachment is addressed and the matrix or other document properly refers to the procedure attachments and the change being reviewed.

A~Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED EN-EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 11OF77 Emeraencv Plannina 10CFR50.54(q) Review Proaram

[7] Documents that may provide useful information to perform a specific 10CFR50.54(q)(2) review or 10 CFR 50.54(q)(3) screening or evaluation that are NOT listed as required qualification documents in step 5.9[2] are:

(a) Site ANS report (b) State and local government plans (c) NRC Bulletin 2005-02 (d) RIS 2003-12 (e) RIS 2007-01 (f) RIS 2008-22 (g) FEMA REP Manual (h) FEMA REP 10 (i) NEI 06-12 (j) N El 99-02 (k) INPO 05-003 (I) INPO 08-007 (m)INPO 10-007 (n) Federal Register Vol. 76, No. 226, November 23, 201'1 5.3 10CFR50.54(q)(2) REVIEW NOTE Changes to procedures or modifications to equipment or facilities used to implement the emergency plan or maintain the emergency preparedness program may require a 10 CFR 50.54(q)(2) review to ensure those changes do not directly or indirectly reduce the ability to maintain the effectiveness of the emergency plan.

[1] Changes to emergency plans themselves may be processed without a 10CFR50.54(q)(2) review. Proceed to section 5.5, Screening.

[2] Proposed activities that may affect the emergency plan or affect the implementation of the emergency plan should be reviewed to determine whether or not the emergency plan or the ability to maintain the emergency plan is affected.

[3] IF the 10 CFR 50.54(q)(2) review determines that an activity results in a change to the emergency plan, THEN the activity is screened as a change under 10 CFR 50.54(q)(3).

[4] 10 CFR 50.54(q)(2) reviews are documented to the level necessary to ensure impact to the emergency plan and the ability to maintain the emergency plan requirements are sufficiently considered.

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 12 OF77 10CFR50.54 Review Pro ram 5.4 10CFR50.54(q)(2) FORM COMPLETION

[1] The purpose of Attachment 9.1 is to review a proposed activity to ensure that the emergency plan effectiveness is maintained.

[2] IF the 10 CFR 50.54(q)(2) review indicates that the emergency plan or EALs are affected or that the ability to maintain the effectiveness of the emergency plan could be reduced by implementation of the* change, THEN the change is not implemented without a change to the emergency plan or EALs using the 10 CFR 50.54(q)(3) screening and evaluation process.

[3] Heading: Provide procedure or document number being changed and identify equipment, facility or other change as appropriate. Identify a revision as appropriate. Identify an appropriate title for the item being changed. "N/A" may be used for heading fields as necessary (e.g., if the document or facility has no identifying number).

[4] Part I: Provide a description of the proposed change. This section may reference an attached document for a list of multiple changes or a procedure change listing or request/approval page, etc.

[5] Part II: Emergency Plan Sections Reviewed: . List all emergency plan sections \

)

reviewed by number and title.

[6] Part Ill: Ability to Maintain the Emergency Plan: This section directs the user to the 50.54(q)(3) screening and evaluation process if appropriate through the U§e of questions related to whether or not a proposed activity changes the emergency plan.

[7] Part IV: Maintaining the Emergency Plan

Conclusion:

Check the conclusion checkbox as applicable. Summarize how the conditions as described in the emergency plan are maintained. Unlike the screening process, each element of the change is not required to be addressed specifically.

e~Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED EN-EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 13 OF 77 Emergency Planning 10CFR50.54lal Review Program

[8] Part V: Signatures:

NOTE At a minimum, 10 CFR 50.54(q)(2) reviews are reviewed by the Nuclear EP Project Manager for the applicable site. This review does not require a "live" signature and may be noted in the appropriate area on Attachment 9.1.

(a) Preparer signs the form and obtains a review from at least one other qualified 50.54(q) reviewer. A corporate review may be waived under the following circumstances:

• The waiver is approved by the Director, Emergency Planning or designee,

• At least one review is performed by a qualified individual other than the preparer,

• The waiver is documented on the review line of the form ("live" signature not required),

)

• A copy of the completed 10CFR50.54(q)(2) review is provided to the

/

Director, Emergency Planning or designee.

(b) Attachment 9.1 is completed with an approval by the site Manager, Emergency Preparedness or designee (c) Ensure that the completed form is retained and filed in accordance with this procedure (refer to section 7.0) 5.5 SCREENING NOTE Changes to the emergency plan or Emergency Action Levels require a 10 CFR 50.54(q)(3) screening.

[1] Proposed activities that may affect the emergency plan or affect the implementation of the emergency plan should be reviewed in accordance with sections 5.3 and 5.4 to determine whether or not a 10 CFR 50.54(q) screening is necessary.

[2] Proposed activities that change the emergency plan or EALs or result in a 10 CFR 50.54(q)(2) review conclusion that the ability to follow and maintain the effectiveness of the emergency plan could be negatively impacted by implementation of the change are screened to determine whether or not a 10 CFR 50.54(q)(3) evaluation is necessary.

ta

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[3] The purpose of this screening is to determine whether or not a 10CFR50.54(q)(3) evaluation is needed rather than to determine if proposed activities reduce the effectiveness of the emergency plan.

[4] IF the screen determines that an activity is a non-editorial change to the emergency plan AND THEN also affects an emergency planning function or an element associated with a planning function, THEN the activity needs to be evaluated as a change under 10 CFR 50.54( q)(3).

(a) The activity affects an emergency planning function or an element associated with the function or element if it changes any of the following:

• the meaning or the intent of a description

• facilities or equipment

• a process

[5] IF the proposed activity does NOT affect program elements associated with one or more emergency planning functions, THEN the screening should conclude that a 10 CFR 50.54(q)(3) evaluation is not necessary.

[6] "Emergency planning function" means capabilities or resources necessary to prepare for and respond to a radiological emergency, as set forth in Appendix E and the planning standards of 10 CFR 50.47(b). The following are emergency planning functions. They are described in attachment 9.7:

(a) Assignment of responsibility/organizational control (b) Onsite emergency organization (c) Emergency response support and resources (d) Emergency classification system (e) Emergency notifications (f) Emergency communications (g) Emergency public information (h) Emergency facilities and equipment (i) Emergency assessment capability (j) Emergency protective actions (k) Emergency radiological exposure control (I) Emergency medical support (m)Recovery and reentry planning (n) Drill and exercise program (o) Emergency responder training (p) Emergency plan maintenance

A-~*Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED EN-EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 15 OF 77 Emergency Planning 10CFR50.54(a) Review Program NOTE In order to screen changes "separately" where multiple changes are being proposed at the same time (e.g., 16 changes to a procedure), the same screening form may be used for all changes provided the documentation within the form is clear that each change is reviewed separately, except where two or more changes may be treated collectively as noted in 5.5[7] below. *

[7] Each proposed change should be screened separately. However, the following types of changes may be treated collectively:

(a) Repetitive identical activities (b) Editorial or typographical changes such as formatting, paragraph numbering, spelling, or punctuation that do not change intent (c) Conforming changes (d) Two or more elements that are interdependent (e.g., a change to one element compensates for a change to another element)

NOTE

' Entergy sites may submit the entire package of 10 CFR 50.54(q) review documentation

)

in lieu of a summary to meet the requirement specified in 10 CFR 50.54(q)(5). -

[8] As specified in 10CFR50.4(b)(5)(ii) and 10CFR50.54(q)(5), a report of each change to the emergency plan that is made without prior NRC approval, including a summary of the 10CFR50.54(q) analysis, shall be submitted to the NRC w,ithin 30 days after the change is put in effect.

(a) The summary of each change to the emergency plan should include the following:

• A description of the change made to the emergency plan

• A description of why the change is editorial (if not editorial, skip this requirement and proceed to bullet 3)

• A description of the licensing basis affected by the change to the emergency plan (if not affected, omit this element)

• A description of how the change to the emergency plan still complies with regulation

• A description of why the proposed change was not a reduction in the effectiveness of the emergency plan

e~-Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED EN-EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 16 OF 77 Emernencv Planning 10CFR50.54(Q) Review Program 5.6 10 CFR 50.54(q)(3) SCREENING FORM COMPLETION NOTE Attachment 9.9 provides a template that may be used as an aid when completing 10 CFR 50.54(q)(3) screenings.

[1] The purpose of Attachment 9.2 is to screen a proposed activity that changes the emergency plan or EALs to determine if the activity affects a program element associated with an emergency planning function. This review is required for changes to EALs, EAL bases and the emergency plan as defined in 3.0[6]. The ultimate purpose is to determine if a 10CFR50.54(q)(3) evaluation should be performed.

[2] IF the screening indicates that an emergency planning function or element is affected as described in step 5.5[4](a), THEN a 10CFR50.54(q)(3) evaluation is

• performed in accordance with Attachment 9.3.

[3] Heading: Provide procedure or document number being changed or identify equipment, facility or other change as appropriate. Identify a revision as appropriate. Identify an appropriate title for the item being changed. "N/A" may be used for heading fields as necessary (e.g., if the document or facility has no identifying number).

[4] Part I: Provide a brief description of the proposed change.

[5] . Part II: IF the proposed change is fully bounded by a previous NRC or FEMA approval (for Alert and Notification System), THEN answer "YES" to Part II, provide justification for the conclusion, including bounding source document information and skip to Part VI.

[6] Part Ill: Determine whether or not other regulatory change control processes are applicable and to what extent to determine to continue with the screening for all or a portion of the proposed change or to complete the screening. Refer to EN-Ll-100.

(a) IF there are other controlling processes, THEN check the appropriate box and list the other controlling processes in the section provided (b) IF the change is fully bounded by another process, THEN check the appropriate box, list the other process in the section provided and skip to Part VI

[7] Part IV: Determine whether or not the change is editorial (refer to step 3.0[5] and EN-AD-101) and follow the checkbox instructions on Attachment 9.2.

(a) J..E...some changes are editorial and some are not, THEN it is acceptable to check "no," provide the justification for the editorial changes and provide the following statement: ""No" is checked because this activity contains other

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PAGE 17 OF 77 REV.4 changes that are not editorial." "Yes" would then be checked only when all changes in the document are editorial.

[8] Part V: IF any of the boxes related to the 29 items are checked, THEN a 10 CFR 50.54(q)(3) Evaluation is required. Complete Part VI and proceed to section 5.7.

(a) IF no items in Part V are checked, THEN an evaluation is not required.

Provide a basis for the conclusion and complete the screening activity by completing Part VI.

[9] Part VI: Approval NOTE At a minimum, 10 CFR 50.54{q)(3) screenings are reviewed by the Nuclear EP Project Manager for the applicable site. This review does not require a "live" signature and may be noted in the appropriate area on Attachment 9.2.

Attachment 9.11 provides a checklist for 10 CFR 50.54(q)(3) screening and evaluation reviewers that may be used as an aid when performing their review.

(a) Preparer signs the form and obtains a review from at least one other qualified 50.54{q) reviewer. A corporate review may be waived under the following circumstances:

• The waiver is approved by the Director, Emergency Planning or designee,

• At least one review is performed by a qualified individual other than the preparer,

• The waiver is documented on the review line of the form ("live" signature not required).

5.7 EVALUATION .

[1] Activities or proposed changes that do not screen out are evaluated to determine whether or not the change reduces the effectiveness of the emergency plan and thereby requires NRG approval prior to implementation.

[2] WHEN considering the impact of a change on one or more program elements, THEN note that a change to a single program element may not always reduce the effectiveness of the associated emergency planning function. This would need to be considered on a case by case basis.

[3] WHEN documenting the 10 CFR 50.54(q)(3) evaluation of a proposed change, THEN there must be an accompanying justification providing a basis for the evaluation. This justification should be complete in the sense that another knowledgeable reviewer would draw the same conclusion. Restatement of evaluation questions in a negative sense or making simple statements of conclusion is not sufficient and should be avoided.

--===:-~Entergy NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED INFORMATIONAL USE EN-EP-305 Emergency Planning 10CFR50.54(q) Review Program I

PAGE 18 OF 77 REV.4

[4] Clearly documenting the basis for the evaluation conclusion is important because experience and knowledge are often relied upon when performing a 10 CFR 50.54(q)(3) evaluation. Thus, the basis for the judgment and the logic used in the determination should be documented to the extent practicable and to a degree commensurate with the significance and complexity of the activity such that a knowledgeable reviewer would understand the basis for the judgment.

Since an important goal of the 1O GFR 50.54(q)(3) evaluation is completeness, the items considered by the evaluator must be clearly stated.

[5] Refer to Attachment 9.5 for examples of program changes described in Regulatory Guide 1.219. This attachment includes examples that would not require NRG prior approval; those that could require NRC prior approval, and changes that should have an exchange of technical information between the site and NRG (conference call) prior to finalization. This attachment also contains operating experience related to 10 GFR 50.54(q).

NOTE Entergy sites may submit the entire package of 10 GFR 50.54(q) review documentation in lieu of a summary to meet the requirement specified in 1O GFR 50.54(q)(5).

[6] a As specified in 10CFR50.4(b)(5)(ii) and 10GFR50.54(q)(5), report of each change to the emergency plan that is made without prior NRC approval, including a summary of the 10CFR50.54(q) analysis, shall be submitted to the NRG within 30 days after the change is put in effect.

(a) The summary of each change to the emergency plan should include the following:

• A description of the change made to the emergency plan

• A description of why the change is editorial (if not editorial, skip this requirement and proceed to bullet 3)

• A description of the licensing basis affected by the change to the emergency plan (if not affected, omit this element)

• A description of how the change to the emergency plan still complies with regulation

• A description of why the proposed change was not a reduction in the effectiveness of the emergency plan

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 190F77 10CFR50.54 Review Pro ram 5.8 10CFR50.54(q)(3) EVALUATION FORM COMPLETION NOTE Attachment 9.1 O provides a template that may be used as an aid when completing 10 CFR 50.54(q)(3) evaluations.

[1] Identify and describe the individual proposed changes to the emergency plan to be evaluated.

NOTE In order to evaluate changes "separately" where multiple changes are being proposed at the same time (e.g., 16 changes in an emergency plan revision), the same evaluation form may be used for all changes provided the documentation within the form is clear that each change is evaluated separately except where two or more changes may be evaluated collectively as noted in 5.8[2] below.

[2] Each proposed change should be evaluated separately. However, the following types of changes may be treated collectively:

(a) Repetitive identical activities (b) Conforming changes (c) Two or more elements that are interdependent (e.g., a change to one element compensates for a change to another element)

[3] Heading: Provide procedure or document number being changed or identify equipment, facility or other change as appropriate. Identify a revision as appropriate. Identify an appropriate title for the item being changed and (Part I) provide a brief description of the proposed change. "N/A" may be used for heading fields as necessary (e.g., if the document or facility has no identifying number).

(a) Identify the affected emergency plan sections or procedure sections. Identify relevant references used.

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 20 OF77 10CFRS0.54 Review Pro ram

[4] Part II: Determine if the proposed change affects the licensing basis. The impact of a proposed change cannot be adequately assessed without knowledge of the rationale for the original structure of the affected program element. When making this determination:

(a) Review the relevant sections of the emergency plan (b) Review the differences between the current emergency plan and the one with the last NRC approved Safety Evaluation Report (SER). Include in this review historical changes made under 10 CFR 50.54(q) without prior NRC approval. Identify the reason for differences between the current emergency plan and the NRC approved emergency plan and/or historical emergency plan changes made under 10 CFR 50.54(q) (e.g., need to compensate for preparedness or response constraints or vulnerabilities specific to the facility, emergency planning zone (EPZ), and jurisdiction).

• Some stations may not be able to identify an NRC approved emergency plan with SER. In this case, reviewers should review historical emergency plans as far back as possible and state the process they used in Part II of the form. All due diligence should be applied in researching and locating an NRC approved original emergency plan/SER.

(c) Relevant license amendments, license conditions, regulatory commitments and correspondence may be reviewed (d) Relevant Commission Orders and related inspection findings may be reviewed (e) Relevant statements of consideration may be reviewed

• Statements of consideration (SOC) are published in the Federal Register for a final 10 CFR rule change. It includes the NRC's analysis and disposition of comments that they received on the proposed rule change.

It often provides clarifying information as to the intent or extent of the changes. There may not be a separate "SOC", but the Federal Register notice for the final rule should include the NRC's analysis and disposition of comments (f) Relevant regulatory generic correspondence, findings, or violations related to similar changes may be reviewed (g) Review relevant statements in the FEMA ANS Design Report as applicable to the change

[5] Part 111: Describe how the proposed change complies with regulations and previous commitments made to the NRC. (Note that proposed changes that do not comply with regulations must be rejected, exempted in accordance with 10 CFR 50.12, or modified so that they do. comply with regulations).

e~-Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED EN-EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 21OF77 Emergencv Planning 10CFR50.54(q) Review ProQram

[6] Part IV: Discuss each emergency planning standard, function and program element (or approved alternative to program element) affected by the proposed change that was checked as applicable on Screening Form Part V:

NOTE A reduction in effectiveness will occur if there is a decrease in the capabilities or timeliness for performing or fulfilling a function or commitment without activities to compensate for the r13duction.

[7] Part V: For each affected function, element or commitment being reviewed, describe the impact of the proposed change (a) Consider whether the proposed change may have impact on more than one emergency planning function (b) Consider the overall impact of the proposed change on the effectiveness of the emergency plan, or its implementation, and not just the effect that individual changes have on a specific part of the emergency plan (c) A comparison of how the affected function, element or commitment is currently fulfilled and how it will be fulfilled as a result of the proposed activity should be documented (d) Documentation should include a discussion of the capability to meet or perform the function, element, or commitment that exists following the change compared to that which existed prior to the change

• IF the change still implements the planning standard utilizing a different method, THEN document the new method and describe how the change does, or does not, reduce the effectiveness of the plan (e) Timeliness of the function, element or commitment should also be addressed (f) Documentation should provide a clear basis for the any differences (e.g.,

special circumstances that require the difference in order to effectively perform the function or as a matter of convenience or operating philosophy)

(g) Documentation should qualify the difference as improving, sustaining or reducing the effectiveness of the planning standard function or commitment (h) Conclusions made under 50.54(q)(3) should be supported by defensible rational statements (e.g., "the proposed change does not affect planning standard (b)(5) because ... ")

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 22 OF77 10CFR50.54 Review Pro ram

[8] Part VI: Evaluation Conclusion (a) Answer the following questions based on the evaluation performed above:

• Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E?

• Does the proposed change maintain the emergency plan (i.e., no reduction in effectiveness)?

• Does the proposed change constitute an emergency action level scheme change?

(b) IF the proposed change complies with the federal regulations discussed above, complies with the site's regulatory commitments, is NOT an emergency action level scheme change AND would NOT result in a reduction in effectiveness of the emergency plan, THEN it may be implemented (c) IF the proposed change does NOT comply with 10 CFR 50.47(b) or 10 CFR 50 Appendix E, THEN it must be rejected, exempted in accordance with 10 CFR 50.12 or modified to comply with the regulations (d) IF a proposed change is an emergency action level scheme change, THEN it must be submitted to the NRC for prior approval as a License Amendment Request (LAR) in accordance with 10 CFR 50.90 and EN-Ll-103 (e) A proposed change that does not comply with a regulatory commitment must be revised to comply with the commitment or action taken to change the commitment in accordance EN-Ll-11 O (f) A proposed change determined to be a reduction in the effectiveness of the emergency plan should be modified such that it no longer is a reduction in the effectiveness of the emergency plan or the proposed change should be submitted to the NRC for prior approval as a License Amendment Request (LAR) in accordance with 10 CFR 50.90 and EN-Ll-103.

A-::::::r:-Entergy NUCLEAR MANAGEMENT NON*QUALITY RELATED EN-EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 23 OF 77 Emeraencv Planning 10CFR50.54(a) Review Program

[9] Part VII: Approval NOTE At a minimum, 10CFR50.54(q)(3) evaluations are reviewed by the Nuclear EP Project Manager for the applicable site. This review does not require a "live" signature and may be noted in the appropriate area on Attachment 9.3.

Attachment 9.11 provides a checklist for 10 CFR 50.54( q)(3) screening and evaluation reviewers that may be used as an aid when performing their review.

(a) Preparer signs the form and obtains a review from at least one other qualified 50.54(q) reviewer. A corporate review may be waived under the following circumstances:

• The waiver is approved by the Director, Emergency Planning or designee,

• At least one review is performed by a qualified individual other than the preparer,

• The waiver is documented on the review line of the form ("live" signature not required),

• A copy of the completed 10CFR50.54(q)(3) evaluation is provided to the Director, Emergency Planning or designee.

(b) Attachment 9.3 is completed with an approval by the site Manager, Emergency Preparedness or designee (c) Ensure that the completed evaluation form is retained and filed in accordance with this procedure (refer to section _7.0)

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 24 OF 77 10CFR50.54 Review Pro ram 5.9 QUALIFICATIONS

[1] Personnel who prepare, review and/or approve 10 CFR 50.54(q)(2) and 10 CFR 50.54(q)(3) documents should be qualified to ensure that they are capable of performing those functions. These personnel should be capable of generating documents that are systematically prepared, thoroughly researched, and adequately documented.

NOTE Corporate reviews of 10CFR50.54(q)(2) and 10CFR50.54(q)(3) documents are performed to ensure an adequate level of fleet consistency and rigor. Site specific requirements are not applicable for the corporate reviewer.

NOTE The list provided in 5.9[2] below represents general background and knowledge needed for performing a 10CFR50.54(q)(2) review, 10CFR50.54(q)(3) screening or 10CFR50.54(q)(3) evaluation and is not all inclusive. A specific 10CFR50.54(q) review may require use and review of other documents at the time (e.g., ANS design report, state and local government plans, other regulatory guidance documents, etc.).

Additional potentially relevant documents are listed in step 5.2[6].

[2] The Manager, Emergency Preparedness (Director, Emergency Planning for corporate reviewers and site Managers, Emergency Preparedness) should approve Attachment 9.4 for each person qualified to perform 10CFR50.54(q) activities based on EP experience and knowledge of the following documents:

(a) EN-EP-305 (b) Site E-Plan (c) Site EP implementing procedures (d) Site EALs (e) Safety analysis section on EP (f) 10CFR50.47 (b)

(g) 10CFR50.54(q)

(h) 10CFR50 Appendix E (i) NUREG 0654, and supplements 1, 2 and 3 (j) Regulatory Guide 1.101 (k) Regulatory Guide 1.219

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 25 OF77 10CFR50.54 Review Pro ram (I) NUREG 0696 (m) NUREG 0737 (n) RIS 2005-02 (o) RIS 2003-018 Supp 2 (p) NEI 11-03

[3] The person performing qualification should document the date on Attachment 9.4 .

that he or she receives training or completes required reading on the identified documents.

[4] Managers, Emergency Preparedness are required to complete assigned reading as noted on Attachment 9.4 prior to being qualified to sign 10 CFR 50.54(q) documentation as an approver.

(a) The Director, Emergency Planning approves Attachment 9.4 for Managers, Emergency Preparedness.

[5] Provide the completed form to Training to be documented using curriculum F-EP-50540, 10CFR50.54(q) Qualification.

)

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4

,__,_ 'Entergy MANAGEMENT MANUAL INFORMATIONAL USE PAGE 26 OF 77 10CFR50.54 Review Pro ram 6.0 INTERFACES

[1] EN-Ll-102, "Corrective Action Program"

[2] EN-AD-103, "Document Control and Records Management Programs"

[3] EN-Ll-103, "Operating License Amendments"

[4] EN-Ll-100, "Process Applicability Determination"

[5] EN-Ll-101, "1 OCFR50.59 Evaluations"

[6] EN-Ll-110, "Commitment Management Program"

[7] EN-Ll-113, "Licensing Basis Document Change Process"

[8] EN-Ll-106, "NRG Correspondence"

[9] EN-AD-101, "Procedure Process" 7.0 RECORDS NOTE Although regulations do not require the licensee to maintain records of changes made without prior NRG approval beyond 3 years, a lack of change documentation does not absolve the licensee from having to justify any change that is subsequently questioned about its impact on the effectiveness of the licensee's emergency plan. *As such, a licensee may find it prudent to save all emergency plan change documentation to facilitate the resolution of such issues.

[1] 10 CFR 50.54(q)(2) review, 10 CFR 50.54(q)(3) screening and 10 CFR 50.54(q)(3) evaluation forms (Attachments 9.1, 9.2 and 9.3) are records and should be processed with the document being reviewed.

(a) IF the review/screening/evaluation form does not accompany the document being reviewed, THEN it should be processed in accordance with EN-AD-103 and maintained as a record until the Commission terminates the license for the nuclear power reactor (b) Retain changes made under 10 CFR 50.54(q)(3) without NRG prior approval as a record until the Commission terminates the license for the nuclear power reactor

[2] Qualification records (Attachment 9.4) should be forwarded to permanent plant files.

[3] 10 CFR 50.54(q)(6) requires the licensee to retain the emergency plan and each change for which it obtained prior NRG approval under 10 CFR 50.54(q)(4) as a record until the Commission terminates the license for the nuclear power reactor.

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 27 OF 77 10CFR50.54 Review Pro ram 8.0 SITE SPECIFIC COMMITMENTS None 9.0 ATTACHMENTS 9.1 10 CFR 50.54(q)(2) Review 9.2 10 CFR 50.54(q)(3) Screening 9.3 10 CFR 50.54(q)(3) Evaluation 9.4 10CFR50.54(q) Training Documentation 9.5 Reg Guide 1.219 Example Changes 9.6 Additional Regulatory Guidance

9. 7 Planning Standards, Appendix E, Functions and Elements 9.8 Background Information 9.9 10 CFR 50.54(q)(3) Screening Template 9.1 O 10 CFR 50.54(q)(3} Evaluation Template 9.11 10 CFR 50.54(q) Project Manager Review Checklist

NON-QUALITY RELATED EN-EP-305 REV.4 NUCLEAR MANAGEMENT MANUAL INFORMATIONAL USE PAGE 28 OF 77 1 OCFR50.54 Review Pro ram ATTACHMENT9.1 10 CFR 50.54{a}{2} REVIEW SHEET1 OF2 Procedure/Document Number: I Revision:

Equipment/Facility/Other:

Title:

Part I. Description of Activity Being Reviewed (event or action, or series of actions that have the potential to affect the emergency plan or have the potential to affect the implementation of the emergency plan):

Part II. Emergency Plan Sections Reviewed (List all emergency plan sections that were reviewed for this activity by number and title. IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE, EAL CHANGE OR EAL BASIS CHANGE, ENTER THE SCREENING PROCESS. NO 10 CFR 50.54(q)(2) E>OCUMENTATION IS REQUIRED.

Part Ill. Ability to Maintain the Emergency Plan (Answer the following questions related to impact on the ability to maintain the emergency plan):

1. Do any elements of the activity change information contained in the emergency plan (procedure section 3.0[6])?

YES D NO D IF YES, enter screening process for that element

2. Do any elements of the activity change an emergency classification Initiating Condition, Emergency Action Level (EAL); associated EAL note or associated EAL basis information or their underlying calculations or assumptions?

YES D NO D IF YES, enter screening process for that element

3. Do any elements of the activity change the process or capability for alerting and notifying the public as described in the PEMA-approved Alert and Notification System design report?

YES D NO D IF YES, enter screening process for that element

4. Do any elements of the activity change the Evacuation Time Estimate results or documentation?

YES D NO .D IF YES, enter screening process for that element

5. Do any elements of the activity change the Onshift Staffing Analysis results or documentation?

YES D NO D IF YES, enter screening process for that element

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 29 OF 77 10CFR50.54 Review Pro ram ATTACHMENT 9.1 10 CFR 50.54(0)(2) REVIEW SHEET20F2 Procedure/Document Number: IRevision:

Equipment/Facility/Other:

Title:

Part IV. Maintaining the Emergency Plan Conclusion The questions in Part II do not represent the sum total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Part IV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.

1. Provide a brief conclusion that describes how the conditions as described in the emergency plan are maintained with this activity.

2. Check the box below when the 10 CFR 50.54(q)(2) review completes all actions for all elements of the activity - no 10 CFR 50.54(q)(3) screening or evaluation is required for any element. Otherwise, leave the checkbox blank.

D I have completed a review of this activity in accordance with 10 CFR 50.54(q)(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan.

No further actions are required to screen or evaluate this activity under 10 CFR 50.54(q)(3).

Part V. Signatures:

Preparer Name (Print) Preparer Signature Date:

(Optional) Reviewer Name (Print) Reviewer Signature Date:

Reviewer Name (Print) Reviewer Signature Date:

Nuclear EP Project Manager Approver Name (Print) Approver Signature Date:

Manager, Emergency Planning or designee

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 30 OF77 10CFR50.54 Review Pro ram ATTACHMENT 9.2 10 CFR 50.54(a)(3) SCREENING SHEET1 OF3 Procedure/Document Number: I Revision:

Equipment/Facility/Other:

Title:

Part I. Description of Activity Being Reviewed (This is generally changes to the emergency plan, EALs, EAL bases, etc. - refer to step 3.0[6]):

Part II. Activity Previously Reviewed? DYES ONO Is this activity fully bounded by an NRG approved 1 O CFR 50.90 submittal or 50.54(q)(3) Continue to Evaluation is ne:Xt part Alert and Notification System Design Report? NOT required.

Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and complete Part proposed change is documented below: VI.

Justification:

D Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

APPLICABILITY CONCLUSION D If there are no other controlling change processes, continue the 50.54(q)(3) Screening.

D One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

D One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT reauired. Identify controllina chanae orocesses below and comolete Part VI.

CONTROLLING CHANGE PROCESSES Part IV. Editorial Change DYES ONO 50.54(q)(3) Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.

Justification: Enter justification and continue to next part or complete Part VI as applicable.

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4

-~Entergy MANAGEMENT INFORMATIONAL USE MANUAL PAGE 31 OF77 10CFR50.54 Review Pro ram ATTACHMENT 9.2 10 CFR 50.54(a)(3) SCREENING 5HEET20F3 Procedure/Document Number: I Revision:

Equipment/Facility/Other:

Title:

Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NU REG-0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1] D

2. The response organization has the staff to respond and to augment staff oh a continuing basis (24/7 D staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] D

4. The process for timely augmentation of onshift staff is established and maintained. [2] D

5. Arrangements for requesting and using off site assistance have been made. [3] D

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] D

7. A standard scheme of emergency classification and action levels is in use. [4] D

8. Procedures for notification of State and local governmental agencies are capable of alerting them of D the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt D instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response D organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6] D

13. Emergency preparedness information is made available to the public on a periodic basis within the D plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. [7] D

15. Adequate facilities are maintained to support emergency response. [8] D

16. Adequate equipment is maintained to support emergency response. [8] D

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] D

18. A range of public PARs is available for implementation during emergencies. [1 O] D

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are D available to support the formulation of PARs and have been provided to State and local governmental authorities. [1 O]

20. A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events.[1 O]

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 32 OF 77 1 OCFR50.54 q Review Pro ram ATIACHMENT 9.2 10 CFR 50.54(a)(3) SCREENING SHEET30F3 Procedure/Document Number: I Revision:

Equipment/Facility/Other:

Title:

21. The resources for controlling radiological exposures for emergency workers are established. [11] D

22. Arrangements are made for medical services for contaminated, injured individuals. [12] D

23. Plans for recovery and reentry are developed. [13] D

24. A drill and exercise program (including radiological, medical, health physics and other program D areas) is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, D maintain, and dem_onstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]

26. Identified weaknesses are corrected. [14] D

27. Training is provided to emergency responders. [15] D

28. Responsibility for emergency plan development and review is established. [16] D

29. Planners responsible for emergency plan development and maintenance are properly trained. [16] D APPLICABILITY CONCLUSION 0 If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI.

0 If any Part V criteria are checked, complete Part VI and perform a 50.54(q}(3} Evaluation.

BASIS FOR CONCLUSiON Part VI. Signatures:

Preparer Name (Print) Preparer Signature Date:

(Optional} Reviewer Name (Print) Reviewer Signature Date:

Reviewer Name (Print) Reviewer Signature Date:

Nuclear EP Project~~nager Approver Name (Print) Approver Signature Date:

Manager, Emergency Planning or designee

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4

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Equipment/Facility/Other:

Title:

Part I. Description of Proposed Change:

Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

Part Ill. Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:

Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change:

Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

NUCLEAR NON*OUALITV RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 34 OF 77 10CFR50.54 Review Pro ram ATTACHMENT 9.3 10 CFR 50.54(0)(3) EVALUATION 5HEET2 OF2 Procedure/Document Number: I Revision:

Equipment/Facility/Other:

Title:

Part VI. Evaluation Conclusion Answer the following questions about the proposed change.

1. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? 0YES0NO

2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no 0YES0NO reduction in effectiveness)?

3. Does the proposed change constitute an emergency action level scheme change? 0YES0NO If questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRC approval under provisions of 10 CFR 50.90. If questions 1 and 2 are answered YES, and question 3 answered NO, implement applicable change process( es). Refer to step 5.8[8].

Part VII. Signatures Preparer Name (Print) Preparer Signature Date:

(Optional) Reviewer Name (Print) Reviewer Signature Date:

Reviewer Name (Print) Reviewer Signature Date:

Nuclear EP Project Manager Approver Name (Print) Approver Signature Date:

Manager, Emergency Preparedness or designee

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 35 OF77 10CFR50.54 q Review Pro ram ATTACHMENT 9.4 10 CFR 50.54(a) TRAINING DOCUMENTATION 5HEET1OF1 10CFR50.54(q) Training Documentation TRAINING COMPLETION DATE

• Site Specific Emergency Plan (Site training or required reading)

• Site Specific Implementing Procedures (Site training or required reading)

AND

• NEI Emergency Planning Training Course (N/A for site Managers, Emergency Preparedness)

OR

• One Year of Emergency Planning Experience or equivalent experience as determined by the site Manager, Emergency Preparedness (N/A for site Managers, Emergency Preparedness)

AND

• Required reading or Training on the following:

- EN.,EP-305

- 10CFR50.47(b)

- 10CFR50.54(q)

- 10CFR50 Appendix E

- NUREG 0654 and supp. 1, 2 and 3

- Regulatory Guide 1.101

- Regulatory Guide 1.219

- NUREG-0696

- NUREG 0737

- RIS 2005-02

- RIS 2003-018 Supp 2

- NEI 11-03

- Site EALs

- Safety analysis section on EP (site specific)

Manager, Emergency Preparedness Date

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 36 OF 77 10CFR50.54 Review Pro ram ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES SHEET1OF13 Note: Examples cannot be used as precedence without first evaluating the licensee's specific circumstances to ensure no reduction in effectiveness results.

1.0 Examples of changes to the licensee's emergency plan

1. Changes that would generally not require prior NRC approval,

2. Changes for which NRC encourages an exchange of information on technical issues before finalization,

3. Changes that could require prior NRC approval, and

4. Operating Experience related to 10 CFR 50.54(q).

1.1 The following are Examples of changes to the licensee's emergency plan that would generally not require prior NRC approval provided that site-specific commitments continue to be met:

(In those cases where the change involves a replacement, the 10 CFR 50.54(q) evaluation must document the basis for equivalency conclusions.)

10 CFR 50.47(b)(1) - Assignment of Responsibility/Organizational Control Proposed changes to ERO names or titles if they do not change the functional relationships, authorities, competencies, or responsibilities for key positions identified in the plan.

10 CFR 50.47(b)(2) - Onsite Emergency Organization A change to ERO staffing levels resulting from changes in circumstances or gains in efficiency provided that it does not impact the timeliness and accuracy of the ERO's performance of major functional areas or major tasks. in accordance with the emergency plan. The installation of digital display screens that eliminate the need for status board keepers, the collocation of offsite personnel at the EOF that eliminates the need for liaison positions, and the installation of messaging systems that reduce the needed number of communicators are examples of this type of change.

A~Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED EN-EP-305 1 REV.4 MANUAL INFORMATIONAL USE PAGE 370F77 Emergency Planning 10CFR50.54Cal Review Proaram ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES SHEET2OF13 10 CFR 50.47(b)(3) - Emergency Response Support and Resources A change to the EOF structure, organization, or location that would impede the principal OROs from participating in the response at the EOF would generally not require NRC approval provided that these organizations accept the availability of reliable telecommunications capabilities (e.g.,

videoconferencing, WebEOC', or digital display boards connected via a data link) as viable alternatives.

10 CFR 50.47(b)(4) - Emergency Classification System A change to an EAL numeric threshold to reflect an approved change in a technical specification provided that the basis of the approved EAL is unchanged (e.g., an EAL basis refers to a particular technical specification but not a limiting condition for operation value).

A change to an EAL numeric threshold to reflect a change in a plant design parameter, instrument response characteristics, or design calculation provided that the meaning or intent of the basis of the approved EAL is unchanged.

RIS 2003-18 provides the following examples of changes that are considered differences from the standard EAL scheme, but still retain the original intent of the scheme. Each proposed change must be compared to the plant specific emergency plan requirements to determine if a reduction in effectiveness exists.

• Choosing the applicable EAL based on plant type (BWR vs. PWR).

• Using a different numbering scheme than the NEI 99-01 scheme without changing the intent of the overall EAL scheme. However, licensees are encouraged to adopt the NEI 99-01 numbering convention to facilitate communication among licensees, and between licensees, the NRC, and State and local governmental authorities.

• The NEI guidance specifically provides an option not to include an EAL if equipment for the EAL does not exist at the site (e.g., automatic real-time dose assessment capability and telemetered perimeter rad monitoring systems), and the licensee, therefore, does not include the EAL.

• Pulling information from the basis section up to the actual EAL that does not change the intent of the EAL.

• Stating "ALL" operating modes are applicable instead of stating "N/A" for the Independent Spent Fuel Storage Installation (ISFSI) EALs, or listing each mode individually under the Abnormal Rad Level/Radiological Effluent and Hazard and Other Conditions Affecting Plant Safety sections.

e~-Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED EN-EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 38 OF77 Emergencv Planning 10CFR50.54lal Review Program ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES SHEET30F 13

• Using synonymous wording, for example:

• rising or lowering vs. increasing and decreasing

• greater than or equal to vs. at or above

• less than or equal vs. at or below

• greater than or less than vs. above or below

• Adding site-specific equipmenVinstrument identification and/or noun names to EALs.

• Changing the format of the EALs to conform to site-specific writers guides (e.g., numbering individual EALs, re-ordering individual EALs within an IC that does not affect the logic, etc.).

• Combining like ICs that are exactly the same but have different operating modes as long as the intent of each IC is maintained and the overall progression of the EAL scheme is not affected.

• Any change to the IC and/or EAL, and/or basis wording, as stated in NEI 99-01, that does not alter the intent of the IC and/or EAL, i.e., the IC and/or EAL continues to:

• Classify at the. correct classification level

• Logically integrate with other EALs in the EAL scheme

• Ensure that the resulting EAL scheme is complete (i.e., classifies all potential emergency conditions) 10 CFR 50.47(b)(5) - Emergency Notifications A change to emergency notification forms to implement an EAL designation scheme that was coordinated with the OROs.

A change to emergency notification protocols requested by a State to have a follow-up verbal discussion between the licensee and the State to discuss the licensee's PAR provided that the initial notification, including the PAR, continues to be made promptly within 15 minutes of the emergency declaration.

10 CFR 50.47(b)(6) - Emergency Communications A change to replace the phone-talker relay of interfacility communications with digital data communication provided that the replacement is equivalent to, or better than, the current system with regard to timeliness, accuracy, and reliability.

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-,.;r. 'Entergy MANAGEMENT MANUAL INFORMATIONAL USE PAGE 39 OF 77 10CFR50.54 Review Pro ram ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES SHEET4OF13 10 CFR 50.47(b)(7) - Emergency Public Information A revision to the annual emergency information packet that changes the format from a brochure to a calendar provided that the calendar still includes all required information.

10 CFR 50.47(b)(8) - Emergency Facilities and Equipment A change that replaces existing ERF equipment with equipment of like quality, reliability, performance, and user interface.

A planned change to relocate the EOF that impedes the principal OROs from participating in the response from the EOF provided that these organizations accept the availability of reliable telecommunications capabilities (e.g., videoconferencing, WebEOC', or digital display boards connected via a data link) as viable alternatives.

10 CFR 50.47(b)(9) - Emergency Assessment Capability A change that replaces existing field monitoring equipment with equipment of like quality, reliability, performance, and user interface.

A change to dose assessment software that updates site parameter files to reflect a change in detector isotopic efficiencies provided that it results from an approved upgrade to the effluent radiation monitoring system.

10 CFR 50.47(b)(10) - Emergency Protective Actions A change that replaces existing PPE with equipment of like quality, reliability, performance, and operation.

A change to a PAR decision that removes Kl as a PAR option for the public following the decision by State officials to no longer issue Kl to the public.

• 10 CFR 50.47(b)(11) - Emergency Radiological Exposure Control A change that replaces existing radiological protection instrumentation (e.g., friskers, survey instruments, continuous air monitors, or dosimeters) relied on in the emergency plan with equipment of like quality, reliability, performance, and operation.

10 CFR 50.47(b)(12) - Emergency Medical Support A change in the designation of a replacement offsite medical facility provided that the new facility has equivalent capabilities and is accessible within a timeframe consistent with the urgency of emergency medical treatment.

e-::::::::--Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED EN*EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 40 OF 77 Emernencv Plannin~ 10CFR50.54(q) Review Program ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES SHEET 5OF13 10 CFR 50.47(b)(13) - Recovery and Reentry Planning A proposed change to the general framework of a recovery organization to reflect changes in position titles made in the normal operating organizations. '

10 CFR 50.47(b)(14) - Drill and Exercise Program A change in the overall exercise program schedule provided that the program continues to meet the scheduling requirements in Appendix E to 10 CFR 50.

10 CFR 50.47(b)(15) - Emergency Responder Training A change to emergency training program lesson plans to conform with approved changes in the emergency plan or to plant systems and equipment relied on in that plan.

10 CFR 50.47(b)(16) - Emergency Plan Maintenance A proposed change that consolidates some site emergency preparedness program maintenance and review activities with those of sister facilities within a corporation provided that site-specific commitments continue to be met.

1.2 Examples of changes to the licensee's emergency plan for which the NRC encourages that licensees arrange a conference call with NRC Headquarters staff for an exchange of information on technical issues before finalizing a change evaluation that concludes that the changes will not reduce the effectiveness of the plan:

10 CFR 50.47(b)(2)

• Onsite Emergency Organization A change that increases the activation time of licensee ERFs or a change in how the activation time is measured (e.g., when the activation period starts and when it ends), either of which results in a delay in those facilities' provision of meaningful support to the control room consistent with the facilities' assigned functions and responsibilities.

A change to ERO staffing that eliminates a key position (i.e., (1) control room (shift manager (emergency director) and shift communicator), (2) TSC (senior manager, operations support, radiological controls, TSC communicator, and technical support), (3) EOF (senior manager, protective measures, and EOF communicator), and (4) OSC (OSC operations manager), or reduces the licensee's capability to staff those positions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week (i.e., 24/7 support}, consistent with the fitness-for-duty requirements in 10 CFR 26, "Fitness for Duty Programs."

A*::;::::.:::"'Entergy NUCLEAR MANAGEMENT NON*OUALITY RELATED EN-EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 41OF77 Emergency Planning 10CFR50.54(q) Review Program ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES 5HEET6OF13 10 CFR 50.47(b)(8) - Emergency Facilities and Equipment A change that relocates the TSC to a location outside of the protected area for the plant site.

10 CFR 50.47(b)(16) - Emergency Plan Maintenance A change that combines the plant-specific emergency plan for two or more noncontiguous plant sites into a common emergency plan.

1.3 Examples of changes to the licensee's emergency plan that could require prior NRG approval:

10 CFR 50.47(b)(1) - Assignment of Responsibility/Organizational Control A change that would reduce the authority and responsibility of persons filling key positions to perform their emergency assignments in accordance with the emergency plan.

A change that assigns major functional areas or major tasks to two or more onsite organizations simultaneously such that it would not be clear to ERO members and the OROs which organization has the authority and responsibility for the activity at any point in the response. An example of this type of change could be one in which the TSC and EOF would perform dose projection functions concurrently without assigned hierarchical responsibility.

A change that would reduce the licensee's capability to staff key ERO positions identified in the plan on a 24/7 basis in accordance with the licensee'.s fitness-for-duty requirements.

10 CFR 50.47(b)(2) - Onsite Emergency Organization A change that would cause any of the major functional areas or major tasks identified in the emergency plan to be unassigned. An example of this type of change would be replacing qualified radiation protection technicians with other personnel who do not have the requisite qualification to provide radiation protection coverage to personnel other than themselves (e.g.,

coverage for an offsite fire department responding onsite).

• A change that increases the ERO augmentation time or a change in how the augmentation time is determined (e.g., when the augmentation period starts and when it ends) could require prior NRG approval if either one would increase the delay in providing meaningful support to the onshift organization beyond the times currently established in the emergency plan. An example of this type of change would be one in which the committed augmentation time is extended by 10 minutes to account for traffic delays or ERO notification or one in which the EOF is relocated such that the augmentation times can no longer be met because of increased ERO travel distances.

A change that eliminates key positions identified in the plan and reassigns the responsibilities of the eliminated positions to other key positions (e.g., multiple functions) and if it would result in an

• ERO member being assigned duties that could be expected to be performed concurrently rather than sequentially. An example of this type of change would be one in which control room

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4

• ~Entergy MANAGEMENT MANUAL INFORMATIONAL USE PAGE 42 OF77 10CFR50.54 Review Pro ram ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES 5HEET7OF13 communicator responsibilities are assigned to a fire brigade member or one in which dose assessment responsibilities are assigned to a shift technical advisor.

A change that would reduce the availability, or timeliness, of offsite corporate support resources relied on in the plan. An example of this type of change would be a consolidation of corporate entities that relocates material, equipment, or personnel relied on in the plan and that impedes the timely availability of these elements to the ERO.

10 CFR 50.47(b)(3) - Emergency Response Support and Resources A change that reduces the availability or scope of the onsite services provided by local agencies (e.g., local law enforcement and fire fighting).

A change that would delay the in-processing of offsite assistance relied on in the emergency plan.

For example, health physics personnel are not available to provide radiological coverage to ambulance crews or fire fighting assistance.

A change that replaces an offsite radiological laboratory relied on in the emergency plan with a laboratory that does not have the capabilities or licenses that allow it to receive and analyze the radioactive samples anticipated in the emergency plan.

10 CFR 50.47(b)(4) - Emergency Classification System A change that would reduce the licensee's capability to assess, classify, and declare an emergency condition within 15 minutes of the availability of indications that an EAL has been exceeded and to promptly declare the emergency condition as soon as possible following the identification of the appropriate emergency classification level. Examples include (a) a change to the normal shift complement that would delay the licensee's capability to classify an emergency condition by making the expertise to read or interpret a seismic instrument reading cited in the EAL scheme unavailable on shift, (b) a change to the EAL scheme that would eliminate all predetermined radiation monitor EAL thresholds and rely instead on manually initiated dose projections, (c) a change to ERO staffing that would impact the timeliness of emergency declaration by assigning competing duties to the ERO positions that are responsible for performing emergency classifications, and (d) a change to a facility procedure that directs that the 15-minute declaration period starts only after the duration of the condition incorporated in the EAL (e.g., a fire lasting for 10 minutes) has elapsed.

A change to a particular EAL that renders it ineffective such that an accurate classification and timely declaration would not occur as required for an event. Examples include (a) a change to mode applicability of the EAL that excludes an operating mode in which the EAL should be applicable, (b) a change to the logic of an EAL that would result in a particular event not being declared when the declaration would have occurred before the change, (c) a change that would replace a viable quantifiable EAL threshold (e.g., an instrument reading or alarm) with a qualitative EAL that relies on user judgment to reach a declaration, (d) a change that re-expresses field monitor EALs in radiation units (e.g., total effective dose equivalent) that could not

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 430F77 10CFR50.54 Review Pro ram ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES SHEETS OF 13 be measured directly in the field and for which monitoring procedures provide no conversion algorithm, and (e) a change to the language of a particular EAL that would render the classification logic unclear and could potentially result in an inaccurate classification (e.g., a site area emergency EAL that reads "vandalism to safety-related equipment" without further qualification or quantification could be applied to events as diverse as someone putting graffiti on an inverter cabinet surface or someone hitting a safety injection pump casing with a sledge hammer).

A change that would result in an EAL that deviates from the meaning or intent of the approved EAL bases such that the classification of the event would be different from that approved by the NRC in a site-specific application or from an endorsed industry EAL scheme that had been approved for licensee use.

RIS 2003-18 provides the following examples of changes that are considered deviations from the standard EAL scheme and would constitute a reduction in effectiveness of the emergency plan and require NRC approval prior to implementation.

• Eliminating an IC. This includes removing an IC from the Fission Product Barrier Degradation category because doing so impacts the logic of Fission Barrier ICs.

• Changing a Fission Product Barrier EAL from a LOSS to a POTENTIAL LOSS, or vice versa.

• Changing a defined term where the intended meaning of the defined word is not maintained.

• Any change to the IC and/or EAL, and/or basis, wording as stated in NEI 99-01 that alters the intent of the IC and/or EAL, i.e., the IC and/or EAL:

• Does not classify at the classification level consistent with NEI 99-01

• Is not logically integrated with other EALs in the EAL scheme

• Results in an incomplete EAL scheme (i.e., does not classify all potential emergency conditions) 10 CFR 50.47(b)(5) - Emergency Notifications A change that would reduce the licensee's capability to promptly alert responsible OROs within 15 minutes after declaring an emergency. Examples include (a) a change to notification forms and their processing that reduces the accuracy or timeliness of emergency notifications, (b) a change to the description of communications hardware that would reduce the capability to initiate and complete required emergency notifications within 15 minutes of the emergency declaration, (c) a change that directs the resta,rt of the 15-minute criterion clock if the condition escalates before the notifications for the prior emergency level are made, (d) a change that eliminates one or more components of initial or followup notifications specified in Section 11.E of NUREG-0654 or the licensee's approved emergency plan (e.g., an omission of whether protective actions are necessary), and (e) a change to ERO staffing that affects the timeliness of.emergency

NUCLEAR NON-QUALITY RELATED EN".EP-305 REV.4

~~*Entergy MANAGEMENT MANUAL INFORMATIONAL USE PAGE 440F77 10CFR50.54 Review Pro ram ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES SHEET9OF13 notifications by assigning collateral duties to the ERO positions that are responsible for performing emergency notifications.

10 CFR 50.47(b)(6) - Emergency Communications A change that would reduce the availability and reliability of primary and backup communications systems* used to (1) riotlfy and activate State and local emergency response centers or (2) enable communications between the licensee's ERFs and with ORO and Federal emergency operating centers in accordance with the emergency plan (e.g., replacing dedicated private lines with a public exchange service).

A change to ERO callout procedures or hardware could require prior NRG approval if it would delay ERO notification such that the augmentation times in the emergency plan can no longer be achieved.

A change that adjusts the frequency of communication testing or maintenance to a level that the site's experience with system reliability does not support. An example of this type of change would be a scheduled maintenance interval that is greater than the observed mean time between failures of the equipment or a reduction in the availability of backup capabilities.

10 CFR 50.47(b)(7) - Emergency Public Information A change that would reduce the licensee's capability to disseminate information to the public in a timely and accurate manner during emergencies in accordance with the emergency plan.

Examples include (a) media contact lists would not be kept up to date, (b) procedural approval protocols cannot be implemented because of organizational changes, (c) corporate spokespersons would not be familiar enough with a particular site and its reactors to be credible spokespersons, (d) sufficient staffing would not be available to adequately perform assigned functions and tasks related to public information, (d) news releases would not be released in a timely manner such that outdated information could be released after it has been superseded by subsequent events (e.g., a press release addressing the declaration of a notification of an unusual event would be released after the ERO has already declared a site area emergency),

and (e) news releases and briefings would not be routinely coordinated with those provided by OR Os.

A change to annually disseminate public emergency information material or postings that would result in the material not containing the minimum information identified in Section 11.G of NUREG-0654 or an NRG-approved alternative.

A change in the means of distributing the annual information materials if it would reduce the assurance that the permanent and transient adult population within the plume exposure EPZ has been given an adequate opportunity to become aware of the information.

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• • ~~Entergy MANAGEMENT MANUAL . INFORMATIONAL USE PAGE 45 OF 77 1 OCFR50.54 Review Pro ram ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES SHEET 10OF13 10 CFR 50.47{b}(8) - Emergency Facilities and Equipment A change that would reduce the capability of the ERO in the TSC, EOF, or OSC to perform assigned functions and tasks in accordance with the emergency plan. Examples include (a) a reduction in the existing reliability or redundancy of data acquisition, display, and analysis equipment provided in the ERFs, (b) a relocation of an EOF that makes it infeasible for State or local ORO personnel to respond to, and participate in, the EOF as they currently do without adequate compensatory measures, (c) a permanent substitution of personal protective equipment for installed engineered habitability features, (d) a reduction in the frequency of ERF equipment maintenance, calibration, or testing that is not supported by the site's experience with equipment reliability (e.g., a frequency greater than the observed mean time between failures), (e) a change to an ERF use that allows nonemergency uses that would decrease the readiness of the ERF for emergency use, and (f) a change that reduces the inventory or availability of equipment.

10 CFR 50.47(b)(9) - Emergency Assessment Capability A change that would reduce the capability of the ERO to perform assessments of imminent and ongoing radioactive releases in accordance with the emergency plan. Examples include (a) a change that reduces the availability of meteorological data in ERFs where dose assessments are performed and PAR decisions are made, (b) a change in ERO staffing that would eliminate the onshift capability to make timely and accurate estimates of the actual or potential radiological hazards through liquid or gaseous release pathways, (c) the reassignment of dose assessment responsibilities from a site-specific EOF member to a common EOF manned with ERO personnel who are not sufficiently competent in the site's radiation monitoring systems, ventilation systems, source terms, or potential release paths to perform a credible dose assessment, (d) the replacement of a site-specific dose assessment model with a generic model that provides results that have not been shown to be representative for the topography, meteorological regimes (e.g.,

valley effects or sea breeze), release pathways, or source terms applicable to that plant and its environs, (e) a change in field-monitoring air sampling media such that the requisite iodine sensitivity could not be met because of interference from the presence of noble gases, and (f) changes to dose assessment software that would reduce the options available to assessment personnel to perform assessments for releases that have not yet started or that could occur through unmonitored release paths.

10 CFR 50.47(b)(10) - Emergency Protective Actions Change that would reduce the capability of the ERO to implement timely and appropriate protective actions for onsite employees and other individuals present in the plant areas controlled by the licensee and to make timely and appropriate PARs to State and local officials in accordance with the emergency plans. Examples include (a) a change that would result in unescorted persons on site not receiving adequate instruction in site evacuation or site accountability, (b) a change that could result in personnel who are not qualified to wear respiratory protection devices being assigned to ERO positions with functions and tasks that could reasonably require the use of such equipment, (c) a change that would result in PARs that relax earlier PARs that have already been relayed to OROs and are being implemented by the public, (d) a change that reduces the availability of ERO personnel who are qualified to wear

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 460F77 10CFR50.54 Review Pro ram ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES SHEET 11OF13 personal protection equipment (PPE) to perform their assigned functions or that reduces the availability of PPE for use by these personnel, (e) a change to PAR decision logic that would mandate 5-mile, 360-degree radius evacuations as a minimum PAR even when the actual wind persistence and wind direction forecasts at the time of the emergency do not warrant such an action, (f) a change to PAR decision logic such that the range of protective actions considered by the ERO would be inappropriately restricted to the extent that the most effective PAR (lowest overall risk to the individual) might not be implemented, and (g) changes that reduce the control a licensee has over access to the owner-controlled area or exclusion area (e.g., a public roadway traversing the site or a public recreational area located within the exclusion area).

10 CFR 50.47(b)(11) - Emergency Radiological Exposure Control A change that would reduce the capability of the ERO to control the radiological exposures of emergency workers in accordance with the emergency plans. Examples include (a) radiation exposures incurred during an emergency not being recorded as occupational exposure under 10 CFR 20, "Standards for Protection against Radiation," (b) radiation dosimetry not being issued in accordance with emergency plans to offsite assistance (e.g., ambulance, fire, or local law enforcement) entering the radiologically controlled area, (c) personnel decontamination materials and agents not being maintained in a ready state, and (d) authority to authorize emergency exposure limits not being available 24/7. {\

10 CFR 50.47(b)(12) - Emergency Medical Support A change that terminates a letter of agreement with an offsite medical facility relied on in the emergency plan that would delay medical treatment for contaminated, injured individuals without a viable alternative facility accessible within a timeframe consistent with the urgency of emergency medical treatment.

A change in licensee training assistance to an offsite medical facility identified in the emergency plan that degrades the ability of hospital personnel to handle contaminated, injured individuals (e.g., training on radiological contamination control involving contaminated, injured individuals or the general primacy of trauma treatment over treatment for radiation exposure).

A change in ERO staffing or in the availability of emergency kits that would preclude site personnel from ensuring that the receiving medical facility has implemented adequate radiological contamination controls.

A change in ERO staffing or in the availability of emergency kits that would reduce onsite first aid capabilities identified in the emergency plan.

NUCLEAR NON*QUALITV RELATED EN*EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 47 OF 77 10CFR50.54 Review Pro ram A1TACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES SHEET 12OF13 10 CFR 50.47(b)(13) - Recovery and Reentry Planning A change to the criteria for terminating the emergency and transitioning to a recovery organization that reduces the likelihood of an orderly transition, including coordination with State officials, to a recovery organization for the spectrum of accident scenarios enveloped by the NUREG-0654 planning basis.

A change that would not provide an adequate level of personal protection in uncertain reentry conditions.

A change that reduces the level of detail in plan provisions for the structure of the recovery

• organization and the authorities and responsibilities of key personnel assigned such that a reasonable general framework no longer exists.

10 CFR 50.47(b)(14) - Drill and Exercise Program A change in the conduct of drills and exercises that would reduce the challenge to ERO personnel to the extent that they are not provided adequate opportunities over the exercise planning cycle to practice key functional areas and major tasks, including the use of the plan,

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procedures, and equipment associated with those functions and tasks. Examples include (a) use of the same general scenarios from exercise to exercise, (b) frequent reuse of a given scenario, (c) lack of sufficient detail in a scenario on an expected ERO response to the data and situations presented by the scenario, (d) scenarios and controller conduct that do not cause drill or exercise participants to "work for the information" as they would in an actual event, (e) an over reliance on player simulation when valid constraints to actual play do not exist (e.g., not obtaining the tools and parts for a simulated repair activity, not obtaining or reviewing the radiation work permit, not donning protective clothing and equipment, not going to the location of the repair, or returning to the OSC sooner than the actual repair would have taken), (f) scenarios that never allow ERO success to change the course of the exercise, and (g) scenario objectives that never exercise the use of backup capabilities (e.g., loss of the primary ring-down phone used for initial notifications).

A change in the conduct of drill and exercise critiques that reduces the ability of the critique to adequately identify weaknesses in the ERO play and to implement necessary corrective actions.

An example would be a critique process that does not identify and formally evaluate any deviation in the ERO performance expected by the scenario. The licensee needs to evaluate such situations to determine whether the scenario was wrong or whether the ERO was wrong. In either case, the licensee needs to evaluate the situation and take the appropriate corrective actions.

10 CFR 50.47(b)(15) - Emergency Responder Training A change in the conduct of ERO training that does not provide ERO personnel sufficient training and other performance development opportunities related to their assigned functions and responsibilities to allow them to perform those functions and responsibilities in an acceptable manner before they are assigned to key ERO positions and periodically as long as they continue to be so assigned. Examples include (a) a change that reduces the frequency of required training

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PAGE 48 OF77 REV.4 Emeraency Plannina 10CFR50.54(CI) Review Program ATTACHMENT 9.5 REG GUIDE 1.219 EXAMPLE CHANGES SHEET 13OF13 that is not supported by demonstrated ERO performance in drills and exercises or by the frequency of changes in the emergency plan and its supporting procedures, (b) a change that reduces the frequency at which training materials are updated to reflect changes in the emergency plan and procedures, (c) a change that lengthens the time to address ERO performance weaknesses attributed to training deficiencies, inconsistent with the significance of the weakness, (d) a change that eliminates training effectiveness measurements (tests and job performance measurements) that are currently required, and (e) a change that reduces the availability of site familiarization training that is currently presented to offsite assistance groups (e.g., firefighters, local law enforcement, and medical services, including mutual aid companies that would support these groups onsite).

10 CFR 50.47(b)(16) - Emergency Plan Maintenance A change that reduces management oversight and control over the emergency preparedness program to the extent that the effectiveness of the emergency plan may be reduced. Examples include (a) a decrease in the scope, periodicity, or independence of the performance of emergency preparedness program reviews, (b) an increase in the amount of time necessary to implement changes to needed emergency plan and supporting procedures identified as corrective actions for identified plan deficiencies and ERO weaknesses, (c) changes in the scope or frequency of training and performance enhancement opportunities for emergency preparedness management and staff, and (d) delegation of responsibility for the performance of various aspects of emergency plan maintenance to contractors or other external groups without adequate supervisory oversight to ensure that program elements continue to be met (e.g., a change delegating the testing and maintenance of the ANS to an external group that is not subject to typical nuclear facility work process and configuration controls).

1.4 Operating Experience related to 10 CFR 50.54(q)

Refer to the Nuclear Energy Institute website at www.nei.org.

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 49 OF 77 10CFR50.54 Review Pro ram ATTACHMENT 9.6 ADDITIONAL REGULATORY GUIDANCE SHEET1 OF3 This section provides a list of regulatory guidance documents that contain information relevant to making changes to the emergency plan.

• Regulatory Guide (RG) 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors" The NRC issues regulatory guides to describe methods that the NRC staff considers acceptable for use in implementing specific parts of the agency's regulations, techniques that the staff uses in evaluating specific problems or postulated accidents, and data that the staff needs in reviewing applications for permits and licenses.

Regulatory Guides (RG) are not substitutes for regulations, and compliance with them is not required. Methods and solutions that differ from those set forth in regulatory guides will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a permit or license by the Commission.

RG 1.219 specifically describes a method that the NRC staff considers acceptable to implement the requirements in Title 10, Section 50.54(q), of the Code of Federal Regulations (10 CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities".

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• NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (NUREG-0654/FEMA-REP-1)"

NUREG-0654 provides guidance and acceptance criteria to provide a basis for NRC licensees, State and local governments to develop radiological emergency plans and improve emergency preparedness. The guidance is the product of the joint FEMA/NRC Steering Committee established to coordinate the agencies' work in emergency preparedness associated with nuclear power plants.

NUREG-0654 is consistent with NRC and FEMA regulations and supersedes other previous guidance and criteria published by FEMA and NRC on this subject. It will be used by reviewers in determining the adequacy of State, local and nuclear power plant licensee emergency plans and preparedness.

• Regulatory Issue Summary (RIS) 2003-18 (including Supplements 1 and 2), "Use of NEI 99-01, "Methodology for Development of Emergency Action Levels," Revision 4, Dated January 2003. A Regulatory Issue Summary is used to:

document NRC endorsement of the resolution of issues addressed by industry-sponsored initiatives, solicit voluntary licensee participation in staff-sponsored pilot programs, inform licensee of opportunities for regulatory relief,

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PAGE 50 OF 77 REV.4 ATTACHMENT 9.6 ADDITIONAL REGULATORY GUIDANCE SHEET20F3 announce staff technical or policy positions not previously communicated to industry or not broadly understood, and address matters previously reserved for administrative letters.

Specifically, RIS 2003-18, including Supplements 1 and 2, provides guidance to develop or change a standard emergency classification and action level scheme. In addition, the documents also provide recommendations to assist licensees in determining whether to seek prior NRG approval of plan changes.

• RIS 2005-02 Revision 1, "Clarifying the Process for Making Emergency Plan Changes" The purpose of the regulatory information summary revision is to (1) clarify the meaning of a reduction in effectiveness, as stated in 10 CFR 50.54(q); (2) clarify the process for evaluating proposed changes to emergency plans; (3) provide a method for evaluating proposed changes to emergency plans; and (4) provide clarifying guidance on the appropriate content and format of applications submitted to the NRG for approval prior to implementation.

• RIS 2007-01, "Clarification of NRG Guidance for Maintaining a Standard Emergency Action Level Scheme" RIS 2007-01 was issued to clarify the regulatory requirement that licensees have a standard emergency classification and action level scheme in use, to ensure classification of events in a logical manner.

• NRG Bulletin (BL) 2005-02, "Emergency Preparedness and Response Actions for Security-Based Events" BL 2005-02 requested the industry to provide information to NRG related to actions taken or actions planned to be taken regarding in the areas of Security-based emergency classification levels and emergency action levels (EALs), emergency response organization augmentation for security-based events, a security-based EP drill and exercise program, and accelerated NRG notifications and onsite protective measures. NEI proposed implementation guidance for the Bulletin issues in May/November 2005, "Enhancements to Emergency Preparedness Programs for Hostile Action." The NRG endorsed the NEI guidance document in Regulatory Information Summary (RIS) 2006-12, "Endorsement of Nuclear Energy Institute Guidance, 'Enhancements to Emergency Preparedness Programs for Hostile Action"'.

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• NRC Information Notice (IN) 2005-19, "Effect of Plant Configuration Changes on the Emergency Plan," dated July 18, 2005, was issued to inform licensees of inspection findings related to licensees' failure to properly evaluate the effect of plant configuration changes (procedures, equipment and facilities) on the emergency plan.

• NRC Inspection Procedure (IP} 71114.04, "Emergency Action Level and Emergency Plan Changes" This IP 71114.04 provides NRC inspectors with the attributes and criteria to verify that EAL schemes continue to meet planning standards and for monitoring the effectiveness of programs for implementing changes to the emergency plans and verifying those programs ensure that changes meet the requirements of 10 CFR 50.54(q).

• NRC Inspection Manual Chapter (IMC) 0609 Appendix 8, Emergency Preparedness Significance Determination Process IMC 0609, Appendix 8 explains the emergency preparedness planning standards and risk significant planning standards along with examples of failures to implement or comply with the rule and the associated regulatory significance determination

A-==::;:-Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED INFORMATIONAL USE EN-EP-305 I REV.4 MANUAL PAGE 52 OF 77 Emergency Planning 10CFR50.54(a) Review Proaram ATTACHMENT 9.7 PLANNING STANDARDS, APPENDIX E, FUNCTIONS AND ELEMENTS SHEET1 OF4 Emergency Plan Functions 10 CFR 50.47(b)(1) - Assignment of Responsibility/Organizational Control

• Responsibility for emergency response is assigned.

• The response organization has the staff to respond and to augment staff on a continuing basis (i.e.,

24/7 support).

Sections IV.A.1-IV.A.9 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section II.A of NUREG-0654 and the licensee's emergency plan.

to CFR 50.47(b)(2) - Onsite Emergency Organization

• The process ensures that onshift emergency response responsibilities are staffed and assigned.

• The process for timely augmentation of onshift staff is established and maintained.

Sections IV.A.2.a-c, IV.A.3, and IV.C of Appendix E to 10 CFR 50 provide supporting requirements.

Informing criteria appear in Section 11.B of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47(b)(3) - Emergency Response Support and Resources

• Arrangements for requesting and using offsite assistance have been made.

• State and local staff can be accommodated at the EOF in accordance with the emergency plan.

Sections IV.A.6 and IV.A.7 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section 11.C of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47(b)(4) - Emergency Classification System

• A standard scheme of emergency classification and action levels is in use.

Sections IV.Band IV.C of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section 11.D of NUREG-0654 and the licensee's emergency plan.

e-=::::::-Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED INFORMATIONAL USE EN-EP-305 I REV.4 MANUAL PAGE 53 OF 77 Emergency Planning 10CFR50.54(q} Review Program ATTACHMENT 9.7 PLANNING STANDARDS, APPENDIX E, FUNCTIONS AND ELEMENTS SHEET20F4 10 CFR 50.47(b}(5) - Emergency Notifications

• Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications

• Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway.

• The public ANS meets the design requirements of FEMA-REP-10, "Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants", or is compliant with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter.

Sections IV.D.1 and IV.D.3 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section 11.E and Appendix 3 to NUREG-0654 and the FEMA-approved ANS design report.

10 CFR 50.47(b)(6) - Emergency Communications

• Systems are established for prompt communication among principal emergency response organizations.

• Systems are established for prompt communication to emergency response personnel.

Section IV.E.9 of Appendix E to 10 CFR 50 provides supporting requirements. Informing criteria appear in Section 11.F of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47(b)(7) ~ Emergency Public Information

• Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway EPZ.

• Coordinated dissemination of public information during emergencies is established.

Section IV.D.2 of Appendix E to 10 CFR 50 provides supporting requirements. Informing criteria appear in Section 11.G of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47(b)(8) - Emergency Facilities and Equipment

• Adequate facilities are maintained to support emergency response.

• Adequate equipment is maintained to support emergency response.

Sections IV.E.1-4, IV.E.8, and IV.G of Appendix E to 10 CFR 50 provide supporting requirements.

Informing criteria appear in Section 11.H of NUREG-0654; NUREG-0696, "Functional Criteria for Emergency Response Facilities," and the licensee's emergency plan.

10 CFR 50.47(b)(9) - Emergency Assessment Capability

• Methods, systems, and equipment for assessment of radioactive releases are in use.

Sections IV.Band IV.E.2 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section II.I of NUREG-0654 and the licensee's emergency plan.

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• A range of public PARs is available for implementation during emergencies.

• Evacuation time estimates for the population located in the plume exposure pathway EPZ are available to support the formulation of PARs and have been provided to State and local governmental authorities.

• A range of protective actions is available for plant emergency workers during emergencies, including those for hostile action events.

Appendix E to 10 CFR 50 does not contain any support requirements. Informing criteria appear in NUREG-0654 in Sections ll.J.1-8, Section 11.J.10, and Supplement 3 and in the licensee's emergency plan.

10 CFR 50.47(b)(11) - Emergency Radiological Exposure Control

• The resources for controlling radiological exposures for emergency workers are established.

Section IV.E.1 of Appendix E to 10 CFR 50 provides supporting requirements. Informing criteria appear in Section 11.K of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47(b)(12) - Emergency Medical Support

• Arrangements are made for medical services for contaminated, injured individuals.

Sections IV.E.5-7 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section 11.L of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47(b)(13) - Recovery and Reentry Planning

• Plans for recovery and reentry are developed.

Appendix E to 10 CFR 50 does not contain any supporting requirements. Informing criteria appear in Section 11.M of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47(b)(14) - Drill and Exercise Program

• A drill and exercise program (including radiological, medical, health physics, and other program areas) is established.

• Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skills, are assessed via a formal critique process in order to identify weaknesses.

• Identified weaknesses are corrected.

Sections IV.F.1-2 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section 11.N of NUREG-0654 and the licensee's emergency plan.

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• Training is provided to emergency responders.

Sections IV.F.1-2 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section 11.0 of NUREG-0654 and the licensee's emergency plan.

10 CFR 50.47(b)(16) - Emergency Plan Maintenance

• Responsibility for emergency plan development and review is established.

• Planners responsible for emergency plan development and maintenance are properly trained.

Appendix E to 10 CFR 50 does not contain any supporting requirements. Informing criteria appear in Section 11.P of NUREG-0654 and the licensee's emergency plan.

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9.8 BACKGROUND

INFORMATION SHEET1 OF8 10 CFR 50.54(q) Rule 10 CFR 50.54(q) permits the licensee to make changes to its emergency plan without prior application to, and approval by, the NRC, provided that the changes do not reduce the effectiveness of the plan and that the plan, as changed, continues to meet the planning standards in 10 CFR 50.47(b) and the requirements in 10 CFR Part 50 Appendix E.

The objectives of the change process are to ensure that the licensee:

• evaluates proposed changes to its emergency plan for their impacts on the effectiveness of the plan,

• obtains prior NRC approval for changes that are deemed to reduce the effectiveness of the plan, and

• documents and reports such changes and the analysis of these changes.

Regulatory Guidance Relationship between 10 CFR 50.54(q) and the NRC's Reasonable Assurance Finding

a. 10 CFR 50.47(a) precludes issuance of an operating license or combined license if the NRC cannot make a finding that it has reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

10 CFR 50.54(q)(2) states that once an operating license is issued, the licensee is required to maintain the effectiveness of its emergency plan.

b. Some changes that a licensee may make to its approved emergency plan warrant prior NRC approval to ensure that the changes would not adversely affect the NRC's reasonable assurance determination.

However, other types of changes may have such a minimal impact on this determination that they would not warrant prior NRC approval.

The change process under 10 CFR 50.54(q):

• enables licensees to make changes that have minimal impact on the NRC's reasonable assurance determination without prior NRC approval while,

• requiring prior NRC approval for changes that may impact the reasonable assurance determination.

Examples Changes that reduce the number of personnel available to perform emergency response tasks or that lengthen the time it takes to staff and activate emergency response facilities (ERFs) could impact the NRC's reasonable assurance determination and would require prior NRC staff approval.

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9.8 BACKGROUND

INFORMATION SHEET20F8 Minor administrative changes, such as updating a telephone number in a notification procedure, would not warrant prior NRC staff review.

Between these extremes is a range of possible changes for which the licensee is required to perform and document a detailed objective evaluation.

c. The change process under 10 CFR 50.54(q) does not establish whether a proposed change would impact reasonable assurance determinations. The change process establishes only whether the licensee has the authority to implement the proposed change without prior NRC approval.

The change process uses the characteristic "reduction in effectiveness" to exclude from the requirement to seek prior NRG approval those changes that would not reduce effectiveness.

A licensee is required to submit a license amendment request in accordance with 10 CFR 50.90 for a change that it concludes will require prior NRG approval.

Based on its review, the NRC may conclude:

1. that the changes do not reduce the effectiveness of the plan,

2. that the changes do reduce the effectiveness of the plan but that the NRG continues to have reasonable assurance that adequate protective measures can and will be taken, or

3. that the change unacceptably affects the NRC's reasonable assurance determination.

Role of Conservatism in 10 CFR 50.54(q) Change Evaluations The NRC has always expected, and continues to expect, licensees to make conservative decisions for the operation of nuclear power reactors. Conservative decision-making is prudent when the data needed for the decision are unknown or uncertain.

Nonetheless, licensees need to remain alert to the possibility of unintended consequences and consider these outcomes in their decisions. The emphasis in emergency preparedness is on prudent risk reduction measures. An overly conservative decision during an emergency response could trigger actions that could place the public at unnecessary risk, thus resulting in a non-conservative situation. "More" is not always "better."

Example Changing a protective action recommendation procedure to mandate a default 5-mile, 360-degree evacuation in lieu of considering the actual wind variability at the time of the event may appear conservative because more people would be evacuated. However, the approach could expose individuals upwind of the plant to unnecessary evacuation risks without the benefits of the associated radiation dose avoidance, a non-conservative situation.

e~Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED EN-EP-305 I REV.4 MANUAL INFORMATIONAL USE PAGE 58 OF77 Emergency Planning 10CFR50.54(a) Review Program ATTACHMENT

9.8 BACKGROUND

INFORMATION 5HEET30F8 Role of Probabilistic Risk Assessment Insights in 10 CFR 50.54(q) Change Evaluations The NRC policy statement, "Safety Goals for the Operation of Nuclear Power Plants," (51 FR 30028; August 4, 1986) states that emergency preparedness is a "defense-in-depth measure."

Emergency preparedness is implemented as a matter of prudence rather than in response to a quantitative analysis of accident probabilities. The effectiveness of an emergency plan is independent of probability.

The planning basis in NUREG-0654 states that the objective of emergency planning is to provide dose savings for a "spectrum" of accidents that could produce offsite doses in exce$S of those given in the U.S. Environmental Protection Agency (EPA) protective action guides (EPA 400-R-92-001 ). The basis goes on to state that no "single specific accident sequence" should be chosen as the one for which to plan because each accident could have different consequences both in nature and degree. The selected planning basis described in NUREG-0654 is independent of specific accident sequences.

The probability of a reactor accident requiring the implementation of a licensee's emergency /

plan has no relevance in determining whether a particular change reduces the effectiveness of  !

' - __ /

the emergency plan. Accordingly, licensees should not consider risk insights about specific accident initiation or progression in performing 10 CFR 50.54(q) evaluations.

Timeliness as an Evaluation Consideration

a. By its very nature, an emergency instills a sense of urgency and dictates the necessity for prompt action, which is a fundamental aspect of the licensee's emergency plan.

Consistent with this imperative, the NRC has specified timeliness criteria in regulations for three specific emergency response activities:

a) emergency declaration, b) emergency notifications, and c) public alerts.

The NRC's emergency planning guidance provides additional time-based criteria. Proposed changes that could delay emergency declarations, notifications, or protective action recommendations (PAR) may reduce the effectiveness of the emergency plan in that subsequent emergency response actions may not be timely and emergency response personnel, facilities, and equipment may not be in position if it becomes necessary to implement measures to protect the public health and safety.

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9.8 BACKGROUND

INFORMATION 5HEET40F8 Generally, the licensee should view any change that could delay an activity or relax a timeliness criterion for the activity as a potential reduction in effectiveness and should evaluate it accordingly. This evaluation would include any change that modifies how the timeliness criterion is evaluated (e.g., "when the clock starts and stops").

Example The purpose of the Emergency Response Organization (ERO) activation is to augment the onshift staff and relieve it of those functions assigned to the technical support center (TSC),

the operations support center (OSC), and the emergency operations facility (EOF). The ERO activation is not complete until the ERO is actively performing those functions at the TSC, OSC, and EOF; actuating a "clock stop" before this would be premature.

The capability to complete an activity within the specified timeframe depends on several factors, including:

• the availability of adequate qualified personnel to perform the activity;

• the number of multiple duties assigned to these personnel;

• augmentation time by offshift personnel; and

• sufficient procedures, tools, instrumentation, equipment, and other material necessary to complete the activity..

The licensee needs to evaluate proposed changes that affect these factors for their impact on the timely completion of emergency planning functions during an emergency response.

Role of the Facility Licensing Basis

a. The licensee cannot properly evaluate a proposed change to the emergency plan if it has not considered the basis for the staff's approval of the original plan or the basis for any subsequent change, whether it has been approved by the staff or implemented by the licensee under 10 CFR 50.54(q).

Example Why did the licensee specify more onshift ERO staff than what was called for in NUREG-0654?

• Was it a matter of exceeding the regulatory minimum as an operating philosophy?

• Was it done to compensate for special circumstances that existed when the decision was made (e.g., lengthy ERO augmentation times because of the remoteness of the site)?

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9.8 BACKGROUND

INFORMATION SHEET50F8 A decrease in staffing in the first case might not reduce effectiveness; a decrease in staffing in the second case would reduce effectiveness if the special circumstances still existed.

b. The licensee should consider the following licensing-basis documents when informing a 10 CFR 50.54(q) evaluation:

1) Regulatory Requirements The Commission's emergency preparedness regulations in 10 CFR Chapter I, "Nuclear Regulatory Commission," are binding on the licensee unless the NRC explicitly exempts them.

2) License, License Conditions, and License Amendments The facility's license may contain emergency preparedness commitments and requirements that are binding on the licensee.

3) Commission Orders Commission orders may establish specific emergency plan requirements for a particular licensee. On October 31, 1980, the NRC issued Generic Letter 80-90, "Post-TMI Requirements," which requires licensees to confirm their commitments on various requirements imposed after the Three Mile Island (TMI) accident, including emergency preparedness items. The Commission issued confirming orders to mandate compliance with the commitments. Other Commission orders may apply.

4) Upgraded Emergency Plans Following the TMI accident, regulations required licensees to upgrade their emergency plans and to submit those plans to the NRC for review. A special inspection program involving onsite evaluations of the upgraded plan and facilities augmented these reviews. The submitted plan, NRC requests for additional information, commitments made in responses to the requests for additional information, NRC safety evaluations, NRC denials, and other correspondence between the licensee and the NRC may be useful in informing a 10 CFR 50.54(q) evaluation.

5) FEMA Alert and Notification System (ANS) Design Report Because the performance of an alert and notification system (ANS) is an offsite concern, Federal Emergency Management Agency (FEMA) has the primary responsibility and authority for evaluating the design of an ANS.

The ANS design report defines the design of the ANS, including the alerting system (e.g., sirens, tone alert radio, and route alert) and the notification system. The ANS

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9.8 BACKGROUND

INFORMATION 5HEET60F8 design report identifies commitments for testing and maintenance.

The NRC considers the approved ANS design report to be part of the facility's licensing basis because it establishes the basis of the NRC's determination that the licensee has complied with Section IV.D.3 of Appendix E to 10 CFR Part 50.

If the licensee has committed to install or maintain the ANS on behalf of State or local governments, changes to the licensee's commitments on the design, testing, and maintenance of the ANS identified within the site's FEMA-approved final ANS design report are evaluated against the criteria of 44 CFR 350.14, "Amendments to State Plans." If warranted, the licensee must submit the proposed changes to FEMA via the responsible State official for review and approval.

6) Other Sources of Licensing Information The following sources of licensing information may be useful in informing 10 CFR 50.54(q) evaluations:

a) Hearing Dockets Atomic Safety and Licensing Board (ASLB) and the Atomic Safety and Licensing Appeal Board Hearings: Emergency preparedness contentions have been raised in numerous proceedings associated with licensing and license amendments. The resulting board decision may have been based, in part, on the licensee's (applicant's) statements about its emergency plan made in testimony presented before the board. This testimony and that of the NRC staff witnesses and witnesses for the interveners and resulting board rulings may be useful in informing a 10 CFR 50.54(q) evaluation on a program element addressed in those hearings.

b) NRC Inspection Findings Inspection findings, inspection reports, commitments made in licensee response letters, root cause analyses, and supplemental inspection results may be useful in informing a 10 CFR 50.54(q) evaluation of a program element addressed in those findings.

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9.8 BACKGROUND

INFORMATION 5HEET70F8 Role of Emergency Preparedness Cornerstone Performance Indicators Representatives of the nuclear power industry developed the emergency preparedness cornerstone performance indicators, and the NRC endorsed them. The nuclear power industry developed these performance indicators and the supporting guidance to monitor licensee performance; however, compliance with a performance indicator does not necessarily demonstrate compliance with regulations. For example, opportunities for demonstrating the capability to notify offsite response organizations (OROs) are considered successful upon notification of the first ORO. However, the NRC expects the licensee to have the capability to notify all OROs within 15 minutes to be in compliance with regulations. Accordingly, the licensee cannot use performance indicators and their guidance as the sole basis for concluding whether a proposed change would reduce the effectiveness of its emergency plan; however, they may be useful in informing such determinations.

• Role of Margin in the 10 CFR 50.54(q) Change Process

a. The 10 CFR 50.54(q) change process establishes a two-factor test to determine when a change to an emergency plan requires prior NRC approval:

• whether the emergency plan, as modified, would continue to comply with the planning standards in 10 CFR 50.47(b) or the requirements in Appendix E to 10 CFR 50 and

• whether the proposed change would reduce the effectiveness ofthe emergency plan.

These two tests are separate and distinct. If the licensee does not meet either test, it must obtain prior NRC approval. Meeting the first test does not imply that the licensee has met the second test, nor does meeting the second test imply that the licensee has met the first test.

b. During licensing, a licensee may have committed to a greater level of capabilities, methods, and resources than what regulation and guidance had explicitly required and subsequently may seek to reduce that level of commitment. Because the original plan "exceeded" the explicit regulatory requirement, the licensee may have enough "margin" to reduce its commitment and still comply with the regulatory requirements. This rationale only considers the first test factor; the second test factor still needs to be evaluated.

• If the licensee's original commitment resulted from a conservative operating philosophy, the licensee may be able to show that the reduction in commitment would not reduce the effectiveness of its emergency plan.

• If the licensee's original commitment resulted from the need to compensate for preparedness or response constraints or vulnerabilities specific to the facility, emergency planning zone (EPZ), and jurisdiction, any reduction in commitment would

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9.8 BACKGROUND

INFORMATION SHEET80F8 likely result in a reduction in effectiveness if the constraints or vulnerabilities are still present.

c. In either case, the conclusion is not based on whether "margin" exists but instead on whether the licensee can demonstrate that the change does not reduce the effectiveness of its emergency plan. In the case discussed in the first bullet in b above, conditions may have developed since the original commitments were made, thus making them necessary to maintain the effectiveness of the emergency plan. As such, the concept of margin has no role in a 10 CFR 50.54(q) change evaluation.

Changing Emergency Action Level Schemes

a. Changes to individual Emergency Action Levels (EAL) may be made without NRC approval prior to implementation as governed by 10 CFR 50.54(q).

b. 10 CFR 50 Appendix E.IV.B, "Assessment Actions" requires licensees to obtain NRC approval prior to implementing certain EAL changes in accordance with 10 CFR 50.90.

"A revision to an emergency action level must be approved by the NRC before implementation if:

• The licensee is changing from one emergency action level scheme to another emergency action level scheme (e.g., a change from an emergency action level scheme based on NUREG-0654 to a scheme based upon NUMARC/NESP-007 or NEl-99-01 );

• The licensee is proposing an alternate method for complying with the regulations; or

• The emergency action level revision reduces the effectiveness of the emergency plan."

• -=;:::::-*Entergy NUCLEAR MANAGEMENT MANUAL NON-QUALITY RELATED INFORMATIONAL USE Emergency Planning 10CFR50.54Cal Review Program EN-EP-305 PAGE 640F77 I REV.4 ATTACHMENT 9.9 10 CFR 50.54(0)(3) SCREENING TEMPLATE SHEET1 OF3 Legend: Italicized text - Notes for users Underlined Text- Information to go on form Procedure/Document Number: I Revision:

Equipment/Facility/Other:

Title:

Part I. Description of Activity Being Reviewed (This is generally changes to the emergency plan, EALs, EAL bases, etc. - refer to step 3.0[6]):

Every change that requires an evaluation Will also have an associated screening - no stand-alone evaluations.

EVERY change MUST be addressed in either screen or evaluation.

ONLY the description of your change (changes) goes here. Do not attempt to explain here why the changes were performed or why they do not (or do) require an evaluation.

It may be easier to number your changes here and then refer to them later by the same number, including using the same number in the evaluation (as applicable).

A revision matrix may be used for large numbers of changes with reference to the matrix on this form. Example revision matrices are orovided in the EP shared drive.

Part II. Activity Previously Reviewed? DYES ONO Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3) Continue to Evaluation is next part Alert and Notification System Design Report? NOT required.

Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and complete Part proposed change is documented below: VI.

Justification:

D Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

APPLICABILITY CONCLUSION Get this from PAD D If there are no other controlling change processes, continue the 50.54(q) (3) Screening. Generally this box is checked.

D One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

D One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT required. Identify controlling change processes below and complete Part VI. This box will rarely be checked.

CONTROLLING CHANGE PROCESSES PAD cQnclusion may be stated here OR just list the controlling change processes OR if 10CFR50.54(q),

then 10CFR50.54(g)

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Enter Justification: USE THEDEFINITION OF "EDITORIAL"AS PROVIDED INEN-AO-justification and 101 ANO REFERENCED IN STEP 3.0/5]. continue to next If some changes are editorial and some are not, then check "no," provide the part or justification for the editorial changes HERE and provide the following statement: "No" is complete Part checked because this activi~ contains other changes that are not editorial. Yes" is VI as ONLY checked when all changes in the document are editorial. applicable.

Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NU REG-0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1] D

2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 D staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] D

4. The process for timely augmentation of onshift staff is established and maintained. [2] D

5. Arrangements for requesting and using off site assistance have been made. [3] D

6. State and local staff can be accommodated at the EOF in accordance with the emergency plah. [3] D

7. A standard scheme of emergency classification and action levels is in use. [4] D

8. Procedures for notification of State and local governmental agencies are capable of alerting them of D the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt D instructions to the public within the plume exposure pathway. [5]

10.The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11.Systems are established for prompt communication among principal emergency response D organizations. [6]

12.Systems are established for prompt communication to emergency response personnel. [6] D

13. Emergency preparedness information is made available to the public on a periodic basis within the D plume exposure pathway emergency planning zone (EPZ). [7]

14.Coordinated dissemination of public information during emergencies is established. [7] D 15.Adequate facilities are maintained to support emergency response. [8] D 16.Adequate equipment is maintained to support emergency response. [8] D 17.Methods, systems, and equipment for assessment of radioactive releases are in use. [9] D 18.A range of public PARs is available for implementation during emergencies. [1 O] D

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 66 OF 77 10CFR50.54 Review Pro ram ATTACHMENT 9.9 10 CFR 50.54(0)(3) SCREENING TEMPLATE SHEET30F3

19. Evacuation time estimates for the* population located in the plume exposure pathway EPZ are D available to support the formulation of PARs and have been provided to State and local governmental authorities. [1 O]

20. A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events.[1 O]

21. The resources for controlling radiological exposures for emergency workers are established. [11] D

22. Arrangements are made for medical services for contaminated, injured individuals. [12] D

23. Plans for recovery and reentry are developed. [13] D

24. A drill and exercise program (including radiological, medical, health physics and other program D areas) is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, D maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]

26. Identified weaknesses are corrected. [14] D

27. Training is provided to emergency responders. [15] D

28. Responsibility for emergency plan development and review is established. [16] D

29. Planners responsible for emergency plan development and maintenance are properly trained. [16] D APPLICABILITY CONCLUSION 0 If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI.

0 If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION Provide a basis for changes that screen out. Include statements that prove. EN-EP-305 step 5.5[4]a (the 3 bullets) "in the negative." For changes that screen out, conclude with the statement"No further evaluation is required for this change (these changes)."

For changes that do not screen out, state (either collectively or individually): "Emergency planning element(s) (insert applicable planning standard element numbers from Part V} in Part V of this form are affected by (describe changes}. A 10CFR50.54 (g}(3} evaluation will be performed to determine whether or not the effectiveness of the emergency ~Ian is reduced and orior NRG annroval is reauired."

Part VI. Signatures:

Preparer Name (Print) Preparer Signature Date:

(Optional) Reviewer Name (Print) Reviewer Signature Date:

Reviewer Name (Print) Reviewer Signature Date:

PM reviews are:

live signatures whenever possible Electronic sign off by site when OK'd by PM Waived by Director, Emergency Planning - RARE Nuclear EP Project Manager Approver Name (Print) Approver Signature Date:

Manager, Emergency Preparedness or designee

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 67 OF 77 10CFR50.54 Review Pro ram ATTACHMENT9.10 10 CFR 50.54(0)(3) EVALUATION TEMPLATE SHEET1 OF6 LEGEND: ITALICIZED TEXT- NOTES FOR USERS UNDERLINED TEXT- INFORMATION TO GO ON FORM Part I. Description of Proposed Change:

GENERAL NOTE: Reg Guide 1.219 refers to "level of rigor (regulatory position 5.2c5) and "significant evaluation" (regulatory position 3. le) when describing 50.54(q(3) evaluations. Expect the evaluation to take some time. Ensure the final product is detailed and informative enough to meet the standard expressed in the Reg Guide.

EVERY change MUST be addressed in either a screen or evaluation.

ONLY the description of your change (changes) goes here. Do not attempt to explain here why the changes were performed, how they continue to meet the regulation or why they do not cause an RIE.

It may be easier to number your changes here and then refer to them later by number.

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4

~'Entergy MANAGEMENT INFORMATIONAL USE PAGE 68 OF 77 MANUAL 10CFR50.54 Review Pro ram ATTACHMENT 9.10 10 CFR 50.54(a)(3) EVALUATION TEMPLATE SHEET20F6 Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

List here WHAT you reviewed. It is not necessary to list here what you DID NOT review such as commission orders or statements of consideration, etc. if you did not review them.

It was decided during a fleet call that it is acceptable to list PAD review statements here that are copied directly from the PAD and to discuss the PAD review performed. If the document you are reviewing is excluded from the PAD review, then you may state that here and why it was excluded. NOTE that 10CFR50.54(q) is NOTthe vehicle to use to PROCESS a PAD exclusion. Follow the requirements of EN-U-100 for such exclusions.

The "emergency plan" is the document (or documents) that provide a programmatic description of the site's emergency preparedness program. For most Entergy sites this will be the document titled "Emergency Plan," but can and often does include other documents as described further in this section. Emergency Plan Implementing Procedures are NOT considered part of the "emergency plan" UNLESS programmatic description information has been historically relocated from the original NRG approved emergency plan to an Implementing Procedure (or other document) - EALs are the common example of this. Refer to Reg Guide 1.219 regulatory position 3.5c.

List here the affected emergency plan sections. DO NOT UST HERE WHY THE CHANGES YOU ARE MAKING DO NOT RESULT IN AN RIE. This is for Part V. DO NOT UST HERE HOW THE CHANGE CONTINUES TO COMPLY WITH THE REGULATIONS. This is for Part Ill.

A review MUST be performed of the last NRG approved version (SER provided) of the emergency plan and subsequent revisions made under 10CFR50.54(q) to inform the basis for the current change. Document this review and the results here. IF an NRG-approved emergency plan cannot be located, THEN state this and state what revisions were reviewed (how far back the review went). Refer to Reg Guide 1.219 regulatory position 1.6a. An example of such a review is provided below:

In addition to those reviewed for the PAD, each of the following documents I relevant sections was reviewed:

a) Reviewed current plan Sections 1, 3, 4, 6, 7 and 8, and Appendices C and I. No additional relevant or affected plan content was identified.

b) The original plan (1982)" was reviewed manually with several differences noted:

• In 1982, plan section 6.4.1.2 addressed Site Evacuation and described the Remote Assembly Area as being located at the Niagara Mohawk Service Center in Oswego. Plan section 7.4.4 further described this same facility as being an "electrical maintenance service dispatch center located approximately eight miles from the site and away from the prevailing downwind direction. The current plan describes the Remote Assembly Area as being located at the Oswego County Airport. The reason for this difference is that the location of the Remote Assembly Area has changed over time to its current location beyond the 10 mile EPZ. Since 1982, the designated Remote Assembly Area has been relocated twice.

The first relocation was to another Niagara Mohawk Service Center located on Howard Road in the Town of Volney, approximately twelve miles from the site. The Howard Road Service Center was later sold and the designated Remote Assembly Area was relocated to its current location at the Oswego County Airport, which is located approximately 13 miles from the site (beyond the 10 mile EPZ) and is adjacent to the JIG and EOF. The current location is not in the prevailing downwind direction from the site, and offers more parking space and suitable structures (airport hangers) than either of the two designated areas.

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 69 OF 77 10CFR50.54 Review Pro ram ATTACHMENT9.10 10 CFR 50.54(0)(3) EVALUATION TEMPLATE SHEET30F6 Part Ill. Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:

At a minimum, list here the 10CFR50.47 planning standards that are checked in the screening form. Applicable 10CFR50 Appendix E items should also be listed where appropriate. Multiple regulatory items may be combined with one Site Compliance paragraph provided for all if the Site Compliance statement is applicable to all.

NOTE that this is NOT a section for discussion of RIE (Part V), but is a discussion of WHY the regulatory requirements are still met with your change. Use the format provided in underline below. The text provided below is ONLY an example.

10 CFR 50.47(b)(2) - The process for timely augmentation of on-shift staff is established and maintained.

Site Compliance - Through implementation of this revision, system testing requirements have been established for the ERO Notification System to test the ERO on a weekly and quarterly basis through a combination of announced and unannounced tests, drills and exercises to ensure that timely augmentation of staff is practiced and continues to meet the regulatory requirements. Guidelines for performing these tests have been updated in this revision of the emergency plan. Re-test criteria have also been established in the event that test results do not meet activation expectations and compensatory actions are put into effect.

10 CFR 50.47(b)(6) - Systems are established for prompt communication to emergency response personnel.

Site Compliance - Through implementation of this revision, system testing requirements have been established for the ERO Notification System to test the* ERO on a weekly and quarterly basis through a combination of announced and unannounced tests, drills and exercises to ensure that the notification system is functioning properly and is capable of providing prompt communications to emergency response pe;sonnel and that personnel are responding appropriately and in a timely manner to the notifications. In the event that the test results do not meet activation expectations, re-test criteria included in the revised emergency plan will be followed and compensatory actions will be implemented.

This section REQUIRES a discussion of previous NRG commitments. Use the format provided in underline below. The text provided below is ONLY an example.

Previous NRC Commitments - The Regulatory Assurance Commitment Management System and NRG commitment system were reviewed for potential NRG commitment changes as a result of this revision. There were no identified conflicts with this emergency plan revision and the current listing of NRG commitments associated with the emergency plan. All current NRG commitments that relate to emergency response notification systems and conduct of drills continue to be maintained and fulfilled under this procedure revision.

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 70 OF 77 10CFR50.54 q Review Pro ram ATTACHMENT9.10 10 CFR 50.54(a}(3} EVALUATION TEMPLATE SHEET40F6 Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change:

This section should be the simplest to complete. List the applicable emergency planning elements (sorted by 10CFR50.47 planning standard) checked in the screening. Use the format provided in underline below taken DIRECTLY from Attachment 9. 7.

• 10 CFR 50.47(b)(6) - Emergency Communications

• Systems are established for prompt communication among principal emergency response organizations.

• Systems are established for prompt communication to emergency response personnel. - IF the change does not involve all elements (bullets), THEN ONLY list those affected or potentially affected.

Section IV.E.9 of Appendix E to 10 CFR 50 provides supporting requirements. Informing criteria appear in Section 11.F of NUREG-0654 and the licensee's emergency plan.

• 10 CFR 50.47(b)(7) - Emergency Public Information

• Emergency preparedness information is made available to the public on a periodic basis within the plume exposure pathway EPZ.

• Coordinated dissemination of public information during emergencies is established. IF the change does not involve /'- - ,

all elements (bullets), THEN ONLY list those affected or potentially affected.

Section IV.D.2 of Appendix E to 10 CFR 50 provides supporting requirements. Informing criteria appear in Section 11.G of NUREG-0654 and the licensee's emergency plan.

DO NOT provide any other information in this section. This section is NOT for the RIE discussion - that is Part V.

However, you should compare this section to Part V to ensure that all applicable elements are addressed in your RIE discussion.

• --:;:;::-Entergy NUCLEAR MANAGEMENT MANUAL NON*QUALITY RELATED INFORMATIONAL USE Emergency Planning 10CFR50.54(q) Review Program EN-EP-305 PAGE 71OF77 I REV.4 ATTACHMENT 9.10 10 CFR 50.54(a)(3) EVALUATION TEMPLATE SHEETS OF6 Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

This is the "meaf' of any evaluation. This section is where you prove that an RIE has not been caused by your change(s). Use clear, logical statements that an independent :fd party reviewer can follow and understand for WHY the change does not reduce the effectiveness of the emergency plan (e.g., "the proposed change does not affect planning standard (b)(5) because ... '?. It is NOT sufficient to state that the change does not reduce the effectiveness of the emergency plan without stating WHY, even if the reason seems perfectly clear to you.

If more than one change is being evaluated in the same document, each change must be addressed. An activity cari impact more than one program element or function under different planning standards. Each impacted element and function must be evaluated separately as a reduction in effectiveness. A reduction in effectiveness may occur in one planning standard but not in the other. Unless an activity results in repetitive identical changes or multiple activities result in interdependent changes, the reduction in effectiveness evaluation should be documented separately for each change.

A reduction in effectiveness is usually based on the change to a planning standard function. A change to one or more program elements may not always reduce the effectiveness of the associated planning standard function. A reduction in effectiveness will occur if there is a decrease in the capabilities or timeliness for performing or fulfilling a function or commitment without activities to compensate for the reduction.

An RIE is caused when the licensee's capability to perform an emergency planning function in the event of an emergency is reduced. Refer to Reg Guide 1.219 regulatory position 3.7a. A comparison of how the affected function, element or commitment is currently fulfilled and how it will be fulfilled as a result of the proposed activity should be documented. Documentation should include a discussion of the capability to meet or perform the function, element, or commitment that exists following the change compared to that which existed prior to the change. Timeliness of the function, element or commitment should also be addressed. Documentation should provide a clear basis for the any differences (e.g., special circumstances that require the difference in order to effectively perform the function or as a matter of convenience or operating philosophy). Documentation should qualify the difference as improving, sustaining or reducing the effectiveness of the planning standard function or commitment.

Use of keywords from the Reg Guide (regulatory position 3.6c) such as "resources," "capabilities" and "methods" is encouraged.

DO NOT use this section to prove EN-EP-305 step 5.5[4]a in the negative. That is ONLY to determine whether or not a change "screens out." For instance, you should not state that a change does not reduce the effectiveness of the emergency plan because "it does not change the meaning or intent of a description, does not make any changes to facilities or equipment and does not change a process." Find another reason OR go back and determine whether or not the change should have screened out in the first place.

When an RIE is not identified, conclude your evaluation with the following general statement:

The proposed changes to the (INSERT SITE NAME) emergency plan (OR OTHER DOCUMENT AS APPLICABLE) continue to meet the planning standards outlined in 10 CFR 50.47(LIST ALL APPLICABLE). The effectiveness of the emergency plan is not reduced. The changes can be incorporated without prior NRC approval."

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 720F77 10CFR50.54 Review Pro ram ATTACHMENT9.10 10 CFR 50.54(a)(3) EVALUATION TEMPLATE 5HEET60F6 Part VI. Evaluation Conclusion Answer the following questions about the proposed change.

1. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? 0YES0NO

2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no 0YES0NO reduction in effectiveness)?

3. Does the proposed change constitute an emergency action level scheme change? 0YES0NO If questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRG approval under provisions of 10 CFR 50.90. If questions 1 and 2 are answered YES, and question 3 answered_ NO, implement applicable change process( es). Refer to step 5.6[8].

Part VII. Signatures Preparer Name (Print) Preparer Signature Date:

(Optional) Reviewer Name (Print) Reviewer Signature Date:

Reviewer Name (Print) Reviewer Signature Date:

PM reviews are:

live signatures whenever possible Electronic sign off by site when OK'd by PM Waived by Director, Emergency Planning - RARE Nuclear EP Project Manager Approver Name (Print) Approver Signature Date:

Manager, Emergency Preparedness or designee

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 730F77 10CFR50.54 Review Pro ram ATTACHMENT 9.11 10 CFR 50.54(Q) PROJECT MANAGER REVIEW CHECKLIST SHEET1 OF5 SCREENING:

Part I

1. Does Part I of the form ONLY list the changes for the document (does NOT attempt to screen out or justify no RIE)?

2. Are ALL changes listed in Part I in some manner?

Part II

1. Is ONE box checked?

2. If YES is checked, do you agree that the activity is fully bounded by previous review and approval? You may need to see NRG SER or FEMA approval of ANS design report to make this determination Part Ill Generally the 1st box is checked for emergency plan changes that are determined by PAD to be fully bounded by the 10CFR50.54(q) process.

The 2nd box will be checked when processes other than 10CFR50.54(q) also apply.

The 3rd box is rarely checked.

1. Is ONE box checked?

2. Are the controlling change processes listed in the area provided OR if the 1st box is checked, "1 OCFR50.54(q)" alone should be listed in the area provided Part IV NOTE: The preparer may have some items that are editorial, some that screen out and some that go to evaluation or any combination. EVERY proposed change MUST be addressed in some manner. Check to ensure each change is addressed.

1. Is ONE box checked?

2. If YES is checked, is the entir~ change being screened as listed in Part 1 actually editorial?

3. If the change involves BOTH editorial and non-editorial changes: NO should be checked with the following statement provided: "No" is checked because the revision contains other changes that are not editorial." Or some similar statement.

4. Do the editorial changes meet the definition of "editorial" as taken from EN-AD-101?

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 74 OF 77 10CFR50.54 Review Pro ram ATTACHMENT 9.11 10 CFR 50.54(a) PROJECT MANAGER REVIEW CHECKLIST 5HEET20F5 SCREENING (Cont'd):

Part IV (Cont'd)

5. Is the justification for editorial changes provided in Part IV and are all editorial changes addressed in some manner (editorial changes may be treated collectively)? Part IV: Determine whether or not the change is editorial (refer to step 3.0[5] and EN-AD-101) and follow the checkbox instructions on Attachment 9.2.

a. Step 5.6[7]: "IF some changes are editorial and some are not, THEN it is acceptable to check "no," provide the justification for the editorial changes and provide the following statement: ""No" is checked because this activity contains other changes that are not editorial." "Yes" would then be checked only when all changes in the document are editorial."

Part V NOTE: The preparer may have some items that are editorial, some that screen out and some that go to evaluation or any combination. EVERY proposed change MUST be addressed in some manner. Check to ensure each change is addressed.

1. If no boxes are checked:

a. Is an appropriate justification provided that proves step 5.5[4]a in the negative and do you agree that NO emergency planning elements are affected as defined by that procedure step?

b. Does the Basis for Conclusion end with the statement "No further evaluation is required?"

2. If at least one box is checked:

a. Do you agree that the correct boxes are checked when compared to step 5.5[4]a?

b. For changes that do not screen out (either collectively or individually), does the Basis for Conclusion end with the statement "Emergency planning element(s) (insert applicable planning standard element numbers from Part V) in Part V of this form are affected by (describe changes). A 10 CFR 50.54(q)(3) evaluation will be performed to determine whether not the effectiveness of the emergency plan is reduced and prior NRG approval is required?"

Part VI The preferred method so signify your review and concurrence is to print and sign your name with a date on the line provided and either fax or scan and email the signature page back to the originator. If this is not possible, then inform the site of your verbal, email or other method of review and concurrence and have them fill out the line for you noting the method (and date) by which you provided your concurrence.

PM reviews may be waived. This should be a rare occurrence and can ONLY be approved by the Director, Emergency Planning (or designee).

e~-Entergy NUCLEAR MANAGEMENT NON-QUALITY RELATED INFORMATIONAL USE EN-EP-305 I REV.4 MANUAL PAGE 75 OF77 Emergency Planning 10CFR50.54(q) Review Proaram AITACHMENT 9.11 10 CFR 50.54(a) PROJECT MANAGER REVIEW CHECKLIST 5HEET30F5 EVALUATION:

NOTE: Reg Guide 1.219 refers to "level of rigor (regulatory position 5.2c5) and "significant evaluation" (regulatory position 3.7c} when describing 50.54(q)(3) evaluations. Ensure the final product is detailed and informative enough to meet the standard expressed in the Reg Guide.

Part I NOTE: ALL evaluations must have an associated screening.

1. Does Part I of the form ONLY list the changes for the document (does NOT attempt to justify no RIE or that regulatory requirements continue to be met)?

2. Are ALL changes listed in Part I in some manner either here and/or in the screening document?

Many times this section will read the same as the screening, but this is not required. It is acceptable (and encouraged) that this section of the evaluation NOT include items that were screened out Part II

1. Are documents reviewed listed? Statements taken from a PAD review and reference to the PAD review are acceptable. It is NOT acceptable to just make a statement such as "see PAD review for details"

2. Are the applicable sections of the emergency plan listed as reviewed and their relationship to the proposed change noted?

3. Was the latest NRG approved (SER provided) emergency plan and subsequent changes reviewed and any differences noted and their reasons documented? *

a. If the latest NRG approved version of the emergency plan cannot be located, is this stated in Part II with reference to the revisions that were in fact reviewed?

Part Ill

1. At a minimum, are all of the emergency planning elements checked in Part V of the screening covered (ONLY the associated planning standard should be listed)?

2. Is the Entergy prescribed format for this part used? See example below 10 CFH 50.47(b)(2} -The process for timely augmentation of on-shift staff is established and maintained.

Site Compliance - Through implementation of this procedure revision, system testing requirements have been established for the ERO Notification System to test the ERO on a weekly and quarterly basis through a combination of announced and unannounced tests, drills and exercises to ensure that timely augmentation of staff is practiced and continues to meet the regulatory requirements. Guidelines for performing these tests have been updated in this revision. Re-test criteria have also been established in the event that test results do not meet activation expectations and compensatory actions are put into effect.

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4

~*Entergy MANAGEMENT INFORMATIONAL USE ,

MANUAL PAGE 760F77 10CFR50.54 Review Pro ram ATTACHMENT 9.11 10 CFR 50.54(a} PROJECT MANAGER REVIEW CHECKLIST SHEET40F5 EVALUATION (Cont'd}:

Part Ill (Cont'd}

3. Do you agree with the statements provided for why the regulatory requirements continue to be met (site compliance)?

4. Are NRC commitments addressed (required) using the Entergy prescribed format? See example below Previous NRC Commitments-The Regulatory Assurance Commitment Management System and NRC commitment system were reviewed for potential NRC commitment changes as a result of this revision. There were no identified conflicts with this emergency plan revision and the current listing of NRC commitments associated with the emergency plan. All current NRC commitments that relate to emergency response notification systems and conduct of drills continue to be maintained and fulfilled under this procedure revision.

Part IV

1. Does Part IV of the form ONLY list the applicable planning standards, functions and program elements affected (does NOT attempt to justify no RIE)?

2. Do the items listed match those selected in Part V of the screening?

3. Is the Entergy prescribed format Attachment 9.10 used?

PartV NOTE: The preparer may have some items that are editorial, some that screen out and some that go to evaluation or any combination. EVERY proposed change MUST be addressed in some manner. Check to ensure each change is addressed.

1. Are clear, logical statements made that indicate no RIE exists for each change being evaluated?

2. Is each emergency planning element in Part IV addressed by the evaluation?

3. Is the evaluation written to support the conclusion that an RIE does not exist (as opposed to written in a manner to justify screening out) with reference to timing of actions, resources, capabilities and methods as applicable?

4. Is a comparison made of how the affected function, element or component is currently fulfilled to how it will be fulfilled as a result of the proposed change?

5. Are you convinced?

6. Does Part V close with the appropriate Entergy prescribed conclusion statement(s)? See examples below When an RIE is not identified, conclude your evaluation with the following general statement:

"The proposed changes to the (INSERT SITE NAME) emergency plan continue to meet the planning standards outlined in 10 CFR 50.47(LIST ALL APPLICABLE). The effectiveness of the emergency plan is not reduced. The emergency plan changes can be incorporated without prior NRC approval."

NUCLEAR NON-QUALITY RELATED EN-EP-305 REV.4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 77 OF 77 10CFRS0.54 Review Pro ram ATTACHMENT 9.11 10 CFR 50.54(a) PROJECT MANAGER REVIEW CHECKLIST SHEETS OF5 Part VI The preferred method so signify your review and concurrence is to print and sign your name with a date on the line provided and either fax or scan and email the signature page back to the originator. If this is not possible, then inform the site of your verbal, email or other method of review and concurrence and have them fill out the line for you noting the method (and date) by which you provided your concurrence.

PM reviews may be waived. This should be a rare occurrence and can ONLY be approved by the Director, Emergency Planning (or designee).

., j ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET1 OF5 Procedure/Document Number: EN-EP-305 I Revision: 4 Equipment/Facility/Other: JAF

Title:

Emergency Planning 10CFR50.54(q) Review Program Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

1. This is a major revision to the procedure to implement a review process for 10CFR50.54(q)(2) that differs from the review process applied to emergency plan changes made under 10CFR50.54(q)(3)

2. Eliminates the NRC submittal requirement for Emergency Plan Implementing Procedure changes to address a change in the regulations *

3. Clarifies training requirements as they apply to site Emergency Planning Managers

4. Eliminates flow charts

5. Adds tools to assist with the completion of 10CFR50.54(q)(3) screenings and evaluations and the performance of Project Manager Reviel(Vs

6. Makes editorial corrections throughout procedure for formatting and consistency, such as changing "Emergency Plan" to (lower case) "emeroencv plan" throuohout the document where applicable Part II. Activity Previously Reviewed? DYES ~NO Is this activity fully bounded by an NRC approved 1 O CFR 50.90 submittal or 50.54(q)(3) Continue to Evaluation is next part Alert and Notification System Design Report? NOT required.

Enter If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and complete Part proposed change is documented below: VI.

Justification:

D Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3)

Screening.

APPLICABILITY CONCLUSION

~If there are no controlling change processes, continue the 50.54(q)(3) Screening.

D One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

D One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT required. ldentifv controllina chanae processes below and complete Part VI.

CONTROLLING CHANGE PROCESSES 10CFR50.54(a)

EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING 5HEET20F5 Procedure/Document Number: EN-EP-305 I Revision: 4 Equipment/Facility/Other: JAF

Title:

Emergency Planning 10CFR50.54(q) Review Program Part IV. Editorial Change DYES [8JNO 50.54(q)(3) Continue to next Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.

Justification: Enter justification and Change 6 makes formatting, style and grammatical changes throughout the procedure complete Part that do not change intent or meaning and are editorial in accordance with EN-AD-101. VI.

"No" is checked because this activity contains other changes that are not editorial."

Part V. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NU REG-0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1] D

2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 D staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] D

4. The process for timely augmentation of onshift staff is established and maintained. [2] D

5. Arrangements for requesting and using off site assistance have been made. [3] D

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] D

7. A standard scheme of emergency classification and action levels is in use. [4] D

8. Procedures for notification of State and local governmental agencies are capable of alerting them of D the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt D instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response D organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6] D

13. Emergency preparedness information is made available to the public on a periodic basis within the D plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination of public information during emergencies is established. [7] D

15. Adequate facilities are maintained to support emergency response. [8] D

16. Adequate equipment is maintained to support emergency response. [8] D

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] D

18. A range of public PARs is available for implementation during emergencies. [1 O] D

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are D available to support the formulation of PARs and have been provided to State and local governmental authorities. [1 O]

20. A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events.[1 O]

EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET30F5 Procedure/Document Number: EN-EP-305 I Revision: 4 Equipment/Facility/Other: JAF

Title:

Emergency Planning 10CFR50.54(q) Review Program

21. The resources for controlling radiological exposures for emergency workers are established. [11] D

22. Arrangements are made for medical services for contaminated, injured individuals. [12] D

23. Plans for recovery and reentry are developed. [13] D

24. A drill and exercise program (including radiological, medical, health physics and other program D areas) is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, D maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]

26. Identified weaknesses are corrected. [14] D

27. Training is provided to emergency responders. [15] D

28. Responsibility for emergency plan development and review is established. [16] D

29. Planners responsible for emergency plan development and maintenance are properly trained. [16] D APPLICABILITY CONCLUSION

~If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI.

0 If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION Change 6 makes editorial changes to the procedure.

Changes 1-5: The 10CFR50.54(q) review process described in this procedure does not provide any means to address planning standards or elements as listed in 10CFR50.47(b) and Appendix E.IV of 10CFR50 (with elements shown above), but instead provides a methodology to determine whether or not the emergency plan continues to comply with these requirements. The procedure also provides the methodology for determining whether or not a proposed change or activity impacts the emergency plan and if it does, whether or not it results in a reduction (decrease) in effectiveness. A change to the process described in this procedure does not in itself directly result in any change to the emergency plan's described capabilities, timing criteria, materials or resources and therefore cannot and does not directly reduce the capability to perform emergency planning functions. In this sense, revision 4 of this procedure maintains the current effectiveness level of the emergency plan and does not affect a planning standard element/function listed above. These changes will not be evaluated. Further detail on each change is provided below.

Change 1: This procedure revision provides a separate method for the conduct of 10CFR50.54(q) reviews of activities that are not in themselves changes to the emergency plan. This change is compatible with the intention of 10CFR50.54(q}(3}, which reserves the determination of a reduction in effectiveness to emergency plan changes. 10CFR50.54(q}(2} requires that changes that are not emergency plan changes "follow and maintain the effectiveness of the emergency plan." Previous to this revision, the 10CFR50.54(q)(3) process was applied to all activities, whether emergency plan changes or not. This process did not provide optimal alignment with the regulation as described in 10CFR50.54(q)(2) and (q)(3}

because it applied a process for emergency plan changes (50.54(q)(3)) to all activities. This procedure revision corrects that process and improves alignment with the 10CFR50.54(q) regulation.

EN-EP-305 REV 3

ATTACHMENT 9.1 10CFR50.54(q) SCREENING SHEET40F5 Procedure/Document Number: EN-EP-305 I Revision: 4 Equipment/Facility/Other: JAF

Title:

Emergency Planning 10CFR50.54(q) Review Program BASIS FOR CONCLUSION (Cont'd)

Change 2: Eliminates the NRG submittal requirement for Emergency Plan Implementing Procedure changes to address a change in the regulations. This change aligns the procedure with revised NRG regulations (revised December, 2015) in 10CFR50 Appendix E.V that eliminates the requirement for submittal of Emergency Plan Implementing Procedure (EPIPs) revisions to the NRG. The submittal of revised EPIPs to the NRG - whether required to be performed or not - has no affect or impact on the processes or facilities described in the EPIPs or in the site-specific emergency plan related to 10CFR50.47(b) planning standards or 10CFR50 Appendix E.IV emergency plan content. Therefore this change does not affect a planning standard element/function listed above.

Change 3: Clarifies training requirements as they apply to site Emergency Planning Managers. Previously, procedure step 5.7[1] stated that "personnel who prepare, review and/or approve 10CFR50.54(q) screenings and evaluations should be qualified to ensure that they are capable of performing those functions ... " .3 was provided to list and document required qualifications. The procedure was not clear how or if this attachment applied to Emergency Planning managers (approvers). The procedure has been revised to indicate that the attachment (new Attachment 9.4) does apply to Emergency Planning Managers in a limited fashion (required reading material). The required training for approvers of 10CFR50.54(q) documentation has no affect or impact on the processes or facilities described in the EPIPs or in the site-specific emergency plan related to 10CFR50.47(b) planning standards or 10CFR50 Appendix E.IV emergency plan content. Therefore this change does not affect a planning standard element/function listed above.

• Change 4: Eliminates flow charts. Previously, the procedure provided flow chart diagrams for the screening and evaluation processes in Attachments 9.5 and 9.6. These flow charts have been eliminated as an administrative change because they repeat a process already described in the procedure body.. Eliminating these flow charts does not change any process because they do not (and did not previously) establish a process, but reflect whatever process is already described in the body of the procedure.

Change 5: Adds tools to assist with the completion of 10CFR50.54(q)(3) screenings and evaluations and the performance of Project Manager Reviews. Attachments 9.9, 9.1 O and 9.11 are new additions to the procedure to assist personnel in completing screenings, evaluations and independent reviews of 10CFR50.54(q) documentation. These attachments are provided as aids only and do not provide procedure requirements. The use of the new procedure attachments in and of themselves has no affect or impact on the processes or facilities described in the EPIPs or in the site-specific emergency plan related to 10CFR50.47(b) planning standards or 10CFR50 Appendix E.IV emergency plan content. Therefore this change does not affect a planning standard element/function listed above.

This justification is sufficient to conclude that a 10CFR50.54(q) evaluation is not necessary because the change to the Entergy 10CFR50.54(q) process does not directly involve or affect site-specific emergency plan elements required to meet the Planning Standards in 10CFR50.47(b) or the requirements for emergency plan content in 10CFR50 Appendix E.IV. No further evaluation is required for this procedure revision.

EN-EP-305 REV 3

J * ' '

ATIACHMENT9.1 10CFR50.54(q) SCREENING SHEET5 OF 5 Procedure/Document Numb.er: EN-EP-305 I Revision: 4 Equipment/Facility/Other: JAF

Title:

Emergency Planning 10CFR50.54(q) Review Program Part VI. $ignatures:

Preparer Name (Print) Preparer Signature Date:

MELLONIE CHRISTMAN m [,.Ln~ 5/10/2016 (Optional) Reviewer Name (Print) Date:

Date:

Reviewer er(~ ~

Nuclear EP Pr~e~ahager ~

Approver Name (Print) Date:

~

EP manager or designee EN-EP-305 REV 3