ML032320056

Radiological Emergency Response Plan Implementing Procedures

ML032320056
Person / Time
Site:	Kewaunee
Issue date:	08/11/2003
From:	Coutu T Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-03-086
Download: ML032320056 (247)

Text

N ll Committed to Nuclear Excell Kewaunee Nuclear Power Plant Operated by Nuclear Management Company, LLC NRC-03-086 10 CFR 50, App. E August 11, 2003 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 KEWAUNEE NUCLEAR POWER PLANT DOCKET 50-305 LICENSE No. DPR-43 RADIOLOGICAL EMERGENCY RESPONSE PLAN IMPLEMENTING PROCEDURES Pursuant to 10 CFR 50 Appendix E, attached is the latest revisions to the Kewaunee Nuclear Power Plant Radiological Emergency Response Plan Implementing Procedures (EPIPs). These revised procedures supersede the previously submitted procedures.

Pursuant to 10 CFR 50.4, two additional copies of this letter and attachment are hereby submitted to the Regional Administrator, U. S. Nuclear Regulatory Commission, Region 1II, Lisle, Illinois. As required, one copy of this letter and attachment is also submitted to the Kewaunee Nuclear Power Plant NRC Senior Resident Inspector.

Thomas Coutu Site Vice-President, Kewaunee Plant SLC Attachment cc US NRC Senior Resident Inspector, w/attach.

US NRC, Region III (2 copies), w/attach.

Electric Division, PSCW, w/o attach.

QA Vault, w/o attach.

WA 5 N490 Highway 42

• Kewaunee, Wisconsin 54216-9510 Telephone: 920.388.2560

KEWAUNEE NUCLEAR POWER PLANT REVISION OF EMERGENCY PLAN IMPLEMENTING PROCEDURES July 31, 2003 Please follow the directions listed below.

EPIP Index, dated 07-31-2003.

REMOVE INSERT PROCEDURE REV. PROCEDURE REV.

EPIP-AD-03 AH EPIP-AD-03 AI EPIP-AD-04 AM EPIP-AD-04 AN EPIP-AD-07 AT EPIP-AD-07 AU EPIP-ENV-01 W EPIP-ENV-01 X EPIP-ENV-02 X EPIP-ENV-02 Y EPIP-ENV-04A T EPIP-ENV-04A U EPIP-ENV-04B X EPIP-ENV-04B Y EPIP-ENV-04C X EPIP-ENV-04C Y EPIP-ENV-04D 0 EPIP-ENV-04D P EPIP-EOF-02 AA EPIP-EOF-02 AB EPIP-EOF-03 AD EPIP-EOF-03 AE EPIP-EOF-04 AK EPIP-EOF-04 AL EPIP-EOF-08 Z EPIP-EOF-08 AA EPIP-EOF-1 1 V EPIP-EOF-1 1 W EPIP-RET-02 W EPIP-RET-02 X EPIP-RET-05 H EPIP-RET-05 I EPIP-SEC-02 Y EPIP-SEC-02 Z EPIP-TSC-08B G EPIP-TSC-08B H EPIP-TSC-10 K EPIP-TSC-10 L Form EPIPF-AD-07-04 C DELETED ---

Form EPIPF-ENV-01-01 D Form EPIPF-ENV-01-01 E Form EPIPF-ENV-01-02 B Form EPIPF-ENV-01-02 C Form EPIPF-ENV-01-04 B Form EPIPF-ENV-01-04 C Form EPIPF-ENV-02-01 N Form EPIPF-ENV-02-01 0 Form EPIPF-EOF-02-01 T Form EPIPF-EOF-02-01 Form_____________________

EPIPF-EOF-020 _ (Clears TCI dated 10-03-2002)

Form EPIPF-TSC-01-03 B Form EPIPF-TSC-01-03 C l Return a signed and dated copy of this transmittal letter, within 10 days of transmittal date, to the sender. If you have any questions or comments, please contact Jerrie Morlino at 8719.

I CERTIFY Copy No. (WPSC No.) of the Kewaunee Nuclear Power Plant's EPIPs has been updated.

SIGNATURE DATE Please return this sheet to DIANE FENCL.

2

EMERGENCY PLAN IMPLEMENTING PROCEDURES INDEX DATE: 07-31-2003 PROC. NO. TITLE l REV. j DATE EP-AD EPIP-AD-01 Personnel Response to the Plant Emergency Siren K 11-26-2002 EPIP-AD-02 Emergency Class Determination AG 05-05-2003 EPIP-AD-03 KNPP Response to an Unusual Event Al 07-31-2003 EPIP-AD-04 KNPP Response to Alert or Higher AN 07-31-2003 EP-AD-5 Site Emergency Deleted 04-27-87 EPIP-AD-05 Emergency Response Organization Shift Relief E 02-18-2003 Guideline EP-AD-6 General Emergency Deleted 04-24-87 EPIP-AD-07 Initial Emergency Notifications AU 07-31-2003 EP-AD-8 Notification of Alert or Higher Deleted 02-26-96 EP-AD-9 Notification of Site Emergency Deleted 04-27-87 EP-AD-10 Notification of General Emergency Deleted 04-27-87 EPIP-AD-l1 Emergency Radiation Controls S 12-19-2002 EP-AD-12 Personnel Assembly and Accountability Deleted 03-26-94 EP-AD- 13 Personnel Evacuation Deleted 04-25-94 EP-AD-13A Limited Area Evacuation Deleted 03-01-83 EP-AD-13B Emergency Assembly/Evacuation Deleted 03-01-83 EP-AD- 13C Site Evacuation Deleted 03-01-83 EP-AD-14 Search and Rescue Deleted 05-25-94 EPIP-AD-15 Recovery Planning and Termination P 09-12-2002 EP-AD-16 Occupational Injuries or Vehicle Accidents Deleted 03-14-97 During Emergencies EP-AD- 17 Communications Deleted 03-05-84 EPIP-AD-18 Potassium Iodide Distribution P 02-27-2002 EPIP-AD- 19 Protective Action Guidelines 5 01-20-2003 PAGE 1 OF 11

EMERGENCY PLAN IMPLEMENTING PROCEDURES INDEX DATE: 07-31-2003 PROC. NO. TITLE EPIP-AD-20 KNPP Response to a Security Threat EP-ENV EPIP-ENV-01 Environmental Monitoring Group Organization X 07-31-2003 and Responsibilities EPIP-ENV-02 Environmental Monitoring Team Activation Y 07-31-2003 EP-ENV-3A Environmental Protection Director Actions and Deleted 09-26-84 Directives EP-ENV-3B EM Team Actions Deleted 09-26-84 EPIP-ENV-03C Dose Projection Using RASCAL Version 2.2 W 08-20-2002 Software EP-ENV-3D Revision and Control of ISODOSE II Deleted 02-14-95 EP-ENV-3E Manual Determination of X/Q Deleted 04-24-87 EP-ENV-3F Manual Determination of X/Q (Green Bay Deleted 05-30-86 Meteorological Data)

EP-ENV-3G Manual Dose Projection Calculation Deleted 06-02-89 EP-ENV-3H Protective Action Recommendations Deleted 04-13-90 EPIP-ENV-04A Portable Survey Instrument Use U 07-31-2003 EPIP-ENV-04B Air Sampling and Analysis Y 07-31-2003 EP-ENV-4C Environmental Monitoring Teams Deleted 04-13-90 EPIP-ENV-04C Ground Deposition Sampling and Analysis Y 07-31-2003 EPIP-ENV-04D Plume Tracking for Environmental Monitoring P 07-31-2003 Teams EP-ENV-5A LCS-1 Operation Deleted 04-14-86 EP-ENV-5B MS-3 Operation Deleted 04-14-86 EP-ENV-5C S SAM Operation Deleted 04-14-86 EP-ENV-5D PAC-4G (Alpha Counter) Operation Deleted 04-14-86 EP-ENV-5E Reuter-Stokes Operation Deleted 08-27-85 PAGE 2 OF 11

EMERGENCY PLAN IMPLEMENTING PROCEDURES INDEX DATE: 07-31-2003 PROC. NO. TITLE REV. DATE EP-ENV-6 Data Analysis, Dose Projections and Protective Deleted 12-21-81 Action Recommendations EP-ENV-6 Alternate Sample Analysis and Relocation of EM Deleted 04-14-86 Team EP-ENV-6A Relocation of Site Access Facility (Habitability) Deleted 03-23-84 EP-ENV-6B SAF Environmental Sample Analysis Relocation Deleted 03-23-84 EP-ENV-7 Site Access Facility Communications Deleted 09-26-84 EP-ENV-8 Total Population Dose Estimate Calculations Deleted 04-14-86 EP-EOF EP-EOF-1 Corporate Emergency Response Organization Deleted 03-11-94 EPIP-EOF-02 Emergency Operations Facility (EOF) Activation AB 07-31-2003 EPIP-EOF-03 EOF Staff Action for Unusual Event AE 07-31-2003 EPIP-EOF-04 EOF Staff Action for Alert or Higher AL 07-31-2003 EP-EOF-5 Corporate Staff Action for Site Emergency Deleted 04-24-87 EP-EOF-6 Corporate Staff Action for General Emergency Deleted 04-24-87 EP-EOF-7 Notification of Unusual Event Deleted 04-06-94 EP-EOF-8 Relocation of EOF Deleted 03-01-83 EPIP-EOF-08 Continuing Emergency Notifications AA 07-31-2003 EP-EOF-9 Interface with Support Organizations Deleted 03-05-84 EP-EOF-9 Notification of Site Emergency Deleted 04-24-87 EP-EOF-10 Notification of General Emergency Deleted 04-24-87 EPIP-EOF-1 1 Internal Communication and Documentation W 07-31-2003 Flow EPIP-EOF-12 Media Center/Emergency Operation Facility/Joint R 06-19-2003 Public Information Center/Security PAGE 3 OF 11

EMERGENCY PLAN IMPLEMENTING PROCEDURES INDEX DATE: 07-31-2003 PROC. NO. TITLE [ REV. DATE Er-OP EP-OP-1 Control Room Emergency Organization Deleted 04-24-87 EP-OP-2 Emergency Control Room Activation for Deleted 04-24-87 Emergency Response EP-OP-3 Control Room Communications Deleted 04-24-87 EP-OSF EP-OSF-I Operation Support Facility Emergency Deleted 04-24-87 Organization EPIP-OSF-02 Operational Support Facility Operations V 11-26-2002 EPIP-OSF-03 Work Orders During an Emergency P 05-09-2002 EP-OSF-4 Operational Support Facility Communications Deleted 04-24-87 EPIP-OSF-04 Search and Rescue E 05-23-2002 EP-RET EP-RET-1 Radiation Emergency Team Organization Deleted 04-16-96 EPIP-RET-02 In-Plant Radiation Emergency Team X 07-31-2003 EPIP-RET-02A Radiation Protection Office/Radiological Analysis U 11-07-2002 Facility (RPO/RAF) Activation EPIP-RET-02B Gaseous Effluent Release Path, Radioactivity, and S 08-06-2002 Release Rate Determination EP-RET-2C Containment Air Sampling and Analysis Deleted 03-01-83 EPIP-RET-02D Emergency Radiation Entry Controls and M 06-12-2001 Implementation EP-RET-2E Handling of Injured Personnel Deleted 04-16-96 EP-RET-2F Personnel Decontamination Deleted 04-13-90 EPIP-RET-03 Chemistry Emergency Team P 02-18-2003 EPIP-RET-03A Liquid Effluent Release Paths L 11-29-2001 EP-RET-3B Post-Accident Reactor Coolant Alternate Deleted 01-25-88 Sampling Procedure PAGE 4 OF 11

EMERGENCY PLAN IMPLEMENTING PROCEDURES INDEX DATE: 07-31-2003 PROC. NO. TITLE REV. DATE EPIP-RET-03C Post Accident Operation of the High Radiation P 01-15-2002 Sample Room EPIP-RET-03D Containment Air Sampling Analysis Using CASP N 01-15-2002 EP-RET-3E Post Accident Operation of High Rad Sample Deleted 08-27-85 Room Inline Multiported Count Cave EPIP-RET-04 SBF Activation U 06-19-2003 EP-RET-4A EOF Radiological Monitoring Deleted 03-10-83 EPIP-RET-04A SBF Operation/Relocation Deleted 10-02-2001 EP-RET4B Radiological Controls at Site Access Facility Deleted 07-12-94 EP-RET-4C Site Radiological Monitoring Deleted 07-12-94 EP-RET-4D SAM-Il Operation Deleted 07-12-94 EP-RET-5 Plume Projection Deleted 09-26-84 EPIP-RET-05 Site Boundary Dose Rates During Controlled I 07-31-2003 Plant Cooldown EP-RET-5A Plume Projection Deleted 04-27-87 EP-RET-6 Dose Projection Deleted 04-24-87 EP-RET-7 Radiological Analysis Facility/Radiation Deleted 04-24-87 Protection Office Communications EPIP-RET-08 Contamination Control of the Aurora Medical Deleted 05-23-2002 Center EPIP-RET-09 Post-Accident Population Dose M 04-29-2003 EP-SEC EP-SEC-1 Security Organization Deleted 04-24-87 EPIP-SEC-02 Security Force Response to Emergencies Z 07-31-2003 EP-SEC-2A Manual Activation of Emergency Sirens Deleted 04-16-82 EPIP-SEC-03 Personnel Assembly and Accountability AG 05-20-2003 EPIP-SEC-04 Security Force Actions for Dosimetry Issue P 10-02-2001 PAGE 5 OF 11

EMERGENCY PLAN IMPLEMENTING PROCEDURES INDEX DATE: 07-31-2003 PROC. NO. TITLE REV. DATE EP-SEC-5 Security Force Response to the EOF Deleted 07-28-88 EPIP-SEC-05 Personnel Evacuation G 06-20-2002 EP-TSC EPIP-TSC-01 Technical Support Center Organization and S 01-28-2003 Responsibilities EPIP-TSC-02 Technical Support Center Activation U 01-20-2003 EPIP-TSC-03 Plant Status Procedure W 05-05-2003 EPIP-TSC-04 Emergency Modifications 0 04-29-2003 EP-TSC-5 Technical Support Center Communications Deleted 04-24-87 Equipment EP-TSC-6 Assessment of Reactor Core Damage Deleted 09-30-86 EPIP-TSC-07 RV Head Venting Time Calculation J 06-20-2002 EPIP-TSC-08A Calculations for Steam Release from Steam 0 11-26-2002 Generators EPIP-TSC-08B* STMRLS Computer Program H 07-31-2003 EP-TSC-8C* See EP-TSC-8B Deleted 04-16-92

• EP-TSC-8B was totally deleted; therefore, EP-TSC-8C was changed to EP-TSC-8B EP-TSC-9 Core Damage Assessment Using Released Deleted 09-30-86 Radionuclides EPIP-TSC-09A* Core Damage Assessment K 05-05-2003 EPIP-TSC-09B1* CORE Computer Program Deleted 05-16-2002 EP-TSC-9C* See EP-TSC-9B Deleted 04-16-92

• EP-TSC-9A, Rev. D was totally deleted; therefore, EP-TSC-9B became EP-TSC-9A. EP-TSC-9B was previously EP-TSC-9C.

EPIP-TSC-10 FTechnical Support for IPEOPs L 07-31-2003 PAGE 6 OF 11

EMERGENCY PLAN IMPLEMENTING PROCEDURES INDEX DATE: 07-31-2003 FIGURES EPIP FIG# Figure EPIPFG DESCRIPTION REV. DATE EP-SEC-5 Technical Support EPIP-APPX-A-06 EP-FIG-003 APPX-A-06-03 Center - KNP Floor Plan B 06-12-2001 Site Boundary Facility -

EPIP-APPX-A-06 EP-FIG-005 APPX-A-06-02 KNP Floor Plan A 10-31-2000 Radiological Analysis EPIP-APPX-A-06 EP-FIG-008 APPX-A-06-01 Facility - KNP Floor Plan A 10-31-2000 EPIP-EOF-12 Division Office Building Form EPIPF-EOF-02-01 EP-FIG-09 EOF-12-01 (2nd Floor) Floor Plan C 06-19-2003 State/County Work Area -

EPIP-APPX-A-06 EP-FIG-012 APPX-A-06-08 WPSC D2-1 Floor Plan C 10-31-2000 NRC Work Area -

EPIP-APPX-A-06 EP-FIG-013 APPX-A-06-09 WPSC D2-4 Floor Plan A 10-31-2000 Population Distribution by Geographical Sub-EPIP-AD-19 EP-FrG-014 AD-19-01 Areas (with sectors) A 10-31-2000 EOF - WPSC D2-3 EPIP-APPX-A-06 EP-FIG-022 APPX-A-06-04 Floor Plan D 04-29-2003 Location of JPIC and Media Briefing Center EPIP-EOF-12 EP-FIG-024 EOF-12-02 Map D 06-19-2003 KNP Site Map &

EP-SEC-5 EP-FIG-026 SEC-05-01 Evacuation Routes C 06-20-2002 Floor Plan - Media APPX-A-6 EP-FIG-034 --- Briefing Center Deleted 08-04-98 EPIP-EOF-12 EPIP-APPX-A-06 EP-FIG-035 APPX-A-06-06 Media Briefing Center D 04-29-2003 Floor Plan - Corporate APPX-A-6 EP-FlG-037 _ _ _ Response Center Deleted 08-04-98 APPX-A-6 EPG038--- Floor Plan - JPIC Deleted 08-04-98 EPIP-OSF-02 EP-FIG-039 OSF-02-01 High Priority Work B 07-31-2003 EPIP-OSF-02 EP-FIG-039A OSF-02-02 Lower Priority Work B 07-31-2003 JPIC - Federal Work EPIP-APPX-A-06 EP-FIG-043 APPX-A-06-10 Area - WPSC D2-9 C 04-29-2003 JPIC - State and County Work Area -

EPIP-APPX-A-06 EP-FIG-044 APPX-A-06-07 WPSC D2-8 D 04-29-2003 WPIC - Utility Work EPIP-APPX-A-06 EP-FIG-045 APPX-A-06-05 Area - WPSC D2-7 D 04-29-2003 Aurora Medical Center RET-08 EP-F1G446 RET-08-01 Location Deleted 05-23-2002 EPIP-APPX-A-02 --- APPX-A-02-01 ERO Call Tree Deleted 12-04-2001 PAGE 7 OF 11

EMERGENCY PLAN IMPLEMENTING PROCEDURES INDEX DATE: 07-31-2003 NUMBER TITLE REVISION DATE APPENDIX A APPX-A-1 Communication System Description AF 08-04-98 EPIP-APPX-A-02 Response Personnel Call List Deleted 02-06-2002 EPIP-APPX-A-03 Off-Site Telephone Numbers Deleted 02-06-2002 EPIP-APPX-A-06 KNPP Emergency Response Facility Figures AB 04-29-2003 PAGE 8 OF 11

EMERGENCY PLAN IMPLENENTING PROCEDURES INDEX DATE: 07-31-2003 FORM EPIPF TITLE REV. DATE APPENDIX B EP-AD AD-07-01 Event Notice - Nuclear Accident Reporting System Form V 05-05-2003 (NARS)

AD-07-02 State Call-Back - Question Guideline C 11-15-2001 AD-07-03 Fax Event Notice B 03-06-2003 AD-07-04 ERO Event Notification Deleted 07-31-2003 AD-11-01 Emergency Radiation Work Permit H 12-19-2002 AD-18-01 Airborne Radioiodine Dose Accountability and Potassium B 08-06-2002 Iodide Distribution AD-18-02 Record of Known Allergy To or Voluntary Refusal to Take A 02-27-2002 Potassium Iodide EP-ENV ENV-01-01 Environmental Dispatch Area Activation Checklist E 07-31-2003 ENV-01-02 EMT Status C 07-31-2003 ENV-01-03 Meteorological and Plant Status Data C 12-14-2001 ENV-01-04 EMT Orders/Field Data C 07-31-2003 ENV-02-01 EMT Activation Checklist 0 07-31-2003 EP-EOF EOF-02-01 EOF Activation Checklist U 07-31-2003 EOF-02-02 EOF Deactivation Checklist N 01-28-2003 EOF-04-01 SRCL Initial Action Checklist D 01-20-2003 EOF-04-02 Telephone Communications Log Sheet A 12-14-2001 EOF-08-03 Fax for Emergency Declaration or Status Updates H 01-20-2003 EOF-08-05 Plant Emergency Status Report A 11-27-2001 EOF-08-06 Radiological Status Report E 01-20-2003 EOF-1 1-02 Operating Status G. 11-7-2002 PAGE 9 OF 11

EMERGENCY PLAN IMPLEMENTING PROCEDURES INDEX DATE: 07-31-2003 FORMS EPIPF TITLE REV. DATE EOF-1 1-03 Environmental Status Board G 11-07-2002 EOF-12-01 I.D. Badge Registration Form G 10-24-2000 EP-OSF OSF 2.2 Maintenance Work in Progress Deleted 07-08-98 OSF-03-01 Operational Support Facility Team Briefing C 12-04-2001 EP-RET RET-02A-02 Emergency Sample Worksheet E 06-05-2001 RET-02B-01 Containment Stack Release (Grab Sample) D 08-06-2002 RET-02B-02 Auxiliary Building Stack (Grab Sample) D 08-06-2002 RET-02B-03 Auxiliary Building Stack (Sping Reading) D 08-06-2002 RET-02B-04 Containment Stack (Sping Reading) C 08-06-2002 RET-02B-05 Steam Release D 08-06-2002 RET-02B-06 Field Reading (Grab Sample) B 08-06-2002 RET-04-01 SAM-2 Counting Equipment Worksheet E 06-12-2001 RET 8.3 Hospital Survey 1 Deleted 06-05-2001 RET 8.4 Hospital Survey 2 Deleted 07-25-97 RET 8.5 Hospital Survey 3 Deleted 07-25-97 RET-08-06 Hospital Survey 4 Deleted 05-23-2002 RET-09-01 Post-Accident TLD Record Sheet D 04-16-2002 EP-SEC SEC-03.01 Emergency Accountability Log A 03-28-2000 SEC-04-01 Emergency Dosimeter Log G 06-20-2002 EP-TSC TSC-01.01 Plant Status Summary for SAM Implementation C 01-28-2003 TSC-01.02 Severe Accident Management Summary and Strategy B 02-06-2002 Recommendation PAGE 10 OF 11

EMERGENCY PLAN INIPLENENTING PROCEDURES INDEX DATE: 07-31-2003 FORM EPIPF TITLE REV. DATE TSC-01-03 Severe Accident Management - Status C 07-31-2003 TSC-02-01 TSC and OSF Activation Checklist P 01-20-2003 TSC-02-02 TSC Ventilation Checklist I 01-20-2003 TSC-02-03 Emergency Response Data System (ERDS) Link Initiation H 01-20-2003 Checklist TSC-02-04 TSC Chart Recorder Operation Checklist E 01-20-2003 TSC-02-05 TSC and OSF De-Activation Checklist C 01-28-2003 TSC-03-01 Plant System Status L 06-12-2001 TSC-03-02 Plant Equipment Status L 06-12-2001 TSC-03-03 Environmental Status Board J 06-12-2001 TSC-03-04 Radiation Monitors I 01-08-2002 TSC-04-01 Emergency Modification Request H 04-29-2003 TSC-04-02 Emergency Physical Change Safety Review Deleted 05-09-2002 TSC-04-03 Emergency Modification Index G 04-29-2003 TSC-07-01 Head Venting Calculation G 06-20-2002 TSC-08A-01 Steam Release Data Sheet (Energy Balance) H 12-14-2001 TSC-08A-02 Steam Release Calculation Sheet (Energy Balance) G 12-14-2001 TSC-08A-03 Steam Release Data/Calculation Sheet (Open Valve) E 12-14-2001 TSC-08A-04 Steam Release Data/Calculation Sheet (STMRLS Program) D 12-14-2001 TSC-09A-01 Core Exit Thermocouple Data D 05-16-2002 TSC-09A-02 Fuel Rod Clad Damage Estimate D 05-16-2002 TSC-09A-03 Fuel Rod Overtemperature Damage Estimate E 05-16-2002 TSC 9A.4 Core Damage Based on Activity Ratios Deleted 05-16-2002 TSC-09A-05 Core Damage Assessment (Monitoring Data) E 05-16-2002 TSC 9A.6 Core Damage Summary Deleted 05-16-2002 TSC-09A-07 Core Damage Assessment Results A 05-05-2003 PAGE 11 OF 11

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 1 of 29 Reviewed By Richard Johnson Approved By Jerrie Morlino Nuclear a Yes PORC C: Yes SRO Approval Of 3 Yes Safety Review Temporary Related 0 No Required 0 No Changes Required Ed No 1.0 Purpose 1.1 This procedure provides instruction for the Shift Manager/Emergency Director and other initial response personnel for an appropriate response to an Unusual Event.

2.0 General Notes 2.1 The Shift Manager (SM) is the initial Emergency Director (ED) in all situations. Any transfer of this responsibility shall be documented in the Shift Manager's log and communicated to all on-site directors.

2.2 At the Unusual Event level, radio-pager activation will be performed by Control Room personnel for all designated emergency response directors (primary and alternate).

2.3 IF approached by the media during a declared emergency, THEN refer them to the Joint Public Information Center (JPIC) at 920-433-1400 or 1-800-838-6192 and tell them that this is their most accurate source for information.

3.0 Precautions and Limitations 3.1 Once indication is available that an emergency action level has been exceeded, classification must be made as soon as possible and must not exceed 15 minutes. Once a classification has been declared, notification must be initiated and in progress to the State and County agencies within 15 minutes of event classification using "Event Notice," Form EPIPF-AD-07-01.

During the initial 15-minute classification assessment, there may be rapidly changing conditions. Classification during this initial period should be based on currently available plant status.

3.2 The SM should remain in the Control Room during a declared emergency.

3.3 The following responsibilities of the ED shall NOT be delegated.

3.3.1 Determination of emergency classification (EPIP-AD-02).

3.3.2 Authorization of emergency exposures in excess of 10CFR Part 20 limits (EPIP-AD-1 1).

3.3.3 UNTIL the Emergency Response Manager assumes the responsibility following EOF activation, recommendations of protective actions to off-site authorities (EPIP-AD-19).

j:\appdata~procpws\draft\epip\eadO3.doc-Amy Kudick/Dori Ziegler--Jeanne Ferris REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 Rev. AI Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant Emer ency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 29 3.4 The ED should carefully consider the status of activities (especially those identified in Step 3.3 above) when electing to locate to the TSC. Locating to the TSC prior to TSC activation should be carefully considered.

3.5 IF an event or condition may have existed which exceeded an EAL criteria but no emergency was declared AND the basis for the emergency classification no longer exists at the time of this discovery, NO classification should be made. This is because the conditions for the classification no longer exist.

An ENS notification (or an ENS update if the event was previously reported but misclassified) shall be provided to the NRC within one hour of the discovery of the undeclared (or misclassified) event. Emergency Preparedness shall be notified of the undeclared or misclassified event. Emergency Preparedness shall provide an update to the State and Counties concerning the event.

4.0 Initial Conditions 4.1 This procedure shall be implemented upon declaration of an Unusual Event.

5.0 Procedure 5.1 SMVED shall take the following Initial Actions:

5.1.1 IF a credible security threat (Lo) exists, THEN go to EPIP-AD-20, "KNPP Response to a Security Threat" (Reference Operations Procedure E-0-08).

5.1.2 Contact the Shift Technical Advisor (STA) and direct them to report to the Control Room.

Note Assembly is conducted at the discretion of the SM/ED for an UnusualEvent.

5.1.3 Determine if personnel assembly is needed based on the nature of the event and their judgment of threat to plant staff safety.

5.1.4 IF assembly could present an unacceptable risk to plant employees as a result of a security event, THEN do NOT initiate assembly.

(Reference Operations Procedure E-0-08).

REFERENCE USE

Title KNPP Response to an Unusual Event WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 I Rev. Al

- :;; - KNPP Response to an Unusual Event

~~~~~~~~Title Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 29 5.1.5 Determine the level of the ERO support needed:

[] CREDIBLE SECURITY THREAT - UNUSUAL EVENT Pager access code "9244" AND "9255" Pager message code "44666"

[Envelope D]

El CREDIBLE SECURITY THREAT - ALERT Pager access code "9244" AND "9255" Pager message code "44777"

[Envelope E]

El UNUSUAL EVENT (Directors and Select Staff) - No activation of ERFs Pager access code "9211" AND "9222" Pager message code "66666"

[Envelope F]

5.1.6 Contact Secondary Alarm Station (SAS):

a. Direct activation of ERO pagers with selected pager access code and pager message code per Step 5.1.5.

5.1.7 Choose and perform the appropriate plant announcement using plant Gai-tronics.

a. Prepare your Gai-tronics message by making the choices identified in the appropriate box below.

b. IF assembly is NOT required, read aloud two (2) times over the Gai-tronics the message below.

"Attention all personnel. We are experiencing an Unusual Event. Designated emergency response directors should report to their duty locations. No additional response is required at this time."

Choose (1) or (2)

(1) No personnel protective actions are required at this time.

(2) Personnel should avoid the (plant area) because of (type hazard)

REFERENCE USE

SEVC WISCONSIN- OP PULI o PI-D0 e.A WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 I Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 I Page 4 of 29

c. IF assembly is required, THEN:

• Sound the plant siren.

• Read aloud two (2) times on the Gai-tronics the message below.

"Attention all personnel. We are experiencing an Unusual Event. Designated emergency response directors should report to their duty locations. All other personnel should report to the nearest assembly area."

Choose (1) or (2)

(1) No additional personnel protective actions are required at this time.

(2) Personnel should avoid the (plant area) because of (type hazard) 5.1.8 Complete the "Event Notice," Form EPIPF-AD-07-01.

a. WHEN completing Box 8, get the downwind sector by using Table 1 on the back of the form.

b. WHEN completing Box 10, check the following item:

• (A) None 5.1.9 Direct the Notifier or ERF Communicator-CR to initiate notifications per EPIP-AD-07, Attachment A, using the "Event Notice," Form EPIPF-AD-07-01, completed in Step 5.1.8.

5.1.10 Direct the STA to notify the NRC in accordance with Step 5.5.3 of this procedure.

5.1.11 Review "State Call-Back - Question Guideline," Form EPIPF-AD-07-02, to prepare for questions which are most likely to be asked by State Duty Officer or State Radiological Coordinator.

5.1.12 Log all significant events and actions.

5.1.13 Update facility directors as needed including such information as:

• Current Emergency Classification

• Conclusions that led to the current classification

• Conditions that may be improving or declining

• Potential changes in status and possible classification changes REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPEP-AD-03 I Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 5 of 29 Note Refer to Attachment A of this procedurefor "Turnover Briefing Worksheet Control Room to Emergency Director/ERM."

5.1.14 UNTIL relieved by a designated ED, continue to make assessments of plant conditions and perform the required actions of the ED (Section 5.2 of this procedure). Go to Step 5.2.7.

5.2 Emergency Director (Designated) shall:

5.2.1 WHEN notified that an Emergency has been declared:

a. Report to the Control Room or TSC.

b. IF an Emergency Director has been designated, UNTIL released, THEN assist the designated Emergency Director.

c. IF an Emergency Director has NOT been designated, THEN notify the Shift Manager of your intent to assume the responsibilities of the Emergency Director and continue implementation of this procedure.

5.2.2 WHEN appropriate, accept a briefing from the Shift Manager and STA. Key points listed below:

a. - Classification chart used to determine emergency level.

b. _ Protective Action Recommendation in effect.

c. Status of off-site and KNPP notifications.

d. Status of plant accountability.

e. _ Status of plant operation.

f. Control Room support priorities.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 IRev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant I Emergency PlanImplementing Procedure Date JUL 31 2003 Page 6 of 29 Note Verbally inform the Shift Manager that you have acceptedthe ED responsibilities.

5.2.3 Accept formal turnover of responsibilities (for ED) from SM to include:

• Direction and supervision of emergency response operations

• Approval of changes in emergency classifications

• Review and approval of all exposures in excess of 10 CFER Part 20 limits

• PARs (unless transferred to the ERM)

• Protective actions for plant personnel

• Continuous accident assessment 5.2.4 Notify other directors and Control Room staff of the transfer of the ED responsibility to you and your location.

5.2.5 Ensure date and time is entered in the Control Room Chronological Log of Events for turnover of responsibilities for ED from SM.

5.2.6 When appropriate:

a. Locate to the Technical Support Center (TSC).

b. Direct TSC Support Personnel to enter date and time of arrival in TSC chronological log.

5.2.7 Ensure the overall emergency level is continually reviewed.

a. _ Event Classification (EPIP-AD-02)

b. . PAR (EPIP-AD-19)

c. _ Emergency radiological exposures (EPIP-AD-1 1) 5.2.8 IF plant conditions degrade to where the declaration of a higher emergency level (escalation) is warranted, THEN suspend further use of this procedure and go to EPIP-AD-04 Step 5.2.7.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 I Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant 1 Emergency Plan Implementing Procedure Date JUL 31 2003 Page 7 of 29 5.2.9 Determine the response status with an information gathering briefing. Include the following emergency response organization directors.

a. Event Operations Director (EOD):

• Off-Site Notifications (EPIP-AD-07)

• Plant Operations Status

• Control Room support priorities

b. _ Radiological Protection Director (RPD):

• Status of Radiological Effluent Releases (potential off-site dose consequences)

• Emergency Radiation Controls (EPIP-AD-1 1) (actions taken in response to this procedure)

• Status of Personal Injuries or Vehicle Accidents

c. Technical Support Center Director (TSCD):

• Significant Plant Trends

• Emergency Response Status

d. Support Activities Director (SAD):

• Maintenance Activities

• Search and Rescue (EPIP-OSF-04)

• Maintenance Support Requirements

e. _ Site Protection Director (SPD):

• Personnel Accountability (EPIP-SEC-03)

• Significant Security Activities 5.2.10 Determine priorities of major tasks required to minimize the impact on the public and mitigate the incident. Weigh activities in the following areas:

• Operations

• Radiological

• Technical Support

• Maintenance

• Security 5.2.11 Inform Emergency Response Manager (ERM) of plant conditions and priorities.

REFERENCE USE

-~~~~~~~~~~~Tte KPPRsos oa nsa vn WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 I Rev. Al l : KNPP Response to an Unu sual Event

~~~~~~~~~~Title Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 8 of 29 5.2.12 WHEN appropriate, brief the emergency directors on plant conditions and priorities.

5.2.13 IF the ERM has not assumed the responsibility, THEN provide Plant Emergency status updates to off-site authorities.

a. IF off-site EOCs are activated, THEN use the Dial Select to contact off-site organizations.

b. IF off-site organization EOCs are NOT activated, WHEN those organizations initiate a request, provide status updates.

c. Use the "State Call-Back - Question Guideline," Form EPIPF-AD-07-02, or "Plant Emergency Status Report," Form EPIPF-EOF-08-05, and/or "Radiological Status Report," Form EPIPF-EOF-08-06, as information guides.

Note In fast breaking events, the ED may give verbal authorization insteadof written approval to release the statement.

d. Review and approve news statements prior to being released to the media.

5.2.14 Review the need for any Emergency Director Assistants.

5.2.15 IF plant conditions indicate the need to activate the full emergency response organization, THEN:

a. Direct SAS to activate pagers for all emergency response personnel (group code 9233), using Envelope A.

b. Notify all Directors of your decision to activate the full ERO.

c. Go to EPIP-AD-04 Step 5.2.4.

5.2.16 If appropriate, plan for a shift relief per EPIP-AD-05.

5.2.17 Review the requirements of Section 5.1 of "Recovery Planning and Termination,"

EPIP-AD-15, and determine if recovery or termination activities can be implemented in accordance with EPIP-AD-15.

5.2.18 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.2.5.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 9 of 29 5.2.19 WHEN Final Conditions (Section 6.0) are met:

a. Notify the Emergency Response Manager of the event termination or entry into recovery and the suspension of use of the EPIPs.

b. IF the event is an ENTRY INTO RECOVERY, THEN read aloud two (2) times on the Gai-tronics the message below.

"Attention all personnel. We have entered plant recovery operations. Review final conditions of all procedures and restore all emergency response materials and equipment to their proper location. Appropriate inventories should be performed and supplies replenished as needed. Use of EPIPs is suspended when all final actions have been completed to the satisfaction of the facility Director. The Recovery Manager is and the Environmental Liaison is ."

c. IF the event is an emergency class TERMINATION, THEN read aloud two (2) times on the Gai-tronics the message below.

"Attention all personnel. We have terminated the Emergency response.

Review final conditions of all procedures and restore all emergency response materials and equipment to their proper location. Appropriate inventories should be performed and supplies replenished as appropriate. Use of EPIPs is suspended when all final actions have been completed to the satisfaction of the facility Director."

d. Ensure that termination or recovery notifications have been initiated by the NRC communicator.

e. Verify that "Event Notice," Form EPIPF-AD-07-01, is being transmitted in accordance with EPIP-AD-07 or EPlP-EOF-08.

f. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to there proper place.

g. Collect all completed records, logs, forms, notes, and other documentation and give them to the TSCD.

h. Implement EPMP-02.01, "Declared Emergency Evaluation and Documentation."

5.3 The Notifier shall:

5.3.1 WHEN notified or upon hearing the Event announcement (except when a Security Event is in progress), report immediately to the SM in the Control Room.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 10 of 29 5.3.2 WHEN directed by the Emergency Director/Shift Manager, perform event notifications. Go to EPEP-AD-07.

5.3.3 IF plant conditions degrade to where the declaration of a higher emergency level (escalation) is warranted, THEN suspend further use of this procedure and go to EPIP-AD-04 Step 5.3.2.

5.3.4 IF an Emergency Response Facility (ERF) Communicator-Control Room (CR) is not available, THEN assume the role of the ERF Communicator-CR and go to Step 5.4.4.

5.3.5 UNTIL released, remain in the Control Room and help the designated ERF Communicator-CR.

5.3.6 WHEN released, report back to the Shift Captain.

5.4 Emergency Response Facility (ERF) Communicator-Control Room (CR) shall:

5.4.1 WHEN directly notified, paged by radio-pager, or hearing the event announcement:

a. Report to the Control Room immediately.

b. IF an ERF Communicator-CR has been designated, UNTIL released, THEN assist the ERF Communicator-CR as instructed.

c. IF an ERF Communicator-CR has NOT been designated, THEN assume the responsibilities of the ERF Communicator-CR and continue to implement this procedure.

5.4.2 Notify the SM/ED of your arrival and assumption of the ERF Communicator-CR duties.

5.4.3 If applicable, obtain the status of notifications and verifications call backs from the Notifier.

5.4.4 IF there is an event *DECLARATION, *TERMINATION, or -ENTRY INTO RECOVERY, and directed by the SM/ED, THEN go to EPIP-AD-07 or EPIP-EOF-08 and make the appropriate event notifications.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 I Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 11 of 29 Note Off-Site and other needed ERO or ERF communications shall be completed before providing supportfor NRC communicationsunless there is more than one ERF Communicator-CR available.

5.4.5 Contact the Event Operations Director (EOD), ask them to determine if the Technical Support Center, Emergency Operations Facility, and Joint Public Information Center want to assign a person in their facilities to man the 4-way communications link with the Control Room.

a. IF yes, ask the EOD to remind the other facilities that they can enter the 4-way communications link by using the telephone number and access code provided in the KPB Emergency Telephone Directory ETD-03, "Emergency Response Facilities Telephone List," THEN enter the 4-Way Communication Link.

b. IF no, THEN make yourself available to support the ED, EOD, or STA.

5.4.6 IF requested by the STA, THEN provide communications support with the NRC.

Note IF there is an event escalation, THEN immediately return supportfor NRC communications back to the STA or the individual assignedby the SM/ED or EOD unless there is more than one ERF Communicator-CR available.

5.4.7 IF plant conditions degrade to where the declaration of a higher emergency level (escalation) is warranted, THEN suspend further use of this procedure and go to EPIP-AD-04 Step 5.4.4.

5.4.8 Review the need for the Notifier and assistant communicators support.

5.4.9 IF additional communicator support is needed, THEN contact the Technical Support Center Director.

5.4.10 If appropriate, plan for a shift relief per EPIP-AD-05.

5.4.11 Notify the EOD of any significant events.

5.4.12 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.4.4.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPEP-AD-03 I Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant Emergency PlanImplementing Procedure f Date JUL 31 2003 Page 12f29 5.4.13 WHEN Final Conditions (Section 6.0) are met:

a. Ensure that termination or recovery communications have been completed in accordance with Step 5.4.6.

b. Verify that the bell switch on the emergency government verification line is in the ON position.

c. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to their proper places.

d. Collect all completed records, logs, forms, notes, and other documentation and give them to the EOD.

5.5 Shift Technical Advisor shall:

Note The Shift TechnicalAdvisor shall be capable of respondingto the Control Room within 10 minutes.

5.5.1 Report to the Control Room to be briefed on plant conditions.

5.5.2 Assist the Shift Manager in assessing plant conditions and determining emergency classification as defined in EPIP-AD-02, "Emergency Class Determination."

Note IF all off-site and ERO notificationsare complete, THEN NRC notifications may be delegatedto an extra ERF Communicator-CR.

5.5.3 Perform NRC Notification:

a. Gather information needed to prepare the NRC "Event Notification Worksheet," Form GNP-1 1.04.04-1.

Note If needed, the commercial telephone number is (301) 951-0550.

b. Notify the NRC (Headquarters, Rockville) as soon as possible, but not more than one hour after declaration of the Event, using the Emergency Notification System (ENS) phone.

Note The NRC may request continuous communicationsper 10CFR50.72(c)(3).

The STA must coordinatethis activity with accident assessment until arrival of sufficient ERF Communicator-CR.

c. Provide the NRC with the necessary information from a completed Event Notification Worksheet.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 I Rev. Al Kelaunee Nuclear Power :Title P.at KNPP Response to an Unusual Event l - Kewaunee Nuclear Power Plant 1 Emergency Plan Implementing Procedure Date JUL 31 2003 Page 13 of 29 5.5.4 WfHEN the ERF Communicator-CR (ERFCM-CR) arrives and plant status and other activities are at a point that it is appropriate, turn NRC communications over to the ERFCM-CR by taking the following actions:

a. Brief the ERFCM-CR on plant conditions, the status of NRC notification and updates.

b. Inform the ERFCM-CR that you are turning over responsibility for NRC communications to them.

5.5.5 Support the Control Room staff with technical and analytical assistance in diagnosing abnormal events and to ensure adequate core cooling.

5.5.6 Monitor plant conditions and provide assistance as needed to the Shift Manager.

5.5.7 IF plant conditions degrade to where the declaration of a higher emergency level (escalation) is warranted, THEN suspend further use of this procedure and go to EPIP-AD-04 Step 5.6.5.

5.5.8 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.5.5.

5.5.9 WHEN Final Conditions (Section 6.0) are met:

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to their proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the EOD.

5.6 Event Operations Director (EOD) shall:

5.6.1 WHEN notified that an Emergency has been declared:

a. Report to the Control Room.

b. IF an Event Operations Director has been designated, UNTIL released, THEN assist the designated Event Operations Director.

c. IF an Event Operations Director has NOT been designated, THEN notify the Shift Manager of your intent to assume the responsibilities of the Event Operations Director and continue implementation of this procedure.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 I Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant Emergency PlanImplementing Procedure Date JUL 31 2003 Page 14 of 29 Note Verbally inform the Shift Manager that you have accepted the EOD responsibilities.

5.6.2 Accept formal turnover of responsibilities (for EOD) from SM to include:

• TSC and EOF communications

• Maintaining verification of accountability

• Staffing of Control Room

• Processing work requests

• Monitoring fire fighting operations and maintaining accountability of fire team

• Obtaining additional assistance from Emergency Response Organization

• Monitoring and support of plant operations 5.6.3 Notify the SM/ED of your arrival and assumption of Event Operations Director responsibilities.

5.6.4 Ensure date and time is entered in the Control Room Chronological Log of Events for turnover of responsibilities for EOD from SM.

5.6.5 WHEN appropriate, accept a briefing from the Shift Manager and STA.

5.6.6 If required, verify Control Room personnel accountability is being maintained.

5.6.7 Review Control Room staffing requirements and:

a. Contact additional operations personnel as needed and request that they report to the site (See KPB Emergency Telephone Directory for names and numbers).

b. Release any personnel not required.

5.6.8 Assess overall plant status.

• Verify equipment status and instrument indications.

• Verify Radiation monitors for abnormal indications.

• Review corrective actions that have been taken.

5.6.9 Make any recommendations to the Shift Manager as necessary.

REFERENCE USE

5.6.10 Brief the Emergency Director of any changes on:

• Off-Site Notifications (EPIP-AD-07)

• Plant Operations Status

• Control Room support priorities 5.6.11 Inform the RPD of any changes in radiological indications.

5.6.12 If required, request technical or maintenance support from the ED.

5.6.13 Prepare all work requests (WR) for approval.

a. Review WR and designate retest requirements.

b. If required to do the job, determine and initiate system lineups and tagouts.

5.6.14 Brief the Control Room staff periodically on:

• Emergency response status

• Priorities

• Specific guidance and assignments 5.6.15 If appropriate, plan for shift relief per EPIP-AD-05.

5.6.16 IF plant conditions degrade to where the declaration of a higher emergency level (escalation) is warranted, TIEN suspend further use of this procedure and go to EPIP-AD-04 Step 5.7.5.

5.6.17 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.6.4.

5.6.18 WHEN Final Conditions (Section 6.0) are met:

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to their proper place.

b. Collect all completed records and logs from all documents generated during the course of the event.

c. Schedule a self critique with all CR event participants (all shifts) as soon as practical.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 I Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 16 of 29 5.7 Radiological Protection Director (RPD) shall:

5.7.1 WHEN notified that an Emergency has been declared:

a. Report to the Radiation Protection Office (RPO).

b. IF a Radiation Protection Director has been designated, UNTIL released, THEN assist the designated RPD.

c. IF a Radiation Protection Director has NOT been designated, THEN assume the responsibilities of the RPD and continue implementing this procedure.

5.7.2 Notify the ED/TSCD of your arrival in the RPO and assumption of RPD responsibilities.

5.7.3 If required, verify personnel accountability in RPO is being maintained.

5.7.4 If required, assist the SAD in search and rescue operations (EPIP-OSF-04).

5.7.5 Check radiological and meteorological information available in the TSC.

5.7.6 If needed, request additional Area and Process radiation monitor information from the Event Operations Director.

5.7.7 Verify that emergency radiation controls are being implemented (EPIP-AD-1 1).

5.7.8 If required, assist the SPD with Personnel Evacuation, (EPIP-SEC-05).

Note Transportationof a contaminatedinjuredperson shall be to the Aurora Medical Center and a Radiation Technologist should be dispatchedto the hospital.

Note IF there is a question as to the extent of injuries, THEN it should be treatedas a critical injury.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPEP-AD-03 I Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant I Emergency Plan Implementing Procedure Date JUL 31 2003 Page 17 of 29 Note Off-Site Support Agencies and theirphone numbers are listed in the KPB Emergency Telephone Directory, ETD 02, "Off-Site Agency Call List".

5.7.9 IF there are injuries or vehicle accidents associated with plant personnel or contractors, THEN contact the appropriate support.

a. IF the injury is a "Medical Attention (Critical) Injury," see NAD-02.09 for definition of critical injuries, a vehicle accident with injuries, THEN:

1. Contact the County Sheriffs office with jurisdiction at the location of the injury(s). (Kewaunee County has jurisdiction on the KNPP site.)

• Kewaunee County Dispatch - 911

• Manitowoc County Dispatch - 920-683-4200

2. Notify the dispatcher of the accident and/or injury and request a rescue squad (all critically injured personnel shall be transported by rescue squad).

3. Provide the dispatcher with the following information:

• Your name, position, and return telephone number.

• The location of the accident and when it occurred.

• How many and how the injury(s) occurred.

• Nature and extent of injuries and condition of the patient(s).

• If any, extent of radioactive contamination and instructions that transportation of a potentially contaminated injured person shall be to the Aurora Medical Center.

• Plant name, location.

• If required, plant access instructions.

4. If the injury is on-site:

• Inform the SPD of your request for a rescue squad and its estimated time of arrival.

• Direct the SPD to have the vehicle driven to the proper plant entrance.

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[WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 Rev. AI K- waunee Nuilear Power Plant Title KNPP Response to an Unusual Event 0 Kewaunee Nuclear Power Plant  :

l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 18 of 29

5. IF the accident potentially involves radioactive contamination, THEN:

• Dispatch a Radiation technologist to the accident site for contamination control.

• Dispatch a Radiation Technologist to the Aurora Medical Center to assist the hospital staff.

6. Insure that the requirements for "Injury/Illness Response," NAD-02.09, are implemented.

7. Inform the Emergency Director, Emergency Response Manager, and the Plant Spokesperson of the accident and details of the injuries.

b. IF the Injury is a "Medical Attention (Non-critical) Injury," THEN:

Note Any KNPP or contractorvehicle may be usedfor transportof (non-critical)injuredpersonnel.

1. Arrange for transportation of the injured person.

2. Direct the SPD to have the vehicle driven to the proper plant entrance.

3. Contact the hospital or clinic and provide the following information:

• Your name, position, and return telephone number.

• When, how many, and how the injury(s) occurred.

• Nature of injuries and condition of the patient.

• If any, extent of radioactive contamination.

• Plant name, location, and access instructions.

• Estimated time of arrival for the patient(s) at the hospital or clinic.

4. IF there are contaminated injuries, THEN send a Radiation Technologist to the Aurora Medical Center to assist the hospital staff.

5. Insure that the requirements for "Injury/Illness Response," NAD-02.09, are implemented.

6. Inform the Emergency Director, Emergency Response Manager, and the Plant Spokesperson of the accident and details of the injuries.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 19 of 29 5.7.10 Brief the Emergency Director of plant radiological conditions.

• Status of Radiological Effluent Releases (potential off-site dose consequences).

• Emergency Radiation Controls (EPIP-AD-1 1) (actions taken in response to this procedure).

• Status of Personal Injuries or Vehicle Accidents.

5.7.11 Review the personnel requirements in the RPO/RAF and:

a. As needed, contact Radiation Technologists to augment the on-shift personnel.

b. Release any RPO staff not required.

5.7.12 If appropriate, coordinate with the ALD to establish contract support for long term accident support.

5.7.13 If appropriate, relocate to the TSC.

5.7.14 If appropriate, plan for a shift relief per EPIP-AD-05.

5.7.15 IF plant conditions degrade to where the declaration of a higher emergency level (escalation) is warranted, THEN suspend further use of this procedure and go to EPIP-AD-04 Step 5.8.5.

5.7.16 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.7.3.

5.7.17 WHEN Final Conditions (Section 6.0) are met:

a. Verify all work areas are returned to normal status and emergency procedures, forns, etc. are returned to there proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the TSCD.

c. Verify all samples collected have been cataloged and appropriately stored.

d. Schedule a self critique with all event participants in the RPO/RAF (all shifts) as soon as practical.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 20 of 29 5.8 Technical Support Center Director (TSCD) shall:

5.8.1 WHEN notified that an Emergency has been declared:

a. Report to the Technical Support Center (TSC).

b. IF a Technical Support Center Director has been designated, UNTIL released, THEN assist the designated TSCD.

c. IF a Technical Support Center Director has NOT been designated, THEN assume the responsibilities of the TSCD and continue implementing this procedure.

5.8.2 Notify the Emergency Director of your assumption of TSCD responsibilities.

5.8.3 Contact the Emergency Director and obtain information on plant status.

5.8.4 If required, verify accountability is being maintained in the TSC (EPIP-SEC-03).

5.8.5 Brief the Emergency Director on TSC activities:

• Significant Plant Trends

• Emergency Response Status 5.8.6 Ensure the TSC staff is informed of plant status and ED priorities.

5.8.7 Review TSC staffing requirements.

5.8.8 If appropriate, plan for a shift relief, per EPIP-AD-05.

5.8.9 IF plant conditions degrade to where the declaration of a higher emergency level (escalation) is warranted, THEN suspend further use of this procedure and go to EPIP-AD-04 Step 5.9.5.

5.8.10 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.8.4.

5.8.11 WHEN Final Conditions (Section 6.0) are met:

a. Ensure TSC and OSF are deactivated per "Technical Support Center Activation," EPIP-TSC-02.

b. Collect all records and logs from all documents generated during the course of the event.

c. Schedule a self critique with all event participants in the TSC (all shifts) as soon as practical.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPEP-AD-03 I Rev. Al Title KNPP Response to an Unusual Event I -

Kewaunee Nuclear Power Plant l Emergency PlanImplementing Procedure Date JUL 31 2003 Page 21 of 29 5.9 Support Activities Director (SAD) shall:

5.9.1 WHEN notified that an Emergency has been declared:

a. Report to the Technical Support Center (TSC).

b. IF a Support Activities Director has been designated, UNTIL released, THEN assist the designated SAD.

c. IF a Support Activities Director has NOT been designated, THEN assume the responsibilities of the SAD and continue implementing this procedure.

5.9.2 Notify the Emergency Director of your assumption of SAD responsibilities and obtain information on plant status and immediate actions.

5.9.3 If needed, direct search and rescue operations (EPIP-OSF-04).

5.9.4 Direct emergency maintenance activities in accordance with the priorities established by the Emergency Director.

5.9.5 Review the maintenance staffing requirements to mitigate the incident.

5.9.6 Brief the Emergency Director on OSF activities:

• Maintenance Activities

• Search and Rescue (EPIP-OSF-04)

• Maintenance Support Requirements 5.9.7 If appropriate, plan for a shift relief per EPEP-AD-05.

5.9.8 IF plant conditions degrade to where the declaration of a higher emergency level (escalation) is warranted, THEN suspend further use of this procedure and go to EPIP-AD-04 Step 5.10.6.

5.9.9 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.9.3.

5.9.10 WHEN Final Conditions (Section 6.0) are met:

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to their proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the TSCD.

c. Schedule a self critique with all event participants in the OSF (all shifts) as soon as practical.

REFERENCE USE

7 I

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant L Emergency Plan Implemenfing Procedure Date JUL 31 2003 Page 22 of 29 5.10 Site Protection Director (SPD) shall:

5.10.1 WHEN notified that an Emergency has been declared:

a. Report to the Security Building.

b. IF a Site Protection Director has been designated, UNTIL released, THEN assist the designated SPD.

c. IF a Site Protection Director has NOT been designated, THEN assume the responsibilities of the SPD and continue implementing this procedure.

5.10.2 Notify the ED/TSCD of your arrival in the Security Building and assumption of the SPD responsibility.

5.10.3 Direct the implementation "Security Force Response to Emergencies," EPIP-SEC-02.

5.10.4 If required, establish "Personnel Assembly and Accountability," EPIP-SEC-03.

5.10.5 IF Search and Rescue is required due to accountability results, THEN notify the Support Activities Director.

5.10.6 If appropriate, relocate to the TSC.

5.10.7 Obtain information from the RPD or the Control Room concerning fire, chemical, or radiological hazards present within the protected area.

5.10.8 IF hazards identified by the RPD or the Control Room warrant it, THEN restrict personnel movement.

5.10.9 IF directed by the ED, THEN initiate a plant evacuation (EPIP-SEC-05).

5.10.10 Brief the Emergency Director on security activities:

• Removal of visitors from site (i.e., fishermen) (EPIP-SEC-02)

• Personnel Accountability (EPIP-SEC-03)

• Access Control

• Significant Security Activities 5.10.11 Ensure that the Security Force and staff are informed of any significant issues relative to their activities.

5.10.12 If required, ensure accountability is maintained (EPIP-SEC-03).

5.10.13 Review security staffing requirements and make appropriate adjustments.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPEP-AD-03 I Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant Emerrency Plan Implementinr Procedure Date JUL 31 2003 I Page 23 of 29 5.10.14 If appropriate, plan for a shift relief per EPIP-AD-05.

5.10.15 IF plant conditions degrade to where the declaration of a higher emergency level (escalation) is warranted, THEN suspend further use of this procedure and go to EPIP-AD-04 Step 5.11.7.

5.10.16 IF Final Conditions (Section 6.0) are NOT met, THEN go to Step 5.10.7.

5.10.17 WHEN Final Conditions (Section 6.0) are met:

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to there proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the TSCD.

c. Schedule a self critique with all event participants in Security (all shifts) as soon as practical.

6.0 Final Conditions 6.1 Plant Emergency has been Terminated or Recovery actions have begun and the responsible director has suspended the use of EPIPs.

7.0 References 7.1 Kewaunee Nuclear Power Plant Emergency Plan 7.2 COMTRAK 87-152, Downgrading of EALs 7.3 COMTRAK 88-068, Calling in Additional Communicators as Required 7.4 NRC Inspection Report K-87-195, same as Step 7.2 7.5 10CFR50.72(c)(3), Maintaining Open Communications with the NRC 7.6 NAD-02.09, Injury/Illness Response 7.7 EPIP-AD-02, Emergency Class Determination 7.8 EPIP-AD-04, KNPP Response to Alert or Higher 7.9 EPIP-AD-05, Emergency Response Organization Shift Relief Guideline 7.10 EPIP-AD-07, Initial Emergency Notifications N.- 7.11 EPIP-AD-1 1, Emergency Radiation Controls REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-03 Rev. Al Title KNPP Response to an Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 24 of 29 7.12 EPIP-AD-15, Recovery Planning and Termination 7.13 EPIP-AD-19, Protective Action Guidelines 7.14 EPIP-AD-20, KNPP Response to a Security Threat 7.15 EPIP-EOF-08, Continuing Emergency Notifications 7.16 EPIP-OSF-04, Search and Rescue 7.17 EPIP-SEC-02, Security Force Response to Emergencies 7.18 EPLP-SEC-03, Personnel Assembly and Accountability 7.19 EPIP-SEC-05, Personnel Evacuation 7.20 EPIP-TSC-02, Technical Support Center Activation 7.21 KPB Emergency Telephone Directory 7.22 EPMP-02.01, Declared Emergency Evaluation and Documentation 7.23 Form GNP-1 1.04.04-1, Event Notification Worksheet 7.24 Form EPIPF-AD-07-01, Event Notice 7.25 Form EPIPF-AD-07-02, State Call-Back - Question Guideline 7.26 Form EPIPF-AD-07-03, Fax Event Notice 7.27 Form EPIPF-AD-07-04, ERO Event Notification 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• Event Notice, Form EPIPF-AD-07-01

• Event Notification Worksheet, Form GNP-1 1.04.04-1 8.1.2 Non-OA Records None REFERENCE USE

TURNOVER BRIEFING WORKSHEET CONTROL ROOM TO EMERGENCY DIRECTOR/ERM

"~ Note: All blanks are not required to be completed.

A. Emergency Classification Status (circle): Unusual Event Alert Site Area Emergency General Emergency

1. Initiating Events:

EAL Charts exceeded:

EAL Charts monitored for escalation:

2. Status of emergency procedure implementation and mitigating actions

"'-' B. Plant / Reactor Status (circle): S table Degrading Improving Safety System operation / problems:

1. Fission Product Barrier Fuel Cladding: Intact Potential Loss Lost Primary Coolant: Intact Potential Loss Lost Containment: Intact Potential Loss Lost Safety System Status:

2. Evolutions in progress Attachment A EPIP-AD-03 Rev. Al Date: JUL 31 2003 Page 25 of 29 REFERENCE USE

TURNOVER BRIEFING WORKSHEET CONTROL ROOM TO EMERGENCY DIRECTOR/ERM

3. Control Room Support Priorities for Maintenance or assistance needed:

4. Radiological conditions Release in progress (circle): YES NO C. On-site Protective Actions D. Off-site Protective Actions recommended (only for a General Emergency classification)

E. Off-site Assistance Requests F. Off-site Notifications Last Notification Time:

1. State & Counties:

2. NRC:

3. Others: (INPO, ANI etc.):.

Attachment A EPIP-AD-03 Rev. Al Date: JUL 31 2003 Page 26 of 29 REFERENCE USE

TURNOVER BRIEFING WORKSHEET CONTROL ROOM TO EMERGENCY DIRECTOR/ERM I- G. Status of ERO activation H. Status of Plant Accountability:

1. Status of outside agency mobilization Obtain a copy of all Event Notifications to State & Counties Attachment A LPFP-AD-U3 Rev. Al Date: JUL 31 2003 Page 27 of 29 REFERENCE USE

TURNOVER BRIEFING WORKSHEET CONTROL ROOM TO EMERGENCY DIRECTOR/ERM (HELP GUIDE)

A. Emergency Classification Status

1. Initiating Events and EALs exceeded:

• Cause, history, and initiating events leading to emergency declaration

• EALs exceeded

2. Status of Emergency Procedure Implementation and Mitigating Actions

• Status of progress in emergency procedures

• Corrective actions taken B. Plant/Reactor Status Condition / stability of reactor and plant conditions improving or declining

1. Fission Product Barrier and Safety System Status

• Fission Product Barrier Status (Fuel, RCS, Containment)

• Safety System alignments and status (flow rates, etc.)

2. Evolutions in Progress

• Control Room activities

• In plant activities (AOs, I&C, Mechanics)

3. Radiological Conditions

• Known in plant conditions

• Known releases and duration C. On-Site Protective Actions

• Existing personnel hazards

• Evacuations (local, site) and status of accountability or assembly

• KI Administration (status)

Attachment A EPIP-AD-03 Rev. Al Date: JUL 31 2003 Page 28 of 29 REFERENCE USE

TURNOVER BRIEFING WORKSHEET CONTROL ROOM TO EMERGENCY DIRECTOR/ERM (HELP GUIDE)

D. Off-Site Protective Actions

• Status of Dose Assessment activities

• PARs made to State/County Agencies E. Off-Site Assistance Request

• Fire, rescue squad, and law enforcement assistance requested F. Off-Site Notifications

• Status of notifications made to:

- State and Counties

- NRC

- INPO

- ANI

- Any others G. Status of ERO Activation

• Minimum staffing positions not reporting in to Automated Notification System

-H. Status of Plant Accountability

• Security actions taken

• Any missing individuals.

1. Status of Outside Agency Mobilization

• Any Reports that the State and Counties, NRC, etc., are activating

• Requests from State/Counties/NRC, etc.

• Time/Content of any News Releases J. Control Room Support Priorities for Maintenance or assistance needed

• Key work items to support the Control Room

• Equipment needed returned to service

• Additional assistance needed to meet Control Room needs Attachment A EPIP-AD-03 Rev. Al Date: JUL 31 2003 Page 29 of 29 REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 1 of 38 Reviewed By Jim Peterson Approved By Jerrie Morlino Nuclear 0 Yes PORC 0 Yes SRO Approval Of 0 Yes Safety Review Temporary Related 0 No Required El No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for the Shift Manager/Emergency Director and other initial response personnel for an appropriate response to an Alert, Site Emergency, or General Emergency.

2.0 General Notes 2.1 The Shift Manager (SM) is the initial Emergency Director (ED) in all situations. Any transfer of this responsibility shall be documented in the Shift Manager's log and communicated to all on-site directors.

2.2 As more information becomes available, initial protective action recommendations should be adjusted in accordance with plant conditions, dose projections, time available to evacuate, estimated evacuation times, and meteorological conditions (EPIP-AD-19, "Protective Action Guidelines").

2.3 IF approached by the media during a declared emergency, THEN refer them to the Joint Public Information Center (JPIC) at (920) 433-1400 or 1-800-838-6192 and tell them that this is their most accurate source for information.

3.0 Precautions and Limitations 3.1 Once indication is available that an emergency action level has been exceeded, classification must be made as soon as possible and must not exceed 15 minutes. Once a classification has been declared, notification must be initiated and in progress to the State and County agencies within 15 minutes of event classification using "Event Notice," Form EPIPF-AD-07-01.

During the initial 15-minute classification assessment, there may be rapidly changing conditions. Classification during this initial period should be based on currently available plant status.

3.2 The SM should remain in the Control Room during a declared emergency.

J:\appdata\procpws\draft\epip\eadO4.doc-Amy Kudick/Amy Kudick-Jeanne Ferris REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 38 3.3 The following responsibilities of the ED shall NOT be delegated:

3.3.1 Determination of emergency classification (EPIP-AD-02, "Emergency Class Determination").

3.3.2 Authorization of emergency exposures in excess of 10CFR Part 20 limits (EPIP-AD-1 1, "Emergency Radiation Controls").

3.3.3 UNTIL the Emergency Response Manager assumes the responsibility following EOF activation, recommendations of protective actions to off-site authorities (EPIP-AD-19).

3.4 Given plant conditions, the ED has the option of initially reporting to the TSC or Control Room to receive a turnover.

3.5 IF an event or condition may have existed which exceeded an EAL criteria but no emergency was declared AND the basis for the emergency classification no longer exists at the time of this discovery, THEN NO classification should be made. This is because the conditions for the classification no longer exist.

An ENS notification (or an ENS update if the event was previously reported but misclassified) shall be provided to the NRC within one hour of the discovery of the undeclared (or misclassified) event. Emergency Preparedness shall be notified of the undeclared or misclassified event. Emergency Preparedness shall provide an update to the State and Counties concerning the event.

4.0 Initial Conditions 4.1 This procedure shall be implemented upon declaration of an Alert, Site Emergency, General Emergency, or when directed by the Shift Manager or Emergency Director.

5.0 Procedure 5.1 SMIED shall take the following Initial Actions:

5.1.1 IF a security threat exists, THEN go to EPIP-AD-20, "KNPP Response to a Security Threat" (Reference Operations Procedure E-0-08).

5.1.2 Contact the Shift Technical Advisor (STA) and direct them to report to the Control Room.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 38 5.1.3 Determine the ERO response needed:

Ei ALERT - Activate ERO and Emergency Response Facilities (ERFs)

Pager access code "9233" Pager message code "77777"

[Envelope A]

Li SITE EMERGENCY - Activate ERO and Emergency Response Facilities (ERFs)

Pager access code "9233" Pager message code "88888"

[Envelope BI El GENERAL EMERGENCY - Activate ERO and Emergency Response Facilities (ERFs)

Pager access code "9233" Pager message code "99999"

[Envelope C]

[1 CREDIBLE SECURITY THREAT - UNUSUAL EVENT Pager access code "9244" AND "9255" Pager message code "44666"

[Envelope DI L] CREDIBLE SECURITY THREAT - ALERT Pager access code "9244" AND "9255" Pager message code "44777"

[Envelope E]

El UNUSUAL EVENT (Directors and Select Staff)

Pager access code "9211 " AND "9222" Pager message code "66666"

[Envelope F]

La TERMINATION OR RECOVERY Pager access code "9233" Pager message code "44444"

[Envelope G)

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 4 of 38 5.1.4 Contact Secondary Alarm Station (SAS):

a. Request a Notifier report to the Control Room immediately.

b. Direct activation of ERO pagers with selected pager access code and pager message code per Step 5.1.3.

c. Direct Security to initiate personnel assembly per EPIP-SEC-03, "Personnel Assembly and Accountability," unless assembly poses an unacceptable risk to plant employees.

d. Direct actions to be taken for EPIP-SEC-02, "Security Force Response to Emergencies."

• Verify on-site members of the general public are directed to leave site.

• Verify control measures for site access/egress are established.

5.1.5 IF assembly could present an unacceptable risk to plant employees as a result of a threat to plant staff safety or due to a security event, THEN do NOT initiate assembly.

Go to Step 5.1.7 (Reference Operations Procedure E-0-08).

5.1.6 Initiate personnel assembly.

a. Prepare your Gai-tronics message by making the choices identified in the box below in Step 5.1.5.c.

b. Sound the plant siren.

c. Read aloud two times on the Gai-tronics the message below.

"Attention all personnel. We are experiencing an (Choose One)

(Alert/Site Emergency/GeneralEmergency). Emergency response organization personnel should report to their duty locations. All other personnel should report to the nearest assembly area."

Choose (1) or (2)

(1) No additional personnel protective actions are required at this time.

(2) Personnel should avoid the (plant area) because of (type hazard)

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 l Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 5 of 38 Note Protective actionsfor the public are requiredfor a General Emergency only.

5.1.7 Complete the "Event Notice," Form EPIPF-AD-07-01.

Note Adverse meteorology exists if.

1. The 10 AND 60 meter wind speed is less than 5 mph, AND

2. Delta T is greaterthan +2.40 F OR Sigma Theta is less than 3.01 degrees.

(Refer to GraphicDisplay #52 from the PPCSterminal).

a. IF adverse meteorology does NOT exist, THEN complete Box 8 by getting the downwind sector(s) from Table 1 on the back of Form EPIPF-AD-07-01.

b. IF adverse meteorology does exist, THEN enter N/A in Box 8 and explain in Box 11.

c. IF the event is a General Emergency and adverse meteorology does NOT exist, WHEN completing Box 10, THEN enter the following items:

• (B) Evacuate ALL sectors out to 2 miles, AND Note To determine sectors in (B), include the downwind sector(s)from Table I on back of Form EPIPF-AD-07-01.

• (B) Evacuate downwind sectors out to 5 miles.

d. IF the event is a General Emergency and adverse meteorology exists, WHEN completing Box 10, THEN enter the following item:

• (B) Evacuate ALL sectors out to 5 miles.

e. IF the event is an Alert or Site Emergency, WHEN completing Box 10, THEN check the following item:

• (A) None 5.1.8 Direct the Notifier or ERF Communicator-CR to initiate notifications per Attachment A of EPIP-AD-07, "Initial Emergency Notifications," using the "Event Notice,"

Form EPIPF-AD-07-01, completed in Step 5.1.7.

5.1.9 Direct the STA to notify the NRC in accordance with Step 5.6.3 of this procedure.

5.1.10 Review "State Call-Back - Question Guideline," Form EPIPF-AD-07-02, to prepare for questions which are most likely to be asked by State Duty Officer or State Radiological Coordinator.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 6 of 38 5.1.11 Log all significant events and actions.

5.1.12 Verify Control Room Ventilation System operation.

5.1.13 Report any increase in Control Room radiation to the Radiological Protection Director (RPD) for habitability assessment.

5.1.14 Request support from Technical Support Center (TSC) or OSF staff as needed.

5.1.15 Update facility directors as needed including such information as:

• Current Emergency Classification

• Conclusions that led to the current classification

• Conditions that may be improving or declining

• Potential changes in status and possible classification changes Note Refer to Attachment A of this procedurefor "Turnover Briefing Worksheet Control Room to Emergency Director/ERM."

5.1.16 Until relieved by a designated ED, continue to make assessments of plant conditions and perform the required actions of the ED (Section 5.2 of this procedure) go to Step 5.2.9.

5.2 Emergency Director (Designated) shall:

5.2.1 WHEN notified that an Emergency has been declared:

a. Report to the Control Room or TSC.

b. IF an Emergency Director has been designated, THEN until released,

• If appropriate, plan a shift relief per EPIP-AD-05.

• Assist the designated Emergency Director.

c. IF an Emergency Director has NOT been designated, THEN notify the Shift Manager of your intent to assume the responsibilities of the Emergency Director and continue implementation of this procedure.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 7 of 38 5.2.2 When appropriate, accept a briefing from the Shift Manager and STA. Key points listed below:

a. Classification chart used to determine emergency level.

b. Protective Action Recommendation in effect.

c. Status of off-site and KNPP notifications.

d. Status of plant accountability.

e. Status of plant operation.

f. Control Room support priorities.

Note Verbally inform the Shift Manager that you have accepted the ED responsibilities.

5.2.3 Accept formal turnover of responsibilities (for ED) from SM to include:

• Direction and supervision of emergency response operations

• Approval of changes in emergency classifications

• Review and approval of all exposures in excess of 10 CFR Part 20 limits

• PARs (unless transferred to the ERM)

• Protective actions for plant personnel

• Continuous accident assessment 5.2.4 Notify other directors and Control Room staff of the transfer of the ED responsibility to you and your location.

5.2.5 Ensure date and time is entered in the Control Room Chronological Log of Events for turnover of responsibilities for ED from SM.

5.2.6 When appropriate:

a. Locate to the Technical Support Center (TSC).

b. Direct TSC Support Personnel to enter date and time of arrival in TSC chronological log.

5.2.7 If appropriate, direct the Offsite Communicator in the TSC to take responsibility for off-site notifications from the Control Room.

5.2.8 Brief the TSC staff on the plant conditions.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 8 of 38 5.2.9 Ensure the overall emergency level is continually reviewed.

a. Event Classification (EPIP-AD-02)

b. __ PAR (EPIP-AD-19)

c. Emergency Radiological Exposures (EPIP-AD-1 1)

Warning It is NOT requiredto de-escalatefrom an Emergency Action Level.

Termination or direct entry into recovery is preferable. However, there may be occasions when it is more appropriateto de-escalate.

EPIP-AD-02 and other EPIPsare NOT written to facilitatede-escalation.

Therefore, any decision to de-escalate instead of entering recovery must be based on a thorough review of EPIP-AD-02 and careful use of appropriate procedures.

5.2.10 IF plant conditions have met the conditions for escalating or de-escalating the emergency classification (EPIP-AD-02), document the time and emergency level being declared, THEN:

a. IF assembly could present an unacceptable risk to plant employees as a result of a Security Event, THEN do NOT initiate assembly.

Go to Step 5.2.10(d).

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 I Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 9 of 38

b. IF accountability has NOT already been completed, THEN:

1. Direct a Control Room staff member to sound the plant siren.

2. WHEN the plant siren has been sounded, read aloud two times on the Gai-tronics the message below:

"Attention all personnel. We have (Choose One) escalated/de-escalat ed from (Choose One) (Unusual Event/Alert/Site Emergency/General Emergency) to (Choose One) ((Unusual Event/Alert/Site Emergency/Gei7eral Emergency). Designated emergency response directors should take appropriate action.

Emergency Personnel shall report to their emergency duty station. Sall other personnel should report to the nearest assembly area."

Choose (1) or (2)

(1) No additional personnel protective actions are required at this time.

(2) Personnel should avoid the (plant area) because of (type hazard)

c. IF personnel assembly has been completed, THEN:

1. Direct a Control Room staff member to sound the plant siren.

2. When the plant siren has been sounded, read aloud two (2) times on the Gai-tronics the message below:

"Attention all personnel. We have (Choose One) escalated/de-escalated from (Choose One) (Unusual Event/Alert/Site Emergency/General Emergency) to (Choose One) (Unusual Event/Alert/Site Emergency/General Emergency). Designated emergency response directors should take appropriate action."

Choose (1) or (2)

(1) No additional personnel protective actions are required at this time.

(2) Personnel should avoid the (plant area) because of (type hazard)

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 10 of 38

d. IF the EOF has NOT accepted responsibility for off-site notifications and PARs, THEN:

Note Protective actionsfor the public are requiredfora General Emergency only.

1. Review current and potential protective action recommendations (EPIP-AD- 19).

2. IF time permits, THEN contact off-site authorities via the Dial-Select to discuss pending changes in classification and/or appropriate PAR.

3. Initiate revised event classifications and/or PAR on "Event Notice,"

Form EPIPF-AD-07-01.

4. Review and sign all "Event Notice," Form EPIPF-AD-07-01, that are generated from the CR/TSC.

5. Forward approved "Event Notice," Form EPIPF-AD-07-01, to the Offsite Communicator for transmission to off-site agencies.

6. For initial classification, direct SAS to activate pagers for all emergency response personnel (group code 9233) using Envelope A.

7. Verify that required state and county notifications are made (EPIP-AD-07 or EPIP-EOF-08, "Continuing Emergency Notifications").

e. IF the EOF has taken responsibility for off-site notifications and PARs, THEN ensure the ERM is notified of the emergency level escalation and the time it was declared.

f. Direct the Shift Technical Advisor to notify the NRC in accordance with Step 5.6.3 of this procedure.

5.2.11 Determine the response status with an information collection brief. Include the following emergency response organization Directors:

a. Event Operations Director (EOD):

• Off-site Notifications (EPIP-AD-07)

• Plant Operations Status

• Control Room support priorities

b. Radiological Protection Director (RPD):

• Status of Radiological Effluent Releases (potential off-site dose consequences)

• Off-site Dose Assessment Evaluation

• Emergency Radiation Controls (EPIP-AD-1 1) (actions taken in response to this procedure)

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EP1P-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 11 of 38

• Status of Personal Injuries or Vehicle Accidents

• Availability of Potassium Iodide (EPIP-AD-18, "Potassium Iodide Distribution")

• Status of plant conditions that could warrant evacuation of non-essential plant personnel

c. Technical Support Center Director (TSCD):

• TSC Activation and Operational Status (EPIP-TSC-02, Technical Support Center Activation")

• Significant Plant Trends

• "Core Damage Assessment" (EPIP-TSC-09A, "Core Damage Assessment")

d. Support Activities Director (SAD):

• OSF Activation and operational status

• OSF Facility Operations (EPIP-OSF-02, "Operational Support Facility Operations")

• Maintenance Activities

• "Search and Rescue" (EPIP-OSF-04, "Search and Rescue")

e. Site Protection Director (SPD):

• Removal of Visitors from site (i.e., fishermen) (EPIP-SEC-02)

• Personnel Accountability (EPIP-SEC-03)

• Access Control

• Significant Security Activities

f. _ _ Severe Accident Management Team Leader (SAMTL):

• SAM Team Status

• Severe Challenge Status

• Strategies Implemented

• Strategies being Evaluated

• New Strategy Recommendations REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 12 of 38 Note Once facility information has been gathered, conduct briefings among ERFs (TSC, EOF, CR). These briefings should be conducted as conditions warrant, or at least hourly, preferably by DAROME. (If the DAROME is not functional, the communication bridge or phone can be used).

5.2.12 Determine priorities of major tasks required to minimize the impact on the public and mitigate the incident. Weigh activities in the following areas:

• Operations

• Radiological

• Technical Support

• Maintenance

• Security 5.2.13 Inform Emergency Response Manager (ERM) of:

• Status of the plant.

• On-site or off-site radiological releases or potential releases.

• Priorities of tasks to minimize the impact to the public.

• Incidents of public interest (i.e., fires, spills, personnel contaminations, and personnel injuries).

5.2.14 When appropriate, brief the Emergency Response Organization on plant conditions and priorities. Give specific guidance and assignments considering the following:

a. If required, direct evacuation of non-essential personnel from the plant.

• Direct the SPD to initiate a plant evacuation.

• Direct the RPD to assist the SPD in the plant evacuation.

• Contact the Manitowoc and Kewaunee County Emergency Directors and the ERM to coordinate the evacuation (may use Dial Select).

• The SPD implements and coordinates instructions.

• Update the Manitowoc and Kewaunee County Emergency Directors and the ERM on the status of the evacuation (may use Dial Select).

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency PlanImplementing Procedure [Date JUL 31 2003 Page 13 of 38

b. If appropriate, instruct the data coordinator to initiate plant parameter trends on the following:

• Safety Assessment System

• Digital Display (#3)

• PPCS Trend Recorders 5.2.15 IF the ERM has NOT assumed the responsibility, THEN provide Plant Emergency status updates to off-site authorities.

a. IF off-site EOCs are activated, THEN use the Dial Select to contact off-site organizations.

b. IF off-site organization EOCs are NOT activated, WHEN those organizations initiate a request, THEN provide status updates.

c. Use the "State Call-Back - Question Guideline," Form EPIPF-AD-07-02, or "Plant Emergency Status Report," Form EPIPF-EOF-08-05, and/or "Radiological Status Report," Form EPIPF-EOF-08-06, as information guides.

Note In fast breaking events, the ED may give verbal authorizationinstead of written approval to release the statement.

d. Review and approve news statements prior to being released to the media.

5.2.16 Review the plant Emergency Response Staffing requirements and need for any Emergency Director Assistants.

5.2.17 If appropriate, plan for a shift relief per EPIP-AD-05.

5.2.18 Review the requirements of Section 5.1 of EPIP-AD-15, "Recovery Planning and Termination," and determine if recovery or termination activities can be implemented.

5.2.19 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.2.7.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPLP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency PlanImplementing Procedure Date JUL 31 2003 Page 14 of 38 5.2.20 WHEN Final Conditions (Section 6.0) are met:

a. Notify the Emergency Response Manager of the event termination or entry into recovery and the suspension of the use of the use of EPIPs.

b. IF the event is an ENTRY INTO RECOVERY, THEN read aloud two times on the Gai-tronics the message below:

"Attention all personnel. We have entered plant recovery operations.

Review final conditions of all procedures and restore all emergency response materials and equipment to their proper location.

Appropriate inventories should be performed and supplies replenished as appropriate. Use of EPIPs is suspended when all final actions have been completed to the satisfaction of the facility Director. The Recovery Manager is and the Environmental Liaison is .99

c. IF the event is an emergency class TERMINATION, THEN read aloud two times on the Gai-tronics the message below:

"Attention all personnel. We have terminated the Emergency response.

Review final conditions of all procedures and restore all emergency response materials and equipment to their proper location. Appropriate inventories should be performed and supplies replenished as appropriate."

d. Ensure that termination or recovery notifications have been initiated by the NRC communicator.

e. Verify that "Event Notice," Form EPIPF-AD-07-01, is being transmitted accordance with EPIP-AD-07 or EPIP-EOF-08.

f. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to there proper place.

g. Collect all completed records, logs, forms, notes, and other documentation and give them to the TSCD.

h. Implement EPMP-02.01, "Declared Emergency Evaluation and Documentation."

5.3 The Notifier shall:

5.3.1 WHEN notified or upon hearing the Event announcement (except when a Security Event is in progress), report immediately to the SM in the Control Room.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher

'Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 15 of 38 5.3.2 WHEN directed by the Emergency Director/Shift Manager to perform event notifications, go to EPIP-AD-07.

5.3.3 IF an Emergency Response Facility (ERF) Communicator-Control Room (CR) is NOT available, THEN assume the role of the ERF Communicator-CR and go to Step 5.4.4.

5.3.4 When notified by the Offsite Communicator in the EOF or TSC that they are prepared to accept offsite communications:

a. Receive confirmation from the ED or EOD that it is appropriate to transfer communications.

b. Inform the Offsite Communicator that he has responsibility for offsite notifications.

c. Ensure date, time, and location is entered in the Control Room Chronological Log of Events for turnover of responsibilities to the Offsite Communicator from the Notifier.

d. Inform the ED or EOD that offsite communications have been transferred to the Offsite Communicator, and that the log entry for this transfer has been made.

e. Ensure the bell is turned off on the Government Verification line.

5.3.5 Until released, remain in the Control Room and help the designated ERF Communicator-CR.

5.3.6 WHEN released, report back to the Shift Captain.

5.4 Emergency Response Facility (ERF) Communicator shall:

5.4.1 WHEN directly notified, paged by radio-pager, or hearing the event announcement:

a. Report to the Control Room immediately.

b. IF the ERF Communicator-CR has been designated, THEN until released, assist the designated ERF Communicator-CR.

c. IF an ERF Communicator-CR has NOT been designated, THEN assume the responsibilities of the ERF Communicator-CR and continue to implement this procedure.

5.4.2 Notify the SM/ED of your arrival and assumption of the ERF Communicator-CR duties.

5.4.3 If applicable, obtain the status of notifications and verification call backs from the Notifier.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 16 of 38 5.4.4 IF there is an event: DECLARATION, ESCALATION, DE-ESCALATION, CHANGE IN PAR, TERMINATION, QR ENTRY INTO RECOVERY, AND directed by the SM/ED, go to EPIP-AD-07 OR EPIP-EOF-08 AND make the appropriate event notifications.

5.4.5 Review the need for the Notifier or additional communicator support.

5.4.6 IF additional Communicator support is needed, THEN contact the Technical Support Center Director 5.4.7 IF State and County notifications and ERO notifications are complete, or if a Notifier is implementing them, THEN enter the 4-Way Communications Link. The "dial in number" and "access number" are listed in the KPB Emergency Telephone Directory, ETD 03, "Emergency Response Facilities Telephone List."

5.4.8 Notify the EOD of any significant events.

5.4.9 If appropriate, plan for a shift relief per EPIP-AD-05.

5.4.10 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.4.4.

5.4.11 WHEN Final Conditions (Section 6.0) are met:

a. Verify that the bell switch on the emergency government verification line is in the ON position.

b. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to their proper place.

c. Collect all completed records, logs, forms, notes, and other documentation and give them to the EOD.

5.5 The Control Room Support Person (SP-C) shall:

5.5.1 WHEN directly notified, paged by radio-pager, or hearing the event announcement:

a. Report to the Control Room immediately.

b. IF a Control Room Support Person has been designated, THEN until released, assist the Control Room Support Person, as instructed.

c. IF a Control Room Support Person has NOT been designated, THEN assume the responsibilities of the Control Room Support Person and continue to implement this procedure.

5.5.2 Initiate or maintain accountability in the Control Room (EPIP-SEC-03).

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 17 of 38 5.5.3 Support the Control Room staff with:

a. Chronological log of events

b. Copying and faxing

c. Answering telephones 5.5.4 Review the need for additional Control Room Support Personnel.

5.5.5 IF additional Support Personnel are needed, THEN notify the EOD.

5.5.6 If appropriate, plan for a shift relief per EPIP-AD-05, "Emergency Response Organization Shift Relief Guideline."

5.5.7 Notify the EOD of any significant issues.

5.5.8 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.5.2.

5.5.9 WHEN Final Conditions (Section 6.0) are met:

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to their proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the EOD.

5.6 Shift Technical Advisor shall:

Note The Shift Technical Advisor shall be capable of responding to the Control Room within 10 minutes.

5.6.1 Report to the Control Room to be briefed on plant conditions.

5.6.2 Assist the Shift Manager in assessing plant conditions and determining emergency classification as defined in EPIP-AD-02, "Emergency Class Determination."

Note The respondingNRC Communicatormay be asked to assist in NRC notification. Off-site and other needed ERO or ERF communications shall be completed before the ERF Communicator-CRcan provide this support, unless there is more than one ERF Communicator-CR available.

5.6.3 Perform NRC Notification:

a. Gather information needed to prepare the NRC "Event Notification Worksheet," Form GNP-1 1.04.04- 1.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 lTRev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 18 of 38 Note If needed, the commercial telephone number is (301) 951-0550.

b. Notify the NRC (Headquarters, Rockville) as soon as possible, but not more than one hour after declaration of the Event, using the Emergency Notification System (ENS) phone.

Note The NRC may request continuous communicationsper 10CFR50.72(c)(3).

The STA must coordinate this activity with accidentassessment until arrival of an NRC Communicator OR activation of the TSC allows them to assume this activity.

c. Provide the NRC with the necessary information from a completed Event Notification Worksheet.

5.6.4 WHEN the NRC Communicator arrives OR the TSC accepts responsibility for NRC communications and plant status and other activities are at a point that it is appropriate, turn NRC communications over by taking the following actions:

a. Brief on plant conditions, the status of NRC notification and updates.

b. Inform them that you are turning over responsibility for NRC communications to them.

c. Ensure date and time is entered in the Control Room Chronological Log of Events for turnover of responsibilities for NRC communications from the STA.

5.6.5 Support the Control Room staff with technical and analytical assistance in diagnosing abnormal events and to ensure adequate core cooling.

5.6.6 Monitor plant conditions and provide assistance as needed to the Shift Manager.

5.6.7 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.6.5.

5.6.8 WHEN Final Conditions (Section 6.0) are met:

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to their proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the EOD.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 19 of 38 5.7 Event Operations Director (EOD) shall:

5.7.1 WHEN notified that an Emergency has been declared:

a. Report to the Control Room.

b. IF an Event Operations Director has been designated, THEN until released,

• If appropriate, plan a shift relief per EPIP-AD-05, AND

• Assist the designated Event Operations Director.

c. IF an Event Operations Director has NOT been designated, THEN assume the responsibilities of the Event Operations Director and continue implementation of this procedure.

Note Verbally inform the Shift Manager that you have accepted the EOD responsibilities.

5.7.2 Accept formal turnover of responsibilities (for EOD) from SM to include:

• TSC and EOF communications

• Maintaining verification of accountability

• Staffing of Control Room

• Processing work requests

• Monitoring fire fighting operations and maintaining accountability of fire team

• Obtaining additional assistance from Emergency Response Organization

• Monitoring and support of plant operations 5.7.3 Notify the SM/ED of your arrival and assumption of Event Operations Director responsibilities.

5.7.4 Ensure date and time is entered in the Control Room Chronological Log of Events for turnover of responsibilities for EOD from SM.

5.7.5 WHEN they are activating, verify DAROME communication links with TSC and EOF.

5.7.6 When appropriate, accept a briefing from the Shift Manager and STA.

5.7.7 Verify Control Room personnel accountability is being maintained.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency PlanImplementing Procedure Date JUL 31 2003 Page 20 of 38 5.7.8 Review Control Room staffing requirements, AND

a. Direct the Notifier/Communicator to contact additional operations personnel as needed and request that they report to the site (See KPB Emergency Telephone Directory for names and numbers).

b. Release any personnel NOT required.

5.7.9 Assess overall plant status.

• Verify equipment status and instrument indications.

• Verify Radiation monitors for abnormal indications.

• Review corrective actions that have been taken.

5.7.10 As necessary, make any recommendations to the Shift Manager.

5.7.11 Brief the Emergency Director of any changes on:

• Off-site Notifications (EPIP-AD-07 or EPIP-EOF-08)

• Plant Operations Status

• Control Room support priorities 5.7.12 Inform the RPD of any changes in radiological indications.

5.7.13 If required, request technical or maintenance support from the ED.

5.7.14 Prepare all work requests (WR) for approval.

a. Review WR and designate retest requirements.

b. If required to do the job, determine and initiate system lineups and tagouts.

5.7.15 Brief the Control Room staff periodically on:

• Emergency response status

• Priorities

• Specific guidance and assignments 5.7.16 If appropriate, plan for shift relief per EPIP-AD-05.

5.7.17 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.7.5.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 21 of 38 5.7.18 WHEN Final Conditions (Section 6.0) are met:

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to their proper place.

b. Collect all completed records and logs from all documents generated during the course of the event.

c. Schedule a self critique with all CR event participants (all shifts) as soon as practical.

5.8 Radiological Protection Director (RPD) shall:

5.8.1 WHEN notified that an Emergency has been declared:

a. Report to the Technical Support Center (TSC).

b. IF a Radiation Protection Director has been designated, THEN until released,

• If appropriate, plan a shift relief per EPIP-AD-05.

• Assist the designated RPD.

c. IF a Radiation Protection Director has NOT been designated, THEN assume the responsibilities of the RPD and continue implementing this procedure.

5.8.2 Notify the ED/TSCD of your arrival in the TSC and assumption of RPD responsibilities.

5.8.3 Direct the staff to activate the RPO/RAF (EPIP-RET-02A, "RPO - RAF Activation").

5.8.4 When conditions warrant, the RPD shall relocate the RPO to the RAF.

5.8.5 Direct staff to establish Radiation Emergency Team organization (EPIP-RET-02, "In-Plant Radiation Emergency Team").

5.8.6 If required, verify personnel accountability in RPO is being maintained.

5.8.7 If required, assist the SAD in search and rescue operations (EPIP-OSF-04).

5.8.8 Check radiological and meteorological information available in the TSC.

5.8.9 If needed, contact the Data Coordinator or ERF Communicator-TSC for additional Area and Process radiation monitor information.

5.8.10 If needed, assign an HP Tech or Chem Tech to the HPN phone.

5.8.11 Verify that emergency radiation controls are being implemented (EPIP-AD-1 1).

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 22 of 38 5.8.12 Verify controlled area access is being maintained (EPIP-RET-02D, "Emergency Radiation Entry Controls and Implementation").

Note Ensure the Control Room is preparedto support sampling.

5.8.13 As dictated by the emergency event, direct the Chemistry Emergency Team (CET) or In-Plant Radiation Emergency Team (IRET) to take samples and to implement additional IRET and CET procedures.

• "Gaseous Effluent Release Path, Radioactivity, and Release Rate Determination," EPIP-RET-02B

• "Liquid Effluent Release Paths," EPIP-RET-03A

• "Post Accident Operation of the High Radiation Sample Room,"

EPIP-RET-03C

• "Containment Air Sampling Analysis Using CASP," EPIP-RET-03D

• "SBF Operation/Relocation," EPIP-RET-04A

• "Site Boundary Dose Rates During Controlled Plant Cooldown,"

EPIP-RET-05

• "Contamination Control of the Aurora Medical Center," HP-01.020

• "Post Accident Population Dose," EPIP-RET-09 5.8.14 IF dose calculation capability is NOT available in the EOF AND a radioactive release has occurred or there is the potential for a release, THEN:

a. Direct the staff to perform dose projections (EPIP-ENV-03C, "Dose Projection Using RASCAL Software").

b. Maintain an overall awareness of environmental conditions and the contributing factors for development of protective action recommendations in accordance with procedure EPIP-AD-19.

5.8.15 Monitor plant conditions for indications of radioactive iodine and with concurrence of the ED make KI available, if appropriate (EPIP-AD-18).

5.8.16 If required, assist the SPD with Personnel Evacuation (EPIP-SEC-05).

Note Transportationof a contaminated injuredperson shall be to the Aurora Medical Center and an IRET should be dispatchedto the hospital.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 23 of 38 Note IF there is a question as to the extent of injuries, THEN it should be treatedas a criticalinjury.

Note Off-Site SupportAgencies and theirphone numbers are listed in the KPB Emergency Telephone Directory.

5.8.17 IF there are injuries or vehicle accidents associated with plant personnel or contractors, THEN contact the appropriate support agencies.

a. IF the injury is a "Medical Attention (Critical) Injury" or a vehicle accident with injuries (see NAD-02.09 for definition of critical injuries), THEN:

1. Contact the County Sheriff's office with jurisdiction at the location of the injury(s). (Kewaunee County has jurisdiction on the KNPP site.)

• Kewaunee County Dispatch - 911

• Manitowoc County Dispatch - (920) 683-4200

2. Notify the dispatcher of the accident and/or injury and request a rescue squad (all critically injured personnel shall be transported by rescue squad).

3. Provide the dispatcher with the following information:

• Your name, position, and return telephone number.

• The location of the accident and when it occurred.

• How many and how the injury(s) occurred.

• Nature and extent of injuries and condition of the patient(s).

• If any, extent of radioactive contamination and instructions that transportation of a potentially contaminated injured person shall be to the Aurora Medical Center.

• Plant name, location.

• If required, plant access instructions.

4. IF the injury is on-site, THEN:

• Inform the SPD of your request for a rescue squad and its estimated time of arrival.

• Direct the SPD to have the vehicle driven to the proper plant entrance.

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WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 l Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 24 of 38

5. IF the accident potentially involves radioactive contamination, THEN:

• Dispatch an IRET member to the accident site for contamination control.

• Dispatch an IRET member to the Aurora Medical Center to assist the hospital staff.

6. Insure that the requirements for "Injury/Illness Response," NAD-02.09, are implemented.

7. Inform the Emergency Director, Emergency Response Manager, and the Plant Spokesperson of the accident and details of the injuries.

b. IF the Injury is a "Medical Attention (Non-critical) Injury," THEN:

Note Any KNPP or contractorvehicle may be usedfor transportof (non-critical) injuredpersonnel.

1. Arrange for transportation of the injured person.

2. Direct the SPD to have the vehicle driven to the proper plant entrance.

3. Contact the hospital or clinic and provide the following information:

• Your name, position, and return telephone number.

• When, how many, and how the injury(s) occurred.

• Nature of injuries and condition of the patient.

• If any, extent of radioactive contamination.

• Plant name, location, and access instructions.

• Estimated time of arrival for the patient(s) at the hospital or clinic.

4. IF there are contaminated injuries, THEN send an IRET member to the Aurora Medical Center to assist the hospital staff.

5. Insure that the requirements for "Injury/Illness Response," NAD-02.09, are implemented.

6. Inform the Emergency Director, Emergency Response Manager, and the Plant Spokesperson of the accident and details of the injuries.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 25 of 38 5.8.18 Brief the Emergency Director of plant radiological conditions:

• Status of Radiological Effluent Releases (potential off-site dose consequences).

• Emergency Radiation Controls (EPIP-AD-1 1) (actions taken in response to this procedure).

• Status of Personal Injuries or Vehicle Accidents.

• Availability of Potassium Iodide (EPIP-AD-18).

5.8.19 Review the personnel requirements in the RPO/RAF and:

a. As needed, direct the staff to contact additional Radiation Emergency Team (RET) members.

b. Release any RPO/RAF staff not required.

5.8.20 If appropriate for long term accident support, then coordinate with the ALD to establish contract support.

5.8.21 If appropriate, plan for a shift relief per EPIP-AD-05.

5.8.22 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.8.5.

5.8.23 WHEN Final Conditions (Section 6.0) are met:

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to their proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the TSCD.

c. Verify all samples collected have been cataloged and appropriately stored.

d. Schedule a self critique with all event participants in the RPOIRAF (all shifts) as soon as practical.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 I Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergenev Plan Implementing Procedure Date JUL 31 2003 I Page 26 of 38 5.9 Technical Support Center Director (TSCD) shall:

5.9.1 WHEN notified that an Emergency has been declared:

a. Report to the Technical Support Center (TSC).

b. If a Technical Support Center Director has been designated, UNTIL released:

• Assist in the activation of the TSC per EPIP-TSC-02.

• If appropriate, plan a shift relief per EPIP-AD-05.

• Assist the designated TSCD.

c. IF a Technical Support Center Director has NOT been designated, THEN assume the responsibilities of the TSCD and continue implementing this procedure.

5.9.2 Notify the Emergency Director of your assumption of TSCD responsibilities.

5.9.3 Notify TSC staff of your assumption of TSCD responsibilities.

5.9.4 Verify that the TSC is being activated (EPIP-TSC-02).

5.9.5 Verify accountability is being maintained in the TSC (EPIP-SEC-03).

5.9.6 Determine the TSC activity status by obtaining the following information from TSC staff.

a. _ _ Operations Coordinator:

• TSC support of control room activities

• Technical support of IPEOPs (EPIP-TSC-10, "Technical Support for IPEOPs")

b. Engineering Coordinator:

• Design change activities (EPIP-TSC-04, "Emergency Physical Changes, Major Equipment Repair")

• Work requests (EPIP-OSF-03, "Work Requests During an Emergency")

• Support Activities REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 27 of 38

c. Core Hydraulics Coordinator:

• Core Damage Assessment (EPIP-TSC-09A)

• If appropriate, Steam Release Calculations (EPIP-TSC-08A, "Calculations for Steam Release from Steam Generators")

• If appropriate, Head Venting Calculations (EPIP-TSC-07, "RV Head Venting Time Calculation")

d. Quality Control Coordinator:

• QC concerns

• Warehouse activities

e. Data Coordinator:

• Status of data collection and posting (EPIP-TSC-03)

• Significant changes in plant parameters

f. ERF Communicators

• CR, TSC, EOF, JPIC Communication (4-Way Communications Link)

• NRC communications

• Emergency Response Data System 5.9.7 Contact the Emergency Director (ED) and obtain information on plant status.

5.9.8 Brief the Emergency Director on TSC activities.

• TSC Activation and Operational Status (EPIP-TSC-02)

• Significant Plant Trends

• Core Damage Assessment (EPIP-TSC-09A) 5.9.9 Ensure the TSC staff is informed of plant status and ED priorities.

5.9.10 Review TSC staffing requirements.

5.9.11 If appropriate, plan for a shift relief per EPIP-AD-05.

5.9.12 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.9.5.

REFERENCE USE

I WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 28 of 38 5.9.13 WHEN Final Conditions (Section 6.0) are met:

a. Ensure the TSC and OSF are de-activated per "Technical Support Center Activation," EPIP-TSC-02.

b. Collect all records and logs from all documents generated during the course of the event.

c. Schedule a self critique with all event participants in the TSC (all shifts) as soon as practical.

5.10 Support Activities Director (SAD) shall:

5.10.1 WHEN notified that an Emergency has been declared:

a. Report to the Technical Support Center (TSC).

b. IF a Support Activities Director has been designated, THEN until released,

• If appropriate, plan a shift relief per EPIP-AD-05.

• Assist the designated SAD.

c. IF a Support Activities Director has NOT been designated, THEN assume the responsibilities of the SAD and continue implementing this procedure.

5.10.2 Notify the Emergency Director of your assumption of SAD responsibilities.

5.10.3 Notify the OSF staff that you have assumed the responsibilities of Support Activities Director.

5.10.4 Direct the OSF coordinator to implement EPIP-OSF-02.

5.10.5 Designate an OSF assembly area giving consideration to manpower pool size and environmental conditions.

5.10.6 If needed, direct the OSF coordinator to initiate search and rescue operations (EPIP-OSF-04).

5.10.7 Contact the Emergency Director for information on plant status and immediate actions.

5.10.8 Direct emergency maintenance activities in accordance with the priorities established by the Emergency Director.

5.10.9 If required, request engineering support from the Engineering Coordinator.

5.10.10 Review the maintenance staffing requirements to mitigate the incident.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 IRev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency PlanImplementing Procedure Date JUL 31 2003 I Page 29 of 38 5.10.11 Brief the Emergency Director on OSF activities.

• OSF Activation and operational status

• OSF Facility Operations (EPIP-OSF-02)

• Maintenance Activities

• Search and Rescue (EPIP-OSF-04) 5.10.12 Ensure the OSF staff is informed of plant status and ED priorities.

5.10.13 If appropriate, plan for a shift relief per EPIP-AD-05.

5.10.14 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.10.6.

5.10.15 WHEN Final Conditions (Section 6.0) are met:

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to their proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the TSCD.

c. Schedule a self critique with all event participants in the OSF (all shifts) as soon as practical.

5.11 Site Protection Director (SPD) shall:

5.11.1 WHEN notified that an Emergency has been declared:

a. Report to the Security Building.

b. If a Site Protection Director has been designated, UNTIL released:

• If appropriate, plan a shift relief per EPIP-AD-05.

• Assist the designated SPD.

c. IF a Site Protection Director has NOT been designated, THEN assume the responsibilities of the SPD and continue implementing this procedure.

5.11.2 Notify the ED/TSCD of your arrival in the Security Building and assumption of the SPD responsibility.

5.11.3 Direct the implementation of "Security Force Response to Emergencies,"

EPEP-SEC-02.

5.11.4 Establish "Personnel Assembly and Accountability," EPIP-SEC-03.

REFERENCE USE

TitleResponse to Alert or Higher~~~~~~~~~~~~~~~~~

KNPP WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 l Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 30 of 38 5.11.5 IF Search and Rescue is required due to accountability results, THEN notify the Support Activities Director.

5.11.6 Direct the security staff to issue dosimetry to personnel responding from off-site (EPIP-SEC-04).

5.11.7 When appropriate, relocate to the TSC.

5.11.8 Obtain information from the RPD or the Control Room concerning fire, chemical, or radiological hazards present within the protected area.

5.11.9 IF hazards identified by the RPD or the Control Room warrant it, THEN restrict ERO personnel movement.

5.11.10 IF directed by the ED, THEN initiate a plant evacuation (EPIP-SEC-05).

5.11.11 Brief the Emergency Director on security activities:

• Removal of Visitors from site (i.e., fishermen) (EPIP-SEC-02)

• Personnel Accountability (EPIP-SEC-03)

• Plant Evacuations (EPIP-SEC-05)

• Access Control

• Dosimetry Issue (EPIP-SEC-04)

• Significant Security Activities 5.11.12 Ensure that the Security Force and staff are informed of any significant issues relative to their activities.

5.11.13 Ensure accountability is maintained (EPIP-SEC-03).

5.11.14 Review security staffing requirements and make appropriate adjustments.

5.11.15 If appropriate, plan for a shift relief per EPIP-AD-05.

5.11.16 IF Final Conditions (Section 6.0) have NOT been met, THEN go to Step 5.10.8.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure -Date JUL 31 2003 Page 31 of 38 5.11.17 WHEN Final Conditions (Section 6.0) are met:

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc. are returned to their proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the TSCD.

c. Schedule a self critique with all event participants in Security (all shifts) as soon as practical.

6.0 Final Conditions 6.1 Plant Emergency has been Terminated or Recovery actions have begun and the responsible Director has suspended the use of EPIPs.

7.0 References 7.1 Kewaunee Nuclear Power Plant Emergency Plan 7.2 COMTRAK 87-152, Downgrading of EALs 7.3 COMTRAK 88-068, Calling in additional communicators as required 7.4 NRC Inspection Report K-87-195, same as Reference 7.2 7.5 10CFR50.72(c)(3), Maintaining open communications with the NRC 7.6 NAD-02.09, Injury/Illness Response 7.7 EPIP-AD-02, Emergency Class Determination 7.8 EPIP-AD-05, Emergency Response Organization Shift Relief Guideline 7.9 EPIP-AD-07, Initial Emergency Notifications 7.10 EPIP-AD-1 1, Emergency Radiation Controls 7.11 EPIP-AD-15, Recovery Planning and Termination 7.12 EPIP-AD-18, Potassium Iodide Distribution 7.13 EPIP-AD-19, Protective Action Guidelines 7.14 EPIP-AD-20, KNPP Response to a Security Threat

'-- 7.15 EPIP-ENV-03C, Dose Projection Using RASCAL Software REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-04 Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 32 of 38 7.16 EPIP-EOF-08, Continuing Emergency Notifications 7.17 EPIP-OSF-02, Operational Support Facility Operations 7.18 EPIP-OSF-03, Work Requests During an Emergency 7.19 EPIP-OSF-04, Search and Rescue 7.20 EPIP-RET-02, In-Plant Radiation Emergency Team 7.21 EPIP-RET-02A, RPO - RAF Activation 7.22 EPIP-RET-02B, Gaseous Effluent Release Path, Radioactivity, and Release Rate Determination 7.23 EPIP-RET-02D, Emergency Radiation Entry Controls and Implementation 7.24 EPIP-RET-03A, Liquid Effluent Release Paths 7.25 EPIP-RET-03C, Post Accident Operation of the High Radiation Sample Room 7.26 EPIP-RET-03D, Containment Air Sampling Analysis Using CASP 7.27 EPIP-RET-04A, SBF Operation/Relocation 7.28 EPIP-RET-05, Site Boundary Dose Rates During Controlled Plant Cooldown 7.29 HP-01.020, Contamination Control of the Aurora Medical Center 7.30 EPIP-RET-09, Post-Accident Population Dose 7.31 EPIP-SEC-02, Security Force Response to Emergencies 7.32 EPIP-SEC-03, Personnel Assembly and Accountability 7.33 EPIP-SEC-05, Personnel Evacuation 7.34 EPIP-TSC-02, Technical Support Center Activation 7.35 EPIP-TSC-04, Emergency Physical Changes, Major Equipment Repair 7.36 EPIP-TSC-07, RV Head Venting Time Calculation 7.37 EPIP-TSC-10, Technical Support for IPEOPs 7.38 EPIP-TSC-09A, Core Damage Assessment REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPEP-AD-04 I Rev. AN Title KNPP Response to Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure I Date JUL 31 2003 I Pawe 33 of 38 7.39 KPB Emergency Telephone Directory 7.40 EPMP-02.01, Declared Emergency Evaluation and Documentation 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• Event Notice, Form EPIPF-AD-07-01

• Event Notification Worksheet, Form GNP-11.04.04-1 8.1.2 Non-OA Records None REFERENCE USE

TURNOVER BRIEFING WORKSHEET CONTROL ROOM TO EMERGENCY DIRECTOR/ERM Note: All blanks are not requiredto be completed.

A. Emergency Classification Status (circle): Unusual Event Alert Site Area Emergency General Emergency

1. Initiating Events:

EAL Charts exceeded:

EAL Charts monitored for escalation:

2. Status of emergency procedure implementation and mitigating actions B. Plant / Reactor Status (circle): Stable Degrading Improving Safety System operation / problems:

1. Fission Product Barrier Fuel Cladding: Intact Potential Loss Lost Primary Coolant: Intact Potential Loss Lost Containment: Intact Potential Loss Lost _

Safety System Status:

2. Evolutions in progress Attachment A EPIP-AD-04 Rev. AN Date: JUL 31 2003 Page 34 of 38 REFERENCE USE

TURNOVER BRIEFING WORKSHEET CONTROL ROOM TO EMERGENCY DIRECTOR/ERM

3. Control Room Support Priorities for Maintenance or assistance needed:

4. Radiological conditions Release in progress (circle): YES NO C. On-site Protective Actions D. Off-site Protective Actions recommended (only for a General Emergency classification)

E. Off-site Assistance Requests F. Off-site Notifications Last Notification Time:

1. State & Counties:

2. NRC:

3. Others: (INPO, ANI etc.):.

Attachment A EPIP-AD-04 Rev. AN Date: JUL 31 2003 Page 35 of 38 REFERENCE USE

TURNOVER BRIEFING WORKSHEET CONTROL ROOM TO EMERGENCY DIRECTOR/ERM

---

G. Status of ERO activation H. Status of Plant Accountability:

1. Status of outside agency mobilization

-1 Obtain a copy of all Event Notifications to State & Counties Attachment A EPIP-AD-04 Rev. AN Date: JUL 31 2003 Page 36 of 38 REFERENCE USE

TURNOVER BRIEFING WORKSHEET CONTROL ROOM TO EMERGENCY DIRECTOR/ERM (HELP GUIDE)

A. Emergency Classification Status

1. Initiating Events and EALs exceeded:

• Cause, history, and initiating events leading to emergency declaration

• EALs exceeded

2. Status of Emergency Procedure Implementation and Mitigating Actions

• Status of progress in emergency procedures

• Corrective actions taken B. Plant/Reactor Status Condition / stability of reactor and plant conditions improving or declining

1. Fission Product Barrier and Safety System Status

• Fission Product Barrier Status (Fuel, RCS, Containment)

• Safety System alignments and status (flow rates, etc.)

2. Evolutions in Progress

• Control Room activities

• In plant activities (AOs, I&C, Mechanics)

3. Radiological Conditions

• Known in plant conditions

• Known releases and duration C. On-Site Protective Actions

• Existing personnel hazards

• Evacuations (local, site) and status of accountability or assembly

• KI Administration (status)

Attachment A EPIP-AD-04 Rev. AN Date: JUL 31 2003 Page 37 of 38 REFERENCE USE

TURNOVER BRIEFING WORKSHEET CONTROL ROOM TO EMERGENCY DIRECTOR/ERM (HELP GUIDE)

D. Off-Site Protective Actions

• Status of Dose Assessment activities

• PARs made to State/County Agencies E. Off-Site Assistance Request

• Fire, rescue squad, and law enforcement assistance requested F. Off-Site Notifications

• Status of notifications made to:

- State and Counties

- NRC

- INPO

- ANI

- Any others G. Status of ERO Activation

• Minimum staffing positions not reporting in to Automated Notification System H. Status of Plant Accountability

• Security actions taken

• Any missing individuals.

1. Status of Outside Agency Mobilization

• Any Reports that the State and Counties, NRC, etc., are activating

• Requests from State/Counties/NRC, etc.

• Time/Content of any News Releases J. Control Room Support Priorities for Maintenance or assistance needed

• Key work items to support the Control Room

• Equipment needed returned to service

• Additional assistance needed to meet Control Room needs Attachment A EPIP-AD-04 Rev. AN Date: JUL 31 2003 Page 38 of 38 REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-07 Rev. AU Title Initial Emergency Notifications Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 1 of 9 Reviewed By Richard Johnson Approved By Jerrie Morlino Nuclear 0 Yes PORC 0 Yes SRO Approval Of 0 Yes Safety Review Temporary Related El No Required 0 No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for the Security Notifier (SEC-N), ERF Communicator - Control Room (ERFCM-C), Operations crew members, or Off-Site Communicator (OFFCM) for notification of Off-Site Authorities of an emergency event escalation, de-escalation, change in Protective Action Recommendation (PAR), termination, or entry into recovery, as directed by the Shift Manager (SM), Emergency Director (ED), or Emergency Response Manager (ERM).

2.0 General Notes 2.1 IF approached by the media during a declared emergency, THEN refer them to the Joint Public Information Center (JPIC) at (920) 433-1400 or 1-(800) 838-6192 and tell them that this is their most accurate source for information.

2.2 This is a "Continuous Use" procedure with steps performed in sequence.

3.0 Precautions and Limitations 3.1 Once indication is available that an emergency action level has been exceeded, classification must be made as soon as possible and must not exceed 15 minutes. Once a classification has been declared, notification must be initiated and in progress to the State and County agencies within 15 minutes of event classification using "Event Notice," Form EPIPF-AD-07-01.

3.2 UNTIL off-site notifications are transferred to the Emergency Operations Facility (EOF) or Technical Support Center (TSC), verify the bell switch on Government Verification Phone is ON in the Control Room.

3.3 IF an event is terminated prior to the initial notification of the event, THEN the off-site notification of the declaration of the event AND the termination of the same event can be made simultaneously by using an appropriately completed "Event Notice,"

Form EPIPF-AD-07-01. Notification of the Emergency Response Organization (ERO) by SAS is not required in this circumstance.

3.4 IF an emergency class escalation, de-escalation, change in PAR, termination, or entry into recovery occurs during the notification AND prior to transfer of off-site notifications to the TSC or EOF, THEN disregard any remaining steps and return to Step 5.1. Begin the appropriate actions and notifications for the new emergency level.

J:\appdata\procpws\draft\epip\eadO7.doc-Amy Kudick/Amy Kudick-Jeanne Ferris CONTINUOUS USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-07 Rev. AU Title Initial Emergency Notifications Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 2 of 9 4.0 Initial Conditions 4.1 This procedure is initiated for the Initial event notifications and will continue to be used for event notifications until the State of Wisconsin Emergency Operations Center (State EOC) is activated. This procedure shall be implemented upon an event

• DECLARATION,

• ESCALATION,

• DE-ESCALATION,

• CHANGE IN PAR, - TERMINATION, or

• ENTRY INTO RECOVERY, as directed by the SM/ED or ERM.

5.0 Procedure Note IF the State EOC is activated, THEN go to "Continuing Emergency Notifications,"

EPIP-EOF-08.

Note Step 5.1 is to be performed by the Notifier.

5.1 Notify the State and County and ERO of the Event Check 5.1.1 Verify the SM/ED has contacted SAS to provide direction on activation of ERO in accordance with Attachment B of EPIP-AD-07, "ERO Event Notification."

5.1.2 Verify that any "Event Notice," Form EPIPF-AD-07-01, received from the SM/ED or ERM has their approval signature, date, and time.

5.1.3 Complete block 12 of Form EPIPF-AD-07-01.

5.1.4 Complete Attachment A of EPEP-AD-07, "State and County Event Notification."

Note Steps 5.2 and 5.3 are NOT to be performed by the ERF Communicator-CR, if another staff member is available to perform these steps.

5.2 FAX Event Notice 5.2.1 Obtain fax cover sheet, Form EPIPF-EOF-08-03, "Fax for Emergency Declaration or Status Updates."

5.2.2 Send fax broadcast of completed "Event Notice," Form EPIPF-AD-07-01 with fax cover sheet, by following instructions on Form EPIPF-AD-07-03, "Fax Event Notice."

CONTINUOUS USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-07 Rev. AU Title Initial Emergency Notifications Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 3 of 9 Check 5.2.3 Contact the Point Beach Duty Shift Manager at (920) 755-6247 and notify him that an "Event Notice" has been faxed to him.

5.3 Return Form EPIPF-AD-07-01 to the SM/ED or ERM who approved the "Event Notice."

5.4 WHEN final conditions are met (Step 6.0), THEN return to EPIP-AD-03, "KNPP Response to an Unusual Event," OR EPIP-AD-04, "KNPP Response to Alert or Higher," OR EPIP-EOF-04, "EOF Staff Action for Alert or Higher," at the step you left the procedure.

6.0 Final Conditions 6.1 The off-site notification implemented upon declaration of an event

• ESCALATION,

• DE-ESCALATION,

• CHANGE IN PAR,

• TERMINATION, or

• ENTRY INTO RECOVERY, is complete.

7.0 References 7.1 Kewaunee Nuclear Power Plant Emergency Plan 7.2 EPIP-APPX-A-1, Communication System Description 7.3 KNPP Emergency Telephone Directory 7.4 EPIP-AD-03, KNPP Response to an Unusual Event 7.5 EPIP-AD-04, KNPP Response to Alert or Higher 7.6 EPIP-AD-07, Attachment B, ERO Event Notification 7.7 EPIP-EOF-04, EOF Staff Action for Alert or Higher 7.8 EPIP-EOF-08, Continuing Emergency Notifications 7.9 Form EPIPF-AD-07-01, Event Notice (Nuclear Accident Reporting System Form (NARS))

7.10 Form EPIPF-AD-07-03, FAX Event Notice 7.11 Form EPIPF-EOF-08-03, Fax for Emergency Declaration or Status Updates CONTINUOUS USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-AD-07 Rev. AU Title Initial Emergency Notifications Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 4 of 9 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• Event Notice (Nuclear Accident Reporting System Form (NARS)),

Form EPIPF-AD-07-01

• Attachment A, State and County Event Notification

• Attachment B, ERO Event Notification

• Form EPIPF-AD-07-03, FAX Event Notice 8.1.2 Non-OA Records None CONTINUOUS USE

STATE AND COUNTY EVENT NOTIFICATION (Page 1 of 3)

Date and Time: Check

1. Verify the bell switch for the Government verification phone at your station is ON.

2. Pick up the Dial Select phone and verify the line is clear.

a. IF someone is using the Dial Select line, THEN state that you have a "PRIORITY 2" notification. They will clear the line unless they have a "PRIORITY 1" call.

b. IF someone states they have a "PRIORITY 1" conversation, THEN acknowledge their priority and monitor the call until they finish.

3. WHEN the line is clear, Dial "22" (All Call for agencies to be notified).

a. IF the Dial Select system is not operating, THEN go to Step 9 (Using Secondary Method, Commercial Phone).

Note Either Warning Center I or Warning Center 11 may respond. Both are NOT requiredto respond.

Note IF an agency does not respond, THEN press # to cancel the ringing.

4. WHEN each party acknowledges:

a. Answer by stating: "This is the Kewaunee Nuclear Plant - Please stay on the line for a Nuclear Accident Reporting System (NARS) message."

b. Record the time each agency responds on top of Form EPIPF-AD-07-01 (NARS form).

c. After all agencies have answered press the # key to cancel the ringing.

AGENCY DIAL SELECT #

All Call 22 State Warning Center I or II 93 (I) and 83 (II)

Kewaunee County Sheriff Dispatch 13 Manitowoc County Sheriff Dispatch 54

• IF after five (5) rings an agency has not answered, THEN press the individual's Dial Select number from the table below.

• WAIT up to five (5) more rings, THEN press the "#" key to cancel ringing.

• IF unable to contact a specific agency, THEN continue with the notification of agencies on the line.

5. Read the message on Form EPIPF-AD-07-01 text aloud, SLOWLY AND DELIBERATELY, using number and letter designations (Ref: "Phonetic Alphabet.")

6. Say: "State Warning Center, please read back this message to verify accuracy."(Pause to allow message to be read back.)

Attachment A EPIP-AD-07 Rev. AU Date: JUL 31 2003 Page 5 of 9 CONTINUOUS USE

STATE AND COUNTY EVENT NOTIFICATION (Page 2 of 3)

Check

7. Say: "Have all agencies received this message?" (Wait for Reply.)

8. Say: "Relay this information to Emergency Management immediately. Have the appropriate personnel verify this message by placing a return phone call to KNPP at 920-388-0101."

9. IF any agencies did not respond to the Dial Select, THEN complete the State and County Event Notification using the secondary method, commercial phone.

AGENCY COMMERCIAL #

State Warning Center I or II 1 (800) 943-0003 Kewaunee County Sheriff 1 (920) 388-7108 Manitowoc County Sheriff 1 (920) 683-4201

a. Call each applicable agency number in the order shown above.

b. WHEN the party answers, record the time on Form EPIPF-AD-07-01 (NARS form).

c. Read the message on Form EPIPF-AD-07-01 text aloud, SLOWLY AND DELIBERATELY, using number and letter designations (Ref: "Phonetic Alphabet.")

d. Say: "(agency name), please read back this message to verify accuracy."(Pause to allow message to be read back.)

e. Say: "Relay this information to Emergency Management immediately. Have the appropriate personnel verify this message by placing a return phone call to KNPP at 920-388-0101."

f. UNTIL all agencies have been notified, repeat Steps a through e.

10. Inform SMIED/ERM that initial notifications have been made and you are waiting for verification callbacks.

Attachment A EPIP-AD-07 Rev. AU Date: JUL 31 2003 Page 6 of 9 CONTINUOUS USE

STATE AND COUNTY EVENT NOTIFICATION (Page 3 of 3)

Check Note WHILE monitoringfor callbacks you may continue with other steps in EPIP-AD-07.

11. Monitor government verification line for Call Backs.

a. WHEN calls are received from State or Local Emergency Government Officials, record time of call, caller name, and phone number.

Time Name Contact Phone #

State of Wisconsin (Duty Officer)

Manitowoc County (Emerg. Mgnt. Dir.)

Kewaunee County (Emerg. Gov. Dir.)

b. IF we have not received verification call backs from each of the off-site officials within 45 minutes from the time recorded for Roll-Call on Form EPIPF-AD-07-01, THEN re-initiate the notification process for those officials by starting at Step 9.

c. IF further information or verification is requested, THEN transfer calls coming from State or Local Emergency Government Officials or the State Radiological Coordinator to the SM/ED/ERM or his designee.

12. Inform SM/ED/ERM when all verification callbacks have been received.

13. Return to procedure Step 5.2.

Attachment A EPIP-AD-07 Rev. AU Date: JUL 31 2003 Page 7 of 9 CONTINUOUS USE

ERO EVENT NOTIFICATION (Page 1 of 2)

DATE: Check Note Any WPSC PBX telephone extension can be used to activate the pagers.

Note WHEN directed, activate the radio pagercode the SM/ED selected in Section 2 and the message code selected in Section 3. If the selection in Section 4 contains two pagercodes, steps 2 through 6 must be performed twice, once for each code.

Note IF the KNPPpaging system is inoperable or unavailable, THEN go to Step 8.

1. Dial ext. "5213" on any WPSC PBX Telephone (extension xxxx).

2. WHEN the phone answers and responds with a single (1) beep, dial the pager access code selected below (the SM/ED must check one of the options below).

o "9233" - ALERT or HIGHER EVENT (All emergency pager holders),

o "9211 " AND "9222"- UNUSUAL EVENT (Directors and Select Staff) o "9244" AND "9255" - CREDIBLE SECURITY THREAT

3. WHEN the phone responds with three (3) beeps, dial the message code selected below (the SM/ED must check one of the options below).

Note Use codes asfound in envelopes.

o "77777" - ALERT o "88888" - SITE EMERGENCY o "99999" - GENERAL EMERGENCY o "44666" - CREDIBLE SECURITY THREAT - UNUSUAL EVENT o "44777" - CREDIBLE SECURITY THREAT - ALERT o "66666" - UNUSUAL EVENT o "44444" - TERMINATION OR RECOVERY Attachment B EPIP-AD-07 Rev. AU Date: JUL 31 2003 Page 8 of 9 CONTINUOUS USE

ERO EVENT NOTIFICATION (Page 2 of 2)

Check

4. Press the "#" key. WHEN the phone responds with five (5) beeps, hang up.

5. IF another pager access code is to be activated, THEN return to Step 1.

6. Verify that the ERO control pager in the Control Room (or any ERO member's pager) has activated and displays the message within 3-4 minutes.

7. IF the PBX phone system is inoperable, THEN:

• Dial "1-920-617-5213" from a Kewaunee (388-xxxx) or other non Green Bay external telephone company exchange line, OR

• Dial "617-5213" from any Green Bay (433-xxxx, 617-xxxx, etc.) external telephone company exchange, OR

• Dial "9-1-920-617-5213" from a Centrex (43 1-xxxx) exchange located in the EOF.

Note The following steps are to be used if the radiopagingsystem is inoperable or significantly degradedoutside of normal working hours.

Note A Liaison should not accept responsibilityfor the ERO Call Tree unless they have immediate access to the KPB Emergency Telephone Directory.

Note IF a Liaison does not accept the responsibilityfor an ERO Call Tree (Part "A " and/orPart "B"), THEN the communicators should implement that part of the Call Tree themselves.

8. IEF problems are encountered with the KNPP paging system, THEN use the alternate ERO notification method.

a. Call the State or County Liaisons listed in the Emergency Telephone Directory tab "KNPP ERO Call List," ETD 01A, until two liaisons accept the ERO Call Tree responsibility.

b. Inform the first Liaison accepting the ERO Call Tree Task that a(n) (select one)

Unusual Event, Alert, Site Emergency, General Emergency, or Credible Security Threat, was declared at _ (time) and the ERO Call Tree Part "A" in the Emergency Telephone Directory tab "KNPP ERO Call List," ETD 01A, should be activated.

c. Inform the second Liaison accepting the ERO Call Tree Task that a(n) (select one)

Unusual Event, Alert, Site Emergency, General Emergency, or Credible Security Threat, was declared at _ _ (time) and the ERO Call Tree Part "B" in the Emergency Telephone Directory tab "KNPP ERO Call List," ETD 01A and tab "KPB ERO Call List," ETD 01C, should be activated.

Attachment B EPIP-AD-07 Rev. AU Date: JUL 31 2003 Page 9 of 9 CONTINUOUS USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-01 Rev. X Title Environmental Monitoring Group Kewaunee Nuclear Power Plant Organization and Responsibilities Emergency Plan Implementing Procedure Date JUL 31 2003 Page 1 of 7 Reviewed By Brent Doering Approved By Jeme Morlino Nuclear 0 Yes PORC 0 Yes SRO Approval Of O Yes Safety Review Temporary Related 0 No Required E0 No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for the Environmental Monitoring Group for formulating and recommending timely Protective Action Recommendations (PARs) to the Emergency Response Manager.

2.0 General Notes 2.1 PARs are developed using plant data, field data and off-site dose projections.

2.2 Collect data using the following techniques in the order presented.

2.2.1 Project the Total Effective Dose Equivalent (TEDE) based on information provided by available plant sources including meteorological and radiological release data.

2.2.2 Determine the boundaries of a radioactive spill or plume, and the total area affected.

2.2.3 Collect samples to determine the isotopic makeup of the plume or spill.

2.2.4 Sampling area for the Environmental Monitoring Teams (EMTs) normally extends from the protected area fence to a 10 mile radius of the plant. However, if dose projections or field readings indicate doses > 1 rem TEDE or > 5 rem thyroid to any population outside the 10 mile radius of the plant then sampling should continue beyond the 10 mile radius. Areas monitored and sampled by the EMTs may include areas such as the access road, parking lot(s), training facilities or other locations on-site but outside the protected area fence as needed.

3.0 Precautions and Limitations 3.1 EMTs shall NOT enter areas where projected or measured external radiation dose rates exceed 1 R/hr without receiving specific directions to enter the area, as approved by the Environmental Protection Director (EPD) or Radiological Protection Director (RPD).

4.0 Initial Conditions 4.1 This procedure may be implemented at the declaration of an Unusual Event.

4.2 Activate the EMTs when an Alert, Site Emergency, General Emergency is declared.

j:\appdata\procpws\dratt\epip\eenvol .doc-Christine Simmons/Dori Ziegler-Rick Adams REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-01 I Rev. X Title Environmental Monitoring Group Kewaunee Nuclear Power Plant Organization and Responsibilities Emergency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 7 5.0 Procedure 5.1 Environmental Protection Director (EPD) responsibilities:

5.1.1 IF an Unusual Event has been declared, THEN implement EPIP-EOF-03, "EOF Staff Action for Unusual Event."

5.1.2 IF an Alert, Site Area, or General Emergency has been declared, THEN implement EPIP-EOF-04, "EOF Staff Action for Alert or Higher."

5.2 The Dose Projection Calculator (DPC) shall:

5.2.1 Report to the EPD upon arrival at the Emergency Operations Facility (EOF).

5.2.2 Assist the EPD in the activation of the Environmental Dispatch Area using Form EPIPF-ENV-01-01, "Environmental Dispatch Area Activation Checklist."

5.2.3 During the initial facility activation, complete applicable portions of Form EPIPF-EOF-08-06, "Radiological Status Report," using the following resources:

5.2.3.1 Information posted on the status boards 5.2.3.2 Meteorological data from the following sources:

a. PPCS/SPDS Computer

b. Green Bay National Weather Service

c. Point Beach Nuclear Plant 5.2.3.3 Obtain current plant status and off-site radiological release information from the following:

a. Engineering/Licensing Coordinator

b. EOF status boards

c. Radiological Analysis Facility (RAF)

d. PPCS/SPDS Computer 5.2.4 Provide the information recorded on Form EPIPF-EOF-08-06 to the following personnel:

a. Environmental Protection Director (EPD)

b. State Radiological Coordinator Liaison (SRCL)

c. Environmental Monitoring Team Coordinator (EMTCD)

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-01 Rev. X Title Environmental Monitoring Group Kewaunee Nuclear Power Plant Organization and Responsibilities Emergency Plan Implementng Procedure Date JUL 31 2003 Page 3 of 7 5.2.5 Update the applicable portions of the form at least every hour (more frequently if conditions are changing) during the first 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of a declared emergency.

5.2.6 After the first 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, update the applicable portions of the form as conditions change.

5.2.7 As directed by the EPD, perform off-site radiological dose projections in accordance with EPIP-ENV-03C, "Dose Projection Using RASCAL Software."

5.2.8 Compare the off-site radiological dose projection results with the following:

a. Off-site radiological dose projection results obtained by the RAF

b. EMT field data 5.2.9 Report the dose projection results and the comparison to the EPD and SRCL.

5.2.10 Assist the EPD and EMTCD as necessary.

5.2.11 Continue dose assessment activities as directed by the EPD.

5.3 The Environmental Monitoring Team Coordinator (EMTCD) shall:

5.3.1 Upon arrival at the Emergency Operations Facility (EOF), report to the EPD.

5.3.2 Assist EPD in the activation of the Environmental Dispatch area using Form EPIPF-ENV-01-01, "Environmental Dispatch Area Activation Checklist."

5.3.3 Obtain meteorological and plant status information from the Dose Projection Calculator (DPC) AND complete Form EPIPF-ENV-01-03, "Meteorological and Plant Status Data."

5.3.3.1 IF all of the following meteorological conditions exist, THEN the potential for a lake breeze effect exists.

a. KNPP or Point Beach Nuclear Plant (PBNP) wind direction is between 020 and 170 degrees, AND

b. Green Bay National Weather Service or PBNP Inland Tower wind direction is between 210 and 330 degrees, AND

c. The time is between 0700 and 2000.

5.3.3.2 IF a potential for a lake breeze effect exists, THEN direct EMTs to verify the plume has NOT traveled in a northern or southern direction along the lakeshore.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-01 I Rev. X

Title Environmental Monitoring Group Kewaunee Nuclear Power Plant Organization and Responsibilities Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 4 of 7 5.3.4 Draw the projected plume on the Emergency Planning Zone (EPZ) grid map located in the Environmental Dispatch Area using the following:

5.3.4.1 Wind direction as the projected plume centerline 5.3.4.2 The projected plume boundaries (based on the stability class) as the lateral edges 5.3.5 Direct the Environmental Monitoring Team Communicator (EMTCM) to establish and maintain communications with the EMTs.

5.3.6 With EPD concurrence, develop a strategy and EMT orders for the following:

a. Plume tracking

b. Sample collection

c. Sample analysis 5.3.7 Relay the strategy to the EMTs through the EMTCM.

5.3.8 Obtain a copy of Form EPIPF-ENV-01-02, "EMT Status," from the EMTCM.

• Team Designation and team members' names

• Standing Order implemented by each team

• Current Annual Dose (TEDE)

• Date and Time Activated

• Team Status (EMT activities in progress including order being implemented by each team, team location, etc.)

5.3.9 Direct the EMTCM to provide the EMTs with initial and updated meteorological and plant status information using EPLPF-ENV-01-03, "Meteorological and Plant Status Data."

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-01 Rev. X Title Environmental Monitoring Group Kewaunee Nuclear Power Plant Organization and Responsibilities Emergency Plan Implementing Procedure Date JUL 31 2003 1 Page 5 of 7 Note EnvironmentalMonitoring Teams (EMTs) should NOT enter areaswhere projected or measured external radiationdose rates exceed I RIhr without specific directionfrom the EPD or RPD.

Note EMT members are instructedto report exposure every hour or when 100 mrem has been received.

5.3.10 Track the cumulative radiation exposure for each EMT member as follows:

5.3.10.1 Obtain deep dose equivalent (DDE) from EMTs every hour.

5.3.10.2 Add the DDE to the current annual TEDE.

5.3.10.3 Direct the EMTCM to periodically report the sum of the current annual TEDE and cumulative DDE to the EMT members.

5.3.11 IF the sum of the current annual TEDE and cumulative DDE approaches administrative limits, THEN consider authorization for increased radiation exposure in accordance with NAD-01.11, "Dosimetry and Personnel Monitoring."

5.3.12 IF radiological conditions are such that EMTs could exceed 10CFR20 limits THEN consider emergency exposure in accordance with EPIP-AD-1 1, "Emergency Radiation Controls."

5.3.13 EMTs should verify adequate supply available and wear radiological protective clothing when directed by the EMT Coordinator.

5.3.14 Ensure that all data received from the EMTs is provided to the EPD and DPC in a timely manner.

5.3.15 Plot EMT field data on the EPZ grid map in the Environmental Dispatch Area.

5.3.16 Continue monitoring team activities as directed by the EPD.

5.4 Environmental Monitoring Team Communicator (EMTCM) duties:

5.4.1 Upon arrival at the EOF, report to the EMTCD.

5.4.2 Assist in the activation of the Environmental Dispatch Area using Form EPIPF-ENV-01-01, "Environmental Dispatch Area Activation Checklist."

5.4.3 Establish communications with each activated EMT.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPEP-ENV-01 I Rev. X Title Environmental Monitoring Group Kewaunee Nuclear Power Plant Organization and Responsibilities Emergency Plan Implementing Procedure Date JUL 31 2003 Page 6 of 7 5.4.4 Obtain the information required on EPIP-ENV-01-02, "EMT Status," from the EMTs AND forward the form to the EMTCD.

5.4.5 Transmit orders and other information from the EMTCD to the EMTs using the following:

a. Fax

b. Cellular phone

c. Radio 5.4.6 Record information from the EMTs on form EPIPF-ENV-01-04, "EMT Orders/Field Data," and forward the form to the EMTCD.

5.4.7 Perform the responsibilities of the EMTCM as long as the EMTs are activated.

5.5 The Environmental Monitoring Team (EMT) members shall:

5.5.1 Activate EMTs in accordance with "Environmental Monitoring Team Activation,"

EPIP-ENV-02.

5.5.2 Implement EPIP-ENV-04D, "Plume Tracking for Environmental Monitoring Teams."

6.0 Final Conditions 6.1 Plant Emergency has been Terminated or Recovery actions have begun and the Emergency Response Manager has suspended the use of EPIPs.

7.0 References 7.1 KNPP Emergency Plan (Appendix D: Letters of Agreement) 7.2 EPIP-AD-1 1, Emergency Radiation Controls 7.3 EPIP-ENV-02, Environmental Monitoring Team Activation 7.4 EPIP-ENV-03C, Dose Projection Using RASCAL Software 7.5 EPIP-ENV-04D, Plume Tracking for Environmental Monitoring Teams 7.6 EPIP-EOF-03, EOF Staff Action for Unusual Event 7.7 EPIP-EOF-04, EOF Staff Action for Alert or Higher 7.8 NAD-0 1.11, Dosimetry and Personnel Monitoring REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-01 Rev. X Title Environmental Monitoring Group Kewaunee Nuclear Power Plant Organization and Responsibilities Emergency Plan Implementing Procedure Date JUL 31 2003 Page 7 of 7 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• Environmental Dispatch Area Activation Checklist, Form EPIPF-ENV-01-01

• EMT Status, Form EPIPF-ENV-01-02

• Meteorological and Plant Status Data, Form EPIPF-ENV-01-03

• EMT Orders/Field Data, Form EPIPF-ENV-01-04

• Radiological Status Report, Form EPIPF-EOF-08-06 8.1.2 Non-OA Records None REFERENCE USE

't WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-02 IRev. Y Title Environmental Monitoring Team

-- Kewaunee Nuclear Power Plant Activation Emergency Plan Implementing Procedure Date JUL 31 2003 1 Page 1 of 2 Reviewed By Brent Doering Approved By Jerrie Morlino s Saflety a Yes PORC ew Yes SRO Approval Of 3 Yes Safety Review Temporary Related 0 No Required 0 No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for timely activation of the Environmental Monitoring Teams (EMTs) at the Site Boundary Facility (SBF).

2.0 General Notes 2.1 None 3.0 Precautions and Limitations Note Keys for all SBF doors and cabinets are kept in the RadiationProtection Office (RPO) and will be brought to the facility by the SBF Coordinatorwhen he responds.

Keys for the front door only are maintained in security.

3.1 IF the SBF is locked, THEN obtain the key from the Security Building.

4.0 Initial Conditions 4.1 This procedure may be implemented at the declaration of an Unusual Event.

4.2 The EMTs shall be activated when an emergency has been classified as an Alert, a Site Emergency, or General Emergency.

5.0 Procedure 5.1 Activation Leader 5.1.1 The first EMT member arriving at the SBF will assume the responsibility of the Activation Leader and shall complete the following steps:

5.1.2 Place his/her name on the EMT status board at the SBF.

5.1.3 If appropriate, then relinquish the duty of activation leader to a more senior EMT member upon his/her arrival and note the turnover on the EMT status board.

J:\appdata~procpws\draft\epip\eenvO2.doc-Dori Ziegler/Dori Ziegler-Rick Adams REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-02 Rev. Y Title Environmental Monitoring Team Kewaunee Nuclear Power Plant Activation Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 2 of 2 5.1.4 Assign the EMT personnel to teams as they arrive at the SBF.

a. Staff each team with a minimum of two members, beginning with Team A.

b. IF manpower is sufficient, THEN assign 3 members to each team.

c. IF insufficient numbers of personnel are available, THEN the Activation Leader may assign him/herself to one of the teams.

d. Record EMT assignments on the EMT status board at the SBF.

5.1.5 Direct each team to complete Form EPIPF-ENV-02-01, "EMT Activation Checklist."

5.1.7 Report the names of any remaining EMT members not assigned to a team to the Environmental Monitoring Team Coordinator (EMTCd) or the Radiological Analysis Facility (RAF).

5.1.8 IF problems with the instruments are encountered, THEN contact the SBF Coordinator, Emergency Operations Facility (EOF), or Radiological Assessment Facility (RAF) for assistance.

5.1.9 IF problems with the communications equipment are encountered, THEN contact the Environmental Monitoring Team Coordinator (EMTCd).

5.1.10 WHEN an EMTeam is activated, THEN they should begin performance of EPIP-ENV-04D.

6.0 Final Conditions 6.1 This procedure is complete when all required EMTs are activated and operational.

7.0 References 7.5 EPIP-ENV-04D, Plume Tracking for Environmental Monitoring Teams 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• EMT Activation Checklist, Form EPLPF-ENV-02-01 8.1.2 Non-QA Records None REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04A Rev. U Title Portable Survey Instrument Use Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 1 of 6 Reviewed By Michael Gagnon Approved By Jerrie Morlino Nuclear Y I PORC Y I SR0 Approval Of O Yes Safety es Review es Temporary Related El No Required 0 No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for using portable survey instruments used by the Environmental Monitoring Teams (EMTs).

2.0 General Notes 2.1 Environmental Monitoring Teams are responsible for following this procedure when using portable survey instruments.

3.0 Precautions and Limitations 3.1 Do not wrap, in plastic, the detector of any instrument that can be used to measure Beta radiation. Wrapping the detector in plastic during operation may shield Beta radiation.

Instruments and their detectors may be placed in a plastic bag to prevent contamination while being transported.

3.2 Each instrument and its attached detector have been calibrated as a set. DO NOT interchange instruments and detectors unless authorized by the Radiation Protection Group.

Interchanging instruments and detectors invalidates the instrument/detector calibration.

3.3 EMTs should verify an adequate supply available and wear protective clothing when directed by the EMT Coordinator based on known or suspected contamination.

3.4 All of the radiological sampling instruments are electronic devices, therefore, care should be taken to keep them dry. Moisture may make them perform erratically and may result in shorts that may pose personal injury potential. (OTH 8801) 4.0 Initial Conditions 4.1 This procedure is used during a declared plant emergency by the EMTs when operating portable survey instruments.

j:\appdata\procpws\draft\epip\eenvO4a.doc-Amy Kudick/Amy Kudick-Doug Piper REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04A IRev. U Title Portable Survey Instrument Use Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure I Date JUL 31 2003 I Page 2 of 6 5.0 Procedure Note Preoperationalinstrument checks are documented on Form EPIPF-ENV-02-01, "EMTActivation Checklist."

Note IF any instrumentfails a preoperationalcheck, THEN obtain a spare instrument OR contact the RPO/RAFfor assistance.

5.1 Prior to using any portable survey instruments, perform a preoperational instrument check which consists of:

• Inspecting the instrument for deterioration or defect (frayed electrical connections, broken meter face, etc.).

• Verifying the instrument has been calibrated within the due date listed on the instrument calibration sticker.

• Verifying the batteries are satisfactory.

• Verify/adjust zero adjustment (as applicable)

• Verifying the instrument response to a check source is satisfactory.

5.2 Ion Chamber Use 5.2.1 Turn the function switch to check the battery(s).

5.2.1.1 IF the battery(s) level indicates satisfactory, THEN use the instrument. Otherwise replace the battery(s) and recheck battery level.

Note The zero setting may be checked in any radiationfield. ForALARA, this should be done in a low backgroundarea.

5.2.2 IF the instrument has a zero knob, THEN perform the following:

• Turn the function switch to the ZERO position.

• Check that the meter reads zero. If not, set it to zero with the ZERO knob.

5.2.3 Perform a source check of the instrument and ensure the meter reads within +/-20% of the check source value as specified on the calibration sticker.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04A I Rev. U Title Portable Survey Instrument Use Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 3 of 6 5.2.4 Set the function switch to the desired range of operation. The switch position selected is usually the full scale reading of that range.

5.2.4.1 The effective center of the ion chamber is usually marked by dimples at the front and sides of the instrument case. Otherwise the center can be found by looking at it with the window open.

5.2.4.2 Do not expose the instrument to fields of radiation significantly above full scale for the range selected or damage may result.

5.2.5 When measuring Beta, open the sliding Beta shield on the bottom of the case and face the bottom of the instrument toward the radiation source. Multiply the Beta Correction Factor value listed on the calibration sticker by the difference of window open minus window closed readings to determine the Beta dose rate in mRAD/hr.

5.2.5.1 To open or close the shield, depress the friction release button and manually move the slide, or let it fall due to gravity. When the shield is open, protect the thin mylar face against puncture damage.

5.2.6 Perform a radiation survey.

Note Survey readings are normally taken with the Beta window closed (Gamma only).

Note A high Beta/Gamma ratio at 1 meter indicates the presence of the plume at ground level (an airsample may be warranted).

Note A high Beta/Gamma ratio at 3 inches indicatesground deposition (environmental sampling may be warranted).

Note No large Beta/Gamma ratio indicates the plume may be overhead, weak, or you are not in the plume.

a. Determine the Gamma radiation level.

1. Hold the detector, with the Beta window closed, approximately 1 meter above the ground.

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b. Determine the corrected Beta radiation level.

1. With the Beta window open, hold the survey meter approximately 1 meter above ground to determine the Beta/Gamma reading.

2. Subtract the reading taken in Step 5.2.6.a.1 from the reading taken in Step 5.2.6.b.1 to obtain the uncorrected Beta reading.

(Uncorrected Beta reading = Beta/Gamma reading - Gamma reading)

3. Multiply the uncorrected Beta reading obtained in Step 5.2.6.b.2 by the Beta Correction Factor (BCF) listed on the instrument calibration sticker to obtain the corrected Beta radiation level.

(Corrected Beta radiation level = uncorrected Beta reading x BCF)

Note Higher correctedBeta radiationlevels at 3 "as compared to I meter indicate the presence of ground deposition.

5.2.7 Determine the presence of ground deposition.

a. Perform Steps 5.2.6.a and 5.2.6.b holding the detector at 1 meter AND approximately 3" above the ground.

b. Compare the corrected Beta reading taken at 3" to the reading taken at 1 meter.

5.3 Operate the ASP-I with the HP-260 Detector 5.3.1 Perform a battery check.

a. Place the selector switch to the BATTERY CHECK position.

b. Confirm the meter indicates within the "BATT OK" area.

1. IF NOT OK, THEN the batteries need to be replaced.

5.3.2 Perform an instrument response to a check source.

Note Readings are sensitive to the check source/sampleposition on the detector. The instrument response to a check source reading should be within +/-20%of the requiredcheck source reading written on the calibrationsticker.

a. Place the HP-260 detector directly on contact with the check source.

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b. Place the SELECTOR switch to a setting that gives an upscale reading, approximately 50% of full scale.

c. Compare the check source reading with the required check source reading on the instrument calibration sticker.

5.3.3 Perform a contamination survey.

Note IF meter readings are erratic, instrument may need to be operatedin the slow response mode of operation.

a. Place the FAST/SLOW instrument response switch to the FAST position.

b. Hold the detector within 1/2" from the surface (ground, equipment, personnel, etc.) to be surveyed.

c. Move the detector over the surface to be surveyed at a rate of approximately 2" per second.

d. Continuously monitor the meter reading and adjust the SELECTOR switch multiplication factor so that the meter reads approximately 50% of full scale.

e. Multiply the meter reading by the selected multiplication factor to determine the contamination level in counts per minute (CPM).

5.3.4 Perform analysis of air sample media.

a. Place the FAST/SLOW instrument response switch to the FAST position.

b. Place the HP-260 detector directly on contact with either the filter paper or the iodine sampling canister to be monitored.

c. Place the selector switch to the lowest range that does not produce an off-scale reading.

Note IF meter readings are erratic, instrument may need to be operatedin the slow response mode of operation.

d. Obtain the stabilized reading and multiply it by the selected multiplication factor to determine the gross Counts Per Minute (CPM) for the sample.

e. Subtract the background CPM from the value obtained in Step d above to determine the net CPM.

6.0 Final Conditions

- 6.1 Plant Emergency has been terminated or Recovery actions have begun and the Emergency Response Manager has suspended the use of EPIPs.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04A l Rev. U Title Portable Survey Instrument Use Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 6 of 6 7.0 References 7.1 HP-06.xxx, Instrument Operating Procedure Series Procedures 7.2 INPO 91-014, Rev. 01, Guidelines for Radiological Protection at Nuclear Power Stations, October 1995 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records None 8.1.2 Non-OA Records None REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04B I Rev. Y Title Air Sampling and Analysis Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 1 of 15 Reviewed By Michael Gagnon Approved By Jerrie Morlino Nuclear PORC SRO Approval Of Safety O Yes Review 0 Yes Temporary E Yes Related E No Required l No Changes Required E No 1.0 Purpose 1.1 This procedure provides instruction for the Environmental Monitoring Teams (EMTs) for collecting and analyzing air samples during a declared plant emergency.

2.0 General Notes 2.1 The EMTs shall collect and analyze air samples in accordance with this procedure when directed.

3.0 Precautions and Limitations 3.1 Care shall be taken during sample acquisition to prevent sample cross contamination.

3.2 To keep personnel exposure ALARA, the air sampler may be left at the sample location to collect the air sample while the EMT waits in a low-dose area.

3.3 EMTs shall NOT enter areas where projected or measured external radiation dose rates exceed 1 R/hr without receiving specific directions to enter the area, as approved by the Environmental Protection Director (EPD) or Radiological Protection Director (RPD).

3.4 EMTs should always verify adequate supply of and wear protective clothing when directed by the EMT Coordinator based on known or suspected contamination.

3.5 EMTs should always wear a reflective vest when performing EMT duties, especially when outside of the vehicle to obtain samples.

4.0 Initial Conditions 4.1 This procedure is used during a declared plant emergency by the EMTs when the teams are directed to collect and/or analyze environmental air samples.

j:\appdata\procpws\dratt\epip\eenvO4b.doc-Amy Kudick/Amy Kudick-Doug Piper REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04B Rev. Y Title Air Sampling and Analysis Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 15 5.0 Procedure 5.1 Prepare for Air Sample Collection Note Whenever practical,perform Steps 5.1.1 and 5.1.2 priorto going to the sample location.

5.1.1 Obtain a 2-inch (Gelman) filter paper for particulates, a silver zeolite cartridge for iodine, and a Marinelli beaker for noble gas samples.

5.1.2 Prepare the air sampler for sample collection.

Note The airsamplers are storedin a "ready configuration," meaning Steps "a" through "e" are complete. Begin with Step "'f" Steps "a" through "e" are included in case complete disassembly and re-assembly are necessary.

a. Attach the blue cartridge housing (large diameter threaded end) to the air sampler inlet.

b. Attach one of the gold filter housings to the blue cartridge housing.

c. Attach the gold coupler to the gold filter housing.

d. Attach one end of a tygon tube to the gold coupler and the other end to the outlet port of the Marinelli beaker.

e. Attach one end of a second tygon tube to the inlet port of the Marinelli beaker and the other end to the blue cartridge housing (small gold diameter threaded end).

f. Verify that the inlet and outlet stop-cocks on the Marinelli beaker are fully open (parallel to flow).

g. Insert a silver zeolite cartridge into the blue cartridge housing with the arrow on the cartridge pointing in the direction of air flow.

1. IF an air gap exists between the silver zeolite cartridge and the blue cartridge housing, THEN place a cartridge seal ring around the silver zeolite cartridge.

h. Attach the second gold filter housing to the blue cartridge housing.

i. With a pen, gently mark an "X" on one side of a particulate filter.

j. Insert the particulate filter into the second gold filter housing over the vents with the marked "X" side facing out, ensuring that the filter is placed into the filter housing side recessed to accept it.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPLP-ENV-04B Rev. Y Title Air Sampling and Analysis Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 15

k. Attach the gold filter retaining ring to the gold filter housing.

1. Verify that the cartridge and filter housings are sealed tightly so that no air will bypass it during sampling.

5.2 Collect an Air Sample Note Air samples are normally collected at locations on the plume centerline. Plume centerline is located at the point where the highest Gamma radiationlevels are observed while traversingthe plume.

5.2.1 Drive to the air sample location.

5.2.2 Measure the Gamma radiation levels (dose rates) using the ion chamber with the window closed, while en route to the sample location.

Note Do not collect an airsample at a location where submersion in the plume is not verified unless specifically instructed to take such action by the Environmental Monitoring Team Coordinator(EMTCd).

5.2.3 Verify submersion in the plume by determining the corrected Beta radiation level at the sample location.

a. Determine the Gamma level.

1. Hold the detector, with the Beta window closed, approximately 1 meter above the ground.

b. Determine the corrected Beta radiation level.

1. With the Beta window open, hold the survey detector approximately 1 meter above ground to determine the Beta/Gamma reading.

2. Subtract the reading taken in Step 5.2.3.a from the reading taken in Step 5.2.3.b.1 to obtain the uncorrected Beta reading.

(Uncorrected Beta reading = Beta/Gamma reading - Gamma reading)

3. Multiply the uncorrected Beta reading obtained in Step 5.2.3.b.2 by the Beta Correction Factor (BCF) listed on the instrument calibration sticker to obtain the correct Beta radiation level.

(Corrected Beta radiation level = uncorrected Beta reading x BCF)

c. IF Step 5.2.3.b.3 above results in a positive (greater than zero) corrected Beta radiation level, THEN submersion in the plume is verified.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04B Rev. Y Title Air Sampling and Analysis Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 4 of 15 5.2.4 Record date and time, sample location (grid coordinates), sample type and Gamma radiation level (dose rate) on Form EPIPF-ENV-01-04, EMT Orders/Field Data or on Attachment A of EPIP-ENV-04D, EMT Standing Order SO-1.

5.2.5 Operate the air sampler to collect an air sample.

a. Verify the number listed on the instrument calibration sticker for particulate, iodine, and noble gas samples is dialed in on the air sampler thumbwheel switches.

b. Place the ON/OFF power switch in the ON position (toggle switch).

c. Start the air sampler by pressing the START button (black).

Note Team should exit the plume while waitingfor airsample collection to be completed, to reduce potentialfor exposure.

d. Record the sample collection start time on a radioactive sample tag.

Note The airsamplerwill automaticallyshut off when 300 liters of airsample is collected.

e. WHEN the air sampler shuts off, then fully close both the inlet and outlet stop-cocks to the Marinelli beaker (perpendicular to flow).

f. Record the sample collection end time on the radioactive sample tag.

g. Record the number from the air sampler LED readout on the radioactive sample tag.

h. Place the air sampling equipment in a poly bag and place in the EMT vehicle.

5.2.6 Go to a location with background Gamma radiation levels (outside the plume) prior to performing sample analysis or labeling and bagging samples (Steps 5.3 and 5.4).

5.2.7 IF directed by the EMTCd, THEN collect an alternate gross-air grab sample.

a. Don a clean pair of rubber gloves.

b. Obtain a water-filled, one liter bottle from the EMT kit.

c. Remove the cap and invert the bottle.

Note Maintain the bottle inverted until the cap is replaced.

d. Allow the water to empty onto the ground.

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WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04B Rev. Y Title Air Sampling and Analysis Kewaunee Nuclear Power Plant Emergency PlanImplementing Procedure Date JUL312003 Page 5 of 15

e. Recap the bottle tightly.

f. Place the bottle in clean poly bag.

g. Proceed to a location with background Gamma radiation levels.

h. Complete the radioactive sample tag with the following information:

• Sample location (to the nearest one-half of a grid coordinate)

• General area dose rate (mR/hr) at sample location

• Type of sample (noble gas)

• Date of sample

• Time of sample

• Initials of individual completing the sample tag

i. Place the radioactive sample tag into the poly bag with the one liter bottle.

j. Seal the bag.

k. Using the ion chamber with the window closed, perform an on-contact Gamma radiation dose rate survey of the bag.

1. Label the bag with the on-contact Gamma radiation dose rate.

5.3 Analyze an Air Sample Note Analyze the sample only when located in an area with background Gamma radiationlevels (outside the plume). Don a clean pairof rubber gloves priorto handling samples.

5.3.1 Count a silver zeolite cartridge (1-131 sample).

a. Using EPIP-ENV-04A, prepare the ASP-1, with HP-260 probe, or equivalent, for a silver zeolite cartridge sample.

b. Determine the background CPM for the area where you are doing the analysis.

c. Place the HP-260 probe directly on the upstream side of the silver zeolite cartridge.

d. Determine the CPM reading for the sample.

e. Subtract the background reading from the sample reading to determine the net CPM for the sample. Record this value as the net CPM for the sample.

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WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04B Rev. Y Title Air Sampling and Analysis Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 6 of 15

f. Using the graphs in Attachment A, determine the I-131 concentration (ItCi/cc) for the sample. Record this value on Form EPIP-ENV-01-04, "EMT Orders/Field Data."

g. Label and bag the silver zeolite cartridge sample according to Step 5.4 of this procedure.

5.3.2 Count a particulate filter (particulate sample).

a. Using EPIP-ENV-04A, prepare the ASP-I with HP-260 probe, or equivalent, for a particulate filter sample.

b. Determine the background CPM for the area where you are doing the analysis.

c. Place the HP-260 probe directly on the upstream side of the particulate filter.

d. Determine the CPM reading for the sample.

e. Subtract the background reading from the sample reading to determine the net CPM for the sample. Record this value as the net CPM for the sample.

f. Using the graphs in Attachment B, determine the particulate concentration (pCi/cc) for the sample. Record this value on Form EPIP-ENV-01-04, "EMT Orders/Field Data."

g. Label and bag the particulate filter sample according to Step 5.4 of this procedure.

5.3.3 Analyze a Marinelli beaker noble gas sample.

a. Label and bag the Marinelli beaker gas sample according to Step 5.4 of this procedure.

5.4 Label and Bag Air Samples Note Label and bag the airsamples when at a location with background Gamma radiationlevels (outside the plume) and use a clean pairof gloves.

5.4.1 Place the particulate filter sample in a small poly bag.

5.4.2 Place the silver zeolite cartridge sample in the same poly bag with the particular filter.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04B Rev. Y Title Air Sampling and Analysis Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 7 of 15 5.4.3 Complete a radioactive sample tag with the following information:

• Sample location (to the nearest one-half of a grid coordinate)

• General area dose rate (mR/hr) at sample location

• Type of sample(s) (iodine, particulate, and noble gas)

• Date

• Time sample started

• Time sample ended

• Flow rate of air sampler (from air sampler calibration sticker)

• Initials of individual completing the sample tag 5.4.4 Place the radioactive sample tag in the poly bag with the particulate filter sample and silver zeolite cartridge sample.

5.4.5 Seal the poly bag.

5.4.6 Place the bag in the deep well of the Marinelli beaker noble gas sample.

5.4.7 Place the bagged particulate filter sample, silver zeolite cartridge sample, and the Marinelli beaker noble gas sample into a larger clean poly bag.

5.4.8 Seal the outermost poly bag.

5.4.9 Using the ion chamber with the window closed, perform an on-contact Gamma radiation dose rate survey of the outermost bag.

5.4.10 Label the outermost bag with the on-contact Gamma radiation dose rate.

5.5 Verify that the following information is recorded for all air sample analysis results on Form EPIPF-ENV-01-04, "EMT Orders/Field Data:"

• Sample date and time

• Sample location (to the nearest one-half of a grid coordinate)

• Sample type (iodine, particulate, noble gas, or dose rate)

• Readings (general area dose rate in mR/hr or net sample analysis results in ACi/cc) 5.6 Report all air-sample analysis results to the EMTCd via fax, telephone, or radio using Form EPIPF-ENV-01-04, "EMT Orders/Field Data."

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04B Rev. Y Title Air Sampling and Analysis Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 8 of 15 5.7 Deliver air sample to KNPP Security Building or alternate location, if directed.

5.8 While you are en route, notify the RPO/RAF via radio or cellular telephone that air samples will be delivered and estimated time of air sample delivery.

6.0 Final Conditions 6.1 This procedure is complete when all orders (EMT Standing Order SO-1, Attachment A of EPIP-ENV-04D, or "EMT Orders/Field Data," Form EPIPF-ENV-01-04) requiring air sampling have been completed, suspended, or terminated, the results have been reported to the EMTCd, and all air samples have been delivered.

7.0 References 7.1 EPIP-ENV-04A, Portable Survey Instrument Use 7.2 EPIP-ENV-04D, Plume Tracking for Environmental Monitoring Teams 7.3 HP-06.043, Battery Powered Air Sampler, Model H-810-B2 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• EMT Orders/Field Data, Form EPIPF-ENV-01-04

• EMT Standing Order SO-1, Attachment A of EPIP-ENV-04D 8.1.2 Non-OA Records

• Radioactive Sample Tags REFERENCE USE

Net CPM vs 1-1 31 Concentration 1.OOOE-06 8.OOOE-07 6.OOOE-07 _ -__

O4.OOOE 2.OOOE _ _ ____

O.OOOE+OO-00_ _ _

O~~~ Oo to 0O <,0O Net CPM Attachment A EPIP-ENV-04B Rev. Y Date: JUL 31 2003 Panns Q nf I1 REFERENCE USE

( ( (

Net CPM Vs 1-131 Concentration 1 .OOOE-05---_

8.OOOE-06-_-- _ _

O6.OOOE-06 O4.OOOE 2.OOOE-06 O.OOOE+ OO00_ _ _ _ __ _ _ _ _ _ _ _

0o

,\

Net CPM Ausacnmenm Aa t:Firl-tiV-Uqt iieV. Y Date: JUL 31 2003 Page 10 of 15 REFERENCE USE

( ( (

Net CPM vs. 1-131 Concentrations 1.OOOE-04  ; 7 L  :; tC'V; L LS f..;. .e itS'r 0

8.OOOE-05 X;S -.. t\E.K- .f..R . 0 A2Xbv ;00 in- ...., < >< ;X-, .- .-

0 6.OOOE-05 tEt dS ;f.. *; StW-:: * , Ce . . .f- XC-7E. .? diC- f f ES C ,) . n.. L 0 4.OOOE-05 ,, e- . ,,, AC,,& ;(.,- - .

2.OOOE-05 ... . .., .... . .. .., . . v. . . .. . .

- . v . f f d ul D E Q i C t - f -- 0 _ X y 7 -. T S T S tS X ;2 \ .

. . ^ .

O.OOOE+00 Net CPM Attachment A EPIP-ENV-048 Rev. Y Date: JUL 31 2003 Page 11 of 15 REFERENCE USE

( (

mR/hr vs. I-131 Concentrations 8.OOOE-05 u 6.OOOE-05 0

• ` 4.OOOE-05 M 2.OOOE-05 O.OOOE+OO 0\0 0 02 . \0 9 00 N( I nlithr Attachment A EPIP-ENV-04B Rev. Y Date: JUL 31 2003 Page 12 of 15 REFERENCE USE

( ( (

Particulate uCi/cc 1.OOOE-07 s-..

..- .- -; - - - - i.- -

8.OOOE-08

' -; " - { - 1 B - " "- s - i ,,,,;' , ,

0 6.OOOE-08 '.'. ' '\' \ M, .0, ,..^,6 , - 'D; '. s /"; _X i '." , ', 0- - , .

0 m 4.OOOE-08 2.OOOE-08 O.OOOE+00 0~ R9i00 S, 5z 4'61 Z00 o0 Nq3 (b('P Net CPM

^1n 2h-al A NDID_=K l~lnat. V  : J-U. - - -u . g 13 f 1 GI Qf-Ir--r-V4V'Vr4D rIeV. T Rate:

JUL FE ZEU Page 13 of 15 REFERENCE USE

( (

Particulate uCi/cc 1.OOOE-06 8.OOOE-07 0

6.OOOE-07 S .-. - -,-. - ,,- - X ,-. -  :--:. -  :,-::.. -

CE)

;=:. S- ,  : L q .t. ._ . .

4.OOOE-07 0U .......................... i . ;: ,: f-,. W.y-: i

.- :.-.,L X-.- ,,

2.OOOE-07 O.OOOE+00 0~

9,~

Net CPM A"--.--. -% r,.r. . . - - - . - . .. - - - -

MLIOWIIM~UM 0 r-IIt-~riV-Uqt3 1eV. T' Date: JUL 31 2003 Page 14 of 15 REFERENCE USE

(

Particulate uCi/cc 8.OOOE-06 8 . 0 0 0 E- 0 6  ;  ; XXXX 7.OOOE-06--

4.000OE -06 O 4.OOE06 3 .000E 06 -- - - -.

2.OOOE-06 0.OOQE+00- __

Net CPM Attachment B EPIP-ENV-04B Rev. Y Date: JUL 31 2003 Page 15 of 15 REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04C Rev. Y Title Ground Deposition Sampling and Analysis Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 1 of 5 Reviewed By Michael Gagnon Approved By Jerrie Morlino Nuclear PORC SRO Approval Of Safety O Yes Review 0 Yes Temporary 0 Yes Related 0 No Required 0Z No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for performing ground deposition sampling and analysis during a declared plant emergency.

2.0 General Notes 2.1 The Environmental Monitoring Teams (EMTs) shall collect and analyze ground deposition samples in accordance with this procedure when directed.

2.2 Environmental Inc. (Midwest Lab.) (Previously Teledyne) (847-564-0700) shall be contacted for more detailed soil/vegetation/water/snow samples.

3.0 Precautions and Limitations 3.1 Wear rubber gloves while collecting all samples listed below and change gloves frequently to prevent sample cross contamination. EMTs should verify adequate supply available and wear protective clothing when directed by the EMT Coordinator based on known or suspected contamination.

3.2 Do NOT use plastic to wrap the detector of any instrument used to measure Beta radiation.

Wrapping the detector in plastic during operation may shield Beta radiation. Instruments and their detectors may be placed in a plastic bag to prevent contamination while being transported.

3.3 EMTs shall NOT enter areas where projected or measured external radiation dose rates exceed 1 R/hr without receiving specific directions to enter the area, as approved by the Environmental Protection Director (EPD) or Radiological Protection Director (RPD).

3.4 Each instrument and its attached probe have been calibrated as a set. Do NOT interchange instruments and probes unless authorized by the Radiation Protection Group. Interchanging instruments and probes invalidates the instrument/probe calibration.

3.5 EMTs should always wear a reflective vest when performing EMT duties, especially when outside of the vehicle to obtain samples.

4.0 Initial Conditions 4.1 This procedure is to be used during a declared plant emergency by the EMTs when the teams are directed to collect and/or analyze ground deposition samples.

j:.\appdata\procpws\draft\epip\eenvO4c.doc-Amy Kudick/Amy Kudick-Doug Piper REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04C Rev. Y Kewaunee Nuclear Power Plant Title Ground Deposition Sampling and Analysis EmIergency Plan Implementing Procedure FDate JUL 31 2003 Page 2 of 5 5.0 Procedure 5.1 Ground Deposition Screening Techniques Note Background readings on roads and mostfields will rangefrom 10 to 150 CPM.

Therefore, 300 CPM was selected as a reasonableaction level.

5.1.1 IF directed to a specific sample location, THEN travel to that sample location.

5.1.2 IF directed to determine the presence of ground deposition, THEN reference EPIP-ENV-04A, Step 5.2.7.

5.1.3 Measure the Gamma radiation level (dose rate) using the ion chamber closed window while en route to the sample location.

5.1.4 Record the dose rate, time, and sample location on Form EPIPF-ENV-01-04, "EMT Orders/Field Data."

5.1.5 Select a representative surface from which a smear sample could be obtained (i.e., road pavement or other horizontal surface).

5.1.6 Perform a survey of the surface using an ASP-1 with the HP-260 probe.

Note IF meter readings are erratic, instrument may need to be operatedin the slow response mode of operation.

a. Place the FAST/SLOW instrument response switch to the FAST position.

b. Hold the detector within 1/2/2-inch from the surface to be surveyed.

c. Move the detector over the surface to be surveyed at a rate of approximately 2 inches per second.

d. Continuously monitor the meter reading and adjust the selector switch multiplication factor to the lowest range that does not produce an off-scale reading.

e. Multiply the meter reading by the selected multiplication factor to determine the contamination level in counts per minute (CPM).

f. IF the reading obtained in Step 5.1.6.e above is 300 CPM or greater, THEN perform Step 5.2 of this procedure.

g. IF the meter reading obtained in above Step 5.1 .6.e is less than 300 CPM, THEN go to next sample location (if any) and repeat Step 5.1 above.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04C IRev. Y Title Ground Deposition Sampling and Analysis Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 5 5.2 Collect Ground Deposition Samples 5.2.1 Collect a smear sample from the same surface measured in Step 5.1.6.f, Ground Deposition Screening.

Note Put on a clean pairof rubbergloves prior to handling samples.

a. Obtain cloth smear disc (NU-CON).

b. Record the following information from the NU-CON cloth smear.

1. Date of sample

2. Time of sample

3. Location of sample

4. Technician (name of individual taking sample)

c. Wipe a 4-inch square or 18-inch "S" shaped area with the cloth smear disc.

d. Fold the smear holding paper in half so that the cloth smear disc is folded onto itself.

e. IF directed, THEN analyze smear per Step 5.3 below.

f. Label and bag smear per Step 5.4 below.

5.3 Analyze Ground Deposition Samples 5.3.1 IF directed, THEN determine the activity (in disintegrations per minute (DPM)) of the ground deposition cloth smear disc sample using an ASP-1 with the HP-260 probe.

Note Count the sample only when located in an area with background Gamma radiationlevels (outside the plume). Don a clean pair of rubbergloves priorto handling samples.

a. Determine the background CPM.

1. Hold the HP-260 probe in the air.

2. Record the results of Step 5.3.1.a.1 above as background (BKGD) CPM.

b. Determine the gross sample CPM.

1. Place the HP-260 probe directly on contact with the cloth smear disc sample (small raised bumps on the detector will prevent contamination of the detector).

2. Record the results of Step 5.3.1 .b. 1 above as gross sample CPM.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04C I Rev. Y Title Ground Deposition Sampling and Analysis Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 4 of 5

c. Determine the net sample CPM.

1. Subtract the background CPM from Step 5.3.1.a.2 above from the cloth smear disc gross sample CPM from Step 5.3.1.b.2.

(Net sample CPM = smear sample CPM - background CPM)

d. Determine the net sample DPM.

1. Multiply the net CPM obtained in Step 5.3.1 .c. 1 above by the efficiency factor (EF) listed on the ASP-1 instrument calibration sticker.

(Net sample DPM = net sample CPM x EF)

e. Record results from Step 5.3.1.d above, as DPMI100 cm 2 or DPM/smear if

< 100 cm 2 area was surveyed on Form EPIPF-ENV-01-04, "EMT Orders/Field Data."

5.3.2 Verify that the following information is recorded for all ground deposition samples on Form EPIPF-ENV-01-04, "EMT Orders/Field Data:"

• Sample date and time

• Sample location (to the nearest one-half of a grid coordinate)

• Sample type (ground deposition or dose rate)

• Readings (sample results in DPM/100 cm2 , DPM/smear, or mR/hr) 5.3.3 Make all ground deposition sample analysis results available to the Environmental Monitoring Team Coordinator (EMTCd) via fax, telephone, or radio using Form EPIPF-ENV-01-04, "EMT Orders/Field Data."

5.4 Label and Bag Ground Deposition Samples 5.4.1 Place each smear sample in a clean poly bag.

5.4.2 Complete the radioactive sample tag.

Note All labels or tags shall contain the following information:

• Sample location (to the nearest one-half of a grid coordinate)

• General area dose rate (mR/hr) at the sample location

• Type of sample (ground deposition)

• Date

• Time sample taken

• Initials of individual completing the sample tag REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04C I Rev. Y

- Title Ground Deposition Sampling and Analysis Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 5 of 5 5.4.3 Place the radioactive sample tag in the bag along with the smear disc.

5.4.4 Seal the bag.

5.4.5 Using the ion chamber with window closed, perform an on-contact Gamma radiation dose rate survey of the bag.

5.4.6 Label the bag with the on-contact Gamma radiation dose rate.

5.4.7 Unless otherwise directed, deliver the ground deposition samples to the KNPP Security Building. Notify the RPO/RAF of the estimate delivery time.

5.4.8 While en route, notify the RPO/RAF via radio or cellular telephone that ground deposition samples will be delivered and estimated time of sample delivery.

5.5 IF final conditions as stated in Step 6.1 have not been met, THEN return to Step 5.1 of this procedure.

6.0 Final Conditions 6.1 This procedure is complete when all orders ("EMT Orders/Field Data," Form EPIPF-ENV-01-04) requiring ground deposition sampling have been completed, suspended, or terminated, the results have been reported to the EMTCd, and all samples have been delivered.

7.0 References 7.1 EPIP-ENV-04A, Portable Survey Instrument Use 7.2 EPIP-ENV-04D, Plume Tracking for Environmental Monitoring Teams 7.3 Teledyne Isotopes Letter of Agreement 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 QA Records

• EMT Orders/Field Data, Form EPEPF-ENV-01-04 8.1.2 Non-pA Records

• Radioactive Sample Tags REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPLP-ENV-04D Rev. P Title Plume Tracking for Environmental Kewaunee Nuclear Power Plant Monitoring Teams Emergency Plan Implementing Procedure Date JUL 31 2003 Page 1 of 10 Reviewed By Stan Baker Approved By Jerrie Morlino Nuclear a Yes PORC 0 Yes SRO Approval Of 0 Yes Safety Review Temporary Related 0 No Required 0 No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for locating and tracking an airborne radiological release.

2.0 General Notes 2.1 None 3.0 Precautions and Limitations 3.1 Perform all actions for tracking an airborne radiological release (plume) while keeping personnel exposures As Low As Reasonably Achievable (ALARA).

3.2 Environmental Monitoring Teams (EMTs) shall NOT enter areas where projected or measured external radiation dose rates exceed 1 R/hr without receiving specific directions to enter the area, as approved by the Environmental Protection Director (EPD) or Radiological Protection Director (RPD).

3.3 IF the presence of radioactive iodine in the plume is suspected or detected, THEN refer to EPIP-AD-18, "Potassium Iodide Distribution," for guidance.

3.4 Each instrument and its attached probe have been calibrated as a set. Do NOT interchange instruments and probes unless authorized by the Radiation Group. Interchanging instruments and probes invalidates the instrument/probe calibration.

3.5 EMTs should verify adequate supply available and wear protective clothing when directed by the EMT Coordinator based on known or suspected contamination.

4.0 Initial Conditions 4.1 An emergency has been declared and a radiological release (plume) has occurred, is imminent, or in progress.

4.2 Off-site monitoring may be implemented to confirm that a radiological release (above normal limits) is not occurring.

4.3 EMT activation per EPIP-ENV-02, "Environmental Monitoring Team Activation," is complete.

l:appdataXprocpws'draft\epip\eenvO4d.doc-Dori Ziegler/Dori Ziegler-Rick Adams REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04D Rev. P Title Plume Tracking for Environmental Kewaunee Nuclear Power Plant Monitoring Teams Emergency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 10 5.0 Procedure Note The RPO/RAF should be the firstfacilityfully activated. Therefore initial contacts and direction should come from there. Once the EOF is activatedthen all directions, reporting, and communication should be through the EMT Coordinator.

5.1 Actions for the EMTs 5.1.1 Obtain current annual dose (TEDE) from the Radiation Protection Office (RPO)/

Radiological Analysis Facility (RAF), or Emergency Operations Facility (EOF).

5.1.2 Obtain meteorological data, and status of any radiological release and record on Form EPIPF-ENV-01-03, "Meteorological and Plant Status Data."

5.1.3 IF changes or discrepancies in meteorological or plant conditions are observed, THEN report them to the EMTCd if activated, otherwise inform the RPO/RAF.

Note Environmental Monitoring Teams (EMTs) shall NOT enter areas where projected or measured external radiationdose rates exceed I R/hr without specific directionfrom the EPD or RPD.

Note The first team activated should perform EMT Standing Order SO-I, the second team activated shouldperform EMT Standing Order S0-2, and the thirdteam activated should perform EMT Standing OrderS0-3.

5.1.4 Implement EMT Standing Orders (SO) based on the team designation as follows:

5.1.4.1 Team A, implement SO-1 5.1.4.2 Team B, implement SO-2 5.1.4.3 Team C, implement SO-3 5.1.5 IF any conflicts occur with the performance of orders assigned, THEN immediately contact the EMTCd (if the EOF is activated, otherwise contact the RPO/RAF) for resolution.

5.1.6 Contact the EMTCd, AND 5.1.6.1 Relay the annual dose information for each team member.

5.1.6.2 Obtain meteorological and plant conditions REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04D I Rev. P Title Plume Tracking for Environmental Kewaunee Nuclear Power Plant Monitoring Teams Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 10 5.1.7 Report field data results promptly to the EMTCd or the RPOIRAF.

a. Use the "EMT Field Data" section of Standing Orders to record Gamma and Beta radiation dose rates.

b. Use Form EPIPF-ENV-01-04, "EMT Orders/Field Data," for air sample and ground deposition sample analysis results.

5.1.8 WHEN an order is completed, suspended, or terminated, THEN request additional instructions from EMTCd or RPOIRAF.

5.1.9 Continue field monitoring activities as directed by the EMTCd until relieved or activities are terminated.

6.0 Final Conditions 6.1 This procedure is complete when all EMT orders (Form EPIPF-ENV-01-04, "EMT Orders/Field Data") have been completed or terminated.

7.0 References 7.1 EPIP-AD-18, Potassium Iodide Distribution 7.2 EPIP-ENV-04A, Portable Survey Instrument Use 7.3 EPIP-ENV-04B, Air Sampling and Analysis 7.4 EPIP-ENV-04C, Ground Deposition Sampling and Analysis 7.5 EPIP-ENV-02, Environmental Monitoring Team Activation REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-ENV-04D l Rev. P Title Plume Tracking for Environmental Kewaunee Nuclear Power Plant Monitoring Teams Emergency Plan Implementing Procedure Date JUL 31 2003 Page 4 of 10 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• Meteorological and Plant Status Data, Form EPIPF-ENV-01-03

• EMT Orders/Field Data, Form EPIPF-ENV-01-04

• EMT Standing Order SO-1, Attachment A

• EMT Standing Order SO-2, Attachment B

• EMT Standing Order SO-3, Attachment C

• Emergency Planning Zone (EPZ) Grid Map

• Form HPF-114, Map J-1, Site Map 8.1.2 Non-OA Records None REFERENCE USE

EMT STANDING ORDER SO-1 Page 1 of 2 DATE/TIME:

TEAM (Circle One): A B C ORDER ID: EMI 'STANDING ORDER SO-1 INSTRUCTIONS: (1) Locate the plume centerline in the vicinity of the site boundary by performing Gamma radiation dose rate surveys according to EPIP-ENV-04A, "Portable Survey Instrument Use."

(2) During a radioactive release, read dosimeters every 15 minutes.

Report dosimeter readings every hour or every 100 mrem (whichever comes first) to the EMTCd.

(2) Collect an air sample on plume centerline according to EPIP-ENV-04B, "Air Sampling and Analysis."

(3) Deliver air sample to KNPP Security Building or alternate location, if directed. Notify RPO/RAF of estimated delivery time.

(4) When directed, determine the extent of ground deposition using EPIP-Env-04C, "Ground Deposition Sampling and Analysis."

d .DIRECTIONS FOR REPORTING FIELD DATA:

1. SAMPLE DATE/TIME - Enter date/time dose rate reading was taken, date/time air sample collection was completed, or date/time deposition sample was collected.

2. GRID COORDINATES - Specify sample location to the nearest one-half of a grid coordinate.

3. SAMPLE TYPE - Enter appropriate description.

Iodine (I)

Particulate (P)

Noble Gas (NG)

Dose Rate (DR)

Deposition (DP)

4. READING - Enter reading using correct units.

Dose Rate - mrem/hour Air Sample (Iodine, Particulate, or Noble Gas) - pCi/cc Deposition - dpm/100 cm 2 or dpm/smear if < 100 cm2 is surveyed Attachment A EPIP-ENV-04D Rev. P Date: JUL 31 2003 Page 5 of 10 REFERENCE USE

EMT STANDING ORDER SO-1 Page 2 of 2 EMT FIELD DATA SAMPLE DATE/TIME COORDINATES SAMPLE TYPE READING DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mremn/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mremr/hr DR mrem/hr DR mrem/hr DR mrem/hr Attachment A EPIP-ENV-04D Rev. P Date: JUL 31 2003 Page 6 of 10 REFERENCE USE

EMT STANDING ORDER SO-2 Page 1 of 2 DATE/TIME:

TEAM (Circle One): A B C ORDER ID: EMT STANDING ORDER SO-2 INSTRUCTIONS: (1) Locate and track the leading boundary (edge) of the plume by performing Gamma radiation dose rate surveys according to EPIP-ENV-04A, "Portable Survey Instrument Use."

(2) During a radioactive release, read dosimeters every 15 minutes.

(3) Report dosimeter readings every hour or every 100 mrem (whichever comes first) to the EMTCd.

(4) When directed, determine the extent of ground deposition using EPIP-ENV-04C, "Ground Deposition Sampling and Analysis."

DIRECTIONS FOR REPORTING FIELD DATA:

1. SAMPLE DATE/TIME - Enter date/time dose rate reading was taken, date/time air sample collection was completed, or date/time deposition sample was collected.

2. GRID COORDINATES - Specify sample location to the nearest one-half of a grid coordinate.

3. SAMPLE TYPE - Enter appropriate description.

Iodine (I)

Particulate (P)

Noble Gas (NG)

Dose Rate (DR)

Deposition (DP)

4. READING - Enter reading using correct units.

Dose Rate - mrem/hour Air Sample (Iodine, Particulate, or Noble Gas) - jACi/cc Deposition - dpm/100 cm2 or dpm/smear if < 100 cm2 is surveyed Attachment B EPIP-ENV-04D Rev. P Date: JUL 31 2003 Page 7 of 10 REFERENCE USE

EMT STANDING ORDER SO-2 Page 2 of 2 EMT FIELD DATA SAMPLE DATE/TIME COORDINATES SAMPLE TYPE (mremAr)

DR mrem/hr DR mrem/hr DR irem/hr DR mremhr DR mrem/hr DR mrem/hr DR mren/hr DR mrernhr DR rnrem/hr DR ruemlhr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrern/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mremlhr DR mrem/hr DR mrrem/hr Attachment B EPIP-ENV-04D Rev. P Date: JUL 31 2003 Page 8 of 10 REFERENCE USE

EMT STANDING ORDER SO-3 Page 1 of 2 DATE/TIME:

TEAM (Circle One): A B C ORDER ID: EMT STANDING ORDER SO-3 INSTRUCTIONS: (1) Locate and track the lateral boundaries (edges) of the plume within 5 miles of KNPP by performing Gamma radiation dose rate surveys according to EPIP-ENV-04A, "Portable Survey Instrument Use."

(2) During a radioactive release, read dosimeters every 15 minutes.

Report dosimeter readings every hour or every 100 mrem (whichever comes first) to the EMTCd.

(3) WHEN the release is terminated, THEN locate and track the trailing edge of the plume.

(4) Report Gamma radiation dose rate readings to EMTCd or RPOIRAF every 15 minutes or more frequently, if directed.

(5) When directed, determine the extent of ground deposition using EPIP-ENV-04C, "Ground Deposition Sampling and Analysis."

DIRECTIONS FOR REPORTING FIELD DATA:

1. SAMPLE DATE/TIME - Enter date/time dose rate reading was taken, date/time air sample collection was completed, or date/time deposition sample was collected.

2. GRID COORDINATES - Specify sample location to the nearest one-half of a grid coordinate.

3. SAMPLE TYPE - Enter appropriate description.

Iodine (I)

Particulate (P)

Noble Gas (NG)

Dose Rate (DR)

Deposition (DP)

4. READING - Enter reading using correct units.

Dose Rate - mrem/hour Air Sample (Iodine, Particulate, or Noble Gas) - pCi/cc Deposition - dpm/100 cm 2 or dpm/smear if < 100 cm2 is surveyed Attachment C EPIP-ENV-04D Rev. P Date: JUL 31 2003 Page 9 of 10 REFERENCE USE

EMT STANDING ORDER SO-3 Page 2 of 2 EMT FIELD DATA SAMPLE DATE/TIME GRID SAMPLE TYPE READING COORDINATES (mrenilhr)

DR niremi/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR rmrem/hr DR mrem/hr DR mrem/hr DR mrem/hr DR mremlhr DR mr DR mremhr DR mrem/hr DR ~~~~~mremf/hr DR

_ DR mremffi/hr

~~~~~mrem/hr DR mremfhr DRmemh DR mrem/hr nrem/hr DR mrem/hr DR DRmemh DR mrem/hr Attachment C EPIP-ENV-04D Rev. P Date: JUL 31 2003 Page 10 of 10 REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-02 Rev. AB Title Emergency Operations Facility (EOF)

Kewaunee Nuclear Power Plant Activation Emergency Plan Impkementing Procedure Date JUL 31 2003 Pa e 1 of 4 Reviewed By Bruce Heitzkey Approved By Jerrie Morlino Nuclear PORC SRO Approval Of Safety 0 Yes Review 0 Yes Temporary 0 Yes Related El No Required El No Changes Required El No 1.0 Purpose 1.1 This procedure provides instruction for activating the Emergency Operations Facility (EOF).

2.0 General Notes 2.1 Telephone numbers and location of staff positions for the EOF are located in Section ETD 01A of the KPB Emergency Telephone Directory, located in the EOF bookcase.

2.2 A general description of communications equipment is contained in APPX-A-1, "Communication System Description," and may be helpful in resolving minor problems with the equipment.

3.0 Precautions and Limitations 3.1 If any of the actions on Form EPIPF-EOF-02-01, "EOF Activation Checklist,"

cannot be satisfied in a reasonable period of time, then the problem shall be noted on Form EPIPF-EOF-02-01 and an Action Request (AR) initiated at the next convenient opportunity. Consideration of activation should not be delayed for problems with individual actions on Form EPIPF-EOF-02-01.

3.2 The Emergency Response Manager (ERM) will make the decision whether the EOF can be activated prior to resolution of problems.

3.3 If it becomes necessary to evacuate or relocate the EOF, the ERM should utilize the guidance supplied in Section 5.2 to assist in transferring the functionality of the EOF to an alternate facility.

4.0 Initial Conditions 4.1 The EOF shall be activated for an Alert, Site Emergency, General Emergency, or at the discretion of the ERM.

4.2 Upon activation of the EOF, the Administrative and Logistics Director (ALD) shall assign and complete actions in accordance with this procedure.

J:\appdata\procpws\draft\epip\eeofO2.doc-Dori Ziegler/Dori Ziegler-Jeanne Ferris REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-02 Rev. AB Title Emergency Operations Facility (EOF)

Kewaunee Nuclear Power Plant Activation Emergency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 4 5.0 Procedure 5.1 Activation Note The ALD is responsiblefor ensuring the EOFActivation Checklist is complete and then handing it over to the ERM. However, any person who arrivesshould take the checklist and start the activation.

5.1.1 Complete Form EPIPF-EOF-02-01, "EOF Activation Checklist."

Note The ERM may declare the EOF activated if he has sufficient staff to perform the functions requiredfor the event.

5.1.2 The following positions and functions are recommended to be established at a minimum to declare the EOF activated:

• Emergency Response Manager - for PAR function

• Environmental Protection Director - for dose assessment

• Dose Projection Calculator - for offsite dose calculations

• Offsite Communicator - for communications with the State and Counties for notifications

• ERF Communicator-EOF - for the 4-way communication bridge

• Engineering and Licensing Support - for completion of the Event Notice form

• State Radiological Coordinator Liaison - for radiological communications with the State 5.1.3 IF communications or PC equipment problems are identified, THEN contact WPSC Information Technology Services (ITS) OR Telecommunications as listed in the KPB Emergency Telephone Directory, Section ETD 04, AND state the following:

• Telephone number or system with the problem

• The nature of the problem

• That emergency service is needed 5.1.4 WHEN Form EPIPF-EOF-02-01, "EOF Activation Checklist," (Items 1 through 4) is completed, give the form to the ERM for review and signature.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-02 Rev. AB Title Emergency Operations Facility (EOF)

Kewaunee Nuclear Power Plant Activation Emergency Plan Implementing Procedure Date JUL 31 2003 1 Page 3 of 4 5.2 EOF Evacuation/Relocation 5.2.1 IF it becomes necessary to evacuate or relocate the EOF, THEN the ERM should consider the following in order to maintain the functionality of the EOF:

• EOF Dose Assessment and Protective Action Recommendations may be formulated in the TSC

• Command and control of Environmental Monitoring Teams may be transferred to the TSC

• NRC and State and County communications may be handled from the TSC

• The ERM may reposition to the TSC or the Point Beach EOF in the Point Beach Site Boundary Command Center 5.3 Deactivation 5.3.1 WHEN final conditions are met, complete Form EPIPF-EOF-02-02, "EOF Deactivation Checklist."

5.3.2 WHEN Form EPIPF-EOF-02-02 is completed, give the form to the ERM for review and signature.

6.0 Final Conditions 6.1 Plant Emergency has been Terminated or Recovery actions have begun and the Emergency Response Manager has suspended the use of EPIPs.

7.0 References 7.1 Kewaunee Nuclear Power Plant Emergency Plan 7.2 APPX-A-1, Communication System Description 7.3 KPB Emergency Telephone Directory 7.4 COMTRAK 88-169, Title Markers for the EOF Staff 7.5 NAD-1 1.08, Action Request Process REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPLP-EOF-02 Rev. AB Title Emergency Operations Facility (EOF)

Kewaunee Nuclear Power Plant Activation Emergency Plan Implementing Procedure Date JUL 31 2003 Page 4 of 4 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• Form EPIPF-EOF-02-01, EOF Activation Checklist

• Form EPIPF-EOF-02-02, EOF Deactivation Checklist 8.1.2 Non-OA Records None REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 1 of 13 Reviewed By Bruce Heitzkey Approved By Jerrie Morlino Nuclear OY PORC OY SRO Approval Of Y Safety es Review es Temporary es Related 0 No Required 0 No Changes Required E0 No 1.0 Purpose 1.1 This procedure provides instruction for the Emergency Response Manager and other initial response personnel for an appropriate response to an Unusual Event at the Emergency Operations Facility (EOF).

2.0 General Notes 2.1 At the Unusual Event level, pager activation will be performed by SAS for all designated emergency response directors (primary and alternate).

2.2 IF approached by the media during a declared emergency, THEN refer them to the Joint Public Information Center (JPIC) at 920-433-1400 or 1-800-838-6192 and tell them that this is their most accurate source for information.

'~- 3.0 Precautions and Limitations 3.1 "Event Notice," Form EPIPF-AD-07-01 should be initiated and in progress to state and local emergency governments within 15 minutes of the emergency level being declared or as soon as possible without further compromise to plant or public safety.

3.2 The Emergency Response Manager has the non-delegable responsibility for making protective action recommendations.

3.3 IF an emergency class escalation occurs during implementation of this procedure, THEN proceed immediately to EPIP-EOF-04, "EOF Staff Action for Alert or Higher."

3.4 Only the following personnel may authorize support personnel, without Kewaunee I.D.

cards, access to the EOF during a declared emergency:

3.4.1 Emergency Response Manager (ERM) 3.4.2 Administrative Logistics Directors (ALD) 3.4.3 Environmental Protection Director (EPD) 4.0 Initial Conditions 4.1 This procedure shall be implemented upon declaration of an Unusual Event or when directed by the Emergency Response Manager.

j:\appdata\procpws\draft\epip\eeofO3.doc-Amy Kudick/Dori Ziegler-Jeanne Ferris REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 13 5.0 Procedure Note It is the ERMs responsibilityto provide overall direction and coordination of the KNPPemergency response activities, make protective action recommendationsto government authorities, coordinateefforts with external organizations (governmental, industry, vendors, etc.), and support the plant's efforts to mitigate the accident by ensuring continuity of resourcesfor long-term operation of the emergency response organization.

5.1 Emergency Response Manager (ERM) shall:

5.1.1 WHEN notified that an Emergency has been declared:

a. Report to the Emergency Operations Facility.

b. IF an Emergency Response Manager has been designated, until released, THEN:

1. If appropriate, plan a shift relief per EPIP-AD-05, "Emergency Response Organization Shift Relief Guideline."

2. Assist the designated Emergency Response Manager.

c. IF an Emergency Response Manager has NOT been designated, THEN assume the responsibilities of the Emergency Response Manager and continue implementation of this procedure.

5.1.2 Notify the Emergency Director of your arrival and assumption of the Emergency Response Manager duties.

Note Consider calling in a State Radiological CoordinatorLiaison (SRCL).

5.1.3 Verify the Environment Protection Director (EPD) is prepared to transmit radiological related data and general plant conditions to the State Radiological Coordinator in the State Emergency Operations Center (Madison).

5.1.4 IF director(s) are NOT arriving at the EOF in a reasonable amount of time, THEN instruct the ALD to contact the individuals needed by telephone and/or by their pager number (see Emergency Telephone Directory).

5.1.5 IF a director position cannot be filled, THEN assign the director's duties to another director's position.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 I Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 13 Note The EOFcan be activatedfor individualfunctions, i.e., off-site notifications without full activationof thefacility.

5.1.6 Direct the Administrative Logistics Director (ALD) to contact the appropriate WPSC support personnel to inform them that their assistance is or may be needed. (See Emergency Telephone Directory, Section ETD 04).

5.1.7 If requested by the ED, direct the ALD to complete activation of the EOF appropriate to the nature of the event in accordance with EPIP-EOF-02, "Emergency Operations Facility (EOF) Activation."

5.1.8 Direct the Environmental Protection Director (EPD) to contact the appropriate Environmental Monitoring Team Personnel with instructions to standby for a possible call in.

5.1.9 Establish communications with the Technical Support Center and Control Room through the Darome Conference System.

5.1.10 Verify the status of off-site agency communications that have taken place from the Control Room.

Note The appropriateGovernment Agency contactsfor the ERM are:

• State of Wisconsin - Office in Charge (OIC) @ DialSelect 83 or 608-242-3260/3261

• Kewaunee County - Emergency Government (Director) @ Dial Select 43 or 920-487-5257

• Manitowoc County - Emergency ManagementDirector @ Dial Select 53 or 920-683-4916/4918 5.1.11 WHEN confirmed that the EOF is capable of assuming off-site notification,

a. Assume the responsibility for off-site notification.

b. Inform the ED of the transfer of this responsibility.

c. Contact the State and County EOCs (if active) and notify them that the EOF has the responsibility for off-site communications.

5.1.12 Contact and notify the JPIC Manager of the EOF activation status.

5.1.13 Ensure the KPB Nuclear Emergency Public Information Plan is being implemented for an Unusual Event.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page4of 13 5.1.14 Review requirements for escalation, termination, and recovery situations with the Emergency Director (per EPIP-AD-02, "Emergency Class Determination").

Note Off-site protective actionsfor the public are NOT requiredfor Unusual Events.

5.1.15 As required, instruct the Environmental Protection Director to review off-site dose measurements and projections to ensure the event classification is appropriate.

5.1.16 IF time permits, THEN contact off-site authorities via the Dial Select to discuss potential changes in classification and/or appropriate PAR.

5.1.17 IF notified by the ED of any change in EALs (event escalation), THEN go to EPIP-EOF-04.

5.1.18 WHEN contacted or periodically provide off-site authorities with the following (Dial Select is the preferred communication link):

• Available information on the event status using "Plant Emergency Status Report," Form EPIPF-EOF-08-05, as a guide

• Feedback that verifies and that clarifies the off-site authorities information

• Information on the nature and direction of the event 5.1.19 Contact the ED periodically to receive an update on:

• Status of the plant

• Material and personnel support requirements

• On-site or off-site radiological releases, potential releases, and release paths

• Priorities of tasks to minimize the impact of the accident on the public

• Incidents of public interest (i.e., fires, spills, personnel contamination/injury) 5.1.20 Periodically inform the ED of:

• State and County priorities

• State and County actions (i.e., protective actions, evacuations, traffic control, etc.)

• State and County areas of concern

• Media areas of interest and any misinterpretations of the plant situation REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure lDate JUL 31 2003 Page 5 of 13 5.1.21 Determine the EOF priorities, evaluate activities in the following areas:

• Logistical requirements to mitigate significant plant evolutions

• Off-site consequences

• Protective action recommendations 5.1.22 Brief the EOF Emergency Response Organization periodically.

5.1.23 Ensure that the Plant Spokesperson is informed.

a. Forward plant status and public interest information to the Plant Spokesperson for appropriate use in briefings to the:

• Public

• Media

• WPSR and NMC Senior Management

• Partners

• Other financial stakeholders in KNPP or WPSR

b. Review news statements.

c. Review press conferences.

d. Inform the Plant Spokesperson of any factual errors or ambiguities in the news statements or conferences.

Note In fast breaking events, the ERM may give verbal authorization insteadof written approval to release the statement.

e. Approve news statements prior to being released to the media.

5.1.24 If appropriate, plan for a shift relief per EPIP-AD-05.

5.1.25 If plant conditions meet the requirements of Section 5.1 of EPIP-AD-15, "Recovery Planning and Termination," recovery activities or termination can be implemented in accordance with EPIP-AD-15.

5.1.26 IF Final Conditions are NOT met (Section 6.0), THEN return to Step 5.1.11.

5.1.27 WHEN Final Conditions are met (Section 6.0):

a. IF plant conditions degrade to where the declaration of a higher emergency level is declared or full activation of the EOF is appropriate, TIEN implement EPIP-EOF-04.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 6 of 13

b. IF termination is declared or plant conditions meet the requirements for plant recovery, THEN the ERM shall ensure the following actions are taken:

1. Ensure that termination or plant recovery Event Notifications has been completed in accordance with EPIP-AD-07.

2. Verify that all off-site agencies and support groups who were initially notified were informed of the Unusual Event termination or plant recovery.

3. Ensure each director notifies the personnel he has previously placed on standby.

4. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

5. Collect all completed records, logs, forms, notes, and other documentation and give them to the ALD.

6. Schedule a self-critique with all event participants in the EOF (all shifts) as soon as practical.

A-- 5.2 Administrative Logistics Director (ALD) shall:

5.2.1 WHEN notified that an emergency has been declared,

a. Report to the Emergency Operations Facility immediately.

b. IF an Administrative Logistics Director has been designated, until released, THEN:

1. If appropriate, plan a shift relief per EPIP-AD-05.

2. Assist the designated Administrative Logistics Director.

c. IF an Administrative Logistics Director has NOT been designated, THEN assume the responsibilities of the Administrative Logistics Director and continue implementation of this procedure.

5.2.2 Notify the Emergency Response Manager of your assumption of the responsibilities of the Administrative Logistics Director.

5.2.3 As directed by the ERM:

a. Contact the EOF support personnel or others.

b. Instruct them to report to the EOF immediately or to remain on standby for further instructions.

5.2.4 Complete activation of the EOF appropriate to the nature of the event in accordance with EPLP-EOF-02.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 IRev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 7 of 13 5.2.5 As needed, assign EOF support personnel.

5.2.6 Establish procedures for the long-term storage of the documents, records, and logs generated by the plant.

5.2.7 Ensure that appropriate logs, records, and documents, as directed below, are maintained for the duration of the event. Those logs, records, and documents shall include, but NOT be limited to,

• Ongoing plant status and conditions

• Date and time of significant accident events

• Chronology of plant accident mitigation and repair priorities

• All calculated, measured, or state provided radiological release data and information

• All event notification and status update documents generated

• Any messages generated or recorded

• All PPCS computer printouts generated for status board maintenance or general information

• All logs maintained by EOF directors

• All News statements from the JPIC 5.2.8 Monitor the flow of information in the EOF and correct any problems.

5.2.9 If required, arrange for communication system service repair (See EPIP-EOF-02, Step 5.1.2).

5.2.10 If required, obtain purchasing support (see Emergency Telephone Directory, ETD04 for NMC contact) for assistance in the following:

• Material purchase and control contract negotiations, expense accounts 5.2.11 If needed, provide for the following manpower needs:

• Technical and craft disciplines through organizations such as Westinghouse Electric Corporation, Fluor Engineering, INPO

• If needed, arrange for labor relations assistance 5.2.12 If needed, obtain the following logistical assistance for:

• Transportation of emergency response personnel

• Airline and hotel accommodations REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 8 of 13

• Office supplies and furniture

• Document reproduction

• Food deliveries

• Sanitation 5.2.13 Periodically contact any EOF staff members on standby and update them on the event status.

5.2.14 If appropriate, plan for a shift relief per EPIP-AD-05.

5.2.15 IF Final Conditions are NOT met (Section 6.0), THEN return to Step 5.2.5.

5.2.16 WHEN Final Conditions are met (Section 6.0),

a. IF plant conditions degrade to where the declaration of a higher emergency level is warranted or full activation of the EOF is appropriate, THEN implement EPIP-EOF-04.

b. IF termination is declared or plant conditions meet the requirements for plant recovery, THEN the ALD shall ensure the following actions are taken:

1. Contact any EOF staff members on standby and notify them of the change in event status.

2. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

3. Collect all completed records, logs, forms, notes, and other documentation generated during the course of the event.

4. Ensure "EOF Deactivation Checklist," Form EPIPF-EOF-02-02, is completed per EPIP-EOF-02.

5.3 Environmental Protection Director (EPD) shall:

5.3.1 WHEN notified that an emergency has been declared:

a. Report to the Emergency Operations Facility.

b. IF an Environmental Protection Director has been designated, until released, THEN:

1. If appropriate, plan a shift relief per EPIP-AD-05.

2. Assist the designated Environmental Protection Director.

c. IF an Environmental Protection Director has NOT been designated, THEN assume the responsibilities of the Environmental Protection Director and continue implementation of this procedure.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 9 of 13 5.3.2 Notify the Emergency Response Manager of your assumption of the responsibilities of the Environmental Protection Director.

5.3.3 IF directed by the ERM, THEN contact the environmental team organization and instruct them to standby for possible call in.

5.3.4 Maintain an overall awareness of environmental conditions and the contributing factors for development of protective action recommendations in accordance with procedure EPIP-AD-19.

5.3.5 As necessary, establish and maintain communication with other Emergency Response Organization Directors and Off-Site Authorities.

5.3.6 Periodically contact Environmental staff members on standby and update them on the event status.

5.3.7 If appropriate, plan for a shift relief per EPIP-AD-05.

5.3.8 IF Final Conditions (Section 6.0) are not met, THEN return to Step 5.3.4.

5.3.9 WHEN Final Conditions are met (Section 6.0),

a. IF plant conditions degrade to where the declaration of a higher emergency level is declared or full activation of the EOF is appropriate, THEN implement EPIP-EOF-04.

b. IF termination is declared or plant conditions meet the requirements for plant recovery, THEN the EPD shall ensure the following actions are taken:

1. Contact any Environmental staff members on standby and notify them of the change in event status.

2. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

3. Collect all completed records, logs, forms, notes, and other documentation and give them to the ALD.

4. Schedule a self-critique with all event participants in the Environmental Group (all shifts) as soon as practical.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure [Date JUL 31 2003 Page 10 of 13 5.4 State Radiological Coordinator Liaison (SRCL) shall:

5.4.1 WHEN notified that an emergency has been declared,

a. Report to the Emergency Operations Facility.

b. IF a State Radiological Coordinator Liaison has been designated, until released, THEN

1. If appropriate, plan a shift relief per EPIP-AD-05.

2. Assist the designated State Radiological Coordinator Liaison.

c. IF a State Radiological Coordinator Liaison has NOT been designated, THEN assume the responsibilities of the State Radiological Coordinator Liaison and continue implementation of this procedure.

5.4.2 Notify the Environmental Protection Director of your assumption of the responsibilities of the State Radiological Coordinator Liaison.

5.4.3 Complete Form EPIPF-EOF-04-01, "SRCL Initial Action Checklist."

Note The SRCL gathers informationfrom initialresponse personnel in order to enter the available information on Form EPIPF-EOF-08-05and Form EPIPF-EOF-08-06,so that this information can be verbally communicated to the State and Counties, orfaxed if they request it.

5.4.4 On a continual basis, collect available information using the following as a guide:

• Form EPIPF-EOF-08-05, "Plant Emergency Status Report"

• Form EPIPF-EOF-08-06, "Radiological Status Report"

• Other sources that would provide information to assist the SRC in making decisions concerning public health and safety.

5.4.5 Transmit information to the SRC and County EOCs by phone as promptly as possible.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementin Procedure Date JUL 31 2003 Page I1 of 13 5.4.6 IF specifically requested by State or County officials, THEN provide written radiological event summaries using Form EPIPF-EOF-08-06 and written plant status updates using Form EPIPF-EOF-08-05, for transmission to those officials by facsimile.

a. Complete the forms with available information.

b. Obtain ERM approval of the completed forms.

c. Inform the EPD that you have completed "Radiological Status Report,"

Form EPIPF-EOF-08-06, to be transmitted by facsimile to State and County officials.

d. Ensure the forms are faxed to the State and County EOCs.

Note If needed, request an extra SRCL to cover the HPN phone.

5.4.7 Respond to calls from the NRC over the HPN phone.

5.4.8 If appropriate, plan for a shift relief per EPIP-AD-05.

5.4.9 IF Final Conditions are NOT met (Section 6.0), THEN return to Step 5.4.4.

5.4.10 WHEN Final Conditions are met (Section 6.0),

a. IF plant conditions degrade to where the declaration of a higher emergency level is declared or full activation of the EOF is appropriate, THEN implement EPIP-EOF-04.

b. IF termination is declared or plant conditions meet the requirements for plant recovery, THEN the SRCL shall ensure the following actions are taken:

1. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

2. Collect all completed records, logs, forms, notes, and other documentation and give them to the ALD.

6.0 Final Conditions 6.1 Plant Emergency has been Terminated or Recovery actions have begun and the Emergency Response Manager has suspended the use of EPIPs.

6.2 Plant conditions degrade to where the declaration of a higher emergency level is warranted or full activation of the ERO is appropriate.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure FDate JUL 31 2003 Page 12of 13 7.0 References 7.1 EPIP-AD-02, Emergency Class Determination 7.2 EPIP-AD-05, Emergency Response Organization Shift Relief Guideline 7.3 EPIP-AD-15, Recovery Planning and Termination 7.4 EPIP-AD-19, Protective Action Guidelines 7.5 EPIP-EOF-02, Emergency Operations Facility (EOF) Activation 7.6 EPIP-EOF-04, EOF Staff Action for Alert or Higher 7.7 EPIP-EOF-08, Continuing Emergency Notifications 7.8 EPIP-EOF-1 1, Internal Communication and Documentation Flow 7.9 EPIP-APPX-A, Communications

- 7.10 EPMP-02.01, Declared Emergency Evaluation and Documentation 7.11 KPB Nuclear Emergency Public Information Plan 7.12 EPIP-AD-07, Initial Emergency Notifications 7.13 Kewaunee Nuclear Power Plant Emergency Plan 7.14 NRC Inspection Report K-87-195 7.15 COMTRAK 91-187, Item 10 7.16 COMTRAK 96-163 REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-03 I Rev. AE Title EOF Staff Action for Unusual Event Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 13 of 13 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• Event Notice, Form EPIPF-AD-07-01

• EOF Activation Checklist, Form EPIPF-EOF-02-01

• Plant Emergency Status Report, Form EPIPF-EOF-08-05

• Radiological Status Report, Form EPIPF-EOF-08-06

• SRCL Initial Action Checklist, Form EPIPF-EOF-04-01

• Telephone Communications Log Sheet, Form EPIPF-EOF-04-02 8.1.2 Non-OA Records None REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page l of 23 Reviewed By Richard Johnson Approved By Jerrie Morlino Nuclear 0 Yes PORC 0 Yes SRO Approval Of 0 Yes Safety Revlew Temporary Related 0 No Required E No Changes Required E No 1.0 Purpose 1.1 This procedure provides instruction for the Emergency Response Manager and other initial response personnel for an appropriate response to an Alert, Site Emergency, or General Emergency, at the Emergency Operations Facility (EOF).

2.0 General Notes 2.1 Personnel on-site depart for the EOF promptly through the security building, unless instructed to assemble elsewhere by the Gai-tronics announcement or security personnel.

2.2 As more information becomes available, initial protective action recommendations should be adjusted in accordance with plant conditions, dose projections, time available to evacuate, estimated evacuation times, and meteorological conditions (EPIP-AD-19).

2.3 IF approached by the media during a declared emergency, THEN refer them to the Joint Public Information Center (JPIC) at 920-433-1400 or 1-800-838-6192 and tell them that this is their most accurate source for information.

3.0 Precautions and Limitations 3.1 "Event Notice," Form EPIPF-AD-07-01, should be initiated and in progress to State and Local Emergency Governments within 15 minutes of the emergency level being declared or as soon as possible without further compromise to plant or public safety.

3.2 The Emergency Response Manager has the nondelegable responsibility for making protective action recommendations.

3.3 IF an emergency class escalation occurs during implementation of this procedure, THEN immediately reinitiate this procedure appropriate to the new emergency level declared.

3.4 Only the following personnel may authorize support personnel without Kewaunee I.D. cards access to the EOF during a declared emergency:

3.4.1 Emergency Response Manager (ERM) 3.4.2 Administrative/Logistics Director (ALD) 3.4.3 Environmental Protection Director (EPD) j:\appdata'procpws\draft\epip\eeofO4.doc-Amy KudickiDori Zegler-Jeanne Ferris REFERENCE USE

Title EOF Staff Action for Alert or Higher WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 I Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant Emergency PlanImplementing Procedure Date JUL 31 2003 Page 2 of 23 4.0 Initial Conditions 4.1 This procedure shall be implemented upon declaration of an Alert, Site Emergency, General Emergency, or when directed by the Emergency Response Manager.

5.0 Procedure Note It is the ERMs responsibility to provide overall direction and coordination of the KNPP emergency response activities, make protective action recommendations to government authorities,coordinate efforts with external organizations (governmental, industry, vendors, etc.), and support the plant's efforts to mitigate the accident by ensuring continuity of resourcesfor long term operation of the emergency response organization.

5.1 Emergency Response Manager (ERM) shall:

5.1.1 WHEN notified that an Emergency has been declared,

a. Report to the Emergency Operations Facility.

b. IF an Emergency Response Manager has been designated, until released, THEN:

1. If appropriate, plan a shift relief per EPIP-AD-05, "Emergency Response Organization Shift Relief Guideline."

2. Assist the designated Emergency Response Manager.

c. IF an Emergency Response Manager has NOT been designated, THEN assume the responsibilities of the Emergency Response Manager or continue implementation of this procedure.

Note The EOFcan be activatedfor individualfunctions, i.e., off-site notifications priorto full activation of thefacility.

5.1.2 Notify the Emergency Director of your arrival and assumption of the Emergency Response Manager duties for facility activation.

5.1.3 Verify the Off-Site Communicator in the EOF is taking responsibility for off-site notifications from the TSC.

5.1.4 Verify a State Radiological Coordinator Liaison (SRCL) or the Radiological Protection Director (RPD) is prepared to transmit radiological related data and general plant conditions to the State Radiological Coordinator in the State Emergency Operations Center (Madison).

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 I Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 23 5.1.5 Verify engineering/licensing and communicator support are available in the EOF.

5.1.6 IF director(s) or supporting staff positions are not arriving at the EOF in a reasonable amount of time, THEN instruct the Off-Site Communicator to contact the individuals needed by telephone and/or by their pager number (see Emergency Telephone Directory).

5.1.7 IF a director position cannot be filled, THEN assign that director's duties to another director's position.

5.1.8 Ensure the ALD is completing EOF activation in accordance with "Emergency Operations Facility (EOF) Activation," EPIP-EOF-02.

5.1.9 Ensure the ALD is establishing security in accordance with "Media Center/Emergency Operation Facility/Joint Public Information Center Security," EPIP-EOF- 12.

5.1.10 Establish Communications with the Technical Support Center and Control Room through the Darome Conference System.

5.1.11 Through the Emergency Response Facility Communicator - EOF, verify the status of off-site agency communications that have taken place from the Control Room.

5.1.12 WHEN confirmed with the Off-Site Communicator that the EOF is capable to assume off-site notification,

a. Assume the responsibility for off-site notifications.

b. Inform the ED of the transfer of this responsibility.

c. Instruct the Off-Site Communicator to contact the State and County EOCs (if active) and notify them that the EOF has the responsibility for off-site communications.

Note Verbally inform the Emergency Directorthat you have accepted the PAR responsibilities.

5.1.13 ACCEPT formal turnover of the responsibility for PARs from the ED.

5.1.14 Ensure date and time is logged for turnover of responsibilities for PARs from the ED in the TSC.

5.1.15 Contact and notify the JPIC Manager of the EOF activation status.

5.1.16 Ensure the KPB Nuclear Emergency Public Information Plan is being implemented for the declared emergency.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 I Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 4 of 23 5.1.17 Ensure the EPD is taking steps to perform dose projections and provide assistance in making protective action recommendations.

5.1.18 Determine the emergency status by obtaining the following information from the emergency response organization in the EOF:

a. Engineering/Licensing Support

• Significant plant evolutions

• NRC response team status and issues

b. Environmental Protection Director

• Status of Radiological Effluent Releases (potential off-site dose consequences)

• Off-Site Dose Assessment Evaluation

• Status of Environmental Monitoring Teams

• Potassium Iodide Distribution

• Adequacy of the Protective Action Recommendations

c. Administrative Logistics Director

• EOF Activation and Operational Status (EPIP-EOF-02)

• EOF/JPIC Security Status (EPIP-EOF-12)

• Status of ERO response

• Status of Information flow in the EOF

• Continuity of resources for long term operation of the emergency response organization

d. State Radiological Coordinator Liaison

• Status of communications with the State of Wisconsin, State Radiological Coordinator

• State or County requests for "Radiological Status Report,"

Form EPIP-EOF-08-06 REFERENCE USE

e. Off-Site Communicator

• Off-Site Communications status

• Significant State and County concerns, priorities, and actions

• PAR implementation status

• State or County requests for "Plant Emergency Status Report,"

Form EPIPF-EOF-08-05, or other information updates Warning It is NOT requiredto de-escalatefrom an Emergency Action Level.

Termination or direct entry into recovery is preferable. However, there may be occasions when it is more appropriateto de-escalate.

EPIP-AD-02, "Emergency Class Determination," and other EPIPsare NOT written to facilitatede-escalation. Therefore, any decision to de-escalate insteadof entering recovery must be based on a thorough review of EPIP-AD-02 and careful use of appropriateprocedures.

5.1.19 Review requirements for escalation and de-escalation situations with the Emergency Director (EPIP-AD-02).

5.1.20 As required, review the EALs and plant status to ensure the event classification is appropriate (EPIP-AD-02).

Note Off-site protective actionsfor the public are NOT requiredfor events classified less than a general emergency.

5.1.21 As required, instruct the Environmental Protection Director to review off-site dose measurements and projections to ensure the event classification is appropriate.

5.1.22 Review current and potential protective action recommendations (EPIP-AD-19).

5.1.23 IF time permits, THEN contact Off-Site Authorities via the Dial Select to discuss potential changes in classification and/or appropriate PAR.

5.1.24 IF notified by the ED of any change in EALs, OR if there is a change in PARs, THEN:

a. Ensure, with the assistance of the Engineering/Licensing Support Coordinator, an "Event Notice," Form EPIPF-AD-07-01, is complete.

b. Review and sign all "Event Notice," Form EPIPF-AD-07-01, generated from the EOF.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 I Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 6 of 23

c. Direct the Off-Site Communicator to initiate State and County notifications using the "Event Notice," Form EPIPF-AD-07-01, and Attachment A of EPIP-EOF-08.

Note The appropriateGovernment Agency contactsfor the ERM are:

• State of Wisconsin - Officer in Charge(OJC) @ Dial Select 83 or 608-242-3260/3261

• Kewaunee County - Emergency Government (Director) @ DialSelect 43 or 920-487-5257

• Manitowoc County - Emergency ManagementDirector @ Dial Select 53 or 920-683-4916/4918 5.1.25 WHEN contacted, or periodically, provide Off-Site Authorities with the following (Dial Select is the preferred communication link):

a. Available information on the event status using applicable sections of "Plant Emergency Status Report," Form EPIPF-EOF-08-05, as a guide.

This data can be provided by the Engineering/Licensing Coordinator.

b. IF a hard copy of "Plant Emergency Status Report" is specifically requested by State or County Officials, THEN:

• Direct the Engineering/Licensing Coordinator to provide written plant event summaries using "Plant Emergency Status Report,"

Form EPIPF-EOF-08-05.

• Review and approve "Plant Emergency Status Report,"

Form EPIPF-EOF-08-05.

• Forward the approved "Plant Emergency Status Report,"

Form EPIPF-EOF-08-05, to the Off-Site Communicator with direction to fax them to the State and County EOCs.

5.1.26 WHEN a completed "Radiological Status Report," Form EPIPF-EOF-08-06, is received:

a. Review,

b. Approve, AND

c. Return to the SRCL.

5.1.27 Contact the ED periodically to receive an update on:

• Status of the plant

• Material and Personnel support requirements

• On-site or off-site radiological releases or potential releases and release paths REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 -

I Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant l Emergency Plan Impkementing Procedure Date JUL 31 2003 Page7of23

• Priorities of tasks to minimize the impact of the accident on the public

• Incidents of public interest (i.e., fires, spills, personnel contaminations/injuries) 5.1.28 Periodically inform the ED of:

• State and County priorities

• State and County actions (i.e., protective actions, evacuations, traffic control, etc.)

• State and County areas of concern

• Media areas of interest and any misinterpretations of the plant situation 5.1.29 Determine EOF priorities, evaluate activities in the following areas:

• Logistical requirements to mitigate significant plant evolutions

• Off-site dose consequences

• Protective action recommendations

• Protective actions implemented by the Counties 5.1.30 Periodically conduct briefings for the EOF Emergency Response Organization:

• Status of the plant

• Material and Personnel support requirements

• On-site or off-site radiological releases or potential releases and release paths

• Incidents of public interest (i.e., fires, spills, personnel contaminations/injuries)

• State and County priorities

• State and County actions (i.e., protective actions, evacuations, traffic control, etc.)

• State and County areas of concern

• Media areas of interest and any misinterpretations of the plant situation

• EOF priorities 5.1.31 Ensure that the Plant Spokesperson is informed. Forward plant status and public interest information to the Plant Spokesperson for appropriate use in briefings to the:

• Public

• Media

• WPSR and NMC Senior Management REFERENCE USE

'WISCONSIN PUBLIC SERVICE CORP. INo. EPIP-EOF-04 I Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 8 of 23

• Partners

• Other financial stakeholders in KNPP or WPSR Note In fast breaking events, the ERM may give verbal authorizationinstead of written approval to release the statement.

5.1.32 Review and approve news statements prior to being released to the media.

5.1.33 If appropriate, plan for a shift relief per EPIP-AD-05.

5.1.34 IF plant conditions meet the requirements of Section 5.1 of EPIP-AD-15, "Recovery Planning and Termination," THEN recovery activities or termination can be implemented in accordance with EPIP-AD-15.

5.1.35 IF Final Conditions are NOT met (Section 6.0), THEN return to Step 5.1.17.

5.1.36 WHEN Final Conditions are met (Section 6.0),

a. Ensure that termination or plant recovery Event Notifications have been initiated by the Off-Site Communicator.

b. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

c. Collect all completed forms, notes, and other documentation and give them to the ALD.

d. Schedule a self-critique with all event participants in the EOF (all shifts) as soon as practical.

5.2 Administrative Logistics Director (ALD) shall:

5.2.1 WHEN notified that an Emergency has been declared,

a. Report to the Emergency Operations Facility immediately.

b. IF an Administrative Logistics Director has been designated, until released, THEN:

1. If appropriate, plan a shift relief per EPIP-AD-05.

2. Assist the designated Administrative Logistics Director.

c. IF an Administrative Logistics Director has NOT been designated, THEN assume the responsibilities of the Administrative Logistics Director and continue implementation of this procedure.

5.2.2 Notify the Emergency Response Manager of your assumption of the responsibilities of the Administrative Logistics Director.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 9 of 23 5.2.3 As directed by the ERM,

a. Contact EOF administrative support personnel or others.

b. Instruct them to report to the EOF immediately or to remain on standby for further instructions.

5.2.4 Support or implement the EOF activation process (EPIP-EOF-02), and ensure Form EPIPF-EOF-02-01, "EOF Activation Checklist" is completed.

5.2.5 Arrange for security support at the EOF, JPIC, and MC by implementing procedure EPIP-EOF-12.

5.2.6 As needed, assign EOF support personnel to provide administrative support as defined in EPIP-EOF-1 1, "Internal Communications and Documentation Flow," to:

a. Maintain status boards and event sheets (Step 5.1).

b. Ensure communications are properly distributed (Step 5.2).

c. Ensure that a "Master Log" is established and maintained (Step 5.3).

5.2.7 Establish procedures for the long term storage of the documents, records, and logs generated by the event.

5.2.8 Ensure that appropriate logs, records, and documents are maintained for the duration of the event. Those logs, records, and documents shall include as a minimum:

• Ongoing plant status and conditions

• Date and time of significant accident events

• Chronology of plant accident mitigation and repair priorities

• All calculated, measured, or State provided radiological release data and information

• All event notification and status update documents generated

• Any messages generated or recorded

• All PPCS computer printouts generated for status board maintenance or general information

• All logs maintained by EOF staff

• All news statements from the JPIC 5.2.9 Monitor the flow of information in the EOF and correct any problems.

5.2.10 If required, arrange for communication system service repair (see EPIP-EOF-02, Step 5.1.2).

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP.

No.

No.

~~~Title EPSP-EOF-04 EPIP-EOF-04 I I Rev. AL Rev. AL EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant

. .~~~~~~~~~-

Emergency Plan Implementing Procedure i Date JUL 31 2003 Page 10 of 23 5.2.11 If required, develop a shift schedule to provide for 24-hour operation of the EOF and security staff per EPIP-AD-05.

5.2.12 Obtain purchasing support (see KPB Emergency Telephone Directory, ETD 04 for NMC contact) for assistance in the following:

• Material purchase and control contract negotiations, expense accounts 5.2.13 If needed, provide for the following manpower needs:

• Technical and craft disciplines through organizations such as Westinghouse Electric Corporation, Fluor Engineering, or INPO

• Labor relations' assistance 5.2.14 If needed, obtain the following logistical assistance for:

• Transportation of emergency response personnel

• Airline and hotel accommodations

• Office supplies and furniture

• Document reproduction

• Food deliveries

• Sanitation 5.2.15 IF Final Conditions are not met (Section 6.0), THEN return to Step 5.2.6.

5.2.16 WHEN Final Conditions are met (Section 6.0),

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

b. Collect all records and logs from all documents generated during the course of the event.

c. Ensure "EOF Deactivation Checklist," Form EPIPF-EOF-02-02, is completed per EPIP-EOF-02.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPLP-EOF-04 l Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 11 of 23 5.3 Environmental Protection Director (EPD) shall:

5.3.1 WHEN notified that an Emergency has been declared,

a. Report to the Emergency Operations Facility.

b. IF an Environmental Protection Director has been designated, until released, THEN:

1. If appropriate, plan a shift relief per EPIP-AD-05.

2. Assist the designated Environmental Protection Director.

c. IF an Environmental Protection Director has NOT been designated, THEN assume the responsibilities of the Environmental Protection Director and continue implementation of this procedure.

5.3.2 Notify the Emergency Response Manager of your assumption of the responsibilities of the Environmental Protection Director.

5.3.3 If necessary, establish the environmental team organization in accordance with EPIP-ENV-01, "Environmental Monitoring Group Organization and Responsibilities."

5.3.4 Ensure environmental and EPZ status boards are maintained along with a record of significant events, data reported, and directives given.

5.3.5 Provide overall direction to the Environmental Monitoring Group.

5.3.6 Prepare plant status updates for transmission to the Environmental Monitoring (EM)

Teams.

5.3.7 Direct the State Radiological Coordinator Liaison to provide available information to the State Radiological Coordinator using Form EPIPF-EOF-08-06 as a guide.

5.3.8 Inform the RPD when an EM Team member approaches administrative or legal radiological exposure limits.

5.3.9 Maintain an overall awareness of environmental conditions and the contributing factors for development of protective action recommendations in accordance with EPIP-AD-19.

5.3.10 Evaluate dose projections and field data.

5.3.11 Assist the Emergency Response Manager (ERM), the Emergency Director (ED), and the Radiological Protection Director (RPD) in determining protective action recommendations.

5.3.12 Communicate frequently with the Radiological Protection Director to confirm the accuracy of input data to the dose projection process.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 l Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 12 of 23 5.3.13 As necessary, establish and maintain communication with other Emergency Response Organization Directors and Off-Site Authorities.

5.3.14 IF a radiological release has occurred or is imminent, THEN contact Environmental Inc. (Midwest Lab.) (see KPB Emergency Telephone Directory for phone number) and make arrangements for conducting soil/vegetation/water/snow deposition sampling and analysis.

a. Identify locations where deposition sampling and analysis is needed using EMT field data and dose projection results.

b. Perform sampling and analysis using the methodology described in the KNPP "Radiological Environmental Monitoring Manual (REMM)."

c. Provide sample analysis results to the State Radiological Coordinator.

5.3.15 If appropriate, plan for a shift relief per EPIP-AD-05.

5.3.16 IF Final Conditions are NOT met (Section 6.0), THEN return to Step 5.3.4.

5.3.17 WHEN Final Conditions are met (Section 6.0),

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the ALD.

c. Schedule a self-critique with all event participants in the environmental group (all shifts) as soon as possible.

5.4 State Radiological Coordinator Liaison (SRCL) shall:

5.4.1 WHEN notified that an Emergency has been declared:

a. Report to the Emergency Operations Facility.

b. IF a State Radiological Coordinator Liaison has been designated, until released, THEN

1. Assist in the activation of the EOF per EPIP-EOF-02.

2. If appropriate, plan a shift relief per EPIP-AD-05.

3. Assist the designated State Radiological Coordinator Liaison.

c. IF a State Radiological Coordinator Liaison has NOT been designated, THEN assume the responsibilities of the State Radiological Coordinator Liaison and continue implementation of this procedure.

5.4.2 Notify the Environmental Protection Director of your assumption of the responsibilities of the State Radiological Coordinator Liaison.

REFERENCE USE

5.4.3 Obtain and complete "SRCL Initial Action Checklist," Form EPIPF-EOF-04-01.

Note Assistance may be obtainedfrom other environmental organizationmembers or by requestingthe ALD to provide EOFsupport staff.

5.4.4 Ensure radiological information provided by the State Radiological Coordinator is passed to the EPD.

5.4.5 Perform an initial core damage assessment.

5.4.5.1 Collect the following values from the plant process computer using Attachment A.

• Core exit thermocouple reading - PPCS Graphic Display #4

• Containment radiation monitor readings R-40 & R PPCS Point ID G004OG & G0041G Note It is not necessary to proceed to Step 5.2 or Step 5.3 of EPIP-TSC-09A.

Only the high level core damage assessment is required.

5.4.5.2 Go to Step 5.1.4 of EPIP-TSC-09A, "Core Damage Assessment," and determine the appropriate classification of fuel damage using all of the parameters collected in Step 5.4.5.1.

5.4.5.3 Provide fuel damage assessment results to the following positions:

• Technical Support Center Director

• Environmental Protection Director

• Dose Projection Calculator REFERENCE USE

T WISCONSIN PUBLIC SERVICE CORP. No.

No.

Title EPIP-EOF-04 EPIP-EOF-04 I I Rev.

Rev. ALAL EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 14 of 23 Note The SRCL completes Form EPIPF-EOF-08-06with availableinformation.

5.4.6 On a continual basis, monitor plant conditions using the following as a guide:

• "Plant Emergency Status Report," Form EPIPF-EOF-08-05 (applicable sections from the Eng./Lic. Coordinator)

• "Radiological Status Report," Form EPIPF-EOF-08-06 (applicable sections from the Dose Projection Calculator and Environmental Monitoring Team Coordinator)

• Other sources that would provide information to assist the SRC in making decisions concerning public health and safety 5.4.7 Transmit information to the SRC by phone as promptly as possible.

5.4.8 IF specifically requested by State officials (or EPD), THEN provide written radiological event summaries using Form EPIPF-EOF-08-06 for transmission to those officials by facsimile.

a. Complete "Radiological Status Report," Form EPIPF-EOF-08-06 with available information.

b. Obtain ERM approval of the completed Form EPIPF-EOF-08-06.

c. Inform the EPD that you have completed "Radiological Status Report,"

Form EPIPF-EOF-08-06, to be transmitted by facsimile to State officials.

d. Ensure Form EPIPF-EOF-08-06 is faxed to the State.

Note If needed, request an extra SRCL to cover the HPNphone.

5.4.9 Respond to incoming calls from the NRC over the HPN phone.

5.4.10 Support the completion of "Event Notice," Form EPIPF-AD-07-01, and the development of protective action recommendations.

5.4.11 If appropriate, plan for shift relief per EPIP-AD-05.

5.4.12 IF Final Conditions are NOT met (Section 6.0), THEN return to Step 5.4.4.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant Emergency PlanImplementing Procedure Date JUL 31 2003 Page 15 of 23 5.4.13 WHEN Final Conditions are met (Section 6.0),

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

b. Collect all completed records, logs, notes, and other documentation and give them to the ALD.

5.5 Engineering/Licensing Support Coordinator shall:

5.5.1 WHEN notified that an Emergency has been declared,

a. Report to the Emergency Operations Facility.

b. IF an Engineering/Licensing Support Coordinator has been designated, until released, THEN

1. Assist in the activation of the EOF per EPLP-EOF-02.

2. If appropriate, plan a shift relief per EPIP-AD-05.

3. Assist the designated Engineering/Licensing Support Coordinator.

c. IF an Engineering/Licensing Support Coordinator has NOT been designated, THEN assume the responsibilities of the Engineering/Licensing Support Coordinator and continue implementation of this procedure.

5.5.2 Notify the Emergency Response Manager that you have assumed the responsibilities of the Engineering/Licensing Support Coordinator.

5.5.3 Monitor engineering, operational, and licensing events related to the event for the ERM.

Note Assistance may be obtainedby requesting the ALD to provide EOF support staff 5.5.4 Ensure status boards are maintained.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 l Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 16 of 23 5.5.5 Review messages in the "IN" box and:

a. Brief the ERM on significant changes, events, and information.

b. IF the message should be placed on the status board or flip chart, THEN mark them as "POST location ."

• Operating Status board

• Environmental Status Board

• Protective Actions board

• Flip Chart

c. Place the reviewed messages in the "OUT" box.

5.5.6 WHEN required by the ERM:

a. Review the event classification (EPIP-AD-02).

b. Complete "Event Notice," Form EPIPF-AD-07-01, for approval and transmittal to off-site agencies.

c. Complete "Plant Emergency Status Report," Form EPIPF-EOF-08-05 (applicable sections).

5.5.7 Perform liaison duties between the ERM and the NRC event response team in the EOF.

5.5.8 Coordinate the activities of the Emergency Response Facility Communicator - EOF for communications with other emergency facilities as appropriate.

5.5.9 If appropriate, plan for a shift relief, per EPIP-AD-05.

5.5.10 IF Final Conditions are not met (Section 6.0), THEN return to Step 5.5.3.

5.5.11 WHEN Final Conditions are met (Section 6.0),

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the ALD.

REFERENCE USE

Title EOF Staff Action for Alert or Higher WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 I Rev. AL

, -0 : ~~~~~~~Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL31 2003 Page 17 of 23 5.6 Off-Site Communicator shall:

5.6.1 WHEN notified that an Emergency has been declared during off-hours, THEN

a. Report to the Emergency Operations Facility.

b. IF an Off-Site Communicator has been designated, until released, THEN

1. Assist in the activation of the EOF.

2. If appropriate, plan a shift relief per EPIP-AD-05.

3. Assist the designated Off-Site Communicator.

c. IF an Off-Site Communicator has NOT been designated, THEN assume the responsibilities of the Off-Site Communicator and continue implementation of this procedure.

5.6.2 Verify the phones needed for the Off-Site Communicator are properly located and functional.

Note Until turnover of off-site communications is complete, the ControlRoom or TSC has primary responsibilityof the government verification lines. These lines should not be answered unless it is obvious that they are not being answeredat the otherfacilities. IF the line is answered in the EOFpriorto official turnover, THEN every effort should be made to reconnect the party on this line with the facility with primary responsibilityand in the interim provide the best information available.

5.6.3 When directed by the ERM, transfer off-site communications from the Control Room or TSC to the EOF.

a. Ensure the Government Verification phone bell switch is ON.

b. Contact the Notifier (CR) or Off-Site Communicator (TSC), and obtain a briefing on the status of off-site notification.

Note Remind the Notifier (CR) or Off-Site Communicator(TSC) to turn the bell switch on the Government Verification phone to the OFFposition.

c. WHEN mutually agreed upon, relieve the Control Room or TSC of off-site notification responsibilities.

d. Ask the Notifier or Off-Site Communicator (TSC) to fax a copy of all "Event Notice," Form EPIPF-AD-07-01, issued from the Control Room or TSC to the EOF.

REFERENCE USE

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e. Inform the ERM that the EOF now has responsibility for off-site communications.

f. Enter the time and date in the log that responsibilities for off-site communications was accepted by the EOF from the TSC or CR.

Note The State and County Liaisons will establish communications with the Off-Site Communicatorat the EOF via commercialphone lines.

5.6.4 Contact off-site EOCs and determine the status of their activation.

5.6.5 When activated, obtain the following information from the off-site EOCs:

• Significant State or County concerns, priorities, and actions

• If appropriate, PAR implementation status

• Required reports or other information needed from KNPP 5.6.6 Review current status board and chronological event sheet entries.

5.6.7 WHEN directed by the ERM, perform off-site notifications.

a. IF off-site EOCs HAVE been activated, THEN Go To EPIP-EOF-08 and perform notifications.

b. IF off-site EOCs have NOT been activated, THEN Go To EPIP-AD-07, Step 5.1 and perform notifications.

5.6.8 IF written plant status updates are requested by State or County officials (or ERM),

THEN:

a. Obtain "Plant Emergency Status Report," Form EPIPF-EOF-08-05 from the EngineeringILicensing Support Coordinator.

b. Ensure ERM approves the completed Form EPIPF-EOF-08-05.

c. Fax Form EPIPF-EOF-08-05 to the State and County EOCs.

Note Assistance may be obtainedby requesting the ALD to provide EOF support staff 5.6.9 Ensure the EOF status board for off-site conditions is updated on a regular basis.

Assistance by the EOF support staff may be requested from the ALD.

5.6.10 Record incoming and outgoing ad hoc telephone messages on "Telephone Communications Log Sheet," Form EPIPF-EOF-04-02.

REFERENCE USE

5.6.11 WHEN requested, brief the ERM on off-site communications, include the following items:

• Off-site Communications status

• Significant State and County concerns, priorities, and actions

• PAR implementation status

• State or County requests for status reports (Form EPIPF-EOF-08-05) or other information updates 5.6.12 Provide communication support as directed by the ERM.

5.6.13 If appropriate, plan for shift relief per EPIP-AD-05.

5.6.14 IF Final Conditions are not met (Section 6.0), THEN return to Step 5.6.5.

5.6.15 WHEN Final Conditions are met (Section 6.0),

a. Ensure that termination or recovery communications are made as directed by the ERM in accordance with Step 5.1.35.a.

b. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

c. Collect all completed records, logs, forms, notes, and other documentation and give them to the ALD.

5.7 Emergency Response Facility (ERF) Communicator - Emergency Operations Facility (EOF) shall:

5.7.1 WHEN notified that an Emergency has been declared,

a. Report to the Emergency Operations Facility.

b. IF an ERF Communicator - EOF has been designated, until released, THEN

1. Assist in the activation of the EOF.

2. If appropriate, plan a shift relief per EPIP-AD-05.

3. Assist the designated ERF Communicator - EOF.

c. IF an ERF Communicator - EOF has NOT been designated, THEN assume the responsibilities of the ERF Communicator - EOF and continue implementation of this procedure.

5.7.2 Notify the Engineering/Licensing Support Coordinator of your assumption of the responsibilities of the ERF Communicator - EOF.

REFERENCE USE

5.7.3 Review the following items:

• Master Log Sheets

• Current Status Board listings

• Current Chronological Event Sheet listing

• Any News Statement that may have been generated 5.7.4 As directed by the Engineering/Licensing Support Coordinator, monitor the data presented on the PPCS computer, obtaining clarification from the plant, as necessary.

5.7.5 Record incoming and outgoing ad hoc telephone messages on "Telephone Communications Log Sheet," Form EPIPF-EOF-04-02.

5.7.6 Enter the 4-Way Communications Link. The "dial in number" and "access number" are listed in the KPB Emergency Telephone Directory, ETD 03, "Emergency Response Facilities Telephone List."

5.7.7 Confer with the ERM and Engineering/Licensing Support Coordinator on key issues and events.

5.7.8 Ensure the ERM and Engineering/Licensing Support Coordinator are kept informed of all key issues/events at the plant. The items listed below are key topics the ERF Communicator - EOF should be listening for:

• Emergency Classification level declared

• Events that caused the classification to be declared

• Actions being taken by NMC-KNP to mitigate the event

• All incidents relating to personnel injury, contamination, or overexposure to radiation

• Events happening outside the protected area of the plant (i.e., crashes, fires, tower or substation damage)

• Outside assistance called in (i.e., ambulance, fire department, or Point Beach Nuclear Plant personnel or equipment) 5.7.9 If appropriate, plan for shift relief per EPIP-AD-05.

5.7.10 IF Final Conditions are not met (Section 6.0), THEN return to Step 5.7.3.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPLP-EOF-04 l Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 21 of 23 5.7.11 WHEN Final Conditions are met (Section 6.0),

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the ALD.

5.8 EOF Support Staff shall:

5.8.1 WHEN notified that an Emergency has been declared,

a. Report to the Emergency Operations Facility.

b. Notify the Administrative Logistics Director of your availability to assume responsibilities of support staff and continue implementation of this procedure as directed by the Administrative Logistics Director.

5.8.2 Ensure the PPCS computer and printer are operating properly. Report problems to ALD.

5.8.3 Ensure the Recorder's PC is operating properly per instructions on Form EPIPF-EOF-02-01, "EOF Activation Checklist." Report problems to ALD.

5.8.4 Assist in activating the EOF in accordance with EPIP-EOF-02.

5.8.5 Perform the tasks described in EPIP-EOF- II.

5.8.6 WHEN directed by the ALD, provide general EOF support.

5.8.7 If appropriate, assist the ALD in plans for shift relief per EPIP-AD-05.

5.8.8 IF Final Conditions are not met (Section 6.0), THEN return to Step 5.8.4.

5.8.9 WHEN Final Conditions are met (Section 6.0),

a. Verify all work areas are returned to normal status and emergency procedures, forms, etc., are returned to their proper place.

b. Collect all completed records, logs, forms, notes, and other documentation and give them to the ALD.

6.0 Final Conditions 6.1 Plant Emergency has been Terminated or Recovery actions have begun and the Emergency Response Manager has suspended the use of EPIPs.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 I Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant Emerrency Plan Implementing Procedure Date JUL 31 2003 I Page 22 of 23 7.0 References 7.1 EPIP-AD-02, Emergency Class Determination 7.2 EPIP-AD-05, Emergency Response Organization Shift Relief Guideline 7.3 EPIP-AD-07, Initial Emergency Notifications 7.4 EPIP-AD-15, Recovery Planning and Termination 7.5 EPIP-AD-19, Protective Action Guidelines 7.6 EPIP-ENV-01, Environmental Monitoring Group Organization and Responsibilities 7.7 EPIP-EOF-02, Emergency Operations Facility (EOF) Activation 7.8 EPIP-EOF-03, EOF Staff Action for Unusual Event 7.9 EPIP-EOF-08, Continuing Emergency Notifications

\..... 7.10 EPIP-EOF-I 1, Internal Communication and Documentation Flow 7.11 EPIP-EOF-12, Media Center/Emergency Operation Facility/Joint Public Information Center Security 7.12 EPIP-TSC-09A, Core Damage Assessment 7.13 EPIP-APPX-A-1, Communication System Description 7.14 KPB Emergency Telephone Directory 7.15 EPMP-02.01, Declared Emergency Evaluation and Documentation 7.16 KPB Nuclear Emergency Public Information Plan 7.17 Kewaunee Nuclear Power Plant Emergency Plan 7.18 NRC Inspection Report K-87-195 7.19 COMTRAK 91-187, Item 10 7.20 COMTRAK 96-163 REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-04 I Rev. AL Title EOF Staff Action for Alert or Higher Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 23 of 23 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• Event Notice, Form EPIPF-AD-07-01

• EOF Activation Checklist, Form EPIPF-EOF-02-01

• Plant Emergency Status Report, Form EPIPF-EOF-08-05

• Radiological Status Report, Form EPIPF-EOF-08-06

• SRCL Initial Action Checklist, Form EPIPF-EOF-04-01

• Telephone Communications Log Sheet, Form EPIPF-EOF-04-02 8.1.2 Non-OA Records None REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-08 Rev. AA Title Continuing Emergency Notifications Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 1 of 6 Reviewed By Richard Johnson Approved By Jerie Morlino Nuclear 3 Yes PORC O Yes SRO Approval Of 0 Yes Safety Review Temporary Related 0 No Required 0 No Changes Required 0l No 1.0 Purpose 1.1 This procedure provides instruction for the Security Notifier (SEC-N), ERF Communicator - Control Room (ERFCM-C), Operations crew members, or Off-Site Communicator (OFFCM) for notification of Off-Site Authorities of an emergency event escalation, de-escalation, change in Protective Action Recommendation (PAR), termination, or entry into recovery, as directed by the Shift Manager (SM), Emergency Director (ED), or Emergency Response Manager (ERM).

2.0 General Notes 2.1 IF approached by the media during a declared emergency, THEN refer them to the Joint Public Information Center (JPIC) at (920) 433-1400 or 1-(800) 838-6192 and tell them that this is their most accurate source for information.

2.2 This is a "Continuous Use" procedure with steps performed in sequence.

3.0 Precautions and Limitations 3.1 "Event Notice," Form EPIPF-AD-07-01, should be initiated and in progress to state and local emergency governments within 15 minutes of the emergency level being declared, or as soon as possible without further compromise to plant or public safety.

3.2 Verify the bell switch for the Emergency Government Verification Phone is ON.

3.3 If an emergency class escalation, de-escalation, change in PAR, termination, or entry into recovery occurs during these notifications, disregard any remaining steps and return to Step 5.1. Begin the appropriate actions and notifications for the new emergency level.

4.0 Initial Conditions 4.1 This procedure is initiated for the Initial event notifications and will continue to be used for event notifications until the State of Wisconsin Emergency Operations Center (State EOC) is activated. This procedure shall be implemented upon an event

• DECLARATION, ESCALATION,. DE-ESCALATION,

• CHANGE IN PAR,

• TERMINATION, or

• ENTRY INTO RECOVERY, as directed by the SM/ED or ERM.

j:\appdata\procpws\draft\epip\eeofO8.doc-Amy Kudick/Amny Kudick-Jeanne Fernis CONTINUOUS USE

Title Continuing Emergency Notifications WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-08 IRev. AA D  : ~~~~~~~TitleContinuing Emergency Notifications Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 2 of 6 5.0 Procedure Note IF the State EOC is NOT activated, THEN go to "Initial Emergency Notifications,"

EPIP-AD-07.

5.1 Notify the State and County of the Event Check 5.1.1 Verify that any "Event Notice," Form EPIPF-AD-07-01, received from the SMIED or ERM has their approval signature, date, and time.

5.1.2 Complete block 12 of "Event Notice," Form EPIPF-AD-07-01.

5.1.3 Complete Attachment A, "State and County Event Notification."

5.2 Fax Event Notice Note You will receive a confirmation copy of yourfax broadcastmaterialand a summary of delivery status at the fax machine in PublicAffairs (A2-South West).

Note IF a confirmationfax is not received or otherproblems are encountered with the broadcastfax, THEN additionalinformation on use can be found in the WPS PublicAffairs DepartmentProcedureNo. 64.1, "PrairieSystems Fax Broadcasting."

Note Detailedinstructionsfor the use of the EOFfax machine are contained in "Communication System Description," EPIP-APPX-A-1, Section 5.10.

5.2.1 Obtain fax cover sheet, Form EPIPF-EOF-08-03, "Fax for Emergency Declaration or Status Updates."

5.2.2 Send fax broadcast of completed "Event Notice," Form EPIPF-AD-07-01, with fax cover sheet, by following instructions on Form EPIPF-AD-07-03, "Fax Event Notice."

5.2.3 Contact the Point Beach Duty Shift Manager at (920) 755-6247 and notify him that an "Event Notice" has been faxed to him.

5.3 Return Form EPIPF-AD-07-01 to the SM4ED or ERM who approved the Event Notice.

CONTINUOUS USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-08 Rev. AA Title Continuing Emergency Notifications Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 6 Check 5.4 WHEN final conditions are met (Step 6.0), THEN return to EPIP-AD-03, "KNPP Response to an Unusual Event," OR EPIP-AD-04, "KNPP Response to Alert or Higher," OR EPIP-EOF-04, "EOF Staff Action for Alert or Higher," at the step you left the procedure.

6.0 Final Conditions 6.1 The off-site notification implemented upon declaration of an event

• ESCALATION,

• DE-ESCALATION,

• CHANGE IN PAR,

• TERMINATION, or

• ENTRY INTO RECOVERY, is complete.

7.0 References 7.1 Kewaunee Nuclear Power Plant Emergency Plan 7.2 EPIP-APPX-A- 1, Communication System Description 7.3 KPB Emergency Telephone Directory

~ 7.4 EPIP-AD-03, KNPP Response to an Unusual Event 7.5 EPIP-AD-04, KNPP Response to Alert or Higher 7.6 EPIP-AD-07, Initial Emergency Notifications 7.7 EPIP-EOF-04, EOF Staff Action for Alert or Higher 7.8 Form EPIPF-AD-07-01, Event Notice (Nuclear Accident Reporting System Form (NARS))

7.9 Form EPIPF-AD-07-03, Fax Event Notice 7.10 Form EPIPF-EOF-08-03, Fax for Emergency Declaration or Status Updates CONTINUOUS USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-08 Rev. AA Title Continuing Emergency Notifications Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure FDate JUL 31 2003 Page 4 of 6 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 QA Records

• Form EPIPF-AD-07-01, Event Notice (Nuclear Accident Reporting System Form (NARS))

• Attachment A, State and County Event Notification

• Form EPIPF-AD-07-03, Fax Event Notice 8.1.2 Non-OA Records None CONTINUOUS USE

STATE AND COUNTY EVENT NOTIFICATION Date and Time: Check

'~-- 1. Verify that any "Event Notice," Form EPIPF-AD-07-01, received from the SM/ED or ERM has their approval signature, date, and time.

2. Pick up the Dial Select phone and verify the line is clear.

a. IF someone is using the Dial Select line, THEN state that you have a "PRIORITY 2" notification. They will clear the line unless they have a "PRIORITY 1" call.

b. IF someone states they have a "PRIORITY 1" conversation, THEN acknowledge their priority and monitor the call until they finish.

3. WHEN the line is clear, Dial "83-43-53" (agencies to be notified).

a. IF the Dial Select system is not operating, THEN go to Step 8 (Using Secondary Method, Commercial Phone).

Note IF an agency does not respond, THEN press # to cancel the ringing.

4. WHEN each party acknowledges:

a. Answer by stating: "This is the Kewaunee Nuclear Plant - Please stay on the line for a Nuclear Accident Reporting System (NARS) message."

b. Record the time each agency responds on top of Form EPIPF-AD-07-01 (NARS form).

c. After all agencies have answered press the # key to cancel the ringing.

• IF after five (5) rings an agency has not answered, THEN press the individual's Dial Select number from the table below.

AGENCY DIAL SELECT #

State EOC 83 Kewaunee County EOC 43 Manitowoc County EOC 53

• WAIT up to five (5) more rings, THEN press the "#" key to cancel ringing.

• IF unable to contact a specific agency, THEN continue with the notification of agencies on the line.

Attachment A EPIP-EOF-08 Rev. AA Date: JUL 31 2003 Page 5 of 6 CONTINUOUS USE

0 STATE AND COUNTY EVENT NOTIFICATION Check

"- 5. Read the message on Form EPIPF-AD-07-01 text aloud, SLOWLY AND DELIBERATELY, using number and letter designations (Ref: "Phonetic Alphabet.")

6. Say: "State of Wisconsin EOC, please read back this message to verify accuracy."

(Pause to allow message to be read back.)

7. Say: "Have all agencies received this message?" (Wait for Reply.)

8. IF any agencies did not respond to the Dial Select, THEN complete the State and County Event Notification using the secondary method, commercial phone.

AGENCY COMMERCIAL #

State EOC 1 (800) 943-0003 Kewaunee County EOC 1 (920) 487-9791 Manitowoc County EOC 1 (920) 683-4916

a. Call each applicable agency number in the order shown above.

b. WHEN the party answers, record the time on Form EPIPF-AD-07-01 (NARS form).

c. Read the message on Form EPIPF-AD-07-01 text aloud, SLOWLY AND DELIBERATELY, using number and letter designations (Ref: "Phonetic Alphabet").

d. Say: "(agency name), please read back this message to verify accuracy."

(Pause to allow message to be read back.)

9. Inform SM[ED/ERM that notifications have been made.

10. Return to procedure Step 5.2.

Attachment A EPIP-EOF-08 Rev. AA Date: JUL 31 2003 Page 6 of 6 CONTINUOUS USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-11 Rev. W Title Internal Communication and Kewaunee Nuclear Power Plant Documentation Flow Emergency Plan Implementdng Procedure Date JUL 31 2003 Page 1 of 3 Reviewed By Bruce Heitzkey Approved By Jerrie Morlino Nuclear PORC _ SRO Approval Of Safety O Yes Review 0 Yes Temporary a Yes Related El No Required 0 No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for the flow of information and documentation through the EOF and how it will be maintained.

2.0 General Notes 2.1 Generally each EOF position should maintain the logs, records, and documents generated by them at their station until the ALD arranges for long-term storage.

3.0 Precautions and Limitations 3.1 All logs, records, and documents generated over the course of the emergency shall be kept until after emergency reviews or investigations of the emergency are complete.

4.0 Initial Conditions 4.1 This procedure will be implemented when an emergency has been declared at the Kewaunee Nuclear Power Plant and it is directed by the Administrative Logistics Director.

5.0 Procedure 5.1 Maintaining Status Boards and Flip Charts - EOF Support Personnel 5.1.1 Update the following EOF status boards approximately every 15 minutes or as directed by the ALD, EPD, or Engineering/Licensing Support Coordinator.

• Operating Status Board

• Environmental Status Board 5.1.2 Update the Protective Actions board as directed by the ALD or Engineering/Licensing Support Coordinator.

j:\appdata~procpws\drattiepip\eeof1 1.doc-Amy Kudick/Amy Kudick-Jeanne Ferris REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPEP-EOF- I I I Rev. W Title Internal Communication and Kewaunee Nuclear Power Plant Documentation Flow l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 3 Note IF the PPCS computer terminal is not operational, THEN use the Formsfound in Appendix B of the EPIPsand complete them by obtaining the information from the ERF Communicatorin the TSC. The Forms are:

• Form EPIPF-EOF-11-02, "OperatingStatus"

• Form EPIPF-EOF-11-03, "Environmental Status Board" 5.1.3 Print the PPCS computer terminal screens that match the EOF status boards from the PPCS computer terminal under the following "Graphic Display" screen addresses:

• #53 - Operating Status

• #54 - Environmental Status 5.1.4 Transcribe the data obtained from the screens to the appropriate EOF status boards.

5.1.5 Place the printouts in the EOF Support Personnel's OUT box for filing.

5.1.6 Transcribe information that is marked "POST" by the Engineering/Licensing Support Coordinator to the appropriate status board or Flip Chart sheet.

5.1.7 Provide recommendations to the Engineering/Licensing Support Coordinator to post any other significant plant or ERO activities/events.

5.1.8 Number each Flip Chart sheet.

5.2 Distributing New Messages - EOF Support Personnel 5.2.1 Distribute To Addressee:

a. IF action is required, THEN hand it directly to the addressee who needs to take the action.

b. IF the information is for informational purposes, THEN place it in the addressee's IN box.

5.2.2 Pick up all messages from all OUT boxes:

a. Messages from EOF staff members should be placed in the ERM's IN box.

b. Messages from the ERM's and ENGLI's OUT boxes that are marked "POST" should be placed in the IN box of the Support Person maintaining the status boards (Step 5.1).

c. Other messages from the ERM's OUT box should be placed in the IN box of the Support Person generating the Master Log.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-EOF-I I I Rev. W Title Internal Communication and Kewaunee Nuclear Power Plant Documentation Flow HI Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 3

d. Messages that have been posted should be placed in the IN box of the Support Person generating the Master Log (Step 5.3).

5.3 Master Log - EOF Support Personnel 5.3.1 Collect all "News Statements" and make a copy for each clip board.

5.3.2 Create an electronic master log.

5.3.3 Enter all messages in the "Master Log" chronologically.

5.3.4 After a full log page is generated or every 30 minutes,

a. Make 4 copies of the last log page and latest news statements,

b. Two-hole punch them at the top, AND

c. Deliver to the IN boxes of the: ERM, SRCL, NRC, State.

5.3.5 Place the originals of all messages in a master file.

6.0 Final Conditions 6.1 Plant Emergency has been Terminated or Recovery actions have begun and the Emergency Response Manager has suspended the use of EPIPs.

7.0 References 7.1 None 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• Operating Status, Form EPIPF-EOF-11-02

• Environmental Status Board, Form EPIPF-EOF-1 1-03

• Flip Chart sheets

• Personal and Master Logs 8.1.2 Non-OA Records None REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-RET-02 I Rev. X Title In-Plant Radiation Emergency Team Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page I of 5 Reviewed By Richard Johnson Approved By Jerrie Morlino Nuclear 3 Yes PORC 3 Yes SRO Approval Of 3 Yes Safety Review Temporary Related 0 No Required 0 No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for the In-Plant Radiation Emergency Team (IRET),

when activated.

2.0 General Notes 2.1 None 3.0 Precautions and Limitations 3.1 Depending on the nature, class, and magnitude of the emergency, the following list of priorities should be generally followed by the IRET:

3.1.1 Protection of personnel from high levels of radiation through radiation surveys and air activity surveys.

3.1.2 Search and rescue for life saving.

3.1.3 First Aid.

3.1.4 Issue dosimetry and respiratory equipment.

3.1.5 Health Physics (HP) coverage for operation or repair of vital equipment.

3.1.6 Radiologically Controlled Area (RCA) access restrictions.

3.1.7 Assist Fire Brigade.

3.1.8 Sampling for gaseous effluent release characterization.

3.1.9 Off-site dose projection.

3.1.10 Assist Chemistry personnel for primary coolant and containment post accident sampling and analysis.

3.1.11 Assist and support the site and environmental monitoring teams as required.

3.1.12 Document radiation exposures to personnel.

j:\appdata\procpws\dratt\epip\eretO2.doc-Amy Kudick/Amy Kudick-Jeanne Ferris REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-RET-02 Rev. X Kewauee Nulear ower lantTitle In-Plant Radiation Emerge ncy Team Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 4.0 Initial Conditions 4.1 An Alert or higher emergency has been declared at the Kewaunee Nuclear Power Plant (KNPP).

5.0 Procedure 5.1 In-Plant Radiation Emergency Team (IRET) Activation 5.1.1 WHEN notified of an emergency at KNPP, assemble in the Radiation Protection Office (RPO).

5.1.2 IF the RPO is not habitable, or at the direction of the Radiological Protection Director (RPD), THEN report to the Radiological Analysis Facility (RAF).

5.2 IRET Duties 5.2.1 Implement procedure EPIP-RET-02A, "Radiation Protection Office/Radiological Analysis Facility (RPO/RAF) Activation."

5.2.2 Dispatch an IRET member to the Site Boundary Facility (SBF) to perform the following:

a. Assume the duties of the SBF Coordinator.

b. Implement EPIP-RET-04, "SBF Activation."

5.2.3 Restrict access into the RCA to emergency related activities as authorized by the Emergency Director (ED) or the RPD.

5.2.4 If any abnormal radioactive releases are occurring use EPIP-RET-02B, "Gaseous Effluent Release Path, Radioactivity, and Release Rate Determination."

5.2.5 IF a radioactive release is imminent or occurring, AND the Technical Support Center/Emergency Operations Facility (TSC/EOF) is NOT activated, THEN complete the following steps:

5.2.5.1 Obtain meteorological conditions from one of the following:

a. Plant Information Computer System

b. PPCS Computer Graphic Output in the TSC (Group Number 9 - Meteorological Data)

c. Chart recorders in the TSC 5.2.5.2 Perform off-site dose projections per EPIP-ENV-03C, "Dose Projection Using RASCAL Software."

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-RET-02 I Rev. X Title In-Plant Radiation Emergency Team Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 5 5.2.5.3 Advise the Shift Manager/Emergency Director (SM/ED) of the results.

Note At an Alert or higher, dosimetry will be issued to arrivingemergency personnel in the Security Buildingper EPIP-SEC-04, "Security Force Actions for Dosimetry Issue. "

5.2.6 IF an Alert or higher is declared, THEN issue dosimetry to all on-site personnel, AND read aloud two times on the Gai-tronics the following message:

Attention in the plant, attention In the plant, dosimetry is required for all on-site personnel. Dosimetry will be issued at all on-site emergency facilities and accountability centers.

5.2.7 WHEN initial issue of dosimetry is completed, THEN read aloud two times on the Gai-tronics the following message:

Attention In the plant, attention In the plant, dosimetry has been issued at all on-site emergency facilities and accountability centers. If you have not yet received dosimetry contact the RP Group at ext.

5.2.8 WHEN an emergency entry into the RCA is planned, THEN provide radiological protection coverage in accordance with EPIP-AD- I1, "Emergency Radiation Controls."

5.2.9 Assist in search and rescue operations in controlled areas.

5.2.10 Perform surveys outside the RCA to ensure contamination control.

5.2.11 If appropriate, plan for a shift relief per EPIP-AD-05, "Emergency Response Organization Shift Relief Guideline."

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-RET-02 I Rev. X Title In-Plant Radiation Emergency Team Kewaunee Nuclear Power Plant Emergency PlanImplementing Procedure Date JUL 31 2003 Page 4 of 5 5.3 In-Plant Radiation Emergency Team Support (IRETS) Personnel Note IRETS personnel may perform limited surveys (measure dose rates, collect smears, and airsamples). Dose rates shall be reviewed and smears and air samples shall be analyzed by a qualified Radiation Protection Technician (RPT).

5.3.1 WHEN assigned, perform the following duties:

a. Hand out dosimetry.

b. IF Potassium Iodide is approved for use, THEN aid in the distribution of the thyroid blocking agents in accordance with EPIP-AD-18, "Potassium Iodide Distribution."

c. Monitor for continued habitability of site facilities.

d. Perform other duties as assigned by Radiation Protection Supervision.

5.4 Subsequent Actions 5.4.1 When directed by the RPD or ED, perform the following:

5.4.1.1 Emergency surveys in accordance with EPIP-RET-02D, "Emergency Radiation Entry Controls and Implementation."

5.4.1.2 Effluent gas sampling in accordance with EPIP-RET-02B.

5.4.1.3 Document emergency exposures in accordance with EPIP-AD-1 1, "Emergency Radiation Controls."

5.4.1.4 Interface with Point Beach Nuclear Plant for the following additional support and resources, if needed:

• Personnel

• Emergency equipment

• Sample transportation

• Sample analysis

• Assistance with injuries 5.4.1.5 Maintain interim storage for highly contaminated samples.

5.4.1.6 Evaluate availability and procurement of supplies which may be required.

5.4.1.7 Interface with Environmental, Inc. for off-site sample analysis.

5.4.1.8 Evaluate methods of recovery planning in accordance with EPIP-AD-15, "Recovery Planning and Termination."

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-RET-02 I Rev. X Title In-Plant Radiation Emergency Team Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 5 of 5 6.0 Final Conditions 6.1 Plant Emergency has been Terminated.

7.0 References 7.1 EPIP-RET-02A, Radiation Protection Office/Radiological Analysis Facility (RPO/RAF)

Activation 7.2 EPIP-RET-02B, Gaseous Effluent Release Path, Radioactivity, and Release Rate Determination 7.3 EPIP-RET-02D, Emergency Radiation Entry Controls and Implementation 7.4 EPIP-RET-04, SBF Activation 7.5 EPIP-ENV-03C, Dose Projection Using RASCAL Software 7.6 EPIP-SEC-04, Security Force Actions for Dosimetry Issue 7.7 EPIP-AD-05, Emergency Response Organization Shift Relief Guideline 7.8 EPIP-AD-l 1, Emergency Radiation Controls 7.9 EPIP-AD-15, Recovery Planning and Termination 7.10 HP-01.020, Contamination Control of the Aurora Medical Center 7.11 EPIP-AD-18, Potassium Iodide Distribution 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records None 8.1.2 Non-OA Records None REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-RET-05 I Rev. I Title Site Boundary Dose Rates During Kewaunee Nuclear Power Plant Controlled Plant Cooldown Emergency Plan Implementing Procedure Date JUL 31 2003 Page 1 of 4 Reviewed By Richard Johnson Approved By Jerrie Morlino Nuclear 0 Yes PORC 0 Yes SRO Approval Of 3 Yes Safety Review Temporary Related 0Z No Required 0E No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for determining the activity release rate from the steam reliefs and the resultant instantaneous dose rates at the site boundary during controlled cooldown of the plant assuming primary-to-secondary leakage in the steam generators and steam release to the environment.

2.0 General Notes 2.1 This procedure is to be used in conjunction with Integrated Plant Emergency Operating Procedure ECA-3.1 and E-1.

3.0 Precautions and Limitations 3.1 Uncontrolled steam releases from the steam generators and applicable plume projection procedures can be found in EPIP-RET-02B, "Gaseous Effluent Sample and Analysis" and EPIP-ENV-03C, "Dose Projection Using Rascal Software."

3.2 Westinghouse guidance specifies that since the steam releases are controlled, the site boundary dose rate limits of the Offsite Dose Calculation Manual (ODCM) are to be followed rather than the emergency limits of Federal Regulation 10CFR100.

3.3 The instantaneous dose rate equations in Section 5.0 of this procedure relate to Equations 2.4 and 2.5 of the ODCM, where:

3.3.1 The default X/Q dispersion factor equals 3.6E-6.

3.3.2 Summation factors are the summation of the Total Body Dose Factors (Ki) and Skin Dose Factors (Li, Mi), listed in Table 2.1 of the ODCM, times the default X/Q.

Isotopes Ar-41, Kr-90, and Xe-137 are not included since they do NOT appear in EPIP-RET-02B, Table 2B.1, "Isotope Normalization Factor."

3.4 The steam line monitor calibration factors are taken from EPIP-RET-02B which is based on Fluor's evaluation performed under DCR 844, Task #965 (KPS-6266) of 3/16/8 1.

4.0 Initial Conditions 4.1 This procedure shall be implemented upon declaration of an Alert, Site Emergency, General Emergency, or when directed by the Shift Manager or Emergency Director.

J:\appdata\procpws\draft\epip\eretO5.doc-Amy Kudick/Amny Kudick-Jeanne Ferris REFERENCE USE

5.0 Procedure 5.1 Obtain the following information from the TSC or Control Room:

5.1.1 Reactor Trip time.

5.1.2 Steam release flow rate (cc/sec) from EPIP-TSC-08A, "Calculations for Steam Release from Steam Generators."

5.1.3 Steam line monitor readings from:

• R-31 1A Steam Line - LO (mRlhr)

• R-32 1A Steam Line - HI (R/hr)

• R-33 lB Steam Line - LO (mR/hr)

• R-34 lB Steam Line - HI (R/hr) 5.2 Using the following table, determine the correct steam line monitor calibration factor based on time since Reactor Trip:

STEAM LINE MONITOR TIME SINCE REACTOR TRIP CALIBRATION FACTOR R/hr 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> 14.5 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 16.7 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 20.3 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 30.4 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 67.9 1 day 887.0 1 week 3.08E + 4 1 month 1.93E + 4 REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-RET-05 I Rev. I Title Site Boundary Dose Rates During Kewaunee Nuclear Power Plant Controlled Plant Cooldown Emerfency Plan Implementing Procedure Date JUL 31 2003 I Page 3 of 4 5.3 Calculate the activity release rate as follows:

HIGHEST STEAM LINE STEAM MONITOR MONITOR RELEASE READING CAL. FACTOR FLOW RATE 1.06E-6 = Ci/sec R/hr uCi/cc cc/sec Ci/pCi R/hr x x x 1.OE-6 = _

5.4 Insert the activity release rate (Ci/sec) into the following equation to calculate the instantaneous total body dose rate at the site boundary:

INSTANTANEOUS DOSE ACTIVITY RELEASE SUMMATION x FACTOR = RATE TO THE TOTAL BODY RATE IN MREM/YEAR (Ci/sec) x 0.190 mRem/yr (TB) 5.5 The ODCM 3.4.1.a limit is 500 mRem/yr for the total body instantaneous dose rate.

5.6 Determine the dose rate to the skin as follows:

ACTIVITY RELEASE INSTANTANEOUS DOSE SUMMATION x FACTOR = RATE TO SKIN IN RATE MREM/WEAR (Ci/sec) x 0.339 mRem/yr (SKIN) 5.7 The ODCM 3.4. .a limit is 3,000 mRem/yr for the instantaneous dose rate to the skin.

6.0 Final Conditions 6.1 Plant Emergency has been Terminated or Recovery actions have begun and the Emergency Response Manager has suspended the use of EPIPs.

REFERENCE USE

I WISCONSIN PUBLIC SERVICE CORP. No. EPEP-RET-05 Rev. I Title Site Boundary Dose Rates During Kewaunee Nuclear Power Plant Controlled Plant Cooldown l Emergency Plan implementing Procedure Date JUL 31 2003 Page 4 of 4 7.0 References 7.1 KNPP Offsite Dose Calculation Manual 7.2 EPIP-RET-02B, Gaseous Effluent Sample and Analysis 7.3 IPEOP ECA-3.1, SGTR With Loss of Reactor Coolant - Subcooled Recovery Desired 7.4 EPIP-TSC-08A, Calculations for Steam Release from Steam Generators 7.5 EPIP-ENV-03C, Dose Projection Using Rascal Software 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records

• EPIP-RET-05 Procedures, Completed 8.1.2 Non-OA Records None REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-SEC-02 Rev. Z Title Security Force Response to Emergencies Kewaunee Nuclear Power Plant Emergency PlanImplementing Procedure Date JUL 31 2003 Page 1 of 24 Reviewed By Bryan Gagnon Approved By Jerrie Morlino Nuclear Q Yes PORC Q Yes SRO Approval Of o Yes Safety Review Temporary Related E No Required 0 No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for Security Force actions in the event of a declared emergency at the Kewaunee Nuclear Power Plant (KNPP).

2.0 General Notes 2.1 Instructions from SDP-51 (Security Force Duties) will be placed in packets at key locations - CAS, SAS, Security Shift Manager's office, and all posts for guidance for all Security Force Members (SFM).

3.0 Precautions and Limitations 3.1 IF the plant emergency is caused by a security event, or should a security event occur during a plant emergency, THEN the Contingency Plan and Security Implementing Procedures have priority over the actions in this procedure.

3.2 After declaration of a plant emergency, all Security Force Members shall wear dosimetry as directed by EPIP-SEC-04, "Security Force Actions for Dosimetry Issue."

3.3 IF the Security Building is declared uninhabitable, THEN ensure an adequate level of security effectiveness is maintained.

3.4 Ensure all vehicles designated for off-site use have their gas tanks topped off.

4.0 Initial Conditions 4.1 The Security Force shall implement this procedure upon declaration of a plant emergency.

5.0 Procedure 5.1 Site Protection Director (SPD) shall:

5.1.1 When a siren is sounded, immediately implement EPIP-SEC-03, "Personnel Assembly and Accountability."

5.1.2 For any announced Unusual Event, Alert, Site Emergency, or General Emergency, ensure that the Secondary Alarm Station (SAS) has immediately dispatched a Security

- Force Supervisor to the Control Room to act as the Notifier.

J:\appdata\procpws\draft\epip\esecO2.doc-Amy Kudick/Amy Kudick-Jeanne Ferris REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPLP-SEC-02 I Rev. Z Title Security Force Response to Emergencies Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 24 5.1.3 Contact the Radiation Protection Director (RPD) to obtain information on any controlled or potentially hazardous areas.

5.1.4 Notify the Support Activities Director (SAD) of the need for any search and rescue operations as determined by personnel accountability.

5.2 IF the event is an Alert or higher, THEN the Security Shift Manager shall:

5.2.1 Set up the TLD and dosimeter issue station per EPIP-SEC-04.

a. Issue dosimetry to all Security Force Members.

b. Ensure dosimetry is issued to all incoming personnel.

5.2.2 Designate a SFM for response to areas within the site boundary as determined to be necessary. The designated Officer shall:

a. Obtain a TLD and dosimeter.

Note NO OTHER INFORMATION SHOULD BE GIVEN BEYOND THE SCOPE OF THIS STATEMENT.

b. Inform members of the general public found on-site that they must leave the area by using the following statement:

"The plant site has been temporarily closed and you are requested to leave. Please do so at this time."

c. Inform KNPP contracted workers on-site and outside of the protected area of the emergency level declared and to report to the Security Building or the Simulator Training Building for assembly.

d. Make a tour of the following areas as necessary to ensure all personnel are responding to the emergency siren:

• Met Towers

• Sewage Treatment Plant

• Warehouse 1

• Substation (external) 5.2.3 Call in additional Security Force Members as necessary to augment the normal shift complement.

REFERENCE USE

T~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-SEC-02 I Rev. Z Title Security Force Response to Emergencies Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 24 5.2.4 IF plant personnel are to be evacuated per EPIP-SEC-05, "Personnel Evacuation,"

THEN assist the Site Protection Director (SPD) in the evacuation.

5.2.5 Divide ingress into the plant according to the following:

5.2.5.1 Until radiological conditions prohibit, the following personnel (Priority 1) shall proceed directly to the Security Building and will be expedited into the plant ahead of other Emergency Response Organization (ERO) personnel using appropriate latitude allowed by the Security Manual (i.e., 10CFR50.54 x and y).

a. Fire Team Members listed in KPB Emergency Telephone Directory

b. All directors and alternates listed in KPB Emergency Telephone Directory

c. Notifiers and communicators as listed in KPB Emergency Telephone Directory

d. NRC Resident Inspector 5.2.5.2 Until radiological conditions prohibit, all ERO personnel arriving from off-site shall proceed directly to the Security Building. Entry into the plant shall follow normal entry procedures, except all Priority 1 personnel shall be expedited past other personnel.

Note IF off-site non-NMC/WPSC emergency assistance (i.e., ambulance driver) arrives on-site, THEN they should be expedited into the plant.

5.2.5.3 IF any personnel who are not emergency responders are found or arrive on-site, THEN inform them to leave the site per Step 5.2.2.b or report to an assembly area per Step 5.2.2.c. Members of the media should be directed to Joint Public Information Center (JPIC) in Green Bay and given (920) 433-1400 or (800) 838-6192 to call for information.

5.2.6 IF the SPD requests site boundary control to be established further out then the Protected Area (PA) boundary, THEN proceed as follows:

5.2.6.1 Establish new boundaries.

5.2.6.2 IF any public roads are within the boundaries, THEN contact the appropriate County Sheriffs' Department for assistance.

5.2.6.3 Establish where dosimetry should be issued and turned in.

5.2.6.4 Establish recommended traffic flow into and out of the new controlled area.

REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-SEC-02 Rev. Z Title Security Force Response to Emergencies Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 4 of 24 5.2.6.5 Special consideration is appropriate for Priority 1 personnel responding to a pager activation.

5.2.6.6 Establish roadblocks with appropriate traffic flow directions USING DESIGNATED SFMs AS APPROPRIATE.

5.2.6.7 Move dosimetry issue in a coordinated effort with the roadblocks.

5.2.6.8 Personnel identification at roadblocks shall be accomplished by using Plant Access lists, personal recognition, plant key card, or other picture I.D., as appropriate.

5.2.7 IF the Security Building is declared uninhabitable, THEN proceed as follows:

5.2.7.1 Security Operational and Administrative functions shall be moved to and directed from another location chosen in conjunction with the SPD, Emergency Director (ED), and RPD.

5.2.7.2 The Security Shift Manager shall designate a SFM to obtain the following items for transport to the location chosen in Step 5.2.7.1:

a. Emergency key cards

b. Keys for the SAS and Armory

c. All additional security portable radios, spare batteries, and chargers

d. Necessary Contingency Equipment 5.2.7.3 Direct Central Alarm Station (CAS) to take over all security functions normally considered primary Secondary Alarm Station (SAS) functions and CAS shall disable SAS.

6.0 Final Conditions 6.1 None REFERENCE USE

7.0 References 7.1 EPIP-AD-07, Initial Emergency Notifications 7.2 EPIP-SEC-03, Personnel Assembly and Accountability 7.3 EPIP-SEC-04, Security Force Actions for Dosimetry Issue 7.4 EPIP-SEC-05, Personnel Evacuation 7.5 NAD-02.10, Responsibilities Under a Fire Emergency 7.6 SDP-51, Security Force Member Duties During a Declared Emergency 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records None 8.1.2 Non-OA Records None REFERENCE USE

POST 1 Notification to the EP Group must be made if changes are made to any Post Duties.

• • On the Emergency/Drill siren, evaluate all of your SMS and CCTV equipment to ensure we are NOT in a Security Event.

1. Start the Emergency Accountability Program on the SMS (begin emergency) no earlier than TWO minutes after the siren has sounded.

2. WHEN the program operation is confirmed, via the word EMERGENCY flashing on the CRT, read aloud two times over the Gai-tronics the message below:

"Attention all personnel. Emergency accountabilityhas been initiated. All badged personnel who are assembled shall swipe their key card in the SMS Accountability CardReader NOW. Any personnel NOT in an assembly area should ensure their supervisor or director is informed of theirstatus. "

3. Conduct a radio check with all Security personnel to ensure accountability of the Security Force.

Notify the Security Shift Manager of your results.

4. When initial accountability is complete, end the Emergency Program on the SMS.

5. Document all Gai-tronics announcements on paper other than the CAS Activity Log (CAL).

6. Direct all media questions to the JPIC in Green Bay at (920) 433-1400 or (800) 838-6192 for information.

Attachment A EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 6 of 24 REFERENCE USE

POST 2 Notification to the EP Group must be made if changes are made to any Post Duties.

~

• • On the Emergency/Drill siren, evaluate all of your SMS and CCTV equipment to ensure we are NOT in a Security Event.

I. IF notified by the Shift Manager/ED of a declared emergency, TIEN the SAS operator shall:

a. Immediately dispatch a Security Force Officer to the Control Room to act as the Security Notifier.

b. Inform the Security Shift Captain of the declared event.

c. Initiate all-call to ensure onsite Security staff is aware of the event.

d. Inform Security Shift Captain if personnel assembly is required.

Note If Shift Manager/EDhas not contacted SAS within S minutes of declaration, callthe Shift Manager to request direction on activation of the ERO.

e. Activate the pagers as directed by the Shift Manager/ED to notify the ERO to respond to their emergency response facility.

f. Verify Shift Manager/ED has directed the envelope to use which contains the pager access code and pager message code to activate ERO pagers per the ERO Event Notification form.

(Attachment B to EPIP-AD-07).

g. Complete the ERO Event Notification form.

2. Obtain a list of Accountability Area Coordinators (See ETD 01A, "Kewaunee Emergency Response Organization (ERO) Call List").

3. Call-in one person from each Accountability Area and circle the name of the person contacted.

Note During normalbusiness hours, call them on the Gai-tronicsto ensure they assume their duties.

4. After 5 minutes generate an emergency report.

5. Ten minutes into the initial accountability generate an emergency report every minute until accountability is complete OR as requested.

6. Help the Accountability Coordinator when a person is unaccounted for (i.e., run a report on the person who is unaccounted for).

7. Continue to monitor all SMS and CCTV equipment to ensure security is maintained.

8. Support additional report requests from the MAC.

9. Direct all media questions to the JPIC in Green Bay at (920) 433-1400 or (800) 838-6192 for information.

Attachment B EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 7 of 24 REFERENCE USE

POST 3 Notification to the EP Group must be made if changes are made to any Post Duties.

"-~- ** On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. No additional duties.

2. Remain posted unless health conditions arise. Report those conditions to the Security Shift Manager.

Attachment C EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 8 of 24 REFERENCE USE

POST 4 Notification to the EP Group must be made if changes are made to any Post Duties.

On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. Respond to the Control Room.

2. Start notifier duties.

3. When relieved, report to the Security Shift Manager.

4. Direct all media questions to the JPIC in Green Bay at (920) 433-1400 or (800) 838-6192 for information.

Attachment D EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 9 of 24 REFERENCE USE

POST 5 Notification to the EP Group must be made if changes are made to any Post Duties.

"'-**" On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. Report to the Security Building and assume lane search duties.

2. Set up the dosimetry issue station per EPIP-SEC-04 only if the declared emergency is at the "alert" status or higher.

3. If the SMS is offline, log all personnel in on PA/VA logs and the emergency check-in sheets located with the MACC. See EPIP-SEC-03, Step 5.4.1 for more information.

Attachment E EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 10 of 24 REFERENCE USE

POST 6 Notification to the EP Group must be made if changes are made to any Post Duties.

• • On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. Obtain the EPIPS binders (3 total), the PCS telephone, the FFD clipboard, FED keys from SAS and turn on the intoxilizer. Report to the visitor counter.

Note Have the first non-emergency responseperson (badgedperson only) take over the dosimetry issue at the entrance turnstile area.

2. Ensure accountability is being performed (SMS Emergency Program started). Document the start and completion of initial accountability. NOTE: The Security Shift Manager assumes the duties of the MAC and SPD until the designated persons arrive.

3. Ensure NO tours are being suspended.

4. Ensure the Dosimetry Issue Station is set up at the entrance turnstyle area.

5. Ensure the site is clear of the public. Ensure the gas tanks are filled on the three (3) designated WPS vans used for emergency purposes. The extra keys are kept in SAS. Notify the Kewaunee Sheriff Dept. when OCA clearing problems exist.

6. Conduct accountability on any visitors on-site (EPIP-SEC-03, Steps 5.2.3 and 5.2.4).

7. Give safe route map (with SPD/RPD guidance) to all persons exiting the site. The map is located in the EPIP binder (Figure EPIPFG-SEC-05-01).

8. Upon evacuation decision, ensure the collection of dosimetry of all persons exiting the site and key cards for disabling (EPIP-SEC-05).

9. Update SFMs as to the current/changing conditions as often as possible.

Attachment F EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 11 of 24 REFERENCE USE

POST 7 Notification to the EP Group must be made if changes are made to any Post Duties.

On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. No additional duties.

2. Should health conditions arise, report those conditions to the Security Shift Manager.

Attachment G EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 12 of 24 REFERENCE USE

POST 8 Notification to the EP Group must be made if changes are made to any Post Duties.

~

• • On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. If on assigned tour, complete tour.

2. Report to HP and pick up dosimetry for yourself, Post 6 (SSS), Post 2 (SAS), Post 14 (Visitor Counter), and all OCA SFMs.

3. If evacuation is required via the Sallyport, respond as directed by the Security Shift Manager.

Attachment H EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 13 of 24 REFERENCE USE

POST 9 Notification to the EP Group must be made if changes are made to any Post Duties.

-~ ** On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. Report to HP and pick up and issue dosimetry for yourself and the following posts:

Post 1 - CAS Post 11 - D.O.

Post 4 - FIELD SUPERVISOR Post 3 - Door # 8 Post 7 - HUT 2 Post 8 - HUT 2 Post 10 - IPO Note If there is no fire, pick up dosimetryfor the watchpersons.

2. Should health conditions arise, report those conditions to the Security Shift Manager.

3. Direct all media questions to the JPIC in Green Bay at (920) 433-1400 or (800) 838-6192 for information.

Attachment I EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 14 of 24 REFERENCE USE

POST 10 Notification to the EP Group must be made if changes are made to any Post Duties.

• • On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. Assume the duties of Post 9 until Post 9 has collected and issued the dosimetry for all SFMs in the power block.

2. Should health conditions arise, report those conditions to the Security Shift Manager.

3. Direct all media questions to the JPIC in Green Bay at (920) 433-1400 or (800) 838-6192 for information.

Attachment J EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 15 of 24 REFERENCE USE

POST I 1 Notification to the EP Group must be made if changes are made to any Post Duties.

~- --- ** On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. No additional duties.

2. Respond as directed by the Security Shift Manager.

3. Should health conditions arise, report those conditions to the Security Shift Manager.

Attachment K EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 16 of 24 REFERENCE USE

POST 12 Notification to the EP Group must be made if changes are made to any Post Duties.

'- --- ** On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. No additional duties.

2. Should health conditions arise, report those conditions to the Security Shift Manager.

Attainment L EPIP-SEC-02 11eV. Z Date: JUL 31 2003 Page 17 of 24 REFERENCE USE

POST 14 Notification to the EP Group must be made if changes are made to any Post Duties.

On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. No additional duties.

2. Assist Post 5 with security building duties.

3. Assist the Security Shift Manager as needed.

4. Direct all media questions to the JPIC in Green Bay at (920) 433-1400 or (800) 838-6192 for information.

Attachment M EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 18 of 24 REFERENCE USE

POST 18 Notification to the EP Group must be made if changes are made to any Post Duties.

'~- On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. When directed, restrict site access to only ERO members or approved emergency personnel.

2. Verify ERO personnel against the ETD 01A (ERO Call List) List is located in Post #18's shift binder.

3. Direct all media questions to the JPIC in Green Bay at (920) 433-1400 or (800) 838-6192 for information.

4. Should health conditions arise, report those conditions to the Security Shift Manager.

Attachment N EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 19 of 24 REFERENCE USE

POST 19 Notification to the EP Group must be made if changes are made to any Post Duties.

~ ** On the EmergencylDrill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. Use the public address system on the security vehicle and make the following announcement to the general public found on-site:

NO OTHER INFORMATION SHOULD BE GIVEN BEYOND THE SCOPE OF THIS STATEMENT.

I "The plant site has been temporarily closed and you are requested to leave. Please do so at this time."

2. Inform contractors working in the OCA of the emergency level declared and to report to the Simulator Training Facility or the Security Building for assembly.

3. Tour entire OCA to include the following:

Met Towers Sewage Treatment Plant Warehouse # 1 Substation (external)

Ensure all personnel in these areas are responding to the emergency siren.

Remain cognizant of all personnel outside of the PA who remain on-site.

4. Ensure gas tanks are topped off on the 3 designated WPS vans. These keys have pagers attached and are located at visitor counter. If the vans are in use, once all pagers have been activated, personnel will return the vans to security.

5. Stop at the security building and pick up dosimetry for all of the OCA personnel.

6. Direct all media questions to the JPIC in Green Bay at (920) 433-1400 or (800) 838-6192 for information.

Attachment 0 EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 20 of 24 REFERENCE USE

POST 20 1l 21 Notification to the EP Group must be made if changes are made to any Post Duties.

• • On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. Assist Posts 18 or 19 as needed.

2. Should health conditions arise, report those conditions to the Security Shift Manager.

3. Direct all media questions to the JPIC in Green Bay at (920) 433-1400 or (800) 838-6192 for information.

Attachment- P- ---- --- -- -Rev. Z EPIP-SEC-02 Date: JUL 31 2003 Page 21 of 24 REFERENCE USE

POST 22 /l 52 Notification to the EP Group must be made if changes are made to any Post Duties.

I ** On the Emergency/Drill siren, evaluate the situation to ensure we are NOT in a Security Event.

1. Respond as directed by the Security Shift Manager.

2. Direct all media questions to the JPIC in Green Bay at (920) 433-1400 or (800) 838-6192 for information.

Attachment Q EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 22 of 24 REFERENCE USE

POST 53 Notification to the EP Group must be made if changes are made to any Post Duties.

A-- ** On the Emergency/Drill siren, if the event requires Fire Brigade response you shall assume your Fire Brigade duties.

1. If the event does NOT require fire brigade response, continue performing fire check duties.

2. Should health conditions arise, report those conditions to the Security Shift Manager.

If responding to a fire, leave the fire check clipboard in CAS.

Attachment R EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 23 of 24 REFERENCE USE

POST 54 Notification to the EP Group must be made if changes are made to any Post Duties.

--** On the Emergency/Drill siren, if the event requires Fire Brigade response you will be relieved by Post 5 so that you can assume your Fire Brigade duties.

1. If the event does NOT require fire brigade response, remain at lane search and control access through the search equipment. Ensure only Emergency Response Organization personnel are allowed into the protected area. All others shall be instructed to report upstairs to Classroom "C". If unsure if the person is ERO personnel, refer to ETD 01A (ERO Call List).

2. Set up the ribbon and table for the dosimetry issue station and route all personnel accordingly.

3. Assist in dosimetry issue until otherwise directed by the Security Shift Manager.

4. Direct all media questions to the JPIC in Green Bay at (920) 433-1400 or (800) 838-6192 for information.

Attachment S EPIP-SEC-02 Rev. Z Date: JUL 31 2003 Page 24 of 24 REFERENCE USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-08B Rev. H Title STMRLS Computer Program Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 1 of 3 Reviewed By John Helfenberger Approved By Jerrie Morlino Nuclear 0 Yes PORC El Yes SRO Approval Of 0dYes Safety Review Temporary Related El No Required 0 No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for tracking revisions to the steam release program software for historical reasons.

2.0 General Notes 2.1 This program can be used in conjunction with EPIP-TSC-08A, "Calculations for Steam Release from Steam Generators," whenever a steam release calculation is needed in support of emergency efforts during a declared emergency at the Kewaunee Nuclear Power Plant.

3.0 Precautions and Limitations 3.1 None 4.0 Initial Conditions 4.1 This procedure shall be implemented upon declaration of an Alert, Site Emergency, General Emergency, or when directed by the Shift Manager or Emergency Director.

5.0 Procedure 5.1 The Lead Plant Reactor Engineer is responsible for the following:

5.1.1 Ensuring that all changes to this procedure are accomplished in accordance with GNP-03.01.01, "Directive and Procedure Administrative Controls."

5.1.2 Ensuring the requirements of RE-27, "Control of Computer Codes," for the STMRLS Program are met.

5.1.3 Ensuring program disks are distributed in the proper locations.

5.1.4 Ensuring the requirements of NAD-05.23, "Computer Software Management Program," are met for the STMRLS Computer Program.

5.2 The STMRLS Program shall be controlled after initial approval by RE-27 as a "Safety Related" Program and shall be reviewed annually to ensure the program is up-to-date.

<_, 5.3 Changes to the STMRLS Program shall be made in accordance with Section 4.2, "Computer Code Revisions," of RE-27.

j:\appdata\procpws\draft\epip\etscO8b.doc-Amny Kudick/Arny Kudick-Ed Coen INFORMATION USE

WISCONSIN PUBLIC SERVICE CORP. No. EP1P-TSC-08B Rev. H Title STMRLS Computer Program Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 3 5.4 All documentation concerning a STMRLS Program revision shall be kept in the STMRLS Programmer/User's Manual.

5.5 All program disks, with the exception of the master disk (which is kept in the Reactor Engineering file), shall be compiled by the IT Group. Reactor Engineering personnel will verify the accuracy of the RUN-ONLY code by comparing the results from the code to the existing benchmark. This shall be done before the copies are distributed.

5.6 Program disks shall be labeled by the Lead Plant Reactor Engineer with the following information:

EPIP-TSC-08B - STMRLS Computer Program Date: October 2. 1990 Revision: A Copy Number:

5.7 Executable copies of the program are distributed by the IT Group as follows:

COPY LOCATION NUMBER NA N:\steamrlO\STMRLS 1& 3 TSC SAM Room - Cabinet One 4 MASTER NPM Trailer - Information Technology Group Master File 6.0 Final Conditions 6.1 Plant Emergency has been Terminated or Recovery actions have begun and the Emergency Response Manager has suspended the use of EPIPs.

INFORMATION USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-08B Rev. H Title STMRLS Computer Program Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 3 of 3 7.0 References 7.1 STMRLS Programmer/User's Manual 7.2 EPIP-TSC-01, Technical Support Center Organization and Responsibilities 7.3 EPIP-TSC-08A, Calculations for Steam Release from Steam Generators 7.4 RE-27, Control of Computer Codes 7.5 NAD-05.23, Computer Software Management Program 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 QA Records None 8.1.2 Non-OA Records None INFORMATION USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 I Rev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 1 of 15 Reviewed By Dave Lohman Approved By Jerrie Morlino Nuclear o Yes PORC O Yes SRO Approval Of E Yes Safety Review Temporary Related 0 No Required 0 No Changes Required 0 No 1.0 Purpose 1.1 This procedure provides instruction for technical guidance to Severe Accident Management Operations (SAMOPs) and Technical Support Center staff members during implementation of the Kewaunee Nuclear Power Plant (KNPP) Integrated Plant Emergency Operating Procedures (IPEOPs).

2.0 General Notes 2.1 This procedure applies to steps in the IPEOPs that require consultation with the Plant Technical Support Engineering staff.

2.2 Amplifying information for most steps can be found in the IPEOP background documents.

3.0 Precautions and Limitations 3.1 This procedure should only be used as a guide to the Technical Support staff. Plant parameters should be monitored to determine plant conditions prior to implementation of these guidelines.

3.2 Shift Manager and Event Operations Director approval is required to activate the Post-Accident Leakage Control System.

3.3 IPEOP implementation may lead to violation of plant Technical Specifications. The NRC must be notified of any violation per 10CFR50.54(x).

4.0 Initial Conditions 4.1 This procedure is used during a declared emergency when plant conditions require assistance by the Technical Support staff in the execution of IPEOPs.

j:.\appdata\procpws\draft\epip\etsc1O.doc-Christine Simmons/Christine Simmons-Kerry Beaman INFORMATION USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 Rev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 2 of 15 5.0 Procedure 5.1 IPEOP E-1: LOSS OF REACTOR OR SECONDARY COOLANT 5.1.1 Evaluate Plant Status (IPEOP Step 17):

a. This step instructs the operator to consult Technical Support staff to determine if E-MDS-30, Post-Accident Leakage Control System, should be implemented.

1. Post-Accident Leakage Control System is actuated if Auxiliary Building radiation levels are increasing or significant core damage has occurred.

2. Procedure E-MDS-30 should be implemented at this time because the procedure requires local actions which may be prohibited following transfer to Containment sump recirculation due to high radiation levels.

b. Chemistry is contacted to:

1. Start up the Containment Hydrogen Monitoring System (EPIP-RET-03C).

2. Obtain primary and secondary samples per other EPIPs.

5.2 IPEOP E-1: LOSS OF REACTOR OR SECONDARY COOLANT 5.2.1 Request a dose projection on steaming steam generators from the Technical Support Staff (IPEOP Step 21):

a. IF a large break LOCA has occurred, THEN the secondary side may still be relatively hot and at a pressure significantly higher than the Reactor Coolant System (RCS).

b. IF this is the case, THEN the operator should attempt to cooldown and depressurize the steam generators.

1. A dose projection is requested to be performed, per EPIP-RET-05.

Radioactivity may have accumulated in the steam generators due to small leaks existing prior to the LOCA. Radiation remains in the steam generators despite any secondary-to-primary back leakage that may have occurred.

INFORMATION USE

WISCONSIN PUBLIC SERVICE CORP. No. EPEP-TSC-10 I Rev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant I Emergency Plan Implementing Procedure Date JUL 31 2003 Page 3 of 15 5.3 IPEOP E-1: LOSS OF REACTOR OR SECONDARY COOLANT 5.3.1 Determine if Reactor Vessel Head Should Be Vented (IPEOP Step 22):

a. The possibility exists for a noncondensable bubble to form in the reactor vessel head region during certain LOCA events.

1. This exists whenever saturation conditions exist in the vessel head or gas is injected into or generated within the RCS.

2. The reactor vessel head might have to be vented using the Reactor Vessel Head Vent System to prevent the bubble from growing to the extent that core cooling flow is adversely affected.

5.3.2 Identify Growth of a Void in the Vessel:

a. Monitor Reactor Vessel Liquid Inventory System (RVLIS) for void growth.

RVLIS is the primary means of determining if voids exist.

b. In addition to RVLIS, other indirect indications of voids in the RCS are listed below.

1. Pressurizer level response to RCS pressure changes may not be normal if voids exist in the RCS.

a) Pressurizer Level may decrease during a RCS pressurization due to void compression or condensation.

b) Pressurizer Level may rise rapidly during a spraying operation due to void expansion or generation.

2. If reactor vessel head temperature is equal to or greater than saturation temperature, a steam bubble has been generated in the reactor vessel head.

3. Noncondensable voids in the RCS may occur after either a complete SI accumulator tank discharge or an inadequate core cooling condition.

c. IF a steam void is formed during post-LOCA cooldown and depressurization or during a steam generator tube rupture recovery, THEN no attempt should be made to condense the void through repressurization.

1. Only RXCP restart or continued cooling from CRDM fans should be used.

2. Refer to IPEOP FR-I.3 and Section 5.27 of this procedure.

INFORMATION USE

Title Technical Support for IPEOPs WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 IRev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant

-l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 4 of 15 5.4 IPEOP E- 1: LOSS OF REACTOR OR SECONDARY COOLANT 5.4.1 Consult with Emergency Director for Additional Recovery Actions (IPEOP Step 23):

a. This step instructs the operator to notify the Emergency Director when the hydrogen concentration inside containment is greater than 6% in dry air.

1. The possible actions to be taken with high hydrogen concentrations in containment are dependent on the containment conditions, the event progression, and off-site conditions.

b. Evaluate actions to be taken for high containment hydrogen concentration using SAG-7.

5.5 IPEOP E-1: LOSS OF REACTOR OR SECONDARY COOLANT 5.5.1 Evaluate Long-Term Plant Status (IPEOP Step 24):

a. The equipment needed to function following an event has been designed so that operation for extremely long periods of time is possible.

1. This allows the Plant Engineering staff time to evaluate the event and develop recovery procedures so that the plant can be repaired and brought back to service.

2. Priority should be given, however, to ensure that equipment needed for accident mitigation remains operable.

b. Actions must be taken to adjust recirculation sump pH to between 8 and 10.5 within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the start of the leak to prevent component stress corrosion cracking.

INFORMATION USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 lRev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 5 of 15 5.6 IPEOP ES-1.2: POST-LOCA COOLDOWN AND DEPRESSURIZATION 5.6.1 Check if RHR System Should Be Placed in Service (IPEOP Step 24):

a. The RHR System is designed to operate below specific RCS pressure and temperature conditions (RCS hot leg temperature less than 4000 F and RCS pressure less than 425 psig). Depending on the size of the break, different actions should be taken.

1. For smaller breaks, the SI pumps will have been stopped in most cases and most of the RWST water will still be available by the time the RHR System entry criteria are satisfied.

a) For these cases, the RHR System could be placed in service with the RHR pumps taking suction from the hot legs.

b) Any high-head pump left running would remain aligned in the cold leg injection mode taking suction from the RWST.

c) When charging flow is established, the injection source is also from the RWST.

2. For larger breaks, the RWST level will eventually decrease to the recirculation transfer setpoint and at least one RHR pump must be used for containment sump recirculation.

a) IF the RHR System is not placed in service, THEN the system can remain in the long-term recirculation mode with the core residual heat being dissipated through the safeguards (RHR) heat exchangers.

5.6.2 Consider These Three Important Factors:

a. The RWST (or alternate) source of injection (make-up) water must be available for operating high-head SI, charging pumps, and RHR in split-train operation.

b. Confirmation of system availability, including all pumps, valves, and adequate inventory in the RCS to preclude steam from entering the RHR pump suction, must take place before RHR operation can begin.

c. Auxiliary building radiation levels should be evaluated.

1. Placing RHR in service in the normal lineup will cause potentially highly radioactive fluid to be transported through lines that did not have radioactive fluid in them prior to the event.

2. Care should be taken to minimize the spread of radioactive fluid through the CVCS system, if possible.

3. Additionally, during a design basis LOCA, some valves and equipment (such as RHR-1OA and RHR-1OB) are projected to be in radiation fields of 1,000 R/hr or more due to "shine" from the containment building.

INFORMATION USE

a I WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 IRev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 6 of 15 5.7 IPEOP ES-1.2: POST-LOCA COOLDOWN AND DEPRESSURIZATION 5.7.1 Consult with Emergency Director for Additional Recovery Actions (IPEOP Step 25):

a. This step instructs the operator to notify the Emergency Director when the hydrogen concentration inside containment is greater than 6% in dry air.

1. The possible actions to be taken with high hydrogen concentrations in containment are dependent on the containment conditions, the event progression, and off-site conditions.

b. Evaluate actions to be taken for high containment hydrogen concentration using SAG-7.

5.8 IPEOP ES-1.2: POST-LOCA COOLDOWN AND DEPRESSURIZATION 5.8.1 Evaluate Long-Term Plant Status (IPEOP Step 27):

a. After reaching and maintaining cold shutdown conditions, the plant is effectively stable for the long term.

1. IF the SI pumps were stopped, THEN RCS subcooling would have been restored and RCS circulation flow should have been adequate to prevent boron precipitation.

2. The transfer of hot leg recirculation would probably not be needed for the smaller breaks where SI flow was reduced.

5.9 IPEOP ES-3.1: POST-SGTR COOLDOWN USING BACKFILL 5.9.1 Evaluate Long-Term Plant Status (IPEOP Step 12):

a. The equipment needed to function following an event has been designed so that operation for extremely long periods of time is possible.

1. This allows the Plant Engineering staff time to evaluate the event and develop recovery procedures so that the plant can be repaired and brought back to service.

2. Priority should be given, however, to ensure that equipment needed for accident mitigation remains operable.

INFORMATION USE

-~~~~~~~~~~~~il TcnclSpotfrIE~

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 I Rev. L Title Technical Support for EPEOPs Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 l Page 7 of 15 5.10 IPEOP ES-3.2: POST-SGTR COOLDOWN USING BLOWDOWN 5.10.1 Evaluate Long-Term Plant Status (IPEOP Step 16):

a. The equipment needed to function following an event has been designed so that operation for extremely long periods of time is possible.

1. This allows the Plant Engineering staff time to evaluate the event and develop recovery procedures so that the plant can be repaired and brought back to service.

2. Priority should be given, however, to ensure that equipment needed for accident mitigation remains operable.

5.11 IPEOP ES-3.3: POST-SGTR COOLDOWN USING STEAM DUMP 5.11.1 Evaluate Long-Term Plant Status (IPEOP Step 16):

a. The equipment needed to function following an event has been designed so that operation for extremely long periods of time is possible.

1. This allows the Plant Engineering staff time to evaluate the event and develop recovery procedures so that the plant can be repaired and brought back to service.

2. Priority should be given, however, to ensure that equipment needed for accident mitigation remains operable.

5.12 IPEOP ECA-0.0: LOSS OF ALL AC POWER 5.12.1 IF core exit temperatures are greater than 12000 F and increasing, THEN go to SACRG-1, Severe Accident Control Room Guideline Initial Response (IPEOP Step 30).

a. The Severe Accident Management Guidelines (SAMGs) are entered from the ERGs by Control Room Operators when core damage occurs.

1. The ERG to SAMG transition uses, as part of the transition criteria, a core exit thermocouple temperature indication of greater than 12000 F to indicate the need to transition from the ERGs to the SAMGs.

2. The 1200TF criteria for transition from the ERGs to the SAMGs is identical to the 1200'F criteria on the Core Cooling Critical Safety Function Status Tree.

b. IF the Operator enters this step and core exit TC temperatures are greater than 1200TF and increasing, THEN the Operator should transition to the SAMGs.

1. This condition indicates that all attempts to restore core cooling have failed, core damage cannot be prevented, and the Operator should go to the SAMGs.

INFORMATION USE

Title Technical Support for IPEOPs WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 I Rev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant l Emergency PlanImplementing Procedure - Date JUL 31 2003 Page 8 of 15 5.13 IPEOP ECA-1.1: LOSS OF EMERGENCY COOLANT RECIRCULATION 5.13.1 Consult with Emergency Director to determine if RHR System should be placed in service (IPEOP Steps 23 and 35).

a. The RHR System is designed to operate below specific RCS pressure and temperature conditions.

1. IF previous actions to establish conditions were not complete, THEN this step directs the Operator to continue with the procedure for completion of the actions.

2. The plant staff should determine RHR System availability.

3. RHR System availability includes:

a) Confirmation of equipment needed for RHR System operation (RHR suction valves, RHR pumps, etc.).

b) Confirmation of adequate liquid inventory in the RCS to preclude steam from entering the RHR pump suction.

5.13.2 Consult with Emergency Director for Additional Recovery Actions (IPEOP Step 37):

a. This step instructs the operator to notify the Emergency Director when the hydrogen concentration inside containment is greater than 6% in dry air.

1. The possible actions to be taken with high hydrogen concentrations in containment are dependent on the containment conditions, the event progression, and off-site conditions.

b. Evaluate actions to be taken for high containment hydrogen concentration using SAG-7.

5.13.3 Consult with Emergency Director (IPEOP Step 38):

a. This procedure provides generic instructions for cooldown and depressurization of the plant to atmospheric conditions following a loss of emergency coolant recirculation.

b. After the steps have been completed and cold shutdown conditions have been maintained, the Plant Engineering staff has time to evaluate the event and develop recovery procedures so that the Plant can be repaired and brought back to service.

INFORMATION USE

Technical Support for IPEO~~~~~~~~~~~~~~~~~~~

Title WISCONSIN PUBLIC SERVICE CORP. No. EPIIP-TSC-10 I Rev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL31 2003 Page 9 of 15 5.14 IPEOP ECA-2.1: UNCONTROLLED DEPRESSURIZATION OF BOTH SGs 5.14.1 Evaluate Long-Term Plant Status (IPEOP Step 43):

a. The equipment needed to function following an event has been designed so that operation for extremely long periods of time is possible.

1. This allows the Plant Engineering staff time to evaluate the event and develop recovery procedures so that the plant can be repaired and brought back to service.

2. Priority should be given, however, to ensure that equipment needed for accident mitigation remains operable.

5.15 IPEOP ECA-3.1: SGTR WITH LOSS OF REACTOR COOLANT - SUBCOOLED RECOVERY DESIRED 5.15.1 Consult with Emergency Director (IPEOP Step 14):

a. This step instructs the Operator to consult with the Emergency Director when ruptured SG narrow range level exceeds 92%.

b. An inability to prevent SG overfill may result from a rupture large enough to require the use of ECA-3.2, "SGTR with Loss of Reactor Coolant - Saturated Recovery Desired."

5.16 IPEOP ECA-3.1: SGTR WITH LOSS OF REACTOR COOLANT - SUBCOOLED RECOVERY DESIRED 5.16.1 Check if RHR System Should Be Placed in Service (IPEOP Step 36):

a. The RHR System is designed to operate below specific RCS pressure and temperature conditions (RCS hot leg temperature less than 4000 F and RCS pressure less than 425 psig).

b. When such conditions are established, the RHR System should be placed in service to complete the cooldown to cold shutdown and provide long-term cooling.

5.16.2 Consider These Three Important Factors:

a. The RWST (or alternate) source of injection (makeup) water must be available for operating high-head SI, charging pumps, and RHR in split-train operation.

b. Confirmation of system availability including all pumps, valves, and adequate inventory in the RCS to preclude steam from entering the RHR pump suction must take place before RHR operation can begin.

INFORMATION USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 IRev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 10 of 15

c. Auxiliary building radiation levels should be evaluated.

1. Placing RHR in service in the normal lineup will cause potentially highly radioactive fluid to be transported through lines that did not have radioactive fluid in them prior to the event.

2. Care should be taken to minimize the spread of radioactive fluid through the CVCS System if possible.

3. During some design basis accidents, some valves and equipment (such as RHR-1OA and RHR-1OB) are projected to be in radiation fields of 1,000 R/hr or more due to "shine" from the containment building.

5.17 IPEOP ECA-3. 1: SGTR WITH LOSS OF REACTOR COOLANT - SUBCOOLED RECOVERY DESIRED 5.17.1 Consult with Emergency Director for Additional Recovery Actions (IPEOP Step 37):

a. This step instructs the operator to notify the Emergency Director when the hydrogen concentration inside containment is greater than 6% in dry air.

1. The possible actions to be taken with high hydrogen concentrations in containment are dependent on the containment conditions, the event progression, and off-site conditions.

b. Evaluate actions to be taken for high containment hydrogen concentration using SAG-7.

5.18 IPEOP ECA-3.1: SGTR WITH LOSS OF REACTOR COOLANT - SUBCOOLED RECOVERY DESIRED 5.18.1 Evaluate Long-Term Plant Status (IPEOP Step 40):

a. After reaching and maintaining cold shutdown conditions, the plant is effectively stable for the long term.

1. This allows the Plant Engineering staff time to evaluate the event and develop recovery procedures so that the plant can be repaired and brought back to service.

2. Priority should be given, however, to ensure that equipment needed for accident mitigation remains operable.

INFORMATION USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 I Rev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant 1 Emergency Plan Impkementing Procedure Date JUL 31 2003 Page 11 of 15 5.19 IPEOP ECA-3.2: SGTR WITH LOSS OF REACTOR COOLANT - SATURATED RECOVERY DESIRED 5.19.1 Check if RHR System Should Be Placed in Service (IPEOP Step 28):

a. The RHR System is designed to operate below specific RCS pressure and temperature conditions (RCS hot leg temperature less than 4000 F and RCS pressure less than 425 psig).

b. When such conditions are established, the RHR System should be placed in service to complete the cooldown to cold shutdown and provide long-term cooling.

5.19.2 Consider These Three Important Factors:

a. The RWST (or alternate) source of injection (make-up) water must be available or operating high-head SI, charging pumps, and RHR in split-train operation.

b. Confirmation of system availability including all pumps, valves, and adequate inventory in the RCS to preclude steam from entering the RHR pump suction must take place before RHR operation can begin.

c. Auxiliary building radiation levels should be evaluated.

1. Placing RHR in service in the normal lineup will cause potentially highly radioactive fluid to be transported through lines that did not have radioactive fluid in them prior to the event.

2. Care should be taken to minimize the spread of radioactive fluid through the CVCS System if possible.

3. During some design basis accidents, some valves and equipment (such as RHR-1OA and RHR-1OB) are projected to be in radiation fields of 1,000 R/hour or more due to "shine" from the containment building.

5.20 IPEOP ECA-3.2: SGTR WITH LOSS OF REACTOR COOLANT - SATURATED RECOVERY DESIRED 5.20.1 Consult with Emergency Director for Additional Recovery Actions (IPEOP Step 29):

a. This step instructs the operator to notify the Emergency Director when the hydrogen concentration inside containment is greater than 6% in dry air.

1. The possible actions to be taken with high hydrogen concentrations in containment are dependent on the containment conditions, the event progression, and off-site conditions.

b. Evaluate actions to be taken for high containment hydrogen concentration using SAG-7.

INFORMATION USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 Rev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 12 of 15 5.21 IPEOP ECA-3.2: SGTR WITH LOSS OF REACTOR COOLANT - SATURATED RECOVERY DESIRED 5.21.1 Evaluate Long-Term Plant Status (IPEOP Step 32):

a. After reaching and maintaining cold shutdown conditions, the plant is effectively stable for the long term.

1. This allows the Plant Engineering staff time to evaluate the event and develop recovery procedures so that the plant can be repaired and brought back to service.

2. Priority should be given, however, to ensure that equipment needed for accident mitigation remains operable.

5.22 IPEOP ECA-3.3: SGTR WITHOUT PRESSURIZER PRESSURE CONTROL 5.22.1 Evaluate Long-Term Plant Status (IPEOP Step 37):

a. After reaching and maintaining cold shutdown conditions, the plant is effectively stable for the long term.

1. This allows the Plant Engineering staff time to evaluate the event and develop recovery procedures so that the plant can be repaired and brought back to service.

2. Priority should be given, however, to ensure that equipment needed for accident mitigation remains operable.

5.23 IPEOP FR-S.1: RESPONSE TO NUCLEAR POWER GENERATION/ATWS 5.23.1 IF core exit temperatures are greater than 1200¶F and increasing, THEN go to SACRG-1, Severe Accident Control Room Guideline Initial Response (IPEOP Step 18).

a. The Severe Accident Management Guidelines (SAMGs) are entered from the ERGs by Control Room Operators when core damage occurs.

1. The ERG to SAMG transition uses, as part of the transition criteria, a core exit thermocouple temperature indication of greater than 1200 0F to indicate the need to transition from the ERGs to the SAMGs.

2. The 1200 0F criteria for transition from the ERGs to the SAMGs is identical to the 1200'F criteria on the Core Cooling Critical Safety Function Status Tree.

b. IF the Operator enters this step and core exit TC temperatures are greater than 1200 0F and increasing, THEN the Operator should transition to the SAMGs.

1. This condition indicates that all attempts to restore core cooling have failed, core damage cannot be prevented, and the Operator should go to the SAMGs.

INFORMATION USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 IRev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant Emergency Plan Implementing Procedure Date JUL 31 2003 Page 13 of 15 5.24 IPEOP FR-C.1: RESPONSE TO INADEQUATE CORE COOLING 5.24.1 Consult with Emergency Director for Additional Recovery Actions (IPEOP Step 7):

a. This step instructs the operator to notify the Emergency Director when the hydrogen concentration inside containment is greater than 6% in dry air.

1. The possible actions to be taken with high hydrogen concentrations in containment are dependent on the containment conditions, the event progression, and off-site conditions.

b. Evaluate actions to be taken for high containment hydrogen concentration using SAG-7.

5.24.2 IF core exit TC temperatures increasing AND RXCPs running in all available RCS cooling loops, THEN go to SACRG-1, Severe Accident Control Room Guideline Initial Response (IPEOP Step 19).

a. The Severe Accident Management Guidelines (SAMGs) are entered from the ERGs by Control Room Operators when core damage occurs.

1. The ERG to SAMG transition uses, as part of the transition criteria, a core exit thermocouple temperature indication of greater than 1200¶F to indicate the need to transition from the ERGs to the SAMGs.

2. The 1200 0F criteria for transition from the ERGs to the SAMGs is identical to the 1200 0F criteria on the Core Cooling Critical Safety Function Status Tree.

b. IF the Operator enters this step and core exit TC temperatures are greater than 1200 0F and increasing and all available RXCPs are running, THEN the Operator should transition to the SAMGs.

1. This condition indicates that all attempts to restore core cooling have failed, core damage cannot be prevented, and the Operator should go to the SAMGs.

5.25 IPEOP FR-Z.2: RESPONSE TO CONTAINMENT FLOODING 5.25.1 Notify Emergency Director of Sump Level and Activity Level to Obtain Recommended Action (IPEOP Step 3):

a. The ED should request evaluation of the cause of the event and provide specific recommendations to the Operators for reducing containment water level.

INFORMATION USE

Title Technical Support for LPEOPs WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 I Rev. L

~~~~Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant l Emergency Plan Implementing Procedure Date JUL 31 2003 Page 14 of 15 5.25.2 Consider the Following Three Methods to Reduce Flooding:

a. Location of critical plant components in relation to containment sump water level.

b. Location, size, and shielding of available storage tanks outside containment.

c. Radiation concerns due to pump and line routing from the containment sump to the various storage tanks.

5.26 IPEOP FR-Z.3: RESPONSE TO HIGH CONTAINMENT RADIATION LEVEL 5.26.1 Notify Emergency Director of Containment Radiation Level to Obtain Recommended Action (IPEOP Step 3):

a. After containment vent isolation has been verified, check the pressurizer water level, charging flow, and operation of the containment sump pumps to determine if a reactor coolant leak is occurring.

1. IF there is a lack of evidence of a reactor coolant leak, THEN verify the alarm condition by selecting the fast advance on the air particulate and sample fresh air for about 15 seconds to confirm that the detector function is normal.

2. IF it is normal, THEN notify the RPD.

b. An additional area to be looked at is the possibility of fuel damage. By checking the thermocouple readings, hydrogen generation level, and RCS activity levels, it can be determined whether or not damage to the fuel has occurred.

5.27 IPEOP FR-I.3: RESPONSE TO VOIDS IN REACTOR VESSEL 5.27.1 Obtain Maximum Allowable Venting Time from Technical Support Center Director (Per EPIP-TSC-07) (EPEOP Step 17):

a. Calculation of the maximum allowable venting time is based on maintaining containment hydrogen concentration below 3% in dry air.

1. The lower the initial hydrogen concentration, the longer the venting can continue.

2. Procedure EPIP-TSC-07 describes the method of determining RCS venting time.

INFORMATION USE

WISCONSIN PUBLIC SERVICE CORP. No. EPIP-TSC-10 IRev. L Title Technical Support for IPEOPs Kewaunee Nuclear Power Plant Emerrency Plan Implementing Procedure Date JUL 31 2003 I Page 15 of 15 6.0 Final Conditions 6.1 This procedure may be terminated when the emergency has been closed out or recovery operations have been entered, the plant is stable, and Operations has determined that technical support of IPEOPs is no longer required.

7.0 References 7.1 Kewaunee Nuclear Power Plant Integrated Plant Emergency Operating Procedures (KNPP IPEOPs) 7.2 KNPP IPEOP Background Documents 7.3 Westinghouse Owners Group Emergency Response Guidelines 7.4 SAG-7 8.0 Records 8.1 The following QA records and non-QA records are identified in this directive/procedure and are listed on the KNPP Records Retention Schedule. These records shall be maintained according to the KNPP Records Management Program.

8.1.1 OA Records None 8.1.2 Non-OA Records None INFORMATION USE

ENVIRONMENTAL DISPATCH AREA ACTIVATION CHECKLIST DATE/TIME STARTED /

ITEM ACTION INITIALS

1. Arrange tables in Environmental Dispatch Area according to Figure EPIPFG-APPX-A-06-04.

2. Obtain communications equipment from the storage closet (Box "C") in the EOF Cootdination Center (D2-3) and install according to Figure EPIPFG-APPX-A-06-04.

3. Perform radio set up as follows:

• Pull out the radio, headset, cable, and power cord.

• Attach the radio cable into the black antenna cable in the wall.

• Attach power cord (as applicable) and plug into outlet.

• Attach headset to radio, located on back side by black and red wires (personal preference if you want to use the headset)

• Turn on the radio, power button located on upper left corner of radio

• Set channel to EP1, located on right side of radio, up/down arrows

• Set volume using up/down arrows located on left of radio, above "MON" button

• Establish radio communications with EMT Field Teams On/Off Button Volume Channel Select Rev E

_PP-N-1O Rev. E Dae JU_120 ae1o ForEPIPF-ENV-01-01 Form Date: JUL 31 2003 Page 1 of 2

ENVIRONMENTAL DISPATCH AREA ACTIVATION CHECKLIST ITEM ACTION INITIALS

4. Obtain ENV forms and figures folder from cabinet in EOF.

5. Synchronize the clock in the Environmental Dispatch Area with the time from the Honeywell plant process computer.

6. Verify ability to perform a dose projection according to EPIP-ENV-03C.

7. Establish communications with at least one EMT using radio or telephone.

8. Verify that an EMT is activated according to EPIP-ENV-02.

9. Notify ERM that the Environmental Monitoring Group is activated.

DATE/TIME COMPLETED l EPD

_r_PP - N - O Rev.

F EPIPF-ENV-01-01 Re_EE Dae JU 31 200 Pa e 2 o Form Date: JUL 31 2003 Page 2 of 2

EMT STATUS Page 1 of _

TEAM: A B C (Circle One)

DATE/TIME ACTIVATION COMPLETE:

NOTE: EMTs shall NOT enter areas with external dose rates > lR/hr without approval from either the EPD or RPD.

NOTE: EMTs should report their dose every hour or when they receive 100 mREM.

Team Member Dose Tracking NAME NAME NAME _

Time Dosimeter Total

_______Reading TEDE Initial L~ ~~~~~ I

< .: =~~~~~~~~

_ _ _ _ I:1 _ I

+ +

Form EPIPF-ENV-01-02 Rev. C Date: JUL 31 2003 Page 1 of 2

EMT STATUS Page of-(Use additional pages as needed)

\ TEAM: A B C (Circle One)

TEAM STATUS (Activities in progress, location, etc.) DATE:

TIME

_P P - N For EPIPF-ENV-01-02 Rev CC 0 Rev. Dae JU 31 200 Pag 2..of 2 Form Date: JUL 31 2003 Page 2of 2

EMT ORDERS/FIELD DATA Page 1 of _

DATE/TIME l

'- TEAM: A B C (Circle One)

ORDER ID 1 Establish Center Line and Take Air Sample (Circle One } Identify Leading Edge if Applicable) 3 Identify Lateral Edge INSTRUCTIONS:

"--INSTRUCTIONS FOR REPORTING FIELD DATA:

1. SAMPLEIDATE/TIME - Enter date/time air sample collection was completed, date/time dose rate reading was taken, or date/time deposition sample was collected.

2. GRID COORDINATES - Specify location to the nearest one-half of a grid point.

3. SAMPLE TYPE - Enter appropriate description.

Iodine (I)

Particulate (P)

Noble Gas (NG)

Dose Rate (DR)

Deposition (DP)

4. READING - Enter reading using correct units.

Air Sample (iodine, particulate, or noble gas) - ACi/cc Dose Rate - mrem/hour Deposition - DPMI100 cm 2 or DPM/smear, if < 100 cm 2 was surveyed Page 1 of 2 Form Rev. C EPIPF-ENV-O1-04 Rev.

Form EPIPF-ENV-01-04 C Date: JUL Date: 31 2003 JUL 31 2003 Pagel1 of 2

EMT ORDERS/FIELD DATA Page _of_

EMT FIELD DATA SAMPLE GRID SAMPLE TYPE READING DATE/TIME COORDINATES (Circle One) (Including Units)

II P /NOG DR IDP II P /NOG DR IDP I / P / NG / DR / DP I / P I NG / DR I DP I / P I NG / DR / DP I I P / NG / DR / DP I P / NG / DR I DP I /P /NG /DR /DP I / P / NG / DR / DP I / P I NG / DR / DP I / P I NG / DR / DP I / P / NG / DR / DP I P I NO DR DP I / P / NO / DR / DP I / P / NG / DR / DP Page 2 of 2 Form C Rev. C EPIPF-ENV-O1 -04 Rev.

Form EPIPF-ENV-01-04 Date: JUL Date: 31 2003 JUL 31 2003 Page 20of2

I EMT ACTIVATION CHECKLIST DATE/TIME STARTED: l TEAM: A B C (Circle One)

ITEM ACTION INITIALS

1. Perform portable survey instrument preoperational checks using EPIP-ENV-04A.

a. Ion Chamber (Serial # )

I) Physical Condition SAT/UNSAT (Circle One)

2) Calibration SAT / UNSAT

3) Battery SAT / UNSAT

4) Zero Instrument SAT /UNSAT

5) Source Response SAT / UNSAT

b. ASP-I with HP-260 probe (Serial # )

1) Physical Condition SAT/UNSAT (Circle One)

2) Calibration SAT / UNSAT

3) Battery SAT/UNSAT

4) Source Response SAT/UNSAT

5) Place in FAST response SAT / UNSAT mode.

2. Obtain battery powered air sampler (Model H-8 10-B2).

a. Air sampler serial number:

b. Verify air sampler accessories are all available:

- Tygon tubing

- Gold filter retaining ring

- Gold filter housing (2)

- Blue cartridge housings (2)

- Plastic cartridge seal rings (2)

3. Obtain Environmental Monitoring Team Kit.

NOTE: IF seal is not broken, THEN do not inventory kit. IF seal is broken, THEN inventory kit using most recent revision of Form HPF- 15, Emergency Equipment Monthly Inventory.

4. Obtain cellular phone and FAX kit.

Date: JUL 2003 31 2003 Page 1 of 3 Form EPIPF-ENV-02-01 Rev. 00 EPIPF-ENV-02-O1 Rev. Date: JUL 31 Page 1 of 3

EMT ACTIVATION CHECKLIST ITEM ACTION INITIALS

5. Obtain portable high-band radio in silver case.

a. Open case and pull out the magnetic based antenna.

b. Place antenna on roof of vehicle.

c. Plug the power connector into vehicle power outlet (typically by cigarette lighter)

d. Turn on radio, power button located on upper left corner of radio.

e. Set channel to EP1, located on right side of radio, up and down arrows.

f. Set volume using up/down arrows located on left of radio, above "MON" button.

g. Establish radio communications with EMT Communicators, if EOF is activated.

On/Off Button Volume Channel Select -

Form EPIPF-ENV-02-01 Form _PP-N Rev 0 O Rev. 0 Dae JU.3 203Pge2o_

Date: JUL 31 2003 Page 2 of 3

EMT ACTIVATION CHECKLIST ITEM ACTION INITIALS

6. Obtain personnel dosimetry for each team member:

a. High range SRPD (zeroed)

b. Low range SRPD (zeroed)

c. TLD

7. Don a reflective vest (each team member).

8. Verify all required equipment is loaded into vehicle to be used by the EMT.

9. Activate the vehicle's amber light.

10. Obtain current annual TEDE for each team member from the RPO/RAF and record on Form EPIPF-ENV-01-02, EMT Status.

11. Obtain meteorological and release data from the EMTCd or the RPO/RAF using Form EPIPF-ENV-01-03, Meteorological and Plant Status Data.

12. Synchronize the EMT timepiece(s) with the time from the PPCS computer. To obtain PPCS computer time, contact the EMTCd or Radiological Protection Director (RPD).

NOTE: When Steps I through 12 above are completed, EMT activation is complete.

DATE/TIME/ACTIVATION COMPLETED: I ITEM ACTION INITIALS

13. Initiate Standing Order SO-1, SO-2, or SO-3 according to EPIP-ENV-04D, Plume Tracking for Environmental Monitoring Teams, or other orders as directed.

14. Establish communications with the Environmental Monitoring Team Coordinator (EMTCd).

15. Report the following information to the EMTCd Using Form EPIPF-ENV-01-02, EMT Status:

a. Team designator (A, B, or C)

b. Team membership (names)

c. Current annual TEDE (mRem)

d. Date/time activated Maintain completed checklist in EMT Log.

Form EPIPF-ENV-02-01 Rev. 0 Date: JUL 31 2003 Page 3of 3

EOF ACTIVATION CHECKLIST ITEM ACTION INITIAL WHEN I ~~~~~~~~~~~~~~COMP 1 Position furniture and communications equipment in accordance with the floor plans attached to the containers listed below:

NOTE: (1) Equipment boxes listed in order ofpriority.

(2) A dial tone should be heardeach time a telephone is connected to the appropriatewall jack.

(3) Title markers (name tents) should be placed in front of the chair where the individual with that title sits.

a. Box - A (SRCLUEPD Area)

b. Box - B (ALD Area)

c. Box - C (ENV Work Area)

d. Box - D (NRC Conference Room)

e. Box - E (State/County Conference Room)

f. Set out clipboards, name tags, baskets, and "Telephone Communication Log" pads.

g. Enter ERO personnel on Duty Roster board.

h. IF full NRC response is anticipated, THEN clear AND set up Conference Room G1-4 (See: Figure EPIPFG-APPX-A-06-06).

2 Establish security for the EOF/JPIC work area using Figure EPIPFG-EOF-12-01 attached to this checklist:

a. Station a person at Station 5 with the appropriate instructions and materials from procedure EPIP-EOF-12.

b. At all Figure locations marked "P" (Post), hang the "This Area Is Secured" signs.

NOTE: IF unauthorizedpersonnel become a problem, THEN the doors marked "L" (Lockable) can be locked. Keys to those doors are hung inside the EOF storage closet door to be issued to EOFpersonnel as needed.

c. Ensure that all EOF/JPIC staff in the facility at the time are logged in on Form EPIPF-EOF-12-01 and issued an EOF/JPIC badge.

Communication System Checks:

a. EOF Telecopier: Send a test page of text to the printer (located in hallway outside EOF) at -5544 to verify the fax transmission capability.

b. Dial-Select: (Sta. 10) contact the TSC (ext. 33).

c. Env. Monitoring Group Communications Systems: Contact at least one EMT using radio or telephone.

Fo m E I F E F 0 - 1 R v ae U 120 a e1 o Form EPIPF-EOF-02-01 Rev. U Date: JUL 31 2003 Page1I of 2

EOF ACTIVATION CHECKLIST ITEM ~~~~~ACTION INITIAL WHEN ITEM A CTIONCOMPLETED

d. PPCS Data Validitv:

• Contact the TSC or Control Room to identity any data points on the PPCS that are invalid (out of service) and should not be used.

• Post the PPCS terminal with the identification of any invalid data points.

e. PPCS Computer: Call up graphic display screen #53.

f. Verify wall clocks in EOF have the same time as the PPCS Computer.

g. Turn on the Recorder's PC located next to fax machine in D2-3. Login ID is EOF1 (upper case), password is 16F150E5 (upper case). Click on advanced and make sure 'Tree" reads "WPSRR," context reads "Non-WPSC," and server reads "GBNUC 1." Click on advanced again.

NOTE: You may get a pop-up window asking for anotherpassword to link to Windows 2000. Use the same password, but in lower case.

Start up Word for recording events. Template for drill and exercise Master Log is located on the "C" drive, under "Documents and Settings." The printer for this PC is located in hallway near department supply closet.

4 ERM Activation Actions

a. Verify capability for EOF to assume the following responsibilities:

(1) Off-site notification (2) Dose Assessment (3) PAR Determination (ERM)

b. Announce EOF activation and scope of responsibilities assumed. (ERM)

c. Notify the ED AND inform him of the scope of EOF activation. (ERM)

ERM SIGNATURE DATE TIME U Dae JU 31 200 Pag 2 of 2 .__

For EPIPF-EOF-02-01 Rev.

Form _PP-O-O Rev. U Date: JUL 31 2003 Page 2of 2

SEVERE ACCIDENT MANAGEMENT - STATUS DATE: TIME:

VALUE WITHIN is IF YES - IF NO -

SCST/DFC CURRENT LIMITS? GUIDE STRATEGY REASONS LIMITS VALUE TREND IN USE? IN EFFECT WHY NOT ARROW Radiation Releases Yes No SCG-1

< Gen. Emrg. Level per SCST Table 1 Yes No Yes No SCG-2 Containment Pressure psig YesN__

< 112 psig Yes No Hydrogen per SCST Yes No SCG-3

< Figure 1 Yes No Containment Pressure ___Yes No SCG4

> -2.8 psig Yes No C

Rev. C Date: JUL 31 2003 Page 1 of 2 EPIPF-TSC-O1 -03 Rev.

Form EPIPF-TSC-01-03 Fcrm Date: JUL 31 2003 Page 1 of 2

SEVERE ACCIDENT MANAGEMENT - STATUS

'-~ DATE: TIME:

VALUE WITHIN is IF YES - IF NO -

SCST/DFC CURRENT LIMITS? GUIDE STRATEGY REASONS LIMITS VALUE TREND IN USE? IN EFFECT WHY NOT ARROW A B Yes No SAG-1 SG Levels

> 44% NR _% NR _%

Yes No

__%WR _%

RCS Pressure . Yes No SAG-2

< 400 psig pgYes No TcYes No SAG-3 Core A LOOP B Yes No Temperature (deg. F)

< 7000 F HL CL Yes No SAG-4 Containment FT.

Level > 6 FT Yes No Radiation Yes No SAG-5 Releases

< Site Emrg.

Level per Yes No DFC Table 1 Containment Yes No SAG-6 Pressure psig Yes No

< 4 psig No Containment Yes No SAG-7 Hydrogen  %

< 5% Yes No ae U 120 ae2o FomEIFTCO-3Rv Form EPIPF-TSC-01-03 Rev. C Date: JUL 31 2003 Page 20of2