ML033180250

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Transmittal of Emergency Plan Implementing Procedure EI-4.3, Revision 15
ML033180250
Person / Time
Site: Palisades Entergy icon.png
Issue date: 10/30/2003
From:
Consumers Energy
To: Mcknight J
Office of Nuclear Reactor Regulation
References
252704 EL-4.3, Rev 15
Download: ML033180250 (47)
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.1 Date Entered: Oct 30, 2003 TO: USNRCIWASHINGTON JMCKNIGHT Copy Number: 145 TRANSMITAL NUMBER: 252704 PROCEDURE NUMBER: El-4.3 TITLE: EMERGENCY OPERATIONS FACILITY ACTIVATION TRANSMITTAL: LISTED BELOW ARE NEW/REVISED PROCEDURES WHICH MUST BE IMMEDIATELY INSERTED INTO OR DISCARDED FROM YOUR PROCEDURE MANUAL.

Action Required Section or Description REMOVE AND DESTROY El-4.3, R/15, ENTIRE PROCEDURE REPLACE WITH El-4.3, R115, ENTIRE PROCEDURE EDITORIAL SIGN, DATE, AND RETURN THEACKNOWLEDGEMENTFORM WITHIN 10DAYS TO THEPALISADES PLANT DOCUMENT CONTROL SIGNATURE OR INITIALS DATE If applicable, REMOVE ALL travelers and marked up pages in front of this procedure.

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Procedure No El-4.3 Revision 15 Effective Date 10/30/03 PALISADES NUCLEAR PLANT EMERGENCY IMPLEMENTING PROCEDURE TITLE: EMERGENCY OPERATIONS FACILITY ACTIVATION Approved: NKBrott l 10/28/03 Procedure Sponsor Date New Procedure/Revision Summary.

Editorial to Revision 15 Specific Changes Rev 15 (6/12/03)

This revision was initiated to correct inaccurate information for contacting outside agencies during an emergency event. The discrepancies were identified after the March 18, 2003 Actual Event. Individuals contacted to secure accurate contact numbers were Dave Crabtree, Paul Harden, Keith Osborne, and Stan Pierce.

Added Security Manager contact number to Attachment I based on discussions with NMC fleet.

Corrected area code for cell phones on Attachment 3, page 3 of 4.

Added the recently updated Mutual Assistance Agreement, Attachment 11, new signatures on last page.

- l a PALISADES NUCLEAR PLANT Proc No El-4.3 EMERGENCY IMPLEMENTING PROCEDURE Revision 15 Page I TITLE: EMERGENCY OPERATIONS FACILITY ACTIVATION Table of Contents 1.0 PURPOSE ....................................... 1

2.0 REFERENCES

....................................... 1 2.1 REFERENCE DOCUMENTS ....................................... 1 3.0 DEFINITIONS ....................................... 2 3.1 ACTIVATION ... 2............

3.2 OPERATIONAL SUPPORT TEAM .............................. 2 3.3 OPERATIONAL FACILITY ............................... 2 3.4 COMMAND AND CONTROL ............................... 2 3.5 FULLY OPERATIONAL ............................... 2 3.6 EMERGENCY OPERATIONS FACILITY ............................... 2 3.7 NRC FACILITY LIAISON ............................... 3 4.0 INITIAL CONDITIONS AND/OR REQUIREMENTS ..................................... 3 5.0 PROCEDURE ....................................... 3 6.0 ATTACHMENTS ....................................... 4 7.0 SPECIAL REVIEWS ....................................... 4 ATTACHMENTS , "Emergency Operations Facility Director" .1, "Emergency Operations Facility Status Updates" , "Emergency Operations Facility Communication Support Team" .1, "Emergency Telephone Numbers" .2, "Additional Emergency Support Request" , "Emergency Operations Facility Health Physics Support Team" , "Emergency Operations Facility Engineering Support Team" .1, "Additional Emergency Support Request" , "Emergency Operations Facility Governmental Liaison" , "Emergency Operations Facility Public Affairs" , "Emergency Operations Facility Emergency Planner" , "Emergency Operations Facility Administrative Support Team" .1, "Emergency Operations Facility Floor Plan" .2, "Nuclear Management Company Emergency Response Sign In" , "Security Officer Instructions" 0, "Emergency Operations Facility Organization" 1, "Mutual Assistance Agreement Between Detroit Edison, Nuclear Management Company, and Indiana Michigan Power Company"

I c PALISADES NUCLEAR PLANT - Proc No El-4.3 EMERGENCY IMPLEMENTING PROCEDURE Revision 15 Page 1 of 4 TITLE: EMERGENCY OPERATIONS FACILITY ACTIVATION USER ALERT REFERENCE USE PROCEDURE Refer to the procedure periodically to confirm that all procedure segments of an activity will be or are being performed. Where required, sign appropriate sign-off blanks to certify that all segments are complete.

1.0 PURPOSE This procedure provides guidance for the activation, operation, and deactivation of the Emergency Operations Facility (EOF).

2.0 - REFERENCES 2.1 REFERENCE DOCUMENTS 2.1.1 Emergency Implementing Procedure El-1, "Emergency Classification and Actions" 2.1.2 Emergency Implementing Procedure El-1.1, "Emergency Response to Credible Security Threats" 2.1.3 Emergency Implementing Procedure El-3, "Communications and Notifications" 2.1.4 Emergency Implementing Procedure El-5.1, "Recovery" -

2.1.5 Emergency Implementing Procedure E.-8, "Onsite Radiological Monitoring" 2.1.6 Emergency Implementing Procedure El-9, "Offsite Radiological Monitoring" 2.1.7 Emergency Implementing Procedure El-10, "Accident Environmental Assessment" 2.1.8 Palisades Administrative Procedure 3.01, "Plant Review Committee" 2.1.9 Palisades Administrative Procedure 10.41, "Procedure and Policy Processes"

PALISADES NUCLEAR PLANT - Proc No El-4.3 EMERGENCY IMPLEMENTING PROCEDURE Revision 15 Page 2 of 4 TITLE: EMERGENCY OPERATIONS FACILITY ACTIVATION 3.0 DEFINITIONS 3.1 ACTIVATION Process by which the EOF is staffed and prepared for operation.

3.2 OPERATIONAL SUPPORT TEAM Status of support team following assumption of responsibilities.

3.3 OPERATIONAL FACILITY Status of the EOF following assumption of command and control.

3.4 COMMAND AND CONTROL Resides with the EOF Director following assumption of overall authority for Nuclear Management Company (NMC) emergency response. At minimum, this individual will assume responsibility for event classification, dose assessment, protective action recommendations, and notification of offsite authorities.

3.5 FULLY OPERATIONAL Status of the EOF following assumption of all responsibilities.

3.6 EMERGENCY OPERATIONS FACILITY EOF consists of Support Room and Main Room located in the Manorside Building.

Additionally, EOF consists of the Manor House (first floor) to accommodate the NRC, if necessary. See Attachment 8.1, pages 1 through 6 for layout.

PALISADES NUCLEAR PLANT Proc No El-4.3 EMERGENCY IMPLEMENTING PROCEDURE Revision 15 Page 3 of 4 TITLE: EMERGENCY OPERATIONS FACILITY ACTIVATION 3.7 NRC FACILITY LIAISON Personnel who possess a broad knowledge of the Palisades Plant and can assist the NRC with securing pertinent information with regard to the emergency.

The responsibilities could include interfacing with plant management and/or facility

.lead personnel, ensuring timely updates of the emergency are made available, answering questions and concerns expressed by the NRC and ensuring NRC personnel have a smooth transition into their assigned facility.

Personnel would be assigned on an as needed basis and support the Technical' Support Center, the Emergency Operations Facility and the Joint Public Information Center.

There is no specific ERO training required for this position.

4.0 INITIAL CONDITIONS AND/OR REQUIREMENTS 4.1 The Plant must be at Alert, Site Area Emergency, or General Emergency before initiation of this procedure.

5.0 PROCEDURE USER ALERT REFERENCE USE PROCEDURE Refer to the procedure periodically to confirm that all procedure segments of an activity will be or are being performed. 'Where required, sign appropriate sign-off blanks to certify that all segments are complete."'

The attachments to this procedure define the responsibilities of the Emergency Operations Facility staff, and provides guidance on tasks to be performed.

Individuals assigned as team leaders or to specific identified roles should ensure the attachment checklists are utilized.

PALISADES NUCLEAR PLANT- Proc No El-4.3 EMERGENCY IMPLEMENTING PROCEDURE Revision 15 Page 4 of 4 TITLE: EMERGENCY OPERATIONS FACILITY ACTIVATION 6.0 ATTACHMENTS 6.1 Attachment 1, "Emergency Operations Facility Director" Attachment 1.1, "Emergency Operations Facility Status Updates" 6.2 Attachment 2, "Emergency Operations Facility Communication Support Team" Attachment 2.1, "Emergency Telephone Numbers" Attachment 2.2, "Additional Emergency Support Request" 6.3 Attachment 3, "Emergency Operations Facility Health Physics Support Team" 6.4 Attachment 4, "Emergency Operations Facility Engineering Support Team" Attachment 4.1, "Additional Emergency Support Request" 6.5 Attachment 5, "Emergency Operations Facility Governmental Liaison" 6.6 Attachment 6, "Emergency Operations Facility Public Affairs" 6.7 Attachment 7, "Emergency Operations Facility Emergency Planner" 6.8 Attachment 8, "Emergency Operations Facility Administrative Support Team" Attachment 8.1, "Emergency Operations Facility Floor Plan" Attachment 8.2, "Nuclear Management Company Emergency Response Sign In" 6.9 Attachment 9, "Security Officer Instructions" 6.10 Attachment 10, "Emergency Operations Facility Organization" 6.11 Attachment 11, "Mutual Assistance Agreement Between Detroit Edison, Nuclear Management Company, and Indiana Michigan Power Company" 7.0 SPECIAL REVIEWS The scope of this procedure does not include activities that require a 50.59 review per Palisades Administrative Procedure 10.41, "Procedure and Policy Processes."

Therefore, changes to this procedure do not require a 50.59 review.

Proc No El-4.3 Attachment I Revision 15 Page 1 of 3 EMERGENCY OPERATIONS FACILITY DIRECTOR RESPONSIBILITIES .

The EOF Director:

1. Has overall responsibility for the entire Nuclear Management Company (NMC) emergency response.
2. Shall have authority to approve any actions or requests for additional assistance.
3. Serves as the primary liaison between the Plant and offsite organizations.

ACTIVATION

1. Establish and maintain a log of key activities. (Attachment 1.1, 'Emergency Operations Facility Status Updates," may be used to track updates.) - -
2. Sign in on the "EOF Emergency Response Staff" status board.
3. ' Ensure incoming responders have noted their attendance on the status board.

NOTE: For EOF response to security-related events, see El-1.1, "Emergency Response to Credible Security Threats."

4. Establish communications with Site Emergency Director (SED) and:
a. Determine extent of emergency situation and what actions have been taken to mitigate the K-) emergency.
b. Determine which emergency priorities have been set by the SED.
c. Synchronize EOF clocks with Control Room clock.
d. Ensure appropriate placards for the 'emergency classification and Command and Control are in place.
5. Announce there will be no eating or drinking in the facility until habitability is completed.
6. Assemble the Support Team Leaders and:
a. Conduct a briefing on the emergency situation, Plant status, and actions taken by the Plant to mitigate the emergency.
b. Assure that a sufficient support staff has been or will be summoned to the Emergency Operations Facility.

-_-'_c. Instruct the Support Team Leaders to prepare to assume responsibility for assigned function.

7. As the County Emergency Operation Centers are activated, dispatch the Governmental Liaisons to their respective facility.
8. As specific teams are prepared to perform their functions:
a. Consult with the SED to transfer responsibilities for that specific team.

-___ b. Announce to the EOF staff when that team assumes responsibility for that function.

Proc No El-4.3 Attachment 1 Revision 15 Page 2 of 3 EMERGENCY OPERATIONS FACILITY DIRECTOR

9. Command and control may be transferred when the EOF Director is prepared to assume responsibility for the following functions (at a minimum, Communications, Health Physics/Dose Assessor):
a. Emergency classification,
b. Protective action recommendations,
c. Dose assessment, and
d. Offsite notifications.
10. Ensure all teams have indicated their readiness on the status board.
11. In consultation with the SED and EOF Communications Team Lead, assume Command and Control. Have SED in the TSC make an announcement in the TSC and OSC the EOF is activated and the EOF Director has Command and Control of the emergency.

NOTE: Coordinate timing of turnover with Communications Team Leader so that turnover does not conflict with timing of notifications.

12. Announce to the EOF staff that the facility is fully operational and the EOF Director has Command and Control, and ensure Command and Control sign reflects EOF Director.
13. Brief facility staff on status of the emergency.
14. Coordinate timing of facility briefings
a. To coincide with the TSC/OSC facility briefings, if possible.
b. Ensure facility briefings do not impede communications to the State, ie, Notification Form update.
c. Periodically address issues identified on EOF Briefing Checklist, Job Aid EOF-001.
15. If necessary to contact the Security Manager, call 2835/2350 or CAS at 2264.

OPERATIONAL

1. Maintain Attachment 1.1, "Emergency Operations Facility Status Updates."
2. Perform emergency classification in accordance with Emergency Implementing Procedure El-1, 'Emergency Classification and Actions."

NOTE: Upgrade to General Emergency classification with the appropriate Protective Action Recommendation (PAR) shall be personally provided to the State Director when the State EOC is operational. The telephone number for the State Director is (517) 324-2323.

a. All further changes in emergency classification should be coordinated with the SED.
b. Ensure the emergency classification placards are updated as the classification changes.

Proc No El-4.3 Attachment 1 Revision 15 Page 3 of 3 EMERGENCY OPERATIONS FACILITY DIRECTOR

3. Provide protective action recommendations to offsite authorities:
a. Review and approve protective action recommendations recommended by the Health Physics Support and Engineering Support Teams.
b. Personally provide initial and revised protective action recommendations to the State Director when the State EOC is operational.

NOTE: The Site Emergency Director (SED) is responsible for establishing and maintaining emergency priorities pertinent to the plant and mitigation of the accident. Emergency priorities related to offsite response should be identified by the EOF Director and communicated to the SED.

4. Review emergency priorities and revise as needed.
5. Review and approve all information transmitted to offsite authorities via the Notification Form.

Review may be delegated to an assistant.

6. Maintain communications with offsite authorities, particularly the State, brief them on actions undertaken at the Plant and EOF, and determine action being taken offsite.
7. Maintain a line of communication to the SED.
8. Authorize potassium iodine (KI) distribution per Emergency Implementing Procedure El-9, "Offsite Radiological Monitoring," and concurrence with Health Physics.
9. Review and approve news releases prepared at the Joint Public Information Center by Consumers K.) Energy Public Affairs personnel.
10. Provide all other assistance requested by the Site Emergency Director or the Palisades Vice President.
11. If necessary to contact the Security Manager, call 2835/2350 or CAS at 2264.

RECOVERY The responsibilities of the EOF Director during the recovery phase of an emergency are addressed in Emergency Implementing Procedure El-5.1, iRecovery."

DEACTIVATION When the situation warrants, the Emergency Operations Facility will be deactivated. Close out all files and submit appropriate forms, records, and logs as directed by the EOF Administrative Support Team Leader.

Proc No El-4.3 Attachment 1.1 Revision 15 Page 1 of 1 EMERGENCY OPERATIONS FACILITY STATUS UPDATES STATE (30 min) PLANT (15/30 min) l I

I . .

I r

l EOF-Team Leaders (30 min.) EOF-AII Personnel (30 min)

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Proc No El-4.3 Attachment 2 Revision 15 Page 1 of 4 EMERGENCY OPERATIONS FACILITY COMMUNICATION SUPPORT TEAM RESPONSIBILITIES The Communication Support Team acts:

NOTE: This does not preclude support teams communicating to their counterparts at the Plant on technical matters.

1. As the official communicator between the EOF, the Plant and outside organizations.
2. Makes and records all official communications from the EOF to offsite authorities..

ACTIVATION NOTE: For EOF response to security-related events, see El-1.1, Ernergency Response to Credible Security Threats.'

1. Establish and maintain a log of key activities.
2. Sign in on the "EOF Emergency Response Staff" status board.
3. Prepare for turnover by establishing a communication link with emergency response facility that has offsite communications responsibilities (either the Control Room or Technical Support Center) and review:
a. Plant status
b. All organizations contacted and obtain telephone numbers used to contact each organization
c. All actions initiated by the organizations contacted
d. Schedule to update the appropriate organizations
e. Coordinate sequence of message numbers and time frame for notification
f. Any other information pertinent to facilitating transfer of offsite notifications
4. Establish communications with the following agencies.

NOTE: The State will direct whether the EOF or the State is responsible for notification of local authorities.

a. State of Michigan-Monitor telephone line 764-1285 which is an extension of the line used in the TSC for State notifications. Verify that if notifications are being made in a timely manner to State Operations, or that an open line has been established with the State Emergency Operations Center. . -

Proc No El-4.3 Attachment 2 Revision 15 Page 2 of 4 EMERGENCY OPERATIONS FACILITY COMMUNICATION SUPPORT TEAM

b. NRC Emergency Notification System (ENS)

Primary: To operate: 1) lift receiver and listen for dial tone, 2) dial "1" followed by the 10 digit number listed on sticker located on telephone, 3) if no answer proceed to next 10 digit number (continue until contact is made with NRC).

Alternate: 1 - (301) 951-0550

5. When it is determined the following responsibilities can be adequately addressed, notify the EOF Director that the Communication Support Team is ready to assume responsibility for communication support.
a. Sufficient Communication Support Team members have arrived and notification of offsite authorities can be made by EOF personnel.
b. Personnel have been assigned to update the EOF Communications Status Board.
c. Sufficient equipment has been verified available and functional.
d. An operable communication line between the Emergency Operations Facility Communication Support Team and the Technical Support Center Communication group has been established.
e. Next message number and time are current on status board.
f. An operable communication link is available to those agencies listed in Step 4 above, and Attachment 2.1, 'Emergency Telephone Numbers.'
6. Indicate on the 'EOF Emergency Response Staff' status board that the Communication Support Team is ready.
7. Notify the following when the EOF Communication Support Team is operational and is prepared to assume responsibility.
a. Plant Technical Support Center.
b. State of Michigan and NRC.
c. Any other organizations as specified by the Technical Support Center Communicator.

OPERATIONAL

1. Communications Support Team Leader
a. Maintain a log of key decisions and activities.

NOTE: Initial notifications of a Protective Action Recommendation based upon dose calculations require that the Event Technical Data Sheet also be completed.

b. Ensure that the Event Notification Form is generated by the Health Physics Dose Assessor for initial notifications following an event classification and all Protective Action Recommendations.
c. Ensure that Health Physics Support has completed Items 6, 7 and 8 on the Event Notification Form.

Proc No El-4.3 Attachment 2 Revision 15 Page 3 of 4 EMERGENCY OPERATIONS FACILITY COMMUNICATION SUPPORT TEAM NOTE: All Plant Messages are to be numbered sequentially, whether generating an Event Notification Form or an Event Technical Data Sheet.

d. Identify the Plant Message Number.
e. Complete Items 1, 3, 4, and 5 on the Event Notification Form.
f. Obtain EOF Director approval of the Event Notification Form, including date and time of approval.
g. Provide the approved Form to Administrative Support for copying, distribution and faxing.

NOTE: A General Emergency classification with the appropriate Protective Action Recommendation (PAR) shall be personally communicated by the EOF Director to the State Director {(517) 324-23231 when the State EOC is operational

h. Ensure that initial notifications to the State of Michigan (and Van Buren County, if necessary) are initiated within 15 minutes of an emergency declaration or development of a Protective Action Recommendation.
i. Ensure that the EOF Communications Status Board is maintained.

-j.-Ensure that the Health Physics Dose Assessor generates the Event Technical Data Sheet for follow-up notifications.

k. Ensure that Health Physics Support has completed Items 5, 6, and 7 on the Event Technical Data Sheet.

I. Complete Items 1, 3, and 4 on the Event Technical Data Sheet.

nm. Obtain EOF Director approval of the Event Technical Data Sheet, including date and time of approval.

n. Provide the approved Data Sheet to Administrative Support for copying, distribution and faxing.
o. Ensure that follow-up notifications using the Event Technical Data Sheet are communicated to the State of Michigan approximately every 30 minutes.
2. NRC Communicator
a. Maintain a log of key activities.
b. Maintain a continuous open line with NRC.
c. Complete Item 2 on each notification form communicated to the NRC, including the time the notification was initiated.
d. All NRC requests for additional information should be routed through the Communications Support Team Leader or designate.

I Proc No El-4.3 Attachment 2 Revision 15 Page 4 of 4 EMERGENCY OPERATIONS FACILITY COMMUNICATION SUPPORT TEAM

3. State of Michigan Communicator
a. Maintain a log of key activities.
b. Upon request, maintain a continuous open line with the State Communicator.

_ c. Complete Item 2 on each notification form communicated to the State, including the time the notification was initiated.

_ d. All State requests for additional information should be routed through the Communications Support Team Leader or designate.

4. Remaining EOF Communicators
a. Maintain a log of key activities.
b. Utilize the EOFITSC ring down phone to communicate with TSC Communication Support Team.
c. Maintain the EOF Communications Status Board.
d. Assist the Communications Support Team Leader and other EOF Communicators with requests for additional information from the NRC, State and County Liaisons. All requests for information, and the resulting responses, are to be documented.
e. As directed, complete Additional Notifications listed in Attachment 2.1, "Emergency Telephone Numbers."

______ f. If non-company emergency support is needed, contact the appropriate group listed in Attachment 2.1, 'Emergency Telephone Numbers."

g. Use Attachment 2.2, "Additional Emergency Support Request," to document requests for non-company emergency support.

DEACTIVATION When the situation warrants, the EOF will be deactivated. Agencies contacted during the emergency should be informed that the EOF is deactivated. Close out all communications as directed by the EOF Director. Close out all files and submit appropriate forms, records, and logs as directed by the EOF Administrative Support Team Leader.

As i Proc No El-4.3 Attachment 2.1 Revision 15 Page 1 of 1 EMERGENCY TELEPHONE NUMBERS ADDITIONAL NOTIFICATIONS: Organizations to be notified and updated as conditions warrant:

(1) Consumers Energy Legal Department 517-788-1257 James Brunner (2) Consumers Energy Insurance Department 517-788-0714 Director, Robert Frounfelker 517-782-3356 (night)

(3) Institute for Nuclear Power Operations 800-321-0614 (Primary) 770-644-8000 (Switchboard) 770-644-8549 (Telecopier) 770-644-8567 (Telecopier)

C 770-644-8594 (Telecopier)

NON-COMPANY SUPPORT (1) Department of Energy, Radiological Assistance Team 630-252-4800 (2) Electric Power Research Institute 704-547-6086 IC NMC Account Manager &

Central Regional Technical Service Manager (3) Framatome ANP (24-Hour Support) 434-832-2533 Rick Heath, Project Manager Home 434-384-0228 Mobile 434-841-0700 Fax 434-832-2932 (4) Westinghouse Electric (Palisades Office)

Jack Bendel 269-764-2004 Night . 269-214-2339 Westinghouse Technical Response Center (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) 724-722-5473 24 Hour Pager 412-300-3161

  • (5) Siemans Westinghouse

. Tim Garvin - Office 269-427-1229 (6) Other

Reference:

INPO Emergency Resources Manual

Proc No El-4.3 Attachment 2.2 Revision 15 Page 1 of 1 ADDITIONAL EMERGENCY SUPPORT REQUEST

1. Date Time
2. Name and title of person making request
3. Nature of emergency
4. Plant Location
5. When the help is needed
6. Where the help is wanted
7. Work to be done
8. Where the help should report
9. The name and title of person to report to
10. Number of personnel requested
11. Classification of personnel
12. Estimated time duration for additional support
13. Equipment needed:
14. Material needed:
15. Services needed:
16. Other information:

Proc No El-4.3 Attachment 3 Revision 15 Page 1 of 4 EMERGENCY OPERATIONS FACILITY HEALTH PHYSICS SUPPORT TEAM RESPONSIBILITIES The Health Physics Support Team Leader is responsible for:

1. Coordinating with the EOF Director on PAR recommendation and updates.
2. Assisting the EOF Director in emergency classification.
3. Assuring the Health Physics Support Team actions are consistent with events occurring in the Plant.
4. Directing radiological sampling activities.

ACTIVATION Upon arrival at the EOF, the Health Physics Support Team Leader should initiate the following actions:

1. Establish radiological controls in the EOF assuring a frisking station is established and verifying the meter is operational.
a. Coordinate with the EOF Director, notify participants if frisking is required.
2. Sign in on the "EOF Emergency Response Staff" status board.
3. - Establish and maintain a log of key activities, ie.
a. Turnover of HP responsibilities from TSC to EOF.
b. Status of EOF habitability.
c. Communications with State EOC HPL.
d. Significant changes in offsite radiological conditions.
4. Review all previous notification forms sent to the State of Michigan.
5. Establish communications with the TSC Health Physics group and review:
a. Current Plant status.
b. Protective actions recommended to the state.
c. Current protective actions initiated by the state.
d. Offsite dose calculations result if a release has occurred or projected dose calculations of a potential radiological release.
e. Telephone numbers currently being used to communicate with the State of Michigan and NRC.
f. Actions initiated by the State of Michigan and NRC dose assessment organizations.
g. The update schedule established to provide the State of Michigan and NRC with current information.
h. The need for supporting the Health Physics Network (HPN) line with the NRC.

Proc No El-4.3 Attachment 3 Revision 15 Page 2 of 4 EMERGENCY OPERATIONS FACILITY HEALTH PHYSICS SUPPORT TEAM

6. Brief the EOF Director on Health Physics aspects of the emergency.
7. Establish the Health Physics Support Team as defined in the Operational Section of this attachment.
8. When the responsibilities defined in the Operational Section of this attachment can be adequately addressed by the Health Physics Support Team, notify the EOF Director that the team is ready to assume responsibility for providing Health Physics support.
9. Indicate on the "EOF Emergency Response Staff" status board that the Health Physics Support Team is ready.
10. Assume responsibility for providing Health Physics support when the Health Physics Support Team is ready.

OPERATIONAL

1. Health Physics Support Team Leader
a. Coordinate HP team actions.
b. Evaluate PAR recommendations and update as appropriate.
c. Review and approve notification forms which have been completed by the Dose Assessor.
d. Ensure HP status boards are maintained accurately and in a timely manner.
e. Provide technical support to Health Physics Support Team members. (ie, selection of source term calculation approach, and selection of offsite monitoring team assignments and general sampling areas)
f. Use Trend Graph Status Board to track radiological conditions.
g. Provide an interface with State Health Physics Liaison on technical issues as requested.

NOTE: The open HPN line can be maintained in the TSC or EOF.

h. Maintain an open HPN line with the NRC, if requested.
i. Evaluate the use of Potassium Iodide (KI) per Emergency Implementing Procedure El-9, "Offsite Radiological Monitoring," and ensure EOF Director is aware of the KI status.
j. Upon activation of the FRMAC, the Health Physics Support Team Leader will assign an individual to report to the FRMAC per Attachment 5 of this procedure.

Proc No El-4.3 Attachment 3 Revision 15 Page 3 of 4 EMERGENCY OPERATIONS FACILITY HEALTH PHYSICS SUPPORT TEAM

2. Dose Assessor NOTE: For Manual Dose Assessment, use emergency notification forms from El-3, Attachment 1 and Attachment 1.1.
a. Obtain current meteorological data from the Plant Process Computer (PPC) or EI-6.7, "Plant Site Meteorological System," or El-6.8, "Backup and Supplemental Meteorology."
b. Obtain meteorological forecast data from El-6.7, "Plant Site Meteorological System."
c. If there is a potential for, or an actual release is in progress, calculate average energy, release rates, and dose estimates using the El-6 procedure series.

NOTE: Initial notifications of a Protective Action Recommendation based upon dose calculations require that both Event Notification Form and Event Technical Data Sheet be completed.

d.' Complete the Event Notification Form for initial notifications for all new emergency classifications, and for all Protective Action Recommendations.

On the Event Notification Form, complete Items 6, 7 and 8.

e. Complete the Event Technical Data Sheet for follow-up notifications.

On the Event Technical Data Sheet, complete Items 5,'6, and 7.

f. Ensure that the Health Physics Support Team Leader reviews the completed form(s).
g. Ensure that the completed form(s) are provided to the Communications Support Team Leader in a timely manner to support the time posted on the EOF Communication Status Board.
3. Radio Communicator NOTE: Radio is the primary means of communication with the offsite teams, and backup is cellular telephones, 269-921-5395 and 269-921-5396.
a. Communicate instructions to offsite teams.
b. Record offsite monitoring team data on status board.
c. Update offsite teams with Plant status including event classification, changes in meteorological data, changes in release information, and protective action recommendations.
d. Track cumulative dose for members of the offsite monitoring teams.

Proc No El-4.3 Attachment 3 Revision 15 Page 4 of 4 EMERGENCY OPERATIONS FACILITY HEALTH PHYSICS SUPPORT TEAM

4. Health Physics Technician
a. Perform habitability assessments and report results to the Health Physics Support Team Leader.
b. If the EOF is determined to be within the pathway of the radioactive plume:

____ Monitor airborne radioactivity levels with the EOF.

____ Issue EOF personnel TLD's and maintain TLD assignment records.

c. Assist the Health Physics Support Team as requested.

RECOVERY During the reentry/recovery phase, the Health Physics Support Team Leader will direct the environmental sampling activities as described in Emergency Implementing Procedure El-10, Accident Environmental Assessment."

DEACTIVATION When the situation warrants, the EOF will be deactivated. Close out all communications as directed by the EOF Director. Close out all files and submit appropriate forms, records, and logs as directed by the EOF Administrative Support Team Leader.

Proc No El-4.3 Attachment 4 Revision 15 Page 1 of 2 EMERGENCY OPERATIONS FACILITY ENGINEERING SUPPORT TEAM -

RESPONSIBILITIES The Engineering Support Team Leader is responsible for providing: -

NOTE: In addition, the Team Leader should focus the team members toward looking ahead in an attempt to be proactive with problems that may arise in the Plant and their impact beyond Plant boundaries.

1. Engineering support for the EOF HP Support Team necessary in performing source term calculations.
2. Interpretation of technical Plant engineering, reactor engineering, and accident analysis to the EOF Director.
3. Technical support for the Plant.
4. Interpretation of operational aspects of the emergency to the EOF Director.

ACTIVATION Upon arrival at the EOF, the Engineering Support Team Leader should initiate the following actions:

1. Sign in on the "EOF Emergency Response Staff" status board.
2. Establish and maintain a log of key activities,-le.
a. Note any changing priorities.
b. Note Plant actions as they pertain to Plant engineering and reactor engineering/ accident analysis.
3. Establish communications with counterpart group in the Technical Support Center (see Emergency Implementing Procedure El-3, "Communications and Notifications," Attachment 3 for telephone numbers),

and:

- a. Review the Plant parameters and safety function status.

b. Review all engineering recommendations and calculations made. -
c. Review recommendations to prevent and/or limit core damage.
d. Review actions initiated by the Plant as they relate to engineering matters, and safe shutdown.
4. Indicate on the "EOF Emergency Response Staff' status board that the Engineering Support Team is ready. -

Proc No El-4.3 Attachment 4 Revision 15 Page 2 of 2 EMERGENCY OPERATIONS FACILITY ENGINEERING SUPPORT TEAM OPERATIONAL

1. Engineering Support Team Leader
a. Ensure that a log of key activities is maintained. (See Activation, Step 2.)
b. Provide engineering support for the EOF HP Support Team necessary in performing source term calculations.
c. Provide the EOF Director and Plant TSC Engineering group with engineering interpretation and recommendations.
d. Provide the EOF Director with a summary of all Plant actions as they pertain to Plant engineering, and reactor engineering/accident analysis.
e. Maintain status board trending reactor parameters with correct, current and timely Plant information.
f. Maintain Emergency PrioritiesNital Equipment Out of Service status board.
g. Request additional support from offsite by completing Attachment 4.1, "Additional Emergency Support Request," and submit to EOF Communications.
h. If the estimated duration of the incident warrants, arrange with the EOF Administrative Support Team Leader to have a relief support team assembled.
2. Technical Information Facilitator (TIF)
a. Maintain the Sequence of Events board in the EOF.
b. Remain on the dedicated group line until relieved by another qualified individual.
c. Assist the EOF Director in maintaining communications with the Control Room, TSC, and OSC.
d. Discuss EOF priorities with the other facility TIFs and notify EOF leadership of impending conflicts.
e. Notify EOF leadership of important and/or emergency developments.
3. Operations Liaison
a. Consult with the EOF Director and his staff regarding the operational aspects of the emergency.
b. Assist with the trending of important operational parameters, as appropriate.
c. Assist EOF personnel in the interpretation of trends in operational parameters and discuss the ramifications of events or developments, as needed.
d. Attend Team Leader briefings as a resource for the EOF Director.

DEACTIVATION When the situation warrants, the EOF will be deactivated. Close out all communications as directed by the EOF Director. Close out all files and submit appropriate forms, records, and logs as directed by the EOF

.,_I Administrative Team Leader.

Proc No El-4.3 Attachment 4.1 Revision 15 Page 1 of 1 ADDITIONAL EMERGENCY SUPPORT REQUEST

1. Date Time.
2. Name and title of person making request
3. Nature of emergency
4. Plant Location
5. When the help is needed
6. Where the help is wanted
7. Work to be done
8. Where the help should report
9. The name and title of person to report to
10. Number of personnel requested
11. Classification of personnel
12. Estimated time duration for additional support
13. Equipment needed:
14. Material needed:
15. Services needed:
16. Other information:

Proc No El-4.3 Attachment 5 Revision 15 Page 1 of 2 EMERGENCY OPERATIONS FACILITY GOVERNMENTAL LIAISON RESPONSIBILITIES

1. State Emergency Operations Center (SEOC) Liaison The Liaison to the.State is responsible for
a. Functioning as a member of the State EOC Executive Group, and being involved in advising the State on protective action decisions.
b. Clarifying/interpreting communications and verifying information between the Company's EOF and the SEOC.
c. Being a technical resource on Plant operations for State emergency response personnel.
2. County Emergency Operations Center (EOC) Liaison The County EOC Liaison is responsible for being a technical resource on Plant operations for county emergency response personnel.
3. Federal Radiological Monitoring and Assessment Center (FRMAC) Liaison The FRMAC Liaison is responsible for providing radiological information and technical support.

ACTIVATION K.>' 1. SEOC Liaison Upon notification of activation of the EOF, proceed directly to the SEOC located at:

4000 Collins Road Lansing, Ml

2. County EOC Liaison Upon arrival at the EOF, the County EOC Liaisons should:
a. Notify the EOF Director or Administrative Support Team Leader of your arrival.
b. Monitor the situation at the EOF to prepare for functioning as the County EOC Liaison.
c. Upon direction from the EOF Director or Administrative Support Team Leader, proceed to assigned County EOC.

Van Buren County: Lower Level of Sheriff Department Paw Paw, Michigan Berrien County: Lower Level of Sheriff Department St Joseph, Michigan Allegan County: Allegan County Building Allegan, Michigan

3. FRMAC Liaison Upon activation of the FRMAC, the Health Physics Support Team Leader will assign an individual to report to that facility as a liaison.

Proc No El-4.3 Attachment 5 Revision 15 Page 2 of 2 EMERGENCY OPERATIONS FACILITY GOVERNMENTAL LIAISON OPERATIONAL

1. SEOC Liaison Upon arrival at the State facility, the SEOC Liaison should:
a. Notify State management personnel of your arrival.
b. Function as a member of the State Executive Group. As such you will be involved in advising the State on protective action decisions.
c. Monitor the situation from within the SEOC to obtain information. If clarification of the situation is necessary, call Communications at the EOF (see Emergency Implementing Procedure El-3, 'Communications and Notifications," for telephone numbers).
d. Ensure that State management personnel are aware of the latest protective action recommendation made by the Company.

NOTE: Official word of those recommendations must come from the EOF Director.

e. Ensure EOF officials are aware (through EOF Communications) of major activities being undertaken by the State in response to the emergency (eg, protective actions ordered by the State for the public).
2. County EOC Liaison Upon arrival at the county EOC:
a. Notify management personnel of your arrival.
b. Monitor the situation to obtain information. If clarification of the situation is necessary, call Communications at the EOF (see Emergency Implementing Procedure El-3, "Communications and Notifications," for phone numbers).

_ c. Ensure EOF officials are aware (through EOF Communications) of major activities being undertaken in response to the emergency

3. FRMAC Liaison Upon arrival at the FRMAC:
a. Notify management personnel of your arrival.
b. Provide support and radiological information to the State, NRC, and local authorities such as:

- Plume deposition predictions

- Airborne radiological concentrations

- Deposition patterns of isotopic concentrations, exposure rates and dose projections

- Isotopic concentrations in environmental media

- Current meteorological conditions and weather forecast

Proc No El-4.3 Attachment 6 Revision 15 Page 1 of I EMERGENCY OPERATIONS FACILITY PUBLIC AFFAIRS RESPONSIBILITIES The Public Affairs Communicator/Technical Advisor is responsible for the flow of information between the EOF and the Joint Public Information Center (JPIC).

ACTIVATION

1. .. Sign in on the 'EOF Emergency Response Staff" status board.
2. Establish and maintain a log of key activities, le.
a. Note times of press releases.
b. Note times of changes/updates.
3. Establish a communications link with the JPIC.

OPERATIONAL

1. Update the JPIC on the status of the emergency.
2. - Communicate information requests from the JPIC to the EOF Director.
3. Have draft news releases from the JPIC reviewed and approved by the EOF Director.
4. Notify the JPIC of any revisions needed to news releases that have been reviewed and approved by the EOF Director.
5. Fax the news releases with the appropriate approval noted on them to the JPIC.

Proc No El-4.3 Attachment 7 Revision 15 Page 1 of 1 EMERGENCY OPERATIONS FACILITY EMERGENCY PLANNER RESPONSIBILITIES The Emergency Planner acts as resource person in technical and nontechnical areas for all participants to ensure an efficiently operated facility and interface between participants at all emergency response facilities (both Company and non-Company).

ACTIVATION

1. Sign in on the M EOF Emergency Response Staff" status board and continue to monitor the status of the emergency with the EOF Director.
2. Establish and maintain a log of key activities to allow reconstruction of the EOF response to this event.
3. Verify the extent of the emergency situation with the EOF Director.

OPERATIONAL

1. Ensure that a log of key activities is maintained. (See Activation, Step 2.)
2. Provide assistance as requested by the EOF Director.
3. Provide assistance as requested by the Health Physics and Engineering Support Team.
4. Provide requested liaison support between NMC and non-NMC groups.
5. Ensure that facility status boards are periodically updated.

DEACTIVATION When the situation warrants, the Emergency Operations Facility will be deactivated. Close out all communications as directed by the EOF Director. Close out all files and submit appropriate forms, records, and logs as directed by the EOF Administrative Support Team Leader.

Proc No El-4.3 Attachment 8 Revision 15 Page 1 of 2 K> EMERGENCY OPERATIONS FACILITY ADMINISTRATIVE SUPPORT TEAM RESPONSIBILITIES The Emergency Operations Facility Administrative Support Team Leader is responsible for:

1. Setting up the Emergency Operations Facility (EOF).
2. Coordinating and maintaining all support services required to keep the EOF operating in a reliable and efficient manner.
3. Coordinating the administrative functions and operation of the EOF.
4. Administering the call-out provisions regarding alcohol in the Fitness for Duty Procedures.

ACTIVATION Upon arrival at the EOF, the Emergency Operations Facility Administrative Support Team Leader should initiate the following actions:

1. -______Maintain a log of key activities, ie,
a. Note time of incoming/outgoing faxes.
b. Note time assembly checklist completed.
. c. Note time shift turnover is complete.
2. Sign in on the "EOF Emergency Response Staff" status board.
3. Ensure South Haven Conference Center personnel set up the EOF in accordance with Attachment 8.1 of this procedure.
4. Verify that all support equipment has been set up and is functioning properly. If not, arrange to have equipment repaired.
5. Establish security per Attachment 9 of this procedure to restrict access to the EOF. Call Allegan County dispatch (269-673-3899) to request activation of reserve unit for Palisades EOF Security.
6. Administer the call-out provisions regarding alcohol in the Fitness for Duty Procedures including administering breath alcohol testing.
7. Contact Plant Security (ext 2299 or 2561, if no answer call ext 2278) to request a status on security at the Plant.
8. Assign Administrative Support personnel to:
a. Control and maintain the distribution of documents and engineering records with the EOF.
b. Operate telecopy machines.
c. Log and distribute received messages to appropriate EOF staff.

K> d. Assist the EOF Director, as requested.

e. Assist personnel signing in on Attachment 8.2.

Proc No El-4.3 Attachment 8 Revision 15 Page 2 of 2 EMERGENCY OPERATIONS FACILITY ADMINISTRATIVE SUPPORT TEAM

9. Verify that support teams have adequate equipment and supplies.
10. Notify the EOF Director as Support Team Leaders indicate a ready status on the "EOF Emergency Response Staff" status board.

OPERATIONAL

1. Throughout the emergency, ensure the following:
a. Status boards are being updated.
b. Tasks assigned to Administrative Support personnel in Step 7 above are being carried out.
c. Administrative Support personnel assigned to Communications Group record "Sequence of Events" board and have copies distributed to all teams.
2. Make arrangements for replacement and/or repairs of equipment as needed.
3. Arrange for additional phones, lines, radios, or other communications equipment and facilities as needed.
4. Coordinate scheduling of work shifts to staff the EOF on a 24-hour basis.
5. Coordinate set up of food services and lodging for the support staff.
6. Ensure that the needs of the NRC personnel located in the EOF are being addressed.

DEACTIVATION When the situation warrants, the Emergency Operations Facility will be deactivated. Return all emergency equipment to its respective storage location. Instruct team leaders to submit appropriate forms, records, and logs.

File this documentation in the Engineering Records Center with copies to Emergency Planning.

Proc No El-4.3 Attachment 8.1 Revision 15 Page 1 of 6 EMERGENCY OPERATIONS FACILITY FLOOR PLAN.

Page left blank intentionally.

Proc No El-4.3 Attachment 8.1 Revision 15 Page 2 of 6 EMERGENCY OPERATIONS FACILITY FLOOR PLAN LAYOUT/PHONE LOCATIONS 1 (269) 637-6608 / 2324 23 (269) 637-7308 2 (269) 637-6615 / 2381 (same as Loc #41**) 24 2398 3 Hotline - SED 25 (269) 764-1285 4 (269) 637-7240 (same as Loc #43/45^*)* 26 700-371-0075 (ENS)*

5 (269) 637-6028* 27 (269) 637-4106 6 700-371-0072 (HPN)* 28 Hotline - TSC 7 (269) 637-7397 29 (269) 637-7307 8 2385 30 (269) 637-6188 9 (269) 637-6695 (same as Loc #42/44**) 31 (269) 637-6787 (same as Loc #46**)*

10 2384 32 (269) 637-6235*

11 (269) 637-6114 (same as Loc #52-*)- 33 (269) 637-3955 12 (269) 637-7012 C-1 Straight Line Computer 34 (269) 637-3944 13 (269) 637-7398 C-2 Segmented Computer 35 (269) 637-1951 14 (269) 637-7321 C-3 Meteorological Computer 36 (616) 458-7815 outgoing fax 15 (269) 637-6647 37 (616) 458-8078 incoming fax 16 2386 38 (269) 637-7309 17 (269) 637-7306 (Laptop Computer) 40 (269) 637-2407/2404 18 2369 47 700-371-0074 (Protective Measures)"

19 (269) 637-5969- 48 700-371-0071 (Management Counterpart)"

20 700-371-0073 (Reactor Safety)* 53 (269) 637-6574 21 (269) 637-7060 (same as Loc #51 *) 54 2383 22 2382*

Phone designated for use by NRC Phone Locations #41 through #52 located in manor House (see El-4.3, Attachment 8.1, Page 6 of 6)

Proc No El-4.3

. Attachment 8.1 Revision 15 Page 3 of 6 EMERGENCY OPERATIONS FACILITY FLOOR PLAN a Phone designated for use by NRC

Proc No El-4.3 Attachment 8.1 Revision 15 Page 4 of 6 EMERGENCY OPERATIONS FACILITY FLOOR PLAN e

  • ARCHWAY OVER DRIVE

Proc No El-4.3 Attachment 8.1 Revision 15 Page 5 of 6 EMERGENCY OPERATIONS FACILITY FLOOR PLAN A RESPONSE STAFF SIGN IN B-1 NOTIFICATION FORMS B-2 EMERGENCY PRIORITIES C PLANT NSSS PARAMETERS D SEQUENCE OF EVENTS E

E PROTECTIVE ACTIONS:

F 10 MILE MAP G PAG CHART H SITE MAP l RADIOLOGICAL TRENDS J. OFFSITE MONITORING

/ 1 K 10 MILE MAP L HP RAD/MET DATA M 50 MILE MAP N* EOF COMMUNICATIONS 0o PHONETIC ALPHABET' P EOF BRIEFING CHECKLIST B-2

'Place on tripod L

1 . - l\ B-i SUPPORT ROOM WWWE < N-\Z

-2 .

\/

MECHANICAL 7 STORAGE ROOM I

Proc No El-4.3 Attachment 8.1 Revision 15 Page 6 of 6 EMERGENCY OPERATIONS FACILITY FLOOR PLAN

+/- NRC Work Area MANOR HOUSE First Floor 0

0 41 2M-637-66152381 (~EC rectr)

NRC 42 M9637-5969 (ECF Brneedng)

Conference 43 Mg637-7240 (NRlC Mmnffnad) 44 2M-637-5969 (E0I &ijneedrin) 45 2M637-7240 (NRfC Mxbngena)

~A 46 26-637-6W8 (RtiicAifars) 47 700-371-0074 (Prodv~e Ivbastes) 48 700~-371-00Y71 (M~agenwt Main Entry 49 2M-67.55M (Open Une) 50 269-637-7264 (Open Uine) 51 Mg-637-706 (ECF Enjneeirxj) 52 269-637-6114 (ECOHP)

K 1I Consumers I Conference I

Dining Kitchen Area

c7 (7. Proc No El-4.3 C Attachment 8.2 Revision 15 Page 1 of 1 NUCLEAR MANAGEMENT COMPANY EMERGENCY RESPONSE SIGN IN Date:

Plant - EOF HAVE YOU CONSUMED ALCOHOL SOCIAL INTHE PAST FIVE HOURS?*

NAME BADGE # AFFILIATION SECURITY NUMBER TIME IN YES NO NRC / NA TIME OUT L _________________________

______'_____________________.__________________ ____=______________________________

l I hlis section to be completed only by individuals fulfilling duties identified in the Emergency Operations Facility Emergency Implementing Procedures or Individuals responding to emergency call-in at the Palisades Plant. Actions taken for all "Yes' answers are to be recorded in the Activities Report.

Program Location Class Hours Course (Module, Topic) Instructor Class # SEP TFIRCMS #

Proc No El-4.3 Attachment 9 Revision 15 Page 1 of 2 SECURITY OFFICER INSTRUCTIONS 1.0 GENERAL REQUIREMENTS

a. Security officers will report to the EOF Administrative Support Team Leader.
b. All exterior doors of the EOF (Support Room and Main Room) shall be secured.

The entrance at the security sign-in desk may remain open.

c. Entry into the EOF (Support Room and Main Room) shall be through one door.

2.0 ACCESS CONTROL

a. NMC employees - Individuals will be granted access who
1. Possess NMC identification,
2. Are personally recognized by EOF personnel,
3. Are cleared by the EOF Administrative Support Team Leader.

(a)

  • Photo identification is to be worn conspicuously at all times when in the EOF.

(b) Individuals leaving the grounds need to sign out.

(c) Additionally, if second shift staffing becomes necessary, personnel being relieved of duty should indicate time of departure on the sign-in sheet beside their name in the "Time Out" column.

b. Non-Company Employees
1. Must be cleared by the EOF Administrative Support Team Leader or designate.
2. Must present photo identification and register on the Nuclear Management Company Emergency Response Sign-In Sheet.
3. Should wear photo identification conspicuously at all times when in the EOF.
c. NRC Personnel
1. Should present their NRC Identification Badge and sign in on the sign-in sheet.
2. Are not subject to our Fitness for Duty requirements.
3. Should wear photo identification conspicuously at all times when in the EOF.
d. Any additions or modifications to instructions will come from the EOF Administrative Support Team Leader.

Proc No El-4.3 Attachment 9 Revision 15 Page 2 of 2 SECURITY OFFICER INSTRUCTIONS 3.0 SECURITY STAFFING - SOUTH HAVEN CONFERENCE CENTER EOF The following security staffing assignments may be made by the EOF Administrative Support Team Leader based upon the nature of the emergency or emergency drill.

a. EOF Drive Entrance Officer - To be located at the Conference Center drive entrance.
1. The officer will allow access to NMC employees.
2. Non-NMC employees will be cleared to enter by contacting EOF Administrative Lead.
b. Roving Patrol Officer - To be located on the grounds to control trespassers.

Proc No El-4.3 Attachment 10 Revision 15.

Page 1 of 1 EMERGENCY OPERATIONS FACILITY ORGANIZATION

Proc No El-4.3 MUTUAL ASSISTANCE AGREEMENT Attachment 11 BETWEEN DETROIT EDISON, NUCLEAR MANAGEMENT Revision 15 COMPANY, AND INDIANA MICHIGAN POWER COMPANY Page 1 of 7 0.1 Nuclear Management Company, Detroit Edison and Indiana Michigan Power Company, WITNESSETH 0.2 WHEREAS, Nuclear Management Company, Detroit Edison, and Indiana Michigan Power Company own electric facilities, including nuclear generation stations, and are engaged in the generation, transmission, distribution and sale of electric power and energy in Michigan; and 0.3 WHEREAS, the parties desire to help assure the availability of adequately trained and experienced emergency personnel in the event of an emergency situation at any*

of their nuclear generating stations;  :

0.4 NOW, THEREFORE, in consideration of the promises and mutual covenants herein set forth, the parties agree as follows:

ARTICLE I DEFINITIONS 1.1 "Alert" shall be defined as a situation in which events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant.

1.2 "Emergency" shall be defined consistent with the definition of "site area emergency" as set forth in NUREG 0654 as a situation in which events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public.

1.3 "Requesting party" shall be defined as any party to this Agreement who, upon the occurrence of an emergency at one of its nuclear generating stations, seeks emergency assistance, pursuant to this Agreement, from one or more of the parties hereto.

1.4 "Responding party" or "responding parties" shall be defined as any party or parties to this Agreement who are presented with a request for emergency assistance pursuant to this Agreement.

Proc No El-4.3 MUTUAL ASSISTANCE AGREEMENT Attachment 11 BETWEEN DETROIT EDISON, NUCLEAR MANAGEMENT Revision 15 COMPANY, AND INDIANA MICHIGAN POWER COMPANY Page 2 of 7 ARTICLE II REQUESTS FOR EMERGENCY ASSISTANCE 2.1 In the event of an alert at one of its nuclear generating stations, any party to this Agreement may notify any or all of the other parties that an alert exists and that their emergency assistance may be required.

2.2 In the event of an emergency at one of its nuclear generating stations, any party to the Agreement may request emergency assistance from any or all of the other parties.

2.3 Requests for emergency assistance shall be made between and among the following party personnel:

Nuclear Management Company Senior Vice President, NMC Detroit Edison Vice President Nuclear Generation Indiana Michigan Power Company Sr Vice President and Chief Nuclear Officer Nuclear Generation ARTICLE IlIl EXCUSED FAILURE TO RESPOND 3.1 Failure to respond to a request for emergency assistance pursuant to this Agreement shall be excused if, in order to respond, the requested party or parties would be forced in its or their sole judgment or judgments to:

3.1.1 Violate its duties relating to the care and staffing at its own nuclear generating stations; or 3.1.2 Jeopardize the public health or safety at a location other than the location of the requesting party's emergency.

Proc No El-4.3 MUTUAL ASSISTANCE AGREEMENT Attachment 11 BETWEEN DETROIT EDISON, NUCLEAR MANAGEMENT Revision 15 COMPANY, AND INDIANA MICHIGAN POWER COMPANY Page 3 of 7 ARTICLE IV SCOPE OF ASSISTANCE 4.1 If requested under this Agreement, the responding party or parties will provide trained and experienced personnel to perform off-site radiation protection activities to the requesting party. All equipment intended for use by the responding personnel, except personal dosimeters and certification documents (such as certificates of Health Physics training, instrument training and dose exposure records), shall be the responsibility of the requesting party to provide.' The responding party or parties may use their own equipment if agreeable to the requesting party. However, use by the responding party or parties of their own equipment shall in no way alter the duties and obligations imposed upon the parties by this Agreement.'

4.2 Emergency assistance provided by the responding party or parties shall continue until their personnel are'dismissed by the requesting party, or are recalled by the responding party to support operations at it own facilities.

4.3 Responding party or parties' personnel exposure shall be limited to off-site radiation, and such exposure'shall not exceed federal requirements as set forth in 10CFR20.

4.4 Wages, hours and other terms and conditions of employment applicable to loaned personnel shall be those of the party providing such personnel.

4.5 Personnel provided by responding party or parties shall, at all times during the period in which emergency assistance is being provided, continue to be employees of the responding party or parties. The responding party, and not the requesting party, shall be liable to loaned personnel for any wages, salaries, cost and expenses associated with the provision of emergency assistance.

Proc No El-4.3 MUTUAL ASSISTANCE AGREEMENT Attachment 11 BETWEEN DETROIT EDISON, NUCLEAR MANAGEMENT Revision 15 COMPANY, AND INDIANA MICHIGAN POWER COMPANY Page 4 of 7 ARTICLE V REIMBURSEMENT FOR EMERGENCY ASSISTANCE RENDERED 5.1 The requesting party shall reimburse each responding party for all costs and expenses incurred by each responding party in providing emergency assistance hereunder. Such costs and expenses shall include:

5.1.1 Salaries and wages paid to loaned personnel (including supervisors) for paid time spent in the requesting party's service area, and paid time for travel to and from such service area; 5.1.2 A percentage of the total of such wages and salaries, as determined by the responding party, reflecting expenses incurred for:

5.1.2.1 Compliance with Worker's Compensation laws; 5.1.2.2 Payroll taxes; 5.1.2.3 Hospitalization, surgical and medical coverage; 5.1.2.4 Pensions and life insurance; 5.1.2.5 Vacation, holiday and sick pay; 5.1.2.6 Travel accident insurance; 5.1.3 Transportation to and from the requesting party's service area, including the cost of travel accident insurance purchased expressly for coverage during such transportation; 5.1.4 Food and lodging; 5.1.5 Personal expenses specifically agreed to between the requesting and responding parties; 5.1.6 Charges, at the rates internally used by the responding party, for the use of transportation equipment and other equipment requested; and 5.1.7 Any further costs specifically agreed to between the requesting and responding parties.

5.2 All time sheets and work records pertaining to loaned personnel shall be maintained by the responding party.

5.3 All charges shall be paid by the requesting party to each responding party within ten (10) days after receipt of an invoice, itemized to the satisfaction of the requesting party.

Proc No El-4.3 MUTUAL ASSISTANCE AGREEMENT Attachment 11 BETWEEN DETROIT EDISON, NUCLEAR MANAGEMENT Revision 15 COMPANY, AND INDIANA MICHIGAN POWER COMPANY Page 5 of 7 ARTICLE VI INDEMNIFICATION 6.1 The requesting party shall indemnify and hold harmless each responding party from and against any and all liability for loss, damage, cost or expense which the responding party shall incur by reason of bodily injury, including death, to any person or persons, or by reason of damage to or destruction of any property, including the loss of use thereof, arising out of or in any manner connected with the giving of emergency assistance to the requesting party.

6.2 In the event of bodily injury, including death, to any employee of the responding party, or in the event of damage to or destruction of any property of the responding.

party, the requesting party shall indemnify the responding party for such loss in the following manner:

6.2.1 If such loss is covered by an insurance policy purchased by the responding party from a third party carrier, the requesting party shall make reimbursement to the extent such losses increase the responding party's insurance costs; 6.2.2 If such loss is not covered by an insurance policy purchased by the responding party or exceeds such coverage, the requesting party shall make reimbursement to the extent of the claims or benefits actually paid or the losses sustained by the responding party.

ARTICLE VII MODIFICATION 7.1 At any time after the date of this Agreement any party, by giving not less than thirty days written notice to the other parties, may from time to time call for reconsideration of the terms and conditions of this Agreement. If such reconsideration is called for, the authorized representatives of the parties shall meet as promptly as convenient and discuss any of the terms and conditions of the Agreement. No party shall be under any obligation to agree to any modification or supplement not satisfactory to it.

Any agreement modifying or supplementing such terms and conditions shall be in writing, signed by all parties, and shall specify the date such modification or supplement shall become effective.

Proc No El-4.3 MUTUAL ASSISTANCE AGREEMENT Attachment 11 BETWEEN DETROIT EDISON, NUCLEAR MANAGEMENT Revision 15 COMPANY, AND INDIANA MICHIGAN POWER COMPANY Page 6 of 7 ARTICLE Vill PLAN EXERCISING 8.1 The parties agree to provide, at their own expense, personnel to observe or assist in demonstrating the effectiveness of a nuclear generating station's emergency plan as may be required by that nuclear generating station's NRC approved emergency plan.

ARTICLE IX TERM OF AGREEMENT 9.1 This Agreement shall continue indefinitely from the date of signing unless and until terminated as provided for in Section 9.2 below.

9.2 Any party, upon sixty (60) days prior written notice to all other parties, may terminate this Agreement.

-, 1r-Proc No El-4.3 MUTUAL ASSISTANCE AGREEMENT Attachment 1 1 BETWEEN DETROIT EDISON, NUCLEAR MANAGEMENT Revision 15 COMPANY, AND INDIANA MICHIGAN POWER COMPANY Page 7 of 7 IN WITNESS WHIEREOF, the parties hereto cause this Agreement to be executed by'their duly' authorized officers on duplicate original pages attached hereto and made a part hereof.

NUCLEAR MANAGEMENT COMPANY Date Palisades Site Vice President, NMC DETROIT EDISON COMPANY

.T AC. . D e Vice President Nuclear Generation INDIANA MICHIGAN POWER ANY

/ /

( SM ,~~~~~~~~, 0/0 03 A. C. Bakklen, gal Date Sr. Vice President and Chief Nuclear Officer

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