ML040440323

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Transmittal of Exelon Emergency Plan Implementing Procedure EP-AA-115, Revision 3
ML040440323
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 02/06/2004
From:
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Security and Incident Response
References
20040015 EP-AA-115, Rev 3
Download: ML040440323 (22)
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Text

EP-AA-115 TMi INSTRUCTION MEMO /

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. Date 0.-.aov! Verif.

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I C3H C 311 Control Rm Control Room Master Book, OOB JPIC Corporate Spokesperson. JPIC I -

M. Mixon 1 RM Admin.

Control Rrn Shift Emergency Director. OOB ,M. Mixon .1 JPIC Director. JPIC RM Admin. 1.

Control Rm Shift Communicator. OOB M. Mixon JPIC Technical Spokesperson. JPIC RM Admin. 1-I Control Rm Damage Control Communicator. OOB M. Mixon JPT Radiatinn Protection knnepnersnn. IPIrc RM Admin.

Control Rm Operations Communicator. OOB M. Mixon JPIC Administrative Coordinator. JPIC RM Admin.

Central File, SOB D. Marshbank ,

PLAIN JPIC Coordinator, JPIC' RM Admin.

-L)ocument control DXesk Label NM- - - l JPIC Access Controller. JPIC RM Admin..

EP Department, NOB-2 B. Brady I OSC Master Book. Rad Field Ops. Svc Bldg T. Berstler Field Monitoring Team 1. Rad Field Ops Svc Blde I T. Berstler OSC Director. Rad Field Ops. Svc Bldg T. Berstler Field Monitoring Team 2. Rad Field Ops Svc Bldg T. Berstler I .. OSC Assistant OSC Director. Rad Field Ops. Svc Bldg T. Berstler TSC Master Book, NOB-2 C. Warlow 1 OSC Damage Control Communicator. Rad Field Ops. Svc Bldg T. Berstler I-,

TSC Station Emergency Director. NOB-2 C. Warlow 1 OSC Operations Group Lead. Rad Field Ops. Svc Bldg T. Berstler TSC Director. NOB-2 C. Warlow OSC Radiation Protection Group Lead. Rad Field Ops Svc Bldg T. Berstler TSC Logistics Coordinator. NOB-2 C. Warlow OSC Chemistry Group Lead. Rad Field Ops Svc Bldg. T. Berstler TSC Security Coordinator, NOB-2 C. Warlow OSC Mech Maint Group Lead. Rad Field Ops. Svc Bldg T. Berstler I TSC State/Local Communicator. NOB-2 C. Warlow OSC I&C/Elect Maint Group Lead. Rad Field Ops. Svc Bldg T. Berstler TSC Operations Manager, NOB-2 C. Warlow I OSC Spare Group Leader Binder. Rad Field Ops Svc. Blde T. Berstler TSC ENS Communicator. NOB-2 C. Warlow OSC Shift Dose Assessor. Rad Field Ops Svc Bldg T. Berstler TSC Operations Communicator. NOB-2 C. Warlow RP Shift Dose Assessor. Rad Field Ops Svc Bldg T. Berstler TSC Technical Manager. NOB-2 C. Warlow 1 Training Department, Trng Bldg C. Flory TSC Technical Communicator. NOB-2 C. Warlow NRC Region 1, Label N.McNammara TSC Tech Support Area, NOB-2 1 I-C. Warlow NRC Onsite, Svc. Bldg P. Sauder TSC Maintenance Manager. NOB-2 C. Warlow I Simulator Rm Simulator Master Book, Sim Bldg S. Van Ormer I.

TSC Damage Control Communicator. NOB-2 C. Warlow' Simulator Rm Shift Emergency Director, Sim Bldg. S. Van Ormer .LI TSC Radiation Protection Manager, NOB-2 C. Warlow Simulator Rm Shift Communicator, Sim Bldg S. Van Ormer TSC Radiation Controls Coordinator. NOB-2 C. Warlow Simulator Rm Damage Control Communicator, Sim Bldg S. Van Ormer TSC Radiation Controls Engineer. NOB-2 C. Warlow I1. Simulator Rm Operations Communicator, Sim Bldg. S. Van Ormer TSC HPN Communicator NOB-2 C. Warlow Record Box, SOB + History Pkg. S. Zimmerman PLAIN JPIC Master Book. JPIC RM Admin.

I I J I .1.

Please update your file with the attached listed below, destroy the superseded/cancelled document(s). Also, please sign the acknowledgment at the bottom of this memo and return to Debbie Marshbank, Configuration Cntrl., Rm. 135 SOB, TMI.

TC

  • TC/PROC! 'Page Procedure Number Rev Number CLD Change Entire Level I Copies Memo Only' EP-AA-I 15 '- _ , ~~~~~.. 22 Controlled Copies, Staple, 3 Hole Punch 2 Plain Copies, Staple, 3 Hole Punch

______ Plain Copies, Staple, 3 Hole Punch (TC Dist)

I hereby acknowledge receipt of this memo and have complied with the instructions Signature _ Date.

' 01108/04

CONTROLLED COPY EP-AA-1 15 Exekrns. Revision 3 Page 1 of 21 Nuclear Level 2 - Reference Use TERMINATION AND RECOVERY

1. PURPOSE 1.1 This procedure provides guidance to the Station and Corporate Emergency Directors to accomplish transition to the Recovery Phase of an event and performance of activities associated with returning the station to a Forced Outage Management or normal organization.

Transitioning out of a Declared Event REFER to section 4.1 Termination Directly from a Declared Event REFER to section 4.2 Preparations to Enter Recovery REFER to section 4.3 Entering Recovery from a Declared Event REFER to section 4.4 Recovery Phase Actions REFER to section 4.5 Termination from Recovery REFER to section 4.6

2. TERMS AND DEFINITIONS 2.1 ANI - American Nuclear Insurers 2.2 INPO - Institute of Nuclear Power Operations 2.3 NEI - Nuclear Energy Institute 2.4 Recovery Phase - That period when major repairs are being performed to return the plant to an acceptable condition and the possibility of the emergency condition degrading no longer exists.

2.5 Detailed Incident Report - A written report that summarizes the facts and assigns corrective actions. The report includes the facts of the emergency, describes the root cause(s) of any emergency response problems and recommends corrective actions.

2.6 Event Summary Report - A written report summarizing the incident prepared for delivery to offsite authorities. This report is required within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of terminating an Unusual Event and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of exiting any higher event.

EP-AA-1 15 Revision 3 Page 2 of 21 2.7 Termination - The point at which the Emergency Plan is deactivated and station operations are controlled under the normal organization, processes and procedures. Unusual Event classifications are directly terminated. Alert classification can be directly terminated or transitioned to Recovery. Site Area and General Emergency classifications must transition to Recovery prior to termination. Termination of the emergency is formally performed per EP-AA-111 with Notifications performed per EP-AA-1 14.

3. RESPONSIBILITIES 3.1 The Corporate Emergency Director is responsible for assignment of personnel for the Recovery Organization.

A typical Corporate Recovery Organization includes:

3.1.1 Recovery Director- Reports to the Chief Nuclear Officer and responsible for recovery planning and overall Exelon activities in coordination with the affected State(s).

3.1.2 Recovery Offsite Manager - Reports to the Recovery Director and is responsible for operation of the offsite facilities, communications, interface with purchasing, legal and insurance representatives.

3.1.3 Recovery Technical Support Manager - Reports to the Recovery Offsite Manager and is responsible for recovery planning and providing corporate technical and engineering support to the station.

3.1.4 Recovery Offsite RP Manager- Reports to the Recovery Offsite Manager and is responsible for environmental monitoring and providing corporate radiological support to the station.

3.1.5 Company Spokesperson - Reports to the Recovery Director and is responsible for media and public information and interfaces.

3.2 The Station Emergency Director is responsible for assignment of personnel for the Recovery Organization.

A typical Station Recovery Organization includes:

3.2.1 Recovery Plant Manager - Reports to the Recovery Director and is responsible for station recovery planning and overall station activities and communications.

3.2.2 Recovery Operations Manager - Reports to the Recovery Plant Manager and is responsible for recovery planning, plant operations and system manipulations through the Control Room.

EP-AA-1 15 Revision 3 Page 3 of 21 3.2.3 Recovery Engineering Manager - Reports to the Recovery Plant Manager and is responsible for recovery planning and technical and engineering support.

3.2.4 Recovery Maintenance Manager - Reports to the Recovery Plant Manager and is responsible for plant maintenance and repair activities.

3.2.5 Recovery Onsite RP Manager - Reports to the Recovery Plant Manager and is responsible for all radiological aspects supporting maintenance, operations and Rad Waste processing.

4. MAIN BODY 4.1 Transitioning out of a Declared Event NOTE: Termination or transition to the Recovery Phase cannot be accomplished until the criteria of EP-AA-1 11, Attachment 1, Termination/Recovery Checklist have been evaluated. It is the responsibility of the Station Emergency Director, in consultation with the Corporate Emergency Director, to terminate the event or enter into Recovery.

4.1.1 REVIEW the criteria of EP-AA-1 11, Attachment 1, Termination/Recovery Checklist.

4.1.2 QUARANTINE or restrict access to any equipment, facilities or systems that may provide insight into the cause(s) of the event. (Refer to OP-AA-1 06-101-1005 Quarantine of Areas, Equipment, and Records as needed.)

4.1.3 ENSURE any reportable event(s) is/are assigned to be reported per the Reportability Manual.

4.1.4 ENSURE that an investigation is initiated in accordance with LS-AA-125, "Corrective Action Program (CAP) Procedure."

4.1.5 ASSIGN the Station EP Manager or designee to begin event documentation in accordance with EP-AA-120, Attachment 5, "Review of Actual Emergency Events."

4.1.6 TERMINATE the event or TRANSITION into the Recovery Phase based on the following:

1. PROCEED to Section 4.2 if terminating following an

- Unusual Event or

EP-AA-1 15 Revision 3 Page 4 of 21

- Alert with no need for recovery phase actions as determined through review of completed EP-AA-1 11, Attachment 1, Termination/Recovery Checklist.

2. PROCEED to Sections 4.3 through 4.5 if transitioning to Recovery following an Alert (requiring recovery phase actions), Site Area, or General Emergency.

4.2 Termination Directly from a Declared Event 4.2.1 IF the NRC or State authorities have activated their Emergency Response Facilities, THEN CONDUCT a formal discussion with them to determine and coordinate communications needs following event Termination.

4.2.2 DECLARE and log the official time the event is terminated.

4.2.3 DIRECT the announcement of the following message (or similar message) to station personnel over the public address system:

"Attention all personnel, attention all personnel. The emergency has been terminated. I repeat, the emergency has been terminated."

4.2.4 NOTIFY ERO personnel, the Shift Manager, and the NDO of the event termination.

4.2.5 INITIATE a State/Local notification within one hour of event termination per EP-MA(MW)-1 14-1 00.

4.2.6 INITIATE an ENS notification within one hour of event termination per EP-AA-114.

4.2.7 ISSUE an Event Summary Report to offsite authority, using Attachment 8 as a guide, as follows:

- For an Unusual Event, the Event Summary Report must be transmitted within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of termination.

- For an Alert, the Event Summary Report must be transmitted within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of termination.

4.2.8 DEACTIVATE the emergency facilities and restore them to a state of readiness.

4.2.9 ENSURE that all emergency records (position logs and forms), are collected and submitted for records retention.

EP-AA-1 15 Revision 3 Page 5 of 21 4.3 Preparations to Enter Recovery 4.3.1 ESTABLISH Emergency Response Facilities staffing requirements until a Recovery Plan Outline, describing the necessary Recovery Organization, has been approved.

1. Maintain at least the minimum ERO staffing for the TSC, EOF and JPIC while preparations for enter into Recovery are completed.
2. Consider establishing a forced outage organization in order to deactivate the OSC. Ensure minimum staffing requirements are met at all times with onsite personnel until Recovery has been entered.

NOTES: Detailed plans and procedures are not required to be developed prior to entry into Recovery. However, a Recovery Plan Outline must be approved and the organizational staffing needs identified prior to exiting the emergency event.

For events of the Alert classification, Emergency Response Organization (ERO) personnel may be adequate to perform the necessary recovery actions.

For event classifications of Site Area or General Emergency, the typical Recovery Organization (as illustrated in Attachment 2) should be established. Additional positions may be assigned to perform specific recovery activities.

4.3.2 DIRECT the Station Emergency Director to develop a Station Issues/Strategies Package and determine staffing needs using Attachments 4 and 7 for guidance.

4.3.3 DIRECT the Corporate Spokesperson to develop a Public Information Issues/Strategies Package and determine staffing needs using Attachments 6 and 7 for guidance.

4.3.4 DIRECT the EOF Director to develop a Corporate Issues/Strategies Package and determine staffing needs using Attachments 5 and 7 for guidance.

4.3.5 CONVENE a joint conference with the EOF Director, Station Emergency Director, and the Corporate Spokesperson to:

- REVIEW the Recovery Issues/Strategies Packages.

- REVIEW the identified recovery staffing requirements.

- DEVELOP and APPROVE the Recovery Plan Outline using Attachment 3 as a guide.

EP-AA-1 15 Revision 3 Page 6 of 21 4.3.6 CONDUCT a formal discussion with regulatory and State authorities to ensure coordination and agreement is met for entry into Recovery.

4.3.7 NOTIFY recovery personnel of assignments and stage or call-in for briefing and turnover.

4.3.8 CONTACT the Exelon Chief Nuclear Officer (CNO) and provide a briefing of the plans to exit the emergency and enter Recovery.

4.4 Entering Recovery from a Declared Event 4.4.1 DECLARE and log the official time the emergency is exited and Recovery entered.

4.4.2 DIRECT the announcement of the following message (or similar message) to station personnel over the public address system:

"Attention all personnel, attention all personnel. The emergency event has been exited and we have entered Recovery. I repeat, the emergency event has been exited and we have entered Recovery."

4.4.3 NOTIFY ERO personnel and the Nuclear Duty Officer (NDO) of entry into Recovery.

4.4.4 INITIATE a State/Local notification within one hour of entry into Recovery per EP-MA(MW)-1 14-1 00.

4.4.5 INITIATE an ENS notification within one hour of entry into Recovery per EP-AA-1 14.

4.4.6 ISSUE an Event Summary Report to offsite authority within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of exiting the emergency event, using Attachment 8 as a guide.

4.4.7 CONDUCT briefing and turnover to recovery personnel.

4.4.8 DEACTIVATE the emergency facilities and restore them to a state of readiness.

4.4.9 ENSURE that all emergency records (position logs and forms), are collected and submitted for records retention.

4.5 Recovery Phase Actions NOTE: Entry into the Recovery Phase can be accomplished when the Recovery Plan outline has been approved and the Recovery Organization has been identified, notified and is prepared to take turnover from the ERO.

EP-AA-1 15 Revision 3 Page 7 of 21 4.5.1 General Guidance

1. Terminate the use of emergency exposure controls.

A. Revert to non-emergency (10 CFR 20) limits and controls for repair activities conducted during Recovery.

B. Refer to existing plant exposure control procedures for guidance.

2. Terminate the use of other Emergency Procedures (e.g., EP-AA-113, Protective Actions).

A. Use existing plant procedures or procedures developed for specific tasks are used for plant repair activities during Recovery.

B. Obtain PORC approval for any special station procedures developed for Recovery activities.

4.5.2 Recovery Director

1. MAINTAIN a log of specific recovery actions taken such as:

- Specific actions taken per this procedure.

- Communication with offsite authorities related to emergency and/or Recovery.

- Any meetings held to discuss conduct or close out of the recovery phase.

2. DIRECT and/or COORDINATE all actions of the Recovery Organization.

A. ENSURE that sufficient personnel, equipment or other resources from Exelon and other organizations are available to support Recovery activities.

B. COORDINATE the integration of available Federal and State assistance into onsite Recovery activities.

C. COORDINATE the integration of available Exelon support with Federal, State, county, and local authorities as applicable, into required offsite Recovery activities.

3. Ensure communications are established and maintained with the following:

- Senior corporate officials.

- Legal, Financial, Insurance, and Supply Management departments.

- INPO, NEI, and ANI

EP-AA-1 15 Revision 3 Page 8 of 21

4. APPROVE any special procedures developed for corporate and offsite recovery activities.
5. APPROVE any reports released to offsite authorities.
6. REVIEW information released by the Corporate Spokesperson that pertains to the emergency or recovery from the accident.

4.5.3 Recovery Plant Manager

1. MAINTAIN a log of specific recovery actions taken such as:

- Specific actions taken per this procedure.

- Communication with offsite authorities related to emergency and/or Recovery.

- Any meetings held to discuss conduct or close out of the recovery phase.

2. DIRECT all station activities in support of the recovery effort.
3. COORDINATE the implementation of the Recovery Plan and procedures with the Recovery Director.
4. CONTINUE to identify and document issues relating to recovery operations.
5. DEVELOP an action plan that will transition the Recovery Organization into a normal Forced Outage Organization through OU-AA-102, "Forced Outage Management" as appropriate.
6. DESIGNATE other Exelon Recovery positions as necessary, in support of station Recovery activities.
7. ENSURE that engineering activities to restore the plant are properly reviewed and approved.

4.5.4 Recovery Offsite Manager

1. COORDINATE all corporate activities in support of the recovery effort.
2. COORDINATE the implementation of the Recovery Plan and procedures with the Recovery Director.
3. CONTINUE to identify and document issues relating to recovery operations.

EP-AA-1 15 Revision 3 Page 9 of 21

4. COMMUNICATE with offsite agencies and coordinate Exelon assistance for offsite recovery activities, including providing liaisons, as needed.
5. DESIGNATE other Exelon Recovery positions as necessary, in support of corporate Recovery activities.
6. PROVIDE post-accident reports to offsite agencies as directed, including the development of offsite accident analysis and radiological release reports (or equivalent) as required.
7. COORDINATE Exelon and contractor environmental sampling activities with state and federal agencies. This should include calculations for total population exposure based on data from available sources and/or mathematical modeling.

4.5.5 Corporate Spokesperson

1. COORDINATE all public information activities in support of the recovery effort.
2. COORDINATE the implementation of the Recovery Plan and procedures with the Recovery Director.
3. CONTINUE to identify and document issues relating to recovery operations.
4. DESIGNATE other Exelon Recovery positions as necessary, in support of public information Recovery activities.
5. FUNCTION as the official spokesperson to the press for Exelon on all matters related to the accident or Recovery activities.
6. COORDINATE with non-Exelon public information groups (Federal, State, county, etc.).
7. COORDINATE continued media monitoring and rumor control activities.

4.6 Termination from Recovery 4.6.1 CONSIDER the following prior to terminating the recovery phase:

- Station and corporate organizations involved with the recovery have been appraised of the existing conditions and of the anticipated termination of recovery activities.

- The news media has received a final status report on the recovery operations.

EP-AA-115 Revision 3 Page 10 of 21

- A review of actions taken during the emergency and recovery phases has been conducted and an investigation report has been prepared.

- Necessary revisions to the Emergency Plan and procedures have been identified.

- Concurrence has been obtained from the NRC and applicable State agencies.

4.6.2 NOTIFY the recovery organization and the NDO of the Recovery termination.

4.6.3 INITIATE aNState/Local notification within one hour of Recovery termination per EP-MA(MW)-1 14-1 00.

4.6.4 INITIATE an ENS notification within one hour of Recovery termination per EP-AA-1 14.

4.6.5 DISBAND the Recovery Organization.

5. DOCUMENTATION None
6. REFERENCES None
7. ATTACHMENTS 7.1 Attachment 1: Recovery Process Illustration 7.2 Attachment 2: Typical Recovery Organization 7.3 Attachment 3: Recovery Plan Outline 7.4 Attachment 4: Station Recovery Issues/Strategies Guide 7.5 Attachment 5: Corporate Recovery Issues/Strategies Guide 7.6 Attachment 6: Public Information Recovery Issues/Strategies Guide 7.7 Attachment 7: Issue/Strategies Form 7.8 Attachment 8: Event Summary Report Format

EP-AA-1 15 Revision 3 Page 11 of 21 ATTACHMENT 1 RECOVERY PROCESS ILLUSTRATION Page 1 of 1 Emergency Event is Declared 9

l

  • Actions are taken to return the plant to a safe condition.

1w Transition

  • Conditions are evaluated per EP-AA-1 11 Attachment 1.
  • Investiaations and event reoorts/documentation are initiated.

UEI AlertI SAE GE Recovery Preparations

  • Selected facilities are kept at full or partial ERO staffing.
  • Recovery Issues/Strategies Package is prepared.
  • Organizational requirements are determined.
  • A Recovery Plan Outline is developed.
  • Personnel are placed on stand-by to assume the identified recovery positions.

r r m -

Emernency Termination Exit Emergency Condition

  • Determine off-site communications
  • The emergency event is declared over (NRC/State) if applicable
  • Notifications are made I
  • The emergency event is declared over
  • An Event Summary Report issued (w/i 8 hrs)

I

  • Notifications are made
  • Emergency Facilities are deactivated
  • An Event Summary Report issued
  • Records are collected (w/i 24 hrs for UE, 8 hrs for Alert)

Select Alerts and all SAEs and GEs I

  • Emergency Facilities are deactivated
  • Records are collected Recovery Phase Entered
  • Recovery organization is established.
  • Recoverv activities are conducted.

Q Recovery Termination

  • Notifications are made.
  • Recoverv organization is disbanded.

The above markers represent points in time in the chronology of a classified emergency:

o The initiating state of emergency no longer exists.

0 Formal termination of the Emergency Phase occurs.

0 Formal termination of the Recovery Phase occurs.

EP-AA-1 15 Revision 3 Page 12 of 21 ATTACHMENT 2 TYPICAL RECOVERY ORGANIZATION Page 1 of I I Recovery Director I~~~~~~~~~~~~~

I I II Recovery Plant Manager Recovery Offsite Manager Company Spokesperson

- Recovery OPs Manager Recovery Tech Support Manager

- Recovery Maint Manger Recovery Offsite RP Manager

- Recovery Eng Manager L Recovery Onsite RP Manager NOTES:

(1) The Recovery Director has overall control of the recovery organization. The position will normally be filled by the ROG, Senior Vice President or designee (Corporate Emergency Director during transition).

(2) The Recovery Plant Manager directs Recovery activities to restore the plant to pre-incident conditions. The position will normally be filled by the Plant Manager or designee (Station Emergency Director during transition).

(3) The Offsite Recovery Director Directs the interface with Federal, State and local agencies and coordinates corporate support for the station. The position will normally be filled by the Emergency Preparedness Manager Director or designee (EOF Director during transition).

(4) The Company Spokesperson directs the Public Information Program. The position will normally be filled by the Corporate Communications Manager or designee (Company Spokesperson during transition).

EP-AA-1 15 Revision 3 Page 13 of 21 ATTACHMENT 3 RECOVERY PLAN OUTLINE Page of I NOTE: The Corporate Emergency Director provides approval of the Recovery Plan Outline with the concurrence of the Station Emergency Director and the Corporate Spokesperson.

SECTION I. RECOVERY ORGANIZATION A. Organization structure B. Assignment of authorities/responsibilities SECTION II. ONSITE RECOVERY PROGRAM A. Major Goals B. Issues and Strategies SECTION III. OFFSITE RECOVERY PROGRAM A. Major Goals B. Issues and Strategies SECTION IV. PUBLIC INFORMATION RECOVERY PROGRAM A. Major Goals B. Issues and Strategies

EP-AA-1 15 Revision 3 Page 14 of 21 ATTACHMENT 4 STATION RECOVERY ISSUES I STRATEGIES GUIDE Page 1 of 3 NOTE: In addition to the ERO positions listed, members of the Security and the Outage Planning Group should attend the initial onsite recovery meeting as necessary.

1. CONVENE a meeting with at least the following positions:
  • Station Emergency Director
  • Radiation Protection Manager
  • Maintenance Manager
  • Technical Manager
  • Operations Manager NOTE: Attachment 7, Issue/Strategies Form should be used to document items identified during the meeting. Complete as much of the form as possible but only the 'Description of Issue' section needs to be completed.
2. REVIEW existing conditions, outline the onsite issues to be resolved, and develop an Issues/Strategies Package that will form the basis for the onsite portion of the plant's Recovery Plan. Issues that should be considered include:

A. Present Activities Being Performed by the ERO

  • Identify ongoing activities and determine the need to continue B. Equipment Status Verifications
  • Perform/Document secured lineups
  • Hang appropriate clearance order tags
  • Document temporary repairs/lineup
  • Obtain appropriate samples to verify core status

EP-AA-115 Revision 3 Page 15 of 21 ATTACHMENT 4 STATION RECOVERY ISSUES / STRATEGIES GUIDE Page 2 of 3 C. Stabilization of Plant Systems for Long Term Cooling

  • Identify present cooling lineup(s)
  • Document available back-up cooling lineup(s)
  • Confirm condition of cooling systems.
  • Develop a plan to transition to long term cooling if required D. System Repairs and Restorations
  • Prioritize out of service equipment for restoration
  • Plan restoration process by milestones
  • Determine testing to increase/ensure equipment reliability
  • Determine long term resolution of temporary repairs
  • Examine options for temporary systems
  • Bring in industry expertise as necessary
  • Ensure proper QA on any repairs made during the emergency E. Normal Radiological Controls
  • Perform comprehensive surveys of onsite areas
  • Establish additional survey and sampling frequency requirements
  • Determine if additional monitoring equipment is required
  • Develop a decontamination plan based on prioritized recovery of plant areas
  • Commence Bioassay program
  • Contract for large volume decontamination equipment/expertise F. Water Management
  • Identify sources, volumes and activity of water inventories
  • Prioritize clean-up
  • Verify/evaluate condition of existing clean-up systems
  • Establish controls to preclude inadvertent discharges

EP-AA-1 15 Revision 3 Page 16 of.21 ATTACHMENT 4 STATION RECOVERY ISSUES / STRATEGIES GUIDE Page 3 of 3

  • Evaluate need to contract portable filtering systems/expertise
  • Establish berms and restraints for control and mitigation of spills
  • Evaluate need for additional onsite waste storage capability
  • Evaluate need for additional burial space for waste G. Logistics of the RecoverV Operation
  • Identify additional staffing needs.
  • Obtain necessary damage control equipment.
  • Consider use of outside specialist.
  • Set up training for off normal conditions (ALARA).
  • Consider restricting site access.
  • Order extra RP supplies to support recovery.
  • Evaluate the need for additional security.
  • Evaluate the need for remote technology for inspections and cleanup.
  • Evaluate the need for additional communications capabilities.

H. Documentation

  • Initiate actions to complete any required NRC reports per the Reportability Manual.
  • Develop onsite portions of the Detailed Incident Report
  • Develop onsite Recovery Plan (short/long term)
  • Write special procedures to perform tasks outside the scope of normal procedures.

EP-AA-115 Revision 3 Page 17 of 21 ATTACHMENT 5 CORPORATE RECOVERY ISSUES / STRATEGIES GUIDE Page 1 of 2 NOTE: In addition to the ERO positions listed, the VP-Licensing and Regulatory Affairs or a representative should attend this meeting.

1. CONVENE a meeting with the following:
  • Corporate Emergency Director
  • Radiation Protection Manager
  • Logistics Manager NOTE: Attachment 7, Issue/Strategies Form should be used to document items identified during the meeting. Complete as much of the form as possible but only the 'Description of Issue' section needs to be completed during initial meeting.
2. REVIEW existing conditions, outline the issues to be resolved, and develop an Issues/Strategies Package that will form the basis for the offsite portion of the Recovery Plan. Issues that should be considered include:

A. Present Activities Being Performed by EOF Staff

  • Identify ongoing activities and determine the need to continue B. Radiological
  • Evaluate the need for an environmental sampling program.
  • If required, estimate total population dose.
  • Evaluate reentry requirements.
  • Evaluate the need to bring in outside expertise for radiation monitoring.

C. Support to Offsite Authorities e Consider outstanding requests from offsite authorities

  • Keep offsite authorities apprised of onsite conditions and activities

EP-AA-1 15 Revision 3 Page 18 of 21 ATTACHMENT 5 CORPORATE RECOVERY ISSUES / STRATEGIES GUIDE Page 2 of 2 D. Corporate Interface

  • Keep corporate management apprised of conditions and activities.
  • Provide information to legal organization as requested.
  • Identify issues applicable to HR and Employee Assistance.

E. Logistics

  • Identify staffing needs to support offsite recovery activities.
  • Identify all non-Exelon personnel and activities currently in place.
  • Review equipment and material needs for EOF recovery activities.
  • Assist onsite and Public Information organizations in obtaining offsite support.
  • Evaluate the need for additional communications capabilities.

F. Documentation

  • Direct that an Event Summary Report be prepared
  • Develop offsite portions of the Detailed Incident Report
  • Develop offsite Recovery Plan (short/long term)

EP-AA-1 15 Revision 3 Page 19 of 21 ATTACHMENT 6 PUBLIC INFORMATION RECOVERY ISSUES / STRATEGIES GUIDE Page 1 of I NOTE: In addition to the ERO positions listed, the Corporate Communications Manager or a representative should attend this meeting.

1. CONVENE a meeting with the following:
  • Corporate Spokesperson
  • JPIC Director
  • Public Information Director NOTE: Attachment 7, Issue/Strategies Form should be used to document items identified during the meeting. Complete as much of the form as possible but only the 'Description of Issue' section needs to be completed during initial meeting.
2. REVIEW existing conditions, outline the public information issues to be resolved, and develop an Issues/Strategies Package that will form the basis for the public information portion of the plant's Recovery Plan. Issues that should be considered in the formation of the package include:

A. Present Activities Being Performed by the Emergency Public Information Organization

  • Identify ongoing activities and determine the need to continue B. Offsite Interface
  • Identify activities needed to keep offsite authorities appraised of Exelon Public Information activities.

C. Documentation

  • Develop the Public Information portion of the Recovery Plan

EP-AA-115 Revision 3 Page 20 of 21 ATTACHMENT 7 ISSUES I STRATEGIES FORM Page 1 of 1 Area Owner Safety Priority Duration Related?

Estimated-hours Description of Issue Resources Needed Use this form to document maior items to be addressed during Recovery.

Area: Onsite / Offsite I Public Information Owner: Responsible individual or organization Safety Related: Yes or No Priority: 1 = Immediate (24 hr.) 2 = Short Term (1 Week) 3 = Intermediate (1 Month) 4 = Long Term (> 1 Month)

Duration: Estimated Calendar Duration Estimated-hours: Estimated Total Project Hours

N, EP-AA-1 15 Revision 3 Page 21 of 21 ATTACHMENT 8 EVENT

SUMMARY

REPORT FORMAT Page 1 of 1 Date Time To: Offsite Authority (NRC, State, Local)

From: Name (Recovery Director or Emergency Director)

Subject:

Event Summary Report of Emergency Declared at the Exelon XX Station The Station has:

Transitioned into Recovery at Terminated from a classification at The following is a review of events and items pertaining to Indicate EAL and Type reported on Provide a narrative of the event (describe the event giving the facts of the emergency including as a minimum:)

Initial Conditions

  • Provide unaffected unit status
  • Provide affected unit status
  • Provide any other pertinent equipment or condition status Initiating and Sequence of Events Time Description of event 0810 description of initiating events 0811 Performance of initial notifications to offsite authorities.

0812 Include information on personnel injuries and status. (Do not include name(s) of victims unless the family has been notified) 0813 Requests for offsite assistance, including time and type.

0814 The magnitude of any radiological release and Protective Action Recommendation information as applicable.

Conclusion K>

  • Provide an update of actions taken and results from investigations of the event.
  • Exelon contact for any additional information.
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