L-HU-07-021, Units 1 and 2, Request for Approval of a Combined Nuclear Management Company Emergency Plan

Units 1 and 2, Request for Approval of a Combined Nuclear Management Company Emergency Plan

ML072200142
Person / Time
Site:	Monticello, Prairie Island
Issue date:	08/07/2007
From:	Weinkam E Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-HU-07-021, TAC MC4930, TAC MC4931, TAC MC5017
Download: ML072200142 (182)

Text

Commi?tedto Nuclear Excel/ence Nuclear Management Company, LLC August 07,2007 L-HU-07-021 10 CFR 50.47 10 CFR 50 Appendix E 10 CFR 50.54(q)

U.S. Nuclear Regulatory Commission APTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Prairie Island Nuclear Generating Plant Docket 50-263 Units 1 and 2 License No. DPR-22 Dockets 50-282, 50-306 and 72-010 License Nos. DPR-42 and DPR-60 SNM License No. SNM-2506 Request for Approval of a Combined Nuclear Manaqement Companv Emergencv Plan for the Prairie lsland and Monticello Nuclear Generating Plants

References:

1) Nuclear Regulatory Commission (NRC) letter to Nuclear Management Company, LLC (NMC), Prairie lsland Nuclear Generating Plant, Units 1 and 2 - Changes to Emergency Action Levels (TAC Nos. MC4930 and MC4931) dated November 18, 2005, (ADAMS Accession No. ML053080024)

2) Nuclear Regulatory Commission (NRC) letter to Nuclear Management Company, LLC (NMC), Monticello Nuclear Generating Plant, Unit No. 1

- Revision to Emergency Plan Emergency Action Levels (TAC NO.

MC5017) dated January 5,2006, (ADAMS Accession No. ML060040437)

Nuclear Management Company, LLC (NMC) hereby submits a combined Nuclear Emergency Plan for the Prairie lsland Nuclear Generating Plant.(PINGP), Units 1 and 2; and the Monticello Nuclear Generating Plant (MNGP) for review and approval pursuant to 10 CFR 50.54(q). The revised Nuclear Emergency Plan includes:

1. A generic Nuclear Emergency Plan applicable to both sites

2. Individual site annexes containing site specific information

Document Control Desk Page 2 This revision to the Emergency Plans for the PINGP and the MNGP is a complete rewrite to establish a new baseline commitment. The changes reflected in the proposed Nuclear Emergency Plan (NEP) incorporate a process to improve response capabilities by establishing an emergency plan which incorporates the latest accepted industry practices.

The revised response capabilities include an on-shift organization to initially implement the Emergency Plan and an augmented response. The augmented response organization deviates from NUREG-0654, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, in that it does not require thirty (30) minute responders. This was accomplished by evaluating the functions fulfilled by the NUREG-0654 thirty-minute responders and assigning those functions that are appropriately required to on-shift functions.

The Emergency Response Organization (ERO) is modeled to place the responsibilities within the facility where the function can be most capably performed. The proposed revisions include the following:

1. Assigning additional personnel to the shift staffing and augmentation roster.

• The addition in on-shift staffing provides enhanced capabilities for immediate mitigation response actions. The immediate actions are Emergency Operating Procedure (EOP) driven. The industry adoption of the EOP concept focuses actions on mitigation rather than on initial maintenance functions.

• Total on-shift responder functions are increased from 10 to 13 for the MNGP by the addition of two plant operators and a Shift Technical Advisor to compensate for the elimination of the 30-minute responders.

• Total on-shift responder functions are increased from 12 to 14 for the PINGP by the addition of a Radiation Protection (RP) Specialist and a Chemistry Technician to the Chemistry function to compensate for elimination of the 30-minute responders.

• Augmented staffing is increased from 23 to 31 for the MNGP and from 26 to 31 for the PINGP.

• The augmented ERO will respond to their respective facilities with a goal of being at minimum staffing level within 75 and 90 minutes of the emergency declaration requiring activation. The expectation is that called out ERO will respond as soon as possible, if fit for duty.

Document Control Desk Page 3

2. Moving Engineering support to the Technical Support Center (TSC) and the Operations Support Center (OSC). Engineering support moved from the Emergency Operations Facility (EOF) to improve the engineering focus on plant recovery actions.

3. Increasing Security staffing in the TSC and EOF.

4. Strengthening of plant team response by centralizing necessary response personnel under the direct control of the OSC.

5. Providing additional support for the Joint Information Center (JIC) in the EOF.

6. Adding the Assistant Emergency Manager in the EOF and the Assistant Emergency Director in the TSC.

7. Providing the Emergency Notification System (ENS) Communicator in the Control Room (CR), TSC, and EOF.

The proposed combined NEP standardizes the commitments of both the PINGP and the MNGP emergency preparedness programs. Standardization enhances the ability of the NMC organization to respond to emergencies by having a common baseline. The ERO Training Program will be standardized with the site specific differences noted. This will allow ERO qualifications to be easily transferred between the sites. For example, this could allow the same dose calculation and dose projection model to be used by both sites allowing effective distribution of critical radiation protection resources.

The emergency classification scheme for each plant has been approved by separate Safety Evaluation Report (SER) (References 1 and 2).

The NEP is organized to align with the section numbering in NUREG-0654 thus providing a direct cross reference to the base planning document. Site specific Annexes contain details applicable to either the PINGP or the MNGP. In addition, Annex sections are then cross referenced to the NEP.

Emergency Plan Implementing Procedures will be developed to implement the NEP commitments. Emergency Plan maintenance and administrative procedures will be developed to maintain facilities and equipment and to administer the Emergency Preparedness Program respectively.

This proposed change is being submitted in accordance with the requirements of 10 CFR 50.54(q) and fully meets the requirements of 10 CFR 50.47, 10 CFR 50 Appendix E and NRC Bulletin 2005-02, Emergency Preparedness and Response Actions for Security-Based Events.

Document Control Desk Page 4 Summary of Commitments This letter makes no new commitments or changes to any existing commitments.

The NMC requests approval of this revision to the Emergency Plans for the PINGP and the MNGP to combine them into one Nuclear Emergency Plan and approval of the corresponding Site Annexes by August 7, 2008. August 7,2008 approval allows adequate time for procedure revisions, training and the drills required for implementation.

b ez2r,~mkam ar Licensing and Regulatory Services Nuclear Management Company, LLC cc: Administrator, Region Ill, USNRC (with two copies of Enclosures 2, 3 and 4)

Project Managers, Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant, USNRC NRC Resident Inspectors, Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant, USNRC Minnesota Department of Commerce State of Wisconsin E. Duncan, Region Ill, USNRC (2 CD-ROMs)

Enclosures (4)

ENCLOSURE 1 PROPOSED ON-SHIFT AND AUGMENTED STAFFING LEVELS FOR THE MONTICELLO AND PRAIRIE ISLAND NUCLEAR GENERATING PLANTS The proposed on-shift and augmented staffing levels for the Monticello Nuclear Generating Plant (MNGP) (Single Unit) and Prairie Island Nuclear Generating Plant (PINGP) (Dual Unit) are shown below.

The current minimum staffing levels for MNGP and PINGP are shown on the following pages.

Table B-1, Minimum Shift Staffing for Emergencies MAJOR FUNCTIONAL POSITION TITLE SINGLE UNIT DUAL UNIT AREA Shift Manager 1 1 Plant Operations and Control Room/Shift Supervisor 1 2 Assessment of Operational Reactor Operators 3 3 Aspects Non-licensed Operators 41, 2 41 Shift Technical Advisor 1 1 Notification/

Communicator 1 1 Communications Radiological Accident RP/Chemistry Technician (dose 11, 2 11 Assessment and Support of assessment and surveys)

Operational Accident Chemistry Technician 1 1 Assessment ONSHIFT TOTAL 13 14 Notes:

1. Non-licensed Operators (NLOs) are trained to provide their own radiological coverage, satisfying the requirement for additional Radiation Protection (RP) Technicians.

2. If Union negotiations do not allow NLOs to provide their own RP coverage, Monticello on-shift RPs will be increased to 3 and NLOs will decrease to 3.

Augmented Staffing AVAILABLE AVAILABLE MAJOR FUNCTIONAL POSITION TITLE ONSHIFT 75 MINUTES 90 MINUTES AREA Emergency Direction Emergency Director/Emergency Onshift (SM) 1 1 and Control Manager Nuclear Engineer Onshift (STA) 1 Plant System Electrical Engineer 1 Engineering / Mechanical Engineer 1 Radwaste Operator 1 Repair and Corrective Mechanical Maintenance 1 1 Actions Electrical Maintenance 1 1 I&C Technician 1 Protective Actions RP Technicians Onshift 2 2 OSC Group Leads 4 Communications Communicator Onshift 3 2 Health Physics (Dose Assessment Radiological protection Onshift 3 4 and surveys)

Local Fire Suppression Plant personnel Onshift Support Rescue Operations and Local Plant Personnel Onshift First Aid Support Site Access Control and Plant Personnel All per All per Personnel (Security/Communications/Personn Security Plan Security Plan Accountability el Accountability)

AUGMENTED TOTAL 19 12

The Current Minimum Staffing Table for Monticello MDNTfCEPGQ NUCLEAR GENERATlkrG PLANT E P-5 TITLE: EMERGENCY PLAN Rwision 27 Page 21 .of 26 Table 5.0-1 Minimum Shif-2Staffing and Capability far Additions fur Nuclear Power Plant Emergencies Notify licenseel Local. Shift Ernerg Comrnuni- 1 Communication State, and Federal cat0r personnel & agencies

-- 1 --

i d Emergen- -- I --

In-Plant Shtweys 1 1 I

The Current Minimum Staffinq Table for Monticello CorwThemral Hyd.

EEectrical Mechanical Repair 6t Ciorre-ective Mech hfairrt Actions RadwasZe Qper Etec Maint 1 1 1 a.Amess Control

b. HP Coverage for re-sponse acfians

c. Personnel monitor-

d. Dosimetry tions, Personnel Accountability

The Current Minimum Staffing Table for Prairie Island WRIEISLAND UWLEAR GEER&TIUG PLANT EMERGENCY PLAN EMERGENCY PLAN Tabla f Guidance for Augmentation of PfmtEmergency Organization CapabjTity for Wditions Mafor Functional Area Major Tasks Position T$le or Expertise On Shift 30 mitl 60 min Plant 3peraons and Shrf! Supenlsor (SRO)' 2 ksessment af Control Room Reactor Opem8onal Aspects Operators fROY Xuxilrary Operabrs:

Emergency Direction Shift Manager or and Go8trcd individual on (ErnzfgencyDI~&M) Emergency D ~ E E ~

Roster. p!

NofiFf State. local Shift Emergency znd Federal Cornmunlcator:

personnel R mahbin mn~n~ranicatiun Ra31ologicalACCI~BR~ Emergency OperatFms Emergency Ssdananager

&sesmient aead Faality {EOQ {as per duty roster):

Suppart of D~~ecZor Operagonal Acctdent Assessment OgsL Dose Radiological Assessment Emergency CmCoordin&or:

Offsite S U W E * ~ Rad Pmt Specblist:

Onsite Surveys Rad Pmt Soecialisf:

[ou~f-plant)

In-plant Suweys f Eant Operators an&r Rad Prot. Spedalis-t:

The Current Minimum Staftinq Table for Prairie Island PRAIRIE ISLAND NUCLEAR GEMERRTfEfG PtANT BdERGUICY PCRN EMERGENCY PLAN Tabk ^f Guidance b r Augmentation of Piant Emergency Organization Capabliityfor Additions Major FunBonar Area Major Tasks Positron M l e or Expertise On 5hlfl 30 min 60 min Chersrldr,<)

Rad~ochemistrf Rad Prot SpectafLffit 1 1 Plant System Technical Suppoipod ShliiTechnicalA&JM Englneer~ng, CoMhermal.

Repair and flectneal.

Correctr~eActions !Jechan~cak Repam and Mechanrcal Malnbnmce. 1': 1 CorreecSve 9ctmns Pad Opemr 1

,$fl Eiectncal Uamtenanw 1 1 Instrumen8 Cow&& 1 Radiation Rad Pmt S$lecia!rst Protectrrwa andh Plan? Operators $3 4 2 2

a. Access Control b HP C O W ~ ~f~Q ~ ?

reprrrr, corrective actcons, search and rescue, Frst-a4d &

Frefightrng

e. Pefs~nnel monlionng d Dosimetrj F~reFighting Fare Ffigade per F5

The Current Minimum Staffing Table for Prairie Island EMERGENCY PLAN Table t Guidance for Augmentation of Pbnt Emergency Organization Capabitity for Additions Major ft~sc?!onatArea Major Tasks Position Title or Expertise On Shrff 30 mtn 60 mrn Rescue Ope&lorrs and FITS41d p! Local SuppH Ss$ Access Control Security, frrerightrng Seclrr~tyPersonnel As per and Personnel coanmuraications. Secunty Accountah~BPq personnel Plan acwuntahil~tf

@' lo RPG u f ia r r ~ e l~9on11ce #iB!n approukrrarely 2-3 hours to auarnsnt anc! rel~evethe Pralne Island RPG o! offsrtesurveys

'" On shi? R35 1s cross-h~nean Rad~atlcnPrctechon apd clh?nXlstryradlochernsny The non~lcensedplan'opentors are fully hanzd to conduct pmt-accldent~ n - p l asunP1eys, t dur~ngthe first hour of the emergency.

ENCLOSURE 2 NUCLEAR MANAGEMENT COMPANY, LCC NUCLEAR EMERGENCY PLAN for the PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 and MONTICELLO NUCLEAR GENERATING PLANT (97 Pages Follow)

Nuclear Management Company Nuclear Emergency Plan

Table of Contents Introduction....................................................................................................................... 7 Purpose............................................................................................................................ 7 Background ..................................................................................................................... 7 Scope............................................................................................................................... 7 SECTION A: ASSIGNMENT OF RESPONSIBILITY............................................ 9 A.1 Primary Federal Organizations ........................................................................... 9 A.1.1 Nuclear Regulatory Commission (NRC) .................................................... 9 A.1.2 U.S. Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA) ................................................................................... 9 A.1.3 U.S. Department of Energy (DOE)............................................................. 9 A.1.4 Federal Bureau of Investigation (FBI)...................................................... 10 A.1.5 National Weather Service (NWS)............................................................. 10 A.1.6 Environmental Protection Agency (EPA)................................................. 10 A.1.7 U. S. Department of Homeland Security (DHS), U.S. Coast Guard (USCG) 10 A.1.8 U.S. Army Corps of Engineers ................................................................. 10 A.1.9 Federal Radiological Preparedness Coordinating Committee (FRPCC) .. 11 A.1.10 Bureau of Indian Affairs ........................................................................... 11 A.1.11 Indian Health Services .............................................................................. 11 A.2 State, Tribal and Local Organizations .............................................................. 11 A.2.1 State of Minnesota .................................................................................... 11 A.2.1.1 Minnesota Department of Public Safety (DPS) ....................................... 11 A.2.1.2 Minnesota Department of Health (MDH)................................................ 12 A.2.1.3 Other Minnesota State Agencies.............................................................. 12 A.2.2 State of Wisconsin .................................................................................... 12 A.2.2.1 Dept. of Military Affairs, Wisconsin Emergency Management (WEM).. 12 A.2.2.2 Dept. of Health & Family Services (DHFS), Radiation Protection Section (RPS) 12 A.2.2.3 Other Wisconsin State Agencies............................................................... 13 A.2.3 The Counties of Goodhue, Dakota, Pierce, Wright and Sherburne .......... 13 A.2.4 Prairie Island Indian Community.............................................................. 13 A.2.5 Other Utilities............................................................................................ 13 A.3 Agreements ....................................................................................................... 13 A.4 Continuous Operations...................................................................................... 14 SECTION B: ONSITE EMERGENCY RESPONSE ORGANIZATION (ERO) .... 15 B.1 Normal Organization......................................................................................... 15 B.1.1 Minimum Staffing..................................................................................... 15 B.2 Emergency Director (ED) ................................................................................. 16 B.3 Line of Succession............................................................................................. 17 B.4 Emergency Director/Emergency Manager Responsibilities............................... 17 Transition of Responsibilities: Table B-4 ..............................................................18 B.5 Emergency Response Organization ................................................................... 18 B.5.12 Operations Group Lead ............................................................................. 23 2

B.6 Onsite and Offsite Interfaces ............................................................................. 24 B.7 Organization and Coordination.......................................................................... 24 B.8 Contractor and Private Organizations ................................................................ 29 B.9 Local Emergency Support Organizations .......................................................... 30 Table B-1, Minimum Shift Staffing for Emergencies ..........................................32 Figure B.1.a: Control Room 2 Unit ........................................................................33 Figure B.1.b: Control Room 1 Unit........................................................................34 Figure B.1.c: TSC Organization .............................................................................35 Figure B.1.d: OSC Organization ............................................................................36 Figure B.1.e: EOF Organization.............................................................................37 Figure B.1.f: JIC Organization...............................................................................38 C.1 Federal Assistance ............................................................................................. 39 C.2 State Interfaces .................................................................................................. 39 C.3 Radiological Laboratories.................................................................................. 39 C.4 Assistance Agreements...................................................................................... 40 SECTION D: EMERGENCY CLASSIFICATION SYSTEM .................................... 43 D.1 Classification of Emergencies ........................................................................... 43 D.1.2 Unusual Event ........................................................................................... 44 D.1.3 Alert .......................................................................................................... 44 D.1.4 Site Area Emergency ................................................................................. 44 D.1.5 General Emergency ................................................................................... 45 D.2 Initiating Conditions .......................................................................................... 45 SECTION E: NOTIFICATION METHODS AND PROCEDURES .......................... 46 E.1 Notification Methodology ................................................................................. 46 E.2 Notification........................................................................................................ 47 E.3 Initial Notification Message............................................................................... 48 E.4 Follow-up Messages.......................................................................................... 48 E.5 State/Tribe/local Public Notification.................................................................. 49 E.6 Public Warning.................................................................................................. 49 E.7 Public Protective Action Messages.................................................................... 49 SECTION F: EMERGENCY COMMUNICATIONS ................................................ 50 F.1 Communications................................................................................................ 50 F.2 Medical Emergency Communications............................................................... 52 F.3 Communications Tests ...................................................................................... 52 SECTION G: PUBLIC EDUCATION AND INFORMATION .................................. 53 G.1 Resident Information ......................................................................................... 53 G.2 Transient Information ........................................................................................ 53 G.3 Joint Information Centers .................................................................................. 53 G.4 Executive Spokesperson .................................................................................... 53 G.5 Media Training .................................................................................................. 54 SECTION H: EMERGENCY FACILITIES AND EQUIPMENT.............................. 55 H.1 Onsite Emergency Response Facilities .............................................................. 55 3

H.1.1 Control Room............................................................................................ 55 H.1.2 Technical Support Center .......................................................................... 55 H.1.3 Operations Support Center (OSC) ............................................................. 57 H.1.4 Emergency Operations Facility ................................................................. 57 H.2 State, Tribal and local Emergency Operations Centers ...................................... 58 H.3 Emergency Response Facility Staffing and Activation...................................... 58 H.4 Onsite Monitoring ............................................................................................. 59 H.4.1 Geophysical Monitors................................................................................ 59 H.4.2 Radiological Monitors and Sampling ........................................................ 60 H.4.2.1 Radiation Monitoring System (RMS) ........................................................ 60 H.4.2.2 Liquid and Gaseous Sampling Systems ..................................................... 60 H.4.2.3 Portable Radiation Monitoring Equipment ................................................ 60 H.4.3 Process Monitors ....................................................................................... 61 H.4.3.1 Plant Monitoring/Information System ....................................................... 61 H.4.3.2 Safety Parameter Display System (SPDS)................................................. 61 H.4.4 Fire Detection System ............................................................................... 61 H.5 Offsite Monitoring............................................................................................. 61 H.5.1 Geophysical Monitors: .............................................................................. 62 H.5.2 Radiological Environmental Monitors and Sampling............................... 62 H.5.3 Laboratory Facilities.................................................................................. 62 H.6 Offsite Radiological Monitoring Equipment...................................................... 62 H.7 Meteorological Equipment ................................................................................ 62 H.8 Operations Support Center ................................................................................ 63 H.9 Emergency Equipment Inventories and Checks................................................. 63 H.10 Emergency Kits ................................................................................................. 63 H.11 Collection Point for Field Samples ................................................................... 63 SECTION I: ACCIDENT ASSESSMENT.................................................................... 65 I.1 Systems and Parameters Monitored................................................................... 65 I.2 Continuing and Post Accident Assessment........................................................ 65 I.3 Offsite Dose Assessment ................................................................................... 66 I.4 Effluent Monitor Readings and Exposures ........................................................ 66 I.5 Meteorological Monitoring................................................................................ 66 I.6 Unmonitored Release ........................................................................................ 66 I.7 Environs Surveys and Monitoring ..................................................................... 67 I.8 Release Assessments ......................................................................................... 67 I.9 Environmental Radioiodine Monitoring Capabilities ........................................ 67 I.10 Relationship of Measured Parameters............................................................... 68 I.11 Severe Accident Management Guidelines (SAMG)......................................... 68 I.12 Federal and State Resources.............................................................................. 68 SECTION J: PROTECTIVE RESPONSE.................................................................... 69 J.1 Alarm Responses............................................................................................... 69 J.2 Site Evacuation Routes ...................................................................................... 70 J.3 Radiological Monitoring of Evacuees................................................................ 70 J.4 Non-essential Personnel Evacuation and Decontamination ............................... 70 J.5 Accountability ................................................................................................... 70 4

J.6 Onsite Protective Actions .................................................................................. 71 J.7 Offsite Protective Action Recommendations (PARs) ........................................ 71 J.8 Evacuation Time Estimates (ETE)..................................................................... 72 J.9 State/Tribal/local Protective Measures .............................................................. 72 J.10 Protective Action Maps ..................................................................................... 72 J.11 State Protective Measures.................................................................................. 72 J.12 State/local Relocation Centers ........................................................................... 72 SECTION K: RADIOLOGICAL EXPOSURE CONTROL ....................................... 74 K.1 Emergency Workers and Lifesaving Protective Actions.................................... 74 Emergency Worker Dose Limits: Table K-1 ........................................................74 K.1.1 Removal of injured persons ....................................................................... 75 K.1.1.1 Transportation Services ............................................................................. 75 K.1.2 Decontamination and First Aid.................................................................. 75 K.1.2.1 Onsite Responsive Action.......................................................................... 75 K.1.3 Medical Treatment .................................................................................... 75 K.2 Emergency Exposure Authorization .................................................................. 75 K.3 Exposure Controls ............................................................................................. 75 K.3.1 24-Hour Capabilities................................................................................. 75 K.3.2 Personnel Monitoring Equipment ............................................................. 76 K.4 Offsite Emergency Workers .............................................................................. 76 K.5 Decontamination ............................................................................................... 76 K.6 Contamination Controls..................................................................................... 77 K.7 Offsite Decontamination.................................................................................... 77 SECTION L: MEDICAL AND PUBLIC HEALTH SUPPORT................................ 78 L.1 Hospital and Medical Services .......................................................................... 78 L.2 First Aid ............................................................................................................ 78 L.3 State Emergency Medical Services.................................................................... 78 L.4 Medical Transport ............................................................................................. 78 SECTION M: RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS ................................................................................................................ 80 M.1 Recovery ........................................................................................................... 80 M.2 Recovery Organization ...................................................................................... 81 Figure M-2, Long Term Recovery Organization .................................................81 M.2.1 Recovery Manager..................................................................................... 81 M.2.2 Plant Actions ............................................................................................. 81 M.3 Recovery Notification........................................................................................ 82 M.4 Population Exposure Estimates ......................................................................... 82 M.5 Termination of Recovery Phase......................................................................... 82 SECTION N: EXERCISES AND DRILLS ................................................................... 83 N.1 Exercises ........................................................................................................... 83 N.1.1 Biennial Exercises ..................................................................................... 83 N.1.2 Participation............................................................................................... 84 N.1.3 Off-Year Drills .......................................................................................... 85 5

N.2 Drills and Tests.................................................................................................. 85 N.2.1 Communications Tests.............................................................................. 85 N.2.2 Fire Drills .................................................................................................. 86 N.2.3 Medical Emergency Drills ........................................................................ 86 N.2.4 Radiological Monitoring Drills................................................................. 86 N.2.5 Health Physics Drills................................................................................. 86 N.2.6 Augmentation Drills.................................................................................. 86 N.2.7 Accountability Drills................................................................................. 87 N.3 Scenarios ........................................................................................................... 87 N.4 Exercise Evaluation and Critique....................................................................... 87 N.5 Exercise/Drill Corrective Actions...................................................................... 88 SECTION O: RADIOLOGICAL EMERGENCY RESPONSE TRAINING........... 89 O.1 Training ............................................................................................................. 89 O.1.1 Training of Local Services Groups ........................................................... 89 O.2 Performance Demonstration .............................................................................. 90 O.3 First Aid Training (triennial) ............................................................................. 90 O.4 ERO Training .................................................................................................... 90 O.4.1 Key Emergency Response Organization.................................................... 90 O.4.2 Active Senior Licensed Control Room Personnel...................................... 91 O.4.3 Radiological Field Monitoring Teams ....................................................... 91 O.4.4 Fire Brigade Training ................................................................................ 91 O.4.5 Operations, Maintenance and Radiation Protection Training................... 91 O.4.6 First Aid Training (triennial) ..................................................................... 92 O.4.7 Training of Local Services Groups ............................................................ 92 O.4.8 Medical Support ........................................................................................ 92 O.4.9 Training of the Corporate Emergency Organization ................................ 92 O.4.10 Communications Personnel ....................................................................... 92 O.4.11 Emergency Communications Staff Training.............................................. 92 O.4.12 News Media Training ................................................................................ 92 O.5 Initial and Annual Retraining............................................................................ 93 SECTION P: RESPONSIBILITIES FOR EMERGENCY PREPAREDNESS PLANNING ..................................................................................................................... 94 P.1 EP Staff Training............................................................................................... 94 P.2 EP Responsibilities............................................................................................ 94 P.3 Emergency Preparedness Manager .................................................................... 94 P.4 Emergency Plan Review.................................................................................... 95 P.5 Emergency Plan Changes .................................................................................. 95 P.6 Supporting Plans................................................................................................ 96 P.7 Implementing Procedures .................................................................................. 96 P.8 Emergency Plan Contents.................................................................................. 96 P.9 Independent Review .......................................................................................... 96 P.10 Emergency Telephone Number Updates ........................................................... 96 6

Introduction Purpose The Nuclear Management Companys (NMC) Nuclear Emergency Plan (NEP) provides the means to protect the health and safety of the general public, persons temporarily visiting or assigned to nuclear power plants operated by NMC, and plant employees. NMC operates the Monticello and Prairie Island nuclear power plants for Xcel Energy.

Background

The NMC Nuclear Emergency Plan (NEP) was developed with the guidance of NUREG-0654, FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." The NEP meets the emergency planning standards of 10 CFR 50.47(b), the requirements of Appendix E and the intent of NUREG 0654.

The layout of the plan provides the cross-reference to the base document.

Scope Detailed procedures concerning the implementation of the NEP are in the Emergency Plan Implementing Procedures (EPIPs), Emergency Plan Maintenance Procedures (EPMPs) and Emergency Plan Administrative Procedures (EPAPs).

Those documents describe the duties of individuals and groups in the event of emergencies and also serve as the interface between the NEP and plant operations, security and radiological control programs. The above procedures are available for use at each of the plants. There are also various supporting and complementing emergency plans, including those of federal agencies and those for the states of Minnesota, Wisconsin, Prairie Island Indian Community and counties.

NMC has overall responsibility for maintaining a state of readiness to implement emergency plans for the protection of plant personnel, the general public and property from hazards associated with any facility operated by the company. The authority for planning, developing, and coordinating emergency control measures is derived from being the Nuclear Regulatory Commission (NRC) license holder for the nuclear power plants operated by NMC.

The NMC NEP describes the organization and facilities, both onsite and off-site, which will be used to address a wide spectrum of accidents ranging from minor onsite incidents to those that could affect the general public.

There are three phases of responsive action contained within the NEP. The first phase includes initial actions directed toward the protection of personnel and the elimination of the potential for further exposure to the hazard. The second phase includes immediate and planned action directed toward termination of the 7

condition, containment of any effluent, establishment of incident boundaries, establishment of control, channeling of information, and protection of the facility and equipment. The third phase is to restore the facility to its normal operating condition. To respond effectively utilizing these phases, emergencies are classified according to increasing severity as Unusual Event, Alert, Site Area Emergency or General Emergency.

8

SECTION A: ASSIGNMENT OF RESPONSIBILITY A.1 Primary Federal Organizations A.1.1 Nuclear Regulatory Commission (NRC)

The NRC is responsible for licensing and regulating nuclear facilities and materials. These responsibilities include protecting the public health and safety, protecting the environment, and protecting and safeguarding materials and nuclear plants in the interest of national security. The NRC Incident Response Plan objectives are to provide for protection from the effects of radiological incidents that may occur at licensed facilities or which involve licensed materials. In addition to fulfilling its regulatory responsibilities, it is expected that the NRC will provide technical assistance and recommendations.

The NRC acts as the lead federal agency regarding technical matters during a nuclear incident, with the Chairman of the Commission as the senior NRC authority for all response aspects. The Chairman can transfer control of emergency response activities when deemed appropriate.

Incident Response Centers have been established at each of the four NRC regional offices and NRC Headquarters, to centralize and coordinate NRCs emergency response. Each NRC Region is prepared to send a team of qualified specialists to an accident scene. For Site Area and General Emergencies, a NRC Region III site team is expected to be dispatched to NMC facilities, with arrival in two to seven hours following notification. Office space, telephones, and other equipment is provided for NRC personnel use at each plants Technical Support Center and Emergency Operations Facility.

A.1.2 U.S. Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA)

By the Federal Response Plan (FRP), FEMA is responsible for the overall coordination of a multi-agency Federal response to a significant radiological incident. The primary role of FEMA is to support the states by coordinating the delivery of federal non-technical assistance. FEMA coordinates state and tribal requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary, FEMA will establish a nearby Federal Response Center from which it will manage its assistance activities.

A.1.3 U.S. Department of Energy (DOE) 9

The DOE has agreed to provide radiological assistance upon request, and has radiological monitoring equipment and personnel resources that it can assemble and dispatch to the scene of a radiological incident. Following a radiological incident, DOE operates as outlined in the Federal Radiological Monitoring and Assessment Plan (FRMAP). DOE has the responsibility to establish the Federal Radiological Monitoring and Assessment Center (FRMAC), which would provide comprehensive post-accident radiological monitoring and assessment. If the affected state(s) deemed that assistance from DOE were necessary, the affected state(s) would notify the appropriate DOE Operations Office. The Radiological Assistance Team can be expected to respond to NMC operated sites as directed by the Chicago Operations Office of DOE.

A.1.4 Federal Bureau of Investigation (FBI)

Support from the FBI is available through its statutory responsibility, based in Public Law and the US code, and through a memorandum of understanding for cooperation with the NRC. Notification to the FBI of emergencies in which they would have an interest will be through the provisions of a plant security plan, or by the NRC.

A.1.5 National Weather Service (NWS)

NWS provides meteorological information during emergency situations, if required. Data available will include existing and forecasted wind directions, wind speeds, and ambient air temperatures.

A.1.6 Environmental Protection Agency (EPA)

The EPA can assist with field radiological monitoring, sampling, and non-plant related recovery and reentry guidance.

A.1.7 U. S. Department of Homeland Security (DHS), U.S. Coast Guard (USCG)

The USCG patrols and ensures the safety of the navigable waterways in the United States, and can supply local weather information, if necessary.

The USCG is notified of any hazardous substance discharges or radioactive contamination of rivers or lakes at levels requiring assistance to effect protective actions. The USCG is responsible for officially closing the waterways to commercial traffic. When requested, the USCG will make a marine broadcast and issue a Notice to Mariners, warning craft of the danger in an area. The USCG is contacted by the appropriate state agencies in the event of an incident at an applicable nuclear power plant.

A.1.8 U.S. Army Corps of Engineers 10

The U.S. Army Corps of Engineers control barge and boat traffic at locks and dams on navigable waterways in the United States. The Corps of Engineers will be contacted by the appropriate state agencies in the event of an incident at an applicable nuclear power plant. The Corps will be responsible for closing their locks and dams to waterway traffic leading to the affected area.

A.1.9 Federal Radiological Preparedness Coordinating Committee (FRPCC)

The FRPCC consists of the Department of Homeland Securitys Federal Emergency Management Agency, which chairs the Committee, the Nuclear Regulatory Commission, the Environmental Protection Agency, the Department of Health and Human Services, the Department of Energy, the Department of Transportation, the Department of Defense, the Department of Agriculture, and the Department of Commerce. Where appropriate, on an ad hoc basis, other federal departments and agencies can join the committee.

The FRPCC assists in providing policy direction for the program of federal assistance to state, tribal and local governments in their radiological emergency planning and preparedness activities.

A.1.10 Bureau of Indian Affairs The Bureau of Indian Affairs is the federal interface with the Prairie Island Indian Community.

A.1.11 Indian Health Services The Department of Indian Health Services deals with Indian health matters at a federal level.

A.2 State, Tribal and Local Organizations A.2.1 State of Minnesota A.2.1.1 Minnesota Department of Public Safety (DPS)

The Minnesota DPS (Homeland Security, Emergency Management and Bureau of Criminal Apprehension [HSEM]) have the responsibility for notification and coordination of Minnesota State Agencies in the event of a major radiological emergency at any Minnesota nuclear power plant. When notified by an affected nuclear plant of an emergency situation, the Minnesota duty officer 11

will call the Minnesota Department of Health, the Governors Authorized Representative and other state agencies with emergency assignments to coordinate the implementation of emergency procedures. The various state emergency response agencies staff twenty-four hour emergency notification and communications systems.

A.2.1.2 Minnesota Department of Health (MDH)

The Minnesota Department of Health (MDH) is responsible for providing radiological expertise in the State Emergency Operations Center in conjunction with the MN HSEM. The Minnesota Department of Health will interpret data and participate in recommending protective actions to the Governors Authorized Representative.

A.2.1.3 Other Minnesota State Agencies Responsibilities of the other state agencies are described in the Minnesota Emergency Plan.

A.2.2 State of Wisconsin A.2.2.1 Dept. of Military Affairs, Wisconsin Emergency Management (WEM)

The Administrator of WEM, as designated by the Governor of the State of Wisconsin, has the primary responsibility and authority for radiological emergency response planning. WEM will also coordinate the activities of other Wisconsin agencies. WEM will brief the governor as to the situation and actions taken by the federal, state, and local agencies and, activate the states Emergency Operations Center (EOC).

A.2.2.2 Dept. of Health & Family Services (DHFS), Radiation Protection Section (RPS)

The Radiation Protection Section (RPS), Department of Health and Family Services, under the Radiation Protection Act, is responsible for preventing exposure to ionizing radiation in detrimental amounts. The state designates a State Radiological Coordinator (SRC) of the State Radiological Response Team for radiological emergencies. Team members are personnel of the Section, augmented by selected personnel from the WEM and other state 12

agencies trained specifically for radiological incidents. They conduct an initial survey to determine direct radiation levels, and the severity and extent of the contaminated area, including soil, food and crop samples. They advise how decontamination of the area should be accomplished; and assist in the radiological monitoring of evacuees.

A.2.2.3 Other Wisconsin State Agencies Responsibilities of the other state agencies are described in the Wisconsin Emergency Plan.

A.2.3 The Counties of Goodhue, Dakota, Pierce, Wright and Sherburne The Goodhue, Dakota, Pierce, Wright and Sherburne County Emergency Management Organizations have the responsibility for notification and providing direction to residents in the event of a major emergency that affects their respective area of responsibility. Each county Sheriffs Department has the responsibility to notify necessary local civil support groups in the event of an accident. The Sheriff is responsible for protection of the public and can provide personnel and equipment for evacuation, relocation and isolation.

A.2.4 Prairie Island Indian Community The Prairie Island Indian Community has an Emergency Operations Plan that includes the description of tribal responsibilities during a declared emergency at the nearby Prairie Island Nuclear Plant. The Prairie Island Nuclear Plant will provide emergency notification to the Treasure Island Casino security dispatch center, which will notify appropriate members of the Prairie Island Indian Community.

A.2.5 Other Utilities The Institute of Nuclear Power Operations (INPO) aids nuclear utilities in obtaining resources beyond their usual capabilities during recovery from an emergency. As one of its roles, INPO will assist affected utilities by applying the resources of the nuclear industry to meet the needs of an emergency.

A.3 Agreements Letters of Agreement (LOAs) are not necessary with federal and state agencies that are legally required to respond to an emergency; however, agreements are 13

necessary if an agency is expected to provide assistance not required by law.

Written agreements have been developed which establish the extent of operations between NMC operated plants and other support organizations which have an emergency response role consistent with this plan. These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information.

The respective nuclear power plants have obtained LOAs with private contractors and others who provide emergency support services. LOAs, as a minimum, state that the cooperating organization will provide their normal services in support of an emergency at the affected plant. Letters of Agreement are referenced in the site-specific plant Annexes and the actual letters are maintained on file for each plant.

A.4 Continuous Operations NMC maintains a 24-hour emergency response capability at each plant. The normal on-shift complement provides the initial response to an emergency.

This group is trained to respond to emergency situations until the augmented Emergency Response Organization (ERO) arrives. The ERO is composed of personnel with specialties in operations, maintenance, engineering, radiochemistry, health physics, material control, fire protection, and security.

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SECTION B: ONSITE EMERGENCY RESPONSE ORGANIZATION (ERO)

B.1 Normal Organization The normal onsite organization of a NMC operated nuclear power plant provides a staff fully capable of providing the initial response to an emergency event. On-shift staffing requirements for operational considerations are contained in each plants Technical Specifications. These on-shift personnel are trained to:

• Recognize abnormal conditions;

• Determine that an emergency exists;

• Provide initial assessment and classification;

• Promptly notify state, tribal, local, federal, onsite personnel;

• Augment the on-shift staff with an Emergency Response Organization (ERO).

B.1.1 Minimum Staffing For any condition, each operating shift is required to have a minimum number of appropriately qualified personnel. The required numbers of each, for emergency response, are found in Table B-1 for single or dual unit sites.

B.1.2 The Shift Manager (SM) is in direct charge of all plant operations during their shift and is directly responsible for the actions of the on-shift crew. In an emergency, the SM assumes the position of the Emergency Director (ED) and takes all necessary actions to identify and respond to the emergency. The ED, at their discretion, or when procedurally required, activates the ERO.

B.1.3 Control Room/Shift Supervisors, who hold Senior Reactor Operator (SRO) licenses, supervise operation of each unit.

B.1.4 Licensed Reactor Operators, who hold Reactor Operator licenses, manipulate reactor and plant controls as ordered by the Control Room/Shift Supervisor.

B.1.5 The Shift Technical Advisor (STA), during an emergency, steps back from shift duties to assume an overview role with the specific responsibility to monitor the maintenance of core cooling and containment integrity, as well as assist the Shift Manager 15

(Emergency Director) in evaluation of plant conditions and the emergency classification.

B.1.6 At least three individuals qualified to perform radiation protection duties are on shift and are required in the initial emergency response.

B.1.7 At least one Chemistry Technician is available on each shift and is required in the initial emergency response and analyses.

B.1.8 Sufficient personnel are available on shift to provide for a Communicator during the initial phase of the emergency.

B.1.9 The Station Security personnel are responsible for the physical security of the site. Included in this organization are security supervision and security officers.

B.1.10 Other initial emergency related needs may be drawn from on-shift Radiation Protection Technicians, Plant Operators, Plant Security, and the Fire Brigade personnel, as available.

B.2 Emergency Director (ED)

B.2.1 A Shift Manager is on duty twenty-four hours a day, and by being capable of assuming the responsibility of the Emergency Director, provides twenty-four hour coverage. Once a classification is made, the Shift Manager assumes the responsibility of the Emergency Director (ED). The ED has initial overall coordinating authority for Nuclear Management Company resources. The ED has the authority and responsibility to immediately initiate any emergency actions, including protective action recommendations to offsite authorities that are responsible for implementing offsite emergency measures. The Shift Manager serves as the ED until relieved by an Emergency Director (ED) in the TSC.

B.2.2 While serving in the ED capacity, the Shift Manager is responsible for:

• Performing those duties outlined in Section B.4 for the Emergency Director;

• Activating the ERO;

• Initiating the NRC Emergency Response Data System (ERDS).

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After being relieved as Emergency Director, the Shift Manager directs the activities of the operating crew and is responsible for the safe operation of the plant. The Shift Manager, after relinquishing Emergency Director duties, functionally reports to the Operations Manager in the TSC.

B.3 Line of Succession B.3.1 The Emergency Director (ED) is from a group consisting of the Plant Manager, their designated senior plant management personnel, and the currently licensed Shift Managers. Command and control normally shifts from the Control Room to the Technical Support Center (TSC), then to the Emergency Operations Facility (EOF). It may move in either direction, depending upon conditions which would warrant passing command and control authority. A qualified ED or Emergency Manager (EM) in any facility can relieve either of the other facilities of the authority and responsibilities.

B.3.2 The line of succession of individuals who serve as the ED or EM is as follows:

The Shift Manager is responsible for the initial classification of an event and assumes the position of Emergency Director. In this capacity, the Shift Manager has the ED responsibilities until relieved. In the event that the Shift Manager is incapacitated, a Control Room/Shift Supervisor will assume emergency responsibilities until relieved by a qualified Shift Manager.

An Emergency Director in the TSC will assume overall authority and responsibility for performing on-site response duties from the Shift Manager/Emergency Director (SM/ED). An Emergency Manager (EM) in the EOF will relieve the SM/ED of overall command and control and assume the responsibilities for Protective Action Recommendation (PAR) determination and notifications to offsite authorities.

B.4 Emergency Director/Emergency Manager Responsibilities B.4.1 The Emergency Director has the following responsibilities:

• Event classification;

• Protective Action Recommendations (PARs) for the public; 17

• Notification of offsite authorities (approval of State/tribal/local and NRC notifications);

• Authorization of emergency exposures in excess of 5 Rem TEDE and the issuance of potassium iodide (KI) to plant employees as a thyroid blocking agent.

B.4.2 The Emergency Director authority to exercise the above critical functions and responsibilities transfers to the Emergency Manager as indicated in Table B-4. NMC plants have the option to shift command and control directly from the Control Room to the EOF if warranted. NMC operated plants normally shift command and control from the Control Room to the TSC and then to the EOF unless the EOF is not activated, or EOF activation is delayed.

B.4.3 Classification and emergency exposure controls (authorizations) will transfer to the EOF if the TSC is not activated. Classification of security events will remain in the Control Room.

Transition of Responsibilities: Table B-4 Control Room TSC EOF Emergency Director Emergency Director (TSC) Emergency Manager (EOF)

Classification Classification Notifications Notifications Notifications PARs PARs PARs Emergency Exposure Emergency Exposure Controls Controls B.5 Emergency Response Organization B.5.1 The minimum quantity of personnel available on shift, and the quantity of additional personnel available within 75 minutes and 90 minutes following declaration of an emergency, to staff the emergency organization, are shown in Table B-1.

B.5.2 Shift Manager B.5.2.1 The Shift Manager, after being relieved of Emergency Director responsibilities, will:

• Exercise the authority to oversee manipulation of reactor and system controls;

• Adhere to the plant Technical Specifications and to review routine operating data to assure safe operation; 18

• Identify applicable EALs and emergency classifications;

• Adhere to plant operating procedures and the requirements for their use;

• Oversee the activities of Control Room personnel and Operations Communicator;

• Invoke the emergency provisions of 10 CFR 50.54(x) if appropriate.

B.5.3 Technical Support Center Emergency Director (TSC ED)

The TSC EDs responsibilities include organizing and coordinating the onsite emergency efforts. Additionally, the TSC ED has the requisite authority, plant operating experience and qualifications to implement in-plant recovery operations.

B.5.3.1 TSC Emergency Director Responsibilities while in Command and Control:

• Perform all responsibilities as the Emergency Director in Command and Control until relieved by the Emergency Manager in the EOF;

• Direct personnel assembly/accountability and evacuation of nonessential personnel at declaration of a Site Area Emergency or as conditions warrant;

• If the emergency involves a hazardous substance and/or oil discharges, ensure that appropriate notifications and responses have been made;

• Authorization of emergency exposures in excess of 5 Rem TEDE;

• Issuance of potassium iodide (KI) to plant employees as a thyroid blocking agent;

• Protective actions for all onsite personnel;

• Inform personnel in the EOF and NRC of the plant status;

• Provide information and recommendations to the Emergency Manager.

B.5.3.3 TSC Staffing Plant supervisory personnel, supplemented by plant engineering, technical and administrative personnel as necessary, will staff the TSC. When activated, it will be continuously staffed until termination of the event or entry into Recovery.

B.5.4 TSC Coordinator 19

B.5.4.1 The TSC Coordinator reports to the TSC Emergency Director and is responsible for coordination of communications between the TSC and other facilities or agencies, administration, and log maintenance. Other responsibilities include:

• Establishing or ensuring that communications are established between all onsite emergency facilities and the EOF;

• Coordinating activities of plant and NRC personnel located in the TSC;

• Periodically updating personnel located in the TSC with current information;

• Coordinating onsite ERO shift relief, transportation arrangements, meals and other special needs.

B.5.5 TSC Operations Manager B.5.5.1 The Operations Manager reports to the TSC Emergency Director.

Major position functions include evaluating plant conditions and initiating mitigative actions. The position has the responsibility to:

• Coordinate TSC efforts in determining the nature and extent of plant conditions affecting plant equipment and facilities in support of Control Room actions;

• Initiate immediate mitigative actions to limit or contain the emergency, invoking the provisions of 10 CFR 50.54(x) if appropriate;

• Recommend equipment operations, checks and miscellaneous actions to the Control Room in support of accident mitigation and restoration;

• Assist the OSC Manager in determining the priority assigned to OSC activities;

• Organize and ensure medical response efforts are made for injured personnel;

• Ensure adequate staffing of the Control Room;

• Supervise the activities of the Operations Assistant, ENS Communicator, and TSC/OSC Communicator;

• Act as the TSC liaison with the NRC Site Team; B.5.6. TSC Radiation Protection Manager (RPM)

B.5.6.1 The TSC Radiation Protection Manager reports to the TSC Emergency Director and supervises the activities of the radiation protection staff and the Health Physics Network (HPN) 20

Communicator. The TSC RPM assists the Radiation Protection/Chemistry Group Lead in the OSC in determining the extent and nature of radiological or hazardous material problems onsite. Responsibilities include:

• Accumulating, tabulating and evaluating data on meteorological and radiological monitoring readings;

• Acting as a liaison with the NRC Site Team;

• Ensuring use of protective clothing, respiratory protection, and access control within the plant, to control personnel exposures;

• Ensuring that personnel are decontaminated;

• Authorizing personnel exposures up to 5 Rem TEDE (EPA-400 lower limit);

• Assisting the TSC Director in determining if exposures in excess of the 5 Rem TEDE (EPA-400 lower limit) are necessary;

• Advising the TSC Director of situations when the use of KI should be considered;

• Advising the Emergency Manager and EOF Radiation Protection Manager of changes in radiological release status;

• Assisting the Operations Manager in planning rescue operations and providing monitoring services as required, including the transfer of injured and/or contaminated personnel;

• Coordinating with Security Manager to determine the routes to be used for evacuation of non-essential personnel;

• Assuring additional radiation protection personnel and/or equipment is arranged for:

• Onsite surveys;

• Chemistry/radiochemistry;

• Onsite radiation protection for access control, damage control, and repair teams.

B.5.7 TSC Security Manager B.5.7.1 The Security Manager reports to the TSC Emergency Director.

The Security Managers responsibilities include:

• Carrying out the plant security and Access Control program;

• Maintaining personnel accountability onsite;

• Assisting in evacuation of onsite areas; 21

B.5.8 TSC Engineering Manager B.5.8.1 The Engineering Manager reports to the TSC Emergency Director.

The Engineering Manager is responsible for the overall direction of Engineering Group activities and assessment. The group consists of engineers from the following engineering disciplines:

• Nuclear;

• Electrical;

• Mechanical.

B.5.9 OSC Manager B.5.9.1 The OSC Manager reports to the TSC Operations Manager and directs a staff in providing labor, tools, protective equipment and parts needed for emergency repair, damage control and recovery.

Responsibilities include:

• Directing the total onsite maintenance and equipment restoration effort;

• Requesting additional equipment in order to expedite recovery and restoration;

• Supervising the activities of the Group Leads and the TSC/OSC Communicator;

• Ensuring the Operations Manager is informed of OSC staffing utilization and activities;

• In coordination with the Operations Manager, determining the priority assigned to OSC activities;

• Ensuring adequate staffing of the OSC;

• Assisting in rescue operations.

B.5.10 OSC Work Control Supervisor (WCS)

B.5.10.1 The WCS reports to the OSC Manager and is responsible for OSC general activation, operation, and repair planning. Other responsibilities of the WCS are to:

• Coordinate emergency repair activities initiated out of the OSC;

• Coordinate activities of plant personnel located in the OSC to support plant operations as requested by the Control Room and TSC;

• Assist personnel performing the accountability check in the OSC; 22

• Periodically update personnel located in the OSC with appropriate information.

B.5.10.2 The Maintenance Group Leads, Engineering Support, and Supply Chain groups report to the OSC Work Control Supervisor. The maintenance groups are made up of the Group Leads and staff from the mechanical, and electrical/I & C groups. Their responsibilities include:

• Planning the activities;

• Selecting team members;

• Briefing the Teams;

• Tracking job progress;

• Maintaining periodic communication with the teams.

The Engineering Support and Supply Chain groups provide engineering support for in-plant activities, and necessary materials and equipment for in-plant team support.

B.5.11 Radiological Monitoring B.5.11.1 The OSC Radiation Protection and Chemistry Groups provide for radiological monitoring, and report to the OSC Manager. Their responsibilities include:

• Onsite radiological surveys;

• Radiation protection;

• Access control;

• In-plant emergency team support;

• Search and rescue/First Aid;

• Personnel monitoring and decontamination;

• Dosimetry issue and monitoring;

• Onsite habitability surveys;

• Chemistry/Radiochemistry sampling and analysis;

• Count room operations;

• Assisting in core damage assessment.

B.5.12 Operations Group Lead The Operations Group Lead reports to the OSC Manager and provides in-plant operations support.

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B.5.13 Dose Assessment Staff B.5.13.1 Offsite and onsite dose assessment is done initially by the on-shift Radiation Protection individual, or the Chemistry Technician.

Onsite dose assessment is done from radiological readings onsite and calculated to identify problem areas, establish access controls, and reduce personnel exposures.

B.6 Onsite and Offsite Interfaces B.6.1.1 Table B-1 lists the key positions of the NMC ERO and the supporting positions assigned to interface with federal, state, tribal and county authorities.

B.6.1.2 Figures B-1a through B-1f illustrate the overall emergency response organization. Section B.5 discusses specific responsibilities and the interrelationships for key positions. Offsite state/tribal/local government interfaces are detailed in the site-specific Annexes.

B.7 Organization and Coordination B.7.1 EOF Organization B.7.1.1 The Emergency Operations Facility (EOF) organization consists of an Emergency Manager and five subordinate groups. Personnel from the affected plant staff the EOF to ensure that it is ready to assume its emergency responsibilities from the Control Room within approximately 90 minutes of classification. A member of designated senior site management shall assume the Emergency Manager position in the EOF. Groups represented in the EOF include:

• EOF Technical Group;

• EOF Radiation Protection Group;

• EOF General Staff, Logistics, and Regulatory Liaison Group;

• EOF Security Group;

• Joint Information Center Support Group.

B.7.2 EOF Emergency Manager B.7.2.1 The Emergency Manager in the EOF relieves the ED in the Technical Support Center of the following responsibilities:

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• Developing Protective Action Recommendations and the notification of offsite authorities;

• Ensuring offsite agency updates are periodically communicated as required or requested;

• Requesting assistance from emergency response organizations, as necessary;

• Approving the technical content of NMC press releases prior to their being released to the media;

• Coordinating NMC emergency response activities;

• Obtaining and coordinating the services of outside consultants and vendors;

• Ensuring that federal, state, tribal and local authorities and industry support agencies remain cognizant of the status of the emergency situation;

• Ensuring dispatch of State and County Liaisons to offsite governmental Emergency Operation Centers (EOCs);

• Advising utility management on matters related to emergency response efforts and needed resources to support the effort;

• Ensuring that offsite dose assessment and offsite radiological monitoring is conducted.

B.7.3 EOF Assistant Emergency Manager (AEM)

The Assistant Emergency Manager is primarily responsible for managing the efforts of the Joint Information Center Group and the Security Group. The AEM also aids the EM (EOF) in carrying out other responsibilities. The AEM will be trained to relieve the EM if necessary.

B.7.4 EOF Technical Group B.7.4.1 The technical group consists of select personnel from various site groups, led by the Technical Manager, who reports to the Emergency Manager. The Technical Group is responsible for:

• Assisting the Emergency Manager in determining plant-based PARs when necessary;

• Ensuring that the Radiation Protection Manager is informed of changes in plant status that impacts or potentially impacts the offsite environment or PARs;

• Interfacing with industry and contractor engineering support organizations; 25

• Advising the Emergency Manager on technical matters related to the event;

• Assisting in the development of post-accident recovery measures.

B.7.4.2 The EOF Technical Manager is supported in these efforts by their staff, an Operations Assistant, and a TSC/EOF Communicator.

The Operations Assistant has the specific responsibility to monitor the Operations Status Line to keep appraised of:

• Control Room activities, including progress on Emergency Operating Procedures;

• Significant changes in plant system/equipment status and critical parameters;

• Possible changes in event classification.

B.7.5 EOF Radiation Protection Group B.7.5.1 The EOF Radiation Protection Group is supervised by the Radiation Protection Manager, who reports to the Emergency Manager. The Radiation Protection Group is staffed by personnel with radiation protection backgrounds. They are trained in performing offsite and environmental radiological monitoring surveys and analyses. Responsibilities for the group include:

• Direction and coordination of the utility offsite radiological field monitoring teams;

• Offsite dose projection;

• EOF Count Room activation and operation;

• EOF habitability, personnel monitoring and decontamination;

• Communications with state assessment groups on matters related to dose projections and offsite protective action recommendations;

• Staffing the Health Physics Network (HPN) and communicating with the NRC.

B.7.5.2 EOF Radiation Protection Manager (RPM)

The EOF Radiation Protection Manager directs the activities of the EOF Radiation Protection staff. Specific responsibilities include:

• Recommending changes in PARs based upon effluent releases or dose projections; 26

• Assisting the Emergency Manager in the evaluation of an emergency with respect to the public;

• Notifying the Emergency Manager of protective actions taken by the station for plant personnel;

• Advising the Emergency Manager on the need for emergency exposures or for issuance of KI to the Field Monitoring Teams or utility personnel required to enter the plume;

• Assisting in the completion and review of the State/Tribal/Local notification form;

• Maintaining cognizance of environmental sampling activities;

• Ensuring state authorities are provided information pertaining to utility Field Monitoring Team activities and sample results;

• Acquiring additional instrumentation, dosimetry, protective equipment and radiological support personnel;

• Upon request, providing in-plant health physics data to Joint Information Center personnel and the HPN Communicator.

B.7.5.3 EOF Dose Assessor The Dose Assessor reports to the EOF Radiation Protection Manager. Dose Assessment also works with the State Radiological Communicator and the Field Monitoring Team Communicator.

Responsibilities include:

• Interpreting radiological data and providing PARs based upon dose projections to the Radiation Protection Manager;

• Advising the EOF Radiation Protection Manager of changes in event classification based on effluent releases or dose projections;

• Initiating evaluation of the need for administering KI to utility nuclear workers when requested by the EOF Radiation Protection Manager;

• Remaining cognizant of forecast and meteorological data and ensuring the status is updated periodically;

• Notifying the EOF Radiation Protection Manager of meteorological changes that may impact identification of downwind areas.

B.7.5.4 Field Monitoring Team (FMT)

B.7.5.4.1 FMTs are dispatched to evaluate the amount of contamination or ambient radiation present outside the Protected Area. The FMTs report to the EOF Radiation Protection Manager through communication via the Field Monitoring Team Coordinator.

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B.7.5.4.2 The purpose of a FMT doing offsite monitoring is to determine the speed, direction and activity of any radiological plume. They will also take samples, as appropriate, of soil, vegetation, snow, and water to help determine the release deposition.

B.7.6 EOF General Staff The EOF General Staff consists of the EOF Coordinator, emergency communicators, administrative and logistics personnel.

B.7.6.1 EOF Coordinator The EOF Coordinator reports to the Emergency Manager. The EOF Coordinator is responsible for activation and operation of the EOF and assists the Emergency Manager with administrative duties.

Reporting to the EOF Coordinator are:

• The Administrative Staff, which is responsible for emergency document control, recording and document distribution at the EOF, and coordinating shift relief and staffing;

• Emergency Communicators, which include the Offsite Communicator, ERF Communicator, and the State/Tribal/County Liaison Communicator;

• A Procurement Specialist, who provides general logistics support and assists the EOF Coordinator; B.7.7 EOF Security Group The EOF Security Group is staffed by personnel from Site Security.

B.7.7.1 EOF Security Manager The EOF Security Manager reports to the Emergency Manager.

Responsibilities for this position include EOF access security, and additional security, if needed, for access control at a Backup EOF or JIC.

B.7.8 Joint Information Center (JIC)

The State of Minnesota operates the JIC utilized by the Monticello and Prairie Island nuclear power plants.

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The Executive Spokesperson is the individual representing NMC at the JIC. The JIC Manager reports to the Executive Spokesperson and supervises the activities of the technical and communications advisors, technical communicator and an administrative staff. JIC Manager Responsibilities include:

• Providing the Emergency Manager with an overview of the public and media impacts resulting from plant and governmental activities;

• Advising the Executive Spokesperson regarding information to be released to the public;

• Maintaining cognizance of conditions of the plant and environment, and the actions of NMC and governmental support personnel;

• Coordinating with the state to review and access media coverage of the emergency event.

B.8 Contractor and Private Organizations B.8.1 Vendors and Construction organizations B.8.1.1 Major equipment providers or Architect-Engineers include:

Westinghouse Electric Corporation, General Electric Corporation, and Bechtel Power Corporation, which can provide the following assistance in an emergency:

• Trained personnel;

• Technical analysis;

• Operational analysis;

• Accident and transient analysis.

B.8.2 Other Utilities B.8.2.1 Other nuclear power plant organizations may provide personnel and equipment. Prior written agreements frequently exist in these situations.

• Monticello and Prairie Island provide mutual support;

• Assistance from any nuclear power plant may be requested through an existing INPO link.

B.8.3 Other Organizations 29

B.8.3.1 Environmental, Inc., Midwest Laboratories can provide assistance in environmental monitoring and sampling.

B.8.3.2 National Weather Service (NWS) provides up to date meteorological information to the individual nuclear power plants.

B.8.3.3 Canadian Pacific Railway may divert or stop traffic on its lines during an emergency, when requested to do so.

B.8.3.4 Burlington Northern Santa Fe Railway; may divert or stop traffic on its lines during an emergency, when requested to do so.

B.8.3.5 U.S. Army Corps of Engineers may close off Lock and Dams, or divert traffic on the Mississippi River during an emergency.

B.8.3.6 Local Organizations Other local organizations are detailed in the site-specific Annexes.

B.8.4 Letters of Agreement (LOAs)

The respective nuclear power plants have obtained LOAs with private contractors and others who provide emergency support services. LOAs, as a minimum, state that the cooperating organization will provide their normal services in support of an emergency at the affected plant. Letters of Agreement are referenced in the site-specific plant Annexes and the actual letters are maintained on file for each plant.

B.9 Local Emergency Support Organizations B.9.1 Local Law Enforcement Agencies Local law enforcement agencies may be called upon to lend assistance during the response to emergencies at any of the NMC operated nuclear power plants. Details on the services offered may be found in each NMC plants site-specific Annexes.

B.9.2 Ambulance Services B.9.2.1 Agreements with ambulance services are in place to transport injured personnel from the plants to the designated medical facility. Training is provided for the transport of contaminated 30

personnel, and qualified utility personnel may accompany the ambulance. Details on the services offered may be found in each NMC plants site-specific Annexes.

B.9.3 Medical B.9.3.1 Prior arrangements have been made for medical treatment at a variety of facilities. All of NMC operated nuclear power plants are supported, and each site offers training to the medical staff in dealing with contaminated injured personnel. Details on the services offered may be found in each NMC plants site-specific Annexes.

B.9.4 Fire Fighting B.9.4.1 To supplement the Fire Brigade onsite, agreements are made with local fire departments. Details on the services offered may be found in each NMC plants site-specific Annexes.

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Table B-1, Minimum Shift Staffing for Emergencies Onshift MAJOR POSITION TITLE SINGLE UNIT DUAL UNIT FUNCTIONAL AREA Shift Manager 1 1 Plant Operations and Control Room/Shift Supervisor 1 2 Assessment of Reactor Operators 3 3 Operational Aspects Non-licensed Operators 41, 2 41 Shift Technical Advisor 1 1 Notification/

Communicator 1 1 Communications Radiological Accident RP/Chemistry Technician (dose 11, 2 11 Assessment and assessment and surveys)

Support of Operational Chemistry Technician 1 1 Accident Assessment ONSHIFT TOTAL 13 14 Notes:

1 Non-licensed Operators are trained to provide their own radiological coverage, satisfying the requirement for additional RP Technicians.

2 If Union negotiations do not allow NLOs to provide their own RP coverage, Monticello on-shift RPs will be increased to 3 and NLOs will decrease to 3.

Augmentation MAJOR FUNCTIONAL POSITION TITLE ONSHIFT AVAILABLE AVAILABLE AREA 75 MINUTES 90 MINUTES Emergency Direction and Emergency Director/Emergency Onshift (SM) 1 1 Control Manager Nuclear Engineer Onshift (STA) 1 Electrical Engineer 1 Plant System Engineering / Mechanical Engineer 1 Radwaste Operator 1 Repair and Corrective Actions Mechanical Maintenance 1 1 Electrical Maintenance 1 1 Protective Actions I&C Technician 1 RP Technicians Onshift 2 2 OSC Group Leads 4 Communications Communicator Onshift 3 2 Health Physics (Dose Assessment and Radiological protection Onshift 3 4 surveys)

Fire Suppression Plant Personnel Onshift Local Support Rescue Operations and First Plant Personnel Onshift Local Support Aid Plant Personnel Site Access Control and All per All per (Security/Communications/Personnel Personnel Accountability Security Plan Security Plan Accountability)

AUGMENTED TOTAL 19 12 32

Figure B.1.a: Control Room 2 Unit 1

I I

I I

I I

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I Non-Licensed Operators

Figure B.1.b: Control Room 1 Unit Non-Licensed Operators

Figure B.1.c: TSC Organization Emergency Director Offsite Assistant ED I Communicator TSC Coordinator I

TSC Rad Operations Engineering Security Protection Manager Manager Manager Administration Manager Logistics Plant Security Operations Assistant 1fi Communicator Communicator ERF Communicator OSC Manager I I

Mechanical Engineering

I I

II I

Manager (TSC)

L-----------

1 n Figure B.1.d: OSC Organization operations l OSC Manager CR / TSC ERF Communicator Communicator Operations Group Lead 1 RPIChemistry Group Lead Control Engineering Support Chain Mechanical Electrical / I&C Group Lead Group Lead E lMechanics I Electricians I I I I Instrument Techs I

I

Figure B.1.e: EOF Organization Emergency Assistant Emergency iD/l Coordinator EOF RP Manager Coordinator Manager Communicator Communicator Assessment Communicator Writer Procurement Specialist L

Communicator I

Communicator Field Monitoring 4~~ Communicator Communicator Field Monitoring Teams

Figure B.1.f: JIC Organization Executive Spokesperson Manager I

I I Technical Communications Advisor Advisor EOF Tech Administration Communicator Assistants

SECTION C: EMERGENCY RESPONSE SUPPORT AND RESOURCES Once an emergency has been declared, the Emergency Director (ED) or Emergency Manager (EM) has the authority and responsibility to request aid from offsite organizations, whether they are other NMC operated nuclear power plants, federal, state, tribal, local, or private organizations.

C.1 Federal Assistance C.1.1 Federal agencies that may provide assistance in direct support of NMC in the event of an accident are identified in Section A of this plan. If needed, federal resources are expected to be made available to NMC.

C.2 State Interfaces C.2.1 Designated NMC personnel are procedurally assigned to the state or county Emergency Operations Centers (EOCs) and provide liaison with state, tribal and local governmental officials.

Positions have been assigned in the Emergency Operations Facility (EOF) for liaisons with state, tribal and county response personnel.

C.3 Radiological Laboratories C.3.1 Onsite Laboratory The onsite laboratory/counting room at each NMC operated nuclear power plant is the primary facility for radiation monitoring and analysis effort. The onsite laboratory is the central point for receipt and analysis of onsite samples and includes equipment for chemical and radiological analyses. The plant laboratories have the capability of quantitative analysis of marine and air samples, and qualitative analysis of terrestrial samples.

Additional facilities for counting and analyzing samples are available at the other NMC operated nuclear plants or state and federal laboratory services. These laboratories can act as backup facilities in the event that the affected nuclear power plant's counting room and laboratory become unusable or the capacity or capability of the plants laboratory is exceeded.

C.3.2 Contract Laboratories 39

Additional outside analytical assistance may be requested from contracted vendors. Environmental, Inc., Midwest Laboratories provides bioassay analysis and radiochemical analysis services.

C.4 Assistance Agreements C.4.1 Nuclear Industry The nuclear industry provides a reservoir of personnel with a wide range of technical expertise and knowledge. A nuclear industry national inventory of personnel who may be called upon to supplement company personnel has been developed through the Institute of Nuclear Power Operations (INPO). In addition, a number of utilities have entered into an INPO coordinated Voluntary Assistance Agreement program. This provides a mechanism to draw upon industry resources during an emergency.

Support may also be requested from neighboring utilities for the following:

• Personnel and equipment to assist with in-plant and emergency field monitoring;

• Engineering, design, and technical expertise to assist in determining the cause of the accident and to support recovery;

• Personnel and equipment to assist in maintenance and repairs to the facility.

C.4.2 Offsite resources NMC supports the sharing of personnel and resources among NMC operated nuclear power plants, providing a large personnel and equipment base to draw upon. As an example, one plants counting room and portable radiation detection equipment would be made available for analysis of samples from an affected plant, and that equipment could be transferred by personnel sent to augment the affected plant.

C.4.2.1 Letters of Agreement (LOAs)

LOAs and other written agreements that describe the level of assistance and resources provided to NMC by external sources are included in the site-specific Annexes.

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C.4.2.2 American Nuclear Insurers (ANI)

ANI provides insurance to cover NMC legal liability up to the limits imposed by the Price-Anderson Act, for bodily injury and/or property damage caused by the nuclear energy hazard resulting from an accident at a nuclear power plant.

C.4.2.3 Civil/Structural Engineers Each plant has an Architect-Engineer that could be called upon to provide engineering expertise in dealing with a nuclear power plant accident.

C.4.2.4 Nuclear Steam Supply System Vendor Under established contracts, the following will supply available engineering expertise, specialized equipment and other services identified as needed and deemed appropriate to provide in an emergency situation:

• General Electric (GE) Nuclear Energy

• Westinghouse Electric Company C.4.2.5 Supplemental Emergency Assistance to the ERO Each NMC operated nuclear power plant maintains agreements with outside support agencies that do not take part in the organizational control of the emergency, but provide assistance when called on during an emergency or during the recovery phase.

These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information. These support agencies provide services of:

• Law enforcement;

• Fire protection;

• Ambulance services;

• Medical and hospital support.

C.4.2.6 Local and Civic Groups In many cases, local groups provide for emergency communications and other services, such as transportation and 41

medical assistance. References to these groups are contained in the site-specific Annexes.

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SECTION D: EMERGENCY CLASSIFICATION SYSTEM D.1 Classification of Emergencies D.1.1 Basis Documents The emergency classifications utilized at each NMC operated nuclear power plant are based on the four emergency classes described in 10CFR50 Appendix E, NEI 99-01, Methodology for Development of Emergency Action Levels, January 2003, endorsed by NRC Regulatory Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors, and NRC Bulletin 2005-02.

These classifications were established by the Nuclear Regulatory Commission (NRC), for grouping off-normal nuclear power plant conditions according to (1) their relative radiological seriousness, and (2) the time sensitive onsite and offsite radiological emergency preparedness actions necessary to respond to such conditions. The existing radiological emergency classes, in ascending order of seriousness, are:

• Unusual Event (UE);

• Alert;

• Site Area Emergency (SAE);

• General Emergency (GE).

The classes determine initial steps to be taken by onsite and corporate emergency response personnel. The emergency classes are used by offsite authorities to determine which of the preplanned actions are to be taken by their emergency organizations.

An emergency classification is indicative of the status of the plant.

Inputs to the emergency classification system include the status of various plant systems, radiation levels in and around plant areas, and the rate of release of radioactivity from the plant. These Initiating Conditions (ICs) are a predetermined subset of nuclear power plant conditions where either the potential exists for a radiological emergency, or such an emergency has occurred.

The Initiating Conditions lead each plant to a Classification Implementing Procedure that contains the specific Threshold Values (TVs) for each Initiating Condition. When an Initiating Condition is 43

observed and the criteria of its associated Threshold Values are met, an Emergency Action Level (EAL) is met and the event is then classified, and a declaration made at the appropriate level.

For dual unit plants, Initiating Conditions and Threshold Values are considered separately for each unit. If both units meet an Emergency Action Level, then both are classified. Notifications are made for the unit with the higher level.

When conditions present themselves that are not explicitly provided for in the EAL scheme, the Emergency Director (ED) has discretion to declare an event based on knowledge of the emergency classes and judgment of the situation or condition.

D.1.2 Unusual Event Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

D.1.3 Alert Events are in progress or have occurred, which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of intentional malicious dedicated efforts of a hostile act. Any releases of radioactive material during an Alert classification are expected to be limited to small fractions of the U.S. Environmental Protection Agency (EPA) Protective Action Guideline (PAG) exposure levels.

D.1.4 Site Area Emergency Events are in progress or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or security events that result in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of, or (2) prevents effective access to equipment needed for the protection of the public. Any releases are not expected to exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

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D.1.5 General Emergency Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential loss of containment integrity or security events that result in an actual loss of physical control of the facility. Releases can reasonably be expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

D.2 Initiating Conditions D.2.1 The Classification Emergency Plan Implementing Procedure is used to classify the emergency condition upon recognition of an off-normal condition relative to an Initiating Condition. Two Initiating Condition Matrices are used depending on the initial mode of the unit. A Hot Initiating Condition matrix is used when the unit is in the Technical Specification defined modes of Hot Shutdown, Hot Standby (Pressurized Water Reactors), Startup or Power Operation. A Cold Initiating Condition matrix is used when the unit is in the Cold Shutdown or Refueling modes.

To facilitate the expeditious classification of emergencies, the various initiating conditions that may result in an emergency class are grouped into six recognition categories as follows:

• Radiological (Hot and Cold - R series);

• Fission Product Barriers (Hot - F series);

• System Malfunctions (Hot - S series);

• System Malfunctions (Cold - C series);

• Independent Spent Fuel Storage Installation (Hot and Cold - E series);

• Hazards (Hot and Cold - H series).

Within each category, subcategories and specific Initiating Conditions are identified. Each NMC plant-specific Annex provides the specific Initiating Conditions associated with that specific plant.

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SECTION E: NOTIFICATION METHODS AND PROCEDURES E.1 Notification Methodology E.1.1 NMC, in cooperation with state, tribal, and county authorities, has established methods and procedures for notification of offsite response organizations consistent with the emergency classification and emergency action level scheme. These notifications include a means of verification or authentication. The methods used for authentication are developed and mutually agreed to by the utility and off-site authorities. The primary notification method will be by telephone.

NMC has proceduralized a fifteen-minute goal for notifying state, tribal and county authorities of any declared emergency at an NMC operated nuclear power plant. The methods and forms used for notifying state, tribal, and county authorities are site-specific, and detailed in the individual plant Annexes.

NRC will be notified, via telephone call to the Headquarters Operations Officer, as soon as possible following state, tribal and local notifications, but within an hour of an emergency classification.

When both units of a dual unit plant are affected by an emergency, the classification shall be reported as applicable to both units. In situations where both units of a dual unit plant are affected by emergency events, but the events are not related and the classification for each unit is different, notification will be made for the highest classification. In situations when one unit is affected by unrelated events, notification will be made for the highest classification.

An accelerated call to the NRC Headquarters Operations Officer will be made following discovery of an imminent threat or attack against a plant. During a plant transient or an imminent threat situation requiring physical security response, plant personnel are primarily responsible for stabilizing the plant and keeping it safe.

An accelerated call will not interfere with plant or personnel safety or physical security response.

The accelerated call will be made after or concurrent with notification of local law enforcement agencies. The goal will be to initiate the call within 15 minutes of discovery of an imminent 46

threat or attack against a plant. The information provided in the accelerated call will be limited to the following:

• Site name;

• Emergency classification if determined prior to the accelerated call;

• Nature of the threat and the attack status.

E.2 Notification E.2.1 Onsite Plant Personnel: When an emergency is declared, reclassified, or terminated, an announcement will be made that includes the emergency classification and response actions to be taken by site personnel.

E.2.2 Onsite and Offsite Plant Personnel: At an Alert classification or higher, Emergency Response Organization augmentation personnel will be notified for activation of a plants Technical Support Center, Operations Support Center, Emergency Operations Facility, Joint Information Center, and NMC State and County Liaisons, using an Autodialer system described in the plant Annexes.

E.2.3 Offsite Authorities: Notifications will be promptly made to offsite emergency response personnel as follows:

State/Tribal/Local Agencies: A notification shall be made within fifteen (15) minutes of:

• The initial emergency classification;

• Classification change;

• The issuance of, or change to, a Protective Action Recommendation (PAR);

• Changes in radiological release status, occurring outside of an event classification or PAR notification, based on agreements with the state(s).

E.2.4 The NRC is notified over a telephone system, the Emergency Notification System (ENS). If the ENS is inoperative, the required notification will be made via commercial telephone service, or any other method that will ensure that a report is made as soon as practical. The computerized data link to the NRC, the Emergency 47

Response Data System (ERDS), will be initiated within one hour of the declaration of an Alert classification or higher.

Specific information on the notifications to the NRC for emergency events is detailed in the reporting requirements of 10 CFR 50.72.

E.3 Initial Notification Message E.3.1 In conjunction with state, tribal and county authorities, NMC operated plants have established the contents of the initial and subsequent state notification message forms to be utilized during an emergency. The contents of the message form include, as a minimum:

• Designation as drill or actual event;

• Transmittal date and time;

• Identity of site;

• Event classification;

• Emergency Action Level (EAL) number; and/or Non-technical event description;

• Date and time of declaration;

• Release status;

• Wind direction and speed;

• Protective Action Recommendations (PAR).

E.4 Follow-up Messages E.4.1 For all emergency classifications, update messages to state/tribal/local authorities will be provided on a prearranged schedule. The facility with offsite notification responsibilities is responsible for ensuring that the updates are completed as scheduled. State updates contain the prearranged information plus any additional information requested at the time of the notification.

Follow-up notifications are provided to the NRC as soon as possible, but not later than one hour after significant new information is available involving:

• The results of evaluations or assessments of plant conditions;

• The effectiveness of response or protective measures taken;

• Information related to plant behavior that is not understood.

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If requested by the NRC, an open, continuous communications channel will be maintained with the NRC Operations Center over the Emergency Notification System (ENS) and/or Health Physics Network (HPN) Circuits. When an open line is maintained on the HPN or ENS circuits, follow-up notification will be made as soon as confirmed information is known.

E.5 State/Tribe/local Public Notification E.5.1 Each NMC operated nuclear power plant has installed a siren system, for notification of the public within the 10-mile Emergency Planning Zone by local authorities. Siren capability, maintenance, and locations are detailed in the site-specific Annexes. The primary purpose of the siren system is to alert the public to listen to emergency broadcasts.

E.6 Public Warning E.6.1 Information as to state, tribal, and local procedures for informing the public of a nuclear plant emergency, including sirens, radio stations and the Emergency Alert System is in the appropriate state, tribe and local emergency plans.

E.7 Public Protective Action Messages E.7.1 State, tribal and local authorities have developed procedures and messages to be provided to the public in the event of an emergency at an NMC operated nuclear power plant. Details as to these procedures and messages are in the appropriate state, tribal and local emergency plans.

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SECTION F: EMERGENCY COMMUNICATIONS F.1 Communications F.1.1 At each NMC operated nuclear power plant several modes of reliable communication are available, during both normal and emergency conditions, to transmit and receive information within the plant and at locations onsite and offsite. These include in-plant intercom systems, public address systems, commercial and dedicated telephone systems, facsimile devices, computer modem communications via the Internet, mobile and fixed radios, microwave and fiber optic systems, and both company-issued and private cellular telephones. Reliable primary and backup means of communication have been established, as further detailed in the site-specific Annexes.

The use of the above communications systems during normal and emergency conditions has been integrated into plans, procedures, and the training program.

F.1.2 NMC operated plants maintain the capability to make initial notifications to the designated offsite agencies 24-hours per day. Offsite notifications can be made to state, tribal and county warning points and Emergency Operations Centers from the Control Room, Technical Support Center, and Emergency Operations Facility. Backup methods include alternate commercial telephone lines, facsimile, radios, and cell phones. State, tribal, and county warning points are continuously staffed.

F.1.3 Provisions exist for continuous communications with state/tribal/local governments within the Emergency Planning Zones, as detailed above.

F.1.4 NMC has established communications systems to provide reliable communications with federal emergency response organizations.

Communications with federal agencies is primarily by commercial telephone, with alternate systems being utilized as needed. Telephone systems are installed for communication with the Nuclear Regulatory Commission (NRC).

F.1.4.1 NRC Emergency Notification System (ENS)

This communications line provides a dialup communications link to the NRC Operations Center in Rockville, MD and is used for continuous communications in a classified emergency. ENS phones are located in the Control Room, TSC, and EOF.

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F.1.4.2 NRC Health Physics Network (HPN)

This communications line provides a dialup communications link with the NRC to provide radiological information. HPN phones are located in the TSC and EOF.

F.1.4.3 NRC Reactor Safety Counterpart Link (RSCL)

This communications line provides a dialup communications link for the NRC to conduct internal NRC discussions on plant equipment conditions separate from the licensee. RSCL phones are located in the TSC and EOF.

F.1.4.4 Protective Measures Counterpart Link (PMCL)

This communications line provides a dialup communications link for the NRC to conduct internal NRC discussions on radiological releases, meteorological conditions, and the need for protective actions. PMCL phones are located in the TSC and EOF.

F.1.4.5 Management Counterpart Link (MCL)

This communications line provides a dialup communications link for any NRC internal discussions between the NRC Executive Team Director or Executive Team members and the NRC response team leader or top-level licensee management at the site. MCL phones are located in the TSC and EOF.

F.1.4.6 Local Area Network (LAN) Access This communications line provides the NRC site team with access to the NRC Operations Center's LAN. LAN connections are provided in the TSC and EOF.

F.1.5 NMC operated nuclear power plants have reliable communications between the plants and their Emergency Operations Facility (EOF), state and local emergency operations center, and radiological monitoring teams, as detailed above.

F.1.6 NMC operated nuclear power plants utilize an automated ERO Notification System to rapidly notify members of the ERO. The system consists of a computer with modem equipment capable of initiating and receiving telephone calls. One of the calls made by the system is to the 51

paging system vendor. The system is designed with redundant power, phone and computer components with geographic separation.

F.2 Medical Emergency Communications F.2.1 Communications are established with the primary or backup medical hospitals and transportation services via commercial telephone.

Communication will be between the NMC operated nuclear power plant and the primary or backup hospital, which will be in communication with the ambulance service via radio.

F.3 Communications Tests F.3.1 Communications with federal, state, tribal and local governments within the plume exposure pathway Emergency Planning Zone (EPZ) are tested periodically.

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SECTION G: PUBLIC EDUCATION AND INFORMATION G.1 Resident Information G.1.1 NMC operated nuclear power plants, in coordination with state, tribal, county and local officials, annually provide the general public with information concerning the methods of public notification and what individual actions should be taken during a nuclear power plant emergency. This information includes:

• Methods of public notification;

• A description of what to do if a take-shelter or evacuate recommendation is given;

• General information as to the nature and effects of radiation;

• Information regarding Potassium Iodide (KI);

• Contact points for additional information;

• Possible protective actions and map of major evacuation routes;

• Special needs for the handicapped;

• Registration cards for the mobility impaired;

• A list of communities likely to serve as host shelter areas.

Methods for disseminating the information may include calendars, brochures, annual publications, public postings and meetings.

Dissemination of information to the public is coordinated with state, tribal and local agencies, and is detailed in the site-specific Annexes.

G.2 Transient Information G.2.1 Information will be provided to any transient populations, at appropriate locations where a transient population may obtain a copy, as detailed in the site-specific Annexes.

G.3 Joint Information Centers G.3.1 Each NMC operated nuclear power plant uses a designated Joint Information Center (JIC). These facilities function as Emergency News Centers, and are used by the media in an emergency as detailed in the site-specific Annexes.

G.4 Executive Spokesperson 53

Each NMC operated nuclear power plant has designated an Executive Spokesperson whose responsibilities will be to attend media briefings to address public concerns. This individual will be the designated NMC Executive Spokesperson in attendance for media conferences.

The Executive Spokesperson will also be responsible for liaison and communication between the plant emergency response organization and other corporate departments affected by the emergency or whose services are required to respond to media inquiries. The Executive Spokesperson will ensure that there is a timely exchange of information among spokespersons for the responding agencies. The Executive Spokesperson has direct access to necessary information.

There are coordinated arrangements for dealing with rumors. Rumors or misinformation are identified during an emergency by media/rumor control monitors at the JIC. They monitor media reports and respond to public and news media calls to ensure that rumors and misinformation on any emergency are quickly corrected.

G.4.1 Press Briefings Periodic press briefings will be held at the JIC. Federal, state, tribal, county, and utility personnel staff the facility to assure timely, periodic exchange and coordination of information. Representatives of these organizations coordinate information prior to conducting news briefings.

G.5 Media Training Local news media personnel will be provided periodic opportunities to become more familiar with information pertaining to radiological emergency planning, nuclear power generation, radiation, and points of contact for release of public information in an emergency.

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SECTION H: EMERGENCY FACILITIES AND EQUIPMENT H.1 Onsite Emergency Response Facilities Each NMC operated nuclear power plant has established a Technical Support Center (TSC) and an onsite Operations Support Center (OSC), which are activated upon declaration of an Alert or higher classification. Until they become operational, required functions of these facilities are performed in the Control Room.

H.1.1 Control Room The Control Room is the centralized onsite location from which the plants reactors and major plant systems are operated. The Control Room is equipped with instrumentation to supply detailed information on the reactors and major plant systems. The Control Room is continuously staffed with qualified, licensed operators, and is the first onsite facility to respond to emergency events. Control Room personnel must evaluate and effect control over any emergency and cope with an emergency until support centers can be activated. As other Emergency Response Facilities (ERFs) become activated, they will support the Control Room, and overall Command and Control of the emergency will transfer to the TSC or the EOF. Control Room activities include:

• Reactor and plant control;

• Initial direction of all plant related operations;

• Accident recognition, classification, mitigation and initial corrective actions;

• Alerting of onsite personnel;

• Notification of appropriate individuals;

• Activation of emergency response facilities and ERO notification;

• Notification of offsite agencies;

• Notification and update of the NRC via Emergency Notification System (ENS);

• Continuous evaluation of the magnitude and potential consequences of any incident;

• Initial dose projections;

• Recommendations for immediate protective actions for the public;

• Activation of the Emergency Response Data System (ERDS).

H.1.2 Technical Support Center 55

Each NMC operated nuclear power plant has established a TSC for use during emergency situations by plant management, technical, and engineering support personnel. The TSC is procedurally required to be activated for all emergencies classified as Alert or higher and Security related Unusual Event classifications. Activation for other Unusual Events or unclassified incidents is optional. When activated, TSC functions include:

• Support for the Control Room's emergency response efforts;

• Performance of response management functions when in Command &

Control;

• Continued evaluation of event classification;

• Assessment of the plant status and potential offsite impact;

• Coordination of emergency response actions;

• Notification of appropriate corporate and plant management;

• Notification and update of the NRC via the Emergency Notification System (ENS).

The TSC is the onsite location utilized to support the Control Room for assessment of plant status and for implementation of emergency actions.

TSC personnel provide technical data and information to the EOF. Each TSC provides reliable voice and facsimile communications to the Control Room, the OSC, the EOF, the NRC, and state Emergency Operations Centers.

Each TSC is sized to accommodate a minimum of 25 individuals and supporting equipment. This includes provisions for five NRC representatives. State, tribal and county personnel are not expected to report to the TSC. Personnel in the TSC are protected from radiological hazards, including direct radiation and airborne contaminants under accident conditions, with similar radiological habitability standards as Control Room personnel.

To ensure adequate radiological protection, radiation monitoring equipment has been installed in the TSC, or periodic radiation surveys are conducted.

These systems indicate radiation dose rates and airborne radioactivity inside the TSC while in use. In addition, potassium iodide (KI) is available for use.

The TSC has access to a controlled set of drawings and other records, including general arrangement diagrams, piping and instrumentation diagrams (P&IDs), and electrical schematics. The TSC has the capability to record and display vital plant data, in real time, to be used by knowledgeable individuals responsible for engineering and management 56

support of reactor operations, and for implementation of emergency procedures.

H.1.3 Operations Support Center (OSC)

Each NMC operated nuclear power plant has established an OSC, an onsite location where plant support personnel report during an emergency and from which they are dispatched on assignments in support of emergency operations. Details as to OSC locations are in the plant Annexes.

H.1.4 Emergency Operations Facility The EOF is where the Emergency Manager will direct a staff in evaluating and coordinating the overall plant activities involved with an emergency.

Activation of the EOF is mandatory upon declaration of an Alert or higher classification. The EOF provides for:

• Management of overall emergency response;

• Coordination of radiological and environmental assessments;

• Protective Action Recommendations;

• Management of recovery operations;

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

A Backup EOF has been designated for each NMC operated nuclear power plant. Details are found in the applicable plant-specific Annexes. This facility is designed with the following considerations:

• The location provides functional and availability characteristics for carrying out the overall strategic actions of NMC onsite and support operations, determination of public protective actions to be recommended to offsite officials, and coordination with federal, state, tribal, and local organizations;

• Engineered for the design life of the plant and of sufficient size to accommodate approximately 50 people;

• Equipped with reliable communications capabilities to the TSC, the Control Room, NRC, and state, tribal and local Emergency Operations Centers;

• Provided with equipment to gather, store, and display data needed in the EOF to analyze and exchange information on plant conditions. The EOF technical data system receives, stores, processes, and displays information sufficient to perform assessments of the actual and potential onsite and offsite environmental consequences of an emergency; 57

• The Backup EOF has access to plant records, procedures, and emergency plans needed for effective overall management of NMC emergency response resources.

H.2 State, Tribal and local Emergency Operations Centers EOCs operated by the state, tribe and local communities allow direction and control of emergency response functions. The states EOCs are capable of continuous (24-hour) operations for a protracted period. These centers contain sufficient communications equipment, maps, emergency plans, and status boards to provide the necessary interfaces with federal, state, tribal, county, and NMC emergency facilities.

The tribal EOC serves as Command and Control headquarters for local Indian emergency response activities as well as a center for the coordination of communications to the state, tribal and county EOCs. Additional details for the tribal EOC is found in the tribal emergency plan.

The county EOCs serve as Command and Control headquarters for local emergency response activities as well as a center for the coordination of communications to field units and to the state EOCs. Additional details for state and county EOCs are found in the state, tribal and county emergency plans.

H.3 Emergency Response Facility Staffing and Activation NUREG-0654 Criterion II.B.5 states that the licensee must be able to augment onshift capabilities within a short period after declaration of an emergency.

Augmentation times are not rigid requirements, but rather goals. It is NMCs intent to expend its best efforts to meet any planned augmentation goals for staffing Emergency Response Facilities with appropriately qualified individuals capable of handling an emergency. Due to the diversity of residential patterns for each plant, possible adverse weather conditions and/or road congestion, planned augmentation time frames might be exceeded.

Each NMC operated nuclear power plant has plans and procedures to ensure timely activation of its emergency response facilities. The Shift Manager, as Emergency Director, will initiate a call-out in accordance with the implementing procedures.

The ERO augmentation process identifies individuals who are capable of fulfilling the specific response functions listed in Table B-1. This table was developed based on the functions listed in NUREG-0654, Table B-1. Although the response time will vary due to factors such as weather and traffic conditions, a goal of 75 and 90 minutes for minimum staffing, following the declaration of an Alert or higher emergency classification, has been established for ERO personnel responding to plant emergency facilities.

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The TSC and OSC are expected to be operational within 75 minutes, and the EOF within 90 minutes. These facilities can be declared activated when the following conditions are met:

• Minimum staffing has been achieved;

• Personnel have been briefed on the situation;

• The facility is capable of performing the required functions.

Additionally, plans have been developed to ensure timely functional activation and staffing of the JIC within two hours, when the classification of Alert or higher is declared. Public Information personnel must first coordinate the decision to activate the JIC with offsite authorities. The JIC Manager may elect to coordinate activation of the facility without meeting minimum staffing if it has been determined that sufficient personnel are available to fully respond to the specific event.

H.4 Onsite Monitoring Each NMC operated nuclear power plant has installed monitoring instrumentation for seismic monitoring, radiation monitoring, fire protection and meteorological monitoring, in accordance with its Updated Final Safety Analysis Report (UFSAR) or Updated Safety Analysis Report (USAR) and plant Technical Specifications (TS), or commitments made to the NRC. Details as to these systems vary from plant to plant, and are found in the plant Annexes.

H.4.1 Geophysical Monitors

• Meteorological Instrumentation: A permanent meteorological monitoring station is located near each plant for the acquisition and recording of wind speed, wind direction, ambient and differential temperatures for use in making offsite dose projections. Meteorological information is displayed in the CR, TSC, and EOF by means of the plant computer system.

• Seismic Monitoring: The seismic monitoring system measures and records the acceleration of the structure if activated by an earthquake of sufficient magnitude. It also provides signals for immediate remote indication that specific preset response accelerations have been exceeded.

• Hydrological Monitors: NMC operated nuclear power plants have hydrological monitors as appropriate. The design basis flood, probable maximum precipitation, and other extremes in hydrologic natural phenomena are as detailed in the UFSAR or USAR as appropriate.

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H.4.2 Radiological Monitors and Sampling H.4.2.1 Radiation Monitoring System (RMS)

Radiation monitoring instruments are located at selected areas within each plant to detect, measure, and record radiation levels. In the event the radiation level should increase above a preset level, an alarm is initiated in the Control Room. Radiation monitoring instruments also alarm locally in selected areas of the facility. The RMS provides the necessary activity or radiation level information required for determining source terms in dose projection procedures. Radiation monitoring systems are detailed in each plants applicable UFSAR or USAR . The RMS is divided into three subsystems:

• Area Radiation Monitors (ARMs) are used for the direct measurement of in-plant exposure rates. The ARM readings allow in-plant exposure rate determinations to be made remotely without requiring local hand-held meter surveys. In addition to permanent monitors, portable Continuous Air Monitors (CAMs) measure airborne particulate and airborne iodine activities at various locations within the operating areas.

• Process Radiation Monitors (PRMs) are used for the measurement of radioactive noble gas, iodine, and particulate concentrations in plant effluent and other gaseous and fluid streams.

• The accident, or high range, radiation monitoring system monitors radiation levels at various locations within the operating area. These are high range instruments used to track radiation levels under accident and post accident conditions. These instruments include the Containment/Drywell Radiation Monitors.

H.4.2.2 Liquid and Gaseous Sampling Systems The process sampling system consists of the normal sampling system and additional sampling panels located throughout the plant. Sampling systems are installed or can be modified to permit reactor coolant and containment atmosphere sampling even under severe accident conditions.

It is capable of providing information relative to post-accident plant conditions to allow operator actions to be taken to mitigate and control the course of an accident. Refer to the specific plants Updated Final Safety Analysis Report (UFSAR) or Updated Safety Analysis Report (USAR) for further detail on sampling capabilities.

H.4.2.3 Portable Radiation Monitoring Equipment 60

Portable radiation survey instruments are available for a wide variety of uses such as area, sample, personnel surveys, and continued accident assessment.

H.4.3 Process Monitors The Control Room and redundant backup locations are equipped with extensive plant process monitors for use in both normal and emergency conditions. These indications include reactor coolant system pressure and temperatures, containment pressure and temperature, and various liquid levels, flow rates, status or lineup of equipment components.

H.4.3.1 Plant Monitoring/Information System A plant monitoring/information system provides the data acquisition and database capability for performing plant monitoring and functions. The system is designed to scan, convert to engineering units, make sensor range and alarm limit checks, apply required transformations, store for recall and analysis, and display the reading of transformed data from plant instrumentation. The system scans flows, pressures, temperatures, fluid levels, radiation levels, equipment, and valve status at required frequencies.

H.4.3.2 Safety Parameter Display System (SPDS)

SPDS is a grouping of critical plant parameters from which the safety status of operations may be assessed in the Control Room, TSC and EOF for each nuclear plant. While a specific plants safety parameter system may not be named SPDS, it serves the same function if it displays critical parameters. The primary function of the SPDS is to help operating personnel in the Control Room make quick assessments of plant safety status. SPDS displays in the TSC and EOF promote the exchange of information between these facilities and the Control Room.

H.4.4 Fire Detection System The Fire Detection System is designed to quickly detect products of combustion or heat in designated areas of the plant. The fire alarm communication systems and subsystems are located at strategic points throughout the plant to warn personnel of a fire or other emergency conditions. Refer to the respective plant UFSAR or USAR for further description of a plants fire protection system.

H.5 Offsite Monitoring 61

NMC operated nuclear power plants have made provisions to access data from the following offsite sources of monitoring and analysis equipment:

H.5.1 Geophysical Monitors:

• In the event that the onsite meteorological tower or monitoring instrumentation becomes inoperative, meteorological data may be obtained directly from the National Weather Service or the Internet.

• A number of earthquake monitoring facilities are located in the Midwest. A central point of contact to obtain information about a seismic event is the National Earthquake Information Service in Golden, Colorado.

H.5.2 Radiological Environmental Monitors and Sampling As noted in H.6, below, each NMC operated nuclear power plant has a Radiological Environmental Monitoring Program (REMP) with fixed locations of offsite TLDs and air sampling.

H.5.3 Laboratory Facilities External facilities for counting and analyzing samples can be provided by the other NMC operated plants, state, federal or contracted laboratories.

Outside analytical assistance may be requested from state and federal agencies, or through contracted vendors. The DOE, through the Interagency Radiological Assistance Program (IRAP) has access to any national laboratory.

H.6 Offsite Radiological Monitoring Equipment Each nuclear plant maintains a sufficient supply of portable offsite radiological monitoring equipment. These supplies are located at each staging point for Field Monitoring Teams.

Each NMC operated nuclear power plant has a Radiological Environmental Monitoring Program (REMP) consisting of locations with dose recording devices and air sampling equipment.

H.7 Meteorological Equipment Each NMC operated nuclear power plant has a meteorological tower equipped with instrumentation for continuous reading of the wind speed, wind direction, air 62

temperature and differential air temperature. Meteorological tower details are in the site-specific Annexes. Additional capabilities are available to obtain representative current meteorological information from other sources, such as the National Weather Service or Internet web sites.

H.8 Operations Support Center The OSC provides an area for coordinating and planning of activities and the staging of personnel and equipment. Further space is available to accommodate additional personnel as may be required. Alternate locations are available should the OSC become uninhabitable.

Each nuclear plant maintains a supply of parts and equipment for normal plant maintenance. These parts, supplies and equipment are also available for damage control use as necessary. Sufficient protective clothing, respiratory protection gear, potassium iodide (KI), and other health physics equipment and supplies is stored and maintained near the OSC. The OSC has first aid and medical supplies. When an emergency condition exists at one NMC operated nuclear power plant, additional supplies can be obtained from other unaffected plants and NMC resources upon request.

H.9 Emergency Equipment Inventories and Checks Emergency facilities and equipment are inspected and inventoried using Emergency Plan Maintenance Procedures (EPMPs). These procedures provide information on location and availability of emergency equipment and supplies. An inventory of all emergency equipment and supplies is performed on a quarterly basis and after each use in an emergency or drill.

Sufficient reserves of instruments and equipment are maintained to replace those removed from emergency kits or lockers for calibration or repair. NMC operated nuclear power plants are responsible for maintaining a current supply of KI at their respective site.

H.10 Emergency Kits Emergency kits are available at each NMC operated nuclear power plant.

Emergency Plan Maintenance Procedures (EPMPs) procedures identify the equipment in the various emergency kits. Details as to kit locations are found in the plant-specific Annexes.

H.11 Collection Point for Field Samples 63

Each NMC operated nuclear power plant has designated a point as the location for receipt and analysis of field monitoring team environmental samples. Sampling and analysis equipment is available for quantitative activity determination of marine and air samples, and qualitative activity determination of terrestrial samples.

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SECTION I: ACCIDENT ASSESSMENT I.1 Systems and Parameters Monitored Each NMC operated nuclear power plant has a comprehensive set of plant system and effluent monitors, as required by the plants Updated Final Safety Analysis Report or Updated Safety Analysis Report. Each plant has identified values characteristic of off-normal values and accidents, and identified the plant parameter values which correspond to the example initiating conditions in the Nuclear Energy Institute (NEI) 99-01 Emergency Action Levels (EALs). These are described in Section D of this plan, and detailed in the site-specific Annexes.

Plant system and effluent parameter values are utilized in the determination of accident severity and subsequent emergency classification. Environmental and meteorological events are also determining factors in emergency classification. An emergency condition can be the result of just one parameter or condition change, or the combination of several. The specific symptoms, parameter values or events for each level of emergency classification are detailed in each plants site-specific Annex.

To adequately assess the emergency condition, applicable emergency facilities have the equipment and instrumentation necessary to monitor essential plant information except where local monitoring is required. Evaluation of plant conditions is accomplished by monitoring plant parameters from both the Control Room and within the plant.

Some of the key plant parameters monitored in the Control Room are assembled into a single display, which is generically designated as the "Safety Parameter Display System" (SPDS). The SPDS monitors such parameters as: reactor coolant system pressure, reactor or pressurizer water level, containment pressure, suppression pool water level and temperature, reactor power, safety system status, containment radiation level and effluent monitor readings. The instrumentation and equipment capabilities available for emergency facilities are described in Section H.

I.2 Continuing and Post Accident Assessment The resources available to provide initial and continuing information for accident assessment throughout the course of an event include plant parameter display systems, liquid and gaseous sampling system, Area and Process Radiation Monitoring Systems, and Accident Radiation Monitoring Systems. Descriptions of these systems are given in Section H, with additional details in the plant Annexes.

Details as to how post-accident sampling will be performed are in the plant-specific Annexes.

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I.3 Offsite Dose Assessment Each NMC operated nuclear power plant utilizes a computerized offsite dose assessment program which estimates doses from radiological accidents for comparison with the EPA Protective Action Guidance in EPA 400-R-92-001 and acute health effect thresholds.

The program estimates reactor source term, atmospheric transport, and doses resulting from radiological emergencies and can be used to assist in making protective action decisions. The system supplements assessments based on plant conditions and quick estimates based on hand-calculational methods.

The computerized model was developed to allow consideration of the dominant aspects of source term, transport, dose, and consequences. Because the program is designed to be used during a radiological emergency, it is assumed that the amount of activity being released and the meteorological conditions will not be precisely known.

I.4 Effluent Monitor Readings and Exposures The offsite dose assessment program addresses the relationship between effluent monitor readings, onsite and offsite exposures, and contamination for various meteorological conditions.

I.5 Meteorological Monitoring Each NMC operated nuclear power plant has a meteorological monitoring system sufficient to acquire and evaluate meteorological information for accident assessment. This information can be accessed in the Control Room, TSC, and EOF, and is transmitted by the Emergency Response Data System (ERDS), for NRC and offsite authorities use.

I.6 Unmonitored Release Dose projections can be made during a release through use of sample data in situations where effluent monitors are either off-scale, inoperative, or the release occurs by an unmonitored flow path. In the absence of effluent sample data, a computerized offsite dose projection can be performed by specifying the accident category as a default. The selection of a default accident category defines the mix, the total curies, and the release pathway(s). The total number of curies from a default mix for each isotope is used to provide an upper bound for release concentration, and hence, an upper bound for the dose rate and dose to the public.

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I.7 Environs Surveys and Monitoring In addition to the capabilities and resources described in Section H, NMC operated nuclear power plants have the ability to take offsite air samples and to directly measure gamma dose rates from a radioactive material release. The capability to take offsite soil, water, and vegetation samples is provided by Field Monitoring Teams (FMTs).

The environmental monitoring equipment, as described in Section H, includes portable survey, counting, and air sampling instrumentation and other radiological monitoring equipment and supplies to be used by the FMTs. Samples are taken at predetermined locations as well as those locations specified during and after a release. Environmental measurements are used as an aid in the determination and assessment of protective actions for the general public and recovery actions for the plant.

Field Monitoring Teams are dispatched by NMC operated plants to perform a variety of functions during conditions that may involve significant releases of radioactive materials from a plant. Radiological survey and sample data is used to define affected area boundaries, verify or modify dose projections and protective action recommendations, and assess the actual magnitude, extent, and significance of a liquid or gaseous radioactive material release.

In addition to contamination and dose rate measurements, the FMTs may change out Thermoluminescent Dosimeters (TLDs) or other radiological recording devices, and air sampler cartridges, which are a part of each plants Radiological Environmental Monitoring Program (REMP). Other actions may include soil, water and vegetation sampling.

The initial environmental surveys involve simple-to-perform measurements to quickly confirm or modify the dose projections based on plant parameters.

Subsequent environmental monitoring efforts will be aimed at further defining the offsite consequences, including instituting an expanded monitoring program to enable prompt assessments of any subsequent releases from the plant.

I.8 Release Assessments Each NMC operated nuclear power plant has instrumentation, procedures, and trained personnel with the expertise to make rapid assessments of the actual or potential magnitude and location of any radiological hazards through liquid or gaseous release pathways.

I.9 Environmental Radioiodine Monitoring Capabilities 67

Field monitoring equipment has the capability to detect and measure airborne radioiodine in the presence of noble gases. Interference from the presence of noble gas and background radiation will be minimized by ensuring that monitoring teams move to areas of low background radiation prior to analyzing the sample cartridge. The collected air sample is measured by hand held survey equipment as an initial check of the projection derived from plant data, to determine if significant quantities of radioiodine have actually been released.

I.10 Relationship of Measured Parameters The computerized offsite dose projection program provides the means for relating the various measured parameters to the gross radioactivity measurements. The program also compares estimated doses with the Environmental Protection Agency Protective Action Guide doses.

I.11 Severe Accident Management Guidelines (SAMG)

The nuclear industry has developed Severe Accident Management Guidelines, (SAMG) which provide guidance for actions to take in response to accidents which are beyond the design basis of a nuclear power plant. NMC operated plants have SAMG procedures, and training on SAMG is provided to select individuals.

I.12 Federal and State Resources The states have the capability to dispatch their own field monitoring teams to track the airborne radioactive plume. The states also have the ability and resources to request and coordinate with federal and utility monitoring teams to compare sample results.

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SECTION J: PROTECTIVE RESPONSE Protective response consists of emergency actions, taken during or after an emergency situation, which are intended to minimize or eliminate hazards to the health and safety of the public and plant personnel. A range of protective actions have been developed for emergency workers and the general public located in the Plume Exposure Pathway Emergency Planning Zone. Guidelines that are consistent with federal guidance have been established to aid in choosing protective actions during an emergency. The responsibility for actions outside of the owner-controlled area rests with the state, tribal, county, and other offsite response agencies.

J.1 Alarm Responses The actuation of fire alarms, radiation alarms, plant evacuation alarm, telephone calls, paging system activation, and public address announcements, as applicable, will alert onsite personnel to hazardous conditions and to actions they must take.

These actions may be to:

• Assemble;

• Report to Emergency Response Facilities;

• Evacuate specific areas within the plant;

• Take cover;

• Evacuate the plant.

The site-specific Annexes describe the assembly areas for personnel onsite to protect them from direct radiation, airborne radioactivity, security threat, or toxic/flammable gas hazards.

For all emergency classifications, everyone within the Protected Area is notified of the initial classification or escalation of an emergency by recognizable alarms and/or verbal announcements over the plant Public Address (PA) System.

Announcements include the emergency classification and response actions to be taken by personnel onsite.

Provisions are made to alert personnel in high noise areas and outbuildings within the Protected Area and within the Owner Controlled Area. Each NMC operated nuclear power plant has identified locations where individuals might be present outside the Protected Area but within the Owner Controlled Area.

The primary protective measure for non-essential onsite personnel during a Site Area or General Emergency is evacuation to an assembly area, outside the Protected Area and inside the Owner Controlled Area.

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J.2 Site Evacuation Routes J.2.1 If a Site Evacuation is required, personnel are directed to either assemble within designated Assembly Areas or to immediately evacuate the site.

Personnel will be directed to either proceed to their homes or to reassemble at designated locations. Visitors to the plant will assemble with and follow the instructions of their escorts. Personal transportation will normally be used and established evacuation routes will be followed. Personnel without transportation will be identified and provided transportation as necessary.

J.2.2 Evacuation of personnel is usually conducted immediately after accountability if a Site Area Emergency or General Emergency has been declared and no impediments to evacuation exist. Evacuation shall commence as directed by the Emergency Director, unless one of the following impeding conditions exist:

• Dangerous weather conditions threaten safe transport;

• A significant radiological hazard would be encountered;

• There is a security threat occurring that would have an adverse impact on personnel leaving the site;

• A condition similar to any of the above in magnitude, which in the opinion of the Emergency Director would adversely affect site personnel.

J.3 Radiological Monitoring of Evacuees Personnel evacuating the site will be monitored for contamination, if required, by portal monitors as they exit the Protected Area, or with portable friskers in Assembly Areas, or sent to offsite monitoring locations.

J.4 Non-essential Personnel Evacuation and Decontamination Requirements for radiological monitoring of non-essential personnel evacuated from the site for external radiation exposure are contained in Section J.3. Section K addresses appropriate actions for any known or suspected overexposures or contamination. Details on the decontamination of non-essential evacuees are found in the site-specific Emergency Plan Implementing Procedures.

J.5 Accountability Performing Accountability requires the determination of the locations of all personnel inside the Protected Area and the assembly of emergency personnel at 70

prearranged locations. When Accountability of onsite personnel is determined to be necessary by the Emergency Director, personnel within the Protected Area will be accounted for and the names of missing individuals determined within thirty minutes of the decision to perform Accountability.

Accountability is performed in conjunction with Assembly, and is required to be initiated whenever a Site Area or General Emergency is declared. The movement of personnel for the purposes of Accountability may be delayed if their health and safety could be in jeopardy, such as by dangerous weather or for security concerns.

If it is determined that the prearranged Assembly Area is unfit for personnel, the Emergency Director may designate an alternative Assembly Area and redirect personnel. Once established, Accountability within the Protected Area is maintained throughout the course of an event.

J.6 Onsite Protective Actions Onsite protective actions for routine and emergency conditions are detailed under each plants Radiation Protection Program. NMC operated nuclear power plants maintain an inventory of respiratory protection equipment, anti-contamination clothing, and potassium iodide (KI) that is available to emergency workers remaining onsite. During an emergency, protective actions would be taken to minimize radiological exposures or contamination problems affecting onsite personnel. Measures which would be taken are:

• On-shift and emergency response personnel use respiratory protection in any environment involving exposure to high level airborne activity or oxygen deficient atmosphere, or where air quality is in doubt. The criteria for issuance of respiratory protection are described in plant Radiation Protection procedures.

• Anti-contamination clothing is available for use by onsite personnel. The criteria for issuance of protective clothing are described in plant Radiation Protection procedures.

• The criteria for administering a thyroid-blocking agent (KI - Potassium Iodide) to emergency personnel depends on the projected absorbed dose to the thyroid based on the severity and magnitude of the accident.

NMC operated nuclear power plants are responsible for maintaining a supply of KI at their respective site. The TSC Emergency Director has the responsibility for approval of issuing KI to site emergency workers.

J.7 Offsite Protective Action Recommendations (PARs) 71

Plant conditions, projected dose and dose rates, and field monitoring data are evaluated to develop PARs for preventing or minimizing exposure to the public.

PARs are provided to the offsite agencies responsible for implementing protective actions for the public within the 10-mile EPZ. The Emergency Director or Emergency Manager will approve PARs. In an emergency that requires immediate protective actions be taken prior to activation of the offsite emergency facilities, PARs are provided directly to state, tribal, and county officials. The PAR decision making flowcharts are site-specific in nature, and are provided in the site-specific Annexes.

J.8 Evacuation Time Estimates (ETE)

An independent ETE report has been performed for each NMC operated nuclear power plant, which provides estimates of the time required to evacuate resident and transient populations surrounding each plant for various times of the year under favorable and adverse conditions. ETEs for evacuation of the plume exposure EPZ surrounding each NMC operated nuclear power plant are summarized in each site-specific Annex and detailed in the referenced ETE report.

J.9 State/Tribal/local Protective Measures There are various types of protective actions that can be implemented by the state, tribe, and counties. They include the following:

• Sheltering;

• Evacuation;

• Controlling food, milk, and water distribution;

• Thyroid blocking agent.

J.10 Protective Action Maps Each NMC nuclear power plant has maps depicting local roads, primary evacuation travel routes, the Emergency Planning Zone (EPZ), and the locations of congregate care locations and facilities. Maps are also available which show the population distribution within the plant EPZ, and are described in the site-specific Annexes.

All EPZ Maps are generated, updated and maintained by the State of Minnesota.

J.11 State Protective Measures State protective measures are described in detail in the Minnesota and Wisconsin emergency plans.

J.12 State/local Relocation Centers 72

State/local Relocation Centers are described in detail in the Minnesota and Wisconsin emergency plans.

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SECTION K: RADIOLOGICAL EXPOSURE CONTROL K.1 Emergency Workers and Lifesaving Protective Actions NMC operated nuclear power plant management will make every reasonable effort to minimize radiation exposure to emergency personnel. Plant management approval is required before emergency workers are allowed to exceed the maximum administrative radiation dose.

Under normal operating conditions, all NMC operated plants maintain personnel exposure control programs in accordance with 10 CFR 20. The TSC Emergency Director has the responsibility for authorizing personnel exposure levels under emergency conditions using the guidance in Environmental Protection Agency (EPA) 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents. In emergency situations, workers may receive exposure under a variety of circumstances in order to assure safety and protection of others and of valuable property.

If emergency operations demand life-saving or rescue actions and external radiation fields are minimal, individuals may be allowed exposures to airborne contamination of 10,000 Derived Air Concentration (DAC)-hours. If external radiation fields are not minimal, the sum of the external and internal doses should be limited to 25 rem Total Effective Dose Equivalent (TEDE). Exposures above 2,000 DAC-hours should be received only with the approval of the TSC Emergency Director. These exposures will be justified if the reduced risks and costs to others outweigh the risks to which the workers are subjected.

Emergency Worker Dose Limits: Table K-1 Dose Applicability Conditions (TEDE) 5 rem All --

10 rem Protecting valuable property (or Lower dose not practicable equipment) 25 rem Lifesaving or protection of large Lower dose not practicable populations

>25 rem Lifesaving or protection of large Only on a voluntary basis to populations persons fully aware of the risks involved 74

K.1.1 Removal of injured persons Injured persons will receive prompt first aid and decontamination, as practical, before transport by ambulance to a local hospital.

K.1.1.1 Transportation Services Agreements have been made with ambulance services at each of the NMC operated nuclear power plants. Training is given to ambulance personnel, and they participate in drills or exercises simulating the transportation of a contaminated, injured individual.

K.1.2 Decontamination and First Aid K.1.2.1 Onsite Responsive Action Selected plant workers at each NMC operated plant have received first aid and decontamination training. If a plant employee cannot be easily decontaminated, the individual is treated as contaminated and measures are taken to prevent the spread of contamination during ambulance transportation and upon arrival at a local hospital.

K.1.3 Medical Treatment Agreements have been made with local hospitals near NMC operated nuclear power plants. Training is given to medical staffs regarding the treatment of contaminated, injured individuals, and hospitals participate in periodic drills using simulated contaminated, injured individuals.

K.2 Emergency Exposure Authorization Each NMC operated plant has a Radiation Protection Program. The TSC Emergency Director may authorize emergency workers to receive doses in excess of the administrative dose levels. In some situations, it is possible that certain activities or duties for the protection of persons or the substantial protection of property may result in doses in excess of 10 CFR 20.1201 limits. Decisions to accept doses in excess of occupational limits will be on a volunteer basis and prospective volunteers shall be made aware of the risks.

K.3 Exposure Controls K.3.1 24-Hour Capabilities 75

Each plant Radiological Protection Group has the equipment and personnel to provide 24-hour capability to determine and control radiation exposures of emergency organization personnel. The equipment consists of the following:

• Portable radiation detection instruments;

• Electronic dosimeters or High and low range dosimeters;

• Thermoluminescent Dosimeters (TLDs);

• Record keeping equipment.

Contractor and vendor representatives may also be present to assist in exposure control and augment the Radiation Protection Group capabilities. In an emergency situation, all onsite personnel, some offsite support personnel and some local governmental emergency response personnel will be issued TLDs and/or self-reading pocket dosimeters, or electronic dosimeters. Exposure records will be maintained for all emergency response personnel issued dosimetry.

K.3.2 Personnel Monitoring Equipment Each NMC operated nuclear power plant has equipment for radiological monitoring of personnel, ranging from hand-held survey equipment to installed or portable portal monitors. Details of plant monitoring equipment are included in the site-specific Annexes.

K.4 Offsite Emergency Workers The responsibility for authorizing state and local agency emergency workers to receive exposures in excess of the EPA General Public Protective Action Guides rests with the state and county organizations.

K.5 Decontamination The radiation protection group is responsible for controlling or minimizing direct or subsequent internal exposure from radioactive materials deposited on the ground or other surfaces, and for determining the extent of contamination in controlled and normally uncontrolled areas. During normal conditions or an emergency, guidelines to follow for contamination limits are established by the site radiation protection program.

Facilities and supplies for decontaminating personnel are available at various plant locations. All personnel leaving the Radiologically Controlled Area (RCA) or leaving a contaminated area will be monitored for contamination. During 76

emergencies, other onsite personnel will be checked for contamination as necessary.

Designated personnel, under the direction of the radiation protection group, will perform material decontamination. Procedures and equipment for material decontamination are available at each plant, as specified in the site radiation protection program.

K.6 Contamination Controls Contaminated areas are isolated as restricted areas with appropriate radiological protection and access control. Measures will be taken to control onsite access to potentially contaminated potable water and food supplies.

K.7 Offsite Decontamination Near-site Emergency Operations Facilities (EOFs) have a decontamination shower with associated liquid retention system. Equipment for small decontaminations is also available along with personnel monitoring equipment.

Nonessential onsite personnel may be evacuated to an offsite relocation center or assembly area, as discussed in Section J. Radiological controls personnel at that location monitor evacuees and determine the need for decontamination. In the event that decontamination of evacuees locally is not possible, personnel will be sent to designated locations for monitoring and decontamination. Provisions for extra clothing are made and suitable decontaminates are available for the expected type of contaminations, particularly with regard to skin contamination.

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SECTION L: MEDICAL AND PUBLIC HEALTH SUPPORT L.1 Hospital and Medical Services Each NMC operated nuclear power plant has arranged for hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.

The hospitals are appropriately equipped and hospital personnel trained to address contaminated injured individuals. Specifically, training of medical support personnel at the agreement hospitals will include basic training on the nature of radiological emergencies, diagnosis and treatment, and follow-up medical care.

Plant personnel are available to assist medical personnel with decontamination, radiation exposure and contamination control. Arrangements, by letter of agreement or contract, are maintained by NMC operated plants with a qualified hospital located in the vicinity of each nuclear power plant for receiving and treating contaminated persons with injuries requiring immediate hospital care.

If necessary, NMC will make available medical consultants who will provide direction of the special care necessary for the treatment of persons having radiation injuries.

L.2 First Aid Each NMC operated nuclear power plant maintains onsite first aid supplies and equipment necessary for the treatment of contaminated and/or injured persons.

Stretcher baskets, first-aid, trauma and burn kits are at various locations throughout the plants. The first-aid treatment of injured personnel shall be administered by trained personnel.

L.3 State Emergency Medical Services The states of Minnesota and Wisconsin have developed lists of facilities that can provide medical support for treating injured, contaminated individuals. Details are found in the respective state emergency plan.

L.4 Medical Transport Contaminated and injured persons are transported to a facility specified for each NMC operated nuclear power plant. Arrangements have been made by each nuclear power plant for prompt ambulance transport of persons with injuries 78

involving radioactivity to designated hospitals. Such services are available on a 24-hour per day basis and are confirmed by letters of agreement. Radiation monitoring services shall be provided by NMC plant personnel whenever it becomes necessary to use an ambulance service for the transportation of contaminated persons.

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SECTION M: RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS M.1 Recovery Guidelines that will be employed for determining the transition from Emergency to Recovery Organization are explained in the plant Emergency Plan Implementing Procedures. The composition of the Recovery Organization will depend upon the nature of the accident and the conditions following the accident.

NMC Nuclear Emergency Plan (NEP) addresses general principles that will serve as guides for developing a Recovery Plan.

The Recovery Organization will be established as directed by the Recovery Manager. It is the responsibility of the Emergency Director (ED) to declare that the facility is safe for reentry.

The following conditions will be met before the Recovery and reentry phase can begin:

• The affected plant is in a controlled and stable condition;

• Releases of radioactive material are controlled and within NRC authorized limits;

• Radiation levels are stable or decreasing in plant areas;

• NRC concurs that Recovery may begin.

Other recovery operations will not be initiated until the area affected by the emergency has been defined. Particular attention will be directed toward isolating and tagging out components and systems as required for controlling or minimizing hazards. A systematic investigation will be conducted to determine the equipment damaged and the extent of the damage.

A detailed investigation of the accident causes and consequences, both to the plant and to the environment, will be conducted. Test programs to confirm fitness for return to service will be developed and executed.

Recovery operations will be conducted in compliance with normal operational radiation exposure level limits as specified in 10 CFR 20. When possible, any necessary releases of radioactive materials or effluent during recovery will be planned, controlled, evaluated in advance for radiological impact, and appropriate offsite organizations and agencies informed of the scheduled releases and estimated impact.

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M.2 Recovery Organization Figure M-2, Long Term Recovery Organization Administration Manager Logistics Planning and Logistics Engineering Operations Radiation Maintenance Protection M.2.1 Recovery Manager The nature and extent of the emergency situation will determine what recovery operations are required. The Recovery Organization, shown above, will be established as directed by the Recovery Manager.

M.2.2 Plant Actions All recovery actions will be preplanned. Each specific action will be thought out in advance and discussed with responsible and knowledgeable personnel.

Every reasonable effort will be made to limit radiation exposure of personnel involved in the recovery to levels as low as reasonably achievable. Exposures should not exceed 10 CFR 20 limits. The Recovery Manager is responsible for evaluating the advisability and timing of authorizing personnel to reenter affected area(s).

The Recovery Manager is responsible gathering all available evidence on contributory factors to the accident, and reviewing the recovery operations to ensure that causal factors have been specifically identified. The Recovery Manager will provide a liaison for the NRC Accident Investigation Team, which will interview primary responders, review any documents generated during the accident, and inspect or test damaged equipment prior to its repair.

M.3 Recovery Notification Members of the ERO will be informed when Recovery is initiated. The recovery organizational structure may be much the same as the emergency response organization with additional modifications depending upon the nature of the accident, post-accident conditions, and other factors to be determined.

The State EOC will be advised when the plant deems it safe to begin the reentry phase of the offsite recovery operation. If the governor has ordered an evacuation, it is legally required for the governor to officially rescind the order prior to return to evacuated areas. The states are responsible for coordinating reentry procedures for the offsite population.

M.4 Population Exposure Estimates It is anticipated that the Federal Radiological Monitoring and Assessment Center (FRMAC) will make a total population exposure calculation, based on estimated dose rates and population representing exposed areas.

M.5 Termination of Recovery Phase Recovery operations may be terminated when appropriate actions have been completed, and the recovery organization, under the direction of the Site Vice President and Recovery Manager, offsite authorities, and NRC agree it is appropriate to terminate.

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SECTION N: EXERCISES AND DRILLS N.1 Exercises NMC operated nuclear power plants will conduct a biennial exercise and additional periodic drills. A drill in this context is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular operation. It is often a component of an exercise, which is an event that tests the integrated capability, and a major portion of the basic elements existing within emergency preparedness plans and organizations. Each drill or exercise is conducted:

• To ensure that the participants are familiar with their duties and responsibilities;

• To verify the adequacy of and methods used in Emergency Plan Implementing Procedures (EPIPs) and other emergency procedures;

• To verify the availability and operability of emergency supplies and equipment.

Drill performance is also measured as one of the NRC Performance Indicators, a portion of the NRC Reactor Oversight Program (ROP).

NMC operated nuclear power plants conduct an emergency response exercise to demonstrate the effectiveness of the NEP on a frequency determined by the NRC.

Exercises may include mobilization of state, tribal, and local personnel and resources, and are intended to verify their capability to respond to an accident.

Joint exercises shall be conducted on a frequency described in NRC/FEMA guidance.

NMC operated plants will invite qualified observers from federal, state, tribal and local governments to observe and critique the exercises. A critique shall be conducted following the exercise to evaluate the ability of organizations to respond as required in their Emergency Plans.

The scenarios for drills and exercises will be varied such that the major elements of the Nuclear Emergency Plan and response organizations are tested within a six-year period.

N.1.1 Biennial Exercises Federally prescribed Biennial exercises are conducted at each NMC operated nuclear power plant Exercises involving offsite agency participation, required under 10 CFR 50 Appendix E, are conducted at each NMC operated nuclear plant based on U.S. Department of Homeland Security [DHS], Federal Emergency Management Agency (FEMA) 83

guidance and the respective state, tribal, and local emergency response plans.

Partial participation means offsite authorities take part in the exercise sufficient to test direction and control functions, including protective action decision making and communication capabilities among affected state, tribal, and local authorities and NMC operated plants. Where partial or full participation by offsite agencies occurs, the sequence of events simulates an emergency that results in the release of radioactivity to the offsite environs, sufficient in magnitude to warrant a response by offsite authorities.

Full participation exercises will include, as appropriate, offsite tribal, local and state authorities and NMC personnel actively participating in testing the integrated capability to assess and respond to an accident at a nuclear power plant. Additionally, full participation exercises will include, as appropriate, testing the major observable portions of the onsite and offsite emergency plans and mobilization of state, tribal, local, and NMC personnel and other resources in sufficient numbers to verify the capability to respond to the accident scenario.

N.1.2 Participation Each NMC operated nuclear power plant will exercise with offsite authorities such that state(s), tribal and local governments, within the plume exposure pathway EPZ, exercise the state and local government emergency plans for each operating nuclear power plant biennially, with full or partial participation.

At a minimum, state, tribal, and local governments are expected to fully participate in at least one offsite exercise every 2 years. In the case of the States of Minnesota and Wisconsin, which have more than one nuclear plant site, they rotate this full participation among the sites and partially participate at the others.

At a minimum, each state, within an ingestion exposure pathway EPZ, is expected to exercise its plans and preparedness related to ingestion exposure pathway measures at least once every 6 years. NMC operated plants will enable any state, tribe or local government located within the plume exposure pathway EPZ to participate in Annual Drills and Biennial Exercises when requested by that state, tribal, or local government.

Drills and exercises will be varied from year to year so as to test major components of the plans and preparedness organizations, which may include federal emergency response agencies, within a six year period.

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Once every six years, provisions should be made to start a drill between 6:00 p.m. and 6:00 a.m. This will be considered an off-hours drill.

N.1.3 Off-Year Drills An Off-Year Drill is conducted at each NMC operated nuclear power plant during the calendar year when an NRC Evaluated Exercise is not scheduled.

An Off-Year Drill shall involve at least two facilities, in order to demonstrate at least two of the following functions:

• Management and coordination of emergency response;

• Accident assessment;

• Protective action decision-making;

• Plant system repair and corrective actions.

For an Off-Year Drill involving no or limited participation by offsite agencies, emphasis is placed on conducting a drill that is operationally realistic. Participants will be able, by implementing appropriate procedures and corrective actions, to affect the outcome of the scenario to a greater extent than when core damage and the release of radioactivity are prerequisites for the demonstration of objectives.

N.2 Drills and Tests N.2.1 Communications Tests Communications tests will be conducted on the frequency specified below.

Each of these tests includes provisions to ensure that participants in the test are able to understand the content of the messages utilized in the drill or test.

• Communications with state, tribal and local governments within the plume exposure pathway will be tested monthly;

• Communications with federal response organizations and state governments within the exposure pathway will be tested quarterly;

• Communications between NMC operated nuclear power plants, state Emergency Operating Centers and all local Emergency Operations Centers, and radiation monitoring teams will be tested annually;

• Communication from the Control Room, TSC and EOF to the NRC Operations Center will be tested monthly;

• The Emergency Response Data System (ERDS) will be tested on a quarterly basis; 85

• The fixed siren portion of Public Alert and Notification System (PANS) will be tested and verified in accordance with existing FEMA approvals.

N.2.2 Fire Drills Fire drills will be conducted at each nuclear plant in accordance with Plant procedures.

N.2.3 Medical Emergency Drills A medical emergency drill, involving a simulated contaminated individual, and containing provisions for participation by local support services organizations are conducted annually at each nuclear plant. Local support service organizations, which support more than one plant, shall only be required to participate once each calendar year.

N.2.4 Radiological Monitoring Drills Plant environs and radiological monitoring drills are conducted annually.

These drills include collection and analysis of sample media and provisions for communications and record keeping. These drills also evaluate the response to, and analysis of, simulated airborne and direct radiation measurements in the environment.

N.2.5 Health Physics Drills Health Physics Drills involving a response to, and analysis of, simulated airborne and liquid samples and direct radiation measurements are conducted semi-annually. At least annually, these drills shall include a demonstration of the sampling system capabilities, as applicable.

N.2.6 Augmentation Drills Augmentation drills serve to demonstrate the capability of the process to augment the on-shift staff by staffing the TSC, OSC and EOF in a short period after declaration of an emergency. These drills are conducted using the following guidelines:

• Semi-annually, each plant will initiate an unannounced off-hours ERO augmentation drill where no actual travel is required; 86

• At least once per drill cycle (every 6 years), an off-hours unannounced activation of the ERO Notification System with actual response to the emergency facilities will be conducted by each plant.

N.2.7 Accountability Drills Accountability drills are conducted annually. The drill includes identifying the locations of individuals within the protected area.

N.3 Scenarios When a major drill or exercise is required, the Emergency Preparedness (EP) group will coordinate the preparation of a scenario. The EP group will also coordinate efforts with appropriate federal, state, tribal and local emergency organizations and agencies, schedule a date to conduct the drill or exercise, and assign qualified controllers.

The Emergency Preparedness group retains critique results for review prior to future drills or exercise and for guidance in properly modifying the site-specific Annexes, Emergency Plan Implementing Procedures (EPIPs), or other procedures as appropriate.

A scenario, prepared in advance, will govern the conduct of each exercise and drill.

Scenarios will include the following:

• Objectives of the drill or exercise; a measurable and observable objective must be specified for each major problem and solution;

• Dates, time period, places, personnel, and participating organizations;

• Simulated events;

• Time schedule of real and simulated initiating events;

• Narrative summary describing the conduct of the exercise or drill, including simulated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing and associated equipment, deployment of personnel and radiological teams, and public information activities.

N.4 Exercise Evaluation and Critique A critique shall be scheduled at the conclusion of the exercise, to evaluate each organization's ability to respond as called for in the Nuclear Emergency Plan.

Qualified personnel will observe and perform a critique of exercises and drills.

Provisions will be made for federal, state, tribal, and local observers, as well as NMC personnel, to observe and critique required exercises.

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Biennially, representatives from the NRC observe and evaluate the licensees ability to conduct an adequate self-critical critique. For partial and full offsite participation exercises, the NRC and DHS, Federal Emergency Management Agency (FEMA), will observe, evaluate, and critique.

Drill and exercise performance objectives will be evaluated against measurable demonstration criteria. As soon as possible following the conclusion of each drill or exercise, a critique is conducted to evaluate the ability of the Emergency Response Organization (ERO) to implement the emergency plan and procedures and a formal evaluation will result from the critique.

A formal written critique report is prepared by the Emergency Preparedness group following a drill or exercise involving the evaluation of designated objectives or following the final simulator set with ERO participation. The report will evaluate the ability of the ERO to respond to a simulated emergency situation. The report will also contain corrective actions and recommendations.

N.5 Exercise/Drill Corrective Actions The critique and evaluation process is used to identify areas of the Emergency Preparedness Program that require improvement. The Emergency Preparedness group is responsible for evaluation of recommendations and comments, to determine which items will be incorporated into the program or require corrective actions, and for the scheduling, tracking, and evaluation of item resolution.

Whenever exercises or drills indicate deficiencies in the NEP, site-specific Annexes, corresponding implementing procedures, or training lesson plans, such documents will be revised as necessary.

The results of exercise critiques, particularly comments on identified areas which require improvement or reevaluation, will be submitted to the plant Emergency Planning Manager, or designee, for review. The Emergency Planning Manager, or designee, will consult with responsible department heads and assign corrective action activities, as appropriate.

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SECTION O: RADIOLOGICAL EMERGENCY RESPONSE TRAINING O.1 Training To achieve and maintain an acceptable level of emergency preparedness, training will be conducted for members of the Emergency Response Organization (ERO) and those offsite organizations who may be called upon to provide assistance in the event of an emergency.

The ERO Training Program assures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency. Specific emergency response task training, prepared for each response position, is described in lesson plans and study guides. The lesson plans, study guides, and written tests are contained in the ERO Training Program. Responsibilities for implementing the training program are contained in plant procedures. Offsite training is provided to support organizations that may be called upon to provide assistance in the event of an emergency.

Personnel from each nuclear power plant shall annually offer to train those non-NMC organizations referenced in the Plant Annexes that may provide specialized services during a nuclear plant emergency. The training offered will acquaint the participants with the special problems potentially encountered during a nuclear plant emergency, notification procedures, and their expected roles. Those organizations that must enter the site shall also receive site-specific emergency response training and be instructed as to the identity of those persons in the onsite organization who will control their support activities.

Training of state, tribal and local offsite emergency response organizations is described in their respective radiological emergency plans, with support provided by NMC if requested.

O.1.1 Training of Local Services Groups A training opportunity will be offered annually for offsite organizations and agencies as specified in respective agreements and understandings. In addition, those offsite organizations and agencies that may provide onsite emergency assistance will be encouraged to become familiar with the general layout of NMC plants, and will be invited to attend applicable Emergency Plan training and orientation courses.

Annually, a training opportunity will be offered for hospital personnel, ambulance/rescue personnel, police, and fire departments. The training shall include the procedures for notification, basic radiation protection, and their organizations expected role.

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O.2 Performance Demonstration In addition to general and specialized classroom training, members of the NMC ERO receive periodic performance based emergency response training.

Performance based training is generally provided via participation in a performance drill or exercise.

A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular operation. Drills described in Section N of this plan are a part of training. These drills allow each individual to demonstrate the ability to perform their assigned emergency functions. During drills, on-the-spot correction of erroneous performance may be made and a demonstration of the proper performance offered by the Controller.

O.3 First Aid Training (triennial)

Individuals assigned to search and rescue teams shall maintain qualifications to meet the requirements of the supporting agency providing first aid and Cardio-pulmonary Resuscitation (CPR) training.

O.4 ERO Training NMC ERO personnel who are responsible for implementing this plan receive specialized training. The training program for emergency response personnel is developed based on the requirements of 10 CFR 50, Appendix E and position specific responsibilities.

On-Shift emergency response personnel perform emergency response activities as an extension of their normal duties and are trained annually as part of their duty specific training.

Requalification training for onsite ERO members consists of an annual review of the Emergency Plan in the form of a general overview, and/or participation in a drill or exercise in their assigned position or a similar one. In addition to Nuclear Emergency Plan overview training, personnel assigned key onsite emergency response positions will receive training specific to their position.

O.4.1 Key Emergency Response Organization Key ERO members will receive Emergency Plan training on an annual basis. Personnel identified receive training appropriate to their position in the areas of:

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• Accident assessment;

• Accident mitigation;

• Notifications;

• Emergency Classifications;

• Protective Action Recommendations;

• Emergency Action Levels;

• Emergency Exposure Control.

O.4.2 Active Senior Licensed Control Room Personnel Active Senior Licensed Control Room Personnel shall have training such that proficiency is maintained on the topics listed below. These subjects shall be covered, as a minimum, on an annual basis:

• Event Classification;

• Protective Action Recommendations;

• Radioactive Release Rate Determination;

• Offsite dose assessment;

• Notification form completion and communication;

• Federal, state, tribal, and local notification procedures as appropriate;

• Activating the onsite and offsite ERO.

O.4.3 Radiological Field Monitoring Teams Radiological Field Monitoring Team personnel will receive classroom and hands-on training in the actions they will be expected to perform during an emergency. The following general topics will be included in the training:

• Equipment and Equipment Checks;

• Communications;

• Plume Tracking Techniques;

• Personnel monitoring;

• Emergency exposure criteria;

• Locations and use of radiological emergency equipment.

O.4.4 Fire Brigade Training Individuals assigned to Fire Brigade shall maintain fire brigade qualifications as required by the Fire Protection Plan.

O.4.5 Operations, Maintenance and Radiation Protection Training 91

Operations, Maintenance and Radiation Protection personnel who would be assigned to Repair and Damage Control Teams are trained as part of their normal job specific duties to respond to both normal and abnormal plant operations.

O.4.6 First Aid Training (triennial)

First Aid and Rescue Team members receive training as outlined in Section O.3.

O.4.7 Training of Local Services Groups Local support service personnel providing assistance during an emergency are invited to receive training as outlined in Section O.1.1.

O.4.8 Medical Support Onsite medical personnel receive specialized training in the handling of contaminated victims and hospital interface. Offsite ambulance and hospital personnel are offered annual training as outlined in Section O.1.1.

O.4.9 Training of the Corporate Emergency Organization NMC Corporate office personnel assigned specific duties associated with the NEP will receive initial and annual continuing training specific to the response role they are assigned.

O.4.10 Communications Personnel ERO personnel receive training on applicable communications protocols as a part of their initial training. Personnel using specialized communications equipment that is not part of their normal daily function receive initial and annual requalification training on the equipment.

O.4.11 Emergency Communications Staff Training Personnel involved in notifications to offsite agencies receive specialized training in the notification process.

O.4.12 News Media Training 92

Local news media personnel will be offered an annual training opportunity as described in Section G.

O.5 Initial and Annual Retraining NMC personnel assigned to an Emergency Response Organization (ERO) position either at the Corporate Office or at one of the managed nuclear power plants will receive initial and annual retraining appropriate to their assigned position as outlined in Section O.4.

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SECTION P: RESPONSIBILITIES FOR EMERGENCY PREPAREDNESS PLANNING P.1 EP Staff Training NMC shall provide training for those individuals responsible for radiological emergency planning. The Emergency Preparedness staff is involved in maintaining an adequate knowledge of state of the art planning techniques and the latest applications of emergency equipment and supplies. The Emergency Preparedness Staff at each NMC operated nuclear power plant will maintain familiarity with emergency preparedness equipment and procedures on an annual basis by attending seminars, workshops, and training. At least once each calendar year each member of the Emergency Preparedness staff will be involved in one or more of the following activities:

• Training courses specific or related to emergency preparedness;

• Observation of or participation in drills and/or exercises;

• Participation in industry review and evaluation programs;

• Participation in regional or national emergency preparedness seminars, committees, workshops or forums;

• Specific training courses in related areas, such as systems, equipment, operations, radiological protection, or Problem Identification & Resolution (PI&R).

P.2 EP Responsibilities The Site Vice President at each NMC operated plant has the overall responsibility for radiological emergency response planning, including the development and updating of emergency plans and coordination of these plans with other organizations, corporate policy and plans, the Updated Final Safety Analysis Report or Updated Safety Analysis Report, and the agreements and understanding with federal, state, tribal, and local organizations. The Site Vice President may designate personnel to assist in meeting this responsibility.

P.3 Emergency Preparedness Manager The Emergency Preparedness Manager at each NMC operated nuclear power plant is responsible for the overall emergency planning efforts and verifying that regulatory emergency preparedness requirements are maintained. The Emergency Preparedness Manager will receive appropriate guidance from the Site Vice President. The Emergency Preparedness Manager may designate other personnel to assist in meeting this responsibility.

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P.4 Emergency Plan Review The NMC Nuclear Emergency Plan (NEP), its Annexes, and supporting Agreements are reviewed on an annual basis. Based on established agreements, this may also include a review by applicable state, tribal, and local emergency response agencies. The annual NEP review/update includes required changes identified during audits, assessments, training, drills, and exercises.

The NMC EP Manager is responsible for determining which recommended changes should be incorporated into the NEP or site-specific Annexes. A letter to file will document the annual review certifying the NEP as current. In those years when the review does not warrant a revision, a letter to that effect will be issued. The NEP and its Annexes shall be revised as needed and the most current approved revisions shall remain in effect so long as they are certified as current.

At each NMC operated nuclear power plant, the Emergency Plan and EPIPs will be reviewed on an annual basis and updated as necessary. Updates will take into account needed changes identified by drills and exercises. Management controls will be implemented for evaluation and correction of review findings.

P.5 Emergency Plan Changes NMC operated nuclear power plants maintain the site-specific Annex to the NEP.

The Site-specific Annexes are maintained up to date by each NMC operated nuclear power plant using established plant procedures.

Emergency Plan Implementing Procedures (EPIPs) are written to implement the commitments contained in the Emergency Plan and site-specific Annexes.

Emergency Plan Maintenance Procedures (EPMPs) are procedures for facility and equipment maintenance. Emergency Plan Administration Procedures (EPAPs) contain provisions for ERO training, guidance for Emergency Plan drills and exercises, Emergency Preparedness Program review, and regulatory compliance processes. Approved changes to the Emergency Plan, site specific Annexes, EPIPs, EPAPs and EPMPs are forwarded to organizations and individuals responsible for their implementation. Revised procedures are dated and pages marked to show where changes have been made.

On a controlled basis, each NMC operated nuclear power plant distributes the Nuclear Emergency Plan, plant Annexes, and implementing procedures. All controlled document holders, including emergency facilities, are issued revision changes upon approval. Selected federal, tribal, state, local agencies and other appropriate locations requiring them are also issued copies. Procedures are in place to control the revision of the NEP and site-specific Annexes.

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P.6 Supporting Plans Other plans that support this NEP are:

• National Response Plan;

• State of Wisconsin Peacetime Radiological Emergency Response Plan;

• State of Minnesota Emergency Operations Plan;

• County and Tribal Emergency Plans;

• INPO Emergency Resources Manual;

• Nuclear Plant Security Plans - Note: withheld from public disclosure under the provisions of 10 CFR 2.790(d).

P.7 Implementing Procedures Site-specific Annexes contain a listing, by number and title, of those procedures that implement this plan during an emergency.

P.8 Emergency Plan Contents The NEP is formatted with a similar numbering system as NUREG-0654, FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in support of Nuclear Power Plants."

The use of this format lends itself to uncomplicated comparison with the criteria set forth in NUREG-0654, FEMA-REP-1.

P.9 Independent Review To meet the requirements of 10 CFR 50.54(t), NMC Nuclear Oversight shall coordinate an independent review the NMC Nuclear Emergency Preparedness Program to evaluate conformance with 10 CFR 50.47, 10 CFR 50.54, and 10 CFR 50 Appendix E. These reviews will be conducted at each NMC operated nuclear power plant.

Results of this audit will be submitted for review to NMC Corporate Management and the Site Vice President. The Emergency Preparedness Manager will ensure that any findings that deal with offsite interfaces are reviewed with the appropriate agencies. Written notification will be provided to the state, tribe and counties of the performance of the audit and the availability of the audit records for review at NMC facilities. Records of the audit will be maintained for at least five years.

P.10 Emergency Telephone Number Updates 96

Each NMC operated nuclear power plant will perform a quarterly review of its emergency telephone list. Emergency telephone lists will be distributed in accordance with plant document distribution procedures.

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ENCLOSURE 3 NUCLEAR MANAGEMENT COMPANY, LCC NUCLEAR EMERGENCY PLAN ANNEX PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 (39 Pages Follow)

Nuclear Management Company Nuclear Emergency Plan Annex Prairie Island Nuclear Generating Plant

Table of Contents Section 1: Introduction........................................................................................................ 5 1.1 Facility Description............................................................................................. 5 1.2 Emergency Planning Zones (NEP J.10).............................................................. 5 1.2.1 Plume Exposure Pathway (NEP J.10)......................................................... 5 1.2.2 Ingestion Pathway (NEP J) ......................................................................... 6 1.3 State of Minnesota (NEP A.2.1) ......................................................................... 6 1.3.1 Minnesota Department of Public Safety (DPS) (NEP A.2.1.1).................. 6 1.3.2 Minnesota Department of Health (NEP A.2.1.2)........................................ 6 1.3.3 Minnesota State Patrol (NEP A.2.1) ........................................................... 6 1.3.4 Minnesota Department of Transportation (NEP A.2.1).............................. 7 1.3.5 Minnesota Department of Public Safety (DPS) (NEP A.2.1.1).................. 7 1.4 Prairie Island Indian Community (NEP A.2.4)................................................... 7 1.5 State of Wisconsin (NEP A.2.2) ......................................................................... 7 1.5.1 Wisconsin Emergency Management (NEP A.2.2.1) .................................. 7 1.5.2 Wisconsin Department of Health & Family Services (NEP A.2.2.2)......... 8 1.6 Local Organizations (NEP A.2).......................................................................... 8 1.7 24-Hour Staffing (NEP F.1.2)............................................................................. 9 Section 2: Organizational Control of Emergencies (NEP B.1)......................................... 10 2.1 Normal Plant Organization (NEP B.1) ............................................................. 10 2.2 Emergency Organization (NEP B.1.6).............................................................. 10 2.3 Non-NMC Support Groups (NEP B.9, B.6.1.2) ............................................... 10 2.3.1 Fire Fighting (NEP B.9.4.1)...................................................................... 10 2.3.2 Hospital and Medical Support (NEP B.9.3.1, L.1) ................................... 11 2.3.3 Ambulance Service (NEP B.9.2.1, L.4).................................................... 11 2.3.4 Westinghouse Support (NEP B.8.1.1, C.4.2.4)......................................... 11 2.3.5 Canadian Pacific Railway (NEP B.8.3.4) ................................................. 12 2.3.6 Burlington Northern, Santa Fe Railroad (NEP B.8.3.4) ........................... 12 2.3.7 U.S. Army Corps of Engineers, Lock & Dam #3 (NEP B.8.3) ................ 12 2.3.8 Public Emergency Planning & Education (NEP G.1.1, G.2.1)................. 12 2.3.9 Media Information (NEP G.3.1) ............................................................... 13 Section 3: Classification of Emergencies (NEP D.1) ....................................................... 14 3.1 Emergency Classifications (NEP D.1).............................................................. 14 3.2 Determination of Levels (NEP D.2) ................................................................. 14 Section 4: Emergency Measures (NEP E) ........................................................................ 15 4.1 Notification of the Emergency Organization (NEP E.2) .................................. 15 4.1.1 Activation of Plant and EOF Organizations (NEP E.2.1)......................... 15 4.1.2 Notification Scheme (NEP E.2.1)............................................................. 15 4.2 Assessment Actions (NEP I.2).......................................................................... 16 4.2.1 Determining Magnitude of Release (NEP I.2).......................................... 16 4.2.2 Dose Projections (NEP I.2, I.3) ................................................................ 16 4.2.3 Radiological Surveys (NEP I.7)................................................................ 17 2 of 39

4.3 Protective Actions for the Offsite Public (NEP J.7) ......................................... 18 4.3.1 Protective Action Recommendations (NEP J.7)....................................... 18 Protective Action Recommendations Flowchart 1 of 2 ....................................... 19 Protective Action Recommendations Flowchart 2 of 2 ....................................... 20 4.3.2 Notification of Offsite Agencies (NEP E.2.3) .......................................... 21 4.3.3 Public Alert and Notification System (PANS) (NEP E.6)........................ 21 4.3.4 Emergency Alert System Radios (NEP E.6)............................................. 21 4.4 Protective Actions for Onsite Personnel (NEP J.6) .......................................... 22 4.4.1 Onsite Respiratory Protection and Protective Clothing (NEP J.6) ........... 22 4.4.2 Potassium Iodide (NEP J.6) ...................................................................... 23 Section 5: Emergency Facilities and Equipment (NEP H) ............................................... 24 5.1 Emergency Response Facilities (NEP H.1) ...................................................... 24 5.1.1 Control Room (NEP H.1.1) ...................................................................... 24 5.1.2 Technical Support Center (TSC) (NEP H.1.2) ......................................... 24 5.1.3 Operations Support Center (OSC) (NEP H.1.3, H.9) ............................... 24 5.1.4 Emergency Operations Facility (EOF) (NEP H.2) ................................... 24 5.1.5 Back-up EOF (NEP H.2) .......................................................................... 25 5.1.6 Joint Information Center (JIC) (NEP B.7.8)............................................. 26 5.2 Onsite Communications (NEP F.1.1) ............................................................... 26 5.3 Offsite Communications (NEP F.1.1)............................................................... 26 5.4 Kits (NEP H.10)................................................................................................ 27 5.5 Facilities and Equipment for On-site Monitoring (NEP H.4)........................... 28 5.5.1. Geophysical Monitors (NEP H.4.1).......................................................... 28 5.5.2 Radiation Monitoring Equipment (NEP H.4.2) ........................................ 29 5.5.3 Process Monitors (NEP H.4.3).................................................................. 29 5.5.4 Fire Detection (NEP H.4.4) ...................................................................... 29 5.5.5 Post Accident Liquid Sampling (NEP H.4.2.2) ........................................ 29 5.5.6 Containment Air Sampling (NEP H.4.2.2) ............................................... 30 5.5.7 Shield Building Vent Sample (NEP H.4) ................................................. 30 5.5.8 Containment High Range Area Monitors (NEP H.4) ............................... 30 5.5.9 In-Plant Iodine Determination (NEP H.4) ................................................ 30 5.5.10 Steam Line Monitors (NEP H.4) .............................................................. 30 5.5.11 Air Ejector Noble Gas Release (NEP H.4) ............................................... 31 5.5.12 Personnel Radiological Monitoring (NEP J) ............................................ 31 5.6 Facilities and Equipment for Offsite Monitoring (NEP H.5) ........................... 32 5.6.1 Meteorological (NEP H.5.1) ..................................................................... 32 5.6.2 Radiological Environmental Monitors and Sampling (NEP H.5.2) ......... 32 5.6.3 Laboratory Facilities (NEP H.5.3) ............................................................. 32 5.7 Assessment Equipment (NEP I)........................................................................ 32 5.8 Protective Facilities and Equipment (NEP J).................................................... 33 5.8.1 Assembly Points (NEP J.1)....................................................................... 33 5.8.2 Operations Support Center (NEP H.1.3, H.9)........................................... 33 5.8.3 Emergency Operations Facility (NEP H.1, H.2)....................................... 34 5.8.4 Red Wing Fire Station (NEP B.9.4).......................................................... 34 5.8.5 Technical Support Center (NEP H) .......................................................... 34 5.9 First Aid and Medical Facilities (NEP H)......................................................... 34 3 of 39

5.9.1 Hospital and Medical Support (NEP B.9.3.1)........................................... 34 5.9.2 Ambulance Service (NEP B.9.2.1) ........................................................... 35 Appendix A: Evacuation Time Estimate Studies and Map references (NEP J.8) ............ 36 Appendix B: Emergency Action Level Initiating Condition (EAL) Scheme (NEP D.1). 37 Appendix C: Prairie Island Plant Letters of Agreement (NEP A.3, P.6, P.7)................... 38 Appendix D: Supporting Plans and Implementing Procedures (NEP P.6, P.7)................ 39 4 of 39

Section 1: Introduction As required in the conditions set forth by the Nuclear Regulatory Commission (NRC) for the operating licenses for the Nuclear Management Company (NMC)

Nuclear Power Plants, the management of NMC recognizes its responsibility and authority to operate and maintain these facilities in such a manner as to provide for the safety of the general public.

The NMC Emergency Preparedness Program consists of the NMC Nuclear Emergency Plan (NEP), Plant Annexes, emergency plan implementing procedures, and associated program administrative documents. The NEP outlines the basis for response actions that would be implemented in an emergency.

Planning efforts common to all NMC nuclear stations are encompassed within the NEP.

This document serves as the Prairie Island Nuclear Generating Plant (PINGP)

Annex and contains information and guidance that is unique to that plant. This includes Emergency Action Levels (EALs), and facility geography, for a full understanding and representation of the stations emergency response capabilities.

The Annex is subject to the same review and audit requirements as the NEP.

In any emergency situation at PINGP, the initial response would be made by the site staff and, if needed, by local support agencies. It is expected that the initial response would have to extend for a period of hours, by which time the site staff would be augmented by other segments of the overall NMC emergency response organization. Once all centers are activated and the emergency organization is at full strength, the scope of the plant staff response will be reduced to the immediate plant site activities. This Annex covers the actions and responsibilities of the PINGP plant staff and the local offsite support agencies.

1.1 Facility Description The Prairie Island Nuclear Generating Plant (PINGP) is located near Red Wing, Minnesota along the Mississippi River, adjacent to the Prairie Island Indian Community reservation. The plant, which first began operating in 1973, has two nuclear pressurized water reactors made by Westinghouse that produce a total 1,100 megawatts of power. They are licensed to operate through 2013 and 2014. The plant is owned by Xcel Energy and is operated by the Nuclear Management Company (NMC).

1.2 Emergency Planning Zones (NEP J.10) 1.2.1 Plume Exposure Pathway (NEP J.10) 5 of 39

The 10-mile Emergency Planning Zone (EPZ) for PINGP approximates a 10-mile radius around the plant site. Appendix A provides additional detail as to the EPZ maps.

1.2.2 Ingestion Pathway (NEP J)

The area between the 10-mile and 50-mile radius is considered the Ingestion Pathway EPZ. The principal exposure risk in this pathway would be from the ingestion of contaminated water, foods such as milk and vegetables, and, on a longer term, contaminated livestock feed. Depending upon the type of release and time, exposure may range from hours to months.

1.3 State of Minnesota (NEP A.2.1)

Coordination between plant, state, local and tribal authorities is defined in the Minnesota and Wisconsin state emergency operations plans, Goodhue, Dakota and Pierce county emergency plans and the Prairie Island Indian Communitys emergency plan. Goodhue, Dakota and Pierce Counties have, formulated for their respective areas, individual evacuation plans which are included in the respective state plans. Notification forms are described in the Emergency Plan Implementing Procedures.

1.3.1 Minnesota Department of Public Safety (DPS) (NEP A.2.1.1)

The Minnesota DPS (Homeland Security, Emergency Management (HSEM) and Bureau of Criminal Apprehension have the responsibility for notification and coordination of Minnesota State Agencies in the event of a major radiological emergency at any Minnesota nuclear power plant. When notified by an affected nuclear plant of an emergency situation, the Minnesota duty officer will call the Minnesota Department of Health, the Governors Authorized Representative and other state agencies with emergency assignments to coordinate the implementation of emergency procedures. The various state emergency response agencies staff twenty-four hour emergency notification and communications systems.

1.3.2 Minnesota Department of Health (NEP A.2.1.2)

The Minnesota Department of Health (MDH) is responsible for providing radiological expertise in the State Emergency Operations Center in conjunction with the MN HSEM.

1.3.3 Minnesota State Patrol (NEP A.2.1) 6 of 39

The Minnesota (MN) State Patrol has the responsibility to protect the general public by providing personnel and equipment to re-route traffic in the event of an emergency situation. Plans have been made for re-routing federal and state highways. The MN Department of Transportation would be notified by the MN State Patrol to erect signs and equipment required for re-routing.

1.3.4 Minnesota Department of Transportation (NEP A.2.1)

The MN Department of Transportation will assist the MN State Patrol in blocking and re-routing traffic around the plant site. In addition to the necessary personnel; vehicles, signals, and barriers for setting up and maintaining detour routes are available.

1.3.5 Minnesota Department of Public Safety (DPS) (NEP A.2.1.1)

The Minnesota DPS (Homeland Security, Emergency Management (HSEM) and Bureau of Criminal Apprehension have the responsibility for notification and coordination of Minnesota State Agencies in the event of a major radiological emergency at any Minnesota nuclear power plant. When notified by an affected nuclear plant of an emergency situation, the Minnesota duty officer will call the Minnesota Department of Health, the Governors Authorized Representative and other state agencies with emergency assignments to coordinate the implementation of emergency procedures. The various state emergency response agencies staff twenty-four hour emergency notification and communications systems.

1.4 Prairie Island Indian Community (NEP A.2.4)

The Prairie Island Indian Community has an Emergency Operations Plan that includes the description of tribal responsibilities during a nuclear plant declared event. The Prairie Island Nuclear Generation Plant conducts emergency notifications to the Treasure Island Casino security dispatch center, who, in turn, notifies appropriate members of the Prairie Island Indian Community.

1.5 State of Wisconsin (NEP A.2.2) 1.5.1 Wisconsin Emergency Management (NEP A.2.2.1)

The Wisconsin Emergency Management (WEM), has the responsibility for notification and coordination of Wisconsin state agencies in the event of a major emergency at PINGP.

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In the event of an emergency situation at the plant, PINGP will notify the WEM duty officer who will notify the Wisconsin Department of Health & Family Services (Radiation Protection Section) and other state agencies with emergency assignments, to coordinate the implementation of any emergency procedures. The state agencies responsible for emergency procedures have established a system of twenty-four hour communications.

1.5.2 Wisconsin Department of Health & Family Services (NEP A.2.2.2)

The Wisconsin Department of Health & Family Services (DHFS) is responsible for preventing exposure to ionizing radiation in amounts which are detrimental to health according to nationally accepted standards.

For emergencies at Prairie Island, the Wisconsin State Emergency Operations Center (EOC) in Madison will be activated as deemed necessary and will serve as a command and control center for Wisconsin response activities. The Wisconsin EOC in Madison will coordinate communications with the Pierce County EOC in Ellsworth and the Joint Information Center (JIC) in St. Paul, Minnesota.

The Wisconsin DHFS, Radiation Protection Section, is responsible for coordination of radiation response activities in the State of Wisconsin. In the event of an emergency at Prairie Island NGP, DHFS, Radiation Protection Section will be concerned with monitoring the air and water about the plant to assure that the public is not exposed to levels of radioactive pollutants potentially detrimental to public health. DHFSs facilities are located in Madison, Wisconsin. Due to the distance and time required for the Wisconsin Radiation Protection Response Team to arrive at the affected area, the State of Minnesota, Department of Health, will provide mutual support to Wisconsin, as spelled out in the letter of agreement in the Wisconsin State emergency operations plan.

1.6 Local Organizations (NEP A.2)

The Sheriffs Departments of Goodhue, Dakota and Pierce County will notify all necessary local civil support groups in the event of an accident.

The Sheriff is responsible for protection of the general public and can provide personnel and equipment for evacuation, relocation and isolation.

The Goodhue, Dakota, Pierce County and City of Red Wing Emergency Management Organizations have the responsibility for notification and 8 of 39

providing direction to residents in the event of a major emergency that affects their respective area of responsibility.

1.7 24-Hour Staffing (NEP F.1.2)

Primary offsite authorities provide a 24-hour per day staffing of communication links, as follows:

Wisconsin authorities:

• State of Wisconsin. (WEM) - WEM Offices during normal business hours and State Patrol District 1 Dispatcher during off-normal business hours;

• Pierce County - Pierce County Sheriffs Dispatcher.

Minnesota authorities:

• State of Minnesota - Duty Officer;

• Goodhue County - Goodhue County Sheriffs Dispatcher;

• Dakota County - Dakota County Sheriffs Dispatcher;

• Tribal Authorities - Treasure Island Security Dispatch.

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Section 2: Organizational Control of Emergencies (NEP B.1) 2.1 Normal Plant Organization (NEP B.1)

The normal plant operating crew is staffed and qualified to perform all actions that may be necessary to initiate immediate protective actions and to implement the emergency plan and is designated as the responsible group for such actions.

The Plant Manager has overall responsibility for the safe, efficient operation of the plant and for compliance with operating license requirements. The Plant Manager will select, train and supervise a qualified staff.

The Shift Manager reports directly to the Assistant Operations Manager who reports directly to the Operations Manager who reports directly to the Plant Manager. The Shift Manager is responsible for the direction and coordination of the Shift Supervisors to perform operations in accordance with the administrative controls and operating procedures. The Shift Manager coordinates activities with other plant groups as required to maintain the safe operation of the plant.

The Shift Supervisor reports to the Shift Manager. The Shift Supervisor is the single focal point for directing and coordinating the operations group, maintenance group and the plant security activities during the assigned shift. The responsibility and authority of the Shift Supervisor will be to maintain the broadest perspective of operational conditions affecting the safety of the plant as a matter of highest priority at all times when on duty in the Control Room.

2.2 Emergency Organization (NEP B.1.6)

PINGPs Emergency Response Organization is provided in the NEP, figures B.1.a through B.1.f (table B.1.b does not apply to PINGP).

2.3 Non-NMC Support Groups (NEP B.9, B.6.1.2)

A complete description of response capabilities, organizational resources, activation plans, designations of emergency operations centers and letters of agreement are available in Minnesota and Wisconsins state emergency operations plans.

2.3.1 Fire Fighting (NEP B.9.4.1)

The Red Wing Fire Department will provide assistance in the event of a fire occurring at the plant. The duties and responsibilities of 10 of 39

the Plant Fire Brigade, insuring complete coordination with the Fire Department, are covered in the Operations Manual, Section F5, Fire Fighting.

2.3.2 Hospital and Medical Support (NEP B.9.3.1, L.1)

Medical support and treatment for non-radiological injuries is provided by the Fairview Red Wing Medical Center, which is located in Red Wing, Minnesota. Radiological related injuries are treated at the medical center which is the primary treatment facility. Emergency plans have been prepared, and training of medical center personnel is accomplished on an annual basis.

North Memorial Hospital, located in Minneapolis and Regions Hospital in St. Paul are designated as Definitive Care Centers, in accordance with Letters of Agreement.

The Definitive Care Center will be responsible for providing definitive evaluation and treatment of more serious trauma, illness and for radiation overexposure. The personnel at the Definitive Care Center may contact the Radiation Emergency Assistance Center/Training Site (REAC/TS) for advice as necessary.

Should the need arise for further advanced medical treatment of radiation overexposure (for example, bone marrow transplant), this arrangement and decision will be made after evaluation of the patient by the medical staff at the Definitive Care Center, in consultation with the Utility Medical Director/Medical Advisor, and any other medical consultants.

Regions Hospital may be used for radiation casualties, severe burn casualties, and other non-radiation injuries with use of an appropriate medical air transport service.

2.3.3 Ambulance Service (NEP B.9.2.1, L.4)

The Red Wing Ambulance Service will provide service to the Prairie Island Nuclear Generating Plant. Training and participation in drills ensures that personnel involved in the transportation of radiation victims are knowledgeable in use of proper procedures and handling methods.

2.3.4 Westinghouse Support (NEP B.8.1.1, C.4.2.4)

Westinghouse emergency assistance is available on a twenty-four hour per day, seven day per week basis. Westinghouse will 11 of 39

activate in support of the plant needs. Westinghouse support will be comprised of individuals with unique technical, managerial and communication skills and experience. A Site Response Team may be dispatched to the site to obtain a first hand assessment of actual conditions and establish communications from the site to the Westinghouse response center, as deemed necessary.

2.3.5 Canadian Pacific Railway (NEP B.8.3.4)

In an emergency situation, Canadian Pacific Railway will make every reasonable effort to expedite unblocking the road/railroad crossing near Prairie Island NGP. The dispatcher will also provide routing assistance during an emergency at Prairie Island NGP.

2.3.6 Burlington Northern, Santa Fe Railroad (NEP B.8.3.4)

The Burlington Northern, Santa Fe Railroad dispatcher will provide routing assistance during an emergency at Prairie Island NGP as per the Minnesota State emergency operations plan.

2.3.7 U.S. Army Corps of Engineers, Lock & Dam #3 (NEP B.8.3)

The Corps of Engineers at Lock & Dam #3 will be notified by the Minnesota Duty Officer of an emergency at Prairie Island NGP.

The Lock and Dam personnel will notify all tows within radio range of impending evacuations and assist in evacuation of personnel at the Lock and Dam.

2.3.8 Public Emergency Planning & Education (NEP G.1.1, G.2.1)

NMC, in coordination with state, county and local officials, annually provides the general public, including transients, with information concerning the methods of public notification and what individual actions should be taken during an emergency.

This information may include:

• methods of public notification;

• possible protective actions;

• general information as to the nature and effects of radiation;

• contact points for additional information;

• special needs for the handicapped;

• registration cards for the mobility impaired.

Methods for disseminating the information may include calendars, brochures, annual publications, public postings and/or meetings.

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Dissemination of information to the public is coordinated with state and local agencies.

2.3.9 Media Information (NEP G.3.1)

The Xcel Energy Communications Department has established a program designed to ensure prompt communications between Xcel Energy or NMC and principal media organizations.

At least once a year, the State of Minnesota will conduct training programs or send mailings to acquaint the news media with the emergency plans and to provide information concerning radiation and points of contact for release of public information in an emergency. NMC has input to this process.

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Section 3: Classification of Emergencies (NEP D.1) 3.1 Emergency Classifications (NEP D.1)

Four classes of Emergency Action Levels are considered according to severity, taking into consideration potential as well as actual events in progress. They are, from the least to the most serious, Unusual Event, Alert, Site Area Emergency, and General Emergency Initiating Conditions (ICs), which determine which level will be declared, are predetermined subsets of plant conditions where the potential exists for a radiological emergency, or such an emergency has occurred. Emergency Action Levels (EALs) are plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions.

3.2 Determination of Levels (NEP D.2)

Appendix B to this Annex contains the matrix for Initiating Conditions used to determine an Emergency Action Level (EAL). They are part of the scheme established by NEI 99-01 (NUMARC/NESP-007) endorsed methodology per RG 1.101 Emergency Planning and Preparedness for Nuclear Power Reactors. The EAL scheme also reflects the NRCs security-based event EALs communicated in NRC Bulletin 2005-02.

Appendix B also contains the matrix which helps determine EALs based on the Three Barrier Criteria, that is, the threat to the fuel clad, the reactor coolant system, and the containment.

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Section 4: Emergency Measures (NEP E) 4.1 Notification of the Emergency Organization (NEP E.2) 4.1.1 Activation of Plant and EOF Organizations (NEP E.2.1)

The Shift Manager will be responsible for activating any part of the emergency organization. During the normal work week, the plant and training center public address systems will be used to activate the organizations. Activation of the emergency organizations will be accomplished using the ERO (Emergency Response Organization) Pager Network and the ERO Auto Dial System.

The ERO Auto Dial System is an automatic dialing telephone network with multiple outgoing telephone lines. When activated, it will call and deliver an emergency message to the Plant and EOF Organizations telephones.

The ERO Auto Dial System and ERO Pager Network are two notification system(s) used to activate the onsite emergency organization. One system is the backup of the other system. Both will be activated for ERO notification.

If the event involves a credible security threat, EOF staff may be directed to staff the Backup EOF by NMC senior management. In this case, the onsite ERO may be directed to the offsite mustering location until it is safe to staff the onsite OSC and TSC.

4.1.2 Notification Scheme (NEP E.2.1)

When an abnormal condition is identified by the Operating Staff/Shift Supervisor, the Shift Supervisor will contact the Shift Manager and the Shift Emergency Communicator. An assessment of the safety significance will be performed, and a determination of the emergency classification will be made using the Emergency Plan Implementing Procedures.

Upon declaring an emergency condition, the Shift Manager will activate portions of the Emergency Plan as appropriate to respond to the declared emergency. The Shift Manager will assume the role as Emergency Director until relieved by a qualified Emergency Director in the TSC. The Shift Manager, or Shift Supervisor if no Shift Manager is available, may designate other Shift personnel to make the necessary notifications of state, tribal 15 of 39

and local authorities as detailed in the plants Emergency Plan Implementing Procedures:

• State of Minnesota Homeland Security Emergency Management (HSEM);

• State of Wisconsin Emergency Management (WEM);

• Local Authorities (Wisconsin & Minnesota);

o Dakota County Sheriff o Pierce County Sheriff o Goodhue County Sheriff

• Prairie Island Indian Community Representatives via Treasure Island Casino Security Dispatch Center;

• NRC Resident Inspectors.

The Shift Manager/Emergency Director will ensure that the NRC Headquarters Operations Officer is notified of the emergency by a qualified individual immediately following state and local notifications and within one hour of emergency declaration. The Emergency Manager, in the Emergency Operations Facility (EOF),

will relieve the Emergency Director of offsite communications and protective action recommendations. At that time offsite notification calls will be initiated by the EOF. The Prairie Island Onsite/Offsite Emergency Organization Interfaces are illustrated in NEP Figure B.1.c.

4.2 Assessment Actions (NEP I.2) 4.2.1 Determining Magnitude of Release (NEP I.2)

The magnitude of releases and release rates from normal pathways are determined using installed plant instrumentation. Installed side-stream isokinetic samplers and wide-range radiation monitors normally monitor plant effluent releases, and would be the primary method used in an emergency. Field measurements will be used to assist in the assessment effort by making physical measurements of dose rates and airborne, liquid and surface contamination.

4.2.2 Dose Projections (NEP I.2, I.3)

Dose projections will be performed by a computerized dose projection program designed to perform dose assessments during inadvertent release of radioactive materials. Dose projection capable computers are located in the Control Room, TSC, EOF, and Backup EOF. The onsite 60 meter meteorological tower supplies the following:

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• Wind speed (10 and 60 meters);

• Wind direction (10 and 60 meters);

• Ambient Temperature;

• Delta Temperature (between 10 and 60 meters);

• Rainfall.

Redundant instrumentation is provided on the onsite 60 meter meteorological tower, and may be designated as primary and secondary sensors. Meteorological data from both sets of instruments are displayed simultaneously as well as the calculated stability class.

The effluent monitor reading, the calibration conversion factor and the vent flow rate result in a release rate. With meteorological and effluent release data available, calculations of atmospheric dispersion and offsite radiation dose from the plume can be made.

Dose calculations are made for Total Effective Dose Equivalents (TEDE) and Thyroid Committed Dose Equivalents (Thyroid CDE). Results of all calculations can be printed in report format and displayed graphically.

The dose assessment computer allows quick accident dose calculations to be made, before any results from the Radiation Survey Teams are received. Radiation Survey Team results will be used to verify the dose calculations.

The capability for remote interrogation of the meteorological data will be provided to NRC by either the Emergency Response Data System (ERDS) or direct telephone access to the individual responsible for making offsite dose projections. Weather forecast information is available from the National Weather Service Twin Cities.

4.2.3 Radiological Surveys (NEP I.7)

The Radiation Protection Group will be responsible for all radiological surveys and personnel monitoring both onsite and offsite. The non-licensed operators of the Operations Group are also trained to conduct post-accident in-plant surveys during the first hour of the emergency.

The Radiation Protection Specialists may be divided into onsite and offsite Radiation Survey Teams. Teams are assigned offsite duties such as radiation surveys, air samples, or liquid sampling.

The offsite survey teams will conduct a search for the plume and obtain dose rates, and iodine, particulate and gaseous samples at 17 of 39

pre-designated sample locations. Plume exposure pathway maps with pre-designated sample locations are contained in the emergency survey kits. One team is assigned duties onsite such as radiation surveys, sampling (airborne or liquid) and sample analysis using the equipment available onsite.

After the initial offsite surveys are completed, the teams assigned offsite duties may be relieved by Monticello Offsite Survey Teams who will continue to perform any offsite surveys assigned by the Emergency Director/Emergency Manager. The Prairie Island Survey Team members may concentrate their efforts and resources to onsite responsibilities.

4.3 Protective Actions for the Offsite Public (NEP J.7)

The primary protective actions for the offsite population are sheltering or evacuation. The Emergency Director/Emergency Manager will recommend the necessary protective actions to offsite authorities based on predetermined protective actions for a General Emergency Classification or results of offsite dose assessment. Upon activation of the EOF, the Emergency Manager will be responsible for recommending protective actions for the offsite population. If protective actions are warranted prior to augmentation of state emergency response organizations, the Emergency Director/Emergency Manager will recommend directly to county and tribal authorities the necessary protective actions. In both cases, total responsibility for carrying out the protective actions rests with offsite authorities. PINGP will make the recommendations and supply the required dose assessments.

4.3.1 Protective Action Recommendations (NEP J.7)

Recommendations for the offsite public are determined from plant conditions and dose projections provided on the following decision chart:

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Protective Action Recommendations Flowchart 1 of 2 The following situations require urgent actions by offsite officials. Conditions are based on Control Room indications with no dose projections required. The following protective action recommendations in this table should be conducted at the same time the General Emergency notifications conducted.

Event Continue to monitor Does a General Yes No plant and radiological Emergency exist?

conditions Evacuate all sectors Is there an ongoing out to 2 miles; Do known Is Met data from radiological release exceeding AND No impediments to No 22 meter tower OR No EPA PAGs to the environment Five downwind evacuation exist? 2 Wind < 5 mph due to the event? 1 sectors out to 5 miles.

Yes Yes Is it known with Evacuate all sectors 5 No certainty that the release miles downwind Advise public in those duration will be < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; affected subareas OR No take KI if available Do known impediments AND the remainder of to evacuation the EPZ to go indoors exist? 2 and monitor EAS Yes State and local Yes authorities will shelter any populations that Shelter all sectors out cannot be evacuated Is Met data from to 2 miles; per offsite protocols.

22 meter tower OR No AND Wind < 5 mph Five downwind sectors out to 5 miles.

Yes Have EPA PAGs been exceeded at > 2 miles? 3 Shelter all sectors 5 miles downwind Yes 1

IF 1(2)R-50 > 3,300 mR/hr OR Steam Release Computer Release Rate > 6.90E+08 uCi/sec, Go to next page for Dose Assessment THEN assume the radiological release will exceed the EPA PAGs. PAR Development 2

Known impediments to evacuation are conditions which make evacuation of the public impractical. Conditions include Inclement Weather (ice/snow storms where driving would be dangerous), and known impacts on the ability to execute public evacuations (severe damage to roads/infrastructure, etc.).

3 This decision is based on Offsite Dose Projection calculations.

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Protective Action Recommendations Flowchart 2 of 2 Dose Assessment PAR Development '

U s e the 4-Day Integrated Dose t o determine the Protective Action Recommendation based2 on the EPA Protective Action Guidelines.

Yes Evacuate all sectys out to 10 Five downwind sectors out to 10 miles. '

(Include any existing PARSin new PAR.)

Update PAR to includ5 new affected sectors.

affected downwind sectors (Include any existing PARSin new PAR.)

I No New Protective Action Recommended.

I I Offsite projected doses include exposure from radioactive plume (external & internal) and 4 days exposure to ground contamination. I 1' Based on EPA 400-R-92-001, May 1992.

I

'TEDE = Total Effective Dose Equivalent, Thyroid CDE = Thyroid Committed Dose Equivalent.

I

'sheltering may be the appropriate action for known impediments to evacuation a controlled puff release.

a) Shelter if there is pre-existing knowledge by the ED or EM that known impediments to evacuation exist. Known impediments to l

evacuation are conditions which make evacuation of the public impractical. Conditions include Inclement Weather (icelsnow storms where driving would be dangerous), and known impacts on the ability to execute public evacuations (severe damage to roads1 infrastructure.etc.)

b) Shelter if there is a controlled release with assurance that the release is short term (puff release < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) and the area near the plant cannot be evacuated before the plume arrives.

4.3.2 Notification of Offsite Agencies (NEP E.2.3)

The incident report form provides for message verification and information for the initial and follow-up messages. The initial messages contain information about:

• Location of incident;

• Name of caller, date/time of incident;

• Class of emergency;

• Release status;

• Potentially affected population and areas;

• Whether protective actions are necessary.

The follow-up messages contain the basic information from the initial message with the following additional information, if it is known and appropriate:

• Type and form of any actual or projected radiological release;

• Meteorological conditions;

• Actual or projected doses in the affected sector(s);

• Emergency response actions in progress;

• Requests made for any needed onsite support.

4.3.3 Public Alert and Notification System (PANS) (NEP E.6)

The plant maintains a basic fixed siren system for essentially 100%

coverage of the offsite population within 5 miles of the plant and population center coverage for the 5-10 mile zone for Goodhue County. Pierce and Dakota counties have 100% fixed siren coverage for the entire 10 mile EPZ. To reach persons not covered by these population center sirens, state, county and city emergency vehicles will be directed to alert the affected downwind geo-political sub-areas.

A special redundant siren is maintained near the Prairie Island Indian Community Center. The TSC has the capability to activate the siren with a special stutter tone at the declaration of a Site Area Emergency for the purpose of quickly notifying the Prairie Island Indian Community. The siren would also be activated with the normal Alert tone by the Goodhue County Sheriffs Department during a General Emergency, as part of the normal Public Alert and Notification System activation.

4.3.4 Emergency Alert System Radios (NEP E.6) 21 of 39

To supplement PANS, emergency alert radios have been installed in various commercial, institutional, and educational facilities in the 10-mile zone. Emergency Alert System radios will be activated by the National Oceanic and Atmospheric Administrations (NOAA) National Weather Service, or by the local county sheriffs dispatch office. In the event of an emergency condition, alert and notification information will be relayed through established communication links described in the Minnesota and Wisconsin emergency response plans. Upon receiving notification of the emergency, offsite governments will, when required, activate public warning and information procedures.

4.4 Protective Actions for Onsite Personnel (NEP J.6)

The primary protective measure for non-essential onsite personnel during a Site Area or General Emergency and possibly during an Alert, is evacuation to a suitable assembly area where the personnel can be accounted for and monitored for contamination.

Control Room personnel will sound the evacuation alarm and announce the designated assembly area. All non-essential personnel will evacuate to the designated assembly area. The plant security force will assist in the evacuation. The security force will perform a check of the Owner Controlled Area and warn all personnel of the evacuation in progress.

Once non-essential personnel are accounted for and monitored for contamination as needed, they may be released from the assembly area.

The Emergency Director will release non-essential personnel for departure from the site when procedurally required or when conditions allow.

Radiation Protection personnel, extra on-shift operators, and Maintenance personnel will report to the Operations Support Center.

4.4.1 Onsite Respiratory Protection and Protective Clothing (NEP J.6)

Protective clothing or respiratory protection for onsite personnel will be as designated by the Radiation Protection Group or the TSC Director.

Respiratory Protection will be used as necessary to reduce the inhalation of radioactive material. During emergency conditions, it may become impossible to maintain normal respiratory protection guidelines. An internal exposure program, whole body counting and/or bioassay program, will be activated to ensure that all internal exposure is determined as assigned to the individual.

Access Control is the main storage area for respiratory equipment.

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The respiratory equipment available is a combination of Self Contained Breathing Apparatus (SCBAs), and full face canister respirators.

4.4.2 Potassium Iodide (NEP J.6)

A supply of potassium iodide (KI) will be maintained at the Technical Support Center and the Emergency Operations Facility.

In the event that an individual is expected to receive a dose to the thyroid in excess of 25 Rem, due to radioiodine uptake, the use of KI as a blocking agent may be recommended.

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Section 5: Emergency Facilities and Equipment (NEP H) 5.1 Emergency Response Facilities (NEP H.1) 5.1.1 Control Room (NEP H.1.1)

The Control Room contains the necessary instrumentation to evaluate plant conditions. Habitability is maintained by shielding and the ventilation system, which is capable of operating in a cleanup or recycle mode.

5.1.2 Technical Support Center (TSC) (NEP H.1.2)

The Technical Support Center (TSC) is located across the Turbine Building from the Control Room. The Technical Support Center has the following capabilities:

• Working space for about twenty-five people on the main floor and working space for additional people on the other floor;

• Shielding, backup diesel power, and ventilation cleanup system to provide habitability under accident conditions;

• An emergency locker containing monitoring equipment, respiratory protection equipment and thyroid blocking agent tablets;

• Communication to onsite and offsite emergency response centers;

• A complete set of as-built drawings which are brought to TSC during activation;

• The capability to record and display plant systems and radiological parameters.

5.1.3 Operations Support Center (OSC) (NEP H.1.3, H.9)

The Operations Support Center is located immediately adjacent to the Control Room. Radiation shielding is provided by concrete wall construction for the room. An emergency locker located in the OSC contains equipment necessary for reentry into the plant such as protective clothing, respiratory protection equipment, dosimeters, radiation detection meters, air samplers, decontamination and first aid equipment, and communication equipment.

5.1.4 Emergency Operations Facility (EOF) (NEP H.2)

The EOF is in the Training Center. The EOF is constructed in a manner which provides habitability in an accident situation.

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Shielding and ventilation treatment systems have been installed to maintain an acceptable environment. The ventilation system has an emergency mode of operation that will pressurize the building through a High Efficiency Particulate Absolute (HEPA) filtration system.

The general layout of the buildings entrances and exits has been given consideration for operation of the building in an emergency mode. Radiological monitoring and alarms are provided for the EOF portion of the building. Extensive communication equipment is installed in the building to provide primary and backup means of communication with outside agencies, offsite survey teams, TSC and the Control Room. The EOF portion of the building is served by a dual source power supply for those services necessary to make the EOF functional.

The EOF provides office space for each plant support group, key supervisors, state, local and tribal officials, and the NRC. The command center functions as a work space for the EOF emergency response, and for related critical communications. This area is the central area for displaying plant status, offsite survey status, and conducting accident assessment.

Radiation monitoring and decontamination equipment has been provided to supply offsite monitoring teams. Normal and emergency data acquisition is made available via the Emergency Response Computer System (ERCS). The ERCS system displays information equivalent to that required by the Safety Parameters Display System (SPDS).

5.1.5 Back-up EOF (NEP H.2)

Because the EOF is located within the 10 mile Emergency Planning Zone (EPZ), a Backup EOF (BEOF) exists in case an evacuation of the EOF is necessary. The BEOF is located at the Xcel Energy corporate office in downtown Minneapolis, approximately 45 miles northwest of the plant. In the event the EOF became uninhabitable, the functions of the EOF would be transferred to the BEOF.

Extensive communications equipment is installed to provide primary and back-up methods of communicating with plant emergency Response Facilities, offsite agencies and utility Field Monitoring teams. Critical plant parameter data is available in the BEOF through the plant Emergency Response Computer System 25 of 39

(ERCS). Meteorological data and offsite dose projection capabilities are provided.

5.1.6 Joint Information Center (JIC) (NEP B.7.8)

The State of Minnesota has established a JIC, which will be activated jointly with the State EOC. The JIC is located in the Minneapolis - St. Paul metropolitan area, accessible to the major Minnesota news media.

5.2 Onsite Communications (NEP F.1.1)

All emergency operating facilities have at least two means of communications, portable or installed radio systems; and normal telephone communications. The normal onsite communications during an emergency will be made via the plant telephone system with a public address system option. The telephone system is powered by non-interruptible power. The public address system includes loudspeakers located throughout the entire plant area. A separate paging system has handsets located at strategic plant areas.

The Control Room, Technical Support Center and EOF each have a multi-channel radio system console for communications. Portable radios are available for use throughout the plant during emergency conditions.

The plant evacuation alarm consists of a 125 VDC operated siren, manually activated from the Control Room. The Control Room operator can remove the siren tone for emergency voice communication over the loudspeaker PA system. The plant fire alarm consists of a modulating signal interrupted continuously. This is also activated manually from the Control Room.

5.3 Offsite Communications (NEP F.1.1)

The Control Room, Technical Support Center and EOF have a dedicated Xcel Energy radio channel link to the Xcel Energy System Control Center, the Backup EOF, and the Minnesota DEM Emergency Operating Center in St. Paul, Minnesota.

The Technical Support Center and EOF have a National Warning System (NAWAS) extension to the Wisconsin Emergency Management EOC at Madison, the Regional Warning Center at Eau Claire and the Pierce County EOC at Ellsworth, Wisconsin.

The Control Room, Technical Support Center and EOF each have a portable cellular phone for emergency communication use.

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The plant telephones have access to a computerized auto dial system used for notification of the sites Emergency Response Organization (ERO).

When activated, it will call and deliver an emergency message to the ERO members.

The plant also has an Emergency Response Organization (ERO) Pager Network. Designated members of the sites emergency organization carry personal pagers which can be activated from any phone with the proper access codes. A special emergency code is displayed on the pager.

The Control Room, Technical Support Center and EOF have multi-channel radio system for communication with Plant Radiation Survey Teams, Plant Operations Personnel, Plant Security Areas, county sheriffs, county EOCs, and Treasure Island Casino Dispatch Center (Prairie Island Tribal contact).

A telecopying network is set up between the TSC, EOF, state and county EOCs and Prairie Island Indian Community for the purpose of telecopying emergency notification forms and other appropriate emergency update information.

Communication links are maintained with medical facilities, both fixed and mobile. The plant can update the hospital via the telephone network of the status of any injuries. Communication channels are provided between the hospital and the ambulance service via the radio system while the victim(s) are enroute.

The plant utilizes Xcel Energys telephone sonet system for communicating with NRC Operations Center in Rockville, Maryland. The dial tone for the PINGP FTS circuits is provided by Xcel Energys corporate communication network. This system provides for reporting emergencies and other significant events to the NRC Operations Center in Rockville, Maryland.

5.4 Kits (NEP H.10)

Designated Emergency Lockers contain emergency survey kits, which include portable instruments, battery operated air samplers, liquid sampling equipment, and communication equipment.

When facilities at Access Control are not available, the assembly area emergency lockers contain equipment for personnel decontamination and personnel monitoring. The decontamination kits contain oxidizing agents for decontamination of the skin due to radioiodines.

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First aid kits are located at the primary emergency centers and at various emergency lockers in the plant.

The hospital emergency kit at Fairview Red Wing Medical Center has instruments for measuring radiation levels and contamination levels of radiation casualties arriving at the medical center for medical treatment.

5.5 Facilities and Equipment for On-site Monitoring (NEP H.4)

The plant instrumentation and monitors perform indicating, recording and protective functions. The Reactor Protection System and associated plant instrumentation provide the ability to maintain plant safety from shutdown to full power operations and to monitor and maintain key variables such as reactor power, flow, temperature, and radioactivity levels within predetermined safe limits at both steady state conditions and during plant transients. Plant instrumentation and control systems also provide means to cope with abnormal operating conditions. The control and display of information of these various systems are centralized in the main Control Room. This instrumentation would provide the basis for initiation of protective actions.

5.5.1. Geophysical Monitors (NEP H.4.1)

Prairie Island has a 60-meter onsite meteorological tower located approximately 0.5 miles northwest of the plant. The tower is equipped with primary and secondary redundant sensors for the 10 and 60-meter temperatures, wind speeds, and wind directions powered by a primary and secondary power source. The following meteorological information is supplied by the tower:

• Wind Direction (10 and 60-meter);

• Wind Speed (10 and 60-meter);

• T between 10 and 60-meter temperature indications;

• Precipitation.

Meteorological data is processed, and may be displayed in the Control Room, TSC, EOF, and Backup EOF.

The Control Room has an installed earthquake detection system with two alarms:

• Seismic Event Alarm;

• Operational Basis Earthquake Exceedance Alarm (OBE).

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A visual and audible alarm will sound in the Control Room when an earthquake is detected. Upon activation, the earthquake detection system will automatically record seismic data.

River water level indication is available from two sources. River water level is available in the Control Room from probes located in the river water canals and intake screenhouse along with Lock and Dam #3.

5.5.2 Radiation Monitoring Equipment (NEP H.4.2)

Onsite radiation monitoring equipment at PINGP can be categorized into the following groups:

• Process radiological monitoring system;

• Effluent radiological monitoring system;

• Airborne radioactivity monitoring system;

• Area radiation monitoring system;

• Portable survey and counting room equipment.

5.5.3 Process Monitors (NEP H.4.3)

Adequate instrumentation monitoring capability exists to properly access the plant status during all modes of operation, as detailed in the Updated Safety Analysis Report (USAR).

5.5.4 Fire Detection (NEP H.4.4)

The fire detection system consists of various types of detectors/flow devices throughout the main power building and in most of the outbuildings. Ionization, flame and thermal type fire detectors are located throughout safety related structures. Audible alarming is on the Control Room annunciator panel system for actuation or trouble. The Control Room fire panel system will indicate zone location of the alarm.

5.5.5 Post Accident Liquid Sampling (NEP H.4.2.2)

A post-accident liquid sampling system is installed at Prairie Island with associated procedures to provide the capability to obtain the following samples:

• Sample of raw reactor water;

• Diluted samples of reactor water (boron, chloride, isotopic analysis, pH, etc.);

• Dissolved gas sample for isotopic analysis (noble gases);

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• Dissolved hydrogen sample.

5.5.6 Containment Air Sampling (NEP H.4.2.2)

Following an accident, a containment air sample may be obtained, utilizing the gas analyzer to extract a sample via the Hydrogen Post LOCA System for determination of:

• Hydrogen content;

• Isotopic analysis (noble gas).

5.5.7 Shield Building Vent Sample (NEP H.4)

The Shield Building Stack Hi-Range Monitor extracts a sample from the Shield Building stack and pumps it through a large sample chamber, which houses the radiation detector.

5.5.8 Containment High Range Area Monitors (NEP H.4)

Two channels of Containment High Range Dome monitors are installed in the containments. This allows personnel to estimate the amount of activity in containment and the severity of the accident from the applicable calibration curves.

5.5.9 In-Plant Iodine Determination (NEP H.4)

Samples for iodine activity are obtained with portable air samplers and continuous air monitors. The iodine is collected on silver zeolite adsorbers.

The silver zeolite adsorbers may be analyzed using the onsite or the EOF Counting Room. The adsorbers could also be analyzed with portable instrumentation.

The Control Room, Operations Support Center, Technical Support Center and EOF have continuous air monitors available to monitor the airborne particulate-iodine levels. A single channel analyzer is continuously analyzing the particulate-radioiodine activity trapped on the charcoal-impregnated particulate filter. This combination of equipment allows iodine determinations under plant accident conditions.

5.5.10 Steam Line Monitors (NEP H.4) 30 of 39

The steam line radiation monitor in conjunction with the ERCS (Emergency Response Computer System) computer will supply a value for noble gas activity released via the steam headers.

5.5.11 Air Ejector Noble Gas Release (NEP H.4)

Releases through the air ejectors are quantified via the installed air ejector radiation monitor and the Shield Building Exhaust Stack monitors or by local sample analysis. Normally, the air ejector discharge is routed to the Shield Building Exhaust stacks, which are monitored by the low and high range stack radiation monitors.

5.5.12 Personnel Radiological Monitoring (NEP J)

The PINGP Radiation Protection Group has the necessary equipment and personnel required to provide continuous capability to control and determine radiation exposures of emergency organization personnel. The equipment consists of the following:

• Portable radiation detection instruments;

• Electronic dosimeters;

• High and low range dosimeters;

• TLDs;

• Extra high range dosimeters;

• Record keeping equipment.

In an emergency situation, all onsite emergency response personnel, some offsite support personnel and some local governmental emergency response personnel will be issued dosimetry. Exposure records will be maintained for all emergency response personnel.

5.5.13 Decontamination Facilities (NEP J)

The primary decontamination facility is located at Access Control.

Decontamination solutions are also available at Access Control. If facilities at Access Control are not available, the assembly area emergency lockers contain equipment for personnel decontamination and personnel monitoring.

Decontamination operations at the assembly area will be confined to minor decontaminations because of limited resources. If necessary, individuals will be furnished with protective clothing and transported to alternate facilities.

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The EOF has a decontamination shower with associated liquid retention system. Equipment for small decontaminations is also available along with personnel monitoring equipment.

Contaminated individuals may be provided whole body counting analysis, as determined by the Radiological Emergency Coordinator. Whole body counting systems are located at Prairie Island and Monticello Nuclear Generating Plants.

5.6 Facilities and Equipment for Offsite Monitoring (NEP H.5) 5.6.1 Meteorological (NEP H.5.1)

Meteorological information from the National Weather Service Twin Cities Local Area is available on a twenty-four hour basis and includes:

• Temperature;

• Wind Direction;

• Wind Speed;

• Stability Class.

5.6.2 Radiological Environmental Monitors and Sampling (NEP H.5.2)

There are TLD badges and airborne particulate and iodine sampling stations installed in areas surrounding the plant. The badges and air sampling stations are installed as part of the Radiation Environmental Monitoring Program. During an emergency, these badges and/or air sampling filters or cartridges may be used for dose assessment purposes.

5.6.3 Laboratory Facilities (NEP H.5.3)

A Letter of Agreement between Nuclear Management Company and Environmental, Inc. Midwest Laboratory exists, which states Environmental, Inc. Midwest Laboratory will respond upon request to augment our environmental sampling and monitoring program.

5.7 Assessment Equipment (NEP I)

The EOF Count Room contains equipment to analyze offsite samples.

The emergency lockers in the Assembly Points have the equipment necessary to collect and analyze air samples (particulate and iodine) and portable instruments for measuring radiation levels.

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The hospital emergency kit at Fairview Red Wing Medical Center has instruments for measuring radiation levels and contamination levels of radiation casualties arriving at the medical center for medical treatment.

All Monticello Nuclear Plant counting room and portable radiation detection equipment is available for analysis of samples from Prairie Island NGP. Some equipment will be brought with the Monticello Radiation Protection Group members arriving onsite to augment the Prairie Island Radiation Protection Group in performing offsite surveys and sampling.

There are TLD badges and airborne particulate and iodine sampling stations installed in areas surrounding the plant. The badges and air sampling stations are installed as part of the Radiation Environmental Monitoring Program (REMP). During an emergency, these badges and/or air sampling filters or cartridges may be used for dose assessment purposes.

All onsite portable equipment and count room equipment at Prairie Island NGP may be used for required offsite radiation surveys or analysis of offsite samples (liquid or airborne).

5.8 Protective Facilities and Equipment (NEP J) 5.8.1 Assembly Points (NEP J.1)

In the event of a plant evacuation, the On-Site Assembly Point (or an Off-Site Assembly Point, as appropriate) will be activated. The function of the assembly point is to provide a center for personnel accountability and radiological contamination screening along with any other immediately necessary actions.

Either the Receiving Warehouse or the North Warehouse may be used for an Assembly Point depending on wind direction. The assembly area emergency locker contains equipment that will be used for personnel contamination checks, personnel decontamination, radiation detection equipment to assess conditions at the assembly area, and communication equipment.

5.8.2 Operations Support Center (NEP H.1.3, H.9)

The Operations Support Center locker contains all the equipment necessary for reentry into the plant. This includes protective clothing, respiratory protection, monitoring devices, and radiation meters. Air sampling and contamination survey equipment is 33 of 39

available for onsite surveys. Decontamination and first aid equipment is available for treatment of onsite personnel.

Instrumentation is stored in the emergency locker which provides for monitoring both direct radiation and airborne radioactive contaminants. Radiation shielding is provided by the concrete wall construction for the room.

5.8.3 Emergency Operations Facility (NEP H.1, H.2)

The EOF can be designated as an alternate assembly area.

Facilities are available for gathering personnel into a specific area.

An emergency locker contains equipment necessary for determining personnel contamination and for decontamination of individuals. A decontamination shower and retention system is available for collection of contaminated waste. A spare Field Survey Team Equipment Kit is located at the EOF.

Communication equipment (radio and telephone) is available for contacting emergency personnel both onsite and offsite.

5.8.4 Red Wing Fire Station (NEP B.9.4)

All fire trucks, ambulances, and cars at the Fire Station are assigned pocket dosimeters for use by Fire Department staff. In addition, the ambulances have TLDs for use by Fire Dept. staff.

A dosimeter charger is stored at the dispatchers station. All dosimeters and TLDs are maintained by plant personnel.

5.8.5 Technical Support Center (NEP H)

The Technical Support Center emergency locker contains the necessary survey instruments, dosimetry and protective clothing to allow reentry or access into the plant during emergency conditions.

5.9 First Aid and Medical Facilities (NEP H) 5.9.1 Hospital and Medical Support (NEP B.9.3.1)

Medical support and treatment for non-radiological injuries is provided by the Fairview Red Wing Medical Center located in Red Wing, Minnesota. Fairview Red Wing Medical Center has the equipment required to handle medical emergencies complicated by radioactive contamination. Monitoring equipment, decontamination materials and waste storage (solid and liquid) are available. Emergency plans have been prepared, and training of medical center personnel is accomplished on an annual basis.

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Regions Hospital in St. Paul, Minnesota is designated as the definitive care center for Prairie Island Nuclear Generating Plant.

Regions Hospital may be used for radiation casualties, severe burn casualties, and other non-radiation injuries with use of an appropriate medical air transport service.

5.9.2 Ambulance Service (NEP B.9.2.1)

The Red Wing Ambulance Service will provide service to the Prairie Island Nuclear Generating Plant. Training and participation in drills ensures that personnel involved in the transportation of radiation victims are knowledgeable in use of proper procedures and handling methods.

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Appendix A: Evacuation Time Estimate Studies and Map references (NEP J.8)

A Prairie Island evacuation time estimate study, Evacuation Time Estimate Study For The Prairie Island Nuclear Generating Plant Emergency Planning Zone, Dated:

September 25, 2003, was prepared by Tom Cod Data Systems, 207 West Water Street, Suite 1, Decorah, IA 52101. The complete Study is on file.

The Prairie Island Nuclear Generating Plant has detailed maps showing the 10-mile and 50-mile Emergency Planning Zones, Evacuation Routes, Radiological Sampling and Monitoring Points, and Traffic Control Points. These maps are maintained by the State of Minnesota and periodically updated as needed.

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Appendix B: Emergency Action Level Initiating Condition (EAL) Scheme (NEP D.1)

General Emergency Site Area Emergency Alert Unusual Event RG1 Offsite Dose Resulting from an Actual or Imminent Release of RS1 Offsite Dose Resulting from an Actual or Imminent Release of RA1 Any UNPLANNED Release of Gaseous or Liquid Radioactivity to RU1 Any UNPLANNED Release of Gaseous or Liquid Radioactivity to Gaseous Radioactivity Exceeds 1000 mRem TEDE or 5000 mRem Gaseous Radioactivity Exceeds 100 mRem TEDE or 500 mRem the Environment that Exceeds 200 Times the Offsite Dose the Environment that Exceeds Two Times the Offsite Dose Thyroid CDE for the Actual or Projected Duration of the Release Thyroid CDE for the Actual or Projected Duration of the Release. Calculation Manual Specification for 15 Minutes or Longer. Calculation Manual Specification for 60 Minutes or Longer.

Using Actual Meteorology.

RA2 Damage to Irradiated Fuel or Loss of Water Level that Has or Will RU2 Unexpected Increase in Plant Radiation.

Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel.

RA3 Release of Radioactive Material or Increases in Radiation Levels Within the Facility That Impedes Operation of Systems Required to Maintain Safe Operations or to Establish or Maintain Cold Shutdown.

HA1 Natural and Destructive Phenomena Affecting the Plant VITAL HU1 Natural and Destructive Phenomena Affecting the PROTECTED AREA. AREA.

HA2 FIRE or EXPLOSION Affecting the Operability of Plant Safety HU2 FIRE Within PROTECTED AREA Boundary Not Extinguished Systems Required to Establish or Maintain Safe Shutdown. Within 15 Minutes of Detection.

HA3 Release of Toxic or Flammable Gases Within or Contiguous to a HU3 Release of Toxic or Flammable Gases Deemed Detrimental to VITAL AREA Which Jeopardizes Operation of Systems Required to Normal Operation of the Plant.

Maintain Safe Operations or Establish or Maintain Safe Shutdown.

HG1 Security Event Resulting in Loss of Physical Control of the HS1 Confirmed Security Event in a Plant VITAL AREA. HA4 Confirmed Security Event in a Plant PROTECTED AREA. HU4 Confirmed Security Event Which Indicates a Potential Degradation in Facility. the Level of Safety of the Plant.

HS4 Site Attack. HA7 Notification of an Airborne Attack Threat.

HA8 Notification of HOSTILE ACTION within the OCA.

HS2 Control Room Evacuation Has Been Initiated and Plant Control HA5 Control Room Evacuation Has Been Initiated.

Cannot Be Established.

HG2 Other Conditions Existing Which in the Judgment of the Emergency HS3 Other Conditions Existing Which in the Judgment of the HA6 Other Conditions Existing Which in the Judgment of the Emergency HU5 Other Conditions Existing Which in the Judgment of the Director Warrant Declaration of General Emergency. Emergency Director Warrant Declaration of Site Area Director Warrant Declaration of an Alert. Emergency Director Warrant Declaration of a UE.

Emergency.

SG1 Prolonged Loss of All Offsite Power and Prolonged Loss of All SS1 Loss of All Offsite Power and Loss of All Onsite AC Power to SA5 AC power capability to Safeguards Buses reduced to a single SU1 Loss of All Offsite Power to Safeguards Buses for GREATER Onsite AC Power to Safeguards Buses. Safeguards Buses. power source for GREATER THAN 15 minutes such that any THAN 15 Minutes.

additional single failure would result in station blackout.

SS3 Loss of All Vital DC Power. SU2 Inability to Reach Required Shutdown Within Technical Specification Limits.

SG2 Failure of the Reactor Protection System to Complete an Automatic SS2 Failure of Reactor Protection System Instrumentation to Complete or SA2 Failure of Reactor Protection System Instrumentation to Complete or SU3 UNPLANNED Loss of Most or All Safety System Annunciation or Trip and Manual Trip was NOT Successful and There is Indication of Initiate an Automatic Reactor Trip Once a Reactor Protection System Initiate an Automatic Reactor Trip Once a Reactor Protection System Indication in the Control Room for Greater Than 15 minutes.

an Extreme Challenge to the Ability to Cool the Core. Setpoint Has Been Exceeded and Manual Trip Was NOT Successful. Setpoint Has Been Exceeded and Manual Trip Was Successful.

SS4 Complete Loss of Heat Removal Capability. SU6 UNPLANNED Loss of All Onsite or Offsite Communications Capabilities.

SS6 Inability to Monitor a SIGNIFICANT TRANSIENT in Progress. SA4 UNPLANNED Loss of Most or All Safety System Annunciation SU4 Fuel Clad Degradation.

or Indication in Control Room With Either (1) a SIGNIFICANT TRANSIENT in Progress, or (2) Compensatory Non-Alarming Indicators are Unavailable.

SU5 RCS Leakage.

SU8 Inadvertent Criticality.

EU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

FG1 Loss of ANY two Barriers AND Loss or Potential Loss of Third FS1 Loss or Potential Loss of ANY two Barriers. FA1 ANY Loss or ANY Potential Loss of EITHER Fuel Clad OR FU1 ANY Loss or ANY Potential Loss of Containment.

Barrier. RCS.

CA3 Loss of All Offsite Power and Loss of All Onsite AC Power CU3 Loss of All Offsite Power to Safeguards Buses for GREATER THAN to Safeguards Buses. 15 Minutes.

CU7 UNPLANNED Loss of Required DC Power for GREATER THAN15 Minutes.

CG1 Loss of RPV Inventory Affecting Fuel Clad Integrity with CS1 Loss of RPV Inventory Affecting Core Decay Heat Removal CA1 Loss of RCS Inventory.

Containment Challenged with Irradiated Fuel in the RPV. Capability.

CS2 Loss of RPV Inventory Affecting Core Decay Heat Removal CA2 Loss of RPV Inventory with Irradiated Fuel in the RPV. CU2 UNPLANNED Loss of RCS Inventory with Irradiated Fuel in Capability with Irradiated Fuel in the RPV. the RPV.

CA4 Inability to Maintain Plant in Cold Shutdown with CU4 UNPLANNED Loss of Decay Heat Removal Capability with Irradiated Fuel in the RPV. Irradiated Fuel in the RPV.

CU6 UNPLANNED Loss of All Onsite or Offsite Communications Capabilities.

CU5 Fuel Clad Degradation.

CU1 RCS Leakage.

CU8 Inadvertent Criticality.

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Appendix C: Prairie Island Plant Letters of Agreement (NEP A.3, P.6, P.7)

Institute of Nuclear Power Operations (INPO)

State of Minnesota Regions Hospital Environmental, Inc. Midwest Laboratory Canadian Pacific Rail System DOE-Radiation Emergency Assistance Center/Training Site North Memorial Health Care Dakota County Emergency Services Goodhue County Emergency Management Pierce County Emergency Management City of Red Wing Red Wing Fire Department Fairview Red Wing Hospital Westinghouse Electric Company State of Wisconsin Sacred Heart Hospital Prairie Island Indian Community The Letters of Agreement are maintained on file at NMC.

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Appendix D: Supporting Plans and Implementing Procedures (NEP P.6, P.7)

• State of Wisconsin Emergency Operations Plan.

• Pierce County Emergency Operations Plan.

• State of Minnesota Emergency Operations Plan.

• City of Red Wing/Goodhue County Emergency Response Plan for the Prairie Island Nuclear Generating Plant.

• Dakota County Emergency Response Plan.

Implementing Procedures for the NMC Nuclear Emergency Plan and Prairie Island Annex will be developed. A complete listing will be provided when developed.

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ENCLOSURE 4 NUCLEAR MANAGEMENT COMPANY, LCC NUCLEAR EMERGENCY PLAN ANNEX MONTICELLO NUCLEAR GENERATING PLANT (33 Pages Follow)

Nuclear Management Company Nuclear Emergency Plan Annex Monticello Nuclear Generating Plant

Table of Contents Section 1: Introduction (NEP) ............................................................................................... 4 1.1 Facility Description (NEP) .................................................................................... 4 1.2 Emergency Planning Zones (NEP J.10)................................................................. 4 1.2.1 Plume Exposure Pathway (NEP J.10)............................................................ 4 1.2.2 Ingestion Pathway (NEP J) ............................................................................ 5 1.3 State of Minnesota (NEP A.2.1) ............................................................................ 5 1.3.1 Minnesota Department of Public Safety (DPS) (NEP A.2.1.1)..................... 5 1.3.2 Minnesota Department of Health (NEP A.2.1.2)........................................... 5 1.3.3 Minnesota State Patrol (NEP A.2.1) .............................................................. 5 1.3.4 Minnesota Department of Transportation (NEP A.2.1)................................. 5 1.3.5 Minnesota Department of Public Safety (NEP A.2.1)................................... 6 1.3.6 Wright County Sheriff (NEP A.2.1) .............................................................. 6 1.3.7 Sherburne County Sheriff (NEP A.2.3) ......................................................... 6 1.3.8 Monticello Civil Defense (NEP A.2.1).......................................................... 6 1.3.9 U.S. Department of Energy (DOE) (NEP A.1.3)........................................... 6 1.3.10 Area Civil Defense Groups (NEP A.2).......................................................... 7 Section 2: Organizational Control of Emergencies (NEP B.1).............................................. 8 2.1 Normal Plant Organization (NEP B.1.1) ............................................................... 8 2.2 Emergency Organization (NEP B.5)...................................................................... 8 2.3 Non-NMC Support Groups (NEP B.9, B.6.1.2) .................................................... 8 2.3.1 Fire Fighting (NEP B.9.4.1)........................................................................... 8 2.3.2 Hospital and Medical support (NEP B.9.3.1, L.1)......................................... 8 2.3.3 Ambulance Service (NEP B.9.2, L.4)............................................................ 9 2.3.4 General Electric Support (NEP B.8.1.1)........................................................ 9 2.3.5 Burlington-Northern and Santa Fe Railway (NEP B.8.3.4)........................... 9 2.3.6 Public Emergency Planning & Education (NEP G.1.1, G.2.1)...................... 9 2.3.7 Media Information (NEP G.3.1) .................................................................. 10 Section 3: Classification of Emergencies (NEP D.1) .......................................................... 11 3.1 Emergency Classifications: (NEP D.1)................................................................ 11 3.2 Determination of Levels: (NEP D.2) ................................................................... 11 Section 4: Emergency Measures (NEP E) ........................................................................... 12 4.1 Notification of the Emergency Organization (NEP E.2) ..................................... 12 4.1.1 Notification Scheme (NEP E.2.1)................................................................ 12 4.2 Assessment Actions (NEP I.2)............................................................................. 12 4.2.1 Determining Magnitude of Release (NEP I.2)............................................. 12 4.2.2 Dose Projections (NEP I.3).......................................................................... 12 4.2.3 Radiological Surveys (NEP I.7)................................................................... 13 4.3 Protective Actions for the Offsite Public (NEP J.7) ............................................ 13 4.3.1 Protective Action Recommendations (NEP J.7).......................................... 14 Protective Action Recommendation Flowchart ........................................................... 15 4.3.3 Public Alert and Notification System (PANS) (NEP E.6)........................... 16 2 of 33

4.3.4 Emergency Alert System Radios (NEP E.6)................................................ 16 4.4 Protective Actions for Onsite Personnel (NEP J.6) ............................................. 17 4.4.1 Onsite Respiratory Protection and Protective Clothing (NEP J.6) .............. 17 4.4.2 Potassium Iodide (NEP J.6) ......................................................................... 17 Section 5: Emergency Facilities and Equipment (NEP H) .................................................. 19 5.1 Emergency Response Facilities (NEP H) ............................................................ 19 5.1.1 Control Room (NEP H.1.1) ......................................................................... 19 5.1.2 Technical Support Center (TSC) (NEP H.1.2) ............................................ 19 5.1.3 Operations Support Center (OSC) (NEP H.1.3, H.9) .................................. 20 5.1.4 Emergency Operations Facility (EOF) (NEP H.1.4) ................................... 20 5.1.5 Backup EOF (NEP H.2)............................................................................... 21 5.1.6 Joint Information Center (JIC) (NEP B.7.8)................................................ 21 5.2 On-Site Communications (NEP F.1.1) ................................................................ 21 5.2.1 Emergency Response Data System (ERDS) (NEP E.2.4) ........................... 21 5.3 Offsite Communications (NEP F.1.1).................................................................. 22 5.3.1 Alternate Offsite Communications (NEP F.1.1).......................................... 22 5.4 Kits (NEP H.10)................................................................................................... 22 5.5 Facilities and Equipment for On-site Monitoring (NEP H.4).............................. 22 5.5.1 Safety Parameter Display System (SPDS) (NEP H.4.3.2)........................... 23 5.5.2 Geophysical Phenomena Monitors (NEP H.4) ............................................ 23 5.5.3 Radiological Monitors (NEP H.4) ............................................................... 23 5.5.4 Process Monitors (NEP H.4.3)..................................................................... 24 5.5.5 Fire Detection Devices (NEP H.4.4)............................................................ 24 5.5.6 Post-Accident Sample System (NEP H.4.2.2) ............................................. 24 5.6 Facilities and Equipment for Off-site Monitoring (NEP H.5) ............................. 24 5.6.1 Meteorological (NEP H.5.1) ........................................................................ 24 5.6.2 Offsite Geophysical Phenomena Monitors (NEP H.4.1) ............................. 25 5.6.3 Offsite Radiological Monitors (NEP H.4) ................................................... 25 5.6.4 Offsite Laboratory Facilities (NEP B.8.3.1, C.3.1, C.3.2, H.6.3)................ 26 5.7 Offsite Meteorological Equipment (NEP H.6.1) ................................................. 26 5.7.1 National Weather Service, Twin Cities Local Area (NEP H.6.1) ............... 26 5.8 Protective Facilities and Equipment (NEP J)....................................................... 26 5.8.1 Assembly Points (NEP J.1).......................................................................... 26 5.8.2 Fire Station (NEP B.9.4).............................................................................. 27 5.9 First Aid and Medical Supplies (NEP L.2).......................................................... 27 5.9.1 First Aid Center (NEP L.2).......................................................................... 27 5.9.2 First Aid Kits (NEP L.2).............................................................................. 27 5.9.3 Hospital and Medical Support (NEP B.9.3.1).............................................. 27 5.9.4 Ambulance Service (NEP B.9.2.1) .............................................................. 27 Appendix A: Evacuation Time Estimate study and map references (NEP J.8)................... 29 Appendix B: Initiating Condition Emergency Action Level (EAL) Scheme (NEP D.1).... 30 Appendix C: Plant Letters of Agreement (NEP A.3, P.6) ................................................... 32 Appendix D: Supporting Plans & Implementing Procedures (NEP P.5, P.7) ..................... 33 3 of 33

Section 1: Introduction (NEP)

As required in the conditions set forth by the Nuclear Regulatory Commission (NRC) for the operating licenses for the Nuclear Management Company (NMC)

Nuclear Power Plants, the management of NMC recognizes its responsibility and authority to operate and maintain these facilities in such a manner as to provide for the safety of the general public.

The NMC Emergency Preparedness Program consists of the NMC Nuclear Emergency Plan (NEP), Plant Annexes, emergency plan implementing procedures, and associated program administrative documents. The NEP outlines the basis for response actions that would be implemented in an emergency. Planning efforts common to all NMC Nuclear stations are encompassed within the NEP.

This document serves as the Monticello Nuclear Generating Plant (MNGP) Annex and contains information and guidance that is unique to that plant. This includes Emergency Action Levels (EALs), and facility geography, for a full understanding and representation of the stations emergency response capabilities. The Station Annex is subject to the same review and audit requirements as the NEP.

In any emergency situation at MNGP, the initial response would be made by the site staff and, if needed, by local support agencies. It is expected that the initial response would have to extend for a period of hours, by which time the site staff would be augmented by other segments of the overall NMC emergency response organization. Once all centers are activated and the emergency organization is at full strength, the scope of the plant staff response will be reduced to the immediate plant site activities. This Annex covers the actions and responsibilities of the MNGP plant staff and the local offsite support agencies.

1.1 Facility Description (NEP)

Monticello is located on a 2,100-acre plant site near Monticello, Minnesota, 40 miles northwest of Minneapolis/St. Paul. The site is divided between Sherburne and Wright counties. Cooling water is drawn from the Mississippi River. The plant is owned by Xcel Energy Inc., and operated by Nuclear Management Company. It is a one-unit, General Electric boiling water reactor which began commercial operation in June 1971. The plants Architect-Engineer and constructor was Bechtel.

1.2 Emergency Planning Zones (NEP J.10) 1.2.1 Plume Exposure Pathway (NEP J.10)

The 10-mile Emergency Planning Zone (EPZ) for MNGP approximates a 10-mile radius around the plant site. See Appendix A.

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1.2.2 Ingestion Pathway (NEP J)

The area between the 10-mile and 50-mile radius is considered the Ingestion Pathway EPZ. The principal exposure risk in this pathway would be from the ingestion of contaminated water, foods such as milk and vegetables, and, on a longer term, contaminated livestock feed. Depending upon the type of release and time, exposure may range from hours to months.

1.3 State of Minnesota (NEP A.2.1) 1.3.1 Minnesota Department of Public Safety (DPS) (NEP A.2.1.1)

The Minnesota DPS (Homeland Security, Emergency Management (HSEM) and Bureau of Criminal Apprehension have the responsibility for notification and coordination of Minnesota State Agencies in the event of a major radiological emergency at any Minnesota nuclear power plant. When notified by an affected nuclear plant of an emergency situation, the Minnesota duty officer will call the Minnesota Department of Health, the Governors Authorized Representative and other state agencies with emergency assignments to coordinate the implementation of emergency procedures. The various state emergency response agencies staff twenty-four hour emergency notification and communications systems.

1.3.2 Minnesota Department of Health (NEP A.2.1.2)

The Minnesota Department of Health (MDH) is responsible for providing radiological expertise in the State Emergency Operations Center in conjunction with the MN HSEM.

1.3.3 Minnesota State Patrol (NEP A.2.1)

The State Patrol may assist with the protection of the general public by providing personnel and equipment to re-route traffic in the event of a general emergency. Plans have been made for re-routing federal and state highways. Signs and equipment required for re-routing will be stored in the areas where they would be needed to facilitate highway closings.

1.3.4 Minnesota Department of Transportation (NEP A.2.1)

The Minnesota Department of Transportation will assist the State Patrol in blocking and re-routing traffic around the plant site. In 5 of 33

addition to the necessary personnel, vehicles, signals, barriers for setting up and maintaining detour routes. They also have radiation monitoring instruments available at each truck stop.

1.3.5 Minnesota Department of Public Safety (NEP A.2.1)

The Minnesota Department of Public Safety has the responsibility for notification and coordination of state agencies in the event of a major emergency at Monticello. In the event of an emergency situation at the plant, the State Emergency Operations Center is activated and the Minnesota Duty Officer will immediately call the Department of Health, Governors Office, and other state agencies with emergency assignments to coordinate the implementation of any emergency procedures. The state agencies responsible for emergency procedures have established a system of 24-hour communications.

1.3.6 Wright County Sheriff (NEP A.2.1)

In the event of an accident the Sheriff of Wright County will notify all necessary civil support groups in Wright County. He is also responsible for protection of the general public and can provide personnel and equipment for evacuation, relocation and isolation of affected areas.

1.3.7 Sherburne County Sheriff (NEP A.2.3)

In the event of an accident, the Sheriff of Sherburne County will notify all necessary civil support groups in Sherburne County. He is also responsible for protection of the general public and can provide personnel and equipment for evacuation, relocation and isolation of affected areas.

1.3.8 Monticello Civil Defense (NEP A.2.1)

The Monticello Civil Defense has the responsibility for coordination of city populace in the event of a major emergency that affects the city of Monticello.

1.3.9 U.S. Department of Energy (DOE) (NEP A.1.3)

Protection for the general public is provided through the Nuclear/Radiological Incident Annex of the National Response Plan.

Under this plan, individual DOE officers are assigned geographic responsibilities for incidents occurring in their region. Their immediate objective is to rapidly dispatch a team of specialists to the 6 of 33

incident site and assist the state in evaluating the hazard. The DOE will then provide the materials and equipment to counteract and control any acute hazard, and establish communications with local authorities.

1.3.10 Area Civil Defense Groups (NEP A.2)

Area Civil Defense Groups are responsible for protecting the general public and providing logistical support such as food, temporary quarters, water and sanitary facilities in the event that evacuation and isolation is required. The Civil Defense Group consists of a permanent staff plus a pool of reserve personnel, vehicles and radiological monitoring equipment, located throughout the State Emergency Services Mobile Support Area VI, in which Monticello is located.

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Section 2: Organizational Control of Emergencies (NEP B.1) 2.1 Normal Plant Organization (NEP B.1.1)

The normal plant operating crew is staffed and qualified to perform all actions that may be necessary to initiate immediate protective actions and to implement the emergency plan and is designated as the responsible group for such actions.

The Plant Manager has overall responsibility for the safe, efficient operation of the plant and for compliance with operating license requirements. The Plant Manager will select, train and supervise a qualified staff.

The Shift Manager reports directly to the Assistant Operations Manager who reports directly to the Operations Manager who reports directly to the Plant Manager. The Shift Manager is responsible for the direction and coordination of the Control Room Supervisors to perform operations in accordance with the administrative controls and operating procedures. The Shift Manager coordinates activities with other plant groups as required to maintain the safe operation of the plant.

The Control Room Supervisor reports to the Shift Manager. The Control Room Supervisor is the single focal point for directing and coordinating the operations group, maintenance group and the plant security activities during the assigned shift. The responsibility and authority of the Control Room Supervisor will be to maintain the broadest perspective of operational conditions affecting the safety of the plant as a matter of highest priority at all times when on duty in the Control Room.

2.2 Emergency Organization (NEP B.5)

The MNGP Emergency Response Organization is described in the NEP figures B.1.b through B.1.f.

2.3 Non-NMC Support Groups (NEP B.9, B.6.1.2) 2.3.1 Fire Fighting (NEP B.9.4.1)

The Monticello Fire Department will provide assistance upon request in the event of a fire at the plant.

2.3.2 Hospital and Medical support (NEP B.9.3.1, L.1)

The Monticello-Big Lake Community Hospital serves as the principal off-site medical facility for initial treatment of radiation complicated injury or illness. In addition, North Memorial Hospital 8 of 33

(in Minneapolis) has been designated as the definitive care center for injuries or illness that requires services/facilities that the local hospital is unable to provide. Emergency procedures have been established at both hospitals and training of hospital personnel is accomplished periodically.

Regions Hospital in St. Paul, Minnesota is designated as a definitive care center for Monticello Nuclear Generating Plant. Regions Hospital may be used for radiation casualties, severe burn casualties, and other non-radiation injuries with use of an appropriate medical air transport service.

2.3.3 Ambulance Service (NEP B.9.2, L.4)

There are two ambulance services that are available to provide service to the MNGP. A complete description of response capabilities, organizational resources, activation plans, designations of emergency operations centers and letters of agreement for the organizations mentioned above are available in the Minnesota Emergency Operations Plan.

2.3.4 General Electric Support (NEP B.8.1.1)

Provisions have been developed for activation of General Electrics BWR Nuclear Emergency Support Program. For procurement of services and equipment which require immediate processing, the emergency procurement process will be used to expedite the delivery of equipment or services. These procurements may be requested to support TSC engineering assessment and mitigation activities.

2.3.5 Burlington-Northern and Santa Fe Railway (NEP B.8.3.4)

The Burlington-Northern and Santa Fe Railway Dispatcher will stop and re-route trains away from the plant site, as necessary.

2.3.6 Public Emergency Planning & Education (NEP G.1.1, G.2.1)

NMC, in coordination with state, county and local officials, annually provides the general public, including transients, with information concerning the methods of public notification and what individual actions should be taken during an emergency. This information may include:

• Methods of public notification;

• Possible protective actions;

• General information as to the nature and effects of radiation; 9 of 33

• Contact points for additional information;

• Special needs for the handicapped;

• Registration cards for the mobility impaired.

Methods for disseminating the information may include calendars, brochures, annual publications, public postings and/or meetings.

Dissemination of information to the public is coordinated with state and local agencies.

2.3.7 Media Information (NEP G.3.1)

The Xcel Energy Communications Department has a program designed to ensure prompt communications between Xcel Energy or NMC and principal media organizations.

The State of Minnesota is responsible to conduct annual training programs or send mailings to acquaint the news media with the emergency plans and to provide information concerning radiation and points of contact for release of public information in an emergency. NMC has input to this process.

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Section 3: Classification of Emergencies (NEP D.1) 3.1 Emergency Classifications: (NEP D.1)

Four classes of Emergency Action Levels are considered according to severity, taking into consideration potential, as well as actual, events in progress. They are, from the least to the most serious, Unusual Event, Alert, Site Area Emergency, and General Emergency. Initiating Conditions (ICs),

which determine which level will be declared, are predetermined subsets of plant conditions where the potential exists for a radiological emergency, or such an emergency has occurred. Emergency Action Levels (EALs) are plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions.

3.2 Determination of Levels: (NEP D.2)

Appendix B to this Annex contains the matrix for Initiating Conditions used to determine an Emergency Action Level (EAL). They are part of the scheme established by NEI 99-01 (NUMARC/NESP-007). The EAL scheme also reflects the NRCs security-based event EALs communicated in NRC Bulletin 2005-02.

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Section 4: Emergency Measures (NEP E) 4.1 Notification of the Emergency Organization (NEP E.2)

When an abnormal condition is identified by the shift operating staff the duty Control Room Supervisor and Shift Manager are notified. An assessment of the safety significance of the event is performed and a determination of the emergency classification made using the Emergency Action Levels (EALs).

Upon declaring an emergency condition, the Shift Manager (or Shift Supervisor if no Shift Manager is available) is responsible for implementation of the Emergency Plan and assumes the role of Emergency Director. The Shift Manager directs the completion of the necessary emergency notifications including notification of the on-site Emergency Response Organization.

4.1.1 Notification Scheme (NEP E.2.1)

When directed, the Shift Emergency Communicator notifies the site Emergency Response Organization. ERO notification is made using the plant public address system, an automated dialing system, and the pager network.

4.2 Assessment Actions (NEP I.2) 4.2.1 Determining Magnitude of Release (NEP I.2)

The magnitude of releases and release rates from normal pathways are determined using installed plant instrumentation. Installed samplers and wide-range radiation monitors normally monitor plant effluent releases, and would be the primary method used in an emergency. Field measurements will be used to assist in the assessment effort by making physical measurements of dose rates and airborne, liquid and surface contamination.

4.2.2 Dose Projections (NEP I.3)

Dose projections will be performed by a computerized dose assessment system designed to perform dose assessments during the inadvertent release of radioactive materials. Dose assessment software is installed on computers located in the Control Room, TSC, EOF, and Backup EOF.

The effluent monitor reading and the vent flow rate result in a release rate. With meteorological and effluent release data available, 12 of 33

calculations of atmospheric dispersion and offsite radiation dose from the plume can be made. Dose calculations are made for Total Effective Dose Equivalents (TEDE) and Thyroid Committed Dose Equivalents (Thyroid CDE). Results of all calculations can be printed in report format and, displayed graphically. This gives a display in which the plume overlays the region of potential highest dose.

The dose assessment software allows quick accident dose calculations to be made, before any results from the Radiation Survey Teams are received. Radiation Survey Team results will be used to verify the dose calculations.

In case of potential release from the containment, the activity available for a release may be obtained using the containment monitor reading and time since shutdown. The dose assessment software can estimate a release rate and offsite dose calculation within the plume exposure pathway. The activity available in containment may also be obtained directly from sample analysis.

The containment monitors are also used as indicators for relative amounts of core damage. The indicated radiation levels in the containment gives an estimate of the gaseous radioactive concentrations in containment. Using the time after shutdown and the radiation levels, an estimate of the relative amount of core damage may be made.

The capability for remote interrogation of the meteorological data will be provided to NRC by the Emergency Response Data System (ERDS). Atmospheric stability class and weather forecast information is available from the National Weather Service.

4.2.3 Radiological Surveys (NEP I.7)

The task of field radiation surveillance will be accomplished by teams under the supervision of Emergency Operations Facility (EOF) personnel. Initially, plant staff personnel will be responsible for on-site as well as off-site monitoring. As the organization is augmented, plant personnel from the Prairie Island Nuclear Generating Plant (PINGP) will take over the off-site surveys. The EOF will be the central point for receipt of off-site field monitoring samples. Survey teams are equipped with appropriate monitoring equipment, including dose rate instruments, air sampling equipment and sample collection media and containers.

4.3 Protective Actions for the Offsite Public (NEP J.7) 13 of 33

The primary protective actions for the offsite population are sheltering or evacuation. The Emergency Director/Emergency Manager will recommend the necessary protective actions to offsite authorities based on predetermined protective actions for a General Emergency Classification or results of offsite dose assessment. Upon activation of the EOF, the Emergency Manager will be responsible for recommending protective actions for the offsite population. If protective actions are warranted prior to augmentation of state emergency response organizations, the Emergency Manager will recommend directly to county authorities the necessary protective actions. Responsibility for carrying out the protective actions rests with offsite authorities.

4.3.1 Protective Action Recommendations (NEP J.7)

Recommendations for the offsite public are determined from plant conditions and dose projections provided on the following decision chart:

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Protective Action Recommendation Flowchart Event Yes '\

Does a General Emergeny exist?

Mn Continue to monitor plant and radiological mnr(binnc

.\

IS there an ongoing At a minimum, evacuate and the EPA PAGs to the environment due to the public take KI if available in the 2-I mile radius and the affected sub-areas 5 miles downwind.

A Is it known with duration will be < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Advise the remainder of the EPZ to go indoor and monitor EAS local authorities to shelter population Yes and the affected subareas 5 miles downwind.

NOTE 2 Sheltering may be the appropriate action for controlled releases from containment if there is assurance that the release is short term (puff release) and the area near the plant cannot be evacuated before the plume arrives.

4.3.2 Notification of Off-Site Agencies (NEP E.2.3)

The incident report form provides for message verification and information for the initial and follow-up messages. The initial messages contain information about:

• Location of incident;

• Name of caller, date/time of incident;

• Class of emergency;

• Release status;

• Potentially affected population and areas;

• Protective Action Recommendations.

The follow-up messages contain the basic information from the initial message with the following additional information, if it is known and appropriate:

• Type and form of any actual or projected radiological release;

• Meteorological conditions;

• Actual or projected doses in the affected sector(s);

• Emergency response actions in progress;

• Requests made for any needed onsite support.

4.3.3 Public Alert and Notification System (PANS) (NEP E.6)

Within the Plume Exposure Emergency Planning Zone (EPZ) there exist provisions for alerting and providing notification to the public.

The state and/or local authorities are responsible for activation of this system.

The Monticello Nuclear Generating Plant has developed a fixed siren system designed for essentially 100% coverage of the population within the EPZ. Sirens installed by MNGP have been sited according to FEMA-REP-10 criterion to ensure the required coverage. Provisions for transient population notification are also included in State and County plans.

4.3.4 Emergency Alert System Radios (NEP E.6)

To further ensure prompt notification, Emergency Alert System (EAS) radios have been installed in various commercial, institutional, and education facilities in the 10 mile zone. These locations may harbor large groups of people during all or part of a day. Emergency Alert System radios will be activated by the National Weather Service of the National Oceanic and Atmospheric Administration (NOAA) or local counties.

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In the event of an emergency condition, alert and notification information will be relayed through established communication links described in the Minnesota Emergency Response Plan. Upon receiving notification of the emergency, state and local governments will, if necessary, activate public warning and information procedures which include the State Emergency Alert System (EAS).

4.4 Protective Actions for Onsite Personnel (NEP J.6)

The primary protective measure for non-essential onsite personnel during a Site Area or General Emergency, is evacuation to a suitable assembly area where the personnel can be accounted for and monitored for contamination.

The Control Room personnel will sound the evacuation alarm and announce the designated assembly area. All non-essential personnel will evacuate to the designated assembly area. The plant security force will assist in the evacuation. The security force will perform a check of the Owner Controlled Area and warn all personnel of the evacuation in progress. Once non-essential personnel are accounted for and monitored for contamination, as necessary, they may be released from the assembly area. The Emergency Director will release non-essential personnel for departure from the site when procedurally required or when conditions allow.

Radiation Protection personnel, extra onshift operators, and Maintenance personnel will report to the Operations Support Center.

4.4.1 Onsite Respiratory Protection and Protective Clothing (NEP J.6)

Protective clothing or respiratory protection for onsite personnel will be as designated by the Radiation Protection Group or the TSC Director.

Respiratory Protection will be used as necessary to reduce the inhalation of radioactive material. During emergency conditions, it may become impossible to maintain normal respiratory protection guidelines. An internal exposure program, whole body counting and/or bioassay program, will be used to ensure that all internal exposure is determined as assigned to the individual. The respiratory equipment available is a combination of Self Contained Breathing Apparatus (SCBAs), and full face canister respirators. The Radiation Protection Group will make decisions on the use of protective clothing and respiratory protection equipment during emergency situations.

4.4.2 Potassium Iodide (NEP J.6) 17 of 33

A supply of potassium iodide (KI) will be maintained at the Technical Support Center and the Emergency Operations Facility.

In the event that an individual is expected to receive a dose to the thyroid in excess of 25 Rem, due to radioiodine uptake, the use of KI as a blocking agent may be recommended.

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Section 5: Emergency Facilities and Equipment (NEP H) 5.1 Emergency Response Facilities (NEP H) 5.1.1 Control Room (NEP H.1.1)

The Control Room contains the necessary instrumentation, both process and radiological, to evaluate plant conditions, as detailed in the plant Updated Final Safety Analysis Report. Habitability is maintained by shielding and the Emergency Filtration Train (EFT) ventilation system, which is capable of operating in a cleanup or recycle mode. All emergency equipment is supplied power from the emergency diesel generators with vital instrumentation powered from inverters connected to the storage batteries located in the battery rooms.

The plant instrumentation and monitors perform indicating, recording and protective functions. The regulating systems provide the ability to regulate the plant safely from shutdown to full power and to monitor and maintain key variables such as reactor power, steam flow, temperature and radioactivity levels within predetermined safe limits during both steady state and plant transients. Plant instrumentation and control systems also provide means to cope with abnormal operating conditions. The control and display of information of these various systems are centralized in the main Control Room.

5.1.2 Technical Support Center (TSC) (NEP H.1.2)

The Technical Support Center (TSC) serves as a center outside of the Control Room that relieves the Shift Manager of the command and control functions of organizing and coordinating on-site emergency efforts. Plant status and diagnostic information will be available at this location for use by technical and management personnel in support of reactor command and control functions.

The TSC is located on 1st Floor of the Plant Engineering Building (PEB) with an area of approximately 5700 sq. ft.. The normal power source for the 480V equipment in the TSC is from the 480V Plant Engineering Building (PEB) Distribution Panel (DP). The secondary power source is from a 480V Load Center, backed up by a diesel generator. The normal and secondary power sources will supply power for the TSC HVAC system and the TSC emergency lighting.

The TSC has access to SPDS.

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Phone and computer network service is provided directly from the MNGP main phone switch room and computer data center to the electrical/data closet. Phone and network wiring feeds the TSC equipment from this closet. The system is powered by a UPS and diesel-backed power supply, with a different diesel-backed alternate power source also available. Equipment is available to support offsite radiological dose assessment via SPDS and ERDS terminals, and monitoring offsite radiological field team results via Field Team Radio links.

The TSC is within the controlled ventilation boundary of the Emergency Ventilation System (EVS), with an available Continuous Air Monitor. A supply of potassium iodide (KI) will be maintained at the TSC. An emergency equipment locker is located in the TSC for protective, anti-contamination clothing for TSC personnel.

5.1.3 Operations Support Center (OSC) (NEP H.1.3, H.9)

The OSC functions as the staging area from which emergency teams are dispatched. The primary OSC is located on the first level of the Plant Administration Building within the Maintenance department offices, outside a filtered ventilation boundary.

Emergency equipment lockers, located in the primary OSC, contain protective clothing for OSC emergency team personnel. This equipment is transported to the Backup OSC if the primary OSC becomes uninhabitable.

5.1.4 Emergency Operations Facility (EOF) (NEP H.1.4)

In the event of an Alert, Site Area Emergency, or a General Emergency, the Emergency Operations Facility (EOF) will be activated.

The EOF is in the Training Center building. The EOF is constructed in a manner which provides habitability in an accident situation.

Shielding and ventilation treatment systems have been installed to maintain an acceptable environment. The ventilation system has an emergency mode of operation that will pressurize the building through a High Efficiency Particulate Absolute (HEPA) filtration system.

The general layout of the buildings entrances and exits has been given consideration for operation of the building in an emergency mode. Radiological monitoring and alarms are provided for the EOF portion of the building.

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Extensive communications equipment is installed to provide primary and backup methods of communicating with plant Emergency Response Facilities, utility headquarters, offsite agencies and utility Field Monitoring teams. Critical plant parameter data is available in the EOF through the plant SPDS. Meteorological data and offsite dose projection capabilities are provided.

5.1.5 Backup EOF (NEP H.2)

The Backup EOF is located at the Xcel Energy corporate office in downtown Minneapolis, 45 miles southeast of the plant. In the event the primary EOF became uninhabitable, the functions of the EOF would be transferred to the Backup EOF.

Extensive communications equipment is installed to provide primary and backup methods of communicating with plant emergency Response Facilities, offsite agencies and utility Field Monitoring teams. Critical plant parameter data is available in the Backup EOF through the plant Emergency Response Display System (ERDS).

Meteorological data and offsite dose projection capabilities are provided.

5.1.6 Joint Information Center (JIC) (NEP B.7.8)

The State of Minnesota has established a JIC, which will be activated jointly with the State EOC. The JIC is located in the Minneapolis-Saint Paul metropolitan area, accessible to the major Minnesota news media.

5.2 On-Site Communications (NEP F.1.1)

Normal on-site communications is provided by the plant telephone system.

The system is powered by a highly reliable, UPS and diesel-backed power supply, with a different diesel-backed alternate power source also available.

The plant Public Address (PA) system may also be used for in-plant communications. The PA system is powered by normal plant power, backed up by uninterruptible power.

Portable radios are used for communications between individuals and base stations located in the Control Room, TSC, EOF, and Security Building.

There is also a plant intercom system. Intercom units are installed at selected plant locations primarily for specific task related activities.

5.2.1 Emergency Response Data System (ERDS) (NEP E.2.4) 21 of 33

This computer/telephone network is an electronic data link between the plants on-site computer system and the NRC Operations Center that provides for the automated transmission of a limited data set of selected parameters. The ERDS supplements the existing voice transmission over the ENS.

5.3 Offsite Communications (NEP F.1.1)

Normal offsite communications are provided by the following telephone circuits:

• Two-way central office lines (TDS Telecom);

• Digital tie-lines to Minneapolis via fiber optic data link;

• Digital tie-lines to the Monticello Training Center (PBX);

• Direct inward dial trunks (TDS Telecom).

5.3.1 Alternate Offsite Communications (NEP F.1.1)

An alternate method for communications is provided by an AC powered radio transceiver with control consoles located in the TSC, Control Room and EOF. From either console, communications may be established with the EOF, Sherburne and Wright County Sheriffs, Plant Security, Operations and Radiation Protection portable radios, and the Xcel Energy System Control Center.

Radio links exist for communications between the State Division of Emergency Management and the Control Room, TSC, EOF, and Backup EOF.

5.4 Kits (NEP H.10)

Designated Emergency Lockers contain emergency survey kits, which include portable instruments, battery operated air samplers, liquid sampling equipment, and communication equipment. A spare Field Survey Team Equipment Kit is located at the EOF.

When facilities at access control are not available, the assembly area emergency lockers contain equipment for personnel decontamination and personnel monitoring. The decontamination kits contain oxidizing agents for decontamination of the skin due to radioiodines.

First aid kits are located at the primary emergency centers and at various emergency lockers in the plant.

5.5 Facilities and Equipment for On-site Monitoring (NEP H.4) 22 of 33

The plant instrumentation and monitors perform indicating, recording and protective functions. The Reactor Protection System and associated plant instrumentation provide the ability to maintain plant safety from shutdown to full power operations and to monitor and maintain key variables such as reactor power, flow, temperature, and radioactivity levels within predetermined safe limits at both steady state conditions and during plant transients. Plant instrumentation and control systems also provide means to cope with abnormal operating conditions. The control and display of information of these various systems are centralized in the main Control Room. This instrumentation would provide the basis for initiation of protective actions.

5.5.1 Safety Parameter Display System (SPDS) (NEP H.4.3.2)

Normal and emergency data acquisition is made available via the plant computer system. The system displays information equivalent to that required by the Safety Parameter Display System (SPDS).

5.5.2 Geophysical Phenomena Monitors (NEP H.4)

The Seismic Monitoring System is made up of three independent sensing systems: the peak-recording accelerometers, the seismic-switch-activated annunciator system and the accelerograph recording system. The peak-recording accelerometers and the sensors for the accelerograph system are located in the drywell, on the refueling floor and in the seismic shed.

Seismic events are indicated on Control Room annunciators as follows:

• Earthquake is initiated by either seismic switch of the Seismic Annunciator System or the seismic trigger of the accelerograph recording system;

• Operational Basis Earthquake OBE;

• Design Basis Earthquake DBE.

The accelerograph recording system gives a more detailed record of a disturbance than the peak recording accelerometers - it records accelerations in three directions (longitudinal, transverse, and vertical) from each of the three sensor locations on magnetic tape cartridges located in the Control Room.

Hydrological Monitoring: River water level is sensed at the intake structure.

5.5.3 Radiological Monitors (NEP H.4) 23 of 33

The function of the process radiation monitoring system is to provide a continuous monitoring and readout of the radioactivity of all process lines and vents that can release radioactivity directly to the environs. In addition, this system also continuously measures, indicates and records the radioactivity concentration levels of in-plant process streams and vents.

5.5.4 Process Monitors (NEP H.4.3)

Adequate instrumentation monitoring capability exists to properly access the plant status during all modes of operation, as detailed in the Updated Final Safety Analysis Report (UFSAR).

5.5.5 Fire Detection Devices (NEP H.4.4)

Fire detectors (smoke, heat, and flame) are located in most areas of the plant. The detectors in each area initiate an alarm locally and in the Control Room upon detecting either combustion or a failure in the detector system. Detectors in certain areas of the plant will activate their respective sprinkler systems. The Heat Activated Device (HAD) System detects the heat from a fire.

5.5.6 Post-Accident Sample System (NEP H.4.2.2)

The Post-Accident Sample System (PASS) was designed to provide a means of assessing core damage during and after a loss-of-coolant accident. The facility is located outside of secondary containment to enhance accessibility. Local shielding and area radiation monitoring are also provided to protect the operator.

The capabilities of the system include:

• Large and small volume liquid coolant samples from jet pumps A and B and RHR pumps A and B;

• Gas samples from drywell and torus.

5.6 Facilities and Equipment for Off-site Monitoring (NEP H.5) 5.6.1 Meteorological (NEP H.5.1)

The purpose of the meteorological monitoring system is to monitor and determine atmospheric dilution and dispersion parameters for the Monticello Plant site. The meteorological monitoring system consists of an instrumented tower, associated signal transmission and 24 of 33

processing equipment, two AC power sources, and battery backup power supplies.

The meteorological tower is located on the plant site east of the Reactor Building. It consists of a 100 meter guyed steel tower with a climate controlled instrument shelter at its base. The instrument platforms are located at 10, 43 and 100 meters. Each platform has two independent sets of instrumentation. Each instrument set includes one combination wind speed and direction sensor and one RTD temperature probe. Wind speed and direction transmitters are provided with heater elements to reduce the potential of becoming inoperable during low temperature conditions. The temperature sensors are housed in forced air, shielded aspirators which include air flow sensors. Insufficient air flow and motor inoperability indicator lights are provided in the instrument shelter. Signal transmission lines from the sensors to the instrument shelter junction box are provided with power surge protection and the tower is equipped with lightning rods and is grounded.

Both sets of sensors and related instrumentation normally receive power from one of two AC power sources. Transfer of power sources may be accomplished manually in the event of a loss of the normal AC power supply. In addition, an Uninterruptible Power Supply (UPS) is provided in the event manual transfer of the AC power supplies does not occur.

Meteorological data from one train of sensors on the tower is provided as digital averages in the Control Room. Displays of current and 15 minute running average meteorological data from a sensor train on the tower is simultaneously available on terminals in both the TSC and EOF.

5.6.2 Offsite Geophysical Phenomena Monitors (NEP H.4.1)

In the event that a seismic disturbance is indicated by on-site detection equipment, confirm of the validity and/or intensity of the disturbance by contacting one of several off-site sources. Off-site sources include:

• Prairie Island Nuclear Plant (Located near Red Wing, Minnesota);

• National Earthquake Information Service (Golden, Colorado).

5.6.3 Offsite Radiological Monitors (NEP H.4) 25 of 33

The MNGP off-site radiation monitoring program includes TLD stations which are located in the general areas of the site boundary, in an outer ring, in special interest areas, and in control stations, many miles from the plant. Also included in the program is a group of air monitoring stations positioned on the site boundary and in the city of Monticello. The program, known as the Radiological Environmental Monitoring Program (REMP), is administered at the Site. A complete description of the program is in the Offsite Dose Calculation Manual (ODCM).

5.6.4 Offsite Laboratory Facilities (NEP B.8.3.1, C.3.1, C.3.2, H.6.3)

In the event that the lab facilities on-site become unusable or overloaded, Backup facilities are available. The chemistry labs at Prairie Island are available for chemical analysis work. For radiochemical analysis, the Backup count room at the EOF is equipped with a multi-channel analyzer and gross beta counting equipment. The counting facilities at the Prairie Island Nuclear Generating Plant are also available, if needed.

5.7 Offsite Meteorological Equipment (NEP H.6.1) 5.7.1 National Weather Service, Twin Cities Local Area (NEP H.6.1)

In addition to the site meteorological monitoring system, regional meteorological data is available through the National Weather Service by commercial telephone. The National Weather Service, Twin Cities Local Area, provides:

• Temperature;

• Wind Direction;

• Wind Speed;

• Stability Class.

5.8 Protective Facilities and Equipment (NEP J) 5.8.1 Assembly Points (NEP J.1)

In the event of a plant evacuation, the On-Site Assembly Point (or an Off-Site Assembly Point, as appropriate) will be activated. The function of the assembly point is to provide a center for personnel accountability and radiological contamination screening along with any other immediately necessary actions.

The On-Site Assembly Point is located approximately 1000 feet south of the plant, within the Site Administration Building. This 26 of 33

structure offers shelter, but does not have special ventilation or shielding properties. An emergency equipment locker at the assembly point contains a supply of emergency equipment and protective clothing.

5.8.2 Fire Station (NEP B.9.4)

A full line of fire fighting equipment and supplies is available for damage control operations. The equipment is stored in the Fire Brigade Room adjacent to the Main Access Control area in addition to various areas within the plant for easy access and quick response to fires.

5.9 First Aid and Medical Supplies (NEP L.2) 5.9.1 First Aid Center (NEP L.2)

A decontamination shower and first aid supplies are located in the Main Access Control area in the lower level of the Plant Administration Building. Immediate and temporary care may be given to a victim in this area. If the injury involves contamination that cannot be removed without causing further injury, steps will be taken to minimize the spread of contamination until medical assistance arrives or until the victim has been transported to the hospital.

5.9.2 First Aid Kits (NEP L.2)

First Aid kits are located in the Fire Brigade Room at Main Access Control, Work Execution Center and various other areas on the plant site. Stretchers and shock blankets are located on each level of the Containment Building, Turbine Building and Main Access Control.

5.9.3 Hospital and Medical Support (NEP B.9.3.1)

The Monticello-Big Lake Community Hospital serves as the principal off-site medical facility for initial treatment of radiation complicated injury or illness. In addition, North Memorial Hospital (in Minneapolis) has been designated as the definitive care center for injuries or illness that requires services/facilities that the local hospital is unable to provide. Emergency procedures have been established at both hospitals and training of hospital personnel is accomplished periodically.

5.9.4 Ambulance Service (NEP B.9.2.1) 27 of 33

There are two ambulance services that are available to provide service to the Monticello Nuclear Generating Plant (MNGP). A complete description of response capabilities, organizational resources, activation plans, designations of emergency operations centers and letters of agreement for the organizations mentioned above are available in the Minnesota Emergency Operations Plan.

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Appendix A: Evacuation Time Estimate study and map references (NEP J.8)

A Monticello Nuclear Generating Plant evacuation time estimate study, Evacuation Time Estimate Study For The Monticello Nuclear Generating Plant Emergency Planning Zone, Dated: November 11, 2003, was prepared by Tom Cod Data Systems, 207 West Water Street, Suite 1, Decorah, IA 52101. The complete study is on file.

The Monticello Nuclear Generating Plant has detailed maps showing the 10-mile and 50-mile Emergency Planning Zones, Evacuation Routes, Radiological Sampling and Monitoring Points, and Traffic Control Points. These maps are maintained by the State of Minnesota and periodically updated as needed.

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Appendix B: Initiating Condition Emergency Action Level (EAL) Scheme (NEP D.1)

General Emergency Site Area Emergency Alert Unusual Event RG1 Off-Site Dose Resulting RS1 Off-Site Dose Resulting from RA1 Any UNPLANNED Release RU1 Any UNPLANNED Release of Gaseous or from any Actual or imminent any Actual or imminent of Gaseous or Liquid Liquid Radioactivity to the Environment that Release of Gaseous Release of Gaseous Radioactivity to the Exceeds Two Times the Offsite Dose Radioactivity Exceeds 1000 Radioactivity Exceeds 100 Environment that Exceeds 20 Calculation Manual Specification for 60 mRem TEDE or 5000 mRem TEDE or 500 mRem Times the Offsite Dose Minutes or Longer.

mRem. Thyroid CDE for the Thyroid CDE for the Actual or Calculation Manual Actual or Projected Duration Projected Duration of the Specification for 15 Minutes of the Release Using Actual Release or Longer.

Meteorology RA2 Damage to Irradiated Fuel or RU2 Unexpected Increase in Plant Radiation.

Loss of Water Level that Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel.

RA3 Release of Radioactive Material or Increases in Radiation Levels Within the Facility That Impedes Operation of Systems Required to Maintain Safe Operations or to Establish or Maintain Cold Shutdown.

HA1 Natural and Destructive HU1 Natural and Destructive Phenomena Affecting Phenomena Affecting the the PROTECTED AREA.

Plant VITAL AREA.

HA2 FIRE or EXPLOSION HU2 FIRE Within PROTECTED AREA Boundary Affecting the Operability of Not Extinguished Within 15 Minutes of Plant Safety Systems Required Detection.

to Establish or Maintain Safe Shutdown.

HA3 Release of Toxic or HU3 Release of Toxic or Flammable Gases Deemed Flammable Gases Within or Detrimental to Normal Operation of the Plant.

Contiguous to a VITAL AREA Which Jeopardizes Operation of Systems Required to Maintain Safe Operations or Establish or Maintain Safe Shutdown.

HG1 Security Event Resulting in HS1 Confirmed Security Event in a HA4 Confirmed Security Event in a HU4 Confirmed Security Event Which Indicates a Loss of Physical Control of Plant VITAL AREA. Plant PROTECTED AREA. Potential Degradation in the Level of Safety of the the Plant.

Facility.

HS4 Site Attack. HA7 Notification of an Airborne Attack Threat.

HA8 Notification of HOSTILE ACTION within the OCA.

HS2 Control Room Evacuation Has HA5 Control Room Evacuation Has Been Initiated and Plant Been Initiated.

Control Cannot Be Established.

HG2 Other Conditions Existing HS3 Other Conditions Existing HA6 Other Conditions Existing HU5 Other Conditions Existing Which in the Which in the Judgment of Which in the Judgment of the Which in the Judgment of the Judgment of the the Emergency Director Emergency Director Warrant Emergency Director Warrant Emergency Director Warrant Declaration of a Warrant Declaration of Declaration of Site Area Declaration of an Alert. UE.

General Emergency. Emergency.

SG1 Prolonged Loss of All SS1 Loss of All Offsite Power and SA5 AC power capability to SU1 Loss of All Offsite Power to Safeguards Buses Offsite Power and Prolonged Loss of All Onsite AC Power Safeguards Buses reduced to a for GREATER Loss of All Onsite AC to Essential Buses. single THAN 15 Minutes.

Power to Essential Buses. power source for GREATER THAN 15 minutes such that any additional single failure would result in station blackout.

SS3 Loss of All Vital DC Power. SU2 Inability to Reach Required Shutdown Within Technical Specification Limits.

SG2 Failure of the Reactor SS2 Failure of Reactor Protection SA2 Failure of Reactor Protection SU3 UNPLANNED Loss of Most or All Safety Protection System to System Instrumentation to System Instrumentation to System Annunciation or Indication in the Complete an Automatic Complete or Initiate an Complete or Initiate an Control Room for Greater Than 15 minutes.

Scram and Manual Scram Automatic Reactor Scram Automatic Reactor Scram was NOT Successful and Once a Reactor Protection Once a Reactor Protection There is Indication of an System Setpoint Has Been System Setpoint Has Been Extreme Challenge to the Exceeded and Manual Scram Exceeded and Manual Scram Ability to Cool the Core. Was NOT Successful. Was Successful.

SS4 Complete Loss of Heat SU6 UNPLANNED Loss of All Onsite or Offsite Removal Capability. Communications Capabilities.

SS6 Inability to Monitor a SA4 UNPLANNED Loss of Most SU4 Fuel Clad Degradation.

SIGNIFICANT TRANSIENT or All Safety System in Progress. Annunciation or Indication in Control Room With Either (1) a SIGNIFICANT TRANSIENT in Progress, or (2) Compensatory Non-Alarming Indicators are Unavailable.

SU5 RCS Leakage.

SU8 Inadvertent Criticality.

FG1 Loss of ANY two Barriers FS1 Loss or Potential Loss of ANY FA1 ANY Loss or ANY Potential FU1 ANY Loss or ANY Potential Loss of AND Loss or Potential Loss two Barriers. Loss of EITHER Fuel Clad Containment.

of Third Barrier. OR RCS.

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CA3 Loss of All Offsite Power and CU3 Loss of All Offsite Power to Essential Buses Loss of All Onsite AC Power for GREATER THAN 15 Minutes.

to Essential Buses.

CU7 UNPLANNED Loss of Required DC Power for GREATER THAN15 Minutes.

CG1 Loss of RPV Inventory CS1 Loss of RPV Inventory CA1 Loss of RCS Inventory.

Affecting Fuel Clad Integrity Affecting Core Decay Heat with Removal Capability.

Containment Challenged with Irradiated Fuel in the RPV.

CS2 Loss of RPV Inventory CA2 Loss of RPV Inventory with CU2 UNPLANNED Loss of RCS Inventory with Affecting Core Decay Heat Irradiated Fuel in the RPV. Irradiated Fuel in Removal the RPV.

Capability with Irradiated Fuel in the RPV.

CA4 Inability to Maintain Plant in CU4 UNPLANNED Loss of Decay Heat Removal Cold Shutdown with Capability with Irradiated Fuel in the RPV. Irradiated Fuel in the RPV.

CU6 UNPLANNED Loss of All Onsite or Offsite Communications Capabilities.

CU5 Fuel Clad Degradation.

CU1 RCS Leakage.

CU8 Inadvertent Criticality.

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Appendix C: Plant Letters of Agreement (NEP A.3, P.6)

• Institute of Nuclear Power Operations (INPO)

• State of Minnesota

• Regions Hospital

• Environmental, Inc. Midwest Laboratory

• Pooled Inventory Management

• Canadian Pacific Railway System

• DOE-Radiation Emergency Assistance Center/Training Site

• North Memorial Health Care

• General Electric

• Monticello-Big Lake Community Hospital & Ambulance Service (Transfer Agreement with U of M Hospital)

• Sherburne County Emergency Services

• Wright County Civil Defense

• Monticello Fire Department (Memorandum of Understanding with Monticello Plant)

The Letters of Agreement are maintained on file at MNGP.

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Appendix D: Supporting Plans & Implementing Procedures (NEP P.5, P.7)

• State of Minnesota Emergency Operations Plan.

• Wright County Emergency Response Plan for the Monticello Nuclear Generating Plant.

• Sherburne County Emergency Response Plan for the Monticello Nuclear Generating Plant.

Emergency Plan Implementing Procedures A complete listing of Emergency Plan Implementing Procedures (EPIPs) will be provided when developed to support the NMC Emergency Plan and Monticello Nuclear Generating Plant Annex.

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