ML14029A056

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Enclosure 1 to 13-495A - Permanently Defueled Emergency Plan
ML14029A056
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 01/16/2014
From:
Dominion Energy Kewaunee
To:
Office of Nuclear Reactor Regulation
References
13-495A
Download: ML14029A056 (31)
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Text

Serial No. 13-495A ENCLOSURE 1 LICENSE AMENDMENT REQUEST 257:

PERMANENTLY DEFUELED EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME PERMANENTLY DEFUELED EMERGENCY PLAN KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

WDominion

Title:

Permanently Defueled Emergency Plan (PDEP)

Revision Number Effective Date 0 DRAFT F TBD Revision Summary:

Permanently Defueled Emergency Plan (PDEP) describes the station's plan for responding to emergencies that may arise at Kewaunee Power Station while in a permanently shutdown and defueled configuration.

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Table of Contents Section Title Page 1.0 Introduction 1 1.1 Purpose 1.2 Scope 2.0 Discussion 2 2.1 Overview of Permanently Defueled Emergency Plan (PDEP) 2.2 Facility Description 3.0 Definitions and Acronyms 3 4.0 References 5 5.0 Emergency Conditions 6 5.1 Emergency Classification System 5.2 Spectrum of Postulated Accidents 6.0 Organizational Control of Emergencies 8 6.1 On-Shift Positions 6.2 ERO Augmented Positions 6.3 Functional Responsibilities 6.4 Support Services 6.5 Public Information 7.0 Emergency Measures 13 7.1 Notification and Activation 7.2 Assessment Actions 7.3 Corrective Actions 7.4 Protective Actions 7.5 Medical Transport and Treatment 8.0 Emergency Equipment and Facilities 17 8.1 Emergency Response Facilities 8.2 Communication Systems 8.3 Assessment Facilities and Equipment 8.4 First Aid and Medical Facilities 8.5 Protective Equipment and Supplies toc -2 REV. 0 DRAFT F

9.0 Maintaining Emergency Preparedness 20 9.1 Emergency Preparedness Responsibilities 9.2 Emergency Response Personnel Training 9.3 Exercises / Drills 9.4 Review and Updating of the PDEP and Emergency Plan Implementing Procedures 9.5 Maintenance and Inventory of Emergency Equipment and Supplies 10.0 Plant Recovery 25 10.1 Plant Recovery Organization 10.2 Plant Recovery Operations 10.3 Plant Recovery Termination Appendix Emergency Equipment, Supplies and Reference Materials 27 A

List of Tables Section Table Title Page 7 7-1 Response Worker Guidelines 16 List of Figures Section Figure Title Page 6 6-1 On-Shift and Emergency Response Organization Positions 12 toc -3 REV. 0 DRAFT F

1.0 INTRODUCTION

The Permanently Defueled Emergency Plan (PDEP) describes the station's plan for responding to emergencies that may arise at Kewaunee Power Station while in a permanently shutdown and defueled configuration. Irradiated fuel is stored in the Independent Spent Fuel Storage Installation (ISFSI) and in the Spent Fuel Pool. In this condition, no reactor operations can take place and the station is prohibited from moving the fuel from the Spent Fuel Pool to the reactor vessel. This PDEP adequately addresses the risks associated with KPS's current conditions.

The analyses of the potential radiological impacts of postulated accidents in a permanently defueled condition indicates that any releases beyond the Site Boundary would be below the Environmental Protection Agency (EPA) Protective Action Guide (PAG) exposure levels, as detailed in the EPA's "Protective Action Guide and Planning Guidance for Radiological Incidents," Draft for Interim Use and Public Comment dated March 2013 (PAG Manual).

Exposure levels, which warrant pre-planned response measures, are limited to onsite areas.

1.1 PURPOSE The purpose of the PDEP is to assure an adequate level of preparedness to cope with the spectrum of emergencies that could be postulated to occur, including means to minimize radiation exposure to plant personnel. This plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations expected to respond to potential emergencies.

1.2 SCOPE The PDEP has been developed to respond to potential radiological emergencies at KPS considering the permanently shutdown and defueled status of the plant. Because there are no postulated accidents that would result in off-site dose consequences that are large enough to require off-site emergency planning, the overall scope of this plan delineates the actions necessary to safeguard onsite personnel and minimize damage to property.

The concepts presented in this plan address the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans", and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities". The plan is consistent with the applicable guidelines established in 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."

Exception to selected portions of 10 CFR 50.47 and 10 CFR 50 Appendix E for Kewaunee Power Station were granted by the Nuclear Regulatory Commission (NRC) per XXX.

The PDEP revision 0 was approved for use by the NRC per Safety Evaluation Report (SER)

XXX.

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2.0 DISCUSSION 2.1 OVERVIEW OF PERMANENTLY DEFUELED EMERGENCY PLAN (PDEP)

In the event of an emergency at the plant, actions are required to identify and assess the nature of the emergency and to bring it under control in a manner that protects the health and safety of plant personnel.

This plan is activated by the Shift Manager / Emergency Director (ED) upon identification of an emergency situation based upon the Emergency Action Level criteria. The emergency measures described in the subsequent sections and implementing procedures are implemented in accordance with the classification and nature of the emergency at the direction of the ED.

This Plan describes the organization and responsibilities for implementing emergency measures. It describes interfaces with Federal, State of Wisconsin, and Kewaunee County organizations which may be notified in the event of an emergency, and may provide assistance. Fire, ambulance, and law enforcement services are provided by local public entities. Medical services are provided by Aurora Medical Center in Two Rivers, Wisconsin.

Because there are no postulated accidents that would result in off-site dose consequences that are large enough to require off-site emergency planning, emergencies are divided into two classifications: 1) Unusual Event, and 2) Alert.

KPS is responsible for planning and implementing emergency measures within the Site Boundary. This plan is provided to meet this responsibility. To carry out specific emergency measures discussed in this Plan, detailed implementing procedures are established and maintained.

In addition to the description of activities and steps that can be implemented during a potential emergency, this Plan also provides a general description of the steps taken to recover from an emergency situation. It also describes the training, drills, planning, and coordination appropriate to maintain an adequate level of emergency preparedness.

2.2 FACILITY DESCRIPTION The Kewaunee Power Station has ceased power operations and is permanently defueled On May 14, 2013, the station certified permanent removal of fuel from the reactor vessel in accordance with 10 CFR 50.82(a)(1)(i) and (ii). The CFR 50 license for KPS no longer authorizes operation of the reactor, emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

The plant consists of a single unit Westinghouse Electric Corporation Pressurized Water Reactor. The reactor design core power was 1,772 megawatts thermal and gross plant electrical output was approximately 600 megawatts electric. An Independent Spent Fuel Storage Installation (ISFSI) is located on the plant site.

The plant is located in the town of Carlton, Kewaunee County, along the west shore of Lake Michigan in east central Wisconsin. The topography of the region is gently rolling to flat, with elevations varying from 10 to 100 feet above the level of Lake Michigan. The land surrounding the site slopes gradually east towards Lake Michigan from the higher elevations in the west.

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At the northern and southern perimeters of the site, bluffs form the boundary between the plant site and Lake Michigan.

3.0 DEFINITIONS and ACRONYMS This section provides definitions and acronyms that are used in this document. Terms capitalized in the text of the definitions indicate that they are defined elsewhere in this section.

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 HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Annual - Frequency of occurrence equal to once per calendar year, January 1 to December 31.

Accountability - Discretionary protective action taken for all persons onsite (within PROTECTED AREA) that involves the gathering of personnel into pre-designated areas and subsequent verification that the location of all personnel is known.

Assessment Actions - Those actions taken during or after an incident to obtain and process information necessary to make decisions to implement specific emergency measures.

Control Room - The Control Room contains the indications, controls, and communication equipment necessary for both normal and emergency conditions. It is operated under the direction of the Shift Manager/Emergency Director and serves as the primary location for Classification of the incident, Notification of incident to offsite agencies, ASSESSMENT ACTIONS, and CORRECTIVE ACTION direction.

Corrective Action - Those emergency measures taken to mitigate or terminate an emergency situation at or near the source of the problem in order to prevent an uncontrolled release of radioactive material or to reduce the magnitude of a release (e.g., equipment shutdown, fire fighting, equipment repair, and damage control).

Design Basis Accident (DBA) - A hypothetical accident assuming a fission product release based upon a major accident at the plant. The hazards that could potentially occur from this postulated accident would not exceed those resulting from any credible accident described in the Updated Safety Analysis Report.

Emergency Action Levels (EALs) - A pre-determined, site-specific, observable threshold for a plant INITIATING CONDITION (IC) that places the plant in a given emergency class.

Emergency Plan Implementing Procedures (EPIP/EIP) - Specific procedures describing actions needed to implement the PDEP.

Emergency Plan Maintenance Procedures (EPMP) - Specific procedures describing the methods established to maintain and monitor the PDEP.

Emergency Response Organization (ERO) - Individuals who have been assigned an emergency response position within the PDEP.

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Hostile Action - An act toward the plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and intimidate to achieve an end. This includes, but is not necessarily limited to, attack by air, land or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Acts of civil disobedience or felonious acts that are not part of a concerted attack on the plant (e.g., violent acts between individuals in the owner controlled area) do not meet this definition.

Hostile Force - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

Initiating Condition (IC) - An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.

Monthly - Frequency of occurrence equal to once per calendar month.

Personnel Monitoring Equipment - Radiation exposure measuring devices designed to be worn or carried by an individual for the purpose of measuring the radiation dose received (e.g.,

direct reading dosimeters, and TLDs).

Projected Dose - An estimate of the radiation dose, which affected individuals could potentially receive if PROTECTIVE ACTIONS are not taken.

Protected Area - That area within the perimeter of the Kewaunee Power Station security fence.

Protective Actions - Those measures taken in anticipation of or after an inadvertent release of radioactive material for the purpose of preventing or minimizing radiological exposures to onsite personnel.

Radioactive Release - Any radioactive material beyond pre-emergency levels and not attributable to normal plant operations, either detected or suspected of migrating beyond the protected area, while in a declared emergency, shall be communicated to the State and County governments as a radioactive release.

Radiological Control Area (RCA) - An area in which radioactive material is present and the potential exists for the spread of radioactive contamination. The area will be posted for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.

Site Boundary - The perimeter of the land owned by Dominion Energy Kewaunee Inc.

surrounding the plant.

Site Relocation Facility (SRF) - A facility located approximately 3 miles northwest of the Plant.

When needed, this facility may be used as a near site relocation and staging area for personnel entering or exiting the site.

Unusual Event (UE) - Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

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4.0 REFERENCES

0 10 CFR 50.47, "Emergency Plans"

  • NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (November 1980)
  • Updated Safety Analysis Report
  • NEI 99-01, Rev. 6, "Development of Emergency Action Levels for Non-Passive Reactors"
  • EPA's "Protective Action Guide and Planning Guidance for Radiological Incidents," Draft for Interim Use and Public Comment dated March 2013
  • NRC Safety Evaluation, Approval of PDEP, dated [ I 5 REV. 0 DRAFT F

5.0 EMERGENCY CONDITIONS This section describes emergency classifications, initiating events, accident detection, emergency action levels, and corresponding actions in response to various postulated emergency situations.

5.1 EMERGENCY CLASSIFICATION SYSTEM The emergency classification system covers an entire spectrum of possible radiological and non-radiological emergencies at the Kewaunee Power Station. The emergency classification system categorizes accidents and/or emergency situations into one of two emergency classification levels depending on emergency conditions at the time of the incident. The emergency classification levels applicable at Kewaunee Power Station, in order of increasing severity, are Unusual Event and Alert. Each of these emergency classes requires notification of the station's ERO, State and County agencies, as well as the NRC.

The emergency classification system is based on NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors".

Once indications are available to plant operators that an Emergency Action Level (EAL) has been met, the event is assessed and classified, and the corresponding emergency classification level is declared. Notification to the State and County off-site authorities is required within 60 minutes of the event being classified.

Incidents may be classified in a lower emergency classification level at first and then escalated to the higher level if the situation deteriorates.

The following subsections outline the plant actions at each classification level. Refer to Permanently Defueled Emergency Action Level Technical Bases for actual parameter values, annunciators, and equipment status used by emergency response personnel to classify emergencies.

Actions associated with an Unusual Event:

  • Bring the Emergency Response Organization (ERO) to a state of readiness.

" Notify Federal, State, and County government authorities.

" Initiate the systematic handling of information and decision making.

  • Augment shift personnel, if needed.

The Unusual Event status will be maintained until an escalation in emergency class occurs or the event is terminated. Off-site authorities will be informed of the change in the emergency status and the necessary documentation will be completed as specified in the Emergency Plan Implementing Procedures.

Actions associated with an Alert:

" Activate the Emergency Response Organization (ERO).

" Notify Federal, State, and County government authorities.

" Initiate the systematic handling of information and decision making.

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  • Initiate immediate and follow-up notification(s) including current plant status information to off-site authorities.

The Alert status shall be maintained until termination of the event or de-escalation in emergency class occurs. The plant may enter recovery operation without de-escalating from a declared Alert. Off-site authorities will be informed of the change in the emergency status and the necessary documentation shall be completed as specified in the Emergency Plan Implementing Procedures.

5.2 SPECTRUM OF POSTULATED ACCIDENTS The Updated Safety Analysis Report Chapter 14 describes the postulated accidents applicable to Kewaunee Power Station. Methods for detecting and evaluating for emergency classification of these events include the use of installed systems, instrumentation, alarms, and approved procedures.

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6.0 ORGANIZATIONAL CONTROL OF EMERGENCIES The Emergency Response Organization (ERO) augments the normal station organization to respond to declared emergencies when activated. Personnel are trained and assigned to the ERO based on either their normal job qualifications or by being specifically trained to fill a position.

The ERO is activated when an Alert is declared or at the discretion of the Shift Manager for an Unusual Event. The on-shift staff is supplemented by station personnel who report to the Emergency Director after being notified. The Shift Manager is responsible for ensuring that the ERO callout system is initiated to augment the on-shift staff.

The minimum augmented staff is a Radiation Protection Director and a Technical Director. The Shift Manager assumes the responsibilities of the Emergency Director. The Shift Manager position is required to be staffed at all times.

Augmenting the ERO is accomplished by the assignment of specific personnel to assist the ERO as needed.

This section of the plan describes the overall emergency organization that would be used during emergency situations at the plant. This section delineates the responsibilities, and assignments.

6.1 ON-SHIFT POSITIONS SHIFT MANAGER / EMERGENCY DIRECTOR The Shift Manager is at the station 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and is the senior management position at the station during off-hours. This position is responsible for monitoring conditions and approving all onsite activities.

When an abnormal situation becomes apparent, the Shift Manager shall assume the position of Emergency Director (ED) once the emergency classification has been made.

The Emergency Director shall assume overall Command and Control of a classified event. The Emergency Director cannot delegate the following responsibilities:

" Classification of event

  • Authorization of radiation exposures in excess of 10 CFR 20 limits Other responsibilities assumed by the Emergency Director include:

" Notification of the emergency classification to the NRC, State of Wisconsin, and Kewaunee County

  • Management of available station resources
  • Initiation of mitigative actions
  • Initiation of corrective actions

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" Decision to call for offsite police, fire or ambulance assistance

" Augmentation of the emergency staff, as deemed necessary

" Coordination of Security activities

" Termination of the emergency condition when appropriate

  • Performance of initial Dose Assessment
  • Maintaining a record of event activities PLANT OPERATOR Plant Operator performs system and component manipulations. The organizational relationship to the Shift Manager / Emergency Director is the same during normal situations and during situations where the PDEP has been implemented.

SECURITY Station Security is administered by the Security Plan. The Security force will report to the Emergency Director when implementing the PDEP.

During non-security events, Security will activate the station ERO callout system and perform accountability at the direction of the Emergency Director.

6.2 ERO AUGMENTED POSITIONS The augmented staff shall be activated at an Alert classification. The augmented staff may be activated at the discretion of the Emergency Director during an Unusual Event.

TECHNICAL DIRECTOR The Technical Director reports to the Emergency Director. The responsibilities of the Technical Director when implementing the PDEP include:

" Evaluation of technical data pertinent to plant conditions

" Augmentation of the emergency staff as deemed necessary

  • Recommend mitigative and corrective actions
  • Direction of search and rescue

" Coordination of maintenance and equipment restoration

" Establishing and maintaining communications as desired by the Emergency Director

" Maintaining a record of event activities RADIATION PROTECTION DIRECTOR The Radiation Protection Director reports to the Emergency Director. The responsibilities of the Radiation Protection Director when implementing the PDEP include:

  • Monitoring of personnel accumulated dose

" Advising the Emergency Director concerning Radiological EALs

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" Directing of radiological monitoring, analysis, and controls

  • Dose Assessment

" Establishing and maintaining communications as desired by the Emergency Director

" Maintaining a record of event activities 6.3 FUNCTIONAL RESPONSIBILITIES Plant Operations and Assessment of Operational Aspects Monitored and under the direction of the Emergency Director.

Emergency Direction and Control Responsibility of the Emergency Director.

Notifications / Communications Responsibility of the Emergency Director.

Radiological Survey, Monitoring and Assessment Performed under the direction of the Radiation Protection Director. Initial dose assessment is performed by Emergency Director.

Plant System Engineering, Repair and Corrective Actions Provided by personnel from the plant staff under the direction of the Technical Director.

Protective Actions Monitored and under the direction of the Emergency Director.

Rescue and First Aid treatment Available at all times and is provided by trained personnel assigned on shift under the direction of the Emergency Director.

Decontamination Performed under the direction of the Radiation Protection Director.

Fire Fighting Addressed in Fire Plan.

Site Access Control and Accountability Performed by the Security Force.

6.4 SUPPORT SERVICES Radiological emergency preplanning is not required for the State of WI and Kewaunee County. The State of WI and Kewaunee County response will be in accordance with each agency's plans and procedures, and commensurate with 10 REV. 0 DRAFT F

the hazard posed by the emergency.

Letters of Agreement are in place for those local agencies that will respond to the site, and for the hospital that will treat a contaminated injured individual from the site.

City of Kewaunee Fire Department Arrangements have been made with the City of Kewaunee Fire Department to provide assistance to the Plant Fire Brigade. The City of Kewaunee Fire Department is a volunteer department headquartered about 10 miles north of the plant.

City of Kewaunee Ambulance Arrangements have been made with the City of Kewaunee for ambulance services. The agreement includes a commitment for medical transportation of all radiation injuries and injuries complicated with radioactive contamination.

Aurora Medical Center Arrangements have been made for medical services with the Aurora Medical Center, located approximately 14 miles south of the Kewaunee Power Station. The agreement includes a commitment by the hospital to accept and treat plant personnel with routine industrial injuries as well as injuries complicated by radioactive contamination or radiation exposure. The Aurora Medical Center maintains the capability and facilities to provide decontamination, first aid, and emergency stabilization medical treatment to injured personnel. These services and facilities are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

Kewaunee County Sheriff's Department An agreement is maintained with the Kewaunee County Sheriff's Department to provide emergency assistance per the Security Plan.

6.5 Public Information As necessary, public information disseminated as news releases / briefings will be conducted per corporate communication protocols. The principal points of contact with the news media are determined in accordance with the corporate communication protocols.

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FIGURE 6-1 On-Shift and Emergency Response Organization Positions ERO Augmented Positions Technical Director 12 REV. 0 DRAFT F

7.0 EMERGENCY MEASURES Emergency measures begin with the recognition of abnormal conditions, identification of established Initiating Conditions, and classification to an Emergency Action Level. Emergency measures also include notifications, mitigative actions, corrective actions and onsite protective actions for station personnel.

7.1 NOTIFICATION AND ACTIVATION The authority and responsibility for classifying and declaring emergencies, initiating notification to the State, County and Federal officials, and initiating corrective and mitigative actions resides with the Emergency Director Position which is assumed by the Shift Manager upon the declaration of an emergency.

ERO Activation The ERO is activated by a plant announcement and by the ERO callout system directed by the Emergency Director.

Nuclear Accident Reporting System (NARS)

The NARS is a communication system used to notify the State and County agencies of a declared emergency. The NARS form contains information that identifies the station, classification, meteorological data and Emergency Action Level (EAL). Notification to the State and County agencies will be made within 60 minutes of event classification. Notification using NARS is the responsibility of the Emergency Director.

NRC Event Notification System (ENS)

The ENS is a dedicated telephone system used to notify the NRC Operations Center. The NRC will be notified as soon as possible after State / County notifications and within 60 minutes of event classification. In the event of failure of the ENS, commercial phone lines will be used to notify the NRC. Notification to the NRC is the responsibility of the Emergency Director.

7.2 ASSESSMENT ACTIONS Initial Assessment Classification of events is performed by the Emergency Director in accordance with the Emergency Action Level scheme.

Dose Assessment Initial dose assessment is the responsibility of the Emergency Director. Subsequent dose assessment is the responsibility of the Radiation Protection Director.

7.3 CORRECTIVE ACTIONS Station normal and abnormal operating procedures, and Emergency Plan Implementing Procedures provide preventive and/or corrective actions that mitigate the consequences of events. Instrumentation, control systems, and radiation monitoring systems provide indications related to the safe and orderly implementation of corrective actions. These systems provide 13 REV. 0 DRAFT F

the operator with the information needed to monitor the Spent Fuel Pool inventory and cooling, and supporting systems.

Fire Fighting Strategies have been developed for fire fighting and fire protection in specific critical areas of the plant. The fire protection plan describes the fire protection organization and individual responsibilities. If outside fire fighting support is needed, the City of Kewaunee Fire Department will be called in to assist.

Damage Control and Repair Processes have been developed and station personnel are trained to perform damage control and repair actions to address emergency conditions.

7.4 PROTECTIVE ACTIONS Protective actions for onsite personnel are provided for their health and safety. Implementation guidelines for onsite protective actions are provided in Emergency Plan Implementing Procedures (EPIPs). Station procedures provide for a range of protective actions to protect on-site personnel during hostile actions.

Accountability Accountability should be considered and used as a protective action whenever a site wide risk to health or safety exists and prudence dictates. If personnel accountability is required, at the direction of the Emergency Director all individuals at the site (including employees without emergency assignments, visitors and contractor personnel) shall be notified of an emergency over the public address system and by the sounding of the plant alarm. Accountability of all personnel onsite should be accomplished within 60 minutes after the announcement. If personnel are unaccounted for, teams shall be dispatched to locate the personnel.

Radiological Control Areas (RCAs)

As necessary, the Radiation Protection Director (RPD) will ensure Radiological Control Areas (RCAs) are established in response to the event. The RPD shall direct control of access to all RCAs unless immediate access is authorized by the Emergency Director to facilitate emergency repairs.

Exposure Control Individuals authorized to enter RCAs are required to have in their possession dosimetry capable of measuring a dose received from external sources of ionizing radiation.

All reasonable measures shall be taken to control the radiation exposure to emergency response personnel providing rescue, first aid, decontamination, emergency transportation, medical treatment services, corrective actions or assessment actions within applicable limits specified in 10 CFR 20. The Emergency Director is responsible for authorizing plant and emergency response personnel to receive doses in excess of 10 CFR 20 limits, if necessary. This authorization is coordinated with the Radiation Protection Director. Table 7-1 contains the guidelines for emergency exposure criteria, which is consistent with the EPA's, "Protective Action 14 REV. 0 DRAFT F

Guide and Planning Guidance for Radiological Incidents", Table 2-2, "Response Worker Guidelines".

Personnel Contamination Control All personnel are monitored for radioactive contamination prior to leaving the site. Portable radiation survey meters are available to frisk personnel for potential contamination.

Documentation of surveys, contamination, and decontamination activities shall be maintained in accordance with Radiation Protection procedures.

Access Control Normal access control shall be maintained unless otherwise directed. The Emergency Director is responsible for control access to the station when the ERO is activated.

7.5 MEDICAL TRANSPORT AND TREATMENT If immediate professional medical help is required, local ambulance services are available to assist in the transport of seriously injured or radioactively contaminated injured personnel.

Arrangements have been made with the Aurora Medical Center for the medical treatment of plant personnel. Hospital personnel have been instructed and trained in the treatment and care of patients with contamination and radiation overexposure.

When personnel are transported to the Aurora Medical Center while in a contaminated condition, personnel trained in radiological monitoring will be dispatched to monitor and maintain radiological controls.

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TABLE 7-1 Response Worker Guidelines Guideline Activity Condition 5 rem All occupational exposures All reasonably achievable actions have been taken to minimize dose.

10 rem(a) Protecting valuable Exceeding 5 rem property necessary for unavoidable and all public welfare appropriate actions taken to reduce dose.

Monitoring available to project or measure dose 25 rem(b) Lifesaving or protection of Exceeding 5 rem large populations unavoidable and all appropriate actions taken to reduce dose.

Monitoring available to project or measure dose (a) For potential doses >5 rem, medical monitoring programs should be considered.

(b) In the case of a very large incident, may need to consider raising the property and lifesaving response worker guidelines to prevent further loss of life and massive spread of destruction.

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8.0 EMERGENCY EQUIPMENT AND FACILITIES This section of the plan identifies and describes the emergency response facilities, the communication systems, the assessment facilities and equipment, the first aid and medical facilities, and protective equipment and supplies that can be utilized during an emergency.

8.1 EMERGENCY RESPONSE FACILITIES Control Room The Control Room is where plant systems and equipment parameters are monitored. The Control Room is the onsite center for emergency Command and Control. Control Room personnel assess plant conditions; evaluate the magnitude and potential consequences of abnormal conditions; initiate preventative, mitigating and corrective actions; and perform notifications. When activated, the ERO reports to the Control Room.

Site Relocation Facility The Site Relocation Facility (SRF) is located in the Carlton Township Hall, 1.6 miles North of KPS on Highway 42 and approximately 2 miles West on County Road G. The SRF functions as a staging area for augmentation of emergency response staff if the site is under threat of or experiencing Hostile Action. The SRF has telephone and Fax communication capability.

8.2 COMMUNICATION SYSTEMS Reliable intraplant and plant-to-offsite communications include:

" PBX telephone system

  • Commercial telephone system

" Plant Public address system

" Portable Radios

  • ERO callout system
  • NRC FTS Network (NRC Emergency Notification System and Health Physics Network) 8.3 ASSESSMENT FACILITIES AND EQUIPMENT This section describes the monitoring instruments and laboratory facilities used to initiate emergency measures and provide continuing assessment of conditions throughout the course of an emergency.

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Meteorological Equipment The meteorological equipment at the site consists of wind speed and direction transmitters, signal translators, and recorders. In addition, the temperature measurement consists of recorders and resistance temperature detectors (RTDs). RTDs on the primary tower are used to monitor ambient temperature and calculate differential temperature. Recorded ambient temperature comes from the ten (10) meter RTD. A RTD on the backup tower is available for monitoring ambient temperature.

Radiation Monitoring System The Radiation Monitoring System provides continuous radiological surveillance. The system performs the following basic functions:

  • Warns personnel of potential radiological health hazards.

" Gives early warning of certain plant malfunctions which might lead to a radiological health hazard or plant damage.

  • Prevents or minimizes the effects of inadvertent releases of radioactivity to the environment by consequence-limiting automatic responses.
  • Provides routine monitoring of controlled off-site plant releases.

The Radiation Monitoring System is divided into two sub-systems. The Process Radiation Monitoring System monitors various liquid and air streams for indication of radiation levels within those streams. The Area Radiation Monitoring System monitors radiation levels in various areas of the plant.

Portable Radiation and Contamination Monitoring Instruments Portable radiation and contamination monitoring instruments and sampling equipment normally utilized and maintained by the Radiation Protection group are available for emergency use.

Laboratory Facilities Facilities for analyzing radioactive samples are equipped with instruments that can detect alpha and beta radioactivity and a gamma spectroscopy system with automatic spectrum analysis.

Fire Detection and Suppression Equipment The fire protection system has been designed to detect and extinguish potential fires. The system is designed in accordance with the standards of the National Fire Protection Association (NFPA) and recommendations of the Nuclear Electric Insurance Limited (NEIL).

Fire detectors have been installed throughout the plant with alarms and indicators located in the Control Room.

8.4 FIRST AID AND MEDICAL FACILITIES The Kewaunee Power Station maintains first aid equipment for personnel working at the site.

Medical supplies for emergency first aid treatment are provided on the site. Stretchers are available for transporting non-mobile, injured personnel. First Aid kits are available at various 18 REV. 0 DRAFT F

plant locations.

8.5 PROTECTIVE EQUIPMENT AND SUPPLIES Protective clothing and respiratory equipment are maintained for use by emergency in-plant teams.

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9.0 MAINTAINING EMERGENCY PREPAREDNESS It is important that a state of emergency preparedness be maintained at all times at the Kewaunee Power Station. To ensure a state of readiness, the Kewaunee Power Station emergency preparedness program was designed to meet each of the following objectives:

" Designation of responsibilities for the PDEP.

  • Planning and conducting periodic drills.

" Annual review and update of the Emergency Plan and the Emergency Plan Implementing Procedures (EPIPs/EIPs).

" Routine calibration, maintenance and inventory of emergency equipment and supplies.

9.1 EMERGENCY PREPAREDNESS RESPONSIBILITIES KPS Executive Management Position Responsible for emergency response planning. This responsibility includes ensuring that the overall emergency preparedness program is maintained and implemented as described in this Plan and applicable requirements and regulations. The KPS executive management position is responsible for the following tasks:

" Implementation and maintenance of the PDEP.

" Drill commitments stated in the plan are met.

" Material readiness of all emergency response facilities.

  • Procedures to ensure adequate preparedness in accordance with this plan.
  • Adequate personnel coverage for specific emergency duties.

" Implementation and maintenance of the Emergency Preparedness Training Program.

Nuclear Licensing Responsible for the following tasks:

" Maintaining current knowledge of changes in Federal regulations and other guidance that impact emergency planning activities.

  • Submit PDEP and related controlled document revisions to the NRC.

Oversight Responsible for performance of independent audit of the emergency preparedness program to meet the requirements of 10 CFR 50.54(t).

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9.2 EMERGENCY RESPONSE PERSONNEL TRAINING Requirements for emergency preparedness training are specified in the Emergency Preparedness Training Program. This program identifies the level and the depth to which individuals are to be trained.

Emergency Preparedness Training Program The training program for emergency response personnel is based on the requirements of 10 CFR 50 Appendix E and position specific responsibilities as defined in the PDEP. Emergency response personnel in the following categories receive initial training and retraining each year:

Shift Managers / Emergency Directors, Technical Directors and Radiation Protection Directors shall have training conducted such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.

  • Emergency Action Level Classification
  • Dose Assessment
  • Federal, State and Local notification procedures as appropriate
  • Site specific procedures for activating the onsite ERO KPS personnel available during declared emergencies to perform emergency response activities as an extension of their normal duties receive duty specific training annually.

Additional emergency preparedness training is provided as part of the Plant Access Training.

Plant Operators and Maintenance personnel are trained to function as emergency in-plant teams.

Radiation Protection personnel are trained to assess the radiological hazards associated with equipment repair and instruct personnel as to the appropriate protective clothing requirements, respiratory protection requirements, time limits, and other protective actions specific to the conditions present.

Security Personnel are trained in accordance with Security Program training requirements.

Personnel who are badged for unescorted access receive Plant Access Training annually.

Information pertaining to their safety and the safety of visitors under escort during a declared emergency is included in this training.

Plant Access Training shall include the following emergency preparedness topics:

" Basic Emergency Plan and implementing procedure (EPIP/EIP) information

  • The meaning of plant alarms and the emergency classification system
  • Use of plant communication systems
  • Personnel accountability and evacuation procedures 21 REV. 0 DRAFT F

Non-KPS Emergency Response Support Organizations Training is offered annually to non-KPS organizations which may provide specialized services during a nuclear plant emergency (e.g., fire-fighting, medical services, transport of injured, etc.). The training shall be structured to meet the needs of that organization with respect to the nature of their support. Topics such as event notification, basic radiation protection and interface activities between the off-site organization and KPS shall be made available.

The Point Beach Nuclear Power Plant and the Kewaunee Power Station share the services of the same off-site organizations and agencies. As specified in an established memorandum of understanding, the two plants keep each other informed regarding the emergency preparedness training being presented, thus allowing the two facilities to alternate presentations and minimize redundant training provided to the off-site agencies.

9.3 Exercises / Drills Exercise and Drill KPS conducts a biennial Exercise to test the adequacy of timing and content of implementing procedures and methods; to test emergency equipment and communication networks; and to ensure that emergency personnel are familiar with their duties. KPS will offer the following agencies the opportunity to participate in the Exercise:

  • State of WI
  • Kewaunee County
  • City of Kewaunee Fire Department
  • City of Kewaunee Ambulance

" Aurora Medical Center

  • Kewaunee County Sheriff's Department For alternating years, a Drill is conducted for the purpose of testing, developing, and maintaining the proficiency of emergency responders.

Exercise and Drill scenarios will include, at a minimum, the following:

" The basic objective(s) of the drill.

" The date(s), time period, place(s), and participating organizations.

" A time schedule of real and simulated initiating events.

  • A narrative summary describing the conduct of the drill to include such items as simulated casualties, off-site fire assistance, rescue of personnel, use of protective clothing.

Critiques will evaluate the performance of the organization. The ability of KPS personnel to self-evaluate weaknesses and identify areas for improvement is the key to successful drill conduct.

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Equipment and Proficiency Drills Equipment and Proficiency Drills may be performed as part of an Exercise, a Drill or as an independent drill.

Communication Drills Communications with the State of WI and Kewaunee County shall be tested monthly.

These communication drills will include the aspect of understanding the content of messages.

Medical Emergency Drills A medical emergency drill involving a simulated contaminated individual and containing provisions for participation by the Aurora Medical Center shall be conducted at least annually. Both the Kewaunee Power Station and Point Beach Nuclear Plant share the facilities provided by the Aurora Medical Center. To minimize redundant training for the hospital staff, the two plants will alternate development and conduct of the drill each year.

Accountability Drill An accountability drill shall be conducted annually. The drill shall include identifying the locations of all individuals onsite.

Augmentation Capability Assessment (ACA) Drills An unannounced off-shift ACA drill shall be conducted semi-annually. These drills shall involve implementation of the notification procedure and documentation of the estimated response time for each responder. No actual travel is required. Participants provide an estimation of the time it would take to report to their designated ERO location. This drill shall serve to demonstrate the capability to augment the on shift staff after declaration of an emergency.

9.4 REVIEW AND UPDATING OF THE PDEP AND EMERGENCY PLAN IMPLEMENTING PROCEDURES PDEP, Emergency Action Level Technical Bases and Emergency Plan Implementing Procedures Review The PDEP, Emergency Action Level Technical Bases, and the Emergency Plan Implementing Procedures (EPIP/EIP) are reviewed annually and updated, as needed. The review shall encompass the need for changes based upon the following aspects:

  • Written critiques and evaluations of drills.

" Changes in the organizational structure.

" Changes in the functions and capabilities of supporting agencies.

" Changes in Federal or State regulations.

" Modifications to the plant facility, site, or operating status which would affect emergency planning.

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0 Recommendations or agreement changes received from other organizations.

Any needed changes shall be incorporated in the PDEP, Emergency Action Level Technical Bases, and appropriate EPIPs/EIPs. All proposed changes will be evaluated prior to issue to ensure that the change would not compromise the effectiveness of any other EPIP/EIP or degrade the effectiveness of the PDEP.

Emergency Action Levels (EALs) State and County Review The EALs shall be made available for review with State and County governmental authorities annually.

Emergency Telephone Directory Emergency telephone numbers shall be reviewed at least quarterly and updated as necessary.

Letters of Agreements The letters of agreement with the support agencies shall be reviewed with the support agency at least every two years (biennially). Changes shall be made and the agreements renewed, as necessary.

KPS reserves the right to enter agreements or contracts which are perpetual and free from biennial renewal, or of a period other than biennial if mutually agreed upon by the co-signers of the agreement letter or contract. However, a letter designated as a perpetual agreement shall be reviewed by KPS at least biennially.

9.5 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT AND SUPPLIES Appendix A, "Emergency Equipment, Supplies and Reference Materials," lists each of the emergency response facilities and the required equipment, supplies and reference materials that are to be maintained in each facility.

Portable radiation monitoring equipment included in these inventories is checked and calibrated in accordance with approved procedures.

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10.0 PLANT RECOVERY 10.1 PLANT RECOVERY ORGANIZATION The plant recovery organization will be based on the normal Kewaunee Power Station (KPS) organization and would function with the KPS executive management position being responsible for directing all site activities.

10.2 PLANT RECOVERY OPERATIONS Kewaunee Power Station is responsible for plant recovery measures and restoring the plant to a stable condition. Notification of on-site personnel and off-site response organizations that the plant recovery is to commence will be performed in accordance with Emergency Plan Implementing Procedures.

The extent and nature of the corrective and protective measures and the extent of plant recovery will depend on the emergency conditions at hand and the status of plant areas and equipment. The general goals for plant recovery are:

  • An orderly evaluation of the cause and effect of the emergency and implementation of solutions to prevent immediate recurrence of the incident.

" A planned approach for returning the plant to a stable condition by obtaining the appropriate manpower, materials, and equipment.

" A planned approach to coordinate with off-site authorities to identify and resolve situations that may impact the general public.

" An evaluation of the radiation exposure records for all on-site emergency response personnel involved in the incident.

  • A planned approach to ensure that radiation exposures and contamination controls are consistent with the ALARA program.
  • To ensure that all nuclear safety related procedures associated with the recovery operation are submitted to the Facility Safety Review Committee (FSRC) for review and approval prior to their implementation.

During a declared emergency, a point will be reached where the plant will be placed in a stable condition. With the understanding that this condition could be attained even though specific Emergency Action Levels are still exceeded, the Emergency Director will determine that there is no longer a need to keep the emergency organization in effect and to begin plant recovery.

Although de-escalation to a lower emergency level may be performed, it is not necessary to de-escalate prior to initiating plant recovery.

Plant recovery activities shall be in accordance with the plant Technical Specifications and other license documents. During plant recovery, the radiation exposure limits of 10 CFR 20 shall apply.

If, during plant recovery, an emergency situation again occurs, the KPS emergency response organization would be activated in accordance with this plan and its EPIPs/EIPs. Plant recovery efforts will be suspended until the emergency condition is resolved. The Emergency Director will re-evaluate plant conditions prior to resuming plant recovery.

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10.3 PLANT RECOVERY TERMINATION The plant recovery will be terminated by the KPS executive management position after the plant has been returned to a stable condition.

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APPENDIX A Emergency Equipment, Supplies and Reference Materials CONTROL ROOM ITEM Emergency Plan Emergency Plan Implementing Procedures Emergency Action Level Bases Document See OP-KW-ORT-SAE-001 for Inventory Procedure.

SITE RELOCATION FACILITY ITEM Emergency Plan Emergency Plan Implementing Procedures Communication Equipment See EPMP-10.01 for Inventory Procedure.

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